5­
1
5.
Responses
to
Comments
EPA
Region
5
(
Illinois,
Indiana,
Michigan,
Minnesota,
Ohio
and
Wisconsin)
5­
2
Comment:
1015­
1
Region:
5
State:
IL
Area:
Chicago­
Gary­
Lake
County,
IL­
IN
Comment:
Gov.
Jim
Doyle
comments
that
Kenosha
County,
WI
should
be
designated
attainment
for
the
PM2.5
standard.
He
believes
that
Kenosha
County
has
little
impact
on
the
Chicago
MSA
for
the
following
reasons:

1.
The
monitor
located
in
Kenosha
County
is
attaining
the
PM2.5
standard.

2.
The
monitor
in
Lake
County
Illinois,
which
falls
in
between
Kenosha
County
and
the
violating
monitor
in
urban
Chicago,
is
also
clean.

3.
The
predominant
wind
direction
from
Kenosha
County
is
away
from
the
violating
counties
in
the
Chicago
MSA.

4.
The
area
outside
of
Kenosha
County
covers
90
percent
of
the
emissions
in
the
Chicago
CMSA.
In
addition,
Year
2000
Census
data
show
that
approximately
75
percent
of
the
Kenosha
County
commuters
travel
to
Lake
County,
IL
that
also
meets
the
PM2.5
standard.

5.
Kenosha
County
has
a
lower
urban
density
than
the
area
with
the
monitor
that
violates
the
PM2.5
standard.

6.
97
percent
of
the
sulfur
dioxide
and
78
percent
of
the
nitrogen
oxide
emissions
in
Kenosha
County
come
from
the
Pleasant
Prairie
Power
Plant
that
has
already
installed
selective
catalytic
reduction
(
SCR)
on
one
unit.

EPA
Response:
EPA
has
reviewed
the
technical
information
found
in
Governor
Doyle's
letter
and
agrees
with
the
recommendation
that
Kenosha
County
should
be
designated
attainment.
Please
see
the
technical
support
document
for
more
information
regarding
this
decision.

Comment:
1013a­
14
Region:
5
State:
IL
Area:
Chicago­
Gary­
Lake
County,
IL­
IN
Comment:
EPA
failed
to
include
DeKalb,
Kankakee
and
parts
of
Grundy
and
Kendall
Counties
in
its
recommended
nonattainment
boundary
for
the
Chicago
CMSA.
These
areas,
in
entirety,
must
be
included
in
the
nonattainment
area.
In
addition,
adjacent
La
Salle
County
appears
to
have
high
emissions,
while
the
design
value
for
this
area
is
14.1
µ
g/
m3.
This
county
should
be
analyzed
for
its
impact
on
the
nonattainment
problem
in
the
Chicago
area.
5­
3
EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
EPA
considered
nine
factors
including
the
emissions,
population,
and
Vehicle
miles
traveled
(
VMT)
from
DeKalb,
Grundy,
Kankakee,
Kendall
and
La
Salle
Counties
before
deciding
to
designate
them
as
attainment/
unclassified.
The
emissions
from
these
counties
are
a
small
percentage
of
the
total
emissions
in
the
Chicago
CMSA
and
the
population
and
VMT
from
all
five
counties
are
a
small
percentage
of
the
population
and
VMT
in
the
Chicago
CMSA.
Aux
Sable
and
Goose
Lake
Townships
in
Grundy
County,
and
Oswego
Township
in
Kendall
County,
however,
were
included
in
the
nonattainment
area
at
the
State's
request
to
maintain
consistency
with
the
8­
hour
ozone
designations
and
thereby
facilitate
planning.

Speciated
PM2.5
weighted
emissions
were
used
in
developing
a
weighted
emission
score
for
each
county
in
a
potential
nonattainment
area.
In
the
Chicago
area,
only
monitors
in
Cook
County
and
Northwest
Indiana
show
a
violation
of
the
PM2.5
standard.
Despite
monitoring
attainment,
EPA
evaluated
LaSalle
County
for
contributions
to
these
violations
using
the
PM2.5
weighted
emissions
(
and
scores)
in
the
context
of
all
the
relevant
factors
in
determining
the
boundary
of
the
nonattainment
area.
On
a
weighted
emissions
basis,
emissions
in
LaSalle
County
are
2.5
percent
of
the
emissions
in
the
Chicago
metropolitan
area.
Based
on
this
information
and
information
for
the
other
factors,
EPA
concluded
that
LaSalle
County
did
not
warrant
being
included
in
the
Chicago
nonattainment
area.

Comment:
1021­
1
Region:
5
State:
IL
Area:
St.
Louis,
MO­
IL
Comment:
Commenter
urges
EPA
to
discard
its
arbitrary
policy
of
designating
adjacent
counties
as
nonattainment
simply
because
of
their
proximity
and
the
fact
they
contain
an
electric
generating
station.
He
notes
that
the
air
quality
data
was
not
used
as
the
basis
for
the
intended
designation.
Commenter
suggests
that
a
nonattainment
designation
would
adversely
impact
the
growth
of
the
county.
He
supports
the
position
of
Illinois
EPA
and
the
Governor
in
designating
Randolph
County
attainment
for
PM2.5.

EPA
Response:
The
EPA
agrees
that
Randolph
County
does
not
have
a
monitor
that
is
violating
the
PM2.5
standard
although
it
is
adjacent
to
counties
in
the
Saint
Louis
area
that
are
monitoring
unhealthful
air
quality
in
excess
of
the
national
standard.
The
CAA
defines
nonattainment
as
an
area
that
is
violating
the
standard
or
contributing
to
a
violation
of
the
standard
in
a
nearby
area.

A
portion
of
Randolph
County
was
recommended
by
the
state
as
unclassified.
In
EPA's
June
29,
2004
letter
to
the
State
of
Illinois,
EPA
indicated
that
Randolph
County
should
be
nonattainment,
but
invited
the
state
to
submit
additional
justification,
based
on
the
9
factors,
to
support
their
original
designation
recommendations.
The
state
submitted
technical
information
pertaining
to
the
county
in
September
2004,
and
satisfactorily
demonstrated
to
EPA
that
part
of
the
county
can
be
designated
as
attainment.
EPA
finds
5­
4
that
Baldwin
Township
warrants
being
designated
nonattainment
because
it
is
contributing
to
the
violation
in
the
Saint
Louis
area.
The
remainder
of
Randolph
County
was
determined
to
not
contribute
to
the
air
quality
violations.

The
Baldwin
power
plant,
located
in
Baldwin
Township,
produces
a
substantial
amount
of
the
Randolph
County
emissions.
EPA
acknowledges
that
the
Baldwin
power
plant
has
significantly
reduced
its
emissions,
however,
it
is
unclear
whether
these
emission
reductions
are
enforceable
and
emissions
are
moderately
high
even
after
the
reductions.
These
emissions
are
located
in
the
portion
of
the
county
nearest
to
the
violation
and
where
winds
would
commonly
blow
toward
the
observed
violations.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.

Comment:
1020­
1
Region:
5
State:
IL
Area:
St.
Louis,
MO­
IL
Comment:
Commenter
believes
that
EPA
expressed
intent
to
designate
Randolph
County
as
nonattainment
simply
because
Randolph
County
has
a
power
plant
and
is
near
to
a
metropolitan
area
that
violates
the
PM2.5
air
quality
standards,
an
approach
that
the
commenter
finds
arbitrary.
Commenter
reaffirms
Illinois
EPA's
previous
recommendation
to
designate
a
portion
of
Randolph
County,
specifically
Baldwin
Township,
as
unclassifiable
and
disagrees
with
EPA's
intended
designation
of
the
entire
county
as
nonattainment.
However,
if
EPA
is
going
to
designate
part/
all
of
Randolph
County
as
nonattainment,
then
only
the
Baldwin
Township
should
be
nonattainment.
The
Baldwin
power
plant,
located
in
the
Baldwin
Township
accounts
for
almost
all
of
the
precursor
emissions
from
Randolph
County.
Of
the
2004
SO2
emissions
(
27,061
tons
per
year)
virtually
all
(
26,
267
tons
per
year)
are
emitted
from
the
Baldwin
power
plant.
5­
5
EPA
Response:
EPA
did
not
apply
the
approach
alleged
by
the
commenter.
That
is,
EPA
did
not
simply
designate
all
counties
near
violating
metropolitan
areas
with
power
plants
as
nonattainment.
Instead,
EPA
examined
emissions
data
for
the
violating
metropolitan
areas
and
other
pertinent
information
for
the
nearby
areas
that
might
be
contributing
to
the
violations.
EPA
expressed
intent
to
apply
a
nonattainment
designation
to
those
counties
or
subcounty
areas
with
high
emissions
judged
likely
to
contribute
to
the
violations,
irrespective
of
whether
those
emissions
arose
from
power
plants
or
from
other
sources.
Conversely,
EPA
expressed
intent
to
apply
an
attainment
designation
to
those
counties
or
subcounty
areas
with
low
emissions
judged
unlikely
to
contribute
to
the
violations,
again
irrespective
of
whether
those
emissions
arose
from
power
plants
or
from
other
sources.

The
EPA
agrees
that
Randolph
County
does
not
have
a
monitor
that
is
violating
the
PM2.5
standard
although
it
is
adjacent
to
counties
in
the
Saint
Louis
area
that
are
monitoring
unhealthful
air
quality
in
excess
of
the
national
standard.
The
CAA
defines
nonattainment
as
an
area
that
is
violating
the
standard
or
contributing
to
a
violation
of
the
standard
in
a
nearby
area.

A
portion
of
Randolph
County
was
recommended
by
the
state
as
unclassified.
In
EPA's
June
29,
2004
letter
to
the
State
of
Illinois,
EPA
indicated
that
Randolph
County
should
be
nonattainment,
but
invited
the
state
to
submit
additional
justification,
based
on
the
9
factors,
to
support
their
original
designation
recommendations.
The
state
submitted
technical
information
pertaining
to
the
county
in
September
2004,
and
satisfactorily
demonstrated
to
EPA
that
part
of
the
county
can
be
designated
as
attainment.
EPA
concludes
that
Baldwin
Township
is
nonattainment
because
it
is
contributing
to
the
violation
in
the
Saint
Louis
area.
The
remainder
of
Randolph
County
was
determined
to
not
contribute
to
the
air
quality
violations.

Comment:
1022­
1
Region:
5
State:
IL
Area:
St.
Louis,
MO­
IL
Comment:
The
commenter
objects
to
EPA's
designation
of
Randolph
County
as
nonattainment.
The
commenter
believes
that
EPA
erred
as
the
designation
was
based
solely
on
the
presence
of
the
Baldwin
Energy
Complex
in
the
county
and
an
arbitrary
assumption
that
its
emissions
of
SO2
and
NOx
contribute
to
nonattainment
in
the
St.
Louis
metropolitan
area.
EPA
did
not
consider
the
recommendations
of
Illinois
EPA
or
the
actual
monitored
PM2.5
data.
The
commenter
states
that
EPA
ignored
key
factors
that
EPA
itself
established
to
evaluate
individual
counties.
A
more
detailed
discussion
of
how
EPA
erred
in
its
decision
is
attached
to
this
letter.
The
commenter
notes
that
the
designation
of
Randolph
County
as
nonattainment
would
have
serious
impacts
on
its
citizens,
local
government
and
business.

The
commenter
offered
the
following
evidence
that
EPA
improperly
applied
its
own
classification
criteria.
5­
6
1.
EPA
used
outdated
Baldwin
Energy
Complex
emission
data
and
failed
to
analyze
the
relationship
between
recent
SO2
and
NOx
emissions
at
the
Baldwin
Energy
Complex
and
measured
ambient
PM2.5
levels
in
the
St.
Louis
area.

2.
PM2.5
concentrations
in
Randolph
County
have
never
exceeded
the
NAAQS
notwithstanding
the
emissions
from
the
Baldwin
plant.

3.
The
Randolph
County
population
density
is
significantly
lower
than
other
most
areas
considered
attainment,
and
much
lower
that
the
others
included
in
the
St.
Louis
nonattainment
area.

4.
The
traffic
and
commuting
patterns
of
Randolph
County
are
much
lower
than
other
areas
considered
attainment,
and
much
lower
that
the
others
included
in
the
St.
Louis
nonattainment
area.

5.
Randolph
County
has
a
negative
expected
growth
factor
significantly
below
the
expected
growth
of
areas
considered
attainment
and
below
several
of
the
other
areas
included
in
the
St.
Louis
nonattainment
area.

6.
Meteorological
characteristics
of
Randolph
County
are
typical
of
the
region.
EPA
provided
no
correlation
between
the
measured
nonattainment
occurrences
in
St.
Louis
and
the
meteorological
conditions
in
Randolph
County.
EPA
provided
no
modeling
or
other
analysis
indicating
that
the
surface
level
measurements
were
in
any
way
related
to
the
emissions
from
the
Baldwin
complex
emitted
from
the
top
of
a
605­
foot
high
stack.

7.
Randolph
County
has
no
geographic
features
that
influenced
its
intended
nonattainment
designations.
EPA
provided
no
modeling
of
geography
or
topography
to
reject
Illinois
EPA's
recommendation.

8.
Regarding
jurisdictional
boundaries,
EPA
excluded
Randolph
County
from
the
St.
Louis
nonattainment
area
and
for
consistency
should
have
excluded
it
from
the
PM2.5
nonattainment
area.

9.
EPA
ignored
the
level
of
emissions
control
at
the
Baldwin
Power
Complex
when
making
its
decision.
Additionally,
there
is
no
correlation
between
emissions
from
the
Baldwin
Power
Complex
and
PM2.5
levels
in
the
St.
Louis
metropolitan
area.

EPA
Response:
The
EPA
agrees
that
Randolph
County
does
not
have
a
monitor
that
is
violating
the
PM2.5
standard
although
it
is
adjacent
to
counties
in
the
Saint
Louis
area
that
are
monitoring
unhealthful
air
quality
in
excess
of
the
national
standard.
The
CAA
defines
nonattainment
as
an
area
that
is
violating
the
standard
or
contributing
to
a
violation
of
the
standard
in
a
nearby
area.

A
portion
of
Randolph
County
was
recommended
by
the
state
as
unclassified.
In
EPA's
June
29,
2004
letter
to
the
State
of
Illinois,
EPA
indicated
that
Randolph
County
should
be
nonattainment,
but
invited
the
state
to
submit
additional
justification,
based
on
the
9
5­
7
factors,
to
support
their
original
designation
recommendations.
The
state
submitted
technical
information
pertaining
to
the
county
in
September
2004,
and
satisfactorily
demonstrated
to
EPA
that
part
of
the
county
can
be
designated
as
attainment.
EPA
finds
that
Baldwin
Township
warrants
being
designated
nonattainment
because
it
is
contributing
to
the
violation
in
the
Saint
Louis
area.
The
remainder
of
Randolph
County
was
determined
to
not
contribute
to
the
air
quality
violations.

The
Baldwin
power
plant,
located
in
Baldwin
Township,
produces
a
substantial
amount
of
the
Randolph
County
emissions.
EPA
acknowledges
that
the
Baldwin
power
plant
has
significantly
reduced
its
emissions,
however,
it
is
unclear
whether
these
emission
reductions
are
enforceable
and
emissions
are
moderately
high
even
after
the
reductions.
These
emissions
are
located
in
the
portion
of
the
county
nearest
to
the
violation
and
where
winds
would
commonly
blow
toward
the
observed
violations.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.

Comment:
1013a­
15
Region:
5
State:
IL
Area:
St.
Louis,
MO­
IL
Comment:
EPA
failed
to
include
Bond,
Calhoun,
Clinton,
Jersey,
Macoupin,
Montgomery,
Morgan
and
Sangamon
Counties
in
its
recommended
St.
Louis
nonattainment
area.
EPA
recommended
that
Randolph
County
be
designated
nonattainment
as
part
of
the
St.
Louis
area,
but
is
allowing
for
the
State
to
submit
further
information
documenting
a
justification
for
including
only
a
portion
of
the
county
in
the
nonattainment
area.
Although
Montgomery,
Morgan
and
Sangamon
Counties
are
not
part
of
the
CMSA,
they
all
contain
power
plants
that
must
be
analyzed
for
their
impacts
on
the
nonattainment
problem.
In
2002,
these
four
plants
together
emitted
over
78,000
tons
of
SO2
and
over
27,000
tons
of
NOx.
5­
8
EPA
Response:
A
portion
of
Randolph
County
was
recommended
by
the
state
as
unclassified.
In
EPA's
June
29,
2004
letter
to
the
State
of
Illinois,
EPA
indicated
that
Randolph
County
should
be
nonattainment,
but
invited
the
state
to
submit
additional
justification,
based
on
the
9
factors,
to
support
their
original
designation
recommendations.
The
state
submitted
technical
information
pertaining
to
the
county
in
September
2004,
and
satisfactorily
demonstrated
to
EPA
that
part
of
the
county
can
be
designated
as
attainment.
EPA
finds
that
Baldwin
Township
warrants
being
designated
nonattainment
because
it
is
contributing
to
the
violation
in
the
St.
Louis
area.
The
remainder
of
Randolph
County
was
determined
to
not
contribute
to
the
air
quality
violations.

The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
OMB
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM\
2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
and
Vehicle
miles
traveled
(
VMT)
from
Bond,
Calhoun,
Clinton,
Jersey,
Macoupin,
Montgomery,
Morgan
and
Sangamon
Counties
before
deciding
to
designate
them
as
attainment/
unclassified.
Although
Clinton
and
Jersey
Counties
are
within
the
CMSA,
their
emissions
are
much
lower
than
from
Madison
and
St.
Clair
Counties,
the
Illinois
counties
in
the
St.
Louis
CMSA
with
violating
monitors.
Bond,
Calhoun,
Clinton,
Jersey
and
Macoupin
Counties
have
fairly
low
emissions
and
the
emissions,
population
and
VMT
from
Bond,
Calhoun,
Clinton,
Jersey,
Macoupin,
Montgomery,
Morgan
and
Sangamon
Counties
represent
a
small
percentage
of
the
total
emissions,
population
and
VMT
from
the
St.
Louis
CMSA.
The
presence
of
power
plants
in
Montgomery,
Morgan
and
Sangamon
Counties
does
not
necessarily
indicate
that
the
counties
should
be
judged
to
be
contributing
to
the
area's
violations.
Also,
Sangamon
County
does
have
a
monitor
which
shows
that
Sangamon
County
is
attaining
the
PM2.5
standard.

Comment:
1020­
2
Region:
5
State:
IL
|
WI
|
IN
Area:
Chicago­
Gary­
Lake
County,
IL­
IN
Comment:
Commenter
states
that
Illinois
EPA
recommends
that
Kenosha
County,
Wisconsin,
and
Lake
and
Porter
Counties,
Indiana
not
be
included
in
the
Chicago
MSA
PM2.5
nonattainment
area.

1.
Regarding
Kenohsa
County,
ambient
data
collected
show
this
county
to
be
in
attainment.
Studies
indicate
that
due
to
the
predominant
wind
direction,
Kenosha
County
has
a
minimal
impact
on
downwind
monitors.
This
county
should
be
designated
attainment.
5­
9
2.
Regarding
Lake
and
Porter
Counties,
commenter
believes
that
if
EPA
and
the
State
of
Indiana
agree
that
these
two
counties
should
be
designated
nonattainment,
they
should
be
designated
as
a
separate
nonattainment
area
and
not
a
part
of
the
Chicago
MSA.
Concerns
stem
from
the
EPA's
policy
regarding
transportation
conformity
in
multi­
state
nonattainment
areas
and
its
impact
on
the
need
for
MPOs
to
conduct
transportation
planning
independently.

EPA
Response:
Response
to
Comment
1.

The
EPA
uses
the
CMSA/
MSA
as
a
presumptive
boundary
of
nonattainment
areas
for
PM2.5.
EPA
guidance
also
provides
for
use
of
9
factors
to
evaluate
alternative
nonattainment
area
boundaries
to
include
the
area
that
is
violating
the
standards
and
the
nearby
areas
that
are
contributing
to
these
violations.

For
the
PM2.5
NAAQS,
the
EPA
invited
States
to
consult
and
make
recommendations
on
air
quality
and
appropriate
boundaries
to
EPA.
When
EPA
first
considered
Kenosha
County
as
nonattainment,
EPA
had
received
no
formal
recommendations
from
the
State
of
Wisconsin
regarding
PM2.5
nonattainment
areas
or
boundaries.
On
August
9,
2004,
EPA
received
a
letter
from
Wisconsin
Governor,
Jim
Doyle,
that
recommended
Kenosha
County
as
attainment.
Many
of
the
points
raised
in
the
letter
from
Illinois
EPA
are
also
raised
in
the
Governor's
letter.

Based
on
the
justification
found
in
Governor
Doyle's
letter,
EPA
has
determined
that
Kenosha
County
should
be
designated
as
attainment
for
the
PM2.5
standard.
See
the
technical
support
document
for
more
information
regarding
the
rationale
for
this
decision.

Response
to
Comment
2.

For
several
large
metropolitan
areas
such
as
the
Chicago­
Gary­
Kenosha
Metropolitan
Area,
EPA
expressed
intent
for
the
nonattainment
area
to
include
applicable
portions
of
multiple
states.
EPA
disagrees
with
Illinois'
recommendation
to
split
the
Chicago­
Gary­
Kenosha
area
into
multiple
single­
state
nonattainment
areas.
EPA
is
designating
Kenosha
County
as
attainment,
but
EPA
is
retaining
the
Illinois
and
the
Indiana
portions
of
the
area
as
a
single
nonattainment
area.
The
air
quality
in
Northeast
Illinois
and
Northwest
Indiana
are
interconnected,
and
the
area
must
be
designated
as
a
single
nonattainment
area
in
order
to
assure
that
air
quality
planning
efforts
address
these
interconnections.

EPA
understands
that
EPA's
conformity
policy
dictates
that
areas
that
included
as
a
single
nonattainment
area
must
address
conformity
as
a
single
area
unless
and
until
separate
emission
budgets
are
prepared
for
separate
portions
of
the
area.
Further,
we
understand
Illinois's
concern
that
this
raises
the
possibility
that
a
conformity
lapse
could
occur
in
Illinois
as
a
result
of
problems
in
Indiana
through
no
fault
of
Illinois.
However,
EPA
believes
that
this
concern
does
not
warrant
distorting
the
planning
process
to
subdivide
what
in
air
quality
terms
is
a
single
area.
EPA
also
believes
that
this
concern
does
not
warrant
modifying
the
conformity
process
to
allow
subdivision
of
the
area
5­
10
subject
to
conformity
planning
prior
to
the
time
that
firm
emission
budgets
for
the
relevant
portions
of
the
area
have
been
established.

Comment:
1032­
2
Region:
5
State:
IN
Area:

Comment:
EPA
has
not
proposed
or
finalized
essential
guidance
or
implementing
the
PM2.5
standards.

The
PM2.5
implementation
rule
is
critical
to
understanding
the
significance
and
consequences
of
a
nonattainment
designation
and
the
planning
procedures
that
a
nonattainment
designation
triggers.
For
example,
if
the
PM2.5
designations
take
effect
in
early
2005
and
the
implementation
rule
has
not
been
finalized,
states
will
be
unable
to
apply
nonattainment
New
Source
Review
requirements
to
new
permit
applications.

EPA
Response:
The
identification
of
areas
that
are
not
meeting,
or
contributing
to
other
areas
not
meeting,
the
PM2.5
standards
is
an
essential
first
step
that
must
occur
before
the
development
of
suitable
PM2.5
control
strategies.
EPA
regrets
that
it
has
not
as
yet
finalized
its
PM2.5
implementation
guidance
that
will
address
these
issues,
including
its
effect
on
permitting.
EPA
recognizes
the
importance
of
this
guidance
and
will
provide
this
guidance
as
soon
as
feasible.
Nevertheless,
EPA
is
required
by
law
to
proceed
with
designations
irrespective
of
the
availability
of
implementation
guidance.

Comment:
1032­
3
Region:
5
State:
IN
Area:

Comment:
EPA
is
poised
to
automatically
impose
tougher
permit
requirements
that
have
not
been
shown
to
be
necessary
for
every
new
nonattainment
area.

Based
on
EPA's
statements
to
date
relative
to
the
ozone
standard,
it
is
presumed
that
EPA
will
seek
to
impose
nonattainment
area
new
source
review
immediately
for
any
area
designated
as
nonattainment
for
PM2.5.
Not
only
is
this
approach
unwarranted,
as
discussed
in
Governor
Kernan's
letter,
but
at
the
very
least
nonattainment
New
Source
Review
should
be
deferred
until
the
implementation
rule
is
final.

EPA
Response:
The
identification
of
areas
that
are
not
meeting,
or
contributing
to
other
areas
not
meeting,
the
PM
2.5
standards
is
an
essential
first
step
that
must
occur
before
the
development
of
suitable
PM2.5
control
strategies.
The
PM2.5
designations
do
not,
by
themselves,
impose
emission
control
or
permitting
requirements.
Although
EPA
has
not
as
yet
finalized
its
PM2.5
implementation
guidance
that
will
address
these
issues,
including
its
effect
on
permitting,
EPA
will
take
this
into
consideration
and
provide
appropriate
guidance
as
soon
as
feasible.
5­
11
Comment:
1032­
4
Region:
5
State:
IN
Area:

Comment:
The
science
associated
with
determining
the
causes
of
and
contributions
to
PM2.5
nonattainment
is
still
developing.

Modeling
and
other
technical
analyses
have
not
progressed
to
the
point
where
we
know
with
certainty
which
geographic
areas
to
control,
which
sources
to
control
and
the
quantity
of
pollutants
to
control.
Significant
technical
work
will
take
place
to
fill
these
gaps
over
the
next
several
years.
Until
these
analyses
are
conducted
and
more
is
known
relative
to
the
causes
and
contributions
to
PM2.5
nonattainment
and
the
trends
in
PM2.5
air
quality,
any
areas
designated
as
nonattainment
should
be
limited
to
those
that
clearly
and
directly
influence
the
existing
monitor
readings.

EPA
Response:
In
addition
to
the
important
contribution
from
long­
range
transport,
EPA
believes
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,
not
just
from
sources
near
the
violating
monitors.
While
determining
the
exact
impact
of
a
source
on
the
fine
particulate
concentration
in
an
area
continues
to
be
developed,
EPA
is
proceeding
using
our
current
knowledge
of
the
problem
to
protect
the
air
quality
in
Indiana.
This
is
why
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
reflect
an
areaspecific
overall
assessment
of
currently
available
technical
information
relating
to
nine
specific
factors:
air
quality
monitoring
information,
pollutant
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.
As
we
learn
more
about
what
sources
and
pollutants
to
control
in
the
future,
control
strategies
can
be
update
to
better
control
fine
particulates.
This
will
expedite
bring
areas
in
attainment
of
the
air
quality
standard.

Comment:
1032­
5
Region:
5
State:
IN
Area:

Comment:
There
is
a
significant
regional
component
to
PM2.5
nonattainment.

Current
scientific
evidence,
including
EPA's
modeling
for
the
proposed
Clean
Air
Interstate
rule
and
the
Lake
Michigan
Air
Director's
Consortium
technical
analysis,
shows
there
is
a
regional
component
to
PM2.5,
in
addition
to
the
local
component.
There
is
widespread
recognition
that
regional
controls
of
SO2
and
NOx
will
be
necessary
to
address
PM2.5
nationwide.
For
those
counties
with
violations,
regional
controls
should
take
them
a
long
way
toward
compliance.
For
example,
EPA's
modeling
shows
its
5­
12
proposed
Clean
Air
Interstate
Rule
will
bring
all
Indiana
counties
into
attainment
by
2015,
and
all
but
one
county
(
Lake)
into
nonattainment
by
2010.
Despite
this
regional
component,
Indiana's
monitors
do
not
show
widespread
violations
of
the
annual
standard.
Many
of
Indiana's
urban
and
suburban
counties
monitor
compliance.
Nonattainment
designations
for
these
urban
and
suburban
counties
would
require
stricter
permitting
of
new
sources,
which
may
be
unnecessary.
Furthermore,
such
designations
would
impose
economic
hardships
and
encourage
urban
sprawl
beyond
the
current
urban
boundaries
without
contributing
to
attainment
in
adjacent
counties.
Technical
analysis
to
date
is
not
conclusive
on
the
issue
of
how
local
emissions
decreases
will
affect
PM2.5
concentrations
downwind.

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
from
areas
that
are
not
adjacent
to
the
metropolitan
area.
EPA
agrees
that
this
is
an
important
issue
and
is
currently
addressing
the
issue
of
regionally
transported
emissions
via
the
proposed
Clean
Air
Interstate
Rule
(
CAIR).

EPA
cannot
base
an
area's
air
quality
designation
on
projected
air
quality
or
on
uncertain
future
emission
reductions.
EPA
agrees
that
it
is
important
to
have
programs
that
address
emissions
on
a
national
and
regional
scale.
These
programs
would
positively
affect
the
air
quality
for
many
areas
in
Indiana
and
across
the
country.
Similarly,
EPA
is
not
delaying
designation
even
though
knowledge
of
contributions
may
improve
in
the
future.

The
criteria
in
the
Clean
Air
Act
for
designating
nonattainment
areas
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
(
GDP)
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
5­
13
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.

EPA
recognizes
that
further
work
needs
to
be
done
to
evaluate
the
impact
of
sources
at
various
distances
from
monitors
recording
violations
of
the
PM2.5
standards.
The
Clean
Air
Act
provides
for
EPA
to
determine
nonattainment
area
boundaries
to
include
all
of
the
nearby
source
areas
which
according
to
currently
available
information
contribute
to
the
violations.
The
Clean
Air
Act
provides
for
states
then
to
conduct
an
analysis
of
the
specific
sources
and
source
areas
that
contribute
to
the
problem
and
to
adopt
emission
control
measures
as
needed
to
achieve
attainment.
However,
before
that
detailed
analysis
is
completed,
EPA
must
establish
nonattainment
area
boundaries
that
reflect
EPA's
best
judgment
of
the
source
areas
near
to
the
monitored
violations
that
warrant
review
in
the
subsequent
planning
process.

Comment:
1032­
6
Region:
5
State:
IN
Area:

Comment:
Local
contributions
and
source
impacts
should
not
be
overlooked.

Of
the
18
full
counties
and
1
partial
county
proposed
as
nonattainment
by
the
EPA
on
June
29,
2004,
only
six
of
these
counties
have
monitors
that
measure
a
violation
of
the
annual
standard
for
fine
particles.
Unlike
ozone,
background
concentrations
of
fine
particles
are
below
the
standard
throughout
the
state.
Although
background
concentrations
are
close
to
the
standard
at
many
monitors,
IDEM
believes
that
in
certain
cases
the
monitors
that
actually
exceed
the
standard
do
so
because
of
urban
excess
and/
or
local
sources.
For
example,
suburban
counties
are
often
below
the
standard
in
areas
adjacent
to
the
urban
core
where
there
is
an
exceedance.
Therefore,
it
should
not
be
assumed
that
a
county
contributes
significantly
to
a
violation
nearby,
especially
if
the
county
is
downwind
of
the
violations
and/
or
monitors
ambient
air
that
meets
the
standard.

EPA
Response:
Once
EPA
determines
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.
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.

In
addition
to
the
impact
from
local
sources
on
an
area's
air
quality,
EPA
believes
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
and
sometimes
beyond.
Fine
particles
include
a
variety
of
constituents.
Some
constituents
are
directly
emitted,
and
tend
to
be
found
at
highest
concentrations
near
to
the
points
of
highest
emissions.
Even
for
these
constituents,
EPA
believes
a
relatively
large
nonattainment
area
is
warranted,
both
because
a
larger
area
facilitates
addressing
mobile
sources
that
originate
in
other
nearby
counties
and
because
the
impacts
5­
14
for
surrounding
counties
can
nevertheless
be
sufficient
to
be
included
in
attainment
planning.
Other
constituents
form
through
atmospheric
chemical
reactions,
such
that
the
point
of
highest
concentrations
may
be
some
distance
from
the
point
of
highest
emissions.
For
these
constituents,
the
counties
surrounding
the
violating
county
may
have
the
most
important
emissions
to
be
addressed.

For
these
reasons,
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
reflects
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.
Thus,
even
if
the
county
is
monitoring
attainment
or
does
not
have
a
monitor,
it
was
evaluated
for
contributing
to
a
nearby
violation
using
the
remaining
eight
factors.
This
includes
reviewing
the
annual
wind
data
as
part
of
the
meteorology
factor.
The
wind
direction
tends
to
vary
day
to
day
in
Indiana,
so
an
area
county
will
be
upwind
of
the
violating
county
some
days
and
downwind
on
other
days.

Comment:
1013a­
16
Region:
5
State:
IN
Area:
Chicago­
Gary­
Lake
County,
IL­
IN
Comment:
EPA
failed
to
include
Jasper,
La
Porte
and
Newton
Counties
in
its
recommendation
for
the
Chicago
nonattainment
area.
These
counties
are
all
part
of
the
CMSA
and
must
be
designated
nonattainment.
EPA
concluded
that
La
Porte
County
is
adjacent
to
the
CMSA
and
does
not
contribute
to
nonattainment
in
the
Chicago
area.
This
county
is
actually
included
in
the
CMSA,
and
contains
a
coal­
fired
power
plant.
Jasper
County
also
contains
a
coal­
fired
power
plant.
Jasper
and
Newton
Counties
do
not
have
monitors
in
order
to
determine
whether
these
areas
are
attaining.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
OMB
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
and
vehicle
miles
traveled
(
VMT)
from
Newton,
Jasper,
and
La
Porte
Counties
before
deciding
to
designate
them
as
attainment/
unclassified.
Even
with
the
power
plants
in
Jasper
and
La
Porte
Counties,
their
combined
emissions
represent
a
small
percentage
of
the
total
emissions
in
the
Chicago
CMSA.
Although
Jasper
and
Newton
counties
do
not
have
monitors,
their
emissions,
5­
15
VMT
and
population
are
much
less
than
Lake
County,
the
only
Indiana
county
in
the
Chicago
CMSA
that
has
monitored
nonattainment
of
the
PM2.5
standard.

Comment:
1032­
8
Region:
5
State:
IN
Area:
Chicago­
Gary­
Lake
County,
IL­
IN
Comment:
Porter
County
is
upwind
of
LaPorte
County
and
LaPorte
County's
monitor
values
are
well
below
the
standard.
Porter
County
does
not
appear
to
be
contributing
to
PM2.5
violations
anywhere
within
the
region.
Therefore,
IDEM
continues
to
recommend
that
Porter
County
be
designated
attainment.

Indiana
comments
that
the
monitoring
site
for
which
EPA
identified
a
design
value
of
17.7
µ
g/
m3
has
been
identified
as
a
hot
spot
site
for
which
concentrations
should
not
be
compared
to
the
annual
standard.
Indiana
states
that
the
design
value
for
Lake
County
should
instead
be
15.2
µ
g/
m3.

EPA
Response:
EPA
agrees
with
Indiana
that
Porter
County
does
not
have
violating
monitor.
While
westerly
winds
are
more
common
in
Porter
County
than
easterly
winds,
the
wind
blows
from
the
east
sufficiently
frequently
that
EPA
believes
that
Porter
County
emissions
contribute
to
violations
in
Lake
County,
Indiana,
and
Cook
County,
Illinois.
Moreover,
the
Porter
County
emissions
rank
fourth
out
of
the
13
Chicago
area
counties.
There
is
also
a
large
number
of
people
commuting
from
Porter
County
into
Lake
County,
Indiana.

Indiana
is
correct
that
it
has
identified
the
site
recording
a
3­
year
average
concentration
of
17.7
µ
g/
m3
as
a
hot
spot
site
for
which
concentrations
are
not
to
be
compared
to
the
annual
average.
EPA
appreciates
this
correction.

Comment:
1013a­
17
Region:
5
State:
IN
Area:
Cincinnati­
Hamilton,
OH­
KY­
IN
Comment:
EPA
failed
to
recommend
a
portion
of
Dearborn
County
and
Franklin
and
Ohio
Counties
for
nonattainment.
These
counties
are
all
part
of
the
Cincinnati
CMSA
and
must
be
included
in
the
nonattainment
area
in
entirety.
It
is
of
particular
importance
that
the
coal­
fired
power
plant
in
Dearborn
County
be
included
within
the
nonattainment
area
boundaries.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
OMB
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
5­
16
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
and
Vehicle
miles
traveled
(
VMT)
from
Dearborn
County
outside
of
Lawrenceburg
Township,
and
Ohio
and
Franklin
Counties
before
deciding
to
designate
them
as
attainment/
unclassified.
The
only
coal­
fired
power
plant
within
these
three
counties
is
in
Lawrenceburg
Township,
which
EPA
is
designating
as
nonattainment.
Outside
of
Lawrenceburg
Township
the
emissions
from
Dearborn,
Ohio
and
Franklin
Counties
are
an
extremely
small
percentage
of
the
total
emissions
in
the
Cincinnati
CMSA
and
the
population
and
VMT
from
all
three
counties
are
a
small
percentage
of
the
population
and
VMT
in
the
Cincinnati
CMSA.

Comment:
1032­
13
Region:
5
State:
IN
Area:
Cincinnati­
Hamilton,
OH­
KY­
IN
Comment:
IDEM
disagrees
with
EPA's
intended
designation
of
Dearborn
County
as
nonattainment
for
the
following
reasons:

1.
There
is
only
one
significant
source
of
PM
in
Dearborn
County,
the
Tanners
Creek
power
plant,
and
it
has
reduced
emissions
by
installing
permanent
combustion
controls
and
low
NOx
burners.
There
are
no
monitors
in
Dearborn
County;
if
there
were,
it
is
not
unreasonable
to
assume
that
the
values
would
be
consistent
with
background
values
elsewhere
in
the
state
and
Midwest.
Therefore,
IDEM
does
not
believe
that
PM2.5
concentrations
exceed
the
standard
in
Dearborn
County.

2.
Based
on
analysis
of
similar
urban
areas,
IDEM
does
not
believe
that
emissions
from
Dearborn
County
contribute
significantly
to
PM2.5
values
elsewhere
in
the
Cincinnati
CMSA.
For
example,
this
county
only
accounts
for
approximately
2%
of
the
population
with
the
CMSA.

IDEM
recommends
Dearborn
County
be
designated
attainment/
unclassifiable.

EPA
Response:
EPA
realizes
that
Dearborn
County
does
not
have
a
monitor
for
the
PM2.5
standard,
but
it
is
adjacent
to
several
counties
in
the
Cincinnati
area
that
are
monitoring
unhealthful
air
quality
in
excess
of
the
national
standard.
The
CAA
defines
nonattainment
areas
as
an
area
that
is
violating
the
standard
or
contributing
to
a
violation
of
the
standard
in
a
nearby
area.
EPA
feels
that
part
of
the
county,
Lawrenceburg
Township,
is
nonattainment
because
it
is
contributing
to
the
violation
in
the
Cincinnati
area.
The
remainder
of
the
mostly
rural
Dearborn
County
was
determined
to
not
contribute
to
the
air
quality
violations.
The
AEP
Tanners
Creek
power
plant,
located
in
Lawrenceburg
Township,
produces
a
substantial
amount
of
the
Dearborn
County
emissions.
Tanners
Creek
has
reduced
its
emissions
by
improving
emissions
control.
Even
with
these
reductions,
the
emissions
from
Lawrenceburg
Township
remain
significant
in
the
Cincinnati
area.
EPA
cannot
consider
potential
future
reductions
5­
17
because
of
the
uncertainty
associated
with
any
proposed
rule.
EPA
evaluated
all
nine
factors
in
determining
that
just
Lawrenceburg
Township
should
be
included
in
the
Cincinnati
nonattainment
area.

Comment:
1032­
9
Region:
5
State:
IN
Area:
Elkhart,
IN
Comment:
The
Elkhart
monitor
exceeds
the
standard
only
marginally
and
the
three
St.
Joseph
County
monitors
are
well
below
the
standard.
It
is
reasonable
to
assume
that
regional
controls
such
as
the
utility
NOx
rule
and
low
sulfur
fuels
will
reduce
PM2.5
concentrations
to
enable
Elkhart
County
to
attain
in
a
reasonable
time.
IDEM
continues
to
recommend
that
St.
Joseph
County
be
designated
attainment.

EPA
Response:
Although
the
CAIR
rule
may
achieve
substantial
emission
reductions,
EPA
cannot
base
an
area's
air
quality
designation
on
projected
air
quality
or
on
uncertain
future
emission
reductions.
EPA
agrees
that
it
is
important
to
have
programs
that
address
emissions
on
a
national
and
regional
scale.
These
programs
would
positively
affect
the
air
quality
for
many
areas
in
Indiana
and
across
the
country.

The
air
quality
in
North
Central
Indiana
continues
to
improve
and
seems
likely
to
attain
the
PM2.5
standard
soon.
EPA
has
decided
to
provide
an
opportunity
for
states
to
provide
complete
2004
data
to
allow
EPA
to
adjust
its
final
designations
according
to
whether
areas
are
violating
the
air
quality
standards
based
on
2002
to
2004
data.
Saint
Joseph
County
has
higher
emissions,
population,
and
vehicle
miles
traveled
than
Elkhart
County.
There
is
also
significant
commuting
between
the
counties.
EPA
continues
to
believe
both
Elkhart
and
Saint
Joseph
Counties
belong
in
the
area.

Comment:
1024­
1
Region:
5
State:
IN
Area:
Evansville,
IN
Comment:
Commenter
expresses
concern
over
EPA's
proposed
designation
of
Spencer
County,
IN
as
nonattainment
for
PM2.5.
He
notes
that
the
Governor
of
IN
and
IN
DEM
believe
this
county
should
be
attainment.
Their
belief
is
based
on
the
following:

1.
Regional
emissions
will
continue
to
be
significantly
reduced
in
compliance
with
current
and
proposed
regulations
2.
A
background
monitor
located
in
Spencer
County
has
shown
the
county
to
be
in
compliance
3.
AEP's
power
plant
has
already
made
significant
emission
reductions
since
1999,
the
base
year
used
by
EPA
to
propose
nonattainment
designation
5­
18
4.
The
nonattainment
designation
will
handicap
the
county's
efforts
to
draw
development
to
the
area
and
expand
industrial
production/
jobs
5.
The
nonattainment
designation
will
undercut
significant
infrastructure
improvements
that
have
been
planned
or
recently
completed.

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.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
updated
information
on
Spencer
County
emission
reductions
including
information
on
controls
added
to
the
Indiana
Michigan
Power
Rockport
power
plant.
Future
control
requirements
are
not
being
considered
because
the
amount
and
time
frame
of
the
reductions
is
unknown.
EPA
considered
the
new
emissions
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
5­
19
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.

Similarly,
EPA
does
not
expect
a
nonattainment
designation
to
have
a
negative
impact
on
infrastructure
projects.
Infrastructure
improvement
projects
may
be
reviewed
to
avoid
negative
impacts
to
the
Spencer
County
air
quality.

Comment:
1027­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
Commenter
is
concerned
about
EPA's
proposed
designation
for
Spencer
County,
IN
as
nonattainment
for
PM2.5.
He
notes
that
the
county
has
had
difficulty
providing
a
sufficient
tax
base
to
fund
schools
and
infrastructure.
He
doesn't
agree
with
designating
the
county
nonattainment
simply
because
of
its
proximity
to
violating
counties,
noting
that
Spencer
County
is
monitoring
attainment.
He
also
comments
that
the
power
plant
in
Spencer
County
has
spent
large
amounts
of
money
to
reduce
emissions.

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.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
does
not
consider
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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
local
contributions.
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:
5­
20
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.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
updated
information
on
Spencer
County
emission
reductions
including
information
on
controls
added
to
the
Indiana
Michigan
Power
Rockport
power
plant.
EPA
considered
this
new
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.
A
nonattainment
designation
is
not
expected
to
have
a
negative
impact
on
the
infrastructure
improvement
projects
in
Spencer
County.

Comment:
1025­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
Commenter
expresses
concern
over
EPA's
proposed
designation
of
Spencer
County,
IN
as
nonattainment.
He
notes
that
the
monitors
are
demonstrating
the
area
is
in
attainment,
and
the
designation
is
due
to
Spencer
County's
proximity
to
adjacent
areas.
He
states
that
the
AEP
power
plant
has
made
significant
emission
reductions
since
1999
and
a
nonattainment
designation
would
impact
the
area
economically.
He
asks
EPA
to
reconsider
its
intended
designation.

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
5­
21
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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
local
contributions.
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
on
emission
sources.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
updated
information
on
Spencer
County
emission
reductions
including
information
on
controls
added
to
the
Indiana
Michigan
Power
Rockport
power
plant.
EPA
considered
this
new
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.
A
nonattainment
designation
is
not
expected
to
have
a
negative
impact
on
the
infrastructure
improvement
projects
in
Spencer
County.
5­
22
Comment:
1026­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
Commenter
expresses
concern
over
EPA's
proposed
designation
of
Spencer
County,
IN
as
nonattainment
for
PM2.5.
She
notes
that
the
air
in
Spencer
County
meets
EPA's
guidelines,
yet
it
is
being
designated
as
nonattainment.
She
offers
the
following
arguments:

1.
Regional
emissions
will
continue
to
be
significantly
reduced
in
compliance
with
current
and
proposed
regulations.

2.
A
background
monitor
located
in
Spencer
County
has
shown
the
county
to
be
in
compliance.

3.
AEP's
power
plant
has
already
made
significant
emission
reductions
since
1999,
the
base
year
used
by
EPA
to
propose
nonattainment
designation.

4.
The
nonattainment
designation
will
handicap
the
county's
efforts
to
draw
development
to
the
area
and
create
jobs.

5.
The
nonattainment
designation
will
undercut
significant
infrastructure
improvements
that
have
been
planned.

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.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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
5­
23
emissions,
population
and
growth
in
the
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
updated
information
on
Spencer
County
emission
reductions
including
information
on
controls
added
to
your
facility,
the
Rockport
power
plant.
Future
control
requirements
are
not
being
considered
because
the
amount
and
timing
of
the
reductions
are
unknown.
EPA
considered
the
new
emissions
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.
A
nonattainment
designation
is
not
expected
to
have
a
negative
impact
on
Spencer
County's
infrastructure
improvement
projects.

Comment:
1023­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
Commenter
writes
on
behalf
of
Spencer
County,
IN.
He
concurs
with
the
comment
letters
already
sent
to
EPA
and
requests
EPA
to
reconsider
its
proposed
designation.

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
5­
24
designate
the
area
as
nonattainment.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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
local
contributions
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.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
updated
information
on
Spencer
County
emissions
including
information
on
controls
added
to
the
Indiana
Michigan
Power
Rockport
power
plant.
EPA
considered
this
new
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.

Please
also
see
EPA's
responses
to
other
comments
on
the
fine
particulate
designation
for
Spencer
County.
5­
25
Comment:
1043­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
The
commenter
makes
the
following
comments
on
behalf
of
Perry
County,
located
adjacent
to
Spencer
County.
He
agrees
with
Indiana
DEP
that
Spencer
County
should
be
designated
attainment/
unclassifiable.

1.
More
current
information
is
available
that
shows
significant
NOx
and
SO2
reductions
in
Spencer
County.
Specifically,
countywide
NOx
emissions
are
down
by
21%
since
1999
while
countrywide
SO2
emissions
have
been
reduced
by
30%.
Point
source
emissions
have
declined
by
10%.
EPA
should
consider
this
more
recent
information.

2.
Too
much
emphasis
was
placed
on
the
fact
that
a
power
plant
is
located
in
Spencer
County.
This
is
a
greater
concern
since
the
power
plant
has
achieved
significant
NOx
and
SO2
emissions.

3.
Spencer
County
is
adjacent
to
but
not
a
part
of
the
Evansville
MSA.
If
designated,
it
should
be
a
rural
nonattainment
area.

The
commenter
is
concerned
about
the
proposed
nonattainment
designation
because
of
the
shared
economy
of
the
area.
He
believes
the
designation
will
hurt
the
economic
development
plans
and
opportunities
of
the
entire
area
(
i.
e.,
both
Spencer
and
Perry
Counties).

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.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
do
not
consider
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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
also
reflect
significant
local
contributions.
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
5­
26
area,
commuting,
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
us
the
updated
information
mentioned
on
Spencer
County
emissions
including
information
on
controls
added
to
the
Indiana
Michigan
Power
Rockport
power
plant.
Even
with
the
modest
reduction,
the
emissions
from
the
Rockport
power
plant
dominate
the
Spencer
County
totals.
EPA
considered
this
new
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.
The
economic
outlook
in
Perry
County
is
unlikely
to
change
much
from
a
neighboring
county
being
designated
nonattainment.

Comment:
1013a­
18
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
EPA
failed
to
recommend
that
Posey
and
Knox
Counties
be
included
in
the
Evansville
nonattainment
area.
Posey
County,
inside
the
MSA,
is
home
to
a
coal­
fired
power
plant
and
must
be
included
in
the
nonattainment
area.
In
2002,
the
A.
B.
Brown
facility
emitted
almost
9,000
tons
of
SO2
and
over
7,000
tons
of
NOx.
Knox
County,
adjacent
to
the
MSA,
also
contains
a
coal­
fired
power
plant
(
Edwardsport)
that
emitted
over
8,000
tons
of
SO2
and
almost
2,000
tons
of
NOx
in
2002.
Neither
of
these
counties
contains
monitors.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
Knox
County
was
not
considered
because
it
is
5­
27
not
within
the
Evansville
CMSA/
MSA
and
its
emissions
are
relatively
small,
especially
considering
that
EPA
is
intending
to
include
Gibson,
Spencer,
and
Pike
Counties,
which
have
coal­
fired
power
plants
and
much
greater
emissions,
as
nonattainment
counties.
Also,
Knox
County
does
have
a
monitor
which
shows
that
Knox
County
is
attaining
the
PM­
2.5
standard.
Although
Posey
County
is
within
the
CMSA/
MSA
its
emissions
are
a
small
percentage
of
the
total
emissions
in
the
metropolitan
area,
especially
considering
the
emissions
from
Gibson,
Spencer
and
Pike
Counties.
In
addition,
the
population
and
VMT
from
Posey
County
are
much
lower
than
from
Vanderburgh
and
Warrick
Counties,
the
other
Indiana
counties
in
the
Evansville
Metropolitan
area.
Although
Posey
County
does
not
have
a
monitor,
its
population
and
VMT
are
much
less
than
from
Vanderburgh
County,
which
has
monitored
nonattainment
and
more
like
that
of
the
adjacent
Henderson
County
in
Kentucky,
which
has
similar
population
and
VMT
as
Posey
County
and
has
monitored
attainment
of
the
PM2.5
standard.
The
presence
of
power
plants,
especially
power
plants
with
comparatively
low
emissions,
does
not
necessarily
indicate
that
the
county
should
be
judged
to
be
contributing
to
an
area's
violations.

Comment:
1032­
11
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
IDEM
disagrees
with
EPA's
intended
designation
of
Gibson,
Pike,
Spencer
and
Warrick
Counties
as
nonattainment.

1.
Monitoring
data
in
Spencer
County
and
Knox
County
demonstrate
these
counties
are
in
attainment
even
though
these
rural
background
monitors
are
impacted
by
air
masses
with
high
PM
levels
that
cross
the
state
line.
These
values
are
an
indication
that
neighboring
Warrick
and
Gibson
Counties
could
be
in
attainment
if
monitors
were
present.

2.
Power
plants
and
industrial
sources
in
Gibson,
Warrick,
Pike
and
Spencer
counties
have
reduced
emissions
significantly
since
1999.
Further,
there
is
no
scientific
evidence
that
emissions
from
these
counties
or
facilities
contribute
to
monitored
violations
in
Vanderburgh
or
Dubois
counties
and
a
nonattainment
designation
is
unnecessary.

EPA
Response:
The
Clean
Air
Act
requires
that
nonattainment
areas
include
not
only
the
area
that
is
violating
the
standard
but
also
any
nearby
areas
that
contribute
to
these
violations.
In
Southwest
Indiana,
violations
have
been
recorded
in
Vanderburgh
and
DuBois
Counties.
The
definition
of
what
area
should
be
nonattainment
is
a
function
of
what
source
areas
contribute
to
these
violations.
Southwest
Indiana
has
numerous
large
power
plants
and
other
large
industrial
sources,
in
rural
as
well
as
urban
locations.
EPA
believes
all
of
the
counties
it
is
designating
as
nonattainment
are
contributing
to
the
violations.
5­
28
EPA
believes
further
that
violations
in
Dubois
and
Vanderburgh
Counties
arise
from
a
common
set
of
sources,
such
that
the
entire
area
should
be
designated
as
a
single
nonattainment
area.

With
all
three
monitors
in
Vanderburgh
County
exceeding
the
standard,
there
is
no
reason
to
believe
that
the
air
quality
in
Warrick
and
Gibson
Counties
is
good.
Even
with
the
monitors
in
Knox
and
Spencer
Counties
measuring
below
the
standard,
Warrick
and
Gibson
Counties
have
emissions
several
times
greater
than
the
Vanderburgh
County
emissions.
There
is
also
a
violation
in
Dubois
County.
Pike
and
Spencer
Counties
have
significant
emissions
as
well.

Comment:
1088­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
The
commenter
expresses
concern
over
EPA's
proposed
designation
of
Spencer
County
Indiana
as
nonattainment.
Commenter
notes
that
the
air
in
Spencer
County
meets
EPA
guidelines.
Indiana
DEP
has
requested
EPA
lift
the
nonattainment
designation.
The
commenter
urges
EPA
to
consider
the
following:

1.
Regional
Emissions
will
continue
to
be
significantly
reduced
in
compliance
with
current
proposed
EPA
regulations.

2.
A
background
monitor
located
in
Spencer
County
has
shown
Spencer
County
to
be
in
compliance.

3.
AEP's
coal­
fired
power
plant
in
Spencer
County
has
already
made
significant
emissions
reductions
since
1999,
the
base
year
used
by
EPA
to
propose
the
nonattainment
designation.

4.
The
nonattainment
designation
will
handicap
Spencer
County
efforts
to
expand
production
and
jobs.

5.
The
nonattainment
designation
will
undercut
significant
infrastructure
improvements
that
have
been
planned
or
completed
in
recent
years,
such
as
the
US
Hwy
231
project.

The
commenter
closes
by
suggesting
that
the
situation
in
Spencer
County
does
not
justify
a
nonattainment
designation
and
undermines
the
Spencer
County
Regional
Chamber
of
Commerce's
long­
term
efforts
to
create
jobs
and
economic
development
in
the
area.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
5­
29
designate
the
area
as
nonattainment.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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
local
contributions.
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
on
emission
sources.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
updated
information
on
Spencer
County
emission
reductions
including
information
on
controls
added
to
the
Indiana
Michigan
Power
Rockport
power
plant.
EPA
considered
this
new
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.
A
nonattainment
designation
is
not
expected
to
have
a
negative
impact
on
the
infrastructure
improvement
projects
in
Spencer
County.
5­
30
Comment:
1089­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
Comment:
The
commenters,
on
behalf
of
the
Spencer
County
Regional
Chamber
of
Commerce,
express
concern
over
EPA's
proposed
designation
of
Spencer
County
as
nonattainment.
Commenters
note
that
the
air
in
Spencer
County
meets
EPA
guidelines.
Indiana
DEP
has
requested
EPA
lift
the
nonattainment
designation.
The
commenters
urge
EPA
to
consider
Indiana
DEP's
comments
that:

1.
Regional
emissions
will
continue
to
be
significantly
reduced
in
compliance
with
current
proposed
EPA
regulations.

2.
A
background
monitor
located
in
Spencer
County
has
shown
Spencer
County
to
be
in
compliance.

3.
AEP's
coal­
fired
power
plant
in
Spencer
County
has
already
made
significant
emissions
reductions
since
1999,
the
base
year
used
by
EPA
to
propose
the
nonattainment
designation.

4.
The
nonattainment
designation
will
handicap
Spencer
County
efforts
to
expand
production
and
jobs.

5.
The
nonattainment
designation
will
undercut
significant
infrastructure
improvements
that
have
been
planned
or
completed
in
recent
years,
such
as
the
US
Hwy
231
project.

The
commenter
closes
by
suggesting
that
the
situation
in
Spencer
County
does
not
justify
a
nonattainment
designation
and
undermines
the
Spencer
County
Regional
Chamber
of
Commerce's
long­
term
efforts
to
create
jobs
and
economic
development
in
the
area.

EPA
Response:
On
April
1,
2003
and
February
13,
2004,
the
Environmental
Protection
Agency
(
EPA)
issued
guidance
for
States
and
Tribes
to
use
in
identifying
nonattainment
areas.
A
nonattainment
area
is
defined
in
section
107(
d)
of
the
Clean
Air
Act
(
CAA)
as
an
area
that
is
violating
an
ambient
air
quality
standard,
or
is
contributing
to
a
nearby
area
that
is
violating
the
standard.
If
an
area
meets
this
definition,
EPA
is
obligated
to
designate
the
area
as
nonattainment.
The
criteria
in
the
Clean
Air
Act
for
establishing
nonattainment
boundaries
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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
5­
31
local
contributions.
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
on
emission
sources.

In
Southwest
Indiana,
monitors
in
Vanderburgh
and
Dubois
Counties
show
a
violation
of
fine
particulate
matter
standard.
Therefore
despite
monitoring
attainment,
EPA
evaluated
Spencer
County
for
contributions
to
these
violations
using
the
other
eight
factors.
Indiana
provided
updated
information
on
Spencer
County
emission
reductions
including
information
on
controls
added
to
the
Indiana
Michigan
Power
Rockport
power
plant.
EPA
considered
this
new
information
in
making
its
final
decision
on
Spencer
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.
A
nonattainment
designation
is
not
expected
to
have
a
negative
impact
on
the
infrastructure
improvement
projects
in
Spencer
County.

Comment:
1032­
1
Region:
5
State:
IN
Area:
Evansville,
IN­
KY
|
Louisville,
KY­
IN
Comment:
The
Emission
Weighting
System
is
flawed
Although
EPA
provided
states
and
Regional
Administrators
guidance
for
devising
nonattainment
boundary
recommendations
that
is
virtually
identical
to
that
associated
with
the
8­
hour
ozone
standard,
it
appears
that
the
EPA
placed
enormous
reliance
on
the
new
emissions
weighting
system
to
substantiate
its
proposed
designations.
IDEM
believes
that
this
weighting
system:
5­
32
­
Was
devised
after
states
submitted
their
recommendations,

­
Was
applied
with
insufficient
consultation
and
consideration
with
states
and
within
EPA,

­
Places
undue
weight
on
outdated
emissions
data
as
opposed
to
other
key
considerations
such
as
meteorology,
photochemical
modeling,
or
speciated
data
analysis,

­
Fails
to
consider
the
true
impact
of
emissions
on
actual
monitor
values,

­
Was
not
applied
to
numerous
counties
that
may
have
a
greater
impact
on
counties
with
a
monitored
violation,
and
­
Unfairly
penalizes
counties
in
smaller
urban
areas
since
it
relies
on
complex
ratios
that
do
not
take
volume
of
actual
emissions
into
consideration.

One
result
of
EPA's
approach
is
that
counties
such
as
Jefferson,
Pike
and
Spencer
that
are
located
adjacent
to,
but
not
within,
urban
areas
are
automatically
included
as
nonattainment
counties
if
they
contain
a
power
plant.
This
result
is
unjustified
for
several
reasons:

a.
There
is
no
scientific
basis
to
assume
that
these
power
plants
are
contributing
to
urban
nonattainment
but
more
remote
plants
are
not.
In
fact,
EPA
has
determined
just
the
opposite
to
be
true:
in
its
proposed
Clean
Air
Interstate
Rule
(
CAIR),
it
found
that
all
power
plants
in
the
east
and
Midwest
are
contributing
to
high
background
PM2.5
levels.

b.
EPA
has
used
outdated
emissions
and
emissions
control
information
about
power
plants
in
the
counties
it
has
proposed
as
nonattainment.

c.
EPA
is
poised
to
require
substantial
reductions
of
NOx
and
SO2
from
the
power
plant
sector
through
the
CAIR
from
facilities
in
both
attainment
and
nonattainment
counties.
Including
these
particular
counties
with
power
plants
in
nonattainment
areas
is
not
necessary
to
ensure
the
reductions
will
occur.

EPA
Response:
Fine
particles
include
a
variety
of
constituents.
Therefore,
EPA's
evaluation
of
the
areas
that
may
contribute
to
monitored
violation
must
consider
emissions
of
several
pollutants.
EPA
formulated
weighted
emission
values
as
a
means
of
compiling
data
on
emissions
of
multiple
pollutants
into
a
single
indicator
of
the
level
of
emissions
that
could
contribute
to
PM2.5
concentrations.

EPA's
letter
to
Indiana
dated
June
29,
2004,
describes
the
calculation
of
weighted
emissions
values.
In
brief,
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.
EPA
used
2001
emissions
information
for
all
counties.
In
step
2,
we
adjust
this
percentage
by
the
violating
area's
excess
urban
emissions
for
the
pertinent
speciated
5­
33
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
pollutants
with
the
greatest
contribution
to
the
urban
excess
PM2.5.
The
emission
weighting
is
then
extended
to
counties
adjacent
to
the
metropolitan
area.
Counties
that
are
further
removed
from
the
metropolitan
area
were
not
given
a
weighted
emission
score.
Emissions
from
these
counties
contribute
to
the
regional
background
PM2.5
levels.

Indiana's
comment
seems
to
object
not
so
much
to
the
formulation
of
the
composite
emission
value
as
to
an
alleged
overuse
of
emissions
data
in
general.
Indiana
is
correct
that
the
level
of
emissions
in
a
county
does
not
by
itself
establish
the
level
of
impact
of
that
county's
emissions
on
ambient
air
quality
at
any
particular
location.
For
that
reason,
EPA
also
examined
several
other
factors
in
considering
the
potential
of
a
county's
emissions
to
contribute
to
observed
violations.
Most
notably,
EPA
considered
meteorology.
Because
the
critical
PM2.5
standard
is
an
annual
standard,
and
because
winds
blow
in
all
directions
at
one
time
or
another
during
a
year,
emissions
in
any
direction
from
a
violation
will
contribute.
At
the
same
time,
winds
in
Indiana
blow
more
often
from
the
southwest
than
from
the
northeast,
and
so
a
ton
of
emissions
to
the
southwest
will
likely
have
greater
impact
than
a
ton
of
emissions
to
the
northeast.
EPA
considered
these
principles
and
considered
the
area­
specific
wind
information
given
under
factor
6
for
each
area.
Generally,
EPA
considered
this
information
in
a
qualitative
manner,
but
in
the
Indianapolis
area
EPA
performed
quantitative
calculations
to
consider
this
information.

EPA
recognizes
that
a
ton
of
emissions
will
result
in
a
higher
composite
emission
score
in
a
small
area
than
in
a
large
area.
For
this
reason,
EPA
is
not
using
composite
emission
scores
to
compare
areas.
EPA
is
instead
using
these
scores
on
an
area­
by­
area
basis
to
evaluate
what
counties
have
more
and
less
emissions
and
thus
more
and
less
potential
impact
resulting
in
the
violation
that
the
area
has
monitored.

EPA
considered
the
additional
emission
information
Indiana
submitted
for
its
areas.
Indiana
provided
updated
emission
inventories
and
information
on
controls
added
to
power
plants
that
further
reduce
emissions.
With
Indiana's
help,
EPA
used
the
best
available
emissions
information
in
judging
potential
contributions
to
observed
violations
of
the
PM2.5
standard.
5­
34
Contrary
to
Indiana's
comment,
in
no
cases
did
EPA
express
intent
to
designate
a
county
as
nonattainment
simply
because
the
county
contained
a
power
plant.
EPA
examined
emissions
data
as
a
first
indicator
of
a
county's
potential
to
contribute
to
violations,
and
EPA
expressed
intent
to
promulgate
a
nonattainment
designation
for
those
counties
which
had
sufficient
emissions
and
for
which
other
factors
supported
the
view
that
the
counties
indeed
contribute
to
nearby
violations.
As
a
general
matter,
large
power
plants
have
significant
emissions
and
commonly
were
found
to
be
potential
contributors
not
just
to
regional
background
concentrations
but
also
to
local
concentrations
above
background
levels.
Conversely,
EPA
is
promulgating
a
designation
of
attainment
for
counties
that
have
small
power
plants
and
that
have
no
other
emissions
or
monitored
violations
that
warrant
a
nonattainment
designation.

Although
the
CAIR
rule
may
achieve
substantial
emission
reductions,
EPA
cannot
base
an
area's
air
quality
designation
on
projected
air
quality
or
on
uncertain
future
emission
reductions.
EPA
agrees
that
it
is
important
to
have
programs
that
address
emissions
on
a
national
and
regional
scale
in
addition
to
local
control
measures.

Regarding
additional
points
that
Indiana
makes,
EPA
finds:

­
The
states
have
had
the
opportunity
to
comment
on
the
weighted
emissions
calculations
as
part
of
the
120­
day
consultation
process
­
EPA
of
course
thoroughly
considered
how
to
make
these
calculations,
and
­
EPA
considered
all
counties
with
potential
to
meet
Clean
Air
Act
criteria
of
being
a
nearby
area
contributing
to
the
violation
Comment:
1042­
1
Region:
5
State:
IN
Area:
Indianapolis,
IN
Comment:
Commenter
is
concerned
about
the
analysis
scheme
that
is
the
basis
for
the
PM2.5
designations.
He
comments
this
scheme
will
result
in
nonattainment
for
many
counties
where
air
quality
meets
the
standard
and
where
the
designation
is
not
necessary
to
address
sources
contributing
to
regional
air
pollution
levels.
He
is
concerned
that
Hamilton
County
will
be
designated
nonattainment
which
could
result
in
economic
loss
for
the
area.
He
asks
EPA
to
reconsider
its
policy
and
limit
designations
to
areas
that
exceed
the
NAAQS.

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.
The
criteria
in
the
Clean
Air
Act
for
establishing
5­
35
nonattainment
boundaries
do
not
include
the
potential
economic
consequences
of
imposing
nonattainment
area
requirements.
Including
all
areas
that
contribute
to
violations
in
the
nonattainment
area
enhances
the
planning
process
and
enhances
the
likelihood
that
the
health
benefits
of
meeting
the
NAAQS
will
be
achieved.

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.

In
the
Indianapolis
area,
monitors
in
Marion
County
show
a
violation
of
the
standard.
There
is
no
monitor
in
Hamilton
County.
Therefore,
EPA
evaluated
Hamilton
County
for
contributions
to
the
Marion
County
violations
using
the
other
eight
factors.
Indiana
did
provide
updated
information
on
emission
including
information
on
fuel
conversion
of
the
PSI
Energy
power
plant
in
Noblesville
from
coal
to
natural
gas.
EPA
considered
this
updated
information
in
making
its
final
decision
on
Hamilton
County.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
(
GDP)
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Focusing
on
nonattainment
areas,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
significantly
retard
economic
growth.
5­
36
Comment:
1013a­
19
Region:
5
State:
IN
Area:
Indianapolis,
IN
Comment:
EPA
did
not
include
10
counties
in
its
recommended
nonattainment
area
for
the
Indianapolis
CMSA.
Those
counties
are:
Bartholomew,
Boone,
Brown,
Hancock,
Henry,
Jennings,
Madison,
Montgomery,
Putnam,
and
Shelby.
The
entire
CMSA
must
be
designated
as
one
nonattainment
area.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
OMB
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM­
2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
vehicle
miles
traveled
(
VMT)
and
wind
frequency
from
Boone,
Hancock,
Madison
and
Shelby
(
which
are
part
of
the
1999
Indianapolis
CMSA/
MSA)
and
Bartholomew,
Brown,
Henry,
Jennings,
Montgomery,
and
Putnam
Counties
(
which
are
part
of
the
2003
Indianapolis
CBSA/
CSA)
before
deciding
to
designate
them
as
attainment/
unclassified.
This
decision
was
made
because
most
of
the
emissions,
population,
and
VMT
are
from
Hamilton,
Hendricks,
Johnson,
Marion
and
Morgan
Counties,
which
will
be
designated
as
nonattainment
for
PM2.5.

Comment:
1032­
10
Region:
5
State:
IN
Area:
Indianapolis,
IN
Comment:
The
only
monitored
violations
of
the
standard
within
the
Indianapolis
MSA
occur
in
Marion
County.
Four
of
the
six
monitors
within
the
MSA
exceed
the
standard.
Marion
County
maintains
the
highest
concentration
for
employment,
VMT,
commerce,
and
recreation
compared
to
the
other
counties
within
the
MSA.
Stationary
sources
within
Marion
County
account
for
over
half
of
the
direct
PM2.5
emissions
from
stationary
sources
within
Central
Indiana
and
the
next
closest
county
within
the
region
accounts
for
just
11
percent.
Sources
within
Marion
County
also
account
for
70
percent
of
the
SO2
emissions
from
stationary
sources
within
the
Central
Indiana
Region.
Unlike
ozone,
PM2.5
monitoring
values
indicate
that
PM2.5
values
decrease
away
from
the
core
of
the
Indianapolis
urban
area
into
the
suburban
area.
This
is
represented
by
the
lower
values
registered
at
the
Mann
Road
monitor
which
is
southwest
of
the
core
urban
area
and
by
the
Madison
County
monitor
which
is
northeast
of
the
core
urban
area.
Both
of
these
monitors
register
values
below
the
standard.
5­
37
As
a
result
of
the
weighted
emission
scoring
system,
EPA
has
proposed
that
Hamilton,
Hendricks,
and
Johnson
and
Morgan
counties
be
included
in
the
nonattainment
area
due
to
population
density
and
the
potential
impact
of
mobile
source
emissions.
However,
the
predominant
VMT
concentrations
and
commuting
patterns
occur
at
the
fringes
of
the
county
along
the
I­
465
corridor
in
the
northeast,
northwest,
and
southwest
corners
of
Marion
County
where
monitor
values
are
either
below
the
standard
or
predicted
to
be
below
the
standard.
There
are
power
plants
in
Hamilton
and
Morgan
counties
that
have
dramatically
reduced
emissions.
The
closest
downwind
monitor
of
Morgan
County
is
the
Mann
Road
monitor
in
Marion
County.
This
monitor
maintains
a
value
below
the
standard.
Therefore,
IDEM
recommends
that
Hamilton
Hendricks,
Johnson
and
Morgan
Counties
be
designated
attainment.

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

Once
we
determine
that
an
area
is
violating
the
standard,
the
next
step
is
to
determine
if
there
are
any
nearby
areas
that
are
contributing
to
the
violation
and
should
be
included
in
the
designated
nonattainment
area.
In
addition
to
the
important
contribution
from
longrange
transport,
we
believe
that
violations
which
we
find
in
urban
areas
reflect
significant
contributions
from
the
associated
metropolitan
area
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
reflects
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.

For
the
Indianapolis
area,
monitors
in
Marion
County
showed
a
violation
of
the
fine
particulate
matter
standard.
EPA
evaluated
the
eight
surrounding
counties
for
contributions
to
the
violation.
Indiana
did
provide
updated
information
on
emission
reductions
at
stationary
sources
in
surrounding
counties.
This
information
did
not
include
emissions
from
mobile
sources.
Information
on
fuel
conversion
of
the
PSI
Energy
power
plant
in
Hamilton
County
from
coal
to
natural
gas
was
included.
The
weight
emission
scores
did
change
slightly
after
adjusting
for
the
updated
emissions.
Marion
County
still
accounts
for
a
just
over
half
of
the
weighted
emissions.
The
emissions
score
for
Hamilton
County
dropped
below
the
Morgan
County
score.
None
of
the
surrounding
counties
stand
out
individually,
although
they
do
collectively,
when
considering
just
emissions
and
only
about
half
of
the
weighted
emissions
for
the
area
are
from
Marion
County.
The
Indianapolis
area
extends
somewhat
into
each
of
the
counties
that
EPA
is
designating
nonattainment,
and
EPA
concluded
more
than
just
Marion
County
contributes
to
the
violations
found
in
Marion
County.
After
evaluating
on
all
nine
factors,
EPA
was
able
to
determine
the
appropriate
counties
to
include
in
the
Indianapolis
nonattainment
area.
5­
38
Comment:
1013a­
20
Region:
5
State:
IN
Area:
Louisville,
KY­
IN
Comment:
EPA
failed
to
recommend
that
Harrison,
Scott
and
Washington
Counties
be
included
in
the
Louisville
nonattainment
area.
None
of
these
counties
contain
monitors
in
order
to
determine
whether
they
are
attaining,
but
since
they
are
all
part
of
the
CMSA,
they
must
be
included
in
the
nonattainment
area.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
OMB
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM­
2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
and
vehicle
miles
traveled
(
VMT)
from
Harrison
and
Scott
Counties
(
which
are
part
of
the
1999
Louisville
CMSA/
MSA)
and
Washington
County
(
which
is
part
of
the
2003
Louisville
CBSA/
CSA)
before
deciding
to
designate
them
as
attainment/
unclassified.
Harrison,
Scott
and
Washington
Counties
have
fairly
low
emissions
and
the
emissions,
population
and
VMT
from
these
counties
represent
a
small
percentage
of
the
total
emissions,
population
and
VMT
from
the
Louisville
CMSA.
In
addition,
a
portion
of
Jefferson
County,
Indiana,
will
be
designated
as
nonattainment,
thereby
making
the
contribution
from
Harrison,
Scott
and
Washington
Counties
even
less
significant.
Harrison,
Scott
and
Washington
Counties
do
not
contain
monitors,
EPA
does
not
have
convincing
evidence
that
these
areas
exceed
the
air
quality
standard,
and
the
emissions
generated
in
these
counties
would
not
be
expected
to
contribute
to
nonattainment
of
the
PM2.5
standard.

Comment:
1032­
12
Region:
5
State:
IN
Area:
Louisville,
KY­
IN
Comment:
IDEM
believes
that
EPA
should
designate
Floyd
and
Jefferson
Counties
as
attainment.
There
are
two
monitors
within
Indiana's
portion
of
the
Louisville
MSA­
Clark
and
Floyd
Counties.
The
Clark
County
monitor
is
the
only
monitor
violating.

1.
Monitoring
data
suggests
that
the
Clark
County
monitor
may
be
affected
by
a
local
source/
sources
within
Clark
County
including
onroad
and
nonroad
contributions
from
a
nearby
interstate
undergoing
major
reconstruction.

2.
Jefferson
County
is
not
a
part
of
the
Louisville
MSA
and
is
downwind
of
Louisville,
thus
it
is
highly
unlikely
that
it
is
significantly
contributing
to
violations
in
the
Louisville
5­
39
MSA.
Counties
should
not
be
singled
out
because
they
are
adjacent
to
a
MSA
or
because
a
power
plant
is
located
within
it.

3.
There
is
a
power
plant
in
Floyd
County
but
there
is
no
scientific
evidence
that
it
is
a
significant
contributor
to
the
Clark
County
monitor
exceedance.
In
addition,
this
source
will
be
regulated
by
future
control
requirements
(
e.
g.,
CAIR).

EPA
Response:
EPA
disagrees
with
Indiana's
comment.
The
Clark
County
monitor
is
showing
a
PM­
2.5
design
value
of
16.2
micrograms/
cubic
meter
based
on
the
three
most
current
years
of
data,
2001­
03.
The
design
value
for
Jefferson
County,
Kentucky
is
16.9
µ
g/
m3
for
2001­
03.
So,
there
is
no
reason
to
believe
the
violation
in
Clark
County
is
caused
by
local
sources
only.
EPA
believes
that
breathing
unhealthy
levels
of
PM2.5
is
a
serious
air
pollution
problem
and
that
the
designation
should
reflect
the
area
that
is
experiencing
and/
or
contributing
to
the
unhealthful
levels
of
the
pollutant.

Even
though
some
rural
counties
are
not
a
part
of
some
CMSAs,
these
counties
are
being
designated
as
nonattainment
areas
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.
Therefore,
EPA
is
including
a
portion
of
Jefferson
County,
Indiana
in
the
Louisville
nonattainment
area.
EPA
is
including
this
area
in
the
nonattainment
area
not
simply
due
to
the
presence
of
a
power
plant
but
rather
because
the
power
plant
has
sufficiently
large
emissions
to
conclude
that
the
area
is
a
nearby
source
area
that
contributes
to
the
Louisville
area
violations.
While
Jefferson
County
is
more
often
downwind
than
upwind
of
Louisville,
the
wind
blows
from
Jefferson
County
toward
Louisville
with
sufficient
frequency
for
Jefferson
County
sources
to
contribute
to
Louisville
area
violations.
The
technical
support
document
defines
the
area
within
Jefferson
County
that
is
being
designated
nonattainment
and
provides
further
discussion
of
EPA's
rationale
for
this
designation.

As
for
Floyd
County,
EPA
cannot
base
an
area's
air
quality
designation
on
projected
air
quality
or
on
proposed
legislation.
EPA
agrees
that
it
is
important
to
have
programs
that
address
emissions
on
a
national
and
regional
scale.
These
programs
would
improve
the
air
quality
in
many
areas
across
the
country.
Further,
Floyd
County
has
the
highest
emissions
of
the
Indiana
counties
in
the
Louisville
area.
There
is
also
substantial
commuting
from
Floyd
County
into
Clark
County
and
Kentucky.
EPA
believes
that
Floyd
County
emissions
contribute
to
violations
found
elsewhere
in
the
Louisville
nonattainment
area.

Comment:
1014­
1
Region:
5
State:
MI
Area:
Detroit­
Ann
Arbor,
MI
Comment:
Commenter
disagrees
with
EPA's
proposal
to
designate
7
counties
as
nonattainment.
MI
DEQ
believes
that
only
Wayne
and
Monroe
counties
should
be
5­
40
designated
nonattainment,
and
that
each
county
should
be
designated
a
separate
nonattainment
area.
Commenter
attaches
comments
that
he
believes
supports
MI
DEQ's
position
for
the
following
reasons:

1.
EPA's
proposal
for
a
7­
county
nonattainment
area
is
SW
Michigan
is
arbitrary
as
it
applies
to
PM2.5,
which
is
clearly
evident
after
reviewing
current
and
historical
PM2.5
data
for
PM.

2.
Most
monitors
intended
to
gauge
attainment
status
are
measuring
attainment,
making
a
widespread
nonattainment
designation
inappropriate
from
a
regulatory
perspective
and
misleading
from
a
public
health
perspective.

3.
The
EPA
proposed
CAIR
with
the
stated
purpose
of
reducing
transport
of
PM2.5
and
precursors
would
include
all
of
the
CMSA.
Most
of
the
transported
particulate
sources
that
may
be
impacting
the
nonattainment
area
will
be
covered
by
CAIR
and
the
NOx
SIP
call.
These
rules
negate
the
need
for
widespread
nonattainment
designations
to
secure
reductions
in
transport.

4.
Even
though
the
prevailing
winds
are
from
the
south
and
southwest,
the
downwind
monitors
in
other
urban
counties
in
the
CMSA
still
measure
attainment,
further
evidence
that
the
presumptive
CMSA
boundary
is
inappropriate.
Michigan
provided
extensive
analyses
of
trajectories
and
related
information,
supplementing
information
submitted
in
February
2004
which
it
believes
EPA
did
not
consider,
which
lead
Michigan
to
conclude
that
several
of
the
counties
that
EPA
expressed
intent
to
designate
as
nonattainment
in
fact
are
predominantly
downwind
of
the
violations
and
do
not
contribute
to
these
violations.

5.
Michigan
has
the
authority
to
adopt
controls
beyond
the
nonattainment
boundary
if
needed
for
reaching
attainment.
Also,
EPA
is
required
to
reject
a
SIP
if
it
does
not
meet
the
attainment
demonstration
test.
Nothing
is
gained
by
lumping
in
counties
where
monitors
record
attainment.

EPA
Response:
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
long­
range
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,
the
boundaries
of
nonattainment
areas
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.
5­
41
Once
an
area
has
a
monitor
violating
the
NAAQS,
EPA
uses
emissions
data,
along
with
other
information,
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.
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.
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
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.

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).
Although
the
CAIR
rule
may
achieve
substantial
emission
reductions,
EPA
cannot
base
an
area's
air
quality
designation
on
projected
air
quality
or
on
proposed
legislation.
Further,
EPA
agrees
that
it
is
important
to
have
programs
that
address
emissions
on
a
national
and
regional
scale.
Although
these
programs
would
have
a
positive
impact
on
many
areas
in
Michigan
and
across
the
country,
EPA
must
also
define
a
nonattainment
area
that
includes
the
more
local
sources
that
need
consideration
in
air
quality
planning.
EPA
appreciates
Michigan's
statement
that
it
can
implement
necessary
control
measures
outside
the
nonattainment
area,
but
EPA
must
follow
the
Clean
Air
Act's
prescription
to
include
both
the
violation
area
and
all
nearby
areas
that
contribute
to
the
violation
and
thereby
providing
for
the
full
range
of
Clean
Air
Act
5­
42
provisions
(
including
but
not
limited
to
the
attainment
planning
requirement)
that
help
address
nonattainment
problems.

In
Southeast
Michigan,
monitors
in
Wayne
and
Monroe
Counties
show
violations
of
the
PM2.5
standard.
Despite
monitoring
attainment,
EPA
evaluated
the
other
counties
in
the
Detroit
CMSA
for
contributions
to
these
violations
using
the
nine
factors
including
the
emissions,
population,
and
vehicle
miles
traveled
(
VMT).
EPA
believes
that
the
Detroit
nonattainment
area
should
include
Livingston,
Macomb,
Monroe,
Oakland,
St.
Clair,
Washtenaw
and
Wayne
Counties.
EPA
disagrees
with
Michigan's
recommendations
to
split
Monroe
and
Wayne
Counties
into
two
smaller
nonattainment
areas.
EPA
believes
that
Wayne
County
and
the
other
nearby
counties
contribute
to
the
violation
in
Monroe
County,
and
EPA
believes
that
Monroe
County
contributes
to
the
violations
in
Wayne
County.
EPA
seeks
to
maximize
consistency
between
the
PM2.5
and
the
8­
hour
ozone
designations
and
keeping
these
counties
together
under
PM2.5
would
be
consistent
with
the
designations
under
8­
hour
ozone.

Michigan
provided
updated
population
and
VMT
information,
in
addition
to
PM2.5
concentration
roses,
to
show
that
the
downwind
counties
are
not
impacting
the
Wayne
County
PM2.5
concentrations.
EPA
considered
this
information
in
making
its
final
decision
on
the
Detroit
CMSA.
In
fact,
EPA's
June
2004
letter
to
Michigan
discusses
the
trajectory
information
provided
with
Michigan's
February
2004
recommendations,
noting
that
trajectory
analyses
and
other
similar
analyses
will
often
better
describe
the
origins
of
regional
transport
rather
than
the
origins
of
local
contributions.
EPA
concludes
that
annual
average
concentrations
reflect
contributions
from
all
wind
directions
and
disagrees
with
the
State's
arguments
that
the
nonattainment
area
need
only
reflect
source
areas
to
the
south
and
west
of
the
monitors
recording
violations.

Michigan
provided
information
from
the
Michigan
Economic
Development
Commission
stating
that
Livingston
County
population
grew
by
only
7
percent
between
2000
and
2003.
However,
data
from
the
U.
S.
Census
Bureau
suggest
a
population
growth
of
10
percent
over
this
period
(
from
156,951
to
172,881),
similar
to
the
growth
rate
for
1990
to
2000
that
led
EPA
to
identify
Livingston
County
as
a
prospective
part
of
the
Detroit
nonattainment
area.
In
addition,
U.
S.
Census
Bureau
data
includes
Livingston
County
in
the
top
100
fastest
growing
U.
S.
counties
with
a
13.2
percent
increase
in
Housing
Unit
estimates
for
this
same
period.
EPA
continues
to
consider
Livingston
County
a
relatively
high
growth
area,
and
EPA
is
including
this
county
in
the
Detroit
PM2.5
nonattainment
area.
5­
43
Comment:
1013a­
29
Region:
5
State:
MI
Area:
Detroit­
Ann
Arbor,
MI
Comment:
Detroit
CMSA:

EPA
failed
to
recommend
Genesee
and
Lapeer
Counties
for
nonattainment.
These
counties
are
part
of
the
CMSA
and
must
be
designated
nonattainment.
EPA's
letter
to
the
state
reports
that
NOx
emissions
in
Genesee
County
are
around
20,000
tons
annually.
EPA
cites
prevailing
wind
direction
as
a
reason
for
not
including
Genesee
County
in
the
nonattainment
area.
Because
the
PM2.5
standard
is
an
annual
standard
prevailing
wind
direction
does
not
have
as
much
impact
on
the
elevated
values
as
it
would
with
the
24­
hour
standard.
Although
Lapeer
County's
emissions
are
lower,
the
population
growth
between
1990
and
2000
was
18%,
which
may
lead
to
an
increasing
emission
trend
in
the
area.
In
addition,
Ingham
County
in
the
Lansing­
East
Lansing­
Owosso
CMSA
has
high
emissions,
due
to
the
Eckert
Station
power
plant,
which
emitted
over
6,500
tons
of
SO2
and
over
3,500
tons
of
NOx
in
2002.
This
county
should
be
included
in
the
nonattainment
area
as
well.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs
include
populated
areas
associated
with
core
urban
areas.
EPA
considered
nine
factors
including
the
emissions,
population,
and
vehicle
miles
traveled
(
VMT)
from
Genesee,
Ingham
and
Lapeer
Counties
before
deciding
to
designate
them
as
attainment/
unclassified.
The
emissions
from
these
counties
are
small
relative
to
the
total
emissions
in
the
Detroit
CMSA,
and
the
population
and
VMT
from
the
three
counties
are
a
small
percentage
of
the
population
and
VMT
in
the
Detroit
CMSA.
The
growth
of
Lapeer's
population
by
18
percent
over
10
years
is
not
high
enough
to
lead
to
a
high
level
of
emissions
any
time
soon.
The
commenter
is
correct
that
annual
average
concentrations
reflect
contributions
from
all
wind
directions,
and
indeed
EPA
disagrees
with
the
State's
arguments
that
the
nonattainment
area
need
only
reflect
source
areas
to
the
south
and
west
of
the
monitors
recording
violations.
Nevertheless,
because
winds
blow
less
frequently
from
the
north
and
east,
the
emissions
in
Genesee
and
Lapeer
Counties
will
have
less
impact
than
comparable
emissions
located
in
areas
that
are
more
frequently
upwind.
Genesee
and
Lapeer
Counties
are
also
somewhat
distant
from
the
monitored
violations,
which
also
reduces
the
likely
impact
of
these
emissions
on
the
violations.
The
presence
of
a
power
plant
in
Ingham
County
does
not
necessarily
indicate
that
the
county
should
be
judged
to
be
contributing
to
the
area's
violations.
Notwithstanding
the
presence
of
the
power
plant,
EPA
concluded
that
the
emissions
from
Ingham
County
are
too
small
and
too
distant
from
the
monitored
violations
to
include
this
county
in
the
Detroit
nonattainment
area.
It
is
worth
noting
that
Ingham
County
has
a
monitor
which
shows
that
Ingham
County
is
attaining
the
PM2.5
standard.
5­
44
Comment:
1013a­
36
Region:
5
State:
OH
Area:
Canton,
OH
Comment:
EPA
failed
to
include
Carroll
County
in
this
recommended
nonattainment
area;
this
area
is
part
of
the
Canton
MSA
and
must
be
designated
nonattainment
with
the
rest
of
this
area.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
the
Office
of
Management
and
Budget
(
OMB)
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
vehicle
miles
traveled
(
VMT)
and
wind
frequency
before
deciding
to
designate
Carroll
County
as
attainment/
unclassified.
Among
the
reasons
for
the
attainment/
unclassified
designation
are:

a.
Carroll
County
is
96%
wooded
or
agricultural.

b.
Carroll
county
has
a
population
density
of
74
persons
per
square
mile,
as
compared
to
656
persons
per
square
mile
in
Stark
County.

c.
The
majority
of
the
population
of
the
Canton­
Massillon
MSA
resides
in
Stark
County
(
29,166
for
Carroll
vs.
377,940
for
Stark).

d.
Although
40%
of
commuters
travel
from
Carroll
County
to
areas
outside
that
county,
that
number
is
only
5,125
persons,
which
is
a
small
amount.
In
Stark
County,
only
1
percent
of
commuters
travel
to
other
counties,
which
suggests
that
any
cause
of
PM2.5
attributed
to
vehicular
traffic
would
tend
to
be
caused
by,
and
reside
in,
Stark
County.

e.
Emissions
emanating
from
Carroll
County
are
small
when
compared
to
Stark
County
(
386
tpy
vs.
2,736
tpy
for
SO2)(
1,886
tpy
vs.
14,968
tpy
for
NOx).

The
majority
of
emissions
and
population
are
located
in
Stark
County.
Carroll
County
is
rural,
with
low
population
density,
and
does
not
significantly
contribute
to
the
CMSA.
5­
45
Comment:
1013a­
37
Region:
5
State:
OH
Area:
Cincinnati­
Hamilton,
OH­
KY­
IN
Comment:
Brown
and
Clinton
Counties
are
not
recommended
for
nonattainment
despite
their
being
part
of
the
Cincinnati
CMSA.
The
entire
CMSA
must
be
designated
nonattainment.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM­
2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
the
Office
of
Management
and
Budget
(
OMB)
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM­
2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
vehicle
miles
traveled
(
VMT)
and
wind
frequency
before
deciding
to
designate
Brown
and
Clinton
counties
as
attainment/
unclassified.
Among
the
reasons
for
the
attainment/
unclassified
designations
for
Brown
and
Clinton
Counties
are:

a.
The
population
of
Brown
and
Clinton
Counties
are
small
when
compared
to
the
rest
of
the
Ohio
portion
of
the
CMSA*
(
84,554
(
Brown
and
Clinton)
vs.
1,532,749)

b.
SO2
emissions
from
Brown
and
Clinton
Counties
are
small
when
compared
to
the
rest
of
the
Ohio
portion
of
the
CMSA
(
for
Brown:
395
tpy
vs.
186,751
tpy)
(
for
Clinton:
375
tpy
vs.
186,751
tpy)

c.
NOx
emissions
from
Brown
and
Clinton
Counties
are
small
when
compared
to
the
rest
of
the
Ohio
portion
of
the
CMSA
(
for
Brown:
2,927
tpy
vs.
131,316
tpy)
(
for
Clinton:
2,490
tpy
vs.
131,316
tpy)

d.
The
population
density
of
Brown
County
is
only
88
persons
per
square
mile.

e.
The
growth
rates
for
the
years
1990­
2000
for
Brown
and
Clinton
Counties
are
21%
and
14%,
respectively.
As
noted
in
point
a,
above,
the
populations
of
these
counties
are
small
when
compared
to
the
remainder
of
the
Ohio
portion
of
the
CMSA,
and
the
growth
experienced
did
not
have
a
significant
impact
on
the
population
of
the
CMSA.

Brown
and
Clinton
Counties
are
a
small
portion
of
the
CMSA's
population
and
emissions.
Accordingly,
EPA
concluded
that
these
counties
do
not
contribute
to
nonattainment
in
the
Cincinnati
area.

*
Butler,
Clermont,
Hamilton,
and
Warren
Counties
5­
46
Comment:
1013a­
38
Region:
5
State:
OH
Area:
Cleveland­
Akron­
Lorain,
OH
Comment:
The
nearby
Wayne
County
should
be
included
in
the
Cleveland
nonattainment
area
due
to
its
high
emissions
of
SO2,
NOx
and
VOC.

EPA
Response:
EPA
recommends
in
our
120­
day
letters
that
the
entire
Cleveland­
Akron­
Elyria
metropolitan
be
designated
nonattainment.
Wayne
County,
which
is
adjacent
to
but
not
part
of
the
Cleveland­
Akron­
Elyria
CMSA,
has
low
emissions
when
compared
to
the
Cleveland
metropolitan
area
(
Ashtabula,
Lake,
Geauga,
Cuyahoga,
Lorain,
Medina,
Summit,
and
Portage
counties).
The
population
of
Wayne
County,
while
moderate
in
size,
is
small
when
compared
to
the
population
of
the
Cleveland
metropolitan
area
(
112,704
persons
vs.
2,950,614
persons).
While
19
percent
of
Wayne
county
commuters
commute
to
other
metro
counties,
the
number
of
commuters
is
small
(
10,099).
For
SO2,
Wayne
County
emissions
are
low
when
compared
to
the
Cleveland
metropolitan
area
(
21,450
tpy
vs.
138,379
tpy).
NOx
emissions
from
Wayne
County
are
also
small
when
compared
to
the
Cleveland
metropolitan
area
(
8,911
tpy
vs.
173,252
tpy).

A
further
analysis
of
Wayne
County's
emissions,
which
consisted
of
a
comparative
review
of
1996
and
1999
NEI
data,
shows
that
between
1996
and
1999,
the
Tenneco
Packaging
facility,
the
second
largest
point
source
in
Wayne
County,
had
shut
down,
taking
with
it
10,328
tpy
SO2.
The
1996
NEI
data
show
the
total
point
source
SO2
emissions
for
Wayne
County
at
28,776.46
tons
per
year.
The
1999
NEI
data
(
which
reflect
the
Tenneco
shutdown)
show
the
total
point
source
SO2
emissions
for
Wayne
County
at
18,716.73
tons,
a
10,000
ton
reduction.
While
neither
the
1996
nor
1999
NEI
values
are
substantially
different
from
the
2001
NEI
value
used
in
the
designations
spreadsheet
(
21,450
tons),
they
suggest
the
variability
and
potential
uncertainty
of
NEI
data
for
rural
or
non­
metropolitan
area
counties.
Regardless,
the
emissions
and
population
of
Wayne
County
are
small
when
compared
to
the
Cleveland
metropolitan
area.

Comment:
1031­
3
Region:
5
State:
OH
Area:
Cleveland­
Akron­
Lorain,
OH
Comment:
Geauga
and
Ashtabula
Counties
are
part
of
the
Cleveland/
Akron/
Ashtabula
combined
metropolitan
statistical
area.
These
counties
only
combine
for
6.6%
of
the
CMSA
population,
have
the
lowest
VMT
in
the
proposed
nonattainment
area
and,
on
annual
average
basis,
are
downwind
of
the
monitored
violations.
While
neither
of
these
counties
are
currently
monitored,
there
are
monitors
measuring
attainment
between
these
counties
and
the
monitors
exhibiting
the
urban
excess.
Ohio
does
not
believe
that
these
5­
47
areas
are
experiencing
or
significantly
contributing
to
the
nonattainment
problems
in
Cleveland
or
Akron.

Based
on
data
from
the
EPA
Clean
Air
Markets
database,
emissions
have
been
reduced
at
the
Ashtabula
plant
since
1996
due
to
various
unit
retirements
and
reductions
in
utilization.
In
fact,
it
appears
that
emissions
at
the
plant
have
been
reduced
from
approximately
67,000
tons
of
SO2
to
2600
tons
and
a
reduction
in
NOx
emissions
from
approximately
4800
to
1700
tons
over
the
same
period.
In
addition,
Ashtabula
County
is
generally
downwind
of
the
Cleveland
nonattainment
area.
Wind
roses
from
Cleveland
and
Erie,
PA,
based
on
National
Weather
Service
meteorological
data
collected
from
1984­
1992,
show
that
there
are
relatively
few
occurrences
of
winds
that
would
transport
emissions
from
Ashtabula
County
to
Cleveland.
Additional
emission
controls
on
sources
in
Ashtabula
County
would
do
little
or
nothing
to
achieve
attainment
in
the
Cleveland
area.

EPA
Response:
Regarding
Ashtabula
County,
the
emissions
data
EPA
used
in
assessing
PM2.5
designations
reflect
emissions
for
2001.
Ohio
cited
emission
reductions
since
1996
but
does
not
specify
whether
any
of
these
reductions
occurred
since
2001.
In
EPA's
database,
the
Ashtabula
Plant
is
estimated
to
emit
11,882
tons
per
year
of
SO2
and
3,085
tons
per
year
of
NOx.
Thus,
it
appears
that
most
of
the
emission
reductions
noted
by
Ohio
have
in
fact
already
been
credited.

As
a
result,
EPA
views
Ashtabula
Township,
which
includes
the
Ashtabula
plant
and
a
significant
fraction
of
the
population
of
Ashtabula
County,
as
contributing
to
nonattainment
in
the
Cleveland
area.
However,
EPA
concludes
that
the
remainder
of
this
county
may
be
designated
attainment.

Regarding
Geauga
County,
EPA
has
reassessed
the
data
for
this
area
and
concluded
that
this
county
indeed
has
low
emissions
and
low
population.
EPA
is
thus
designating
Geauga
County
as
attaining
the
standard.

Comment:
1013a­
39
Region:
5
State:
OH
Area:
Columbus,
OH
Comment:
EPA
failed
to
include
Ross,
Madison,
Morrow,
Pickaway,
Union,
Marion,
Know
and
Fayette
Counties
in
the
recommended
Columbus
CMSA
nonattainment
area.
The
Picway
electric
generating
station
in
Pickaway
County
emitted
over
10,000
tons
of
SO2
in
2002.
Coshocton
County,
adjacent
to
the
CMSA,
is
home
to
the
Conesville
electric
generating
facility.
In
2002
this
facility
emitted
over
135,000
tons
of
SO2
and
almost
27,000
tons
of
NOx.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
the
Office
of
Management
and
Budget
(
OMB)
in
1999,
include
5­
48
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
vehicle
miles
traveled
(
VMT)
and
wind
frequency
before
deciding
to
designate
Ross,
Madison,
Morrow,
Pickaway,
Union,
Marion,
Knox,
and
Fayette
Counties
as
attainment/
unclassified.
Among
the
reasons
for
the
attainment/
unclassified
designations
for
Ross,
Madison,
Morrow,
Pickaway,
Union,
Marion,
Knox,
and
Fayette
Counties
are:

a.
Ross
County:

­
Ross
County
is
outside
the
Columbus
MSA,
yet
considered
part
of
the
Columbus
CSA.
However,
urban
increment
data
for
Columbus
show
that
the
PM2.5
urban
excess
in
Columbus
is
27%
nitrates
and
73%
carbon.
While
nitrogen
precipitation
is
known
to
occur
long
distances
away
from
the
source,
nitrogen
emissions
are
small
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
counties
(
8,000
tpy
vs.
62,000).
The
direct
carbon
emissions
from
Ross
County
are
small
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties
(
423
tpy
vs.
4,073
tpy).

b.
Madison
County:

­
While
part
of
the
Columbus
MSA,
Madison
County,
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties,
has
low
population
(
40,365
persons
vs.
1,490,105
persons)
and
emissions
(
SO2:
233
tpy
vs.
9466
tpy)(
NOx:
3,106
tpy
vs.
62,000
tpy)(
direct
carbon:
259
tpy
vs.
4,073
tpy).

c.
Morrow
County:

­
Morrow
County,
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties,
has
low
population
(
32,976
persons
vs.
1,490,105
persons)
and
emissions
(
SO2:
291
tpy
vs.
9466
tpy)(
NOx:
2,434
tpy
vs.
62,000
tpy)(
direct
carbon:
157
tpy
vs.
4,073
tpy).

d.
Pickaway
County:

­
EPA's
comparison
of
the
concentrations
of
PM2.5
components
in
Columbus
versus
background
locations
suggest
that
the
principal
impacts
of
Columbus
area
sources
on
concentrations
in
Columbus
are
from
sources
of
nitrogen
oxides
and
directly
emitted
carbonaceous
particles.
Specifically,
the
Columbus
urban
excess
is
estimated
to
be
comprised
of
27%
nitrates
and
73%
direct
carbon.
Notwithstanding
the
uncertainties
in
this
estimate,
and
notwithstanding
the
fact
that
Pickaway
County
emits
about
half
of
the
SO2
of
the
metropolitan
area,
the
evidence
suggests
that
SO2
emissions
should
not
be
an
important
factor
in
defining
the
area
from
which
local
contributions
to
Columbus
5­
49
violations
arise.
More
significantly,
the
NOx
and
direct
carbon
emissions
from
Pickaway
are
low
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties
(
NOx:
5,971
tpy
vs.
62,000
tpy)
(
direct
carbon:
363
tpy
vs.
4,073
tpy).

e.
Union
County:

­
Union
County,
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties,
has
low
population
(
74,469
persons
vs.
1,490,105
persons)
and
emissions
(
SO2:
377
tpy
vs.
9466
tpy)(
NOx:
2,202
tpy
vs.
62,000
tpy)(
direct
carbon:
246
tpy
vs.
4,073
tpy).

f.
Marion
County:

­
Marion
County,
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties,
has
low
population
(
66,028
persons
vs.
1,490,105
persons)
and
emissions
(
SO2:
675
tpy
vs.
9466
tpy)(
NOx:
3,896
tpy
vs.
62,000
tpy)(
direct
carbon:
273
tpy
vs.
4,073
tpy).

g.
Knox
County:

­
Knox
County,
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties,
has
low
population
(
56,037
persons
vs.
1,490,105
persons)
and
emissions
(
SO2:
302
tpy
vs.
9466
tpy)(
NOx:
2,225
tpy
vs.
62,000
tpy)(
direct
carbon:
258
tpy
vs.
4,073
tpy).

h.
Fayette
County:

­
Fayette
County,
when
compared
to
Delaware,
Fairfield,
Franklin,
and
Licking
Counties,
has
low
population
(
28,176
persons
vs.
1,490,105
persons)
and
emissions
(
SO2:
309
tpy
vs.
9466
tpy)(
NOx:
2,136
tpy
vs.
62,000
tpy)(
direct
carbon:
204
tpy
vs.
4,073
tpy).

Regarding
the
Conesville
power
plant
in
Coshocton
County,
EPA
concurs
with
the
commenter
and
is
designating
Franklin
Township
as
nonattainment
in
order
that
the
nonattainment
area
include
the
Conesville
power
plant.

Comment:
1013a­
40
Region:
5
State:
OH
Area:
Dayton­
Springfield,
OH
Comment:
Champaign,
Darke,
Miami
and
Preble
Counties
were
left
out
of
EPA's
recommended
nonattainment
area,
but
are
part
of
the
Dayton
CMSA
and
must
be
included
in
the
nonattainment
area.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM­
2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
OMB
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
5­
50
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
vehicle
miles
traveled
(
VMT)
and
wind
frequency
from
Miami
County
(
which
is
part
of
the
1999
Dayton
CMSA/
MSA),
and
Champaign,
Darke,
and
Preble
counties
(
which
are
part
of
the
2003
CSA/
CBSA)
before
deciding
to
designate
them
as
attainment/
unclassified.
Among
the
reasons
we
designated
these
counties
attainment
are:

a.
Miami
County
­
The
population
of
Miami
County
is
low
when
compared
to
the
rest
of
the
MSA
(
99,596
vs.
847,850).

­
The
emissions
for
Miami
County
are
small
when
compared
to
the
rest
of
the
MSA
(
for
SO2:
478
tpy
vs.
13,653
tpy)
(
for
NOx:
4,116
tpy
vs.
38,709
tpy)

(
for
direct
carbon:
337
tpy
vs.
1,974
tpy)
(
for
crustal:
972
tpy
vs.
3,298
tpy)

­
We
do
not
feel
that
Miami
County
is
contributing
to
PM2.5
violations
in
the
Dayton
Area
b.
Champaign
County
­
The
population
of
Champaign
County
is
low
when
compared
to
Clark,
Greene
and
Montgomery
counties
(
39,121
vs.
847,850)

­
The
emissions
from
Champaign
County
are
small
when
compared
to
emissions
from
Clark,
Greene,
and
Montgomery
Counties
(
for
SO2:
383
tpy
vs.
13,653
tpy)
(
for
NOx:
1,757
tpy
vs.
38,709
tpy)
(
for
direct
carbon:
180
tpy
vs.
1,974
tpy)
(
for
crustal:
602
tpy
vs.
3,298
tpy)

­
We
do
not
feel
that
Champaign
County
is
contributing
to
PM2.5
violations
in
the
Dayton
area.

c.
Darke
County
The
population
of
Darke
County
is
low
when
compared
to
Clark,
Greene
and
Montgomery
counties
(
52,966
vs.
847,850)

­
The
emissions
from
Darke
County
are
small
when
compared
to
emissions
from
Clark,
Greene,
and
Montgomery
Counties
(
for
SO2:
551
tpy
vs.
13,653
tpy)
(
for
NOx:
3,174
tpy
vs.
38,709
tpy)
(
for
direct
carbon:
381
tpy
vs.
1,974
tpy)
(
for
crustal:
1,316
tpy
vs.
3,298
tpy)

­
We
do
not
feel
that
Darke
County
is
contributing
to
PM2.5
violations
in
the
Dayton
area.
5­
51
d.
Preble
County
The
population
of
Preble
County
is
low
when
compared
to
Clark,
Greene
and
Montgomery
counties
(
42,680
vs.
847,850)

­
The
emissions
from
Preble
County
are
small
when
compared
to
emissions
from
Clark,
Greene,
and
Montgomery
Counties
(
for
SO2:
428
tpy
vs.
13,653
tpy)
(
for
NOx:
2,765
tpy
vs.
38,709
tpy)
(
for
direct
carbon:
1228
tpy
vs.
1,974
tpy)
(
for
crustal:
721
tpy
vs.
3,298
tpy)

­
We
do
not
feel
that
Preble
County
is
contributing
to
PM2.5
violations
in
the
Dayton
area.

Comment:
1031­
2
Region:
5
State:
OH
Area:
Huntington­
Ashland,
WV­
KY­
OH
Comment:
Several
facilities
have
installed
controls
in
response
to
the
NOx
SIP
call.
These
facilities
include:
SCR:
Avon
Lake,
Eastlake,
Cardinal,
Gavin,
Keiger
Creek,
Killen,
Miami
Fort,
Sammis,
Stuart,
and
Zimmer.
With
respect
to
the
counties
that
we
are
requesting
to
be
excluded
from
the
nonattainment
list,
Killen
and
Stuart
are
in
Adams
County
and
Gavin
and
Kyger
Creek
are
in
Gallia
County.

Ohio
EPA
is
also
in
the
process
of
reviewing
permit
applications
and
modeling
protocols
for
the
installation
of
sulfur
dioxide
scrubbers
for
several
facilities.
A
permit
application
(
or
a
determination
of
environmentally
beneficial
project
by
the
Director)
for
scrubbers
at
Miami
Fort
units
7
and
8
is
currently
being
processed.
Modeling
protocols
have
been
submitted
for
scrubber
installations
at
Cardinal,
Killen,
and
Stuart.
Killen
and
Stuart
are
in
Adams
County.
The
rise
in
the
cost
of
SO2
allowances
is
partially
responsible
for
driving
these
utilities
to
install
this
equipment.

EPA
Response:
While
SCR
on
these
facilities
is
a
good
and
necessary
measure
for
reducing
emissions
from
these
facilities,
SCR
primarily
reduces
NOx
emissions
and
does
not
address
SO2
emissions
from
these
facilities.
EPA
believes
that
even
with
SCR,
power
plants
can
still
contribute
to
the
sulfate
component
of
PM2.5
violations
in
the
state.

In
regards
to
the
permits
in
process
at
the
State,
EPA
reiterates
that
future
controls
cannot
be
a
factor
in
determining
the
attainment/
nonattainment
status
for
any
area.
Notwithstanding
the
submittal
of
modeling
protocols
and
other
indications
of
progress
toward
Ohio
permitting
installation
of
controls,
Ohio
EPA
did
not
identify
when
these
controls
might
become
effective
and
provided
no
means
of
assuring
that
these
controls
will
necessarily
be
installed.
Therefore,
EPA
cannot
give
credit
for
these
potential
controls.
5­
52
Comment:
1031­
5
Region:
5
State:
OH
Area:
Huntington­
Ashland,
WV­
KY­
OH
Comment:
Scioto
County
contains
one
monitoring
location.
Based
on
the
complete
three
year
period
2001­
2003,
that
monitor
was
not
attaining
the
PM2.5
annual
standard.
The
peak
three­
year
average
annual
concentration
for
the
period
1999­
2001
was
22.03
µ
g/
m3.
The
three­
year
annual
average
concentration
for
the
period
2001­
2003
at
that
monitor
was
17.23
µ
g/
m3.
Based
on
the
most
recent
10
quarters,
(
January
2002­
June
2004),
the
highest
annual
average
concentration
is
14.37
µ
g/
m3.
The
improvement
at
this
monitor
is
obviously
attributable
to
the
shutdown
of
the
New
Boston
Coke
facility
in
April
2002
as
well
as
the
reductions
associated
with
the
compliance
with
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990.
This
area
will
clearly
attain
the
annual
PM2.5
standard
by
the
proposed
effective
date
for
PM2.5
designations
in
early
2005.

EPA
Response:
EPA
has
decided
to
provide
a
45­
day
opportunity
for
states
to
provide
complete
2004
data.
This
will
allow
EPA
to
adjust
its
final
designations
according
to
whether
areas
are
violating
the
air
quality
standards
based
on
2002
to
2004
data.
However,
EPA
views
the
Huntington­
Ashland
area
as
a
single
nonattainment
area,
so
EPA
does
not
intend
to
designate
Ohio
portions
of
the
area
as
attainment
if
violations
continue
to
be
monitored
for
example
in
the
West
Virginia
portion
of
the
area.

Comment:
1031­
6
Region:
5
State:
OH
Area:
Huntington­
Ashland,
WV­
KY­
OH
Comment:
Lawrence
County
contains
one
monitoring
location.
Based
on
the
complete
three
year
period
2001­
2003,
that
monitor
was
not
attaining
the
PM
2.5
annual
standard.
The
peak
three­
year
average
annual
concentration
for
the
period
199­
2001
was
17.67
ug/
m3.
The
three­
year
annual
average
concentration
for
the
period
2001­
2003
at
that
monitor
was
15.83
ug/
m3.
Based
on
the
most
recent
10
quarters
(
January
2002­
June
2004),
the
highest
annual
average
concentration
is
14.03
ug/
m3.
The
improvement
at
this
monitor
is
obviously
attributable
to
reductions
associated
with
compliance
with
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990.
This
area
will
clearly
attain
the
annual
PM2.5
standard
by
the
proposed
effective
date
for
PM
2.5
designations
in
early
2005.

EPA
Response:
EPA
has
decided
to
provide
a
45­
day
opportunity
for
states
to
provide
complete
2004
data.
This
will
allow
EPA
to
adjust
its
final
designations
according
to
whether
areas
are
violating
the
air
quality
standards
based
on
2002
to
2004
data.
However,
EPA
views
the
Huntington­
Ashland
area
as
a
single
nonattainment
area,
so
EPA
does
not
intend
to
designate
Ohio
portions
of
the
area
as
attainment
if
violations
continue
to
be
monitored
for
example
in
the
West
Virginia
portion
of
the
area.
5­
53
Comment:
1031­
1
Region:
5
State:
OH
Area:
Huntington­
Ashland,
WV­
KY­
OH
|
Cleveland­
Akron­
Lorain,
OH
|
Wheeling,
WV­
OH
|
Columbus,
OH
Comment:
The
commenter
believes
that
the
boundaries
U.
S.
EPA
is
proposing
are
too
broad.

The
inclusion
of
adjacent
"
power
plant"
counties
represents
an
inconsistent
implementation
of
U.
S.
EPA's
findings
that
all
power
plants
in
the
NOx
SIP
Call/
CAIR
region
contribute
to
nonattainment.
For
U.
S.
EPA
to
be
consistent,
all
areas
containing
coal­
fired
power
plants
should
be
designated
nonattainment.

U.
S.
EPA
has
indicated
that
all
power
plants
within
the
region
contribute
significantly
to
nonattainment,
but
yet
only
counties
with
power
plants
that
are
in
or
adjacent
to
an
area
with
a
measured
violation
are
included
into
the
nonattainment
area.
The
inconsistent
application
of
nonattainment
designations
will
put
a
number
of
counties
in
Ohio
at
a
disadvantage
to
similar
power
plants
in
other
states.
This
is
especially
unfortunate
given
the
faulty
logic
EPA
used
to
justify
its
eleventh
hour
inclusion.
For
example,
designating
Adams
County
will
not
affect
the
ability
of
the
Scioto
County
monitor
to
reach
attainment.

Ohio
EPA
does
not
believe
that
designating
power
plant
counties
nonattainment
will
improve
air
quality
or
in
any
way
assist
states
in
developing
plans
to
bring
attainment
to
these
areas.
Adams,
Ashtabula,
Belmont,
Coshocton,
and
Gallia
Counties
should
not
be
designated
nonattainment.

Ohio
EPA
also
expressed
concern
about
the
identification
and
control
of
those
sources
associated
with
the
urban/
industrial
excess
in
areas
where
the
CAIR
requirements
will
not
be
sufficient
to
attain
the
standards.
U.
S.
EPA
has
made
major
assumptions
about
the
source
of
the
urban
excess
concentrations
which
have
been
found
at
the
violating
monitors.
An
extensive
analysis
was
prepared
by
U.
S.
EPA
which
purports
to
identify
the
location
of
the
sources
of
the
urban
excess.
In
this
weighted
emissions
analysis,
all
emissions
within
and
adjacent
to
the
metropolitan
area
have
been
assumed
to
have
equal
potential
to
contribute
to
the
urban
excess.
We
believe
that
this
fundamental
assumption
underlying
the
weighted
emissions
analysis
is
flawed.

Finally,
Ohio
EPA
identified
several
areas
in
the
State
for
which
data
from
2002
to
mid­
2004
show
attainment;
Ohio
EPA
recommends
that
these
areas
be
designated
attainment.

EPA
Response:
EPA
cannot
take
into
account
proposed
rules
like
CAIR
when
designating
areas
as
attainment
or
nonattainment
for
the
PM2.5
NAAQS.
Since
there
is
no
guarantee
that
proposed
rules
like
CAIR
will
be
implemented,
EPA
cannot
take
CAIR
into
consideration
in
this
process.
Regarding
the
NOx
SIP
Call,
it
is
true
that
NOx
emissions
from
power
plants,
which
can
contribute
to
an
area's
PM2.5
problem,
are
5­
54
addressed.
However,
the
same
facilities
also
emit
SO2,
which
is
not
addressed
in
the
NOx
SIP
Call
and
contributes
to
PM2.5
problems
in
Ohio.

Section
107(
d)(
1)(
A)(
i)
of
the
Clean
Air
Act
requires
EPA
to
designate
as
"
nonattainment,
any
area
that
does
not
meet
(
or
that
contributes
to
ambient
air
quality
in
a
nearby
area
that
does
not
meet)
the
national
primary
or
secondary
ambient
air
quality
standard
for
the
pollutant".
If
EPA
were
to
simply
designate
all
areas
with
power
plants
in
the
state
as
nonattainment,
it
might
be
viewed
as
arbitrary
and
capricious.
EPA
intends
to
designate
as
nonattainment
full
and
partial
counties
which
include
all
but
one
of
the
power
plants
listed
in
Title
IV.
The
power
plant
in
Pickaway
County
is
the
only
Title
IV
plant
to
be
located
in
an
proposed
attainment
area.
This
is
because
EPA's
9­
factor
review
shows
that
Pickaway
county
does
not
significantly
contribute
to
emissions
violations
in
the
Columbus
area.

EPA
has
decided
to
provide
a
45­
day
opportunity
for
states
to
provide
complete
2004
data.
This
will
allow
EPA
to
adjust
its
final
designations
according
to
whether
areas
are
violating
the
air
quality
standards
based
on
2002
to
2004
data.

a.
Adams
County
­
EPA
intends
to
designate
Sprigg
and
Monroe
Townships
as
nonattainment
for
PM2.5.
The
J.
M.
Stuart
and
Killen
plants
are
located
in
the
proposed
nonattainment
area.
EPA
believes
that
emissions
from
these
plants
are
contributing
to
violations
in
the
Huntington­
Ashland
Area.

b.
Gallia
County
­
EPA
intends
to
designate
Cheshire
Township
as
nonattainment
for
PM2.5.
The
Kyger
Creek
and
J.
M.
Gavin
plants
are
located
in
the
proposed
nonattainment
area.
EPA
believes
that
emissions
from
those
plants
are
contributing
to
violations
in
the
Huntington­
Ashland
area.

c.
Belmont
County
­
Not
only
does
the
power
plant
in
Belmont
County
contribute
to
violations
in
the
Parkersburg­
Marietta
area,
but
the
69,448
persons
living
in
Belmont
County
represent
46%
of
the
three­
County
metropolitan
area
population.

d.
Ashtabula
County
­
EPA
believes
that
emissions
in
Ashtabula
Township
within
Ashtabula
County
significantly
contribute
to
PM2.5
Violations
in
the
Cleveland
area.
5­
55
e.
Coshocton
County
­
EPA
intends
to
designate
Franklin
Township
as
nonattainment
for
PM2.5.
The
Conesville
plant
is
located
in
the
proposed
nonattainment
area.
EPA
believes
that
the
plant
contributes
to
violations
in
the
Columbus
area.

With
respect
to
EPA's
weighted
emissions
information,
this
information
is
only
part
of
the
information
EPA
considered.
Emissions
information
is
one
of
9
factors
which
EPA
used
to
analyze
potential
nonattainment
areas.
The
weighted
emissions
value
was
intended
as
a
means
of
compiling
information
on
emissions
of
a
variety
of
pollutants
that
have
different
emissions­
air
quality
relationships
to
obtain
a
single
indicator
of
the
overall
level
of
emissions
in
a
county.
However,
EPA
recognizes
that
other
factors
also
influence
the
impact
that
each
county's
emissions
have.
This
is
why
the
other
8
factors
(
most
notably
wind
data
and
information
on
geographic
proximity)
were
utilized
by
EPA
to
judge
better
the
potential
contribution
of
a
county's
emissions
to
its
respective
metropolitan
area.

Comment:
1031­
4
Region:
5
State:
OH
Area:
Parkersburg­
Marietta,
WV­
OH
Comment:
Washington
County
is
part
if
the
Parkersburg/
Marietta
MSA.
The
area
has
one
monitor,
located
in
Wood
County,
West
Virginia.
Annual
average
concentrations
for
this
monitor
have
been
significantly
decreasing.
Annual
average
concentrations
for
the
period
2001
to
present
are
2001,
17.4
µ
g/
m3,
2002,
15.8
µ
g/
m3,
2003,
14.9
µ
g/
m3,
and
2004
(
so
far)
12.7
µ
g/
m3.
The
most
recent
three
year
average,
including
the
2004
partial
year,
is
14.47
µ
g.
m3.
The
improvement
at
this
monitor
is
obviously
attributed
to
reductions
associated
with
compliance
with
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990.
This
area
will
clearly
attain
the
annual
PM2.5
standard
by
the
proposed
effective
date
for
PM
2.5
designations
in
early
2005.

Ohio
EPA
also
notes
that
a
"
recently
approved
SIP
revision
to
the
AMP
Ohio
Gorsuch
facility
greatly
reduces
the
potential
emissions
of
PM2.5
precursors".

EPA
Response:
EPA
has
decided
to
provide
a
45­
day
opportunity
for
states
to
provide
complete
2004
data.
This
will
allow
EPA
to
adjust
its
final
designations
according
to
whether
areas
are
violating
the
air
quality
standards
based
on
2002
to
2004
data.

Despite
the
reduction
in
the
'
potential'
emissions
from
the
AMP
Gorsuch
Plant,
EPA
has
seen
no
evidence
that
the
actual
emissions
from
the
Gorsuch
Plant
have
decreased,
and
so
EPA
has
no
evidence
that
the
actual
contribution
from
this
plant
has
decreased.
5­
56
Comment:
1013a­
41
Region:
5
State:
OH
Area:
Toledo,
OH
Comment:
EPA
failed
to
recommend
that
the
Toledo
CMSA
counties
of
Fulton,
Ottawa
and
Sandusky
be
designated
nonattainment;
these
areas
must
be
included
in
the
nonattainment
area.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
the
presumptive
boundary
for
considering
PM­
2.5
nonattainment
areas.
The
boundaries
of
CMSAs
and
MSAs,
which
were
delineated
by
OMB
in
1999,
include
populated
areas
associated
with
core
urban
areas.
EPA's
April
2003
guidance
recognized
that
OMB
planned
to
publish
revised
urban
area
definitions
sometime
in
2003,
but,
because
the
release
date
(
which
turned
out
to
be
June
6,
2003)
was
not
known
at
that
time,
EPA
decided
that
it
needed
to
use
the
1999
definitions
for
the
PM­
2.5
designation
process.
However,
EPA
encouraged
states
to
consider
counties
in
the
CBSAs
or
CSAs
under
the
2003
definitions.
EPA
considered
nine
factors
including
the
emissions,
population,
vehicle
miles
traveled
(
VMT)
and
wind
frequency
from
Fulton
and
Ottawa
Counties
(
which
are
part
of
the
1999
Dayton
CMSA/
MSA),
and
Sandusky
County
(
which
is
part
of
the
2003
CSA/
CBSA)
before
deciding
to
designate
them
as
attainment/
unclassified.
Among
the
reasons
we
designated
these
counties
attainment
are:

a.
Fulton
County
­
The
population
of
Fulton
County
is
low
when
compared
to
Lucas
and
Wood
Counties
(
42,573
vs.
575,893).

­
The
emissions
for
Fulton
County
are
small
when
compared
to
Lucas
and
Wood
Counties
(
for
SO2:
878
tpy
vs.
32,410
tpy)
(
for
NOx:
5,105
tpy
vs.
45,797
tpy)

(
for
direct
carbon:
336
tpy
vs.
1,836
tpy)
(
for
crustal:
692
tpy
vs.
3,115
tpy)

­
We
do
not
feel
that
Fulton
County
is
contributing
to
PM2.5
violations
in
the
Toledo
Area
b.
Ottawa
County
­
The
population
of
Ottawa
County
is
low
when
compared
to
Lucas
and
Wood
Counties
(
41,049
vs.
847,850)

­
The
emissions
from
Ottawa
County
are
small
when
compared
to
emissions
from
Lucas
and
Wood
Counties
(
for
SO2:
1,544
tpy
vs.
32,410
tpy)
(
for
NOx:
5,031
tpy
vs.
45,797
tpy)
(
for
direct
carbon:
403
tpy
vs.
1,836tpy)
(
for
crustal:
687
tpy
vs.
3,115
tpy)

­
We
do
not
feel
that
Ottawa
County
is
contributing
to
PM2.5
violations
in
the
Toledo
5­
57
c.
Sandusky
County
The
population
of
Sandusky
County
is
low
when
compared
to
Lucas
and
Wood
Counties
(
61,698
vs.
847,850)

­
The
emissions
from
Sandusky
County
are
small
when
compared
to
emissions
from
Lucas
and
Wood
Counties
(
for
SO2:
2,937
tpy
vs.
32,410
tpy)
(
for
NOx:
8,288
tpy
vs.
45,797
tpy)
(
for
direct
carbon:
300
tpy
vs.
1,836
tpy)
(
for
crustal:
1,170
tpy
vs.
3,115
tpy)

­
We
do
not
feel
that
Sandusky
County
is
contributing
to
PM2.5
violations
in
the
Toledo
area.

Comment:
1031­
7
Region:
5
State:
OH
Area:
Toledo,
OH
Comment:
The
Toledo
MSA
contains
three
monitoring
locations.
Based
on
the
complete
three
year
period
2001­
2003,
there
was
one
monitor
not
attaining
the
PM
2.5
annual
standard.
The
peak
three­
year
annual
average
concentration
for
the
period
1999­
2001
was
16.97
µ
g/
m3.
The
three­
year
annual
average
concentration
for
the
period
2001­
2003
at
that
monitor
was
15.07
µ
g/
m3.
Based
on
the
most
recent
10
quarters,
(
January
2002­
June
2004),
the
highest
annual
average
concentration
is
14.03
µ
g/
m3.
The
improvement
in
this
area
is
obviously
attributable
to
the
reductions
associated
with
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990.
This
area
will
clearly
attain
the
annual
PM2.5
standard
by
the
proposed
effective
date
for
PM
2.5
designations
in
early
2005.

EPA
Response:
EPA
has
decided
to
provide
a
45­
day
opportunity
for
states
to
provide
complete
2004
data.
This
will
allow
EPA
to
adjust
its
final
designations
according
to
whether
areas
are
violating
the
air
quality
standards
based
on
2002
to
2004
data.

Comment:
1031­
8
Region:
5
State:
OH
Area:
Youngstown­
Warren­
Sharon,
OH­
PA
Comment:
The
Youngstown
MSA
currently
contains
four
monitors.
During
the
period
2001­
2003,
there
were
two
monitors
with
three
years
worth
of
data.
The
peak
three­
year
annual
average
concentration
for
the
period
1999­
2001
was
16.43
µ
g/
m3.
The
highest
three
year
annual
average
concentration
for
the
period
2001­
2003
was
15.20
µ
g/
m3.
Based
on
the
most
recent
10
quarters,
(
January
2002­
June
2004),
the
highest
annual
average
concentration
is
14.10
µ
g/
m3.
The
improvement
in
this
area
is
obviously
attributable
to
the
reductions
associated
with
Title
IV
of
the
Clean
Air
Act
Amendments
of
1990.
This
area
will
clearly
attain
the
annual
PM2.5
standard
by
the
proposed
effective
date
for
PM
2.5
designations
in
early
2005.
5­
58
EPA
Response:
EPA
has
decided
to
provide
a
45­
day
opportunity
for
states
to
provide
complete
2004
data.
This
will
allow
EPA
to
adjust
its
final
designations
according
to
whether
areas
are
violating
the
air
quality
standards
based
on
2002
to
2004
data.

Comment:
1031­
9
Region:
5
State:
OH
Area:
Youngstown­
Warren­
Sharon,
OH­
PA
Comment:
Columbiana
County
is
part
of
the
Youngstown/
Warren
MSA.
The
MSA
also
includes
Mahoning
and
Trumbull
Counties.
Columbiana
County
should
be
excluded
from
this
MSA
nonattainment
even
if
the
remainder
of
the
MSA
is
retained.
Columbiana
County
should
be
excluded
due
to:

­
Proximity
to
the
source
region/
nonattainment
area:
Columbiana
County
is
located
south
of
the
Youngstown
urban/
industrial
area.
The
area
would
not
expect
to
be
impacted
by,
nor
should
it
be
considered
a
receptor
for,
the
Youngstown
area.

­
Population:
The
population
of
Columbiana
County
is
112,075
which
is
only
19%
of
the
total
MSA
(
594,746).

Emissions:
Columbiana
County
emissions
of
SO2,
VOX,
and
NOx
are
1291,
6157
and
5511
tons
per
year,
respectively.
MSA
total
emissions
of
VOC
and
NOx
are
40,968
and
39,376
tons
per
year,
respectively.
Columbiana
County
is
near
the
Steubenville
and
Canton
MSAs
but
is
northeast
(
downwind)
of
a
primarily
rural/
agricultural
area.

­
Land
use:
Columbiana
County
is
over
96%
wooded
or
agricultural.

EPA
Response:
EPA
believes
that
19%
is
a
large
fraction
of
an
area's
representative
population.
When
looking
at
the
entire
nation,
Columbiana
County's
demographics
and
emissions
are
small
numbers,
but
they
represent
a
significant
proportion
(
about
16%
of
the
overall
emissions)
of
a
fairly
small
metropolitan
area
that
nevertheless
violates
the
PM2.5
standard.
EPA
believes
that
Columbiana
County
is
contributing
to
PM2.5
violations
in
Youngstown­
Warren,
and
should
be
part
of
the
nonattainment
area.

Also,
while
Mahoning
and
Trumbull
counties
have
seen
population
losses
in
the
past
10
years
(­
7,251
and
­
2,697
persons,
respectively),
Columbiana
County
has
seen
an
increase
(
3,799),
the
only
population
increase
in
the
3­
County
MSA.

Comment:
1006­
1
Region:
5
State:
WI
Area:
Chicago­
Gary­
Lake
County
,
IL­
IN
Comment:
Commenters
express
concern
regarding
the
presumptive
inclusion
of
Kenosha
County
in
the
Chicago­
Gary
nonattainment
area.
They
are
concerned
about
a
5­
59
presumptive
designation
that
does
not
cite
unacceptable
levels
of
PM2.5
in
the
county
and
one
that
does
not
distinguish
state
regulations
and
local
efforts.
They
ask
EPA
to
carefully
consider
specific
conditions
in
Kenosha
County
before
they
lump
it
in
with
the
other
counties
in
the
Chicago­
Gary
MSA.

EPA
Response:
The
EPA
uses
the
CMSA/
MSA
as
a
presumptive
boundary
of
nonattainment
areas
for
PM2.5
EPA
guidance
also
provides
for
use
of
9
factors
to
evaluate
alternative
nonattainment
area
boundaries
to
include
the
area
that
is
violating
the
standards
and
the
nearby
areas
that
are
contributing
to
these
violations.

For
the
PM2.5
NAAQS,
the
EPA
invited
States
to
consult
and
make
recommendations
on
air
quality
and
appropriate
boundaries
to
EPA.
At
the
time
this
comment
was
received,
the
EPA
had
received
no
formal
recommendations
from
the
State
of
Wisconsin
regarding
PM2.5
nonattainment
areas
or
boundaries.
On
August
9,
2004,
EPA
received
a
letter
from
Wisconsin
Governor,
Jim
Doyle,
that
recommended
Kenosha
County
as
attainment.
Many
of
the
points
raised
in
the
commenter's
letter
are
also
raised
in
the
Governor's
letter.

EPA
has
reviewed
the
justification
found
in
Governor
Doyle's
letter
and
evaluated
other
available
information
regarding
the
pertinent
9
factors.
Based
on
this
review,
EPA
has
determined
that
Kenosha
County
should
be
designated
as
attainment
for
the
PM2.5
standard.
The
technical
support
document
provides
a
more
complete
discussion
of
EPA's
rationale
for
this
decision.

Comment:
1034­
1
Region:
5
State:
WI
Area:
Chicago­
Gary­
Lake
County,
IL­
IN
Comment:
Commenters
strongly
urge
EPA
to
reconsider
designating
Kenosha
County
as
attainment
and
including
it
as
part
of
the
Chicago­
Gary­
Kenosha
area.
They
believe
Kenosha
County
should
be
excluded
on
the
basis
of
the
following
factors:

1.
Kenosha
County
has
a
reading
of
11.7
ppm,
which
is
well
below
the
NAAQS
standard
of
15
ppm.

2.
Kenosha
County's
level
of
emissions
represent
less
that
10%
of
the
total
emissions
in
the
MSA.

3.
Kenosha's
population
density
of
548.2
persons/
square
mile
is
less
than
half
of
neighboring
Lake
County,
IL
and
less
than
one­
tenth
of
Cook
County,
IL.

4.
Approximately
75%
of
Kenosha
County
commuters
travel
to
Lake
County,
IL,
which
also
meets
the
PM2.5
NAAQS.
5­
60
5.
The
predominant
direction
of
wind
from
Kenosha
County
is
away
from
the
violating
areas.

6.
Most
of
the
SO2
and
NOx
emissions
in
Kenosha
County
can
be
traced
to
power
plant
that
has
already
made
significant
pollution
equipment
upgrades.

EPA
Response:
While
EPA
originally
considered
Kenosha
County
as
a
candidate
for
nonattainment,
that
was
based
on
a
presumption
that
all
counties
in
a
CMSA
with
a
violating
monitor
should
be
nonattainment
unless
a
technical
justification
from
the
State
gave
a
compelling
reason,
or
reasons,
to
consider
a
county
attainment.
At
the
time,
there
was
no
recommendation
from
Wisconsin
regarding
Kenosha
County
or
any
other
counties
in
Wisconsin.

On
August
9,
2004,
Wisconsin
Governor,
Jim
Doyle,
submitted
a
letter
to
EPA
that
recommended
Kenosha
County
as
attainment
for
the
PM2.5
standard.
Given
the
technical
justification
in
that
letter
(
many
of
the
same
points
were
raised
by
Congressmen
Feingold,
Kohl
and
Ryan
in
their
letter)
EPA
has
determined
that
Kenosha
County
should
be
attainment.
Please
see
the
technical
support
document
for
more
details
regarding
this
decision.

Comment:
1035­
1
Region:
5
State:
WI
Area:
Chicago­
Gary­
Lake
County,
IL­
IN
Comment:
The
commenter
writes
on
behalf
of
the
City
of
Kenosha
to
request
that
EPA
designate
Kenosha
County
as
an
attainment
area
for
the
PM2.5
National
Ambient
Air
Quality
Standard.
The
available
data
does
not
support
the
inclusion
of
Kenosha
County
in
the
Chicago
CSMA
PM2.5
nonattainment
area.

The
City
is
very
concerned
about
the
potential
economic
impacts
and
impediments
to
job
growth
that
could
occur
in
our
community
as
a
result
of
a
nonattainment
designation.
Based
on
the
available
data,
it
does
not
appear
that
designating
Kenosha
County
as
nonattainment
(
when
our
county
has
some
of
the
lowest
concentrations
of
particulates
in
the
area)
will
in
any
way
help
EPA
achieve
its
goal
or
improve
air
quality
in
the
counties
experiencing
exceedances
of
the
PM2.5
particulate
standard.

FACTOR
1.
EMISSIONS
IN
AREAS
POTENTIALLY
INCLUDED
VERSUS
EXCLUDED
FROM
THE
NONATTAINMENT
AREA.
According
to
EPA's
data,
Kenosha
County
has
a
composite
emissions
score
of
5.4,
meaning
that
almost
ninety­
five
percent
of
emissions
contributing
to
PM2.5
originates
from
outside
of
the
County.
See
Illinois
Response
at
4­
5.
Moreover,
as
explained
in
detail
in
Factor
9
below,
prior
to
the
time
state
implementation
plans
are
due,
emissions
from
Kenosha
County
will
have
been
reduced
through
federally
enforceable
controls
to
a
level
that
would
represent
an
approximate
composite
emission
score
of
2.7.
See
Exhibit
A.
Thus,
more
than
ninety­
five
5­
61
percent
of
the
emissions
contributing
to
PM2.5
will
originate
from
outside
of
Kenosha
County.

Significantly,
EPA
has
proposed
to
designate
as
attainment
the
counties
of
DeKalb
and
Kankakee
as
well
as
the
majority
of
Grundy
and
Kendall
counties
in
Illinois
concluding
that
the
bulk
of
emissions
in
the
Chicago
CMSA
area
would
be
captured
without
including
those
counties.
See
id.
At
4.
For
comparison
purposes,
DeKalb,
Kankakee,
Grundy
and
Kendall
counties
have
a
total
composite
emission
score
of
5.2.
Id.
Clearly,
Kenosha
County,
with
a
current
composite
emission
score
of
5.4
and
an
ultimate
composite
emission
score
of
2.7
(
once
federally
enforceable
controls
are
fully
implemented),
is
similarly
situated
to
the
Illinois
counties
EPA
has
proposed
to
designate
as
attainment.

FACTOR
2.
AIR
QUALITY
IN
POTENTIALLY
INCLUDED
VERSUS
EXCLUDED
AREAS.
As
EPA's
data
indicates,
Kenosha
County
has
no
monitored
violations
for
PM2.5.
See
Illinois
Response
at
5.
The
design
value
for
this
monitoring
site
is
11.7
µ
g/
m3
which
is
well
below
the
15
µ
g/
m3
standard.
Id.,
see
also
EPA's
air
emissions
monitoring
data
available
on
the
World
Wide
Web
at
http://
www.
epa.
gov/
air/
data/.
In
fact,
according
to
EPA's
data,
the
Kenosha
County
design
value
is
the
lowest
value
for
any
of
the
counties
in,
or
adjacent
as
attainment.
See
id.
At
5­
6.
Furthermore,
monitors
in
the
adjoining
Chicago
CMSA
counties
of
Lake
and
McHenry,
both
of
which
fall
in
between
the
Kenosha
County
monitor
and
the
violating
monitor
in
urban
Chicago,
also
have
no
monitored
violations
for
PM2.5.
See
id.

FACTOR
3.
POPULATION
DENSITY
AND
DEGREE
OF
URBANIZATION
INCLUDING
COMMERCIAL
DEVELOPMENT
INCLUDED
VERSUS
EXCLUDED
AREAS.
According
to
EPA's
data,
Kenosha
County
only
represents
approximately
1.7
percent
of
the
total
population
in
the
Chicago
CMSA
area.
See
Illinois
Response
at
6.
Consistent
with
its
analysis
under
Factor
1,
the
EPA
has
proposed
to
designate
as
attainment
the
counties
of
DeKalb
and
Kankakee
as
well
as
the
majority
of
Grundy
and
Kendall
counties
in
Illinois
concluding
that
the
bulk
of
the
population
would
be
captured
without
including
those
counties.
Id.
at
4.
For
comparison
purposes,
DeKalb,
Kankakee,
Grundy
and
Kendall
counties
account
for
approximately
3.2
percent
of
the
population
in
the
Chicago
CMSA
area
compared
to
the
1.7
percent
of
the
population
in
Kenosha
County.

Moreover,
Kenosha
County
has
a
lower
urban
density
than
the
areas
with
monitors
that
violate
the
PM2.5
standard.
Id.
at
6.
Furthermore,
the
further
away
from
the
area
of
urban
density,
the
lower
the
PM2.5
measurements
are.
This
would
tend
to
indicate
that
the
problem
originates
in
the
urban
area
instead
of
coming
from
the
less
dense
area
into
the
urban
area.

FACTOR
4.
TRAFFIC
AND
COMMUTING
PATTERNS.
According
to
EPA's
data,
Kenosha
County
represents
only
1.8
percent
of
the
total
Chicago
CMSA
daily
vehiclemiles
traveled
while
DeKalb
and
Kankakee
counties
represent
2.3
percent
and
Grundy
and
Kendall
counties
represent
1.2
percent.
See
Illinois
Response
at
6.
Moreover,
EPA's
5­
62
data
shows
that
only
about
28
percent
of
the
Kenosha
County
resident
labor
force
commutes
to
another
county
in
the
Chicago
CMSA
compared
to
31
percent
for
DeKalb,
19
percent
for
Kankakee,
46
percent
for
Grundy
and
67
percent
for
Kendall.

In
addition,
only
20,500
residents
of
Kenosha
county
commute
to
other
counties
in
the
Chicago
CMSA
compared
to
23,000
commuters
from
DeKalb
and
Kankakee
Counties
and
27,500
commuters
from
Grundy
and
Kendall
Counties.
Furthermore,
according
to
the
Year
2000
U.
S.
Census,
approximately
seventy­
five
percent
of
the
Kenosha
County
commuters
traveling
to
other
counties
in
the
Chicago
CMSA
travel
to
adjacent
Lake
County,
IL
which
currently
meets
the
standard.
This
supports
the
argument
that
commuters
from
Kenosha
County
are
not
significantly
contributing
to
PM2.5
exceedances
and
that
Kenosha
County
should
not
be
included
in
the
nonattainment
area.

FACTOR
5.
EXPECTED
GROWTH
(
INCLUDING
EXTENT,
PATTERN
AND
RATE
OF
GROWTH).
According
to
EPA's
data,
the
growth
in
population
in
Kenosha
County
from
1990
to
2000
was
about
17
percent
compared
to
14
percent
in
DeKalb,
8
percent
in
Kankakee,
16
percent
in
Grundy
and
38
percent
in
Kendall.
See
Illinois
Response
at
7.
Clearly
the
similarity
in
growth
patterns
between
Kenosha
County
and
the
excluded
counties
of
DeKalb,
Kankakee,
Grundy
and
Kendall
support
excluding
Kenosha
County
from
the
nonattainment
designation.

FACTOR
6.
METEOROLOGY
(
WEATHER/
TRANSPORT
PATTERNS).
According
to
EPA's
data,
the
predominant
wind
direction
from
Kenosha
County
is
away
from
the
violating
counties
in
the
Chicago
CMSA
while
the
wind
direction
from
DeKalb,
Kankakee,
Grundy
and
Kendall
counties
is
more
predominately
toward
the
violating
counties.
See
Illinois
response
at
7.

FACTOR
7.
GEOGRAPHY/
TOPOGRAPHY
(
MOUNTAIN
RANGES
OR
OTHER
AIR
BASIN
BOUNDARIES).
It
does
not
appear
the
geography/
topography
is
a
significant
factor
in
considering
whether
Kenosha
County
should
be
included
in
the
Chicago
CMSA
nonattainment
area.

FACTOR
8.
JURISDICTIONAL
BOUNDARIES
(
e.
g.,
COUNTIES,
AIR
DISTRICTS,
RESERVATIONS,
ETC.).
Jurisdictional
boundaries
do
not
support
including
Kenosha
County
in
the
Chicago
CMSA
nonattainment
area.
For
example,
EPA
recommends
that
states
consider
common
boundaries
for
areas
classified
as
nonattainment
for
both
PM2.56
and
ozone.
See
e.
g.,
Boundary
Guidance
at
5
("
EPA
seeks
to
maximize
consistency
between
designations
for
PM2.5
and
designations
for
the
8­
hour
ozone
standard.").
As
EPA
is
aware,
Kenosha
County
is
considered
to
be
part
of
the
Milwaukee
CMSA
for
the
purpose
of
defining
1­
hour
and
8­
hour
ozone
nonattainment
areas.
Accordingly,
to
maximize
consistency
between
the
PM2.5
and
ozone
designations,
Kenosha
County
should
be
treated
as
part
of
the
Milwaukee
CMSA
for
PM2.5
air
quality
planning
purposes.
As
a
result,
since
there
are
no
PM2.5
exceedances
in
the
Milwaukee
CMSA,
Kenosha
County
should
be
designated
attainment
for
the
PM2.5
standard.
5­
63
Furthermore,
treating
Kenosha
County
as
part
of
Chicago
CMSA
lessens
Wisconsin's
control
over
its
air
quality
programs,
and
may
penalize
the
County
for
actions
in
other
states
that
are
entirely
out
of
Wisconsin's
control.
For
example,
although
Wisconsin
has
no
control
over
a
conformity
failure
to
Indiana,
it
would
suffer
the
consequences
(
e.
g.,
loss
of
federal
funding
and
projects
stop)
for
such
a
failure.

FACTOR
9.
LEVEL
OF
CONTROL
OF
EMISSION
SOURCES.
Perhaps
most
importantly,
EPA
should
note
that
in
2001,
more
than
85
percent
of
sulfur
dioxide
(
SO2)
and
nitrogen
oxide
(
NOX)
emissions
in
Kenosha
County
came
from
the
Pleasant
Prairie
Power
Plant
operated
by
We
Energies.
That
company
has
already
installed
Selective
Catalytic
Reduction
(
SCR)
on
one
unit.
In
addition,
Wisconsin
DNR
issued
permit
number
03­
RSG­
296
on
April
5,
2004
to
We
Energies
to
allow
installation
of
SCR
on
the
remaining
unit
as
well
as
scrubbers
to
control
sulfur
dioxide
emissions
on
both
units
(
a
copy
of
the
We
Energies
permit
is
attached
as
Exhibit
B).
These
controls
are
expected
to
be
fully
operational
prior
to
December
2007
when
state
implementation
plans
for
PM2.5
attainment
are
expected
to
be
due.

Furthermore,
these
controls
and
the
level
of
emissions
from
the
We
Energies
facility
will
be
federally
enforceable.
Notably,
once
these
controls
are
fully
implemented,
emissions
from
Kenosha
County
will
represent
less
than
2.7
percent
of
the
total
Chicago
CMSA
emissions.
See
Composite
Emission
Score
for
Kenosha
County
shown
in
Exhibit
A.
The
composite
emission
score
for
Kenosha
County
was
calculated
by
factoring
in
the
emission
reductions
that
will
be
achieved
at
the
We
Energies
facility.
More
specifically
the
composite
emission
score
was
calculated
as
follows:
first,
the
projected
maximum
allowable
emissions
(
assuming
the
plant
operates
8760
hours
per
year
at
full
capacity)
from
the
facility
after
the
controls
are
fully
implemented
using
the
limits
specified
in
the
permit
were
calculated;
second,
the
maximum
allowable
emissions
were
subtracted
from
the
2001
actual
emission
totals
from
the
facility
to
provide
a
total
emission
reduction
number;
third
the
total
emission
reductions
that
will
be
realized
were
then
subtracted
from
the
county­
wide
emission
totals
for
Kenosha
County
as
shown
in
Factor
1
of
the
Illinois
Response;
finally
the
composite
emission
was
calculated
using
the
"
urban
increment"
weighted
averages
as
shown
in
the
Illinois
Response.
As
a
result,
these
federally
enforceable
emission
controls
should
allow
EPA
to
exclude
Kenosha
County
from
the
Chicago
CMSA
PM2.5
nonattainment
area.

EPA
Response:
While
EPA
originally
considered
Kenosha
County
as
a
candidate
for
nonattainment,
that
was
based
on
a
presumption
that
all
counties
in
a
CMSA
with
a
violating
monitor
should
be
nonattainment
unless
a
technical
justification
from
the
State
gave
a
compelling
reason,
or
reasons,
to
consider
a
county
attainment.
At
the
time,
there
was
no
recommendation
from
Wisconsin
regarding
Kenosha
County
or
any
other
counties
in
Wisconsin.

On
August
9,
2004,
Wisconsin
Governor,
Jim
Doyle,
submitted
a
letter
to
EPA
that
recommended
Kenosha
County
as
attainment
for
the
PM2.5
standard.
Given
the
technical
justification
in
that
letter
(
many
of
the
same
points
were
raised
in
the
letter
submitted
by
5­
64
the
City
of
Kenosha)
EPA
has
determined
that
Kenosha
County
should
be
attainment.
Please
see
the
technical
support
document
for
more
details
regarding
this
decision.
5­
65
Comments
Received
Late
Response
to
comment
letter
dated
November
30,
2004,
from
Steven
Chester
to
Bharat
Mathur:

A
letter
dated
November
30,
2004,
from
Steven
Chester
to
Bharat
Mathur,
comments
on
the
PM2.5
designation
for
the
Detroit
area.
The
core
of
these
comments
are
expressed
as
8
numbered
paragraphs.
The
following
responses
refer
to
the
numbers
of
the
items
as
given
in
that
letter.

Items
1,
2,
3,
6,
and
7
are
points
that
were
made
in
the
letter
from
the
Michigan
Department
of
Environmental
Quality
dated
September
1,
2004,
and
were
addressed
in
the
response
to
that
set
of
comments.

Regarding
items
4
and
5,
as
stated
in
the
response
to
the
letter
from
the
Michigan
Department
of
Environmental
Quality
dated
September
1,
2004,
EPA
cannot
base
an
area's
air
quality
designation
on
projected
air
quality
or
on
proposed
legislation.
Further,
EPA
agrees
that
it
is
important
to
have
programs
that
address
emissions
on
a
national
and
regional
scale.
Although
these
programs
would
have
a
positive
impact
on
many
areas
in
Michigan
and
across
the
country,
EPA
must
also
define
a
nonattainment
area
that
includes
the
more
local
sources
that
need
consideration
in
air
quality
planning.

In
response
to
item
8,
although
preliminary
2004
monitoring
data
indicate
Monroe
County
may
be
in
attainment
of
the
PM2.5
standard,
Monroe
County
contributes
to
violations
of
the
standard
in
Wayne
County.
Thus,
Monroe
County
should
be
designated
as
part
of
the
Detroit
nonattainment
area
regardless
of
Monroe
County
air
quality.

Comment
and
Response
11/
30/
04
email
from
Dona
J.
Bergman,
Director
Evansville
Environmental
Protection
Agency
Comment:
As
of
the
end
of
the
2004
third
quarter,
Vanderburgh
County
is
nonattainment
of
the
PM2.5
annual
national
ambient
air
quality
standard
based
upon
data
through
the
first
three
quarters
of
2004.
In
addition,
the
PM2.5
levels
in
SW
Indiana
for
the
fourth
quarter
have
been
lower
than
each
year's
third
quarter
numbers.

Response:
Three
full
calendar
years
of
PM
air
quality
data
are
required
to
establish
an
area's
designation
status.
The
Vanderburgh
County
data
for
2004
cannot
be
used
until
the
data
for
the
entire
year
has
been
quality
assured
and
the
2001­
2003
PM
air
quality
data
has
a
15.2
micrograms/
cubicmeter,
which
indicated
nonattainment
of
the
PM
standard.
However,
EPA
is
allowing
sufficient
time
for
the
2004
fourth
quarter
data
to
be
included,
provided
that
this
quality
assured
is
submitted
to
EPA
by
45
days
after
the
PM
designation
notice
is
published.

EPA
views
Southwest
Indiana,
including
Evansville
as
well
as
DuBois
County,
as
a
single
area
in
which
sources
throughout
the
area
contribute
to
violations
currently
being
5­
66
observed
in
both
Vanderburgh
and
DuBois
Counties.
EPA
intends
to
retain
a
nonattainment
designation
for
the
entire
area
until
such
time
as
all
monitors
in
the
area,
including
the
monitor
in
DuBois
County
as
well
as
the
monitors
in
Vanderburgh
County,
are
showing
attainment.

Comment:
USEPA
has
stated
the
predominant
wind
direction
for
SW
Indiana
is
from
the
S­
SW.
Therefore,
we
can
conclude
Vanderburgh
County
with
PM2.5
levels
meeting
the
NAAQS,
would
not
be
adversely
impacting
Dubois
County
monitors.

Response:
The
predominant
wind
direction
to
Dubois
County
is
SW
and
Vanderburgh
County
is
SW
of
Dubois
County.

Comment:
In
that
much
of
the
area
between
Vanderburgh
and
Dubois
is
rural,
with
few
if
any
point
sources,
we
believe
it
would
be
unfounded
and
unfair
to
designate
Vanderburgh
County,
as
well
as
Gibson,
Pike,
Spencer,
and
Warrick
as
nonattainment
simply
on
the
basis
of
the
Dubois
County
monitor.

Response:
In
fact,
Gibson,
Pike,
Spencer,
and
Warrick
have
significant
(
mostly
power
plant)
emissions.

Response
to
late
comments
from
Indiana
Department
of
Environmental
Management:

EPA
uses
three
full
years
of
data
to
determine
the
design
value
for
an
area.
EPA
did
examine
the
2004
PM
2.5
data
provided
by
Indiana.
This
data
indicates
the
air
quality
in
Southwestern
Indiana
is
improving
since
the
monitored
PM
2.5
values
continue
to
trend
down.
We
understand
your
desire
to
avoid
designating
the
area
as
nonattainment
in
December
2004
and
then
begin
the
redesignation
process
several
months
later
if
the
complete
2004
PM
2.5
data
indicates
the
area
attains
the
annual
NAAQS.
This
is
why
EPA
is
allowing
states
to
submit
their
2004
data
before
the
designations
effective
date.
EPA
can
revise
its
nonattainment
designation
for
the
area
counties
if
the
2004
data
shows
that
the
entire
Evansville
area
is
attaining
the
fine
particulate
NAAQS.
This
data
policy
will
also
be
applied
in
other
areas.

We
agree
that
power
plant
emissions
are
a
substantial
contributor
to
regional
values.
This
includes
contributions
to
the
violations
in
Dubois
and
Vanderburgh
Counties.
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.
That
is
why
EPA
is
designating
Dubois,
Vanderburgh,
and
Warrick
Counties
and
portions
of
Gibson,
Pike,
and
Spencer
Counties
as
the
Evansville
nonattainment
area.
5­
67
Response
to
late
comments
from
the
mayor
of
Evansville:

EPA
is
required
to
use
three
full
years
of
data
to
determine
the
design
value
for
an
area.
Thus,
the
2002­
2004
design
value
for
Vanderburgh
County
cannot
be
determined
until
all
the
2004
data
is
received.
EPA
did
examine
the
PM
2.5
data
for
the
first
three
quarters
of
2004
provided
by
the
Indiana
Department
of
Environmental
Management.
This
data
indicates
the
air
quality
in
Southwestern
Indiana
is
improving
since
the
monitored
PM
2.5
values
continue
to
trend
down.
We
understand
the
desire
to
avoid
designating
Vanderburgh
County
as
nonattainment
in
December
2004
and
then
begin
the
redesignation
process
just
months
later
if
the
complete
2002­
2004
PM
2.5
data
indicates
the
area
attains
the
annual
NAAQS.
This
is
why
EPA
is
allowing
states
to
submit
their
2004
data
before
the
designations
effective
date.
EPA
can
revise
its
nonattainment
designation
for
Vanderburgh
County
and
the
rest
of
the
area
if
the
2004
data
shows
that
the
entire
Evansville
area
is
attaining
the
fine
particulate
NAAQS.

Many
people
believe
that
designation
of
an
area
as
a
nonattainment
area
significantly
limits
economic
growth.
EPA
does
not
share
this
belief.
First,
the
requirements
for
new
sources
in
nonattainment
areas
are
fairly
similar
to
those
in
attainment
areas:
in
both
areas,
new
sources
must
be
well
controlled
and
must
address
their
impact
on
the
area's
air
quality.
Second,
while
companies
sometimes
blame
environmental
restrictions
for
plant
location
decisions,
in
fact
these
decisions
reflect
a
variety
of
factors
such
as
access
to
markets,
access
to
skilled
labor,
access
to
raw
materials,
and
various
cost
factors
that
will
commonly
have
more
influence
on
the
company's
bottom
line.
Third,
EPA
believes
that
history
has
shown
that
nonattainment
designations
have
not
significantly
affected
economic
growth.
Nationally,
from
1970
to
2003,
the
Gross
Domestic
Product
of
the
nation
has
risen
176
percent,
even
while
total
emissions
of
the
six
criteria
pollutants
have
decreased
by
51
percent.
Also,
many
areas
that
have
been
designated
nonattainment
have
been
growing
just
as
much
or
more
than
attainment
areas.
Therefore,
even
beyond
the
fact
that
impacts
on
growth
are
not
a
criterion
for
designations
under
the
Clean
Air
Act,
EPA
does
not
agree
that
nonattainment
designations
limit
economic
growth.

There
is
no
consent
decree
requiring
EPA
to
make
its
designations
prior
to
December
15,
2004.
EPA
met
the
congressional
deadline
of
December
31,
2004
for
making
PM
2.5
designations.
As
stated
above,
EPA
is
nevertheless
providing
the
opportunity
for
states
to
submit
air
quality
data
showing
that
2002
to
2004
data
support
a
different
designation
than
2001
to
2003
data.
As
for
the
Dubois
County
monitor,
we
have
no
information
on
the
monitor
being
incorrectly
sited.
Therefore
EPA
considers
the
monitor
site
as
appropriate
and
the
data
collected
as
valid.
