HQ­
1
HQ.
Responses
to
Comments
EPA
Headquarters
HQ­
2
Comment:
1013­
1
Region:
HQ
State:
Area:

Comment:
This
letter
transmits
spreadsheets
used
in
a
previous
analysis
submitted
on
the
same
day
(
9­
1­
04).

EPA
Response:
Dear
Ms.
Copeland
and
Ms.
Patton:

Thank
you
for
your
letter
of
June
16,
2004,
concerning
the
designation
of
nonattainment
areas
for
the
fine
particulate
matter
(
PM2.5)
air
quality
standards.
In
your
letter
you
expressed
concerns
over
the
designation
recommendations
submitted
by
States
to
address
PM2.5.
In
particular
you
expressed
concerns
that
some
States
may
have
submitted
recommendations
which
only
identified
counties
with
monitored
violations,
and
did
not
identify
counties
that
contributed
significant
emissions
to
the
affected
area.
You
also
expressed
concerns
that
some
State
recommendations
failed
to
recommend
all
counties
within
a
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
nonattainment,
and
you
indicated
concern
that
some
States
may
not
have
considered
the
updated
2003
Office
of
Management
and
Budget
(
OMB)
boundaries
in
making
their
nonattainment
recommendations.

As
you
indicated
in
your
letter,
State
recommendations
for
PM2.5
designations
were
received
in
February
2004.
We
subsequently
responded
to
these
recommendations
on
June
29,
2004.
EPA
is
required
to
notify
States
and
Tribes
of
any
intended
modifications
to
their
recommendations
at
least
120
days
prior
to
promulgating
the
designations.
The
120­
day
period
is
designed
for
consultation
between
EPA
and
the
States
and
Tribes.
We
have
asked
States
to
provide
additional
information
that
they
would
like
for
us
to
consider
in
the
designations
process
by
September
1,
2004.
EPA
intends
to
promulgate
final
designations
in
November
2004.
At
that
time,
EPA
will
address
all
state
and
tribal
lands
during
the
designations
process.

On
April
1,
2003
and
February
13,
2004,
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
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.
As
discussed
in
the
above
referenced
guidance,
this
determination
is
based
on
the
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
and
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.
HQ­
3
To
help
assess
the
emissions
of
multiple
air
pollutants
contributing
to
the
formation
of
PM2.5,
we
developed
a
weighted
emissions
score
for
each
county
under
consideration.
The
methodology
for
calculating
these
county
scores
was
distributed
to
our
State
and
local
air
quality
agency
contacts
and
discussed
with
them
on
STAPPA/
ALAPCO
conference
calls.
In
responding
to
State
nonattainment
recommendations
we
examined
all
available
information
and
identified
a
number
of
counties
adjacent
to
violating
urban
areas
that
had
relatively
high
emissions.
We
have
included
these
counties
in
the
list
of
our
prospective
nonattainment
areas.
In
some
cases
the
boundary
recommendations
submitted
by
a
State
have
been
modified
to
reflect
the
addition
of
various
counties
adjacent
to
the
CMSA/
MSA
which
we
believe
contribute
significant
emissions
to
the
nonattainment
area.

Comment:
1013a­
1
Region:
HQ
State:
Area:

Comment:
Commenters
representing
public
health
and
environmental
organizations
urge
EPA
to
reconsider
and
significantly
strengthen
its
recommended
air
quality
designations
for
PM2.5.
They
believe
an
alarming
number
of
the
recommendations
contravene
the
law,
EPA's
long­
standing
policy,
good
science,
and
basic
common
sense.

The
nonattainment
designations
serve
two
essential
public
health
functions.
First,
they
establish
the
framework
for
air
quality
management
plans
across
the
country
to
address
harmful
particulate
pollution
levels.
Second,
the
nonattainment
designations
tell
the
public
whether
the
community
where
they
live
and
are
raising
their
families
has
air
that
is
unhealthful.
Such
information
can
and
does
build
public
support
for
the
measures
needed
to
clean
up
the
air.
If
EPA
further
advances
the
narrow
approach
it
has
recommended,
the
nation
would
suffer
severe
public
health
consequences.

EPA
has
recommended
that
244
counties,
including
11
partial
counties
and
several
cities
and
the
District
of
Columbia
be
designated
nonattainment
for
PM2.5.
Our
analysis
found
that
406
counties
should
be
included
in
the
nonattainment
areas
in
order
to
include
complete
C/
MSAs
and
to
properly
control
emissions.
We
are
especially
concerned
that
EPA's
recommendations
left
out
30
coal­
fired
power
plants
that
are
either
in
or
adjacent
to
nonattaining
C/
MSAs.
The
sulfur
dioxide
(
SO2),
totaling
451,453
tons
per
year,
and
nitrogen
oxides
(
NOx),
totaling
164,569
tons
per
year,
from
these
facilities
contribute
greatly
to
fine
particulate
air
pollution.
Clean
up
of
these
power
plants
must
be
an
integral
part
of
state
implementation
plans
to
restore
healthy
air.

Below
are
deficiencies
identified
by
the
commenters
that
they
believe
threaten
the
nation's
pressing
need
to
protect
public
health
and
lower
the
harmful
concentrations
of
PM2.5.

1.
Presumptive
nonattainment
boundaries
that
constitute
the
full
C/
MSAS
are
essential
to
protect
public
health
from
harmful
particulate
pollution
HQ­
4
EPA's
August
29,
2003
draft
staff
assessment
of
the
policy
implications
of
scientific
and
technical
information
about
particulate
matter
or
"
staff
paper,"
acknowledges
that
there
is
a
large
body
of
new
health
effects
studies
for
particulates
(
PM),
indicating
further
evidence
of
the
serious
adverse
health
effects
of
the
pollutant.
These
studies
are
based
on
epidemiologic,
toxicological,
controlled
human
exposure,
and
dosimetry
analyses.
Any
delay
in
attainment
of
the
PM2.5
national
ambient
air
quality
standard
will
prolong
these
sensitive
groups'
exposure
to
unhealthy
particulate
pollution
levels.

Unfortunately,
many
of
EPA's
recommended
nonattainment
designations
for
the
PM2.5
standard
do
not
encompass
all
counties
in
a
Metropolitan
Statistical
Area
or
Consolidated
Metropolitan
Statistical
Area
(
C/
MSA)
within
which
a
monitored
violation
of
the
standard
has
occurred.
These
recommendations
are
contrary
to
the
Clean
Air
Act,
lacking
in
any
reasoned
basis,
and
must
be
rejected
in
the
absence
of
a
compelling
technical
justification
for
the
smaller
boundary.

The
failure
of
EPA
to
promulgate
protective
nonattainment
designations
would
threaten
vital
public
health
protections.
Many
urban
centers
are
surrounded
by
rapidly
expanding
suburban
counties.
Timely
attainment
of
the
PM2.5
standard
will
depend
on
comprehensive
boundaries
that
ensure
that
all
pollution
sources,
both
existing
and
new,
are
subject
to
effective
air
pollution
abatement
measures.
In
the
absence
of
a
nonattainment
designation
for
the
entire
C/
MSA,
both
existing
air
pollution
sources
and
growth
in
counties
that
have
been
designated
attainment
or
unclassifiable
will
result
in
increased
air
pollution
just
outside
the
core
nonattainment
counties.
This
unchecked
air
pollution
could
dramatically
undercut
the
emission
reductions
progress
being
made
in
the
core­
designated
counties.
And
this
would
mean
that
critical
progress
in
lowering
particulate
pollution
levels
will
be
stymied.

Narrow
boundaries
will
also
unfairly
distribute
pollution
control
burdens
among
sources
that
contribute
to
the
nonattainment
problem.
The
private
firms
in
the
counties
designated
nonattainment
will
have
to
make
additional
pollution
reductions
to
compensate
for
pollution
abatement
strategies
that
do
not
in
fact
encompass
all
contributing
pollution
sources.
Comprehensive
boundaries
will,
by
contrast,
help
ensure
all
contributing
sources
are
responsible
for
their
share
of
pollution
reductions.

2.
EPA
Must
Use
The
Most
Recent
OMB
Metropolitan
Boundary
Lists
For
The
Designation
of
Nonattainment
Boundaries
In
order
to
base
these
designations
on
the
most
representative
data
available,
EPA
must
use
the
most
recent
(
2003)
OMB
metropolitan
boundary
lists
for
its
PM2.5
nonattainment
boundary
designations.
This
must
be
done
in
order
to
reflect
current
populations
and
the
emissions
resulting
from
those
populations.
Our
comments
in
this
letter
are
based
on
the
2003
OMB
lists.

3.
Designation
of
Attainment/
Unclassifiable
Areas
Must
Be
Consistent
with
the
Mandates
of
the
Prevention
of
Significant
Deterioration
Program.
HQ­
5
Commenter
is
concerned
that
several
states
(
e.
g.,
Montana,
Utah,
and
Wyoming)
are
dividing
their
area
into
numerous
"
postage
stamp"
attainment/
unclassifiable
areas.

EPA
Response:
Thank
you
for
your
letter
of
June
16,
2004,
to
Assistant
Administrator
Holmstead,
concerning
the
designation
of
nonattainment
areas
for
the
fine
particulate
matter
(
PM2.5)
air
quality
standards.
In
your
letter
you
expressed
concerns
over
the
designation
recommendations
submitted
by
States
to
address
PM2.5.
In
particular
you
expressed
concerns
that
some
States
may
have
submitted
recommendations
which
only
identified
counties
with
monitored
violations,
and
did
not
identify
counties
that
contributed
significant
emissions
to
the
affected
area.
You
also
expressed
concerns
that
some
State
recommendations
failed
to
recommend
all
counties
within
a
Consolidated
Metropolitan
Statistical
Area/
Metropolitan
Statistical
Area
(
CMSA/
MSA)
as
nonattainment,
and
you
indicated
concern
that
some
States
may
not
have
considered
the
updated
2003
Office
of
Management
and
Budget
boundaries
in
making
their
nonattainment
recommendations.

As
you
indicated
in
your
letter,
State
recommendations
for
PM2.5
designations
were
received
in
February
2004.
We
subsequently
responded
to
these
recommendations
on
June
29,
2004.
The
Environmental
Protection
Agency
(
EPA)
is
required
to
notify
States
and
Tribes
of
any
intended
modifications
to
their
recommendations
at
least
120
days
prior
to
promulgating
the
designations.
The
120­
day
period
is
designed
for
consultation
between
EPA
and
the
States
and
Tribes.
We
have
asked
States
to
provide
additional
information
that
they
would
like
for
us
to
consider
in
the
designations
process
by
September
1,
2004.
EPA
intends
to
promulgate
final
designations
in
November
2004.
At
that
time,
EPA
will
address
all
State
and
Tribal
lands
during
the
designations
process.

On
April
1,
2003,
and
February
13,
2004,
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
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.
As
discussed
in
the
above
referenced
guidance,
this
determination
is
based
on
the
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
and
vehicle
miles
traveled,
meteorology,
terrain,
jurisdictional
boundaries,
and
the
existing
level
of
control
of
emissions
sources.

To
help
assess
the
emissions
of
multiple
air
pollutants
contributing
to
the
formation
of
PM2.5,
we
developed
a
weighted
emissions
score
for
each
county
under
consideration.
The
methodology
for
calculating
these
county
scores
was
distributed
to
our
State
and
local
air
quality
agency
contacts
and
discussed
with
them
on
State
and
Territorial
Air
Pollution
Administrators/
Association
of
Local
Air
Pollution
Control
Officials
conference
HQ­
6
calls.
In
responding
to
State
nonattainment
recommendations
we
examined
all
available
information
and
identified
a
number
of
counties
adjacent
to
violating
urban
areas
that
had
relatively
high
emissions.
We
have
included
these
counties
in
the
list
of
our
prospective
nonattainment
areas.
In
some
cases,
the
boundary
recommendations
submitted
by
a
State
have
been
modified
to
reflect
the
addition
of
various
counties
adjacent
to
the
CMSA/
MSA
which
we
believe
contribute
significant
emissions
to
the
nonattainment
area.

Comment:
1032­
7
Region:
HQ
State:
IN
Area:

Comment:
EPA's
rules
should
be
completed
soon,
should
provide
flexibility,
and
should
harmonize
dates
and
planning.

We
urge
EPA
to
complete
the
PM2.5
implementation
rule
soon,
and
in
doing
so,
provide
states
with
as
much
flexibility
as
possible
to
develop
State
Implementation
Plans.
In
addition,
we
urge
EPA
to
reconcile
the
attainment
dates
for
PM2.5
with
the
NOX
and
SO2
reduction
dates
in
the
Clean
air
Interstate
Rule.
PM2.5
SIPs
will
be
due
in
early
2008,
and
attainment
will
be
required
by
early
2010.
If
the
first
phase
of
the
proposed
reductions
does
not
occur
until
2010,
attainment
may
not
be
achieved
until
2013
or
later.
EPA
should
harmonize
as
much
as
possible
the
planning
and
implementation
for
PM2.5
with
ozone
and
regional
haze
efforts.

EPA
Response:
Thank
you
for
your
comments
concerning
the
PM2.5
Implementation
rule
and
the
reconciliation
of
the
timelines
for
PM2.5
State
Implementation
Plans
(
SIPs)
and
the
require
emissions
reductions
related
to
the
CAIR
rule.
EPA
is
currently
in
the
process
of
finalizing
the
PM2.5
Implementation
rule
and
it
is
our
intent
to
propose
the
rule
in
the
fall
of
2004
and
finalize
the
rule
in
the
Spring
of
2005.
It
is
also
EPA's
intent
to
designate
areas
for
PM2.5
under
Subpart
1
of
Part
D.
EPA's
believes
that
Subpart
1
provides
sufficient
flexibility
in
terms
of
implementation
of
control
measures
that
constitute
RACM
and
RACT
for
specific
areas.

It
is
EPA's
intent
not
to
propose
a
multi­
category
classification
scheme
for
PM2.5
nonattainment
areas
under
which
areas
are
assigned
different
classifications,
attainment
dates,
and
varying
control
strategy
requirements
based
on
the
varying
design
values
and
severity
of
the
nonattainment
problem
in
the
area.
EPA
has
taken
into
consideration
the
associated
attainment
dates
for
SIPs
due
for
areas
related
to
the
8
hour
ozone
standard
and
the
CAIR
rule,
and
to
the
extent
possible
we
have
tried
to
reconcile
these
dates.
However,
due
to
the
differences
in
the
implementation
dates
related
to
these
rules
it
is
possible
that
the
dates
for
meeting
these
requirements
do
not
totally
correspond.
In
the
event
that
States
find
that
regional
controls
are
required
to
provide
emissions
reductions
necessary
to
attain
the
standard
along
with
the
implementation
of
local
control
measures,
State's
may
request
an
extension
of
the
attainment
date
of
up
to
five
years.
Requests
for
HQ­
7
extensions
of
attainment
dates
will
be
granted
based
upon
the
severity
of
the
nonattainment
problem
in
the
area
among
other
related
requirements.

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

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

Comment:
Commenter
notes
that
ambient
data
for
the
period
of
1999­
2004
continues
to
show
a
downward
trend
in
PM2.5
levels
in
Kentucky.
This
improvement
in
PM2.5
levels
is
consistent
with
those
seen
in
the
southeast
during
the
same
time
period.
According
to
a
recent
EPA
report
on
air
quality
improvements,
PM2.5
levels
have
decreased
18%
in
the
southeastern
U.
S.
since
monitoring
began
in
1999.

It
would
appear
that
consideration
of
this
data
would
be
prudent
in
the
designation
process.
Failure
to
do
so
ignores
the
fact
that
some
areas
in
Kentucky
are
on
track
to
achieve
the
PM2.5
standard
by
the
end
of
2004.

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

EPA
thanks
the
commenter
for
his
comments
regarding
the
designations
for
the
PM2.5
standard.
EPA's
decisions
on
the
State's
recommendations
are
contained
in
the
TSD.
