4­
8­
04
Draft
1
Qualitative
Assessment
of
Alternative
Coverage
and
Classification
Options
First
Addendum
to
"
Cost,
Emission
Reduction,
Energy,
and
Economic
Impact
Assessment
of
the
Proposed
Rule
Establishing
the
Implementation
Framework
for
the
8­
hour,
0.08ppm
Ozone
National
Ambient
Air
Quality
Standard"

Prepared
by
Innovative
Strategies
and
Economics
Group
Air
Quality
Strategies
and
Standards
Division
Office
of
Air
Quality
Planning
and
Standards
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
North
Carolina
April
8,
2004
4­
08­
04
Draft
1
The
Clean
Air
Act
requires
attainment
as
"
expeditiously
as
practicable
but
no
later
than"
the
maximum
period
specified
in
the
Act.
2
U.
S.
Environmental
Protection
Agency.
2003.
Cost,
Emission
Reduction,
Energy,
and
Economic
Impact
Assessment
of
the
Proposed
Rule
Establishing
the
Implementation
Framework
for
the
8­
hour,
0.08ppm
Ozone
National
Ambient
Air
Quality
Standard,
Prepared
by
the
Innovative
Strategies
and
Economics
Group,
Air
Quality
Strategies
and
Standards
Division,
Office
of
Air
Quality
Planning
and
Standards,
Office
of
Air
and
Radiation,
Research
Triangle
Park,
N.
C.,
April
24.
Option
2,
allowed
non­
attainment
areas
with
1­
hour
ozone
design
values
less
than
0.0121ppm
to
use
the
less
prescriptive
Subpart
1,
while
areas
with
higher
concentrations
would
use
Subpart
2.

2
1.0
Introduction
and
Summary
This
qualitative
assessment
finds
that
Option
2
remains
a
lower
cost
way
for
regulatory
coverage
and
classifying
non­
attainment
areas
for
the
8­
hour
Ozone
National
Ambient
Air
Quality
Standard.
Coverage
refers
to
the
use
of
Subpart
1
or
Subpart
2
of
Part
D,
Title
II
of
the
Clean
Air
Act
as
Amended
in
1990.
Classification
refers
to
the
requirements
of
the
Subpart
2
provisions
if
a
nonattainment
area
is
covered
under
Subpart
2.
The
time
and
mandatory
control
and
progress
requirements
vary
across
Subpart
2'
s
marginal,
moderate,
serious,
severe­
15,
severe
17,
and
extreme
classifications.
The
corresponding
maximum
attainment
dates
are
3,6,9,15,17,
and
19
from
the
date
an
area
is
designated
non­
attainment.
1
For
the
mandatory
control
and
progress
requirements
associated
with
these
classifications,
there
is
a
gradation
across
the
classifications.
Marginal
areas
have
the
fewest
and
extreme
areas
the
most
mandatory
requirements.
Subpart
1
has
two
sets
of
attainment
times:
up
to
5
years
from
designation;
and,
with
a
potential
extension
of
no
more
than
another
5
years
from
the
end
of
the
first
5
year
period.
The
progress
requirements
under
Subpart
1
are
more
general
than
under
Subpart
2.

Furthermore,
this
qualitative
assessment
is
intended
as
an
addendum
to
the
quantitative
assessment
prepared
for
the
proposed
rule.
The
reader
is
referred
to
the
April
24,
2002
assessment
referenced
in
Section
1.1
and
found
in
the
docket
for
the
rule­
making.

1.1
Background
A
quantitative
assessment
conducted
for
the
proposed
rule
showed
that
allowing
8­
hour
nonattainment
areas
to
meet
certain
criteria
and
use
Subpart
1
provisions
(
i.
e.
Option
2)
is
lower
cost
than
an
approach
that
requires
all
designated
non­
attainment
areas
to
use
Subpart
2
provisions.
2
The
approach
where
the
use
of
Subpart
1
is
prohibited
is
referred
to
as
Option
1
in
the
proposal
rule­
making
package.

During
the
public
comment
process,
there
were
suggestions
on
other
criteria
for
allowing
areas
to
use
Subpart
1.
There
were
also
suggestions
on
the
ranges
of
ozone
design
values
for
determining
an
area's
classification
under
Subpart
2.
Several
comments
suggested
promising
4­
08­
04
Draft
368FR60054.
October
21,
2003.

3
alternatives
that
addressed
perceived
problems
with
Option
2.
We
call
these
Alternatives
Y
and
Z.
We
analyze
these
options
more
fully
below.
We
chose
not
to
analyze
two
other
options
that
were
put
forth
in
an
October
21,
2003
Federal
Register
Notice
that
reopened
the
public
comment
period.
Those
were
called
Alternatives
A
and
Alternative
B.
The
findings
for
an
assessment
of
A
and
B
would
be
similar
to
that
shown
in
Section
3
for
Alternatives
Y
and
Z.
The
reason
is
that
Alternatives
A
and
B
are
based
on
features
of
Alternatives
Y
and
Z.
For
example,
Alternatives
A
and
B
have
more
areas
classified
as
Subpart
2­
serious
and
above
and
fewer
areas
covered
under
Subpart
1
relative
to
Option
2.3
1.2
Analyzed
Alternatives
to
Option
2
There
are
2
alternatives
to
Option
2
evaluated
in
this
qualitative
assessment.

1.2.1
Alternative
Y
Comments
suggesting
this
Alternative
were
aimed
at
alleviating
a
perceived
equity
issue.
The
concern
was
that
under
Option
2
areas
with
the
same
8­
hour
design
value
may
be
treated
differently.
For
example,
under
Option
2,
an
8­
hour
nonattainment
areas
in
attainment
with
the
1­
hour
standard
is
covered
under
1.
However,
another
area
not
meeting
the
1­
hour
standard
and
having
the
same
8­
hour
design
value
is
covered
under
Subpart
2.
Under
Alternative
Y,
designated
8­
hour
ozone
non­
attainment
areas
with
ozone
design
values
between
0.085ppm
and
0.090ppm,
8­
hour
average
would
be
covered
under
Subpart
1.
Under
Alternative
Y,
areas
with
8­
hour
design
values
of
0.091ppm
and
greater
are
required
to
use
Subpart
2.
However,
under
Option
2,
designated
non­
attainment
areas
not
meeting
the
1­
hour
ozone
standard
and
with
concentrations
from
0.085ppm
to
0.092ppm
use
Subpart
2
and
are
classified
as
marginal.
In
essence,
Alternative
Y
starts
the
classification
intervals
at
higher
concentrations.
Hence,
there
are
more
marginal
and
moderate
classifications
under
Alternative
Y
than
under
Option
2.

1.2.2
Alternative
Z
Comments
suggesting
this
Alternative
were
aimed
at
addressing
attainment
times
that
were
perceived
as
too
short
for
certain
areas
as
a
result
of
the
classification
derived
from
Option
2
for
Subpart
2
areas.
Under
Alternative
Z,
the
criterion
for
categorizing
a
non­
attainment
area
under
Subpart
1
is
the
used
in
Option
2.
However,
the
concentration
intervals
corresponding
to
marginal,
serious,
severe­
15,
severe­
17,
and
extreme
are
much
narrower.
By
taking
50%
of
Option
2'
s
Subpart
2
classification
intervals,
Alternative
Z
has
more
designated
non­
attainment
areas
classified
as
serious,
severe­
15,
severe­
17,
and
extreme
than
Option
2.
Subsequent
comments
suggested
that
if
an
area's
1­
hour
classification
was
higher
this
should
also
be
the
areas
8­
hour
classification.
Furthermore,
the
comments
noted
that
if
such
areas
have
the
same
classification
under
the
1­
hour
standard,
many
of
the
requisite
mandatory
control
and
progress
requirements
may
have
already
been
satisfied.

1.3
Data
Classifications
for
1­
hour
non­
attainment
areas,
hypothetical
8­
hour
design
value
concentrations
using
2000­
2002
data,
categorizations
and/
or
classifications
for
hypothetical
8­
hour
nonattainment
areas,
base
case
8­
hour
design
value
projections,
and
information
on
the
geographic
4­
08­
04
Draft
4
Ibid.

4
boundaries
of
1­
hour
and
hypothetical
8­
hour
non­
attainment
areas
are
used
in
the
qualitative
assessment.

1.4
Methodology
Coverage
and/
or
classifications
for
each
hypothetical
8­
hour
ozone
non­
attainment
area
under
Option
2,
Alternative
Y,
and
Alternative
Z
are
determined
using
the
corresponding
criteria
for
each.
Hypothetical
non­
attainment
areas
are
divided
into
3
groups.

1.4.1
Areas
with
no
expected
differences
in
costs.
These
areas
have
one
of
the
following
sets
of
characteristics:

°
No
difference
in
coverage
and/
or
classifications
across
Option
2,
Alternative
Y,
and
Alternative
Z.
°
Classified
as
Subpart
1
or
Subpart
2­
marginal
and
meeting
the
standard
by
2007
in
base
case
air
quality
projections.
The
quantitative
analysis
done
for
proposal
noted
the
similarities
in
costs
for
similar
areas
classified
as
Subpart
1
or
Subpart
2­
marginal.
4
°
Projected
to
meet
the
8­
hour
standard
in
the
base
case
for
an
alternative
that
has
a
shorter
attainment
date
and/
or
fewer
mandatory
or
progress
requirements
than
another
alternative.
However,
the
1­
hour
requirements
for
that
area
are
equivalent
to
the
8­
hour
alternative
which
has
more
prescribed
requirements.
Furthermore,
the
geographic
boundaries
of
the
1­
hour
and
8­
hour
non­
attainment
areas
are
the
same.

1.4.2
Areas
where
the
cost
difference
is
uncertain.
Such
areas
are
not
projected
to
meet
the
8­
hour
standard
in
the
base
case
for
the
attainment
dates
of
the
alternative
with
a
shorter
attainment
date.

1.4.3
Areas
where
there
are
likely
to
be
cost
differences.
Such
areas
meet
the
standard
in
the
base
case
for
the
option
with
the
nearer
term
attainment
date
and/
or
fewer
progress
or
mandatory
requirements.
Furthermore,
the
1­
hour
non­
attainment
classification
is
less
stringent
and/
or
the
geographic
scope
of
the
8­
hour
area
is
broader
than
that
of
the
1­
hour
nonattainment
or
maintenance
area.

1.5
Findings
and
Limitations
Although
there
are
no
anticipated
cost
differences
for
54
of
101
hypothetical
non­
attainment
areas
and
the
potential
cost
difference
is
unknown
in
30
other
areas,
the
qualitative
assessment
finds
that
Option
2
is
preferred
on
cost
grounds
to
Alternatives
Y
and
Z.
More
specifically,
we
find
the
following.
°
In
the
17
areas
where
potential
differences
could
be
determined,
Alternatives
Y
and
Z
had
higher
anticipated
control
costs
than
Option
2
for
5
and
10
areas,
respectively.
The
quantitative
analyses
done
for
proposal
showed
such
differences
could
be
in
the
tens
of
millions
of
dollars.
4­
08­
04
Draft
5
°
For
23
of
the
30
areas
where
the
cost
differences
area
unknown,
Alternatives
Y
or
Z
had
22
areas
with
classifications
higher
than
Option
2.
With
the
higher
classification,
there
are
additional
mandated
controls
and
progress
requirements.
These
requirements
may
result
(
if
those
obligations
are
not
already
met
for
all
parts
of
the
hypothetical
non­
attainment
area)
in
additional
control
costs
relative
to
Option
2
if
the
8­
hour
standard
can
be
met
under
Option
2'
s
coverage
and/
or
classification.
However,
the
higher
classifications
of
Alternatives
Y
or
Z
have
more
distant
attainment
dates.
Hence,
under
circumstances
when
the
standard
cannot
be
met
under
the
initial
Option
2
categorization
and/
or
classification,
Alternatives
Y
or
Z
may
avoid
additional
administrative
costs
to
request
bump­
up
to
a
higher
classification.
But,
the
quantitative
analysis
done
at
proposal
showed
the
control
cost
differences
in
10
hypothetical
areas
to
be
about
80
times
the
base
administrative
cost
estimate
in
the
Federal
Register
Notice
for
the
proposed
rule.
Furthermore,
the
base
control
cost
estimate
was
2
orders
of
magnitude
higher
than
the
base
administrative
cost
estimate.
Hence,
were
cost
differences
to
arise
among
these
22
areas
due
to
control
as
well
as
administrative
cost
differences,
we
would
expect
those
differences
due
to
higher
control
costs
of
Alternative
Y
or
Z
to
be
collectively
higher
than
those
arising
from
administrative
cost
differences
with
Option
2.
°
For
the
remaining
7
of
the
30
areas,
there
is
not
a
difference
in
cost
across
the
coverage
and/
or
classifications
of
Option
2,
Alternative
Y,
and
Alternative
Z.
They
are
Subpart
1
or
Subpart
2­
Marginal.
However,
if
bump­
up
is
called
for,
there
is
higher
administrative
cost
and
possibly
higher
control
costs
for
Alternative
Y
(
Subpart
2­
Marginal)
compared
to
Alternative
Z
or
Option
2
(
Subpart
1).

Table
1­
1
summarizes
the
certain
features
of
the
hypothetical
non­
attainment
areas.

Table
1­
1.
Numbers
of
Hypothetical
Non­
attainment
Areas
and
Their
Characteristics*

Descriptive
Characteristic
Number
of
Areas
With
That
Characteristic
Total
Number
of
Hypothetical
Areas
101
Number
With
No
Anticipated
Cost
Difference
54
Number
Where
The
Cost
Difference
is
Unknown
30
Number
of
These
Where
Y
or
Z
had
a
Higher
Classification
than
Option
2
22
Number
of
These
Where
The
Coverage
is
Subpart
1
or
Subpart
2­
Marginal
7
Number
Where
Potential
For
and
Type
of
Cost
Difference
is
Known
17
Number
of
These
Where
Alternative
Z
had
Higher
Cost
10
Number
of
These
Where
Alternative
Y
had
Higher
5
Number
of
These
Where
Option
2
had
Higher
Cost
2
*
The
number
of
areas
without
at
cost
difference
(
i.
e.
54),
the
number
of
areas
where
the
cost
difference
is
unknown
(
i.
e.
30),
and
the
number
of
areas
where
there
is
an
expected
cost
difference
(
i.
e.
17)
sum
to
101
hypothetical
non­
attainment
areas.
4­
08­
04
Draft
5
The
air
quality
values
for
2010
are
the
result
of
CAM­
X
simulations.
The
values
for
2007
are
the
result
of
linear
interpolation
of
2001
and
2010
values.
The
values
for
2013
are
the
result
of
linear
interpolating
of
2010
and
2015
CAM­
X
projections.
Refer
to
Docket
Number
OAR­
2003­
0079­
0682.
6The
final
ozone
implementation
rule
contains
anti­
backsliding
requirements
to
ensure
that
Subpart
2
control
measures
required
for
1­
hour
standard
purposes
are
not
discontinued.
7The
quantitative
assessment
done
for
the
proposed
rule­
making
showed
the
estimated
differences
between
Option
1
and
Option
2
to
be
$
80
million.
8The
administrative
requirements
section
of
the
proposed
rule
indicated
base
costs
incremental
to
the
1­
hour
standard
of
$
1million.
Even
if
these
base
costs
were
$
4
or
$
8
million,
we
would
expect
the
incremental
administrative
costs
to
request
bump­
up
to
be
in
the
thousands
to
tens
of
thousands
of
dollars.

6
2.0
Data
and
Methodology
The
hypothetical
non­
attainment
areas
and
their
corresponding
classifications
and
categorizations
are
included
in
the
Revised
Background
Information
Document:
Hypothetical
Nonattainment
Areas
for
Purposes
of
Understanding
the
EPA
Proposed
Rule
For
Implementing
the
8­
hour
Ozone
National
Ambient
Air
Quality
Standard
in
Relation
to
Re­
Opened
Comment
Period
(
PDF),
10­
16­
03.
It
can
be
found
at
http://
www.
epa.
gov/
ttn/
naaqs/
ozone/
o3imp8hr/
proprule.
html
There
are
101
such
areas.
The
8­
hour
design
values
for
hypothetical
non­
attainments
in
the
CAM­
X
domain
are
projected
for
2007,
2013,
2010
and
2015.
The
projections
for
each
of
these
years
represent
base
case
conditions.
5
Base
case
conditions
are
illustrative
of
what
future
8­
hour
ozone
design
values
may
be
in
the
absence
of
any
additional
state
implementation
plan
or
federal
regulatory
emission
reductions
requirements
(
beyond
the
heavy­
duty
diesel
and
non­
road
rules).
The
assessment
does
not
include
emission
reductions
associated
with
the
Reciprocal
Internal
Combustion
Engine
Maximum
Achievable
Control
Technology
Rule
or
the
recently
proposed
Interstate
Air
Quality
Rule.
The
hypothetical
non­
attainment
areas
and
air
quality
projections
for
the
areas
within
the
CAM­
X
domain
are
found
in
Addendum
Appendix­
A.

Two
general
types
of
cost
differences
may
arise
among
Option
2,
Alternative
Y,
and
Alternative
Z
as
a
result
of
coverage
and/
or
classification
differences.
One
type
is
additional
control
costs
associated
with
mandatory
requirements
that
are
not
needed
to
meet
the
8­
hour
standard
in
the
target
year.
But,
if
these
mandatory
requirements
are
part
of
an
area's
1­
hour
attainment
and
maintenance
obligations
and
the
geographic
boundaries
for
the
1­
hour
and
8­
hour
are
the
same,
the
mandatory
requirement
is
fulfilled
and
no
additional
control
costs
are
attributable
to
the
coverage
and/
or
classification
differences.
6
However,
if
there
are
additional
control
requirements,
the
result
may
be
additional
costs
of
tens
of
millions
of
dollars.
7.

Another
type
of
cost
difference
is
additional
administrative
costs
associated
for
areas
needing
more
time
to
meet
the
8­
hour
standard.
In
that
case,
the
state
requests
more
time
to
bump­
up
to
a
higher
classification.
Under
the
Clean
Air
Act,
the
EPA
Administrator
must
grant
such
requests.
These
additional
costs
associated
with
bump­
up
are
much,
much
smaller
than
those
associated
further
control
requirements.
8
4­
08­
04
Draft
7
2.1
Hypothetical
8­
hour
Non­
Attainment
Areas
With
No
Expected
Cost
Differences
There
are
45
areas
where
the
coverage
and/
or
classifications
do
not
vary
among
Option
2,
Alternative
Y
and/
or
Alternative
Z.
These
areas
and
their
categorization
and,
where
appropriate,
classification
are
listed
in
Table
2­
1.

Table
2­
1.
Hypothetical
8­
hour
Non­
attainment
Areas
With
No
Expected
Cost
Difference
Because
The
Coverage
And/
Or
Classification
Does
Not
Vary
Across
Alternatives
Hypothetical
Area
Coverage/
Classification
Hypothetical
Area
Coverage/
Classification
Asheville,
NC
Subpart
1
Johnstown,
PA
Subpart
1
Augusta­
Aiken,
GA­
SC
Subpart
1
Kansas
City­
MO­
KS
Subpart
1
Austin­
San
Marcos,
TX
Subpart
1
Lima,
OH
Subpart
1
Bell
County,
KY
Subpart
1
Little
Rock­
North
Little
Rock,
AR
Subpart
1
Benzie
County,
MI
Subpart
1
Louisville,
KY­
IN
Subpart
1
Bloomington,
IN
Subpart
1
Mason
County,
MI
Subpart
1
Bowling
Green,
KY
Subpart
1
Murray
County,
GA
Subpart
1
Canton­
Massillon,
OH
Subpart
1
Nashville,
TN
Subpart
1
Charleston,
WV
Subpart
1
Norfolk­
Virginia
Beach­
Newport
News,
VA
Subpart
1
Chico,
CA
Subpart
1
Owensboro,
KY­
IN
Subpart
1
Clarksville­
Hopkinsville,
TN­
KY
Subpart
1
Parkersburg­
Marietta,
WV­
OH
Subpart
1
Columbus,
OH
Subpart
1
Phoenix­
Mesa,
AZ
Subpart
1
Dayton­
Springfield,
OH
Subpart
1
Putnam
County,
TN
Subpart
1
Decatur,
AL
Subpart
1
Roanoke,
VA
Subpart
1
Detroit­
Ann
Arbor­
Flint,
MI
Subpart
1
Rochester,
NY
Subpart
1
Erie,
PA
Subpart
1
Rocky
Mount,
NC
Subpart
1
Essex
County,
NY
Subpart
1
San
Antonio,
TX
Subpart
1
Evansville­
Henderson,
IN­
KY
Subpart
1
Scranton­
Wilkes­
Barre­
Hazleton,
PA
Subpart
1
Fayetteville,
NC
Subpart
1
State
College,
PA
Subpart
1
Florence,
SC
Subpart
1
Steubenville­
Weirton,
OH­
WV
Subpart
1
Fort
Wayne,
IN
Subpart
1
Toledo,
OH
Subpart
1
Greenville­
Spartanburg­
Anderson,
SC
Subpart
1
Wheeling,
WV­
OH
Subpart
1
Huntington­
Ashland,
WV­
KY­
OH
Subpart
1
In
addition,
there
are
5
other
hypothetical
8­
hour
non­
attainment
areas
where
there
is
not
an
anticipated
cost
difference.
In
these
areas,
the
coverage
is
either
Subpart
1
or
Subpart
2­
marginal
and
the
projected
2007
design
value
is
at
or
below
the
standard.
Those
areas
and
the
categorizations
and/
or
classifications
and
projected
design
values
are
presented
in
Table
2­
2.

Table
2­
2.
Hypothetical
Non­
Attainment
Areas
With
No
Expected
Difference
In
Cost
Because
the
8­
hour
Standard
Is
Met
In
The
Base
Case
And
The
Alternatives
Are
Either
Subpart
1
or
Subpart
2­
Marginal.

Hypothetical
Non­
Attainment
Area
Option
2
Alternative
Y
Alternative
Z
2007
Value
Chattanooga,
TN­
GA
Subpart
1
Subpart
2­
Marginal
Subpart
1
0.81ppm
Columbia,
SC
Subpart
1
Subpart
2­
Marginal
Subpart
1
0.83ppm
Hickory­
Lenoir­
Morganton,
NC
Subpart
1
Subpart
2­
Marginal
Subpart
1
0.80ppm
Johnson
City­
Kingsport­
Bristol,
TN­
VA
Subpart
1
Subpart
2­
Marginal
Subpart
1
0.81ppm
New
Orleans,
LA
Subpart
2­
Marginal
Subpart
1
Subpart
2­
Marginal
0.81ppm
There
are
also
other
hypothetical
non­
attainment
areas
where
there
is
not
anticipated
difference
in
cost
across
Option
2,
Alternative
Y,
and
Alternative
Z.
For
those
areas,
the
standard
is
met
in
the
base
case
with
a
less
stringent
classification.
However,
the
mandatory
control
and
progress
requirements
of
the
higher
classification
were
already
required
of
the
area
because
of
its
1­
hour
classification.
To
the
extent
the
one­
hour
requirements
have
alreadybeen
met,
the
area
may
not
4­
08­
04
Draft
8
have
higher
controls
costs.
Table
2­
3
identifies
such
areas.

Table
2­
3.
Hypothetical
Non­
Attainment
Areas
Where
Meeting
1­
hour
Obligations
May
Preclude
a
Cost
Difference
Among
the
Alternatives
Because
the
Geographic
Boundaries
Of
The
1­
hr
And
Hypothetical
8­
hour
Areas
Are
the
Same
and
the
1­
hr
Classification
Is
Equivalent
To
The
Most
Stringent
Classification
Base
Case­
Hypothetical
Non­
Attainment
Area
1­
hr
Classification
Alternative
Z
Alternative
Y
Option
2
Year
Attains
Baton
Rouge,
LA
Severe­
15
Severe­
15
Subpart
1
Marginal
2007
Beaumont­
Port
Arthur,
TX
Moderate
Moderate
Subpart
1
Marginal
2007
Portland,
ME
Moderate
Moderate
Subpart
1
Marginal
2007
Springfield
(
Western
MA),
MA
Serious
Serious
Marginal
Moderate
2010
2.2
Areas
Where
The
Cost
Difference
Is
Unknown
There
are
two
sets
of
areas
where
the
cost
differences
are
unknown.
One
set
are
the
hypothetical
8­
hour
non­
attainment
areas
for
which
we
do
not
have
base
case
projected
8­
hour
design
values.
There
are
6
areas
in
that
set.
They
are
identified
in
Table
2­
4.

Table
2­
4.
Hypothetical
Non­
Attainment
Areas
With
No
Projected
Base
Case
Design
Values
Hypothetical
Non­
Attainment
Area
Option
2
Categorization
Alternative
Y
Alternative
Z
Los
Angeles­
South
Coast
Air
Basin,
CA
Severe­
17
Serious
Extreme
Sacramento,
CA
Moderate
Moderate
Severe­
17
San
Diego,
CA
Subpart
1
Moderate
Subpart
1
San
Joaquin
Valley,
CA
Serious
Moderate
Severe­
17
Southeast
Desert,
CA
Moderate
Moderate
Severe­
17
Ventura
County,
CA
Moderate
Moderate
Severe­
17
The
other
set
of
areas
where
the
cost
difference
is
unknown
is
the
result
of
not
having
control
strategies
simulating
attainment
of
the
standard
under
each
of
the
alternatives.
Furthermore,
8­
hour
design
value
projections
may
show
these
areas
meet
the
standard
in
the
base
case
for
a
more
distant
attainment
date
of
one
of
the
alternatives,
but
not
alternatives
with
a
nearer
term
attainment
date.
Those
areas
are
identified
in
Table
2­
5.

Table
2­
5.
Areas
Where
The
Cost
Difference
Is
Unknown
Because
We
Do
Not
Have
Control
Strategies
and
Resultant
8­
hour
Design
Value
Projections
Hypothetical
Non­
Attainment
Area
Option
2
Alternative
Y
Alternative
Z
Base
Case­
Year
Attains
Atlanta,
GA
Moderate
Moderate
Serious
2013
Buffalo­
Niagara
Falls,
NY
Subpart
1
Moderate
Subpart
1
2013
Chicago­
Gary­
Lake
County,
IL­
IN­
WI
Moderate
Moderate
Severe
17
Above
standard
in
2013*
Cleveland­
Akron,
OH
Moderate
Moderate
Serious
Above
standard
in
2013*
Dallas­
Fort
Worth,
TX
Moderate
Moderate
Serious
Above
standard
in
2013*
Grand
Rapids­
Muskegon­
New
Holland
MI
Moderate
Marginal
Moderate
2010
Greater
Connecticut,
CT
Moderate
Moderate
Severe
15
Above
standard
in
2013*
Green
Bay­
Appleton­
Neenah­
Door,
WI
Subpart
1
Marginal
Subpart
1
2010
Hancock­
Waldo
Counties,
ME
Subpart
1
Marginal
Subpart
1
2010
Houston­
Galveston­
Brazoria,
TX
Serious
Moderate
Severe
17
Above
standard
in
2013*
Indianapolis,
IN
Subpart
1
Marginal
Subpart
1
2010
Jamestown,
NY
Subpart
1
Marginal
Subpart
1
2010
Memphis,
TN­
AR­
MS
Moderate
Moderate
Serious
Above
standard
in
2013*
Milwaukee­
Racine,
WI
Moderate
Moderate
Severe
17
Above
standard
in
2013*
NYC­
N.
New
Jersey­
Long
Is.,
NY­
NJ­
CT
Serious
Moderate
Severe
17
Above
standard
in
2013*
Phil.­
Wilmington­
Atlantic
City,
PA­
NJ­
DE
Serious
Moderate
Severe
17
Above
standard
in
2013*
Pittsburgh,
PA­
WV
Subpart
1
Moderate
Subpart
1
2013
Providence
(
All
RI),
RI
Moderate
Moderate
Serious
Above
standard
in
2013*
Reading,
PA
Subpart
1
Marginal
Subpart
1
2010
4­
08­
04
Draft
9
Sheboygan,
WI
Moderate
Moderate
Serious
Above
standard
in
2013*
Syracuse,
NY
Marginal
Marginal
Moderate
2010
Washington­
Baltimore,
DC­
MD­
VA­
WV
Moderate
Moderate
Severe­
17
Above
standard
in
2013*
York,
PA
Subpart
1
Marginal
Subpart
1
2010
Youngstown­
Warren­
Sharon,
PA­
OH
Subpart
1
Marginal
Subpart
1
2010
*
Recognize
that
these
are
base
case
projections
that
understate
emission
reductions
from
Federal
Rules
and
presume
no
reductions
of
ozone
precursors
under
the
8­
hour
state
implementation
planning
process.

2.3
Areas
Where
There
Is
A
Likely
Difference
In
Cost
Across
Coverage
And/
Or
Classification
Alternatives
For
5
hypothetical
non­
attainment
areas,
it
appears
that
Alternative
Y
could
result
in
higher
costs
relative
to
Option
2
and
Alternative
Z.
For
these
areas,
the
Option
2
and
Subpart
2
categorizations
are
equivalent.
The
higher
costs
for
Alternative
Y
would
be
for
additional
mandatory
controls
and
progress
requirements
that
are
not
needed
to
meet
the
standard
by
the
prescribed
attainment
date.
Table
2­
6
identifies
the
areas,
coverage
and
classification
differences,
year
the
standard
is
achieved
in
the
base
case,
the
1­
hour
classification,
and
size
of
the
1­
hour
non­
attainment
compared
to
the
hypothetical
8­
hour
area.
If
the
1­
hour
classification
is
less
stringent
and/
or
the
1hour
area
is
smaller,
the
mandatory
control
and
progress
requirements
of
Alternative
Y
would
result
in
more
control
costs
than
either
Option
2
or
Alternative
Z.

Table
2­
6.
Hypothetical
Non­
attainment
Areas
Where
Alternative
Y
is
Higher
Cost
Base
Case­
Hypothetical
Non­
Attainment
Area
Yr
Attains
Opt.
2
&
Alt.
Z
Alt.
Y
1­
Hour
Classification
Size
1­
hr
Area
Allentown­
Bethlehem­
Easton,
PA­
NJ
2010
Subpart
1
Moderate
Marginal
Same
Harrisburg­
Lebanon­
Carlisle,
PA
2010
Subpart
1
Moderate
Marginal
Same
Knoxville,
TN
2010
Subpart
1
Moderate
Maintenance
(
Marg.)
Smaller
Lancaster,
PA
2010
Subpart
1
Moderate
Marginal
Same
Raleigh­
Durham­
Chapel
Hill,
NC
2010
Subpart
1
Moderate
Moderate
Smaller
For
10
areas,
Alternative
Z
is
the
highest
cost
option
compared
to
Option
2
or
Alternative
Y.
The
difference
is
due
to
additional
control
costs
resulting
from
mandatory
progress
and
control
requirements
that
are
not
needed
to
meet
the
standard
in
the
target
year.
The
areas,
the
year
the
standard
is
achieved
in
the
base
case,
the
alternative
8­
hour
categorizations
and/
or
classifications,
the
1­
hour
classification,
and
size
of
the
1­
hour
area
compared
to
the
hypothetical
8­
hour
nonattainment
area
boundaries
are
presented
in
Table
2­
7.

Table
2­
7.
Hypothetical
Non­
Attainment
Areas
Where
Alternative
Z
Has
Higher
Cost
than
Option
2
or
Alternative
Y
Base
Case­
Hypothetical
NA
Area
Yr.
Attains
Option
2
Altern.
Y
Altern.
Z
1­
hour
Classification
Size
1­
hr
Area
Benton
Harbor,
MI
2007
Marginal
Subpart
1
Moderate
Attainment
Smaller
Boston­
Lawrence­
Worcester*
2010
Moderate
Marginal
Serious
Serious
Smaller
Charlotte­
Gastonia­
Rock
Hill**
2013
Moderate
Moderate
Severe­
15
Moderate
Smaller
Cincinnati­
Hamilton,
OH­
KY­
IN
2010
Moderate
Moderate
Serious
Moderate
Smaller
Greensboro­
Winston
Sal­
High
Pt
2007
Moderate
Moderate
Serious
Maintenance
(
Mod.)
Smaller
Longview­
Marshall,
TX
2007
Marginal
Subpart
1
Moderate
Attainment
Smaller
Richmond­
Petersburg,
VA
2007
Marginal
Subpart
1
Moderate
Moderate
Smaller
South
Bend­
Elkhart,
IN
2007
Marginal
Subpart
1
Moderate
Maintenance
(
Marg.)
Same
as
8­
hr
St.
Louis,
MO­
IL
2007
Marginal
Subpart
1
Moderate
Maintenance
(
Serious)
Smaller
Tulsa,
OK
2007
Marginal
Subpart
1
Moderate
Attainment
Smaller
*
Thirteen
of
14
counties
in
the
hypothetical
non­
attainment
area
are
classified
as
serious
for
the
1
hour
standard.
The
county
not
included
in
the
1­
hour
non­
attainment
boundary
is
classified
as
marginal.
**
For
this
area
it
is
conceivable,
but
not
likely
that
the
area
may
have
to
bump
up
to
Serious.
However,
the
administrative
costs
associated
with
4­
08­
04
Draft
10
requesting
bump­
up
to
a
higher
classification
is
small
compared
to
the
additional
control
costs
of
a
Severe­
15
classification.

For
2
other
areas,
Option
2
and
Alternative
Z
are
higher
cost
than
Alternative
Y.
The
areas,
the
year
the
standard
is
achieved
in
the
base
case,
the
alternative
8­
hour
categorizations
and/
or
classifications,
the
1­
hour
classification,
and
the
size
of
the
area
compared
to
the
hypothetical
8­
hour
non­
attainment
area
boundaries
are
presented
in
Table
2­
8.

Table
2­
8.
Hypothetical
Non­
Attainment
Areas
Where
Option
2
and
Alternative
Z
have
higher
cost
than
Alternative
Y
Base
Case­
Hypothetical
NA
Area
Yr.
Attains
Option
2
Altern.
Y
Altern.
Z
1­
hour
Classification
1­
hour
size
Birmingham,
AL
2007
Moderate
Marginal
Moderate
Marginal
Smaller
Macon,
GA
2007
Moderate
Marginal
Moderate
Attainment
Smaller
3.0
Findings
and
Limitations
3.1
Findings
Two
major
findings
emerge
from
this
qualitative
assessment.
4­
08­
04
Draft
11
°
First,
for
most
areas,
there
is
not
a
cost
difference.
For
54
of
101
hypothetical
nonattainment
areas,
there
is
not
an
anticipated
difference
in
control
or
administrative
costs
amongst
Option
2,
Alternative
Y,
and
Alternative
Z.
The
tables
in
Section
2
identify
those
areas.
°
Second,
given
anticipated
cost
differences
for
some
areas
and
the
potential
magnitudes
of
administrative
versus
possible
control
cost
differences
in
other
areas,
Option
2
is
preferred
on
cost
grounds
to
Alternatives
Y
and
Z.
°
In
the
17
areas
where
potential
cost
differences
could
be
determined,
Alternatives
Y
or
Z
had
higher
anticipated
controls
costs
than
Option
2
for
15
of
the
areas.
The
17
areas
are
identified
in
Tables
2­
6,
2­
7,
and
2­
8.
°
In
22
of
the
30
areas
where
the
potential
cost
differences
could
not
be
determined,
Alternatives
Y
or
Z
had
a
higher
classification
than
Option
2.
Hence,
there
is
a
potential
for
higher
control
costs
with
Alternatives
Y
or
Z
for
these
areas.
Given
the
potential
magnitude
of
differences
in
control
costs
exceed
those
in
administrative
costs,
we
expect
that
if
there
are
administrative
cost
differences
for
some
of
these
22
areas
and
control
cost
differences
for
some
of
the
other
areas,
collectively
the
control
cost
differences
will
be
greater.
These
areas
are
identified
in
Table
2­
5.
°
For
7
other
areas
in
this
group
of
30,
there
may
not
be
a
cost
difference
if
a
bumpup
is
not
requested.
However,
if
a
bump­
up
is
requested
in
1
or
more
of
these
areas,
there
are
higher
administrative
costs
and
possibly
higher
control
costs
for
Alternative
Y
as
compared
to
Option
2
or
Alternative
Z.

3.2
Limitations
There
are
several
limitations
in
any
assessment.
Here
are
5
major
ones.
°
The
base
case
air
quality
projections
do
not
reflect
other
emission
reduction
programs
proposed
or
recently
promulgated.
These
include
the
promulgated
Reciprocating
Internal
Combustion
Maximum
Achievable
Control
Technology
rule
as
well
as
the
recently
proposed
Interstate
Air
Quality
Rule
and
Utility
Maximum
Achievable
Control
Technology
Rule.
This
limitation
could
understate
the
number
of
areas
projected
to
meet
the
standard
under
base
case
conditions.
°
The
base
case
air
quality
projects
may
be
misconstrued
as
a
precise
and
accurate
prediction
of
resulting
air
quality
when
the
states
develop
and
implement
plans
to
attain
and
maintain
the
8­
hour
ozone
standard.
This
misunderstanding
could
cause
some
to
overstate
the
challenges
in
attaining
the
8­
hour
standard.
The
base
case
air
quality
projections
do
not
consider
forthcoming
federal
rules
mentioned
above
and
do
no
assume
any
reductions
in
emissions
as
a
result
of
state
implementation
plans
to
meet
the
8­
hour
standard.
°
The
qualitative
analysis
is
intended
only
as
an
addendum
to
the
quantitative
analysis
prepared
for
the
proposed
rule.
The
reader
is
referred
to
the
original
assessment
for
further
background.
°
The
qualitative
assessment
was
based
on
hypothetical
non­
attainment
area
boundaries
developed
solely
for
purposes
of
analysis.
Further
caveats
regarding
those
areas
are
presented
in
Addendum
Appendix
A.
4­
08­
04
Draft
12
°
Air
quality
modeling
and
projections
are
tools.
The
listing
of
areas
and
associated
concentrations
may
indicate
more
reliability
than
a
large
scale
regional
assessment
would
yield
for
any
one
area.
THE
END.

Addendum
Appendix
A
4­
08­
04
Draft
13
1­
hour
and
8­
hour
Option
2
Coverage,
Classifications,
and
Design
Value
Projections
for
Hypothetical
Non­
Attainment
Areas
Note:
The
EPA's
Inclusion
and
grouping
of
counties
into
hypothetical
nonattainment
areas
for
purposes
of
the
final
implementation
rule
was
done
solely
for
the
purpose
of
analyzing
and
illustrating
how
the
various
implementation
options
might
apply
to
areas
designated
non­
attainment
for
the
8­
hour
ozone
national
ambient
air
quality
standard.
The
creation
of
this
set
of
hypothetical
nonattainment
areas,
while
based
on
data
from
2000­
2002,
is
not
intended
to
pre­
judge
the
designation
process
that
will
occur
over
the
next
months
and
that
will
be
based
on
2000­
2003
data,
if
available.
Thus
final
designations
by
EPA
in
April
2004
may
include
as
non­
attainment
areas
not
on
this
list.
Similarly,
States
may
recommend
and
EPA
may
designate
as
attainment
areas
that
are
on
this
list.
In
addition,
boundaries
of
non­
attainment
areas
could
be
different
than
as
defined
on
this
list
of
hypothetical
non­
attainment
areas.
Furthermore,
this
list
does
not
account
for
areas
that
may
receive
treatment
as
Early
Action
Compact
areas.
This
list
should
not
be
construed
as
a
proposal
by
EPA
of
areas
that
should
be
designated
non­
attainment.
Finally,
the
States
cannot
rely
solely
on
the
projections
of
future
attainment
contained
or
implied
herein
for
final
analyses
necessary
for
attainment
demonstrations
in
State
Implementation
Plans.
The
air
quality
values
for
2010
are
the
result
of
CAM­
X
simulations.
The
values
for
2007
are
the
result
of
linear
interpolation
of
2001
and
2010
values.
The
values
for
2013
are
the
result
of
linear
interpolating
of
2010
and
2015
CAM­
X
projections.
Refer
to
Docket
Number
OAR­
2003­
0079­
0682.
4­
08­
04
Draft
14
10/
15/
03
8­
HR
O3
NAAQS
HYPOTHETICAL
NONATTAINMENT
AREAS
(
2000­
2002
data)

Option
2
as
proposed
(
w/
o
incentive
feature)

A
B
C
D
E
F
G
H
I
AREA
1­
hr
DV
8­
hr
DV
Opt
2
no
inc
1hr
class
1hr
main
2007
2010
2013
Baton
Rouge,
LA
135
86
Marginal
Severe­
15
82
80
78
Beaumont­
Port
Arthur,
TX
144
90
Marginal
Moderate
81
79
78
Benton
Harbor,
MI
123
90
Marginal
82
78
76
Longview­
Marshall,
TX
122
88
Marginal
79
74
72
New
Orleans,
LA
122
85
Marginal
Sec185A
81
79
78
Portland,
ME
126
90
Marginal
Moderate
85
82
81
Richmond­
Petersburg,
VA
124
90
Marginal
Moderate
82
77
76
South
Bend­
Elkhart,
IN
123
90
Marginal
Marginal
83
78
76
St
Louis,
MO­
IL
123
90
Marginal
Serious
84
81
80
Syracuse,
NY
121
91
Marginal
85
82
81
Tulsa,
OK
122
87
Marginal
79
76
75
Atlanta,
GA
144
99
Moderate
Serious
90
86
83
Birmingham,
AL
127
92
Moderate
Marginal
82
76
72
Boston­
Lawrence­
Worcest
er
(
E.
MA),

MA­
NH
130
93
Moderate
Serious
86
82
81
Charlotte­
Gastonia­
Rock
Hill,
NC­
SC
130
102
Moderate
Moderate
91
85
83
Chicago­
Gary­
Lake
County,
IL­
IN
(
WI)
135
100
Moderate
Severe­
17
96
94
87
Cincinnati­
Hamilton,

OH­
KY­
IN
121
96
Moderate
Moderate
87
83
81
Cleveland­
Akron,
OH
128
99
Moderate
Moderate
92
88
86
Dallas­
Fort
Worth,
TX
135
99
Moderate
Serious
92
88
85
4­
08­
04
Draft
A
B
C
D
E
F
G
H
I
AREA
1­
hr
DV
8­
hr
DV
Opt
2
no
inc
1hr
class
1hr
main
2007
2010
2013
15
Grand
Rapids­
Muskeg
on­
Holland,
MI
123
92
Moderate
Moderate
86
82
80
Greater
Connecticut,
CT
139
100
Moderate
Serious
93
91
90
Greensboro­
Winston
Salem­
High
Point,
NC
121
95
Moderate
Moderate
84
78
75
Macon,
GA
125
92
Moderate
75
65
62
Memphis,
TN­
AR­
MS
123
94
Moderate
Marginal
89
86
85
Milwaukee­
Racine,
WI
134
100
Moderate
Severe­
17
96
94
93
Providence
(
All
RI),
RI
130
97
Moderate
Serious
92
89
86
Sacramento
Metro,
CA
143
106
Moderate
Severe­
15
NA
NA
NA
Sheboygan,
WI
123
99
Moderate
Moderate
93
90
88
Southeast
Desert
Modified
AQMA,
CA
(
LA
CMSA)
147
105
Moderate
Severe­
17
NA
NA
NA
Springfield
(
Western
MA),

MA
132
92
Moderate
Serious
86
83
82
Ventura
Co,
CA
(
part
of
LA
CMSA)
124
97
Moderate
Severe­
15
NA
NA
NA
Washington­
Baltimore,

DC­
MD­
VA­
WV
143
106
Moderate
Severe­
15
97
93
91
Houston­
Galveston­
Brazor
ia,
TX
175
107
Serious
Severe­
17
103
100
99
New
York­
N.
New
Jersey­
L.
Island,

NY­
NJ­
CT­
PA
149
115
Serious
Severe­
17
108
105
103
Philadelphia­
Wilmin­
Atlanti
c
Ci,
PA­
NJ­
MD­
D
E
143
107
Serious
Severe­
15
100
98
97
San
Joaquin
Valley,
CA
151
115
Serious
Severe­
15
NA
NA
NA
Los
Angeles
South
Coast
Air
Basin,
CA
(
LA
CMSA)
169
128
Severe­
17
Extreme
NA
NA
NA
count
4­
08­
04
Draft
A
B
C
D
E
F
G
H
I
AREA
1­
hr
DV
8­
hr
DV
Opt
2
no
inc
1hr
class
1hr
main
2007
2010
2013
16
Allentown­
Bethlehem­
East
on,
PA­
NJ
117
94
Subpart
1
87
83
81
Asheville,
NC
106
89
Subpart
1
76
70
68
Augusta­
Aiken,
GA­
SC
112
88
Subpart
1
80
75
73
Austin­
San
Marcos,
TX
103
85
Subpart
1
79
75
73
Bell
Co,
KY
(
SE
KY
at
TN
&
VA
border)
104
86
Subpart
1
75
69
67
Benzie
Co,
MI
(
N
on
Lake
Michigan)
116
86
Subpart
1
81
78
76
Bloomington,
IN
(
Greene
and
Jackson
Cos,
IN)
102
89
Subpart
1
81
77
75
Bowling
Green,
KY
104
86
Subpart
1
Marginal­
RT
76
70
68
Buffalo­
Niagara
Falls,
NY
116
97
Subpart
1
Marginal
92
90
88
Canton­
Massillon,
OH
109
89
Subpart
1
82
79
77
Charleston,
WV
105
85
Subpart
1
Moderate
75
69
67
Chattanooga,
TN­
GA
119
93
Subpart
1
81
75
73
Chico,
CA
107
89
Subpart
1
Sec185a
NA
NA
NA
Clarksville­
Hopkinsville,

TN­
KY
101
85
Subpart
1
72
65
63
Columbia,
SC
115
93
Subpart
1
83
77
74
Columbus,
OH
117
90
Subpart
1
Marginal
84
80
78
Dayton­
Springfield,
OH
112
90
Subpart
1
Moderate
83
78
76
Decatur,
AL
107
85
Subpart
1
77
73
71
Detroit­
Ann
Arbor­
Flint,
MI
119
88
Subpart
1
Moderate
85
84
86
Erie,
PA
108
88
Subpart
1
Marginal
82
79
78
Essex
Co,
NY
(
Whiteface
Mountain)
108
86
Subpart
1
Marginal­
RT
82
80
79
Evansville­
Henderson,

IN­
KY
108
87
Subpart
1
Marginal
79
75
74
Fayetteville,
NC
108
87
Subpart
1
77
73
71
Florence,
SC
103
86
Subpart
1
77
73
70
4­
08­
04
Draft
A
B
C
D
E
F
G
H
I
AREA
1­
hr
DV
8­
hr
DV
Opt
2
no
inc
1hr
class
1hr
main
2007
2010
2013
17
Fort
Wayne,
IN
104
88
Subpart
1
81
78
75
Green
Bay­
Appleton­
Oshko
sh­
Neenah­
Doo
r,
WI
110
91
Subpart
1
Marginal
RT
86
83
81
Greenville­
Spartanburg­
An
derson,
SC
114
90
Subpart
1
Marginal
80
74
71
Hancock
&
Waldo
Cos,

ME
120
93
Subpart
1
Marginal
85
81
78
Harrisburg­
Lebanon­
Carlis
le,
PA
114
94
Subpart
1
Marginal
85
80
78
Hickory­
Morganton­
Lenoir,

NC
110
91
Subpart
1
80
73
70
Huntington­
Ashland,

WV­
KY­
OH
115
88
Subpart
1
Moderate
80
76
74
Indianapolis,
IN
119
93
Subpart
1
Marginal
87
83
81
Jamestown,
NY
115
92
Subpart
1
86
83
82
Johnson
City­
Kingsport­
B
ristol,
TN­
VA
113
92
Subpart
1
81
74
72
Johnstown,
PA
106
88
Subpart
1
Marginal
80
76
74
Kansas
City,
MO­
KS
115
85
Subpart
1
Other
80
78
77
Knoxville,
TN
118
98
Subpart
1
Marginal
85
79
78
Lancaster,
PA
118
94
Subpart
1
Marginal
87
83
81
Lima,
OH
108
88
Subpart
1
82
78
76
Little
Rock­
North
Little
Rock,
AR
114
86
Subpart
1
80
76
74
Louisville,
KY­
IN
114
90
Subpart
1
Moderate
83
79
77
Mason
Co,
MI
(
N
on
Lake
Michigan)
116
87
Subpart
1
81
78
76
Murray
Co,
GA
(
E
of
Chattanooga)
104
87
Subpart
1
75
68
65
Nashville,
TN
116
88
Subpart
1
Moderate
80
76
74
Norfolk­
Virginia
Beach­
Newport
News,
VA­
NC
117
89
Subpart
1
Marginal
83
80
78
4­
08­
04
Draft
A
B
C
D
E
F
G
H
I
AREA
1­
hr
DV
8­
hr
DV
Opt
2
no
inc
1hr
class
1hr
main
2007
2010
2013
18
Owensboro,
KY­
IN
(
includes
Perry
Co,
IN)
115
90
Subpart
1
Marginal
76
72
72
Parkersburg­
Marietta,

WV­
OH
113
88
Subpart
1
Moderate
79
74
70
Phoenix­
Mesa,
AZ
107
85
Subpart
1
Serious
NA
NA
NA
Pittsburgh,
PA
(
WV)
119
95
Subpart
1
Moderate
89
85
84
Putnam
Co,
TN
(
between
Nashville
&

Knoxville)
102
86
Subpart
1
77
72
69
Raleigh­
Durham­
Chapel
Hill,
NC
118
94
Subpart
1
Moderate
85
81
77
Reading,
PA
113
93
Subpart
1
Moderate
85
81
79
Roanoke,
VA
107
87
Subpart
1
78
73
70
Rochester,
NY
110
85
Subpart
1
80
77
76
Rocky
Mount,
NC
106
88
Subpart
1
80
75
73
San
Antonio,
TX
119
86
Subpart
1
75
72
76
San
Diego,
CA
118
95
Subpart
1
Serious
NA
NA
NA
Scranton­
Wilkes­
Barre­
Ha
zleton,
PA
112
85
Subpart
1
Marginal
78
74
71
State
College,
PA
109
85
Subpart
1
78
74
72
Steubenville­
Weirton,

OH­
WV
110
86
Subpart
1
Sect­
185A
80
77
76
Toledo,
OH
111
89
Subpart
1
Moderate
84
81
80
Wheeling,
WV­
OH
109
85
Subpart
1
78
74
72
York,
PA
114
92
Subpart
1
Marginal
85
81
79
Youngstown­
Warren­
Shar
on,
PA­
OH
116
92
Subpart
1
Marginal
85
80
78
count
COL
DEFINITION
A
Name
of
hypothetical
8­
hr
O3
nonattainment
area
B
1­
hr
O3
design
value
for
2000­
2002
(
ppm
O3)

C
8­
hr
O3
design
value
for
2000­
2002
(
ppm
O3)
4­
08­
04
Draft
19
D
Area's
8­
hr
classification
under
proposed
classification
option
2
E
Area's
current
classification
if
nonattainment
under
1­
hr
O3
NAAQS
(
blank
if
maintenance
or
never
attainment)

F
No
entry
means
either
the
area
is
nonattainment
(
see
col.
D)
or
is
attainment
and
has
never
been
nonattainment.

Entry
indicates
area
is
designated
attainment
and
has
a
maintenance
plan­­
the
entry
is
the
area's
former
classification
G
8­
hr
O3
design
value
projected
to
2007
H
8­
hr
design
value
projected
tp
2010
I
8­
hr
design
value
projected
to
2013
