North
Carolina
Department
of
Environment
and
Natural
Resources
Division
of
Air
Quality
Michael
F.
Easley,
Governor
William
G.
Ross,
Jr.,
Secretary
B.
Keith
Overcash,
P.
E.,
Director
1641
Mail
Service
Center,
Raleigh,
North
Carolina
27699­
1641
2728
Capital
Blvd.,
Raleigh,
North
Carolina
27604
Phone:
919­
733­
3340
/
FAX
919­
715­
7175
/
Internet:
www.
ncair.
org
An
Equal
Opportunity/
Affirmative
Action
Employer
 
50%
Recycled/
10%
Post
Consumer
Paper
July
14,
2004
James
I.
Palmer,
Jr.,
Esq.
Regional
Administrator
U.
S.
EPA,
Region
IV
61
Forsyth
Street,
SW
Atlanta,
Georgia
30303­
3104
RE:
Request
to
Classify
Greensboro/
Winston­
Salem/
High
Point
area
as
Marginal
for
8­
hour
Ozone
Dear
Mr.
Palmer:

Pursuant
to
Section
181
(
a)
(
4)
of
the
Clean
Air
Act,
I
formally
request
that
the
Greensboro/
Winston­
Salem/
High
Point
(
Triad)
area's
nonattainment
classification
for
8­
hour
ozone
be
adjusted
from
moderate
to
marginal.
The
2001
 
2003
design
value
for
this
area
is
0.093
ppm,
well
within
five
percent
of
the
marginal/
moderate
threshold,
a
requirement
of
Section
181
(
a)
(
4).

There
are
nine
monitors
in
the
Triad
area.
Of
these
monitors,
only
two
have
design
values
above
the
marginal/
moderate
threshold
of
0.092
ppm,
Cooleemee
(
0.093
ppm)
located
in
Davie
County
and
Hattie
Avenue
(
0.093
ppm)
located
in
Forsyth
County.
One
of
the
monitors
in
the
area
is
attaining
the
8­
hour
ozone
standard
and
the
remaining
six
monitors
range
from
0.085
to
0.089
ppm,
all
within
the
marginal
classification
range.

The
design
values
for
two
monitors
that
determine
the
nonattainment
classification
for
the
area
have
steadily
decreased
since
1998,
from
0.098
to
0.093
ppm
for
Cooleemee
and
from
0.097
to
0.093
ppm
for
Hattie
Avenue.
This
reduction
is
in
part
because
North
Carolina
has
begun
implementing
emission
reduction
strategies
in
the
area.
I
believe
that
this
trend
will
continue
and
the
area
will
be
attaining
the
standard
at
all
of
its
monitors
within
a
few
short
years.
These
emission
reduction
strategies
include
our
expanded
inspection
and
maintenance
program,
going
from
nine
counties
to
48
counties
phased
in
through
January
1,
2006,
and
our
Clean
Smokestacks
Act,
adopted
in
2002,
that
will
reduce
emissions
from
power
plants
significantly
over
the
next
few
years.
Additionally,
this
area
is
participating
in
the
Early
Action
Compact
program
and
community
leaders
and
area
businesses
are
working
together
and
making
commitments
to
further
reduce
the
emissions
in
the
area.

One
of
the
considerations
for
adjusting
the
classification
of
an
area
is
the
number
of
exceedances
of
the
National
Ambient
Air
Quality
Standard
(
NAAQS).
In
2003,
the
Cooleemee
and
Hattie
Avenue
monitors
had
only
four
and
five
exceedances,
respectively.
Although
2003
was
a
cool
summer,
even
during
the
drought
conditions
of
2002,
these
two
monitors
only
had
15
(
Hattie
Avenue)
and
22
(
Cooleemee)
exceedances.
J.
I.
Palmer
USEPA,
Region
IV
July
14,
2004
page
2
of
2
2
Another
consideration
for
adjusting
the
classification
of
an
area
is
the
level
of
pollution
transport
between
the
area
and
other
affected
areas,
including
both
intrastate
and
interstate
transport.
There
are
three
areas
near
the
Triad
nonattainment
area
that
are
violating
the
8­
hour
ozone
NAAQS;
Raleigh/
Durham/
Chapel
Hill,
NC
(
Triangle)
area,
Hickory/
Morganton/
Lenoir,
NC
(
Unifour)
area,
and
Charlotte/
Gastonia/
Rock
Hill,
NC­
SC
(
Charlotte)
area.
I
believe
that
the
Triad
area
is
undertaking
appropriate
measures
to
address
transport
of
pollution
to
its
neighboring
urban
areas.
In
fact,
recent
air
quality
modeling
suggests
that
two
of
these
areas
(
Triangle
and
Unifour)
will
attain
the
8­
hour
ozone
standard
by
2007.

As
for
the
Charlotte
area,
it
is
believed
that
this
area
is
impacting
the
Triad
area
on
most
high
ozone
days,
and
not
the
other
way
around.
The
prevailing
winds
tend
to
be
from
the
southwest
during
the
ozone
season,
and
analysis
has
shown
that
on
the
highest
ozone
days
at
the
Cooleemee
monitor,
the
ozone
comes
from
Charlotte
area.
Additionally,
preliminary
modeling
shows
that
the
Charlotte
area
will
be
attaining
the
8­
hour
ozone
NAAQS
by
the
2010
attainment
date.

The
modeling
analysis
mentioned
above
is
presented
in
the
Triad
Area's
June
30,
2003
status
report
and
attached
herein.
The
emissions
trends
can
be
found
on
page
10
of
the
report.
The
emissions
data
shows
an
expected
decrease
in
NOx
emissions
of
about
382
tons
per
day
between
2000
and
2007.
Further
NOx
emissions
reductions
are
expected
beyond
2007
due
to
implementation
of
Federal,
State
and
local
control
measures.
The
VOC
emissions
will
decrease
by
20
tons
per
day
between
2000
and
2007.
Again,
further
reductions
are
expected
beyond
2007.
The
modeling
results
are
presented
on
pages
13
through
16
of
this
report.
All
monitors
are
expected
to
attain
by
2007.
Further
details
on
this
modeling
analysis
are
available
in
previous
Triad
Area
EAC
status
reports,
and
will
be
presented
as
part
of
the
Triad
EAC
SIP
to
EPA
in
December
2004.

North
Carolina
is
committed
to
conserving
and
protecting
our
natural
resources
and
maintaining
a
high
quality
environment
for
the
health,
well­
being
and
benefit
of
all.
We
believe
that
improving
air
quality
is
critical
to
the
health
of
our
citizens
and
that
our
future
growth,
prosperity
and
quality
of
life
will
be
threatened
if
we
do
not
remain
diligent.
With
the
rules
and
legislation
that
North
Carolina
has
already
enacted,
I
believe
that
the
Triad
area
will
attain
the
8­
hour
ozone
NAAQS
without
having
to
implement
the
control
measures
prescribed
by
the
moderate
classification.
It
is
because
of
North
Carolina's
demonstrated
commitment
to
air
quality
that
I
request
you
to
consider
adjusting
the
Triad
area's
nonattainment
classification
from
moderate
to
marginal.

Please
contact
Sheila
Holman
at
(
919)
715­
0971
should
you
have
any
questions
regarding
this
request.

Sincerely,

B.
Keith
Overcash,
P.
E.

BKO/
sh
cc:
Secretary
Bill
Ross
Brock
Nicholson
Sheila
Holman
Bob
Fulp
