
July
12,
2004
Mr.
Donald
S.
Welsh
Regional
Administrator
EPA
Region
III
1650
Arch
Street
Philadelphia,
PA
19103­
2029
Dear
Mr.
Welsh:

Pursuant
to
Section
181(
a)
(
4)
of
the
Clean
Air
Act
and
on
behalf
of
the
Governor
of
the
Commonwealth
of
Virginia,
I
am
hereby
submitting
a
formal
petition
for
consideration
to
EPA
Region
III.
The
purpose
of
this
petition
is
request
that
EPA
reclassify
the
Richmond
area
from
a
moderate
to
marginal
nonattainment
area
under
the
8­
hour
Ozone
National
Ambient
Air
Quality
Standard
(
NAAQS).
Such
a
request
is
allowed
by
the
Act
if
the
design
value
in
an
area
is
within
five
percent
(
5%)
of
the
lower
classification
level.
Specifically,
in
the
case
of
the
Richmond
area,
the
current
design
value
is
94
parts
per
billion
which
is
within
the
allowed
5%
range
for
reclassification
consideration.

Enclosed
is
a
detailed
technical
analysis
document
developed
to
support
this
petition
and
request.
This
document
contains
analyses
of
monitoring,
modeling,
and
emissions
data
for
the
Richmond
area.
In
summary,
these
analyses
support
the
reclassification
request
in
that:

 
Monitoring
data
and
trends
in
the
area
are
mainly
indicative
of
a
marginal
ozone
nonattainment
area.
 
Various
DEQ
and
EPA
modeling
exercises
indicate
that
the
area
is
likely
to
attain
the
8­
hour
ozone
as
soon
as
2007.
 
An
emissions
analysis
indicates
that
substantial
emission
reductions
will
be
achieved
in
the
area
by
2007.

We
believe
that
this
document
presents
a
compelling
case
to
support
the
reclassification
of
the
Richmond
area
to
the
lower
marginal
nonattainment
classification.
Donald
S.
Welsh
July
12,
2004
page
two,
Virginia
Ozone
Reclassification
Letter
Thank
you
for
the
opportunity
submit
this
petition
and
for
your
consideration
of
this
request.
Please
contact
me
if
you
have
any
questions
concerning
this
petition
and
supporting
information.

Sincerely,

Robert
G.
Burnley
Enclosure
cc:
W.
Tayloe
Murphy,
Jr.
Judith
Katz
John
M.
Daniel,
Jr.
