1Section
182(
b)(
3)
specifies
that
EPA
would
approve
any
request
from
a
State
to
reclassify
to
a
higher
classification.

1
Technical
Support
Document
for
Richmond,
Virginia
September
2004
1.0
Summary
The
EPA
designated
this
area
as
moderate
on
April
15,
2004
due
to
8­
hour
ozone
values
(
design
value
is
94
ppb).
On
July
12,
2004
the
Virginia
Department
of
the
Environmental
Quality
submitted
a
request
to
reclassify
Richmond
from
moderate
to
marginal
ozone
nonattainment.

2.0
Introduction
This
section
describes
the
statutory
provisions
and
EPA
guidance
regarding
reclassification
of
ozone
nonattainment
areas.
Sections
181(
a)(
4)
and
182(
b)(
3)
of
the
Clean
Air
Act
provide
that
areas
may
be
reclassified
under
certain
circumstances.
This
technical
support
document
addresses
the
provisions
of
section
181(
a)(
4)
and
a
specific
request
for
reclassifications
received
by
the
State
of
Indiana.
The
EPA
has
not
received
any
requests
for
reclassification
under
section
182(
b)(
3)
for
the
8­
hour
ozone
standard.
1
Under
section
181(
a)(
4),
an
ozone
nonattainment
area
may
be
reclassified
"
if
an
area
classified
under
paragraph
(
1)
(
Table
1)
would
have
been
classified
in
another
category
if
the
design
value
in
the
area
were
5
percent
greater
or
5
percent
less
than
the
level
on
which
such
classification
was
based."
In
the
April
30,
2004
notice,
we
indicated
that
an
area
with
a
moderate
design
value
of
96
ppb
(
or
less)
would
be
eligible
to
request
a
bump
down
because
five
percent
less
than
96
ppb
is
91
ppb,
a
marginal
design
value.

The
EPA
previously
described
criteria
to
implement
the
section
181(
a)(
4)
provisions
in
a
final
rule
designating
and
classifying
areas
published
on
November
6,
1991
(
56
FR
56698).
As
stated
in
that
notice,
the
provisions
of
section
181(
a)(
4)
set
out
general
criteria
and
grant
the
Administrator
broad
discretion
in
making
or
determining
not
to
make,
a
reclassification.
As
part
of
the
1991
action,
EPA
developed
more
specific
criteria
to
evaluate
whether
it
is
appropriate
to
reclassify
a
particular
area.
The
EPA
also
described
these
criteria
in
the
April
30,
2004
final
rule.
The
general
and
specific
criteria
are
as
follows:
2
General:
The
EPA
may
consider
the
number
of
exceedances
of
the
national
primary
ambient
air
quality
standard
for
ozone
in
the
area,
the
level
of
pollution
transport
between
the
area
and
other
affected
areas,
including
both
intrastate
and
interstate
transport,
and
the
mix
of
sources
and
air
pollutants
in
the
area.

Request
by
State:
The
EPA
does
not
intend
to
exercise
its
authority
to
bump
down
areas
on
EPA's
own
initiative.
Rather,
EPA
intends
to
rely
on
the
State
to
submit
a
request
for
a
bump
down.
A
Tribe
may
also
submit
such
a
request
and,
in
the
case
of
a
multi­
state
nonattainment
area,
all
affected
States
must
submit
the
reclassification
request.

Discontinuity:
A
five
percent
reclassification
must
not
result
in
an
illogical
or
excessive
discontinuity
relative
to
surrounding
areas.
In
particular,
in
light
of
the
areawide
nature
of
ozone
formation,
a
reclassification
should
not
create
a
"
donut
hole"
where
an
area
of
one
classification
is
surrounded
by
areas
of
higher
classification.

Attainment:
Evidence
should
be
available
that
the
proposed
area
would
be
able
to
attain
by
the
earlier
date
specified
by
the
lower
classification
in
the
case
of
a
bump
down.

Emissions
reductions:
Evidence
should
be
available
that
the
area
would
be
very
likely
to
achieve
the
appropriate
total
percent
emission
reduction
necessary
in
order
to
attain
in
the
shorter
time
period
for
a
bump
down.

Trends:
Near­
and
long­
term
trends
in
emissions
and
air
quality
should
support
a
reclassification.
Historical
air
quality
data
should
indicate
substantial
air
quality
improvement
for
a
bump
down.
Growth
projections
and
emission
trends
should
support
a
bump
down.
In
addition,
we
will
consider
whether
vehicle
miles
traveled
and
other
indicators
of
emissions
are
increasing
at
higher
than
normal
rates.

Years
of
data:
For
the
8­
hour
ozone
standard,
the
2001­
2003
period
is
central
to
determining
classification.
Data
from
2004
may
be
used
to
corroborate
a
bump
down
request
but
should
not
be
the
sole
foundation
for
the
bump
down
request.

Limitations
on
Bump
Downs
An
area
may
only
be
reclassified
to
the
next
lower
classification.
An
area
cannot
present
data
from
other
3
years
as
justification
to
be
reclassified
to
an
even
lower
classification.
In
addition,
section
181(
a)(
4)
does
not
permit
moving
areas
from
subpart
2
into
subpart
1.

In
1991,
EPA
approved
reclassifications
when
the
area
met
the
first
requirement
(
a
request
by
the
State
to
EPA)
and
at
least
some
of
the
other
criteria
and
did
not
violate
any
of
the
criteria
(
emissions,
reductions,
trends,
etc.).
In
our
April
30,
2004
final
rule
on
designations
and
classifications,
we
stated
our
intention
to
use
this
method
and
these
criteria
once
again
to
evaluate
reclassification
requests
under
section
181(
a)(
4),
with
minor
changes
described
in
that
notice.
In
that
notice
we
also
described
how
we
applied
these
criteria
in
1991.
For
additional
information,
see
section
5,
"
Areas
requesting
a
5%
downshift
per
§
181(
a)(
4)
and
EPA's
response
to
those
requests,"
of
the
Technical
Support
Document,
October
1991,
for
the
1991
rule.
[
Docket
A­
90­
42A.]

The
EPA
is
not
basing
this
reclassification
determination
on
consideration
of
whether
the
nonattainment
area
being
reclassified
does
or
does
not
cause
any
pollution
transport.
The
EPA
is
presently
addressing
ozone
pollution
transport
issues
throughout
the
eastern
part
of
the
United
States
under
other
Clean
Air
Act
provisions.
Specifically,
EPA
has
proposed
a
determination
that
emissions
from
certain
states
contribute
significantly
to
downwind
nonattainment
for
ozone
under
CAA
section
110(
a)(
2)(
D)
through
the
Clean
Air
Interstate
Rule
(
CAIR).
The
CAIR
proposal,
published
in
a
Federal
Register
notice
dated
January
30,
2004,
would
require
upwind
States
to
eliminate
emissions
that
contribute
significantly
to
nonattainment
in
downwind
States.
69
Fed.
Reg.
454566.
The
EPA
previously
issued
the
NOx
SIP
call
(
63
FR
57356)
to
address
interstate
ozone
transport.
In
the
event
of
any
intrastate
transport
issue,
states
have
the
obligation
to
develop
attainment
SIPs
for
each
area
that
show
timely
attainment,
and
can
address
any
intrastate
transport
issues
in
that
context.

The
April
30,
2004
notice
invited
States
to
submit
the
reclassification
requests
within
30
days
of
the
effective
date
of
the
designations
and
classifications.
The
effective
date
was
June
15
which
means
that
reclassification
requests
were
to
be
submitted
by
July
15,
2004.
This
relatively
short
time
frame
is
necessary
because
section
181(
a)(
4)
only
authorizes
the
Administrator
to
make
such
reclassifications
within
90
days
after
the
initial
classification,
September
15,
2004.

3.0
Background
4
The
EPA
designated
this
area
as
moderate
on
April
15,
2004
due
to
8­
hour
ozone
values
(
design
value
is
94
ppb).
On
July
12,
2004
the
Virginia
Department
of
the
Environmental
Quality
submitted
a
request
to
reclassify
Richmond
from
moderate
to
marginal
ozone
nonattainment.
The
Richmond,
VA
moderate
ozone
nonattainment
area
consists
of
five
counties
(
Charles
City,
Chesterfield,
Hanover,
Henrico,
and
Prince
George)
and
four
independent
cities
(
Colonial
Heights,
Hopewell,
Petersburg,
and
Richmond).
This
area
is
adjacent
to
the
southeast
edge
of
the
Washington
D.
C.
moderate
8­
hour
ozone
nonattainment
area.

4.0
Reclassification
Request
by
State
The
Virginia
DEQ
supports
their
reclassification
request
with
analyses
of
ambient
air
quality
monitoring
data
and
trends
in
the
area,
various
DEQ
and
EPA
modeling
exercises
which
indicate
that
the
area
is
likely
to
attain
the
8­
hour
ozone
as
soon
as
2007,
and
an
emissions
analysis
which
indicates
that
substantial
emission
reductions
will
be
achieved
in
the
area
by
2007.

5.0
EPA
Review
of
Reclassification
Request
5.1
Request
by
State
On
July
12,
2004,
Virginia
DEQ
submitted
a
request
to
EPA
to
bump­
down
the
Richmond,
VA
moderate
ozone
nonattainment
area
from
"
moderate"
to
"
marginal."

5.2
Discontinuity
The
Richmond,
VA
moderate
ozone
nonattainment
area
consists
of
five
counties
(
Charles
City,
Chesterfield,
Hanover,
Henrico,
and
Prince
George)
and
four
independent
cities
(
Colonial
Heights,
Hopewell,
Petersburg,
and
Richmond).
This
area
is
adjacent
to
the
southeast
edge
of
the
Washington
D.
C.
moderate
8­
hour
ozone
nonattainment
area.
To
the
northeast
of
Richmond,
and
across
the
Chesapeake
Bay,
is
the
Philadelphia
moderate
8­
hour
ozone
nonattainment
area.
Richmond
is
also
adjacent
to
and
located
to
the
northwest
of
the
Norfolk­
Virginia
Beach,
VA
subpart
1
8­
hour
ozone
nonattainment
area.
Reclassification
of
the
Richmond
area
will
not
create
a
discontinuity
since
there
would
be
no
area
of
one
classification
surrounded
by
areas
of
a
higher
classification.

5.3
Attainment
The
modeling
performed
by
Virginia
for
demonstrating
attainment
in
Richmond
by
2007
was
based
on
modeling
conducted
for
the
5
Roanoke,
VA
EAC.
While
not
optimized
for
the
Richmond
area,
this
modeling
can
be
used
to
indicate
whether
Richmond
might
attain
by
2007.
However,
VA
found
errors
in
the
emissions
inventory.
Virginia
re­
ran
their
EAC
modeling
with
improved
emissions
data.
The
revised
EAC
modeling
projects
attainment
in
the
Richmond
area
in
2007.
The
highest
of
these
projected
design
values
is
84.1
ppb
for
the
Hanover
monitor.

To
provide
additional
evidence
that
the
Richmond
area
is
likely
to
attain
in
2007,
relative
reduction
factors
were
developed
by
the
State
based
on
the
NOx
SIP
call
and
the
Heavy
Duty
Diesel
Rule
modeling
for
the
Richmond
area,
resulting
in
projected
2007
ozone
design
values
of
81.5
ppb
and
82.5
ppb,
respectively.
Because
the
CAIR
regional
modeling
uses
more
up­
to­
date
data
and
methodologies
than
the
NOx
SIP
Call
or
Heavy
Duty
Diesel
Rule
modeling,
EPA
is
not
relying
on
these
two
older
analyses
for
purposes
of
the
bump
down.

The
EPA's
January
2004
CAIR
modeling
projects
Richmond's
ozone
concentrations
to
be
well
below
the
ozone
standard
in
2010
(
77
ppb).
Although
neither
analysis
is
as
comprehensive
an
assessment
as
would
be
expected
with
a
SIP
attainment
demonstration,
together
they
provide
support
that
the
Richmond
area
will
attain
the
ozone
standard
by
2007.

5.4
Emission
Reductions
On
August
30,
2004,
the
Director
of
Virginia's
Department
of
Environmental
Quality
submitted
a
letter
to
EPA
(
followed
up
by
a
letter
on
September
2,
2004
from
the
VA
Air
Director)
committing
to
adopt
additional
emission
control
measures
to
reduce
ozone
levels.
Several
of
these
measures
are
already
in
place
in
the
smaller
1­
hour
Richmond
ozone
nonattainment
area
or
in
the
northern
Virginia
(
Washington
D.
C.)
1­
hour
ozone
nonattainment
area.
This
letter
stated
that
control
measures
such
as
reformulated
gasoline,
stage
I,
and
existing
source
RACT
regulations
would
be
extended
into
the
larger
Richmond
8­
hour
ozone
nonattainment
area.
The
northern
Virginia
control
measures
(
solvent
cleaning,
architectural
and
maintenance
coatings,
motor
vehicle
refinishing,
and
portable
fuel
containers)
would
be
studied
and
the
process
of
adoption
for
the
Richmond
8­
hour
ozone
nonattainment
area
would
commence.
Therefore,
the
emissions
trend
is
expected
to
decrease
due
to
the
implementation
of
various
local,
regional,
and
national
rules.

In
the
Richmond
area,
Virginia
has
implemented
RACT
and
NSR
requirements
under
the
1
hour
ozone
standard.
Richmond
was
redesignated
to
attainment
for
the
1
hour
ozone
standard
on
6
December
17,
1997
(
62
FR
61237).
Richmond,
VA
was
designated
a
moderate
1hour
ozone
nonattainment
area
in
1991
by
EPA
(
56
FR
56694,
November
6,
1991)
but
in
1997,
EPA
made
a
determination
that
the
Richmond
area
was
monitoring
attainment
of
the
1
hour
ozone
standard
and
made
inapplicable
certain
Part
D
requirements,
including
RFP
and
attainment
demonstration
requirements
(
62
FR
52029,
October
6,
1997).
EPA's
determination
of
inapplicability
of
certain
Part
D
requirements
was
made
using
a
May
10,
1995
EPA
memorandum
("
Reasonable
Further
Progress,
Attainment
Demonstration,
and
Related
Requirements
for
Ozone
Nonattainment
Areas
Meeting
the
Ozone
National
Ambient
Air
Quality
Standard").
As
a
result,
Richmond
did
not
implement
I/
M
or
NOx
RACT
and
did
not
complete
a
15%
plan
or
attainment
demonstration
as
a
moderate
1hr
ozone
nonattainment
area.

5.5
Trends
The
2004
ozone
data
in
the
Richmond
areas
show
that
a
downward
trend
in
ozone
concentrations
is
continuing.
This
data
(
to
date)
show
that
one
monitor
is
in
attainment
and
the
remaining
three
area
monitors
are
within
the
marginal
nonattainment
range
as
shown
by
the
updated
design
values
(
2002­
2004)
provided
below:

Richmond
Ozone
Monitor
Design
Values
(
2002
to
2004)
Chesterfield
82
ppb
(
attainment)
Henrico
85
ppb
(
marginal
nonattainment)
Hanover
90
ppb
(
marginal
nonattainment)
Charles
City
87
ppb
(
marginal
nonattainment)

It
can
be
expected
that
ozone
values
will
decline
due
to
the
implementation
of
local,
regional,
and
national
rules
relative
to
ozone
levels
in
recent
years.

From
the
8
hour
ozone
designations
analysis,
population
growth
(
from
1990
to
2001)
in
the
Richmond
area
varies
but
in
general
there
is
moderate
growth
(
relative
to
other
Region
III
counties)
in
the
counties
and
a
reduction
in
population
in
the
independent
cities.
VMT
growth
also
varies
depending
on
the
specific
county/
independent
city
but
overall,
VMT
growth
is
moderate,
when
compared
to
other
Region
III
counties.

5.6
Years
of
Data
Virginia
has
appropriately
evaluated
Richmond
based
on
the
2003
ozone
design
value,
which
uses
ozone
data
from
2001,
2002
and
2003.
The
2003
ozone
design
value
for
Richmond,
VA
is
94
ppb.

5.7
Additional
Information
7
In
addition
to
the
technical
information
and
analyses
provided
as
part
of
this
process,
the
State
plans
to
proactively
evaluate
and
implement
additional
controls
in
the
Richmond
area
to
further
improve
local
and
regional
air
quality.
First,
because
the
geographic
area
of
the
Richmond
nonattainment
area
has
increased
under
the
8­
hour
ozone
standard,
the
State
will
begin
the
process
to
extend
certain
nonattainment
requirements
to
the
additional
jurisdictions
involved
to
satisfy
basic
nonattainment
requirements
and
area
equity
issues.
These
jurisdictions
include
Charles
City
County,
Prince
George
County,
and
the
City
of
Petersburg.
This
action
will
include
the
implementation
of
such
measures
as
reformulated
gasoline,
stage
I
vapor
recovery,
and
other
existing
source
(
RACT)
controls.
The
State
hopes
to
have
these
measures
implemented
in
the
extended
area
by
the
summer
of
2006.
The
State
will
initiate
the
process
of
extending
some
or
all
of
the
"
Ozone
Transport"
controls
on
various
area
sources
to
the
Richmond
area.
These
measures
have
been
or
are
being
adopted
in
the
Northern
Virginia
portion
of
the
Washington,
D.
C.
1­
hour
ozone
nonattainment
area.
However,
because
the
Lead
Planning
Organization
(
LPO)
for
the
Richmond
area
has
not
yet
been
established,
the
State's
commitment
is
contingent
upon
the
review
and
discussion
of
these
controls
by
this
group.
Measures
that
are
formally
selected
in
the
Richmond
area
may
be
implemented
by
the
summer
of
2006.
Beyond
the
controls
mentioned
above,
the
Virginia
Legislature
has
initiated
the
evaluation
of
two
additional
ozone
precursor
control
programs.
First,
a
report
and
plan
has
been
developed
for
the
implementation
of
a
remote­
sensing
program
for
vehicle
emissions
in
several
areas
of
Virginia,
including
Richmond.
Second,
the
agency
is
currently
working
with
interested
parties
and
plans
to
support
a
utility
bill
similar
to
the
North
Carolina
"
Clean
Smokestacks"
program.

5.8
Conclusions
The
following
factors
support
the
request
for
reclassification
to
marginal
for
the
Richmond
area:
the
design
value
of
94
ppb
meets
our
criteria
to
qualify
for
consideration
of
bump
down,
local
and
regional
modeling
together
with
declining
emissions
from
local,
regional
and
national
regulations
support
the
conclusion
that
Richmond
is
likely
to
attain
by
2007.

5.9
EPA
Action
Thhe
request
meets
certain
criteria
EPA
established
(
request,
discontinuity,
emission
reductions,
attainment,
and
data)
and
does
not
violate
any
of
the
criteria
(
trends).
Therefore,
EPA
is
approving
the
reclassification
request
for
the
Richmond
area.
8
6.0
Additional
Information
Additional
information
regarding
the
bump
down
request
for
this
area
is
contained
in
the
docket
for
this
action.
This
information
includes
the
State
request,
supporting
documents,
and
other
necessary
material.
