1Section
182(
b)(
3)
specifies
that
EPA
would
approve
any
request
from
a
State
to
reclassify
to
a
higher
classification.
Technical
Support
Document
for
Lancaster,
Pennsylvania
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
92
ppb).
On
July
9,
2004
the
Pennsylvania
Department
of
Environmental
Protection
submitted
a
request
to
reclassify
Lancaster
County
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:

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
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
Lancaster,
PA
was
designated
moderate
nonattainment
under
the
8
hour
ozone
standard
on
April
15,
2004.
Lancaster's
design
value
is
92
ppb.

4.0
Reclassification
Request
by
State
The
State's
request
is
based
on
a
comparison
of
Lancaster
County,
"
marginal"
nonattainment
areas
and
other
nonattainment
areas
within
Pennsylvania.
The
comparison
addresses:
1­
hr
and
8­
hr
design
values,
8­
hr
ozone
exceedances,
1999
NEI
NOx
and
VOC
emissions,
2000
Census
population
figures,
an
analysis
of
potential
transport
into
and
out
of
Lancaster
County,
an
analysis
of
regional
nonattainment
designations,
and
an
analysis
of
EPA's
NOx
SIP
Call
Modeling.

5.0
EPA
Review
of
Reclassification
Request
5.1
Request
by
State
On
July
9,
2004,
the
Pennsylvania
Department
of
Environmental
Protection
submitted
a
request
to
EPA
to
bump­
down
Lancaster,
PA
moderate
ozone
nonattainment
area
from
"
moderate"
to
"
marginal."

5.2
Discontinuity
Lancaster,
PA
is
a
single
county
8
hour
ozone
nonattainment
area
located
immediately
west
of
the
Philadelphia
moderate
8
hour
ozone
nonattainment
area
and
immediately
north
of
the
Baltimore
moderate
8
hour
ozone
nonattainment
area.
The
counties
adjacent
to
and
surrounding
Lancaster
on
its
west
and
north
are
designated
subpart
1
("
basic")
8
hour
ozone
nonattainment
areas.
Reclassification
of
Lancaster
County
will
not
create
a
discontinuity
since
there
would
be
no
area
of
one
classification
surrounded
by
areas
of
a
higher
classification.

5.3
Attainment
Pennsylvania's
submittal
included
the
use
of
EPA's
NOx
State
Implementation
Plan
(
SIP)
call
regional
modeling
analyses
to
demonstrate
that
Lancaster,
PA
can
attain
by
the
2007
marginal
classification
attainment
date
rather
than
by
the
2010
moderate
classification
attainment
date.
Pennsylvania
correctly
obtained
the
appropriate
RRF
from
the
NOx
SIP
call
modeling
(
1996
base
year
and
2007
projection)
but
then
incorrectly
multiplied
it
with
the
2003
ozone
design
value
for
Lancaster.
However,
applying
the
NOx
SIP
call
RRF
to
the
greater
of
the
1997
ozone
design
value
or
the
2003
ozone
design
value
produced
83.6
ppb.
Because
the
CAIR
regional
modeling
uses
more
up­
to­
date
data
and
methodologies
than
the
NOx
SIP
Call
modeling,
EPA
is
not
relying
on
the
NOx
SIP
Call
modeling
for
purposes
of
the
bump
down.

The
EPA's
January
2004
CAIR
modeling
projects
attainment
for
Lancaster
County,
MD
in
the
2010
attainment
year
(
83
ppb).
No
local
air
quality
modeling
is
available.
The
EPA
believes
the
CAIR
modeling
analysis
is
not
conclusive
with
respect
to
Lancaster's
attainment
status
in
2007.
The
analysis
is
not
as
comprehensive
an
assessment
as
would
be
expected
with
a
SIP
attainment
demonstration.
However
the
CAIR
analysis
provides
support
for
a
decision
to
reclassify
the
area
since
it
indicates
air
quality
will
be
improving
over
the
next
several
years.

5.4
Emission
Reductions
The
emissions
trend
is
expected
to
decrease
due
to
the
implementation
of
various
regional
rules,
including
the
NOx
SIP
Call
and
rules
contained
in
1­
hour
ozone
attainment
plans
in
the
Baltimore,
Philadelphia
and
Washington
D.
C.
areas.
In
addition,
because
the
state
of
Pennsylvania
is
located
in
the
statutorilyestablished
Ozone
Transport
Region
(
OTR),
Lancaster
County
has
been
implementing
moderate
nonattainment
area
level
emission
controls.
Moderate
area
OTR
controls
include
RACT,
NSR,
and
Stage
II
comparable
measures.
Further,
Lancaster
has
an
OTR
enhanced
I/
M
program
that
became
state
law
in
November
2003
and
has
been
implemented
since
February
2004.
On
August
23,
2004,
PA
submitted
a
list
of
emission
control
measures
effective
in
Lancaster,
PA.
This
list
includes
federal
and
state
measures
such
as
autobody
refinishing,
solvent
cleaning,
consumer
products,
portable
fuel
container
requirements
and
enhanced
I/
M.

5.5
Trends
The
area's
design
value
is
92
ppb,
just
one
ppb
above
the
marginal
classification
design
value
based
on
2001
­
2003
data.
The
17­
year
ozone
air
quality
trends
in
Lancaster
County
are
relatively
flat.
The
short­
term
trend
in
the
4th
highest
8­
hour
ozone
value
over
the
last
3
years
is
downward
(
97,
96,
and
83
ppb).
Further,
it
can
be
expected
that
ozone
values
will
decline
due
to
the
implementation
of
national
and
regional
rules
relative
to
ozone
levels
in
recent
years.

Population
growth
(
from
1990
to
2001)
in
Lancaster,
PA,
relative
to
other
Region
III
counties
is
moderate
while
VMT
growth
in
Lancaster
(
also
relative
to
other
Region
III
counties)
is
relatively
high.

5.6
Years
of
Data
Pennsylvania
has
appropriately
evaluated
Lancaster
based
on
the
2003
ozone
design
value,
which
uses
ozone
data
from
2001,
2002
and
2003.
The
2003
ozone
design
value
for
Lancaster,
PA
is
92
ppb.

5.7
Additional
Information
On
August
23,
2004,
Pennsylvania
submitted
some
additional
modeling
information
generated
using
a
PC­
based
CALGRID
developed
for
the
Ozone
Transport
Commission.
This
modeling
showed
that
the
ozone
contribution
from
Lancaster,
PA
is
not
significant
when
compared
to
the
ozone
transport
contribution
from
the
entire
state
of
Pennsylvania
and
that
contributions
from
Lancaster
are
generally
to
areas
within
Pennsylvania.
This
is
supported
by
the
relatively
small
VOC
and
NOx
emissions
of
Lancaster,
PA
when
compared
with
the
total
VOC
and
NOx
emissions
of
Pennsylvania
(
4%
VOC
emissions
and
3%
NOx
emissions).

5.8
Conclusions
The
following
factors
support
the
request
for
reclassification
to
marginal
for
Lancaster
County:
the
design
value
of
92
ppb
meets
our
criteria
to
qualify
for
consideration
of
bump
down,
CAIR
modeling
indicates
air
quality
will
be
improving
over
the
next
several
years,
and
additional
reductions
from
regional
and
national
regulations
should
lower
ambient
ozone
values.

5.9
EPA
Action
The
request
meets
certain
criteria
EPA
established
(
request,
discontinuity,
emission
reductions,
and
data)
and
does
not
violate
any
of
the
criteria
(
attainment
and
trends).
Therefore,
EPA
is
approving
the
reclassification
request
for
Lancaster
County.

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.
