1Section
182(
b)(
3)
specifies
that
EPA
would
approve
any
request
from
a
State
to
reclassify
to
a
higher
classification.
Technical
Support
Document
for
Greensboro,
North
Carolina
September
2004
1.0
Summary.

The
State
of
North
Carolina
presented
a
petition
to
EPA,
Region
4,
requesting
downward
reclassification
of
the
Greensboro/
Winston­
Salem/
High
Point
(
Triad)
Ozone
Nonattainment
Area
from
Moderate
to
Marginal
for
the
8­
hour
standard.
The
petition
was
presented
to
EPA
July
14,
2004.
The
petition
is
based
on
the
area's
Moderate
design
value
of
0.093
parts
per
million
(
ppm)
being
within
5
percent
of
the
maximum
Marginal
design
value
of
0.091
ppm
as
allowed
by
the
Clean
Air
Act.

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.]

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.

The
Triad
area
was
designated
nonattainment
for
the
8­
hour
ozone
standard
on
April
15,
2004,
and
classified
"
Moderate"
based
on
a
design
value
of
0.093
ppm.
The
modeling
was
developed
according
to
EPA's
draft
8­
hour
ozone
modeling
guidance
and
it
was
used
to
support
a
deferral
of
the
effective
date
for
the
nonattainment
area.
The
recently
revised
Triad
Metropolitan
Statistical
Area
(
MSA),
which
has
a
population
of
over
1.3
million,
includes
Davidson,
Davie,
Forsyth,
Guilford,
Alamance,
Caswell,
Randolph,
and
Rockingham
counties.
In
2000,
Davie
County
had
a
population
of
just
over
34,000
(
which
includes
the
Cooleemee
monitor),
while
Forsyth
County
reported
a
population
of
306,000
(
which
includes
the
Hattie
monitor)
and
Guilford
County
had
a
population
of
over
421,000.
The
remaining
counties
had
the
following
populations:
Davidson,
147,000;
Randolph,
over
130,000;
Stokes,
over
44,000;
Yadkin,
over
36,000;
Rockingham,
over
91,000
and
Caswell,
under
24,000.

There
are
nine
monitors
in
the
Triad
area.
Two
monitors
have
a
design
value
of
0.093
ppm
which
is
above
the
moderate
threshold
but
within
5
percent
of
the
marginal
category:
the
Cooleemee
monitor
located
in
Davie
County
and
the
Hattie
monitor
in
Forsyth
County.
One
of
the
monitors
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.

4.0
Reclassification
Request
by
States.

The
State's
request
and
the
rationale
is
as
follows:

1.
Request
by
State:
The
State
of
North
Carolina
presents
this
petition.

2.
Discontinuity:
The
Triad
area
is
downwind
of
the
Charlotte
moderate
nonattainment
area.
Although
this
area
has
a
later
attainment
date,
attainment
by
2007
for
the
Triad
area
should
not
be
affected.
Local
photochemical
grid
modeling
for
the
Triad
area
includes
emissions
and
emissions
reductions
from
the
Charlotte
nonattainment
area.
Attainment
is
still
indicated.

3.
Attainment:
Local
photochemical
grid
modeling,
developed
under
the
Early
Action
Compact
(
EAC)
program,
demonstrates
attainment
of
the
Triad
area
which
includes
the
Greensboro
MSA.

4.
Emissions
Reductions:
Appropriate
and
achievable
emissions
reductions
are
detailed
in
the
petition
and
the
EAC
progress
report
submittals.

5.
Trends:
Since
1998,
monitored
ozone
levels
at
the
Greensboro
MSA
monitors
have
steadily
decreased
and
support
reclassification.

6.
Years
of
Data:
2001­
2003
air
quality
data
was
used
to
designate
the
nonattainment
area.

5.0
EPA
Review
of
the
Reclassification
Request.

5.1
Request
by
State.

The
state
of
North
Carolina
submitted
the
petition
by
the
date
required;
July
15,
2004.

5.2
Discontinuity.

The
modeling
screening
tests
documented
in
the
petition
demonstrate
that
no
discontinuity
exists
with
surrounding
areas.
Surrounding
areas
include
the
Charlotte
area
which
has
the
same
classification,
and
the
Raleigh
area
which
has
a
lower
classification.
The
Charlotte
attainment
date
of
2010
is
later
than
the
Triad
attainment
date
of
2007.
There
are
three
areas
near
the
Triad
nonattainment
area
that
are
violating
the
8­
hour
NAAQS
based
on
2001­
2003
data;
Raleigh/
Durham/
Chapel
Hill
(
Triangle)
area,
Hickory/
Morganton/
Lenoir
(
Unifour),
and
Charlotte/
Gastonia/
Rock
Hill
area
(
Charlotte).
The
EAC
air
quality
modeling
indicates
that
two
of
these
areas
will
attain
the
standard
by
2007
(
Triangle
and
Unifour).
Local
controls
are
being
implemented
to
reduce
the
impact
of
regional
transport
from
the
remaining
nonattainment
area
(
Charlotte).

5.3
Attainment.

Local
photochemical
grid
modeling,
developed
under
the
EAC
program,
demonstrates
attainment
for
the
Triad
area
which
includes
the
Greensboro
MSA.
The
modeling
predicts
a
2007
future
design
value
of
0.084
ppm
for
the
Triad
area
which
indicates
attainment.
Eight
of
the
nine
monitors
are
projected
to
be
at
0.08
ppm
or
below.
In
addition,
the
EAC
modeling
for
2010
also
indicates
maintenance
of
the
8­
hr
ozone
NAAQS.
The
modeling
was
developed
according
to
EPA's
draft
8­
hour
ozone
modeling
guidance
and
was
used
to
support
a
deferral
of
the
effective
date
for
the
nonattainment
area.
Updated
local
modeling
data
included
in
the
June
2004
EAC
progress
report
were
referenced
to
support
the
attainment
criteria
of
the
reclassification
petition.
Future
design
values
from
the
June
report
for
the
nine
Triad
monitors
are
presented
in
the
following
table.

Monitoring
Site
AIRS
ID
2007
Design
Values
(
ppm)
Cooleemee
37­
059­
0002
0.084
Hattie
Avenue
37­
067­
0022
0.080
Union
Cross
37­
067­
1008
0.079
Bethany
37­
157­
0099
0.076
Cherry
Grove
37­
033­
0001
0.076
McLeansvill
e
37­
081­
0011
0.076
Shiloh
Church
37­
067­
0028
0.076
Sophia
37­
151­
0004
0.072
Pollirosa
37­
067­
0027
0.069
Regional
scale
modeling
developed
by
EPA
to
support
the
Clean
Air
Interstate
Rule
(
CAIR)
predicts
a
2010
future
area­
wide
8­
hour
ozone
design
value
for
the
Triad
area
of
0.078
ppm.
This
indicates
the
area
will
continue
to
comply
with
the
8­
hour
NAAQS
beyond
2007.
The
CAIR
modeling
data
are
from
the
proposed
rulemaking's
2010
base
case.

5.4
Emissions
Reductions
Attainment
is
expected
because
of
the
combination
of
measures
to
be
implemented
and
potential
measures
listed
in
the
petition
along
with
the
commitment
of
the
area
to
implement
additional
measures
as
needed
to
achieve
attainment.
Implementation
of
controls
both
within
the
nonattainment
area
and
in
the
surrounding
areas
of
the
State
provide
assurances
of
attainment
for
the
area.
The
oxides
of
nitrogen
(
NOx)
and
volatile
organic
compounds
(
VOC)
controls
that
are
being
implemented
within
the
Greensboro
nonattainment
area
and
the
surrounding
areas
to
achieve
improved
air
quality
and
attainment
are
presented
as
follows.

Greensboro
(
Triad)
EAC
Controls
NOx
SIP
Call
Reductions
(
regulation)
­
Reducing
NOx
emissions
from
Power
Plants
by
68%
(
full
implementation
in
2006
­
but
most
controls
already
implemented)
­
Reducing
NOx
emissions
from
Internal
combustion
(
IC)
Engines,
implementation
in
2004
modeled:
yes
Inspection
and
Maintenance
Program
­
Onboard
Diagnostics
(
OBD)
(
regulation)
­
Required
in
all
counties
of
the
Triad,
phasing
in
between
July
2002
and
2005.
All
counties
except
Stokes
and
Surry
will
implement
prior
to
2005
modeled:
yes
Full
Maintenance
Plan
through
2017
Greensboro
city
­
conversion
to
biodesiel
for
all
on
and
off
road
vehicles
(
voluntary)
modeled:
no
Guildford
County
­
School
bus
diesel
retrofits
(
voluntary)
modeled:
no
Open
Burning
Ban
­
Code
orange/
Red
Days
(
regulation)
modeled:
yes
RJ
Reynolds
­
Tobaccoville
eliminate
use
of
4
coalfired
boilers
(
2004­
2007)
(
regulation)
modeled:
yes
Piedmont
Authority
for
Regional
Tranportation
(
PART)
has
funds
to
build
20
park
and
ride
lots
(
voluntary)
modeled:
no
Linked
Regional
Transit
Planning
(
PART)
to
EAC
Goals
(
voluntary)
modeled:
no
No
idling
policy
for
all
Guilford
county
school
buses
(
voluntary)
modeled:
no
On­
line
data
Base
and
Reporting
System
for
vehicle
replacement
(
Forsyth
County/
Greensboro)
(
voluntary)
modeled:
no
All
of
the
above
local
controls
will
have
begun
implementation
by
the
beginning
of
the
2006
ozone
season.

5.5
Trends.

The
area's
design
value
is
0.093
ppm,
2
ppb
above
the
Marginal
classification
design
value
based
on
2001­
2003
data.
The
area
has
not
had
any
exceedances
at
the
Cooleemee
or
Hattie
monitor
in
2004
through
August
10.
The
4th
highest
monitor
value
is
0.070
ppm
at
the
Cooleemee
monitor
and
0.069
ppm
at
the
Hattie
monitor.
If
these
values
remain
the
4th
highest
for
2004,
the
design
value
will
decline
to
0.085
for
both
monitors,
well
within
the
Marginal
range
and
only
1
ppb
above
the
attainment
level.
With
the
monitor
values
already
established
for
2002
and
2003,
the
Cooleemee
and
Hattie
monitors
could
have
a
4th
high
value
as
high
as
0.090
and
0.092
ppm
respectively
and
the
design
value
would
still
decline
to
0.092
ppm,
which
is
within
five
percent
of
the
upper
limit
for
the
Marginal
classification.
Design
value
trends
for
the
monitors
in
the
Triad
area
have
generally
declined
since
1997.
Therefore,
the
trends
in
air
quality
8­
hour
ozone
design
values
indicate
the
Marginal
classification
is
appropriate.
(
See
Figure
1)

Emissions
data
demonstrate
a
decrease
in
NOx
emissions
of
about382
tons
per
day
between
2000
and
2007.
Beyond
2007,
further
NOx
emissions
reductions
are
expected
due
to
the
Federal,
State
and
local
control
measures.
VOC
emissions
will
decrease
by
20
tons
per
day
between
2000
and
2007
with
additional
future
reductions
expected.
An
aggressive
control
program
is
being
implemented
throughout
the
State
that
affects
stationary
and
mobile
sources.

5.6
Years
of
data.

The
period
used
for
classification
is
2001­
2003.

5.7
Additional
Information.

North
Carolina
is
committed
to
conserve
and
protect
its
natural
resources
and
maintaining
a
high
quality
environment.
With
the
rules
and
legislation
that
North
Carolina
has
already
enacted,
it
is
expected
the
Triad
area
will
attain
the
8­
hour
ozone
NAAQS
without
having
to
implement
the
control
measures
prescribed
by
the
moderate
classification.

5.8
Conclusions
The
data
and
analysis
presented
in
the
petition
support
the
request
for
downward
revision
to
the
8­
hour
ozone
classification
for
the
Triad
area.
The
downward
trends
in
air
quality
monitor
and
emissions
data
are
strong
indicators
of
future
attainment.
The
emission
reductions
available
along
with
the
commitment
by
the
state
and
local
agencies
to
add
necessary
controls
further
serve
to
justify
downward
classification.
Under
the
EAC,
although
not
required,
the
December
31,
2004
EAC
SIP
submittal
will
include
a
"
section
175A
type"
maintenance
plan.

5.9
EPA
Action
The
EPA
is
approving
the
reclassification
request
for
Greensboro
because
the
request
meets
all
of
the
criteria
EPA
established.

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.
1994­
2004
Greesnboro
design
values
0.075
0.08
0.085
0.09
0.095
0.1
94­
96
95­
97
96­
98
97­
99
98­
00
99­
01
00­
02
01­
03
02­
04
design
value
years
ozone
(

ppm)
Cooleemee
37­
059­
0002
Hattie
Ave.
37­
067­
0022
Union
Cross
37­
067­
1008
Shiloh
Church
37­
067­
0028
Cherry
Grove
37­
033­
0001
McLeansville
37­
081­
0011
Bethany
37­
157­
0099
Sophia
37­
151­
0004
Pollirosa
37­
067­
0027
