4 1 4. Responses to Comments EPA Region 4 ( Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina, and Tennessee) 4 2 Comment: 1013a 2 Region: 4 State: AL Area: Atlanta, GA Comment: Atlanta CMSA:

Chambers County, Alabama is part of the Atlanta CMSA but EPA did not analyze the inclusion of this county in the nonattainment area. This county must be included in the Atlanta nonattainment area.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

Comment: 1013a 3 Region: 4 State: AL Area: Birmingham, AL Comment: In its June 29, 2004 letter to Alabama, EPA recommended the inclusion of Jefferson, Shelby and Walker Counties in the Birmingham PM2.5 nonattainment area; in addition to these counties, we recommend that Bibb, Blount, Chilton, Cullman, Etowah and St. Clair Counties be added to the nonattainment area. With the exception of Etowah County, these counties are all part of the Birmingham CMSA. EPA mentioned that 4 3 Walker County " is contiguous to the MSA " and asked for the state to comment on which portion of the county should be designated nonattainment. The 2003 OMB metropolitan area list indicates that Walker County is actually part of the Birmingham CMSA and therefore, the entire county must be included in the nonattainment area. According to EPA's letter, St. Clair and Blount Counties both experienced around 30% population growth between 1990 and 2000, suggesting that this high rate of population growth may contribute to the PM2.5 problem in the area.

EPA did not recommend that Etowah County be part of the nonattainment area despite its being adjacent to the nonattainment area and containing the Gadsden power plant. According to EPA's 2002 Acid Rain Database, this plant has no SO2 or NOx controls and the 2002 SO2 emissions were 8,741 tons per year while NOx emissions were 1,918 tons per year. And the three year PM2.5 design value for Etowah County is very close to violating the annual standard, at 14.8 µ g/ m3.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources. 4 4 Comment: 1038 4 Region: 4 State: AL Area: Birmingham, AL Comment: ADEM disagrees with EPA including Walker County in the Birmingham nonattainment area due to the following reasons:

1. Monitors located between Walker County and the non attaining monitors in Jefferson County measure PM2.5 concentrations below the NAAQS. This is an indication that Walker County is not contributing to nonattainment in Jefferson County and that nonattainment in Jefferson County may be a localized problem.

2. Limited data from a PM2.5 monitor in Walker County indicates attainment.

3. Walker County has a very low population density and VMT compared to Jefferson County.

4. The overwhelming majority of NOx and SO2 emissions in Walker County are due to the Alabama Power Company steam plant. There are few other point sources in the county. An SCR was installed on the largest unit at the power plant in 2002. SO2 scrubbers are scheduled to be in operation on this unit and two smaller units in 2008.

5. The wind infrequently blows from the direction of Walker County towards Jefferson County on days with high PM2.5 concentrations.

EPA Response: Alabama's submittal in February 2004, recommended Jefferson County be designated nonattainment for the fine particulate matter ( PM2.5), based on 2001  2003 monitoring data. Based on the analysis in the TSD EPA believes that Jefferson, Shelby and Walker Counties should be included in the PM2.5 nonattainment area. Jefferson County has a violating monitor and the State recommended it as nonattainment. Shelby County is within the MSA, has high PM, SOx, NOx, and VOC emissions, approximately 52 percent of its commuters commute to Jefferson County, has relatively high population and VMT, and has a power plant within the County. Walker County has high SOx and NOx emissions from a power plant. We have included in our recommended nonattainment area Walker County which is contiguous to the MSA, has a violating monitor, is generally rural in character, and contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this County in our initial recommendations in order to ensure that a sufficient portion of this County, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invited the State to submit to us a recommendation as to what portion of Walker County, encompassing the large facility or facilities, should be designated nonattainment. Based on the following analysis, EPA agrees that Blount, St. Clair, Calhoun, Talladega, Tuscaloosa and Morgan Counties should be recommended attainment/ unclassifiable for PM2.5. Blount County has no major sources, has relative 4 5 low emissions and has the lowest population and VMT in the Birmingham area. St. Clair County has relatively low SOx and PM emissions and has a small population. Calhoun County has no major sources, 84 percent of its commuters commute within its County and it is adjacent to the MSA. Talladega County has a small population, an attaining monitor ( 14.7 DV), low VMT and it is adjacent to the MSA. Tuscaloosa County has no major sources, 89 percent of its commuters commute within its County, has an attaining monitor ( 11.6 DV) and it is adjacent to the MSA. Morgan County has an attaining monitor, is part of another MSA, 72 percent of its commuters commute within its County and is several Counties away from Jefferson County.

Comment: 1038 5 Region: 4 State: AL Area: Birmingham, AL Comment: ADEM disagrees with EPA's intention to include Shelby County in the Birmingham nonattainment area due to the following reasons:

1. The monitor in Shelby County measures attainment of the PM2.5 standard, along with 5 of the 6 Jefferson County monitors. Monitoring data collected from the monitors do not suggest that Shelby County is contributing to nonattainment in Jefferson County.

2. 71% of the MSA population resides in Jefferson County.

3. Jefferson County's VMT is 7.5 times that of Shelby County.

4. The vast majority of NOx and SO2 emissions in Shelby County are due to the Alabama Power Company Gaston Steam Plant. SCRs and scrubbers are scheduled to be installed.

EPA Response: Alabama's submittal in February 2004, recommended Jefferson County be designated nonattainment for the fine particulate matter ( PM2.5), based on 2001  2003 monitoring data. Based on the analysis in the TSD EPA believes that Jefferson, Shelby and Walker Counties should be included in the PM2.5 nonattainment area. Jefferson County has a violating monitor and the State recommended it as nonattainment. Shelby County is within the MSA, has high PM, SOx, NOx, and VOC emissions, approximately 52 percent of its commuters commute to Jefferson County, has relatively high population and VMT, and has a power plant within the County. Walker County has high SOx and NOx emissions from a power plant. We have included in our recommended nonattainment area Walker County, which is contiguous to the MSA, has a violating monitor, is generally rural in character, and contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this County in our initial recommendations in order to ensure that a sufficient portion of this County, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invited the State to submit to us a recommendation as to what 4 6 portion of Walker County, encompassing the large facility or facilities, should be designated nonattainment. Based on the following analysis, EPA agrees that Blount, St. Clair, Calhoun, Talladega, Tuscaloosa and Morgan Counties should be recommended attainment/ unclassifiable for PM2.5. Blount County has no major sources, has relative low emissions and has the lowest population and VMT in the Birmingham area. St. Clair County has relatively low SOx and PM emissions and has a small population. Calhoun County has no major sources, 84 percent of its commuters commute within its County and it is adjacent to the MSA. Talladega County has a small population, an attaining monitor ( 14.7 DV), low VMT and it is adjacent to the MSA. Tuscaloosa County has no major sources, 89 percent of its commuters commute within its County, has an attaining monitor ( 11.6 DV) and it is adjacent to the MSA. Morgan County has an attaining monitor, is part of another MSA, 72 percent of its commuters commute within its County and is several Counties away from Jefferson County.

Comment: 1013a 5 Region: 4 State: AL Area: Chattanooga, TN GA Comment: EPA recommended that all or a portion of Jackson County be included in the Chattanooga nonattainment area due to large contributing facilities. EPA asked the state to recommend which portion( s) of this county should be included in the nonattainment area. Our analysis found that the Widows Creek power plant is located in Jackson County. This facility emits almost 44,000 tons per year of SO2 and over 25,000 tons per year of NOx. Jackson County in its entirety should be included in the nonattainment area.

EPA Response: Even though some rural counties are not a part of some CMSAs, these counties are being designated as nonattainment areas because they have violating monitors or because they contribute emissions to the nonattainment problem in the affected CMSAs. The CAA requires EPA to designate as nonattainment any area that is violating the standard and any area that is contributing to a violation in a nearby area. The designated nonattainment area will need to determine what local controls are appropriate for bringing the area into attainment in conjunction with national and regional control requirements.

Jackson County has high SOx and NOx emissions from a power plant. We have included in our recommended nonattainment area Jackson County, which is generally rural in character, and contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this County in our initial recommendations in order to ensure that a sufficient portion of this County, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invited the State to submit to us a recommendation as to what portion of Jackson County, encompassing the large facility or facilities, should be designated nonattainment. 4 7 Comment: 1038 3 Region: 4 State: AL Area: Chattanooga, TN GA Comment: ADEM disagrees with the inclusion of Jackson County in the Chattanooga nonattainment area for the following reasons:

1. The wind blows infrequently from the direction of Jackson County towards Chattanooga on days where the PM2.5 concentrations are high.

2. Vehicle Miles Traveled ( VMT) in Jackson County accounts for less than 11% of the total VMT for the nonattainment counties proposed by EPA.

3. Jackson County has a small population and population density compared to Hamilton County, Tennessee ( Chattanooga).

4. The vast majority of NOx and SO2 emissions in Jackson County are due to the TVA Widows Creek Steam Plant. ADEM has legal authority to require emission reductions form this utility and other sources to correct air quality problems regardless of the county's attainment designation.

5. SCR and SO2 scrubbers are installed on the two largest units at the TVA Widows Creek facility.

EPA Response: Jackson County has high SOx and NOx emissions from a power plant. We have included in our recommended nonattainment area Jackson County, which is generally rural in character, and contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We included this County in our initial recommendations in order to ensure that a sufficient portion of this County, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invited the State to submit to us a recommendation as to what portion of Jackson County, encompassing the large facility or facilities, should be designated nonattainment. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

Comment: 1038 2 Region: 4 State: AL Area: Columbus, GA AL Comment: ADEM disagrees with the inclusion of Lee County in Phenix/ Columbus Georgia nonattainment area for the following reasons:

1. There are few significant point sources in Lee County. 4 8 2. NOx and VOC emissions account for the vast majority ( 78%) of total emissions in Lee County. The majority of NOx emissions come from mobile sources and half of the VOC emissions are from mobile sources. About 68% of all Lee County commuters stay or work in Lee County. Only 5% work in Russell County where the standard is exceeded.

3. The wind infrequently blows from the direction of Lee County towards Phenix City on days with high PM2.5 concentrations.

4. Alabama counties are much larger than Georgia counties, which result in higher " composite emission scores". Russell County alone is almost as large as the two Georgia counties ( Muscogee and Harris) which EPA proposed for nonattainment.

EPA Response: Alabama's submittal in February 2004, recommended that Russell County be designated nonattainment for the fine particulate matter ( PM2.5), based on 2001  2003 monitoring data. Georgia's submittal in June 2004, recommended that Harris, Muscogee and Chattahoochee Counties be designated attainment for PM2.5. Based on the analysis in the TSD, EPA recommends that Russell County in Alabama, and Muscogee County in Georgia should be included in the PM2.5 nonattainment area. Russell County has a violating monitor and the State recommended it as nonattainment. Muscogee County has high NOx and VOC emissions, high VMT and a large population. Based on the analysis in the TSD, EPA agrees with the recommendation that Barbour, Chambers, Lee, Montgomery, Elmore and Tallapoosa Counties in Alabama, and Chattahoochee, Harris, Troup, Stewart, Meriwether, and Sumter Counties in Georgia, should be attainment/ unclassifiable for PM2.5 based on low emissions, low VMT and low population.

Comment: 1038 1 Region: 4 State: AL Area: Columbus, GA AL | Chattanooga, TN GA | Birmingham, AL Comment: On behalf of the Alabama Department of Environmental Management ( ADEM), the commenter disagrees with EPA's decision to designate four additional counties in Alabama as nonattainment. Based on a thorough review of EPA's information, the commenter requests that EPA designate only Jefferson County as nonattainment for PM2.5. The commenter offers the following on EPA's intended designation.

1. ADEM has the authority to impose reduction measures as necessary in any county near a nonattainment county, regardless of the attainment status of that nearby county. Accordingly, ADEM's recommendation only included those counties with monitoring data exceeding the PM2.5 standard. High background levels of PM2.5 present in the eastern United States are the major cause of PM2.5 problems, not emissions generated solely in the local areas. 4 9 2. ADEM's analysis of EPA's 11 factors supported the state's recommendation that only those counties that violated the annual PM2.5 standard, Jefferson and Russell should be designated nonattainment.

3. ADEM has several problems with EPA's composite emission score methodology including: there was no public or scientific review of the complex process used to develop the composite emission score; the inventory used to calculate the composite scores used emission data not available to ADEM and did not use the more recent 1999 national inventory; and the composite score did not take into account several important factors like the distance of emissions sources from violating monitors, the size of counties, and meteorology.

EPA Response: The CAA requires EPA to designate as nonattainment any area that is monitoring a violation of the standard or that is contributing to a violation of the standard in a nearby area. Thus, our designations include both areas monitoring violations of the PM2.5 standard as well as those nearby areas that are determined to be contributing to violations at the affected monitors. The issue of regional transport primarily concerns long range transport  i. e., transport from areas that are not " nearby". EPA agrees that this is an important issue and is currently addressing the issue of regionally transported emissions via the Clean Air Interstate Rule ( CAIR).

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

As a part of the process to determine what areas should be designated as nonattainment, EPA first uses the Federal Reference Method ( FRM) monitors to determine violations of the NAAQS. The FRM monitors measure the total mass of PM2.5 in the ambient air. 4 10 These monitors are used to calculate the values that are compared to the NAAQS ( 15 µ g/ m3) in deciding if the ambient air in an area exceeds the NAAQS.

Second, once an area has a monitor violating the NAAQS, EPA uses the speciated PM2.5 air quality data, along with other data, to help determine which counties in the area are contributing to the violation. In identifying counties that contribute to an area's violating air quality, it is important to give more weight to emissions ( sources) that contribute to the excess PM2.5 in the urban area. For example, a ton of nitrogen oxide emitted within an area contributes less to the PM2.5 in that area than a ton of organic carbon emissions. Nitrogen oxide takes time to form into PM2.5 in the atmosphere and therefore is more of a regional pollutant. In addition, it will be important to understand which emissions are mostly contributing to an area's PM2.5 level in determining what sources could be effectively controlled within the area.

To give each county in an urban area the proper " weight" for their " contributing" emissions, the emissions in the county must be adjusted in two steps. In step 1, we determine the county's percentage of the violating area's total emissions. In step 2, we adjust this percentage by the violating area's excess urban emissions for the pertinent speciated PM2.5 component. In doing this, we calculate the excess levels associated with sulfates, nitrates, carbonaceous matter and crustal material. These components represent the vast majority of chemicals that make up PM2.5 in urban areas.

The calculated urban excess for each of the four components is the difference between the speciated PM2.5 components for an urban area and speciated components from a near by rural area. While it may seem best to choose a " rural" FRM ( total mass) monitor and an " urban" FRM monitor for purposes of estimating the mass of the urban excess, this would not allow us to relate the air quality levels to the area's emissions. This situation is one of the main reasons for a monitoring network for speciated PM2.5. Accordingly, we are using the speciated PM2.5 data from rural and urban monitors, along with estimates of emissions within the area, to identify the urban sources with the greatest contribution to the urban excess PM2.5.

It is also important to note that the PM2.5 ( air quality) weighted emissions ( and scores) are considered in the context of all the relevant factors in determining the boundary of a nonattainment area. We consider the other factors, in addition to air quality and emissions, in identifying the counties that should comprise the nonattainment area. As described above, the speciated PM2.5 weighted emissions are used in developing a ranking score ( weight) for each county in a potential nonattainment area. In developing these scores, we do not intend that they be used in " bright line" manner. Rather, they offer a basis for looking closest at the counties in an area that may contribute to the most to the elevated PM2.5 in the area. For the counties with the highest score, we look at the other information as we determine the collection of counties in a nonattainment area. 4 11 Comment: 1013a 4 Region: 4 State: AL | GA Area: Columbus, GA AL Comment: With regard to the Columbus CMSA, EPA recommended that Lee and Russell Counties be designated nonattainment; Macon County should be included in the nonattainment area as well since it is part of the CMSA. EPA mentioned that Lee County is, " adjacent to the MSA, has high VMT and a large population;" this county is actually part of the CMSA and therefore must be included in the nonattainment area. Despite the fact that Macon County is part of the CMSA, EPA's analysis failed to consider the county when analyzing several factors for determining the nonattainment boundary, including population data and growth and traffic data and VMT growth.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM 2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

Comment: 1013a 11 Region: 4 State: GA Area:

Comment: Correspondence between the State and EPA indicates that Richmond County ( Augusta) may be on the verge of nonattainment. Georgia had originally recommended 4 12 that this county be designated nonattainment, but both the State and EPA since determined that incomplete data capture at one of the monitoring sites should lead to an attainment/ unclassifiable determination. According to the State's June 15, 2004 letter to EPA, the monitor with complete data ( after data substitution) has a design value of 14.8 µ g/ m3, very near the PM2.5 annual standard. EPA's AirData website indicates that the 2001 2003 design value for the monitor with incomplete data is 15.2 µ g/ m3. While we recognize that an area can not be designated nonattainment with incomplete data, we request that EPA and the State be diligent in collecting complete data for this area in order to determine whether this area is indeed attaining the standard. Due to the monitoring data showing that are quality is most likely poor, this area should receive an unclassifiable designation at the most.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. The EPA is using the most current data in the decision making process. EPA and the States continue to work to improve data collection and analysis. On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification. On September 1, 2004, the State submitted additional information and revised recommendations for the Augusta area. The revision recommended that Richmond County be attainment/ unclassifiable. Richmond County has two PM2.5 monitors with air quality data for 2001 2003. The data for one monitor demonstrates attainment and the other monitor has incomplete data for 2001 2003 that was violating. EPA's analysis of all the available monitoring data indicates that the area should be designated as attainment/ unclassifiable.

Comment: 1036 6 Region: 4 State: GA Area:

Comment: Georgia EPD Recommendations A table indicating Georgia EPD's revised recommendations for all counties and partial counties in the state and a map indicating EPD's revised designations is attached to the comment letter.

Please note that during this evaluation, EPD discovered that the vehicle miles traveled ( VMT) data posted on EPA's PM2.5 technical information web site and used by both EPA and Georgia EPD in attainment designation analysis is incorrect. EPD has used correct VMT data for the analyses created for this response. EPD will be checking the VMT data utilized in the data supporting our June 17, 2004, submittal and will notify EPA if the updated VMT data alters any of those analysis results.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations. 4 13 Comment: 1013a 9 Region: 4 State: GA Area: Athens, GA Comment: EPA did not recommend the inclusion of Oglethorpe County in the Athens nonattainment area, but this county is part of the MSA and must be included in the nonattainment boundary. There is no monitor in Oglethorpe County to prove that this county is attaining despite the PM2.5 violations in Clarke County.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

Comment: 1036 4 Region: 4 State: GA Area: Athens, GA Comment: Athens PM2.5 Nonattainment Area U. S. EPA's June 29, 2004 letter added Madison and Oconee Counties to Georgia EPD's recommendation for the Athens PM2.5 nonattainment area. In our June 17th submission, EPD did not analyze Oconee County for the 7 " other factors," since EPD's Updated LScore analysis indicated that the urban excess from Oconee County did not significantly 4 14 impact on the Athens area. Since U. S. EPA has included Oconee County in its recommendation for the Athens PM2.5 nonattainment area, EPD has conducted additional analysis for Oconee County. Also, EPD has conducted an analysis of meteorological factors that was not included in our June 17th submittal. Both of these analyses, together with the information already submitted to U. S. EPA on June 17th, indicate that neither Oconee nor Madison should be included in the Athens PM2.5 nonattainment area. Additionally, should EPA accept EPD's recommendation that Clarke County be designated as unclassifiable, then Madison and Oconee Counties should be designated either as attainment or unclassifiable. The additional analyses for Oconee and Madison Counties are contained in attachment 6.

EPA Response: On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties that contained a monitored violation and provided no further justification. On June 17, 2004, the State submitted additional information and revised recommendations. The revision recommended that Clarke County be designated as nonattainment. EPA has reviewed the State's additional information and now agrees with the State's recommendation as to Oconee and Madison Counties.

Comment: 1036 1 Region: 4 State: GA Area: Athens, GA | Macon, GA Comment: Commenter recommends that certain areas be classified as " unclassifiable." Based on PM2.5 monitoring trends through mid 2004, it is very possible that the 2002 2004 data will indicate attainment for the Athens monitor, the Macon Allied Chemical monitor ( the Macon Forestry Office monitor already shows attainment), and the Rossville monitor. Data indicating these trends is included in attachment 3. We will have more complete data later this Fall, before U. S. EPA's expected November action. If these monitoring trends continue, EPD recommends that Clarke County, Bibb County, the partial county area of Monroe County that includes Plant Scherer, and Walker County be designated as " unclassifiable."

EPA Response: The EPA is using the most current data in the decision making process. EPA and the States continue to work to improve data collection and analysis.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in 4 15 the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

Comment: 1013a 10 Region: 4 State: GA Area: Atlanta, GA Comment: EPA did not include all or portions of Butts, Dawson, Haralson, Heard, Jasper, Lamar, Meriwether, Pickens, Pike, Polk, Hall, Troup and Upson Counties and Chambers County, Alabama in the Atlanta nonattainment boundary. These counties are all part of the CMSA and must be included in the nonattainment area. Instead, EPA listed Hall, Heard and Jasper as being adjacent to the CMSA and recommended partial inclusion in the nonattainment boundary. We agree that Putnam County should be included in the nonattainment area due to the Harllee Branch power plant located in the county, but for planning purposes, we believe that the entire county should be included in the nonattainment area.

EPA has agreed with the state to make Floyd County a separate nonattainment area; this county must be included in the Atlanta CMSA nonattainment area. The Hammond power plant, located in Floyd County contributes to the nonattainment problem in the Atlanta area. As for the other counties that are included in the CMSA, but not recommended to be part of the nonattainment area, EPA's letter to the state does not even address most of these other counties. Thus, it appears that no analysis has been done for several counties that are part of the CMSA and these counties must be included in the nonattainment area.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment. 4 16 Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

Comment: 1036 3 Region: 4 State: GA Area: Atlanta, GA Comment: Atlanta PM2.5 Nonattainment Area U. S. EPA's June 29, 2004 letter added Jasper and Putnam Counties to Georgia EPD's recommendation for the Atlanta PM2.5 nonattainment area. EPA's letter also suggested that EPD submit partial county recommendations for those counties. EPD has determined that it is not practical to design partial county nonattainment boundaries for Jasper and Putnam County. We have also conducted additional analysis using EPA's wind direction frequency data that, together with information submitted with our June 17th recommendation, supports EPD's earlier recommendation that neither Jasper nor Putnam County be included in the Atlanta PM2.5 nonattainment area. Also, by designating Jasper and Putnam County " attainment" for PM2.5, the Atlanta PM2.5 nonattainment boundary will be basically identical to the Atlanta 8 hour ozone nonattainment boundary ensuring more efficient air quality and transportation planning. EPD's additional analysis of Putnam County is included.

EPA Response: Please refer to the TSD which explains EPA's decisions on the States' recommendations.

Comment: 1036 2 Region: 4 State: GA Area: Chattanooga, TN GA Comment: Chattanooga PM2.5 Nonattainment Area U. S. EPA's June 29, 2004 letter included all of the Georgia Counties that are part of the Chattanooga MSA in the Chattanooga PM2.5 nonattainment area. It is our understanding 4 17 that this was due in part to the fact that EPD had not submitted an analysis of this area prior to EPA's June 29th letter. EPD has completed this analysis and it is attached. EPD has recommended above that Walker County be designated unclassifiable and further recommends that Catoosa County and Dade County be classified as " attainment". Should additional data available this fall not indicate that the Rossville monitor will attain the PM2.5 standard using 2002 2004 data or should U. S. EPA reject EPD's unclassifiable recommendation for Walker County, we recommend that the portion of Walker County as described below be included in the Chattanooga PM2.5 nonattainment area.

From the west Walker County line ¾ of a mile south of Lookout Mtn. city limits, the boundary travels southeast to the 3700 block of Lula Lake Rd. Boundary then travels south intersecting the 2200 block of Nick a Jack Rd. and continues south 1 ½ miles. Boundary then travels east to 7600 block of Hwy 193 at N. Cedar Ln. intersection. Boundary then travels east following southern right of way of Walker Hollow Rd. to 1500 block of N. Marbletop Rd. Boundary then travels southeast intersecting 400 block of Childress Hollow Rd. and continuing east to east right of way of McCarty Rd. Boundary then travels south ½ mile. Boundary then travels east to north right of way of Peter Lewis Trl. Boundary then travels southeast to 1100 block of S. Hwy 341 at Garretts Chapel Rd. intersection. Boundary then travels southeast to southern right of way of Hames Rd. and Driftwood Dr. Boundary then travels east to intersect 800 block of Lofton Ln. Boundary then travels northeast to 100 block of Glass Mill Rd. at Old Bethel Rd. intersection. Boundary then travels east along southern right of way of Glass Mill Rd. Boundary then intersects 500 block of Old LaFayette Rd. at Glass Mill Rd. intersection. Boundary continues east intersecting 9900 block of N. Hwy 27, 300 block of Arnold Rd., and 500 block of Long Hollow Rd. Boundary continues east to 1200 block of Peaving Rd. at E. Long Hollow Rd. intersection. Boundary continues east along southern right of way of Peavine Rd. to east Walker County line.

Clearly the opportunity for a partial county designation is something EPA is willing to consider ( EPA's June 29, 2004 suggestion regarding both Putnam and Jasper counties, for example). In evaluating this recommendation, EPA should consider Walker County's geography, the location of the emission sources, other factors we have analyzed, and the fact that the northern urbanized area is not unlike the localized stationary sources EPA refers to in Jasper and Putnam counties.

A complete analysis and a map of the partial county area are included in an attachment.

EPA Response: On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in 4 18 the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

Comment: 1013a 12 Region: 4 State: GA Area: Columbus, GA AL Comment: EPA has not recommended the inclusion of the CMSA counties of Chattahoochee and Marion in the Columbus nonattainment area. Our letter to you indicated that Troup County should be analyzed for its impact on the nonattainment problem. According to EPA's June 29, 2004 letter to Georgia, Troup County's NOx emissions were over twice as high as any of the counties EPA has recommended for nonattainment in this area. Primary PM and VOC emissions in Troup County also appear to be high.

EPA Response: Based on the analysis contained in the TSD, EPA agrees with the recommendation that Barbour, Chambers, Montgomery, Elmore and Tallapoosa Counties in Alabama, and Chattahoochee, Troup, Stewart, Meriwether, Sumter Counties in Georgia, should be attainment/ unclassifiable for PM2.5 based on low emissions, low VMT and low population.

Comment: 1036 5 Region: 4 State: GA Area: Columbus, GA AL Comment: Columbus/ Phenix City Nonattainment Area The commenter does not agree with U. S. EPA's recommended boundary. However, On July 28, 2004, EPD, in cooperation with Alabama's Department of Environmental Management, submitted a request for revision to the PM2.5 Monitoring Plan for the Columbus/ Phenix City area. U. S. EPA's prompt action on this request will result in the attainment designation for the entire Columbus/ Phenix City area, including both Muscogee and Harris County in Georgia. 4 19 EPA Response: Alabama's submittal in February 2004, recommended that Russell County be designated nonattainment for the fine particulate matter ( PM2.5), based on 2001  2003 monitoring data. Georgia's submittal in June 2004, recommended that Harris, Muscogee and Chattahoochee Counties be designated attainment for PM2.5. Based on the analysis in the TSD, EPA recommends that Russell County in Alabama, and Muscogee County in Georgia should be included in the PM2.5 nonattainment area. Russell County has a violating monitor and the State recommended it as nonattainment. Muscogee County has high NOx and VOC emissions, high VMT and a large population. Based on the analysis in the TSD, EPA agrees with the recommendation that Barbour, Chambers, Lee, Montgomery, Elmore and Tallapoosa Counties in Alabama, and Chattahoochee, Harris, Troup, Stewart, Meriwether, and Sumter Counties in Georgia, should be attainment/ unclassifiable for PM2.5 based on low emissions, low VMT and low population.

Comment: 1013a 13 Region: 4 State: GA Area: Macon, GA Comment: EPA has not recommended that Crawford, Jones, Peach, Houston, and Twiggs Counties be part of the Macon nonattainment area despite the fact that these counties are all part of the CMSA. These counties must be included in the nonattainment area. In addition, EPA has only recommended that part of Monroe County be included in the nonattainment area; as this county is also part of the CMSA, the entire county must be included in the nonattainment area. Although EPA has assumed that air quality in the other counties is clean, Crawford, Jones, Peach and Twiggs Counties have no monitors in order to determine whether those counties are attaining or not. While Houston County's monitor is attaining, at 12.8 µ g/ m3, the county has the second largest population for the CMSA, after Bibb County, at 35%. In addition, Houston County is experiencing much faster growth than is Bibb County, with 24% growth between 1990 and 2000.

EPA Response: The Macon MSA contains the counties of: Bibb, Houston, Jones, Peach, and Twiggs. EPA agrees with the State's recommendation that Bibb County be nonattainment and Monroe County as a partial county nonattainment area.

Comment: 1013a 4 Region: 4 State: GA | AL Area: Columbus, GA AL Comment: With regard to the Columbus CMSA, EPA recommended that Lee and Russell Counties be designated nonattainment; Macon County should be included in the nonattainment area as well since it is part of the CMSA. EPA mentioned that Lee County is, " adjacent to the MSA, has high VMT and a large population;" this county is actually part of the CMSA and therefore must be included in the nonattainment area. Despite the fact that Macon County is part of the CMSA, EPA's analysis failed to consider the 4 20 county when analyzing several factors for determining the nonattainment boundary, including population data and growth and traffic data and VMT growth.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

Comment: 1041 6 Region: 4 State: KY Area:

Comment: Commenter states that EPA indicated in previous guidance its intention to consider 2002 2004 monitoring when making PM2.5 designations. Kentucky feels that EPA should follow through with its original intentions.

Commenter states that the Commonwealth of Kentucky believes that the date for official designation should be extended until after the beginning of 2005, instead of mid November 2004. This would allow states to utilize the 2004 data, and would provide the use of the most recent available data, a requirement that EPA consistently espouses.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations. 4 21 The EPA is using the most current data in the decision making process. EPA and the States continue to work to improve data collection and analysis.

Comment: 1041 7 Region: 4 State: KY Area:

Comment: The commenter states that the geographic location of a county and the historic prevailing wind data in an area has an impact on PM2.5 monitored values. In addressing comments from information presented in the February 2004 recommendations from Kentucky, EPA claims that an area may contribute to the monitored violation even if it is located downwind of another area, due to this being a " year long" standard. EPA has previously made numerous references to " upwind areas impacting downwind areas" and " predominant wind patterns." This has been the premise for several control programs recently implemented by EPA and most recently set the stage for the CAIR and BART proposals. Therefore, if the geographic location and predominant wind patterns are an important variable when determining when and at what levels PM impacts are seen, including at Class I areas, then the same variable should be taken into account when EPA makes final PM2.5 designations.

EPA Response: The CAA requires EPA to designate as nonattainment any area that is monitoring a violation of the standard or that is contributing to a violation of the standard in a nearby area. Thus, our designations include both areas monitoring violations of the PM2.5 standard as well as those nearby areas that are determined to be contributing to violations at the affected monitors. The issue of regional transport primarily concerns long range transport  i. e., transport from areas that are not " nearby". EPA agrees that this is an important issue and is currently addressing the issue of regionally transported emissions via the Clean Air Interstate Rule ( CAIR).

Comment: 1041 2 Region: 4 State: KY Area:

Comment: The Commonwealth was surprised to learn that EPA had employed the use of a " weighted emissions scoring" process to evaluate counties for emissions contributions to an area attainment problem. At no time did U. S. EPA offer information concerning this methodology. Further, EPA did not afford the states the opportunity to provide input on the appropriateness of or the science behind this methodology. This approach was revealed in late May 2004, a full three months after states had been required to submit boundary recommendations to EPA. Taking this approach, especially at such a late date, is not only contrary to boundary guidance provided to states by U. S. EPA, but insults the established designation process which allows states to use their thorough knowledge of the monitoring network and local and regional circumstances to make those designations. 4 22 A full detailed explanation of the origin of the data and how EPA has used the scoring methodology has still not been released for review.

Given the facts presented above, the Commonwealth must go on record as being strongly opposed to the use of this process.

However, since EPA has utilized the weighted emission scores in its PM2.5 response letter to the states, it still remains important to document the problems that exist with the methodology used by EPA in determining those weighted emission scores:

1. EPA did not include adjacent county ( i. e., county outside the MSA) emissions into the total emissions for an area when calculating the weighted emissions score. The weighted emissions score, in some instances for counties within the MSA, would have been drastically different if all counties emissions had been included in calculating the weighted emissions scores.

2. EPA's choice of regional speciation monitors must be questioned. EPA, has provided no explanation how it determined " appropriate" regional monitoring sites to use in the weighted emissions scoring process. This eliminates states air quality agencies from having any input on the appropriateness of those sites. States have " background" monitors located to determine background pollutant levels. For EPA to ignore the availability of area specific information, or request input from states on the appropriateness of using one site versus another, is shortsighted. It stands to reason that an in state regional background monitor would have been more representative of the area than a monitor located in another state. This could have drastic impacts on the results obtained from the analysis.

3. EPA used the SMOKE model information from the Clear Skies modeling that was based on the 1996 NEI to generate the total carbon and crustal components of the emissions data used in their analyses. This data was used in an attempt to generate urban excess in the weighted emissions score calculation. This approach is subjective at best.

4. The use of a cumulative percentage roll up of the weighted emissions scores is inherently flawed since it causes the inclusion of counties that have scores that are significantly lower than the top scoring counties in an area. The cumulative roll up is purely an arbitrary mathematical exercise that does not take into account important information ( e. g. geographic location, predominant wind patterns, future national control measures, etc.) that should be considered in making PM2.5 nonattainment designations.

5. EPA has still not supplied the speciation data nor the timeframes used in their analysis for the background monitor sites used in the regional analysis.

6. Other national studies performed have taken a different approach in determining source apportionment. Of particular note are conclusions contained in 2003 National Air Quality and Emissions Trends Report that compares the percent difference in PM constituency from regionally representative monitors and urban monitors. While this 4 23 approach on the front end is similar to the methodology EPA used, EPA went a step further in attempting to use that data to correlate with actual emissions within a set geographic area. Of a more specific concern, when reviewing regional background PM constituency compared with urban data, sulfates appear to make up a small percentage of urban excess. We believe this shows that sulfates are a regional problem and that the proposed regional controls of SO2 should alleviate the problem. The second concern is that carbon mass seems to make up the largest percentage of the urban excess and it appears that mobile sources are a major contributor to PM2.5 levels in our urban areas. With the proposed federal changes to fuels and engine requirements, contributions from this sector will also be lowered within the next few years.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

As a part of the process to determine what areas should be designated as nonattainment, EPA first uses the Federal Reference Method ( FRM) monitors to determine violations of the NAAQS. The FRM monitors measure the total mass of PM2.5 in the ambient air. These monitors are used to calculate the values that are compared to the NAAQS ( 15 µ g/ m3) in deciding if the ambient air in an area exceeds the NAAQS.

Second, once an area has a monitor violating the NAAQS, EPA uses the speciated PM2.5 air quality data, along with other data, to help determine which counties in the area are contributing to the violation. In identifying counties that contribute to an area's violating air quality, it is important to give more weight to emissions ( sources) that contribute to 4 24 the excess PM2.5 in the urban area. For example, a ton of nitrogen oxide emitted within an area contributes less to the PM2.5 in that area than a ton of organic carbon emissions. Nitrogen oxide takes time to form into PM2.5 in the atmosphere and therefore is more of a regional pollutant. In addition, it will be important to understand which emissions are mostly contributing to an area's PM2.5 level in determining what sources could be effectively controlled within the area.

To give each county in an urban area the proper " weight" for their " contributing" emissions, the emissions in the county must be adjusted in two steps. In step 1, we must determine the county's percentage of the violating area's total emissions. In step 2, we adjust this percentage by the violating area's excess urban emissions for the pertinent speciated PM2.5 component. In doing this, we calculate the excess levels associated with sulfates, nitrates, carbonaceous matter and crustal material. These components represent the vast majority of chemicals that make up PM2.5 in urban areas.

The calculated urban excess for each of the four components is the difference between the speciated PM2.5 components for an urban area and speciated components from a near by rural area. While it may seem best to choose a " rural" FRM ( total mass) monitor and an " urban" FRM monitor for purposes of estimating the mass of the urban excess, this would not allow us to relate the air quality levels to the area's emissions. This situation is one of the main reasons for a monitoring network for speciated PM2.5. Accordingly, we are using the speciated PM2.5 data from rural and urban monitors, along with estimates of emissions within the area, to identify the urban sources with the greatest contribution to the urban excess PM2.5.

It is also important to note that the PM2.5 ( air quality) weighted emissions ( and scores) are considered in the context of all the relevant factors in determining the boundary of a nonattainment area. We consider the other factors, in addition to air quality and emissions, in identifying the counties that should comprise the nonattainment area. As described above, the speciated PM2.5 weighted emissions are used in developing a ranking score ( weight) for each county in a potential nonattainment area. In developing these scores, we do not intend that they be used in " bright line" manner. Rather, they offer a basis for looking closest at the counties in an area that may contribute to the most to the elevated PM2.5 in the area. For the counties with the highest score, we look at the other information as we determine the collection of counties in a nonattainment area.

Comment: 1041 1 Region: 4 State: KY Area:

Comment: EPA has finalized or is in the process of finalizing several new control initiatives that are designed to lower emissions that contribute to PM2.5 levels. The implementation dates for many of these initiatives will begin within the next two years and in many instances, will be in place well before control plan submittal deadlines or attainment dates. This fact should lead to the conclusion that greater caution should be 4 25 exercised before saddling an area with a nonattainment designation when no local control strategies will be available or required.

1. Clean Air Interstate Rule ( CAIR)/ BART In the June 29, 2004, response to Kentucky, EPA has proposed nonattainment designations for several counties, either within the MSA or adjacent to an MSA, due to the location of a power plant within their borders.

The May 5, 2004, proposed BART rule states on page 25204 that " Based on our current evaluation, we believe the IAQR rule, as proposed, is clearly better than BART for those affected EGUs in the affected States which we propose to cover under the IAQR. We thus expect that the final IAQR would satisfy the BART requirements for affected EGUs that are covered pursuant to the final IAQR". Per this EPA finding regarding PM and EGUs under the IAQR/ BART, EPA should not include counties in PM2.5 nonattainment areas because they contain a power plant. EPA has determined that the IAQR ( i. e., CAIR) will achieve the necessary PM air quality improvements.

Upon implementation of the Clean Air Interstate Rule ( CAIR) SO2 emissions from power plants will be reduced nationwide by 3.6 million tons in 2010 ( approximately 40 percent below current levels) and by another 2 million tons per year when the rules are fully implemented ( approximately 70 percent below current levels). NOx emissions would be cut by 1.5 million tons nationwide in 2010 and 1.8 million tons annually in 2015 ( about 65 percent below today's levels).

To designate counties nonattainment because they have a power plant in them would place additional hardships on the county and would be counterproductive since the EGUs in the entire region will be mandated by EPA's CAIR rule to significantly control their PM precursor emissions without being designated nonattainment. In addition, Non EGUs in Kentucky will also be required to put on BART controls, which will further achieve PM air quality improvements.

2. Mobile Controls In many areas, EPA based potential nonattainment designations on the supposition that population, commuter traffic, or local VMT played an important role in determining potential impacts on PM2.5 levels within an MSA. It is not feasible to designate a county as nonattainment if the only reason an area has been included was due to these population based factors. With national controls being implemented that would address this contribution, including these counties as nonattainment would place additional, burdensome planning requirements on these local areas for no useful purpose. Due to the Tier 2 Vehicle and Low Sulfur Gasoline, scheduled to be in place by 2006, average national gasoline sulfur levels will be 90% lower. The new Low Sulfur Diesel Rule, scheduled to be phased in beginning in 2007, along with new clean engines operating requirements will reduce NOx emissions by 50%, and reduce PM emissions by more than 90%. The implementation of these new federal rules will significantly decrease the fine 4 26 particulate contribution in and from areas impacted by population and transportation factors.

EPA Response: The CAA requires EPA to designate as nonattainment any area that is monitoring a violation of the standard or that is contributing to a violation of the standard in a nearby area. Thus, our designations include both areas monitoring violations of the PM 2.5 standard as well as those nearby areas that are determined to be contributing to violations at the affected monitors. The issue of regional transport primarily concerns long range transport  i. e., transport from areas that are not " nearby". EPA agrees that this is an important issue and is currently addressing the issue of regionally transported emissions via the Clean Air Interstate Rule ( CAIR).

Comment: 1004 1 Region: 4 State: KY Area: Cincinnati Hamilton, OH KY IN Comment: Senator Mitch McConnell, U. S. Senate, requests EPA to consider the comments of Harold Tomlinson, County Judge/ Executive of Carroll County, Kentucky. Mr. Tomlinson disagrees with EPA's proposed decision to designate Carroll County as nonattainment and comments that this will hurt Carroll County economically. He notes that there are no data demonstrating that Carroll County exceeds the PM2.5 standard, Carroll County is not a part of the Cincinnati Hamilton, OH KY IN MSA, and Carroll County is not within the boundaries of an 8 hour ozone nonattainment area.

He believes EPA proposed the nonattainment designation solely on the fact that the LG& E coal fired generating station is in Carroll County. He believes that EPA has the authority elsewhere in the CAA to regulate point sources and should not subject the entire county to a nonattainment designation for the purpose of exerting regulatory control over one facility.

EPA Response: Thank you for your letter of June 8, 2004, on behalf of Mr. Harold Tomlinson, the County Judge/ Executive for Carroll County, Kentucky, concerning fine particulate matter ( PM2.5) designations and northern Kentucky. In your letter you requested that the Environmental Protection Agency ( EPA) provide you with an update on the status of PM2.5 designations, as well as relevant information on EPA's decisions regarding any region of Kentucky.

In determining an area's designation, we rely on the Clean Air Act ( CAA) definition of a nonattainment area in section 107( d)( 1)( A)( i): an area that is violating an ambient standard or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment. In making designations, we use the most recent 3 years of monitoring data. Once we determine that a monitor is recording a violation, the next step is to determine if there are any nearby areas that are contributing to the violation and include them in the designated nonattainment area. In making this determination, we review all available technical data 4 27 such as air quality, source locations and emissions, meteorology, terrain, population, commuting, and growth in the area. PM2.5 is a regional pollutant and can be transported by prevailing wind.

States had until February 2004 to recommend to EPA areas that should be designated as attainment and nonattainment. The Commonwealth of Kentucky recommended that Fayette and Jefferson Counties be designated nonattainment and deferred making a recommendation on Boyd County in their February 20, 2004, submittal. EPA will review and consider those recommendations, and intends to respond to states and tribes by the end of June 2004. In that response, the Agency will notify states and tribes of any modifications EPA wishes to make to state or tribal recommendations. States will have an opportunity to comment on any modifications EPA makes to their recommendations. EPA expects to take the 2001 2003 data into consideration when making the final designations ( by November 17, 2004). Tribes that have their own air quality programs may submit recommendations for designations; however, they are not required to do so. Because air quality data is lacking in some tribal areas, EPA will work with tribes to determine the appropriate designations. EPA will address all state and tribal lands during the designations process.

SCHEDULE States/ Tribes recommend designations February 2004 EPA responds with letters describing intended " modifications" June 28 30, 2004 EPA proposes implementation rule Fall 2004 EPA finalizes designations November 17, 2004 Effective date of PM2.5 designations February 2005 EPA finalizes implementation rule Spring 2005 State/ Tribal plans due February 2008 Attainment dates 2010  2015 Additional information regarding PM2.5 designations, along with links to the technical support documentation, is available on the web at the following web site: http:// www. epa. gov/ pmdesignations/.

If you have questions or need additional information from EPA, please contact me or the Region 4 Office of Congressional and Intergovernmental Relations at ( 404) 562 8327. 4 28 Comment: 1013a 21 Region: 4 State: KY Area: Cincinnati Hamilton, OH KY IN Comment: EPA failed to include Bracken, Carroll, Gallatin, Grant, Mason and Pendleton Counties in its recommended nonattainment area for Cincinnati. Bracken, Gallatin, Grant and Pendleton Counties are all part of the nonattainment area and must be designated nonattainment. Carroll and Mason Counties are adjacent to the Cincinnati CMSA, but both contain high emitting coal fired power plants and therefore should be included in the nonattainment area due to their probable contribution to the poor air quality in the Cincinnati area. EPA's June 29, 2004 letter to the State explains that these counties should be designated attainment/ unclassifiable despite their power plants because they have low population, population growth and VMT. These factors do not change the important fact that the Ghent electric generating facility in Carroll County produced over 46,000 of SO2 and over 19,000 tons of NOx while the H. L. Spurlock power plant in Mason County emitted over 40,000 tons of SO2 and over 8,000 tons of NOx in 2002. Regardless of population in these counties, these high emitting plants must be controlled for their impact on the nonattainment problem in the Cincinnati area.

EPA Response: In February 2004, Kentucky recommended that all Kentucky counties in the Cincinnati Hamilton MSA be designated attainment for the PM2.5 standard. EPA is modifying Kentucky's recommendation to include Boone, Campbell and Kenton Counties in the Cincinnati Hamilton nonattainment area. Boone County has significant emissions, relatively high population growth, and a large (> 10,000 tons per year SO2) power plant located in the County. Campbell and Kenton Counties have significant VMT, significant numbers of commuters into violating Hamilton County, and both counties part of the Cincinnati 1 hour ozone nonattainment area due to violating monitors. Kenton County also has monitoring data close to the standard. EPA agrees that the remaining KY MSA counties of Gallatin, Grant, and Pendleton should be designated as attainment/ unclassifiable due to low emissions, very low population relative to the area, and very low numbers of commuters into the violating counties.

EPA agrees that the adjacent counties of Carroll and Mason should be designated attainment/ classifiable for the PM2.5 standard, although they have significant emissions due to power plants. These counties have relatively low populations, low population growth, and low VMT . Further, their commuting patterns and distance from the violating monitors indicate that these counties do not contribute to the violations in the area. The other adjacent counties do not contribute and therefore, will be designated as attainment/ unclassifiable. Please refer to the TSD which explains EPA's decisions on the States' recommendations. 4 29 Comment: 1041 5 Region: 4 State: KY Area: Cincinnati Hamilton, OH KY IN | Dayton Spriengfield, OH | Lexington, KY Comment: Commenter states there were many contradictions or inaccuracies noted throughout the June 29, 2004 letter from EPA. These include:

1. On page 3, the letter states " Campbell and Kenton Counties  and both counties part [ sic] of the Cincinnati 1 hour ozone nonattainment area due to violating monitors." This statement is incorrect. On August 30, 2002, EPA's final rule, redesignating the Kentucky portion of the Cincinnati Hamilton 1 Hour Ozone Nonattainment Area to maintenance, became effective.

2. On page 4, the table that EPA utilizes in it's analysis of the weighted emissions factor for the area includes Montgomery County, Ohio. However, Montgomery County, Ohio is not in the MSA, it is in the Dayton Springfield MSA, so the emissions from this county would skew the analysis.

3. Comments on page 5 and page 12 indicate that even though a monitor shows attainment with the standard, being close to the standard is a reason for nonattainment designation.

4. On page 20, the letter states " Although Pulaski County This factor did not appear significant for the remaining counties listed in this table." It appears that a sentence ending is missing.

5. On page 22, the letter states that Madison County "  has the largest number of workers commuting into Fayette County ( 6,870), which is relatively insignificant for such a large county as Fayette. Based on the analysis for this factor, there are no counties with commuting data showing a potential to contribute to the PM2.5 violations in Fayette County." On page 23, the letter states, "  no other Kentucky counties, with the exception of Madison County, have VMT and commuting data with a potential to contribute to the PM2.5 violations in Fayette County." One page indicates that commuting data indicates no potential impact; the next page states that the commuting data indicates a potential impact.

EPA Response: On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in 4 30 the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

As a part of the process to determine what areas should be designated as nonattainment, EPA first uses the Federal Reference Method ( FRM) monitors to determine violations of the NAAQS. The FRM monitors measure the total mass of PM2.5 in the ambient air. These monitors are used to calculate the values that are compared to the NAAQS ( 15 µ g/ m3) in deciding if the ambient air in an area exceeds the NAAQS.

Second, once an area has a monitor violating the NAAQS, EPA uses the speciated PM2.5 air quality data, along with other data, to help determine which counties in the area are contributing to the violation. In identifying counties that contribute to an area's violating air quality, it is important to give more weight to emissions ( sources) that contribute to the excess PM2.5 in the urban area. For example, a ton of nitrogen oxide emitted within an area contributes less to the PM2.5 in that area than a ton of organic carbon emissions. Nitrogen oxide takes time to form into PM2.5 in the atmosphere and therefore is more of a regional pollutant. In addition, it will be important to understand which emissions are mostly contributing to an area's PM2.5 level in determining what sources could be effectively controlled within the area.

To give each county in an urban area the proper " weight" for their " contributing" emissions, the emissions in the county must be adjusted in two steps. In step 1, we must determine the county's percentage of the violating area's total emissions. In step 2, we adjust this percentage by the violating area's excess urban emissions for the pertinent speciated PM2.5 component. In doing this, we calculate the excess levels associated with sulfates, nitrates, carbonaceous matter and crustal material. These components represent the vast majority of chemicals that make up PM2.5 in urban areas.

The calculated urban excess for each of the four components is the difference between the speciated PM2.5 components for an urban area and speciated components from a near by rural area. While it may seem best to choose a " rural" FRM ( total mass) monitor and an " urban" FRM monitor for purposes of estimating the mass of the urban excess, this would not allow us to relate the air quality levels to the area's emissions. This situation is one of the main reasons for a monitoring network for speciated PM2.5. Accordingly, we are using the speciated PM2.5 data from rural and urban monitors, along with estimates of emissions within the area, to identify the urban sources with the greatest contribution to the urban excess PM2.5. 4 31 It is also important to note that the PM2.5 ( air quality) weighted emissions ( and scores) are considered in the context of all the relevant factors in determining the boundary of a nonattainment area. We consider the other factors, in addition to air quality and emissions, in identifying the counties that should comprise the nonattainment area. As described above, the speciated PM2.5 weighted emissions are used in developing a ranking score ( weight) for each county in a potential nonattainment area. In developing these scores, we do not intend that they be used in " bright line" manner. Rather, they offer a basis for looking closest at the counties in an area that may contribute to the most to the elevated PM2.5 in the area. For the counties with the highest score, we look at the other information as we determine the collection of counties in a nonattainment area.

Comment: 1013a 22 Region: 4 State: KY Area: Evansville, IN Comment: Our June 16, 2004 letter to you indicated that the Kentucky portions of the Evansville MSA must be designated nonattainment along with the Indiana portion of this MSA. But EPA has failed to recommend that this area be designated nonattainment. Henderson and Webster Counties must be included in this nonattainment area. In addition, Daviess County, adjacent to the MSA, must be included in the nonattainment area. There are two coal fired power plants in both Webster and Henderson Counties while the Elmer Smith power plant is located in Daviess County. Together, these facilities emitted almost 25,000 tons of SO2 and almost 24,000 tons of NOx in 2002. These power plants are most likely important factors in the area's nonattainment problem and must be controlled.

EPA Response: The CAA requires EPA to designate as nonattainment any area that is monitoring a violation of the standard or that is contributing to a violation of the standard in a nearby area. Thus, our designations include both areas monitoring violations of the PM2.5 standard as well as those nearby areas that are determined to be contributing to violations at the affected monitors. The issue of regional transport primarily concerns long range transport  i. e., transport from areas that are not " nearby". EPA agrees that this is an important issue and is currently addressing the issue of regionally transported emissions via the Clean Air Interstate Rule ( CAIR).

EPA is designating Henderson County as attainment. The following factors played a role in this decision: low emissions, attaining monitor ( 14.0), low population growth ( 4% or 1785 persons), relatively low commuting, designated attainment for the 8 hour ozone standard, relatively low VMT ( 510,000 miles/ year), and no large power plants. The adjacent Kentucky Counties of Daviess and Webster were included in this analysis. EPA is designating the adjacent counties of Daviess and Webster as attainment. The following reasons played a role in this decision for Webster County: relatively low emissions as compared to MSA and adjacent counties, low population ( 14,079), low population growth rate, low VMT ( 119,000 miles/ year), and low number of commuters. The following reasons played a role in this decision for Daviess County: attaining monitor 4 32 ( 14.9), relatively low emissions as compared to MSA and adjacent counties, adjacent to Henderson ( attaining), and low number of commuters.

Comment: 1013a 23 Region: 4 State: KY Area: Huntington Ashland, WV KY OH Comment: EPA failed to include Greenup County, part of the Huntington MSA, in its recommended nonattainment area. There is no monitor in this county in order to determine that this area is attaining despite the violation in the adjacent county. This county must be included in the nonattainment area.

EPA Response: In February 2004, Kentucky recommended that the PM2.5 designation for Boyd County be deferred and that Greenup and Carter Counties be designated attainment for the Huntington Ashland MSA. EPA is modifying Kentucky's recommendation to include Boyd County and Lawrence Counties in Kentucky in the Huntington Ashland nonattainment area. The following factors played a significant role in this decision for Boyd County: attaining monitor reading of 15.0 µ g/ m3, at the standard; significant SOx, NOx, and PM emissions; proximity to the violating MSA counties; controls with anticipated, substantial SOx, NOx, and PM emission reductions will not be implemented until the end of 2005, well after designations are made. Lawrence County, Kentucky is included due to significant emissions of SOx and NOx from a power plant and its close proximity to the violating counties in the MSA. We have included in our recommended nonattainment area this County that is adjacent to the Huntington Ashland MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility ( e. g., power plant) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such a large facility, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility, should be designated nonattainment.

EPA agrees with the State's recommendation that Greenup and Carter Counties in Kentucky should be designated attainment/ unclassifiable due to their relatively low emissions, low populations, low VMT, low numbers of commuters into the violating counties, and small point sources.

Comment: 1013a 24 Region: 4 State: KY Area: Lexington, KY Comment: EPA failed to include 10 counties in the Lexington nonattainment area; those counties are: Anderson, Bath, Bourbon, Franklin, Jessamine, Menifee, Montgomery, 4 33 Pulaski, Rock Castle and Scott. With the exception of Pulaski County, all of these counties are part of the CMSA. The entire CMSA must be designated nonattainment. The Cooper electric generating facility is located in Pulaski County; this facility emitted over 22,000 tons of SO2 and almost 5,000 tons of NOx in 2002. Therefore, this county must be included in the nonattainment area due to its probable contribution to the poor air quality in the area.

EPA Response: In February 2004, Kentucky recommended that Fayette County be designated attainment for the PM2.5 standard for the Lexington, KY MSA, and the remaining MSA counties be designated attainment. EPA agrees that Fayette County should be designated nonattainment for PM2.5 due to a violating monitor ( South Limestone). EPA is modifying Kentucky's recommendation to include a portion of the adjacent county of Mercer in the Lexington nonattainment area. EPA agrees that the remaining MSA Counties of Bourbon, Clark, Jessamine, Madison, Scott, and Woodford in Kentucky be designated attainment/ unclassifiable due to their relatively low emissions, low populations, low VMT, low numbers of commuters into the violating counties, and small point sources.

EPA agrees with the State's recommendation that the adjacent county of Pulaski should be designated attainment/ classifiable for the PM2.5 standard, although it has significant emissions due to a power plant. This county has relatively low population, low population growth, and low VMT. Further, the commuting patterns and distance from the violating monitors indicate that this county does not contribute to the violations in the area. The other adjacent counties do not contribute and therefore, will be designated as attainment/ unclassifiable.

Comment: 1013a 25 Region: 4 State: KY Area: Louisville, KY IN Comment: EPA failed to include 9 counties ( Hardin, Henry, Larue, Meade, Nelson, Oldham, Shelly, Spencer and Trimble) in its recommended nonattainment area for the Louisville CMSA. EPA's analysis only indicates that Bullitt, Jefferson and Oldham Counties are part of the CMSA, but there are 6 other counties that are part of the CMSA. All of these counties must be included in the nonattainment area. Hardin County is the only county with a monitor besides Jefferson and Bullitt. The 2001 2003 design value for Hardin County is 14.1 µ g/ m3, which is very near to a violation.

EPA Response: In February 2004, Kentucky recommended that Jefferson County be designated nonattainment and that Bullitt and Oldham Counties be designated attainment for the PM2.5 standard for the Louisville MSA.

EPA agrees that the Kentucky MSA County of Oldham be designated attainment/ unclassifiable due to low emissions and relatively low population. EPA agrees that Jefferson County be designated nonattainment due to four violating monitors in the 4 34 County and is modifying Kentucky's recommendation to include Bullitt County in the Louisville nonattainment area due to a relatively high number of commuters into violating Jefferson County, a monitored PM2.5 value of 14.9 that is very close to the standard, and relatively high population growth.

EPA agrees that the adjacent counties should be designated as attainment/ unclassifiable due to low population growth, a low percentage of workers commuting into the Louisville MSA, relatively low emissions, and large distance from the violating monitors in the area.

Comment: 1037 3 Region: 4 State: NC Area:

Comment: Commenter states that the emissions weighted analysis fails to account for prevailing wind directions during the periods when PM2.5 values are higher, assumes incorrectly that emissions impact a monitor equally throughout the year, fails to consider distance between emissions and the monitors, and fails to recognize any effects from the significant reductions resulting from North Carolina's Clean Smokestacks Act. The most glaring demonstration of the weakness of the emissions weighted approach is that some counties EPA intends to designate as nonattainment under this approach actually are in attainment according to monitors located in those counties. Moreover, this emissionsweighted analysis was introduced late and so could not be addressed by the Governors in their initial recommendations. This runs counter to the state federal interactive process prescribed by law. For these reasons, the State believes that the use of the emissionsweighted approach is arbitrary and should not influence the final delineation of nonattainment area boundaries.

EPA Response: As a part of the process to determine what areas should be designated as nonattainment, EPA first uses the Federal Reference Method ( FRM) monitors to determine violations of the NAAQS. The FRM monitors measure the total mass of PM2.5 in the ambient air. These monitors are used to calculate the values that are compared to the NAAQS ( 15 µ g/ m3) in deciding if the ambient air in an area exceeds the NAAQS.

Second, once an area has a monitor violating the NAAQS, EPA uses the speciated PM2.5 air quality data, along with other data, to help determine which counties in the area are contributing to the violation. In identifying counties that contribute to an area's violating air quality, it is important to give more weight to emissions ( sources) that contribute to the excess PM2.5 in the urban area. For example, a ton of nitrogen oxide emitted within an area contributes less to the PM2.5 in that area than a ton of organic carbon emissions. Nitrogen oxide takes time to form into PM2.5 in the atmosphere and therefore is more of a regional pollutant. In addition, it will be important to understand which emissions are mostly contributing to an area's PM2.5 level in determining what sources could be effectively controlled within the area. 4 35 To give each county in an urban area the proper " weight" for their " contributing" emissions, the emissions in the county must be adjusted in two steps. In step 1, we must determine the county's percentage of the violating area's total emissions. In step 2, we adjust this percentage by the violating area's excess urban emissions for the pertinent speciated PM2.5 component. In doing this, we calculate the excess levels associated with sulfates, nitrates, carbonaceous matter and crustal material. These components represent the vast majority of chemicals that make up PM2.5 in urban areas.

The calculated urban excess for each of the four components is the difference between the speciated PM2.5 components for an urban area and speciated components from a near by rural area. While it may seem best to choose a " rural" FRM ( total mass) monitor and an " urban" FRM monitor for purposes of estimating the mass of the urban excess, this would not allow us to relate the air quality levels to the area's emissions. This situation is one of the main reasons for a monitoring network for speciated PM2.5. Accordingly, we are using the speciated PM2.5 data from rural and urban monitors, along with estimates of emissions within the area, to identify the urban sources with the greatest contribution to the urban excess PM2.5.

It is also important to note that the PM2.5 ( air quality) weighted emissions ( and scores) are considered in the context of all the relevant factors in determining the boundary of a nonattainment area. We consider the other factors, in addition to air quality and emissions, in identifying the counties that should comprise the nonattainment area. As described above, the speciated PM2.5 weighted emissions are used in developing a ranking score ( weight) for each county in a potential nonattainment area. In developing these scores, we do not intend that they be used in " bright line" manner. Rather, they offer a basis for looking closest at the counties in an area that may contribute to the most to the elevated PM2.5 in the area. For the counties with the highest score, we look at the other information as we determine the collection of counties in a nonattainment area.

Comment: 1037 1 Region: 4 State: NC Area: Greensboro Winston Salem High Point, NC Comment: Commenter notes that the non attainment boundary recommended by EPA include several counties that North Carolina continues to believe should be designated attainment for PM2.5. Commenter also attaches PM2.5 Designation Response Technical Support Document.

1. In the Greensboro/ Winston Salem/ High Point area, EPA recommends that the entire counties of Stokes, Guilford, Davidson, Forsyth and Randolph be designated nonattainment North Carolina originally recommended Davidson County only as the PM2.5 non attainment boundary. We continue to believe that only Davidson County should be designated as non attainment. 4 36 2. North Carolina believes that Stokes County should be designated attainment for the following reasons. While Stokes County contains the Belews Creek power plant, an analysis of forward trajectories indicates that emissions from Belews Creek do not frequently impact the PM2.5 monitor in Davidson County. There are also PM2.5 monitors currently attaining the standard in Forsyth County that lie between Stokes County and the non attaining monitor in Davidson County. Even if the Belews Creek facility is affecting the Lexington area, significant NOx controls have already been installed on the plant. Selective catalytic reduction systems have already been installed on units 1 and 2 at the Belews Creek facility, and additional burner technology has been added at unit 2. This NOx control technology began operation in 2003 and 2004. Consequently, the NOx emissions will decrease from 43,567 tons per year to 7,022 tons per year and new SO2 controls will be installed over the next several years as a result of the Clean Smokestacks Act. SO2 emissions from Belews Creek will be reduced by nearly 90% in the next several years as these controls become fully operational.

3. Stokes County is an extremely rural county, and therefore has very little mobile emissions. North Carolina believes that the current and future controls on the Belews Creek facility, the apparent small impact of Belews Creek on Davidson County, and the rural nature of the county support designating Stokes County in attainment for PM2.5. If EPA continues to believe that Stokes County should be designated non attainment because of Belews Creek, North Carolina recommends that only the Sauratown Township where the Belews Creek power plant is located be designated non attainment.

4. North Carolina believes that Randolph County should be designated attainment for several reasons. The EPA L Factor ranking for Randolph County is the lowest of the counties recommended by EPA to be designated non attainment. Randolph County is also predominately downwind of Davidson County during the summer months when PM2.5 concentrations are the highest and therefore emissions from Randolph County would not be expected to contribute significantly to PM2.5 concentrations in Davidson County during those months. The majority of emissions within Randolph County are mobile emissions and less than 5% of the workforce commutes into Davidson County. Furthermore, the mobile source emissions will be addressed by federal rules such as heavy duty engine standards and low sulfur diesel.

5. Guilford and Forsyth counties each contain PM2.5 monitors that are attaining the standard based on current design values. The counties also lie to the north and northeast of Davidson County, which makes Guilford and Forsyth counties predominately downwind of Davidson County during the summer months when PM2.5 is the highest. The majority of emissions from these counties are mobile, and therefore these counties and surrounding counties will benefit from federal rules addressing mobile emissions as well as the expanded North Carolina motor vehicle inspection program. They will also benefit from local measures aimed at reducing mobile emissions as part of the Early Action Compact ( EAC) effort in the Triad area.

6. North Carolina has an analysis that shows PM2.5 concentration and its relationship to population density in the Triad area. The Lexington monitor does not behave the same as 4 37 surrounding monitors when considering the population around the monitoring site. The analysis suggests that the higher concentrations of PM2.5 in Davidson County are the result of local factors rather than broader population related regional influences and therefore the addition of counties beyond just Davidson County will not help the monitor attain the standard. Please see appendix for details.

7. With regard to the Lexington monitor, there has been a downward trend in the PM2.5 concentrations since 1999. We believe that this in considerable part reflects some reductions in the emission of pollutants in certain upwind states over that period. EPA itself has already concluded that these out of state sources contribute significantly to elevated PM2.5 in North Carolina. We expect that the downward trend should continue at this site as more emissions reductions are expected due to implementation of the Clean Smokestacks Act, NOx SIP call rules, federal heavy duty engine standards and new fuel standards. We anticipate further improvement in Lexington monitor air quality will result from positive action by EPA on North Carolina's section 126 petition, as well as actual promulgation of the proposed Clean Air Interstate Rule, both of which will further reduce the contribution from upwind, out of state sources to the Lexington area's non attainment and maintenance problems.

For the reasons stated herein, North Carolina believes that only Davidson County should be designated non attainment, while Stokes, Randolph, Guilford and Forsyth counties should be designated as attainment for PM2.5.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

For the Greensboro area, EPA proposed to modify the State's recommendation to include Davidson County and the MSA counties of Guilford, Stokes, Forsyth and Randolph. Guilford, Forsyth and Randolph counties are adjacent to Davidson County and have large populations and large emissions. Stokes has significant power plant emissions. EPA did not take into consideration participation in Early Action Compacts ( EACs) for 8 hour ozone in making modifications to recommended designations and boundaries for this area.

Comment: 1013a 34 Region: 4 State: NC Area: Greensboro Winston Salem High Point, NC Comment: Davie, Surry, Yadkin, and Rockingham Counties are all part of the Greensboro CMSA, but EPA has not recommended that these areas be included in the nonattainment area. Rockingham County in particular is home to the Dan River coal fired power plant, which emitted almost 3,000 tons of SO2 and over 1,000 tons of NOx in 2002. In addition, the adjacent counties of Chatham and Rowan must be included in the nonattainment area due to the coal fired power plants located within these counties that 4 38 contribute to the nonattainment problem. The Cape Fear power plant emitted almost 12,000 tons of SO2 and over 2,000 tons of NOx in 2002. The Buck electric generating facility is located in Rowan and must be included in the nonattainment area as well due to its likely contribution to the poor air quality in this area.

EPA Response: In February 2004, North Carolina recommended that the entire county of Davidson, be designated as nonattainment for the Fine Particulate Matter Standard. In the June 29, 2004, response, EPA recommended Davidson County be designated nonattainment because it has a violating PM 2.5 monitor. The MSA counties of Guilford, Stokes, Forsyth and Randolph were also being recommended as nonattainment. EPA agreed that Alamance, Davie, Yadkin, Rowan, Chatham, Rockingham, and Iredell Counties be designated attainment/ unclassifiable. Alamance is an MSA county with an attaining monitor of 13.7 micrograms per cubic meter ( µ g/ m3), 75 % of the commuters remain in Alamance County and the county has low emissions. Davie and Yadkin are MSA counties that do not contain PM 2.5 monitors, have low populations, and low commuting into Davidson. There is significant distance between the violating monitor and the counties of Iredell and Yadkin. Rowan and Iredell are adjacent to the MSA, do not contain PM 2.5 monitors and are a part of the Charlotte Gastonia Rock Hill nonattainment area for ozone. Rowan and Rockingham both have small power plants, and there are attaining monitors in Rockingham between the SO2/ NOx sources in Rockingham and the violating monitor. Chatham is an adjacent county to the Greensboro Winston Salem High Point MSA with an attaining monitor of 12.2 µ g/ m3, has low population, and part of the county is in the Raleigh Durham Chapel Hill nonattainment area for ozone. The remaining adjacent counties all have low emissions, low population and low VMT, indicating they should be attainment/ unclassifiable. EPA's final decisions on the State's recommendations are contained in the TSD.

Comment: 1072 1 Region: 4 State: NC Area: Greensboro Winston Salem High Point, NC | Hickory Morganton Lenoir, NC Comment: Commenter is commenting on behalf of the Southern Environmental Law Center ( SELC) and the Southern Alliance for Clean Energy. Commenter is concerned that without adequate justification, EPA proposes to exclude numerous counties that lie within presumptive nonattainment boundaries as well as other areas that contribute to monitored violations. Commenter is also concerned about the small boundaries that North Carolina is proposing in the Piedmont area of the state.

Commenter urges EPA to expand North Carolina boundaries to include all counties in all MSAs where a violations is registered anywhere within the MSA. This would result in the entire MSA of Greensboro Winston Salem High Point and Hickory Morganton Lenoir being designated nonattainment for PM2.5. Commenter also urges EPA designate all areas that contribute to a nonattaining monitor. This would result in EPA designating at least Rowan County as nonattainment within the Charlotte MSA, and quite likely the 4 39 entire Charlotte MSA as nonattainment. Commenter specifically requests a response from EPA on their letter requesting EPA designate the entire Charlotte MSA as nonattainment for PM2.5. Commenter urges installation of a PM2.5 monitor in Rowan County to ensure that fine particulate matter levels in Rowan meet the NAAQS.

Specific comments are found below:

1. EPA has not justified its proposal to designate only part of the Hickory and Triad areas as nonattainment. EPA's proposed designations are an improvement over the state's recommendation but are still not nearly sufficient to meet CAA requirements and ensure good air quality. EPA should follow its own presumptive boundaries and designate as nonattainment all counties in the Hickory and Greensboro MSAs.

2. EPA must designate Rowan County as nonattainment because of its significant contributions to violating PM2.5 levels in Davidson County in the Greensboro MSA. As EPA's own data demonstrates, Rowan matches or exceeds counties that have been recommended for nonattainment designation in all nine sections of EPA's 9 factor analysis. Furthermore, during the summer months when the State reports that most PM2.5 violations occur, meteorological patterns put the county upwind of much of the Greensboro MSA, including the violating monitor in Davidson County.

3. EPA has not addressed SELCs recommendations to designate the Charlotte MSA nonattainment. EPA is required to designate as nonattainment any areas that contribute pollution to monitors registering violations. EPA information has consistently indicated that sources from the Charlotte area contribute to violations of PM2.5 in Davidson and Catawba Counties.

4. EPA should designate the balance of the Charlotte MSA nonattainment because of its significant contributions to PM2.5 Violations in Davidson County.

5. North Carolina's recommendation that only a portion of Catawba County be designated as nonattainment is inconsistent with EPA guidance. Counties containing violating monitors must be designated in their entirety.

6. North Carolina's argument based on economic considerations is flawed and inapplicable to health based NAAQS.

7. Trends and predictions are irrelevant with regard to nonattainment designations. What North Carolina characterizes as a trend toward cleaner air may in fact simply reflect a temporary lowering of PM2.5 values during the cooler, wetter years of 2003 and 2004.

8. Areas that were designated nonattainment for ozone should not be excluded from PM2.5 nonattainment designation.

9. Davidson County is receiving pollution from both local and regional sources. This supports a much larger area for designation than Davidson County alone. It is no surprise 4 40 that a county located between Greensboro, Charlotte and Catawba County is facing a serious air quality problem. It is essential that EPA respond by designating as nonattainment all areas that contribute to Davidson County's dirty air, including the entire Greensboro, Hickory, and Charlotte MSAs.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations. EPA has considered the Charlotte MSA and based on our analysis disagrees with the commenter that Charlotte be included in the Greensboro area. It would be inconsistent with the Clean Air Act for EPA, at this stage, to add any counties not previously cited in its notice of proposed modifications to the State's recommendations.

Comment: 1037 2 Region: 4 State: NC Area: Hickory Morganton Lenoir, NC Comment: 1. With regard to the non attaining monitor in Hickory, North Carolina continues to oppose a non attainment designation for any area beyond the metropolitan planning organization boundary of Catawba County. There is little to be gained by including the partial counties of Burke and Caldwell in the non attainment area for the Hickory region for several reasons. Catawba County emissions are significantly higher than both Burke and Caldwell counties in the L Factor analysis. The bulk of emissions from these counties is from the mobile sector and therefore will benefit from state and federal rules addressing mobile emissions. There would be little to no additional opportunity to reduce mobile emissions by designating Burke and Caldwell counties as non attainment.

2. A non attainment designation for PM2.5 would place significant additional burdens on Burke and Caldwell counties since these counties are already participating in an EAC for ozone. These counties are making progressive strides to reduce emissions as part of the EAC effort and North Carolina feels that a designation of non attainment for these counties would do little to reduce PM2.5 in Catawba County. North Carolina believes the recommendation to designate only Catawba County as non attainment is appropriate, while Burke, Caldwell and the non MPO parts of Catawba counties should be designated as attainment for PM2.5.

3. Furthermore, on the basis of air quality data for 2004 gathered to date, North Carolina believes there is a significant probability that the Hickory monitor will attain the standard based on complete 2002 2004 data. We expect that it will be possible to maintain this attainment status as more emissions reductions are expected due to implementation of the Clean Smokestacks Act, NOx SIP call rules, federal heavy duty engine standards and new fuel standards. We are also anticipating needed reductions from upwind out of state sources from the proposed Clean Air Interstate Rule, North Carolina's section 126 petition and other initiatives, which will help Davidson County as well. EPA already has 4 41 concluded that these out of state sources contribute significantly to elevated PM2.5 in North Carolina.

4. North Carolina therefore suggests that EPA designate the Hickory area as " unclassifiable", if the designation is made before December 31, 2004. The designation for this area as attainment can then be finalized in February 2004 using the 2002 2004 data, assuming that it in fact shows what we anticipate. Alternatively, if the designation is made after December 31, 2004, the designation should be based on the 2002 2004 data. This approach would conserve significant federal, state and local resources by avoiding the need for the redesignation demonstration, as well as transportation conformity, in an area that is already attaining the PM2.5 standard.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM 2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

Comment: 1013a 35 Region: 4 State: NC Area: Hickory Morganton Lenoir, NC Comment: EPA only recommended parts of Burke and Caldwell Counties for nonattainment and did not recommend Alexander, Cleveland and Rutherford Counties for nonattainment. Cleveland and Rutherford Counties, adjacent to the Hickory MSA, both have higher emissions and must be included in the nonattainment area. The Cliffside coal fired power plant, located in both of these counties, emitted over 22,000 tons of SO2 and almost 4,000 tons of NOx in 2002. All of these counties must be included in the nonattainment area in their entirety.

EPA Response: In February 2004, North Carolina recommended that the Unifour Metropolitan Planning Organization's ( MPO) Planning Boundary in Catawba County, be designated as nonattainment. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

Comment: 1039 1 Region: 4 State: SC Area: Greenville Spartanburg, SC Comment: Commenter reaffirms South Carolina DHEC's recommendation of the entire state as attainment for the PM2.5 NAAQS. They disagree with EPA's recommendation of the Greenville Spartanburg area as unclassifiable until 3 years of data are collected.

1. The Greenville EQC sampler was placed into operation in August 2001. This sampler in addition to the two ' core' samplers required for the MSA demonstrate attainment with the annual and 24 hour PM2.5 NAAQS. 4 42 2. All of these areas have been reviewed and it has been determined that spatial averaging is appropriate for the planning areas in South Carolina.

3. Apart from the process for attainment determination, DHEC is concerned about the atypical impacts on air quality indicated by the Greenville EQC sampler. DHEC has taken steps to evaluate the potential sources of emissions that cause atypical readings in cold weather. The nature and distribution of these unusual samples indicate impact at the monitoring site from a local particulate source, possibly residential sources that heat with wood, fuel, oil and coal. DHEC intends to work closely with EPA for advice and assistance as they work with the community on this effort.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

On April 1, 2003 and February 13, 2004, the Environmental Protection Agency ( EPA) issued guidance for States and Tribes to use in identifying nonattainment areas. A nonattainment area is defined in section 107( d) of the Clean Air Act ( CAA) as an area that is violating an ambient air quality standard, or is contributing to a nearby area that is violating the standard. If an area meets this definition, EPA is obligated to designate the area as nonattainment.

Once we determine that an area is violating the standard, the next step is to determine if there are any nearby areas that are contributing to the violation and should be included in the designated nonattainment area. In addition to the important contribution from longrange transport, we believe that violations which we find in urban areas reflect significant contributions from the associated Consolidated Metropolitan Statistical Area/ Metropolitan Statistical Area ( CMSA/ MSA) as well. Therefore, our guidance establishes a presumption that the full metropolitan area contributes to observed violations in urban areas. Nevertheless, our final set of boundaries of nonattainment areas will reflect an area specific overall assessment of currently available technical information relating to nine specific factors: air quality monitoring information, pollutant emissions, population and growth in the area, commuting, vehicle miles traveled, meteorology, terrain, jurisdictional boundaries, and the existing level of control of emissions sources.

Comment: 1040 2 Region: 4 State: TN Area: Chattanooga, TN GA Comment: 1. Tennessee does not object to the naming of Hamilton County, as it is consistent with our most recent recommendation and the fact that it is measuring nonattainment of the PM2.5 standard. 4 43 2. Tennessee does object to the naming of Marion County as there are essentially no point source emissions and most of the county's emission inventory is mobile source emissions from through commuters ( heavy duty trucks) along Interstate 24. Because of federal preemptions on fuels and the fact that these trucks are not stationed in Marion County, there is nothing that the county or the state can do but wait on the federal fuels and diesel rules to take effect. It makes no sense to place a county in economic growth jeopardy by declaring them to be nonattainment contributing when the facts so clearly justify otherwise.

3. There have been numerous meetings since June with local city & county representatives, Metropolitan Planning Organizations, Economic and Community Development, environmental groups, industry and the public. This has also provided an opportunity for additional discussions regarding the potential PM2.5 nonattainment areas. Control measures that are being implemented to address ozone nonattainment will also have positive impacts in mitigation of PM2.5 nonattainment. Tennessee is also planning to implement, in a number of areas, including Knoxville and Chattanooga, PM2.5 forecasting or Air Quality forecasts ( in areas with existing Ozone forecasting programs). The opportunity to educate the public and encourage business participation and involvement in reducing PM2.5 emissions and precursors will also provide a positive benefit toward achieving and maintaining PM2.5 attainment.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations.

Comment: 1073 3 Region: 4 State: TN Area: Chattanooga, TN GA Comment: Hamilton County MSA 1. Supports EPA's inclusion of Marion County in the Hamilton County nonattainment area. Marion County is a significant contributor of PM2.5 in the Chattanooga area because of the commuting patterns of its residents, high VMTs and the presence of a major highway, I 24, through the county.

EPA Response: EPA thanks the commenter for his comments regarding the designations for the PM2.5 standard. Please refer to the TSD which explains EPA's decisions on the States' recommendations. 4 44 Comment: 1073 1 Region: 4 State: TN Area: Chattanooga, TN GA | Knoxville, TN Comment: The commenter, on behalf of the Southern Alliance for Clean Energy, national Parks Conservation Association, Tennessee Citizens for Wilderness Planning, Southern Environmental Law Center, and Tennessee Environmental Council, suggests EPA make their designations in a cautious manner. She notes that EPA's scientists have suggested that the current PM2.5 standard of 15 µ g/ m3 is not protective and have recommended a standard as low as 12 µ g/ m3 and healthcare experts have recommended a standard as low as 10 µ g/ m3. She suggests EPA should keep in mind that many counties have design values that exceed 10 12 µ g/ m3 as the agency designates nonattainment areas. She supports broad designations that will lead to controlling sources outside of the violating area that are likely contributing to nonattainment. In addition she comments that the Tennessee DEC recommendations are not in the best interest of citizens and would result in people in Knox and Hamilton Counties breathing unhealthy air far longer than is necessary. In general, commenter agrees with EPA's proposal for nonattainment areas with the exception of the exclusion on Campbell and Union Counties from the Knox County area.

EPA Response: In a February 12, 2004 letter, the State recommended that Knox, Roane, and McMinn Counties be designated nonattainment based on 2000 2002 monitoring data. The State revised its recommendation on May 7, 2004, to recommend that McMinn and Roane Counties be designated attainment due to 2001 2003 data. Therefore, the State's current recommendation for the Knoxville MSA PM2.5 nonattainment area only includes Knox County and recommends that all other MSA and adjacent counties be designated attainment. The State submitted justification for this recommendation. Union County has very small amounts of PM2.5 and precursor emissions, indicating no contribution. Therefore, EPA agrees that Union County should be designated attainment/ unclassifiable.

Please refer to the TSD which explains EPA's decisions on the States' recommendations Comment: 1040 1 Region: 4 State: TN Area: Knoxville, TN Comment: Tennessee offered the following comments regarding the PM2.5 nonattainment designations recommended by the Environmental Protection Agency ( EPA) as outlined in EPA's June 29, 2004 letter.

1. McMinn and Roane Counties:

EPA has proposed the inclusion of McMinn and Roane Counties as PM2.5 nonattainment areas primarily because of a large source in each county despite the fact that these two 4 45 counties are not in a metropolitan statistical area ( MSA). Apparently, the sources of concern are Bowater Newsprint and the TVA Kingston Steam Plant. The EPA June 29, 2004 letter declares that meteorology or geography/ topography are not factors in the EPA rationale for including the counties.

Tennessee avers that the naming of these rural counties as nonattainment based upon a large source in that county is patently unfair to the citizens of that county. The monitors currently measure PM2.5 attainment, so it has to be an argument of contribution. Tennessee agrees that in general, the larger sources do have a potential to be contributors to the formation of PM2.5, but there has been no plausible demonstration to show that these sources actually impact either the Chattanooga or Knoxville MSAs where air monitoring measures PM2.5 nonattainment.

Therefore, with respect to McMinn and Roane counties, Tennessee declares the following:

· Neither county should be listed as significantly contributing to the nonattainment of another county.

· If a source( s) in a county outside of an MSA is to be listed as significantly contributing to the nonattainment of another county, it should be listed only after modeling confirms that.

· Ultimately, a state implementation plan to ensure that all of Tennessee will attain the PM2.5 standard will be required.

· In preparing the PM2.5 State Implementation Plan, Tennessee commits to model the two sources to ascertain their impact upon the Knoxville and Chattanooga MSAs and to the extent necessary, require sufficient control on the facilities to attain the standard.

· EPA extends the invitation to discuss a partial county designation to capture these sources of concern as long as the ultimate nonattainment boundary in that county captures the source and is contiguous to an MSA nonattainment area. Tennessee rejects this offer, as it has no scientific or technical merit. The counties measure attainment, so it is not an argument over how large an area a nonattaining monitor should represent. This argument concerns contribution from point, rather than area sources. If a boundary is to be drawn, it must be point limited without a peninsula connecting it to a nonattaining MSA.

· Upon designation of nonattainment, existing sources are expected to meet a RACT level of control for the pollutants causing nonattainment. In the case of the TVA Kingston Plant, oxides of nitrogen control in the form of Low NOx burners and Selective Catalytic Reduction units is underway. Lower sulfur fuels are being used in the interim and ultimately scrubbers will be installed. Details of the control efficiencies and timeline for implementation are enclosed as attachments to this letter. Since the facility of concern will have controls for SOx and NOx that far exceed the requirements of RACT, it seems 4 46 useless to name a county or a well controlled facility as being nonattainment contributing without a specific modeling study done at the controlled level making a demonstration of attribution.

· The " urban excess" evaluations conducted by EPA and proposed as a method for " L factor" ranking of the counties within an area ( MSA), according to their relative emissions of direct and indirect PM2.5 related air contaminants, also provides a method to evaluate potential reductions needed. An evaluation of the urban excess data for Knoxville, Tennessee area reveals that approximately 3 µ g/ m3 total urban excess is present. This can be apportioned based on the emission inventory. The approximate amount of reduction needed, based on the urban excess calculations is equal to about 2% of the inventory. This is the projected amount needed to reduce the PM2.5 levels below the 15.0 µ g/ m3 threshold for the Knoxville area. When the entire emission reduction amounts are actually realized, the PM2.5 monitored levels could be reduced to approximately 14.0 µ g/ m3 ( assuming a reduction equal to the total urban excess amount).

· The existing reductions proposed as part of the NOx SIP call and the NOx RACT requirements along with the other federal program reductions planned and the TVA NOx reductions already underway, should produce reductions that will achieve these goals.

· It is unreasonable to include the Roane and McMinn county areas that are monitoring attainment for the PM2.5 standard, when it is highly likely that the emission reductions described above will alone be significant enough to bring the Knoxville area into attainment. The implementation of the federal programs and the NOx SIP/ RACT requirements will also bring about similar reductions for the sources in those counties as well. These reductions will also have a positive impact if the areas are considered to be contributing to PM2.5 nonattainment in the Knoxville region.