Gallia Counties facilities in Ohio provided EPA with information used in
our final designations.  Updates on emission controls added since the
last emissions inventory are helpful.  Knowing the latest reductions
allows EPA to make a more informed decision on whether a county or
partial county is contributing to violations.

After considering the controls being added, EPA determined that the
partial county areas in Adams and Gallia Counties, Ohio still contribute
to the violations in the Huntington-Ashland area and that in Coshocton
County, Ohio still contributes to the Columbus area violations.  The
partial counties were designated nonattainment because they contribute
to violations.  Ohio needs to determine if additional measures are
required beyond the planned emission controls to bring the areas into
attainment.  EPA has provided a detailed response to these issues in
full in the State and Tribal RTC and/or the relevant area specific TSDs;
please refer to these documents for additional related information.

Comment:

One commenter (0104) disagrees with EPA’s recommended designations.

The commenter requests that EPA designate Clarksville, TN-KY and
McCracken County, KY as unclassifiable or in attainment.  The commenter
believes that if the most recent data from 2008 is used, Evansville, IN,
and McCracken County, KY, are likely to be able to be in compliance.

The commenter notes the current pending litigation and believes that
many of EPA’s proposals fail to articulate how the 9 factors apply to
each designation and the relationship among the factors. Because the
commenter believes that the EPA failed to articulate this relation the
commenter disagrees to all the proposed designations for non-violating
counties in Alabama, Tennessee, and Muhlenberg County, KY.

The commenter disagrees with EPA’s proposed designation for Humphreys
County, TN and Muhlenberg County, KY because neither is “nearby” the
violating monitor. The commenter notes the pending litigation of EPA’s
designation of counties that are not adjacent to violating counties.

The commenter believes that Roane County, TN is not contributing to the
violating monitor in Knox County, TN. The commenter states that
contribution is not supported by EPA’s CES or the speciation of
emissions.

The commenter notes that EPA’s description of controls in Muhlenberg,
Stewart and Humphreys counties are incorrect and provides information on
the level of control from the Clean Air Markets Division.

EPA Response:

In the specific case of the Clarksville area, there is a violating
monitor in Montgomery County, TN that does not meet the standard.
Further, EPA has made the determination (through its analysis and the
information provided by the Commonwealth of Kentucky and the State of
Tennessee as fully explained in the TSD that a portion of Muhlenberg,
Humphreys and Stewart Counties are contributing to the violations at the
Montgomery County monitor.  EPA acknowledges that updated information on
controls for Muhlenberg, Stewart and Humphreys Counties became available
and has considered this updated information for designation purposes for
this area.  EPA believes its technical analysis of the nine factors and
other analysis tools was appropriate in general, clearly explained in
the TSDs, and applied accurately in Clarksville.  EPA concluded that
even with this additional control data the facilities in the partial
counties were still contributing to the monitored violations.  It is
important to note that air quality data and level of emissions (not
necessarily level of controls) are important considerations for whether
an area is violating or contributing to a violation.  EPA’s approach
of including noncontiguous partial counties to capture sources that
contribute emissions to a downwind area which has violations is
consistent with the approach used for the nonattainment designations for
the 1997 annual PM2.5 standard and with the statute.  Please refer to
the TSD and the State and Tribal RTC document which explains EPA’s
decisions.

Regarding Knoxville, the commenter disagrees with the inclusion of a
portion of Roane County, TN, in the Knoxville nonattainment area for the
2006 24-hour PM2.5 standard.  Speciation data from the Knoxville region
indicates that the days with the highest PM2.5 concentrations typically
occur in the warm season, with sulfate accounting for about 65 percent
of the PM2.5 mass and carbon accounting for about 32 percent of the
PM2.5 mass.  The Kingston power plant in this portion of Roane County
has high annual emissions (51,000 tons SO2, 12,000 tons NOx), and this
factor combined with supporting meteorological data indicates a
contribution from the Kingston plant to exceedances in Knoxville.  In
addition, this portion of Roane County also was included in the boundary
for the 1997 PM2.5 nonattainment area as well.  The Knoxville area, with
an annual design value of 15.7 ug/m3 for 2005-2007, still has not
attained the annual standard.  The partial county area in Roane County
was designated as part of the original nonattainment area on the basis
of its contribution to annual average fine particle concentrations in
nearby Knoxville.  The major component of fine particle mass on an
annual average basis and on the highest days is sulfate.  EPA
understands that scrubbers are to be installed on the nine units at the
Kingston power plant in 2010.  EPA applauds these steps toward cleaner
air, and the resulting emission reductions can be accounted for in the
State’s future attainment plan for the 24-hour standard.  However,
since the reductions occur after December 2008, they cannot be factored
into the current designation decision by EPA.  For all of the above
reasons, EPA finds that it is reasonable and consistent to maintain the
partial county area of Roane County as part of the Knoxville
nonattainment area for the 24-hour PM2.5 NAAQS.

With regard to decisions on nonattainment boundaries in other parts of
the country, EPA’s designations guidance for the 2006 24-hour PM2.5
standard states that the criteria for determining appropriate boundaries
is to be made on a case-by-case basis considering the recommended nine
factors and other relevant information, including information submitted
in State recommendations.  Not every factor was equally relevant in each
area (e.g., in many eastern locations topography is not an issue), nor
was every factor equally important to each area.  Due to the complex and
variable nature of PM2.5, the important factors varied from one area to
another based on local circumstances.  EPA considered the individual
facts and circumstances of each area in determining whether to include a
county or part of a county as contributing to a particular nonattainment
problem.  Neither the CAA nor EPA’s designations guidance establishes
thresholds for determining the designations status of an area.  For
example, the guidance does not identify a set amount of a pollutant, or
a specific level of commuting between counties, that would automatically
require a county or part of a county to be included in a nonattainment
area.  While the commenter attempts to make a comparison between carbon
emissions in Roane County and nine other counties in the area with less
carbon emissions, EPA notes that the determination of a county’s (or
portion thereof) contribution is based on the totality of the analysis
and not based on this individual factor alone. Roane County has a large
point source (i.e., Kingston Power Plant) and high level of sulfate
contribution.

The CAA defines a nonattainment area as any area that does not meet an
ambient air quality standard or that is contributing to ambient air
quality in a nearby area that does not meet the standard.  If an area
meets either prong of this definition, then EPA is obligated to
designate the area as nonattainment.  EPA identifies violations of the
2006 24-hour PM2.5 NAAQS on the basis of three years of complete,
quality-assured ambient air quality monitoring data from an eligible air
quality monitor.  The design value for the monitor in McCracken County
is 36 μg/m3 which is above the standard and makes this county an
automatic candidate for nonattainment.

Please see 2.3 above regarding the submission of 2008 data and 2.2 above
for EPA’s detailed responses to additional issues raised by the
commenter.  EPA has provided a detailed response to these issues in full
in the State and Tribal RTC and/or the relevant area specific TSDs;
please refer to these documents for additional related information.

Comment:

One commenter (0108) is concerned about the weight of the CES because of
the following assumptions:

Volatile Organic Carbon (VOC) emissions are not included in the
calculation of CES;

The SANDWICH algorithm was applied to FRM sites but not to the
Interagency Monitoring of Protected Visual Environments (IMPROVE) sites
used in the analysis in the Technical Support Document (Derivation of
the Contributing Emissions Score, August 20, 2008) describing the
generation of CES values.

EPA Response:

While EPA would have liked to have incorporated VOC emissions into the
CES to provide a better indication of the impact those emissions have on
the violating monitor, the science behind the chemistry of PM2.5
formation from VOC emissions is not as advanced to the point where the
relationship between secondary organic particle concentrations and VOC
emissions could be reliably quantified.  EPA also believes that the
uncertainty about what proportion of VOC emissions in a particular
county might participate in PM formation directly also precluded VOC
emissions from being considered for use in the CES.  Counties with
predominant primary carbon emitters were more of a concern with the CES
in the western United States where there was also a large wood smoke
contribution.  This potential problem was not as important an issue in
the eastern US. However, VOC emissions were directly considered in
making designations through the emissions data charts for all areas.

EPA acknowledges some ambiguity in the CES Technical Support Document
(TSD) regarding the comparison between the IMPROVE and SANDWICH
processed CSN data.  The urban increment calculation in the CES involved
using both IMPROVE and CSN data.  The CSN data were processed using the
SANDWICH technique to account for the loss of nitrate from the Teflon
filter and the retention of water mostly among hydrated ammonium
sulfate.  The IMPROVE nitrate and sulfate data were also adjusted in a
similar fashion so that the data from the two networks could be used
together to calculate the urban increment at each CSN site within the
violating area.  The CES TSD has been updated to better clarify this
part of the CES methodology.

Comment:

One commenter (0085) is concerned with the following technical data in
EPA’s CES:

The definition of “high” PM2.5 days;

The calculation of Area-normalized High Day Emissions; identification of
the Urban Increment and usage of the SANDWICH algorithm;

Implementation of trajectory and distance weighing; and

Uncertainties associated with VOC assumptions, the SANDWICH algorithm,
and back trajectories.

EPA Response:

The commenter made several comments regarding the ambiguity of
explanation given in the CES technical support document regarding
several aspects of the calculation of the CES.  For clarification, the
CES TSD has been updated to better describe how “high” days were
chosen for the various components of the CES.  The commenter’s
greatest concern is over how the high days were chosen for the urban
increment calculation.  To clarify this, the high days for the urban
increment calculation were chosen from the highest 5 percent of days
measured at each CSN site for each season and year.

In regard to how the area-normalized high day emissions were calculated,
the commenter drew the correct conclusion in that the total seasonal
high day emissions in an individual county were normalized to the total
seasonal high days emissions from the CBSA/CSA.

The CES TSD has been updated to better clarify the comparability between
the IMPROVE and SANDWICH adjusted CSN data.  As the commenter indicates
elsewhere, two different methods were used to calculate the crustal
component.  Since the crustal component itself was very small, the
approximate 10 percent difference between the between the two methods
for computing crustal material is also small typically on the order of a
few tenths of a microgram and, therefore, does not greatly affect the
urban increment for crustal material or the carbon concentrations which
depend upon the non-carbon estimates.

Regarding the trajectory weighting algorithm used in the CES, the
commenter has asked EPA to better clarify some of the associated
details.  The trajectories were run for the 10 percent highest measured
PM2.5 days for each year and season.  For the calculation of the
probability field of the likelihood of a trajectory passing through an
individual county, all of the trajectories from each starting height
level were analyzed as an entire group.  For determining the individual
county weights, a probability density field was calculated using Kernel
Density Estimation and the results of this analysis are spread over a
grid.  The fraction of an individual county’s average probability
density to the total across all counties was used as the weight applied
to the emissions data.  The sum of all of the individual county
fractions is equal to one.  The values presented in Table A-7 are scaled
between 1 and 100 for display purposes only.

The commenter expressed confusion over how the distance weighting factor
was calculated.  The CES TSD states that the factor was calculated as
1/distance between the centroid of the violating county to the centroids
of surrounding nearby counties.

The commenter also mentioned the absence of VOC emissions from the
calculation.  While the commenter admitted that “the scientific basis
for developing a simple relationship between VOC emissions and organic
particle concentration is limited, some sort of approximation of aerosol
yields from VOC emissions would help” the CES distortion in organic
carbon attribution.  While EPA would have liked to have incorporated VOC
emissions into the CES to provide a better indication of the impact
those emissions have on the violating monitor, the science behind the
chemistry of PM2.5 formation due to VOC emissions is not as advanced to
the point where the relationship between secondary organic particle
concentrations and VOC emissions could be reliably quantified.  EPA also
believes that the uncertainty about what proportion of VOC emissions in
a particular county might participate in PM formation directly also
precluded VOC emissions from being considered for use in the CES.
Counties with predominant primary carbon emitters were more of a concern
with the CES in the western United States where there is also a large
wood smoke contribution.  This potential problem is not an important
issue in the eastern US. However, VOC emissions were directly considered
in making designations through the emissions data charts for all areas.

The commenter also cited a publication regarding the error associated
with using trajectories.  The paper does not specifically critique the
HYSPLIT model utilized by EPA in the CES.  EPA assumes that the
conclusion drawn by the paper applies specifically to the models and
studies assessed.  In that case, the paper was published ten years ago
so that advances in trajectory modeling could not have been accounted
for.  EPA recognizes that every data source has some of level of
uncertainty associated with it and that one cannot solely rely on any
one piece of information in making a regulatory decision.  EPA has
recommended through guidance that the CES is but one of many analytical
tools and data sources that could be used as a starting point for the
designation process to help inform the final decision.

Comment:

One commenter (0085) believes that there was inconsistent and arbitrary
application of the CES as follows:

CES values vary enormously: nonattainment CES numbers range from 100-5
and attainment CES numbers are as high as 33 and go down to zero.

EPA uses counties from other Consolidated/MSAs (C/MSAs) while
calculating CES calculations for a given C/MSA:

e.g.  Kanawha County, WV has CES value of 100 when calculated with the
Charlestown MSA and the value of 15 when calculated with the
Huntington-Ashland MSA.

e.g.  in the Huntington-Ashland MSA, counties with CES values of 33 and
higher in the MSA are all nonattainment and those below are attainment
the exception to this Kanawha County which is nonattainment even though
its CES as it relates to Huntington-Ashland is 15.  It seems safe to
assume that the Kanawha nonattainment designation is based upon its
contribution to the Charleston C/MSA, but its presence in the
Huntington-Ashland CES calculations makes CES values difficult to
interpret in light of their relationship to nonattainment.

In the Cleveland-Akron MSA, Portage has a CES of 15 and is recommended
nonattainment by both Ohio and EPA.  Wayne County has a CES of 15 and is
recommended attainment by both Ohio and EPA.  Portage County is
currently monitoring attainment.  Lorrain County, which received a
relatively high CES of 60, has been recommended by both Ohio and EPA,
but is monitoring attainment.

In the Columbus MSA, Franklin County has a CES of 100 and is recommended
nonattainment.  Pickaway, Adams and Ross Counties are respectively
scored 19, 18 and 18 and are recommended attainment by both Ohio and
EPA.  Delaware, Licking and Fairfield Counties are respectively scored
11, 10, and 9 and are all recommended nonattainment by both Ohio and
EPA.

In the Dayton-Springfield MSA, all three MSA counties listed are
nonattainment and their scores are 95 for Montgomery County, 14 for
Greene County, and 5 for Clark County.  Clark County is monitoring
attainment.

In the Cleveland-Akron MSA, Lorain and Portage Counties are monitoring
attainment, are recommended for nonattainment, and have CES values
differing by 45 points.

EPA Response:

The commenter has made a point with several examples stating that EPA
applied the CES inconsistently and arbitrarily in its nonattainment area
designations.  As noted in responses to other commenters, the CES was a
screening tool to provide a list of counties to be considered for
inclusion into the nonattainment area of a violating monitor.  It was
not considered outcome-determinative but one measure using information
from some of the factors recommended through EPA guidance to serve as a
starting point in determining nonattainment area boundaries.  Additional
data from a variety of different sources were then considered to better
refine the designation areas to include counties which had evidence of
contributing to the violating monitor.  EPA does not agree that the
manner in which the CES was utilized was either inconsistent or
arbitrary.  The CES served its purpose to highlight possible nearby
contributing counties that could then be further examined to better
determine the overall contribution based the data EPA had on hand.

A particular county’s CES is unique to the area being evaluated even
if the county has multiple scores from being included in the evaluations
of multiple violating areas.  Therefore, the score for a particular
county in one area cannot be compared to the score for the same county
when its contribution is being assessed for another violating area.
 Also, it is important to realize that the CES is not outcome
determinative.  The CES is one analytical tool that attempts to provide
an initial starting point to which additional information from the
recommended factors in EPA guidance as well as data from the State and
Local air agencies can be applied to inform the final decision.

Kanawha County, WV's CES value is only 15 which is low relative to the
scores of the other counties included in the Huntington-Ashland area
analysis because it is a greater distance from the violating monitor in
Cabell County, and meteorological data indicates that its has a lesser
impact on Cabell County.  Prevailing winds at the Cabell County air
quality monitor are north-northeast, as well as southwest and south.
 Only occasional winds are from the east, the direction of Kanawha
County.  In EPA's technical analysis for the Huntington-Ashland area,
EPA determined that Kanawha County should not be included in the
Huntington-Ashland nonattainment area.

Kanawha County, WV's CES value is 100 which is very high relative to
other counties included in the Charleston area analysis, which is
comprised of Kanawha and Putnam Counties, WV.  Kanawha County has two
air quality monitors showing violations of 2006 24-hour PM2.5 NAAQS,
considering 2005-2007 data.  Meteorological data indicates that days
with low wind speeds are more likely to record high PM2.5 levels at the
Kanawha County air quality monitors.  This indicates that local
emissions from Kanawha County contribute to the Charleston area’s
nonattainment, including emissions from the Kanawha River electric
generating unit and Bayer Cropscience.  In EPA's technical analysis for
the Charleston area, EPA determined that Kanawha County should be
included in the Charleston nonattainment area.

Counties such as Lorrain and Porter Counties, which have air quality
data meeting the standards, can still contribute to violations in other
counties.  These contributing counties are included in the nonattainment
area.  Examining factors such as commuting and jurisdictional boundaries
show differences between Portage and Wayne Counties.  Ohio’s
recommendations were also considered.

In the Columbus area specifically, EPA determined that Pickaway and Ross
Counties should be designated attainment based on the analysis detailed
in the TSD.  The analysis indicated that Delaware, Fairfield, and
Licking Counties should be included in the Columbus nonattainment area.
EPA used information relevant to the recommended factors, not just the
emissions inventory, to determine which counties to designate as
nonattainment.  Factors including population and commuting supported
including Delaware, Fairfield, and Licking Counties and not including
Pickaway and Ross Counties in the nonattainment area.  Adams County was
included in the Huntington-Ashland nonattainment area.

Clark County is monitoring a violation of the 2006 fine particulate
standards based on 2005 to 2007 data.  Therefore, Clark County was
included in the Dayton-Springfield nonattainment area.

3.0.  Comments Specific To Area

3.1.  Allentown, PA

See section 2.2 for general comments relevant to this particular
nonattainment area.

3.2.  Baltimore, MD

Comment:

Four commenters (0095) comment that, according to EPA’s AirData
database, a monitor in Prince Georges County, Maryland (Prince Georges
Equestrian Center monitor 2) is violating the 24-hour PM2.5 standard
based on 2005-2007 data.

EPA Response:

The monitor in question is a collocated monitor in place for quality
assurance purposes only.  The Maryland Department of the Environment
operates this and other collocated monitors to comply with Federal
regulations to quantify PM2.5 measurement precision at 15 percent of its
sites Statewide.  The primary monitor, and not the collocated monitor,
is used to determining compliance with the PM2.5 NAAQS.  (See 40 CFR
Part 50 Appendix N, 3(d)(1).)  The primary monitor at this site operates
every third day.  The collocated monitor operated every sixth day in
2005 and 2006, and every twelfth day starting in 2007.

PM2.5 design values are calculated by site, not by monitor.  According
to 40 CFR Part 50 Appendix N, 1(c)(2), the 3-year average of annual 98th
percentile 24-hour average values recorded at each monitoring site
(referred to as the “24-hour standard design value”).  Therefore,
there is no design value for the collocated monitor.

Data from the collocated monitor is used to substitute for missing data
from the primary monitor, pursuant to 40 CFR Part 50 Appendix N,
3(d)(2):

Data for the primary monitor shall be augmented as much as possible with
data from collocated FRM, FEM, or Approved Regional Method (ARM)
monitors.  If a valid 24-hour measurement is not produced from the
primary monitor for a particular day (scheduled or otherwise), but a
valid sample is generated by a collocated FRM/FEM/ARM instrument (and
recorded in the Aerometric Information Retrieval System Air Quality
System (AQS) database), then that collocated value shall be considered
part of the site data record (i.e., that site's daily value).  If more
than one valid collocated FRM/FEM/ARM value is available, the average of
those valid collocated values shall be used as the daily value.

2007 data would be 30.7 μg/m3 for the primary monitor and 37.2 μg/m3
for the collocated monitor.  This value for the collocated monitor is
unrepresentatively high due to the small number of monitored samples
which gives more weight to high values when the 98th percentile 24-hour
average values are determined.  The proper design value for the site is
32.0 μg/m3 when missing data from the primary monitor is supplemented
with data from the collocated monitor.

Comment:

Four commenters (0095) comment that data in the AirData database shows
consistently high 24-hour PM2.5 levels at the two monitors at 34th and
Dix NE.  The commenters state that, “[t]aking the higher of the values
at the two monitors in each year, the site is in violation for
2005-2007.”

EPA Response:

The monitors referenced above are the primary and collocated monitors at
34th and Dix Streets in Washington, D.C.  It is not appropriate to
simply pick the highest values at each site to determine compliance with
the PM2.5 NAAQS.  As described in the response to the above comment,
data from the collocated monitor is only used in design value
calculations when valid data is missing at the primary monitor.  The
correct design value for this site is 35 μg/m3 for 2005-2007.
Therefore, this site meets the 24-hour PM2.5 NAAQS.

Comment:

Four commenters (0095) comment that because the Washington, D.C. area is
violating the PM2.5 NAAQS and is consistently recording elevated PM2.5
levels, EPA must designate the entire metropolitan area as
nonattainment.

EPA Response:

As explained above, the Washington, D.C. area is not violating the 2006
PM2.5 standard.  It should also be noted that the PM2.5 data referenced
by the commenters was obtained from EPA's “AIRNOW/AirData” website
and not the Aerometric Information Retrieval System AQS database.  AQS
is the database that contains all State and local agency submitted and
EPA certified air monitored data and is used for determining compliance
with the NAAQS.

Comment:

Four commenters (0095) comments that even if the Washington area were
not itself violating the 2006 NAAQS, EPA would have to designate the
area nonattainment as part of a greater Washington-Baltimore-Northern
Virginia, DC-MD-VA-WV CSA nonattainment area, because Congress intended
that nonattainment areas encompass the entirety of combined statistical
urban areas.

EPA Response:

See section 2.2 comments regarding designating entire CSAs
nonattainment.

Comment:

Four commenters (0095) comment that EPA’s data and analysis show that
the Washington, D.C. area contributes to PM2.5 levels in the Baltimore
area.  The commenters assert that:

The Washington, D.C.  area generates substantial emissions of PM2.5 and
precursors;

EPA’s analysis shows that regional wind patterns are often southwest
to northeast;

EPA’s data indicate that PM2.5 emissions in both Montgomery and Prince
Georges Counties are higher than in any county in the proposed Baltimore
nonattainment area;

Montgomery and Prince Georges Counties, combined, emit more sulfur
dioxide (SO2) than any county in the proposed Baltimore area; and

Collectively, the Maryland counties currently in the Washington
nonattainment area emit about as much PM2.5 as and far more SO2 than all
the counties in the proposed Baltimore area, combined.

EPA Response:

Based upon public comment received, EPA determined that it was
appropriate to further analyze the technical information used to support
EPA’s boundary recommendation for the Baltimore area.  Based on
EPA’s further analysis of that technical information, EPA has informed
Maryland that it proposes to modify the boundary of the Baltimore
nonattainment area for the 2006 24-hour PM2.5 standard to include
Montgomery and Prince Georges Counties, Maryland.

EPA is taking final action on the remaining areas  (the City of
Baltimore and Anne Arundel, Baltimore, Carroll, Harford, and Howard
Counties) in December 2008.  On December 5, 2008, EPA gave notice that
it is proposing  to add Prince George's and Montgomery Counties,
Maryland to the Baltimore nonattainment area.  EPA is giving the State
the benefit of the statutory opportunity to respond to this proposal,
and will not finalize the designation of these counties as part of the
Baltimore area for the 120-day period provided in the statute.  EPA will
thus make a final designation determination whether Montgomery and
Prince George’s Counties should be included in the Baltimore
nonattainment area for the 2006 24-hour PM2.5 standard in April 2009.

3.3.  Birmingham, AL

See section 2.3 for comments regarding this particular nonattainment
area.

3.4.  Canton-Massillon, OH

Comment:

One commenter (0118) supports EPA recommendations for the State of Ohio.
 The commenter requests that EPA designation Stark County as
nonattainment.  This is the same county that EPA has proposed as a
candidate for a designation of nonattainment.  The commenter cites
negative health impacts from PM2.5 and its contribution to regional
haze.

EPA Response:

EPA acknowledges this comment and has made the final determination that
Stark County should be within the boundary for the designated
Canton-Massillon area as nonattainment.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer to the TSD and
the State and Tribal RTC document which explains EPA’s decisions.

3.5.  Charleston, WV

See section 2.2 for general comments relevant to this particular
nonattainment area.

3.6.  Chicago-Gary-Lake County, IL-IN

Comment:

One commenter (0091) supports EPA recommendations that the Counties of
Cook, Will, DuPage, Lake, Kane, McHenry and portions of Kendall and
Grundy Counties in Illinois; and Lake and Porter Counties in Indiana be
designated as nonattainment in the Chicago-Gary-Lake, IL-IN area.  The
commenter is concerned the modernization and expansion of the BP
refinery in Whiting, IN due to be completed in 2011 or 2012.  The
commenter disagrees with EPA’s recommended designations of a partial
for Kendall County.  The commenter recommends that EPA to designate the
remainder of Kendall County, IL as nonattainment due to commuting and
growth patterns.

EPA Response:

EPA is aware of the growth that Kendall County has experienced.  Still,
the emissions from Kendall County remain a small amount of the Chicago
area emissions.  EPA agreed with Illinois to include a portion of
Kendall County in the Chicago nonattainment area.  This also retains the
same nonattainment area as for the 1997 fine particulate standards and
the ozone area which aids in the planning process.

EPA is also designating Lake and Porter Counties in Indiana as
nonattainment.  Changes at a Lake County, Indiana refinery will follow
the permitting process.  The impact of the planned expansion on fine
particulate pollution in the area will be analyzed as part of the
permitting process.  Illinois and Indiana will also need to include
planned expansions and the resulting from the loss of CAIR as the States
develops plans to bring the Chicago area into attainment.

Comment:

One commenter (0100) supports EPA’s recommendation and request that
EPA designate Cook, DuPage, Kane, Lake, McHenry, Will, Kendall, and
Grundy (partial) counties in Illinois as nonattainment.  The commenter
cites negative health impacts from PM2.5 and its contribution to
regional haze.

EPA Response:

EPA acknowledges this comment and has made the final determination that
Cook, DuPage, Kane, Lake, McHenry, Will, Kendall (partial), and Grundy
(partial) counties should be included in the nonattainment boundary for
the Chicago-Gary-Lake County area for the designations for the 2006
24-hour PM2.5 standard.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer to the TSD and
the State Tribal RTC document which explains EPA’s decisions.

3.7.  Chico, CA

See section 2.2 for general comments relevant to this particular
nonattainment area.

3.8.  Cincinnati-Hamilton, OH-KY-IN

Comment:

One commenter (0114) requests that EPA deny the exceptional events
request from Kentucky Division of Air Quality, citing negative health
impacts from PM2.5.  The commenter requests that EPA designate Kenton
and Warren Counties as nonattainment.

EPA Response:

EPA has reviewed the Commonwealth of Kentucky’s request for
consideration of exceptional events and has made a determination for
these requests on an individual basis depending on the event and the
supporting document.  As explained in EPA’s June 08, 2007, guidance
entitled Air Designations for the Revised 24-hour Fine Particulate
Matter Standard,

“Air quality monitoring data affected by exceptional events may be
excluded from use in identifying a violation if they meet the criteria
for such an exclusion, as specified in the Final Rule on the Treatment
of Data Influenced by Exceptional Events (72 FR 13560).”

 Attached to the TSD in support of EPA’s final designations for the
revised daily PM2.5 standard
(http://www.epa.gov/pmdesignations/2006standards) is a very detailed
analysis all of the exceptional events requests for Kenton County,
Kentucky.  (See Enclosure 3 of TSD).  While EPA did concur with this
exceptional events request and thus the Kenton monitor is not shown as
violating based on 2005-2007 monitoring data, EPA is designating Kenton
County, KY and Warren County, OH as part of the Cincinnati-Hamilton
nonattainment area because these counties have been shown through
EPA’s analysis as contributing to the violations in the
Cincinnati-Hamilton area.  This conclusion is further supported by the
conclusion that was reached for this same area when EPA finalized the
nonattainment designation for the Cincinnati-Hamilton area in 2005 for
the 1997 annual PM2.5 standard.   The Cincinnati-Hamilton area
(consisting of the same boundaries as outlined in the designations for
the 2006 24-hour PM2.5 standard) is still in violation of the 1997
annual PM2.5 standard.  Please refer to the TSD and the State and Tribal
RTC document which explains EPA’s decisions.

Comment:

One commenter (0118) supports EPA recommendations for the State of Ohio.
 The commenter requests that EPA designate Butler, Clermont, Hamilton,
Knox and Warren counties as nonattainment.  These are the same counties
that EPA has proposed as candidates for a designation of nonattainment.
The commenter cites negative health impacts from PM2.5 and its
contribution to regional haze.

EPA Response:

EPA acknowledges this comment and has made the final determination that
Butler, Clermont, Hamilton, Knox and Warren Counties in Ohio should be
included in the nonattainment boundary for the Cincinnati-Hamilton area
for the designations for the 2006 24-hour PM2.5 standard.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer to the TSD and
the State Tribal RTC document which explains EPA’s decisions.

Comment:

One commenter (0137) supports EPA’s recommendations and requests that
EPA designate Boone, Campbell and Kenton counties in Kentucky as
nonattainment.  The commenter cites negative health impacts from PM2.5
and its contribution to regional haze.

EPA Response:

EPA acknowledges this comment and has made the final determination that
Boone, Campbell and Kenton counties in Kentucky should be included in
the nonattainment boundary for the Cincinnati-Hamilton area for the
designations for the 2006 24-hour PM2.5 standard.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.

3.9.  Clarksville, TN-KY

Comment:

One commenter (0137) supports EPA’s recommendations and requests that
EPA designate Muhlenberg County, KY, as nonattainment.  The commenter
cites negative health impacts from PM2.5 and its contribution to
regional haze.

EPA Response:

EPA acknowledges this comment and has made the final determination that
a portion of Muhlenberg County, KY should be included in the
nonattainment boundary for the Clarksville-Hopkinsville area for the
designations for the 2006 revised daily PM2.5 standard.  While it was
announced in the August 19th letter from EPA to Governor Beshear, that
EPA was considering the entire county of Muhlenberg for nonattainment,
the Commonwealth of Kentucky has provided EPA with sufficient
information regarding the source of emissions in the county to justify a
partial boundary versus the entire county.  Please refer to the TSD and
the State and Tribal RTC document which explains the additional data and
EPA’s decisions.

Comment:

One commenter (0086) disagrees with EPA’s recommended designation that
Humphreys County, TN be designated nonattainment as a contributor to the
violating monitor in Montgomery County, TN.  The commenter believes that
EPA based the nonattainment designation solely on presence of a power
plant and believes this is inappropriate under the criteria set forth in
section 107(d) of the CAA.  The commenter believes that EPA’s approach
to designations fails to articulate a technical basis for each
designation.  The commenter cites the factors used in the CAIR rule for
determining contribution, and implies that the same approach should be
used for purposes of designations.  The commenter believes that
Humphreys County should be in attainment since no monitor shows a
violation and the county is not contiguous to Clarksville MSA.  The
commenter believes that EPA improperly evaluated its own 9-factor
analysis and that, at a minimum, the nonattainment area can be narrowed
to the census block(s) encompassing the power plant, if it remains the
cause of EPA’s concern.  The commenter generally endorses the comments
submitted by the Tennessee Valley Authority (TVA) in response to EPA’s
proposed determination with respect to designating a partial county in
the Clarksville KY-TN nonattainment area.

EPA Response:

EPA has evaluated additional information obtained after the announcement
of EPA’s initial intended recommendations as outlined in the August
19, 2008 letter from EPA to Governor Bredesen regarding designations for
the 2006 PM2.5 standard.  The review of this additional information
provides EPA with sufficient information to justify a partial county
boundary for Humphreys County as recommended by this commenter.

Further, EPA acknowledges the commenter’s concern with the
consideration of emissions due to the power plant and also acknowledges
the commenter’s concern with the use of the factors as outlined in
EPA’s June 08, 2008 boundary guidance versus factors used in the CAIR.
  EPA believes that it is most appropriate to use the recommended nine
factors that States and EPA would take into consideration, in addition
to other relevant factors or circumstances specific to a particular
area, in determining appropriate nonattainment area boundaries and would
also note that the CAIR was recently vacated by the D.C. Circuit Court.
EPA does not believe that modeling is required by section 107(d), or
necessary to make a determination for nonattainment area boundaries.
EPA use relevant information such as monitoring data, emissions data,
meteorological data, and other relevant information to make the
determination on boundaries.  Please see responses in section 2.2 above
relating to inclusion of non-contiguous counties including power plant
sources, relevance of litigation on prior designations, and relevance of
modeling done to support CAIR.  In addition, please see the TSD for this
area which outlines the technical determination that based on the size
of the contributing sources, location in relation to the violating
monitors, meteorology, and lack of other sources, population or
commuting within the county, EPA concluded that the partial county only
was appropriate for inclusion within the nonattainment area.

With regard to the commenter’s statement that Humphreys County should
not be designated nonattainment because the county does not have a
violating monitor and is not contiguous to the Clarksville MSA, EPA
notes that the Act requires that EPA consider areas that contribute to
violations in addition to areas that have violating monitors.  EPA
determined that the emissions from an identified power plant in
Humphreys County were contributing to the violations in a nearby area.
In this case, EPA’s assessment identified that source as the most
significant emissions source in the area (i.e., little or no mobile
source or other human activity-based emissions), and EPA concluded that
it was appropriate to designate as nonattainment only the portion of the
county where the source is located, even if that portion is not
contiguous with the remainder of the nonattainment area.  EPA selected
the boundaries for this noncontiguous portion of the nonattainment area
by relying on legally recognized governmental boundaries (e.g.,
townships, tax districts, or census blocks) in which the source is
located.  EPA’s 2006 PM2.5 designation boundary guidance states that
the criteria for determining appropriate boundaries is to be made on a
case-by-case basis, considering the recommended nine factors in addition
to other relevant factors or circumstances specific to a particular
area.

EPA recognizes that many areas in the country are making improvements in
their air quality, and believes that it is important to recognize such
improvements.  In making decisions about whether an area is meeting the
24-hour PM2.5 NAAQS, EPA also believes that it is important to use the
most recent air quality data.  EPA will be unable to use 2008 data air
quality data for the designation decisions that will be made in December
2008 as that data will not be available at that time.  However, all
States will still have the opportunity to benefit from their efforts to
improve air quality by using 2008 air quality data to demonstrate
attainment of the 24-hour PM2.5 NAAQS.  Please see section 2.3 regarding
the submission of 2008 data.

Comment:

Factor 1 - The commenter (0086) believes that the CES does not represent
emissions of Humphreys County.  The commenter provides additional
information on the emissions after 2005 in the county.

EPA Response:

EPA recognizes that the distance weighting factor used in the CES
affects an individual county’s score.  However, the difference between
the weighting factor associated with a distance of 39 miles versus 50
miles is only 0.005, which is too small to make a substantial difference
in the contribution from Humphrey’s County.  Even though the commenter
recalculated the Humphreys County CES to be 84, that value is still high
relative to the other CES values of the surrounding counties to warrant
considering its inclusion in a nonattainment area boundary for
Clarksville.

Comment:

Factor 2 - The commenter (0086) believes that if the most recent data
from 2008 is used, the violating monitor is likely to be in compliance;

Factor 6 – The commenter cites there were only two high days according
to EPA’s pollution rose and on those days the average wind speed is
very low, indicative of days.  The commenter states that Davidson County
has higher VOC, NOX, NH3 and carbon emissions and is closer to the
violating monitor.  The commenter provided additional information;

Factor 8 – Humphreys County is not in the MSA; and

Factor 9 – The commenter provides additional information on the
controls in the county.

EPA Response:

EPA considered the individual facts and circumstances in the Clarksville
nonattainment area in determining whether to include a county or part of
a county as contributing to a particular nonattainment problem.  Neither
the CAA nor EPA’s designations guidance establishes thresholds for
determining the designations status of an area.  For example, the
guidance does not identify a set amount of a pollutant, or a specific
level of commuting between counties, that would automatically require a
county or part of a county to be included in a nonattainment area.

EPA acknowledges the commenters concern with EPA’s use of the CES, the
contribution based on meteorology and the commenter’s attempt to make
a direct comparison of emissions for this area and Davidson County. As
EPA conducted its analysis, Davidson County was considered but a
determination was made that this county is not contributing to
violations in Montgomery County.  Further, after review and
consideration of all pertinent information as described in the TSD for
this area, EPA has made the determination that only a portion of
Humphreys County should be included in the Clarksville nonattainment
area.   It is important to note that EPA makes a case-by-case
determination in considering the nine factors.   Based on the emissions
from Humphreys County, location in relation to the violating monitor,
and meteorology, EPA concluded that the stationary source emissions did
contribute to the violating monitor even with consideration of current
controls.   Not every factor was relevant in each area (e.g., in many
eastern locations topography is not an issue), nor was every factor
equally important to each area.   Due to the complex and variable nature
of PM2.5, the important factors varied from one area to another based on
local circumstances.  While Humphreys County is not within the MSA, EPA
has made a determination that it is contributing to the violations for
the Montgomery County monitor.  EPA has included non-MSA counties as
part of other nonattainment areas when a determination has been made
that these counties, or a portion thereof, are contributing to a
violation.  See section 2.2 above fro general responses on 2008 data,
MSA boundaries, and consideration of emissions controls.

Comment:

One of commenters (0128) disagrees with EPA’s proposed designation for
Muhlenberg County, KY as nonattainment.  The commenter does not believe
that Muhlenberg County, KY is contributing to the violating monitor in
Montgomery County, TN.  The commenter believes that Tennessee should be
given additional time to address a Clarksville violation, referring to
the State’s letter.  The commenter believes the CES was incorrectly
applied for Muhlenberg County because the score is 100 and the commenter
believes that Muhlenberg does not contribute 100 percent of the excess
urban PM2.5 emission in Clarksville, TN.  The comment believes that it
is improper for the EPA to use the CES because there was no public
notice and comment period prior to using the metric.  The commenter
noted that Muhlenberg is not contiguous and is separated by Montgomery
County which shows attainment.  The commenter states that factors 1 and
9 are flawed because EPA does not consider controls.  The commenter
believes that EPA’s proposal is based on MSA boundaries.  The
commenter notes pending litigation challenging EPA’s 1997 PM2.5
designations (e.g., nonattainment designation of isolated areas that
show attainment because they contain power plants).

EPA Response:

EPA disagrees with the commenter’s assertion that the application of
the 9-factor analysis and how it applies to the designation decision was
inappropriate.  The technical support document in association with the
designation rulemaking clearly articulates EPA’s analysis of each
factor in relation to this area.  EPA has evaluated additional
information obtained after the announcement of EPA’s initial intended
recommendations as outlined in the August 19, 2008 letter from EPA to
Governor Beshear and Governor Bresdsen regarding designations for the
2006 PM2.5 standard.   The review of this additional information
provides EPA with sufficient information to justify a partial county
boundary for Muhlenberg County as recommended by this commenter.   EPA
believes it has sufficient data to make a designation for this area and
thus can not delay the designation.

Further, EPA acknowledges the commenter’s concern with the
consideration of emissions due to the power plant and also acknowledges
the commenter’s concern with the use of the recommended factors as
outlined in EPA’s June 08, 2008 guidance.  Power plant emissions in
this area account for a large amount of the emissions in this area.  EPA
used the nine factors to make a determination on whether this area is
contributing to the violation in Montgomery County.  EPA believes that
it is most appropriate to use the recommended nine factors that States
and EPA would take into consideration, in addition to other relevant
factors or circumstances specific to a particular area, in determining
appropriate nonattainment area boundaries.

With regard to the commenter’s statement that Muhlenberg County should
not be designated nonattainment because the commenter believes that
Muhlenberg is not contributing to monitored violations in the
Clarksville nonattainment area, EPA notes that the Act requires that EPA
consider areas that contribute violations in addition to areas that have
violating monitors.  EPA determined that the emissions from an
identified power plant in Muhlenberg County were contributing to the
violations in a nearby area.  In making this determination EPA did
consider controls currently in place at this facility.  In this case,
EPA’s assessment identified that source as the most significant
emissions source in the area (i.e., little or no mobile source or other
human activity-based emissions) and thus concluded that it was
appropriate to designate as nonattainment only the portion of the county
where the source is located, even if that portion is not contiguous with
the remainder of the nonattainment area.  EPA selected the boundaries
for this noncontiguous portion of the nonattainment area by relying on
legally recognized governmental boundaries (e.g., townships, tax
districts, or census blocks) in which the source is located.  EPA’s
2006 PM2.5 Designation Boundary Guidance states that the criteria for
determining appropriate boundaries is to be made on a case-by-case
basis, considering the recommended nine factors in addition to other
relevant factors or circumstances specific to a particular area.  Please
refer to the TSD and the State and Tribal RTC document which explains
EPA’s decisions.

The commenter is mistaken about the interpretation of the CES.  The CES
TSD states the total score a county receives is normalized to the
highest scoring county.  This means that a particular county’s score
is relative to the score from the county with the largest contribution.
So a county with a score of 100 means that county had the highest
contribution on the violating county, while a county with a score of 34
means that particular county’s contribution was 34 percent of the
contribution belonging to the county with the score of 100.  The CES
does not in any way attempt to quantify the total contribution to the
violating monitor across all counties, or indicate that the county with
a score of 100 is contributing all of the pollution in a given
nonattainment area.  Rather, it attempts to quantify the contribution
any one county has on the violating county based on the largest
contribution across all of the counties. Muhlenberg’s score of 100
clearly supports the inclusion within the nonattainment area in
conjunction with other information.

Comment:

Another commenter (0164) believes the CES was incorrectly applied in the
instance of determining nonattainment for Muhlenberg County.
Specifically the commenter notes the following:

Emissions data from the 2005 NEI referenced by EPA are not
representative of current emissions from Muhlenberg County;

Insufficient information is provided by EPA to review the wind
trajectory weighting factor in the CES equation; and

The centroid method for determining distance in CES equation is not
appropriate because the location of primary emission sources and taller
stacks at large distances.

EPA Response:

With respect to the concern about accuracy of the 2005 NEI emissions
inventory, EPA invited States to provide supplemental information to the
Agency if it would indicate significant changes in emissions since 2005,
and where submitted EPA took such information into consideration for the
final designations decisions.

EPA believes that the pollution roses it provided illustrate the pattern
of contribution to ambient high PM2.5 concentration days in this area.
The trajectories that the State of Kentucky submitted have limitations
in their interpretation.  First, all of the trajectories are backward
trajectories that start on the sixth hour of the day following the day
with the exceedance.  This can lead to misleading results since the air
impacting the violating site arrives at the site during the day of the
exceedance not following it.  Thus, air patterns on the day of the
exceedance can be very different than those seen even six hours after
the 24-hour exceedance is captured.  Another issue with Kentucky’s
trajectory analysis is that only State boundaries are plotted to orient
the viewer as to where the trajectory paths are traversing over.  There
are no county boundaries to give a good indication of whether or not the
trajectories are over or near Muhlenberg County.

EPA relied on more than surface wind patterns in assessing the
contribution of Muhlenberg County on Clarksville, TN.  HYSPLIT back
trajectories were used to determine which counties’ air parcels were
passing through on their way to the violating monitor.  Those
trajectories played an essential role in the calculation of the CES.
EPA used several trajectories that started from four heights at three
hour intervals on the day of the exceedance.  All start heights were at
or below the mixing height.  The commenter has questioned the
methodology of how EPA calculated the mixing heights.  The mixing
heights were calculated directly through the HYSPLIT model at the
initial starting time and then at each point the model outputted along
the trajectory path.  EPA also plotted the trajectories from days where
the PM2.5 concentrations were greater than the 98th percentile to see
where the air parcels were traversing on their way to the violating
monitor.  On several of those days, air passes over Muhlenberg County on
its way to the violating monitor in Clarksville, TN.  In fact, the days
when air passed over Muhlenberg County from 2005-2007, the Clarksville
monitor measured higher concentrations than when the winds were from the
south.

Although the Brode memo concluded that a 1/D1.5 weighting factor is
appropriate for low-level sources and for all source types for long-term
averages, the results appeared to support using the 1/D screening
technique as a conservative approach to screening out sources.  Since
the CES is foremost a screening tool to provide an initial set of
counties to be assessed for inclusion in a nonattainment area, the use
of 1/D to conservatively filter out counties appearing to contribute to
the violation is appropriate for the general application of the CES
across the entire country.  Information specific to an individual area
would then have been used to further refine which counties would remain
within a nonattainment area’s boundaries.

With respect to the commenter’s concerns about the “centroid”
approach EPA adopted in the CES methodology, EPA has explained the basis
for this approach in the TSD for the CES.

Comment:

The commenter (0164) also believes that the TSD does not support the
inclusion of Muhlenberg County.  The commenter believes the monitor
placement is flawed.  The commenter states that monitor #47-125-1009 is
sited in an area that could result in elevated air contamination due to
localized influences, and thus concentrations at this monitor would not
be representative of the wider region.

EPA Response:

EPA conducted a site evaluation on the Clarksville monitor on July 9 -
10, 2008 and concluded that the site meets siting criteria of 40 CFR 58
Appendix E.  A second PM2.5 monitoring site has been established in
order to verify the accuracy of data collected at the initial site and
to identify any potential local influence.

Comment:

One commenter (0164) specifically notes the following:

Factor 1 – The commenter believes the CES is inappropriate because
controls were installed at one of the power plants in the county in 2006
and the data used to calculate the CES is from 2005;

Factor 2 – There is no PM2.5 ambient monitor in Muhlenberg County and
thus no violations of the PM2.5 NAAQS have been shown.  Moreover, the
monitor located between Muhlenberg County and Clarksville, TN shows
compliance;

Factor 3 – The commenter believes this factor does not support
including Muhlenberg County in the designation;

Factor 4 – The commenter believes this factor does not support
including Muhlenberg County in the designation;

Factor 5 – The commenter believes this factor does not support
including Muhlenberg County in the designation;

Factor 6 – The commenter suggests that EPA should re-evaluate the use
of only surface meteorological wind speeds and directions and consider
back trajectories at all atmospheric levels to determine whether or not
Muhlenberg County emissions are truly in the mixed boundary layer
arriving in Montgomery County.  The commenter cited back trajectories
submitted by Kentucky; and

Factor 8 – The commenter believes this factor does not support
including Muhlenberg County in the designation because Muhlenberg County
is not included in the Clarksville MSA.

EPA Response:

EPA disagrees with the commenter’s assertion that the application of
the 9-factor analysis (including the CES, see response above) and how it
applies to the designation decision was inappropriate.  The TSD in
association with the designation rulemaking clearly articulates EPA’s
analysis of each factor in relation to this area.  The Act specifically
prescribes that EPA designate any area that does not meet the standard
or that contributes to an area’s inability to meet the standard for a
newly established or revised standard.  EPA has made the determination
as described in the TSD (through its analysis and the information
provided by the Commonwealth of Kentucky and the State of Tennessee)
that a portion of Muhlenberg County is contributing to the violations at
the Montgomery County monitor.  Further, EPA acknowledges that updated
information on controls for Muhlenberg County became available and has
considered this updated information for designation purposes for this
area.  It is important to note that air quality data and level of
emissions (not necessarily level of controls) are important
considerations for whether an area is violating or contributing to a
violation.  EPA concludes, as explained in the TSD, that even with
additional controls on the facility in Muhlenberg the plant is still
contributing to the monitored violations.  EPA’s approach of including
non-MSA, noncontiguous partial counties to capture sources that
contribute emissions to a downwind area which has violations is
consistent with the approach used for the nonattainment designations for
the 1997 annual PM2.5 standard.  In this case, EPA’s assessment
identified that source as the most significant emissions source in the
area (i.e., little or no mobile source or other human activity-based
emissions), and thus concluded that it was appropriate to designate as
nonattainment only the portion of the county where the source is
located, even if that portion is not contiguous with the remainder of
the nonattainment area.

3.10.  Cleveland-Akron-Lorain, OH

Comment:

One commenter (0118) supports EPA recommendations for the State of Ohio.
 The commenter requests that EPA designate Ashtabula (partial),
Cuyahoga, Lake, Lorain, Medina, Portage and Summit Counties as
nonattainment.  These are the same counties that EPA has proposed as
candidates for a designation of nonattainment.  The commenter cites
negative health impacts from PM2.5 and its contribution to regional
haze.

EPA Response:

Ohio supplied additional information on a power plant in Ashtabula
County.  The facility has permanently shut down most of its operations
resulting in large decrease in emissions.  Ohio has shown that the
facility cannot increase emissions without obtaining a new permit.  EPA
initially recommended designating a partial county area of Ashtabula
County as nonattainment because its emissions contributed to the
violations in the Cleveland area.  Based on the new data, EPA concludes
that the county has lowered emissions to such an extent that the area no
longer can be considered contributing to the monitored violations.
Thus, EPA is designating all of Ashtabula County as
unclassifiable/attainment because of the emission reductions.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer to the TSD and
the State and Tribal RTC document which explains EPA’s decisions.

3.11.  Columbus, OH

Comment:

One commenter (0118) supports EPA recommendations for the State of Ohio.
 The commenter requests that EPA designate Coshocton (partial),
Delaware, Fairfield, Franklin and Licking Counties as nonattainment.
These are the same counties that EPA has proposed as candidates for a
designation of nonattainment.  The commenter cites negative health
impacts from PM2.5 and its contribution to regional haze.

EPA Response:

EPA acknowledges the supporting comment and made the final designations
for the 2006 24-hour PM2.5 NAAQS using an evaluation of the recommended
nine factors described in the June 2007 guidance as well as other
relevant information in determining appropriate nonattainment area
boundaries.  Please refer to the TSD and the State and Tribal RTC
document which explains EPA’s decisions.

3.12.  Davenport-Moline-Rock Island, IA-IL

Comment:

One commenter (0171) supports EPA’s recommendations for all of Scott
County, IA, and Rock Island County, IL, to be designated as
nonattainment.  The commenter states that high background concentrations
of fine particulate matter indicate sources outside the cities of
Muscatine and Davenport are the sources are contributing to the fine
particulate matter concentrations recorded.

EPA Response:

EPA recommended designating the whole county of Scott County as
nonattainment due to monitored violations and an initial review of the
9-factor analysis.  In October 2008, Iowa provided additional
information on the area in response to EPA’s 120-day letter.  Based on
an analysis of the data provided by the State, in conjunction with the
9-factor analysis, EPA determined that it could not support the
State’s recommended boundary, but that a partial county designation
was appropriate.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer the TSD and the
State and Tribal RTC document which explains EPA’s decisions.

Please refer to the TSD for long range transport discussion.

Comment:

One commenter (0100) supports EPA’s recommendation and requests that
EPA designate Rock Island County, IL, as nonattainment.  The commenter
cites negative health impacts from PM2.5 and its contribution to
regional haze.

EPA Response:

EPA recommended designating the whole county of Rock Island County as
nonattainment due to its contributions in Scott County, Iowa and an
initial review of the 9-factor analysis. In October 2008, Illinois and
Iowa provided additional information on this bi-state area in response
to EPA’s 120-day letters.  Based on a analysis of the data provided by
the States, in conjunction with the 9-factor analysis, EPA determined
that it could not support the State’s recommendation to exclude Rock
Island County from the designation, but that a partial county
designation was appropriate.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer to the TSD and
the State and Tribal RTC document which explains EPA’s decisions.

Comment:

One commenter (0091) agrees with EPA’s recommendations for the
proposed Davenport-Moline-Rock Island area and for including Rock Island
and Scott Counties based on measured nonattainment with the standard
within that combined urbanized area.

EPA Response:

EPA recommended designating the whole county of Rock Island County, IL
and Scott County, IA as nonattainment due monitored violations,
contributions to those monitored violations, and an initial review of
the 9-factor analysis. In October 2008, Illinois and Iowa provided
additional information on this bi-state area in response to EPA’s
120-day letters.  Based on an analysis of the data provided by the
States, in conjunction with the 9-factor analysis, EPA determined that
it could not support the State’s recommendation to exclude Rock Island
County from the designation, or designate a very small portion of Scott
County, but that a partial county designations for both counties was
appropriate.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer the TSDs and
the State and Tribal RTC document which explain EPA’s decisions.

Comment:

One commenter (0142) disagrees with EPA’s designations.  The commenter
requests that Rock Island County, IL, be designated as attainment.  The
commenter requests a 1-year delay from the EPA for the designation of
Scott County, IA.

EPA Response:

EPA noted that there was sufficient monitoring data to designate the
violating area as nonattainment, and a 1-year extension to obtain
additional monitoring information is not justified.  EPA must designate
an area as nonattainment if the area is monitoring, or contributing to,
a violation of the standard based on the most recent three years of
monitoring data. There is sufficient monitoring data available to make
the designation.

Comment:

One commenter (0142) cites the following issues with the technical
analysis:

Factor 1 – The commenter believes EPA’s Regions 5 and 7 do not
provide criteria (i.e., the CES) that concludes to Rock Island
contributing to Scott County.  The commenter cites that the 2005
National Emissions Inventory (NEI) for Rock County are higher that the
values published by the Illinois EPA.

EPA Response:

There is no specific level or value of the CES that determines whether
or not a county contributes enough to a PM problem at a violating
monitor.  Rather, the CES provides an indication of the magnitude of a
county’s contribution in relation to the county with the largest
contribution.  Any county with a CES larger than zero can be viewed as
contributing something to the violation.  However, the information from
the CES needs to be used in conjunction with data from other sources
such as the nine factors recommended in EPA guidance to fully consider a
range of factors that could possibly be contributing to the violation.

The CES suggests that Rock Island County contributes about 27 percent of
the contribution that Scott County contributes to the violation.  The
quantities of emissions for individual particulate matter-related
pollutants present a similar perspective.  For two examples, for SO2,
Rock Island County versus Scott County estimated emissions are 2,169
versus 9,173 tons per year, or 24 percent, and for NOx, Rock Island
County versus Scott County estimated emissions are 6,140 versus 11,317
tons per year, or 54 percent.  Examination of trajectory information
also suggests that emissions in various parts of Rock Island County
contribute to the violation in Davenport with a very similar frequency
as do the emissions in various parts of Scott County.  EPA considers
these indicators of impact from Rock Island County to signify
sufficiently large impact to conclude that Rock Island County
contributes to violations in Scott County.

EPA utilized 2005 National Emissions Inventory (NEI) data in its
technical analysis.  EPA used the NEI because it is the most recent
quality assured data maintenance system available nationally.  The EPA
promulgated nonattainment area boundary (Rock Island County and Scott
County) captures 98 percent of the total SO2 emissions, 91 percent of
the total NOX emissions and 63 percent of the total PM2.5 emissions.

Comment:

Factor 2 – The commenter (0142) believes that the background 24-hour
PM2.5 value for the state is approximately 30 μg/m3.  This is the same
value measured in Rock Island County.  This conclusion is supported by
the monitoring data which shows that the two other monitoring sites in
Scott County report very similar air quality results as the Rock Island
monitor.  These values are at or near the typical regional background
level.

EPA Response:

There are multiple monitoring objectives served by the State’s
monitoring network.  In the instance of the Davenport area, the
violating monitor at the 300 Wellman site is situated to assess the
potential for source level impacts in the neighborhoods surrounding
several industrial facilities.  The Adams School site is situated to
assess population exposures in direct comparison with the NAAQS.  The
Jefferson School site is also situated for assessment of population
exposure NAAQS compliance, and it also incorporates chemical speciation
and a continuous monitor to establish a clearer picture of PM2.5
behavior in the Davenport area.  Monitor network design is largely
influenced by the data collection priorities of each individual State.
Annual monitoring network plans are submitted by each state and are
reviewed and approved by EPA.   EPA establishes minimum monitoring
network requirements in the code of federal regulations, but States are
allowed and encouraged to invest in more thorough data collection
systems.  Both of the violating monitors are designated as eligible for
comparison with the NAAQS consistent with 40 CFR Part 58.

The monitored values at the Rock Island County monitor and some of the
Scott County monitors show values consistent with other monitors in
Illinois.  The commenter seems to attribute the Scott County violation
solely to emissions from local sources.  EPA feels that emissions from
throughout the Davenport-Rock Island-Moline area also contribute to the
Scott County violation.  Local sources may add the “last increment”
to cause the Scott County violation, but they are not responsible for
the entire concentration.  Source throughout the area also contribute to
the violations.  It is not surprising that monitors in other moderately
sized Illinois areas show similar concentrations to the Rock Island
County value.  These are areas would likely have similar emissions and
thus add a similar urban increment to the regional background
concentration.

Comment:

The commenter (0142) cites that Iowa DNR modeling demonstrates that the
nonattainment site in Scott County is significantly influenced by local
sources.

EPA Response:

As stated previously, nonattainment area designations are to include the
area in violation and areas shown to contribute to the violation.
Although modeling data provided by the state demonstrates that the two
named local sources influence the violation at the 300 Wellman monitor,
the modeling did not demonstrate that other point sources in the
Davenport-Moline-Rock Island area do not contribute to the violation as
well.  For the reasons detailed in the TSDs for the
Davenport-Moline-Rock Island area and Muscatine, EPA has determined that
other point sources in the area contribute to violations of the NAAQS.
Thus, EPA is establishing a nonattainment area boundary to include these
sources.  Refer to EPA’s TSDs for Iowa and Illinois which address
these issues in greater detail.

Comment:

Factors 4, 6 and 8 – The commenter ( 0142) cites EPA’s statement
from the Technical Support Document stating, “Population data give an
indication of whether it is likely that population-based emissions might
contribute to violations” and believes EPA did not provide any
additional analysis.

EPA Response:

The urbanized portions of Scott and Rock Island counties are
geographically located close to each other, i.e. the area is commonly
known as the Quad Cities area.  The Quad Cities area of Iowa includes
the cities of Davenport and Bettendorf on the Iowa side, and Moline and
Rock Island on the Illinois side.  The populations in the counties
evaluated are predominantly concentrated in the urbanized portions of
the counties in near proximity to the 300 Wellman monitor.  The EPA
designated nonattainment area is focused primarily on the urbanized area
of Scott County, and captures approximately 89 percent of the county
population.

Rural Scott County, which comprises a relatively small portion of the
county’s population, is associated with relatively low
population-based area source emissions and potential contribution to the
violating monitor.  Similarly, the near proximity of the urbanized
population in Rock Island County to the violating monitor can indicate
potential to contribute to the violating monitor.  This supports a
boundary that is focused on the urbanized portions of Scott County and
Rock Island County that includes about 89 percent of the population of
both counties.

There are emissions associated people such as emissions from cars, both
for commuting and local trips, and houses.  Population and population
density are logically good indicators of these emissions.

Comment:

Factors 4, 6 and 8 – The commenter (0142) believes EPA did not explain
how these factors impact the monitored violations.

EPA Response:

In regards to vehicle miles traveled, the metropolitan area is the most
heavily vehicle-traversed part of the county.  As such, it is reasonable
to include the contiguous metropolitan area in the nonattainment
boundary.  The traffic and commuting data evaluated under Factor 4 are
also indicative of the vehicle related emissions and their distribution.

In evaluating the meteorology factor, the wind rose (refer to the Iowa
TSD) indicates that winds most frequently occur from a generally
southerly direction, from the southwest to the southeast, on high PM2.5
days.  This suggests relatively low contributions from areas located to
the west, north, and east of the monitor, including Clinton County,
northern portions of Rock Island County, and the most northerly portions
of Muscatine County.  EPA’s nonattainment boundary includes potential
emissions sources located upwind to the southwest, south, and southeast
of the violating monitor.

In evaluating the jurisdictional boundary factor, consideration was
given to existing boundaries and organizations that may facilitate air
quality planning and the implementation of control measures to attain
the standard.  There was a review of the information regarding the
Bi-State Regional Commission which represents the Metropolitan Planning
Organization (MPO) for urbanized area transportation planning in the
Quad Cities area.  The MPO serves Henry, Mercer, and Rock Island
Counties in Illinois, and Scott and Muscatine Counties in Iowa.  Its web
site is:   HYPERLINK "http://www.bistateonline.org"
www.bistateonline.org .  However, the Bi-State planning area itself was
not a key factor in determining the intended nonattainment boundary;
other factors pointed to a more localized nonattainment area boundary.

Comment:

Factor 9 – The commenter (0142) believes that Region 7 appropriately
considers emission reductions in Clinton County but not in Rock Island.

EPA Response:

Illinois did not provide information on control of sources in Rock
Island County.  So, EPA assumes that the emission estimates in the 2005
inventory reasonably represent current emissions.  If sources in Rock
Island County had added additional controls or other emission reductions
that would have lowered emissions from the 2005 levels, EPA would have
considered this.  Since this was not the case for Rock Island County,
the emissions considered in Factor 1 were accurate.

Comment:

One commenter (0083) requests that EPA designate a partial county
boundary for Scott County, Iowa, that is within the borders of the city
of Davenport, as nonattainment.  The commenter cites the technical
analysis from Iowa DNR that points to a point source nearby the
violating monitor as justification for the nonattainment boundaries.

EPA Response:

EPA conducted a case-by-case analysis of the violating areas based on
the information provided to it by the State and other relevant
information.  EPA must designate the violating area as nonattainment as
well as the area contributing to the violation.  The 120-day letter sent
to the State noted that the data the State provided did not support very
small partial county boundaries.  The data did not demonstrate a lack of
contribution from other sources in the area, nor did it demonstrate that
only the sources in immediate proximity to the violating monitors
contributed to violations.  As this information was not provided to the
EPA, its case-by-case review resulted in a decision to notify the State
of its intent to include county-wide areas in the nonattainment area
boundaries. Since that time the State responded to EPA’s 120-day
letter and submitted more data for review.  However, this data also did
not demonstrate that no other sources in the area were contributing to
the violation, nor did it demonstrate an overwhelming contribution
solely from the point sources nearest to the violating monitors.  On the
contrary it showed a considerable contribution (almost 50 percent of the
total filter mass) of secondary formation attributable to emissions
transported from a longer range in addition to a smaller contribution of
secondary formation from local point source emissions.  The State’s
technical response to EPA’s 120-day letter did not support as narrow a
boundary as recommended by the State.  EPA concluded that a larger
partial county designation, inclusive of the townships of the major
metropolitan areas includes the violating area and the nearby
contributing areas.  Refer to EPA’s response above concerning the
nature of the monitors.

Comment:

The commenter (0083) asserts that the violating monitoring sites are not
representative of ambient air quality throughout the county as the
violating monitors are source-oriented monitors and that “all
information” indicates that the air quality violations are limited to
the immediate areas around Blackhawk Foundry and Grain Processing
Corporation.  The commenter states that emissions from the entire
three-county area have not been shown to contribute to the monitored
violations and that the nonattainment area should not exceed the
“representative scale” of the two monitors.

EPA Response:

There are multiple monitoring objectives served by the State’s
monitoring network.  In the instance of the Davenport area, the
violating monitor at the 300 Wellman site is situated to assess the
potential for source level impacts in the neighborhoods surrounding
several industrial facilities.  The Adams School site is situated to
assess population exposures in direct comparison with the NAAQS.  The
Jefferson School site is also situated for assessment of population
exposure NAAQS compliance, and it also incorporates chemical speciation
and a continuous monitor to establish a clearer picture of PM2.5
behavior in the Davenport area.  Monitor network design is largely
influenced by the data collection priorities of each individual State.
Annual monitoring network plans are submitted by each state and are
reviewed and approved by EPA.   EPA establishes minimum monitoring
network requirements in the code of federal regulations, but States are
allowed and encouraged to invest in more thorough data collection
systems.  Both of the violating monitors are designated as eligible for
comparison with the NAAQS consistent with 40 CFR Part 58.

Nonattainment area designations are to include the area in violation and
areas shown to contribute to the violation.  Although modeling data
provided by the state demonstrates that the two named local sources
influence the violation at the monitors, the modeling did not
demonstrate that other point sources in the Quad Cities area do not
contribute to the violation as well.  For the reasons detailed in the
TSDs for the Davenport-Moline-Rock Island area and Muscatine, EPA has
determined that other point sources in the area contribute to violations
of the NAAQS.  Thus, EPA is establishing a nonattainment area boundary
to include these sources.  Refer to EPA’s TSDs for Iowa and Illinois
which address these issues in greater detail.

Comment:

The commenter (0083) suggests that EPA should not designate entire
counties as nonattainment, but should take into consideration efforts of
the two named point sources to negotiate, with the State,
“voluntary” control strategies.

EPA Response:

EPA recognizes the efforts by the state and the stakeholders to achieve
emissions reductions as soon as possible.  EPA also encourages both
states to continue efforts to assist the community in implementing
voluntary measures.

However, under section 107(d) of the Clean Air Act, in designating
nonattainment areas, EPA must designate, as nonattainment, areas that
are violating a NAAQS and areas that are contributing to the violations.
 This requirement does not authorize EPA to rely on the ongoing efforts
to develop further control strategies in determining nonattainment
boundaries.  EPA’s decision must be based on the statutory
requirements, and EPA’s promulgation of the nonattainment designations
for these areas, as described in detail in the TSDs, meets the statutory
requirements.

We also note that the state’s submission includes a “mitigation
plan” submitted by Blackhawk Foundry.  The plan states that the
company’s intended control strategy, when fully implemented, “will
significantly reduce PM2.5 concentrations”.  However, the document
also concludes that, after implementation of the “preferred
alternatives” identified in the company’s control strategy, the
“combination of the predicted concentration” from the foundry, and
the background concentration, “could result in a predicted exceedance
of the PM2.5 NAAQS”.  (“PM2.5 Emissions Mitigation Plan”, Oct. 10,
2008, at p. 3.)  This uncertainty provides additional justification for
establishing a boundary to ensure that emissions from other nearby
sources in the area are considered in developing the attainment
demonstration control strategies for these two areas.

Comment:

One commenter (0063/0067) disagrees with EPA’s designations.  The
commenter requests that Rock Island County, IL, be designated as
attainment.  The commenter believes that only a portion of Scott County,
IA should be designated as nonattainment.  The commenter cited the
following issues with the technical analysis:

Rock Island, IL, Scott County IA (Davenport-Moline-Rock Island, IA-IL)

Factor 1 – The commenter believes EPA gave inappropriate and
distortional weight to the CES.  The commenter believes EPA’s Regions
5 and 7 do not provide criteria (i.e., the CES) that concludes to Rock
Island contributing to Scott County.  The commenter cites that the 2005
NEI for Rock County are higher that the values published by the Illinois
EPA.

EPA Response:

EPA recognizes that the CES is one analytical tool used in the process
of determining nonattainment area boundaries and should not be
considered as the sole factor for EPA’s conclusions.  The CES is a
tool to provide an initial set of potential counties contributing to a
violation in an area.  Those counties were then further examined using
the nine factors and other information from the State and local air
agencies to determine the strength an validity of the evidence for
keeping or dropping counties from the initial set.

EPA is designating the partial county nonattainment area in Rock Island
and Scott Counties for the 2006 24-hour PM2.5 standard after considering
each of the nine factors, as detailed in the TSD.  For this decision the
EPA relied most heavily on emissions, air quality, meteorology, and
population.  The additional modeling data provided evidence that was
used to determine that a majority of emissions from nearby sources that
cause or contribute to the violation should be included in the
nonattainment area.  EPA determined that inclusion of the local point
source PM2.5 emissions is a highly significant consideration in
establishing the nonattainment boundaries.  For Scott County, the
boundary includes all of the local point sources.  The EPA defined
nonattainment includes the area violating the standard and the area that
is contributing significantly to the violation. The partial county areas
of Rock Island and Scott Counties fulfill this definition.

Comment:

 μg/m3.  The commenter cites that Iowa DNR modeling demonstrates that
the nonattainment site in Scott County is significantly influenced by
local sources and the monitor is designated as a SPM.

EPA Response:

As stated previously nonattainment area designations are to include the
area in violation and areas shown to contribute to the violation.
Although modeling data provided by the state demonstrates that the two
named local sources influence the violation at the monitor, the modeling
did not demonstrate that other sources in the Davenport-Moline-Rock
Island area do not contribute to the violation as well.  For the reasons
detailed in the TSDs for the Davenport-Moline-Rock Island area and
Muscatine, EPA has determined that other sources in the area contribute
to violations of the NAAQS.  Thus, EPA is establishing a nonattainment
area boundary to include these sources.  Refer to EPA’s TSDs for Iowa
and Illinois which address these issues in greater detail.

Comment:

Factors 4 and 6 – The commenter (0063/0067) believes EPA did not
explain how these factors impact the monitored violations.

EPA Response:

In regards to vehicle miles traveled, the metropolitan area is the most
heavily vehicle-traversed part of the county.  As such, it is reasonable
to include the contiguous metropolitan area in the nonattainment
boundary.  In evaluating the meteorology factor, the wind rose (refer to
the Iowa TSD) indicates that winds most frequently occur from a
generally southerly direction, from the southwest to the southeast, on
high PM2.5 days.  This suggests relatively low contributions from areas
located to the west, north, and east of the monitor, including Clinton
County, northern portions of Rock Island County, and the most northerly
portions of Muscatine County.  EPA’s nonattainment boundary includes
potential emissions sources located upwind to the southwest, south, and
southeast of the violating monitor.

EPA determined nonattainment area includes sufficient portions of Rock
Island County in Illinois to represent the predominance of population
and emissions.  EPA believes that sufficient commuting occurs between
Rock Island County and Scott County that Rock Island County must be
considered an integral part of the Davenport area.

Comment:

One commenter (0070) suggests that the EPA recommended entire county
nonattainment area designation for Scott County, IA be reduced to a “3
square mile area adjacent to the foundry”.  The commenter believes
that a whole county designation is unjust for the citizens and
businesses of Scott County, IA.

EPA Response:

EPA must designate the violating area as nonattainment as well as the
area contributing to the violation.  The 120-day letter sent to the
State noted that the technical support data it provided did not support
very small partial county boundaries.  The data did not demonstrate a
lack of contribution from other sources in the area, nor did it
demonstrate that only the sources in immediate proximity to the
violating monitors contributed to violations.  As this information was
not provided to the EPA, its case-by-case review resulted in a decision
to notify the State of its intent to include county-wide areas in the
nonattainment area boundaries. Since that time the State responded to
EPA’s 120-day letter and submitted more data for review.  However,
this data also did not demonstrate that no other sources in the area
were contributing to the violation, nor did it demonstrate an
overwhelming contribution directly from the point sources nearest to the
violating monitors.  On the contrary it showed a considerable
contribution (almost 50 percent of the total filter mass) of secondary
formation attributable to emissions transported from a longer range in
addition to a smaller contribution of secondary formation from local
point source emissions.  The State’s technical response to EPA’s
120-day letter did not support as narrow a boundary as recommended by
the State.  EPA concluded that larger partial county designations,
inclusive of the townships of the major metropolitan area will protect
public health and allow the State greater flexibility in establishing
its attainment demonstration.  With respect to impacts on county
residents and businesses, the State has flexibility under the CAA to
consider such impacts as it develops the control strategy to bring the
area into attainment of the air quality standard.

Comment:

One commenter (0079) disagrees with EPA’s recommended designations.
The commenter requests a one-year extension of the designation of Scott
County, IA and Rock County, IL.

EPA Response:

EPA notes that there was sufficient monitoring data to designate the
violating area as nonattainment, and a one-year extension to obtain
additional monitoring information is not justified.  EPA is obligated to
designate an area as nonattainment if the area is monitoring a violation
of the standard based on the most recent three years of monitoring data.
There is sufficient monitoring data available to make the designation.

Comment:

The commenter (0079) believes that there is insufficient information
based on the dramatically different technical conclusions between Iowa
DNR and EPA based on similar technical data and that designation of a
county in a statistical metropolitan statistical area is not supported
by EPA’s guidance and claims that EPA is not applying the guidance in
designation of Scott County, IA, Rock County, IL. The commenter believes
that EPA did not follow proper procedures required by 107(d)(1)(A) by
using 2005-2007 data.

EPA Response:

EPA did conduct a case-by-case analysis of the violating areas based on
the information provided to it by the State and other relevant
information.  EPA must designate the violating area as nonattainment as
well as the area contributing to the violation.  The 120-day letter sent
to the State noted that the data the State provided did not support very
small partial county boundaries.  The data did not demonstrate a lack of
contribution from other sources in the area, nor did it demonstrate that
only the sources in immediate proximity to the violating monitors
contributed to violations.  As this information was not provided to the
EPA, its case-by-case review resulted in a decision to notify the State
of its intent to include county-wide areas in the nonattainment area
boundaries. Since that time the State responded to EPA’s 120-day
letter and submitted more data for review.  However, this data also did
not demonstrate that no other sources in the area were contributing to
the violation, nor did it demonstrate an overwhelming contribution
solely from the point sources nearest to the violating monitors.  On the
contrary it showed a considerable contribution (almost 50 percent of the
total filter mass) of secondary formation attributable to emissions
transported from a longer range in addition to a smaller contribution of
secondary formation from local point source emissions.  The State’s
technical response to EPA’s 120-day letter did not support as narrow a
boundary as recommended by the State.  EPA concluded that a larger
partial county designation, inclusive of the townships of the major
metropolitan areas includes the violating area and the nearby
contributing areas.  Refer to EPA’s response above concerning the
nature of the monitors.

Comment:

The commenter (0079) believes that the Blackhawk Foundry monitor is not
representative of the general air quality conditions. The commenter
references 40 CFR 58 to describe the special purpose monitor in Scott,
County. The commenter believes that the PM2.5 concentrations are
dominated by long range transport.

EPA Response:

There are multiple monitoring objectives served by the State’s
monitoring network.  In the instance of the Davenport area, the
violating monitor at the 300 Wellman site is situated to assess the
potential for source level impacts in the neighborhoods surrounding
several industrial facilities.  The Adams School site is situated to
assess population exposures in direct comparison with the NAAQS.  The
Jefferson School site is also situated for assessment of population
exposure NAAQS compliance, and it also incorporates chemical speciation
and a continuous monitor to establish a clearer picture of PM2.5
behavior in the Davenport area.  Monitor network design is largely
influenced by the data collection priorities of each individual State.
Annual monitoring network plans are submitted by each state and are
reviewed and approved by EPA.   EPA establishes minimum monitoring
network requirements in the code of federal regulations, but States are
allowed and encouraged to invest in more thorough data collection
systems.  Both of the violating monitors are designated as eligible for
comparison with the NAAQS consistent with 40 CFR Part 58.

Nonattainment area designations are to include the area in violation and
areas that contribute to the violation.  Although modeling data provided
by the state demonstrates that the two named local sources influence the
violation at the monitor, the modeling did not demonstrate that other
sources in the Quad Cities area do not contribute to the violation as
well.  For the reasons detailed in the TSDs for the
Davenport-Moline-Rock Island area and Muscatine, EPA has determined that
other sources in the area contribute to violations of the NAAQS.  Thus,
EPA is establishing a nonattainment area boundary to include these
sources.  Refer to EPA’s TSDs for Iowa and Illinois which address
these issues in greater detail.

Please refer to the Iowa TSD for long range transport discussion.

Comment:

One commenter (0152) disagrees with EPA’s designations.  The commenter
requests that Rock Island County, IL be designated as attainment.  The
commenter believes that only a portion of Scott County, IA should be
designated as nonattainment.  The commenter cited the following issues
with the technical analysis:

Factor 1 – The commenter believes EPA gave inappropriate and
distortional weight to the CES.  The commenter believes EPA’s Regions
5 and 7 do not provide criteria (CES) that concludes to Rock Island
contributing to Scott County.  The commenter cites that the 2005 NEI for
Rock County are higher that the values published by the Illinois EPA.

EPA Response:

EPA’s intent for creating the CES was to use it as an initial
screening tool to emphasize nearby counties to the violating site that
should be evaluated as candidates for possible inclusion in a
nonattainment area based on contribution to the violations in the area.
Data from other sources including the factors proposed by EPA guidance
and State information provided through comment were considered for the
final boundary determination.  At no point in the process was any single
source of information used to be outcome-determinative nor was any
factor given more weight than another in making the final boundary
decisions.

Comment:

Factor 2 – The commenter (0152) believes that the background 24-hour
PM2.5 value for the State is approximately 30 μg/m3.  The commenter
cites that Iowa DNR modeling demonstrates that the nonattainment site in
Scott County is significantly influenced by local sources and the
monitor is designated as a SPM.

EPA Response:

There are multiple monitoring objectives served by the State’s
monitoring network.  In the instance of the Davenport area, the 300
Wellman site is situated to assess the potential for source level
impacts in the neighborhoods surrounding several industrial facilities.
The Adams School site is situated to assess population exposures in
direct comparison with the NAAQS.  The Jefferson School site (is also
situated for assessment of population exposure NAAQS compliance, but it
also incorporates chemical speciation and a continuous monitor to
establish a clearer picture of PM2.5 behavior in the Davenport area.
Monitor network design is largely influenced by the data collection
priorities of each individual State.  Annual monitoring network plans
are submitted by each state and are reviewed and approved by EPA.   EPA
establishes minimum monitoring network requirements in the code of
federal regulations, but States are allowed and encouraged to invest in
more thorough data collection systems.  Both of the violating monitors
are designated as eligible for comparison with the NAAQS consistent with
40 CFR Part 58.

As stated previously nonattainment area designations are to include the
area in violation and areas shown to contribute to the violation.
Although modeling data provided by the state demonstrates that the two
named local sources influence the violation at the monitor, the modeling
did not demonstrate that other point sources in the Quad Cities area do
not contribute to the violation as well.  For the reasons detailed in
the TSDs for the Davenport-Moline-Rock Island area and Muscatine, EPA
has determined that other point sources in the area contribute to
violations of the NAAQS.  Thus, EPA is establishing a nonattainment area
boundary to include these sources.  Refer to EPA’s TSDs for Iowa and
Illinois which address these issues in greater detail.

Comment:

Factors 4 and 6 – The commenter (0152) believes EPA did not explain
how these factors impact the monitored violations.

EPA Response:

EPA determined nonattainment area includes sufficient portions of Rock
Island County in Illinois to represent the predominance of population
and emissions.  Rock Island County has moderate emissions that commonly
are blown toward the violating monitor in Scott County.  EPA believes
that sufficient commuting occurs between Rock Island County and Scott
County that Rock Island County must be considered an integral part of
the Davenport area.

Comment:

One commenter (0144) requests EPA to designate the Davenport, IA-IL area
as unclassifiable pending the completion of source apportionment
modeling and chemical filter analysis studies.

EPA Response:

EPA must designate the violating area as nonattainment as well as the
area contributing to the violation.  The 120-day letter sent to the
State noted that the technical support data it provided did not support
very small partial county boundaries.  The data did not demonstrate a
lack of contribution from other sources in the area, nor did it
demonstrate that only the sources in immediate proximity to the
violating monitors contributed to violations.  As this demonstration was
not made, EPA’s case-by-case review resulted in a decision to notify
the State of its intent to include county-wide areas in the
nonattainment area boundaries. Since that time the State responded to
EPA’s 120-day letter and submitted more data for review.  However,
this data also did not demonstrate that no other sources in the area
were contributing to the violation, nor did it demonstrate an
overwhelming contribution directly from the point sources nearest to the
violating monitors.  On the contrary it showed a considerable
contribution (almost 50 percent of the total filter mass) of secondary
formation attributable to emissions transported from a longer range in
addition to a minor contribution of secondary formation from local point
source emissions.  The State’s technical response to EPA’s 120-day
letter did not support as narrow a boundary as recommended by the State.
 EPA concluded that larger partial county designations, inclusive of the
townships of the major metropolitan area will protect public health and
allow the State greater flexibility in establishing its attainment
demonstration.  Refer to EPA’s response above concerning the nature of
the monitors.  EPA only has authority to designate an area
“unclassifiable” if it lacks sufficient information to promulgate a
designation, and EPA does not lack information for this area.

Comment:

The commenter (0144) suggests that EPA’s whole county recommendation
is not in line with previous designations for PM10.  The commenter cites
Buffalo, IA as a reference to its point and notes that two large point
sources were contributing the violation of PM10 standard and subsequent
consent orders “appear to have been a successful solution to the air
quality issues in that area”.

EPA Response:

Prior designations for PM10 areas have little, if any, relevance for the
PM2.5 NAAQS.   PM10 and PM2.5 are different NAAQS, with different size
indicator particles, that behave differently in the atmosphere, and are
often caused by emissions from different sources that may require
different controls strategies.  PM2.5 typically transports much greater
distances in the atmosphere and typically is much more likely to consist
of secondarily formed particles that result from the mixture of
precursors in the atmosphere.  Finally, PM10 boundaries were often
designated nearly 20 years ago, and current facts and circumstances in
the area may have changed.

Comment:

One commenter (0089) disagrees with EPA’s recommended designation that
Scott and Rock Island Counties be designated as nonattainment.  The
commenter requests that the counties be designated as attainment.  The
commenter suggests as an alternative that if EPA designates the counties
nonattainment, that the boundaries are the narrower boundaries.  The
commenter believes that EPA is not permitted to base designations upon
2005-2007 data and must do so based upon 2004-2006.

EPA Response:

EPA has used the most recent monitoring data available to identify areas
that violate the new standard. The Clean Air Act requires that EPA
promulgate designations based on valid air quality data available at the
time of the promulgation.  That data must be quality assured in order to
be considered in the designation process.  That data set may change
during the designation process as data is submitted by the state to the
EPA each year and it is quality assured. The State was asked to make
recommendations for all areas in the State to be designated as
unclassifiable, attainment, or nonattainment.  These recommendations
were due to EPA by December 2007.   Iowa based its recommendation of the
entire state being attainment on the most recent quality assured data
available to it at the time of the recommendation, which was 2004-2006
monitoring data. At that time the data did not indicate violations of
the 2006 24-hour PM2.5 standard. The State anticipated that more recent
data might show violations and asked EPA to consider that data in making
decisions.   During 2008, 2007 monitoring data was quality assured and
as such was ready for consideration by the State and EPA.  Monitoring
data from 2005-2007 showed two areas in the state with violations of the
standard.  Based on this more recent data the EPA informed the State of
the violating monitors and requested a revised recommendation.  Iowa
subsequently recommended two very small partial county areas in the
violating counties.  In addition, EPA is not “re-designating the
area” as suggested by the commenter.  It is instead promulgating
initial designations based on the most current information available as
it is required to do.

Finally, if EPA were required to promulgate designations based upon
2004-2006 data, it could not consider more recent data from 2008 that
the state may elect to submit if it were to affect the attainment status
of this area prior to the effective date of the designation.

Comment:

EPA used monitoring data from two source-oriented, SPMs with middle
spatial scale ranges, that exhibited exceedance that were not
representative of general air quality conditions;

EPA Response:

There are multiple monitoring objectives served by the State’s
monitoring network.  In the instance of the Davenport area, the
violating monitor at the 300 Wellman site is situated to assess the
potential for source level impacts in the neighborhoods surrounding
several industrial facilities.  The Adams School site is situated to
assess population exposures in direct comparison with the NAAQS.  The
Jefferson School site is also situated for assessment of population
exposure NAAQS compliance, and it also incorporates chemical speciation
and a continuous monitor to establish a clearer picture of PM2.5
behavior in the Davenport area.  Monitor network design is largely
influenced by the data collection priorities of each individual State.
Annual monitoring network plans are submitted by each state and are
reviewed and approved by EPA.   EPA establishes minimum monitoring
network requirements in the code of federal regulations, but States are
allowed and encouraged to invest in more thorough data collection
systems.  Both of the violating monitors are designated as eligible for
comparison with the NAAQS consistent with 40 CFR Part 58.

Nonattainment area designations are to include the area in violation and
areas that contribute to the violation.  Although modeling data provided
by the state demonstrates that the two named local sources influence the
violation at the monitor, the modeling did not demonstrate that other
sources in the Quad Cities area do not contribute to the violation as
well.  For the reasons detailed in the TSDs for the
Davenport-Moline-Rock Island area and Muscatine, EPA has determined that
other sources in the area contribute to violations of the NAAQS.  Thus,
EPA is establishing a nonattainment area boundary to include these
sources.  Refer to EPA’s TSDs for Iowa and Illinois which address
these issues in greater detail.

Comment:

EPA’s statements on whether sufficient data is available to properly
characterize the nonattainment area are contradictory;

EPA Response:

EPA noted that there was sufficient monitoring data to designate the
violating area as nonattainment, and a 1-year extension to obtain
additional monitoring information is not justified.    EPA must
designate an area as nonattainment if the area is monitoring a violation
of the standard based on the most recent three years of monitoring data.
There is sufficient monitoring data available to make the designation.
However, there was not sufficient data provided by the State to support
a very small partial county designation as recommended by the State.
Therefore EPA’s statements were related to two separate issues and not
inconsistent.

Comment:

EPA has failed to follow its own policy guidance in the establishment of
proposed area designations.

EPA Response:

EPA did conduct a case-by-case analysis of the violating areas based on
the information provided to it by the State and other relevant
information.  EPA must designate the violating area as nonattainment as
well as the area contributing to the violation.  The 120-day letter sent
to the State noted that the data the State provided did not support very
small partial county boundaries.  The data did not demonstrate a lack of
contribution from other sources in the area, nor did it demonstrate that
only the sources in immediate proximity to the violating monitors
contributed to violations.  As this information was not provided to the
EPA, its case-by-case review resulted in a decision to notify the State
of its intent to include county-wide areas in the nonattainment area
boundaries. Since that time the State responded to EPA’s 120-day
letter and submitted more data for review.  However, this data also did
not demonstrate that no other sources in the area were contributing to
the violation, nor did it demonstrate an overwhelming contribution
solely from the point sources nearest to the violating monitors.  On the
contrary it showed a considerable contribution (almost 50 percent of the
total filter mass) of secondary formation attributable to emissions
transported from a longer range in addition to a smaller contribution of
secondary formation from local point source emissions.  The State’s
technical response to EPA’s 120-day letter did not support as narrow a
boundary as recommended by the State.  EPA concluded that a larger
partial county designation, inclusive of the townships of the major
metropolitan areas includes the violating area and the nearby
contributing areas.  Refer to EPA’s response above concerning the
nature of the monitors.

Comment:

EPA should give consideration to the efforts already underway in the
Quad Cities area to address high background levels of PM2.5.

EPA Response:

EPA recognizes the efforts by the state and the stakeholders to achieve
emissions reductions as soon as possible.  EPA also encourages both
states to continue efforts to assist the community in implementing
voluntary measures.

However, under section 107(d) of the Clean Air Act, in designating
nonattainment areas, EPA must designate, as nonattainment, areas that
are violating a NAAQS and areas that are contributing to the violations.
 This requirement does not authorize EPA to rely on the ongoing efforts
to develop further control strategies in determining nonattainment
boundaries.  EPA’s decision must be based on the statutory
requirements, and EPA’s promulgation of the nonattainment designations
for these areas, as described in detail in the TSDs, meets the statutory
requirements.

We also note that the state’s submission includes a “mitigation
plan” submitted by Blackhawk Foundry.  The plan states that the
company’s intended control strategy, when fully implemented, “will
significantly reduce PM2.5 concentrations”.  However, the document
also concludes that, after implementation of the “preferred
alternatives” identified in the company’s control strategy, the
“combination of the predicted concentration” from the foundry, and
the background concentration, “could result in a predicted exceedance
of the PM2.5 NAAQS”.  (“PM2.5 Emissions Mitigation Plan”, Oct. 10,
2008, at p. 3.)  This uncertainty provides additional justification for
establishing a boundary to ensure that emissions from other nearby
sources in the area are considered in developing the attainment
demonstration control strategies for these two areas.

Comment:

Two commenters (0155, 0150) suggest as an alternative that if EPA
designates the Scott County, IA and Rock Island County, IL areas, as
nonattainment, that narrower boundary designations are made as
recommended by the Iowa Department of Natural Resources (DNR).  The
commenters believe that the monitor results are not representative of
the general area air quality.  The commenters believe that the monitor
results are not representative of the general area air quality.  One of
the commenters (0155) also requests that Rock Island County, IL, be
designated as attainment.

EPA Response:

There are multiple monitoring objectives served by the State’s
monitoring network.  In the instance of the Davenport area, the
violating monitor at the 300 Wellman site is situated to assess the
potential for source level impacts in the neighborhoods surrounding
several industrial facilities.  The Adams School site is situated to
assess population exposures in direct comparison with the NAAQS.  The
Jefferson School site is also situated for assessment of population
exposure NAAQS compliance, and it also incorporates chemical speciation
and a continuous monitor to establish a clearer picture of PM2.5
behavior in the Davenport area.  Monitor network design is largely
influenced by the data collection priorities of each individual State.
Annual monitoring network plans are submitted by each state and are
reviewed and approved by EPA.   EPA establishes minimum monitoring
network requirements in the code of federal regulations, but States are
allowed and encouraged to invest in more thorough data collection
systems.  Both of the violating monitors are designated as eligible for
comparison with the NAAQS consistent with 40 CFR Part 58.

EPA believes that Rock Island County has moderate emissions that
commonly are blown toward the violating monitor in Scott County.  We
also believe that sufficient commuting occurs between Rock Island County
and Scott County such that Rock Island County must be considered an
integral part of the Davenport area.

Comment:

The commenter (0155) suggests that EPA should not designate the entire
county as nonattainment but should take into consideration efforts of
the named point source to negotiate, with the State, a “voluntary”
control strategy.

EPA Response:

EPA recognizes the efforts by the state and the stakeholders to achieve
emissions reductions as soon as possible.  EPA also encourages both
states to continue efforts to assist the community in implementing
voluntary measures.

However, under section 107(d) of the Clean Air Act, in designating
nonattainment areas, EPA must designate, as nonattainment, areas that
are violating a NAAQS and areas that are contributing to the violations.
 This requirement does not authorize EPA to rely on the ongoing efforts
to develop further control strategies in determining nonattainment
boundaries.  EPA’s decision must be based on the statutory
requirements, and EPA’s promulgation of the nonattainment designations
for these areas, as described in detail in the TSDs, meets the statutory
requirements.

3.13.  Dayton-Springfield, OH

Comment:

One commenter (0118) supports EPA recommendations for the State of Ohio.
 The commenter requests that EPA designation Clark, Greene and
Montgomery Counties as nonattainment.  These are the same counties that
EPA has proposed as candidates for a designation of nonattainment.  The
commenter cites negative health impacts from PM2.5 and its contribution
to regional haze.

EPA Response:

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer to the TSD and
the State and Tribal RTC document which explains EPA’s decisions.

3.14.  Detroit-Ann Arbor, MI

Comment:

One commenter (0130) believes that the Port Huron monitor (St. Clair
County) should be treated separately and EPA is inappropriately
expanding regulatory scope.  The commenter believes the EPA’s
designation of multiple counties in southeast Michigan, including Wayne,
Oakland, Macomb, Washtenaw, St. Clair, Monroe, and Livingston Counties
inappropriately expands regulatory scope far beyond the specific
location with a specific challenge.  The commenter refers to technical
comments submitted by another commenter (0110) for support. Several
commenters (0075, 0094, 0097, 0110, 0113, 0130) disagree with EPA’s
proposed designations in the Detroit nonattainment area.  The commenters
support Michigan Department of Environmental Quality’s (MDEQ) initial
recommendation that southeast Michigan be separated into three distinct
nonattainment areas, reflecting the distinct circumstances that lead to
measured nonattainment.

EPA Response:

EPA disagrees with the commenters assertions that EPA should follow the
recommendations of the State of Michigan’s to divide the Detroit
nonattainment area into three separate nonattainment areas for a number
of reasons.  EPA generally will not divide areas because having one area
allows for better planning.  Instead of assessing the impact of a source
on several nonattainment areas, determining the impact is simplified
when there is just one area.  Having a single nonattainment area also
eliminates the need to integrate planning for multiple areas.

Specifically in the Detroit area, the metropolitan planning organization
addresses the seven counties of the existing nonattainment area and thus
is already designed to conduct planning for the prospective
nonattainment area as a whole.  Michigan noted that the air quality in
St. Clair and Wayne Counties may be impacted by unique sources.  These
counties are also impacted by the same common sources as all counties in
the Detroit area.  Therefore, a single Detroit nonattainment area better
reflects the integrated planning that will be needed for this area.
Michigan will have the opportunity in its nonattainment plan development
to include specific control measures to address the air quality in St.
Clair and Wayne Counties beyond the controls implemented for area-wide
air quality improvement.

Please refer to the State RTC Document for a more detailed explanation
of EPA’s designation of the Detroit area, including EPA assessment of
the State’s various technical arguments that these pubic commenters
endorsed.   See section 2.2 of this document for EPA’s responses to
the various legal comments submitted by these commenters challenging
EPA’s interpretation of the statute and designations process
generally.

3.15.  Evansville, IN

Comment:

One commenter (0058) requests a 1-year extension of the designation
deadline for Dubois County, IN.

EPA Response:

Indiana submitted exceptional events information for several areas in
the State.  EPA concurred with some of the exceptional events and
adjusted the design values appropriately.  As explained in the TSD, in
the Evansville area, the 2005-2007 design value for Dubois County shows
that it now attains the 2006 PM2.5 air quality standards.  Dubois County
was recommended as nonattainment because it was considered to be
violating the air quality standards.  EPA reexamined the information for
Dubois County and determined that after concurrences on the exceptional
events claims it is neither violating the 24-hour PM2.5 NAAQS nor is it
contributing to violations in Vanderburgh County.  EPA is making the
designations in December 2008.  EPA is designating Dubois County as
attainment and a 1-year extension is not warranted because EPA has
available information to support the designation.

Comment:

One commenter (0106) supports EPA’s recommendation and requests that
EPA designate Dubois, Gibson, Pike, Spencer, Vanderburgh, Knox and
Warrick Counties in Indiana as nonattainment.  The commenter cites
negative health impacts from PM2.5 and its contribution to regional
haze.

EPA Response:

Indiana submitted exceptional events information for several areas in
the State.  EPA concurred with some of the exceptional events and
adjusted the design values appropriately.  As explained in the TSD, in
the Evansville area, the 2005-2007 design value for Dubois County shows
that it now attains the 2006 PM2.5 air quality standards.  Dubois County
was initially recommended as nonattainment because it was considered to
be violating the air quality standards.  EPA reexamined the information
for Dubois County in light of the exceptional events claims and
determined that it is neither violating the 24-hour PM2.5 NAAQS nor is
it contributing to violations in Vanderburgh County.  Thus EPA is
designating Dubois County as attainment.

EPA made the final designations for the 2006 24-hour PM2.5 NAAQS using
an evaluation of the recommended nine factors described in the June 2007
guidance as well as other relevant information in determining
appropriate nonattainment area boundaries.  Please refer to the TSD and
the State and Tribal RTC document which explains EPA’s decisions.

Comment:

One commenter (0103) requests a 1-year extension from the EPA to
designate the proposed Evansville, IN nonattainment area, in order to
obtain sufficient information.  The commenter believes that if the most
recent data from 2008 is used Evansville, IN, is likely to be able to be
in compliance.  The commenter recommends if EPA proceeds with 2008
designations, that EPA designate as nonattainment only those counties
with violating monitors.  The commenter provided additional technical
analysis to support its claims.

EPA Response:

EPA is required by the Clean Air Act to promulgate designations within
two years of the promulgation of an air quality standard, in this case
by December 18, 2008.  An extension may be granted in cases where
information is insufficient to promulgate designations, but because EPA
believes there is sufficient information an extension is not warranted
for Indiana.  Therefore, EPA is making its designations in December
2008.

EPA is required by the Act to designate all areas that contribute to
violations as nonattainment in addition to areas that actually violate
the standard, thus EPA can not designate only the areas that have
violating monitors.  As for monitoring data, EPA uses data from FRM or
FEM monitors to determine the air quality.   If 2008 data will show that
the Evansville area attains the 2006 air quality standards, then Indiana
needs to submit the quality assured data to EPA within the specified
period.

Please see section 2.3 above for EPA’s Response regarding the
submission of 2008 data.  Please refer to the TSD and the State and
Tribal RTC document which explains EPA’s decisions for this area.

The commenter supplied information to support its comments.  As noted,
EPA can only use FRM or FEM data in making designations.  Supplied
monitoring data shows the decreasing trend of PM2.5 concentration in the
Evansville area.  EPA is aware of this trend.  However, EPA must
designate areas under the statute based on current conditions, and
Evansville is currently violating the standard.  Emissions data were
supplied.  Emissions data is one of the nine factors that EPA examined
in determining the nonattainment area.  Information on wind speed and
direction were provided for the days of 17 “pollution episodes.”
The winds came from a variety of directions with a slight tendency to be
from the southwest.  EPA developed a pollution rose for Evansville which
showed prevailing surface winds come from a variety of directions.  The
information provided by the commenter used just “episodes,” so it is
only a small sample set.  Examination of the Appendix K of the comments
graphs shows the wind direction is often varied even within an
“episode.”  EPA concluded that the varying winds did support
contribution from the areas included in the designation.

The commenter also supplied a number of back trajectories.  The PM2.5
concentration in a location such as Evansville is the result of complex
atmospheric reactions.  In addition to the PM2.5 directly emitted, some
of the concentration is formed from precursor emissions.  The sources
emitting the various components may be in different areas making the
analysis for wind information more complex.  Back trajectories also do
not account for the dispersion that occurs as pollutants are carried
from their source.  The back trajectories illustrate that some of the
pollution impacting an area is from distant sources.  EPA is aware that
emissions from sources around the nation contribute a regional
background level of PM2.5.  EPA has developed a number of national
emissions control programs to reduce the regional background
concentration.  The CAA provides other mechanisms to address regional
pollution problems, such as section 110(a)(2)(D) and section 126.  In
the context of designations, however, EPA must determine what nearby
areas contribute to violations within those areas, and the nonattainment
area plan provisions of section 172 then address the “local”
component of the nonattainment problem in the area.   In the Evansville
area, even accounting for the regional background, emissions from the
nonattainment area counties still contribute to violations as discussed
in the TSD.

Comment:

The commenter (0103) questions the use of the CES for designations.

EPA Response:

The CES is an analytical tool to provide an initial assessment of areas
that may be contributing to violations in a specific area.  EPA
recognized this fact and therefore used additional forms of information
to evaluate areas.  EPA also solicited additional information from State
and local agencies that was unique to the area in question.  EPA made
its final designations using information it had and the States provided
on the recommended nine factors as well as other analytical tools.  The
CES uses two seasonal factors to better weight the score based on
seasonal variances in chemical composition of the PM2.5 concentration in
an area.  One can see some of this seasonal variability in the
speciation data charts in Appendix G of the comments.  Calculating this
factor for all high concentration days in areas across the nation would
be a substantial undertaking.  In the Evansville area, EPA used the nine
factors and analytical tools in deciding that Posey County, Indiana,
Henderson County, Kentucky, and other counties to the south and west of
Vanderburgh County are not contributing to the monitored violations.
EPA used a county-by-county evaluation to determine a nonattainment area
that contains violating and contributing areas as required instead of
simply including all metropolitan area counties which could have been
overinclusive or just the violating counties which would have been
underinclusive.

3.16.  Fairbanks, AK

Comment:

One commenter (0019/0084) disagrees that Eielson Air Force Base (EAFB)
contributes to the violation in Fairbanks, AK.  On September 11, 2008
the commenter requested that the EPA extend the public comment period
because the commenter believed there was data to show that the Eielson
Air Force Base in Alaska is in attainment.  On October 1, 2008, the
commenter requested a 1-year extension for the designation of Fairbanks,