6 137 6.4 Region 4 Nonattainment Areas 6.4.1 EPA 9 Factor Analyses for Alabama for the Designation of PM2.5 Nonattainment Areas <IP_ADDRESS> Birmingham Area MSA The following is the 9 factor analysis for Birmingham MSA and surrounding Counties. Alabama's submittal in February 2004, recommended Jefferson County be designated nonattainment for the fine particulate matter ( PM2.5), based on 2001  2003 monitoring data. Based on the following analysis EPA believes that Jefferson, Shelby and Walker Counties should be included in the PM2.5 nonattainment area. Jefferson County has a violating monitor and the State recommended it as nonattainment. Shelby County is within the MSA, has high PM, SOx, NOx, and VOC emissions, approximately 52 percent of its commuters commute to Jefferson County, has relatively high population and VMT, and has a power plant within the County. Walker County has high SOx and NOx emissions from a power plant. We have included in our recommended nonattainment area Walker County that is contiguous to the MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this County in our initial recommendations in order to ensure that a sufficient portion of this County, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of Walker County, encompassing the large facility or facilities, should be designated nonattainment. Based on the following analysis, EPA agrees that Blount, St. Clair, Calhoun, Talladega, Tuscaloosa and Morgan Counties should be recommended attainment/ unclassifiable for PM2.5. Blount County has no major sources, has relative low emissions and has the lowest population and VMT in the Birmingham area. St. Clair County has relatively low SOx and PM emissions and has a small population. Calhoun County has no major sources, 84 percent of its commuters commute within its County and it is adjacent to the MSA. Talladega County has a small population, an attaining monitor ( 14.7 DV), low VMT and it is adjacent to the MSA. Tuscaloosa County has no major sources, 89 percent of its commuters commute within its County, has an attaining monitor ( 11.6 DV) and it is adjacent to the MSA. Morgan County has an attaining monitor, is part of another MSA, 72 percent of its commuters commute within its County and is several Counties away from Jefferson County.

Area EPA Recommendation State Recommendation Birmingham, AL Full Counties: Jefferson, Shelby and Walker Full Counties: Jefferson The following is a brief summary of the 9 criteria for the Birmingham MSA and surrounding Counties. These analyses were based on existing available data. 6 138 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5, SO2, NOx, VOC, and NH3 emissions in tons, and weighted emissions scores for the Birmingham Area and surrounding counties. The MSA counties are in bold.

Birmingham MSA and Surrounding Counties Emissions County PM SO2 NOX VOC NH3 Weighted Emissions Score Cumulative Weighted Emissions Score Jefferson 12,772 56,703 69,364 44,782 1,198 50.3 27.5 Shelby 8,780 126,125 42,095 9,650 386 40.9 91.2 St Clair 976 1,087 7,159 4,673 1,395 4.8 96.0 Blount 937 454 3,054 2,781 4,049 3.9 99.9 Walker 3,916 59,256 23,982 4,750 1,491 19.2 Tuscaloosa 2,065 5,183 11,252 14,752 915 12.8 Morgan 2,386 10,949 12,012 17,639 2,183 11.0 Etowah 2,193 11,850 8,487 7,089 1,842 9.9 Calhoun 2,000 2,271 7,115 9,452 1,098 9.5 Talladega 1,968 12,270 8,593 6,065 769 9.1 Dallas 1,505 3,296 4,124 3,670 411 6.2 Cullman 1,459 1,004 5,433 6,612 8,408 6.0 Marshall 1,294 1,525 4,749 7,283 4,275 5.5 Autauga 1,069 2,569 4,897 3,099 249 5.3 Lawrence 1,429 2,422 5,981 2,946 1,649 5.3 Elmore 1,014 517 4,443 4,368 326 4.8 Chilton 777 486 3,621 3,260 300 4.3 Bibb 613 189 1,260 1,433 169 3.8 Winston 574 320 1,547 3,311 1,336 3.4 Marion 567 450 2,835 3,151 742 3.1 Fayette 456 306 1,246 1,509 346 2.8 Coosa 408 152 791 1,410 102 2.4 Hale 430 156 2,373 1,462 215 2.3 Perry 415 218 589 799 166 2.3 Based on the analysis for this factor, there appears to be emissions in Shelby and Walker, Counties that contribute to the air quality in Jefferson County, resulting in a violating monitor there. 6 139 Factor 2: Air quality in potentially included versus excluded areas Birmingham MSA and Surrounding Counties Design Value ( DV)

County 2001 2003 DV Jefferson 18.0 Shelby 14.4 Walker 12.8 Tuscaloosa 11.6 ** Morgan 17.6 Etowah 14.8 Talladega 14.7 Jefferson County has 6 monitors, only one monitor exceeded the PM2.5 standard ( North Birmingham/ Wylam). Shelby, Walker, Tuscaloosa, Etowah, and Talladega counties all have monitors that show attainment of the PM2.5 standard.

** Morgan County has a violating monitor, however, the Decatur, Alabama, fine particulate matter ( PM2.5) monitoring site ( AQS # 01 103 0010) began operating in January 1999, and was terminated in August 2001. A new site ( AQS # 01 103 0011) was selected in the Decatur area and monitoring begain in August 2001. The State of Alabama requested and received Region 4 concurrence for these network design changes. The changes were approved due to a local diesel source impacting the initial monitoring site. The data from the initial monitoring site was left in the Air Quality System ( AQS) database and is in the current calculations for the Decatur area. Data sets from each of the sites are incomplete when considered individually. When the data sets are combined the calculations demonstrate the Decatur area to be below the level of the PM2.5 NAAQS.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Birmingham MSA and adjacent Counties.

Birmingham MSA and Surrounding Counties Population & Area County Population 2002 Percent in MSA Population Density 2002 Jefferson 661,153 71 594 Shelby 153,832 16 193 St Clair 67,215 7 106 Blount 59,968 6 82 Walker 70,655 89 Tuscaloosa 166,512 126 Morgan 111,725 192 Etowah 103,105 193 Calhoun 111,616 183 Talladega 80,638 109 6 140 Of the MSA population, 87 percent resides in Jefferson County ( 661,153) and Shelby County ( 153,832). Blount and St. Clair Counties have a much lower population and population density than Jefferson and Shelby Counties.

Factor 4: Traffic and commuting patterns Commuting Information  Following is an analysis of the commuting in the Birmingham MSA and adjacent Counties.

Jefferson County, an MSA county, has a total of 288,136 commuters.  Commuters who remain in Jefferson County 265,661 ( 92%)

Shelby County, an MSA county, has a total of 70,873 commuters.  Commuters from Shelby County to Jefferson County 37,119 ( 52%)  Commuters who remain in Shelby County: 32,573 ( 46%)

St. Clair County has a total of 27,773 commuters.  Commuters from St. Clair County to Jefferson County 12,870 ( 46%)  Commuters who remain in St. Clair County: 10,648 ( 38%)

Blount County has a total of 22,255 commuters.  Commuters from Blount County to Jefferson County 9,669 ( 43%)  Commuters who remain in Blount County: 8,966 ( 40%)

Walker County has a total of 27,448 commuters.  Commuters from Walker County to Jefferson County 6,746 ( 25%)  Commuters who remain in Walker County: 17,293 ( 63%)

Tuscaloosa County has a total of 73,292 commuters.  Commuters from Tuscaloosa County to Jefferson County 4,385 ( 6%)  Commuters who remain in Tuscaloosa County: 65,331 ( 89%)

Morgan County has a total of 49,769 commuters.  Commuters who remain in Morgan County: 36,005 ( 72%)

Etowah County has a total of 42,636 commuters.  Commuters from Etowah County to Jefferson County 1,658 ( 4%)  Commuters who remain in Etowah County: 32,181 ( 75%)

Calhoun County has a total of 47,181 commuters.  Commuters from Calhoun County to Jefferson County 842 ( 2%)  Commuters who remain in Calhoun County: 39,856 ( 84%)

Talladega County has a total of 31,443 commuters.  Commuters from Talladega County to Jefferson County 2,292 ( 7%)  Commuters who remain in Talladega County: 20,563 ( 65%) 6 141 The following Counties have significant commuters commuting to Jefferson County on a percentage basis: Shelby ( 52%), Walker ( 25%), St. Clair ( 46%) and Blount County ( 43%). Although a relatively high percentage of commuters in Blount and St. Clair Counties go to Jefferson County, they only contribute 3% and 4% respectively.

Birmingham MSA and Surrounding Counties VMT County VMT 2002 VMT Growth 02 10 Jefferson 8,242 3,485 Shelby 1,449 345 St. Clair 1,111  331 Blount 594 134 Walker 851 212 Tuscaloosa 2,430 176 Morgan 1,296 816 Etowah 1,235 500 Calhoun 1,525 431 Talladega 801 39 Jefferson County has over 70% of the VMT in the MSA 6 142 Factor 5: Expected growth.

The following table has the population and population growth figures for the Birmingham MSA and Surrounding Counties.

Birmingham MSA and Surrounding Counties Population/ Growth County Population Growth 90 00 Percent Growth Jefferson 661,153 10,522 2 Shelby 153,832 43,935 44 St. Clair 67,215 14,733 29 Blount 59,968 11,776 30 Walker 70,655 3,043 4 Tuscaloosa 166,512 14,353 10 Morgan 111,725 11,021 11 Etowah 103,105 3,619 4 Calhoun 111,616  3,785  3 Talladega 80,638 6,214 8 Blount County had one of the higher population growth ( 30 percent) in the MSA, however, its population ( 59,968) is small compared to that of the entire CMSA ( 942,168) or to either Jefferson County ( 661,153) and Shelby County ( 153,832). St. Clair County had a fairly high population growth ( 29 percent), its population ( 67,215) is small compared to that of the entire CMSA ( 942,168) and is only one tenth the population of Jefferson County ( 661,153) and less than half the population of Shelby County ( 153,832). Shelby County had a high population growth ( 44 percent).

Factor 6: Meteorology Not a significant factor in the analyses.

Factor 7: Geography/ topography Not a significant factor in the analyses.

Factor 8: Jurisdictional boundaries The Birmingham 8 hour ozone nonattainment area consist of Jefferson and Shelby Counties.

Factor 9: Level of control of emission sources Reasonable Available Control Technology for VOC has been in place since 1979 Stage 1 Vapor Recovery has been in place since 1990 1 Hour Attainment Demonstration required further NOx reductions from electric generating plants Gorgas and Miller, totaling 68.2 tons per day of NOx reductions ( seasonal). Tier II National Fuel Standard ( starting 2004) 6 143 NOx SIP Call requires large reductions in NOx emissions from major utilities, large industrial boilers, gas turbines and cement kilns ( seasonal). As a result Gaston, Gorgas and Miller power plants have/ will install the following controls:

Miller Units 1 & 2 Selective Catalytic Reduction ( SCR) Gaston Units 1  4 overfire air Gaston Unit 5 advanced low NOx burners The following controls are being or have been placed on Gorgas and Miller power plants to meet the requirements of the Birmingham attainment SIP:

Gorgas Unit 10 SCR Gorgas Units 6, 7, and 8 low NOx burners Miller Units 3& 4 SCR There is only one significant NOX source in St. Clair County, a cement kiln ( National Cement Co. 1,851 tpy), which is implementing significant controls which have been determined to be reasonable and highly cost effective to meet the Alabama's NOX SIP requirements.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Walker County, AL:

In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area ( as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant in the nonattainment area. Walker County, AL is one of those counties. Walker County has low population ( 70,655 compared to 661,153 in Jefferson County where the city of Birmingham is located), low population density ( 89 people per square mile compared to 594 in Jefferson County), low VMT ( 851,000 compared to 8,242,000 in Jefferson County ), and the only large point source is the Gorgas Steam Plant.

A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small " free standing" boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd shaped " land connector" extending from the main part of the nonattainment area to the power plant. The State of Alabama subsequently submitted two partial county recommendations, one included the Gorgas Steam Plant boundary as a noncontiguous area and the other was contiguous to the Birmingham area. 6 144 After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source ( e. g. partial county boundaries recently established for 8 hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free standing portions of nonattainment areas should be based on a pre existing boundary for a minor civil division ( such as a township or tax district) or other boundary defined for governmental use ( such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifiers ( StateFIPs CoFIPs Tract# Block Group#) 01 127 214 5, 01 127 0215 4, and 01 127 0216 2 portion of Walker County as part of the Birmingham nonattainment area.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Birmingham, AL area: Jefferson, Shelby, and Walker ( Partial).

<IP_ADDRESS> Columbus Area MSA The following is the 9 factor analysis for Columbus MSA and surrounding Counties. Alabama's submittal in February 2004, recommended that Russell County be designated nonattainment for the fine particulate matter ( PM2.5), based on 2001  2003 monitoring data. Georgia's submittal in June 2004, recommended that Harris, Muscogee and Chattahoochee Counties be designated attainment for PM2.5. Based on the following analysis EPA recommends that Lee and Russell counties in Alabama, and Harris, and Muscogee Counties in Georgia, should be included in the PM2.5 nonattainment area. Lee County is adjacent to the MSA, has high VMT and a large population. Russell County has a violating monitor and the State recommended it as nonattainment. Harris County has relatively high NOx and VOC emissions and relatively high VMT. Muscogee County has high NOx and VOC emissions, high VMT and a large population. Based on the following analysis, EPA agrees with the recommendation that Barbour, Chambers, Montgomery, Elmore and Tallapoosa Counties in Alabama, and Chattahoochee, Troup, Stewart, Meriwether, Sumter Counties in Georgia, should be attainment/ unclassifiable for PM2.5 based on low emissions, low VMT and low population.

Area EPA Recommendation State Recommendation Columbus, GA Lee and Russell Counties in Alabama and Harris and Muscogee Counties in Georgia Russell County, Alabama 6 145 The following is a brief summary of the 9 criteria for the Columbus MSA and surrounding Counties . These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5, SO2, NOx, VOC, and NH3 emissions in tons, and weighted emissions scores for the Columbus Area and surrounding counties. The MSA counties are in bold.

Columbus MSA and Surrounding Counties Emissions County PM SO2 NOX VOC NH3 Weighted Emissions Score Cumulative Weighted Emissions Score Russell, AL 1,344 2,550 5,718 4,434 179 35.1 35.1 Harris, GA 590 104 2,856 1,748 128 26.8 61.9 Muscogee, GA 513 803 5,965 9,476 323 25.4 87.3 Chattahoochee, GA 208 43 387 482 15 12.7 100 Troup, GA 1,194 422 12,277 8,223 382 48.7 Montgomery, AL 1,421 6,292 10,454 14,966 973 43.3 Lee, AL 1,043 1,425 5,125 7,474 333 42.8 Barbour, AL 874 419 2,208 2,529 497 41.6 Sumter, GA 2,578 1,725 1,726 2,262 847 40.5 Meriwether, GA 844 190 1,866 3,006 167 33.7 Elmore, AL 1,014 517 4,443 4,368 326 30.8 Tallapoosa, AL 679 655 1,993 3,230 263 26.5 Chambers, AL 579 527 2,350 2,882 124 23.9 Stewart, GA 429 32 360 464 189 23.3 Taylor, GA 398 76 966 622 833 18.3 Macon, AL 412 223 2,242 1,871 133 17.1 Talbot, GA 288 70 903 520 74 15.9 Marion, GA 314 32 328 517 470 15.4 Bullock, AL 273 93 407 570 214 12.7 Webster, GA 303 128 358 201 114 12.6 Schley, GA 192 14 195 290 163 8.4 Based on the analysis for this factor, there appear to be emissions in Lee County, Alabama, that contribute to the violation in Russell County.

Factor 2: Air quality in potentially included versus excluded areas.

Columbus MSA and Surrounding Counties Design Value ( DV)

County 2001 2003 DV Russell, AL 15.3 Muscogee, GA 14.7 Montgomery, AL 14.2 6 146 Muscogee and Montgomery Counties have monitors that show attainment of the PM2.5 standard while Russell County is violating the standard.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the Counties in the Columbus MSA and adjacent Counties.

Columbus MSA and Surrounding Counties Population & Area County Population20 02 Percent in MSA Population Density 2002 Russell, AL 49,415 18 77 Harris, GA 25,092 9 54 Muscogee, GA 185,948 67 861 Chattahoochee, GA 15,440 6 62 Troup, GA 59,767 144 Montgomery, AL 223,346 283 Lee, AL 118,123 194 Barbour, AL 28,826 33 Sumter, GA 33,247 69 Meriwether, GA 22,623 45 Elmore, AL 68,771 111 Tallapoosa, AL 40,946 57 Chambers, AL 36,251 61 Stewart, GA 5,040 11 Lee County is adjacent to Russell County and its population ( 118,123) is about two and half times that of Russell County ( 49,415).

Factor 4: Traffic and commuting patterns Commuting Information  Following is an analysis of the commuting in the Columbus MSA and adjacent Counties.

Russell County, AL has a total of 19,859 commuters.  Commuters who remain in Russell County 7,051 ( 36%)

Harris County, GA has a total of 11,811 commuters.  Commuters from Lee County to Russell County 214 ( 2%)  Commuters who remain in Harris County 2,867 ( 24%)

Muscogee County, GA has a total of 82,977 commuters.  Commuters from Muscogee County to Russell County 2,479 ( 3%)  Commuters who remain in Muscogee County 71,862 ( 87%)

Chattahoochee County, GA has a total of 8,538 commuters.  Commuters who remain in Chattahoochee County 5,482 ( 64%) 6 147 Troup County, GA has a total of 26,339 commuters.  Commuters who remain in Troup County 22,074 ( 84%) Montgomery County, AL has a total of 96,943 commuters.  Commuters who remain in Montgomery County 90,943 ( 94%)

Lee County, AL has a total of 52,119 commuters.  Commuters who remain in Lee County 35,549 ( 68%)  Commuters from Lee County to Russell County 2,682 ( 5%)

Barbour County, AL has a total of 10,023 commuters.  Commuters who remain in Barbour County: 8,370 ( 84%)  Commuters from Lee County to Russell County 335 ( 3%)

Sumter County, GA has a total of 13,963 commuters.  Commuters who remain in Sumter County 11,652 ( 83%)

Meriwether County, GA has a total of 8,893 commuters.  Commuters who remain in Meriwether County 4,114 ( 46%)

Elmore County, AL has a total of 28,143 commuters.  Commuters who remain in Elmore County 9,415 ( 33%)

Tallapoosa County, AL has a total of 17,009 commuters.  Commuters who remain in Tallapoosa County 12,125 ( 71%)

Chambers County, AL has a total of 15,480 commuters.  Commuters who remain in Chambers County 9,281 ( 60%)

Stewart County, GA has a total of 1, 892 commuters.  Commuters who remain in Stewart County 965 ( 51%)

There are no Counties that have significant commuters commuting to Russell County.

Columbus MSA and Surrounding Counties VMT County VMT 2002 VMT Growth 02 10 Russell, AL 671 276 Harris, GA 547  207 Muscogee, GA 1,594 534 Chattahoochee, GA 56 160 Troup, GA 1,454  839 Montgomery, AL 2,565 642 Lee, AL 1,119 457 Barbour, AL 431  129 Sumter, GA 405  62 Meriwether, GA 271 138 6 148 Elmore, AL 615 168 Tallapoosa, AL 502  56 Chambers, AL 378  44 Stewart, GA 75 47 Over 50% of the VMT in the MSA is in Muscogee County, Georgia. As noted above, none of the adjacent Counties have appreciable commuting into the MSA.

Factor 5: Expected growth The following table has the population and population growth figures for the Columbus MSA and surrounding Counties.

Columbus MSA and Surrounding Counties Population/ Growth County Population 2002 Growth 90 00 Percent Growth Russell, AL 49,415 2,896 6 Harris, GA 25,092 5,907 33 Muscogee, GA 185,948 7,013 4 Chattahoochee, GA 15,440  2,052  12 Troup, GA 59,767 3,243 6 Montgomery, AL 223,346 14,425 7 Lee, AL 118,123 27,946 32 Barbour, AL 28,826 3,621 14 Sumter, GA 33,247 2,972 10 Meriwether, GA 22,623 123 1 Elmore, AL 68,771 16,664 34 Tallapoosa, AL 40,946 2,649 7 Chambers, AL 36,251  293  1 Stewart, GA 5,040  402  7 Harris County, Georgia has large growth on a percentage basis.

Factor 6: Meteorology A wind analysis using wind data from the Columbus, Georgia Airport was completed to evaluate the predominant wind direction( s) in Phenix City over the 3 year period on all days. There is a large easterly component to the winds during the 3 year time period., but there is not sufficient information to use meteorology as a deciding factor for an annual average..

Factor 7: Geography/ topography Not a significant factor in the analyses.

Factor 8: Jurisdictional boundaries Not a significant factor in the analyses. 6 149 Factor 9: Level of control of emission sources Reasonable Available Control Technology for VOC has been in place since 1979 Stage 1 Vapor Recovery has been in place since 1990 NOx SIP Call requires large reductions in NOx emissions from major utilities, large industrial boilers, gas turbines and cement kilns ( seasonal for Macon, Tallapoosa, Chambers, Elmore and Lee Counties). Tier II National Fuel Standard ( starting 2004)

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendations on June 29, 2004, included the Lee County, Alabama, and Harris County, Georgia, as part of the Columbus, GA nonattainment area. Upon further review of additional information provided by the states, EPA is revising its recommendation and is designating Lee County, AL and Harris County, GA as attainment/ unclassifiable.

Lee County, AL:

Lee County, Alabama, is being designated attainment/ unclassifiable because it has no major point sources of precursor emissions with 40% ( 7,474 tons) of its total VOC and 87% ( 5,125 tons) of its total NOx emissions coming from mobile sources. Lee County is adjacent to the MSA. The majority of the commuting population remains inside Lee County, with only 5 percent commuting to Russell County where the violating monitor is located.

We considered the data in the request for spatial averaging for the Columbus area, which was denied, while evaluating the other factors and determined that Lee County is not contributing to the violations.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Columbus, GA AL area: Russell.

<IP_ADDRESS> Chattanooga Area The Chattanooga MSA contains the following Tennessee counties: Marion and Hamilton; and the following Georgia Counties: Dade, Walker, and Catoosa. Based on air quality data for 2001 2003, the monitor with the highest design value in Hamilton County has a design value of 16.1 and the monitor in Walker County has a design value of 15.6. No other counties in the MSA contain ambient air monitors. The State of Tennessee recommended as nonattainment the county of Hamilton and the State of Georgia recommended as nonattainment the county of Walker. The States have recommended that all other counties be designated attainment. The State of Tennessee submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. EPA is modifying the State 6 150 of Tennessee's recommendation and will review the additional information during the 120 day period following the notification letter.

EPA has received some information from the State of Tennessee that Marion ( MSA) County should be designated attainment for the PM2.5 standard and no justification from the State of Georgia indicating that any other counties should be included or excluded from the Chattanooga PM2.5 nonattainment area. Adjacent counties with significant emissions include McMinn and Roane Counties which are attached to the Knoxville nonattainment area and Floyd County which is a separate nonattainment area.

Additionally we have included in our recommended nonattainment area Jackson County, AL, that is adjacent to the Chattanooga MSA, that is generally rural in character, and that contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contribute to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment. Therefore EPA is modifying the States' recommendations to include all of the counties in the MSA and the adjacent county of Jackson, Alabama.

Area EPA Recommendation State Recommendation Chattanooga TN GA Full counties: Marion, Hamilton, TN; Dade, Walker, Catoosa, GA; Jackson, AL Full counties: Hamilton and Walker Drop: Marion 6 151 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Chattanooga MSA and some adjacent counties. ( MSA counties are in bold.)

County PM SOx NOx VOC Amm Weighted Emissions Score Cumulative Weighted Emissions Score Hamilton 1,498 5,300 20,048 27,150 1,022 49.5 49.5 Walker 856 632 2,798 4,516 958 17.9 67.4 Marion 679 477 3,156 2,640 501 14.1 81.5 Catoosa 617 167 3,085 3,601 680 11.9 93.4 Dade 302 107 2,415 1,574 285 6.5 99.9 Roane 4967 92331 30865 4300 285 296.9 Jackson, AL 4389 44333 31502 4742 1494 176.1 Floyd, GA 10057 31821 22736 7139 976 154.0 McMinn 3348 10216 10829 5546 1268 73.3 Whitfield, GA 2732 1747 7283 7386 991 54.2 Rhea 1405 302 2625 3643 149 31.2 Loudon 804 4035 5899 5338 360 24.3 DeKalb, AL 1193 741 4776 5867 5765 21.3 Bradley 1233 419 4230 7551 1916 21.1 Warren 1164 1189 1869 3675 446 20.7 Monroe 743 154 2387 3420 554 16.4 Gordon, GA 872 200 3645 4019 2630 15.8 Fannin, GA 614 65 887 1266 283 14.2 Franklin 644 482 2100 2929 1512 13.4 Chattooga, GA 450 1228 1834 1634 197 11.7 Murray, GA 576 130 2067 1700 910 11.4 Polk 295 2066 900 949 553 11.3 Cherokee, NC 428 143 921 1753 111 10.6 Grundy 202 164 1000 1150 1170 4.8 Bledsoe 203 31 475 528 335 4.5 Meigs 198 112 885 871 118 4.3 Sequatchie 140 22 304 591 173 3.4 Van Buren 118 178 291 320 74 3.3 Based on the analysis for this factor there appears to be emissions in all MSA counties and the adjacent county of Jackson, AL, which show a potential to contribute. Other adjacent counties with large emissions ( McMinn and Roane, TN and Floyd, GA) are included in other nonattainment areas. 6 152 Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001 2003 PM2.5 Design Values for all Chattanooga MSA Counties and adjacent counties. ( MSA counties are in bold.)

County 2001 2003 design value Hamilton 16.1 Walker 15.6 Roane 14.2 Floyd, GA 15.7 McMinn 14.6 Loudon 15.4 * DeKalb, AL 14.7 * Incomplete data that is not sufficient to determine attainment/ nonattainment. Data substitution does not apply.

Based on this factor, Hamilton County, TN and Walker and Floyd Counties in GA are violating the PM 2.5 standard. Catoosa County, GA is located between violating monitors in Hamilton and Walker Counties.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Chattanooga MSA and some adjacent counties. Urban population figures were not available. ( MSA counties are in bold.)

County 2002 Population Percent of MSA Population ( 2002) 2002 Population Density ( people/ sq. mile) Hamilton 309,321 65.7 570 Walker 61,949 13.2 139 Marion 27,654 5.9 55 Catoosa 56,341 12.0 348 Dade 15,615 3.3 90 Roane 52,316 145 Jackson, AL 54,035 50 Floyd, GA 92,606 181 McMinn 50,051 116 Whitfield, GA 87,037 300 Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by the following MSA counties: Hamilton, Walker, and Catoosa. The five adjacent counties also have population with a potential to contribute. 6 153 Factor 4: Traffic and commuting patterns Commuting Information Hamilton has a working population of 146, 824   Commuters who remain in Hamilton: 133,644 ( 91%)

Marion has a working population 11766.   Commuters who remain in Marion: 5596 ( 48%)   Commuters from Marion to Hamilton: 4271 Dade has a working population of 6983.   Commuters who remain in Dade: 2363   Commuters from Dade to Hamilton: 3091 ( 44%)   Commuters from Dade to Walker: 747 Catoosa has a working population of 26710.   Commuters who remain in Catoosa: 7167   Commuters from Catoosa to Hamilton: 12320 ( 46%)   Commuters from Catoosa to Walker: 1937 Walker has a working population of 27223.   Commuters who remain in Walker: 11244 ( 41%)   Commuters from Walker to Hamilton: 9098 Whitfield, GA has a working population of 38,909   Commuters who remain in Whitfield: 33,796 ( 87%)   Remaining commuters do not commute to the Chattanooga MSA DeKalb, AL has a working population of 7798   Commuters who remain in DeKalb: 5179 ( 66%)   Remaining commuters do not commute to the Chattanooga MSA The following table contains the vehicle miles traveled ( thousand miles) for the counties in the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.) 6 154 County 2002 VMT ( thousand miles/ year) Hamilton 3,743 Walker 742 Marion 654 Catoosa 810 Dade 512 Roane 784 Jackson, AL 786 Floyd, GA 948 McMinn 787 Whitfield, GA 1423 Based on the analysis for this factor the VMT for all MSA counties indicate a potential to contribute. Although Whitfield County has a relatively high VMT, none of the commuters go to the Chattanooga MSA.

Factor 5: Expected growth The following table has the population and population growth figures for the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.)

County 2002 Population Growth ( 90 00) % Growth ( 90 00) Hamilton 309,321 22360 8 Walker 61,949 2713 5 Marion 27,654 2916 12 Catoosa 56,341 10818 25 Dade 15,615 2007 15 Roane 52,316 4683 10 Jackson, AL 54,035 6130 13 Floyd, GA 92,606 9314 11 McMinn 50,051 6632 16 Whitfield, GA 87,037 11063 15 Based on the analysis for this factor, there appears to be significant growth on a percentage basis in Catoosa County that indicates a contribution to the air quality in the Chattanooga MSA.

Factor 6: Meteorology This factor did not play a significant role in the decision making process.

Factor 7: Geography/ topography The Chattanooga area does not have any geographical or topographical boundaries limiting its airshed. 6 155 Factor 8: Jurisdictional boundaries Hamilton and Meigs Counties, TN and Catoosa County, GA were designated nonattainment for the 8 hour ozone standard on April 15, 2004.

This factor did not play a significant role in the decision making process.

Factor 9: Level of control of emission sources Sources in the Chattanooga area are subject to Prevention of Significant Deterioration ( PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology ( CTG RACT)  ( Hamilton County only}, Maximum Achievable Control Technology ( MACT) for Hazardous Air Pollutants ( HAP), New Source Performance Standards ( NSPS), and the NOx SIP call.

This factor did not play a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Jackson County, AL:

In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area ( as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant in the nonattainment area. Jackson County, AL is one of those counties. Jackson County has 4,389 tons of PM, 4,333 tons of SO2 and 31,502 of NOx emissions, with the majority of emissions coming from the Widows Creek Power Plant. The commuting patterns show that 68% ( 16,642) of the working population in the county actually works in Jackson County with 8% ( 1,853) working in Madison County and another 8% ( 1,695) working in Dekalb County. The available data indicate that there are no identifiable commuting patterns between Jackson County and Chattanooga.

A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small " free standing" boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd shaped " land connector" extending from the main part of the nonattainment area to the power plant. The State of Alabama subsequently submitted two partial county recommendations, one included the Widows Creek Plant boundary as a contiguous area and the other was contiguous to the nearest county recommended as nonattainment. 6 156 After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source ( e. g. partial county boundaries recently established for 8 hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free standing portions of nonattainment areas should be based on a pre existing boundary for a minor civil division ( such as a township or tax district) or other boundary defined for governmental use ( such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier ( StateFIPs CoFIPs Tract# Block Group#) 01 071 9503 1 portion of Jackson County as part of the Chattanooga nonattainment area.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Chattanooga, TN GA area: Jackson ( Partial).

<IP_ADDRESS> DeKalb and Etowah Counties Based on incomplete monitoring data and data substitution not being a viable alternative, it is EPA's position that DeKalb and Etowah Counties be designated as unclassifiable. These two counties had monitoring data for 2000 2002 that was violating and have incomplete data for 2001 2003. Applying the data substitution policy will not confirm attainment. There is no distinction, regulatorily between attainment and unclassifiable.

Area EPA Recommendation State Recommendation De Kalb County Etowah County De Kalb County Etowah County Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as unclassifiable for the Dekalb County, AL area: Dekalb.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as unclassifiable for the Gadsden, AL area: Etowah.

6.4.2 EPA 9 Factor Analyses for Georgia for the Designation of PM2.5 Nonattainment Areas <IP_ADDRESS> Atlanta Area MSA The Atlanta MSA contains the counties of: Barrow, Bartow, Caroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Pickens, Rockdale, Spalding, and Walton. 6 157 On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification at that time. On June 17, 2004, the State submitted additional information and revised recommendations. The revision recommended the 20 county ozone nonattainment area, which includes the adjacent county of Hall, plus a partial county recommendation for Heard County adjacent to the Atlanta MSA which contains no monitor, but a power plant with large SO2 and NOx emissions. The State also recommended that Floyd County which is adjacent to the Atlanta MSA and has a violating monitor be designated as a separate nonattainment area. The adjacent counties of Hall, Jasper and Putnam have significant emissions with a potential to contribute to the violations in the Atlanta area. Putnam county contains a power plant with large SO2 and NOx emissions. We have included in our recommended nonattainment area Putnam County in your state that is contiguous to this CMSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of such contiguous county, encompassing the large facility or facilities, should be designated nonattainment. Based on emission levels and the other nine factors, EPA is modifying the Georgia submittal to a include Jasper and Putnam counties. EPA agrees with the partial county recommendation for Heard County, and Floyd County as a separate nonattainment area.

Area EPA Recommendation State Recommendation Atlanta, GA Full counties: Barrow, Bartow, Caroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Rockdale, Spalding, and Walton Adjacent: Floyd as a separate area; Hall, Heard as a partial, Jasper, Putnam Full counties: Barrow, Bartow, Caroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Rockdale, Spalding, and Walton Adjacent: Floyd as a separate area; Hall, Heard as a partial The following is a brief summary of the 9 criteria for the Atlanta MSA and surrounding counties. These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted scores for the counties in the Atlanta MSA and some adjacent counties. ( MSA counties are in bold.) 6 158 County PM SOx NOx VOC Amm Weighted score Cumulative Weighted score Fulton 16,041 11,819 48,166 44,184 1,948 18.7 18.7 Bartow 9,181 154,447 43,326 5,725 1,309 12.5 31.2 Cobb 3,767 26,411 27,948 27,219 969 9.6 40.8 Coweta 3,795 44,839 15,822 5,048 241 9.4 50.2 De Kalb 3,557 1,734 27,204 36,184 1,175 8.6 58.8 Cherokee 3,761 400 6,769 7,334 1,450 7.4 66.2 Clayton 2,727 612 9,808 10,776 437 6.1 72.3 Gwinnett 2,514 1,446 23,075 27,071 992 5.7 78.0 Henry 2,090 392 14,577 6,349 269 3.6 81.6 Forsyth 1,917 288 5,267 5,763 1,990 2.7 84.3 Carroll 1,629 293 5,536 7,224 2,808 2.6 86.9 Paulding 1,415 236 4,393 3,593 449 2.5 89.4 Douglas 822 239 4,565 4,342 163 1.8 91.2 Newton 1,147 226 4,109 5,047 240 1.8 93.0 Fayette 1,122 252 4,531 4,499 173 1.6 94.6 Walton 919 176 2,759 3,952 755 1.4 96.0 Spalding 795 180 3,251 3,839 212 1.1 97.1 Barrow 706 128 2,340 2,738 1,632 1.0 98.1 Rockdale 774 222 3,678 3,820 166 1.0 99.1 Pickens 463 83 1,116 1,769 1,204 0.9 100.0 Jasper 2,835 210 28,144 2,453 360 6.3 Putnam 3,726 65,560 34,202 1,175 399 6.3 Floyd 10,057 31,821 22,736 7,139 976 6.1 Monroe 3,403 75,571 34,069 2,189 644 6.1 Heard 4,090 75,745 21,714 1,170 634 5.6 Hall 2,347 1,045 7,714 11,062 3,709 3.0 Troup 1,194 422 12,277 8,223 382 2.5 Lee 1,043 1,425 5,125 7,474 333 2.2 Meriwether 844 190 1,866 3,006 167 1.6 Gilmer 646 69 1,148 1,273 2,663 1.5 Walker 856 632 2,798 4,516 958 1.5 Tallapoosa 679 655 1,993 3,230 263 1.3 Gordon 872 200 3,645 4,019 2,630 1.3 Harris 590 104 2,856 1,748 128 1.3 Jackson 817 151 3,639 2,935 3,584 1.3 Chambers 579 527 2,350 2,882 124 1.2 Habersham 651 103 1,757 2,201 3,031 1.1 Polk 660 142 2,345 3,485 575 1.1 Jones 455 105 1,537 1,506 230 1.0 Cherokee 633 222 1,184 2,036 778 0.9 Randolph 404 223 9,276 1,891 1,294 0.9 Lumpkin 403 60 905 1,067 1,090 0.9 Taylor 398 76 966 622 833 0.9 Upson 476 84 1,568 1,926 286 0.9 White 449 58 1,000 1,190 1,462 0.9 Cleburne 331 130 2,057 1,091 1,227 0.8 Chattooga 450 1,228 1,834 1,634 197 0.8 Clarke 395 215 3,362 5,223 390 0.8 Haralson 410 96 1,768 3,071 371 0.8 6 159 Morgan 390 121 2,422 3,176 1,129 0.8 Talbot 288 70 903 520 74 0.8 Butts 357 112 1,609 1,438 88 0.7 Crawford 346 38 645 570 242 0.7 Dawson 324 58 915 1,246 1,142 0.7 Oconee 507 111 1,599 2,047 1,050 0.7 Banks 325 65 1,178 1,127 3,407 0.6 Pike 314 42 607 823 148 0.5 Lamar 257 59 812 1,090 491 0.4 Based on the emissions analysis the adjacent counties of Floyd, Hall, Heard, Jasper, and Putnam have significant emissions indicating potential contribution to the violations in the area. The Agency agrees that Floyd can be designated as a separate PM2.5 nonattainment area and with the partial county recommendation for Heard. The Agency also agrees with the State that Pickens is not contributing based on the low emissions levels. It was not included in the ozone nonattainment area based on noncontribution.

Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 Design Value Fulton 18.0 Cobb 16.1 De Kalb 16.1 Clayton 16.1 Gwinnett 15.6 Paulding 14.1 Floyd 15.7 Hall 14.9 Walker 15.6 Clarke 15.6 There are five counties containing violating monitors in the area recommended by the State and one violating in the adjacent county of Floyd recommended as a separate nonattainment area. Hall County contains an attaining monitor but was recommended by the State as contributing.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Atlanta MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 Population Percent Population of MSA Population Density Fulton 825,431 18.8 1,560 Bartow 82,607 1.9 180 Cobb 651,485 14.9 1,916 Coweta 97,771 2.2 221 De Kalb 676,996 15.4 2,526 Cherokee 159,295 3.6 376 6 160 Clayton 252,733 5.8 1,767 Gwinnett 650,771 14.8 1,503 Henry 139,699 3.2 433 Forsyth 116,924 2.7 517 Carroll 94,907 2.2 190 Paulding 94,184 2.1 300 Douglas 98,650 2.2 496 Newton 71,594 1.6 259 Fayette 96,611 2.2 490 Walton 67,069 1.5 204 Spalding 59,410 1.4 300 Barrow 51,016 1.2 315 Rockdale 73,558 1.7 562 Pickens 25,619 0.6 110 Jasper 12,283 33 Putnam 19,390 56 Floyd 92,606 181 Monroe 22,675 57 Heard 11,340 38 Hall 152,235 386 Pickens County has the lowest population of any of the MSA counties supporting the noncontributing determination. Although, Heard, Jasper and Putnam counties have small population, they contain sources with large emissions.

Factor 4: Traffic and commuting patterns Commuting Information:

Fulton County has a total of 385,442 commuters.  Commuters that remain in Fulton County: 265,870  Commuters from Fulton County to Cobb County: 24,991  Commuters from Fulton County to Dekalb County: 41,232  Commuters from Fulton County to Clayton County: 9,722  Commuters from Fulton County to Gwinnett County: 21,211 Bartow County has a total of 35,953 commuters.  Commuters that remain in Bartow County: 20,692  Commuters from Bartow County to Fulton County: 1,882  Commuters from Bartow County to Cobb County: 6,936  Commuters from Bartow County to Dekalb County: 678  Commuters from Bartow County to Gwinnett County: 392  Commuters from Bartow County to Floyd County: 986 Cobb County has a total of 325,412 commuters.  Commuters that remain in Cobb County: 179,750  Commuters from Cobb County to Fulton County: 92,014  Commuters from Cobb County to Dekalb County: 18,098  Commuters from Cobb County to Gwinnett County: 8,723 6 161 Coweta County has a total of 43,506 commuters.  Commuters that remain in Coweta County: 20,735  Commuters from Coweta County to Fulton County: 8,855  Commuters from Coweta County to Cobb County: 1,136  Commuters from Coweta County to Dekalb County: 1,014  Commuters from Coweta County to Clayton County: 3,097 Dekalb County has a total of 341,110 commuters.  Commuters that remain in Dekalb County: 149,919  Commuters from Dekalb County to Fulton County: 121,921  Commuters from Dekalb County to Cobb County: 13,448  Commuters from Dekalb County to Clayton County: 5,644  Commuters from Dekalb County to Gwinnett County: 34,747 Cherokee County has a total of 74,075 commuters.  Commuters that remain in Cherokee County: 26,239  Commuters from Cherokee County to Fulton County: 17,494  Commuters from Cherokee County to Cobb County: 18,911  Commuters from Cherokee County to Dekalb County: 2,898  Commuters from Cherokee County to Gwinnett County: 2,037 Clayton County has a total of 112,580 commuters.  Commuters that remain in Clayton County: 42,924  Commuters from Clayton County to Fulton County: 40,271  Commuters from Clayton County to Cobb County: 4,053  Commuters from Clayton County to Dekalb County: 9,024  Commuters from Clayton County to Gwinnett County: 2,785 Gwinnett County has a total of 309,797 commuters.  Commuters that remain in Gwinnett County: 169,000  Commuters from Gwinnett County to Fulton County: 57,737  Commuters from Gwinnett County to Cobb County: 8,648  Commuters from Gwinnett County to Dekalb County: 51,481 Henry County has a total of 60,381 commuters.  Commuters that remain in Henry County: 18,751  Commuters from Henry County to Fulton County: 14,157  Commuters from Henry County to Cobb County: 1,365  Commuters from Henry County to Dekalb County: 5,597  Commuters from Henry County to Clayton County: 13,541  Commuters from Henry County to Gwinnett County: 1,531 Forsyth County has a total of 51,224 commuters.  Commuters that remain in Forsyth County: 21,039  Commuters from Forsyth County to Fulton County: 15,251 6 162  Commuters from Forsyth County to Cobb County: 1,790  Commuters from Forsyth County to Dekalb County: 3,067  Commuters from Forsyth County to Gwinnett County: 5,663 Carroll County has a total of 39,730 commuters.  Commuters that remain in Carroll County: 24,611  Commuters from Carroll County to Fulton County: 3,570  Commuters from Carroll County to Cobb County: 2,044  Commuters from Carroll County to Dekalb County: 700  Commuters from Carroll County to Paulding County: 493 Paulding County has a total of 40,830 commuters.  Commuters that remain in Paulding County: 10,094  Commuters from Paulding County to Fulton County: 7,432  Commuters from Paulding County to Cobb County: 14,850  Commuters from Paulding County to Dekalb County: 1,288  Commuters from Paulding County to Clayton County: 440  Commuters from Paulding County to Gwinnett County: 655 Douglas County has a total of 46,176 commuters.  Commuters that remain in Douglas County: 16,924  Commuters from Douglas County to Fulton County: 14,253  Commuters from Douglas County to Cobb County: 7,450  Commuters from Douglas County to Dekalb County: 2,211  Commuters from Douglas County to Clayton County: 1,196  Commuters from Douglas County to Gwinnett County: 747  Commuters from Douglas County to Paulding County: 596 Newton County has a total of 28,560 commuters.  Commuters that remain in Newton County: 11,545  Commuters from Newton County to Fulton County: 2,399  Commuters from Newton County to Cobb County: 411  Commuters from Newton County to Dekalb County: 3,567  Commuters from Newton County to Clayton County: 480  Commuters from Newton County to Gwinnett County: 1,320 Fayette County has a total of 45,231 commuters.  Commuters that remain in Fayette County: 16,977  Commuters from Fayette County to Fulton County: 14,745  Commuters from Fayette County to Cobb County: 1,124  Commuters from Fayette County to Dekalb County: 1,683  Commuters from Fayette County to Clayton County: 6,048 Walton County has a total of 29,031 commuters.  Commuters that remain in Walton County: 11,204  Commuters from Walton County to Fulton County: 1,666 6 163  Commuters from Walton County to Dekalb County: 2,978  Commuters from Walton County to Gwinnett County: 7,037 Spalding County has a total of 24,931 commuters.  Commuters that remain in Spalding County: 13,715  Commuters from Spalding County to Fulton County: 1,917  Commuters from Spalding County to Cobb County: 273  Commuters from Spalding County to Dekalb County: 583  Commuters from Spalding County to Clayton County: 2,113 Barrow County has a total of 22,616 commuters.  Commuters that remain in Barrow County: 7,751  Commuters from Barrow County to Fulton County: 959  Commuters from Barrow County to Dekalb County: 1,177  Commuters from Barrow County to Gwinnett County: 8,229 Rockdale County has a total of 32,931 commuters.  Commuters that remain in Rockdale County: 14,378  Commuters from Rockdale County to Fulton County: 4,792  Commuters from Rockdale County to Cobb County: 570  Commuters from Rockdale County to Dekalb County: 6,187  Commuters from Rockdale County to Clayton County: 804  Commuters from Rockdale County to Gwinnett County: 1,985 Pickens County has a total of 11,116 commuters.  Commuters that remain in Pickens County: 5,318  Commuters from Pickens County to Fulton County: 741  Commuters from Pickens County to Cobb County: 938  Commuters from Pickens County to Dekalb County: 250  Commuters from Pickens County to Gwinnett County: 218 Jasper County has a total of 5,123 commuters.  Commuters that remain in Jasper County: 1,910  Commuters from Jasper County to Fulton County: 267  Commuters from Jasper County to Dekalb County: 238  Commuters from Jasper County to Clayton County: 105  Commuters from Jasper County to Gwinnett County: 57 Putnam County has a total of 8,055 commuters.  Commuters that remain in Putnam County: 4,478  Commuters from Putnam County to Fulton County: 177  Commuters from Putnam County to Dekalb County: 129  Commuters from Putnam County to Gwinnett County: 82 Floyd County has a total of 39,622 commuters.  Commuters that remain in Floyd County: 32,440 6 164  Commuters from Floyd County to Fulton County: 528  Commuters from Floyd County to Cobb County: 662 Monroe County has a total of 10,316 commuters.  Commuters that remain in Monroe County: 4,116  Commuters from Monroe County to Fulton County: 318  Commuters from Monroe County to Dekalb County: 140  Commuters from Monroe County to Clayton County: 233 Heard County has a total of 4,488 commuters.  Commuters that remain in Heard County: 1,413  Commuters from Heard County to Fulton County: 308  Commuters from Heard County to Cobb County: 70 Hall County has a total of 65,402 commuters.  Commuters that remain in Hall County: 46,680  Commuters from Hall County to Fulton County: 2,244  Commuters from Hall County to Dekalb County: 1,716  Commuters from Hall County to Gwinnett County: 7,189 6 165 The following table contains the vehicle miles traveled ( thousand miles) for the counties in the Atlanta MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 VMT 2002 2010 VMT Growth Fulton 11,358 4,592 Bartow 1,322  285 Cobb 7,015 4,008 Coweta 1,562  596 De Kalb 9,356 4,119 Cherokee 1,795 222 Clayton 3,148 1,341 Gwinnett 6,736 1,600 Henry 1,744  508 Forsyth 1,271  328 Carroll 1,431  255 Paulding 1,047  157 Douglas 1,251 465 Newton 1,049  300 Fayette 1,197  324 Walton 684  104 Spalding 796  59 Barrow 590  123 Rockdale 924 345 Pickens 237 90 Jasper 112 70 Putnam 179 37 Floyd 948 732 Monroe 572  283 Heard 146 40 Hall 1,897  181 Pickens County has a very low VMT and VMT growth thus supporting the attainment/ unclassifiable recommendation. Approximately 82 percent of Floyd County commuters stay within the county. This commuting pattern supports Floyd County as a separate nonattainment area. Although Jasper and Putnam have low VMT, they have large emission sources. 6 166 Factor 5: Expected growth The following table has the population and population growth figures for the Atlanta MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 Population Growth 90 00 Percent Growth Fulton 825,431 167,055 26 Bartow 82,607 20,108 36 Cobb 651,485 160,006 36 Coweta 97,771 35,362 66 De Kalb 676,996 120,028 22 Cherokee 159,295 51,699 57 Clayton 252,733 54,465 30 Gwinnett 650,771 235,538 67 Henry 139,699 60,600 103 Forsyth 116,924 54,324 123 Carroll 94,907 15,846 22 Paulding 94,184 40,067 96 Douglas 98,650 21,054 30 Newton 71,594 20,193 48 Fayette 96,611 28,848 46 Walton 67,069 22,101 57 Spalding 59,410 3,960 7 Barrow 51,016 16,423 55 Rockdale 73,558 16,020 30 Pickens 25,619 8,551 59 Jasper 12,283 2,973 35 Putnam 19,390 4,675 33 Floyd 92,606 9,314 11 Monroe 22,675 4,644 27 Heard 11,340 2,384 28 Hall 152,235 43,849 46 Pickens County has a high percent growth rate. However, the actual numbers of population growth are low which support it's recommendation as attainment.

Factor 6: Meteorology This factor did not constitute a significant role in the decision making process.

Factor 7: Geography/ topography This factor did not constitute a significant role in the decision making process.

Factor 8: Jurisdictional boundaries This factor did not constitute a significant role in the decision making process.

Factor 9: Level of control of emission sources 6 167 This factor did not constitute a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendations on June 29,2004, included Jasper County as part of the Atlanta nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Jasper County as attainment/ unclassifiable, and a portion of Putnam County as nonattainment. The remainder of Putnam County will be designated attainment/ unclassifiable.

Jasper County:

Jasper County emissions in tons per year are: PM ( 2,835), NOx ( 28,144), SO2 ( 210), VOC ( 2,453). Jasper County was added to the Altanta metropolitan area in the 2003 OMB definition, has no monitor, a low population ( 12,283), and a low population density ( 33 people/ square mile), when compared to the Atlanta MSA. For example, Fulton County, which contains the design value monitor, has a population of ( 825,431), and a population density of ( 1,560 people/ square mile). The county has low emissions when compared to the Atlanta MSA. The majority of the emissions in Jasper County come from a Georgia Pacific facility which is 45 miles from the nearest violating monitor. Additionally, Jasper County has a low number of commuters ( 5,123) and only 667 of those commuters commute to the Atlanta MSA. The 2002 VMT ( 112,000) for Jasper county is lower than any county in the Atlanta MSA.

Putnam County:

In the June 29,2004, letters from EPA to the State responding to their designation recommendations, EPA proposed the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area ( as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Putnam County, GA is one of those counties.

Putnam County is adjacent to Jasper County which was added to the Altanta metropolitan area in the 2003 OMB definition, and has no monitor. Putnam County emissions in tons per year and percent of MSA are: PM ( 3,726), SO2 ( 65,560), NOx ( 34,202), and VOC ( 1,175). The NOx and SO2 emissions are primarily from the Harlee Branch power plant which is approximately 67 miles from, and downwind of, the nearest violating monitor. Putnam County has a total of ( 8,055) commuters of which only ( 388) commute to the Atlanta MSA. The 2002 VMT ( 179,000) for Putnam County is lower than any county in the Atlanta MSA.

A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small " free standing" boundaries that are 6 168 considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd shaped " land connector" extending from the main part of the nonattainment area to the power plant.

After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source ( e. g. partial county boundaries recently established for 8 hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free standing portions of nonattainment areas should be based on a pre existing boundary for a minor civil division ( such as a township or tax district) or other boundary defined for governmental use ( such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier ( StateFIPs CoFIPs Tract# Block Group#) 13 237 9603 1 portion of Putnam County as part of the Atlanta nonattainment area.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Atlanta, GA area: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Heard ( Partial), Henry, Newton, Paulding, Putnam ( Partial), Rockdale, Spalding, and Walton. 6 169 <IP_ADDRESS> Macon Area MSA The Macon MSA contains the counties of: Bibb, Houston, Jones, Peach, and Twiggs.

On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification. On June 17, 2004, the State submitted additional information and revised recommendations. The revision recommended that Bibb County be nonattainment and Monroe County as a partial county nonattainment area. EPA agrees with the State's recommendation.

Area EPA Recommendation State Recommendation Macon, GA Full counties: Bibb, Monroe as partial Full counties: Bibb, Monroe as partial The following is a brief summary of the 9 criteria for the Macon MSA and surrounding counties. These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted scores for the counties in the Macon MSA and some adjacent counties. ( MSA counties are in bold.)

County PM SOx NOx VOC AMM Weighted score Cumulative Weighted score Bibb 2,723 8,521 11,353 10,061 370 46.9 46.9 Houston 1,243 1,666 6,285 5,627 629 18.3 65.2 Twiggs 1,203 198 2,263 1,141 92 18.2 83.4 Jones 455 105 1,537 1,506 230 10.5 93.9 Peach 478 89 2,025 2,261 202 6.1 100.0 Monroe 3,403 75,571 34,069 2,189 644 104.3 Putnam 3,726 65,560 34,202 1,175 399 100.8 Jasper 2,835 210 28,144 2,453 360 69.0 Wilkinson 4,397 170 1,368 821 55 48.3 Laurens 1,222 2,674 4,717 3,688 444 28.6 Dooly 1,130 140 2,115 1,442 676 19.8 Macon 1,124 1,395 2,539 1,248 1,349 15.7 Upson 476 84 1,568 1,926 286 10.3 Taylor 398 76 966 622 833 9.7 Baldwin 451 122 2,007 2,949 203 8.9 Crawford 346 38 645 570 242 8.1 Butts 357 112 1,609 1,438 88 7.6 Pulaski 434 37 452 503 263 6.9 Bleckley 341 31 505 642 146 6.2 Lamar 257 59 812 1,090 491 4.9 6 170 Based on this analysis, Monroe County has significant emissions which contribute to the violations at the Bibb County monitor. Although Jasper and Putnam counties also have significant emissions, EPA believes those counties should be included in the Atlanta nonattainment area, rather than the Macon nonattainment area. For the counties in the Macon MSA, there is a natural break in the weighted emission score between Bibb and the remaining counties.

Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 Design Value Bibb 15.2 Houston 12.8 Wilkinson 14.9 There are two counties containing monitors in the Macon area. Bibb County contains a violating monitor while Houston County contains an attaining monitor. An adjacent county, Wilkinson, also contains an attaining monitor.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Macon MSA and some adjacent counties. Urban population figures were not available. ( MSA counties are in bold.)

County 2002 Population Percent Population of MSA Population Density Bibb 154,824 47 619 Houston 116,768 35 310 Twiggs 10,545 3 29 Jones 24,492 7 62 Peach 24,224 7 160 Monroe 22,675 57 Putnam 19,390 56 Jasper 12,283 33 Wilkinson 10,357 23 Laurens 45,890 56 Dooly 11,505 29 Twiggs, Jones, and Peach counties all have low populations with low populations densities which support their attainment recommendations. Houston County's population density is approximately half that of Bibb County's which supports it's attainment recommendation.

Factor 4: Traffic and commuting patterns Commuting Information:

Bibb County, the design value county, has a total of 63,229 commuters.  Commuters who remain in Bibb County: 54, 125 6 171 Houston County has a total of 53,089 commuters.  Commuters that remain in Houston County: 39, 954  Commuters from Houston County to Bibb County: 8,570 Twiggs County has a total of 4,086 commuters.  Commuters who remain in Twiggs County: 1,019  Commuters from Twiggs County to Bibb County: 1,929 Jones County has a total of 10,543 commuters.  Commuters who remain in Jones County: 2,472  Commuters from Jones County to Bibb County: 5,988 Peach County has a total of 9,731 commuters.  Commuters that remain in Peach County: 4,137  Commuters from Peach County to Bibb County: 2,361 Monroe County, an adjacent county, has a total of 10,316 commuters.  Commuters that remain in Monroe County: 4,116  Commuters from Monroe County to Bibb County: 3,262 Putnam County has a total of 8,055 commuters.  Commuters that remain in Putnam County: 4,479  Commuters from Putnam County to Bibb County: 329 Jasper County has a total of 5,123 commuters.  Commuters that remain in Jasper County: 1,910  Commuters from Jasper County to Bibb County: 112 Wilkinson County has a total of 4,060 commuters.  Commuters that remain in Wilkinson County: 1,933  Commuters from Wilkinson County to Bibb County: 538 Laurens County has a total of 18,986 commuters.  Commuters that remain in Laurens County: 16,046  Commuters from Laurens County to Bibb County: 501 Dooly County has a total of 4,160 commuters.  Commuters that remain in Dooly County: 2,399  Commuters from Dooly County to Bibb County: 75 The commuting patterns support Bibb County as the only MSA county in the nonattainment area. 6 172 The following table contains vehicle miles traveled ( thousand miles) for the counties in the Macon MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 VMT VMT Growth 02 10 Bibb 1,653 1,096 Houston 1,068 130 Twiggs 469  270 Jones 283 129 Peach 496  210 Monroe 572  283 Putnam 179 37 Jasper 112 70 Wilkinson 152 68 Laurens 1,037  527 Dooly 348  185 Twiggs, Jones, and Peach counties have low VMTs with low VMT growth, or negative growth. Houston County has a low VMT growth. This information supports the attainment recommendations for these counties.

Factor 5: Expected growth The following table has the population and population growth figures for the Macon MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 Population Growth 90 00 Percent Growth Bibb 154,824 3,920 3 Houston 116,768 21,557 24 Twiggs 10,545 784 8 Jones 24,492 2,900 14 Peach 24,224 2,479 12 Monroe 22,675 4,644 27 Putnam 19,390 4,675 33 Jasper 12,283 2,973 35 Wilkinson 10,357  8  0 Laurens 45,890 4,886 12 Dooly 11,505 1,624 16 Twiggs, Jones, and Peach counties all have low populations with low growth rates. This supports their recommendations as attainment/ unclassifiable.

Factor 6: Meteorology This factor did not constitute a significant role in the decision making process.

Factor 7: Geography/ topography This factor did not constitute a significant role in the decision making process. 6 173 Factor 8: Jurisdictional boundaries This factor did not constitute a significant role in the decision making process.

Factor 9: Level of control of emission sources This factor did not constitute a significant role in the decision making process.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Macon, GA area: Bibb and Monroe ( Partial).

<IP_ADDRESS> Athens Area MSA The Athens MSA contains the counties of: Clarke, Madison, and Oconee.

On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification. On June 17, 2004, the State submitted additional information and revised recommendations. The revision recommended that Clarke County be designated as nonattainment and that Oconee and Madison counties be designated as attainment.

Area EPA Recommendation State Recommendation Athens, GA Full counties: Clarke, Oconee, and Madison Full counties: Clarke The following is a brief summary of the 9 criteria for the Athens MSA and surrounding Counties. These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted scores for the counties in the Athens MSA and some adjacent counties. ( MSA counties are in bold.) 6 174 County PM SO2 NOx VOC AMM Weighted score Cumulative Weighted score Clarke 395 215 3,362 5,223 390 41.2 41.2 Oconee 507 111 1,599 2,047 1,050 30.5 71.7 Madison 543 70 1,449 1,219 3,013 28.3 100 Walton 919 176 2,759 3,952 755 57.1 Jackson 817 151 3,639 2,935 3,584 52.2 Greene 437 161 2,137 1,582 468 42.3 Barrow 706 128 2,340 2,738 1,632 40.2 Morgan 390 121 2,422 3,176 1,129 33.1 Franklin 449 84 2,068 1,813 4,128 27.6 Elbert 410 71 1,357 1,280 343 27.5 Wilkes 340 46 507 756 491 26.9 Oglethorpe 343 40 639 730 1,664 24.7 Hart 505 63 1,321 1,595 1,516 24.2 Banks 325 65 1,178 1,127 3,407 22.3 Taliaferro 131 32 718 355 89 13.1 Analysis of this factor indicates that Clarke, Oconee, and Madison counties have emissions with potential to contribute to the violation in Clarke County.

Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 Design Value Clarke 15.6 There is one violating monitor in Clarke County. Therefore, Clarke County is nonattainment.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Athens MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 Population Percent Population of MSA Population Density Clarke 103,881 66 859 Oconee 27,264 17 147 Madison 26,717 17 94 Walton 67,069 204 Jackson 45,374 133 Greene 15,101 39 Barrow 51,016 315 Morgan 16,301 47 Franklin 20,778 79 Elbert 20,667 56 Wilkes 10,734 23 Ogelthorpe 13,176 30 Hart 23,249 100 Banks 15,123 65 Taliafero 1,977 10 6 175 Walton County has appreciable population, but is population that is included in the Atlanta nonattainment area.

Factor 4: Traffic and commuting patterns Commuting Information:

Jackson County has total of 19,132 commuters.  Commuters that stay in Jackson County: 7,960  Commuters that commute to Clarke County: 3,022 Clarke County, the design value county, has a total of 48,241 commuters.  Commuters that stay in Clarke County: 39,009 Oconee County has a total of 12,903 commuters.  Commuters that stay in Oconee County: 3,630  Commuters that commute to Clarke County: 6,696 Madison County has a total of 12,257 commuters.  Commuters that stay in Madison County: 3,432  Commuters that commute to Clarke County: 6,048 Greene County has a total of 5,609 commuters.  Commuters that stay in Greene County: 3,856  Commuters that commute to Clarke County: 266 Morgan County has a total of 7,278 commuters.  Commuters that stay in Morgan County: 4,570  Commuters that commute to Clarke County: 417 Franklin County has a total of 8,844 commuters  Commuters that stay in Franklin County: 4,766  Commuters that commute to Clarke County: 461 Elbert County has a total of 8,576 commuters.  Commuters that stay in Elbert County: 6,238  Commuters that commute to Clarke County: 417 Hart County has a total of 10,275 commuters.  Commuters that stay in Hart County: 6,768  Commuters that commute to Clarke County: 272 Wilkes County has a total of 4,457 commuters.  Commuters that stay in Wilkes County: 3,464  Commuters that commute to Clarke County: 181 6 176 More than 50 percent of the commuters in Oconee County and almost 50 percent of the commuters in Madison County commute to Clarke County.

The following table contains vehicle miles traveled ( thousand miles) for the counties in the Athens MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 VMT VMT Growth 02 10 Clarke 820 929 Oconee 330 43 Madison 351 96 Jackson 748  226 Greene 354  153 Morgan 514  302 Madison 351 96 Franklin 546  228 Elbert 259 43 Hart 269 59 Wilkes 95 53 Analysis of this factor indicates that Oconee and Madison counties have commuting patterns and VMT which contribute to the violation in Clarke County.

Factor 5: Expected growth The following table has the population and population growth figures for the Athens MSA and some adjacent counties with significant emissions. ( MSA counties are in bold.)

County 2002 Population Growth 90 00 Percent Growth Clarke 103,881 13,895 16 Oconee 27,264 8,607 49 Madison 26,717 4,680 22 Jackson 45,374 11,584 39 Greene 15,101 2,613 22 Morgan 16,301 2,574 20 Franklin 20,778 3,635 22 Elbert 20,667 1,562 8 Hart 23,249 3,285 17 Wilkes 10,734 90 1 Analysis of this factor indicates that Oconee and Madison counties contain growth patterns which potentially contribute to the violation in Clarke County.

Factor 6: Meteorology This factor did not constitute a significant role in the decision making process. 6 177 Factor 7: Geography/ topography This factor did not constitute a significant role in the decision making process.

Factor 8: Jurisdictional boundaries This factor did not constitute a significant role in the decision making process.

Factor 9: Level of control of emission sources This factor did not constitute a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendations on June 29,2004, included the counties of Oconee and Madison as part of the Athens nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Oconee and Madison as attainment/ unclassifiable.

Oconee County:

Oconee County emissions in tons per year and percent of MSA emissions are: SO2 ( 111 / 28%), NOx ( 1,599/ 25%), PM ( 507/ 35%) and VOC ( 2,047/ 24%). These emissions are low when compared to Clarke County which has over half of the SO2, NOx, and VOC emissions for the MSA. Oconee County also has a low population ( 27,264/ 17% of MSA), and a low population density ( 147 people/ square mile) when compared to Clarke County which has a population of ( 103,881/ 66%) and a high population density ( 859 people/ square mile).

Oconee County has a low total number of commuters ( 12,903) of which 6,696 commute to Clarke County. This is a low number of commuters compared to Clarke County's ( 48,241) of which 80 percent ( 39,009) remain in Clarke County. Of the daily VMT in the MSA, 55 percent occurs in Clarke County. Oconee County does not contain a monitor.

Madison County:

Madison County emissions in tons per year and percent of MSA are: SO2 ( 70/ 18%), NOx ( 1,449/ 23%), PM ( 543/ 38%), and VOC ( 1,219/ 14%). These emissions are low when compared to Clarke County which has over half of the SO2, NOx, and VOC emissions for the MSA. Madison County also has a low population ( 26,717/ 17% of MSA), and a low population density ( 94 people/ square mile) when compared to Clarke County which has a population of ( 103,881/ 66%) and a high population density ( 859 people/ square mile).

Madison County has a low total number of commuters ( 12,257) of which 6,048 commute to Clarke County. This is a low number of commuters compared to Clarke County's ( 48,241) of 6 178 which 80 percent ( 39,009) remain in Clarke County. Of the daily VMT in the MSA, 55 percent occurs in Clarke County. Madison County does not contain a monitor.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Athens, GA area: Clarke <IP_ADDRESS> Chattanooga Area The Chattanooga MSA contains the following Tennessee counties: Marion and Hamilton; and the following Georgia Counties: Dade, Walker, and Catoosa. Based on air quality data for 2001 2003, the monitor with the highest design value in Hamilton County has a design value of 16.1 and the monitor in Walker County has a design value of 15.6. No other counties in the MSA contain ambient air monitors. The State of Tennessee recommended as nonattainment the county of Hamilton and the State of Georgia recommended as nonattainment the county of Walker. The States have recommended that all other counties be designated attainment. The State of Tennessee submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. EPA is modifying the State of Tennessee's recommendation and will review the additional information during the 120 day period following the notification letter.

EPA has received some information from the State of Tennessee that Marion ( MSA) County should be designated attainment for the PM2.5 standard and no justification from the State of Georgia indicating that any other counties should be included or excluded from the Chattanooga PM2.5 nonattainment area. Adjacent counties with significant emissions include McMinn and Roane Counties which are attached to the Knoxville nonattainment area and Floyd County which is a separate nonattainment area.

Additionally we have included in our recommended nonattainment area Jackson County, AL, that is adjacent to the Chattanooga MSA, that is generally rural in character, and that contains an identifiable large emitting facility or facilities ( e. g., power plants) which we believe contribute to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment. Therefore EPA is modifying the States' recommendations to include all of the counties in the MSA and the adjacent county of Jackson, Alabama.

Area EPA Recommendation States Recommendations Chattanooga Full counties: Marion, Hamilton, TN; Dade, Walker, Catoosa, GA; Jackson, AL Full counties: Hamilton and Walker 6 179 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Chattanooga MSA and some adjacent counties. ( MSA counties are in bold.)

County PM SOx NOx VOC Amm Weighted Emissions Score Cumulative Weighted Emissions Score Hamilton 1,498 5,300 20,048 27,150 1,022 49.5 49.5 Walker 856 632 2,798 4,516 958 17.9 67.4 Marion 679 477 3,156 2,640 501 14.1 81.5 Catoosa 617 167 3,085 3,601 680 11.9 93.4 Dade 302 107 2,415 1,574 285 6.5 99.9 Roane 4967 92331 30865 4300 285 296.9 Jackson, AL 4389 44333 31502 4742 1494 176.1 Floyd, GA 10057 31821 22736 7139 976 154.0 McMinn 3348 10216 10829 5546 1268 73.3 Whitfield, GA 2732 1747 7283 7386 991 54.2 Rhea 1405 302 2625 3643 149 31.2 Loudon 804 4035 5899 5338 360 24.3 DeKalb, AL 1193 741 4776 5867 5765 21.3 Bradley 1233 419 4230 7551 1916 21.1 Warren 1164 1189 1869 3675 446 20.7 Monroe 743 154 2387 3420 554 16.4 Gordon, GA 872 200 3645 4019 2630 15.8 Fannin, GA 614 65 887 1266 283 14.2 Franklin 644 482 2100 2929 1512 13.4 Chattooga, GA 450 1228 1834 1634 197 11.7 Murray, GA 576 130 2067 1700 910 11.4 Polk 295 2066 900 949 553 11.3 Cherokee, NC 428 143 921 1753 111 10.6 Grundy 202 164 1000 1150 1170 4.8 Bledsoe 203 31 475 528 335 4.5 Meigs 198 112 885 871 118 4.3 Sequatchie 140 22 304 591 173 3.4 Van Buren 118 178 291 320 74 3.3 Based on the analysis for this factor there appears to be emissions in all MSA counties and the adjacent county of Jackson, AL, which show a potential to contribute. Other adjacent counties with large emissions ( McMinn and Roane, TN and Floyd, GA) are included in other nonattainment areas. 6 180 Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001 2003 PM2.5 Design Values for all Chattanooga MSA Counties and adjacent counties. ( MSA counties are in bold.)

County 2001 2003 design value Hamilton 16.1 Walker 15.6 Roane 14.2 Floyd, GA 15.7 McMinn 14.6 Loudon 15.4 * DeKalb, AL 14.7 * Incomplete data that is not sufficient to determine attainment/ nonattainment. Data substitution does not apply.

Based on this factor, Hamilton County, TN and Walker and Floyd Counties in GA are violating the PM 2.5 standard. Catoosa County, GA is located between violating monitors in Hamilton and Walker Counties.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Chattanooga MSA and some adjacent counties. Urban population figures were not available. ( MSA counties are in bold.)

County 2002 Population Percent of MSA Population ( 2002) 2002 Population Density ( people/ mile^ 2) Hamilton 309,321 65.7 570 Walker 61,949 13.2 139 Marion 27,654 5.9 55 Catoosa 56,341 12.0 348 Dade 15,615 3.3 90 Roane 52,316 145 Jackson, AL 54,035 50 Floyd, GA 92,606 181 McMinn 50,051 116 Whitfield, GA 87,037 300 Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by the following MSA counties: Hamilton, Walker, and Catoosa. The five adjacent counties also have population with a potential to contribute.

Factor 4: Traffic and commuting patterns Commuting Information: 6 181 Hamilton has a working population of 146, 824   Commuters who remain in Hamilton: 133,644 ( 91%)

Marion has a working population 11766.   Commuters who remain in Marion: 5596 ( 48%)   Commuters from Marion to Hamilton: 4271 Dade has a working population of 6983.   Commuters who remain in Dade: 2363   Commuters from Dade to Hamilton: 3091 ( 44%)   Commuters from Dade to Walker: 747 Catoosa has a working population of 26710.   Commuters who remain in Catoosa: 7167   Commuters from Catoosa to Hamilton: 12320 ( 46%)   Commuters from Catoosa to Walker: 1937 Walker has a working population of 27223.   Commuters who remain in Walker: 11244 ( 41%)   Commuters from Walker to Hamilton: 9098 Whitfield, GA has a working population of 38,909   Commuters who remain in Whitfield: 33,796 ( 87%)   Remaining commuters do not commute to the Chattanooga MSA DeKalb, AL has a working population of 7798   Commuters who remain in DeKalb: 5179 ( 66%)   Remaining commuters do not commute to the Chattanooga MSA The following table contains the vehicle miles traveled ( thousand miles) for the counties in the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.)

County 2002 VMT ( thousand miles/ year) Hamilton 3,743 Walker 742 Marion 654 Catoosa 810 Dade 512 Roane 784 Jackson, AL 786 Floyd, GA 948 McMinn 787 Whitfield, GA 1423 6 182 Based on the analysis for this factor the VMT for all MSA counties indicate a potential to contribute. Although Whitfield County has a relatively high VMT, none of the commuters go to the Chattanooga MSA.

Factor 5: Population Growth The following table has the population and population growth figures for the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. ( MSA counties are in bold.)

County 2002 Population Growth ( 90 00) % Growth ( 90 00) Hamilton 309,321 22360 8 Walker 61,949 2713 5 Marion 27,654 2916 12 Catoosa 56,341 10818 25 Dade 15,615 2007 15 Roane 52,316 4683 10 Jackson, AL 54,035 6130 13 Floyd, GA 92,606 9314 11 McMinn 50,051 6632 16 Whitfield, GA 87,037 11063 15 Based on the analysis for this factor, there appears to be significant growth on a percentage basis in Catoosa County that indicates a contribution to the air quality in the Chattanooga MSA.

Factor 6: Meteorology This factor did not constitute a significant role in the decision making process.

Factor 7: Geography/ topography The Chattanooga area does not have any geographical or topographical boundaries limiting its airshed.

This factor did not constitute a significant role in the decision making process.

Factor 8: Jurisdictional boundaries Hamilton and Meigs Counties, TN and Catoosa County, GA were designated nonattainment for the 8 hour ozone standard on April 15, 2004.

This factor did not constitute a significant role in the decision making process.

Factor 9: Level of control of emission sources Sources in the Chattanooga area are subject to Prevention of Significant Deterioration ( PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology ( CTG 6 183 RACT)  ( Hamilton County only), Maximum Achievable Control Technology ( MACT) for Hazardous Air Pollutants ( HAP), New Source Performance Standards ( NSPS), and the NOx SIP call.

This factor did not constitute a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendations on June 29,2004, included Dade County as part of the Chattanooga nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and designating Dade County as attainment/ unclassifiable.

Dade County:

Dade County emissions in tons per year and percent of MSA are: PM ( 302/ 8%), SO2 ( 107/ 1.6%), NOx ( 2,415/ 7.7%), and VOC ( 1,574/ 4%). These are the lowest emissions of any county in the MSA. Dade County contains no major point sources of precursor emissions, has the lowest population in the MSA ( 15,615), and low population density 90 people/ square mile. Dade County constitutes approximately 3 percent of the total MSA commuters. Dade County contains no monitor.

In addition, the State's topography analysis indicates that the Lookout Mountain Ridge ( 2,100 feet) separates the low level emissions in Dade County from the violating monitors. The County is located to the west of the ridge, while the violating monitors reside to the east of the ridge.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Chattanooga, TN GA area: Catoosa and Walker.

<IP_ADDRESS> Columbus Area MSA The following is the 9 factor analysis for Columbus MSA and surrounding Counties. Alabama's submittal in February 2004, recommended that Russell County be designated nonattainment for the fine particulate matter ( PM2.5), based on 2001  2003 monitoring data. Georgia's submittal in June 2004, recommended that Harris, Muscogee and Chattahoochee Counties be designated attainment for PM2.5. Based on the following analysis EPA recommends that Lee and Russell counties in Alabama, and Harris, and Muscogee Counties in Georgia, should be included in the PM2.5 nonattainment area. Lee County is adjacent to the MSA, has high VMT and a large population. Russell County has a violating monitor and the State recommended it as nonattainment. Harris County has relatively high NOx and VOC emissions and relatively high VMT. Muscogee County has high NOx and VOC emissions, high VMT and a large population. Based on the following analysis, EPA agrees with the recommendation that Barbour, Chambers, Montgomery, Elmore and Tallapoosa Counties in Alabama, and Chattahoochee, Troup, Stewart, 6 184 Meriwether, Sumter Counties in Georgia, should be attainment/ unclassifiable for PM2.5 based on low emissions, low VMT and low population.

Area EPA Recommendation State Recommendation Columbus, GA Full counties: Lee and Russell Counties in Alabama and Harris and Muscogee Counties in Georgia Full counties: Russell County, Alabama 9 Factor Analysis for the Columbus, Georgia MSA Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5, SO2, NOx, VOC, and NH3 emissions in tons, and weighted emissions scores for the Columbus Area and surrounding counties. The MSA counties are in bold.

Columbus MSA and Surrounding Counties Emissions County PM SO2 NOX VOC NH3 Weighted Emissions Score Cumulative Weighted Emissions Score Russell, AL 1,344 2,550 5,718 4,434 179 35.1 35.1 Harris, GA 590 104 2,856 1,748 128 26.8 61.9 Muscogee, GA 513 803 5,965 9,476 323 25.4 87.3 Chattahoochee, GA 208 43 387 482 15 12.7 100 Troup, GA 1,194 422 12,277 8,223 382 48.7 Montgomery, AL 1,421 6,292 10,454 14,966 973 43.3 Lee, AL 1,043 1,425 5,125 7,474 333 42.8 Barbour, AL 874 419 2,208 2,529 497 41.6 Sumter, GA 2,578 1,725 1,726 2,262 847 40.5 Meriwether, GA 844 190 1,866 3,006 167 33.7 Elmore, AL 1,014 517 4,443 4,368 326 30.8 Tallapoosa, AL 679 655 1,993 3,230 263 26.5 Chambers, AL 579 527 2,350 2,882 124 23.9 Stewart, GA 429 32 360 464 189 23.3 Taylor, GA 398 76 966 622 833 18.3 Macon, AL 412 223 2,242 1,871 133 17.1 Talbot, GA 288 70 903 520 74 15.9 Marion, GA 314 32 328 517 470 15.4 Bullock, AL 273 93 407 570 214 12.7 Webster, GA 303 128 358 201 114 12.6 Schley, GA 192 14 195 290 163 8.4 Based on the analysis for this factor, there appear to be emissions in Lee County, Alabama, that contribute to the violation in Russell County. 6 185 Factor 2: Air quality in potentially included versus excluded areas.

Columbus MSA and Surrounding Counties Design Value ( DV)

County 2001 2003 DV Russell, AL 15.3 Muscogee, GA 14.7 Montgomery, AL 14.2 Muscogee and Montgomery Counties have monitors that show attainment of the PM2.5 standard while Russell County is violating the standard.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas.

The following table has the populations for the Counties in the Columbus MSA and adjacent Counties.

Columbus MSA and Surrounding Counties Population & Area County Population20 02 Percent in MSA Population Density 2002 Russell, AL 49,415 18 77 Harris, GA 25,092 9 54 Muscogee, GA 185,948 67 861 Chattahoochee, GA 15,440 6 62 Troup, GA 59,767 144 Montgomery, AL 223,346 283 Lee, AL 118,123 194 Barbour, AL 28,826 33 Sumter, GA 33,247 69 Meriwether, GA 22,623 45 Elmore, AL 68,771 111 Tallapoosa, AL 40,946 57 Chambers, AL 36,251 61 Stewart, GA 5,040 11 Lee County is adjacent to Russell County and its population ( 118,123) is about two and half times that of Russell County ( 49,415).

Factor 4: Traffic and commuting patterns Commuting Information:

Russell County, AL has a total of 19,859 commuters.  Commuters who remain in Russell County 7,051 ( 36%)

Harris County, GA has a total of 11,811 commuters.  Commuters from Lee County to Russell County 214 ( 2%) 6 186  Commuters who remain in Harris County 2,867 ( 24%)

Muscogee County, GA has a total of 82,977 commuters.  Commuters from Muscogee County to Russell County 2,479 ( 3%)  Commuters who remain in Muscogee County 71,862 ( 87%)

Chattahoochee County, GA has a total of 8,538 commuters.  Commuters who remain in Chattahoochee County 5,482 ( 64%)

Troup County, GA has a total of 26,339 commuters.  Commuters who remain in Troup County 22,074 ( 84%)

Montgomery County, AL has a total of 96,943 commuters.  Commuters who remain in Montgomery County 90,943 ( 94%)

Lee County, AL has a total of 52,119 commuters.  Commuters who remain in Lee County 35,549 ( 68%)  Commuters from Lee County to Russell County 2,682 ( 5%)

Barbour County, AL has a total of 10,023 commuters.  Commuters who remain in Barbour County: 8,370 ( 84%)  Commuters from Lee County to Russell County 335 ( 3%)

Sumter County, GA has a total of 13,963 commuters.  Commuters who remain in Sumter County 11,652 ( 83%)

Meriwether County, GA has a total of 8,893 commuters.  Commuters who remain in Meriwether County 4,114 ( 46%)

Elmore County, AL has a total of 28,143 commuters.  Commuters who remain in Elmore County 9,415 ( 33%)

Tallapoosa County, AL has a total of 17,009 commuters.  Commuters who remain in Tallapoosa County 12,125 ( 71%) Chambers County, AL has a total of 15,480 commuters.  Commuters who remain in Chambers County 9,281 ( 60%)

Stewart County, GA has a total of 1, 892 commuters.  Commuters who remain in Stewart County 965 ( 51%)

There are no Counties that have significant commuters commuting to Russell County. 6 187 Columbus MSA and Surrounding Counties VMT County VMT 2002 VMT Growth 02 10 Russell, AL 671 276 Harris, GA 547  207 Muscogee, GA 1,594 534 Chattahoochee, GA 56 160 Troup, GA 1,454  839 Montgomery, AL 2,565 642 Lee, AL 1,119 457 Barbour, AL 431  129 Sumter, GA 405  62 Meriwether, GA 271 138 Elmore, AL 615 168 Tallapoosa, AL 502  56 Chambers, AL 378  44 Stewart, GA 75 47 Over 50% of the VMT in the MSA is in Muscogee County, Georgia. As noted above, none of the adjacent Counties have appreciable commuting into the MSA.

Factor 5: Expected growth The following table has the population and population growth figures for the Columbus MSA and surrounding Counties.

Columbus MSA and Surrounding Counties Population/ Growth County Population 2002 Growth 90 00 Percent Growth Russell, AL 49,415 2,896 6 Harris, GA 25,092 5,907 33 Muscogee, GA 185,948 7,013 4 Chattahoochee, GA 15,440  2,052  12 Troup, GA 59,767 3,243 6 Montgomery, AL 223,346 14,425 7 Lee, AL 118,123 27,946 32 Barbour, AL 28,826 3,621 14 Sumter, GA 33,247 2,972 10 Meriwether, GA 22,623 123 1 Elmore, AL 68,771 16,664 34 Tallapoosa, AL 40,946 2,649 7 Chambers, AL 36,251  293  1 Stewart, GA 5,040  402  7 Harris County, Georgia has large growth on a percentage basis.

Factor 6: Meteorology. 6 188 A wind analysis using wind data from the Columbus, Georgia Airport was completed to evaluate the predominant wind direction( s) in Phenix City over the 3 year period on all days. There is a large easterly component to the winds during the 3 year time period., but there is not sufficient information to use meteorology as a deciding factor for an annual average..

Factor 7: Geography/ topography This factor did not constitute a significant role in the decision making process.

Factor 8 Jurisdictional boundaries.

This factor did not constitute a significant role in the decision making process.

Factor 9 Level of control of emission sources.

Reasonable Available Control Technology for VOC has been in place since 1979 Stage 1 Vapor Recovery has been in place since 1990 NOx SIP Call requires large reductions in NOx emissions from major utilities, large industrial boilers, gas turbines and cement kilns ( seasonal for Macon, Tallapoosa, Chambers, Elmore and Lee Counties). Tier II National Fuel Standard ( starting 2004)

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA's initial nonattainment recommendations on June 29, 2004, included the Counties of Lee in Alabama and Harris in Georgia as part of the Columbus, GA nonattainment area. Upon further review of additional information provided by the states, EPA is revising its recommendation and is designating Lee County, AL and Harris County, GA as attainment/ unclassifiable.

Harris County:

Harris County, Georgia, is being designated attainment/ unclassifiable because it has low population in the MSA which is only 9% ( 25,092) as compared to 185,948 in Muscogee County, the most populated County. Only 214 of Harris County commuters commute into Russell County, where the violating monitor is located, and it has low VMT ( 547,000) as compared to 1,594,000 in Muscogee. Harris County has no major point sources of precursor emissions and comparatively low emissions of 590 tons of PM, 104 tons of SO2, and 2,856 tons of NOx.

We considered the data in the request for spatial averaging for the Columbus area, which was denied, while evaluating the other factors and determined that Harris County is not contributing to the violations. 6 189 Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Columbus, GA AL area: Muscogee.

<IP_ADDRESS> Augusta Area On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification. On June 15, 2004, the State submitted additional information and revised recommendations for the Augusta area. The revision recommended that Richmond County be unclassifiable.

Richmond County has two PM2.5 monitors with air quality data for 2001 2003. The data for one monitor demonstrates attainment and the other monitor has incomplete data for 2001 2003 that was violating. EPA's analysis of all the available monitoring data indicates that the area should be designated as attainment/ unclassifiable.

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as attainment/ unclassifiable for the Augusta, GA area: Richmond.

6.4.3 EPA 9 Factor Analyses for Kentucky for the Designation of PM2.5 Nonattainment Areas <IP_ADDRESS> Cincinnati Hamilton Area The MSA contains the Kentucky Counties of Boone, Campbell, Kenton, Grant, Pendleton, Gallatin; the Ohio Counties of Hamilton, Clermont, Butler, Warren, Brown; and the Indiana Counties of Dearborn and Ohio.

The following counties are violating the PM2.5 standard: Hamilton County, Ohio; Butler County, Ohio; and Montgomery County, Ohio.

In February 2004, Kentucky recommended that all Kentucky counties in the Cincinnati Hamilton MSA be designated attainment for the PM2.5 standard. EPA is modifying Kentucky's recommendation to include Boone, Campbell and Kenton Counties in the Cincinnati Hamilton nonattainment area. Boone County has significant emissions, relatively high population growth, and a large (> 10,000 tons per year SO2) power plant located in the County. Campbell and Kenton Counties have significant VMT, significant numbers of commuters into violating Hamilton County, and both counties part of the Cincinnati 1 hour ozone nonattainment area due to violating monitors. Kenton County also has monitoring data close to the standard. EPA agrees that the remaining KY MSA counties of Gallatin, Grant, and Pendleton should be designated as attainment/ unclassifiable due to low emissions, very low population relative to the area, and very low numbers of commuters into the violating counties. 6 190 EPA agrees that the adjacent counties of Carroll and Mason should be designated attainment/ classifiable for the PM2.5 standard, although they have significant emissions due to power plants. These counties have relatively low populations, low population growth, and low VMT . Further, their commuting patterns and distance from the violating monitors indicate that these counties do not contribute to the violations in the area. The other adjacent counties do not contribute and therefore, will be designated as attainment/ unclassifiable.

Area EPA Recommendation State Recommendation Cincinnati Hamilton, OH KY IN Full counties: Boone County Campbell County Kenton County Full counties: none The following is a brief summary of the nine criteria for the Cincinnati Hamilton, OH KY IN area. These analyses were based on existing available data.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Cincinnati Hamilton MSA and surrounding counties. ( MSA counties are in bold; Kentucky MSA counties in bold italics.)

County PM SOx NOx VOC Amm Score Cum. Score Hamilton, OH 7,601 88,053 58,398 47,014 2,422 30.3 30.3 Clermont, OH 6,443 84,599 45,618 7,638 326 20.0 50.3 Dearborn, IN 3581 56,773 31,138 3,732 246 11.4 61.7 Butler, OH 3,153 13,204 19,735 14,228 1,363 9.9 71.6 Boone, KY 1,946 14,717 15,794 6,644 256 7.7 79.3 Warren, OH 1,844 895 7,565 7,003 417 6.9 86.2 Kenton, KY 741 1,573 8,365 7,392 285 4.2 90.4 Campbell, KY 590 860 5,294 4,421 267 2.8 93.2 Brown, OH 748 395 2,927 1,995 294 2.0 95.2 Grant, KY 381 210 2,664 1,364 257 1.8 97.0 Pendleton, KY 363 597 3,396 900 186 1.5 98.5 Gallatin, KY 367 350 2,365 904 192 1.0 99.5 Ohio, IN 142 113 682 380 238 0.5 100.0 Adams, OH 6,417 125,136 52,992 1,508 431 19.4 N/ A Montgomery, OH 2,542 11,214 24,177 28,598 1,170 12.2 N/ A Carroll, KY 3,547 53,086 26,269 3,249 159 10.3 N/ A Mason, KY 2,316 38,142 16,071 1,640 520 7.0 N/ A Greene, OH 1,516 1,895 8,841 5,827 538 4.0 N/ A Preble, OH 963 428 2,765 2,638 762 2.2 N/ A Ripley, IN 743 140 2,081 3,519 796 2.0 N/ A Scott, KY 627 260 3,629 6,041 481 2.0 N/ A Fayette, OH 883 309 2,136 2,100 310 1.9 N/ A Decatur, IN 922 154 2,525 3,876 1,538 1.8 N/ A Clinton, OH 788 375 2,490 2,572 329 1.8 N/ A Rush, IN 1,003 140 1,274 1,839 1,227 1.6 N/ A 6 191 Highland, OH 687 242 1,756 2,089 373 1.6 N/ A Fayette, IN 561 150 1,426 2,609 387 1.4 N/ A Franklin, IN 491 92 1,335 1,634 664 1.3 N/ A Harrison, KY 354 290 1,786 1,158 303 1.1 N/ A Owen, KY 236 57 572 566 245 1.1 N/ A Switzerland, IN 257 251 1,554 776 364 1.0 N/ A Bracken, IN 174 52 570 479 134 0.7 N/ A Union, IN 343 58 548 705 266 0.6 N/ A Robertson, KY 74 12 112 107 65 0.3 N/ A Based on the analysis for this factor for Kentucky only, Boone, Carroll, and Mason Counties have significant emissions which could indicate a potential emissions contribution to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties listed in this table.

Factor 2: Air quality in potentially included versus excluded areas The following table contains the design value for the MSA and adjacent counties that contain PM2.5 monitors. Design values followed by " a" indicate that the value is based on incomplete monitoring data. ( MSA counties are in bold; Kentucky MSA counties in bold italics.)

County 2001 2003 design value Hamilton, OH 17.8 Butler, OH 16.2 Kenton, KY 15.0 Campbell, KY 14.5 Montgomery, OH 15.2 Greene, OH 9.5a Preble, OH 13.5a Based on an analysis of this factor for Kentucky only, the Campbell and Kenton County monitors are attaining. The Kenton County monitor reading of 15.0 indicates that there may be a potential emissions contribution from the County to the area. This factor is not significant for the remaining Kentucky counties.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Cincinnati Hamilton MSA and some adjacent counties with violating monitors and those with significant emissions. The total MSA 2002 population is 2,009,679. ( MSA counties are in bold; Kentucky MSA counties in bold italics.)

County 2002 Population Percent of Population of MSA 2002 Population Density Hamilton, OH 833,721 41.49 2,048 Clermont, OH 183,352 9.12 406 Dearborn, IN 47,333 2.36 155 6 192 Butler, OH 340,543 16.95 729 Boone, KY 93,290 4.64 379 Warren, OH 175,133 8.71 438 Kenton, KY 152,164 7.57 934 Campbell, KY 88,604 4.41 583 Brown, OH 43,464 2.16 88 Grant, KY 23,620 1.18 91 Pendleton, KY 14,815 0.74 53 Gallatin, KY 7,836 0.39 79 Ohio, IN 5,804 0.29 67 Adams, OH 27,804 48 Montgomery, OH 554,470 1,200 Carroll, KY 10,223 79 Mason, KY 16,916 70 Based on the analysis for this factor, the populations for the Kentucky counties are much smaller than those in the Ohio Counties of Hamilton, Butler, and Montgomery. The Kentucky Counties of Boone, Kenton, and Campbell have population values of some significance as compared to the much smaller MSA Kentucky Counties of Grant, Gallatin, and Pendleton. This factor is not significant for the remaining Kentucky counties in this table.

Factor 4: Traffic and commuting patterns Commuting Information Total number of workers in Boone County, KY: 44,507 Commuters in Boone County, KY who work in Boone County, KY: 23,589 ( 53%) Commuters from Boone County, KY to Hamilton County, OH: 8,351 ( 19%) Commuters from Boone County, KY to Butler County, OH: 641 ( 1%)

Total number of workers in Kenton County, KY: 76,169 Commuters in Kenton County, KY who work in Kenton County, KY: 30,771 ( 40%) Commuters from Kenton County, KY to Boone County, KY: 17,053 ( 22%) Commuters from Kenton County, KY to Hamilton County, OH: 20,200 ( 27%) Commuters from Kenton County, KY to Butler County, OH: 908 ( 1%)

Total number of workers in Campbell County, KY: 42,820 Commuters in Campbell County, KY who work in Campbell County, KY: 15,474 ( 36%) Commuters from Campbell County, KY to Boone County, KY: 4,062 ( 9%) Commuters from Campbell County, KY to Hamilton County, OH: 14,946 ( 35%) Commuters from Campbell County, KY to Butler County, OH: 652 ( 2%)

Total number of workers in Gallatin County, KY: 3,589 Commuters in Gallatin County, KY who work in Gallatin County, KY: 1,317 ( 37%) Commuters from Gallatin County, KY to Boone County, KY: 1,038 ( 29%) Commuters from Gallatin County, KY to Hamilton County, OH: 196 ( 5%)

Total number of workers in Grant County, KY: 10,262 6 193 Commuters in Grant County, KY who work in Grant County, KY: 4,181 ( 41%) Commuters from Grant County, KY to Boone County, KY: 2,852 ( 28%) Commuters from Grant County, KY to Hamilton County, OH: 716 ( 7%)

Total number of workers in Pendleton County, KY: 6,467 Commuters in Pendleton County, KY who work in Pendleton County, KY: 2,482 ( 38%) Commuters from Pendleton County, KY to Boone County, KY: 789 ( 12%) Commuters from Pendleton County, KY to Hamilton County, OH: 785 ( 12%) Commuters from Pendleton County, KY to Butler County, OH: 101 ( 2%)

Total number of workers in Carroll County, KY: 4,466 Commuters in Carroll County, KY who work in Carroll County, KY: 3,475 ( 78%) Commuters from Carroll County, KY to Boone County, KY: 54 ( 1%) Commuters from Carroll County, KY to Hamilton County, OH: 48 ( 1%)

Total number of workers in Mason County, KY: 7,560 Commuters in Boone County, KY who work in Boone County, KY: 5,978 ( 79%) Commuters from Mason County, KY to Hamilton County, OH: 95 ( 1%)

A notable number of commuters from Kenton and Campbell Counties commute into violating Hamilton County. Although these numbers are far less than the number of commuters in Hamilton County, in conjunction with VMT data analyzed below, they indicate some potential for contributing to the mobile source emissions in the area.

Although 47% of Boone's 44,507 workers commute into other counties in the MSA, a relatively small number commute into the violating counties. In Carroll County, 78% of the 4,466 workers commute within the County. Similarly, in Mason County, 79% of the 7,560 workers commute within the County. Thus, onroad mobile source emissions from commuting patterns for Boone, Carroll, and Mason Counties do not appear to be contributing to violations in the area. This factor is not significant for the remaining Kentucky counties listed above.

Vehicle Miles Traveled:

The following table has the vehicle miles traveled ( thousand miles) for the counties in the Cincinnati Hamilton MSA and some adjacent counties with significant emissions. ( MSA counties are in bold; Kentucky MSA counties in bold italics.)

County 2002 VMT ( thousand miles/ year) Hamilton, OH 8,420 Clermont, OH 1,649 Dearborn, IN 607 Butler, OH 2,610 Boone, KY 842 Warren, OH 1,354 Kenton, KY 1,816 Campbell, KY 1,097 6 194 Brown, OH 417 Grant, KY 379 Pendleton, KY 169 Gallatin, KY 254 Ohio, IN 56 Adams, OH 283 Montgomery, OH 5,668 Carroll, KY 213 Mason, KY 178 Based on an analysis of this factor for Kentucky only, the VMT for Boone, Kenton, and Campbell Counties are in the relatively moderate to high range as compared to the counties listed above, with the exception of the the violating Ohio counties of Hamilton, Butler, and Montgomery. Boone, Kenton, and Campbell VMT data indicate some potential to contribute to the PM2.5 violations in the area. VMT values for Carroll and Mason are very low and do not indicate a potential contribution. This factor is not significant for the remaining Kentucky counties listed in this table.

Factor 5: Expected growth The following table has the population and population growth figures for the Cincinnati Hamilton MSA and some adjacent counties with significant emissions. ( MSA counties are in bold; Kentucky MSA counties in bold italics.)

County 2002 Population growth ( 90 00) % growth ( 90 00) Hamilton, OH 833,721  20,925  2 Clermont, OH 183,352 27,790 19 Dearborn, IN 47,333 7,274 19 Butler, OH 340,543 41,328 14 Boone, KY 93,290 28,402 49 Warren, OH 175,133 44,474 39 Kenton, KY 152,164 9,433 7 Campbell, KY 88,604 4,750 6 Brown, OH 43,464 7,319 21 Grant, KY 23,620 6,647 42 Pendleton, KY 14,815 2,354 20 Gallatin, KY 7,836 2,477 46 Ohio, IN 5,804 308 6 Adams, OH 27,804 1,959 8 Montgomery, OH 554,470  14,747  3 Carroll, KY 10,223 863 9 Mason, KY 16,916 134 1 While the Kentucky Counties of Boone, Grant, and Gallatin have the highest population growth rates from 1990 2000 than all of the counties in the MSA, only Boone County's resulting population increase of 28,402, ( third highest increase in the MSA), is significant enough to indicate a potential to contribute to violations in the area. The population growth rates of Carroll and Mason Counties are relatively very low and thus, do not indicate a potential to contribute to 6 195 the area's violations. This factor is not significant for the remaining Kentucky counties listed in this table.

Factor 6: Meteorology The following meteorological information was provided by Kentucky for the MSA Kentucky Counties of Boone, Campbell, Kenton, Gallatin, Pendleton, and Grant. ( The figure referenced is a wind rose for April 1 October 31 for the 1988 1992 period that is provided in Kentucky's PM2.5 recommendations submittal.)

Meteorological Information " Due to the close proximity of Cincinnati, Ohio, meteorological data from Cincinnati was used for this Kentucky area. Wind speed/ wind direction information shows that the majority of the time for the period 1988   1992, the wind in the... County area came from the southwest and typically from 7 10 knots. ( See figure 1 A) The mean high temperature for July for the area from 1961 through 1990 was 86

F, the mean low was 66

F. The mean precipitation for the same period was 3.8 inches." ( Source: Kentucky PM2.5 submittal)

Based on an analysis of this factor, the information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds. This information was provided only for the summertime winds.

Factor 7: Geography/ topography Based on an analysis of this factor, there are no significant topographical issues associated with this MSA. For the adjacent Carroll and Mason Counties in Kentucky with significant emissions, both counties are two counties removed from the nearest county with a violating monitor ( Hamilton, Ohio), with attaining monitors in between in Kenton and Campbell Counties in Kentucky.

Factor 8: Jurisdictional boundaries The following MSA counties were designated nonattainment for the 8 hour ozone standard on April 15, 2004: the Kentucky Counties of Boone, Campbell, and Kenton; the Indiana County of Dearborn; and the Ohio Counties of Hamilton, Clermont, Butler, Warren, Montgomery, Greene, Clinton. This factor did not play a significant role in the decision making process.

Factor 9: Level of control of emission sources The following information was provided by Kentucky for Boone, Campbell, Kenton, Grant, Gallatin and Pendleton Counties. " Point sources located within... County are subject to PSD requirements, CTG RACT requirements, Maximum Achievable Control Technology ( MACT) requirements for sources of Hazardous Air Pollutants, and New Source Performance Standards ( NSPS). Any controls imposed as a result of previous nonattainment designations are required to remain in... County." 6 196 For Boone County only: " Additionally, substantial NOx reductions have occurred during the last year from East Bend Power Plant which would further lower the contribution of NOx emissions from Boone County."

This factor did not play a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States No Changes Made to June 29, 2004, Recommendations.

Boone County, KY:

Boone County contains one major point source, the Cinergy East Bend ( Cincinnati Gas & Electric) power plant. Kentucky provided the following information on controls at this facility: scrubber with 85% control efficiency; ESP with > 99% control efficiency; and low NOx burners and SCR with annual efficiency 69%. NOx controls have been in place since 2002. The NOx SCR controls are seasonal. The installation of SCR in 2002 gained 2,534 tpy of NOx reductions.

Corrections to TSD for Cincinnati Hamilton MSA:

<IP_ADDRESS> Factor 1: The following corrections are made to the third paragraph in this section as follows:

Insert redlined phrase: "... and both counties were previously designated part of the Cincinnati 1 hour ozone nonattainment area..."

Add an " s" to: "... very low populations relative to the area..."

<IP_ADDRESS>  Factor 2: The 2001 2003 design values in the Factor 2 table for Campbell and Kenton Counties are corrected to read as follows:

County 2001 2003 design value Kenton, KY 14.9 Campbell, KY 13.9 <IP_ADDRESS> Factor 4:

The following correction is made to the section, " Commuting Information," for Mason County: 6 197 Replace " Boone" with " Mason" as noted: " Commuters in MasonBoone County, KY who work in MasonBoone County, KY..."

Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Cincinnati   Hamilton, OH KY IN area: Boone, Campbell, and Kenton.

<IP_ADDRESS> Louisville Area The Louisville MSA contains the Kentucky Counties of Jefferson, Bullitt, and Oldham; and the Indiana Counties of Floyd, Clark, Harrison, and Scott. Jefferson County, Kentucky and Clark County, Indiana are violating the PM2.5 standard. The adjacent Kentucky County of Carroll has relatively high emissions for the area, however, it was evaluated as part of the Cincinnati area.

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

EPA agrees that the Kentucky MSA County of Oldham be designated attainment/ unclassifiable due to low emissions and relatively low population. EPA agrees that Jefferson County be designated nonattainment due to four violating monitors in the County and is modifying Kentucky's recommendation to include Bullitt County in the Louisville nonattainment area due to a relatively high number of commuters into violating Jefferson County, a monitored PM2.5 value of 15.0 that is very close to the standard, and relatively high population growth.

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

Area EPA Recommendation for KY State Recommendation Louisville, KY Full counties: Jefferson County Bullitt County Full counties: Jefferson The following is a brief summary of the nine criteria for the Louisville, KY area. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Louisville MSA and surrounding counties. ( MSA counties are in bold; Kentucky MSA counties in bold italics.)

County PM SOx NOx VOC Amm Score Cum. Score 6 198 Jefferson, KY 7,385 62,526 81,398 55,376 1,539 51.5 51.5 Floyd, IN 3,826 47,796 10,282 4,789 346 16.4 67.9 Clark, IN 1,612 484 4,960 7,125 498 12.2 80.1 Bullitt, KY 829 343 3,463 5,817 210 7.3 87.4 Harrison, IN 794 419 3,677 2,702 2,632 5.3 92.7 Oldham, KY 770 529 3,707 2,168 224 4.7 97.4 Scott, IN 397 100 1,515 2,426 318 2.6 100.0 Carroll, KY 3,547 53,086 26,269 3,249 159 15.2 Jefferson, IN 2,247 39,599 33,990 2,921 302 11.2 Hardin, KY 1,207 1,774 7,695 6,713 1,114 9.1 Lawrence, IN 1,544 4,330 5,707 3,330 543 6.5 Jackson, IN 919 260 3,427 4,721 898 5.8 Nelson, KY 781 497 2,134 7,923 1,147 5.0 Trimble, KY 869 7,998 8,458 520 182 4.6 Breckinridge, KY 566 321 2,592 1,273 757 4.4 Grayson, KY 593 412 1,532 1,796 1,166 4.0 Meade, KY 692 661 4,551 2,272 556 4.0 Shelby, KY 699 397 2,906 2,778 842 4.0 Franklin, KY 506 601 3,059 4,396 217 3.8 Jennings, IN 640 233 1,589 2,274 256 3.5 Perry, IN 518 789 3,102 2,018 403 3.4 Hart, KY 391 162 1,839 1,499 662 3.2 Washington, IN 580 136 1,452 2,448 3,468 3.1 Taylor, KY 408 632 3,642 1,609 461 3.1 Crawford, IN 319 536 3,842 1,237 192 2.9 Orange, IN 475 86 2,017 2,599 313 2.9 Anderson, KY 335 443 1,535 2,648 164 2.5 Marion, KY 381 143 801 1,400 775 2.5 Henry, KY 424 156 1,465 1,246 420 2.1 Owen, KY 236 57 572 566 245 2.1 Larue, KY 294 186 768 646 573 1.8 Washington, KY 273 115 618 1,051 584 1.8 Green, KY 261 104 507 586 331 1.7 Spencer, KY 281 31 393 574 221 1.7 Based on the analysis for this factor for Kentucky only, the Kentucky Counties of Jefferson and Carroll have significant emissions. Bullitt County has emissions with a potential to contribute to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties listed in this table. 6 199 Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 design value Jefferson, KY 16.9 Floyd, IN 14.9 Clark, IN 16.2 Bullitt, KY 15.0 Franklin, KY 13.6 Hardin, KY 14.1 There are four counties in the MSA with PM2.5 monitors, two of which have violating design values ( Jefferson County, Kentucky and Clark, Indiana). Bullitt County, Kentucky has an attaining monitor whose design value is close to the standard ( 15.0), which indicates that there is a potential to contribute to the PM2.5 violations in area. The adjacent Kentucky Counties of Hardin and Franklin are monitoring attainment and thus, do not indicate emissions contributions. This factor is not significant for the remaining Kentucky counties listed in this table.

Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Louisville MSA and adjacent counties with significant emissions. The total MSA 2002 population is 1,039,599. ( MSA counties are in bold; Kentucky MSA counties are in bold italics.)

County 2002 Population % of MSA Population (%) Population Density Jefferson, KY 698,080 67.15 1,813 Floyd, IN 71,633 6.89 484 Clark, IN 98,198 9.45 262 Bullitt, KY 63,800 6.14 213 Harrison, IN 35,244 3.39 73 Oldham, KY 49,310 4.74 261 Scott, IN 23,334 2.24 123 Hardin, KY 95,724 N/ A 152 Based on the analysis for this factor for Kentucky only, Jefferson County's population of 698,080 is approximately 6 30 times higher than all the other MSA counties. Hardin County's population is the third largest of the counties analyzed, however, it is still relatively insignificant in comparison to Jefferson County's population. Thus, this factor is not significant for the Kentucky counties listed in this table with the exception of Jefferson County.

Factor 4: Traffic and commuting patterns Commuting Information:

Total number of workers in Jefferson County, KY: 329,091 Commuters in Jefferson County, KY who work in Jefferson County, KY: 303,624 ( 92%) Commuters from Jefferson County, KY to Clark County, IN: 7,047 ( 2%) 6 200 Total number of workers in Bullitt County, KY: 30,648 Commuters in Bullitt County, KY who work in Bullitt County, KY: 8,419 ( 27%) Commuters from Bullitt County, KY to Jefferson County, KY: 19,730 ( 64%) Commuters from Bullitt County, KY to Clark County, IN: 418 ( 1%)

Total number of workers in Oldham County, KY: 27,716 Commuters in Oldham County, KY who work in Oldham County, KY: 7,207 ( 33%) Commuters from Oldham County, KY to Jefferson County, KY: 12,684 ( 58%) Commuters from Oldham County, KY to Clark County, IN: 326 ( 1%)

Total number of workers in Hardin County, KY: 44,815 Commuters in Hardin County, KY who work in Hardin County, KY: 36,030 ( 80%) Commuters from Hardin County, KY to Jefferson County, KY: 5,347 ( 12%)

Based on the commuting data for the Kentucky counties listed above, there appears to be potentially significant on road mobile source emissions contributions from Bullitt and Oldham to Jefferson County, which has over 300,000 resident commuters. A large percent ( 78% 80%) of the workers in Carroll and Hardin Counties, respectively, commute within their resident counties. Thus, with the exception of Bullitt, Jefferson, and Oldham Counties, this factor is not significant for the remaining Kentucky counties listed above.

Vehicle Miles Traveled ( VMT):

The following table has the vehicle miles traveled ( thousand miles) for the counties in the Louisville MSA and the adjacent county of Hardin due to its relatively high VMT and population. ( MSA counties are in bold; Kentucky MSA counties are in bold italics.)

County 2002 VMT ( thousand miles/ year) Jefferson, KY 7,149 Floyd, IN 843 Clark, IN 1,262 Bullitt, KY 849 Harrison, IN 528 Oldham, KY 507 Scott, IN 364 Hardin, KY 1,333 Based on the analysis for this factor, the VMT for Jefferson County far exceeds the VMT of the MSA and surrounding counties. Although Hardin County has a relatively high VMT, 80% of its workers commute within the County, with an additional 12% commuting into Jefferson County, Kentucky. Based on the analysis for this factor, Hardin County does not appear to significantly contribute on road mobile source emissions to Jefferson County. Thus, with the exception of Jefferson County, this factor is not significant for the remaining Kentucky counties listed in this table. 6 201 Factor 5: Expected growth The following table has the population and population growth figures for the Louisville MSA and the adjacent Hardin County due to its relatively high VMT and population. ( MSA counties are in bold; Kentucky MSA counties are in bold italics.)

County 2002 Population growth ( 90 00) % growth ( 90 00) Jefferson, KY 698,080 28,667 4 Floyd, IN 71,633 6,419 10 Clark, IN 98,198 8,695 10 Bullitt, KY 63,800 13,669 29 Harrison, IN 35,244 4,435 15 Oldham, KY 49,310 12,915 39 Scott, IN 23,334 1,969 9 Hardin, KY 95,724 4,934 6 Based on the analysis for this factor for Kentucky only, the population growth in Bullitt and Oldham Counties indicate that these counties may contribute to the PM2.5 issues in Jefferson County. Although Jefferson County's growth rate is fairly low, the magnitude of its population increase is the highest in the MSA and is approximately twice that of the increases in Bullitt and Oldham. Although Hardin County's population is the third largest of the counties analyzed above, its population growth is relatively low. Thus, with the exception of Bullitt, Jefferson, and Oldham Counties, this factor is not significant for the remaining Kentucky counties listed in this table.

Factor 6: Meteorology The following meteorological information was provided by Kentucky for Jefferson, Bullitt, and Oldham.

Wind speed/ wind direction information shows that the majority of the time for the period 1988   1992, the wind in the... County area came from the south southwest and typically at 7 10 knots. The mean high temperature for July for the area from 1961 through 1990 was 87

F and the mean low was 70

F. The mean precipitation for the same period was 4.3 inches.

The information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds. The information provided was based only on summertime winds.

Factor 7: Geography/ topography Based on an analysis of this factor, there are no significant geographical or topographical issues associated with this MSA. boundary. 6 202 Factor 8: Jurisdictional boundaries The following MSA counties were designated nonattainment for the 8 hour ozone standard on April 15, 2004: the Kentucky Counties of Jefferson, Bullitt, and Oldham; and the Indiana Counties of Floyd, Clark, and Jackson. This factor did not play a significant role in the decisionmaking process for these counties.

Factor 9: Level of control of emission sources The following information was provided by Kentucky for Bullitt, Oldham, and Jefferson Counties: " Point sources located within... County are subject to Prevention of Significant Deterioration ( PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology ( CTG RACT) requirements, Maximum Achievable Control Technology ( MACT) requirements for sources of Hazardous Air Pollutants ( HAP), and New Source Performance Standards ( NSPS)." This factor did not play a significant role in the decisionmaking process for these counties.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States No Changes Made to June 29, 2004, Recommendations.

Corrections to TSD for Louisville MSA:

<IP_ADDRESS> Factor 2: The 2001 2003 design value in the Factor 2 table for Bullitt County is corrected to read as follows:

Bullitt, KY 14.9 Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Louisville, KY IN area: Bullitt and Jefferson.

<IP_ADDRESS> Lexington Area The Lexington MSA contains the Counties of Fayette, Bourbon, Clark, Jessamine, Madison, Scott, and Woodford. Fayette County is violating the PM2.5 standard.