6 251 6.5 Region 5 Nonattainment Areas 6.5.1 EPA 9 Factor Analyses for Illinois for Designation of PM2.5 Nonattainment Areas The following table identifies the individual areas and counties comprising those areas in Illinois that EPA is designating as nonattainment for the fine particulate matter (" PM2.5") air quality standard. Where EPA is including only part of a county in a nonattainment area, we have indicated the boundaries of the portion of the county that will be included. Following this table is a description of the data EPA examined and a discussion of each area and the basis for EPA's designations. EPA is designating as attainment/ unclassifiable all other Illinois counties or parts thereof not identified in the table below.

Area Illinois Counties in Metropolitan Area Illinois Recommended Nonattainment Counties Counties EPA is Designating Nonattainment Chicago Gary Kenosha, IL INWI Cook Du Page Kane Lake Mc Henry Will Grundy Kendall De Kalb Kankakee Cook Du Page Kane Lake Mc Henry Will Grundy: Aux Sable Township Goose Lake Township Kendall: Oswego Township Cook Du Page Kane Lake Mc Henry Will Grundy: Aux Sable Township Goose Lake Township Kendall: Oswego Township Saint Louis, MOIL Madison Monroe St Clair Clinton Jersey Madison Monroe St Clair Madison Monroe St Clair Randolph: Baldwin Township <IP_ADDRESS> Chicago Gary Kenosha Area Discussion:

EPA reviewed the nine factors for the thirteen counties within the metropolitan area ( including ten counties in Illinois) as well as all counties adjacent to the metropolitan area in order to determine the appropriate nonattainment area. There are violating monitors in Cook County and in Lake County, Indiana. EPA agrees with the Illinois EPA to include Cook, Du Page, Kane, Lake, Mc Henry, and Will counties, Aux Sable and Goose Lake Townships in Grundy County, and Oswego Township in Kendall County in the Chicago nonattainment area. The bulk of emissions and population are captured without including DeKalb, Grundy, Kankakee and Kendall Counties, since these counties have limited emissions and population. Nevertheless, we support the recommendation by the Illinois EPA to include the three townships in Grundy and Kendall counties in the nonattainment area to maintain consistency with the ozone designations and thereby facilitate planning. 6 252 There are eight Illinois counties adjacent to the metropolitan area, including Boone, Ford, Iroquois, LaSalle, Lee, Livingston, Ogle, and Winnebago Counties. Emissions are relatively low for these counties, and no other factor warranted designating these counties nonattainment. Therefore, the following data summaries for factors 3 through 9 do not address these counties.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area County SO2 NOx Carbon Crustal Composite emissions score Cook 61,676 195,428 10,110 8,268 33.0 De Kalb 445 4,885 384 1,875 1.0 Du Page 2,990 29,479 1,731 1,229 4.9 Grundy 6,149 9,589 563 1,235 2.1 Kane 1,395 9,490 1,047 2,326 2.8 Kankakee 551 6,628 490 1,720 1.4 Kendall 292 2,941 265 961 0.7 Lake 14,223 24,488 2,092 1,777 6.7 Mc Henry 637 5,834 564 1,992 1.6 Will 80,847 37,518 1,447 4,120 11.7 Lake, IN 50,110 72,142 5,708 7,588 19.5 Porter, IN 21,601 41,315 2,702 5,587 9.2 Kenosha, WI 33,122 27,469 770 1,236 5.4 Boone 849 2,188 215 834 0.6 Ford 219 1,462 216 1,280 0.6 Iroquois 458 4,177 452 2,290 1.3 La Salle 2,140 13,984 845 3,352 2.5 Lee 3,978 4,793 345 1,722 1.3 Livingston 503 4,686 485 2,413 1.3 Ogle 672 4,985 335 1,536 1.1 Winnebago 1,100 10,496 656 1,405 1.9 Benton, IN 101 1,326 215 724 0.5 Berrien, IN 1,390 10,269 740 1,340 0.6 6 253 Jasper, IN 34,435 23,020 668 1,838 5.2 La Porte, IN 10,974 19,681 826 1,643 3.3 Newton, IN 89 1,321 160 642 0.4 Pulaski, IN 111 1,187 196 667 0.5 St Joseph, IN 2,850 13,690 1,482 1,825 4.0 Starke, IN 100 2,852 188 551 0.5 White, IN 188 2,495 292 1,185 0.8 Racine, WI 2,309 7,252 662 890 1.9 Walworth, WI 866 5,693 470 908 1.3 Urban increment: Total mass= 3.6 µ g/ m3 25% sulfates; 8% nitrates; 65% carbon; 2% crustal. Urban site= 170310076; Rural site= BOND1 ( Bondville)

Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 Design Value Cook 17.3 µ g/ m3 Du Page 14.4 µ g/ m3 Kane 14.2 µ g/ m3 Lake 12.8 µ g/ m3 Mc Henry 12.7 µ g/ m3 Will 12.8 µ g/ m3 Lake, IN 15.2 µ g/ m3 Porter, IN 13.8 µ g/ m3 Kenosha, WI 11.7 µ g/ m3 La Porte 13.6 µ g/ m3 La Salle 14.1 µ g/ m3 Winnebago 13.6 µ g/ m3 St Joseph, IN 14.3 µ g/ m3 Berrien, MI 12.7 µ g/ m3 6 254 Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas County 2003 Population Population Density Cook 5,377,507 5,684 De Kalb 91,561 144 Du Page 924,589 2,768 Grundy 38,839 92 Kane 443,041 850 Kankakee 104,657 154 Kendall 61,222 191 Lake 674,850 1,506 Mc Henry 277,710 460 Will 559,861 669 Lake, IN 487,016 980 Porter, IN 150,403 360 Kenosha, WI 154,433 566 Factor 4: Traffic and commuting patterns County County VMT Percent Number Cook 44,107,000 12 274,167 De Kalb 729,000 31 13,894 Du Page 6,609,000 40 186,686 Grundy 530,000 46 8,431 Kane 841,000 43 82,968 Kankakee 889,000 19 9,122 Kendall 278,000 67 19,070 Lake 3,549,000 32 100,810 Mc Henry 792,000 47 62,415 Will 2,136,000 55 131,834 Lake, IN 5,012,000 25 52,922 Porter, IN 1,680,000 36 25,819 6 255 Kenosha, WI 1,228,000 28 20,506 Factor 5: Expected growth County Percent growth 1990 2000 Cook 5 De Kalb 14 Du Page 16 Grundy 16 Kane 27 Kankakee 8 Kendall 38 Lake 25 Mc Henry 42 Will 41 Lake, IN 2 Porter, IN 14 Kenosha, WI 17 Factor 6: Meteorology Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Cook 26 37 16 21 De Kalb 27 34 19 21 Du Page 26 37 17 21 Grundy 26 36 17 21 Kane 26 35 18 21 Kankakee 25 38 17 19 Kendall 26 36 17 21 Lake 26   37 17 20 Mc Henry 28 32 19 20 Will 26 37 17 21 6 256 Lake, IN 25 38 17 19 Porter, IN 25 38 18 19 Kenosha, WI 28 35 18 20 Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Illinois has no features that significantly influenced EPA's intended nonattainment areas.

Factor 8: Jurisdictional boundaries The Chicago Area Transportation Study ( CATS) Policy Committee is the Metropolitan Planning Organization ( MPO) for the northeastern Illinois region.  source: CATS web page, http:// www. catsmpo. com/

The Illinois portion of the Chicago ozone nonattainment area consists of the following counties: Cook, Du Page, Kane, Lake, Mc Henry, Will, Aux Sable and Goose Lake Townships in Grundy County, and Oswego Township in Kendall County.

Factor 9: Level of control of emission sources The state provided no information about the level of control of emission sources for this area.

<IP_ADDRESS> Saint Louis Area Discussion:

EPA reviewed the nine factors for the counties within the metropolitan area as well as counties adjacent to the metropolitan area in order to determine the appropriate nonattainment area. There are violating monitors in Madison and St. Clair counties as well as in the City of Saint Louis. EPA agrees with the Illinois EPA to include Madison, Monroe and St. Clair counties in the Illinois portion of the St. Louis nonattainment area.

In the June 2004 letters from EPA to the States 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 extend to the relevant power plant to include it in the nonattainment area. 6 257 Illinois recommended a designation of unclassified for a portion of Randolph County, specifically Baldwin Township, which contains the Baldwin power plant. EPA is designating Baldwin Township in Randolph County nonattainment as part of the Saint Louis nonattainment area. EPA notes that the Baldwin plant has recently reduced its emissions significantly. The Illinois submission did not indicate whether these emission reductions are enforceable or how much potential exists for further emission reductions at this facility such as annual operation of its NOx emission controls. Randolph County adjoins a county that is monitoring a violation of the standard, and the most significant emissions are located in Baldwin Township, the portion of the county closest to the violation. These emissions are located where winds would commonly blow the emissions toward the observed violations. Emissions are moderately high even after the recent reductions. EPA concludes that these emissions are sufficient to contribute to violations in the Saint Louis area.

There are 11 other Illinois counties adjacent to the Metropolitan Area, namely Bond, Calhoun, Fayette, Greene, Macoupin, Marion, Montgomery, Morgan, Pike, Sangamon, and Washington Counties. Emissions for these counties are relatively low and no other factor warranted designating the adjacent counties nonattainment. Therefore, the following data summaries for factors 3 through 9 do not address these counties.

Besides Randolph County, Illinois also recommended a designation of unclassifiable for Jersey County, and recommended attainment for all other counties in the state that are not part of the recommended Saint Louis or Chicago nonattainment areas. EPA is designating as attainment/ unclassifiable all counties that are not part of the Saint Louis or Chicago nonattainment areas.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area County SO2 NOx Carbon Crustal Composite emissions score Clinton 624 3,717 238 1,067 2.0 Jersey 246 1,755 165 544 1.2 Madison 69,938 37,593 1,563 4,425 16.8 Monroe 244 2,489 206 647 1.6 St Clair 4,471 11,813 863 1,996 6.8 Franklin, MO 45,216 15,482 918 2,864 9.1 Jefferson, MO 52,671 13,612 1,160 3,291 10.4 Lincoln, MO 221 2,935 273 1,358 2.1 St Charles, MO 40,596 25,793 896 2,415 10.2 St Louis, MO 30,400 53,358 3,456 2,897 27.4 Warren, MO 324 1,803 205 674 1.5 St Louis ( City), MO 14,647 27,193 1,214 958 11.0 Bond 177 1,883 137 628 1.1 Calhoun 192 1,162 88 170 0.7 Fayette 290 2,795 223 786 1.7 Greene 196 1,409 159 771 1.2 Macoupin 281 3,123 344 1,415 2.5 6 258 Marion 297 3,879 290 891 2.3 Montgomery 38,079 18,254 625 2,230 7.6 Morgan 24,066 6,713 500 1,725 4.7 Pike 6,252 4,850 259 901 2.4 Randolph 23,984 33,023 559 1,863 8.9 Sangamon 16,411 19,811 900 2,742 8.7 Washington 167 2,045 199 814 1.5 Crawford, MO 110 2,199 183 396 1.4 Dent, MO 100 521 121 431 0.8 Gasconade, MO 248 1,727 132 393 1.0 Iron, MO 34,225 1,851 140 291 2.1 Madison, MO 47 727 86 143 0.6 Montgomery, MO 364 1,740 145 719 1.2 Perry, MO 349 2,776 218 531 1.7 Phelps, MO 754 2,990 244 645 1.9 Pike, MO 15,205 10,931 206 773 3.3 St Francois, MO 697 4,204 328 825 2.5 Ste Genevieve, MO 3,666 7,315 255 940 2.7 Washington, MO 152 1,161 137 322 1.0 Urban increment: Total mass= 6.2 µ g/ m3 8% sulfates; 29% nitrates; 58% carbon; 5% crustal. Urban site= 295100085; Rural site= MING1 ( Mingo)

According to information provided in Illinois' submittal of September 1, 2004, the Baldwin Plant in Baldwin Township represents approximately 96% of the SOX emissions and 86% of the NOX emissions for Randolph County. Therefore, designating Baldwin Township as nonattainment will capture the bulk of emissions from Randolph County.

Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 Design Value Madison 17.5 µ g/ m3 St Clair 16.2 µ g/ m3 Jefferson, MO 14.5 µ g/ m3 St Charles, MO 14.3 µ g/ m3 St Louis, MO 14.0 µ g/ m3 St Louis ( City), MO 15.2 µ g/ m3 Randolph 12.4 µ g/ m3 6 259 Sangamon 13.3 µ g/ m3 Ste Genevieve, MO 13.6 µ g/ m3 Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas County 2003 Population Population Density Clinton 35,855 76 Jersey 21,858 59 Madison 261,409 361 Monroe 29,058 75 St Clair 257,904 388 Franklin, MO 95,890 104 Jefferson, MO 203,993 310 Lincoln, MO 42,280 67 St Charles, MO 303,030 540 St Louis, MO 1,018,102 2,004 Warren, MO 26,193 61 St Louis ( City), MO 338,353 5,457 Randolph 33,641 58 Factor 4: Traffic and commuting patterns County County VMT Percent Number Clinton 375,000 35 5,915 Jersey 196,000 51 5,259 Madison 2,768,000 35 43,125 Monroe 264,000 57 8,172 St Clair 2,857,000 36 40,389 Franklin, MO 1,391,000 36 16,422 Jefferson, MO 2,511,000 63 61,991 Lincoln, MO 493,000 52 9,622 St Charles, MO 2,738,000 52 77,347 St Louis, MO 11,553,000 27 134,153 Warren, MO 348,000 54 6,414 St Louis ( City), MO 4,178,000 40 56,734 Randolph 278,000 20 2,798 Factor 5: Expected growth County Percent growth 1990 2000 Clinton 5 Jersey 5 Madison 4 Monroe 23 St Clair  3 Franklin, MO 16 6 260 Jefferson, MO 16 Lincoln, MO 35 St Charles, MO 33 St Louis, MO 2 Warren, MO 26 St Louis ( City), MO  12 Randolph  2 Factor 6: Meteorology Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Clinton 28 29 29 15 Jersey 28 28 29 15 Madison 28 28 29 15 Monroe 28 28 29 15 St Clair 28 28 29 15 Franklin, MO 27 27 31 15 Jefferson, MO 28 27 31 15 Lincoln, MO 27 27 31 15 St Charles, MO 29 27 30 15 St Louis, MO 29 27 30 15 Warren, MO 27 27 31 16 St Louis ( City), MO 29 27 30 15 Randolph 28 28 29 15 Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Illinois has no features that significantly influenced EPA's intended nonattainment areas.

Factor 8: Jurisdictional boundaries The East West Gateway Council of Governments ( EWGCC) is the Metropolitan Planning Organization ( MPO) for the bi state St. Louis area.  source: EWGCC web page, http:// www. ewgateway. org/

The Illinois portion of the Saint Louis ozone nonattainment area consists of the following counties: Jersey, Madison, Monroe, and St. Clair.

Factor 9: Level of control of emission sources The State has provided no information about the level of control of emission sources for this area. Although EPA is aware that the Baldwin Generating Station is purchasing low sulfur coal and has installed NOx emission controls on some of its units, EPA does not 6 261 have information as to the permanence of those reductions and whether the NOx emission controls are operated on an annual basis.

6.5.2 EPA 9 Factor Analyses for Indiana for Designation of PM2.5 Nonattainment Areas The following table identifies the individual areas and counties comprising those areas in Indiana that EPA is designating as nonattainment for the fine particulate matter (" PM2.5") air quality standard. Following this table is 1) discussion of the general issue of the size of nonattainment areas, 2) a description of the data EPA examined, and 3) a discussion of each area and the basis for EPA's designations. EPA is designating as attainment/ unclassifiable all counties or portions of counties not identified in the table below, except that EPA is designating Delaware County in the Muncie area as unclassified because it has insufficient information to justify either a nonattainment or an attainment designation for this area.

Area Indiana Counties in Metropolitan Area Indiana Recommended Nonattainment Counties Counties EPA is Designating Nonattainment Chicago Northwest Indiana Lake Porter Lake Lake Porter Cincinnati Dearborn Ohio None Dearborn: Lawrenceburg Township Elkhart Elkhart Elkhart Elkhart Saint Joseph Evansville Vanderburgh Warrick Posey Vanderburgh Dubois Dubois Vanderburgh Warrick Gibson: Montgomery Township Pike: Washington Township Spencer: Ohio Township Indianapolis Boone Hamilton Hancock Hendricks Johnson Madison Marion Morgan Shelby Marion Hamilton Hendricks Johnson Marion Morgan 6 262 Louisville Clark Floyd Harrison Scott Clark Clark Floyd Jefferson: Madison Township General Issue of Size of Nonattainment Areas Indiana's recommendations for nonattainment areas included only counties that monitored nonattainment and did not include any additional counties that contributed to nonattainment. Indiana's submissions noted several areas where relatively nearby monitors showed differing concentrations, for example Lake County monitoring nonattainment and Porter County monitoring attainment. Indiana deduces from this that the impacts of emissions within an area added to large " background concentrations" arising from long range transport are very localized. Therefore, Indiana concludes, counties lacking a monitored violation may be considered not to contribute to monitored violations in other counties.

EPA's guidance recommends a presumption for nonattainment areas that include entire metropolitan areas, reflecting a presumption that violations in a metropolitan area reflect contributions from the entire area. EPA's guidance recognizes that violations of the PM2.5 standard reflect both regional scale impacts from contributions originating outside the metropolitan area and more local scale impacts. Indeed, the different components of PM2.5 have different ranges of impacts, with some components showing greatest impacts very close to the emissions sources, some components showing peak impacts at a moderate distance from the emissions ( such as from rapid photochemical reactions), and some components showing similar impacts over distance ranges of hundreds of kilometers. Consequently, the existence of neighboring counties with somewhat different concentrations, like Lake County observing design values up to 15.2 µ g/ m3 versus the Porter County site having a design value of 13.8 µ g/ m3, does not signify that emissions in the county with lower concentrations fails to contribute to the higher concentrations in the neighboring county.

Further considerations apply to mobile sources. By definition, these sources can be associated with a residence or business in one county but emit PM2.5 and its precursors in another county. Some of the relevant control measures address the " home" of these vehicles. This consideration supports including counties that are the origin of sizable numbers of vehicles in the nonattainment area.

Indiana has not provided convincing evidence to rebut EPA's general presumption or the underlying view of the typical characteristics of the PM2.5 problem, nor has Indiana demonstrated that the presumption does not apply in any Indiana areas. Therefore, EPA is including the additional counties that it believes contribute to the observed violations in the nonattainment areas it is promulgating. 6 263 <IP_ADDRESS> Chicago Northwest Indiana Area Discussion The following is the nine factor analysis for the Indiana portion of the Chicago Northwest Indiana area including adjacent counties in Indiana. The Chicago Gary Kenosha Metropolitan Area includes 10 counties in Illinois, two in Indiana and one in Wisconsin. Indiana recommended that Lake County, which has a violating monitor, be designated as nonattainment for PM2.5, and that Porter County, which has a monitor showing attainment, be designated as attainment/ unclassified. However, EPA is designating both Lake and Porter Counties as nonattainment.

Lake and Porter Counties both have high composite emissions scores. Although Porter County has a monitor which shows attainment, its emissions contribute to over 9% of the Chicago area composite emissions score largely as a result of significant power plant coal combustion and steel mill emissions as well as some emissions from mobile sources and other sources. The composite emissions scores from the adjacent counties are all modest. La Porte County, adjacent to the metropolitan area, is monitoring attainment of the annual PM2.5 standard and is judged not to contribute to nonattainment in the Chicago Northwest Indiana area.

In addition, Porter has a sizeable population with over 150,000 residents, and over 21,000 workers travel into Lake County on a daily basis, thereby contributing to Lake County monitored PM levels. There is limited commuting from Jasper, La Porte, and Newton Counties into the metropolitan area. Lake County experienced very little growth from 1990 to 2000. During this time, Porter County added nearly 18,000 people. Jasper County growth rate was high, but even with the increase of 5,000 people, its population is still quite small for the area.

EPA considered the emissions, population, and vehicle miles traveled ( VMT) from Newton, Jasper, and La Porte Counties, which are adjacent to Lake and Porter Counties. Based upon the emissions, populations, and VMT, EPA is designating these three counties as attainment/ unclassified.

Other factors EPA reviewed are meteorology, geography, jurisdictional boundaries, and emission controls. The wind data presented below shows no dominant wind direction for Northwest Indiana. There are no geographical features in this area that would effect the distribution of PM2.5. Lake and Porter Counties are both included in the Chicago ozone nonattainment area. La Porte County is in a separate ozone nonattainment area. All three counties make up the area's metropolitan planning organization. The state has not submitted any information on emission controls in Northwest Indiana. 6 264 Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emissions score Lake, IN 50,110 72,142 5,708 7,588 19.5 Porter, IN 21,601 41,315 2,702 5,587 9.2 Cook, IL 61,676 195,428 10,110 8,268 33.0 De Kalb, IL 445 4,885 384 1,875 1.1 Du Page, IL 2,990 29,479 1,731 1,229 4.9 Grundy, IL 6,149 9,589 563 1,235 2.1 Kane, IL 1,395 9,490 1,047 2,326 2.8 Kankakee, IL 551 6,628 490 1,720 1.4 Kendall, IL 292 2,941 265 961 0.7 Lake, IL 14,223 24,488 2,092 1,777 6.7 McHenry, IL 637 5,834 564 1,992 1.6 Will, IL 80,847 37,518 1,447 4,120 11.7 Kenosha, WI 33,122 27,469 770 1,236 5.4 Benton 101 1,326 215 724 0.6 Jasper 34,435 23,020 668 1,838 5.2 La Porte 10,974 19,681 826 1,643 3.3 Newton 89 1,321 160 642 0.4 Pulaski 111 1,187 196 667 0.5 Starke 100 2,852 188 551 0.5 White 188 2,495 292 1,185 0.8 Boone, IL 849 2,188 215 834 0.6 Ford, IL 219 1,462 216 1,280 0.6 Iroquois, IL 458 4,177 452 2,290 1.3 La Salle, IL 2,140 13,984 845 3,352 2.5 Lee, IL 3,978 4,793 345 1,722 1.3 Livingston, IL 503 4,686 485 2,413 1.3 Ogle, IL 672 4,985 335 1,536 1.1 Winnebago, IL 1,100 10,496 656 1,405 1.9 6 265 Racine, WI 2,309 7,252 662 890 1.9 Walworth, WI 866 5,693 470 908 1.3 All emissions are from the 2001 NEI and are in tons. Metropolitan area counties are shown in bold. Speciation profile for Chicago: 25% Sulfates, 8% Nitrates, 65% Carbon, and 2% Crustal derived by comparing data from site number 170310076 in Chicago against data from the Bondville monitor.

Factor 2: Air quality County 2001 03 Design Value Lake, IN 15.2 µ g/ m3 Porter, IN 13.8 µ g/ m3 Cook, IL 17.3 µ g/ m3 Du Page, IL 14.4 µ g/ m3 Kane, IL 14.2 µ g/ m3 Lake, IL 12.8 µ g/ m3 McHenry, IL 12.7 µ g/ m3 Will, IL 14.7 µ g/ m3 Kenosha, WI 11.7 µ g/ m3 La Porte, IN 13.6 µ g/ m3 Metropolitan area counties are shown in bold.

Jasper and Newton Counties do not have monitors.

Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Lake, IN 487,016 980 Porter, IN 150,403 360 Cook, IL 5,377,507 5684 De Kalb, IL 91,561 144 Du Page, IL 924,589 2768 Grundy, IL 38,839 92 6 266 Kane, IL 443,041 850 Kankakee, IL 104,657 154 Kendall, IL 61,222 191 Lake, IL 674,850 1506 Mc Henry, IL 277,710 460 Will, IL 559,861 669 Kenosha, WI 154,433 566 Jasper 30,815 55 La Porte 110,384 185 Metropolitan area counties are shown in bold.

Factor 4: Traffic and commuting patterns County VMT Growth % Change Lake, IN 5,012,000 1,235,000 25 %

Porter, IN 1,680,000 38,000 14 %

Cook, IL 44,107,000 12,254,000 28 %

De Kalb, IL 729,000  176,000  24 %

Du Page, IL 6,609,000 1,971,000 30 %

Grundy, IL 530,000  175,000  33 %

Kane, IL 841,000 309,000 37 %

Kankakee, IL 889,000 281,000 32 %

Kendall, IL 278,000 34,000 12 %

Lake, IL 3,549,000 1,479,000 42 %

Mc Henry, IL 792,000 234,000 29 %

Will, IL 2,136,000 240,000 11 %

Kenosha, WI 1,228,000 318,000 26 %

Jasper, IN 722,000  261,000  36 %

La Porte, IN 1,536,000  343,000  22 %

Metropolitan area counties are shown in bold.

Commuting Information: 6 267 Porter Jasper La Porte Illinois Into Lake County 21,654 2,817 1,783 11,672 From Lake County 5,066 270 1,200 34,263 Jasper La Porte Illinois Into Porter County 988 4,238 524 From Porter County 363 3,390 5,273 Factor 5: Growth County % Population Change Lake 2 %

Porter 14 %

Cook, IL  2 %

De Kalb, IL 5 %

Du Page, IL 1 %

Grundy, IL 2 %

Kane, IL 4 %

Kankakee, IL 7 %

Kendall, IL  8 %

Lake, IL  1 %

Mc Henry, IL 8 %

Will, IL 9 %

Kenosha, WI  1 %

Jasper 20 %

La Porte 3 %

Metropolitan area counties are shown in bold. 6 268 Factor 6: Meteorology Year round average wind direction for:

Lake County, Indiana: 25% NW, 38% SW, 17% SE, 19% NE; Porter County: 25% NW, 38% SW, 18% SE, 19% NE;

Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA's intended nonattainment areas.

Factor 8: Jurisdictional boundaries Lake and Porter Counties are both designated as nonattainment in the Chicago ozone nonattainment area. La Porte County is also designated as ozone nonattainment in its own area.

Northwestern Indiana Regional Planning Commission is the MPO for Lake ( Indiana), La Porte, and Porter Counties.

Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in Northwest Indiana.

<IP_ADDRESS> Cincinnati Area Discussion The Cincinnati Metropolitan Area includes five Ohio counties, six Kentucky counties, and two Indiana counties: Dearborn and Ohio. Indiana did not recommend either of their counties for nonattainment in the Cincinnati area. After considering all nine factors for both counties, EPA is designating Lawrenceburg Township in Dearborn County as nonattainment. All other Dearborn County townships are being designated as attainment/ unclassified.

In the June 2004 letters from EPA to the States 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 extend to the relevant power plant to include it in the nonattainment area. 6 269 Data are provided for full counties only. Dearborn County's main emissions sources including the Tanners Creek power plant are found in Lawrenceburg Township.

Dearborn County has significant emissions yielding a composite emissions score of 11.4. This score ranks third in the three State, 13 county metropolitan area. The wind, with a westerly component 63% of the time, commonly transports Dearborn County emissions east into the rest of the Cincinnati area.

Considering its modest population, a significant number of Dearborn County workers commute into the Ohio and Kentucky portions of the area. This shows that it is an integral part of the area. Dearborn County's Lawrenceburg Township is also included as a partial county in the Cincinnati ozone nonattainment area. The county is in Cincinnati's metropolitan planning organization as well.

Because emissions are relatively low for the counties adjacent to the metropolitan area, and no other factor warranted designating these counties nonattainment, the following data summaries for factors 3 through 9 do not display these counties.

Indiana noted some further emission reductions at the Tanners Creek power plant in Lawrenceburg Township of Dearborn County. However, EPA determined that these reductions reduced the composite emission score only from 11.4 to 10.2. EPA thus continues to believe that Lawrenceburg Township of Dearborn County contributes to violations in the Cincinnati area.

Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emission score Dearborn, IN 56,773 31,138 900 2,121 11.4 Ohio, IN 113 682 49 89 0.5 Boone, KY 14,717 15,794 721 1,068 7.7 Campbell, KY 860 5,294 285 260 2.8 Gallatin, KY 350 2,365 100 234 1.0 Grant, KY 210 2,664 182 191 1.8 Kenton, KY 1,573 8,365 415 301 4.2 Pendleton, KY 597 3,396 139 207 1.5 Brown, OH 395 2,927 208 520 2.0 Butler, OH 13,204 19,735 956 1,752 9.9 Clermont, OH 84,599 45,618 1,693 3,916 20.0 Hamilton, OH 88,053 58,398 2,780 3,873 30.3 6 270 Warren, OH 895 7,565 743 1,063 6.9 Decatur 154 2,525 190 717 1.8 Fayette 150 1,426 156 392 1.4 Franklin 92 1,335 143 341 1.3 Ripley 140 2,081 221 507 2.0 Rush 140 1,274 177 814 1.6 Switzerland 251 1,554 101 145 1.0 Union 58 548 68 272 0.6 All emissions are from the 2001 NEI and are in tons.

Speciation profile for Cincinnati: 7% Sulfates, 15% Nitrates, 78% Carbon, 0% Crustal based on a comparison of data from site number 211170007 against data from the Livonia monitor.

Factor 2: Air quality There are no PM2.5 monitors in the Indiana portion of the Cincinnati area. The design value for the metropolitan area is 17.8 µ g/ m3 from Hamilton County, Ohio. The following are design values for Cincinnati area counties in Ohio and Kentucky with monitors.

County 2001 2003 Design Value Butler, OH 16.2 µ g/ m3 Hamilton, OH 17.8 µ g/ m3 Campbell, KY 14.5 µ g/ m3 Kenton, KY 15.0 µ g/ m3 Preble, OH 13.5 µ g/ m3 Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Dearborn, IN 47,333 155 Ohio, IN 5,804 67 6 271 Boone, KY 93,290 379 Campbell, KY 88,604 583 Gallatin, KY 7,836 79 Grant, KY 23,620 91 Kenton, KY 152,164 934 Pendleton, KY 14,815 53 Brown, OH 43,464 88 Butler, OH 340,543 729 Clermont, OH 183,352 406 Hamilton, OH 833,721 2048 Warren, OH 175,133 438 Factor 4: Traffic and commuting patterns County VMT Growth % Change Dearborn 607,000  55,000  9 %

Ohio 56,000 64,000 114 %

Commuting Information:

Ohio Ripley Hamilton, OH Butler, OH Boone, KY Kenton, KY Into Dearborn 906 1,082 1,335 163 350 244 From Dearborn 311 1,095 7,672 750 1,466 459 Hamilton, OH Boone, KY Switzerland Into Ohio County 87 25 393 From Ohio County 463 135 74 Factor 5: Growth County % Population Change Dearborn 19%

Ohio 6% 6 272 Factor 6: Meteorology Year round average wind direction for Dearborn County, Indiana: 23% NW, 40% SW, 18% SE, 19% NE;

Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA's intended nonattainment areas.

Factor 8: Jurisdictional boundaries Lawrenceburg Township in Dearborn County is designated nonattainment for ozone as part of the Cincinnati ozone nonattainment area. The rest of this county and Ohio County are designated as attainment/ unclassified for ozone.

The Ohio Kentucky Indiana Regional Council of Governments ( OKI) is the Metropolitan Planning Organization ( MPO) for Butler, Warren, Clermont, and Hamilton Counties in Ohio; Campbell, Kenton, and Boone Counties in Kentucky; and Dearborn County, Indiana.

Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in this area.

<IP_ADDRESS> Elkhart Area Discussion The Elkhart, Indiana Metropolitan Area consists solely of Elkhart County, which has a violating monitor. As a result of the violating monitor, Indiana recommended that it be designated as nonattainment. EPA also considered the impact of the surrounding seven counties. These counties in Indiana include Saint Joseph, Kosciusko, Marshall, Noble, Lagrange Counties, which Indiana recommended be designated as attainment for PM2.5 and in Michigan include Saint Joseph and Cass Counties. Of the surrounding counties, EPA is designating Saint Joseph County, Indiana, as nonattainment and the remaining six counties as attainment/ unclassified.

Over half of the composite emissions score for the eight counties is from Elkhart and Saint Joseph ( Ind.) Counties. In fact, Saint Joseph County has the highest emissions score with emissions comparable to Elkhart County. In addition, Saint Joseph County has a large population with Elkhart County's population being slightly less. The vehicle miles traveled ( VMT) was significant in both counties. There are a large number of Elkhart County workers commuting from Saint Joseph County. Although Saint Joseph 6 273 County has a monitor showing attainment, the particulate matter emissions from Saint Joseph County would reasonably be expected to contribute to concentrations in Elkhart County. This is because Saint Joseph County is directly west of Elkhart County and the winds are from the northwest or southwest 64% of the time. Elkhart and Saint Joseph Counties are designated as a single nonattainment for the ozone standard. Also, both counties are in the same metropolitan planning organization, the Michiana Area Council of Government. EPA is designating the remaining six counties as attainment/ unclassified because they have much lower emissions, population, and VMT than Elkhart and Saint Joseph Counties.

Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emission score Elkhart 1,409 12,549 1,828 2,228 100.0 Kosciusko 428 5,387 679 1,682 36.5 Lagrange 809 3,259 326 755 28.8 Marshall 463 3,569 621 1,322 33.6 Noble 390 3,740 457 1,302 26.6 Saint Joseph 2,850 13,690 1,482 1,825 114.1 Cass, MI 325 2,080 263 814 17.1 St Joseph, MI 744 4,212 427 1,775 32.5 Speciation profile for Elkhart: 25% Sulfates, 8% Nitrates, 65% Carbon, and 2% Crustal based on a comparison of data from site 170310076 ( in Chicago) against data from the Bondville monitor. Adequate speciation data were not available from Elkhart.

Factor 2: Air quality County 2001 03 Design Value Elkhart 15.2 µ g/ m3 Saint Joseph 14.3 µ g/ m3 Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Elkhart 186,465 402 Saint Joseph 267,120 585 6 274 Factor 4: Traffic and commuting patterns County VMT Growth % Change Elkhart 2,087,000 615,000 29 %

Saint Joseph 2,304,000 1,037,000 45 %

Commuting Information: 29,756 people commuted into Elkhart County in 2002. 107,500 people lived and worked in Elkhart County in 2002.

Saint Joseph Into Elkhart County 10,850 From Elkhart County 3,722 Factor 5: Growth County % Growth 1990 2000 Elkhart 17 %

Saint Joseph 7 %

Factor 6: Meteorology Year round average wind direction for Elkhart County: 25% NW, 39% SW, 19% SE, 16% NE; Saint Joseph County: 25% NW, 39% SW, 20% SE, 16% NE;

Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA's intended nonattainment areas.

Factor 8: Jurisdictional boundaries Elkhart and Saint Joseph counties are designated as a joint nonattainment area for the ozone air quality standard.

The Michiana Area Council of Government is the MPO for Elkhart and Saint Joseph Counties. 6 275 Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in the Elkhart area.

<IP_ADDRESS> Southwest Indiana ( Evansville Area)

Discussion:

The Evansville Metropolitan Area includes Warrick, Posey, and Vanderburgh Counties in Indiana and Henderson County in Kentucky. Dubois County is not part of a metropolitan area, according to 1999 Office of Management and Budget metropolitan area definitions. EPA also considered numerous other adjacent counties, particularly Gibson, Pike, and Spencer Counties. Both Vanderburgh and Dubois Counties have violating monitors and were recommended by Indiana to be designated as nonattainment for the PM2.5 standard. For the Evansville Area, EPA is designating a nonattainment area that includes Dubois, Vanderburgh, and Warrick Counties as well as portions of Gibson, Pike, and Spencer Counties.

In the June 2004 letters from EPA to the States 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 extend to the relevant power plant to include it in the nonattainment area.

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.

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 freestanding 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, Montgomery Township in Gibson County, Washington Township in Pike County, and Ohio Township in Spencer County are partial county areas included in the Evansville nonattainment area. 6 276 Gibson, Spencer, Pike, and Warrick Counties have the highest emission levels in Southwest Indiana. Emissions of both direct PM2.5 and precursors are high for these counties, resulting in their high composite emission scores. Dubois and Vanderburgh Counties have design values exceeding the PM2.5 standard of 15.0 µ g/ m3, despite their more modest emissions. Spencer County, Indiana, and Daviess County, Kentucky are monitoring below the standard while the rest of the area including the adjacent counties have no monitors.

Vanderburgh County is home to a majority of the Evansville area population. Commuting patterns show a connection between Vanderburgh and Warrick Counties. Population growth was modest for all counties being considered.

Gibson and Pike Counties are located north of Vanderburgh County and west of Dubois County. Spencer and Warrick Counties are east of Vanderburgh County and south of Dubois County. The meteorological data presented under Factor 6 indicates no prevailing wind direction. The location of the area counties and the varied wind directions mean that Vanderburgh County or Dubois County will commonly be downwind from at least some of the high emissions sources in these counties.

EPA believes that the high emissions in several counties in the area contribute to the violations recorded in Vanderburgh and Dubois Counties. Gibson, Pike, Spencer, and Warrick Counties all contain power plants with significant emissions that contribute to the violations in Dubois and Vanderburgh Counties. The townships identified above include these power plants.

Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emission score Posey 18,715 14,866 595 1,308 19.5 Vanderburgh 1,421 9,538 1,550 1,337 17.5 Warrick 102,206 28,647 1,655 4,940 52.3 Henderson, KY 6,308 8,075 418 971 10.7 Crawford 536 3,842 161 137 4.3 Daviess 328 1,542 179 621 24.2 Dubois 1,694 5,665 1,037 995 11.3 Gibson 148,808 46,937 1,767 6,093 76.3 Martin 110 797 193 252 1.9 Perry 789 3,102 195 257 4.0 Pike 63,626 28,567 745 2,209 39.4 6 277 Spencer 57,983 38,521 1,107 3,124 49.5 Webster, KY 19,201 15,934 551 2,035 20.8 All emissions are from the 2001 NEI and are in tons. Metropolitan area counties are shown in bold.

Speciation profile for Southwest Indiana: 20% Sulfates, 51% Nitrates, 23% Carbon, and 6% Crustal based on a comparison of data from site number 210590014 ( in Owensboro) against data from the Mammoth Cave monitor.

The Indiana Power and Light Company Petersburg facility and the Hoosier Energy Ratts Station together represent approximately 99% of the SO2, 96% of the NOX, 83% of the carbonaceous particles and 88% of the crustal emissions for Pike County. Designating Washington Township as nonattainment captures these emissions and therefore the bulk of the emissions for Pike County. The Indiana Michigan Power Rockport facility and AK Steel Rockport Works together represent approximately 99% of the SO2, 91% of the NOX, 77% of the carbonaceous particles and 81% of the crustal emissions for Spencer County. Designating Ohio Township as nonattainment will capture the bulk of the emissions for Spencer County. The PSI Gibson facility represents approximately 99% of the Gibson County NOx and SO2 emissions. Montgomery Township is in the Evansville nonattainment area because it captures most of the Gibson County emissions.

Factor 2: Air quality County 2001 03 Design Value Vanderburgh 15.5 µ g/ m3 Henderson, KY 14.0 µ g/ m3 Dubois 16.2 µ g/ m3 Spencer 14.4 µ g/ m3 Daviess, KY 14.9 µ g/ m3 There are no monitors in Gibson, Pike, Posey, or Warrick Counties.

Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Posey 26,990 66 Vanderburgh 171,744 731 Warrick 53,624 140 6 278 Henderson, KY 44,995 102 Dubois 40,015 93 Gibson 32,590 67 Pike 12,908 38 Spencer 20,353 51 Metropolitan area counties are shown in bold.

Factor 4: Traffic and commuting patterns County VMT Growth % Change Posey 508,000  63,000  12 %

Vanderburgh 1,732,000 552,000 32 %

Warrick 828,000  166,000  20 %

Henderson, KY 510,000 271,000 53 %

Dubois 479,000 39,000 8 %

Gibson 429,000 70,000 17 %

Pike 178,000 104,000 58 %

Spencer 392,000 47,000 12 %

Metropolitan area counties are shown in bold.

Commuting Information: 29,553 people commuted into Vanderburgh County in 2002. 104,660 people lived and worked in Vanderburgh County in 2002.

Warrick Posey Gibson Spencer Pike Dubois Into Vanderburgh 14,522 5,484 3,509 1,056 393 178 From Vanderburgh 1,891 1,355 1,696 103 39 84 8,101 people commuted into Dubois County in 2002. 26,873 people lived and worked in Dubois County in 2002.

Spencer Pike Gibson Warrick Into Dubois 1,494 1,653 236 293 From Dubois 393 124 173 48 6 279 Factor 5: Growth County % Growth 1990 2000 Posey 4 %

Vanderburgh 4 %

Warrick 17 %

Henderson, KY 4 %

Dubois 8 %

Gibson 2 %

Pike 3 %

Spencer 5 %

Metropolitan area counties are shown in bold.

Factor 6: Meteorology Year round average wind direction for Vanderburgh County: 30% NW, 30% SW, 21% SE, 19% NE; Dubois County: 27% NW, 30% SW, 22% SE, 20% NE;

Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA's intended nonattainment areas.

Factor 8: Jurisdictional boundaries Vanderburgh and Warrick Counties are designated as nonattainment for the ozone NAAQS. All other area counties are designated as attainment/ unclassified.

The MPO for the Evansville area, the Evansville Urban Transportation Study, covers Vanderburgh, Gibson, Posey, and Warrick Counties.

Factor 9: Level of control of emission sources The Indiana Michigan Power Rockport facility in Spencer County has installed low NOX burners and over fire air to reduce NOX and SO2 emissions. Facility emissions information for the years 1999 2003 show an approximate reduction in NOX and SO2 6 280 emissions of 10% and 15 %, respectively. For the years 2001 2003 the reductions are approximately 3% and 1% for NOX and SO2, respectively.

<IP_ADDRESS> Indianapolis Area Discussion The Indianapolis Metropolitan Area includes nine Indiana counties: Boone, Hamilton, Hancock, Hendricks, Johnson, Madison, Marion, Morgan, and Shelby. Indiana recommended designating Marion County as nonattainment of the PM2.5 standard.

The monitors in Marion County are showing a violation of the standard. Madison County's monitor indicates concentrations below the annual PM2.5 standard of 15.0 µ g/ m3. No other area counties have monitored air quality data. The Indianapolis area has one central county, Marion County, ringed by the other eight counties. The eight outlying counties are all a similar distance from the central county with no intermediate counties. This configuration allows the EPA to consider a combination of emissions and wind data to estimate each county's potential contributions to violation of the annual PM2.5 standard in Marion County. A description of the methods for assessing this information is given along with the Indianapolis area emissions data below. EPA believes that this approach provides a fine tuned comparison of the potential of each of the counties surrounding Marion County to contribute to the violations recorded in Marion County.

Marion County contributes about 50 percent of the emissions of the metropolitan area on a composite emissions basis. Consistent with its intended designations elsewhere, EPA believes that this indicates that more than just Marion County contributes to the violations, and that the planning area for evaluating strategies must include a greater fraction of emissions in the area.

The wind weighted emissions information suggests that Hamilton, Hendricks, Johnson, Madison, Morgan and Shelby Counties have significant potential to contribute to violations in Marion County. Conversely, this information suggests that Boone and Hancock have somewhat limited potential to contribute to violations in Marion County.

EPA further examined the proximity of the emissions in the surrounding to the violations in Marion County and commuting and growth information. None of the Indianapolis urbanized area as defined by the U. S. Census Bureau is in Madison or Shelby Counties. As a result, Madison and Shelby Counties have less growth and less commuting into Marion County than other counties that are more integrally part of the Indianapolis area. Much of the population and emissions in Madison and Shelby Counties are in Anderson and Shelbyville, respectively. Thus, these emissions are at a greater distance from the violations in Marion County than the other counties, for which population and emissions tend to be concentrated at the edge of Marion County.

Indiana stated that significant emission reductions have occurred in Hamilton County due to conversion of the Noblesville power plant to natural gas. However, EPA finds that 6 281 even were this plant's emissions to be eliminated, the remaining emissions in Hamilton County would still be sufficient to be considered to be contributing to violations in Marion County.

For these reasons, EPA believes that Hamilton, Hendricks, Johnson, Marion, and Morgan Counties contribute to the violations in Marion County. This is why EPA is designating them as nonattainment. EPA believes that Boone, Hancock, Madison, and Shelby Counties do not contribute and were designated attainment/ unclassified. EPA also concluded that none of the numerous counties that are outside but adjacent to the Indianapolis Metropolitan Area should be considered to contribute to the violations in Marion County.

Factor 1: Emissions Given the unique geography of the Indianapolis area, EPA calculated a wind weighted emissions score as well as a composite emissions score for the Indianapolis area. The wind data used in calculating the wind weighted score reflect the frequency of winds in the Indianapolis area from each of 16 directions. This data is provided under factor 6 below.

The wind weighted score is calculated as follows: for each of the eight counties surrounding Marion County, EPA identified the direction for which the winds would blow most directly over Marion County, and tabulated the sum of the frequency of winds for that direction and the two adjacent directions among the set of 16 directions. This frequency of being upwind was multiplied times the composite score to obtain a preliminary wind weighted composite emissions score. These eight preliminary scores added up to 8.7. For Marion County, EPA retained the unweighted composite emissions score of 50.6. EPA then normalized the scores of the surrounding scores to add up to 49.4. Each county score was multiplied by 49.4/ 8.7, yielding the wind weighted emissions score. The total of the wind weighted emissions scores for all 9 counties is 100.

The EPA derived wind weighted emissions scores reflect the variability of frequency of winds from different directions. This process seeks to assess more precisely the relative potential impacts of the counties in the Indianapolis area. The following table has the SO2, NOx, carbon, and crustal emissions, the composite emissions scores, along with the wind weighted emissions scores for the nine counties in the Indianapolis area. Emissions data and composite emissions scores are also provided for counties adjacent to the Indianapolis Metropolitan Area. All emissions are from the 2001 NEI and are in tons.

County SO2 NOx Carbon Crustal Composite emissions score Wind weighted emissions score Boone 224 3,468 297 988 3.1 3.1 Hamilton 5,215 9,251 730 1,635 8.0 6.2 6 282 Hancock 338 3,936 395 1,022 3.8 2.8 Hendricks 773 5,802 593 1,596 5.7 6.8 Johnson 338 5,165 416 918 4.4 5.0 Madison 934 8,106 884 1,548 8.3 6.0 Marion 49,549 52,848 4,891 4,429 50.6 50.6 Morgan 17,343 8,303 554 1,362 7.0 11.3 Shelby 329 6,212 1,141 1,277 9.1 8.2 Bartholomew 520 5,309 659 1,382 5.9   Brown 46 828 132 131 1.1   Clay 243 2,057 209 641 2.0   Clinton 411 2,614 246 1,061 2.5   Decatur 154 2,525 190 717 2.1   Delaware 1,548 6,353 593 1,019 5.9   Fayette 150 1,426 156 392 1.5   Fountain 167 2,109 395 1,311 3.1   Grant 1,280 5,341 381 1,135 4.3   Henry 291 3,919 707 1,243 5.7   Jackson 260 3,427 341 533 3.3   Jefferson 39,599 33,990 549 1,368 11.2   Jennings 233 1,589 208 408 1.8   Monroe 2,168 4,852 545 647 5.1   Montgomery 1,072 4,099 691 1,213 5.7   Owen 100 1,052 118 273 1.1   Parke 125 3,140 389 571 3.5   Putnam 2,643 6,116 230 548 3.7   Randolf 494 2,731 232 968 2.4   Ripley 140 2,081 221 507 2.1   Rush 140 1,274 177 814 1.5   Scott 100 1,515 151 236 1.5   Tippecanoe 11,434 9,922 1,632 2,345 13.8   6 283 Tipton 81 1,040 158 730 1.3   Wayne 13,919 5,951 589 1,498 6.2   Speciation profile for Indianapolis: 3% Sulfates, 38% Nitrates, 59% Carbon, and 0% Crustal based on a comparison of data from site 180970078 against data from the Livonia monitor.

Factor 2: Air quality County 2001 03 Design Value Madison 14.6 µ g/ m3 Marion 16.7 µ g/ m3 There are no monitors in Boone, Hamilton, Hancock, Hendricks, Johnson, Morgan, and Shelby Counties.

Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Boone 48,277 114 Hamilton 205,610 517 Hancock 58,343 191 Hendricks 114,301 280 Johnson 121,604 380 Madison 132,068 292 Marion 863,429 2,180 Morgan 67,791 167 Shelby 43,674 106 Factor 4: Traffic and commuting patterns County VMT Growth % Change Boone 752,000  160,000  21 %

Hamilton 1,807,000  81,000  5 % 6 284 Hancock 732,000  2,000 0 %

Hendricks 1,240,000 6,000 0 %

Johnson 1,368,000  8,000  1 %

Madison 1,601,000 457,000 29 %

Marion 9,983,000 3,260,000 33 %

Morgan 913,000 17,000 2 %

Shelby 641,000  30,000  5 %

Commuting Information: 189,804 people commuted into Marion County in 2002. 489,449 people lived and worked in Marion County in 2002.

Into Marion From Marion Boone 9,905 990 Hamilton 46,440 10,958 Hancock 15,700 1,487 Hendricks 33,009 4,602 Johnson 29,458 4,917 Madison 6,603 755 Morgan 15,749 807 Shelby 5,664 663 Factor 5: Growth County % Growth 1990 2000 Boone 21 %

Hamilton 68 %

Hancock 22 %

Hendricks 37 %

Johnson 31 %

Madison 2 %

Marion 8 %

Morgan 19 % 6 285 Shelby 8 %

Factor 6: Meteorology Indianapolis Airport wind data for 1984 to 1992 ( 9 year average, all seasons):

N 5.07 %

NNE 4.11 %

NE 4.35 %

ENE 4.31 %

E 3.76 %

ESE 4.96 %

SE 5.95 %

SSE 4.94 %

S 7.22 %

SSW 7.76 %

SW 11.38 %

WSW 9.20 %

W 5.82 %

WNW 6.13 %

NW 6.27 %

NNW 5.43 %

Calm 3.34 %

Wind directions for each county used in computing wind weighted emissions scores:

County Wind Directions Boone NNW NW WNW Hamilton N NNE NE Hancock ENE E ESE Hendricks WSW W WNW Johnson SSE S SSW Madison NNE NE ENE 6 286 Morgan SSW SW WSW Shelby ESE SE SSE Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA's intended nonattainment areas.

Factor 8: Jurisdictional boundaries Boone, Hamilton, Hancock, Hendricks, Johnson, Madison, Marion, Morgan, and Shelby Counties are all designated as nonattainment for the ozone air quality standard.

The Indianapolis Metropolitan Planning Organization ( MPO) serves Boone, Hamilton, Hancock, Hendricks, Johnson, Marion, Morgan, and Shelby Counties.

Factor 9: Level of control of emission sources The PSI Energy Noblesville power plant in Hamilton County was converted from burning coal to natural gas in 2003. This conversion significantly reduced NOX and SO2 emissions at this facility. However, when EPA recalculated composite emission scores assuming the complete elimination of emissions from this facility, the composite emission score declined only from 8.0 to 7.2.

<IP_ADDRESS> Louisville Area Discussion The Louisville Metropolitan Area includes three Kentucky counties and Clark, Floyd, Harrison, and Scott Counties in Indiana. Several counties adjacent to the metropolitan area were evaluated, especially Jefferson County, Indiana. Indiana recommended designating Clark County as nonattainment of the PM2.5 standard. EPA is designating Clark and Floyd Counties and Madison Township in Jefferson County as non attainment.

In the June 2004 letters from EPA to the States 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 extend to the relevant power plant to include it in the nonattainment area. 6 287 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.

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 freestanding 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, Madison Township in Jefferson County is a partial county area included in the Louisville nonattainment area.

The monitor in Clark County is showing a violation of the standard. Floyd County's monitor is just below the annual PM2.5 standard of 15 µ g/ m3. The emissions from both Floyd and Clark Counties are significant, with Floyd County's emissions being greater. Jefferson County, Indiana also has a substantial level of emissions, the bulk of which is captured by designating Madison Township as nonattainment. There are relatively low emissions from Harrison and Scott Counties.

The population in Clark and Floyd Counties dominates the Indiana population in the area. All metropolitan area counties had a similar growth rate. There is significant commuting between Clark and Floyd Counties and from both counties into the Kentucky portion of the Louisville area. Commuting from Harrison and Scott Counties to the rest of the metropolitan area is modest. There is very limited commuting from Jefferson County, Indiana.

Meteorological data shows the wind is from the northeast about 21% of the time. Jefferson County, Indiana is located northeast of Clark and Floyd Counties. EPA believes that winds blow sufficiently frequent from the northeast and emissions from Jefferson County, Indiana, are sufficient that Jefferson County should be considered to contribute to violations in Louisville. Clark and Floyd Counties are included in the Louisville area ozone designations and with its metropolitan planning organization. The state did not provided any information on emission controls in the Indiana portion of the Louisville area.

Jefferson County is adjacent to the Louisville Metropolitan Area and contains a power plant with significant emissions that contribute to the violations in the Louisville Metropolitan Area. These emissions are captured by designating Madison Township as nonattainment. 6 288 Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emissions score Clark 484 4,960 725 773 12.2 Floyd 47,796 10,282 954 2,301 16.4 Harrison 419 3,677 305 466 5.3 Scott 100 1,515 151 236 2.6 Bullitt, KY 343 3,463 433 379 7.3 Jefferson, KY 62,526 81,398 2,817 3,816 51.5 Oldham, KY 529 3,707 271 475 4.7 Crawford 536 3,842 161 137 2.9 Jefferson 39,599 33,990 549 1,368 11.2 Jennings 233 1,589 208 408 3.5 Lawrence 4,330 5,707 376 909 6.5 Orange 86 2,017 171 286 2.9 Perry 789 3,102 195 257 3.4 Washington 136 1,452 380 119 3.1 Anderson, KY 443 1,535 144 180 2.5 Breckinridge, KY 321 2,592 260 288 4.4 Carroll, KY 53,086 26,269 821 2,177 15.2 Franklin, KY 601 3,059 217 273 3.8 Grayson, KY 412 1,532 235 341 4 Green, KY 104 507 103 151 1.7 Hardin, KY 1,774 7,695 524 644 2.1 Hart, KY 162 1,839 188 193 3.2 Henry, KY 156 1,465 125 288 1.8 Larue, KY 186 768 108 180 4.0 Marion, KY 143 801 147 225 2.5 Meade, KY 661 4,551 227 439 5.0 Nelson, KY 497 2,134 296 463 4.0 6 289 Owen, KY 57 572 126 105 2.1 Shelby, KY 397 2,906 231 446 1.7 Spencer, KY 31 393 102 174 4.6 Taylor, KY 632 3,642 172 221 3.1 Trimble, KY 7,998 8,458 249 506 2.9 Washington, KY 115 618 110 157 1.8 All emissions are from the 2001 NEI and are in tons. Metropolitan area counties are in bold.

Speciation profile for Louisville: 0% Sulfates, 7% Nitrates, 93% Carbon, and 0% Crustal based on a comparison of data from site number 211110043 ( in Louisville) against data from the Livonia monitor.

The Clifty Creek Station in Madison Township represents approximately 99% of the SO2, 92% of the NOX, 62% of the carbonaceous particles and 76% of the crustal emissions for Jefferson County. Therefore, designating Madison Township as nonattainment will capture the bulk of Jefferson County's emissions.

Factor 2: Air quality 6 290 County 2001 03 Design Value Clark 16.2 µ g/ m3 Floyd 14.9 µ g/ m3 Bullitt, KY 15.0 µ g/ m3 Jefferson, KY 16.9 µ g/ m3 There are no monitors in Harrison, Scott, and Jefferson Counties in Indiana.

Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Clark 98,198 262 Floyd 71,633 484 Harrison 35,244 73 Scott 23,334 123 Bullitt 63,800 213 Jefferson 698,080 1813 Oldham 49,310 261 Jefferson 32,113 89 Factor 4: Traffic and commuting patterns County VMT Growth % Change Clark 1,262,000 144,000 11 %

Floyd 843,000 292,000 35 %

Harrison 528,000 79,000 15 %

Scott 364,000  89,000  25 %

Bullitt, KY 849,000  178,000  21 %

Jefferson, KY 7,149,000 4,398,000 62 %

Oldham, KY 507,000 2,000 0 %

Jefferson 331,000 26,000 8 %

Commuting Information: 6 291 Floyd Harrison Scott Jefferson, IN Kentucky Into Clark County 5,224 1,376 866 198 780 From Clark County 4,591 530 316 775 16,582 Harrison Scott Jefferson, IN Kentucky Into Floyd County 2,073 223 39 466 From Floyd County 921 66 492 12,647 Factor 5: Growth County % Growth 1990 2000 Clark, IN 10%

Floyd, IN 10%

Harrison, IN 15%

Scott, IN 9%

Bullitt, KY 29%

Jefferson, KY 4%

Oldham, KY 39%

Jefferson, IN 6%

Factor 6: Meteorology Year round average wind direction for Clark County, Indiana: 22% NW, 33% SW, 24% SE, 21% NE; Floyd County, Indiana: 22% NW, 32% SW, 25% SE, 21% NE;

Factor 7: Geography/ topography The geography/ topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The States of Indiana and Kentucky have no features that significantly influenced EPA's intended nonattainment areas. 6 292 Factor 8: Jurisdictional boundaries Clark and Floyd Counties are designated as nonattainment in the Louisville ozone nonattainment area. Harrison, Scott, and Jefferson Counties in Indiana are designated as attainment/ unclassified.

The Kentuckiana Regional Planning and Development Agency serves as the Metropolitan Planning Organization ( MPO) for Clark and Floyd Counties in Indiana.

Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in this area.

<IP_ADDRESS> Muncie Area Discussion The Muncie area consists of Delaware County, Indiana. EPA is designating Delaware County as unclassifiable for the PM2.5 standard. This represents a modification of the State's recommendation that this county be designated attainment/ unclassifiable.

Data must be collected for at least 75% of the scheduled days in a calendar quarter to meet the completeness criteria for showing attainment.

Muncie has a single PM2.5 monitor that is scheduled to sample on every third day. In the first quarters of 2001 and 2003, this monitor recorded less than 75 percent of the scheduled values but more than 11 samples. EPA policy states that this quantity of data is insufficient to label an area as attainment, insofar as the data are considered complete. On the other hand, EPA policy states that this quantity of data is sufficient to label an area nonattainment, with the data being considered complete in this case. The following are the 3 year average values recorded at this site.

County 2000 02 Design Value 2001 03 Design Value Delaware 15.1 µ g/ m3 14.3 µ g/ m3 The annual PM2.5 standard is 15.0 µ g/ m3.

Under EPA policy, the data for 2000 to 2002 are considered complete, and the data for 2001 to 2003 are considered incomplete. On the other hand, the most recent data suggest that the area is attaining the standard. Therefore, EPA concludes that it cannot currently judge the most appropriate designation for this area. EPA intends to promulgate either a nonattainment or an attainment/ unclassifiable designation for this area once further data are available. EPA will consult further with the State once the necessary data become available. 6 293 6.5.3 EPA 9 Factor Analyses for Michigan for Designation of PM2.5 Nonattainment Areas The following table identifies the individual areas and counties comprising those areas in Michigan that EPA is designating as nonattainment for the fine particulate matter (" PM2.5") air quality standard. EPA is designating as attainment/ unclassifiable all other Michigan counties not identified in the table below.

Area Michigan Counties in Metropolitan Area Michigan Recommended Nonattainment Counties Counties EPA is Designating Nonattainment Detroit Ann Arbor Flint Monroe Wayne Livingston Macomb Oakland St Clair Washtenaw Genesee Lapeer Lenawee Monroe Wayne Monroe Wayne Livingston Macomb Oakland St Clair Washtenaw <IP_ADDRESS> Detroit Ann Arbor Flint Area Discussion:

EPA reviewed the nine factors for the counties within the metropolitan area as well as counties adjacent to the metropolitan area in order to determine the appropriate nonattainment area. There are violating monitors in Monroe and Wayne counties. EPA agrees with the Michigan DEQ to designate Monroe and Wayne counties as nonattainment. However, based upon our nine factor analysis, EPA believes that in addition to Monroe and Wayne counties, the Detroit nonattainment area should also include Livingston, Macomb, Oakland, St. Clair, and Washtenaw counties as one contiguous area. These counties have significant emissions and the population, population density, and vehicle miles traveled ( VMT) are at sufficient levels to be part of the designated area. This is consistent with the national approach of capturing the majority of emissions and population in a metropolitan area. Genesee, Lapeer, and Lenawee counties are also in the Metropolitan area but were excluded upon review of the 9 factors. Except for Genesee County, which is discussed below, these counties have lower emissions, population, population density, and VMT.

Michigan supported its recommendation of attainment for most counties by attributing the violations in Wayne County predominantly to high emissions in Wayne County, and attributing the violation in Monroe County to emissions in Toledo, Ohio. Michigan notes the monitored attainment in Macomb County, and observes that trajectories for high and low concentration days in Wayne County indicate that the highest concentrations occur when winds are from the south and west. Michigan concludes from this evidence that the 6 294 Wayne County violations arise from a combination of long range transport and very localized emissions, and that counties other than Wayne County do not contribute to violations in Wayne County.

EPA disagrees with Michigan's analysis. EPA's guidance includes a presumption that the entire metropolitan area contributes to the nonattainment problem, reflecting evidence that the various types of emissions that lead to PM2.5 concentrations have impacts on many distance scales including metropolitan scale. Michigan has not provided a convincing demonstration that EPA's presumption and the underlying understanding of the nature of PM2.5 is invalid or inapplicable to the Detroit area. The design value in Macomb County is 15.0 micrograms per cubic meter, just barely attaining the standard. While it is evident that Macomb County does not by itself cause violations in Wayne County, the wind data shown for factor 6 below demonstrate that winds often blow from Macomb County into Wayne County. While the wind blows from the southwest quadrant more frequently than other quadrants, the wind blows from the northwest or northeast quadrants about 40 percent of the time. Trajectory information can often be misleading; since a high fraction of observed PM2.5 concentrations are attributable to long range transport, trajectories for high concentration days tend to be a better measure of whether distant contributions to transported " background" concentrations are high rather than indicating high local contributions. Michigan's analysis also does not address the contributions to Wayne County concentrations from mobile sources that originate in other counties. Although different components of PM2.5 have different geographic scales of impact, EPA continues to believe that emissions throughout a metropolitan area can contribute significantly to observed violations. Since a significant fraction of the Detroit area's emissions occur in Livingston, Macomb, Oakland, St. Clair, and Washtenaw Counties, EPA believes that these contribute to nonattainment in Wayne and Monroe Counties.

The composite emissions score for Genesee County is somewhat higher than that of Washtenaw County. EPA nevertheless believes that Washtenaw County contributes to violations in Wayne and Monroe Counties and Genesee County does not. Washtenaw County is upwind of Wayne and Monroe Counties somewhat more frequently than Genesee County. More importantly, Washtenaw County is closer to Wayne and Monroe Counties and the observed violations, which means that the emissions are likely to have a greater impact and mobile sources are more likely to be traveling into the violating counties. Finally, Washtenaw County is part of the Detroit ozone nonattainment area whereas Genesee County is part of a separate ozone nonattainment area, and the Detroit area metropolitan planning organization includes Washtenaw County and not Genesee County. Therefore, including Washtenaw County in the PM2.5 nonattainment area will facilitate coordinated ozone and PM2.5 planning.

Michigan requested that Wayne and Monroe Counties each be treated as single county nonattainment areas. Michigan has not justified a conclusion that either of these counties may be considered single county nonattainment areas. While Monroe County may sometimes be considered part of the Toledo area ( along with Lucas and Wood Counties, Ohio), particularly when winds are from the south, on such occasions Monroe County 6 295 also contributes to violations in Wayne County. The Detroit area also contributes to violations in Monroe County. Therefore, EPA intends to designate a single Detroit area nonattainment area that includes Monroe County.

There are seven counties adjacent to the metropolitan area that are not a part of another violating metropolitan area. These counties have relatively low emissions, and no other factors warrant including these counties in the nonattainment area. Therefore, no data are provided for these counties under factors 3 to 9 below.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emissions score Genesee 3,010 20,648 1,377 1,914 7.5 Lapeer 895 5,202 389 1,109 2.1 Lenawee 642 4,496 554 1,488 2.5 Livingston 701 8,024 852 1,695 4.0 Macomb 4,602 33,482 1,413 1,282 9.5 Monroe 126,037 62,432 1,565 4,834 15.1 Oakland 8,277 44,171 2,264 1,829 13.6 St. Clair 72,450 40,659 1,248 2,687 10.4 Washtenaw 2,163 14,980 944 1,502 5.3 Wayne 59,884 107,604 4,435 2,823 29.9 Hillsdale 1,286 3,270 245 812 1.4 Ingham 13,381 17,912 648 1,126 4.9 Jackson 1,093 7,895 599 1,269 3.2 Saginaw 2,812 9,755 978 2,457 4.8 Sanilac 397 2,893 422 1,429 1.9 Shiawassee 768 3,749 318 1,024 1.7 Tuscola 531 3,162 417 1,404 1.9 Fulton, OH 878 5,105 336 692 1.9 Lucas, OH 31,000 36,975 1,370 1,702 10.0 Urban increment: Total mass= 4.3 µ g/ m3 0% sulfates; 54% nitrates; 42% carbon; 4% crustal. Urban site= 261630001; Rural site= MKGO1 ( M. K. Goddard)

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

County 2001 2003 Design Value Genesee 12.6 Macomb 13.3 Monroe 15.1 Oakland 14.8 6 296 St. Clair 13.9 Washtenaw 14.6 Wayne 19.5 Ingham 13.4 Saginaw 11.0 Lucas, OH 15.2 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2003 Population Population Density Genesee 441,423 690 Lapeer 90,776 139 Lenawee 100,145 133 Livingston 168,862 297 Macomb 808,529 1684 Monroe 149,253 271 Oakland 1,202,721 1378 St. Clair 167,712 231 Washtenaw 334,351 471 Wayne 2,045,540 3331 Factor 4. Traffic and commuting patterns:

County County VMT ( Thousands) Percent Number Genesee 4,842 18 33,966 Lapeer 1,139 50 20,118 Lenawee 908 22 10,026 Livingston 1,804 54 42,858 Macomb 6,964 41 156,343 Monroe 1,679 28 19,372 Oakland 10,758 28 167,943 St. Clair 2,029 35 26,992 Washtenaw 3,521 21 35,525 Wayne 20,171 24 201,563 Factor 5. Expected growth:

County Percent growth 1990 2000 Genesee 1 Lapeer 18 Lenawee 8 Livingston 36 Macomb 10 Monroe 9 Oakland 10 St Clair 13 Washtenaw 14 Wayne  2 6 297 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Genesee 24 42 18 16 Lapeer 25 40 18 17 Lenawee 25 40 16 19 Livingston 26 40 18 17 Macomb 26 39 18 18 Monroe 25 40 16 19 Oakland 25 39 18 18 St. Clair 25 39 18 18 Washtenaw 26 39 17 19 Wayne 26 38 17 19 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in land elevation, etc.) that affect this area. The state provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Southeast Michigan Council of Governments ( SEMCOG ) is the Metropolitan Planning Organization ( MPO) for Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and Wayne counties.  source: SEMCOG web page, http:// www. semcog. org/

This metropolitan area is divided into two ozone nonattainment areas. The Detroit area includes the following counties: Lenawee, Livingston, Macomb, Monroe, Oakland, St Clair, Washtenaw, and Wayne. The Flint area includes the following counties: Genesee and Lapeer.

Factor 9. Level of control of emission sources:

The state provided no information about the level of control of emission sources for this area.

6.5.4 EPA 9 Factor Analyses for Ohio for Designation of Nonattainment Areas for PM2.5 The following table identifies the individual areas and counties comprising those areas in Ohio that EPA is designating as nonattainment. Ohio provided two options of recommendations: Option 1 only includes counties monitoring nonattainment, and Option 2 includes the Option 1 counties plus additional counties recommended as contributing to nonattainment. EPA finds the Option 2 recommendations generally to reflect a proper review of nonattainment areas in accordance with EPA guidance, and so this table 6 298 compares EPA's recommendations to Ohio's Option 2 recommendations. Following this table is a description of the data EPA examined and a discussion of each area and the basis for EPA's designations. EPA is designating as attainment/ unclassifiable all counties not identified in the table below.

Area Ohio Counties in Metropolitan Area Ohio Recommended Nonattainment Counties ( Option 2) Counties EPA is Designating Nonattainment Canton Massillon, OH Stark Carroll Stark Stark Cincinnati Hamilton, OH KY IN Butler Clermont Hamilton Warren Brown Butler Clermont Hamilton Warren Butler Clermont Hamilton Warren Cleveland Akron Lorain, OH Cuyahoga Lake Lorain Medina Portage Summit Ashtabula Geauga Cuyahoga Lake Lorain Medina Portage Summit Cuyahoga Lake Lorain Medina Portage Summit Ashtabula Ashtabula Township Columbus, OH Delaware Fairfield Franklin Licking Madison Pickaway Delaware Fairfield Franklin Licking Delaware Fairfield Franklin Licking Coshocton Franklin Township Dayton Springfield, OH Clark Greene Montgomery Miami Clark Greene Montgomery Clark Greene Montgomery Huntington Ashland, WV KY OH Lawrence Lawrence Scioto Lawrence Scioto Adams Monroe Township Sprigg Township Gallia Cheshire Township Parkersburg Marietta, WV OH Washington Washington Steubenville Weirton, OH WV Jefferson Jefferson Jefferson Toledo, OH Lucas Wood Fulton Lucas Wood Lucas Wood 6 299 Wheeling, WV OH Belmont Belmont Youngstown Warren, OH Columbiana Mahoning Trumbull Columbiana Mahoning Trumbull Columbiana Mahoning Trumbull <IP_ADDRESS> Canton Massillon, OH Discussion: There are two counties in this metropolitan area, Stark County and Carroll County. EPA agrees with the Ohio EPA that the Canton Massillon area should include only Stark County. The majority of the emissions and population are located in Stark County, which contains a monitor that is violating the standard. Stark County also represents the ozone nonattainment area for the Canton Massillon Metropolitan Area. There are four counties that are adjacent to the metropolitan area, Harrison, Holmes, Tuscarawas and Wayne Counties that are not part of other metropolitan areas. Of these counties, only Wayne County required further review due to the population and emissions in the county. Wayne County is adjacent to both the Cleveland and Canton Metropolitan areas. It does not appear appropriate to associate this county with the Canton Massillon Metropolitan Area. There is limited commuting from Wayne County to the Canton Massillon Metropolitan Area and there does not appear to be additional interaction that would indicate a need to include Wayne County in the nonattainment area. In addition, Wayne County has relatively low emissions when compared to emissions in the Cleveland Metropolitan Area.

Because emissions are relatively low for Harrison, Holmes, and Tuscarawas Counties, and no other factor warranted designating these counties nonattainment, the following data summaries for factors 3 through 9 do not address these counties.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emission score Carroll 386 1,886 120 234 10.0 Stark 2,736 14,968 1,255 2,158 90.0 Harrison 258 712 70 116 5.2 Holmes 272 1,687 141 448 10.8 Tuscarawas 3,970 6,333 354 553 40.5 Wayne 21,450 8,911 702 1,849 126.4 6 300 Urban increment: Total mass = 4.2 µ g/ m3 11% sulfates; 30% nitrates; 49% carbon; 10% crustal. Urban site = 390990014; Rural site = MKGO1 ( M. K. Goddard)

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

County 2001 2003 Design Value Stark 17.3 µ g/ m3 Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Carroll 29,166 74 Stark 377,940 656 Wayne 112,704 203 Factor 4: Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Carroll 5,125 40 193 Stark 956 1 3,135 Wayne 1,681 3 1,039 Factor 5: Expected growth County Percent growth 1990 2000 Carroll 9 Stark 3 Wayne 10 Factor 6: Meteorology 6 301 Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Carroll 27 39 18 17 Stark 24 41 17 17 Wayne 24 41 18 16 Factor 7: Geography/ topography There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8: Jurisdictional boundaries The Stark County Regional Planning Commission/ Stark County Area Transportation Study ( SCATS) is the Metropolitan Planning Organization ( MPO) for the Canton Massillon, OH.  Source: SCATS web page, http:// www. rpc. co. stark. oh. us/ scats. html The area's ozone nonattainment area consists of the following county:  Stark Factor 9: Level of control of emission sources The State provided no information about the level of control of emission sources for this area.

<IP_ADDRESS> Cincinnati Hamilton Area Discussion:

There are five Ohio counties in this Metropolitan area: Brown, Butler, Clermont, Hamilton and Warren Counties. There are violating monitors in Butler and Hamilton Counties. EPA agrees with the Ohio EPA's Option 2 recommendation to include Butler, Clermont, Hamilton and Warren Counties as nonattainment for the Cincinnati Hamilton nonattainment area. Brown County is not included because there are minimal emissions and population in this county relative to the Metropolitan area. Brown County was also excluded from the ozone nonattainment area for Cincinnati Hamilton. There are four counties that are adjacent to the metropolitan area in Ohio and not included in other metropolitan areas. These counties are Preble, Clinton, Highland and Adams Counties. Of these adjacent counties, Adams County merits further review due to the emissions in 6 302 the county. Adams County is more likely to contribute to violations in Scioto County and the Huntington Ashland metropolitan area, and is addressed in connection with that area.

Because emissions are relatively low for Preble, Clinton, and Highland Counties, and no other factor warranted designating these counties nonattainment, the following data summaries for factors 3 through 9 do not address these counties.

Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area County SOx NOx Carbon Crustal Composite emission score Boone, KY 14,717 15,794 721 1,068 7.7 Brown, OH 395 2,927 208 520 2.0 Butler, OH 13,204 19,735 956 1,752 9.9 Campbell, KY 860 5,294 285 260 2.8 Clermont, OH 84,599 45,618 1,693 3,916 20.0 Dearborn, IN 56,773 31,138 900 2,121 11.4 Gallatin, KY 350 2,365 100 234 1.0 Grant, KY 210 2,664 182 191 1.8 Hamilton, OH 88,053 58,398 2,780 3,873 30.3 Kenton, KY 1,573 8,365 415 301 4.2 Ohio, IN 113 682 49 89 0.5 Pendleton, KY 597 3,396 139 207 1.5 Warren, OH 895 7,565 743 1,063 6.9 Adams, OH 125,136 52,992 1,435 3,973 19.4 Bracken, KY 52 570 76 94 0.7 Carroll, KY 53,086 26,269 821 2,177 10.3 Clinton, OH 375 2,490 193 583 1.8 Franklin, IN 92 1,335 143 341 1.3 6 303 Harrison, KY 290 1,786 114 225 1.1 Highland, OH 242 1,756 177 498 1.6 Mason, KY 38,142 16,071 562 1,429 7.0 Owen, KY 57 572 126 105 1.1 Preble, OH 428 2,765 228 721 2.2 Ripley, IN 140 2,081 221 507 2.0 Switzerland, IN 251 1,554 101 145 1.0 Union, IN 58 548 68 272 0.6 Urban increment: Total mass= 2.1 µ g/ m3 7% sulfates; 15% nitrates; 78% carbon; 0% crustal. Urban site= 211170007; Rural site= LIVO1 ( Livonia)

Factor 2: Air quality in potentially included versus excluded areas County 2001 2003 Design Value Butler, OH 16.2 µ g/ m3 Campbell, KY 14.5 µ g/ m3 Hamilton, OH 17.8 µ g/ m3 Kenton, KY 15.0 µ g/ m3 Preble, OH 13.5 µ g/ m3 Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Boone, KY 93,290 379 Brown, OH 43,464 88 Butler, OH 340,543 729 6 304 Campbell, KY 88,604 583 Clermont, OH 183,352 406 Dearborn, IN 47,333 155 Gallatin, KY 7,836 79 Grant, KY 23,620 91 Hamilton, OH 833,721 2048 Kenton, KY 152,164 934 Ohio, IN 5,804 67 Pendleton, KY 14,815 53 Warren, OH 175,133 438 Adams, OH 27,804 48 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands) Boone, KY 19,805 44 842 Brown, OH 9,901 53 417 Butler, OH 62,298 39 2610 Campbell, KY 26,658 62 1097 Clermont, OH 50,763 57 1649 Dearborn, IN 10,978 48 607 Gallatin, KY 1,805 50 254 Grant, KY 5,234 51 379 Hamilton, OH 54,833 14 8420 Kenton, KY 44,002 58 1816 Ohio, IN 1,644 59 56 Pendleton, KY 3,704 57 169 Warren, OH 32,089 42 15 Adams 2,578 23 283 Factor 5. Expected growth 6 305 County Percent growth 1990 2000 Boone, KY 49 Brown, OH 21 Butler, OH 14 Campbell, KY 6 Clermont, OH 19 Dearborn, IN 19 Gallatin, KY 46 Grant, KY 42 Hamilton, OH  2 Kenton, KY 7 Ohio, IN 6 Pendleton, KY 20 Warren, OH 39 Adams, OH 8 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Boone, KY 22 41 18 19 Brown, OH 23 40 18 18 Butler, OH 24 40 18 18 Campbell, KY 23 40 18 19 Clermont, OH 23 40 18 18 Dearborn, IN 23 40 18 19 Gallatin, KY 22 41 19 19 Grant, KY 21 40 19 20 Hamilton, OH 23 41 18 19 Kenton, KY 22 41 18 19 6 306 Ohio, IN 22 39 19 19 Pendleton, KY 21 40 19 20 Warren, OH 24 39 19 18 Adams, OH 22 39 20 19 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Ohio Kentucky Indiana Regional Council of Governments ( OKI) is the Metropolitan Planning Organization ( MPO) for Butler, Warren, Clermont, and Hamilton Counties in Ohio; Campbell, Kenton, and Boone Counties in Kentucky; and Dearborn County, Indiana.  Source: OKI web page, http:// www. oki. org/

The Ohio portion of this area's ozone nonattainment area consists of the following Ohio counties:  Butler, Clermont, Hamilton, Warren, Clinton Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area.

<IP_ADDRESS> Cleveland Akron Lorain Area Discussion: There are violating monitors in Cuyahoga and Summit Counties. EPA is modifying the Ohio EPA Option 2 recommendation to include Cuyahoga, Lake, Lorain, Medina, Summit , and Portage Counties, and Ashtabula Township in Ashtabula County in the Cleveland Akron Lorain nonattainment area. These counties are all in the ozone nonattainment area, which will facilitate planning for both standards.

In the June 2004 letters from EPA to the States 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 extend to the relevant power plant to include it in the nonattainment area. 6 307 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.

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 freestanding 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, Ashtabula Township in Ashtabula County is a partial county area included in the Cleveland Akron Lorain nonattainment area.

The State of Ohio submitted information on August 30, 2004, further supporting its recommendation that Geauga County has low emissions and should not be included in the nonattainment area. EPA agrees with this recommendation. EPA is also designating most of Ashtabula County as nonattainment, with the exception of Ashtabula Township, which contains the Ashtabula power plant and a significant fraction of the population of Ashtabula County.

There are four counties adjacent to this metropolitan area that are not a part of another metropolitan area. These are Erie, Huron, Ashland and Wayne Counties. Emissions are relatively low for these counties.

Because emissions are relatively low for Ashland, Erie, Huron, and Wayne Counties, and no other factor warranted designating these counties nonattainment, the following data summaries for factors 3 through 9 do not address these counties.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emissions score Ashtabula 14,985 16,470 870 1,098 9.7 Cuyahoga 15,440 52,547 3,126 1,808 28.0 Geauga 624 3,985 472 648 3.6 6 308 Lake 53,219 24,531 1,074 1,570 16.2 Lorain 35,677 31,826 1,212 2,007 17.1 Medina 527 7,132 526 788 4.6 Portage 1,643 9,120 712 794 6.0 Summit 16,264 27,641 1,511 1,066 14.8 Ashland 825 3,460 214 663 2.4 Crawford, PA 1,231 8,034 413 772 4.4 Erie 1,341 7,327 447 635 11.8 Huron 557 3,828 242 697 2.6 Wayne 21,450 8,911 702 1,849 8.9 Urban increment: Total mass= 7.1 µ g/ m3 13% sulfates; 34% nitrates; 42% carbon; 11% crustal. Urban site= 390350060 Rural site= MKGO1 ( M. K. Goddard)

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

County 2001 2003 Design Value Cuyahoga 18.3 µ g/ m3 Lake 13.4 µ g/ m3 Lorain 13.9 µ g/ m3 Portage 14.2 µ g/ m3 Summit 16.6 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2003 Population Population Density Ashtabula 102,515 146 6 309 Cuyahoga 1,379,049 3,011 Geauga 92,980 230 Lake 229,004 1,004 Lorain 288,360 585 Medina 158,439 375 Portage 153,886 313 Summit 546,381 1,323 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Ashtabula 11,106 24 1,107 Cuyahoga 49,985 8 11,461 Geauga 24,452 55 901 Lake 42,894 37 1,833 Lorain 40,464 30 2,514 Medina 37,343 49 1,622 Portage 34,001 44 1,796 Summit 51,921 20 5,141 Factor 5. Expected growth:

County Percent growth 1990 2000 Ashtabula 3.0 Cuyahoga  1.0 Geauga 12.0 Lake 6.0 Lorain 5.0 Medina 23.0 6 310 Portage 7.0 Summit 5.0 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Ashtabula 24 40 20 15 Cuyahoga 21 45 16 18 Geauga 23 41 20 16 Lake 22 43 18 17 Lorain 21 45 16 18 Medina 21 45 16 18 Portage 25 40 19 16 Summit 23 42 17 17 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Northeast Ohio Areawide Coordinating Agency ( NOACA) is the Metropolitan Planning Organization ( MPO) for Cuyahoga, Geauga, Lake ( OH), Lorain, and Medina Counties.  source: NOACA web page, http:// www. noaca. org/

The area's ozone nonattainment area consists of the following counties:  Ashtabula, Cuyahoga, Geauga, Lake, Lorain, Medina, Portage, and Summit Factor 9. Level of control of emission sources:

Although the State has indicated that the power plant located in Ashtabula County has reduced its NOX and SO2 emissions, EPA does not have information as to the permanence or federal enforceability of those reductions, nor did the State indicate what 6 311 portion of these emission reductions occurred after the 2001 date for which EPA's emissions data base applies.

<IP_ADDRESS> Columbus Area Discussion: Franklin County contains a violating monitor. There are no other monitors in the metropolitan area. Ohio EPA's Option 2 recommendation was to designate Delaware, Fairfield, Franklin, and Licking Counties as nonattainment. EPA is including these counties as well as Franklin Township in Coshocton County in the Columbus nonattainment area. Pickaway and Madison Counties are excluded from the nonattainment area. These two counties have the lowest composite emissions scores in the metropolitan area. Pickaway County was not included as part of the ozone nonattainment area, and Madison County was included in the ozone nonattainment area because it contained a monitored violation of the ozone standard. These two counties also have the lowest population, population density and vehicle miles traveled in the metropolitan area. There are eleven counties adjacent to the metropolitan area that are not included in another metropolitan area. Most of these counties have relatively low emissions and do not warrant further discussion. The exception is Coshocton County, which has significant emissions, principally from the Conesville power plant located in Franklin Township. EPA believes that these emissions are contributing to the violation in the Columbus Metropolitan Area. By designating Franklin Township in Coshocton County as nonattainment, these emissions are being captured.

In the June 2004 letters from EPA to the States 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 extend to the relevant power plant to include it in the nonattainment area.

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.

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 freestanding 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 6 312 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, Franklin Township in Coshocton County is a partial county area included in the Columbus nonattainment area.

Because emissions are relatively low for the counties adjacent to the metropolitan area other than Coshocton County, and no other factor warranted designating these counties nonattainment, the following data summaries for factors 3 through 9 do not address these counties.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emissions score Delaware 676 6,088 573 1,277 11.2 Fairfield 1,301 6,556 507 1,098 10.4 Franklin 6,435 41,541 2,084 2,098 48.2 Licking 1,054 7,815 909 1,701 17.1 Madison 233 3,106 259 1,033 5.2 Pickaway 9,854 5,971 363 1,282 7.9 Champaign 383 1,757 180 602 3.5 Coshocton 97,412 24,560 1,385 3,733 30.9 Fayette 309 2,136 204 669 4.0 Hocking 408 2,161 104 154 2.4 Knox 302 2,225 258 657 4.9 Marion 675 3,896 273 909 5.7 Morrow 291 2,434 157 532 3.4 Muskingum 1,908 5,595 363 656 7.8 Perry 327 2,079 133 326 2.9 Ross 31,103 8,000 423 910 9.6 6 313 Union 377 2,202 246 897 4.7 Urban increment: Total mass= 2.1 µ g/ m3 0% sulfates; 27% nitrates; 73% carbon; 0% crustal. Urban site= 390171004; Rural site= LIVO1 ( Livonia)

The Conesville Power Plant in Franklin Township represents approximately 99% SO2, 90% NOX, 78% Carbon and 87% Crustal emissions for Coshocton County. Therefore, designating Franklin Township as nonattainment will capture the bulk of Coshocton County's emissions.

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

County 2001 2003 Design Value Franklin 16.7 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Delaware 125,399 283 Fairfield 129,161 255 Franklin 1,086,814 2013 Licking 148,731 216 Madison 40,365 87 Pickaway 53,437 106 Coshocton 36,836 65 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Delaware 32,350 56 1,099 Fairfield 31,533 52 1,064 6 314 Franklin 24,992 5 10,081 Licking 25,636 36 1,474 Madison 8,378 47 619 Pickaway 10,498 48 545 Coshocton 843 5 308 Factor 5. Expected growth County Percent growth 1990 2000 Delaware 64 Fairfield 19 Franklin 11 Licking 13 Madison 8 Pickaway 9 Coshocton 3 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Delaware 24 35 23 19 Fairfield 24 34 23 19 Franklin 24 33 24 20 Licking 24 35 23 19 Madison 24 34 23 19 Pickaway 24 33 24 19 Coshocton 24 42 18 16 6 315 Muskingum 24 36 23 18 Perry 24 35 23 19 Ross 24 34 23 19 Union 24 34 23 19 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Mid Ohio Regional Planning Commission ( MORPC) is the Metropolitan Planning Organization ( MPO) for the Columbus, OH area. Source: MORPC web page, http:// www. morpc. org/ MORPC. htm The area's ozone nonattainment area consists of the following counties:  Delaware, Franklin, Licking, Fairfield, Madison, and Knox Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area.

<IP_ADDRESS> Dayton Springfield Area Discussion: There is a violating monitor in Montgomery County. EPA agrees with the Ohio EPA Option 2 to include Clark, Greene, and Montgomery Counties in the Dayton Springfield nonattainment area. The majority of emissions and population are captured notwithstanding the exclusion of Miami County, which has limited emissions and population. Miami County is also lower in terms of population density and VMT in the metropolitan area.

There are six counties adjacent to the metropolitan area and not included in another metropolitan area. Emissions are relatively low for these counties, and no other factor warranted designating these counties nonattainment. Therefore the following data summaries for factors 3 through 9 do not address these counties.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area: 6 316 County SOx NOx Carbon Crustal Composite emissions score Clark 544 5,691 395 1,024 16.1 Greene 1,895 8,841 389 1,064 17.9 Miami 478 4,116 337 972 13.2 Montgomery 11,214 24,177 1,190 1,210 52.8 Champaign 383 1,757 180 602 6.8 Darke 551 3,174 381 1,316 14.0 Preble 428 2,765 228 721 8.9 Clinton 375 2,490 193 583 7.7 Fayette 309 2,136 204 669 7.8 Shelby 803 3,468 225 670 9.3 Urban increment: Total mass= 2.1 µ g/ m3: 0% sulfates; 27% nitrates; 73% carbon; 0% crustal. Urban site= 390171004; Rural site= LIVO1 ( Livonia)

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

County 2001 2003 Design Value Clark 14.7 µ g/ m3 Greene 9.5 µ g/ m3 Montgomery 15.2 µ g/ m3 Preble 13.5 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density 6 317 Clark 143,416 359 Greene 149,964 361 Miami 99,596 245 Montgomery 554,470 1200 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Clark 14,604 22 1,483 Greene 27,963 38 1,299 Miami 13,764 28 850 Montgomery 31,453 12 5,668 Factor 5. Expected growth County Percent growth 1990 2000 Clark  2 Greene 8 Miami 6 Montgomery  3 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Clark 25 36 21 18 Greene 25 36 21 18 Miami 25 38 20 17 Montgomery 25 38 20 17 Factor 7. Geography/ topography: 6 318 There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Miami Valley Regional Planning Commission ( MVRPC) is the Metropolitan Planning Organization ( MPO) for the following counties: Greene, Miami, Montgomery, and portions of Warren.  Source: MVRPC website, http:// www. mvrpc. org/ index. htm The area's ozone nonattainment area consists of the following counties:  Clark, Greene, Miami, and Montgomery Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area.

<IP_ADDRESS> Huntington Ashland Area Discussion: There are monitors showing violations of the standard in Scioto and Lawrence Counties. Therefore, EPA agrees with Ohio's Option 2 recommendation to designate these counties nonattainment. We are also including Monroe and Sprigg Townships in Adams county and Cheshire Township in Gallia County in this nonattainment area. Lawrence County is the only county in the Ohio portion of the metropolitan area. Aside from Scioto County, there are four counties in Ohio adjacent to the metropolitan area. These are Adams, Pike, Jackson and Gallia Counties. Adams County contains the DP& L Killen Generating Station and the DP& L J. M. Stuart Generating Station. Gallia contains the Ohio Power Gavin power plant and Ohio Valley Electric Corporation Kyger Creek power plant. The townships listed for Adams and Gallia counties are included to capture the significant emissions from these plants which are contributing to violations.

In the June 2004 letters from EPA to the States 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 extend to the relevant power plant to include it in the nonattainment area.

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" 6 319 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.

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 freestanding 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, Monroe and Sprigg Townships in Adams county and Cheshire Township in Gallia County are partial county areas included in the Hunting Ashland nonattainment area.

Emissions are relatively low for Pike and Jackson Counties, and no other factor warranted designating these counties nonattainment. The following data summaries for factors 3 through 9 do not address these counties.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emissions score Boyd, KY 11,740 13,478 689 1,242 25.2 Cabell, WV 5,155 27,903 1,318 774 40.3 Carter, KY 237 2,615 242 249 6.8 Greenup, KY 2,519 4,336 295 160 9.5 Lawrence, OH 841 4,399 293 379 8.6 Wayne, WV 1,023 6,485 317 199 9.6 Adams, OH 125,136 52,992 1,435 3,973 102.4 Elliott, KY 115 393 114 46 3.1 Gallia, OH 164,984 61,079 2,171 6,238 141.4 Jackson, OH 461 1,320 164 219 4.7 6 320 Lawrence, KY 56,055 21,265 745 1,718 48.3 Lewis, KY 469 2,873 285 121 8.1 Lincoln, WV 67 1,314 143 108 4.0 Martin, KY 661 1,236 136 131 4.0 Mason, WV 70,053 31,327 899 2,162 60.0 Mingo, WV 281 2,842 191 217 5.5 Rowan, KY 313 1,691 204 123 5.7 Scioto, OH 2,790 5,566 400 559 12.5 Urban increment: Total mass= 3.2 µ g/ m3: 10% sulfates; 6% nitrates; 84% carbon; 0% crustal. Urban site= 210190017; Rural site= QUCI1 ( Quaker City)

The DP& L Killen Generating Station and the DP& L J. M. Stuart Generating Station represent approximately 99% of the SO2, 93% of the NOX, 88% of the carbonaceous particles and 94% of the crustal emissions for Adams County. Designating Monroe and Sprigg Townships as nonattainment will capture these emissions, and therefore the bulk of the emissions for Adams County. The Ohio Power Gavin power plant and Ohio Valley Electric Corporation Kyger Creek power plant represents approximately 99% of the SO2, 97% of the NOX, 93% of the carbonaceous particles and 96% of the crustal emissions for Gallia County. Designating Cheshire Township as nonattainment will capture these emissions, and therefore the bulk of the emissions for Gallia County.

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

County 2001 2003 Design Value Boyd, KY 15.0 µ g/ m3 Cabell, WV 16.6 µ g/ m3 Carter, KY 12.2 µ g/ m3 Lawrence 15.8 µ g/ m3 Scioto 17.2 µ g/ m3 6 321 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Lawrence, OH 62,172 137 Boyd, KY 49,603 310 Cabell, WV 95,266 338 Carter, KY 27,055 66 Greenup, KY 36,761 106 Wayne, WV 42,382 84 Adams 27,804 48 Gallia 31,301 67 Scioto 78,041 128 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Lawrence, OH 11,446 49 796 Boyd, KY 3,967 21 411 Cabell, WV 2,864 7 1,030 Carter, KY 2,088 20 665 Greenup, KY 5,743 40 264 Wayne, WV 8,203 52 377 Adams 2,578 23 283 Gallia 337 3 266 Scioto 1,333 5 633 Factor 5. Expected growth: 6 322 County Percent growth 1990 2000 Lawrence, OH 1 Boyd, KY  3 Cabell, WV 0 Carter, KY 10 Greenup, KY 0 Wayne, WV 3 Adams 8 Gallia 7 Scioto 9 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Lawrence, OH 22 39 20 19 Boyd, KY 21 38 21 19 Cabell, WV 22 39 20 20 Carter, KY 2 39 20 20 Greenup, KY 22 39 20 19 Wayne, WV 22 39 20 20 Adams 22 39 20 19 Gallia 22 39 20 20 Scioto 22 39 20 20 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area. 6 323 Factor 8. Jurisdictional boundaries:

The KYOVA Interstate Planning Commission is the Metropolitan Planning Organization ( MPO) for Lawrence County, OH.  Source: KYOVA website. http:// www. state. wv. us/ kyova/

There are no counties in the Ohio portion of the metropolitan area designated nonattainment for the ozone standard.

Factor 9. Level of control of emission sources:

The state has indicated that selective catalytic reduction ( SCR) equipment has been installed on the DP& L Killen Generating Station and the DP& L J. M. Stuart Generating Station in Adams County and on the Ohio Power Gavin power plant and the Ohio Valley Electric Corporation Kyger Creek power plant in Gallia County. However, EPA does not have information as to the permanence, federal enforceability, or magnitude of those reductions. It is also unclear whether the NOX emission controls are operated on an annual basis. The state is in the process of reviewing modeling protocols for SO2 scrubber installations at the DP& L Killen Generating Station and the DP& L J. M. Stuart Generating Station. The scrubbers have not yet been installed, there is no current requirement for installation of this equipment, and EPA has no information on when these possible reductions might occur. Thus, EPA is not giving credit to these reductions as part of its designations decisionmaking.

<IP_ADDRESS> Parkersburg Marietta Area Discussion: Only one county in Ohio, Washington County, is in the metropolitan area. This county has a high level of emissions and contributes to violations in Wood County, West Virginia. Washington County also has a significant fraction of the area's population. Therefore, EPA is designating Washington County nonattainment as part of the Parkersburg Marietta nonattainment area.

There are five counties in Ohio adjacent to the metropolitan area, including Meigs, Athens, Morgan, Noble and Monroe Counties. Emissions are relatively low for these counties, and no other factor warranted designating these counties nonattainment. The following data summaries for factors 3 through 9 do not address these counties.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emission score Washington 173,312 37,020 2,415 6,711 82.2 6 324 Wood, WV 6,514 6,943 591 482 17.8 Athens 733 3,166 176 222 5.4 Jackson, WV 3,464 3,947 451 1,128 13.3 Meigs 375 2,244 147 145 4.4 Monroe 4,532 2,809 162 504 5.2 Morgan 81 558 88 122 2.5 Noble 144 1,622 87 127 2.7 Pleasants, WV 68,264 23,398 823 1,411 30.1 Ritchie, WV 118 713 97 63 2.8 Tyler, WV 176 1,233 122 126 3.6 Wirt, WV 19 206 46 36 1.3 Urban increment: Total mass= 3.2 µ g/ m3: 10% sulfates; 6% nitrates; 84% carbon; 0% crustal. Urban site= 210190017; Rural site= QUCI1 ( Quaker City)

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

County 2001 2003 Design Value Wood, WV 16.0 µ g/ m3 Athens 12.5 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Washington 62,561 99 Wood, WV 87,306 238 Factor 4. Traffic and commuting patterns: 6 325 County Number Percent County VMT ( Thousands)

Washington 5,927 21 737 Wood, WV 3,316 9 911 Factor 5. Expected growth:

County Percent growth 1990 2000 Washington 2 Wood, WV 1 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Washington 22 37 19 21 Wood, WV 22 39 18 21 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Wood Washington Wirt Interstate Planning Commission ( WWW) is the Metropolitan Planning Organization ( MPO) for the following townships in Washington County, OH: Newport, Marietta, Fearing, Muskingum, Warren, Dunham and Belpre Townships.  Source: WWW website, http:// www. triplew. org/ index. html The area's ozone nonattainment area consists of the following counties:  Washington County, OH, and Wood County, WV Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area. 6 326 <IP_ADDRESS> Steubenville Weirton Area Discussion: The only Ohio county in the metropolitan area is Jefferson County. There is a monitor violating the standard in Jefferson County. EPA agrees with Ohio and is including Jefferson County in the Steubenville Weirton nonattainment area. There is one county adjacent to the metropolitan area in Ohio that is not part of another violating metropolitan area, namely Harrison County. This county has a low composite emissions score as well as having relatively low population and VMT for the area.

Because emissions are relatively low for Harrison County, and no other factor warranted designating this county nonattainment, the following data summaries for factors 3 through 9 do not address this county.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emission score Brooke, WV 1,663 2,500 191 277 3.7 Hancock, WV 1,982 4,961 1,243 1,747 18.7 Jefferson 217,794 61,402 2,723 7,529 77.6 Harrison 258 712 70 116 1.3 Urban increment: Total mass= 4.2 µ g/ m3: 11% sulfates; 30% nitrates; 49% carbon; 10% crustal. Urban site= 390990014; Rural site= MKGO1 ( M. K. Goddard)

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

County 2001 2003 Design Value Brooke, WV 16.8 µ g/ m3 Hancock, WV 17.4 µ g/ m3 Jefferson 17.8 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas: 6 327 County 2002 Population Population Density Brooke, WV 25,179 283 Hancock, WV 32,082 387 Jefferson 72,402 177 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands) Brooke, WV 2,548 24 313 Hancock, WV 4,029 28 212 Jefferson 3,161 11 741 Factor 5. Expected growth:

County Percent growth 1990 2000 Brooke, WV  6 Hancock, WV  7 Jefferson  8 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Brooke, WV 29 36 19 16 Hancock, WV 29 36 19 16 Jefferson 28 37 19 16 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area. 6 328 Factor 8. Jurisdictional boundaries:

The Brooke Hancock Jefferson Metropolitan Planning Commission ( BHJMPC) is the Metropolitan Planning Organization ( MPO) for Jefferson County, OH.  Source: BHJMPC website, http:// www. bhjmpc. org/

The Ohio portion of this ozone nonattainment area consists of the following county:  Jefferson Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area.

<IP_ADDRESS> Toledo Area Discussion: There is a violating monitor in Lucas County. EPA agrees with the Ohio EPA's Option 2 recommendation and is designating Lucas and Wood Counties as the Toledo nonattainment area. Fulton County is also in the Metropolitan area but was excluded upon review of the nine factors. Fulton County has lower emissions, population, population density, and VMT in the Metropolitan area. Fulton County was also excluded from the ozone nonattainment area. There are several counties adjacent to the metropolitan area and in Ohio, including Hancock, Henry, Ottawa, Putnam, Sandusky, Seneca, and Williams Counties. These counties have lower composite emissions scores and are also lower in the other factors including population and VMT.

Thus, no other factor warranted designating these counties nonattainment. The following data summaries for factors 3 through 9 do not address these counties.

Monroe County, Michigan, has a design value of 15.1 µ g/ m3, but this county is part of the Detroit Metropolitan Area. EPA is designating this county as part of the Detroit nonattainment area.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emission score Fulton 878 5,105 336 692 12.0 Lucas 31,000 36,975 1,370 1,702 69.2 Wood 1,410 8,822 466 1,413 18.8 6 329 Hancock 567 4,351 342 1,036 11.1 Henry 3,139 2,547 185 662 6.3 Hillsdale, MI 1,286 3,270 245 812 8.2 Ottawa 1,544 5,031 403 687 13.0 Putnam 306 2,749 237 935 7.4 Sandusky 2,937 8,288 300 1,170 15.4 Seneca 826 4,575 281 951 10.4 Williams 469 3,600 196 634 7.8 Urban increment: Total mass= 4.8 µ g/ m3: 0% sulfates; 64% nitrates; 36% carbon; 0% crustal. Urban site= 390950026; Rural site= QUCI1 ( Quaker City)

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

County 2001 2003 Design Value Lucas 15.1 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Fulton 42,573 105 Lucas 453,506 1334 Wood 122,387 198 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Fulton 5,825 28 672 6 330 Lucas 19,011 9 4,324 Wood 19,773 32 1,400 Factor 5. Expected growth:

County Percent growth 1990 2000 Fulton 9 Lucas  2 Wood 7 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Fulton 25 41 16 18 Lucas 24 41 16 19 Wood 24 41 16 18 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Toledo Metropolitan Area Council of Governments ( TMACOG) is the Metropolitan Planning Organization ( MPO) for Fulton, Lucas, Ottawa, Sandusky, and Wood Counties in Ohio.  Source: TMACOG web page, http:// www. tmacog. org/

This area's ozone nonattainment area consists of the following counties:  Lucas and Wood Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area. 6 331 <IP_ADDRESS> Wheeling Area Discussion: The only Ohio county in the metropolitan area is Belmont County. This county contains higher emissions due in part to the R. E. Burger power plant. This county was also included as part of the ozone nonattainment area and contains the largest county population in the metropolitan area. There are four Ohio counties adjacent to the metropolitan area, namely Guernsey, Harrison, Monroe, and Noble Counties. These counties are excluded due to lower emissions, population and VMT.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emission score Belmont, OH 51,374 13,036 734 1,667 29.5 Ohio, WV 514 3,609 192 135 5.5 Marshall, WV 113,921 44,521 1,319 3,417 65.0 Greene, PA 217,794 61,402 2,723 7,529 99.2 Guernsey, OH 1,164 5,643 229 261 7.3 Harrison, OH 258 712 70 116 1.8 Monroe, OH 4,532 2,809 162 504 5.5 Noble, OH 144 1,622 87 127 2.5 Wetzel, WV 698 4,323 160 79 5.2 Urban increment: Total mass= 5.7 µ g/ m3: 27% sulfates; 24% nitrates; 46% carbon; 3% crustal. Urban site= 421290008; Rural site= DOSO1 ( Dolly Sods / Otter Creek Wilderness)

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

County 2001 2003 Design Value Ohio, WV 15.2 µ g/ m3 6 332 Marshall, WV 15.7 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Belmont, OH 69,448 129 Ohio, WV 46,126 435 Marshall, WV 34,898 114 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Belmont, OH 5,667 20 1,066 Ohio, WV 2,964 15 437 Marshall, WV 5,233 37 233 Factor 5. Expected growth:

County Percent growth 1990 2000 Belmont, OH  1 Ohio, WV  7 Marshall, WV  5 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Belmont, OH 28 37 19 16 Ohio, WV 29 36 19 16 Marshall, WV 28 36 19 16 Factor 7. Geography/ topography: 6 333 There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Bel O Mar Regional Council and Interstate Planning Commission is the Metropolitan Planning Organization ( MPO) for Belmont County, OH.  Source: Bel O Mar Regional Council website, http:// www. belomar. org/

The Ohio portion of this area's ozone nonattainment area consists of the following county in Ohio:  Belmont Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area.

<IP_ADDRESS> Youngstown Warren Area Discussion: EPA agrees with the Ohio EPA's Option 2 recommendation to include Columbiana, Mahoning and Trumbull Counties as nonattainment. These counties all have significant emissions contributing to the violations in Mahoning County. There are no adjacent counties to this metropolitan area in Ohio that are not a part of another violating metropolitan area.

Ohio's submittal of September 1, 2004, urges EPA to designate Columbiana County as attainment. However, EPA finds that this county contributes a significant percentage of the emissions in the Youngstown Warren Area. In addition, this county is surrounded by monitors showing violations, which suggests that Columbiana County ( which has no monitoring data) may be experiencing concentrations above the standard.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal composite emission score Columbiana 1,291 5,825 442 696 15.9 Mahoning 3,511 12,210 920 804 31.2 Trumbull 30,327 19,010 1,217 1,365 52.9 Mercer, PA 874 7,459 412 760 16.7 6 334 Crawford, PA 1,231 8,034 413 772 17.3 Lawrence, PA 35,620 13,065 681 1,833 41.2 Urban increment: Total mass= 4.2 µ g/ m3: 11% sulfates; 30% nitrates; 49% carbon; 10% crustal. Urban site= 390990014; Rural site= MKGO1 ( M. K. Goddard)

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

County 2001 2003 Design Value Mahoning 15.2 µ g/ m3 Trumbull 15.0 µ g/ m3 Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density Columbiana 111,806 210 Mahoning 253,308 610 Trumbull 223,518 363 Factor 4. Traffic and commuting patterns:

County Number Percent County VMT ( Thousands)

Columbiana 9,090 18 928 Mahoning 22,894 21 2,576 Trumbull 12,347 13 2,108 Factor 5. Expected growth:

County Percent growth 1990 2000 6 335 Columbiana 4 Mahoning  3 Trumbull  1 Factor 6. Meteorology:

Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Columbiana 27 39 18 17 Mahoning 25 39 21 15 Trumbull 25 38 22 15 Factor 7. Geography/ topography:

There are no geographical features ( mountain ranges, abrupt changes in elevation, etc.) that affect this area. The State provided no information about geography/ topography for this area.

Factor 8. Jurisdictional boundaries:

The Eastgate Regional Council of Governments ( Eastgate) is the Metropolitan Planning Organization ( MPO) for Mahoning and Trumbull Counties in Ohio.  Source: Eastgate web page, http:// www. eastgatecog. org/

The Ohio portion of this area's ozone nonattainment area consists of the following counties:  Columbiana, Mahoning, and Trumbull Factor 9. Level of control of emission sources:

The State provided no information about the level of control of emission sources for this area. 6 336 6.5.5 EPA 9 Factor Analyses for Wisconsin for Designation of Nonattainment Areas for PM2.5 EPA is designating all Wisconsin counties as attainment/ unclassifiable. The only area in or near Wisconsin with a monitored violation is the Chicago Gary Kenosha Area. Wisconsin did not provide a recommended list of designations in February 2004. Therefore, EPA sent the State a letter on June 29, 2004, stating an intent to designate Kenosha County nonattainment because this county is part of the Chicago Gary Kenosha metropolitan area and thus was presumptively part of the Chicago Gary Kenosha nonattainment area. Governor Doyle then sent EPA a letter on August 9, 2004, recommending that Kenosha County be designated attainment. The following discussion presents EPA's rationale for its designations in the Wisconsin portion of the Chicago Gary Kenosha Area.

<IP_ADDRESS> Chicago Gary Kenosha Area Discussion: EPA reviewed the nine factors for the thirteen counties within the metropolitan area including Kenosha County in Wisconsin as well as all counties adjacent to the metropolitan area in order to determine the appropriate nonattainment area. There are violating monitors in Cook County, Illinois and in Lake County, Indiana. Kenosha County monitoring indicates that PM2.5 concentrations in the county are below the standard. The counties in Illinois and Indiana that are being designated as nonattainment include 90% of the metropolitan area emissions. Kenosha County emissions are relatively low and will continue to decrease as federally enforceable SO2 and NOX controls are installed at the Pleasant Prairie Power Plant operated by WE Energies. Furthermore, prevailing winds in Kenosha County are predominantly away from the violating monitors in the metropolitan area. Therefore, EPA agrees with Governor Jim Doyle's recommendation to designate Kenosha County as attainment/ unclassifiable.

In Wisconsin, Racine and Walworth Counties are adjacent to the metropolitan area. Emissions are relatively low for these counties, and no other factor warranted designating these counties nonattainment. Therefore, the following data summaries for factors 3 through 9 do not address these counties.

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emissions score Cook 61,676 195,428 10,110 8,268 33.0 De Kalb 445 4,885 384 1,875 1.0 Du Page 2,990 29,479 1,731 1,229 4.9 Grundy 6,149 9,589 563 1,235 2.1 6 337 Kane 1,395 9,490 1,047 2,326 2.8 Kankakee 551 6,628 490 1,720 1.4 Kendall 292 2,941 265 961 0.7 Lake 14,223 24,488 2,092 1,777 6.7 Mc Henry 637 5,834 564 1,992 1.6 Will 80,847 37,518 1,447 4,120 11.7 Lake, IN 50,110 72,142 5,708 7,588 19.5 Porter, IN 21,601 41,315 2,702 5,587 9.2 Kenosha, WI 33,122 27,469 770 1,236 5.4 Boone 849 2,188 215 834 0.6 Ford 219 1,462 216 1,280 0.6 Iroquois 458 4,177 452 2,290 1.3 La Salle 2,140 13,984 845 3,352 2.5 Lee 3,978 4,793 345 1,722 1.3 Livingston 503 4,686 485 2,413 1.3 Ogle 672 4,985 335 1,536 1.1 Winnebago 1,100 10,496 656 1,405 1.9 Benton, IN 101 1,326 215 724 0.5 Berrien, IN 1,390 10,269 740 1,340 0.6 Jasper, IN 34,435 23,020 668 1,838 5.2 La Porte, IN 10,974 19,681 826 1,643 3.3 Newton, IN 89 1,321 160 642 0.4 Pulaski, IN 111 1,187 196 667 0.5 St Joseph, IN 2,850 13,690 1,482 1,825 4.0 Starke, IN 100 2,852 188 551 0.5 White, IN 188 2,495 292 1,185 0.8 Racine, WI 2,309 7,252 662 890 1.9 Walworth, WI 866 5,693 470 908 1.3 Urban increment: Total mass= 3.6 µ g/ m3 25% sulfates; 8% nitrates; 65% carbon; 2% crustal. Urban site= 170310076; 6 338 Rural site= BOND1 ( Bondville)