**North Carolina Recommendation for Rowan County**

The purpose of this paper is to discuss the rationale for recommending
less than the entire Rowan County as nonattainment for the 8-hour ozone
standard, which is part of the Charlotte/Gastonia/Rock Hill Metropolitan
Statistical Area (MSA). We recommend the following five small townships
in the northwestern corner of the county located in 2 Census tracts
containing 50-100 people per square mile not to be designated
nonattainment: Cleveland, Mount Ulla, Scotch Irish, Steele, and Unity
township. This MSA County has the Enochville and Rockwell monitor
located in it.

-   First, this area has a moderate 8-hour ozone problem, with a design
    value in 2001-2003 for both monitors of 0.099 ppm. Recent future
    year modeling results for 2007 show the DVF value of 0.090 ppm
    classifying this area in the marginal category.

-   Second, winds in Rowan County are climatologically from the
    southwest. With this climatological wind pattern, the county is not
    in an upwind sector that would routinely have an impact on air
    quality in the urban portion of the Charlotte/ Gastonia/Rock Hill
    MSA. On the days when the two monitors exceed the 8-hour standard,
    it appears to be measuring the urban plume or pollution from the
    Charlotte. As the pollution in the Charlotte area is reduced, the
    monitors should observe lower ozone levels.

-   Third, based on 1997 emissions inventories, Rowan County has 47.67
    tons per day of NOx (state total is 2529 tons per day) and the
    county has 26.70 tons per day of VOC (state total is 1842 tons per
    day -- anthropogenic only). In Rowan County there are some major
    point sources subject to control. In particular, the Buck Steam
    Station will have controls put on to meet both the NOx SIP Call and
    the Clean Smokestacks Act. The impact of the Transco Natural Gas
    Pumping Station (located southwest of Rowan County) NOx emissions
    from neighboring Iredell County will be controlled under the NOx SIP
    Call and the Clean Smokestacks Act.

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-   Fourth, another major NOx emissions source in Rowan County are
    mobile sources (16.36 tons of the 47.67 tons come from mobile
    sources each day, and an additional 6.03 tons per day comes from
    nonroad sources). The combined Federal and state control programs
    will address these emissions including the introduction of low
    sulfur gasoline statewide. In July of 2003 Rowan County began
    implementing an I/M program that requires OBD testing for model year
    1996 and newer cars. Expansion of this program has or will be phased
    in neighboring counties in this region by January 1, 2004. These
    counties include Catawba, Davidson, Iredell, Rowan, Lincoln, Stanley
    and Union.

-   Fifth, the population in the 5 townships North Carolina recommends
    to be excluded from the nonattainment area represents 7.5 percent of
    the total Rowan county population. The northwest corner is a rural
    area as indicated in the 2 Census tracts containing 50-100 people
    per square mile. Traffic and commuting patterns analysis show that
    Rowan County ranked number 7 for commuters driving into Mecklenburg
    County. Only 1.0 percent of all commuters are from Rowan County.
    Also the expected population growth for this county between 2000 and
    2010 is only16.2% as compared to Mecklenburg County (29.3 percent).

-   Based on the information presented above, North Carolina continues
    to believe this is an appropriate boundary for this region. This
    site is clearly a \"downwind\" area from the emissions of any
    consequence and the Enochville and Rockwell monitors were sited at
    these locations to be the downwind monitor for the upwind source
    area that North Carolina is recommending for non-attainment.