## Fayette County, Kentucky

Fayette County is located in the Lexington, Kentucky Metropolitan
Statistical Area (MSA) and is located to the east of Woodford County, to
the northeast of Jessamine County, to the northwest of Madison County,
to the west of Clark County, to the southeast of Scott County, and to
the southwest of Bourbon County.

EPA's June 29, 2004 proposal on appropriate designations for Kentucky
included Fayette County as nonattainment based on the following
criteria:

-   EPA indicates that Fayette County has over 10,000 tons per year
    (considered by EPA to be significant) of NOx and VOC emissions;

-   Fayette County has a violating PM~2.5~ monitor; and

-   EPA indicates that the population and population density, expected
    growth, and vehicle miles traveled (VMTs) and commuters have a
    potential to contribute to the PM~2.5~ violations in the area.

##### 

##### Emissions Data

In Kentucky's original February recommendations, 1999 NEI data was used
in the original analysis.

However, in EPA's June 29, 2004, letters to states, EPA looked outside
the original MSA boundaries to determine if large emissions
contributions from adjacent areas were having an impact on PM~2.5~
levels in many of the areas. EPA also used the 2001 NEI which provided
slightly newer data than had been recommended that states use.

Specifically, in the Lexington metropolitan area, EPA has recommended
that Fayette County be included as nonattainment areas due to the
significant emissions in the county. However, Fayette County has
emissions greater than 10,000 tpy of NO~x~ and VOC only. In this area,
as shown by speciation data in Figure 5, of greatest concern are SOx and
organic carbon.

With Mercer County included in the recommended nonattainment area,
Fayette County emits only 6% of SOx and 19% of the PM emissions from the
eight county area recommended by EPA as having the potential to impact
the violating monitor. See Figures 1-4 below.

#### Figure 1

![](media/image1.wmf)

Figure 2

![](media/image2.wmf)

Figure 3

![](media/image3.wmf)

Figure 4

![](media/image4.wmf)

Air Monitoring Data and Trends

Fayette County has two PM~2.5~ monitors, one located in a central urban
area in the midst of the University of Kentucky (UK) on Limestone
Avenue, and the other is located out on an arterial roadway 1.9 miles
north of downtown (Newtown Pike).

The Newtown Pike monitor shows attainment with the standard, having an
average of 14.9 μg/m^3^ over the time period 2001-2003, and having an
average of 13.6 μg/m^3^ through April 2004. The UK monitor currently has
a design value of 15.6 μg/m^3^ over the 2001-2003 time period. However,
the average through April 2004 for this monitor has declined to 14.7
μg/m^3^.

As can been seen in Figure 5 below, the speciation data from Kentucky's
Lexington speciation monitor indicates that sulfate and organic carbon
are the major components of the PM~2.5~ values in this area. As can be
seen in Figure 1 above, Fayette County, Kentucky, contributes only 6% of
the SO~x~ in the combined area.

#### Figure 5

![](media/image5.wmf)

Although the UK Limestone monitor for the 2001-2003 timeframe exceeded
the annual standard (15.6 μg/m^3^), it currently shows attainment with
the PM~2.5~ standard with data through April 2004 (14.7 μg/m^3^). As
well, the annual concentrations for the entire area continue to show a
downward trend as depicted in Figure 6 below, which utilized data from
the year 2000 through April 2004.

#### Figure 6

![](media/image6.wmf)

Specifically, the PM 2.5 levels have decreased in Fayette County by 15%
at the Newtown monitor and 12% at the Limestone monitor, and by 13% in
Madison County (See Figure 7 below).

**Figure 7**

![](media/image7.wmf)

**Localized vs Regional Impacts**

It is Kentucky's position that the monitor located on the UK Campus
exhibits an "Urban Core Phenomenon." That is, the monitor's location is
at the center of a large public university situated in a downtown
metropolitan area with significant activity having a direct relationship
to the PM~2.5~ levels being monitored. This monitor is located only 1.9
miles from the monitor showing attainment of the standard on Newtown
Pike.

This monitor is bracketed by numerous large and small boilers on the
University of Kentucky campus and is located adjacent to continuing
construction on the campus. The University of Kentucky encompasses a
very large campus with numerous buildings. UK estimates that there are
approximately 112 boilers on campus. Many of these boilers are small,
natural gas powered boilers, which could account for a significant
difference in SOx vs NOx emissions in the area. However, several of
these boilers are also coal fired and have the potential to impact PM2.5
levels in the vicinity of the monitor.

Significant local impacts are occurring not only due to the close
proximity of the boilers, but also from the emission contributions of
construction and delivery equipment in the area.

In 2003, the University of Kentucky completed construction of three new
buildings within close proximity to the monitor. These buildings
included the College of Engineering's Ralph G. Anderson Building; the
College of Health Sciences Building; and the College of Agriculture
Plant Sciences Building.

Construction continues on the Biomedical/Biological Science Research
Building, the Linda and Jack Gill Building, The Main Building and
Patterson Plaza, and four new dormitories.

Without the localized impacts from this vicinity, Kentucky believes that
neither monitor would be showing a violation of the PM~2.5~ standard in
Fayette County.

Population Density and Growth

EPA stated that 2002 population levels in Fayette County are 3-11 times
higher population than the other counties under review in this area and
that this factor could contribute to PM2.5 problems in the area. See
Figure 8 below.

**Figure 8**

![](media/image8.wmf)

However, Fayette County was fifth in growth rate (16%), showing that
other counties within the region are growing at a more rapid rate than
Fayette County. As discussed later in this document, several national
control programs will be implemented within the next three years to
reduce population related emissions that contribute to PM2.5 problems in
many of our urban areas, including Fayette County.

# Traffic and Commuting Patterns

EPA noted that Fayette County has substantially large numbers of
commuters and VMT.

The potential of Fayette County's growth to contribute significantly to
traffic and commuting emissions will be mitigated by the referenced
national fuel programs, the Low Sulfur Diesel Program and the Tier 2
Vehicle and Low Sulfur Gasoline program.

Additional Regional/National Controls

The implementation of new federal rules to decrease the amount of sulfur
in both gasoline and diesel fuel will significantly decrease the amount
of SO~2~ in the entire area. Because of the Low Sulfur Diesel Rule, in
2007, new clean engines operating on 15-ppm sulfur diesel fuel will
reduce NOx emissions by 50%, and reduce PM emissions by more than 90%.
Due to the Tier 2 Vehicle and Gasoline Sulfur program, by 2006 average
national gasoline sulfur levels will be 90% lower.

Upon implementation of the Clean Air Interstate Rule (CAIR) SO~2~
emissions from power plants will be reduced nationwide by 3.6 million
tons in 2010 (approximately 40 percent below current levels) and by
another 2 million tons per year when the rules are fully implemented
(approximately 70 percent below current levels). NO~x~ emissions would
be cut by 1.5 million tons nationwide in 2010 and 1.8 million tons
annually in 2015 (about 65 percent below today's levels).

The first phase of compliance under the CAIR rule to reduce both SO~2~
and NO~x~ emissions would be required by 2010, allowing substantial
emission reductions in the area, by the proposed attainment date for
PM~2.5~ nonattainment areas.

**Conclusions**

Based on the factors discussed above, Kentucky believes that if any part
of Fayette County should be designated nonattainment it should be
limited to the area directly surrounding the monitoring site within New
Circle Road. Supporting factors are as follows:

-   The only monitor showing a violation throughout the entire eight
    county region is being impacted by extreme urban core activities in
    a specific geographic location on the University of Kentucky Campus
    in Fayette County. The other monitor which is located 1.9 miles away
    is showing attainment of the standard.

-   EPA has suggested that one large regional source in Mercer County is
    contributing to the violation in Fayette County. However, with the
    monitors being located only 1.9 miles from each other, with the
    Newtown Pike monitoring site showing attainment, if this area was
    receiving an impact from one significant source, both monitors would
    be showing a violation. This further identifies a localized impact
    on the monitor located on the University of Kentucky campus.

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-   PM~2.5~ levels continue to decline throughout the entire region.
    From a review of all monitors in the region, an average 13% decline
    in PM~2.5~ levels has occurred from 2000 through 2003. Every monitor
    in the region is currently showing values well within attainment of
    the annual PM~2.5~ standard using 2002 through 2004 data.

-   Additional emission reductions on a national and regional level will
    provide substantial additional emission reductions in the region.
    The anticipated sulfur reductions due to the Low Sulfur Diesel Rule,
    the Tier 2 Vehicle and Gasoline Low Sulfur programs, and the Clean
    Air Interstate Rule (CAIR) will further lower pollutant levels
    within this region.

To have this entire county designated nonattainment would invoke
additional substantial and unnecessary requirements on local government
planning agencies. Data exist to show that a localized impact is being
seen on the Limestone monitor.

Drastic emission reductions are scheduled to occur in the mobile sector
throughout the next several years that will greatly impact pollutant
levels in the area. In addition, reductions anticipated by the CAIR
provisions, the air monitoring data demonstrating attainment of the
PM~2.5~ Standard at two of the three monitors in the area, the downward
trend in monitored values, and Kentucky's position that the monitored
violation of the standard in the downtown area is the result of a
localized "urban core phenomenon" lead to the conclusion that only a
specific portion of Fayette County should be designated as nonattainment
for the PM2.5 standard.