Appendix F 

Public Notice Report, 

Comments Received and Responses 
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Supplement to the Attainment Demonstration for the Appendix F 

Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment Area April 5, 2010 

TABLE OF CONTENTS 

Public Notice Report ........................................................................................................................1 

Comment Letter: 3/17/2010, Richard A. Schutt, Chief of Air Planning Branch, 

USEPA Region 4 .................................................................................................................3 

Comment Letter: 3/22/2010, J. David Farren and Thomas Gremillion, Southern Environmental 

Law Center ...........................................................................................................................7 

The Charlotte Observer Affidavit ..................................................................................................11 
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Public Notice Report, Comments Received, and Responses 1 

Supplement to the Attainment Demonstration for the Appendix F 

Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment Area April 5, 2010 

Public Notice Report 

Supplement to the North Carolina 8-Hour Ozone Attainment Demonstration for the 

Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment Area 

(Cabarrus, Gaston, Lincoln, Mecklenburg, Rowan, Union Counties and 

Coddle Creek and Davidson Townships in Iredell County) 

On February 12, 2010, a pre-hearing draft version of the Supplement to the North Carolina 8-Hour Ozone 

Attainment Demonstration for the Charlotte-Gastonia-Rock Hill, NC-SC (referred to as the Metrolina 

area), 8-hour ozone nonattainment area was submitted to the U. S. Environmental Protection Agency 

(USEPA). A request for public hearing, in accordance with 40 CFR 51.102, and the public comment 

period were noticed in the local newspaper on Friday, February 12, 2010. The public comment period 

was open from February 12, 2010, through March 22, 2010, with a tentative hearing scheduled for 

Monday, March 22, 2010. No request for public hearing was received and the hearing was cancelled. A 

hearing cancellation notice was posted on the North Carolina Division of Air Quality (NCDAQ) website 

on Tuesday, March 16, 2010. The public comment period elicited comment letters from the USEPA and 

the Southern Environmental Law Center (SELC). 

Background 

In July 1997, the USEPA promulgated a new 8-hour ozone National Ambient Air Quality Standard 

(NAAQS), setting a standard at 0.08 parts per million (ppm) averaged over an 8-hour period. On 

April 15, 2004, the USEPA designated areas as nonattainment for the 1997 8-hour ozone NAAQS based 

upon air quality monitoring data measured during the 2001, 2002 and 2003 ozone seasons. These 

designations became effective on June 15, 2004. The Metrolina area was designated as a Moderate 

nonattainment area. 

The attainment date for a Moderate area is June 15, 2010, with an attainment demonstration State 

Implementation Plan (SIP) submittal date of June 15, 2007. The North Carolina Division of Air Quality 

(NCDAQ) submitted an attainment demonstration SIP on June 15, 2007, which demonstrated that the 

Metrolina nonattainment area would attain the standard by the end of 2009. 

The USEPA notified North Carolina in a letter dated November 17, 2008, that they planned to disapprove 

the Metrolina attainment demonstration SIP unless North Carolina requested a voluntary reclassification 

to Serious. In that letter, the USEPA stated: “Because we are now so close to the attainment date, we now 

believe that attainment will not be achieved by the required moderate area deadline based on the air 

quality measurements from the summers of 2007 and 2008 that exceed the standard by a sizable amount. 

Furthermore, we believe that the area will not meet the requirements for a one-year extension of the 

attainment date.” 

Before responding to the November 17, 2008, letter, North Carolina thoroughly considered the two most 

apparent options: the proposed disapproval of the attainment demonstration SIP and the voluntary 

reclassification to Serious. Both options presented rather negative consequences for the State. While the 

USEPA believed that it was unlikely that the Metrolina area would attain the 1997 ozone standard by its 

attainment date, North Carolina believed that the region could meet the requirement for requesting a one-
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Supplement to the Attainment Demonstration for the Appendix F 

Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment Area April 5, 2010 

year extension if the attainment date was not met and believed that disapproval of the attainment 

demonstration SIP was premature. 

Many of the control requirements in the Clean Air Act Amendments (CAAA) for a Serious nonattainment 

area focus on reducing Volatile Organic Compound (VOC) emissions. For example, stationary sources 

with potential annual VOC emissions greater than 50 tons per year must implement reasonably available 

control technology or RACT. The Metrolina region is nitrogen oxide (NOx) limited, so reductions in 

VOC emissions will not result in the reductions in ozone needed to meet the standard. Therefore, the 

NCDAQ did not wish to request a voluntary reclassification of the Metrolina area to Serious when there 

was still a chance that the area would be eligible to request a one-year extension of the attainment date. 

North Carolina believed that in these difficult economic times, it was unreasonable for the State to require 

business and industry to go through a resource intensive and burdensome process and implement costly 

VOC controls when lower ozone levels would not be achieved as a result of that exercise. 

Therefore, on December 19, 2008, North Carolina responded to the USEPA letter by withdrawing the 

attainment demonstration SIP submitted in 2007 and by committing to submit a revised SIP by 

November 30, 2009. In August 2009, the NCDAQ shared an internal draft of the revised attainment 

demonstration with the USEPA and the transportation partners for comment. The NCDAQ learned at the 

end of the comment period that the USEPA had issues with the attainment year as proposed in the revised 

SIP being 2011. 

By the time the NCDAQ learned of the USEPA’s concerns, the majority of the ozone season was over. 

Although the Metrolina area did not have a design value below the 1997 8-hour ozone standard for the 

three-year period including the 2009 data, the area did have clean data for 2009; i.e., the fourth highest 

values at all of the monitors were below the 1997 ozone standard. The CAAA allows the USEPA to 

extend the attainment date for one year even if the area has a 3-year design value above the standard for 

the attainment year, provided certain other conditions exist. The conditions for the extension are that an 

area has clean data in the designated attainment year and that the State has complied with all requirements 

and commitments in its implementation plan. With clean data for 2009, the area qualifies for a one-year 

extension of the attainment date once the attainment demonstration is deemed complete by the USEPA. 

The USEPA discussed internally various options of what the NCDAQ could submit that would address 

their concerns with the 2011 attainment date. On November 4, 2009, the NCDAQ was given two options 

to consider: 

• Option 1 - The State could re-submit the original attainment demonstration and then submit 

supplemental information. The supplemental information would include the 2009 ambient air 

quality data showing the area qualifies for a one-year extension and the 2011 modeling as weight 

of evidence that the Metrolina region would attain the standard by June 15, 2011. 

• Option 2 - The State could use the original 2009 modeling and the revised 2011 modeling to 

develop a plan to demonstrate the area would attain the standard by June 15, 2011. 

The NCDAQ chose Option 1, and on November 12, 2009, the agency re-submitted the attainment 

demonstration SIP for the Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment Area to 

the USEPA. 
Public Notice Report, Comments Received, and Responses 3 

Supplement to the Attainment Demonstration for the Appendix F 

Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment Area April 5, 2010 

This Public Notice Report addresses the comments received on the Supplement to the Metrolina 

attainment demonstration. The Supplement contains the information requested by the USEPA, which 

includes the 2009 ambient air quality data showing the area qualifies for a one-year extension and the 

2011 modeling as weight of evidence that the Metrolina region will attain the standard by June 15, 2011. 

Summary of Public Notice and Comment Period 

The public comment period was open from February 12, 2010 through March 22, 2010. Comment letters 

were received from the USEPA and SELC, which are attached at the end of this Appendix. The USEPA 

letter stated that they had no comments at this time on the Supplement to the Attainment Demonstration. 

The comments from the SELC focused on their belief that the Metrolina region should be reclassified to a 

“Serious” nonattainment area and that the region does not qualify for a one-year extension of the 

attainment date. Below is a summary of pertinent comments from the SELC and the NCDAQ’s response. 

Some of the SELC’s comments received were extensive and touched on a number of somewhat related 

issues. This report does not attempt to address comments that are not applicable to the Supplement to the 

Metrolina attainment demonstration SIP. 

SELC: SELC incorporated by reference their comments submitted with regards to the North Carolina 

8-Hour Ozone Reasonable Further Progress Demonstration for the Charlotte-Gastonia-Rock Hill, NC-SC 

8-Hour Ozone Nonattainment Area (referred to as the RFP SIP). 

NCDAQ’s Response: These comments were addressed in the RFP SIP that was submitted to the USEPA 

on November 30, 2009. 

SELC: The Metrolina region does not qualify for a 1-year extension of the attainment date and should be 

reclassified to Serious nonattainment status. 

NCDAQ’s Response: The NCDAQ disagrees that the region should be reclassified to Serious. Although 

the region’s 3-year design value is slightly over the 1997 8-hour ozone standard, the region has clean 

data for 2009 and the NCDAQ believes that the area meets the requirements necessary to request a 1-

year extension of the attainment date. Please see the preceding “Background” section for an explanation 

of the USEPA’s clean data policy. 

SELC: The NCDAQ should develop prospective strategies for controlling emissions, particularly from 

motor vehicles and ensure both short term and long term attainment of health-based air quality standards. 

NCDAQ’s Response: The NCDAQ had submitted an attainment demonstration for the Metrolina region 

in June 2007 that was a prospective plan for attainment of the health-based 1997 8-hour ozone NAAQS. 

The purpose of this supplemental SIP is to address additional information that was requested by the 

USEPA that would further supplement the original attainment demonstration. 

SELC: SELC stated that NCDAQ has simultaneously relaxed important controls on emissions and 

declined to adopt any new measures, even those which the Clean Air Act requires. 

NCDAQ’s Response: When the 1997 8-hour ozone NAAQS was promulgated, North Carolina was 

proactive in developing control measures to meet this standards long before areas were designated. In 
Public Notice Report, Comments Received, and Responses 4 

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Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment Area April 5, 2010 

1999 the North Carolina General Assembly (NCGA) passed the Clean Air Bill that expanded the motor 

vehicle inspection and maintenance program from nine to 48 counties, which is well beyond what is 

required through the CAAA. In 2002, the NCGA passed the Clean Smokestacks Act that required the 

larger coal-fired power plants to control to meet set emission caps that could not be met through 

purchasing credits. Additionally, the NCDAQ has an open burning regulation that prohibits burning of 

trash and, on air quality action days, the burning of vegetative materials as well. This past year, the 

NCDAQ developed an Idle Reduction Rule to reduce emissions from idling heavy duty motor vehicles, 

which we believe will become effective in 2010 after it passes through the NCGA review. None of these 

controls on emissions have been relaxed and the NCDAQ believes that all controls required by the CAAA 

have been adopted.

SELC: The resubmission and SIP supplement continue to omit any valid contingency measures that 

would take effect “without further action by the State or the Administrator.” 

NCDAQ’s Response: In accordance with the guidance from the USEPA, the contingency measures 

should equal approximately three percent of the baseline emission and these measures could include 

Federal programs that are already in place. The estimated amount of emission reductions expected from 

the fleet turnover of highway and off-road mobile sources provided approximately three percent of the 

baseline emission reductions. These emission reductions would take effect without further action by the 

State or the Administrator. The NCDAQ believes North Carolina has met the contingency measure 

requirement of the CAAA. 

SELC: The Supplemental SIP does not establish motor vehicle emission budgets (MVEBs) for 2010. 

NCDAQ’s Response: In preparing the supplement to the attainment demonstration SIP, the USEPA 

guidance was that the motor vehicle emission budgets needed to be for 2009 and budgets needed to be 

established for NOx and VOC. Therefore, MVEBs have been established for 2009. 

SELC: The SIP Supplement and its accompanying revisions and resubmissions are inconsistent with the 

Clean Air Act statutory scheme and its emphasis on attainment deadlines. 

NCDAQ’s Response: The NCDAQ has coordinated with the USEPA to ensure that the attainment 

demonstration and this supplement fulfill the requirements of the CAAA.

SELC: North Carolina officials should prepare a new SIP revision consistent with the Metrolina area’s 

legally required bump-up to “serious” status, and the state should focus efforts on actually achieving the 

tough new standards on the horizon. 

NCDAQ’s Response: The NCDAQ has already started the modeling work that will be needed to 

determine what additional controls will be needed to meet the “tough new standards on the horizon.” 

Additionally, the NCDAQ believes that our focus and energy should be on the modeling and rule 

development work to attain the new 2010 ozone standard when it is promulgate, as opposed to preparing 

a new SIP for the Metrolina area to meet the 1997 8-hour ozone standard, especially since we believe the 

region will attain this standard with the conclusion of the 2010 ozone season. 

SELC: The SELC incorporated by reference their comments submitted to the Metrolina transportation 

planners on their draft conformity analysis and determination report for their long range transportation 
Public Notice Report, Comments Received, and Responses 5 

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plans. Many of the comments in this referenced letter are similar to those addressed above. Comments 

on the conformity analysis do not pertain to the Supplemental SIP and will not be addressed. One 

comment in the referenced letter discussed the various MVEBs for Mecklenburg County and questioned 

the descrepancies. 

NCDAQ’s Response: The MVEBs that were established in the redesignation demonstration and 

maintenance SIP for the Charlotte-Gastonia 1-hour nonattainment area submitted in 1995 were 

calculated using the current USEPA mobile model at that time (MOBILE5b) and highway performance 

monitoring system (HPMS) vehicle miles traveled (VMT) data. HPMS data was used since it was the 

only VMT data available at the time of the SIP development. Since that time, the USEPA has developed 

another mobile model (MOBILE6.2) which estimates higher emission factors than its predecessor 

MOBILE5b. Additionally, the Metrolina region developed a travel demand model (TDM) that provides a 

better estimate of the VMT than HPMS data. Therefore, it is to be expected that emission estimates made 

with the new mobile model and the better TDM data would be higher than what was estimated in the 

1-hour ozone SIP. 

The difference between the 2008 RFP MVEBs and the 2009 MVEBs in the attainment demonstration can 

be attributed to a couple of factors. First, the USEPA’s mobile model estimates a 10.5% reduction in 

emissions due to fleet turnover between 2008 and 2009 in Mecklenburg County. Additionally, the data 

used to estimate the 2009 MVEBs were TDM predictions developed in the 2005-2006 timeframe. Since 

that time, the region has developed a newer and more refined TDM. It was with this newer model’s data 

that the 2008 MVEBs were developed. Furthermore, the 2008 MVEBs were developed in 2009 when 

there was a better understanding of what the actual VMT was, as opposed to the 2009 MVEBs which 

were a three or four year forecast into the future. The combination of fleet turnover and the use of newer 

more refined data accounts for the differences between the 2008 RFP MVEBs and the 2009 MVEBs from 

the attainment demonstration. 

Conclusions

The NCDAQ believes it has adequately addressed the SELC’s comments. The NCDAQ will be moving 

forward with the final submittal to the USEPA of the Supplement to the North Carolina 8-Hour Ozone 

Attainment Demonstration for the Charlotte-Gastonia-Rock Hill, NC-SC 8-Hour Ozone Nonattainment 

Area. 
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 Appendix F 

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 Appendix F 

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