### Mr. Ron Curry STATE OF 

### ARKANSAS ASA HUTCHINSON GOVERNOR 

### August 28, 2015



### Region VI, Regional Administrator United StatesEPA Region VI 1445 

### Ross Avenue, Suite 1200 

### Dallas, Texas 75202-2733


### Re: Crittenden County Emission Base Year Inventory Revision
Dear Mr. Curry: 

### RECEIVED-- oPDL 

### AIR**PL!\~HI!NG** 

### SEC. 

## 15 SEP -3 PM 5:**2~**



### On behalfofthe State ofArkansas andtheArkansas Departmentof Environmental Quality, I herebyrespectfully submittothe United StatesEnvironmental 

## Protection Agency (EPA) the Crittenden County Emission Inventory, for approval. The inventorywas completedto meetEPA statutoryrequirements underthe Federal Clean AirAct.
The package accompanying this letter consists ofone hardcopy and one electronic copy (on disk), summarizedas follows:

• Crittenden County NOx, VOC andCO Emission Inventory • Affidavit ofPublic Hearing
•· Responsive summaryto comments received duringthe public commentperiod • Complete record ofthe public hearing and commentperiod
I certifythat all documents submittedtothe Regional Office in electronicform are exact duplicates ofthehardcopy documents. Should any questions arise, please contactBecky Keogh, ADEQ Director, at (501) 682-0959. 

### Thankyou for your consideration ofArkansas's submission.

Enclosures

500 WooDLANE STREET, 

### Sum 250 ·LITTLE RocK,AR 

### 72201 TELEPHONE 

### (501) 682·2345 

### www.governor.arkansas.gov

# Crittenden County NOx, VOC & CO

Base Year Emission Inventory1



### TABLE OF CONTENTS 1

Introduction 2 A. Background B. Emissions Summary

Section I 3 Area Source Inventory

Section II 6 On-road Source Inventory

Section III 7 Non-road Emission Inventory

Section IV 8 Point Source Inventory

LIST OF TABLES
Table 1: Summary 3 Table 2: Area NOx by Sector 4 Table 3: Area VOCs by Sector 5 Table 4: Area CO by Sector 6 Table 5: On-Road Mobile 6 Table 6: Non-Road Mobile 7 Table 7: Point Source 82



### INTRODUCTION

A. BACKGROUND
This document represents the 2008 8-Hour Ozone State Implementation Plan (SIP) emissions inventory for Crittenden County, Arkansas and includes emission data for NOx, VOCs and CO as required by the Clean Air Act Amendments (CAAA) of 1990. The Clean Air Act of 1970 and the Clean Air Act Amendments of 1990 both contain provisions for the attainment and maintenance of National Ambient Air Quality Standards (NAAQS) for criteria pollutants. The CAAA requires revision of existing plans in states containing areas designated as nonattainment prior to 1990 and also requires development of new plans in newly designated nonattainment
areas. On March 12, 2008, the United States Environmental Protection Agency (EPA) lowered the eight-hour ozone NAAQS from 0.08 parts per million (ppm) to 0.075 ppm. Under the 0.075 ppm (75 parts per billion) standard, the EPA designated the Memphis TN-MS-AR area, as nonattainment with a marginal classification. Crittenden County, Arkansas is located within this nonattainment area. The CAAA requirements are very specific and vary in accordance with the severity of the particular area’s air pollution problem. Section 182(a)(1) of the CAAA requires states with nonattainment areas to submit a comprehensive and accurate inventory of ozone precursor emissions from all sources within two years of the effective date of designation, which was July 20, 2012. EPA’s proposed 40 Code of Federal Regulations §51.1115, specified that states use 2011 as a base year in the proposed implementation rule for the 2008 eight-hour ozone NAAQS.
Enclosed is the base year 2011 emission inventory for Crittenden County, Arkansas which was classified as “marginal” by the EPA. For marginal ozone nonattainment areas, three pollutants must be inventoried: oxides of nitrogen (NOx); volatile organic compounds (VOCs); and carbon monoxide (CO). Air Emissions Reporting Requirements (AERR) Rule submittals every three years thereafter will be used to satisfy the periodic EI requirements.

B. EMISSIONS SUMMARY
The agency directly responsible for the preparing and submitting the 2008 Ozone SIP Emissions Inventory was the Arkansas Department of Environmental Quality (ADEQ). The 2011 EI of NOx, VOCs and CO for Crittenden County was created from four general categories of emissions sources: point, area, on-road mobile, and non-road mobile.3



### The annual emissions for NOx, VOCs and CO are estimated in tons per year (tons/year) and ozone season daily emissions are estimated in tons per day (tons/day). Daily emissions are estimated for the typical peak ozone season day. The peak ozone season is defined as that contiguous three-month period of the year during which the highest number of ozone exceedances have occurred over the past three years. The months of June, July, and August were selected for Crittenden County. Peak ozone daily emissions represent average emissions that occurred on a typical weekday during the peak ozone season. All references to daily or seasonal emissions in this document represent peak ozone season daily emissions. In this inventory, NOx, VOCs and CO emissions sources are categorized into point, area, non-road, on-road and biogenic sources. Peak ozone season daily emissions are estimated for all of these emission source categories. Sources for the area, non-road, on-road, and biogenic categories were developed using the AERR and are based on EPA-generated information for Crittenden County.
Table 1: Summary Category Ozone

Season Daily NOx Annual

NOx Ozone

Season Daily VOC Annual

VOC Ozone

Season Daily CO Annual

CO
Units tons/day tons/year tons/day tons/year tons/day tons/year Point 0.0017 0.63 0.51 186.84 0.004 1.58 Area 8.70 3,165.17 24.90 8,868.94 20.32 7,375.56 Non-road Mobile 2.11 582.63 3.66 881.35 13.78 3,476.63
On-road Mobile 6.80 2,542 2.42 845 23.13 9,051
Total 17.61 6,290.43 31.49 10,782.13 57.234 19,904.77

SECTION I

AREA SOURCE INVENTORY
Stationary sources that do not meet the reporting requirements for point sources are classified as area sources. Area sources are small-scale industrial, commercial, and residential sources that use materials or perform processes that generate emissions. Area sources can be characterized by the mechanism in which emissions are released into the atmosphere: evaporative or combustion. Evaporative emission sources include the following: oil and gas production facilities, printing processes, industrial coating and degreasing operations, gasoline service station underground tank filling, and vehicle refueling operations. Combustion sources include the following small facilities with less than 100 tons per year of emissions: oil and gas production facilities, stationary source fossil fuel combustion at residences and businesses, outdoor burning, structural fires, and wildfires.4



### Arkansas accepts EPA emission estimates for the Area Sources category.
The area source inventory includes emitters of ozone precursors (i.e., VOCs and NOx) such as devices that combust fuel (e.g., wood stoves, commercial and industrial boilers), disperse industrial and commercial VOC sources (e.g., dry cleaners, degreasing and industrial surfaces coating), gasoline distribution, off-road mobile sources (planes, trains, and watercraft), fires and open burning (e.g., agricultural burning, structural fires wildfires, prescribed burning). Biogenic sources are also included in this category.
Seasonal Adjustment for Area Source Emissions Daily emissions (tons per day) for area sources are calculated using the EPA-prescribed method in, “Procedures for the Preparation of Emission Inventories for Carbon Monoxide and Precursors of Ozone Volume 1: Guidance for Stationary Sources” found at: http://www.epa.gov/ttn/naaqs/aqmguide/collection/cp2/bakup/19910501_oaqps_epa-450_4-91- 016_ei_preparation_stationary_sources.pdf.
Table 2: Area NOx by Sector Area NOx by Sector Tons/year Days/Week Ozone Season Daily tons/day Biogenics - Vegetation and Soil 545.17 7 1.498 Bulk Gasoline Terminals 0.63 6 0.002 Fires - Agricultural Field Burning 136.02 7 0.374 Fires - Prescribed Fires 55.10 7 0.151 Fuel Comb - Comm/Institutional - Other 0.01 6 0.00005 Fuel Comb - Residential - Natural Gas 30.80 7 0.085 Fuel Comb - Residential - Oil 0.04 7 0.0001 Fuel Comb - Residential - Other 6.55 7 0.018 Fuel Comb - Residential - Wood 1.77 7 0.005 Miscellaneous Non-Industrial NEC 0.21 6 0.001 Mobile - Aircraft 2.80 7 0.008 Mobile - Commercial Marine Vessels 261.42 7 0.718 Mobile - Locomotives 791.46 7 2.174 Mobile - Locomotives 1327.79 7 3.648 Waste Disposal 5.40 6 0.017 Total 3165.17 8.705



### Table 3: Area VOCs by Sector Area VOCs by Sector Tons/year Seasonal Factor Days/Week Ozone Season Daily tons/day Biogenics - Vegetation and Soil 6193.09 1 7 17.014 Bulk Gasoline Terminals 45.11 1 6 0.145 Bulk Gasoline Terminals 102.99 1 6 0.330 Commercial Cooking 0.33 1 7 0.0009 Fires - Agricultural Field Burning 240.50 1 7 0.661 Fires - Prescribed Fires 569.34 1 7 1.564 Fuel Comb - Comm/Institutional - Other 0.0005 0.6 6 0.000001 Fuel Comb - Residential - Natural Gas 1.80 0.3 7 0.001 Fuel Comb - Residential - Oil 0.0015 0.3 7 0.000001 Fuel Comb - Residential - Other 0.24 0.3 7 0.0002 Fuel Comb - Residential - Wood 16.76 0.3 7 0.014 Gas Stations 455.64 1 7 1.252 Industrial Processes - Storage and Transfer 110.24 1 6 0.353 Industrial Processes - Storage and Transfer 141.73 1 6 0.454
Miscellaneous Non-Industrial NEC 68.29 1 6 0.219 Mobile - Aircraft 6.16 1 7 0.017 Mobile - Commercial Marine Vessels 5.98 1 7 0.016 Mobile - Locomotives 39.09 1 7 0.107 Mobile - Locomotives 92.02 1 7 0.253 Solvent - Consumer & Commercial Solvent Use 650.71 1 6 2.086 Solvent - Dry Cleaning 1.93 1 6 0.006 Solvent - Industrial Surface Coating & Solvent Use 56.50 1 6 0.181 Solvent - Non-Industrial Surface Coating 59.56 1 6 0.191 Waste Disposal 10.95 1 6 0.035 Total 8,868.94 24.906



### Table 4: Area CO by Sector Area CO by Sector Tons/year Days/Week Ozone Season Daily tons/day Biogenics - Vegetation and Soil 1425.79 7 3.92 Bulk Gasoline Terminals 1.58 6 0.01 Fires - Agricultural Field Burning 2760.70 7 7.58 Fires - Prescribed Fires 2386.49 7 6.56 Fuel Comb - Comm/Institutional - Other 0.008 6 0.00003 Fuel Comb - Residential - Natural Gas 13.11 7 0.04 Fuel Comb - Residential - Oil 0.01 7 0.00003 Fuel Comb - Residential - Other 3.67 7 0.01 Fuel Comb - Residential - Wood 97.13 7 0.27 Miscellaneous Non-Industrial NEC 0.001 6 0.000003 Mobile - Aircraft 227.07 7 0.62 Mobile - Commercial Marine Vessels 53.14 7 0.15 Mobile - Locomotives 171.40 7 0.47 Mobile - Locomotives 116.71 7 0.32 Waste Disposal 118.76 6 0.38 Total 7375.56 20.32

SECTION II

A. ON-ROAD SOURCE INVENTORYOn-road mobile sources consist of passenger cars, passenger trucks, motorcycles, buses, heavyduty trucks, and other motor vehicles traveling on public roadways. Combustion-related emissions are estimated for vehicle engine exhaust, and evaporative hydrocarbon emissions are estimated for the fuel tank and other non-tailpipe sources from the vehicle. To calculate pollution from on-road mobile sources, emission rates are estimated as a function of county, vehicle type, roadway type, hour, and operating speed. These rates are then matched with appropriate activity from transportation data parameters such as vehicle miles traveled (VMT), number of vehicles parked, hours spent in extended idle mode, etc.
Arkansas utilized a county scale run of the MOVES 2010b model for this data.

Table 5: On-Road Mobile Category Ozone Season

Daily NOx Annual

NOx Ozone

Season Daily VOC Annual

VOC Ozone

Season Daily CO Annual

CO Units tons/day tons/year tons/day tons/year tons/day tons/year On-road Mobile 6.80 2,542 2.42 845 23.13 9,0517



### SECTION III

A. NON-ROAD EMISSION INVENTORY
Non-road mobile sources encompass a wide variety of equipment types that either move under their own power or are capable of being moved from site-to-site. More specifically, these sources, which are not licensed or certified as highway vehicles, are defined as those that move or are moved within a 12-month period and are covered under the EPA’s emissions regulations as non-road mobile sources. The non-road EI includes emissions from non-road equipment such
as:

▪ Agricultural equipment (i.e. tractors,combines and balers)
▪ Construction equipment (i.e. graders and back hoes) ▪ Ind ustrial and

commercial equipment (i.e. fork lifts and sweepers)
▪ Residential and commercial lawn and garden equipment (i.e. lawn mowers and weed trimmers)
▪ Recreational equipment, (i.e. four wheelers and off-road motorbikes) This category does not include commercial marine, locomotives, and aircraft.
Arkansas utilized the National Mobile Inventory Model for this data.

Table 6: Non-Road Mobile Category Ozone Season

Daily NOx Annual

NOx Ozone

Season Daily VOC Annual

VOC Ozone

Season Daily CO Annual

CO
Units tons/day tons/year tons/day tons/year tons/day tons/year Non-road Mobile 2.11 582.63 3.66 881.35 13.78 3,476.638



### SECTION IV

A. POINT SOURCE INVENTORY
Point Sources are large, stationary, emissions sources that release pollutants into the atmosphere. Stationary point source emissions data is collected annually from those sources that meet reporting requirements outlined in the Air Emissions Reporting Requirements (40 C.F.R. Part 51). These sources include, but are not limited to, refineries, chemical plants, bulk terminals, and utilities. Facilities are required to report emissions data via a web-based database system. Reporting of information characterizing the process equipment, the abatement units, and the emission points is also required.
The Arkansas Department of Environmental Quality is responsible for compiling the point source inventory. The Air Division Emission Inventories and Data Management Section is accountable for identifying point sources that meet the reporting threshold criteria as outlined in the AERR and the collection of facility emissions data from designated reporting facilities. ADEQ also processes, compiles, and manages the collected emissions data. Emissions data provided by reporting facilities includes estimates of actual emissions generated by the facility during the previous year. Estimation methodologies are required to follow state and federal guidelines.
ADEQ uses a web-based emissions inventory reporting and database management system to gather point source data from the regulated community. The system is named SLEIS (State & Local Emissions Inventory System). For the 2011 EI, facilities could use SLEIS to electronically submit their EI reports to ADEQ for review; however, they also were required to submit a paper copy of the certifying statement, signed by the responsible official. All submitted data is reviewed for quality assurance purposes and then stored in the SLEIS database. At the end of the annual reporting cycle, point source emission data is reported each year to the EPA for inclusion in the National Emissions Inventory (NEI).

Table 7: Point Source Ozone Season Daily NOx Annual

NOx Ozone

Season Daily VOC Annual

VOC Ozone

Season Daily CO Annual

CO tons/day tons/year tons/day tons/year tons/day tons/year 0.0017 0.63 0.51 186.84 0.004 1.58

# Affidavit of Public Hearing

### Affidavit Regarding Arkansas's State Implementation Plan (SIP): Public Hearing for Revisions to Crittenden County Emission Inventory 2008 Ozone NAAQS Nonattainment

Before me, the undersigned authority, personally appeared Chris Hemann, who, being by me duly sworn, deposed as follows:

My name is Chris Hemann. I am ofsound mind, capable ofmaking this affidavit, and personally acquainted with the facts herein stated:
I am an Epidemiologist for the Air Division ofthe Arkansas Department of Enviromnental Quality (ADEQ) in its regular course ofbusiness, and I am familiar with the public participation process for Arkansas's SIP.

I attest that a Public Hearing was publicly noticed February 16, 2015, and held at the Eugene Woods Civic Center, 212 W. Polk, West Memphis Arkansas at 2:00p.m., on March 18,2015. One individual provided spoken comments at the Hearing. The public comment period ended April!, 2015, at 4:30p.m.
No written comments were received during the public comment period. A transcript ofthe Hearing is included as part ofthe record for Arkansas's proposed Revisions to Crittenden County Emission Inventory 2008 Ozone NAAQS Nonattainment.

# ~- Affiant: Chris Hemann, Epidemiologist Arkansas Department ofEnvironmental Quality

SWORN AND SUBSCRIBED before me, on the , 

# ';i day of

## d'~ '2015.

County Notary Public, State ofArkansas 

# Ca. ro 

# I 

# 8. lli1<er Notary's Printed Name**Fll~H:~· (~**  C'-::J.'!7'1**~:OT.',:;','** ,**~** . ., · i**~.:,~N3~.!l** My**COi'llt{i;~:,.;:;;l')** l:.:::p.:::**J~.:;y** 01, 2018 Comrr:lts!on No. 12::t17564

# Responsive 

# Summary

### RESPONSIVE SUMMARY FOR EMISSION INVENTORY REVISION FOR CRITTENDEN COUNTY

·Pursuant to Arkansas Code Annotated § 8-4-317(b)(2)(B)(i), Arkansas Department of Environmental Quality ("ADEQ") must prepare a record ofthe public process in the form ofa written response to each issue raised during the public comment period. A responsive summary groups public comments into similar categories and explains why ADEQ accepts or rejects the rationale for each category.
On March 18, 2015, Chris Hemann, Arkansas Department ofEnvironmental Quality (ADEQ) Epidemiologist, acted as Hearing Officer and conducted a public hearing for the Emission Inventory revision. The public comment period ended April I, 2015. The only comments received were at the public hearing.
Comment 1: The Commenter states that a model run by ADEQ stafffor 2011 shows higher emissions using Actual Vehicle Miles traveled and higher temperature data than default values used in this Emission Inventory and the original Motor Vehicle Emission Budget. Commenter provided a copy ofdaily emissions results for 2011, 2013 and 2015 from a test run with a handwritten date of"2/27/13". Response: The data shown on the commenter's submission does show higher Nitrogen Oxide (NOx) emissions. The 2011 emission inventory default inputs were chosen based on the 2011 National Emission Inventory and to be consistent with the last Interagency Consultation Committee decision to use default data for transpmiation confom1ity for 2011.
Comment 2: The Commenter states that he knows ADEQ is working on the new Motor Vehicle Emission Budget for the new redesignation request/maintenance planbut wants to make sure actual data is used rather than using default numbers to get a higher budget. Response: This comment is outside the scope ofthis Emission Inventory. Inputs for running the MOVES Model for transpm1ation conformity, etc. are set by the Interagency Consultation Committee, which is made up oflocal, state and federal partners. The commenter is a part of this committee and will have significant input on the decision for the new Motor Vehicle Emission Budget.
Comment 3: The Commenter wants to expedite the process for redesignation and the new Motor Vehicle Emission Budget, so they can update their long range transportation plan and show conformity which is due in June of2017. Response: This comment is outside the scope ofthis Emission Inventory. The pr9cess is underway and the Interagency Consultation Committee is meeting to discuss the inputs. It is an agency priority to complete this as expeditiously as possible.Comment 4: The Commenter had discussed a schedule in January with ADEQ on the process for adjusting the Motor Vehicle Emission Budget and has not seen a schedule yet. Response: This comment is outside the scope ofthis Emission Inventory. The schedule the commenter is referring to was based on modifying the original Motor Vehicle Emission Budget. Based on discussions with the Environmental Protection Agency (EPA) since the hea1ing date, it -will be better to create a new Motor Vehicle Emission Budget based on data :fi:om one ofthe

three years ofclean data used in the redesignation 1;equest: 2012,2013, or 2014. A new schedule will be developed based on the Interagency Consultation Committees meetings. Comment 5: The Commenter wants to make sure this 2011 inventory does not affect the new Motor Vehicle Emission Budget. Response: This comment is outside the scope ofthis Emission Inventory. The maintenance plan for the redesignation request will include a new Motor Vehicle Emission Budgetthat will be based on data :fi·om 2012, 2013 or 2014, not the 2011 data.
Conclusion: No revisions to the proposed Emission Inventory are necessary due to the comments received.

By: Prepared by:
Arkansas Department of Environmental Quality

# ~ Stum1 Spencer Air Division Chief

# Record of Public ParticipationArkansas Depatiment ofEnvironmental Quality Public Notice
The Arkansas Depatiment ofEnvironmental Quality (ADEQ) is publishing this Public Notice to provide interested persons the oppmiunity to comment on ADEQ's proposed Emission Inventory (EI) revision for Crittenden County. This EI revision will be submitted in response to the U.S. Environmental Protection Agency's (EPA) designation ofCrittenden County as being in nonattainment with the 2008 8-hour Ozone National Ambient Air Quality Standards (NAAQS). This designation was effective July 20, 2012.
The EI revision represents the 2008 8-hour ozone emissions inventory for Crittenden County, Arkansas, and includes emission data for ozone precursors, which include Nitrogen Oxide (NOx), Volatile Organic Compounds (VOCs), and Carbon Monoxide (CO), as required by the Clean Air Act Amendments (CAAA) of 1990. The Clean Air Act of 1970 and the CAAA of 1990 contain provisions for the attainment and maintenance ofthe NAAQS for criteria pollutants. The CAAA requires revision ofexisting plans in states containing areas designated as nonattainment prior to 1990 and also requires development ofnew plans in newly designated nonattaimnent areas.
On March 12, 2008, EPA lowered the 8-hour ozone NAAQS from 0.08 parts per million (ppm) to 0.075 ppm. Underthe 0.075 ppm (75 patis per billion) standard, EPA designated the Memphis TN-MS-AR metropolitan statistical area as nonattainment with a marginal classification. Crittenden County, Arkansas, is located within this nonattainment area designation. The CAAA requirements are very specific and vary in accordance with the severity ofthe patticular area's air pollution problem. Section 182(a)(l) ofthe CAAA requires states with nonattainment areas to submit a current, comprehensive and accurate inventory ofozone precursor emissions from all
sources within two years ofthe effective date ofdesignation. EPA's proposed 40 Code of Federal Regulations Section 51.1115 Federal Register notice issued on June 6, 2013, recommends that states use 2011 as a base year in the proposed implementation rule for the 2008 8-hour ozone NAAQS. ADEQ is providing the public with the opportunity to comment on this proposed EI revision in two ways. ADEQ has scheduled a public hearing on this issue for 2:00p.m. March 18,2015. The public hearing location will be the West Room ofthe Eugene Woods Civic Center, 212 W. Polk, West Memphis, Arkansas. Oral and written statements will be accepted at the hearing, but written comments are prefened in the interest ofaccuracy. In lieu ofcommenting at the public hearing, written and electronic mail comments will be accepted. To be considered, written and electronic mail comments must be received no later than 4:30 p.m. (Central Time) April 1, 2015. Written comments should be mailed to Tony Davis, Air Division, Arkansas Department of Environmental Quality, 5301 Nmthshore Drive, Nmth Little Rock, AR 72118. Electronic mail comments should be sent to: DavisA@adeq.state.ar.us.
In the event ofinclement weather or other unforeseen circumstances, a decision may be made to postpone the hearing. Ifthe hearing is postponed and rescheduled, a new legal notice will be published to announce the details ofthe new hearing date and comment period.Pending any comments received, Arkansas will submit this EI revision to the EPA. Copies ofArkansas's proposed Crittenden County

## El revision are available for public inspection during normal business hours at the Public Outreach and Assistance (POA) Division in the ADEQ headquarters building in North Little Rock and in ADEQ infonnation depository located at the public library in West Memphis. In addition, an electronic copy ofthe Arkansas's proposed Crittenden County EI revision is available for viewing or downloading on ADEQ's Internet web site at http://www.adeq.state.ar.us/air/branch plmming/default.htm

Published February 16, 2015, Ryan Benefield, P.E., Interim Director, Arkansas Department ofEnvironmental Quality

# Arkansas Democrat ·. . QVazette
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### Transcript: Revisions to Crittenden County Emission Inventory 2008 Ozone NAAQS Nonattainment public hearing


### Date: March 18, 2015


### Time: 2:00 p.m. Central Time


### Location: West Room ofthe Eugene Woods Civic Center, 212 W. Polk, West Memphis Arkansas
"Good Afternoon, my name is Chris Hemann, Epidemiologist for the Air Division's Planning Branch. Ihave been designated today as the Hearing Officer, today's March 18th, 2015 Hearing. We are here today in West Memphis regarding the emission inventory revision for Crittenden County, which is based on the nonattainment decision for the 2008 Ozone NAAQS Standard. We are ready to take verbal comments. Would anyone like to make a verbal comment?"
Commenter: "My name is Eddie Brawley and I am the study director for the West Memphis
area study, MPO Study area. We are currently classified nonattainment in Crittenden County. The lastthree years, 2012, 2013, 2014, we are in attainmentbased on the three year average, 8 hour average. We have been working with ADEQ, with the understanding thatthey are pushing forward with the request for redesignation to EPA. Iknow this is related to inventory but Ijust wantto go on record thatthough this is a 2011 inventory and it is based on older data perhaps, I wanted to say that because ofthe vehicle emissions that's related to types ofvehicles on the road in our area, that in the past using defaults have created a budget that is less than ifwe use actual data. There was a run made by ADEQ's modeler in 2011 that shows different numbers than what's in this inventory. I understand they used defaults ratherthan actual numbers; these are based on actual numbers. I'd like to present these to ya'll as part ofthe record. This is using actual AHTD data and using temperatures that are higher than what was used in the original budget period. It has 11 tons ofNOx that is the biggest area ofconcern versus the 6 point somethingtons you are showing in the inventory. We realize you are working on this, we justwant to make sure this is pushed forward. Iwantto also say that when we getthe new designation, we want to be sure we are getting the right vehicle miles traveled, we are getting the correct speeds, we are getting the correcttemperatures, and so forth that goes into the modelling. Iknow ya'll are aware ofthat, we need to use real numbers. That was our main concern. The otherthing wasjust mainly, that we need to hurry up that process because the economic development directors here in West Memphis and Marion are getting calls all the time, one Iknow oftoday, because they sent that call to me. Wanting to know where we stand. They are being told that we are in attainment now and we are in attainment by thenumbers but we have notbeen designated yet as being in attainment and would like to rush that up and remind you that in the January meeting Mark McCorkle said that he was going to do a schedule, and Ihave not seen anything on that schedule for getting that accomplished. We need to get that done as soon as possible. We are going to be/already started on updating our plan in '17 and I know when we presentthatto EPA it's going to take some time, and it has to go into the federal register, and then wait for comments and that still is going to be pushing us to getthe budget in time to show conformity in time for
our next update for the long range transportation plan.
Iknow thatthe budget issues and these are somewhat different, but Ijustwantto be sure thatthe tonnage shown in the inventory here that when it's possibly even doubled that it wouldn't bring such a shock that it interferes with us getting the budgetthat we really need to actually use the real numbers. Iknowyou are all aware ofthat, but I wanttojust reinforce that we are in a hurry on that. The inventory get that done as soon as you can I guess butthe biggest issue locally is the nonattainment designation and getting that changed as quickly as possible. That is all Ihave to say."