Mr. Ron Curry 

STATE OF ARKANSAS 

ASA HUTCHINSON 

GOVERNOR 

August 28, 2015 

Region VI, Regional Administrator 

United States EPA 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 behalf of the State of Arkansas and the Arkansas Department of 

Environmental Quality, I hereby respectfully submit to the United States Environmental 

Protection Agency (EPA) the Crittenden County Emission Inventory, for approval. The 

inventory was completed to meet EPA statutory requirements under the Federal Clean 

Air Act. 

The package accompanying this letter consists of one hard copy and one 

electronic copy (on disk), summarized as follows: 

• Crittenden County NOx, VOC and CO Emission Inventory 

• Affidavit of Public Hearing 

•· Responsive summary to comments received during the public comment period 

• Complete record of the public hearing and comment period 

I certify that all documents submitted to the Regional Office in electronic form 

are exact duplicates of the hard copy documents. Should any questions arise, please 

contact Becky Keogh, ADEQ Director, at (501) 682-0959. Thank you for your 

consideration of Arkansas's submission. 

Enclosures 

500 WooDLANE STREET, Sum 250 ·LITTLE RocK,AR 72201 

TELEPHONE (50 1) 682 · 2345 

www.governor.arkansas.gov 
Crittenden County NOx, VOC & CO

Base Year Emission Inventory
1

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 8
2

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 8.70
5

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 24.90
6

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 INVENTORY

On-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 9,051
7

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) 

▪ Industrial 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 3,476.63
8

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 of sound mind, capable of making this 

affidavit, and personally acquainted with the facts herein stated: 

I am an Epidemiologist for the Air Division of the Arkansas Department of 

Enviromnental Quality (ADEQ) in its regular course of business, 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 of the 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 of Environmental Quality 

SWORN AND SUBSCRIBED before me, on the , ';i day of d'~ '2015. 

County 

Notary Public, State of Arkansas 

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 of the public process in the form of a 

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 staff for 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 of daily 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 plan but 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 of this Emission Inventory. Inputs for running the 

MOVES Model for transpm1ation conformity, etc. are set by the Interagency Consultation 

Committee, which is made up of local, 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 of this 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 of this 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 of the 

three years of clean 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 of this Emission Inventory. The maintenance 

plan for the redesignation request will include a new Motor Vehicle Emission Budget that 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 Participation 
Arkansas Depatiment of Environmental Quality 

Public Notice 

The Arkansas Depatiment of Environmental 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 of Crittenden 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 of the 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 

nonattaimnent areas. 

On March 12, 2008, EPA lowered the 8-hour ozone NAAQS from 0.08 parts per million (ppm) 

to 0.075 ppm. Under the 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 of the patticular area's 

air pollution problem. Section 182(a)(l) of the CAAA requires states with nonattainment areas to 

submit a current, comprehensive and accurate inventory of ozone precursor emissions from all 

sources within two years of the effective date of designation. 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 of accuracy. In lieu of commenting 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 of inclement weather or other unforeseen circumstances, a decision may be made to 

postpone the hearing. If the hearing is postponed and rescheduled, a new legal notice will be 

published to announce the details of the new hearing date and comment period. 
Pending any comments received, Arkansas will submit this EI revision to the EPA. 

Copies of Arkansas'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 of the 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 of Environmental Quality 
Arkansas Democrat ·. . QVazette 

STATEMENT OF LEGAL ADVERTISING 

ADEQ 

5301 NORTHSHORE DR 

NORTH LITTLE ROCK AR 72118 

.l\TTN: 

DATE 02/16/1.5 

ACCT II: 1.844316 

STATE OF ARKANS.Z\S, 

COUNTY OF PULASKI, 

Fiscal Office 

.INVOICE #: 2966873 

p .0. 41: 

ss. 

I, Annette Holcombe do solemnly swear that I am 

the Legal Billing Clerk of the Arkansas Democrat -

Gazette, a daily newspaper printed and published 

in said County, State of Arkansas; that I was so 

related to this publication at and during the 

publication of the annexed legal advertisement in 

the matter of: 

ADEQ 

pending in the Court, in said County, and 

at theda~ei ~f the several publications of said 

adver.tisement stated belO\.,, and that during ·.said 

periods and at said dates, said newspaper was 

printed and h~d a bona fide circulation in said 

County; that said newspaper had been regularly 

printed and published in said County, and had a 

bona fide circulation therein for the period of 

one month before the date of the first publication 

of said advertisement; and that said advertisement 

was·published in the regular daily issues of said 

newspaper as stated below. 

DATE DAY LINAGE RATE 

02/16 Mon 172 1.25 

TOTJI.L C6ST 

Billing Ad#: -,3030785 

DATE DAY LINAGE RATE 

21S.OO 

REMIT TO: 

ARKANSAS DEMOCRAT-GAZETTE, INC. 

P.o. nox 2221 

LITTLE ROCK, AR 72203 

BlLLING QUESTIONS CALL378-3812 

AD COPY 
Arkansas Democrat · 

STATEMENT OF LEGAL ADVERTISING 

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Speaker # (Attached or tack of card) 

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A R K A N S A S Otplrtrntnt of Environmental Quality 

www.adeq.state.ar.us 
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 of the 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. I have 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 last three years, 2012, 2013, 2014, we are in attainment based on the three 

year average, 8 hour average. We have been working with ADEQ, with the understanding 

that they are pushing forward with the request for redesignation to EPA. I know this is 

related to inventory but I just want to go on record that though this is a 2011 inventory and 

it is based on older data perhaps, I wanted to say that because of the vehicle emissions 

that's related to types of vehicles on the road in our area, that in the past using defaults 

have created a budget that is less than if we 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 rather than actual numbers; these are based on actual 

numbers. I'd like to present these to ya'll as part of the 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 of NOx that is the biggest area of concern versus the 6 point 

something tons you are showing in the inventory. We realize you are working on this, we 

just want to make sure this is pushed forward. I want to also say that when we get the 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 correct temperatures, and so forth that goes 

into the modelling. I know ya'll are aware of that, we need to use real numbers. That was 

our main concern. 

The other thing was just 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 I know of today, 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 the 
numbers but we have not been 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 I have 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 present that to 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 get the budget in time to show conformity in time for 

our next update for the long range transportation plan. 

I know that the budget issues and these are somewhat different, but I just want to be sure 

that the 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 budget that we really need 

to actually use the real numbers. I know you are all aware ofthat, but I want to just 

reinforce that we are in a hurry on that. The inventory get that done as soon as you can I 

guess but the biggest issue locally is the nonattainment designation and getting that 

changed as quickly as possible. That is all I have to say."