UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

ATLANTAFEDERALCENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

JUN 2 9 2004 

Honorable Ernie Fletcher 

Governor of Kentucky 

State Capitol 

700 Capitol Avenue 

Frankfort, KY 40601 

Dear Governor Fletcher: 

Fine-particle pollution represents one of the most significant barriers to clean air facing 

our nation today. These tiny particles - about l/30th the diameter of a human hair - have been 

scientifically linked to serious human health problems. Their ability to be suspended in air for 

long periods of time makes them a public health threat far beyond the source of emissions. An 

important part of our nation's commitment to clean, healthy air deals with reducing levels of this 

fine particle or PM2.5 pollution. 

In February, your State submitted its recommended boundaries for PM2.5 attainment and 

nonattainment areas. We have thoroughly reviewed your recommendations and the technical 

information you have submitted to support your recommendations. We appreciate the effort your 

State has made to develop this supporting information. Consistent with the Clean Air Act, this 

letter is to notify you that based on the information contained in your submittal, EPA intends to 

make modifications to recommended designations and boundaries in your State. 

The detailed enclosure contains a description of areas where EPA intends to modify your 

State recommendations, and the basis for such modification. Should you have additional 

information that you wish to be considered by EPA in this process, we request that you provide it 

to us by September 1. 

You will hear from us again in November when EPA takes the final step in the PM2.5 

designation process and determines those areas that are in attainment and meet the fine particle 

standards and those areas that do not meet them. For areas in attainment, the challenge will be 

not only to maintain, but also to continue the progress you have made toward clean air. It is a 

commitment to no backsliding in your State's clean air status for fine particles. EPA will also 

issue a proposed fine particle implementation rule prior to final designations, which will allow 

you to proceed with planning to achieve clean air. 

The Bush Administration is addressing fine particle pollution with a comprehensive 

national clean air strategy. This strategy includes EPA's recent rule to reduce pollution from 

nonroad diesel engines, and the proposed rule to reduce pollution from power plants in the 

Internet Address (URL) http://www.epa.gov 

Recycled/Recyclable Plinted with Vegetable Oil Based Inks on Recyded Paper (Minimum 30% Postconsumer) 
eastern U.S. These two rules are important components of EPA's efforts to help States and 

localities meet the more protective national fine-particle and 8-hour ozone air quality standards. 

Together these rules will help all areas of the country achieve cleaner air. 

Should you or your staff have any questions, I invite you to contact Beverly H. Banister, 

Director, Air Pesticides and Toxics Management Division, at 4041562-9077, or Kay T. Prince, 

Chief, Air Planning Branch, at 4041562-9026. We look forward to a continued dialogue with you 

as we work together to implement the PM2.5 standards. 

Sincerely, s4 . I. Palmer, Jr. 

Regional Administrator 

Enclosure 

cc: LaJuana Wilcher, KYDEP 

John Lyons, KYDEP 

Art Williams, Jefferson County 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

ATLANTAFEDERALCENTER 

61 FORSYTH STREET 

ATLANTA, GEORG lA 30303-8960 

LaJuana Wilcher, Secretary 

Environmental and Public 

Protection Cabinet 

Capital Plaza Tower, 5Ih Floor 

Frankfort, KY 4060 1 

Dear Ms. Wilcher: 

Fine-particle pollution represents one of the most significant barriers to clean air facing 

our nation today. These tiny particles - about 1 /30ththe diameter of a human hair - have been 

scientifically linked to serious human health problems. Their ability to be suspended in air for 

long periods of time makes them a public health threat far beyond the source of emissions. An 

important part of our nation's commitment to clean, healthy air deals with reducing levels of this 

fine particle or PM2.5 pollution. 

In February, your State submitted its recommended boundaries for PM2.5 attainment and 

nonattainment areas. We have thoroughly reviewed your recommendations and the technical 

information you have submitted to support your recommendations. We appreciate the effort your 

State has made to develop this supporting information. Consistent with the Clean Air Act, this 

letter is to notify you that based on the information contained in your submittal, EPA intends to 

make modifications to recommended designations and boundaries in your State. 

Your Governor was sent a letter today notifying him that EPA is modifying the State's 

recommendation. This letter contains a more detailed enclosure containing a description of areas 

where EPA intends to modify your State recommendations, and the basis for such modification. 

Should you have additional information that you wish to be considered by EPA in this process, 

we request that you provide it to us by September 1,2004. 

You will hear from us again in November when EPA takes the final step in the PM2.5 

designation process and determines those areas that are in attainment and meet the fine particle 

standards and those areas that do not meet them. For areas in attainment, the challenge will be 

not only to maintain, but also to continue the progress you have made toward clean air. It is a 

commitment to no backsliding in your State's clean air status for fine particles. EPA will also 

issue a proposed fine particle implementation rule prior to final designations, which will allow 

you to proceed with planning to achieve clean air. 

The Bush Administration is addressing fine particle pollution with a comprehensive 

national clean air strategy. This strategy includes EPA's recent rule to reduce pollution from 

Internet Address (URL) http://www.epa.gov 

RecycledlRecyclable Printed with Vegetable Oil Based Inks on Recyded Paper (Mlnimum 30% Postconsumer) 
nonroad diesel engines, and the proposed rule to reduce pollution from power plants in the 

eastern U.S. These two rules are important components of EPA's efforts to help States and 

localities meet the more protective national fine-particle and 8-hour ozone air quality standards. 

Together these rules will help all areas of the country achieve cleaner air. 

Should you or your staff have any questions, I invite you to contact Beverly H. Banister, 

Director, Air, Pesticides and Toxics Management Division, at 4041562-9077, or Kay T. Prince, 

Chief, Air Planning Branch, at 4041.562-9026. We look forward to a continued dialogue with you 

as we work together to implement the PM2.5 standards. 

Sincerely, 

Regional Administrator 

Enclosure 

cc: John Lyons, KYDEP 

Art Williams, Jefferson County 
Enclosure for 120 Day Letter 

Justification for Modification to State Recommendations 

PM2.5 Nonattainment Areas 

Commonwealth of Kentucky 

An Explanation of EPA9s 9-Factor Analysis: 

Factor 1. Emissions in areas potentially included versus excluded from the nonattainment 

area: 

The analysis for factor I looks at emissions of carbonaceous particles ("'carbon'?, 

inorganic particles ("crustal '7, SO2 , and NOx. EPA computed a composite emission 

score for each county by multiplying the county's emissions as a fraction of the 

metropolitan area emissions for each of these pollutants times a corresponding air 

quality weighting factor. The air quality weighting factors for each area are given below 

and reflect the percentages of the total estimated "urban excess" value found as, 

respectively, carbonaceous particles, miscellaneous inorganic particles ("'crustal 

material1% ammonium sulfate, and ammonium nitrate. These scores add to 100 for the 

metropolitan area counties. Composite scores were also calculated for counties adjacent 

to the metropolitan area. Tables presented under factor I present the emissions of 

carbonaceous particles, inorganic particles, SO2 , and NOx and the composite emission 

scores for the counties in the corresponding metropolitan area and adjacent counties. 

Metropolitan area counties are in bold. Emissions data indicate the potential for a 

county to contribute to observed violations, ojen making the emissions data the most 

important factor in assessing boundaries of nonattainment areas. 

"Urban excess" values are derived by comparing urban monitored component 

concentrations against rural monitored component concentrations. Concentrations of 

the four PM2.5 components are obtainedfrom local data if available (or, ifnecessary, 

from the nearest available urban site), and are compared to available rural 

concentrations. The monitoring sites used for this purpose are identified below. 

Although this information is air quality information, it is presented under Factor 1 due to 

its integration into the analysis of emissions information. 

Factor 2. Air quality in potentially included versus excluded areas: 

The air quality analysis looks at the annual averaged design value for each area based 

on data for 2001 to 2003. 

Factor 3. Population density and degree of urbanization including commercial 

development in included versus excluded areas: 

Tables presented under factor 3 show the 2003 population for each metropolitan area, as 

well as the population density for each county in that area. Population data indicate the 

likelihood ofpopulation-based emissions that might contribute to violations. 
Factor 4. Traffic and commuting patterns: 

The traffic and commuting analysis looks at the number of commuters in each county 

who drive to another county within the metropolitan area ("Number"), the percent of 

total commuters in each county who commute to other counties within the metropolitan 

area ((percent '7 *, as well as the total Vehicle Miles Traveled (VMT) for each county in 

thousands of miles. A county with numerous commuters is generally an integral part of 

the area, and would be an appropriate part of the domain of some mobile source 

strategies, thus warranting inclusion in the nonattainment area. 

*Note that the percent of commuters traveling to counties within the metropolitan area is 

based on the total number of commutersfrom that county. This total includes commuters 

who may travel outside the metropolitan area from their county of origin. 

Factor 5. Expected growth: 

The expected growth analysis looks at the percent growth for counties in each 

metropolitan area from 1990 to 2000. 

Factor 6. Meteorology: 

The meteorology analysis looks at wind data gathered over a ten year period by the 

National Weather Service. Tables presented under factor 6 list the year round average 

prevailing wind directions by quadrant for each county in the corresponding 

metropolitan area. These data show that annual average PM2.5 concentrations are 

influenced by emissions in any direction at various times, but these data may also suggesi 

that emissions in some directions relative to the violation may be more prone to 

contribute than emissions in other directions. 

 actor 7. Geographyltopography: 

The geographyhopography analysis looks at physical features of the land that might have 

an effect on the airshed, and therefore, the distribution ofparticulate matter over an 

area. The Commonwealth has no such features that significantly influenced EPA 's 

recommended nonattainment areas. 

Factor 8. Jurisdictional boundaries: 

The analysis ofjurisdictional boundaries looks at the planning and organizational 

structure of an area to determine ifthe implementation of controls in a potential 

nonattainment area can be carried out in a cohesive manner. 

Factor 9. Level of control of emission sources: 

The level of control analysis looks at what controls are currently implemented in each 
area. 

PM 2.5 Nine Factor Analysis for 

Cincinnati-Hamilton OH-MY-IN MSA 

The MSA contains the Kentucky Counties of Boone, Campbell, Kenton, Grant, 

Pendleton, Gallatin; the Ohio Counties of Hamilton, Clermont, Butler, Warren, Brown; 

and the Indiana Counties of Dearborn and Ohio. 

The following counties are violating the PM2.5 standard: Hamilton County, Ohio; Butler 

County, Ohio; and Montgomery County, Ohio. 

In February 2004, Kentucky recommended that all Kentucky counties in the CincinnatiHamilton MSA be designated attainment for the PM2.5 standard. EPA is modifying 

Kentucky's recommendation to include Boone, Campbell and Kenton Counties in the 

Cincinnati-Hamilton nonattainment area. Boone County has significant emissions, 

relatively high population growth, and a large (>10,000 tons per year S02) power plant 

located in the County. Campbell and Kenton Counties have significant VMT, significant 

numbers of commuters into violating Hamilton County, and both counties part of the 

Cincinnati 1 -hour ozone nonattainment area due to violating monitors. Kenton County 

also has monitoring data close to the standard. EPA agrees that the remaining KY MSA 

counties of Gallatin, Grant, and Pendleton should be designated as 

attainment/unclassifiable due to low emissions, very low population relative to the area, 

and very low numbers of commuters into the violating counties. 

EPA agrees that the adjacent counties of Carroll and Mason should be designated 

attainment/classifiable for the PM2.5 standard, although they have significant emissions 

due to power plants. These counties have relatively low populations, low population 

growth, and low VMT . Further, their commuting patterns and distance from the 

violating monitors indicate that these counties do not contribute to the violations in the 

area. The other adjacent counties do not contribute and therefore, will be designated as 

attainmenthnclassifiable. 

Factor 1 : Emissions in areas potentially included versus excluded from the 

Area 

Cincinnati-Hamilton, 

OH-KY-IN 

The following is a brief summary of the nine criteria for the Cincinnati-Hamilton, OHKY-IN area. These analyses were based on existing available data. 

EPA Recommendation 

Full counties: 

Boone County 

Campbell County 

Kenton County 

State Recommendation 

Full counties: 

none 
nonattainment area 

The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in 

tons and weighted emissions scores for the counties in the Cincinnati-Hamilton MSA and 

surrounding counties. (MSA counties are in bold; Kentucky MSA counties in bold 

italics.) 

County Amrn I Score I Cum. * Score I 

Hamilton, OH 1 7,601 

I 

Clermont, OH ) 6,443 TGG&FpK 

Butler, OH 3,153 

Boone, KY 1 1,946 

Warren, OH 1 1,844 

Kenfon, KY 1 741 I 

Campbell, KY 1 590 

I 

Brown, OH 1 748 

I 

Grant, KY 1 381 

Pendleton, KY 1 363 

Gallatin, KY 367 

Montgomery, 12.542 

Carroll, KY 1 3,547 

Mason, KY 1 2,3 16 

Greene, OH 1 1,5 16 

Preble, OH 1 963 

Ripley, IN 1 743 

310 NIA 

I 

Scott, KY 1 627 

I 

Fayette, OH 1 883 

Decatur, IN 1 X!: 

Clinton, OH 

Rush, IN 1,003 
I I I I I I I 

Based on the analysis for this factor for Kentucky only, Boone, Carroll, and Mason 

Counties have significant emissions which could indicate a potential emissions 

contribution to the PM2.5 violations in the area. This factor is not significant for the 

remaining Kentucky counties listed in this table. 

Owen, KY 1 236 

Switzerland, IN 

Bracken, IN 

Union, IN 

Robertson, KY 

Factor 2: Air quality in wotentiallv included versus excluded areas 

57 1 572 1 566 1 245 ( 1.1 1 N/ A 

The following table contains the design value for the MSA and adjacent counties that 

contain PM2.5 monitors. Design values followed by "a" indicate that the value is based 

on incomplete monitoring data. (MSA counties are in bold; Kentucky MSA counties in 

bold italics.) 

257 

174 

343 

74 

I Hamilton, OH I 17.8 I 

25 B 

52 

58 

12 

County 200 1 -2003 design value 

I Kenton, KY I 15.0 I 

1,554 

570 

548 

112 

I 

1 Campbell, KY I 14.5 I 

Butler, OH 

Montgomery, OH 

Greene, OH 

Preble, OH 13.5a 

776 

479 

705 

107 

16.2 

Based on an analysis of this factor for Kentucky only, the Campbell and Kenton County 

monitors are attaining. The Kenton County monitor reading of 15.0 indicates that there 

may be a potential emissions contribution from the County to the area. This factor is not 

significant for the remaining Kentucky counties. 

Factor 3: Population densitv and degree of urbanization including commercial 

development in included versus excluded areas 

364 

134 

266 

65 

1 .O 

0.7 

0.6 

0.3 

NIA 

N/ A 

N/ A 

N/ A 
The following table has the populations for the counties in the Cincinnati-Hamilton MSA 

and some adjacent counties with violating monitors and those with significant emissions. 

The total MSA 2002 population is 2,009,679. (MSA counties are in bold; Kentucky 

MSA counties in bold italics.) 

County 

Hamilton, OH 

Clermont, OH 

I I I 

Boone, KY / 93,290 4.64 1 379 ( 

Dearborn, IN 

Butler, OH 

2002 Population 

833,721 

183,352 

47,333 

340,543 

I I I 

Percent of 

Population of MSA 

41.49 

9.12 

Warren, OH 1 175,133 

I I I 

2002 Population 

Density 

2,048 

406 

2.36 

16.95 

8.71 1 438 

Kenton, KY 1 152,164 

I I I 

155 

729 

7.57 1 934 

Campbell, KY 1 88,604 

I I I 

4.41 / 583 

Brown, OH 1 43,464 

I I I 

Ohio, IN 1 5,804 I 0.29 1 67 I 

2.16 1 88 

Grant, KY 1 23,620 

1 I I 

Adams, OH 1 27,804 I I 48 1 

1.18 I 91 

Pendleton, KY I 14,815 

Based on the analysis for this factor, the populations for the Kentucky counties are much 

smaller than those in the Ohio Counties of Hamilton, Butler, and Montgomery. The 

Kentucky Counties of Boone, Kenton, and Campbell have population values of some 

significance as compared to the much smaller MSA Kentucky Counties of Grant, 

Gallatin, and Pendleton. This factor is not significant for the remaining Kentucky 

counties in this table. 

0.74 

Montgomery, OH 

Carroll, KY 

Mason, KY 

Factor 4: Traffic and commuting patterns 

53 

Commuting Information 

554,470 

10,223 

16,916 

1,200 

79 

7 0 
Total number of workers in Boone County, KY: 44,507 

Commuters in Boone County, KY who work in Boone County, KY: 23,589 (53%) 

Commuters from Boone County, KY to Hamilton County, OH: 8,35 1 (1 9%) 

Commuters fiom Boone County, KY to Butler County, OH: 641 (1%) 

Total number of workers in Kenton County, KY: 76,169 

Commuters in Kenton County, KY who work in Kenton County, KY: 30,771 (40%) 

Commuters from Kenton County, KY to Boone County, KY: 17,053 (22%) 

Commuters from Kenton County, KY to Hamilton County, OH: 20,200 (27%) 

Commuters fiom Kenton County, KY to Butler County, OH: 908 (1%) 

Total number of workers in Campbell County, KY: 42,820 

Commuters in Campbell County, KY who work in Campbell County, KY: 15,474 (36%) 

Commuters fiom Campbell County, KY to Boone County, KY: 4,062 (9%) 

Commuters from Campbell County, KY to Hamilton County, OH: 14,946 (35%) 

Commuters from Campbell County, KY to Butler County, OH: 652 (2%) 

Total number of workers in Gallatin County, KY: 3,589 

Commuters in Gallatin County, KY who work in Gallatin County, KY: 1,3 17 (37%) 

Commuters from Gallatin County, KY to Boone County, KY: 1,038 (29%) 

Commuters from Gallatin County, KY to Hamilton County, OH: 196 (5%) 

Total number of workers in Grant County, KY: 10,262 

Commuters in Grant County, KY who work in Grant County, KY: 4,18 1 (41 %) 

Commuters from Grant County, KY to Boone County, KY: 2,852 (28%) 

Commuters fiom Grant County, KY to Hamilton County, OH: 7 16 (7%) 

Total number of workers in Pendleton County, KY: 6,467 

Commuters in Pendleton County, KY who work in Pendleton County, KY: 2,482 (38%) 

Commuters from Pendleton County, KY to Boone County, KY: 789 (12%) 

Commuters from Pendleton County, KY to Hamilton County, OH: 785 (12%) 

Commuters fiom Pendleton County, KY to Butler County, OH: 101 (2%) 

Total number of workers in Carroll County, KY: 4,466 

Commuters in Carroll County, KY who work in Carroll County, KY: 3,475 (78%) 

Commuters from Carroll County, KY to Boone County, KY: 54 (1%) 

Commuters from Carroll County, KY to Hamilton County, OH: 48 (1%) 

Total number of workers in Mason County, KY: 7,560 

Commuters in Boone County, KY who work in Boone County, KY: 5,978 (79%) 

Commuters from Mason County, KY to Hamilton County, OH: 95 (1 %) 

A notable number of commuters from Kenton and Campbell Counties commute into 

violating Hamilton County. Although these numbers are far less than the number of 
commuters in Hamilton County, in conjunction with VMT data analyzed below, they 

indicate some potential for contributing to the mobile source emissions in the area. 

Although 47% of Boone's 44,507 workers commute into other counties in the MSA, a 

relatively small number commute into the violating counties. In Carroll County, 78% of 

the 4,466 workers commute within the County. Similarly, in Mason County, 79% of the 

7,560 workers commute within the County. Thus, onroad mobile source emissions from 

commuting patterns for Boone, Carroll, and Mason Counties do not appear to be 

contributing to violations in the area. This factor is not significant for the remaining 

Kentucky counties listed above. 

Vehicle Miles Traveled: 

The following table has the vehicle miles traveled (thousand miles) for the counties in the 

Cincinnati-Hamilton MSA and some adjacent counties with significant emissions. (MSA 

counties are in bold; Kentucky MSA counties in bold italics.) 

County 

Hamilton, OH 

Clermont, OH 

I 

Boone, KY 1 842 

2002 VMT 

(thousand mileslyear) 

8,420 

1,649 

Dearborn, IN 

Butler, OH 

I 

Warren, OH 1 1,354 

607 

2,610 

I 

Kenton, KY 1 1,816 

I 

Campbell, KY 1 1,097 

I 

Brown, OH 1 417 

I 

Grant, KY 1 379 

I 

Ohio, IN 1 56 

Pendleton, KY 

Gallatin, KY 

I 

Adams, OH 1 283 

169 

254 

I 

Montgomery, OH 1 5,668 

Carroll, KY 

Mason, KY 

213 

178 
Based on an analysis of this factor for Kentucky only, the VMT for Boone, Kenton, and 

Campbell Counties are in the relatively moderate to high range as compared to the 

counties listed above, with the exception of the the violating Ohio counties of Hamilton, 

Butler, and Montgomery. Boone, Kenton, and Campbell VMT data indicate some 

potential to contribute to the PM2.5 violations in the area. VMT values for Carroll and 

Mason are very low and do not indicate a potential contribution. This factor is not 

significant for the remaining Kentucky counties listed in this table. 

Factor 5: Expected growth 

The following table has the population and population growth figures for the CincinnatiHamilton MSA and some adjacent counties with significant emissions. (MSA counties 

are in bold; Kentucky MSA counties in bold italics.) 

County 

Hamilton, OH I I I 

2002 

Population 

833,721 

Clermont, OH 1 183,352 

Dearborn, IN 

Butler, OH 

Boone, KY 

Warren, OH 

Kenton, KY 

Campbell, KY 

Brown, OH 

Grant, KY 

27,790 1 19 

Pendleton, KY 

Gallatin, K Y 

growth 

(90-00) 

-20,925 

47,333 

340,543 

93,290 

175,133 

152,164 

88,604 

43,464 

23,620 

I I I 

% growth 

(90-00) 

-2 

14,815 

7,836 

Ohio, IN 1 5,804 

I I I 

7,274 

41,328 

28,402 

44,474 

9,433 

4,750 

7,319 

6,647 

308 1 6 

Adams, OH 1 27,804 

I I I 

Mason, KY 1 16,916 1 134 1 1 

19 

14 

49 

39 

7 

6 

21 

42 

2,354 

2,477 

1,959 1 8 

Montgomery, OH / 554,470 

Carroll, KY 1 10,223 

While the Kentucky Counties of Boone, Grant, and Gallatin have the highest population 

growth rates from 1990-2000 than all of the counties in the MSA, only Boone County's 

resulting population increase of 28,402, (third highest increase in the MSA), is significant 

enough to indicate a potential to contribute to violations in the area. The population 

20 

46 

-14,747 1 -3 

863 1 9 
growth rates of Carroll and Mason Counties are relatively very low and thus, do not 

indicate a potential to contribute to the area's violations. This factor is not significant for 

the remaining Kentucky counties listed in this table. 

The following meteorological information was provided by Kentucky for the MSA 

Kentucky Counties of Boone, Campbell, Kenton, Gallatin, Pendleton, and Grant. (The 

figure referenced is a wind rose for April 1 -October 3 1 for the 1988-1 992 period that is 

provided in Kentucky's PM2.5 recommendations submittal.) 

Meteorological Information 

"Due to the close proximity of Cincinnati, Ohio, meteorological data from Cincinnati was 

used for this Kentucky area. Wind speedlwind direction information shows that the 

majority of the time for the period 1988-1992, the wind in the ... County area came from 

the southwest and typically from 7- 10 knots. (See figure 1 -A) The mean high temperature 

for July for the area from 1961 through 1990 was 86" F, the mean low was 66" F. The 

mean precipitation for the same period was 3.8 inches." (Source: Kentucky PM2.5 

submittal) 

Based on an analysis of this factor, the information provided is not sufficient to provide a 

compelling argument to exclude counties based on prevailing winds. This information 

was provided only for the summertime winds. 

Factor 7: Geographvltopogravhy 

Based on an analysis of this factor, there are no significant topographical issues associated 

with this MSA. For the adjacent Carroll and Mason Counties in Kentucky with significant 

emissions, both counties are two counties removed from the nearest county with a 

violating monitor (Hamilton, Ohio), with attaining monitors inbetween in Kenton and 

Campbell Counties in Kentucky. 

Factor 8: Jurisdictional boundaries 

The following MSA counties were designated nonattainrnent for the 8-hour ozone 

standard on April 15,2004: the Kentucky Counties of Boone, Campbell, and Kenton; the 

Indiana County of Dearborn; and the Ohio Counties of Hamilton, Clermont, Butler, 

Warren, Montgomery, Greene, Clinton. This factor did not play a significant role in the 

decision-making process. 

Factor 9: Level of control of emission sources 

The following information was provided by Kentucky for Boone, Campbell, Kenton, 

Grant, Gallatin and Pendleton Counties. 
"Point sources located within.. . County are subject to PSD requirements, CTG 

RACT requirements, Maximum Achievable Control Technology (UACT) 

requirements for sources of Hazardous Air Pollutants, and New Source 

Performance Standards (NSPS). Any controls imposed as a result ofprevious 

nonattainment designations are required to remain in ... County. " 

For Boone County only: 

"Additionally, substantial NOx reductions have occurred during the last year from 

East Bend Power Plant which would further lower the contribution of NOx 

emissi~ns from Boone County." 

This factor did not play a significant role in the decision-making process. 
PM 2.5 Nine Factor Analysis for Louisville, KY-IN MSA 

The Louisville MSA contains the Kentucky Counties of Jefferson, Bullitt, and Oldham; 

and the Indiana Counties of Floyd, Clark, Harrison, and Scott. Jefferson County, 

Kentucky and Clark County, Indiana are violating the PM2.5 standard. The adjacent 

Kentucky County of Carroll has relatively high emissions for the area, however, it was 

evaluated as part of the Cincinnati area. 

In February 2004, Kentucky recommended that Jefferson County be designated 

nonattainment and that Bullitt and Oldham Counties be designated attainment for the 

PM2.5 standard for the Louisville MSA. 

EPA agrees that the Kentucky MSA County of Oldharn be designated 

attainmenthnclassifiable due to low emissions and relatively low population. EPA agrees 

that Jefferson County be designated nonattainment due to four violating monitors in the 

County and is modifying Kentucky's recommendation to include Bullitt County in the 

Louisville nonattainment area due to a relatively high number of commuters into violating 

Jefferson County, a monitored PM2.5 value of 15.0 that is very close to the standard, and 

relatively high population growth. 

EPA agrees that the adjacent counties should be designated as attainment/unclassifiable 

due to low population growth, a low percentage of workers commuting into the Louisville 

MSA, relatively low emissions, and large distance from the violating monitors in the area. 

The following is a brief summary of the nine criteria for the Louisville, KY area. 

These analyses were based on existing available data. 

Area 

Louisville, KY 

Factor 1: Emissions in areas potentiallv included versus excluded from 

the nonattainment area 

EPA Recommendation for KY 

Full counties: 

Jefferson County 

Bullitt County 

The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in 

tons and weighted emissions scores for the counties in the Louisville MSA and 

surrounding counties. (MSA counties are in bold; Kentucky MSA counties in bold 

italics.) 

State Recommendation 

Full counties: 

Jefferson 
County 

Jefferson, KY 

Floyd, IN 

Clark, IN 

Bullitt, KY 

Harrison, IN 

Oldham, KY 

Scott, IN 

Carroll, KY 

Jefferson, IN 

Hardin, KY 

Lawrence, IN 

Jackson, IN 

Nelson, KY 

Trimble, KY 

Breckinridge, 

KY 

Grayson, KY 

Meade, KY 

Shelby, KY 

Franklin, KY 

Jennings, IN 

Hart, KY 

Washington, 

IN 

PM I Sox 1 NQx I VQC ( Arnm I Score 1 Cum. 

Score 

7,385 62,526 81,398 55,376 1,539 51.5 51.5 

, 

Taylor, KY 408 632 3,642 1,609 46 1 3.1 

Crawford, IN 3 19 536 3,842 1,237 192 2.9 

Orange, IN 475 86 2,017 2,599 313 2.9 

Anderson, 335 443 1,535 2,648 164 2.5 

KY 
Based on the analysis for this factor for Kentucky only, the Kentucky Counties of 

Jefferson and Carroll have significant emissions. Bullitt County has emissions with a 

potential to contribute to the PM2.5 violations in the area. This factor is not significant for 

the remaining Kentucky counties listed in this table. 

Factor 2: Air quality in potentially included versus excluded areas 

County 

Jefferson, KY 

I 

Clark, IN 16.2 1 

200 1-2003 design value 

16.9 I 

I 

Bullitt, KY 15.0 1 

Floyd, IN 14.9 

I 1 Hardin, KY 14.1 

I 

There are four counties in the MSA with PM2.5 monitors, two of which have violating 

design values (Jefferson County, Kentucky and Clark, Indiana). Bullitt County, Kentucky 

has an attaining monitor whose design value is close to the standard (1 5.0), which 

indicates that there is a potential to contribute to the PM2.5 violations in area. The 

adjacent Kentucky Counties of Hardin and Franklin are monitoring attainment and thus, 

do not indicate emissions contributions. This factor is not significant for the remaining 

Kentucky counties listed in this table. 

Franklin, KY 

Factor 3: Population density and de~ree of urbanization including 

commercial development in included versus excluded areas 

13.6 

The following table has the populations for the counties in the Louisville MSA and 

adjacent counties with significant emissions. The total MSA 2002 population is 
1,039,599. (MSA counties are in bold; Kentucky MSA counties are in bold italics.) 

I Hardin, KY I 95,724 I N/A I 152 

Scott, IN 1 23,334 

Based on the analysis for this factor for Kentucky only, Jefferson County's population of 

698,080 is approximately 6-30 times higher than all the other MSA counties. Hardin 

County's population is the third largest of the counties analyzed, however, it is still 

relatively insignificant in comparison to Jefferson County's population. Thus, this factor 

is not significant for the Kentucky counties listed in this table with the exception of 

Jefferson County. 

2.24 1 123 

Factor 4: Traffic and commutinp gatterns 

Commuting Information 

Total number of workers in Jefferson County, KY: 329,091 

Commuters in Jefferson County, KY who work in Jefferson County, KY: 303,624 (92%) 

Commuters from Jefferson County, KY to Clark County, IN: 7,047 (2%) 

Total number of workers in Bullitt County, KY: 30,648 

Commuters in Bullitt County, KY who work in Bullitt County, KY: 8,419 (27%) 

Commuters from Bullitt County, KY to Jefferson County, KY: 19,730 (64%) 

Commuters from Bullitt County, KY to Clark County, IN: 41 8 (1%) 

Total number of workers in Oldham County, KY: 27,7 16 

Commuters in Oldham County, KY who work in Oldham County, KY: 7,207 (33%) 

Commuters from Oldham County, KY to Jefferson County, KY: 12,684 (58%) 

Commuters from Oldham County, KY to Clark County, IN: 326 (1 %) 
Total number of workers in Hardin County, KY: 44,8 15 

Commuters in Hardin County, KY who work in Hardin County, KY: 36,030 (80%) 

Commuters from Hardin County, KY to Jefferson County, KY: 5,347 (12%) 

Based on the commuting data for the Kentucky counties listed above, there appears to be 

potentially significant on-road mobile source emissions contributions from Bullitt and 

Oldham to Jefferson County, which has over 300,000 resident commuters. A large 

percent (78%-80%) of the workers in Carroll and Hardin Counties, respectively, commute 

within their resident counties. Thus, with the exception of Bullitt, Jefferson, and Oldham 

Counties, this factor is not significant for the remaining Kentucky counties listed above. 

Vehicle Miles Traveled NMT): 

The following table has the vehicle miles traveled (thousand miles) for the counties in the 

Louisville MSA and the adjacent county of Hardin due to its relatively high VMT and 

population. (MSA counties are in bold; Kentucky MSA counties are in bold italics.) 

Floyd, IN 1 843 

County 

Jefferson, KY 

2002 VMT 

(thousand mileslyear) 

7,149 

Based on the analysis for this factor, the VMT for Jefferson County far exceeds the 

Clark, IN 

Bullitt, KY 

Harrison, IN 

Oldham, KY 

Scott, IN 

Hardin, KY 

VMT 

1,262 

849 

528 

50 7 

364 

1,333 

of the MSA and surrounding counties. Although Hardin County has a relatively high 

VMT, 80% of its workers commute within the County, with an additional 12% 

commuting into Jefferson County, Kentucky. Based on the analysis for this factor, Hardin 

County does not appear to significantly contribute on-road mobile source emissions to 

Jefferson County. Thus, with the exception of Jefferson County, this factor is not 

significant for the remaining Kentucky counties listed in this table. 

Factor 5: Ex~ected prowth 

The following table has the population and population growth figures for the Louisville 

MSA and the adjacent Hardin County due to its relatively high VMT and population. 
(MSA counties are in bold; Kentucky MSA counties are in boM italics.) 

County 

Jefferson, KY 

Floyd, IN 

Clark, IN 

Bullitt, KY 

Harrison, IN 1 35,244 

Hardin, KY 1 95,724 I 4,934 1 6 

2002 Population 

698,080 

71,633 

98,198 

63,800 

4,435 1 15 

Oldham, KY 

Scott, IN 

Based on the analysis for this factor for Kentucky only, the population growth in Bullitt 

and Oldham Counties indicate that these counties may contribute to the PM2.5 issues in 

Jefferson County. Although Jefferson County's growth rate is fairly low, the magnitude 

of its population increase is the highest in the MSA and is approximately twice that of the 

increases in Bullitt and Oldham. Although Hardin County's population is the third largest 

of the counties analyzed above, its population growth is relatively low.Thus, with the 

exception of Bullitt, Jefferson, and Oldham Counties, this factor is not significant for the 

remaining Kentucky counties listed in this table. 

Factor 6: Meteorolo~v 

growth 

(90-00) 

28,667 

6,419 

8,695 

13,669 

49,310 

23,334 

The following meteorological information was provided by Kentucky for Jefferson, 

Bullitt, and Oldham. 

% growth 

(90-00) 

4 

10 

10 

29 

Wind speedwind direction information shows that the majority of the time for the period 

1988-1992, the wind in the ... County area came from the south southwest and typically at 

7-10 knots. The mean high temperature for July for the area from 1961 through 1990 was 

87" F and the mean low was 70" F. The mean precipitation for the same period was 4.3 

inches. 

12,915 

1,969 

The information provided is not sufficient to provide a compelling argument to exclude 

counties based on prevailing winds. The information provided was based only on 

summertime winds. 

39 

9 

Factor 7: Geoyraphvltopo~raphv 

Based on an analysis of this factor, there are no significant geographical or topographical 

issues associated with this MSA. boundary. 
Factor 8: .lurisdictional boundaries 

The following MSA counties were designated nonattainment for the 8-hour ozone 

standard on April 15,2004: the Kentucky Counties of Jefferson, Bullitt, and Oldham; and 

the Indiana Counties of Floyd, Clark, and Jackson. This factor did not play a significant 

role in the decision-making process for these counties. 

Factor 9: Level of control of emission sources 

The following information was provided by Kentucky for Bullitt, Oldham, and Jefferson 

Counties: "Point sources located within ... County are subject to Prevention of Significant 

Deterioration (PSD) requirements, Control Technology Guidelines Reasonable Available 

Control Technology (CTG RACT) requirements, Maximum Achievable Control 

Technology (MACT) requirements for sources of Hazardous Air Pollutants (HAP), and 

New Source Performance Standards (NSPS)." This factor did not play a significant role 

in the decision-making process for these counties. 
PM2.5 Nine Factor Analysis for Lexington, KY MSA 

The Lexington MSA contains the Counties of Fayette, Bourbon, Clark, Jessamine, 

Madison, Scott, and Woodford. Fayette County is violating the PM2.5 standard. 

In February 2004, Kentucky recommended that Fayette County be designated attainment 

for the PM2.5 standard for the Lexington, KY MSA, and the remaining MSA counties be 

designated attainment. EPA agrees that Fayette County should be designated 

nonattainment for PM2.5 due to a violating monitor (South Limestone). EPA is 

modifying Kentucky's recommendation to include the MSA counties of Clark, Madson 

and Woodford and the adjacent county of Mercer in the Lexington nonattainment area. 

Clark and Madison Counties are included significant emissions. Madison County also has 

relatively high population and population growth, and relatively high VMT. Woodford 

County as nonattainment due to the level of emissions. We have included in our 

recommended nonattainment area Mercer County that is adjacent to the Lexington MSA 

with a violating monitor, that is generally rural in character, and that contains an 

identifiable large emitting facility (e.g., power plants) which we believe contributes to the 

nearby nonattainment problem. We have included this county in our initial 

recommendations in order to ensure that a sufficient portion of this county, including such 

a large facility, is included within the boundaries of the nonattainment area as part of the 

final designations. We invite you to submit to us a recommendation as to what portion 

of this adjacent county, encompassing the large facility, should be designated 

nonattainment. EPA agrees that the remaining MSA Counties of Bourbon, Jessamine, and 

Scott in Kentucky be designated attainment/unclassifiable due to their relatively low 

emissions, low populations, low VMT, low numbers of commuters into the violating 

counties, and small point sources. 

EPA agrees that the adjacent county of Pulaski should be designated 

attainmentklassifiable for the PM2.5 standard, although it has significant emissions due to 

a power plant. This county has relatively low population, low population growth, and low 

VMT . Further, the commuting patterns and distance from the violating monitors indicate 

that this county does not contribute to the violations in the area. The other adjacent 

counties do not contribute and therefore, will be designated as attainment/unclassifiable. 

The recommendations of EPA and Kentucky are summarized in the table below. 

Area 

Lexington, KY 

EPA Recommendation 

Full counties: 

Fayette County 

Clark County 

Madison County 

Mercer County 

Woodford County 

State Recommendation 

Full counties: 

Fayette 

Drop: 

Bourbon, Clark, Madison, 

Jessamine, W oodford and 

Scott Counties 
The following is a brief summary of the nine criteria for the Lexington, KY area. 

These analyses were based on existing available data. 

Factor 1: Emissions in areas ~otentiallv included versus excluded from 

the nonattainment area 

The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in 

tons and Weighted Emissions Scores for the counties in the Lexington MSA and 

surrounding counties. (MSA counties in Kentucky are in bold.) 

County 

Fayette (KY) 

Clark (KY) 

PM SOX 

Madison (KY) 

Woodford (KY) 

1703 

1132 

. , 

Scott (KY) 

Jessamine (KY) 

Bourbon (KY) 

NOx 

867 

559 

Mercer (KY) 

Pulaski (KY) " 

Based on the analysis for this factor, the following counties appear to have significant 

emissions (over 10,000 tons per year of any pollutant): Fayette, Mercer and Pulaski. 

Clark, Madison, and Woodford also have significant level of emissions. Although Pulaslu 

County This factor did not appear significant for the remaining counties listed in this 

table. 

3925 

9647 

627 

504 

444 

Laurel (KY) 

Nelson (KY) 

Factor 2: Air qualitv in potentially included versus excluded areas 

1189 

2663 

3136 

2403 

1 2001-2003 design value I 

VOC 

13620 

6622 

260 

323 

147 

770 

78 1 

Amm Score 

5512 

3530 

49269 

25156 

Based on the analysis for this factor, only Fayette County's South Lomestone monitoring 

data exceeds the standard. The Newtown Pike monitor, also in Fayette County, is 

attaining at 14.9. Madison County and the adjacent county of Laurel have monitors with 

readings well below the standard. This factor is not significant for the remaining counties 

listed in the area. 

Cum. 

Score 

15720 

2374 

3629 

2189 

1424 

1044 

497 

Fayette (KY) 

Madison (KY) 

Laurel (KY) 

4215 

2852 

9145 

10996 

15.7 

13.5 

12.6 

606 

398 

6041 

2436 

1352 

4564 

2134 

641 

427 

1686 

3901 

31.4 

25.7 

3823 

7923 

31.4 

57.1 

13.6 

9.5 

88.1 

95.7 

100.0 

481 

242 

597 

409 

877 

70.7 

80.2 

7.9 

7.6 

4.3 

439 

1147 

83.8 

56.8 

N/A 

N/ A 

14.6 

10.3 

N/A 

N/A 
Factor 3: Po~ulation densitv and de~ree of urbanization including 

commercial development in included versus excluded areas 

The following table has the populations for the counties in the Lexington MSA and 

adjacent counties with significant emissions. The total MSA 2002 population is 489,717. 

(MSA counties are in bold.) 

County 

Fayette (KY) 

Clark (KY) 

2002 

Population 

Madison (KY) 

Woodford (KY) 

263,618 

33,726 

Scott (KY) 

Jessamine (KY) 

Bourbon (KY) 

Mercer (KY) 

I Nelson (KY) 38,823 92 

Percent of Total 

MSA Population 

73,334 

23.403 

. , 

Fayette County's population is roughly 3-1 1 times higher than the other counties listed. 

Madison County has the second highest of the MSA counties and surrounding counties 

with significant weighted emissions scores. Based on an analysis of this factor, no other 

Kentucky counties, with the exception of Madison County, have populations significant to 

indicate a potential contribution to the PM2.5 violations in Fayette County. 

Population Density 

53.83 

6.89 

35,320 

40,740 

19,576 

2 1.047 

Laurel (KY) 

Factor 4: Traffic and cornrnutin~ patterns 

925 

133 

14.97 

4.78 

Commutine Information 

166 

123 

7.21 

8.32 

4.0 

54,313 

Total number of workers in Fayette County, KY: 136,793 

Commuters in Fayette County, KY who work in Fayette County, KY: 117,584 (86%) 

124 

235 

67 

84 

125 

Total number of workers in Bourbon County, KY: 9,103 

Commuters in Bourbon County, KY who work in Bourbon County, KY: 4,764 (52%) 

Commuters from Bourbon County, KY to Fayette County, KY: 2,600 (29%) 

Total number of workers in Clark County, KY: 15,487 

Commuters in Clark County, KY who work in Clark County, KY: 8,492 (55%) 

Commuters from Clark County, KY to Fayette County, KY: 4,777 (3 1 %) 

Total number of workers in Jessamine County, KY: 18,885 
Commuters in Jessamine County, KY who work in Jessamine County, KY: 8,721 (46%) 

Commuters from Jessamine County, KY to Fayette County, KY: 8,748 (46%) 

Total number of workers in Madison County, KY: 34,494 

Commuters in Madison County, KY who work in Madison County, KY: 24,061 (70%) 

Commuters from Madison County, KY to Fayette County, KY: 6,870 (20%) 

Total number of workers in Scott County, KY: 16,536 

Commuters in Scott County, KY who work in Scott County, KY: 10,148 (61%) 

Commuters from Scott County, KY to Fayette County, KY: 4,287 (26%) 

Total number of workers in Woodford County, KY: 12,377 

Commuters in Woodford County, KY who work in Woodford County, KY: 5,591 (45%) 

Commuters from Woodford County, KY to Fayette County, KY: 4,308 (35%) 

Total number of workers in Laurel County, KY: 2 1,180 

Commuters in Laurel County, KY who work in Laurel County, KY: 16,286 (77%) 

Total number of workers in Mercer County, KY: 9,610 

Commuters in Mercer County, KY who work in Mercer County, KY: 5,235 (54%) 

Commuters from Mercer County, KY to Fayette County, KY: 1,319 (14%) 

Total number of workers in Nelson County, KY: 17,594 

Commuters in Nelson County, KY who work in Nelson County, KY: 11,189 (64%) 

Madison County has the largest number of workers commuting into Fayette County 

(6,870 commuters), which is relatively insignificant for such a large county as Fayette. 

Laurel and Nelson County workers do not commute into the Lexington MSA at all. Based 

on the analysis for this factor, there are no counties with commuting data showing a 

potential to contribute to the PM2.5 violations in Fayette County. 

Vehicle Miles Traveled: 

The following table has the vehicle miles traveled (thousand miles) for the counties in the 

Lexington MSA and adjacent counties with significant emissions. (Kentucky MSA 

counties are in bold.) 

[ Clark (KY) 523 

County 

Favette (KY) 

2002 VMT 

2764 

. , I Scott (KY) 645 

Madison (KY) 

Woodford (KY) 

944 

311 

[ Jessamine (KY) 362 
Bourbon (KY) 

Mercer (KY) 

Fayette County's VMT is substantially higher than the other MSA counties. Although 

Madison and Laurel Counties have the second and third highest VMT of the counties 

analyzed, commuting data do not indicate significant (or any) contributions to Fayette 

County. Further, Laurel County is a significant distance from Fayette County and does 

not contribute to Fayette County through its commuting patterns. Based on the analysis 

for this factor, no other Kentucky counties, with the exception of Madison County, have 

VMT and commuting data with a potential to contribute to the PM2.5 violations in Fayette 

County. 

204 

224 

Laurel (KY) 

Nelson (KY) 

Factor 5: Expected ~rowth 

852 

427 

The following table has the population and population growth figures for the Lexington 

MSA and adjacent counties with significant emissions. (MSA counties are in bold.) 

County 

Fayette (KY) 

Clark (KY) 

2002 

Population 

Madison (KY) 

Woodford (KY) 

I Bourbon (KY) I 19576 1 124 1 1 I 

263618 

33726 

Scott (KY) 

Jessamine (KY) 

growth 

(90-00) 

73334 

23403 

I Nelson (KY) 38823 1 7,767 1 26 1 

% growth 

(90-00) 

35,146 

3,648 

35320 

40740 

Mercer (KY) 

Laurel (KY) 

Fayette County's population is substantially higher than the MSA counties and adjacent 

counties with significant weighted emissions scores, and grew the most during the 1990- 

2000 time period. Madison County is the third fastest growing county in the MSA based 

on a percent growth rate with the second largest population and the second largest 

population increase. Thus, Madison County's population growth is significant enough to 

contribute to PM2.5 violations in Fayette County. None of the other MSA and adjacent 

counties listed above have population characteristics which appear to be contributing to 

the PM2.5 violations in Fayette County. 

16 

12 

13,364 

3.253 

Factor 6: Meteorolo~v 

23 

16 

9,194 

8.533 

21047 

543 13 

39 

28 

1,669 

9,277 

9 

2 1 
The following meteorological information was provided by Kentucky. The figure 

referenced is a wind rose for April 1-October 3 1 for the 1988-1992 period that is provided 

in Kentucky's PM2.5 recommendations submittal. The text below is the same for Fayette, 

Bourbon, Clark, Jessamine, Scott, and Woodford Counties. 

"Wind speedlwind direction information shows that the majority of the time for 

the period 1988-1992, the wind in the ... County area came from the southwest and 

typically from 7-10 knots. (See figure 1-A) The mean high temperature for July 

for the area from 1961 through 1990 was 86" F and the mean low was 66" F. The 

mean precipitation for the same period was 4.8 inches." (Source: KY submittal) 

For Madison County, the following statement preceded the excerpted paragraph above: 

Due to the close proximity of Lexington, Kentucky, meteorological data from 

Lexington was used for the Madison county area." 

This factor did not play a significant role in the decision making process. The submitted 

information was only for the summertime winds. 

Factor 7: Geo~raphpltopo~raphp 

Based on an analysis of this factor, there are no significant topographical issues associated 

with this MSA. 

Factor 8: .Jurisdictional boundaries 

No county in the Lexington MSA was designated nonattainment for the 8-hour ozone 

standard on April 15, 2004. This factor did not play a significant role in the decision 

making process. 

Factor 9: Level of control of emission sources 

The following information was provided by Kentucky for Fayette, Bourbon, Clark, 

Jessamine, Madison, Scott, Woodford Counties. 

"Point sources located within ... County are subject to PSD requirements, 

CTG RACT requirements, Maximum Achievable Control Technology (MACT) 

requirements for sources of Hazardous Air Pollutants, and New Source 

Pe$ormance Standards (NSPS)." (Source: KY PM2.5 submittal) 

This factor did not play a significant role in the decision making process. 
PM 2.5 Nine Factor Analysis for 

Huntington-Ashland, WV-KY -OH MSA 

The Huntington-Ashland MSA contains the Kentucky Counties of Boyd, Carter, and 

Greenup; the West Virginia Counties of Cabell and Wayne; and Lawrence County, Ohio. 

The following MSA and adjacent counties are violating the PM2.5 standard: Cabell 

County, West Virginia (MSA) and Lawrence (MSA) and Scioto (adjacent) Counties, 

Ohio. 

In February 2004, Kentucky recommended that the PM2.5 designation for Boyd County 

be deferred and that Greenup and Carter Counties be designated attainment for the 

Huntington-Ashland MSA. EPA is modifying Kentucky's recommendeation to include 

Boyd County and Lawrence Counties in Kentucky in the Huntington-Ashland 

nonattainment area. The following factors played a significant role in this decision for 

Boyd County: attaining monitor reading of 15.0, at the standard; significant SOX, NOx, 

and PM emissions; proximity to the violating MSA counties; controls with anticipated, 

substantial SOX, NOx, and PM emission reductions will not be implemented until the end 

of 2005, well after designations are made. Lawrence County, Kentucky is included due to 

significant emissions of SOX and NOx from a power plant and its close proximity to the 

violating counties in the MSA. We have included in our recommended nonattainment 

area this County that is adjacent to the Huntington-Ashland MSA with a violating 

monitor, that is generally rural in character, and that contains an identifiable large emitting 

facility (e.g., power plant) which we believe contributes to the nearby nonattainment 

problem. We have included this county in our initial recommendations in order to ensure 

that a sufficient portion of this county, including such a large facility, is included within 

the boundaries of the nonattainment area as part of the final designations. We invite you 

to submit to us a recommendation as to what portion of this adjacent county, 

encompassing the large facility, should be designated nonattainment. 

EPA agrees that Greenup and Carter Counties in Kentucky should be designated 

attainment/unclassifiable due to their relatively low emissions, low populations, low 

VMT, low numbers of commuters into the violating counties, and small point sources. 

The recommendations of EPA and Kentucky are summarized in the table below. 

The following is a brief summary of the nine criteria for the Kentucky portion of the 

Huntington-Ashland, WV-KY-OH area. These analyses were based on existing available 

data. 

Area 

Huntington-Ashland, 

WV-KY-OH 

EPA Recommendation for KY 

Full counties: 

Boyd County 

Lawrence County (adjacent) 

State Recommendation 

Full counties: 

Boyd (Defer Designation) 

Factor 1: Emissions in areas ~otentiallv included versus excluded from the 

nonattainment area 

The following table has the 2001 PM2.5, SOX, NOx, VOC, and ammonia emissions in 

tons per year and weighted emissions scores for the counties in the Huntington-Ashland 

MSA and surrounding counties. (MSA counties are in bold; Kentucky MSA counties are 

in bold italics.) 

I Cabell (WV) 1 2.365 1 5.155 1 27.903 1 7.080 1 181 1 40.3 1 40.3 

County 

I Boyd (KY) 1 2,314 1 11,740 1 13,478 [ 8,620 1 467 1 25.2 1 65.5 

PM 

Wayne (WV) 

Greenup (KY) 

SOX 

Lawrence (OH) 

Carter (KY) 

Gallia (OH) 

550 

477 

Adams (OH) 

Putnam (WV) 

Mason (WV) 

Lawrence (KY) 

Scioto (OH) 

770 

506 

10,010 

Lewis (KY) 

Pike (OH) 

NOx 

1,023 

2,519 

6,417 

4,395 

3,610 

2,903 

1,053 

Rowan KY 

Mingo (WV) 

Jackson (OH) 

Martin (KY) 

Lincoln (WV) 

Based on the analysis for this factor, the following Kentucky counties appear to have 

significant emissions (over 10,000 tons per year of any pollutant): Boyd and Lawrence. 

This factor is not significant for the remaining Kentucky counties listed in this table. 

VOC 

841 

237 

164,984 

429 

425 

I I I I I I I 

Factor 2: Air aualitv in potentiallv included versus excluded areas 

Cum. 

Score 

Amm 

6,485 

4,336 

125,136 

80,150 

70,053 

56,066 

2,790 

336 

437 

404 

281 

259 

Elliott (KY) 

Score 

4,399 

2,615 

61,079 

469 

4,203 

2,620 

1,795 

52,992 

39,795 

31,327 

21,265 

5,566 

3 13 

28 1 

46 1 

66 1 

67 

164 

4,366 

1,996 

1,839 

2,873 

2,08 1 

56 

156 

1,508 

3,752 

2,831 

919 

4,703 

1,691 

2,842 

1,320 

1,236 

1,3 14 

207 

223 

300 

990 

1,311 

115 

9.6 

9.5 

431 

97 

264 

56 

350 

1,535 

1,379 

1,717 

706 

1,128 

42 

75.1 

84.6 

8.6 

6.8 

141.4 

102.4 

72.7 

60.0 

48.3 

12.5 

222 

149 

393 3.1 

93.2 

100.0 

8.1 

6.8 

9 1 

150 

165 

762 

37 

313 

5.7 

5.5 

4.7 

4 .O 

4.0 
County 

Cabell (WV) 

2001-2003 design value 

16.6 

Boyd (KY) 

Lawrence (OH) 

There are four monitors in the MSA, with two of them in the Kentucky Counties of Boyd 

and Carter. The Kentucky monitors are monitoring attainment. Three monitors in the 

MSA and surrounding counties are violating: Cabell County, West Virginia; Lawrence 

County, Ohio; and the adjacent Scioto County, Ohio. Based on the analysis for this factor 

for Kentucky only, Boyd County has attaining monitoring data very close to the standard, 

thus indicating a potential to contribute to the PM2.5 violations in the area. This factor is 

not significant for the remaining Kentucky counties. 

15.0 

15.8 

Carter (KY) 

Scioto (OH) 

Factor 3: Population densitv and depree - of urbanization includin~ - commercial 

development in included versus excluded areas 

12.2 

17.2 

The following table has the populations for the counties in the Huntington-Ashland MSA 

and adjacent counties with significant emissions. The total MSA 2002 population is 

313,239. (MSA counties are in bold; Kentucky MSA counties are in bold italics.) 

County 

I I I 

2002 Population 

Cabell (WV) 1 95,266 

Boyd (KY) 

Wayne (WV) 

30.41 1 338 

Greenup (KY) 

Lawrence (OH) 

Scioto (OH) 1 78,041 128 1 

Percent of Total 

MSA Population 

49,603 

42,382 

Based on the analysis for this factor for Kentucky only, Boyd County has the third largest 

population in the MSA and the second largest population density, indicating a potential to 

contribute to the PM2.5 violations in the area. This factor is not significant for the 

remaining Kentucky counties. 

2002 Population 

Density 

36,761 

62.172 

66 

67 

48 

. , 

1 5.84 

13.53 

Carter (KY) 

Gallia (OH) 

Adams (OH) 

31 0 

84 

11.74 

19.85 

106 

137 

2 7,055 

31,301 

27,804 

8.64 
Factor 4: Traffic and commutinp patterns 

Commuting Information 

Total number of workers in Boyd County, KY: 19,106 

Commuters in Boyd County, KY who work in Boyd County, KY: 13,816 (72%) 

Commuters from Boyd County, KY to Cabell County, WV: 1,157 (6%) 

Commuters from Boyd County, KY to Lawrence County, OH: 540 (3%) 

Total number of workers in Carter County, KY: 10,258 

Commuters in Carter County, KY who work in Carter County, KY: 5,641 (55%) 

Commuters from Carter County, KY to Boyd County, KY: 1,401 (14%) 

Commuters from Carter County, KY to Cabell County, WV: 237 (2%) 

Total number of workers in Greenup County, KY: 13,798 

Commuters in Greenup County, KY who work in Greenup County, KY: 5,930 (43%) 

Commuters from Greenup County, KY to Boyd County, KY: 4,147 (30%) 

Commuters from Greenup County, KY to Cabell County, WV: 473 (3%) 

Commuters from Greenup County, KY to Lawrence County, OH: 443 (3%) 

Commuters from Greenup County, KY to Scioto County, KY: 1,252 (9%) 

Total number of workers in Lawrence County, KY: 4,899 

Commuters in Lawrence County, KY who work in Lawrence County, KY: 2,483 (51 %) 

Commuters from Lawrence County, KY to Boyd County, KY: 575 (12%) 

Commuters from Lawrence County, KY to Cabell County, WV: 193 (4%) 

Commuters from Lawrence County, KY to Lawrence and Scioto Counties, OH: 0 (0%) 

Based on commuting data above, none of the Kentucky counties appear to be contributing 

a significant level of onroad mobile source emissions to the area. 

Vehicle Miles Traveled: 

The following table has the vehicle miles traveled (thousand miles) for the counties in the 

Huntington-Ashland MSA and some adjacent counties with significant emissions. (MSA 

counties are in bold; Kentucky MSA counties are in bold italics.) 

County 

I Boyd (KY) 1 411 

2002 VMT 

Cabell (WV) 

(thousand mileslyear) 

1,030 

Wayne (WV) 

Greenup (KY) 

Lawrence (OH) 

377 

264 

796 
I Carter (KY) 1 665 

I Putnam (WV) 1 578 

Gallia (OH) 

Adams (OH) 

266 

283 

Based on the total VMT of the Kentucky counties only, there appears to be a potential 

contribution of onroad mobile source emissions to the area from Boyd and Carter 

Counties. However, the analysis of the commuting data above shows that a low number 

of workers commute from these Kentucky counties into the violating counties. Thus, this 

factor is not significant for the Kentucky counties listed above when VMT and commuting 

data are analyzed together. 

Mason (WV) 

Scioto (OH) 

Factor 5: Expected mowth 

270 

633 

The following table has the population and population growth figures for the HuntingtonAshland MSA and adjacent counties with significant emissions. (MSA counties are in 

bold; Kentucky MSA counties are in bold italics.) 

County 

Cabell (WV) 

Boyd (KY) 

2002 

Population 

Wayne (WV) 

Greenup (KY) 

Lawrence (OH) 

95,266 

49,603 

Carter (KY) 

Gallia (OH) 

growth 

(90-00) 

42,382 

36,761 

62,172 

Adams (OH) 

Putnam (WV) 

Based on an analysis of this factor for Kentucky only, there appears to be relatively 

significant population growth in Carter County to indicate a potential air quality 

contribution. However, Carter County's population is low. Boyd and Greenup Counties 

have a negative or zero population growth rate. Thus, this factor is not significant. for the 

Kentucky counties. 

% growth 

(90-00) 

-43 

-1,398 

2 7,055 

31,301 

Mason (WV) 

Scioto (OH) 

Factor 6: Meteorologv 

-0 

-3 

1,267 

149 

485 

27,804 

52,230 

The following meteorological information was provided by Kentucky. The text below is 

3 

0 

1 

2,549 

115 

26,004 

78 ,04 1 

10 

0 

1,959 

8,754 

8 

20 

779 

-1,132 

3 

- 1 
the same for Boyd, Carter, and Greenup Counties in Kentucky. The figure referenced is a 

wind rose for April 1-October 31 for the 1988-1992 period that is provided in Kentucky's 

PM2.5 recommendations submittal. 

Meteorological Information 

"Due to the close proximity of Huntington, West Virginia, meteorological data from 

Huntington was used for this Kentucky area. Wind speedwind direction information 

shows that the majority of the time for the period 1988-1992, the wind in the 

Huntington-Ashland area came from the southwest and typically from 4-6 knots. (See 

figure 1-A) The mean high temperature for July for the area from 1961 through 1990 

was 85" F and the mean low was 65" F. The mean precipitation for the same period was 

4.5 inches." (Source: Kentucky PM2.5 submittal) 

Based on an analysis of this factor, the information provided is not sufficient to provide a 

compelling argument to exclude counties based on prevailing winds. The information 

provided was for only the summertime winds. 

Factor 7: Geo~ra~hvlto~oeraphv 

Based on an analysis of this factor, there are no significant topographical issues associated 

with this MSA. 

Factor 8: Jurisdictional boundaries 

The following MSA counties were designated nonattainment for the 8-hour ozone 

standard on April 15,2004: Boyd County, Kentucky; the West Virginia Counties of 

Cabell, Wayne, and Putnarn; and no counties in Ohio. This factor did not play a 

significant role in the decision-malung process. 

Factor 9: Level of control of emission sources 

The following information was provided by Kentucky for Boyd, Carter, and Greenup 

Counties. "Point sources located within ... County are subject to PSD requirements, 

CTG RACT requirements, Maximum Achievable Control Technology (MACT) 

requirements for sources of Hazardous Air Pollutants, and New Source 

Pe$omzance Standards (NSPS)." This factor did not play a significant role in the 

decision-making process for these counties. 

The following information was provided by Kentucky for Boyd County. 

Kentucky anticipates that emissions of PM2.5, SOX, and NOx will decrease substantially 

within Boyd County over the next two years. These anticipated emission decreases 

are due to source modernization and new controls being implemented at two major 
sources in Boyd County: the Marathon-Ashland Refinery and Calgon Carbon Corporation. 

For the Marathon-Ashland Refinery, the facility modifications are anticipated to be 

completed by the end of 2005. According to Kentucky, based on 2002 emissions data, 

this would mean an approximate reduction of 1,571 tons per year of S02, a 761 ton per 

year reduction in NOx, and a 32 ton per year reduction in particulate matter. 

For Calgon Carbon Corporation, the May 2003 shutdown of two of their activator lines 

resulted in SO2 emissions being reduced from this facility by approximately 187 tons in 

2003. Before these lines can be reactivated, scrubbers, with SO2 and PM control 

efficiencies of 90% will be required to be installed on these units. If brought back into 

operation, these units will have controls in place to reduce emissions of SO2 from these 

two lines to approximately 32 tons per year. 

Based on an analysis of this factor, these controls will not be implemented in a timeframe 

early enough to influence the decision for Boyd County on PM2.5 designations.