The Atlanta Eight-Hour Ozone Attainment Demonstration 

Appendix S 

May 11, 2006, Letter to EPA 

Requesting Concurrence on I/M 

Applicability 

May 31, 2006, Letter from EPA 

Concurring 
Georgia Department of Natural Resources 

Environmental Protection Division m Air Protection Branch 

4244 International Parkway 0 Suite 120 * Atlanta * Georgia 30354 

4041363-7000 0 Fax: 4041363-71 00 

Noel Holcomb, Commissioner 

Carol A. Couch, Ph.D., Director 

May 1 1,2006 

Kay Prince 

Chief, Air Planning Branch 

U.S. EPA, Region IV 

61 Forsyth St., SW 

Atlanta, GA 30303-8909 

Dear Ms. Prince: 

This letter is to request EPA's concurrence regarding whether Georgia's existing motor vehicle 

emissions inspection and maintenance program satisfies the IIM requirements for a moderate ozone 

nonattainment area under the 8-hour ozone standard. 

Section 182(b)(4) of the Clean Air Act requires a "Basic" Motor Vehicle Emissions Inspection and 

Maintenance program for areas classified as moderate and above. 40 CFR 51.350(a)(8) and (b)(2) 

contain specifics regarding the population criteria and area of coverage for areas which are 

reclassified from marginal to moderate. 

Sec. 5 1.350 Applicability. 

(a) Nonattainment area classification and population criteria. 

(8) If a marginal ozone nonattainrnent area, not required to implement enhanced I/M under 

paragraph (a)(l) of this section, is reclassified to moderate, a basic I/M program shall be 

implemented in the 1990 Census-defined urbanized area(s) with a population of 200,000 or more. 

If the area is reclassified to serious or worse, an enhanced IIM program shall be implemented in 

the 1990 Census-defined urbanized area, if the 1980 Census-defined urban area population is 

200,000 or more. 

(b) Extent of area coverage. 

(2) Outside of ozone transport regions, programs shall nominally cover at least the entire 

urbanized area, based on the 1990 census. Exclusion of some urban population is allowed as long 

as an equal number of non-urban residents of the MSA containing the subject urbanized area are 

included to compensate for the exclusion. 

It is probable that the Atlanta 8-hour ozone nonattainment area will be reclassified fiom marginal to 

moderate in the foreseeable future. When and if that occurs, Atlanta will be subject to the provision 

of 40 CFR 52.350(a)(8) since the population of the urbanized area was 2,157,806 according to the 

1990 census'. 
Kay Prince 

May 1 1,2006 

Page Two 

The Atlanta 8-hour ozone nonattainment area consists of 20 counties. An "enhanced" motor vehicle 

emissions inspection and maintenance (I/M) program is currently in operation in 13 of these counties 

(Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, 

Paulding, and Rockdale) and is required for the entire area of each county. There are 7 counties within 

the Atlanta 8-hour ozone nonattainment county without an I/M program (Barrow, Bartow, Carroll, Hall, 

Newton, Spalding, and Walton). (see attached map). 

According to 40 CFR 51.350(b)(2), the extent of the I/M program must cover the entire urbanized area, 

based on the 1990 census and that "exclusion of some urban population is allowed as long as an equal 

number of non-urban residents of the MSA containing the subject urbanized area are included to 

compensate for the exclusion." According to the 1990 Census, only a very small portion of the 7 

counties currently not covered by an I/M program is "urbanized." This area consists of a significant 

portion of Census Block Group 4 (BG4) and a small area of Census Block Group 2 (BG2), both of 

Census Track 9608 in southeast Bartow County (see attached maps). The combined 1990 population of 

these two Census Block Groups was 2700 (1 146 for BG4 and 1554 for BG~~). Thus, in order for the 

current 13-county I/M program to satisfy the requirements of the CAA and 40 CFR 350 for a moderate 

area, the area covered by the program must include non-urbanized areas with a 1990 population of at 

least 2700. The existing IIM program includes large portions of counties that are not urbanized 

according to the 1990 census. One such area is all of Paulding County. The 1990 census population of 

Paulding County was 41,6 1 1 3. 

Therefore, should the Atlanta 8-hour ozone nonattainment area be reclassified from marginal to 

moderate, the existing I/M program satisfies the statutory and regulatory requirement for an I/M 

program. This determination does not preclude Georgia from voluntarily adding any or all of these 7 

counties to an I/M program. This issue was discussed with Dale Espy and others of your staff on May 

10,2006, and their initial response was in agreement to this conclusion. 

Should you have any questions, please contact me at 4041363-7014, 

Sincerely, 

Program Manager 

Planning & Support Program 

c: Kent Pierce 

www.factfinder.census.~ov, population figures are not available for areas smaller than a block group 

w~w.factfinder.census.~ov 



BG 2, BNA 9608, Bartow County, Georgia - Reference Map - Americ ... http://factfmder.census.gov/servlet/MapIrawServlet?geoidl500... 

BG 2, BNA 9608, Bartow County, Georgia 

2.8 miles across 
BG 4, BNA 9608, Bartow County, Georgia - Reference Map - Arneric ... http://factfinder.census.gov/servlet/MapIrawServlet?geoid=l500... 

BG 4, BNA 9608, Bartow County, Georgia 

Boundarias 

,M" state 

'99 Ccs~*ty 

cwrs9is Tract 

Block Group 

Place 

Place 

'W M 

Faaturtas 

7 miles across 
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

Jci.j ri 2006 

MAY 3 1 2006 

0 

James P. Johnston, P.E. 

Air Protection Branch 

Environmental Protection Division 

Georgia Department of Natural Resources 

4244 International Parkway, Suite 120 

Atlanta, Georgia 30354 

Dear Mr. Johnston: 

This correspondence is in response to your request, dated May 11,2006, for U.S. 

Environmental Protection Agency (EPA) concurrence regarding whether the State of 

Georgia's existing motor vehicle emissions inspection and maintenance (IJM) program 

satisfies the I/M requirements for a moderate ozone nonattainment area under the 8-hour 

ozone National Ambient Air Quality Standard. We have completed our review of your 

request and have made the following determination. 

As you noted in your letter, federal requirements at 40 C.F.R. section 

5 1.350(b)(2) require the I/M program to cover the entire urbanized area, as defined in the 

1990 Census. This section also indicates that the "exclusion of some urban population is 

allowed as long as an equal number of non-urban residents of the MSA [Metropolitan 

Statistical Area] containing the subject urbanized area are included to compensate for the 

exclusion." Based upon the information that you presented from the U.S. Census Bureau, 

EPA concurs that the small area of Bartow County, the only 1990 urbanized area not 

covered by the existing program, is more than compensated for by the inclusion of nonurbanized areas in the 13 county I/M program. This determination does not preclude the 

State of Georgia from voluntarily adding any or all of the seven counties to the existing 

I/M program. 

Thank you for the opportunity to provide you with this determination. If you 

have any questions or comments, please contact Dale Aspy of the EPA Region 4 staff at 

(404) 562-9041. 

Sincerely, 

K~$T. Prince, Chief 

Air Planning Branch 

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

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