REDESIGNATION REQUEST

AND

MAINTENANCE DEMONSTRATION

Jackson County, Alabama

Chattanooga

Annual PM2.5 Nonattainment Area

Prepared by:

Alabama Department of Environmental Management

Air Division

DRAFT Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

i

Executive Summary

This document contains Alabama's demonstration under the federal Clean Air Act (CAA) 

Amendments of 1990 that the Jackson County portion of the Chattanooga Annual PM2.5 

Nonattainment Area (NAA) should be redesignated from nonattainment to attainment with 

respect to the National Ambient Air Quality Standard (NAAQS) for annual fine particle 

pollution. This area consists of Hamilton County in Tennessee, Catoosa and Walker Counties 

in Georgia, and the portion of Jackson County in Alabama that is described as U.S. Census 

2000 block group identifier 01–071-9503–1. There are no PM2.5 monitors located in the 

Jackson County, Alabama, portion of the nonattainment area; however, the air quality 

monitoring data for 2001-2003 from monitors located in the Georgia and Tennessee portions of 

the nonattainment area indicated that the annual average PM2.5 concentrations (design values) 

exceeded the 15.0 micrograms per cubic meter (μg/m3)NAAQS. The U.S. Environmental 

Protection Agency (EPA) included the above-mentioned portion of Jackson County, Alabama, 

in the Chattanooga nonattainment area because they concluded that the Tennessee Valley 

Authority (TVA) Widows Creek Fossil Plant located in the county contributes to the 

nonattainment situation in the Chattanooga NAA. 

This redesignation request is based on three years of ambient monitoring data, 2007 to 2009, at 

all four PM2.5 monitors in the Chattanooga NAA showing no violation of the annual PM2.5 

standard, the implementation of permanent and enforceable reductions in PM2.5 and precursor 

emissions, compliance with Section 110 and Part D requirements of the CAA, and the 

Chattanooga Maintenance Plan with projections demonstrating that the 2007 emission levels in 

this nonattainment area will not be exceeded through at least the year 2025. 

The Alabama Department of Environmental Management (ADEM), the Chattanooga-Hamilton 

County Air Pollution Control Bureau, the Tennessee Division of Air Pollution Control and the 

Georgia Air Protection Branch collaborated to develop a PM2.5 NAAQS State Implementation 

Plan (SIP) for each jurisdiction. 

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga 

nonattainment area had attained the 1997 annual average PM2.5 NAAQS. This determination 

was based upon quality-assured and certified ambient air monitoring data for the 2007-2009 

period, which showed a design value of 12.7 μg/m3. This final rule became effective on June 

30, 2011. Upon EPA’s determination that the area had, in fact, attained the standard, Alabama, 

Georgia and Chattanooga began work on redesignation requests for their respective portions of 

the nonattainment area. As part of this work, coordination and consultation took place between 

the three agencies concerning emissions, monitoring data and the expectations of maintenance 

for the entire area. The emissions and monitoring data gathered as a result of this consultation 

is reflected in this request.

This document contains the redesignation request for the Jackson County, Alabama, portion of 

the nonattainment area, which demonstrates maintenance of the annual PM2.5 NAAQS, 

promulgated in 1997, in the Chattanooga NAA thru 2025. The State of Georgia’s redesignation 

request and maintenance plan is located in Appendix A, and the Chattanooga-Hamilton County 

Air Pollution Control Bureau’s draft redesignation request and maintenance plan is located in 

Appendix E.
DRAFT Jackson County Annual PM2.5 Nonattainment Area

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TABLE OF CONTENTS

1.0 Introduction..................................................................................................................................1-1

1.1 Purpose.....................................................................................................................................1-1

1.2 Historic Background ................................................................................................................1-1

1.3 Formation of PM2.5...................................................................................................................1-3

1.4 Criteria for Redesignation........................................................................................................1-4

2.0 Attainment Demonstration...........................................................................................................2-1

2.1 Demonstration that the NAAQS Has Been Attained ...............................................................2-1

2.1.1 PM2.5 Monitoring Network .................................................................................................. 2-1

2.2 Permanent and Enforceable Reductions in Emissions.............................................................2-4

3.0 Fully Approved SIP, Section 110 and Part D Requirements........................................................3-1

3.1 Section 110 Implementation Plans...........................................................................................3-1

3.2 Part D Plan Requirements for Nonattainment Areas ...............................................................3-1

3.2.1 Nonattainment Areas in General.......................................................................................... 3-1

3.2.1.1 Section 172(c) – ...........................................................................................................3-1

3.2.1.2 Section 176(c) – ...........................................................................................................3-1

3.2.1.2.1 Nitrogen Oxides (NOX)...........................................................................................3-2

3.2.1.2.1.1 Analysis of motor vehicle NOX emissions in the Jackson County portion of the 

Chattanooga nonattainment area..........................................................................................3-2

3.2.1.2.1.2 The current state of the air quality in Jackson County......................................3-3

3.2.1.2.1.3 The absence of SIP motor vehicle controls for the area. ..................................3-4

3.2.1.2.1.4 Historical trends and future projections of the growth of motor vehicle 

emissions. ..........................................................................................................................3-4

3.2.1.2.2 Direct PM2.5.............................................................................................................3-4

3.2.1.2.2.1 Analysis of motor vehicle PM2.5 emissions in the Jackson County portion of the 

Chattanooga nonattainment area..........................................................................................3-4

3.2.1.2.2.2 The current state of the air quality in Jackson County......................................3-6

3.2.1.2.2.3 The absence of SIP motor vehicle controls for the area. ..................................3-6

3.2.1.2.2.4 Historical trends and future projections of the growth of motor vehicle 

emissions. ..........................................................................................................................3-6

4.0 Maintenance Plan........................................................................................................................4-1

4.1 Maintenance Demonstration ....................................................................................................4-1
DRAFT Jackson County Annual PM2.5 Nonattainment Area

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4.2 Attainment Inventory...............................................................................................................4-1

4.2.1 Point Sources ....................................................................................................................... 4-2

4.2.2 Nonpoint Sources................................................................................................................. 4-2

4.2.3 On-road Mobile Sources...................................................................................................... 4-4

4.2.4 Nonroad Mobile Sources ..................................................................................................... 4-5

4.3 Projected Emissions Inventory ................................................................................................4-5

4.3.1 Point Sources ....................................................................................................................... 4-6

4.3.2 Nonpoint Sources................................................................................................................. 4-6

4.3.3 Onroad Mobile Sources ....................................................................................................... 4-6

4.3.4 Nonroad Mobile Sources ..................................................................................................... 4-7

4.4 Maintenance Plan Inventory ....................................................................................................4-9

4.5 Plan to Maintain Air Quality..................................................................................................4-11

4.5.1 Verification of Continued Attainment................................................................................ 4-12

4.5.2 Contingency Plan............................................................................................................... 4-12

5.0 Conclusion ...................................................................................................................................5-1

TABLES

Table 2.1.1-1 Annual and Three-year Average Ambient PM2.5 Concentrations.................................2-2

Table 3.2.1.2.1.1-1 2007, 2017, 2025 NOX (TPY) Emissions in the Nonattainment portion of Jackson 

County by Source Type....................................................................................................................3-3

Table 3.2.1.2.1.1-2 2007, 2017, 2025 NOX (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions in the 

entire Chattanooga NAA.................................................................................................................3-3

Table 3.2.1.2.1.4-1 Historical and Future Projections of NOX emissions from On-Road Mobile Sources 

in Jackson County...........................................................................................................................3-4

Table 3.2.1.2.2.1-1 2007, 2017, 2025 Direct PM2.5 (TPY) Emissions in the Nonattainment Portion of 

Jackson County by Source Type......................................................................................................3-5

Table 3.2.1.2.2.1-2 2007, 2017, 2025 Direct PM2.5 (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions in the 

Entire Chattanooga NAA................................................................................................................3-5

Table 3.2.1.2.2.4-1 Historical and Future Projections of PM2.5 emissions from On-Road Mobile Sources 

in Jackson County...........................................................................................................................3-6

Table 4.2.1-1 2007 Point Emissions (TPY)........................................................................................4-2

Table 4.2.2-1 Jackson County NAA Nonpoint Source Emissions for 2007 (TPY) .............................4-3

Table 4.2.4-1 2007 Nonroad Mobile Source Emissions (tons)...........................................................4-5

Table 4.3.4-1 Projected Nonroad Mobile Source Emissions (tons per year).....................................4-8
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Table 4.4-1 Jackson County, AL portion of the Chattanooga Annual PM2.5 Attainment Area Maintenance 

Plan Emissions (Tons per Year)......................................................................................................4-9

Table 4.4-2 Maintenance Inventory for the Chattanooga NAA (TPY).............................................4-10

Table 4.5.2-1 Schedule for Permit Revisions or Rule Revisions for Contingency Measures...........4-13

FIGURES

Figure 1.2-1 The Jackson County, AL portion of the Chattanooga Annual PM2.5 NAA.....................1-2

Figure 2.1.1-1 Locations of PM2.5 Monitors in the Chattanooga NAA..............................................2-3
DRAFT Jackson County Annual PM2.5 Nonattainment Area

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APPENDICES

GA Maintenance Plan and Redesignation Request ............................................................................... A

Insignificance Determination for Transportation Conformity Under PM2.5 NAAQS for Jackson County, 

AL........................................................................................................................................................... B

Emissions Inventory Documentation .....................................................................................................C

Development of the Point Source Emissions Inventory for 2007 in the SESARM Region (Version 

1.10a), January 18, 2012................................................................................................................C-1

Area and Nonroad 2007 Base Year Inventories, Revised Final Report, Jan 2012 .........................C-2

Onroad and Nonroad Emissions Modeling Data ...........................................................................C-3

Growth Factors, Control Factors, and Emission Summaries for Emission Inventory (includes 

memorandum from K. Thesing)......................................................................................................C-4

MACTEC, August 2009. Point Source, On-road, and Fire Base Year, Future Year, and Control 

Strategy Emissions Inventories Draft Quality Assurance Project Plan..........................................C-5

E.H. Pechan and Associates, July 29, 2009. Quality Assurance Project Plan for Non- road and Area 

Source Base Year and Future Year Emissions Inventories..............................................................C-6

The Federal Facilities Compliance Agreement Between EPA and the Tennessee Valley Authority, Docket 

No. CAA-04-2010-1760 .........................................................................................................................D

Chattanooga, TN DRAFT Maintenance Plan and Redesignation Request – Narrative Only................ E
DRAFT Jackson County Annual PM2.5 Nonattainment Area

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List of Acronyms

Acronym Meaning Acronym Meaning

ADEM Alabama Department of 

Environmental Management FR Federal Register

AERR Annual Emissions Reporting

Requirements FRM Federal Reference Monitor

AIRS

Aerometric Information Retrieval

System ICI

Industrial and

Commercial/Institutional

ALDOT Alabama Department of 

Transportation LRTP Long Range Transportation Plan

AQS Air Quality Subsystem MOVES Motor Vehicle Emissions Simulator

CAA Clean Air Act NAA Nonattainment Area

CAIR Clean Air Interstate Rule NAAQS

National Ambient Air Quality

Standard

CERR

Consolidated Emissions Reporting

Rule NEI National Emissions Inventory

CFR Code of Federal Regulations NESHAP National Emissions Standards for 

Hazardous Air Pollutants

CMV Commercial Marine Vessels NMIM National Mobile Inventory Model

EGAS Economic Growth Analysis System NSR New Source Review

EGU Electric Generating Unit NOx Nitrogen Oxides

EIA Energy Information Administration PM Particulate Matter

EPA U.S. Environmental Protection

Agency PM2.5 Fine Particulate Matter

FGD Flue Gas Desulfurization PPM parts per million
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Acronym Meaning Acronym Meaning

PSD Prevention of Significant Deterioration SIP State Implementation Plan

RACM Reasonably Available Control Measures SO2 Sulfur Dioxide

RACT Reasonably Available Control

Technology TIP Transportation Improvement Plan

RFP Reasonable Further Progress TPY tons per year

RVP Reid Vapor Pressure TVA Tennessee Valley Authority

SAFETEALU

Safe, Accountable, Flexible, Efficient 

Transportation Equity Act – A Legacy 

for Users

ULSD Ultra-Low Sulfur Diesel

SCC Source Classification Code VISTAS

Visibility Improvement – State 

and Tribal Association of the 

Southeast

SCR Selective Catalytic Reduction VMT Vehicle Miles Traveled

SEMAP Southeastern Modeling Analysis Plan

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1.0 Introduction

1.1 Purpose

This document contains the technical support necessary for the ADEM request that the Jackson 

County, Alabama, portion of the Chattanooga annual PM2.5 NAA be redesignated as an area 

attaining the annual PM2.5 NAAQS pursuant to §§107(d)(3)(D) and (E) of the CAA, as 

amended.

1.2 Historic Background

On January 5, 2005, the EPA designated a portion of Jackson County, Alabama, as a part of the 

Chattanooga NAA for the annual PM2.5 standard. The official designations and classifications 

were printed in the Federal Register on January 5, 2005 (70FR944), and were amended on April 

5, 2005 (70FR19844). Figure 1.2-1 shows the boundaries of the Jackson County portion of the 

NAA.

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga 

NAA had attained the 1997 annual average PM2.5 NAAQS. This determination was based 

upon quality-assured and certified ambient air monitoring data for the 2007-2009 period, 

which showed a design value of 12.7 μg/m3. This final rule became effective on June 30, 

2011.
DRAFT Jackson County Annual PM2.5 Nonattainment Area

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Figure 1.2-1 The Jackson County, AL portion of the Chattanooga Annual PM2.5 NAA

Legend 

CJ PM2.5 NonattainmentArea 

Ocounty 

o Smurfit-Stone 

o lVAV\Iidows Creek 
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1.3 Formation of PM2.5

Fine particulate matter, also known as fine particles and PM2.5, refers to airborne particles less 

than or equal to 2.5 micrometers (μm) in diameter. Fine particles are treated as though they are 

a single pollutant, but they come from many different sources and are composed of many 

different compounds. PM2.5 exposure adversely affects human health, especially respiratory 

and cardiovascular systems. Individuals particularly sensitive to PM2.5 exposure include 

children, people with heart and lung disease, and older adults.

PM2.5 can be liquid, solid, or can have a solid core surrounded by liquid. PM2.5 can include 

material produced by combustion, photochemical reactions, and can contain salt from sea spray 

and soil like particles. Particles are distinguished based on the method of formation. Primary 

particles are particles directly emitted into the atmosphere and retain the same chemical 

composition as when they were released. Secondary particles are those formed through 

chemical reactions involving atmospheric oxygen, water vapor, hydroxyl radicals, nitrates, 

sulfur dioxide (SO2), nitrogen oxides (NOX), and organic gases from natural and anthropogenic 

sources. PM2.5 can therefore be composed of varying amounts of different species, including:

• Sulfates

• Nitrates (usually found in the form of ammonium nitrate)

• Ammonium

• Hydrogen ion

• Particle bound water

• Elemental carbon

• Organic compounds

o Primary organic species (from cooking and combustion)

o Secondary organic compounds

• Crustal material (includes calcium, aluminum, silicon, magnesium, and iron)

• Sea salt (generally only found at coastal monitoring sites)

• Transitional metals

• Potassium (generally from wood burning or cooking)

The most significant sources of PM2.5 and its precursors are coal-fired utilities, industrial 

boilers, and other combustion sources. These emissions are often transported over large 

distances. Other sources of PM2.5 emissions include mobile sources, area sources, biogenic 

sources, fires, windblown dust, and oceans.

A variety of meteorological and geographic factors influence the concentration levels of fine 

particles, including both the regional and local distribution of urbanized areas, primary and 

precursor emissions sources, and natural features such as oceans and forests. Since PM2.5 

concentrations can exceed the NAAQS at any time of the year, the EPA mandates the year 

round monitoring of the pollutant throughout the country (40 CFR 58, App. D). 
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1.4 Criteria for Redesignation

Section 107(d) of the federal CAA, as amended in 1990, states that an area can be redesignated 

to attainment if the following conditions are met:

1. The EPA has determined that the NAAQS have been attained.

2. The applicable implementation plan has been fully approved by EPA under Section 

110(k).

3. The EPA has determined that the improvement in air quality is due to permanent and 

enforceable reductions in emissions.

4. The state has met all applicable requirements for the area under Section 110 and Part D.

5. The EPA has fully approved a maintenance plan, including a contingency plan, for the 

area under Section 175A.

The first and third of these requirements relate directly to air quality and the reasons for its 

improvement. These requirements are discussed together in Section 2 of this document.

The second and fourth requirements relate to the implementation plan. All requirements under 

§110 and Part D of the Act have been met. These requirements are discussed in Section 3.

The maintenance plan has two required components under Section 175A. First, the state must 

submit a revision to the SIP, which provides for maintenance of the NAAQS in the area for at 

least ten years after the redesignation. EPA has up to 18 months after submittal of the 

redesignation request to approve or disapprove it. Therefore, EPA is required to make its 

decision by mid-2014 since this document is being submitted in early 2013. Thus, the State 

must demonstrate that the Chattanooga NAA will maintain the standard through at least 2025

[2015 + 10 = 2025]. The end year of our plan is 2025. Also, the plan revision must incorporate 

a contingency plan outlining commitments by the state to promptly correct any future 

violations. The maintenance demonstration and contingency plan are discussed in Section 4.
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2.0 Attainment Demonstration

2.1 Demonstration that the NAAQS Has Been Attained

Compliance with the NAAQS for annual PM2.5 is demonstrated when the three year average of 

the annual arithmetic mean PM2.5 concentrations is less than or equal to 15 μg/m3. The 

resulting concentration represents an annual PM2.5 design value. A violation of the annual PM2.5 

NAAQS occurs when the design value exceeds 15 μg/m3 at any monitor. 

The three year period of annual PM2.5 monitoring data for 2007-2009 for the Chattanooga NAA 

demonstrate compliance with the NAAQS for annual PM2.5, as will be illustrated in the next 

section.

On May 31, 2011, EPA promulgated its determination (76 FR 31239) that the Chattanooga 

NAA had attained the 1997 annual average PM2.5 NAAQS. This determination was based upon 

quality-assured and certified ambient air monitoring data for the 2007-2009 period, which 

showed a design value of 12.7 μg/m3

. This final rule became effective on June 30, 2011.

2.1.1 PM2.5 Monitoring Network

Four PM2.5 federal reference monitors (FRM) are located in the nonattainment area. Three 

monitors are located in Hamilton County, Tennessee, and one monitor is located in Walker 

County, Georgia. FRMs collect samples that are used to determine if an area is in attainment 

with the PM2.5 NAAQS. The FRM located at Soddy-Daisy High School is the most rural site of 

the three Hamilton County FRMs and has always shown attainment. The other three monitors 

showed exceedances of the annual standard for the 2001-2003 averaging period, which is the 

period the EPA used in the designation of the NAA. Table 2.1.1-1 shows the annual average 

PM2.5 concentrations and the associated 3-year average that demonstrate attainment of the 

standard in the Chattanooga nonattainment area. The 2007–2009 three-year design value is 

12.7 μg/m3, which is below the standard of 15.0 μg/m3. The table includes annual averages 

from 2003 through 2010, demonstrating the downward trend in the measured ambient PM2.5 

level in the nonattainment area. The 2008-2010 three-year design value (Monitor ID

470654002) is 11.6 μg/m3. This provides continued evidence that the area is meeting the 

standard. Monitor locations are shown in Figure 2.1.1-1. All of the PM2.5 ambient monitoring 

data that was collected during 2007, 2008, and 2009 was collected in accordance with 40 CFR 

58 and has been stored in EPA's Aerometric Information Retrieval System (AIRS) Air Quality 

System (AQS).
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Table 2.1.1-1 Annual and Three-year Average Ambient PM2.5 Concentrations

Year

Monitor

13-295-0002

(μg/m3)

Monitor

47-065-0031

(μg/m3)

Monitor

47-065-1011

(μg/m3)

Monitor

47-065-4002

(μg/m3)

2003 15.9 16.5 14.3 14.9

2004 14.9 15.6 13.3 14.5

2005 16.4 16.1 13.8 15.5

2006 14.4 14.3 13.1 15.0

2007 13.7* 14.9 14.2 15.0

2008 12.5 12.3 11.4 12.7

2009 10.7 10.5 9.5 10.5

2010 8.9 12.0 13.3 11.7

2011† 10.8* 11.1 10.3 11.1

2007-2009 12.3* 12.6 11.7 12.7

2008-2010 10.7 11.6 11.4 11.6

2009-2011 10.1* 11.2 11.0 11.1

*Values subject to data substitution (76 FR 15895)

† Data obtained from AQS 
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Figure 2.1.1-1 Locations of PM2.5 Monitors in the Chattanooga NAA
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2.2 Permanent and Enforceable Reductions in Emissions

Since 2000, there have been several major federal programs enacted that have led to significant 

actual, enforceable PM2.5 and PM2.5 precursor emission reductions. These programs were 

established to provide reductions in emissions from the mobile source and industrial sectors.

These programs are listed below. 

1. Tier II Motor Vehicle Emissions Standards 

2. Federal Onroad Diesel Engine Standards 

3. Federal Nonroad Diesel Engine Standards 

4. Federal Marine Engine Requirements 

5. Federal Locomotive Requirements 

6. The New Source Performance Standards under Section 111 (42 U.S.C 7411) 

7. The National Emission Standards for Hazardous Air Pollutants under Section 112 (42 

U.S.C. 7412) 

8. The NOX SIP Call 

9. The Clean Air Interstate Rule

10. After December 1, 2014, all on-road, non-road, locomotive and marine diesel fuel produced 

and imported will be Ultra-Low Sulfur Diesel (ULSD-15 ppm).

11. Installation of Selective Catalytic Reduction (SCR) on Unit 7 (2003) and Unit 8 (2004) at 

TVA Widows Creek. SCRs were added as a result of the NOx SIP Call. The Flue-gas 

desulfurization (FGD) on Unit 8 was upgraded in efficiency in 2004. Year round operation 

of the SCRs and FGDs was planned in anticipation of the Clean Air Interstate Rule (CAIR)

rule, and subsequent replacement rule.
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3.0 Fully Approved SIP, Section 110 and Part D Requirements

3.1 Section 110 Implementation Plans

On October 5, 2012, EPA finalized approval of a SIP revision (77 FR 60904) submitted by 

ADEM on October 7, 2009, for the purpose of demonstrating attainment of the 1997 PM2.5

NAAQS in the Alabama portion of the tri-state Chattanooga PM2.5 NAA. The Chattanooga 

Area is comprised of Catoosa and Walker Counties in Georgia; Hamilton County in Tennessee; 

and a portion of Jackson County in Alabama. The Alabama SIP revision pertains only to the 

Alabama portion of the Chattanooga Area. EPA finalized approval of Alabama’s October 7, 

2009, SIP revision regarding reasonably available control technology (RACT) and reasonably 

available control measures (RACM); reasonable further progress (RFP); contingency measures; 

and, for transportation conformity purposes, an insignificance determination for PM2.5 and NOx

for the mobile source contribution to ambient PM2.5 levels for the Alabama portion of the 

Chattanooga Area. This action is being taken in accordance with the CAA and the ‘‘Clean Air 

Fine Particle Implementation Rule,’’ issued by EPA on April 25, 2007. EPA also approved the 

base year emissions inventory for the 2009 attainment SIP for the Alabama portion of the 

Chattanooga NAA on February 8, 2012 (77 FR 6469). 

The general elements required in a SIP are listed in §110(a). These elements include 

procedures for air quality monitoring and modeling; criteria for establishing stationary source 

controls, monitoring and reporting; implementation of permitting programs under Part C 

(Prevention of Significant Deterioration or PSD) and Part D (New Source Review or NSR); and 

provisions for public involvement. Alabama has a fully approved SIP under the authority of 

§110. 

3.2 Part D Plan Requirements for Nonattainment Areas

3.2.1 Nonattainment Areas in General

3.2.1.1 Section 172(c) –

In October of 2009, ADEM submitted to EPA the attainment demonstration for the Jackson 

County, Alabama, portion of the Chattanooga annual PM2.5 NAA. This plan demonstrates 

attainment of the annual PM2.5 NAAQS beginning in 2010 based on implementation of a 

combination of federal measures, other regional controls, and local controls and unit shutdowns 

associated with NAA utilities. Thus, ADEM has met the requirement of Section 172(c). EPA 

also approved the base year emissions inventory for the 2009 attainment SIP for the Alabama 

portion of the Chattanooga NAA on February 8, 2012 (77 FR 6469).

3.2.1.2 Section 176(c) –

The concept of transportation conformity was introduced in the CAA of 1977, but the 

requirements became substantially more rigorous in the Amendments of 1990. The CAA and 

the Safe, Accountable, Flexible, Efficient Transportation Equity Act – A Legacy for Users 

(SAFETEA-LU) define the framework for effective integration of transportation and air quality 

planning.
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Transportation conformity is a process by which it is determined that on-road mobile (highway) 

source emissions evaluated from the Transportation Improvement Program (TIP) and/or Long 

Range Transportation Plan (LRTP) will not adversely impact air quality in a determined area of 

nonattainment. Federal funding and approval are given to transportation activities that are 

consistent with air quality goals.

As part of the Jackson County attainment demonstration submitted in 2009, ADEM included a 

report entitled “Insignificance Determination for Transportation Conformity Under PM2.5 

NAAQS for Jackson County, AL”. The report, which was approved by EPA in a June 18, 2010,

Federal Register notice (75 FR 34735), shows that emissions of NOx and direct fine particles 

(PM2.5) from mobile sources in the small portion of Jackson County designated by EPA as 

nonattainment for the annual fine particle NAAQS, are an insignificant contributor to 

nonattainment of the PM2.5 NAAQS. Therefore, the Jackson County portion of the 

Chattanooga annual PM2.5 nonattainment area is not subject to transportation conformity. The 

analysis performed in the 2009 Insignificance Determination is presented below:

According to 40 CFR 93.109(f), there are several factors that are used to support a finding of 

insignificance for these transportation-related PM2.5 precursor pollutants. The first factor is the 

percentage of motor vehicle emissions in the context of the total SIP inventory. The second 

factor is the current state of the air quality in the area. The third factor is the absence of SIP 

motor vehicle emission control measures. Lastly, historical trends and future projections of the 

growth of motor vehicle emissions are reviewed. These factors are discussed in detail in the 

sections to follow. Each section supports the insignificance of NOX and direct PM2.5 emissions 

from mobile sources in the Jackson County portion of the nonattainment area under the 

transportation conformity rule for the PM2.5 NAAQS.

3.2.1.2.1 Nitrogen Oxides (NOX)

3.2.1.2.1.1 Analysis of motor vehicle NOX emissions in the Jackson County portion of the Chattanooga 

nonattainment area.

Only a small portion of Jackson County, Alabama, was included in the Chattanooga PM2.5

nonattainment area. The small portion of the county designated nonattainment contains a 

limited number of roads. In order to determine the on-road emissions of NOX from motor 

vehicles in that portion of Jackson County, the document titled “Chattanooga Nonattainment 

Area Year 2035 Conformity Determination Report for Particulate Matter (PM2.5)” was used to 

determine how emissions were calculated for Jackson County and the same methodology was 

applied in this analysis. In order to estimate on-road mobile source emissions for the 

nonattainment portion of Jackson County, a ratio of the size of the nonattainment portion of 

Jackson County in square miles to the size of the entire county in square miles was calculated. 

The nonattainment portion of Jackson County was determined to be only about one percent of 

the total area of the entire county. The same ratio was applied to obtain area and non-road 

mobile source emissions for the nonattainment portion of the county. The following table 

shows the small percentage of NOX emissions from on-road mobile sources as compared to 

NOX emissions from all other sources in the Jackson County portion of the nonattainment area. 

Emission data were obtained from the SEMAP 2007 base year emissions inventory.
DRAFT Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

3-3

Table 3.2.1.2.1.1-1 2007, 2017, 2025 NOX (TPY) Emissions in the Nonattainment portion of 

Jackson County by Source Type

Source 

Category

2007 

(attainment)

% of 

total 2017

% of 

total 2025

% of 

total

Point 18,591.83 99.668 3,468.44 98.962 3,607.05 99.27

Area 1.58 0.008 1.55 0.044 1.57 0.043

Nonroad 37.32 0.2 25.86 0.737 18.95 0.522

Mobile 23 0.123 9 0.257 6 0.165

Total 18,653.73 100 3,504.83 100 3,633.57 100

As the above table demonstrates, NOX emissions from on-road mobile sources in the 

nonattainment portion of Jackson County are 0.123% of the total NOX emissions from all 

source categories in the same area for 2007, 0.257% for 2017, and 0.165% for 2025.

In the table below, a comparison is made of the mobile source NOX emissions from the 

nonattainment portion of Jackson County to total mobile source NOX emissions for the entire 

Chattanooga nonattainment area.

Table 3.2.1.2.1.1-2 2007, 2017, 2025 NOX (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions 

in the entire Chattanooga NAA

Area

2007 

Emissions 

(TPY)

Percentage 

of Total

2017 

Emissions 

(TPY)

Percentag

e of Total

2025 

Emissions 

(TPY)

Percentage 

of Total

Jackson County 

NAA Portion 23 .18% 9 .11% 6 .16%

Chattanooga 

NAA 12,773 8,105 3,827

As the table above demonstrates, NOX emissions from on-road mobile sources in the Jackson 

County portion of the nonattainment area are .18% of the total NOX emissions from on-road 

mobile sources in the entire Chattanooga nonattainment area for 2007, .11% for 2017, and .16% 

for 2025. 

3.2.1.2.1.2 The current state of the air quality in Jackson County.

As stated earlier in this document, the small portion of Jackson County, Alabama, was included 

in the Chattanooga PM2.5 nonattainment area due to the fact that a power plant is located in that 

area and it was thought by EPA to contribute to the PM2.5 problem in Chattanooga. There are 
DRAFT Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

3-4

no PM2.5 monitors located in Jackson County. Monitors in Alabama near Jackson County have 

monitored values below the annual PM2.5 NAAQS. Other counties surrounding the county are 

either in attainment or unclassifiable. 

3.2.1.2.1.3 The absence of SIP motor vehicle controls for the area.

There are no SIP motor vehicle controls for Jackson County.

3.2.1.2.1.4 Historical trends and future projections of the growth of motor vehicle emissions.

The “Chattanooga Non-Attainment Area Year 2035 Conformity Determination Report for 

Particulate Matter (PM2.5)” was used to obtain past and future projections of the growth in NOX

emissions from on-road mobile sources. As demonstrated in the table below, future emissions 

of NOX are expected to decrease. 

Table 3.2.1.2.1.4-1 Historical and Future Projections of NOX emissions from On-Road 

Mobile Sources in Jackson County

Year Emissions (TPY)

2002 21.31

2009 12.87

2015 7.17

2025 4.11

2035 3.71

3.2.1.2.2 Direct PM2.5

3.2.1.2.2.1 Analysis of motor vehicle PM2.5 emissions in the Jackson County portion of the 

Chattanooga nonattainment area

Only a small portion of Jackson County, Alabama, was included in the Chattanooga PM2.5

nonattainment area. The portion designated as nonattainment contains a limited number of 

roads. In order to determine the on-road emissions of PM2.5 from motor vehicles in that portion 

of Jackson County, the document titled “Chattanooga Non-Attainment Area Year 2035

Conformity Determination Report for Particulate Matter (PM2.5)” was used to determine how 

emissions were calculated for Jackson County and the same methodology was applied in this 

analysis. In order to estimate on-road mobile source emissions for the nonattainment portion of 

Jackson County, a ratio of the size of the nonattainment portion of Jackson County in square 

miles to the size of the entire county in square miles was calculated. The nonattainment portion 

of Jackson County was determined to be only about one percent of the total area of Jackson 

County. The same ratio was applied to obtain area and non-road mobile source emissions for 

the nonattainment portion of the county. The following table shows the small percentage of 

PM2.5 emissions from on-road mobile sources as compared to PM2.5 emissions from all other 
DRAFT Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

3-5

sources in the nonattainment portion of Jackson County. Emission data were obtained from the 

SEMAP 2007 base year inventory.

Table 3.2.1.2.2.1-1 2007, 2017, 2025 Direct PM2.5 (TPY) Emissions in the Nonattainment Portion 

of Jackson County by Source Type

Source 

Category

2007 

(attainment)

% of 

total 2017

% of 

total 2025

% of 

total

Point 755.49 96.194 534.89 94.79 534.89 94.682

Area 27.11 3.452 28.08 4.976 29.17 5.164

Nonroad 2.05 0.261 1.01 0.179 0.63 0.112

Mobile 0.73 0.093 0.31 0.055 0.24 0.042

Total 785.38 100 564.29 100 564.93 100

As the above table demonstrates, direct PM2.5 emissions from on-road mobile sources in the 

nonattainment portion of Jackson County are less than 1% of the total direct PM2.5 emissions 

from all source categories in the same area. 

In the table below, a comparison is made of the mobile source direct PM2.5 emissions from the 

nonattainment portion of Jackson County to total mobile source PM2.5 emissions for the entire 

Chattanooga nonattainment area.

Table 3.2.1.2.2.1-2 2007, 2017, 2025 Direct PM2.5 (TPY) On-road Mobile Source Emissions in the 

Nonattainment Portion of Jackson County Compared to Total On-road Mobile Source Emissions 

in the Entire Chattanooga NAA

Area

2007 

Emissions 

(TPY)

Percentage of 

Total

2017 

Emissions 

(TPY)

Percentage 

of Total

2025 

Emissions 

(TPY)

Percentage 

of Total

Jackson 

County NAA 

Portion

0.73 0.2% 0.31 0.2% 0.24 0.2%

Chattanooga 

NAA 390 197 134

As the table above demonstrates, direct PM2.5 emissions from on-road mobile sources in the 

Jackson County portion of the nonattainment area are 0.2% of the total direct PM2.5 emissions 

from on-road mobiles sources in the entire Chattanooga NAA for 2007, 2017, and 2025. 
DRAFT Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

3-6

3.2.1.2.2.2 The current state of the air quality in Jackson County.

The small portion of Jackson County, Alabama, was included in the Chattanooga PM2.5

nonattainment area due to the fact that a power plant is located in that area and it was thought 

by EPA to contribute to the PM2.5 problem in Chattanooga. There are no PM2.5 monitors 

located in Jackson County. Monitors in Alabama near Jackson County have monitored values 

below the annual PM2.5 NAAQS. Other counties surrounding the county are either in 

attainment or unclassifiable. 

3.2.1.2.2.3 The absence of SIP motor vehicle controls for the area.

There are no SIP motor vehicle controls for Jackson County.

3.2.1.2.2.4 Historical trends and future projections of the growth of motor vehicle emissions.

The “Chattanooga Non-Attainment Area Year 2035 Conformity Determination Report for 

Particulate Matter (PM2.5)” was used to obtain past and future projections of the growth in 

direct PM2.5 emissions from on-road mobile sources. As demonstrated in the table below, future 

emissions of direct PM2.5 are expected to decrease. 

Table 3.2.1.2.2.4-1 Historical and Future Projections of PM2.5 emissions from On-Road Mobile 

Sources in Jackson County

Year Emissions (TPY)

2002 0.413

2009 0.241

2015 0.155

2025 0.130

2035 0.136

Each of the factors set forth in 40 CFR 93.109(k) were reviewed for the transportation-related 

PM2.5 precursor pollutants NOX, SOX, and direct PM2.5. These reviews support the conclusion 

that mobile source emissions of NOX, SOX, and direct PM2.5 in the Jackson County portion of 

the Chattanooga annual PM2.5 nonattainment area are insignificant under the transportation 

conformity rule for the annual PM2.5 NAAQS. 

The report is included in this request as Appendix B.
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-1

4.0 Maintenance Plan

Section 175A of the CAA Amendments of 1990 defines the general framework of a 

maintenance plan. The core provisions include the attainment inventory, the maintenance 

demonstration, the verification of continued attainment, and the contingency plan.

4.1 Maintenance Demonstration

The required maintenance plan must become a part of the SIP and provide for maintenance 

of the air quality in the affected area for at least 10 years after designation. Specifically, the 

CAA requirement is that a maintenance plan that is at least 10 years in length (i.e., after 

EPA’s expected approval) be submitted with the redesignation request. Subsequently, 8 

years after redesignation and submittal of the initial maintenance plan, the State is required 

to submit an additional maintenance plan that shows maintenance for the remainder of the 

20 year period. Alabama has chosen 2025 as the end year of the initial maintenance plan for 

the Chattanooga NAA.

The general approach used for the maintenance plan to demonstrate that attainment of the 

annual PM2.5 standard will continue to be maintained is based upon restricting the future 

anthropogenic emissions to a level that is representative of attainment of the standard. If 

these future emissions are no greater than the actual emissions during a year in which 

attainment of the standard was monitored, then it can be assumed that attainment of the 

standard will also be achieved in future years.

The following sections discuss the attainment year inventory, the projected inventories, and 

verification of continued attainment. Table 4.4-1 shows a calculated safety margin for 

PM2.5, NOX and SO2 for each year in the maintenance plan.

4.2 Attainment Inventory 

2007 was selected as the year for the attainment year emissions inventory. 2007 is one of 

the three years (2007 – 2009) on which the Chattanooga area’s clean data determination is 

based. The pollutants inventoried and addressed in this maintenance plan are direct PM2.5, 

SO2, and NOx. The following emissions sectors are included in the inventory:

• Point sources (EGU and non-EGU).

• Nonpoint sources (including fire),

• Onroad mobile sources, and

• Nonroad mobile sources (including marine vessels, aircraft, and rail).

The 2007 inventory, with the exception of on-road mobile emissions, was prepared for 

Alabama by the contractors for the Southeastern Modeling, Analysis, and Planning 

(SEMAP) project. SEMAP is funded by the same ten states that participated in the Visibility 

Improvement – State and Tribal Association of the Southeast (VISTAS) project. Under the 

SEMAP project, emissions estimates are reported by county and source classification code 

(SCC). The SEMAP emissions inventories were developed using data from a number of 

sources, including state and local agencies and EPA’s National Emissions Inventory (NEI). 
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-2

ADEM developed the 2007 inventory of on-road mobile emissions. Please see Table 4.4-1

for a summary of the base year inventory.

4.2.1 Point Sources

Point sources captured in the inventory include stationary sources whose actual emissions 

equal or exceed 100 tons per year of SO2, NOx, or particulate matter. Emissions from point 

sources have been calculated for EGU and non-EGU sources.

There are only two point sources in the Jackson County portion of the NAA: TVA Widows 

Creek Plant and Rock-Tenn Mill Company, LLC – Stevenson Mill. 

Table 4.2.1-1 2007 Point Emissions (TPY)

Facility Unit NOx PM2.5 SO2

Rock-Tenn Mill Company, 

LLC - Stevenson Mill

Neutral Sulfite SemiChemical Recovery System 147.17 0.14 0.67 

No. 1 Power Boiler 99.85 34.08 45.78 

No. 2 Power Boiler 51.45 9.44 32.98 

No. 1 Wood Waste Boiler 251.68 42.53 1.01 

No. 2 Wood Waste Boiler 436.68 5.15 6.54 

 986.83 91.34 86.98 

TVA Widows Creek

Unit 1 1,646.00 20.00 3,550.00

Unit 2 1,706.00 7.04 3,673.00

Unit 3 1,750.00 111.00 3,766.00

Unit 4 2,028.00 18.40 4,363.00

Unit 5 1,316.00 20.40 2,834.00

Unit 6 1,818.00 2.21 3,911.00

Unit 7 3,694.00 63.10 6,519.00

Unit 8 3,647.00 422.00 4,101.00

17,605.00 664.15 32,717.00

Facility/Point Emissions Total 18,591.83 755.49 32,803.98

Emissions estimates for point sources in 2007 were obtained from SEMAP point source 

inventory v1.10. For more information regarding the SEMAP point inventory, please refer 

to Appendix C-1.

4.2.2 Nonpoint Sources 

Nonpoint sources can be defined as those sources and activities that are too small or too 

numerous to be handled individually in a point source inventory. Nonpoint sources captured 

in the inventory include stationary sources whose emissions levels of SO2, NOx, and

particulate matter are each less than 100 tons per year. Emissions from nonpoint sources in 

2007 were obtained from the SEMAP final nonpoint source inventory version 1.1. A default 

2007 nonpoint source inventory was created that includes all of the source categories 

covered by the 2008 nonpoint source NEI.
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-3

For all source categories, except industrial and commercial/institutional (ICI) fuel 

combustion, emissions data from the 2008 nonpoint source NEI were directly incorporated 

when the NEI emissions were based on 2007 emissions activity data. The NEI emissions 

estimates were recalculated to reflect 2007 activity levels when the NEI emissions reflected 

2006 or 2008 activity levels. Emissions associated with activity reflected in the point source 

inventory were removed from the nonpoint inventory.

For ICI fuel combustion, the 2008 nonpoint source NEI developed emissions activity 

estimates rather than emission estimates. Because of the potential importance of these 

source categories and the availability of methodological improvements, TranSystems1

utilized an emissions estimation method for ICI fuel combustion that incorporates a few 

refinements to the NEI method. These emissions were supplemented with carry-forward 

categories from Alabama’s 2005 Consolidated Emissions Reporting Rule (CERR)

submission grown using EPA’s Economic Growth Analysis System 5.0 (EGAS). For more 

information regarding the SEMAP nonpoint inventory, please refer to Appendix C-2.

Emissions from fires in 2007 were obtained from the SEMAP final “actual” fire emissions

inventory. This inventory was developed using 2007 burned area data submitted by 

Alabama, as well as updated fuel consumption and emissions factors. The 2007 nonpoint 

source emissions for Jackson County are presented in Table 4.2.2-1. 

Table 4.2.2-1 Jackson County NAA Nonpoint Source Emissions for 2007 (TPY)

Pollutant

Nonpoint 

(excluding 

fire)

Fire Total 

Nonpoint

SO2 0.1455 0.1083 0.2538

NOx 1.0722 0.5107 1.5829

PM2.5 25.363 1.7508 27.1138

The 2007 level of PM2.5 emissions from nonpoint sources, excluding fire, was 25.363

tons. This quantity accounted for about 3 percent of total PM2.5 emissions in Jackson 

County.

As area sources are largely a function of population, the ratio of the population of the single 

census block to the entire county’s population was applied to the county-wide area source 

emissions, as seen below:

Census Block Population/County Population * County-wide Area Source Emissions = 

Partial County Area Source Emissions 

 

1 TranSystems is supporting SESARM in the SEMAP project that is funded by the same ten states originally 

involved in the VISTAS project. The SEMAP project addresses the next phase of ozone, fine particle, and 

regional haze assessment obligations of the SESARM member states. The SEMAP project is designed to 

produce technical analyses to aid the participating agencies in developing SIPs required by the CAA.

In June 2010, TranSystems developed a set of “final” 2007 area and nonroad source base year inventory 

emission estimates.
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-4

1,469 / 53,227 * 38.85 TPY NOx = 1.0722 TPY NOx.

For fire emissions calculations, the ratio of the area of the single census block to the entire 

county’s area was applied to the county-wide fire emissions, as seen below:

Census Block Area/County Area * County-wide Fire Emissions = Partial County Fire 

Emissions

12.88 sq. miles/1127 sq. miles * 44.6891 TPY NOx = 0.5107 TPY NOx.

Population data used in calculations was taken from the 2010 Census.

4.2.3 On-road Mobile Sources

The U.S. EPA’s MOVES2010b mobile source emissions model was run in inventory mode 

to generate 2007 mobile source emissions for SO2, NOX and PM2.5 for Jackson County, 

Alabama. Local vehicle miles traveled (VMT) data for Jackson County was developed by 

the Alabama Department of Transportation (ALDOT) for 2007. The VMT data was used to 

make appropriate calculations in the development of the MOVES2010b input files.

The runspecs for all years modeled were developed using the same format. All were set to 

the county scale with all months, days and hours being modeled. The aggregation level was 

set to hour with the appropriate state and county being selected in the geographic bounds 

section. 

All relevant gasoline and diesel vehicles were chosen as well as all road types. The 

pollutants of concern were NOX, PM2.5 and SO2. For those pollutants where the emissions 

calculation is based on prior calculation of another pollutant, the appropriate base pollutants 

were also selected. “Tons” was selected as the emissions unit, and the emissions detail was 

aggregated to “year” in order to retrieve data in tons per year. Input data was then imported 

through the County Data Manager (CDM). 

MOVES2010b default data was exported, reviewed and re-imported for the following CDM 

inputs: Age Distribution, Average Speed Distribution, Fuel Supply, Meteorology and Ramp 

Fraction. Source Type Population, Vehicle Type, VMT, and Road Type Distribution were 

derived from either manual calculation or by using one of the converters provided by EPA. 

For Fuel Formulation, the Reid vapor pressure (RVP) was adjusted to 9.0 for MaySeptember with the default RVP being used for all other months.

The process of data collection and emissions modeling was conducted in accordance with 

the Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in 

State Implementation Plans and Transportation Conformity. The onroad mobile source 

emissions for the portion of Jackson County in the nonattainment area were derived by 

taking 1% of the total for all of Jackson County for each of the pollutants (SO2, NOx and 

PM2.5). 1% is based on the ratio of the size of the nonattainment portion of Jackson County 

in square miles to the size of the entire county in square miles. The 2007 onroad mobile 

source emissions totals for the portion of Jackson County in the nonattainment area are 

listed in Table 4.4-1 (Please also see Appendix C-3).
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-5

4.2.4 Nonroad Mobile Sources

The nonroad sector is comprised of nonroad engines included in EPA’s NONROAD model,

such as recreational marine and land-based vehicles, farm, construction and industrial 

machinery, and lawn and garden equipment. This sector also includes engines not modeled 

in NONROAD, specifically aircraft, commercial marine vessels (CMV), and locomotives. 

There are no aircraft emissions sources in the portion of Jackson County that is included in 

the nonattainment area. Nonroad mobile emissions for 2007 for the portion of Jackson 

County in the nonattainment area are presented in detail in Table 4.2.4-1 and summarized in 

Table 4.4-1. 

Emissions from NONROAD model source categories in 2007 were obtained from the 

SEMAP final nonroad mobile sources emissions inventory. These emissions were 

calculated using EPA’s latest National Mobile Inventory Model, NMIM2008, which 

incorporates EPA’s latest NONROAD model (NONROAD2008) and reflects all of EPA’s 

final nonroad standards to date. For more information regarding the SEMAP nonroad 

inventory, please refer to Appendices C-2, C-3 and C-4. Emissions from commercial marine 

vessels and locomotives for 2007 were obtained from the SEMAP final nonroad mobile 

source emissions inventory. For more information regarding the SEMAP marine, aircraft 

and locomotives inventory, please refer to Appendices C-2, C-3 and C4 

Nonroad sources encompass sources that are a function of population as well as sources that 

are more location specific. To develop more conservative nonroad estimates for the partial 

county, a population ratio was applied. The equation is below:

Census Block Population/County Population * County-wide Emissions = Partial County 

Emissions

Table 4.2.4-1 2007 Nonroad Mobile Source Emissions (tons)

Pollutant

(tons) Nonroad* CMV Locomotives Total

Nonroad

SO2 .55 .08 .28 .91

NOx 11.40 1.08 24.84 37.32

PM2.5 1.19 .03 .83 2.05

*Excludes CMV and Locomotives. 

4.3 Projected Emissions Inventory

Projected emissions inventories are calculated by applying applicable control and growth 

factors to the 2007 emissions of individual sources or source categories. The pollutants 

whose emissions are projected are SO2, NOx, and direct PM2.5. As with the attainment 

inventory, emissions from the following sectors are projected:

• Point sources (non-EGU).

• Nonpoint sources (including fire).
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-6

• Onroad mobile sources. and

• Nonroad mobile sources (including marine vessels, aircraft, and rail).

The projected inventories are presented in the following subsections and a summary can be 

found in Table 4.4-1. The methods used to develop the emissions projections are presented 

in more detail in Appendix C-4.

4.3.1 Point Sources

To establish 2017 and 2025 projected point emissions, the following issues were taken into 

account:

• A federal facilities compliance agreement between EPA and the Tennessee Valley 

Authority, Docket No. CAA-04-2010-1760 (Compliance Agreement) requires TVA 

Widows Creek to retire Units 1-6 by July 31, 2015 (Please see Appendix D).

• Power Boilers 1 and 2 at the Stevenson Mill are switching from Grade 6 Residual Oil 

to Natural Gas. The new permit limits are reflected in their Title V.

Growth rates for Widows Creek Units 1-6 were set to zero to reflect the retirement of those 

units. For Units 7 and 8, an average rate of growth was calculated based on emissions from 

2000-2010 as reflected in the Clean Air Markets Division Database. EGAS 5.0 factors were 

applied to all units at the Stevenson Mill; however, new base estimates were calculated for 

the two power boilers to reflect the switch in fuels. These estimates are based on similar 

units within the State. Please see Appendix C-4 for the projection calculations.

4.3.2 Nonpoint Sources

Nonpoint source emissions, excluding fire, in future years 2017 and 2025 were estimated 

using SCC- and county-specific growth factors generated with EGAS 5.0. Appendix C-4

contains the SCC- specific growth factors for Jackson County. Just as for the base year, the 

emissions were apportioned to the census block group by applying the ratio of block group 

population to county population. No additional future controls can be defined for these 

sources at this time. Emissions from fire in future years 2017 and 2025 were assumed to be 

the same as 2007 emissions. 

4.3.3 Onroad Mobile Sources

The U.S. EPA’s MOVES2010b mobile source emissions model was run in inventory mode 

to generate 2017 and 2025 mobile source emissions for SO2, NOx and PM2.5 for Jackson 

County, Alabama. Local VMT data for Jackson County was developed by the ALDOT for 

2017 and 2025. The VMT data was used to make appropriate calculations in the 

development of the MOVES2010b input files.

The same methodologies described in Section 4.2.3 for runspec and input file development 

were used for 2017 and 2025. The process of data collection and emissions modeling was 

conducted in accordance with the Technical Guidance on the Use of MOVES2010 for 

Emission Inventory Preparation in State Implementation Plans and Transportation 

Conformity. The same methodologies described in section 4.2.3 to calculate partial county 

emissions were also used for 2017 and 2025. The projected onroad mobile source emissions 
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-7

totals for the portion of Jackson County in the nonattainment area are listed in Table 4.4-1

(Please see Appendix C-3).

4.3.4 Nonroad Mobile Sources

Projections of nonroad emissions in 2017 and 2025, excluding commercial marine vessels 

and rail sources, were calculated using NMIM2008. Defaults in NMIM2008 were used for 

inputs. 

Category 1 & 2 growth and control factors were applied to the “diesel underway” category

(SCC2280002200). Growth factors for CMV emissions were calculated based on fuel 

consumption forecasts published by the Energy Information Administration (EIA). Table 67 

of EIA’s Annual Energy Outlook, 2010 provides national-level forecasts by domestic and 

international shipping sectors for years out to 2035 (EIA, 2010). Control factors were 

developed based on emission reductions calculated from national base case and control case 

inventories developed for the years 2002 through 2040. Growth and control factors were 

received from TranSystems/Pechan. The development of these growth and control factors is 

discussed in Appendix C-4. 

For Class I and Class II/III line haul and diesel switchyard operations, growth factors were 

calculated based on freight rail sector fuel consumption forecasts, as published by the EIA. 

Similar to CMVs, diesel locomotive engines are subject to revised Federal Tier 0, Tier 1 and 

Tier 2 standards, as well as Tier 3 and 4 standards. Control factors were developed for 

diesel-powered locomotive engine emissions based on EPA’s locomotive engine regulatory 

impact analysis and associated emission factor guidance. Growth and control factors were 

received from TranSystems/Pechan. The development of these growth and control factors is 

discussed in Appendix C-4. 

The nonroad mobile source emissions projections for the portion of Jackson County in the 

nonattainment area are presented in detail in Table 4.3.4-1 and summarized in Table 4.4-1. 

Total emissions of all three pollutants trend downward during the maintenance period. For 

more information regarding the nonroad inventory please see Appendices C-2, C-3 and C-4. 

Nonroad sources encompass sources that are a function of population as well as sources that 

are more location specific. To develop more conservative nonroad estimates for the partial 

county, a population ratio was applied. The equation is below:

Census Block Population/County Population * County-wide Emissions = Partial County 

Emissions
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-8

Table 4.3.4-1 Projected Nonroad Mobile Source Emissions (tons per year)

Source Type Pollutant 2007 2017 2025

Nonroad*

SO2 0.55 0.02 0.02

NOx 11.4 8.16 6.42

PM2.5 1.19 0.6 0.37

CMV

SO2 0.08 0.08 0.08

NOx 1.08 0.9 0.66

PM2.5 0.03 0.02 0.02

Locomotive

SO2 0.28 0.05 0.05

NOx 24.8 16.8 11.9

PM2.5 0.83 0.39 0.24

Total Nonroad

SO2 0.91 0.15 0.15

NOx 37.3 25.9 19

PM2.5 2.05 1.01 0.63

*Excludes CMV and Locomotives.
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-9

4.4 Maintenance Plan Inventory

Table 4.4-1 Jackson County, AL portion of the Chattanooga Annual PM2.5 Attainment Area 

Maintenance Plan Emissions (Tons per Year)

Source 

Category Pollutant 2007 (attainment)

% of 

total 2017 % of total 2025 % of total

Point

SO2 32,803.98 99.996 10,515.63 99.996 10,517.47 99.996 

NOX 18,591.83 99.668 3,468.44 98.962 3,607.05 99.270 

PM2.5 755.49 96.194 534.89 94.790 534.89 94.682 

Area

SO2 0.25 0.001 0.25 0.002 0.24 0.002 

NOX 1.58 0.008 1.55 0.044 1.57 0.043 

PM2.5 27.11 3.452 28.08 4.976 29.17 5.164 

Non-road

SO2 0.91 0.003 0.15 0.001 0.15 0.001 

NOX 37.32 0.200 25.86 0.737 18.95 0.522 

PM2.5 2.05 0.261 1.01 0.179 0.63 0.112 

Mobile

SO2 0.19 0.001 0.07 0.001 0.07 0.001 

NOX 23.00 0.123 9.00 0.257 6.00 0.165 

PM2.5 0.73 0.093 0.31 0.055 0.24 0.042 

Total

SO2 32,805.33 100.00 10,516.10 100.000 10,517.93 100.000 

NOX 18,653.73 100.00 3,504.83 100.000 3,633.57 100.000 

PM2.5 785.38 100.00 564.29 100.000 564.93 100.000 

Maintenance Plan Decrease from 2007

SO2 22,287.40 

NOX 15,020.16 

PM2.5 220.45 
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-10

Table 4.4-2 Maintenance Inventory for the Chattanooga NAA (TPY)

Source 

Category

NOx SO2 PM2.5

2007 2017 2025 2007 2017 2025 2007 2017 2025

Point

Chattanooga, 

TN 2,437 2,651 3,155 919 798 866 160 169 206 

Georgia 48 49 52 280 287 295 0 0 0 

Alabama 18,592 3,468 3,607 32,804 10,516 10,517 755 535 535 

Point Total 21,077 6,168 6,814 34,003 11,601 11,678 915 704 741 

Nonpoint/Area

Chattanooga, 

TN 3,415 4,090 4,881 333 383 441 875 1,001 1,122 

Georgia 359 414 456 77 82 87 1,548 1,807 1,998 

Alabama 2 2 2 0.25 0.25 0.24 27 28 29 

Nonpoint/Area 

Total 3,776 4,506 5,339 410 465 528 2,450 2,836 3,149 

Nonroad

Chattanooga, 

TN 1,792 1,003 675 99 14 16 154 101 64 

Georgia 633 372 277 27 8 9 51 32 22 

Alabama 37 26 19 1 0.15 0.15 2 1 0.63 

Nonroad Total 2,462 1,401 971 127 22 25 207 134 87 

Onroad

Chattanooga, 

TN* 8,308 5,554 2,799 59 43 28 255 117 98 

Georgia 4,442 2,542 1,022 20 15 11 134 80 36 

Alabama 23 9 6 0.19 0.07 0.07 0.73 0.31 0.24 

Onroad Total 12,773 8,105 3,827 79 58 39 390 197 134 

Total

Chattanooga, 

TN 15,952 13,298 11,510 1,410 1,238 1,351 1,444 1,388 1,490 

Georgia 5,482 3,377 1,807 404 392 402 1,733 1,919 2,056 

Alabama 18,654 3,505 3,634 32,805 10,516 10,518 785 564 565 

Total 40,088 20,180 16,951 34,619 12,146 12,271 3,962 3,871 4,111 

*Emissions for the Chattanooga, TN area are draft. Further, the maintenance demonstration for the Chattanooga, TN 

counties used 2016 as a mid-year rather than 2017. Therefore, the emissions estimates for TN in the 2017 column are 

actually 2016 values.
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-11

4.5 Plan to Maintain Air Quality

ADEM has implemented programs that will remain enforceable and are hereby submitted as 

the plan to ensure that maintenance of the annual PM2.5 standard will continue. Sources are 

prohibited from reducing emission controls ('anti-backsliding') following the redesignation 

of the area unless such a change is first approved by the EPA as a revision to the Alabama 

SIP that is consistent with Section 110(l) of the CAA.

The following regulatory programs will remain in place in the Chattanooga NAA:

• Federal Tier II Motor Vehicle Emissions Standards

• Federal On-road Diesel Engine Standards

• Federal Non-road Diesel Engine Standards

• Federal Marine Engine Requirements

• Federal Locomotive Requirements

• The Federal New Source Performance Standards under Section 111 (42 U.S.C. 7411)

• The Federal National Emissions Standards for Hazardous Air Pollutants (NESHAP) 

under Section 112 (42 U.S.C 7412)

• The Federal NOX SIP Call

• The Clean Air Interstate Rule2

• Georgia Rules for Air Quality Control Chapter 391-3-1 Rule (sss) “Multipollutant 

Control of Electric Steam Generating Units”

• The federal facilities compliance agreement between EPA and the Tennessee Valley 

Authority, Docket No. CAA-04-2010-1760 requiring TVA Widows Creek to retire 

Units 1-6. The compliance dates for this action are staggered as follows:

o 2 units by July 31, 2013;

o 2 units by July 31, 2014;

o 2 units by July 31, 2015.

The overall expected reductions are 15,111 tons per year of NOX and 28,192 tons per 

year of SO2. The consent decree further required year-round operation of the SCRs 

on Units 7 and 8 (See Appendix D).

• Rock-Tenn Mill Company, LLC – Stevenson Mill is switching from Grade 6 

Residual Oil to Natural Gas in the power boilers (units Z001 and X008). The new 

permit limits are reflected in their Title V.

 

2 The Cross-State Air Pollution Rule was vacated by the United States Court of Appeals for the District of 

Columbia Circuit on August 21, 2012. The Clean Air Interstate Rule was reinstated until a permanent 

transport rule is put into place; however, EPA’s modeling for the Transport Rule demonstrates the Chattanooga 

Area would be able to obtain the 1997 Annual PM2.5 standard even in the absence of the Transport Rule. 
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-12

4.5.1 Verification of Continued Attainment

Verification of continued attainment is monitored through the State of Georgia, the 

Chattanooga-Hamilton County Air Pollution Control Bureau, and the Tennessee Division of 

Air Pollution Control’s operation of the ambient fine particulate matter monitor network and 

the maintenance of updating the area's emissions inventory.

The current four ambient PM2.5 monitors that are operating in the annual PM2.5

nonattainment area will continue to operate unless a change(s) is approved by EPA. No 

plans are underway to discontinue operation, relocate, or otherwise affect the integrity of the 

ambient monitoring network in place. Any change would only be made if it is consistent 

with 40 CFR Part 58.

The Air Emissions Reporting Requirements (AERR) was promulgated by EPA on 

December 5, 2008. For the purposes of verifying continued attainment based upon the 

emissions inventory, the three main components of the inventory, point, area and mobile, 

will be updated on different schedules. The major point sources of air pollution will 

continue to submit data on their emissions on an annual basis. This has been required under 

40 CFR 51, Subpart Q for many years. For the area source and mobile source portions of 

the inventory, these emissions will continue to be quantified on a three-year cycle. 

4.5.2 Contingency Plan

Section 175A(d) of the CAA Amendments requires the inclusion of contingency provisions 

that would be implemented by the State to correct any future violation of the NAAQS in 

areas that had been redesignated as an attainment area. Alabama commits to adopt, within 

18 months of certification of a violation of the annual PM2.5 standard, one or more control 

measure(s) (contingency measures) as needed to re-attain the standard. The State of Alabama 

will use actual ambient monitoring data as the indicator or trigger to determine when these 

contingency measures, if deemed necessary, would be implemented. In accordance with

40 CFR 58, ambient fine particulate matter monitoring data that indicates a future violation 

of the annual PM2.5 NAAQS will begin the process to implement these contingency 

measures. Also, in the event that the annual average PM2.5 concentrations in a year at any 

individual monitor in the nonattainment area records a reading of 15 μg/m3 or higher, the 

State will evaluate existing control measures to determine whether any further emission 

reduction measures should be implemented at that time. If periodic emission inventory 

updates reveal excessive or unanticipated emissions growth greater than 30%, the State will 

evaluate existing control measures to determine whether any further emission reduction 

measures should be implemented at that time.

Several factors will be considered in determining the need for additional control measures in 

the event of a future year violation of the annual PM2.5 standard. Depending on when such 

future year violation occurs, additional local and regional emissions reductions may still be 

on the way from various regulatory programs. If a future year violation occurs, ADEM will 

consider the air quality impact of these various regulatory programs in determining the need 

for additional local reductions in emissions of direct PM2.5 and/or SO2. 

If deemed necessary, contingency measure(s) will be selected from the following types of 

measures or from any other measures deemed appropriate and effective at the time the 

selection is made:
Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

4-13

• Reasonably Available Control Measures (RACM) for sources of SO2 and PM2.5;

• Reasonably Available Control Technology (RACT) for point sources of SO2 and 

PM2.5;

• Expansion of RACM/RACT to area(s) of transport within the State; and

• Additional SO2 and/or PM2.5 reduction measures yet to be identified.

Any resulting contingency measure(s) will be based upon cost effectiveness, emission 

reduction potential, economic and social considerations, ease and timing of implementation, 

and other appropriate factors.

A timeline for the development of NOX, PM2.5 and/or SO2 regulations or permit conditions 

follows. This schedule initiates with certification of ambient air quality monitoring data 

indicating a violation of the annual PM2.5 NAAQS: 

Table 4.5.2-1 Schedule for Permit Revisions or Rule Revisions for Contingency Measures

1. Identify and quantify the emissions reductions expected to result in 

the future from existing and future state and federal regulatory 

programs. 

3 months

2. Use the best available air quality modeling to evaluate the air 

quality improvement expected to result in Jackson County from the 

programs and emissions reductions identified in step 1 above. 

6 months

3. Draft any needed permit conditions or SIP regulations. 3 months

4. Complete rulemaking or permit revision process and submit to 

EPA. 6 months

Completion no later than: 18 months

Jackson County Annual PM2.5 Nonattainment Area

Request for Redesignation to Attainment

5-1

5.0 Conclusion

The most recent three years of quality-assured PM2.5 monitoring data for the Chattanooga 

NAA demonstrate compliance with the NAAQS for annual PM2.5. This redesignation 

request and maintenance demonstration has been prepared to meet the requirements of the 

1990 CAAAmendments.