1 

# Appendix M



# State and Local Control Measures2 

## Kentucky’s Regulation s are located at:

Open Burning http://www.lrc.ky.gov /kar/401/063/005.htm

Fugitive Dust http://www.lrc.ky.gov /kar/401/063/010.htm

LouMetro Air Pollution Control Distri ct’s Regulations are located at:

Open Burning

http://www.louisvilleky.gov/NR/rdonlyres/94818773-D227-4F1B-A30D-1B3D2A0D8488/0/111FV10.pdf



## Fugitive Particulate Emissions

http://www.louisvilleky.gov/NR/rdonlyres/BBE8 C0CA-F988-4885-BB59-5775C 7304B63/0/114fv2.pdfJanuary 16, 2008 

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### Fine Particle Air Quality Task Force Report and Plan of Action

Executive Summary

Fine particulate matter (PM 2.5 ), a subset of inhalable partic ulate matter, is a mixture of solid particles and liquid droplets wi th diameters of 2.5 micrometers ( μ m) or less (for reference, the average human hair is about 70 μ m in diameter – 30 times larger than the largest fine particle). PM 2.5 is regulated as a criteria po llutant under the Clean Air Act. The federal primary annual standard for PM 2.5 is 15 micrograms per cubic meter ( μ g/m 3 ).

In April 2005, Jefferson and Bullitt Counties in Kentucky, and Clark, Floyd and portions of Jefferson County in Indiana, were de signated nonattainment for the annual PM 2.5 standard. Under federal law, Indiana and Kentucky are required to develop State Implementation Plan revisions (SIPs) due in April 2008, that outline how the Louisville

nonattainment area will meet the annual PM 2.5 standard by April 2010. There are many requirements for SIPs, such as identifying reasonably available c ontrol technologies and measures (RACT/RACM) for major sources and performing air quality modeling to

demonstrate attainment of the annual standard. In addition to targeting PM 2.5 control measures, states are also required to address controls for PM 2.5 precursor emissions, such as sulfur dioxide and oxides of nitrogen th at, under certain conditi ons, can lead to the

formation of PM 2.5 in the air.

In April 2007, the Fine Particle Air Qualit y Task Force (Task Force) was created by Mayor Jerry Abramson to identify, evaluate and recommend strategies for reducing PM 2.5 to achieve the annual PM 2.5 standard. The Louisville Metr o Air Pollution Control District (District) invited business leaders, environmental and health advocates, health professionals, neighborhood representati ves and regional and local government representatives to particip ate in the Task Force.

The Task Force formed working committees to perform central tasks such as: the

characterization of PM 2.5 pollution and its related health effects, collection and analysis of historical and projected air quality data, identifica tion of major sources of PM 2.5 and precursor emissions and strategies to reduce these emissions. As part of the development of such strategies, the committees of the Task Force compiled and synthesized information that may be used by the District in development of the SIP, such as an assessment of control measures to support the RACT/RACM analysis and modeling data

to be included in the at tainment demonstration.

Committee reports and recommendations are included in Section 4 (Health Committee), Section 5 (Emissions Inventory and Modeli ng Data Committee), Section 6 (Stationary and Area Source Committee), Section 7 (Mobile and Nonroad Mobile Source Committee) and Section 8 (Repor t and Plan of Action Committee). These efforts served as the basis for building consensus on final Task Force recommendations.

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### Fine Particle Air Quality Task Force Report and Plan of Action

Section 9 (Plan of Action) includes 63 Task Force recommendations aimed at reducing

PM 2.5 and precursor pollution from a variety of sources. These recommendations cover a broad combination of strategies that can be accomplished through local, state and regional efforts. Eight of the 63 were selected as leading recommenda tions, or strategies, that the Task Force deemed as implementa tion priorities. Leading strategies include aggressive retrofit and replacement of onroad and nonroad diesel fleets, local adoption of onroad and nonroad idling regulatio ns and enactment of local ordinances to prohibit open burning. Other leading strategies will require collaborative efforts, such as the District working with Kentucky and Indiana to reduce PM 2.5 precursor emissions from major regional sources within 150 mile s and working with local an d regional planning agencies to expand the evaluation of development plan and subdivi sion proposals for air quality impacts.

This Report and Plan of Action is the result of the collaborative efforts of Task Force members. The Task Force recognized th at regional modeling groups project the

Louisville nonattainment area to achieve the annual PM 2.5 standard by the 2010 attainment deadline with existing and planned controls from various programs, such as the Clean Air Interstate Rule (CAIR). The Ta sk Force also recognized the need to reduce

levels of PM 2.5 below the annual standard to protec t public health with an adequate margin of safety. This will require ongoing and continuous review of all sources of PM 2.5 and precursor emissions. Considering the potential for significant reductions to ambient

concentrations of PM 2.5 from CAIR and other federal programs, the Task Force agreed to reconvene in 2010, after implementation of Phase I of CAIR, to review available monitoring data, modeling results and health studies and determine whether additional

actions are advisable for the conti nuous improvement of air quality.

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### Fine Particle Air Quality Task Force Report and Plan of Action

Table of Contents

Section 1 Introduction ..................................................................................................... 1

1.1 Definition of Fine Particulat e Matter and its Precursors ........................................ 1

1.2 History of National Ambient Air Quality Standards for PM .................................. 2

1.3 Overview of SIP Requirements .............................................................................. 3

1.4 Pollutants to be Evaluated ....................................................................................... 5

Section 2 Related Federal, Regional, State and Local Actions .................................... 6

2.1 Federal Actions ....................................................................................................... 6

2.1.1 Regulatory Programs .......................................................................................... 6

2.1.2 Voluntary Programs ............................................................................................ 7

2.2 Regional Actions ..................................................................................................... 9

2.2.1 Association for Southeastern Integrated Planning Modeling ............................. 9

2.2.2 Lake Michigan Air Directors Consortium Modeling ........................................ 10

2.3 State and Local Actions ........................................................................................ 10

2.3.1 Kentucky Division for Air Quality ................................................................... 10

2.3.2 Indiana Department of Environmental Management ........................................ 11

2.3.3 Louisville Metro Air Pollution Control District ............................................... 12

Section 3 Fine Particle Air Quality Task Force .......................................................... 13

3.1 Development of the Task Force ............................................................................ 13

3.2 Committees of the Task Force .............................................................................. 13

3.2.1 Health Committee ............................................................................................. 13

3.2.2 Emissions Inventory and Modeling Data Committee ....................................... 14

3.2.3 Stationary and Area Source Committee ............................................................ 14

3.2.4 Mobile and Nonroad Mobile Source Committee .............................................. 14

3.2.5 Report and Plan of Action Committee .............................................................. 14

Section 4 Report of the Health Committee.................................................................. 15

4.1 Background ........................................................................................................... 15

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### Fine Particle Air Quality Task Force Report and Plan of Action

4.2 Committee Actions ............................................................................................... 16

4.2.1 Scientific Literature Review ............................................................................. 16

4.2.2 Goal or Standard ............................................................................................... 16

4.2.3 Regional and Local Contributions to PM 2.5 Pollution ...................................... 16

4.2.4 Health-based Goal ............................................................................................. 17

4.3 Committee Recommendations .............................................................................. 18

Section 5 Report of the Emissions Inventory and Modeling Data Committee ......... 20

5.1 Background ........................................................................................................... 20

5.2 Committee Actions ............................................................................................... 20

5.2.1 Historical Data .................................................................................................. 21

5.2.1.1 Monitoring Data ......................................................................................... 21

5.2.1.2 Emissions Inventory Data .......................................................................... 25

5.2.2 Projected Data ................................................................................................... 27

5.2.2.1 Boundaries and Assumptions ..................................................................... 27

5.2.2.2 Projected PM 2.5 Design Values .................................................................. 28

5.2.2.3 Emissions Inventory Data .......................................................................... 29

5.3 Committee Recommendations .............................................................................. 30

5.3.1 Information Needs ............................................................................................ 30

5.3.2 Data Collection Process .................................................................................... 31

5.3.3 Interpretation of Data ........................................................................................ 31

Section 6 Report of the Stationary and Area Source Committee .............................. 33

6.1 Background ........................................................................................................... 33

6.2 Committee Actions ............................................................................................... 33

6.3 Committee Recommendations .............................................................................. 34

6.3.1 Stationary Diesel Engines ................................................................................. 34

6.3.2 Emission Controls for Direct PM 2.5 .................................................................. 34

6.3.2.1 Direct PM 2.5 Controls for Electric Generating Units ................................. 34

6.3.2.2 Direct PM 2.5 Controls for Other Stationary Sources .................................. 35

6.3.3 Improved Capture of Particulate Emissions ..................................................... 36

6.3.4 Emissions Controls for PM 2.5 Precursors .......................................................... 36

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### Fine Particle Air Quality Task Force Report and Plan of Action

6.3.4.1 PM 2.5 Precursor Controls for Electric Generating Units ............................ 36

6.3.4.2 PM 2.5 Precursor Controls for Other Stationary Sources ............................ 37

6.3.4.3 Reduced Sulfur Content of Fuels ............................................................... 38

6.3.5 Energy Efficiency Measures ............................................................................. 38

6.3.6 Measures to Reduce Fugitive Dust ................................................................... 40

6.3.7 Open Burning .................................................................................................... 41

6.3.8 Woodstoves, Fireplaces and Wood Boilers ...................................................... 41

6.3.9 Charbroiling and Other Co mmercial Cooking Operations ............................... 42

6.3.10 Use of Consumer Products ................................................................................ 42

6.3.11 Charcoal Grilling .............................................................................................. 42

Section 7 Report of the Mobile and Nonroad Mobile Source Committee ................ 44

7.1 Background ........................................................................................................... 44

7.2 Committee Actions ............................................................................................... 44

7.3 Committee Recommendations .............................................................................. 46

7.3.1 Onroad and Nonroad Diesel Retrofit, Rebuild or Replacement ....................... 47

7.3.2 Diesel Idling Programs ..................................................................................... 48

7.3.3 Long-range Land Use and Transportation Planning Solutions ......................... 48

7.3.4 Emission Reductions or Accelerated Retirement of High Emitting Lawn and Garden Equipment ............................................................................................ 50

7.3.5 Emissions Testing and Re pair/Maintenance Programs ..................................... 50

7.3.6 Clean Burning Fuel Programs........................................................................... 50

7.3.7 Contracting for Low Emissions Specifications ................................................. 51

Section 8 Report of the Report and Plan of Action Committee................................. 52

8.1 Background ........................................................................................................... 52

8.2 Committee Actions ............................................................................................... 52

8.3 Committee Recommendations .............................................................................. 52

Section 9 Plan of Action ................................................................................................. 53

9.1 Leading Recommendations ................................................................................... 53

9.2 Recommendations for Re gional and State Action ................................................ 55

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### Fine Particle Air Quality Task Force Report and Plan of Action

9.2.1 Currently Achievable ........................................................................................ 55

9.2.2 Achievable in the Short-term ............................................................................ 55

9.2.3 Achievable in the Long-term ............................................................................ 56

9.3 Recommendations for Louisville Metro Government Action .............................. 56

9.3.1 Currently Achievable ........................................................................................ 56

9.3.2 Achievable in the Short-term ............................................................................ 56

9.3.3 Achievable in the Long-term ............................................................................ 57

9.4 Recommendations for District Action .................................................................. 58

9.4.1 Currently Achievable ........................................................................................ 58

9.4.2 Achievable in the Short-term ............................................................................ 59

9.4.3 Achievable in the Long-term ............................................................................ 63

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### Fine Particle Air Quality Task Force Report and Plan of Action

List of Tables

Table 1-1. Categories of Particulate Matter...................................................................1

Table 5-1. Annual PM 2.5 Means in μ g/m 3 for Area FRM Monitors...........................21

Table 5-2. Future Design Values for Local Monitors ..................................................28



### List of Figures

Figure 5-1. Map of Area PM 2.5 Monitors......................................................................21

Figure 5-2. PM 2.5 Design Values in μ g/m 3 for Area FRM Monitors ..........................22

Figure 5-3. Speciation Data for Louisv ille Metro and Kentucky, 2002 to 2006........23

Figure 5-4. Monthly Speciation Data from Monitor 21-111-0043 in 2006.................23

Figure 5-5. PM 2.5 Composition and Estimated Urban Excess for U.S. Cities ...........24

Figure 5-6. Source Apportionment, by Percen t, of Total Emissions in Jefferson County, KY Based on APCD 2005 Em issions Inventory Data ...............26

Figure 5-7. Maps of ASIP and LA DCO Regional Modeling Domains.......................27

Figure 5-8. ASIP 2002, 2009 and 2018 Emi ssions for the State of Kentucky ............29

Figure 5-9. ASIP 2002, 2009 and 2018 Emi ssions for Jefferson County, KY............30

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### Fine Particle Air Quality Task Force Report and Plan of Action

List of Appendices

Appendix 1: Acronyms and Abbreviations .................................................................66

Appendix 2: Fine Particle Air Quality Task Force Members....................................69

Appendix 3: Fine Particle Air Quality Task Force Committee Members................70

Appendix 4: Record of Heal th Committee Meeting Attendance...............................71

Appendix 5: List of source categories for starting point for identifying potentially

ava ilable control strategies for nonattainment area.............................72

Appendix 6: Stationary/Area Source Reduction Strategy Evaluation Matrix ........74

Appendix 7: DRAFT E.ON U.S. Planned Control Projects.......................................75

Appendix 8: Current and Planned Pollu tant Control Measures for Indiana

Utilities ......................................................................................................77

Appendix 9: Energy Efficiency Programs and Projects.............................................79

Appendix 10: Draft Idle Reduction Regulation ............................................................86

Appendix 11: Report and Plan of Acti on Committee Leading Recommendations ...88

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### Fine Particle Air Quality Task Force Report and Plan of Action

Section 1 Introduction

1.1 Definition of Fine Particulate Matter and its Precursors

According to the United States Environmental Protection Agency (EPA) 1 , particle pollution, also called particulate matter (PM), is a mixture of solid particles and liquid droplets found in the air. PM comes in ma ny sizes and shapes and may contain many different chemicals. Particles are generall y classified by their diameter, which is measured in micrometers ( μ m). The categories of PM are provided in Table 1-1. EPA monitors and regulates ambient concen trations of inhalable particles (PM 10 ) and fine particles (PM 2.5 ).

Table 1-1. Categories of Particulate Matte r

Particle Category Diameter ( μ m)
Inhalable (PM 10 ) ≤ 10 Coarse (PM 10-2.5 ) 10 to 2.5 Fine (PM 2.5 ) ≤ 2.5 Ultrafine (PM 0.1 ) ≤ 0.1

Fine particles can be emitte d directly by a source and may include organic carbon (OC), elemental carbon (EC) and crustal material (e.g. dust, sea salt, metals and other trace elements). This pollution is referred to in this Report and Plan of Action (Report) as

direct PM 2.5 . Fine particles can also be formed though chemical reactions of gaseous precursors in the atmosphere (e.g. ammonium nitrate and ammonium sulfate). Precursors include sulfur dioxide (SO 2 ), oxides of nitrogen (NO

x ), volatile organic compounds (VOCs) and ammonia (NH 3 ). In the Louisville nonattainment area, EPA has identified

SO 2 and NO

x as significant precursors contri buting to the monitored ambient

concentration of PM 2.5 . These two pollutants are collectively referred to as precursors in this Report. VOCs and NH 3 do not significantly contribut e to the formation of PM 2.5 in

this area.

The health effects associ ated with exposure to PM 2.5 can be considerable. Particles less than or equal to 2.5 μ m in diameter can be inhaled deep into the lungs and some may enter the bloodstream. Long-term exposure to PM 2.5 has been associated with adverse

health effects such as decr eased lung function, developmen t of chronic bronchitis and premature death. Short-term expos ure (i.e. hours or days) to PM 2.5 has been associated with a range of effects, including decreas ed lung function, increased respiratory symptoms, cardiac arrhythmias, heart attacks, emergency room visits for heart or lung disease and premature death. Although fine pa rticles affect the ge neral population to some degree, older adults, individuals with heart or lung diseas e and children are particularly sensitive to PM 2.5 exposure.

1 A list acronyms and abbreviations is included in Appendix 1.

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1.2 History of National Ambient Air Quality Standards for PM

On July 18, 1997, EPA announced new National Ambient Air Quality Standards (NAAQS) for PM. EPA revised the primary, or health-based, PM standards by setting a

new annual standard for PM 2.5 of 15 micrograms per cubic meter ( μ g/m 3 ) and a new 24-

hour PM 2.5 standard of 65 μ g/m 3 . The PM 10 standards were also revised and monitoring requirements were issued using new federal reference methods.

A number of events delayed the implementation of the 1997 PM NAAQS:

 In 1998, the Transportation Equity Act for the 21 st Century revised the deadline for publishing nonattainment de signations to provide additional time to collect three years of air quality monitoring data.

 In 1999, the 1997 PM NAAQS were challe nged in court by the American Trucking Association, the U.S. Chambe r of Commerce and other state and business groups.

 In 2001, the Supreme Court upheld EPA' s authority under the Clean Air Act (CAA) to set NAAQS that protect the Am erican public from harmful effects of air pollution. The Supreme Court also se nt the case back to the D.C. Circuit Court of Appeals to resolve several additional issues.

 In 2002, the D.C. Circuit Court rejected all remaining legal challenges to EPA's 1997 PM NAAQS.

Early in 2003, EPA provided guidance to states 2 for recommending nonattainment area

boundaries for the annual PM 2.5 standard. Consistent with the CAA, the guidance gave states the following instruction:

 Begin analysis of attainment and no nattainment area boundaries based on the boundaries of metropolitan areas.

 Include nearby counties with sources of direct PM 2.5 and precursor emissions in a metropolitan area’s nonattainment area.

 Give consideration to the use of common boundaries for areas to be designated nonattainment for PM 2.5 and 8-hour ozone to help coordinate future planning and implementation activities.

 Give consideration to population de nsity, traffic and commuting patterns, commercial development and area grow th when areas are recommended for attainment and nonattainment designation.

In mid-February 2004, states recommended areas to be designated nonattainment for the

annual PM 2.5 standard by EPA. After assessing thr ee years of monitoring data from 2001 to 2003, EPA designated areas not meeting the annual PM 2.5 standard. The nonattainment designations became effective on April 5, 2005 for 39 metropolitan areas, affecting a population of approximately 88 million across 20 8 counties in the United States. The area

that includes Jefferson and Bullitt Counties in Kentucky, and Clark, Floyd and portions

2 Throughout this Report, “states” is used to re ference any jurisdiction wi th appropriate authority.

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### Fine Particle Air Quality Task Force Report and Plan of Action

of Jefferson County in Indiana, was designa ted nonattainment (Loui sville nonattainment area). This designation plays an important ro le in letting the p ublic know whether air quality in their area is healt hy and becomes an important co mponent of state, local and tribal governments' efforts to reduce fine particle pollution.

On October 17, 2006, EPA published revised PM NAAQS that signific antly strengthened

the 24-hour PM 2.5 standard from 65 μ g/m 3 to 35 μ g/m 3 while retaining the annual PM 2.5 standard of 15 μ g/m 3 . In EPA’s judgment, the revi sed 24-hour standard provided adequate protection from short-term exposure to PM 2.5

.

The federal government has made the reduction of PM 2.5 a critical element of a comprehensive national clean air strategy. This strategy includes EPA's recent National Clean Diesel Campaign to reduce pollution from diesel engines and the Clean Air Visibility Rule and Clean Air Interstate Rule (CAIR) to redu ce pollution from power plants in the eastern U.S. These initiatives are important components of EPA's efforts to help states and localities meet the more protective PM 2.5 NAAQS through a largely regional approach.

1.3 Overview of SIP Requirements

By law, Indiana and Kentucky are subject to a number of requirements to reduce PM 2.5 , including submittal of State Implementation Plan revisions (SIPs), which outline how nonattainment areas, including the Louisville nonattainment area, will meet the annual

PM 2.5 standard. The SIP submission deadline is April 5, 2008, three years from the date of designation, as required by the CAA.

On April 25, 2007, EPA published the Clean Air Fine Particle Implementation Rule 3
(Implementation Rule), which describes the C AA framework and requirements that state, local and tribal governments must meet in developing their PM 2.5 SIPs. For areas designated as nonattainment, states are required to attain the annual PM 2.5 standard of 15 μg/m 3 by April 2010, five years from the date of designation. As part of the SIP, states may propose an attainment date extension of up to five years. Those areas for which EPA approves an extension must achieve complian ce as soon as possible, but no later than

2015. The Implementation Rule does not specifically addr ess implementation of the 24- hour standard, revised in 2006.

In compliance with 40 CFR 51 (sections numbers included below for reference), PM 2.5 SIPs must include the following components:

Attainment demonstration and modeling requirements (§51.1007) – States are required to submit attainment demonstrations consisting of:

3 Throughout this Report, underlined text indicates a link to related websites or documents. Links can be accessed in an electronic version of this Report available at http://www.louisvilleky.gov/APCD/TaskForce/ A detailed list of links to documents reviewed by the Task Force and committees can also be found there.

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 Technical analyses that locate, identi fy and quantify sources of emissions contributing to nonattainmen t of the standard.

 Analyses of future year emission reducti ons and air quality improvement resulting from already-adopted national and local programs, and from potential new local measures to meet RACT/RACM and RFP requirements (defined below).

 Adopted emission reduction measures with schedules for implementation.

 Contingency measures required under the CAA.

Emissions inventory requirements (§51.1008) – States must include a complete emissions inventory for all sources of PM 2.5 and precursor emissions in the nonattainment area. The inventory should include all so urce categories including stationary, onroad mobile, nonroad mobile and area sources.

Reasonable further progress (RFP) requirements (§51.1009) – States demonstrating attainment by April 2010 will be considered to have satisfied RFP requirements. However, states requesting an extended atta inment deadline must submit an RFP plan and supporting emissions inventory informati on, which describes incremental emission reductions needed to ensure progress towa rds attainment by the extended deadline.

Reasonably available control technology (RACT) and reasonably available control measures (RACM) requirements (§51.1010) – RACT and RACM include emission

reduction measures that are ne cessary to obtain the annual PM 2.5 standard as expeditiously as practicable or that would advance attainment of the standard by at least one year. States define measures as “reason ably available” through an analysis including

considerations for economic and technical feasibility. In the Implementation Rule , EPA presumes that implementation of CAIR cont rol measures are reasonably available and would satisfy, with certain restrictions, RACT/RACM for SO 2 and NO

x emissions from power plants. However, states may impose a dditional requirements on a specific source, large or small, if it determines that these requirements are both necessary and reasonable to expeditiously atta in the standard.

Transportation conformity requirement (§51.390) – States are required to determine appropriate motor vehicl e emissions budgets for PM 2.5 and precursors to satisfy transportation conformity requirements. Tr ansportation conformity, required under the CAA, ensures that federally supported highw ay and transit projec t activities reflect consideration for air quality issues. Conformity means that transportation activities will not cause new air quality viola tions, worsen existing violations or delay timely attainment of the relevant NAAQS ( 40 CFR 93 ). On March 10, 2006, EPA published a final rule that established transportation conformity crit eria and procedures for determining which transportation projects must be analy zed for local air quality impacts in PM nonattainment areas ( 71 FR 12468 ).

Contingency measures requirement (§51.1012) – States are required to include contingency measures, which are additional control measures to be implemented in the

event that an area fails to meet RFP or fails to attain the standard by its attainment date.

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### Fine Particle Air Quality Task Force Report and Plan of Action

States must show that contingency measur es can be implemented without significant further action by the state or EPA.

In addition, throughout 40 CFR 51 the basic requirements to receive federal approval of

emission reduction measures in the SIP are defined as:

 Surplus

– Emission reductions are considered su rplus as long as they are not

otherwise relied on in air quality-related programs al ready included in the SIP.

 Enforceable – Emission reductions and other requ ired actions must be enforceable against the source of emissions. State or local agencies are responsible for ensuring that voluntary emission reduc tions are achieved, making voluntary emission reductions enforceable against the agency.

 Quantifiable – Emissions and emission reductions attributed to the measure are quantifiable if someone can reliably and replicably measure or determine them.

 Permanent – An emission reduction measure is considered permanent if it continues throughout the term that the cr edit is granted, unless it is replaced by

another measure or the state demonstrates in a subsequent SI P revision that the

emission reductions from the measure are no longer needed to attain and maintain compliance with the annual PM 2.5 standard.

1.4 Pollutants to be Evaluated

There are five main types of pollutants that may be addressed in the SIP: direct PM 2.5 , SO 2 , NO

x , VOCs and NH 3 . The effect of reducing emissions varies depending on particle composition, emission levels and other area-speci fic factors. Therefore, EPA requires the following evaluation:

 Direct PM 2.5 must be evaluated for emission reduction measures in all nonattainment areas, but allows some fl exibility after the initial evaluation.

 SO 2 must be evaluated for emission re duction measures in all nonattainment

areas.

 NO

x must be evaluated for emission re duction measures in each area unless

the state and EPA demonstrate that NO

x is not a significant contributor to

PM 2.5 concentrations in a specific area.

 VOCs are not required to be evaluate d for emission reduction measures in

each area unless the state or EPA de monstrates that VOCs significantly

contribute to PM 2.5 concentrations in a specific area.

 NH 3 is not required to be evaluated fo r emission reduction measures in each

area unless the state or EP A demonstrates that NH 3 significantly contributes to

PM 2.5 concentrations in a specific area.

Demonstrations to show significance of VOCs and NH 3 or insignificance of NO

x must represent available information including speciation data analyses, air quality modeling studies, chemical tracer studies, emissions in ventories or special atmospheric chemistry studies. Only direct PM 2.5 , SO 2 and NO

x are considered significant for the Louisville

nonattainment area.

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### Fine Particle Air Quality Task Force Report and Plan of Action

Section 2 Related Federal, Regional, State and Local Actions

2.1 Federal Actions

There are a number of nati onal initiatives that are e xpected to reduce ambient PM 2.5 concentrations. These regulatory and voluntary programs, promulgated by EPA, will

reduce emissions of direct PM 2.5 as well as precursor emissions. The following are among those expected to have the greatest effect.

2.1.1 Regulatory Programs

Clean Air Interstate Rule (CAIR) – CAIR is a two-phased program that dramatically reduces and permanently caps emissions of SO 2 and NO

x from coal-fired power plants in

the eastern United States. Based on an asse ssment of the emissions contributing to interstate transport of air pollution and avai lable control measures, EPA has determined that achieving required reductions in the id entified states by cont rolling emissions from power plants is highly cost-effective. When fully implemented, CAIR will reduce SO 2 emissions from power plants in 28 eastern st ates and the District of Columbia by more

than 70% and NO

x emissions by more than 60% from 2003 levels. For more information, please visit http://www.epa.gov/CAIR/basic.html

.

Clean Air Visibility Rule – On June 15, 2005, EPA finalized amendments to the July 1999 regional haze rule. These amendments appl y to the provisions of the regional haze rule that require emission c ontrols known as best availa ble retrofit technology (BART) for industrial facilities emitting air polluta nts that reduce visibility by causing or contributing to regional haze. The pollutants include PM 2.5 and compounds that

contribute to PM 2.5 formation, such as NO

x , SO 2 , and under certain conditions, VOCs and

NH 3 . EPA evaluated three possible scenarios of actions states may take to comply with this rule. Under the medium stringency scen ario EPA estimates that implementation of

BART controls will reduce annual emissions of NO

x and SO 2 by approximately 600,000 and 400,000 tons, respectively. For more information, please visit http://www.epa.gov/air/visibility/index.html

.

Heavy-Duty Highway Diesel Rule – EPA established a comprehensive national control program that regulates a heavy-dut y vehicle and its fuel as a si ngle system. As part of this program, new emission standards took effect in model year 2007 and apply to heavy-duty highway engines and vehicles. These standard s are based on the use of high-efficiency catalytic exhaust emission control devi ces or comparably effective advanced technologies. Because these devices are damaged by sulfur, EPA also mandated the

reduction in the level of sulfur in highway diesel fuel by 97% in 2006.

EPA projects a 2.6 million ton reduction of NO

x emissions in 2030 when the current heavy-duty vehicle fleet is subs tantially replaced with newe r heavy-duty vehicles that comply with these emission standards. By 2030, this program will reduce annual

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### Fine Particle Air Quality Task Force Report and Plan of Action

emissions of non-methane hydrocarbons by 115,000 tons and PM by 109,000 tons. For more information, please visit http://www.epa.gov/ot aq/diesel/index.htm

.

Clean Air Nonroad Diesel Rule – EPA's Clean Air Nonroad Diesel Rule requires stringent pollution controls on diesel engines used in industries such as construction, agriculture and mining, and will sl ash sulfur content of diesel fuel. This nonroad diesel program combines cleaner engine technologies with cleaner fuel, similar to the onhighway diesel program. The new standard s will cut emissions from nonroad diesel engines by over 90%. Sulfur levels will be reduced in nonroad diesel fuel by 99% from 2006 levels (from approximately 3,000 parts per million [ppm] in 2006 to 500 ppm in 2007 to 15 ppm in 2010). The lower sulfur fu el will provide immediate public health benefits by reducing PM from engines in existing nonroad equipment. It also makes it possible for engine manufacturers to use advanc ed clean technologies, similar to catalytic technologies used in passenger cars. New engi ne standards take effect, based on engine horsepower, starting in 2008. EP A anticipates annual reductions of 738,000 tons of NO

x and 129,000 tons of PM. For more information, please visit http://www.epa.gov/otaq/diesel/index.htm

.

Tier 2 Vehicle and Gasoline Sulfur Program – Compared to Model Year 2003 and earlier, vehicles meeting the Tier 2 emissi on standards are much cleaner. For the first time, under this rule all passenger cars and lig ht trucks are covered by the same emission standards. The key to meeting the stringent Tier 2 emission standards has been the large

reduction of sulfur levels in gasoline. Sulfur in the fuel impairs the effectiveness of vehicle emission control systems. Vehicles meeting the Tier 2 emission standards are 77 to 95% cleaner, depending on vehicle size, compared with model year 2003 and earlier. EPA expects this program to reduce emissions of NO

x from vehicles by approximately 74% (nearly 3 million tons) by 2030. For more information, please visit http://www.epa.gov/tier2/

.

Proposed Emissions Standards for Locomotives and Marine Compression-Ignition Engines – This EPA proposed rule is another as pect of its clean diesel program that already has established rules for highway and other nonroad diesel equipment. In its regulatory announcement, EPA estimates th at by 2030 this comprehensive emission control program will reduce annual emissions of NO

x and PM by 765,000 and 28,000 tons, respectively, and the magnitude of these reductions c ould continue to grow well beyond 2030. For more information, please visit http://www.epa.gov/otaq/locomotv.htm

.

2.1.2 Voluntary Programs

National Clean Diesel Campaign (NCDC) – Building on EPA’s regulatory and voluntary efforts to reduce emissions from diesel engines, EPA created NCDC. Participants are committed to reducing diesel emissions and finding innovative ways to protect human health and the e nvironment. To address the challenges of reducing diesel emissions, NCDC is using a multi-pronged appr oach that includes regulations for clean diesel engines and fuels, EPA regional coll aboratives and partne rships and voluntary programs for the existing diesel fleet. In addition to providing a framework for

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partnerships and information for outreach a nd education, some of these programs also include grant money to support their goals . For more information, please visit http://www.epa.gov/cleandiesel/index.htm

.

Southeast Diesel Collaborative (SEDC) – SEDC is a voluntary, public/private partnership involving federal, state and local government, the private sector and other stakeholders in Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina and Tennessee. SEDC is part of EPA’s National Clean Diesel Campaign. The goal of SEDC is to improve air quality and public health by encouraging the use of clean, renewable energy and technology and by reducing diesel emissions from existing engines and equipment from the agriculture, heavy c onstruction and onroad sectors. For more information, please visit http://www.southeastdiesel.org

.

Clean School Bus USA – Clean School Bus USA brings toge ther partners from business, education, transportation and public health or ganizations to work toward these goals:

1. Encouraging policies and practices to eliminate unnecessary public school bus idling. 2. Upgrading (i.e. retrofitting) buses that will remain in the fleet with better emission control technologies and/ or fueling them with cleaner fuels. 3. Replacing the oldest buses in the fleet with new, less polluting buses.

For more information, please visit http://www.epa.gov/cleanschoolbus/

.

Clean Ports USA – Clean Ports USA is an incentive- based, voluntary program designed to reduce emissions from existing diesel e ngines and non-road equipment at ports with comprehensive strategies and information for the diverse range of por ts and their staff. For more information, please visit http://www.epa.gov/cleandiesel/ports/

.

Clean Construction USA – Clean Construction USA is a voluntary program designed to promote the reduction of diesel emissions from construction equipment and vehicles. Clean Construction USA encourag es contractors, owners a nd operators of construction equipment to properly maintain their equipm ent, reduce idling, retrofit diesel engines with verified technologies, replace older equipment, use cleaner fuels and repower equipment (i.e. replace older engines with newe r, cleaner engines). For more information, please visit http://www.epa.gov/cleandiesel/construction/

.

SmartWay Transport – The SmartWay Transport Pa rtnership is a voluntary

collaboration between EPA and the frei ght industry designed to increase energy efficiency while significantly reducing gr eenhouse gases and air pollution. There are three primary components of the program: cr eating partnerships, re ducing all unnecessary engine idling and increasing the efficiency and use of rail and intermodal operations. Several members of the freight industry that operate locally are already partners in the SmartWay program. For example, UPS, which has a significant pres ence in Louisville Metro, is a charter member of the SmartWay program. For more information, please visit http://www.epa.gov/smartway/index.htm

.

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Voluntary Diesel Retrofit Tec hnology Verification Program – This program offers information and technical support on retrofitting diesel engines to reduce toxic emissions. The objective of the voluntary Diesel Retr ofit Technical Verification Program is to introduce verified technologies to the market as cost-effectively as possible, while providing customers with confidence that verified technologies will provide emission reductions as advertised. For more information, please visit http://www.epa.gov/otaq/retrofit

.

Best Workplaces for Commuters (BWC) – This is a voluntary business/government program that distinguishes and provides national recognition to employers offering outstanding commuter benefits such as free or low-cost bus passes, strong telework programs, carpool matching and vanpool s ubsidies. EPA and the United States Department of Transportati on (DOT) assist participati ng employers by offering public recognition and promotion, technical assistance, training, web-based to ols and forums for information exchange.

Employers that meet EPA's National Standard of Excellence in commuter benefits are included on the BWC list, a fast -growing mark of ex cellence in environmental leadership. Sometimes outstanding commuter benefits are provided not by the employers themselves, but by another organization such as a busin ess park, downtown district, developer or property manager. To recognize these areas fo r their leadership, EPA designates them a

BWC District.

Smart Growth Program – Through research, tools, part nerships, case studies, grants and technical assistance, EPA is helping Amer ica's communities turn their visions of the future into reality. Smart growth practices can lessen the environmental impacts of development with techniques that include compact development, reduced impervious surfaces and improved water detention, safeguard ing of environmentally sensitive areas, mixing of land uses (e.g., homes, offices and shops), transit acce ssibility and improved pedestrian and bicycle amenities. For more information, please visit http://www.epa.gov/smartgrowth/index.htm

.

2.2 Regional Actions

Draft guidance from EPA indicated th at a significant requirement of PM 2.5 SIPs would be

attainment demonstrations usi ng, at least in part, modeling an alyses to define effective emissions control strategies and confirm that attainment can be achieved after implementation of the strategies. The fo llowing organizations conducted large scale regional modeling projects to help member stat es demonstrate projected attainment of the

annual PM 2.5 standard in their SIPs.

2.2.1 Association for Southeastern Integrated Planning Modeling

The Association for Southeastern Integrated Planning (ASIP) is a co llaborative effort to develop information upon which to base the PM 2.5 and 8-hour ozone attainment demonstrations. Collaborating states include Alabama, Florida, Georgia, Kentucky,

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Mississippi, North Carolina, South Carolina, Tennessee, Virginia and West Virginia. Several local air regulatory agencies, in cluding the Louisville Metro Air Pollution Control District (District), have also become signatory parties to this collaborative effort. ASIP operated regional scale, three-dimensional air quality models for ozone and PM 2.5 that simulate the emissions, chemical transf ormations and transport of PM and gaseous precursors in the eastern United States. A key element of this work includes the integration of emissions inventories and mode ls with regional transport models. Through regional modeling, ASIP worked with member states to demonstrate attainment of the

annual PM 2.5 standard. The ASIP regional ozone and PM 2.5 modeling builds off of the Visibility Improvement State and Tribal A ssociation of Southeast (VISTAS) Phase II 2002 annual modeling.

2.2.2 Lake Michigan Air Directors Consortium Modeling

The Lake Michigan Air Directors Consor tium (LADCO) was established in 1990 by the states of Illinois, Indiana, Michigan and Wisconsin. In March 2004, the states signed a new Memorandum of Agreement which added the state of Ohio as a member. The main purpose of LADCO is to provide technical assistance to its member states on problems of air quality; and to provide a forum for its me mber states to discuss air quality issues. LADCO's major pollutants of concern are ozone , fine particles and regional haze and their precursors; however, pr oblems related to other pollu tants (e.g. air toxics and greenhouse gases) may be assessed at the direction of the member states. LADCO's primary geographic focus is the area encomp assed by its member states and any areas which affect air quality in its member states. For more information, please visit http://www.ladco.org/about.html

.

2.3 State and Local Actions

In addition to the myriad of programs being ad ministered at the federal level, there are regulatory and voluntary programs at the state an d local level that ha ve the potential to

affect direct PM 2.5 and precursor emissions in the Louisville nonattainment area.

2.3.1 Kentucky Division for Air Quality

Open Burning – The Kentucky Division for Air Quality’s (KY DAQ) open burning rules allow for some materials to be burned; however, many materials, including garbage, construction materials and tires, are illegal to burn. The state open burning rules impose limits on when and where burning can occur. It is illegal to conduc t open burning in those counties that are designated as nonattainme nt for the 1-hour ozone, 8-hour ozone, PM 10 or PM 2.5 NAAQS during the months of May through September. Illegal burns are subject to a fine of up to $25,000. For more information, please visit http://www.air.ky.gov/homepage_repository/Open+Burning.htm

.

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2.3.2 Indiana Department of Environmental Management

Open Burning – Open burning is generally prohibited in Indiana. However, there are exceptions, which are described in the rules on open burning, found in 326 IAC 4 . In addition to the listed exceptions, permits ma y be obtained from the Indiana Department of Environmental Management (IDEM) to e ngage in open burning. Approval of an open burning permit is subject to evaluation based on several criteria incl uding whether or not the burning site is located in a county that is designated nonattainment for PM 10 or ozone. Residential open burning (i.e. hous ehold or yard waste) is tota lly banned in Lake, Porter, Clark and Floyd Counties, and no permits are granted for burning in those counties. For more information, please visit http://www.state.in.us/idem/your_e nvironment/air_quality/openburning/

.

DieselWise Web Resource – As part of IDEM’s contin uing education and outreach program associated with ozone and fine par ticles, the DieselWise web page provides a reference point for various diesel and alternat ive fuel topics. These topics include: health issues, idling issues, Indiana diesel reduc tion initiatives and pr ojects, school-related programs, alternative fuels and diesel retrof it technologies. For more information, please

visit http://www.state.in.us/idem/programs/air/dieselwise/index.html

.

State-Sponsored Retrofit Projects – In partnership with the Indiana Department of Transportation (INDOT), IDEM helped develop and implement a program to retrofit over 500 INDOT heavy-duty dies el trucks, many of which operate out of the Seymour District

in Southern Indiana. The emission reductions from this “lead by example” program will be realized on a regional , as well as local, level.

School Bus Idle Reduction – In cooperation with the School Transportation Association of Indiana (STAI), IDEM introduced a volunt ary reduced-idling prog ram across Indiana. This policy was unanimously adopted by STAI members at its annu al conference in 2004 and is being implemented by the greater majo rity of Indiana schools, including those in Southern Indiana. Benefits of implementing th is policy include: prot ecting the health of student passengers and school bus drivers, re ducing air pollutants that contribute to high ozone and fine particles in a commun ity, and saving money by lowering fuel consumption and maintenance costs. For more information, please visit http://www.state.in.us/idem/program s/air/dieselwise/schoolbuses.html

.

Rail and Port Projects – In partnership with The Ports of Indiana-Jeffersonville and MG Rail, Inc., IDEM received an EPA grant award to improve air quality and the quality of life in and around this Ohio River port. Four locomotives operate nearly 24 hours per day, 7 days per week at The Ports of Indiana- Jeffersonville facility. This project will add auxiliary power units to two of the locomotives to dramatically reduce unnecessary idling. In addition, two slug-units (i.e. non-powered locomotives with active electromotive drive) will be mated to existi ng locomotives allowing these mated pairs to move twice the number of rail cars per di esel powered locomotive, thereby making significant reductions in fuel consumption as well as harmful diesel emissions.

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2.3.3 Louisville Metro Air Pollution Control District

Open Burning – Open burning is generally prohibit ed in Louisville Metro. There are exceptions, however, including a broad acceptance of noncommercial cooking (e.g. backyard grilling), as well as specially perm itted fires, such as bon fires, fire-training exercises and agricultura l fires. For more information, please visit http://www.louisvilleky.gov/APCD/EE/OpenBurning.htm

.

Ozone Air Quality Task Force – The Ozone Air Quality Task Force was created in 2003 to help develop a long-term strategy to improve Louisville Metro’s air quality. The group’s responsibility was to identify, evalua te and recommend strategies to the Air Pollution Control Board (Board) to be incl uded in a new SIP for the 8-hour ozone standard. The task force presented the Bo ard with a report in January 2006, which

included recommendations for increased di esel retrofits, an idling regulation and

reduction measures at air ports, among others. Several of the task force’s

recommendations could also help reduce emissions of PM 2.5 throughout the Louisville nonattainment area. For more information, please visit http://www.louisvilleky.gov/APCD/B oard/AirQualityTaskForce.htm

.

Strategic Toxic Air Reduction (STAR) Program – The District’s STAR program, designed to reduce toxic air contaminants, wa s created in response to several studies

which demonstrated that Louisville Me tro had unacceptably high levels of toxic chemicals in the air. There are three key components of the STAR program. The first component establishes the framework and meth odologies for determining risk associated with toxic air pollution. The s econd regulates toxic emission s from large and moderate industrial and commercial operations. The third component addresses smaller sources (e.g., dry cleaners, diesel trucks, marine vessels) through the creation of a plan of action, including stakeholder involvement. The STAR 5.30 Stakeholder Group recommended strategies for reducing toxi c emissions from these sources. Several of the group’s

recommendations could also reduce emissions of PM 2.5 . For more information, please

visit http://www.louisvilleky.gov/APCD/STAR

.

Partnership for a Green City (PGC) – The PGC began in August 2004, as a major step toward overcoming challenges to Louisville Metro's environmental practices. The PGC represents a collaborative effort to improve environmental education, health and management by three of Louisville Metro' s largest public entitie s: Louisville Metro Government, the University of Louisville (U of L) and the Jefferson County Public Schools (JCPS). Together, these agencies ow n more than 500 buildings, 7,000 vehicles and 25,000 acres of land in Louisville Metr o. Through the coordination of efforts and cooperation, the PGC has been able to realize results that will have long-term impacts on the health, education and we ll-being of Louisville Metro citizens. The PGC’s Climate Change Committee is preparing a community-wide plan for reducing greenhouse gases in

the Louisville Metro area. Other PGC co mmittees are working on improving energy efficiency, increasing green purchasing and decreasing fleet emissions among the partner entities. PGC efforts could also help reduce emissions of PM 2.5 . For more information, please visit http://www.jefferson.k12.ky.us/Departmen ts/EnvironmentalEd/GreenCity/

.

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Section 3 Fine Particle Air Quality Task Force

3.1 Development of the Task Force

The Fine Particle Air Quality Task For ce (Task Force) was created by Mayor Jerry Abramson in April 2007 to identify, evaluate and recommend strategies for reducing

PM 2.5 to achieve the annual PM 2.5 standard. The District invited business leaders, environmental and health advocates, health professionals, nei ghborhood representatives and regional and local governme nt representatives to participate in the Task Force. Dr.

Robert Powell and Mr. Patrick Moran co-chaired the Task Force. A full list of Task Force members is included as Appendix 2.

After initial meetings to review back ground information and establish goals and expectations, the Task Force formed worki ng committees to perfor m central tasks such

as: the characterization of PM 2.5 pollution and its related heal th effects, collection and analysis of historical and projected air qual ity data, identification of major sources of

direct PM 2.5 and precursor emissions in the L ouisville nonattainment area and the recommendation of strategies to reduce these emissions. As part of the development of such strategies, the committees compiled and synthesized information that may be used by the District in development of the SIP, su ch as an assessment of control measures to support the RACT/RACM analysis and modeling data to be included in the attainment

demonstration.

Throughout the process, the Task Force and it s committees heard presentations on federal

PM 2.5 standards and implementation guidance, air quality monitoring, federal emission and fuel requirements, the co-benefits of local ozone and toxics programs, PM 2.5 speciation data and regional modeling results.

Committee reports and recommendations are included as Section 4 (Health Committee), Section 5 (Emissions Inventory and Modeli ng Data Committee), Section 6 (Stationary and Area Source Committee), Section 7 (Mobile and Nonroad Mobile Source Committee) and Section 8 (Repor t and Plan of Action Commit tee) of this Report. The

members of each committee are listed in Appendix 3.

As committee work concluded, committee reports and recommendations were submitted

to the full Task Force for consideration. The Task Force members then began discussions on the plan of action that was recommended to the Board at its January 2008 meeting.

3.2 Committees of the Task Force

3.2.1 Health Committee

The Health Committee was formed to focus on issues related to the health effects of

PM 2.5 exposure. The primary task of the H ealth Committee was to determine whether there is a theoretically “safe” level of ambient PM 2.5 and whether public health concerns

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related to PM 2.5 exposure could be further addressed by setting a goal to reduce ambient

PM 2.5 to levels more stringent than the annual standard of 15 μg/m 3

.

3.2.2 Emissions Inventory and Modeling Data Committee

The Emissions Inventory and Modeling Data Committee was formed to support the Task Force and its committees with the collection, distribution and understa nding of technical

information related to PM 2.5

.

3.2.3 Stationary and Area Source Committee

The Stationary and Area Source Committee was formed to identify stationary and area

sources of direct PM 2.5 and precursor emissions and the control measures being implemented throughout the Louisville nonattainment area. The committee considered various educational, voluntary and regul atory strategies for reducing direct PM 2.5 and precursor emissions.

Stationary sources are generally industrial or commercial operations subject to the District’s permit requirements and include those companies with Title V, Federally Enforceable District Origin Operating Pe rmits (FEDOOPs) and minor source permits. Area sources include anthropogenic sources of emissions that are not considered stationary, onroad mobile or nonroad mobile. Examples of area sour ces include backyard charcoal grilling, wood burning a nd commercial charbroiling.

3.2.4 Mobile and Nonroad Mobile Source Committee

The Mobile and Nonroad Mobile Source Comm ittee was formed to identify onroad and

nonroad mobile sources of direct PM 2.5 and precursor emissions and the control measures being implemented throughout the Louisville nonattainment area. The committee considered various educational, voluntary a nd regulatory strategies for reducing direct

PM 2.5 and precursor emissions.

Onroad mobile sources are motorized vehicles that are registered for use on public roads and highways, including automobiles, light- and heavy-duty trucks, buses and motorcycles. Nonroad mobile sources are moto rized vehicles that are not registered for use on public roads and highways or any other equipment with a foss il fuel-fired engine that is not a point source. Examples include aircraft, boats, railroad engines, construction equipment and nonroad recreational equipment.

3.2.5 Report and Plan of Action Committee

The Report and Plan of Action Committee was formed to oversee documentation of the issues reviewed and the process under taken by the Task Force to determine recommendations for reducing ambient concentrations of PM 2.5 . The work product of this

Committee was this Fine Particle Air Quality Task Force Report and Plan of Action which was submitted to the Board at its January 2008 meeting.

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Section 4 Report of the Health Committee

4.1 Background

The task of the Health Committee (Committee) was to determine whether the community should address public health concerns re lated to ambient c oncentrations of PM 2.5 by establishing a goal more st ringent than the annual PM 2.5 standard of 15 μg/m 3 . The Committee met and reviewed background information on PM 2.5 , peer-reviewed scientific literature regarding the health effects of PM and the acti ons of states and concerned organizations to address more stringent heal th-based goals and standards. A record of attendance at each meeting is included as Appendix 4.

Several organizations (e.g. the Clean Air Sc ientific Advisory Committee [CASAC], the

American Medical Association and the Amer ican Public Health Association) have

determined that the annual PM 2.5 standard of 15 μg/m 3 is not adequate for protecting public health and have recommended that mo re stringent standard s are necessary. Other organizations (e.g. the Utility Air Regul atory Group, the National Association of

Manufacturers and the U.S. Chamber of Commerce) believe the annual PM 2.5 standard to be sufficiently protective of public health and have opposed any further reduction in the annual standard without adequate supporting scientific evidence.

In the 2006 Review of the National Ambient Air Quality Standard for Particulate Matter

, EPA technical staff recommended a primar y annual standard between 15 and 12 μg/m 3

. CASAC also advised EPA to adopt a stricter annual PM 2.5 standard, in the range of 14 to 13 μg/m 3 . In a September 2006 letter to EPA Ad ministrator Steven Johnson , CASAC

cited:

...clear and convincing scientific evidence that significant adverse human-health effects occur in response to short-term and chronic particulate matter exposures at and below 15 μg/m 3 , the level of the current annual PM 2.5 standard.

The letter also stated that:

It is the CASAC’s consensus scientific opinion that the decision to retain without change the

annual PM 2.5 standard does not provide an “adequate margin of safety ... requisite to protect the public health” (as required by the Clean Air Act), leaving parts of the population of this country at significant risk of adverse health effects from exposure to fine PM. Significantly, we wish to point out that the CASAC’s recommendations were consistent with the mainstream scientific advice... [T]o our knowledge there is no science, medical or public health group that disagrees with this very important aspect of the CASAC’s recommendations.

After reviewing information and recommendations received from internal technical staff, CASAC and extensive public comments, EPA determined that the annual PM 2.5 standard of 15 μg/m 3 was sufficient and met the requirement of the CAA to protect public health with an adequate margin of safety. This conclusion has been challenged and will be subject to judicial review.

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Some states have implemented strategies to set forth more stringent health goals and

standards. California has an annual PM 2.5 standard of 12 μg/m 3 , Vermont is in the process of adopting an annual PM 2.5 standard in the range of 14 to 13 μg/m 3 and New Jersey is in the process of adopting 12 μg/m 3 as an annual health-based goal for their SIP, citing no

safe level of PM 2.5 . Additionally, the World Health Organization’s (WHO) guideline

value for PM 2.5 is 10 μg/m 3

.

4.2 Committee Actions

4.2.1 Scientific Literature Review

To determine the advisability of a more st ringent goal for the local area, the Committee

reviewed available information on ambient PM 2.5 concentrations, emission levels andrelated health effects. The Committee also performed a preliminary review of healthbased, peer-reviewed scientif ic literature. The Committee reviewed literature which stated that chronic and acute exposure to ambient PM 2.5 concentrations below the current EPA regulatory standards corre lated to increases in car diovascular and lung cancer mortality, as well as increased incide nce of: asthma, cough, pneumonia, chronic bronchitis, change in lung function, change in heart rhythm, doctor visits and hospitalization.

4.2.2 Goal or Standard

The Committee initially discu ssed the implications of setting a health-based goal rather than adopting a more stringent annual PM 2.5 standard. The Committee decided that a health-based goal should be adopted and th at the strategies re commended by the Task Force could give adequate consideration to what is achievable, or attainable, through implementation of control strategi es on local and regional scales.

Consistent with the structure and principles of the CAA, the adoption of health-based goals should not be confused with econo mic or technological considerations in achievement of regulatory standards, but shoul d instead establish th e goal based solely on protection of public health (including the health of sensitive s ubpopulations) with an adequate margin of safety to account for the uncertainties in scientific knowledge of lowdose exposure. Questions of implementation of measures to achieve those goals, and particularly of whether regul atory control measures are appropriate to achieve ambient

PM 2.5 concentrations below regulator y standards, are properly distinct from the healthbased goal, as has been reaffirm ed by Congress and the courts.

4.2.3 Regional and Local Contributions to PM 2.5 Pollution

The local contribution to the total ambient PM 2.5 concentration in Jefferson County, Kentucky is estimated to vary be tween 10 and 20% (1.6 to 3.3 μg/m 3 ). The remaining contribution is generally attr ibuted to regional transport. Therefore, lowering ambient

PM 2.5 concentrations to levels needed to pr otect public health will require coordinated efforts locally and throughout the regional airs hed. Successful models exist for regulating

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pollution to protect public health through a c oordinated regional approach, such as the Ozone Transport Commission and the Ohio River Valley Water Sanitation Commission.

The Committee recommends the Board devel op such a strategy within and among the states to coordinate meaningf ul reductions in direct PM 2.5 , precursor emissions and other regional pollutants.

4.2.4 Health-based Goal

There is no theoretically “s afe” level of exposure to PM 2.5 in the ambient air. Epidemiologic evidence suggests adverse health effects of PM 2.5 exposure at annual averages less than 15 μg/m 3 , while EPA has identified significant uncertainties in

modeled risk values for ambient PM 2.5 concentrations below 13 μg/m 3 ( EPA/600/R06/063 and EPA/600/P-99/002aF-bF ).

The Committee was presented the most rece nt regional modeling results. A detailed explanation of the following results is incl uded in Section 5 of this Report. ASIP projected that annual PM design values for monitors in the Louisville nonattainment area will decrease from the 2002 base-year design values of 16.8 to 14.9 2.5 μg/m 3 , to 15.0 to

13.1 μg/m 3 as early as 2009, and 14.1 to 12.2 μg/m 3 by 2018. LADCO reported that, due in part to implementation of CAIR, projected annual PM design values for monitors in

the Louisville nonattinment area will decrease from the 2005 base-year design values of

16.5 to 14.7 2.5

μg/m 3 , to 13.6 to 12.1 μg/m 3 as early as 2009, and 13.2 to 11.5 μg/m 3 by 2018. These results were considered by the Committee during discussion regarding the attainability of a goal lowe r than the annual standard.

Independent of air quality concerns, the Loui sville Metro population continues to have higher reported incidence of asthma and ot her respiratory illnesses, cardiovascular illnesses and infant mortality, in addition to higher rates of tobacco use than other communities in the U.S., which has been historically documented for the local population 4 . Furthermore, Louisville Metro aspires to be a world-class city, necessitating a healthy ambient environment to attract and maintain business and a productive

workforce

. Numerous opportunities for improved effici encies and efficacies have yet to be fully employed throughout the airshed. In light of these findings, the Committee achieved consensus in suppor t of a recommendation for establishing an ongoing and continuous process of review of all sources and categories of PM 2.5 emissions, and developing and implementing strategies to continue progress towards reducing ambient

PM 2.5 concentrations, so as to protect public heal th with an adequate margin of safety.

The Committee members also recognize that additional reductions below the annual

PM 2.5 standard may be advisable to provide an additional margin of safety that allows and compensates for scientific uncertainty, as well as the lack of precise predictions regarding the health impacts of air pollution on a multiplicity of potentially susceptible subpopulations. A majority of the Committee additionally decided to recommend an

4 As noted in the Louisville MSA Community Assessment Factbook produced by The Lewin Group on behalf of the UAW/Ford Motor Company.

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interim health-based annual goal of 12 to 10 μg/m 3 , to be achieved by 2018, while the minority did not support esta blishing specific numeric goa ls or deadlines beyond the federally prescribed annual PM 2.5 standard.

4.3 Committee Recommendations

The Committee met on October 25, 2007 and, except as noted below, reached consensus on the following recommendations to be presented to the full Task Force for its

consideration.

Recommendation 1:

The District should reiterat e the principle that ambien t concentrations of fine particulate matter, expressed as PM 2.5 , should be reduced to levels sufficient to protect public health with an adequate margin of safety. Additional reductions below the federal primary annual standard of 15 μg/m 3 are advisable to provide an additional margin of safety that al lows and compensates for scientific uncertainty, as well as the lack of pr ecise predictions regarding the health impacts of air pollutants on a multiplicity of potentially susceptible populations. The process and strategies set forth in Recommendation 2 below should be utilized to achieve this goal. In implem enting these strategies, a strong emphasis should be placed on educational programs for the public.

Recommendation 2: The District should establish an ongoing and continuous process of review of all sources of PM 2.5 emissions from all sectors of the economy (including mobile sources, area sources, stationary sources, etc.), and develop and implement policies, practices and standards to con tinue progress towards reducing ambient concentrations of PM 2.5 and precursors. In the devel opment of such policies, practices and standards, those strategies that achieve lower emissions of hazardous air pollutants (HAPs) and oz one precursors in conjunction with reducing PM 2.5 should be a priority. Stakeholde r involvement in the development of such programs and processes should be an integral part of the process.

Recommendation 3: In furtherance of achievement of reductions in PM 2.5 and other regional pollutants, the District should initiate e fforts to create an interstate commission to effectively reduce ambient PM 2.5 through coordinated efforts within the Commonwealth and among states whose sources of PM 2.5 are identified as contributing to the boundary pollu tion levels in Kentucky.

Recommendation 4: The District should evaluate and, as a ppropriate, employ existing mechanisms under the Clean Air Act (CAA) to address id entifiable contributing sources of fine particulates and particulate precursors t hat interfere with attainment and maintenance of healthful air quality in the Louisville Metro community.

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Recommendation 5:

The District should create a regionally based stakeholder advisory committee to continue to focus and advise on issues of air pollution and pub lic health and to strategize on policies, practices and programs to reduce PM 2.5 emissions.

Recommendation 6 : A majority of the Committee recommends adoption of an interim health-based annual goal of 12 to 10 μg/m 3 , to be achieved by 2018, while the minority did not support establishing specific numeric goal s or deadlines beyond the federally prescribed annual standard.

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Section 5 Report of the Emissi ons Inventory and Modeling Data

Committee

5.1 Background

The Emissions Inventory and Modeling Data Committee (Committee) was formed to support the Task Force and its committees with the collection, distribution and understanding of technical information related to PM 2.5 . The District, with cooperation from state and regional entitie s, compiled and disseminated available information at the request of the Committee for these purposes.

5.2 Committee Actions

The Committee reviewed availabl e data related to direct PM 2.5 and precursor emissions,

SO 2 and NO

x . EPA determined other known PM 2.5 precursors, including NH 3 and VOCs, to be insignificant contributors to the ambient concentration of PM 2.5 in this region. Therefore, the Committee did not review data concerning emi ssions of these precursors.

Information was gathered from a variety of s ources to provide insight into the spatial and temporal distribution of the target pollutants. Historical and project ed data were obtained at local, state and regional levels. Th e Committee collected information including: ambient monitoring data and design values , speciated monitoring data, emissions inventories and source apportionment data. While a thorough technical review of all data

collection methods was not included in this report, the Committee has noted limitations

and uncertainties associated with thes e reviewed methods as appropriate.

To demonstrate attainment, each SIP will requi re modeling to show that nonattainment

areas will meet the annual PM 2.5 standard of 15 μg/m 3 by the attainment deadline of 2010. Fine particulate matter, by nature, has a la rge regional component such that an area’s attainment could be influenced by sources outside the designated nonattainment area. Realizing this, EPA funded regi onal modeling groups to support states with their regional haze, ozone and PM 2.5 SIPs. Two of these groups have modeling domains that include the Louisville nonattainment area: ASIP, whic h supports Kentucky and other southeastern states, and LADCO, which supports I ndiana and other midwestern states.

To provide further technical analysis of th e information, the Committee invited regional experts to speak to the Comm ittee and other members of the Task Force. On September 19, 2007, Pat Brewer, ASIP Technical Coordina tor, presented ASIP’s regional modeling results and related work products. On September 28, 2007, Joel Huey, PM 2.5 Expert for EPA Region 4, presented an overview of PM 2.5 SIP requirements, current and proposed federal regulations impacting state attainment demonstrations and examples of other state

and local actions to address control stra tegies for reducing PM. On October 11, 2007, Michael Koerber, Executive Director of LADCO, presented the most recent regional modeling results from LADCO. Thes e presentations are available at http://www.louisvilleky.gov/APCD/TaskForce/AQTFPMDocuments.htm

.

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The following sections provide a summary of the information collected and reviewed by

this committee.

5.2.1 Historical Data

5.2.1.1 Monitoring Data

The Committee collected historical monitoring data from local ambient PM 2.5 monitors in the area, including those used for the Federal Reference Method (FRM) and for speciation (similar to monitors in the Speciat ion Trends Network). The locations of local monitors are shown in Figure 5-1. The PM 2.5 FRM is a gravimetric method that measures

total PM 2.5 mass on daily, three- or six-day schedu les. Historical annual averages from

local FRM monitors are provided in Table 5-1.

Figure 5-1. Map of Area PM 2.5 Monitors.

Table 5-1. Annual PM 2.5 Means in μg/m 3 for Area FRM Monitors.

Monitor Site 1999 2000 2001 2002 2003 2004 2005 2006

18-019-0005/6 Clark County, IN 16. 6 18.6 16.9 16.0 15.8 15.1 18.5 15.0 18-043-1004 Floyd County, IN 15. 0 16.0 15.8 14.6 14.5 13.7 16.8 13.3 21-029-0006 Bullitt County, KY 15.4 16.4 15.6 14.7 14.4 13.6 16.3 14.1
21-111-0043 Jefferson County, KY 17.5 17.3 17.1 * 17.2 16.0 14.5 16.7 15.0 21-111-0044 Jefferson County, KY 16. 9 16.7 17.7 17.5 15.4 14.1 16.5 15.2 21-111-0048 Jefferson County, KY 17. 2 16.7 16.9 16.4 15.5 13.7 16.8 14.0 21-111-0051 Jefferson County, KY 15. 2 16.8 16.3 15.7 14.9 12.6 16.5 13.7
* Recovery below 75% due to renovation at the Southwick site in 2001

Valid data from FRM monitors for a given year are averaged on a quarterly basis to determine a monitor’s annual average. The de sign value (DV) is the mean of three

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consecutive annual averages for each monitori ng site. The highest design value in an area becomes the design value site from which at tainment designations are made. Historical design values from local FRM monitors are provided in Figure 5-2.

14.0 14.5 15.0 15.5 16.0 16.5 17.0 17.5 18.0Annual PM2.5 Design Value (μg/m3)

18-019-0005/6 Clark County, IN 17.4 17.2 16.2 15.6 16.5 16.2

18-043-1004 Floyd County, IN 15.6 15.5 15 14.3 15 14.6

21-029-0006 Bu llitt County, KY 15.8 15.6 14.9 14.2 14.8 14.7

21-111-0043 Jefferson County, KY 17.3 17.2 16.6 15.9 15.7 15.4

21-111-0044 Jefferson County, KY 17.1 17.3 16.9 15.7 15.3 15.3

21-111-0048 Jefferson County, KY 16.9 16.7 16.3 15.2 15.3 14.8

21-111-0051 Jefferson County, KY 16.1 16.3 15.6 14.4 14.7 14.3 1999-2001 2000-2002 2001-2003 2002-2004 2003-2005 2004-2006

Figure 5-2. PM 2.5 Design Values in μg/m 3 for Area FRM Monitors.

The Committee used data collected from speciation monitors to identify individual components of PM 2.5 measured at monitor sites. A nnual data compiled from speciation monitors in Louisville Metro are compared to those in Kentucky in Figure 5-3. Analytical

methods for PM 2.5 speciation allow for quantificat ion of the following components: sulfate (SO 4 ), nitrate (NO 3 ), ammonium (NH 4 ), OC, EC and crustal (e.g. fine soil and trace elements). A simple mass balance is used to determine the portion of PM 2.5 that is not accounted for by analytical methods. This portion is characterized as “other” and is unknown. Figure 5-4 shows the monthly variation in PM 2.5 speciation for the monitor 21-

111-0043 in 2006.

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0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

211110048 211110043

Barret 2002-2005 Average Southwick 2002-2005 Average All KY Monitors 2004- 2006 Average Other

Crustal component

Elemental
carbon

Organic
carbon

Ammonium

Sulfate

Nitrate

Figure 5-3. Speciation Data for Louisv ille Metro and Kentucky, 2002 to 2006.

0 5 10 15 20 25

Jan Feb March April May June July August Sept Oct Nov DecConcentration ug/m3 Other

Crustal component

Elemental

carbon

Organic

carbon

Ammonium

Sulfate

Nitrate

Figure 5-4. Monthly Speciation Data from Monitor 21-111-0043 in 2006.

Local and regional sources contribute to monitored PM 2.5 pollution. The contribution from local sources is usually greater in urban areas than in rural. PM 2.5 in rural areas is generally attributed to regional transpor t. For instance, of the three major PM 2.5

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components (sulfate, carbon and nitrate), greate r levels of carbon and nitrate are typically monitored in urban areas and are genera lly attributed to local sources.

The range of local contribution to total ambient PM 2.5 concentrations was determined by subtracting background levels of PM 2.5 from monitored concentrations within the Louisville nonattainment area. The backgr ound site for Kentucky is located at Camp Webb at Grayson Lake State Park in Carter County. The 2004-2006 design value for this site was 12.1 μg/m 3 . The background site for Indian a is located in Knox County. The 2004-2006 design value for this site was 13.8 μg/m 3 . When subtracted from the

Louisville nonattainment area’s 2004-2006 design value of 15.4 μg/m 3 , the local contribution, or urban excess component, ranges from 1.6 to 3.3 μg/m 3 for the Louisville

nonattainment area.

The relative contribution of PM 2.5 from regional and local sour ces has been extrapolated from monitoring data made available by EPA. Figure 5-5 shows that the local, or urban, component of PM 2.5 in Louisville is primarily organic carbon. A more refined understanding of the relative cont ribution of local and regional sources and the impact of various emission sources would require more detailed computer modeling of the area than currently available.

Estimated PM 2.5 Composition

Figure 5-5. PM 2.5 Composition and Estimated Urban Excess for U.S. Cities. Based on constructed mass (not SANDWICH), 2003 *Indicates areas with > 30% UE nitrates 0% 20% 40% 60% 80% 100% York, ; Harrisb, PA

Washington, DC St, Louis, MO-IL * Reading, LancasterPA; Pittsb, Wheeling

Philadelphia, New York, NY-NJ-CT Louisville, KY-IN

Knoxville, KY * Indianapolis, IN Hickory, NC Greensboro, NC * Evansville, IN-KY * Detroit, MI Columbus, OH; * Cleveland, OH Cincinnati, OH-KY-IN

Chicago,IL-IN-WI; Chattanooga, TN-GA Charleston, Hngtn,WV; * Canton, Steuben OH/WV Birmingham, AL

Baltimore, MD Atlanta, GA; Macon, GA

0% 20% 40% 60% 80% 100% York, ; Harrisb, PA

Washington, DC St, Louis, MO-IL Reading, LancasterPA; Pittsb, Wheeling

Philadelphia, New York, NY-NJ-CT Louisville, KY-IN

Knoxville, KY Indianapolis, IN

Hickory, NC Greensboro, NC Evansville, IN-KY Detroit, MI Columbus, OH;

Cleveland, OH Cincinnati, OH-KY-IN

Chicago,IL-IN-WI; Chattanooga, TN-GA Charleston, Hngtn,WV; Canton, Steuben OH/WV Birmingham, AL

Baltimore, MD Atlanta, GA; Macon, GA

Carbon Sulfates Nitrates Crustal Estimated Urban Excess

Carbon Sulfates Nitrates Crustal

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5.2.1.2 Emissions Inventory Data

Stationary sources with Title V and FEDOOP permits are required to submit a report of their actual emissions of PM, SO 2 , carbon monoxide (CO), nitrogen dioxide (NO 2 ), ozone precursor emissions of VOCs and NO

x , lead (Pb), NH 3 and all hazardou s air pollutants (HAPs) each year. Minor sources are required to submit these reports every three years. The most recent required emissions inventor y for all three categor ies of stationary sources was for calendar year 2005.

Estimates of NO

x and SO 2 emissions are generally well understood, have standardized

EPA emission factors and are therefore consider ed to be relatively accurate. Additionally, some sources utilize site-specific emission data such as stack tests and continuous emissions monitoring systems to directly quan tify their emissions of these pollutants.

Direct PM 2.5 emissions are generated from fuel combustion, material handling, surface coating, vehicle travel across unpaved work sites and numerous other activities. Total particulate matter, and in some cases PM 10 , emission factors have been developed for a number of processes, but very little information exists for PM 2.5 . The lack of standardized emission factors along with the multitude of different PM 2.5 sources requires a significant amount of engineering judgment to estimat e stationary source emissions. Thus, the Committee noted significant variation in reported emissions estimates; whereas values reported by the District, in some cases, were tw o to three times higher than those reported by sources. Estimates of direct PM 2.5 emissions from stationary sources were derived

from District recalculations of the sour ces’ certified 2005 Emissions Inventory Statement using process rates provided by the individua l sources and related emissions factors. While the District’s estimated values provi de an understanding of where emissions are generated and a relative ranking of the various sources, direct PM 2.5 data should be reviewed with the knowledge that uncertain ties exist in emissions estimates.

The most recent emissions inventory for area sources was generated for calendar year 2005 using various source emissions factors and related activity levels. Emissions factors were obtained directly from EPA AP-42 or , in some cases, from well-documented methods, typically developed by public ag encies. Emissions for area sources are generally estimated using activity levels, which are most commonly calculated using population data or the actual number of s ources. Emissions were calculated for NO

x , PM 2.5 and SO 2

.

The emissions inventory for onroad mobile sources was generated for calendar year 2005 by using EPA’s MOBILE6.2 modeling so ftware. Emission factors for NO

x , SO 2 and

PM 2.5 – including OC, EC, SO 4 as speciates – were calculat ed for this process. MOBILE6 calculates emission factors for twenty-eight individual vehicle types. These emission factor estimates depend on various conditions , such as ambient temperatures, travel speeds, operating modes, fuel volatility and mileage accrual rates. The emission factors derived from the MOBILE6 runs were multiplied by the vehicle miles traveled (VMT) for each county in the Louisville nonattainment area, supplied by the Kentuckiana Regional Planning and Development Agency (KIPDA), to obtain emission tonnage per

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year for each pollutant of interest. MOBILE6 is the best attempt to date by EPA and the Federal Highway Administration to aid transportation planning and air quality conformity concerns. MOVES is the next generation of soft ware to be available for use in the near future, which will more accura tely account for PM, greenhouse gases and new vehicle technology. Tests have been underway to fina lize the program’s ability to account for gasoline PM, which has been especially diffi cult to rank as to contributing factors.

The most recent emissions inventory for nonroad mobile sources was generated for calendar year 2005 by using EPA’s Nationa l Mobile Inventory Model (NMIM).

Emissions were calculated for NO

x , PM 2.5 and SO 2 . NMIM incorporated all the relevant variables developed by EPA which affect th e emission factor outcome for the various emission sources, including engi ne characteristics, fuel fo rmulation and a temperature and humidity database.

The District provided the most recent emissions inventory for Jefferson County, Kentucky, from 2005. Separate inventories were combined for stationary sources, area sources, onroad mobile sources and nonroad mobile sources. Emissions inventories for other stationary sources in the Louisvill e nonattainment area were also provided by

IDEM for the Indiana counties of Clar k, Floyd and Jefferson, and by KY DAQ for Bullitt County. KY DAQ also provided th e 2005 stationary source em issions inventory for the entire state of Kentucky. All 2005 emissions inventories for Je fferson County, Kentucky were combined and are shown in Figure 5-6.

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

*Data in table reported as tons per year (tpy) Area 1272.6 0.0 645.9

Nonroad 12404.4 790.2 877.5

Mobile 19682.0 213.1 291.0

Stationary 25745.0 45313.1 2517.7 NOx SO2 PM2.5

Figure 5-6. Source Apportionment, by Percen t, of Total Emissions in Jefferson County, KY, Based on APCD 2005 Emissions Inventory Data.

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Additional historical emissions inventory da ta are presented in Figures 5-8 and 5-9 below. In these figures emissions for all counties in the ten ASIP member states, reflecting a base year of 2002, are compared to projected emissions inventories for 2009

and 2018.

5.2.2 Projected Data

5.2.2.1 Boundaries and Assumptions

The ASIP and LADCO regional models calcul ated projected annual design values and emissions inventories based on inputs to the model within a set boundary. The Louisville nonattainment area was included within the boundaries of both regiona l models. Maps of the model boundaries for ASIP and LADCO can be found in Figures 5-7.

Figure 5-7. Maps of ASIP and LADCO Regional Modeling Domains.

The base-years used for ASIP and LADCO regional modeling were 2002 and 2005, respectively. At the time of this report, the LADCO modeling results for base-year 2005 were only recently made available for public review. While much of the information presented in this report involves results from ASIP modeling, the Committee would like to encourage full consideration of the limited outputs from LADCO’s base-year 2005 model. The use of a more recent base-year al lows for more accurate representation of projected data. It was the Committee’s vi ew that the LADCO 2005 modeling reflected more recent monitoring data and more inclus ive emissions inventories, utilized a more recent growth projection model and better accounts for the impacts of federal programs

than ASIP’s 2002 model run.

Imbedded in the ASIP and LADCO regional modeling outputs are many assumptions derived from planned reductions of direct PM 2.5 and precursor emissions. These include reductions from federal rules and other regulati ons that are thought to have an impact on ASIP/VISTAS 12km Modeling Domain LADCO 12km Modelin g Domain

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ambient concentrations of PM 2.5 . The following assumptions were used in the ASIP and LADCO regional models.

ASIP Assumptions – CAIR; Clean Air Mercury Rule; NO

x SIP Call; NC Clean Smokestacks Act; Consent Agreements (TECO, VEPCO, Gulf Power Crist7); 1-hr ozone SIPs (Atlanta / Birmingham / Northern Kentucky); NO

x RACT; Heavy-Duty Diesel (2007) Engine Standard; Tier 2 Tailpipe; Large Spark Igni tion and Recreational Vehicle Rule; Nonroad Diesel Rule; Industrial Bo iler/Process Heater/R ICE MACT; Combustion Turbine MACT; VOC 2-, 4-, 7- and 10-year MACT Standards.

LADCO Assumptions – Tier II/Low sulfur fuel; Inspection/Maintenance programs (nonattainment areas); Reformulated gasolin e (nonattainment areas); Federal control programs incorporated into NONROAD m odel (e.g. Nonroad Diesel Rule) and evaporative Large Spark Ignition and Recreati onal Vehicle standards; Heavy-Duty Diesel (2007) Engine Standard/Low sulfur fuel; Fe deral railroad/locomotiv e standards; Federal commercial marine vessel engine standa rds; Title IV (Phases I and II); NO

x SIP Call; CAIR; VOC 2-, 4-, 7- and 10-year MACT standards; Combustion turbine MACT; Industrial boiler/pro cess heater/RICE MACT; Miscel laneous consent decrees and settlement agreements; Aerosol coatings (n ew rule); Architectural and industrial maintenance (AIM) coatings (amendments) ; Household and institutional consumer products (amendments); Portable fuel containers (Mobile Source Air Toxics Rule).

The model protocols for ASIP and LADCO can be viewed on the District’s website at, http://www.louisvilleky.gov/APCD/TaskForce/AQTFPMDocuments.htm

.

5.2.2.2 Projected PM 2.5 Design Values

Future design values (DVF) were modeled for those monitors in the ASIP and LADCO regional modeling domains, which include the Louisville nonattainment area. Table 5-2 shows projected PM 2.5 design values from ASIP and LADCO modeling for local

monitors.

Table 5-2. Future Design Values for Local Monitors.

Monitor LADCO

Base DV LADCO

2009 DVF LADCO

2018 DVF ASIP

Base DV ASIP

2009 DVF ASIP

2018 DVF 18-019-0005/6 Clark County, IN 16.5 13.6 13.2 16.8 15.0 14.1 18-043-1004 Floyd County, IN 14.9 12.1 11.5 14.9 13.1 12.3 21-029-0006 Bullitt County, KY 14.9 12.4 12.0 14.9 13.2 12.2 21-111-0043 Jefferson County, KY 15.7 12.8 12.1 --- --- --- 21-111-0044 Jefferson County, KY 15.4 12.8 12.4 16.6 14.9 14.1 21-111-0048 Jefferson County, KY 15.2 12.5 12.1 16.1 14.3 13.5 21-111-0051 Jefferson County, KY 14.7 12.1 11.7 15.4 13.8 12.9 18-083-0004 Knox County, IN * 14.1 11.6 11.1 --- --- --- 21-043-0500 Carter County, KY* 12.2 9.9 9.5 12.2 10.3 8.9

* Background Monitors for Indiana and Kentucky

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5.2.2.3 Emissions Inventory Data

ASIP projected 2009 and 2018 emissions summari es for all counties in the ten ASIP member states. Figures 5-8 and 5-9 compare these projected emissions summaries with actual inventory data from base year 2002 for the state of Kentucky and Jefferson County, Kentucky respectively. The Committee noted the similarity in state and county

level trends in NO

x and PM 2.5 reductions. The Committee also noted the difference in

reduction trends between stat e and county emissions of SO 2 . Controls for SO 2 emissions are being added at many utilit ies around the state in complia nce with Phase I of CAIR. For utilities in Jefferson County, SO 2 controls were added to a ll units prior to base year 2002, which explains the different trends shown in these figures.

0 100000 200000 300000 400000 500000 600000tons per year (tpy)

NonRoad Mobile 104570 94752 79391 14043 9180 8591 6045 5203 4256

Mobile 154633 100025 46992 6237 750 693 2666 1898 1157

Industrial 12203 12962 15277 24359 26945 31146 19256 20260 23147

Other Fuel Combustion 65712 66860 70083 51472 52555 53718 8814 8180 7695

Electric Generating Units 201928 91587 64377 495152 290192 226062 2847 4269 4433

Miscellaneous 354 1116 1143 91 300 309 14147 17418 17865 2002 2009 2018 2002 2009 2018 2002 2009 2018

NOx SO2 PM2.5

Figure 5-8. ASIP 2002, 2009 and 2018 Emissi ons for the state of Kentucky.

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0 10000 20000 30000 40000 50000 60000tons per year (tpy)

NonRoad Mobile 10989 9785 7865 1428 921 859 720 649 566

Mobile 25548 14335 4840 904 110 87 364 238 136

Industrial 2358 2018 2466 355 386 473 558 613 736

Other Fuel Combustion 1470 1500 1554 1211 1173 1209 100 84 89

Electric Generating Units 22084 16954 4898 39915 42127 40032 166 197 202

Miscellaneous 0 0 0 0 0 0 101 111 127 2002 2009 2018 2002 2009 2018 2002 2009 2018

NOx SO2 PM2.5

Figure 5-9. ASIP 2002, 2009 and 2018 Emi ssions for Jefferson County, KY.

5.3 Committee Recommendations

The Committee met on October 11, 2007 and reached consensus on the following recommendations to be presented to th e full Task Force for its consideration.

The results presented to this committee fr om the ASIP and LADCO regional modeling groups project that the Louisville nonattainment area will achieve the annual PM 2.5 standard by the 2010 federal attainment dead line with existing a nd planned controls. Implementation of planned controls over the ne xt decade will continue to decrease VOC,

NO

x and SO 2 emissions in the region and local PM 2.5 levels.

5.3.1 Information Needs

The scientific and regulatory communities’ understanding of PM 2.5 emissions, atmospheric reactions and mode ling capabilities is not as mature as other criteria pollutants such as ozone. The ability to accurately and precisely estimate direct PM 2.5 emissions has improved since 2002, but mo re work is needed. The following recommendations address improvements nece ssary in modeling and monitoring of PM 2.5 to more accurately reflect an area’s issues a nd to identify appropriate control strategies.

Recommendation 1: The District should work with EPA, the states of Kentucky and Indiana and local sources to improve methods to estimate local sources of PM 2.5 emissions.

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Recommendation 2:

The District should work with EPA and th e states of Kentucky and Indiana to continue to fund existing, as we ll as increase the number of, PM 2.5 speciation

monitors in the area so as to be tter understand the local and regional contributors of PM 2.5

.

Recommendation 3: The District should work with EPA, the regional modeling groups and local sources to conduct updated and more de tailed regional and local modeling studies to gain a better understanding of the re lative impact and timing of regional and local emission reductions , beyond planned controls, on local PM 2.5 concentrations after 2009.

5.3.2 Data Collection Process

The Committee did not have sufficient time dur ing this process to collect, analyze and synthesize all the data that it would have liked in an effort to gain a full u nderstanding of

the relative contributors of PM 2.5 levels in the region. The Committee did not have time to investigate any projected emissions or modeling data beyond annual information for

the Louisville nonattainment area.

Recommendation 4: In future Task Force planning groups, the Emissions Inventory and Modeling

Data Committee should start its deliberati ons months before other committees to have sufficient time to collect, analyze and synthesi ze needed information.

5.3.3 Interpretation of Data

Regional modeling predicts that the Louisville nonattainment area will reach attainment

of the annual PM 2.5 standard of 15 μg/m 3 by the 2010 deadline. While the area is predicted to be in attainment, the Hea lth Committee recommended that a goal more stringent than the annual PM 2.5 standard is necessary to protect public health in our community. A majority of the Health Co mmittee suggested a range of 12 to 10 μg/m 3 as an appropriate health-based goal to be reached by 2018.

Additionally, source apportionment and urban excess data presented to the Committee suggests that by 2009, OC and SO 4 will be the two largest chemical constituents found in

annual monitored PM 2.5 locally.

Based on this information, the Committee recommended the following starting points that may help the Louisville Metro area reach a mo re stringent health-based goal with the acknowledgement that multiple data gaps existed because of time and data availability

constraints.

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Recommendation 5: Based on the data reviewed, and the Health Committee recommendations, the District should pursue strategies to reduce the PM 2.5 precursor emissions from major regional sources within a range of 150 miles, so as to reach a design value

below 12 μg/m 3 by 2018.

Recommendation 6: Based on current monitoring and modeling da ta from local and regional sources, the data suggest that an important component of PM 2.5 is local organic carbon. This suggests that pursuing local measures to reduce emissions of organic carbon may be worthwhile. The data also suggest that local SO 2 precursor emissions have less effect on the local PM 2.5 contribution in the area; therefore, measures for reducing sulfate contributions from sources outside the local area may be

worthwhile.

Recommendation 7: The Lake Michigan Air Directors Consor tium (LADCO) projected design values should be given as much, or more, wei ght as the Association for Southeastern Integrated Planning (ASIP) projections, because the LADCO modeling is based on 2005 inventory data, vs. 2002 for ASIP, and for the other reasons listed in

Section 5.2.2.1.

Recommendation 8:

The District should conti nue to monitor the progre ss of the regional modeling groups and other sources of PM 2.5 data utilized by Task Force to look for additional information that will assist the community in improving its understanding of PM 2.5 emissions and health impacts.

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Section 6 Report of the Station ary and Area Source Committee

6.1 Background

The Stationary and Area Source Committee (Com mittee) was formed to identify control measures in place in the community to reduce direct PM 2.5 and precursor emissions and

determine whether additional control strate gies could be implemented throughout the region to achieve early a ttainment of the annual PM 2.5 standard. The Committee met to review emissions data and interview represen tatives of several local stationary sources regarding current and future controls for direct PM 2.5 and precursor emissions. The Committee also completed an informal RACT/R ACM assessment for stationary and area

sources in the Louisville nonattainme nt area in accordance with the Implementation Rule

.

6.2 Committee Actions

The Committee reviewed data collected by the Emissions Inventory and Modeling Data

Committee. Emissions inventories for Jeffe rson County, the state of Kentucky and the

three nonattainment counties in southern Indi ana were used to determine the top 90% of

emitters for direct PM 2.5 , NO

x and SO 2 . The Committee then developed a telephone questionnaire to learn more a bout current and planned future control strategies for these major sources of direct PM 2.5 and precursor emissions. Th e following questions were

included in the control meas ures questionnaire administer ed by District staff:

1. What are the sources of PM 2.5 , NO

x and SO 2 at your facility? 2. What assumptions are used in the cal culation of emissions from these sources? 3. What control measures are currently in place for these sources? 4. Are there any plans for further redu ction measures, mandatory or voluntary?

5. What are the costs associated with any future control measures? 6. What reductions are anticipated fro m the 2005 baseline em issions inventory?

District staff received responses to the que stionnaire from several companies including Duke Energy, General Electric (GE) and Süd- Chemie Inc. Other companies, including E.ON U.S., Kosmos Cement Co mpany (Kosmos) and OxyVinyls, presented information on emissions and control strategies directly to the Committee. The Committee considered this information during its RACT/RACM assessment.

The Committee used language from the Implementation Rule as a starting point for completing its RACT/RACM assessment of sta tionary and area sources for the Louisville nonattainment area. A copy of this language fr om the Implementation Rule is included as Appendix 5. The EPA starting point list was used in conjunction with EPA’s List of

Potential Control Measures for PM 2.5 and Precursors , the National Association of Clean Air Agencies’ (NACAA) Controlling Fine Particulate Under the Clean Air Act: A Menu of Options and responses to the control measur es questionnaire to complete the assessment. Additionally, the Committee developed an evaluation matrix to aid in

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quantifying and prioritizing contro l strategies necessary to reac h attainment of the annual standard. The matrix is included as Appendix 6.

6.3 Committee Recommendations

The Committee met on October 24, 2007 and reached consensus on the following recommendations to be presented to th e full Task Force for its consideration.

6.3.1 Stationary Diesel Engines

There are large numbers of st ationary diesel engines th roughout Jefferson County. These engines mainly serve as emergency genera tors which run less than 500 hours per year. The particulate emissions from stationary dies el engines are regulated under the District’s Strategic Toxic Air Reduction program and c ontrolling this source for toxics emissions will satisfactorily control for direct PM 2.5 emissions.

The Committee also discussed emission reduc tions from switching to ultra low sulfur diesel (ULSD) fuel, which could significantly reduce SO 2 emissions from stationary engines. There are federal regulations in pl ace that require the phase-in of ULSD in nonroad sources. However, the Committee was reluctant to recommend that ULSD be used in all stationary diesel engines because of concerns about increased cost and the reliability of supply.

Recommendation 1: The District should continue to address po llution from stationary diesel engine sources through compliance with Stra tegic Toxic Air Reduction (STAR) regulations ( DR 5.21 and DR 5.22 ).

6.3.2 Emission Controls for Direct PM 2.5

6.3.2.1 Direct PM 2.5 Controls for Electric Generating Units

The Committee received responses to the cont rol measures questionnaire from Kentucky and Indiana utilities regarding current controls for direct PM 2.5 and definitive plans for future control measures. E.ON U.S, whic h operates several lo cal utilities across Kentucky, has electrostatic precipitators (ESPs) on all units operati ng across the state of Kentucky including Mill Creek and Cane Run Stations, lo cated in Jefferson County. Duke Energy, which operates the Gallagher Station in Floyd County, Indiana, is in the process of installing baghouse controls on all four units which should be completed by May 2008.

The Committee also consid ered contributions of PM 2.5 from regional sources including the Paradise Station in Muhlenberg County, Kentucky, which is operated by the Tennessee Valley Authority (TVA). TVA Paradise has three units, one of which has ESP

controls. TVA removed ESPs from the othe r two units to make room for flue gas

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desulfurization (FGD) cont rols. The FGDs are used primarily to remove SO 2 from stack emissions. TVA reports that the FGDs may also reduce PM 2.5 emissions.

Recommendation 2:

Louisville Metro Government should enc ourage the Tennessee Valley Authority’s (TVA’s) Paradise Station to look at cost-effective controls for direct PM 2.5 in the future.

6.3.2.2 Direct PM 2.5 Controls for Other Stationary Sources

The Committee received responses to the c ontrol measures questionnaire from GE, OxyVinyls, Süd-Chemie and Kosmos. The fo llowing responses were considered by the

Committee.

GE operates a landfill/natural gas boiler with a backup coal-fired boiler. It is GE’s intent to eventually eliminate the use of coal in generating building heat and process steam. GE has obtained a permit from the District for the construction of an additional landfill/natural gas boiler, which will serve as a backup to the existing landfill/natural gas

boiler.

OxyVinyls operates one natura l gas boiler and two coal-fir ed boilers, which provide steam to OxyVinyls and three other companies. One coal-fired boiler, built in the 1980’s, is controlled with a baghouse. The other coal -fired boiler, built in the 1960’s is controlled with a multicyclone. The company estimates that the 1960’s boiler is responsible for 80- 85% of its total suspended particulate (TSP) em issions, which is equal to 50 tons per year (tpy). OxyVinyls researched adding contro ls to the 1960’s boile r, including baghouse technology. Unfortunately, because of the proxim ity of this boiler to other structures, baghouse controls are cost prohibitive.

Süd-Chemie’s direct PM 2.5 emissions come from the pr oduction of catalysts which is regulated under the District’s STAR program . Unlike many industrial sources, a majority

of Süd-Chemie’s direct PM 2.5 emissions is valuable product. Süd-Chemie uses baghouses

to reduce direct PM 2.5 emissions and is in the proce ss of installing high efficiency particulate air (HEPA) filters after the baghouses, where needed, to improve its capture efficiency. This improvement is be ing made to comply with STAR.

Kosmos has made several improvements to its Louisville Metro facility since 2005, which the company reports has reduced emission of direct PM 2.5 . In 2005, baghouse dust collectors were replaced, a clinker storag e facility was added and a truck wash was installed. In 2006, the company paved and curb ed portions of the property and purchased a new sweeper to control dust from its out door operations. Finally, in 2007, Kosmos installed a wheel wash for trucks exiting the facility and submitted plans to convert from shaker to pulse jet dust collectors. Kosmos has permission from its corporate headquarters to purchase four pulse jet dus t collectors and has begun the process to receive necessary permits from the District. Kosmos has over 100 dust collectors throughout its plant. These control devices are fitted with ten foot pleated dust collection

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bags. In February of 2008, the company plans to upgrade to twelve foot pleated bags, which will increase the efficiency of the cont rols. Additionally, most transfer operations are controlled with covers and/or wet jets.

Recommendation 3: The District should prescreen permit app lications and give review priority to pollution prevention projects, especially those that could reduce direct PM 2.5 and precursor emissions.

Recommendation 4:

The District should review the cu rrent backlog of construction permit applications for pollution prevention projects that could reduce direct PM 2.5 and precursor emissions. If any construction permit applications that meet this criteria are identified, the District shoul d prioritize review of these applications so that a decision is made before the end of 2007 so that, if approved, these projects can be installed in early 2008.

Recommendation 5:

The District should consider working in voluntary partn ership with the owners of non-utility coal-fired boilers to research the cost-effect iveness of converting these boilers to alternative fuels and/or installing additional direct PM 2.5 control

devices.

6.3.3 Improved Capture of Particulate Emissions

EPA intended this category of the RACT/R ACM analysis to consider the improved containment of pollutants by ductwork that deli vers the gas stream to the control device. The Committee agreed that the District should continue to be mindfu l, in inspection and permitting processes, of situations where greater capture efficiency to control devices can be achieved; however, it believed that suffi cient control measures are in place where necessary and did not wish to set fo rth any recommendations at this time.

6.3.4 Emissions Controls for PM 2.5 Precursors

6.3.4.1 PM 2.5 Precursor Controls for Electric Generating Units

As noted above, the Committee received respon ses to the control m easures questionnaire from Kentucky and Indiana utilities. The fo llowing responses from E.ON U.S. and Duke Energy were considered by the Committee.

All E.ON U.S. units operating in Jeffe rson County, KY are controlled for SO 2 and NO

x emissions. At the Mill Creek and Cane Run Stat ions, all units are controlled with an FGD system, which reduces the company’s SO 2 emissions. E.ON U.S. controls NO

x emissions

at its Cane Run Station with low NO

x burners on all units. At the Mill Creek Station, two

units are controlled with low NO

x burners and two units are controlled with selective catalytic reduction (SCR). These SCRs are only operated from May through September.

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E.ON U.S. plans to operate the SCRs y ear round, beginning in 2009, to comply with CAIR requirements. Additionally, E.ON U.S. plans to voluntarily operate the SCRs approximately one extra month per unit in 2008. The District suggest ed that an extra month at the end of its scheduled operation woul d be more beneficial than an extra month at the beginning of the schedule. A complete list of E.ON U.S.’s current and planned control measures is included as Appendix 7.

Duke Energy’s Gallagher Station does not have SO 2 controls or plans for future controls. All units at the Gallagher Station operate with low NO

x burners and there are no plans to upgrade these controls in the fo reseeable future. A detailed list of current and planned

control measures for Indiana util ities is included as Appendix 8.

The majority of the Committee agreed that current and planned measures required to meet federal CAIR reductions sufficiently address RACT/RACM for electric generating unit (EGU) sources and that addi tional controls were not nece ssary in light of significant regional reductions to be observed with CAIR implementation. Two Committee members noted that local EGUs account for the majority of precursor emissions in the Louisville nonattainment area, and believed that loca l EGUs, such as Cane Run and Gallagher Stations, should be urged to make further emission reductions through increased control

efficiencies or installation of modern controls to pursue at taining cleaner air than that achieved by meeting the minimum required by federal standards.

Recommendation 6: E.ON U.S. and Duke Energy should continue to install control devices according to their current schedules, set forth to comply with Clean Air Interstate Rule (CAIR) requirements.

Recommendation 7: The District should encourage electric generating units (EGUs) to achieve as many early reduction credits as possible for 2007 and/or 2008.

6.3.4.2 PM 2.5 Precursor Controls for Other Stationary Sources

As noted above, the Committee received seve ral responses to the control measures questionnaire. The following responses fr om GE, OxyVinyls and Kosmos were considered by the Committee.

GE operates one coal-fired boiler as a b ackup heat and energy source. The company plans to eventually eliminat e the use of coal in its ope ration completely. Along with

reduction of direct PM 2.5 emissions, conversion from coal-fired to landfill/natural gas

boilers should also reduce PM 2.5 precursor emissions.

OxyVinyls considered replacing its 1960’s coal-fired boiler wi th a natural gas boiler. The company estimated reductions of 75 tpy of NO

x and 261 tpy of SO 2 . Based on a cost analysis, the company concluded that it can no t afford to replace the 1960’s coal-fired

boiler.

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Kosmos installed a water sprayer in its cement kiln, which reduces thermal NO

x coming from the main front burner. The company is interested in using selective non-catalytic recovery (SNCR) units to reduce NO

x emissions an additional 30 to 40%. Kosmos has begun the process to receive th e necessary permits from the District to install these controls. Additionally, in May 2008 Kosmos plans to test used tires as a fuel source for the cement kiln. The trial will measure the possible reduction of NO

x emissions. If successful, tires could replace coal in the cement kiln permanently.

Recommendation 8:

The District should consider working in voluntary partn ership with the owners of non-utility coal-fired boile rs to research the cost-effe ctiveness of converting to alternative fuels and/or installing additional NO

x and SO 2 control devices.

6.3.4.3 Reduced Sulfur Content of Fuels

The Committee determined that all coal-fir ed boilers in Jefferson County, Kentucky that are operating without FGD controls are require d to burn low-sulfur coal. Those boilers in Jefferson County, Kentucky operating with FGD controls, incl uding two E.ON U.S. facilities and a unit at American Synthetic Rubber Corporation (AS RC) are not required

to burn low-sulfur coal. The E.ON U.S. facilit ies operate using coal with varying highersulfur contents. ASRC uses low-sulfur coal. Th e Committee agreed that low-sulfur coal is utilized where necessary and did not wish to set forth any recommendations at this time.

6.3.5 Energy Efficiency Measures

The Committee recognized that increasing energy efficiency can indirectly reduce direct

PM 2.5 and precursor emissions. A decrease in energy use leads to a decrease in energy production, which reduces direct PM 2.5 and precursor emissions from the burning of fossil fuels. The Committee discussed the evolution of energy efficiency measures in the

Louisville nonattainment area over time. It was noted that historically, industrial operations have been implementing energy efficiency measures mainly because these measures translate into direct cost savings for the companies. Committee members also agreed that a general move toward energy efficiency in the commercial sector is underway but there is still room for impr ovement in the residential sector.

A study by the Kentucky Pollution Prevention Center (KPPC) and the American Council for an Energy Efficient Economy was presented to the Committee indicating substantial untapped potential for more cost -effective energy efficiency measures to be implemented in the commercial and industrial sectors. Speci fically, it lists 11 measur es in the industrial sector which could cut Kentucky's industrial electricity usage by 15.5% at a cost of 3 cents per kilowatt hour (KWh) or less. Accord ing to the study, similar opportunities for more efficiency are possible in the commercial and residential sectors.

The Committee heard presentations from E.ON U.S. and Duke Energy on the implementation of demand side management (DSM) programs to capture the largely untapped energy efficiency possibilities in the residential sector. E.ON U.S.’s DSM

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program includes programs, offerings and activ ities to reduce reside ntial, business and industrial energy use. In addi tion, E.ON U.S. continues to increase its program and is working on several new DSM offerings. D uke Energy’s DSM program incorporates services, products, rebates, educational tools and other programs tailored to its residential, business and industrial customer s. Complete listings of DSM programs for E.ON U.S. and Duke Energy are included as Appendix 9.

The Committee also discussed other large sc ale energy efficiency initiatives throughout the community. PGC, which includes representa tives from U of L, JCPS and Louisville Metro Government, is promoting energy effi ciency measures throughout the partnering entities. The Energy Use Partnership (EUP), a committee of the PGC, has the goal of reducing energy usage in all three institutions by seeking out new technologies, practices and other opportunities for energy savings a nd by sharing this information among the participants. All of the partne rs have already undertaken pr ojects to reduce their energy usage and are continuing to incorporate ener gy efficiency technologies and policies into their institutions’ practices. Several examples of these projects are discussed below.

Louisville Metro Government has nearly co mpleted a citywide pr oject to convert all Metro-owned traffic lights from incandescent bulbs to light-emitting diodes (LEDs). These LEDs are energy efficient and reduce consumption by an average of 80%. Additionally, they save time and money by lowering maintenance costs significantly. LEDs last six or more years instead of an in candescent bulb’s lifespa n of eight to twelve months. This retrofit project is expected to save 7.5 million kilowatt hours, enough to power 750 homes for a year. Additionally, Louisville Metro Government recently became an Energy Star Partner organization and committed to measure, track and improve the city’s energy performance.

KPPC has performed energy audits on 17 PGC buildings. The purpose of these audits is to identify building conditions th at are not optimal for energy e fficiency and to prioritize

the correction of these conditions based on cost and payback.

U of L has installed Vending Misers on se veral beverage machines around campus. The Vending Miser is a device that can be added to any cold beverage vending machine to conserve electricity. By sensing the ambient temperature around the machine, as well as whether there is anyone in the vicinity of the machine, the Vendi ng Miser will power the machine down when it is not necessary to cool the product or illuminate the sign. U of L will potentially save thousands of dollars a year from reduced electric consumption by these machines, without affecting th e quality of the product delivered.

JCPS has been exploring ways to take a dvantage of available solar resources. JCPS conducted pilot projects to test daylight harv esting ballasts and solar reflectors that throw sunlight from windows further in to a classroom. After the resu lts of these pilot projects were analyzed, JCPS decided that these technologies could be incorporated into new building construction and possibly even build ing renovations. JCPS has already installed and is operating a solar water heater at its Churchill Park Rehabilitation Center and plans are underway to include this technology in tw o new buildings. An early adopter in the

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area of energy efficiency, JCPS has been inve stigating ways to in corporate energy saving technologies into buildings as they are built , a much more cost-effective alternative to retrofitting. This includes improvements to the building’s thermal envelope, more efficient HVAC technologies and lighting upgr ades. A list of many of the projects planned for JCPS is included in Appendix 9.

Recommendation 9: In the funding decisions of the Partne rship for a Green City (PGC) entities, priority should be given to energy efficiency projects as specified by the committees of the PGC.

Recommendation 10: The Partnership for a Green City (P GC) entities should increase funding for facility audits to determine where energy efficiency projects are needed most.

Recommendation 11: The Board should encourage existing fundi ng entities to incr ease funding of Project Warm.

Recommendation 12: A partnership should be created, among state and local agencies and chambers of commerce, to increase awareness of and participation in elec tric utilities’ demand side management (DSM) programs.

Recommendation 13: The District should explore partnership opportunities wi th companies specializing in energy efficient products and services to increase awareness of the benefits of energy efficiency for industrial, commercial and residential customers.

Recommendation 14:

The District should work with Louisvill e, Kentucky and Indiana Home Builders

Associations to educate members on the economic and environmental benefits of incorporating energy efficiency me asures into building projects.

Recommendation 15: The District should develop and implem ent a recognition program to reward energy efficiency initiatives and achi evements throughout the community on a variety of scales.

6.3.6 Measures to Reduce Fugitive Dust

The Committee reviewed the District’s re gulation to control fugitive particulate emissions. While this regulation is not specific to emissions of PM 2.5 , enforcement of the regulation will help to reduce direct PM 2.5 emissions. The regulation outlines preventative measures that must be taken to control fug itive dust from materials handling activities, unpaved roads and parking areas an d other activities as specified.

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Recommendation 16: The District should continue enforcemen t of its regulation to control fugitive particulate emissions ( DR 1.14 ).

6.3.7 Open Burning

The Committee reviewed regulations regard ing open burning throughout the Louisville nonattainment area. Jefferson County, Kentucky bans open burning without a permit from the District. The state of Kentucky allo ws for open burning in certain instances but restricts most open burning in PM 2.5 nonattainment areas from May to September. Open burning is totally banned in Clark and Floyd Counties in In diana and no variances for residential open burning are granted in these counties. The state of Indiana allows for open burning in certain instances but re stricts burning on air pollution alert days.

Recommendation 17: The District should continue enforcement of its regulation on control of open burning ( DR 1.11 ).

Recommendation 18: The Kentucky Division for Air Quality (KY DAQ) should continue to enforce its regulation regarding open burning and shoul d amend that regulation to prohibit all open burning of household waste and debris. ( 401 KAR 63:005 ).

Recommendation 19: The Kentucky Division for Air Quality (KY DAQ) should consider amending its regulation to ban open burning in areas in nonattainment of the federal primary annual standard for PM 2.5

.

Recommendation 20: In the interim, when authorizing open bur ning in areas in nonattainment of the federal primary annual standard for PM 2.5 , the Kentucky Division for Air Quality (KY DAQ) should consider the local pr ojected ambient concentration of PM 2.5 in its decision making.

6.3.8 Woodstoves, Fireplaces and Wood Boilers

The Committee discussed the impact of woods toves, fireplaces and wood boilers on the nonattainment of this area. Collectively, the impact from all these sources appears to be relatively low. However based on informati on from EPA, replacing twenty non-certified, older woodstoves with twenty EPA-certified woodstoves can preven t the emissions of one ton of fine particulate matter per year. The Committee determined that the potential for significant emission reductions from this source category exists and steps should be

taken to reduce these em issions where possible.

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Recommendation 21:

The District should increa se public awareness of the effects of the use of fireplaces and woodstoves on am bient concentrations of PM 2.5 and NO

x

Recommendation 22: The District should promote EPA’s Great American Woodstove Changeout

program.

Recommendation 23:

The District should increase outreach on the benefits of switching from woodstoves, fireplaces and wood boilers to more effi cient sources of heat.

6.3.9 Charbroiling and Other Commercial Cooking Operations

The Committee determined that commercial charbroiling and cooking operations account for approximately 10% of total area source PM 2.5 emissions within Jefferson County, Kentucky. However, the Committee believed str ongly that they could not determine the feasibility of control measures for th is source category w ithout speaking to representatives from local restaurant associations.

Recommendation 24:

The District should meet with local restaurant associati ons to discuss potentially feasible and co st-effective PM 2.5 control measures that that could reduce PM 2.5 emissions from restaurants in Louisvill e Metro and southern Indiana, particularly

those with commercial charbroilers.

6.3.10 Use of Consumer Products

The Committee determined that the use of solvents containing organic compounds such as toluene, xylene and trimethyl benzene in commercial and household applications did not appear to contri bute significantly to total area source PM 2.5 and precursor emissions in Jefferson County, Kentucky. However, the Committee believed that through education and outreach reductions may be achieved.

Recommendation 25: Through outreach, the District should increase public awareness of alternatives to residential solvent usage and the benefits of avoiding household products containing organic compounds such as tolu ene, xylene and trimethyl benzene.

6.3.11 Charcoal Grilling

Although not included in the EPA starting poin t list, the Committee found that backyard charcoal grilling accounted for as much as 63% of direct PM 2.5 and 11% of NO

x emissions from area sources in Jefferson C ounty, Kentucky. Methods for estimating area source emissions are included in Section 5.2.1.2 of this Report.

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Recommendation 26:

The District should increase public awareness of the ef fects of charcoal grilling on ambient concentrations of PM 2.5 and NO

x .

Recommendation 27: The District should develop and implemen t a program to encourage replacement of charcoal grills in Jefferson County with gas and/or electric units through a rebate system similar to the Lawn Care for Cleaner Air program.

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Section 7 Report of the Mobile and Nonroad Mobile Source Committee

7.1 Background

The Mobile and Nonroad Mobile Source Comm ittee (Committee) was formed to identify control measures in place in th e community to reduce direct PM 2.5 and precursor emissions and determine whether additional control strategies could be implemented throughout the region to achieve early attainme nt of the annual standard. The Committee met to review emissions data and interview representatives of several large local fleets regarding current and future controls for direct PM 2.5 and precursor emissions. The Committee also completed an informal RACT/RACM assessment for mobile and

nonroad mobile sources in the Louisville nonattainment area in accordance with the Implementation Rule

.

7.2 Committee Actions

The Committee reviewed PM 2.5 and precursor source apportionment data, collected by the Emissions Inventory and Modeling Data Committee, for mobile and nonroad mobile sources to determine the source categories of greatest concern in Jefferson County, Kentucky. Onroad mobile 5 sources were easily broken into four major vehicle categories including light- and heavy-dut y diesel and light- and hea vy-duty gasoline. For nonroad

mobile 6 sources, the top 90% of source categorie s were identified with the remaining

considered as “other”. The Committee de termined that Jefferson County, Kentucky

nonroad mobile sources emit more direct PM 2.5 and SO 2 than mobile sources, while mobile sources are responsib le for a majority of NO

x emissions. The Committee also identified diesel vehicles and equipment, both onroad and nonroad, as the major sources

of concern.

The Committee also reviewed the work of previous air quality task forces, stakeholder groups and committees. In 2006, the Board adopted a set of recommendations for reducing ozone precursor emissions to lowe r ambient ozone conc entrations in the Louisville Metro area. In 2007, the STAR Regulation 5.30 Stakeholder Group produced a Report and Plan of Action to reduce emissions of and exposure to toxic air contaminants. Finally, PGC’s Climate Change Committee is working to reduce greenhouse gas emissions. The Committee noted that these efforts involve similar pollutants, issues and

sources. The Committee determined that many of the recommendations developed through these processes may also reduce direct PM 2.5 and precursor emissions.

Representatives of several large local fleets gave presentations to the Committee on current and future planned efforts to reduce direct PM 2.5 and precursor emissions. The

5 Onroad mobile sources are motorized vehicles that are registered for use on public roads and highways, including automobiles, light- and heavy-duty trucks, buses and motorcycles.

6 Nonroad mobile sources are motori zed vehicles that are not register ed for use on the public roads and highways or any other equipment with a fossil fuel-fired engine that is not a point source. Examples include aircraft, boats, railroad engines, construction equipment, and nonroad recreational equipment.

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representatives also helped the Committee to understand the investment and maintenance costs associated with certain control measures and technologies. The Committee heard presentations from the Transit Authority of the River City (TARC), JCPS, the Regional Airport Authority (RAA), the Kentucky Mo tor Transport Association (KMTA) and United Parcel Service (UPS). The Committee considered this information during its

RACT/RACM assessment.

TARC has an active fleet of 255 vehicles (e.g. diesel and hybrid dies el-electric buses and trolleys) and contracts the operation of 90 paratransit ve hicles. TARC operates nine hybrid diesel buses, which use approximately 20% less fuel than a traditional transit bus. As new hybrids are purchased, TARC replaces th e oldest, dirtiest buses in the fleet. TARC reports that the use of hybrids in its fleet has significantly reduced its total emissions. The transit authority also began using ULSD two full years before mandated by the federal government and retrofitted its en tire fleet with dies el oxidation catalysts (DOCs) in the late 1990’s. TARC recently ordere d six new buses that will be the first in

the fleet to be fitted with di esel particulate filters (DPFs). TARC recognizes the pollutant

reduction benefits of control t echnologies and continues to utilize these te chnologies in its fleet; however, TARC foresees the la rgest emission reductions coming from an increase in the use of public transit with a corresponding de crease in the use of single occupant vehicles.

JCPS has a large school bus fleet, with more than 1,150 diesel buses running more than 850 routes per day. JCPS reported that 648 of its buses are model year 2000 or newer and many of the older buses are used less frequently as a part of large spare fleet. The school system also operates a vehicle fleet of 471 cars and trucks, 246 of which are powered by diesel engines. Over its entire fleet, JCPS burns approximately 2.5 million gallons of fuel annually. In December 2006, JCPS began using a 2% biodiesel blend to fuel its entire

diesel fleet. JCPS also has an idling policy that restricts idling at schools and limits idling at depots to that which is necessary for proper start up in cold weather. Through its maintenance program, JCPS ensures that all its buses have no more than a five pound variance in tire pressure, which helps to increase the fleet’s fuel economy. Average turnover for the fleet is fifteen years and JCPS is considering purchasing hybrid school

buses in the future to reduce total fleet emissions.

RAA is an independent, public agency that owns and operates Loui sville International Airport and Bowman Field, both located in Louisville Metro. The larger of the two airports, Louisville Interna tional, has three active runway s, 62,000 feet of taxiways and 325 acres of concrete apron. RAA leases spac e to commercial airlines and other major tenants. According to Airports Council In ternational statistics (2006), Louisville

International is the 68 th busiest airport for passe nger travel and the 4 th busiest cargo airport, largely because of UPS’s Worl dport operation. Mobile emission sources at Louisville International include vehicles (e .g. taxis, buses, cars) while nonroad mobile sources include aircraft, gr ound support equipment (GSE), auxiliary power units (APU) and landscape maintenance equipment. In 2006, RAA published an emissions baseline for Louisville International, which outlines its contribution of criteria pollutants and HAPs to ambient concentrations. The inventory showed that the larges t sources of direct

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PM 2.5 and NO

x are the aircraft. The inventory also showed emissions from APUs and GSE. RAA is in the process of establishing an emissions baseline for Bowman Field. It anticipates using these baselines to apply for the Federal Aviation Administration’s (FAA) Voluntary Airport Low Emissions (VA LE) program, which offers grants toward capital expenditures aimed at reducing emissi ons from airport activ ities. RAA is also implementing a clean fuels program to use bi odiesel in appropriat e airport vehicles.

With approximately 450 members, KMTA supports the trucking industry through education, advocacy and career development. KMTA reported that the average local trucking company has a fleet of ten vehicles or less. There are 7,000 fleets in Kentucky with a combined gross weight of greate r than 59,999 pounds per fleet. KMTA recognized a trend in the freight movement industry to ward combining trucking and rail operations around the country. KMTA also noted that EP A’s SmartWay program is not being used effectively in Jefferson County or the state of Kentucky. In its opinion, most carriers in this area are too small to take advantage of the program and there is a general lack of awareness of the benefits of programs like these. KMTA also reported on the use of emission reduction technologies throughout the industry. While e ffective, DOCs and DPFs are slow in being accepted industry wide. The use of APUs, which provide power to a truck when the main engine is shut off to reduce emissions, is increasing but is more

common in over-the-road trucks than local fl eets. Another popular upgrade is to replace

the traditional double wide-base tires with si ngle wide-base tires, which reduces the weight of the vehicle and increases fuel ec onomy. Retrofitting a truck with single widebase tires can be cost prohibitive and this upgrade is usually found on new trucks.

UPS operates its Worldport glob al distribution hub out of Louisville International Airport. The system of distribution at this hub has transitioned in recent years from a labor and equipment intensive operation to a totally automated system of loading and unloading. The Worldport expansion will elimin ate the use of 38 diesel loaders and 38 diesel ground power units. As of December 2007, UPS is using a 5% biodiesel blend to fuel over 300 pieces of GSE. Additionally, U PS is considering alternative technologies available for nonroad equipment including fuel injection, 4-cylinder engines and nonroad

vehicles certified to California Air Resources Board (CARB) standards.

The Committee used language from the Implementation Rule as a starting point for completing its RACT/RACM assessment of mo bile and nonroad mobile sources for the Louisville nonattainment area. A copy of this language from the Implementation Rule is included as Appendix 5. The EP A starting point list was used in conjunction with EPA’s

List of Potential Control Measures for PM 2.5 and Precursors and NACAA’s Controlling Fine Particulate Under the Clean Air Act: A Menu of Options to complete the

assessment.

7.3 Committee Recommendations

The Committee met on October 22, 2007 and reached consensus on the following recommendations to be presented to th e full Task Force for its consideration.

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7.3.1 Onroad and Nonroad Diesel Re trofit, Rebuild or Replacement

Recommendation 1: Local government and quasi-governmental agencies should adopt a plan for retrofit or replacement of all diesel fleet vehicles and equipment with state-of-theart technology and the use of alternative fuels.

Recommendation 2:

Louisville Metro Government’s General Services Administ ration (GSA) should analyze the Metro fleet and create a pl an to improve fleet emissions through diesel retrofit or replacement along w ith the use of alternative fuels.

Recommendation 3: The Partnership for a Green City (PGC) entities should continue to move toward the use of alternative fuels and technol ogies, including retrofit and replacement options.

Recommendation 4:

The District should work with public and private fl eet owners operating in Louisville Metro through education, incenti ves and grants to aggressively retrofit or replace both onroad and nonroad diesel fl eets with state-of-the-art technology.

Recommendation 5: State and local governments should create tax incentives, low interest loans and other financial incentives for the retr ofit or replacement of onroad and nonroad diesel fleets.

Recommendation 6: Louisville Metro Government should explore the creation of a Louisville Metro Environmental Grant Partnership to aggressively coordinate, apply for and receive federal and state grants to reduce direct PM 2.5 and precursor emissions from mobile and nonroad mobile sources. Federal political partnerships should
be utilized to increase success.

The Committee determined that marine and railroad operations are significant

contributors of direct PM 2.5 and precursor emissions in Jefferson County, Kentucky. However, the federal Clean Air Act does not provide regulatory authority for local jurisdictions, like the District, to further rest rict or regulate these transportation sectors.

The Committee believes that mean ingful reductions of direct PM 2.5 and precursor emissions from these sectors are possible a nd encourages reasonably available control measures be voluntarily taken at ports a nd switchyards throughout the Louisville

nonattainment area.

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Recommendation 7: The District should work in partnership with marine and railroad operations in the Louisville nonattainment area to identify and reduce direct PM 2.5 and precursor emissions.

7.3.2 Diesel Idling Programs

Louisville Metro and the states of Kentucky and Indiana do not have idling restrictions or regulations. The Committee discussed th e connection betwee n idling reduction, especially of diesel vehicles , and reductions of direct PM 2.5 and precursor emissions. The Committee agreed with the conclusion of the STAR 5.30 Stakeholder Group that an idling regulation is needed in this commun ity. The Committee further addresses idling reduction in Section 7.3.3 of this Report.

Recommendation 8:

The District should initiate a stakeholder process for local adoption of an idling regulation with the proposed Draft Id le Reduction Regulation (included as Appendix 10) used as a starting point for discussion.

7.3.3 Long-range Land Use and Transportation Planning Solutions

The Committee discussed long-range land us e and transportation planning solutions. Transportation control measures (TCMs), ec onomic incentive packages (EIPs) and land use measures (LUMs) were all recognized by the Committee as t ools that influence development patterns. The Committee considered that Louisville Metro could be eligible for SIP credits in these areas, but more information needs to be gathered from local agencies to make that determination. EPA endorses the creation of alternative growth scenarios that, when compared to business-as-usual scenarios, allow for quantification of TCMs, EIPs and LUMs for SIP credits. The Committee noted the importance of these data components for future task force committees charged with balancing emissions controls for stationary and mobile sources. Data on these topics and the framework necessary for cooperation between local agencies to obtain the requisite data does not currently exist.

Recommendation 9 : The District should cooperate with loca l and regional agencies to determine if any transportation control measures (TCMs), economic incentive packages (EIPs) and land use measures (LUMs) are currently being implemented that have

not been included in the exi sting emissions budget and could be credited in the State Implementation Plan (SIP).

Recommendation 10 : The District should cooperate with local and regional planning agencies to evaluate major subdivision proposals and development plan proposals for all emission components, projected changes in vehicle miles traveled (VMT),

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projected changes in average daily trip s (ADT) and their corresponding impacts on the emissions budget.

Recommendation 11 : The District should cooperate with local and regional planning agencies to quantify the difference between emissions budgets that re sult from business-asusual and alternative growth scenarios using comparison guidelines provided by

EPA.

Recommendation 12:

Louisville Metro Government should c ooperate with regional transportation and planning agencies to identify opportunities to spur transit-oriented development through the implementation of economic incentive packages (EIPs) and land use measures (LUMs).

Recommendation 13: District staff, as part of its development review, s hould review and comment on a project’s emissions related to PM 2.5 and precursors, ozone, air toxics, greenhouse gases and vehicle miles traveled (VMT).

Recommendation 14: The District should recognize those businesses that have implemented Best Workplaces for Commuters (BWC) practices to reduce the total vehicle miles traveled (VMT) by employees.

Recommendation 15: Continue strict enforcem ent of current speed limit s throughout the Louisville nonattainment area to reduce emissions of direct PM 2.5 and precursors.

The Committee also agreed with the fo llowing recommendations of the STAR 5.30 Stakeholder Group that address transportation planning measur es to reduce vehicle idling and average commute duration.

Recommendation 16: Improve and expand traffic light sign alization synchronization throughout

Louisville Metro to reduce a verage commute length and idling.

Recommendation 17: Improve Traffic Response and Incident Management Assisting the River Cities (TRIMARC) incident management and roads ide assistance to reduce idling on the highways.

Recommendation 18: Encourage significant coordination am ong the Kentucky Transportation Cabinet (KTC), local transportation officials and private fleets during major highway repair or construction, including the L ouisville-Southern Indiana Ohio River

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Bridges project, to develop plans to minimi ze traffic backups and delays to reduce idling and toxic emissions.

7.3.4 Emission Reductions or Accelerate d Retirement of High Emitting Lawn and Garden Equipment

The Committee recognized the efforts of th e District’s Lawn Care for Cleaner Air program, which offers vouchers for the r ecycling of gasoline powered lawn care equipment and rebates toward the purchase of electric or battery powered mowers and string trimmers, reel mowers, electric blower /vacs and replacement batteries. The District also offers a manufacturer-spons ored rebate aimed at commer cial users for purchase of Stihl’s 4-stroke gasoline power ed engine line of products.

Recommendation 19: The District should continue providin g rebates, through the Lawn Care for Cleaner Air program, for the retiremen t of gasoline powered lawn and garden equipment and the purchase of low emissions equipment.

Recommendation 20: The District should expand corporate spons orship of the Lawn Care for Cleaner Air program to increase brands and pr oducts that are rebate eligible.

7.3.5 Emissions Testing and Repair/Maintenance Programs

The Committee discussed the effectiveness of vehicle emissions testing programs at reducing direct PM 2.5 and precursor emissions. However, in light of state law restricting mandatory vehicle emissions testing, the Committ ee did not consider this measure to be a viable recommendation. Other maintenance pr ograms including on-board diagnostic and tire pressure checks were also discussed.

Recommendation 21:

The District should consider including as contingency measures in the State Implementation Plan (SIP) for the annual PM 2.5 standard those onroad and nonroad mobile contingency measures from the 8-hour Ozone SIP that will also

reduce direct PM 2.5 and precursor emissions.

Recommendation 22: Provide free tire pressure stations, fr ee air, free on-board diagnostics checks and free gas caps to promote increased fuel economy and reduce emissions of direct

PM 2.5 and precursors.

7.3.6 Clean Burning Fuel Programs

The Committee also agreed with the fo llowing recommendations of the STAR 5.30 Stakeholder Group that address the use of alternative fuel s and technologies to reduce

direct PM 2.5 and precursor emissions.

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Recommendation 23: Expand the use of alternative fuels and technologies by all municipal and transit fleets, both onroad and nonroad, in Loui sville Metro within one year.

Recommendation 24: Work in partnership with the Kentucky Petroleum Marketers Association, retailers, distributors and other stak eholders to evaluate, develop and achieve goals to provide biodiesel (ASTM standard) blends at retail stations throughout

Louisville Metro.

Recommendation 25: Develop a partnership, between rental car agencies and public and private entities utilizing rental fleets, to incr ease the use of biodiesel (ASTM standard) and/or alternative fuels and tec hnologies in rental fleets.

Recommendation 26: Create partnerships, tax incentives and other financial incen tives to encourage the use of biodiesel (ASTM standard) and/or alternative fuels and technologies by private fleets.

7.3.7 Contracting for Low Emissions Specifications

In light of the rapid devel opment of Louisville Metro and the surrounding areas, the Committee discussed opportunities for emissi on reductions through the incorporation of preference in contracts for lower project emi ssion profiles. Louisville Metro Government uses a request for proposal system to evalua te purchasing and/or contracting options. The Committee noted that this system allows fo r adequate considerat ion of preferences beyond price.

Recommendation 27: Louisville Metro Government should give pr eference to contractors that provide the best project emission profile through the use of diesel retrofits or newer equipment and alternative fuels.

Recommendation 28: Encourage members of the Associated Ge neral Contractors (AGC) of Kentucky, The Association of Union Constructors (T AUC) and other trade associations to retrofit or replace both onr oad and nonroad diesel equipment.

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Section 8 Report of the Report and Plan of Action Committee

8.1 Background

The Report and Plan of Action Committ ee (Committee) was formed to oversee

documentation of the issues reviewed and th e process undertaken by the Task Force to

determine recommendations for reduci ng ambient concentrations of PM 2.5 . The work product of this Committee was this Fine Particle Air Quality Task Force Report and Plan of Action . District staff, with input from Task Force committees, drafted the majority of the language contained in the Report. The Repor t reflects the information presented to the Task Force and committees throughout the pr ocess. The committee report sections and the Plan of Action reflect specific discussi ons that led to consensus on recommendations by the respective committees and the Task Force as a whole.

8.2 Committee Actions

During initial meetings, the Committee discusse d its role in the Task Force process and the operating timeline for the Task Force and committees. It also di scussed and agreed upon the structure and content to be used in the Report. The Committee developed an

outline for all sections of the Report, including backgr ound sections, committee reports, and the plan of action. The outline served as a reference for the Dist rict to begin drafting language to be included in the Report.

At subsequent meetings, the Committee re viewed and commented on sections of the Report, as they became available, to ensu re consistent language and proper flow throughout the Report. The final Report wa s adopted by all Task Force members on December 20, 2007.

8.3 Committee Recommendations

On December 13, 2007, the Committee reached consensus on the following recommendations to be presented to th e full Task Force for its consideration.

Recommendation 1: The Task Force should include the language included as Appendix 11 in Section 9.1 of the Report and Plan of Action.

Recommendation 2:

All recommendations included in Secti on 9 of the Report and Plan of Action should be prioritized by the Task Force.

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Section 9 Plan of Action

The preceding committee reports and recommendations were presented to the full Task Force for its consideration. Each committee recommendation was discussed thoroughly and modifications were made where necessary to reach consensus. During this process, numerous changes were made to committee recommendations, including consolidation, revision, broadening/narrowing of scope and elimination of recommendations. This Plan

of Action reflects the consensus of the fu ll Task Force. It includes recommended strategies for regional, st ate and local level implementation to reduce direct PM 2.5 and precursor emissions.

9.1 Leading Recommendations

In Section 8.3, the Report and Plan of Action Committee proposed eight leading recommendations (included as Appendix 11) to be given priority during the implementation process and recommended that th e Task Force consider assigning priority

to all consensus recommendations. While time di d not allow for the prioritization of all consensus recommendations, the Task Force adopted the proposed leading recommendations with one exception, a s ubstitution for Leading Recommendation 6.

The following recommendations include strate gies that should be given priority for implementation. These recommendations re present a diverse group of strategies addressing the full breadth of issues consider ed by the Task Force and its committees. It should be noted that the following eight recommendations were selected from the full list of 63 recommendations which are presented, without exclusion, in Sections 9.2 and 9.3

below.

Leading Recommendation 1: Building upon the Clean Air Act (CAA) prin ciple that ambient concentrations of

PM 2.5 should be reduced to levels suffici ent to protect public health with an adequate margin of safety, reductions below the federal primary annual standard of 15 μg/m 3 are advisable to provide an additiona l margin of safety that allows and compensates for scientific uncertainty, including the potential health impacts on sensitive populations. To achieve thes e reductions, the District should establish an ongoing and continuous process of review of all sources of PM 2.5 emissions (including onroad and nonroad mobile sources, area sources, stationary sources, etc.) and develop and implement policies, practices and standards to continue progress towards reducing ambient concentrations of PM 2.5 and precursors. In the development of su ch policies, practices and standards,

stakeholder involvement should be an integral part of the process. Those strategies that achieve lower emissions of hazard ous air pollutants (HAPs) and ozone precursors in conjunction with reducing PM 2.5 should be a priority and a strong emphasis should be placed on educational programs for the public.

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Leading Recommendation 2:

The District should create a diverse sta keholder advisory committee to continue to focus and advise the Board on issues of air pollution, public health and environmental justice related to PM 2.5 and to strategize on policies, practices and programs to reduce PM 2.5 ambient concentrations, as outlined in Leading

Recommendation 1.

Leading Recommendation 3: As a part of the ongoing process, a sta keholder group should be convened in 2010 to review peer-reviewed health literat ure, ambient monito ring data and modeling results to determine whether interim numeric goals are advisable to achieve continued progress towards the reduction of ambient PM 2.5 concentrations sufficient to protect public health with an adequate margin of safety. Six months prior to convening the 2010 review, comm ittees responsible for synthesizing data shall be convened to have sufficient time to collect, analyze and synthesize needed information.

Leading Recommendation 4: The District should work with the states of Kentucky and Indiana to pursue and develop strategies to reduce the PM 2.5 precursor emissions from major regional sources within a range of 150 miles to achieve additional reductions in ambient

PM 2.5 concentrations to protect public health.

Leading Recommendation 5:

The District should work with public and private fl eet owners operating in Louisville Metro through education, incenti ves and grants to aggressively retrofit or replace both onroad and nonroad diesel fl eets with state-of-the-art technology

that reduces emissions.

Leading Recommendation 6: The District should cooperate with local and regional planning agencies to evaluate major subdivision proposals and development plan proposals for all emission components (e.g. PM 2.5 and precursors, ozone, air toxics, greenhouse gases), projected changes in vehicle miles traveled (VMT), projected changes in average daily trips (ADT) and their corresponding impacts on the emissions budget.

Leading Recommendation 7:

The District should initiate a stakehol der process for loca l adoption of onroad and nonroad idling regulations, with the proposed Draft Idle Reduction Regulation (included as Appendix 10) us ed as a starting point for discussion.

Leading Recommendation 8: Counties and municipalities within the Louisville nonattainment area should enact local ordinances to prohibit open burning. To the extent it is allowed, open

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burning should be restricted on days when PM 2.5 concentrations are forecasted to be unhealthy for sensitive populations.

9.2 Recommendations for Regional and State Action

The following recommendations include those th at can only be achieved with action from regional and state entities. Reductions below th e federal standard w ould require a unified regional effort aimed at reducing direct PM 2.5 and precursor emissions.

9.2.1 Currently Achievable

Recommendation 1: All regulated utilities should continue to install control devices according to their current schedules, set forth to comply with Clean Air Interstate Rule (CAIR) requirements.

Recommendation 2: Local and regional authorities should strictly enforce current speed limits throughout the Louisville nonattainment ar ea to reduce emissions of direct PM 2.5 and precursors.

Kentucky and Indiana have state regulations on open burning. Within the Louisville nonattainment area, open burning is strictly pr ohibited in Clark and Floyd Counties in Indiana. Jefferson County, Kentucky, also restricts open burni ng through regulation.

Because direct emissions of PM 2.5 from open burning can affect local ambient air quality,

the Task Force recommends several stra tegies to reduce open burning throughout the

entire Louisville nonattainment area. Issues of enforcement and response times were

discussed and the Task Force determined that additional local ordinances could enhance state efforts to restrict open burning.

Recommendation 3: The Kentucky Division for Air Quality (KY DAQ) and the Indiana Department of Environmental Management (IDEM) shoul d continue to enforce regulations regarding open burning (401 KAR 63:005 and 326 IAC 4)

9.2.2 Achievable in the Short-term

Recommendation 4: Counties and municipalities within the Louisville nonattainment area should enact local ordinances to prohibit open burning. To the extent it is allowed, open burning should be restricted on days when PM 2.5 concentrations are forecasted to be unhealthy for sensitive populations.

Recommendation 5: The Kentucky Division for Air Quality (KY DAQ) should consider amending its regulation to ban open burning in areas in nonattainment of the federal primary

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annual standard for PM 2.5 and to prohibit all burni ng of household rubbish and

waste.

9.2.3 Achievable in the Long-term

Recommendation 6: Federal, state and local governments shoul d create tax incentives, low interest loans and other financial incentives for th e retrofit or replacement of onroad and nonroad diesel fleets.

9.3 Recommendations for Louisvill e Metro Government Action

The following recommendations will requir e action by Louisville Metro Government. The Task Force recognizes that several of these recommendations are only achievable through regional collaboration initia ted by Louisville Metro Government.

9.3.1 Currently Achievable

Recommendation 7: The Partnership for a Green City (PGC) entities should continue to move toward the use of alternative fuels and tech nologies that reduce onroad and nonroad mobile emissions, including retr ofit and replacement options.

9.3.2 Achievable in the Short-term

Recommendation 8: In the funding decisions of the Partne rship for a Green City (PGC) entities, priority should be given to energy efficiency projects as specified by the committees of the PGC.

The Stationary and Area Source Committee propo sed a recommendation to address direct

PM 2.5 emissions from a specific regional source generally thought to influence ambient

concentrations of PM 2.5 in the Louisville nonattainment area. The Task Force believed

that the recommendation should not be limited to a single source and should be expanded to include precursor emissions.

Recommendation 9:

Louisville Metro Government should enc ourage all regional electric generating units (EGUs) to continue to look at cost-effective controls for direct PM 2.5 and precursor emissions in the future.

Recommendation 10: Encourage significant coordination am ong the Kentucky Transportation Cabinet (KTC), the Indiana Department of Trans portation (INDOT), the Kentuckiana Regional Planning and Development Agency (KIPDA), local transportation officials and private fleets during ma jor highway repair or construction,

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including the Louisville-Southern Indiana Ohio River Bridges project, to develop plans to minimize traffic backups and delays to reduce emissions.

Recommendation 11: Louisville Metro Government should explore the creation of a Louisville Metro Environmental Grant Partnership to aggressively coordinate, apply for and receive federal and state grants to reduce direct PM 2.5 and precursor emissions from onroad and nonroad mobile sources. Fe deral political pa rtnerships should
be utilized to increase success.

The Task Force discussed the many reasons for the use of alternative fuels and technologies, such as improving air quali ty, increasing fuel economy and reducing dependence on foreign oil. However the Task Force believed that only those alternative fuels and technologies that re duce air pollution emissions shoul d be considered in this Report.

Recommendation 12: Louisville Metro Government should give pr eference to contractors that provide the best project emission profile through the use of diesel retrofits or newer equipment and alternative fuels that reduce onroad and nonroad mobile

emissions.

Recommendation 13:

Louisville Metro Government’s General Services Administ ration (GSA) should analyze the Metro fleet and create a pl an to improve fleet emissions through diesel retrofit or replacement along with the use of alternativ e fuels that reduce

onroad and nonroad mobile emissions.

9.3.3 Achievable in the Long-term

Recommendation 14: Louisville Metro Government and quasi- governmental agencies should adopt a plan to accelerate the retrofit or repla cement of all diesel fleet vehicles and equipment with state-of-the-art technol ogy and the use of alternative fuels that

reduce onroad and nonroad mobile emissions.

Recommendation 15: Create partnerships, tax incentives and other financial incen tives to encourage the use of biodiesel (ASTM standard) or other alternative fuels and technologies

that reduce onroad and nonroad mobile emissions by private fleets.

Recommendation 16:

Louisville Metro Government should c ooperate with regional transportation and planning agencies to identify opportunities to spur transit-oriented development through the implementation of economic incentive packages (EIPs) and land use measures (LUMs).

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Recommendation 17:

Louisville Metro Government should wo rk with the Kentucky Transportation Cabinet (KTC) and the Indiana Department of Transportation (IDEM) to improve and expand traffic signal synchronization th roughout Louisville Metro to reduce average commute duration and idling.

Recommendation 18:

Louisville Metro Government should wo rk with the Kentucky Transportation Cabinet (KTC), the Indiana Departm ent of Transportation (INDOT) and the Federal Highway Administration to im prove Traffic Response and Incident Management Assisting the River Cities (TRIMARC) incident management and roadside assistance to reduce idling on the highways.

Recommendation 19: Louisville Metro Government should provide free tire pressure stations, free air, free on-board diagnostics checks and free gas caps to promote increased fuel economy and reduce emissions of direct PM 2.5 and precursors.

Recommendation 20: The Partnership for a Green City (P GC) entities should increase funding for facility audits to determine where energy efficiency projects are needed most.

9.4 Recommendations for District Action

The following recommendations will require action by the District. The Task Force recognizes that several of these reco mmendations are only achievable through collaborative efforts and partnerships initiated by the District.

9.4.1 Currently Achievable

Recommendation 21: The District should continue to address po llution from stationary diesel engine sources through compliance with Stra tegic Toxic Air Reduction (STAR) regulations (DR 5.21).

Recommendation 22: The District should make enforcement of its regulation on control of open burning (DR 1.11) a priority in 2008 and 2009.

Recommendation 23: The District should make enforcement of its regulation to control fugitive particulate emissions (DR 1.14 ) a priority in 2008 and 2009.

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Recommendation 24: The District should continue providin g rebates, through the Lawn Care for Cleaner Air Program, for the retiremen t of gasoline powered lawn and garden equipment and the purchase of low emissions equipment.

In committee, consensus was reached for highlighting the regional modeling results from one regional planning organization over anot her based on the use of more recent data. While the majority of the Task Force ag reed with the committee recommendation, one member of the Task Force cautioned agains t comparing results from two different regional models. While the two models projec t very different results, both models are technically sound and relevant to the Louisvil le nonattainment area, and thus, should be given proper consideration in the State Implementation Plan (SIP). The following recommendation represents the consensus of the full Task Force.

Recommendation 25: Of the two regional modeling efforts consid ered by the Task Force, the District should give the Lake Michigan Air Dir ectors Consortium (LADCO) projected design values as much, or more, weight as the Association for Southeastern Integrated Planning (ASIP) projections for reasons listed in Section 5.2.2.1.

Recommendation 26: Based on current monitoring and modeling da ta from local and regional sources, it may be worthwhile for the District to pursue local measures to reduce emissions of organic carbon in addition to measures outside the local area to reduce emissions of SO 2 , a precursor of sulfate formation.

Recommendation 27:

The District should conti nue to monitor the progre ss of the regional modeling groups and other sources of PM 2.5 data utilized by the Task Force to look for additional information that will assist the community in improving its understanding of PM 2.5 emissions and health impacts.

9.4.2 Achievable in the Short-term

Recommendation 28: Building upon the Clean Air Act (CAA) prin ciple that ambient concentrations of

PM 2.5 should be reduced to levels suffici ent to protect public health with an adequate margin of safety, reductions below the federal primary annual standard of 15 μg/m 3 are advisable to provide an additiona l margin of safety that allows and compensates for scientific uncertainty, including the potential health impacts on sensitive populations. To achieve thes e reductions, the District should establish an ongoing and continuous process of review of all sources of PM 2.5 emissions (including onroad and nonroad mobile sources, area sources, stationary sources, etc.) and develop and implement policies, practices and standards to continue progress towards reducing ambient concentrations of PM 2.5 and precursors. In the development of su ch policies, practices and standards,

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stakeholder involvement should be an integral part of the process. Those strategies that achieve lower emissions of hazard ous air pollutants (HAPs) and ozone precursors in conjunction with reducing PM 2.5 should be a priority and a strong emphasis should be placed on educational programs for the public.

Recommendation 29:

The District should create a diverse sta keholder advisory committee to continue to focus and advise the Board on issues of air pollution, public health and environmental justice related to PM 2.5 and to strategize on policies, practices and programs to reduce PM 2.5 ambient concentrations, as outlined in

Recommendation 28.

The Task Force agreed that there is no theoretically safe level of PM 2.5 and that reducing

ambient concentrations of PM 2.5 to levels below the federal standard would further protect public health and welfare. Several Task Force members in itially supported the notion of setting a numeric health-b ased annual goal of 12 to 10 μg/m 3 by 2018. Several other members believed that setting an in terim numeric goal was premature given the magnitude of emission reductions expect ed over the next few years with the implementation of federal rules, namely CA IR. In the end, many proponents of setting a numeric goal agreed that such an effort ma y be premature, noting that a goal more stringent than 12 to 10 μg/m 3 by 2018 may be necessary give n the anticipated reductions

for ambient PM 2.5 . The following recommendation repres ents consensus of the full Task

Force on this issue.

Recommendation 30: As a part of the ongoing process, a sta keholder group should be convened in 2010 to review peer-reviewed health literat ure, ambient monito ring data and modeling results to determine whether interim numeric goals are advisable to achieve continued progress towards the reduction of ambient PM 2.5 concentrations sufficient to protect public health with an adequate margin of safety. Six months prior to convening the 2010 review, comm ittees responsible for synthesizing data shall be convened to have sufficient time to collect, analyze and synthesize needed information.

Recommendation 31: The District should work with the states of Kentucky and Indiana to pursue and develop strategies to reduce the PM 2.5 precursor emissions from major regional sources within a range of 150 miles to achieve additional reduction in ambient

PM 2.5 concentrations to protect public health.

Recommendation 32: The District should cooperate with local and regional planning agencies to evaluate major subdivision proposals and development plan proposals for all emission components (e.g. PM 2.5 and precursors, ozone, air toxics, greenhouse gases), projected changes in vehicle miles traveled (VMT), projected changes in

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average daily trips (ADT) and their corresponding impacts on the emissions budget.

Recommendation 33:

The District should initiate a stakehol der process for loca l adoption of onroad and nonroad idling regulations, with the proposed Draft Idle Reduction Regulation (included as Appendix 10) us ed as a starting point for discussion.

Recommendation 34: The District should prescreen permit app lications and give review priority to pollution prevention projects, especially those that could reduce direct PM 2.5 and precursor emissions.

Recommendation 35:

The District should review the backlog of construc tion permit applic ations for pollution prevention projects that could reduce direct PM 2.5 and precursor emissions. If any construction permit applic ations that meet these criteria are identified, the District should prioritize review of these applic ations so that, if approved, these projects can be installed in early 2008.

Recommendation 36: The District should encourage electric generating units (EGUs) to achieve as many early reduction credits as possible for 2008.

Recommendation 37: The District should cooperate with loca l and regional agencies to determine if any transportation control measures (TCMs), economic incentive packages (EIPs) and land use measures (LUMs) are currently being implemented that have

not been included in the exi sting emissions budget and could be credited in the State Implementation Plan (SIP).

Recommendation 38:

The District should consider including as contingency measures in the State Implementation Plan (SIP) for the annual PM 2.5 standard those onroad and nonroad mobile contingency measures from the 8-hour Ozone State SIP that will

also reduce direct PM 2.5 and precursor emissions.

Recommendation 39:

The District should evaluat e and employ existing mechanisms under the Clean Air Act (CAA) to address identifiable contri buting sources of fine particulates and particulate precursors that interfere with attainment and mainte nance of healthful air quality in the Louisville Metro community.

Recommendation 40: The District should work with EPA, the regional modeling groups and local sources to conduct updated and more de tailed regional and local modeling

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studies to gain a better understanding of the re lative impact and timing of regional and local emission reductions , beyond planned controls, on local PM 2.5 concentrations after 2009.

Recommendation 41: The District should explore partnership opportunities wi th companies specializing in energy efficient products and services to increase awareness of the benefits of energy efficiency for industrial, co mmercial and residential customers.

Recommendation 42:

The District should work with Louisvill e, Kentucky and Indiana Home Builders

Associations to educate members on the economic and environmental benefits of incorporating energy efficiency me asures into building projects.

Recommendation 43: The Board should encourage existing fundi ng entities to incr ease funding of Project Warm.

Recommendation 44:

The District should increase public awareness of the ef fects of charcoal grilling on ambient concentrations of PM 2.5 and NO

x .

Recommendation 45:

The District should meet with Louisville and sout hern Indiana restaurant associations to discuss potentia lly feasible and cost-effective PM 2.5 control

measures that that could reduce PM 2.5 emissions from local restaurants, particularly those with commercial charbroilers.

Recommendation 46: The District should promote EPA’s Great American Woodstove Changeout

program.

Recommendation 47:

The District should increase public awareness of the effects of using fireplaces,

woodstoves and wood boilers on ambi ent concentrations of PM 2.5 and NO

x and the benefits of switching to more efficient sources of heat.

Recommendation 48: The District should expand corporate spons orship of the Lawn Care for Cleaner Air Program to increase brands and products that are rebate eligible.

Recommendation 49: Through outreach, the District should increase public awareness of alternatives to residential solvent usage and the benefits of avoiding household products containing organic compounds such as tolu ene, xylene and trimethyl benzene.

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Recommendation 50: The District should recognize those businesses that have implemented Best Workplaces for Commuters (BWC) practices to reduce the total vehicle miles traveled by employees.

Recommendation 51: The District should encourage members of the Associated General Contractors (AGC) of Kentucky, The Association of Union Constructors (TAUC) and other trade associations to retrofit or replace both onroad and nonroad diesel equipment.

9.4.3 Achievable in the Long-term

Recommendation 52:

The District should work with public and private fl eet owners operating in Louisville Metro through education, incenti ves and grants to aggressively retrofit or replace both onroad and nonroad diesel fl eets with state-of-the-art technology

that reduces emissions.

Recommendation 53: A partnership should be created, among st ate and local agencies and chambers of commerce, to increase awareness of and participation in elec tric utilities’ demand side management (DSM) programs.

Recommendation 54: The District should develop and implem ent a recognition program to reward energy efficiency initiatives and achi evements throughout the community on a variety of scales.

Recommendation 55:

The District should consider working in voluntary partn ership with the owners of non-utility coal-fired boilers to research the cost-effect iveness of converting these boilers to alternative fuels and/or installing additional direct PM 2.5 , NO

x and SO 2 control devices.

Recommendation 56: The District should initiate efforts to create an interstate commission to reduce

ambient PM 2.5 and precursor emissions through coordinated regional efforts within and among states whos e sources of direct PM 2.5 and precursor emissions are identified as contributing to the boundar y air pollution levels in the Louisville

nonattainment area.

Recommendation 57: The District should work with EPA, the states of Kentucky and Indiana and local sources to improve methods to estimate local sources of PM 2.5 emissions.

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Recommendation 58:

The District should work with EPA and th e states of Kentucky and Indiana to continue to fund existing, as we ll as increase the number of, PM 2.5 speciation

monitors in the area so as to be tter understand the local and regional contributors of PM 2.5

.

Recommendation 59: The District should develop and implemen t a program to encourage replacement of charcoal grills in Jefferson County with gas and/or electric units through a rebate system similar to the Lawn Care for Cleaner Air program.

Recommendation 60: The District should cooperate with local and regional planning agencies to quantify the difference between emissions budgets that re sult from business-asusual and alternative growth scenarios using comparison guidelines provided by

EPA.

Recommendation 61: The District, in conjunction with Greater Louisville Inc. (GLI), should develop a partnership, between rental car agencies and public and private entities utilizing rental fleets, to increase the use of biodiesel (ASTM standard) or other alternative fuels and technologies that reduce emissions from rental fleets.

Recommendation 62: The District should work in partnership with the Kentucky Petroleum Marketers Association, the Indiana Petroleum Marketers and Convenience Store Association, retailers, distributors a nd other stakeholders to evaluate, develop and achieve goals to provide biodiesel (ASTM standard) blends at retail stations throughout the Louisville nonattainment area.

Recommendation 63: The District should work in partnership with marine and railroad operations in the Louisville nonattainment area to identify and reduce direct PM 2.5 and precursor emissions.

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Report and Plan of Action

Appendices

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Appendix 1 Acronyms and Abbreviations

ACI...................................Airports Counc il International ADT .................................Average daily trips

AGC .................................Associated General Contractors APU..................................Auxiliary power unit

ASIP.................................Association for Southeas tern Integrated Planning ASRC ...............................American Synthetic Rubber Company ASTM Standard ...............Quality standard set by the American Society for Testing and

Materials BART...............................Best Available Retrofit Technology BWC ................................Best Workplaces for Commuters

Board................................Air Pollution Control Board CAA .................................Clean Air Act, 42 USC 7401 et seq

CAIR................................Clean Air Interstate Rule

CARB...............................California Air Resources Board CASAC ............................Clean Air Scientific Advisory Committee CFR .................................Code of Federal Regulations

CO....................................Carbon monoxide

District..............................Air Pollution Control District

DOC .................................Diesel oxida tion catalyst DOT .................................United States Department of Transportation DPF ..................................Diesel part iculate filter DR....................................District Regulation DSM.................................Demand side management DV....................................Design value DVF..................................Future Design Value

EC ....................................Elemental carbon EGU .................................Electric generating unit EIP....................................Economic incentive packages EPA..................................U.S. Environmental Protection Agency ESP...................................Electrostatic precipitator EUP..................................Energy Use Partnership

FAA..................................Federal Aviation Administration FEDOOP .........................Federally enforceable District origin operating permit FGD..................................Flue gas desulfurization FR.....................................Federal Register

FRM .................................Federal Reference Method

GE ....................................General Electric

GLI...................................Greater Louisville In c. (Chamber of Commerce)

GSA..................................Louisville Metro General Services Administration GSE..................................Ground support equipment HAP..................................Hazardous air pollutant HEPA filter ......................High efficiency particulate air filter

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IAC...................................Indiana Administrative Code IDEM ...............................Indiana Department of Environmental Management Implementation Rule........Clean Air Fine Particle Implementation Rule INDOT .............................Indiana Department of Transportation JCPS.................................Jefferson County Public Schools KAR .................................Kentucky Administrative Regulations KIPDA .............................Kentuckiana Regional Pl anning and Development Agency KMTA..............................Kentucky Motor Transport Association Kosmos ............................Kosmos Cement Company KPPC................................Kentucky Pollution Prevention Center KTC..................................Kentucky Transportation Cabinet

KWh.................................Kilowatt hour KY DAQ ..........................Kentucky Division for Air Quality LED..................................Light-emitting diode LADCO............................Lake Michigan Air Directors Consortium

LUM.................................Land use measures

MACT..............................Maximum achievab le control technology

μ m ....................................Micrometers

μ g/m 3 ................................Micrograms per cubic meter NAAQS............................National Ambient Air Quality Standard NACAA ...........................National Association of Clean Air Agencies NCDC ..............................National Clean Diesel Campaign (EPA program)

NH 3 ..................................Ammonia

NH 4 ..................................Ammonium NMIM ..............................National Mobile Inventory Model (EPA model)

NO 2 ..................................Nitrogen dioxide

NO 3 ..................................Nitrate

NO

x ..................................Nitrogen oxides OC....................................Organic carbon

Pb .....................................Lead PGC..................................Partnership for a Green City

PM....................................Particulate matter

PM 0.1 ................................Ultrafine particulate matter

PM 10 .................................Inhalable particulate matter

PM 10-2.5 .............................Course particulate matter

PM 2.5 ................................Fine particulate matter ppm ..................................Parts per million RAA .................................Regional Airport Authority RACM..............................Reasonably Availabl e Control Measures RACT...............................Reasonably Availa ble Control Technology Report...............................Report and Plan of Action RFP ..................................Reasonable Further Progress SCR..................................Selective catalytic reduction

SEDC ...............................Southeast Diesel Collaborative SIP....................................State Implementation Plan

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### Fine Particle Air Quality Task Force Report and Plan of Action

SNCR ...............................Selective non-catalytic reduction

SO 2 ...................................Sulfur dioxide

SO 4 ...................................Sulfate STAI.................................School Transportation Association of Indiana STAR ...............................Strategic Toxic Air Reduction TARC...............................Transit Authority of River City Task Force........................Fine Particle Air Quality Task Force

TAUC...............................The Association of Union Constructors TCM.................................Transportation control measures Tier #................................Represents the correspondi ng iteration of federal engine requirements Title V, TV.......................Title Five of the Clean Air Act, 42 USC 7661 et seq. tpy ....................................Tons per year TRIMARC .......................Traffic Response and Incident Management Assisting the River

Cities TSP...................................Total suspended particulate TVA .................................Tennessee Valley Authority

ULSD ...............................Ultra Low Sulfur Diesel U of L...............................University of Louisville

UPS ..................................United Parcel Service VALE...............................Voluntary Airport Low Emissions VISTAS............................Visibility Improvement State and Tribal Association of the

Southeast

VMT.................................Vehicle miles traveled VOC .................................Volatile organic compound WHO................................World Health Organization

Page 68 January 16, 2008

### Fine Particle Air Quality Task Force Report and Plan of Action

Appendix 2 Fine Particle Ai r Quality Task Force Members

Tony Arnold University of Louisville

Graham Baughman
Thorntons Inc.

John Brazel Associated General Contractors of Kentucky

Lona Brewer Kentucky Division for Air Quality

Christy Lee Brown Community Representative

Dennis Conniff
Frost Brown Todd LLC Representing Greater Louisville, Inc.

Air Toxics Task Force

Tim Corrigan The Rotunda Group Representing Greater Louisville, Inc.

Pat Daniel Indiana Dept. of Environmental Management

Sharon Dodson

E.ON U.S. Alt. Gary Revlett

Alt. Sarah Scheetz

Jamie Fiepke Kentucky Motor Transport Association

Tom FitzGerald Kentucky Resources Council Alt. Sarah Lynn Cunningham

Arnita Gadson University of Louisville West Jefferson County Community Task Force

Tim Hagerty
Frost Brown Todd LLC Representing Greater Louisville, Inc.

Environmental Affairs Committee

Dr. Lauren Heberle University of Louisville

Alt. Isabella Christensen

Regina Henry Cemex Kosmos Cement Company

Alt. Shannon Graves Alt. Amy Osborn Wayne Hicks Transit Authority of the River City Alt. Geoffrey Hobin

Mark Hussung
General Electric

Alt. Steve Marks

Alt. Tim Hooker

Bill Jacob
United Parcel Service

Rick Larkins Highview Fire District

Dr. John Lewis Greater Louisville Medical Society

Jesse Mayes Kentucky Transportation Cabinet

Heidi McKenzie Ford Motor Company Alt. Greg Long

Wallace McMullen
Sierra Club

Patrick Moran Community Representative

Suzy Post Metropolitan Housing Coalition

Dr. Robert Powell
Norton Healthcare Representing Greater Louisville Medical Society

& Louisville Metro Air Pollution Control Board

Karen Scott Regional Airport Authority Alt. Bob Slattery

Kevin Spangler OxyVinyls, L.P.

Jim Vaughn Jefferson County Public Schools

Dan Weiss Duke Energy

Paul Wheatley
One Southern Indiana

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### Fine Particle Air Quality Task Force Report and Plan of Action

Appendix 3 Fine Particle Air Qu ality Task Force Committee Members

Report and Plan of Action Committee

Tony Arnold

Dennis Conniff Tim Corrigan

Arnita Gadson

Lauren Heberle Heidi McKenzie

Dr. Robert Powell Karen Scott (Chair) Kevin Spangler

Health Committee

Christy Lee Brown

Sharon Dodson

Tom FitzGerald

Arnita Gadson Tim Hagerty

Dr. Lauren Heberle

Dr. John Lewis (Chair)
Dr. Robert Powell (Vice-chair)

Stationary and Area Source Committee

Tim Corrigan (Chair)

Sharon Dodson

Tom FitzGerald

Arnita Gadson

Rick Larkins

Wallace McMullen Heidi McKenzie

Dr. Robert Powell

Karen Scott Kevin Spangler

Dan Weiss Paul Wheatley

Mobile and Nonroad Mobile Source Committee

Tim Corrigan Jamie Fiepke Tom FitzGerald (Chair)

Arnita Gadson Wayne Hicks Jim Vaughn Mark Hussung

Bill Jacob

Pat Moran

Karen Scott

Emissions Inventory and Modeling Data Committee

Tim Corrigan, GLI

Sharon Dodson

Arnita Gadson Regina Henry Wallace McMullen

Pat Moran

Karen Scott Dan Weiss (Chair)

Page 70 January 16, 2008

### Fine Particle Air Quality Task Force Report and Plan of Action

Appendix 4 Record of Heal th Committee Meeting Attendance

The following table is a record of Health Committee meeting attendance. A record of attendance is kept through meeting sign in sheets, which may be supplemented by District staff notes from each meeting.

Member 19-Sep 26-Sep 3-Oct 10-Oct 25-Oct

Christy Lee Brown Y Y Sharon Dodson (Alt. Sarah Scheetz) Y Y Y Y Tom FitzGerald (Alt. Sarah Lynn Cunningham) Y Y Y Y Y

Arnita Gadson Y Y Y Y Tim Hagerty Y Y

Lauren Heberle Y Y Y Y Y

Dr. John Lewis Y Y Y Y Y Suzy Post Y

Dr. Robert Powell Y Y Y

Dan Weiss Y

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### Fine Particle Air Quality Task Force Report and Plan of Action

Appendix 5 List of source categories for starting point for identifying potentially available control strategies for nonattainment area

Stationary source measures

- Stationary diesel engine retrofit, rebuild or replacement, with cat alyzed particle filter

- New or upgraded emission cont rol requirements for direct PM 2.5 emissions at stationary sources (e.g., installation or improved performance of control devices such as a baghouse or electrostatic precipitator; revised opacity standard; improved compliance monitoring methods)

- Improved capture of particulate em issions to increase the amount of PM 2.5 ducted to control devices, and to minimize the amount of PM 2.5 emitted to the atmosphere, for example, through roof monitors

- New or upgraded emission controls for PM 2.5 precursors at stati onary sources (e.g., SO 2 controls such as wet or dry scrubbers, or reduc ed sulfur content in fuel; desulfurization of coke oven gas at coke ovens; improved sulf ur recovery at refineries; increasing the recovery efficiency at sulfuric acid plants)

- Energy efficiency measures to reduce fu el consumption and associated pollutant emissions (either from local sour ces or distant power providers)

- Measures to reduce fugitive dust from industrial sites

Mobile source measures - Onroad diesel engine retrofits for school buses, 34 trucks and transit buses using EPAverified technologies

- Nonroad diesel engine retrofit, rebuild or replacement, with catalyzed particle filter 35

- Diesel idling programs for trucks, lo comotive, and other mobile sources 36

- Transportation control measures (including t hose listed in section 108(f) of the CAA as well as other TCMs), as well as other transportation demand management and transportation systems management strategies 37

- Programs to reduce emissions or accelerate retirement of high emitting vehicles, boats, and lawn and garden equipment

- Emissions testing and repair/maint enance programs for onroad vehicles

- Emissions testing and repair/maintenance programs for nonroad heavy-duty vehicles and equipment 38

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### Fine Particle Air Quality Task Force Report and Plan of Action

- Programs to expand use of clean burning fuels 39

- Low emissions specifications for equipm ent or fuel used for large construction contracts, industrial facilities, ship yards, airports, and public or private vehicle fleets

- Opacity or other emissions standards for “gross-emitting” diesel equipment or vessels

Area source measures

- New open burning regulations and/or measures to improve program effectiveness such as programs to reduce or eliminate burning of land clearing vegetation

- Programs to reduce emissions from w oodstoves and fireplace s including outreach programs, curtailments during days with expected high ambient levels of PM 2.5 , and programs to encourage replacement of woodstoves when houses are sold

- Controls on emissions from charbroili ng or other commercial cooking operations

- Reduced solvent usage or solvent substituti on (particularly for or ganic compounds with 7 carbon atoms or more, such as toluen e, xylene, and trimethyl benzene)

Category-Specific Guidelines on innovative approaches

.

The EPA has issued a number of category specific guidelines on approaches to taking into account innovative approaches to em issions reductions for purposes of SIPs. Categories currently covered by these guide lines include: (1) El ectric-sector Energy Efficiency and Renewable Energy Measures (2) Long Duration Switch Yard Locomotive Idling (3) Long Duration Truck Idling (4) Clean Diesel Combustion Technology (5) Commuter Choice Programs. See http://www.epa.gov/ttn/airinnova tions/measure_specific.html

34 See Clean School Bus USA program at http://www.epa.gov/cleanschoolbus/. See also:

What You Should Know About Diesel E xhaust and School Bus Idling", (June 2003, EPA420-F-03-021) at http://www.epa.gov/ otaq/retrofit/documents/f03021.pdf.

35 See EPA’s voluntary diesel re trofit program web site at http://www.epa.gov/otaq/retro fit/overfleetowner.htm.

36 See EPA’s voluntary diesel re trofit program web site at http://www.epa.gov/otaq/retrofit/idling.htm.

37 See EPA’s website on transp ortation control measures at http://www.epa.gov/otaq/transp/traqtcms.htm.

38 See EPA’s web site on nonroad engines, equipment, and vehicles at http://www.epa.gov/otaq/nonroad.htm.

39 Fuels adopted in SIPs must be consiste nt with the Energy Policy Act of 2005 and EPA guidance on SIP-approved boutique fu els at 71 FR 78192 (December 28, 2006).

Page 73 January 16, 2008Fine Particle Air Quality Task ForceReport and Plan of ActionPage 74January 16, 2008Appendix 6 Stationary/Area Source Reduction Strategy Evaluation MatrixSuggestedEmissionReductionMeasureStrategyTypeResponsibleEntities andPotentialPartnersImpactedPollutants(includingCobenefits)Ease ofImplementation(politicalclimate,stakeholderreceptivness,challenges,additionalresourcesrequired,availableresources,etc.)LocalExamples ofImplementationAdditionalAPCDResourcesNeeded forImplementation Current Control Reduction Contributin Reduction Efficiency M/V/P Reasonableness-Social Reasonableness-Political Cost-Effective TotalCurrent: Relative ranking (1-3: low to high) of current emissions from the sourcecategory affected by the reduction measureControl: Are there measures that could be implemented toreduce emissions, relative ranking (1-3: low to high)Reduction Contribution: How much emission reduction could be achieved compared to area emission, relative ranking (1-3: low to high)Reduction Efficiency: How much emission reduction could be achieved compared to current emissions per source, relative ranking(1-3: low to high)M/V/P = Mandatory, Voluntary or PartnershipReasonableness-Social: How socially feasible are the measures? (1-3: low to high)Reasonableness-Political: How politically feasible are the measures?Cost-Effective: Relative cost-effectiveness measure (1-3: low to high)Total: Total points from thefour relative ranking factors

### Fine Particle Air Quality Task Force Report and Plan of Action

Appendix 7 DRAFT E.ON U.S. Planned Control Projects

Planned NO

x 

### Control Projects

Company Facility Unit Existing Controls Pla nned Controls Regulatory

Driver Operating

Year % Change (2005 Baseline) 2005

Emission Projected

Annual

Emission Change in

Tons

LGE Cane Run 4 Low NOx Burners 2,115

LGE Cane Run 5 Low NOx Burners 2,325

LGE Cane Run 6 Low NOx Burners 2,601

WKE Coleman 1 Rotary Over-Fire Air 1,655

WKE Coleman 2 Advanced Over-Fire Air 1,723

WKE Coleman 3 Advanced Over-Fire Air 1,755

KU E.W. Brown 1 Low NOx Burners 1,694

KU E.W. Brown 2 Low NOx Burners 1,607

KU E.W. Brown 3 Low NOx Burners 2,504

KU Ghent 1 SCR year round CAIR 2009 -81% 4,778 914 -3,864

KU Ghent 2 Low NOx Burners 3,736

KU Ghent 3 SCR year round CAIR 2009 -75% 2,585 658 -1,927

KU Ghent 4 SCR year round CAIR 2009 -75% 2,810 701 -2,109

KU Green 1 Coal Re-burn year round CAIR 2009 -17% 3,041 2,524 -517

KU Green 2 Coal Re-burn year round CAIR 2009 -12% 2,650 2,332 -318

KU Green River 3 Low NOx Burners 900

KU Green River 4 Low NOx Burners 655

WKE Henderson 1 SCR year round CAIR 2009 -71% 1,574 456 -1,118

WKE Henderson 2 SCR year round CAIR 2009 -74% 2,133 555 -1,578

LGE Mill Creek 1 Low NOx Burners 3,205

LGE Mill Creek 2 Low NOx Burners 2,845

LGE Mill Creek 3 SCR year round CAIR 2009 -79% 3,280 674 -2,607

LGE Mill Creek 4 SCR year round CAIR 2009 -81% 3,738 724 -3,015

WKE Reid 1 Over-fire Air 1,097

LGE Trimble County 1 SCR year round CAIR 2009 -74% 3,381 894 -2,487

KU Tyrone 3 Low NOx Burners 955

WKE Wilson 1 SCR year round CAIR 2009 -80% 6,330 1,266 -5,064

Reductions E.ON
U.S. -36% 67,671 -24,604

Total/Ave at units

with additional
controls -68% 36,301 -24,604

Note : The following facilities plan to run existing SCR’s year round starting 2009: Henderson Units 1 & 2, Mill Creek Units 3 & 4 , Ghent 1, 3 & 4, Trimble 1, Wilson 1. There will be significant increased operating costs to do this, although relatively little capital expense. KY ERC's available: 14,035

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### Fine Particle Air Quality Task Force Report and Plan of Action

Planned SO 2 

### Control Projects

Company Facility Unit Existing

Controls Planned

Controls Regulatory

Driver Operating

Year % Change (2005 Baseline) 2005

Emission Projected

Annual

Emission Change

in Tons Project Cost Original

Estimates* (million $)

LGE Cane Run 4 FGD 5,543

LGE Cane Run 5 FGD 5,085

LGE Cane Run 6 FGD 8,234

WKE Coleman 1 FGD CAIR 2006 -97% 17,988 540 -17,448 $98

WKE Coleman 2 FGD CAIR 2006 -97% 17,757 533 -17,224

WKE Coleman 3 FGD CAIR 2006 -97% 21,069 632 -20,437

KU E.W. Brown 1 FGD CAIR 2009 -96% 8,682 340 -8,342 $234

KU E.W. Brown 2 FGD CAIR 2009 -95% 13,804 720 -13,084

KU E.W. Brown 3 FGD CAIR 2009 -91% 20,376 1,860 -18,516

KU Ghent 1 FGD 5,503

KU Ghent 2 FGD CAIR 2009 -87% 13,960 1,780 -12,180 $150

KU Ghent 3 FGD CAIR 2007 -87% 15,054 2,000 -13,054 $129

KU Ghent 4 FGD CAIR 2008 -86% 15,669 2,200 -13,469 $146

KU Green 1 FGD 1,434

KU Green 2 FGD 846

KU Green River 3 9,017

KU Green River 4 6,901

WKE Henderson 1 FGD 2,104

WKE Henderson 2 FGD 2,637

LGE Mill Creek 1 FGD 4,157

LGE Mill Creek 2 FGD 4,270

LGE Mill Creek 3 FGD 7,703

LGE Mill Creek 4 FGD 7,903

WKE Reid 1 9,280

LGE Trimble County 1 FGD FGD upgrade 2006 -84% 5,236 862 -4,373 $7

KU Tyrone 3 3,192

WKE Wilson 1 FGD 11,008

Subtotal Original

Estimate -57% 244,409 -138,127 $764

Expected Increase

in Costs $240

Current Estimate

E.ON U.S. -57% 244,409 -138,127 $1,004

Total/Ave at units

with additional

controls -92% 149,594 -138,127 $1,004

The FGD’s being installed at Brown and Ghent are expected to achieve around 98% removal. However, since the units will be switc hing to higher sulfur coal than they burned in 2005, the net reduction compared to 2005 is somewhat less. *Project Cost Original Estimates includes estimated Costs for KU & LGE from PSC Testimony of John Malloy, Dec. 2004.

Costs for FGDs at Brown and Ghent are now expected to be approx. $900 million, rather than the origin ally estimated ~ $660M. The total cost is now expected to be over $1 Billion.

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### Fine Particle Air Quality Task Force Report and Plan of Action

Appendix 8 Current and Planned Pollutant Control Measures for

Indiana Utilities

Southern Indiana CAIR Policy Case Controls CAIR

Costs (Millions$) Plant Name Capacity Existing Control*

2008 2009 2010-12 2015 2018 2008-2025

SIGECO A B BROWN: 1 250 SCR+Scrubber

SIGECO A B BROWN: 2 250 SCR+Scrubber

DUKE CAYUGA: 1 500 Scrubber SCR 244.651

DUKE CAYUGA: 2 495 Scrubber SCR 242.984

IKEC CLIFTY CREEK: 1 199 SCR Scrubber 81.519

IKEC CLIFTY CREEK: 2 199 SCR Scrubber 81.519

IKEC CLIFTY CREEK: 3 199 SCR Scrubber 81.519

IKEC CLIFTY CREEK: 4 199 SCR Scrubber 81.519

IKEC CLIFTY CREEK: 5 199 SCR Scrubber 81.519

IKEC CLIFTY CREEK: 6 199 SCR+Scrubber 130.872

DUKE EDWARDSPORT: 7-1 40 Retire

-

DUKE EDWARDSPORT: 7-2 40 Retire

-

DUKE EDWARDSPORT: 8-1 40 Retire

-

IPL ELMER W STOUT: 50 109 SNCR 3.817

SIGECO F B CULLEY: 2 90 Scrubber

-

SIGECO F B CULLEY: 3 270 SCR+Scrubber

-

HEC FRANK E RATTS: 1SG1 122

-

HEC FRANK E RATTS: 2SG1 121
-

DUKE GIBSON: 1 630 SCR Scrubber 181.820

DUKE GIBSON: 2 630 SCR Scrubber 181.820

DUKE GIBSON: 3 630 SCR Scrubber 181.820

DUKE GIBSON: 4 622 SCR+Scrubber

-

DUKE GIBSON: 5 620 SCR+Scrubber

-

HEC MEROM: 1SG1 507 SCR+Scrubber

-

HEC MEROM: 2SG1 493 SCR+Scrubber

-

NIPSCO MICHIGAN CITY: 12 469 SCR

-

IPL PETERSBURG: 1 232 Scrubber

-

IPL PETERSBURG: 2 407 Scrubber SCR 78.600

IPL PETERSBURG: 3 510 Scrubber SCR 91.050

IPL PETERSBURG: 4 545 Scrubber

-

DUKE R GALLAGHER: 1 140 baghouse 25.000

DUKE R GALLAGHER: 2 140 baghouse 25.000

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### Fine Particle Air Quality Task Force Report and Plan of Action

DUKE R GALLAGHER: 3 140 baghouse 25.000

DUKE R GALLAGHER: 4 140 baghouse 25.000

AEP ROCKPORT: MB1 1,300

-

AEP ROCKPORT: MB2 1,300

-

AEP TANNERS CREEK: U1 140

-

AEP TANNERS CREEK: U2 140

-

AEP TANNERS CREEK: U3 200

-

AEP TANNERS CREEK: U4 500 SCR+Scrubber 244.651

DUKE WABASH RIVER: 2 85 SNCR 3.245

DUKE WABASH RIVER: 3 85 SNCR 3.245

DUKE WABASH RIVER: 4 85 SNCR 3.245

DUKE WABASH RIVER: 5 95

-

DUKE WABASH RIVER: 6 318 SCR+Scrubber 565.446

SIGECO WARRICK: 4 150 SCR 41.007
Total Capital

Dollars = 2,705.865

Run Year Structure: MY2008 = 2007-2008, MY2009 = 2009, MY2012 = 2010-2013, MY2015 = 2014-2017, MY2018=MY2018, MY2020 = 2019-2022

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### Fine Particle Air Quality Task Force Report and Plan of Action

Appendix 9 Energy Efficiency Programs and Projects

Duke Energy Indiana Energy Effici ency & Conservation Initiatives

A. Residential Customers

Free Services Home Energy House Call Home Energy House Call is a free in-home energy analysis for Duke Energy homeowners who meet the guid elines. Sign up today and receive a free Energy Efficiency Starte r Kit retail valued at $40.
Refrigerator Replacement Duke Energy offers free installation of energy-efficient refrigerators for those customers meeting income qu alifying guidelines and who live in single-family homes.

Indiana Home Weatherization Duke Energy, in partnership with the St ate of Indiana, offers free energysaving home upgrades for customers meeting income qualifying guidelines.

Products, Rebates & Other Programs
Power Manager The Power Manager Program pays you annually for having your air conditioning cycled off-and-on a few days each summer and up to a $35

installation credit.

Smart $aver® Smart $aver promotes the use of high-efficiency heat pump and airconditioning systems for existing home s. Install a new high-efficiency heat pump and you may be eligible to receive a rebate up to $200. Smart $aver Eligibility and FAQs

ENERGY STAR® New Home ENERGY STAR® is a government-backed symbol of quality that identifies a new home as being more energy efficient than a standard home. ENERGY STAR homes may qua lify for Duke Energy Indiana’s

ENERGY STAR incentives. ENERGY STAR® Eligibility & FAQs Online Energy Store Visit our Online Energy Store to purc hase a variety of energy-efficient products including compact fluorescent bulbs, water conservation tools

and much more.

Energy Saving Tools Home Energy Calculator

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### Fine Particle Air Quality Task Force Report and Plan of Action

This tool provides a quick example of how energy saving measures could lower your energy costs. It estimates how new energy efficient practices and/or equipment in your home could save you money. Appliance Calculator Use this tool to estimate the cost of operating the electric appliances in your home.

B. Business Customers - En ergy Management Programs

Energy Efficiency Incentive Program Reward your business for saving energy. Install qualifying high-efficiency lighting, cooling or motors/pumps at your facility, complete a short application form, and you will receive a rebate.

Business Services Newsletter Our Duke Energy Business Services Ne wsline For Your Business is a free

electronic newsletter filled with inform ation about energy efficiency, industry trends and Duke Energy products and services.

Energy Saving Tips Take advantage of these money-saving tip s to help manage your energy costs. Business Energy Calculator This tool provides a quick example of how energy saving measures could lower your energy costs. It estimates how different business practices and/or equipment could save you money. Business Energy Systems Library This extensive library provides in-depth information on various business energy systems, building desi gn, and energy technologies. Understanding Demand Learn more about how your demand for electricity can impact your electricity costs. This interactive to ol explains the concept of demand and how the equipment you use add up each hour of the day. Power Quality From voltage fluctuations to flickeri ng lights, our team of engineers and technicians can visit you r business to evaluate your power supply or distribution system and answer any questions you may have.

Products and Services News and Reports

Information

Contact Us

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### Fine Particle Air Quality Task Force Report and Plan of Action

C. Industrial Customers Energy Management Programs

Energy-Saving Tips It's very simple! As a service to our cust omers, we put together a reference guide to help you better manage your electric bill.

Cutting Your Energy Costs Calculator Use this calculator to estimate possi ble savings which may be gained from reducing your energy usage.

PowerShare® PowerShare provides the opportunity for you to profit from curtailment of your energy usage. Duke Energy will work with you to help you better understand your unique energy consumption profile. The n, we can assist you in developing a customized plan that identifies potential curtailable loads. For more information
or to enroll in PowerShare, contact our business service cent er at 1-800-774-1202.

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### E.ON U.S. Energy Efficiency Programs

Existing Programs

Program / Offering / Activity Comment

"Demand Conservation" Load Control Program This program provides for the installation of a switch on the customer air conditioning unit or water heater that permits LG&E/KU to cycle that load to manage demand at peak times. For pa rticipating, th e customer receives either a $20 credit per year or a programmable thermostat. Program enrollment exceeds 80,000 at present and provides ~100 MW of peak demand savings. Residential Energy Audits This program provides energy audits for residential customers to identify area s in the home for reduction of wasted energy. Commercial Energy Audits This program provides energy audits for commercial customers to identify areas in the facility for reduction of wasted energy.

Low-Income Weatherization (WeCare) This program provides for energy improvements at the homes of qualified low income customers.

Online Home Energy Calculator This is an online web tool for customers to help them estimate their home energy bill and find savings.

Online Commercial Energy

Calculator This is an online web tool for customers to help them estimate their workplace en ergy bill and find savings.

Online Home Energy Reference Library This is an online web tool for 'room by room' analysis of a typical home to help the customer find energy savings. Online Commercial Energy Reference Library This is an online web tool for 'room by room' analysis of a typical workplace to help the customer find energy savings. Energy Efficiency in E.ON U.S. Corporate Facilities E.ON U.S. has implemented energy efficiency initiatives at corporate facilities where conditions (leased facilities vs. company-owned) permit – including efficient lighti ng, load control switching, and/or programmable thermostats.
Net Metering Tariff This tariff is av ailable to customers who own, operate and maintain a solar, wind or hydroelectric generation system on their pr emises, in parallel with the Company’s electric system to provide all or part of their electrical requirements.

### Fine Particle Air Quality Task Force Report and Plan of Action

Green Energy Program This program allo ws customers to contribute funds in $5 blocks (residential/co mmercial) or $13 blocks (industrial) for LG&E/KU to purchase Green Tags from qualified renewable resources (hydro, landfill gas, or wind) in KY and surrounding states. Responsive Pricing & Smart Metering Pilot Program This program combines the use of Smart Meters, Programmable Thermostats, Energy Use Displays, and a Time of Use Rate (with critical peak component) to provide customers greater control of their energy usage--and thus their energy bill. Carbon Footprint on the Bill Beginning July 2007, LG&E and KU are placing on

customer bills the amount of carbon dioxide emissions associated with their consumption, coupled with monthly tips on what ac tions they can take to reduce the effects of those emissions. This is to help give customers greater awar eness of and control over the impact of their energy usage. Hybrid Vehicle Addition to Company Fleet Beginning in July 2007, LG&E and KU began to add hybrid electric Ford Escape vehicles to the Company fleet; further additions will be subject to on-going economic analysis.

Proposed Programs

Program / Offering / Activity Comment

Brownfield Tariff Filed with the Kentucky PSC on 5/10/07. This tariff provides an incentive to commercial/industrial

customers to locate facilities at sites for which

distribution infrastructure already exists but for which some environmental mitigation may be required. Under review by the KPSC at this time.
Real-Time Pricing Pilot Program Filed w ith Kentucky PSC on 4/21/07. This program permits participating industrial customers to receive a real-time hourly price signa l, to provide them the opportunity to modify consum ption and control costs. Under review by the KPSC at this time.

Energy Efficiency Program Filing: New Programs Filed with the Kentucky PSC on 07/19/07 for the 2008 – 2014 time period. Under review by the KPSC

at this time.

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### Fine Particle Air Quality Task Force Report and Plan of Action

Efficient Lighting Program Working with manufacturer s and retailers, this program would provide incen tives to put significant numbers of Compact Fluorescent Light ("CFL")

bulbs into the residential market. Promotion of other forms of efficient lighting is included. Several million CFLs are contemplated over the first few

years. HVAC Diagnostics/ Tune-Up The program would offer cen tral air conditioning or heat pump diagnostics at a subsidized cost. Customers needing remediat ion could choose to have an “approved” dealer make repairs at a reduced cost.The program would focus on over- or underrefrigerant charge and air flow restrictions. This program would be availa ble to residential and

commercial customers.

Residential New

Construction

Certification The Company would encourage builders to develop

homes that meet the Ener gy Star standards. Homes would have to pass plan re views as well as on-site inspections to ensure compliance.

Dealer Referral Network This program w ould provide customers with a list of energy efficiency dealers who had agreed to meet certain minimum standards, such as insurance and bonding, but would also agree to perform the service according to manufacturer and industry standards and requirements. Energy Efficiency

Education & Promotion This program would educat e the public about energy efficiency. This includes a program for students, about sources of energy and energy efficiency in homes and schools through a curriculum provided to

schools in the service terr itory. Teacher workshops are anticipated. The curriculum includes lesson plans, energy efficiency materials, and demonstration

materials. Program Development

and Administration This program would allow LG&E/KU to invest in energy efficiency program design that is not easily assigned to an individua l program noted above, including research—e.g. new technologies for metering, control systems, appliances & home electronics, etc., as appropriate.

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Jefferson County Public Schools Recent, Current and Future Energy Efficiency ProjectsNew School projectRenovation ProjectOccupancy sensors cycling HVACOccupancy sensors cycling lightsDirect Digital Control building automationhot/cold AHU recovery wheelsNew high efficient chillersNew high efficient boilersLighting replacementsNew windowsVariable frequency drive motorsSolar domestic hot waterDaylight harvesting ballast controlsShelf lightingRoof replacementsEnergy Star AwardDishwasher removal (Kitchen)Pot Scrubbers (Kitchen)Trash Compactors (Kitchen)Pulpers (Kitchen)

Conway Middle 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Hartstern Elementary 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Klondike Elementary 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Luhr Elementary 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Pleasure Ridge Park Tech 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Ramsey Middle 2008 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Ahrens/Brown 2007/08 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Barrett Middle 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Breckinridge Metro 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Farmer Elementary 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Myers Middle 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Price Elementary 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Johnsontown Road El 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Iroquois High 2007 ☻ 1994 ☻ ☻ ☻ ☻

Stopher Elementary 2007 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Auburndale Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Churchill Park 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Gutermuth Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Highland Middle 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Watterson Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Wheeler Elementary 2006 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

Shelby Elementary 2004 ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻ ☻

All 170 JCPS buildings Gas and Electric Usage/Cost are recor ded and compiled into several reports by Energy Watchdog. All 170 JCPS buildings Gas, Electric, Water, Sewage, and Drainage Usage/Cost are recorded and mo nitored by the JCPS Energy Audi tor.

JCPS has over 1000 buses that travel a combined 85,000 miles a day. All JC PS diesel powered engines are using a bio-diesel blen d. JCPS is open to alternative fu els as they are made available. JCPS hopes to include Vending machine energy saving devices in the upcoming district wide contract. JCPS replaced lighting in 13 buildings, and windows in 11 buildings as part of a 2001 Energy Performance contract. The Performance contract has guaranteed an annual savi ngs of nearly $400,000.

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Appendix 10 Draft Idle Reduction Regulation

(a) Purpose: The purpose of this law is to protec t public health and the environment by reducing emissions while conservi ng fuel and maintaining adequa te rest and safety of all

drivers of diesel vehicles.

(b) Applicability: This law applies to commercial dies el vehicles whic h are designed to operate on highways (as defined under 49 CFR 390.5), and to locations where

commercial diesel vehicles load or unload (hereinafter referred to as “load/unload locations”).

(c) General Requirement for Load/Unload Locations: No load/unload location owner shall cause vehicles covered by th is rule to idle for a period greater than 30 minutes while waiting to load or unload at a location under their control.

(d) General Requirement for Vehicles: No owner or operator of a vehicle shall cause or permit vehicles covered by this rule to idle for more than 5 minutes in any 60 minute period except as noted in sections (e) and (f), and except as provided in section (c) in the

case of a load/unload location.

(e) Exemptions: Section (d) does not apply for the period or periods where:

(1) A vehicle idles while forced to remain motionless because of on-highway traffic, an official traffic control device or signal, or at the direction of a law enforcement

official.

(2) A vehicle idles when operating defrosters , heaters, air conditioners, or installing other equipment solely to prevent a safety or health emergency, and not as part of a rest period.

(3) A police, fire, ambulance, public sa fety, military, other emergency or law enforcement vehicle, or any vehicle bei ng used in an emergency capacity, idles while in an emergency or training m ode and not for the convenience of the vehicle operator.

(4) The primary propulsion engine idles fo r maintenance, servicing, repairing, or diagnostic purposes if idling is necessary for such activity.

(5) A vehicle idles as part of a state or fe deral inspection to verify that all equipment is in good working order, provided idling is required as part of the inspection.

(6) Idling of the primary propulsion engine is necessary to power work-related mechanical or electrical operations other than propulsion (e.g., mixing or processing cargo or straight truck refrig eration). This exemption does not apply when idling for cabin comfort or to op erate non-essential on-board equipment.

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(7) An armored vehicle idles when a person remains inside the vehicle to guard the contents, or while the vehicle is being loaded or unloaded.

(f) Conditional Exemptions: Subsection (d) does not apply for the period or periods

where:

(1) A passenger bus idles a maximum of 15 minutes in any 60 minute period to maintain passenger comfort while no n-driver passengers are onboard. The exemption expires 5 years after implemen ting a state financial assistance program

for idle reduction techno logies or strategies.

(2) An occupied vehicle with a sleeper be rth compartment idles for purposes of air conditioning or heating during rest or sleep period, until 5 years after implementing a state financial assistance pr ogram for idle reduction technologies or strategies, whereupon this exemption expires.

(3) An occupied vehicle idles for purposes of air conditioning or heating while waiting to load or unload, until 5 years after implementing a state financial assistance program for idle reduction t echnologies or strategies, whereupon this exemption expires.

(4) A vehicle idles due to mechanical difficulties over which the driver has no control; provided that the vehicle owner submits the repair paperwork or product receipt (by mail; within 30 days) to the a ppropriate authority verifying that the mechanical problem has been fixed.

(g) Auxiliary Power Units

(1) Generally, operating an auxiliary power un it or generator set as a means to heat, air condition, or provide el ectrical power as an alternative to idling the main engine is not an idling engine, per se.

(2) Operating an auxiliary power unit or ge nerator set on all model year 2006 or older

commercial diesel vehicles is allowed. [Reserved for possible inclusion of criteria for APU use on 2007 and subsequent model year commercial vehicles]

(h) Penalties: The owner and/or operator of a vehicl e, and/or the owner of a load/unload location, that is in violation of this la w is responsible for penalties as follows.

(1) First offense: Warning ticket issued to vehicle driver and owner, and where applicable, the load/unload facility owner.

(2) Second and subsequent offenses: $150 cita tion is issued to the vehicle driver; and/or, $500 citation issued to the registered vehi cle owner or load/unload

location owner.

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Appendix 11 Report and Plan of Action Committee Leading

Recommendations

The following recommendations include strategi es that should be given priority for implementation. These recommendations repr esent a diverse group of strategies addressing the full breadth of issues consider ed by the Task Force and its committees. It should be noted that the following eight recomme ndations were selected from the full list of 63 recommendations which are presente d, without exclusion, in Sections 9.2 and 9.3

below.

Leading Recommendation 1: Building upon the Clean Air Act (CAA) prin ciple that ambient concentrations of

PM 2.5 should be reduced to levels suffici ent to protect public health with an adequate margin of safety, reductions below the federal primary annual standard of 15 μg/m 3 are advisable to provide an additiona l margin of safety that allows and compensates for scientific uncertainty, including the potential health impacts on sensitive populations. To achieve thes e reductions, the District should establish an ongoing and continuous process of review of all sources of PM 2.5 emissions (including onroad and nonroad mobile sources, area sources, stationary sources, etc.) and develop and implement policies, practices and standards to continue progress towards reducing ambient concentrations of PM 2.5 and precursors. In the development of su ch policies, practices and standards,

stakeholder involvement should be an integral part of the process. Those strategies that achieve lower emissions of hazard ous air pollutants (HAPs) and ozone precursors in conjunction with reducing PM 2.5 should be a priority and a strong emphasis should be placed on educational programs for the public.

Leading Recommendation 2:

The District should create a diverse sta keholder advisory committee to continue to focus and advise the Board on issues of air pollution, public health and environmental justice related to PM 2.5 and to strategize on policies, practices and programs to reduce PM 2.5 ambient concentrations, as outlined in Leading

Recommendation 1.

Leading Recommendation 3: As a part of the ongoing process, a sta keholder group should be convened in 2010 to review peer-reviewed health literat ure, ambient monito ring data and modeling results to determine whether interim numeric goals are advisable to achieve continued progress towards reducing ambient PM 2.5 concentrations sufficient to protect public health with an adequate marg in of safety. Six months prior to convening the 2010 review, committees responsible for synthesizing data shall be convened to have sufficie nt time to collect, analyz e and synthesize needed information.

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Leading Recommendation 4: The District should work with the states of Kentucky and Indiana to pursue and develop strategies to reduce the PM 2.5 precursor emissions from major regional sources within a range of 150 miles to achieve additional reduction of ambient

PM 2.5 concentrations to protect public health.

Leading Recommendation 5:

The District should work with public and private fl eet owners operating in Louisville Metro through education, incenti ves and grants to aggressively retrofit or replace both onroad and nonroad diesel fl eets with state-of-the-art technology

that reduces emissions.

Leading Recommendation 6: The District should cooperate with local and regional planning agencies to quantify the difference between emissions budgets that re sult from business-asusual and alternative growth scenarios using comparison guidelines provided by

EPA.

Leading Recommendation 7:

The District should initiate a stakehol der process for loca l adoption of onroad and nonroad idling regulations, with the proposed Draft Idle Reduction Regulation (included as Appendix 10) us ed as a starting point for discussion.

Leading Recommendation 8: Counties and municipalities within the Louisville nonattainment area should enact local ordinances to prohibit open burning. To the extent it is allowed, open burning should be restricted on days when PM 2.5 concentrations are forecasted to be unhealthy for sensitive populations.

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