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Additionally, there are no monitors in the adjacent counties that violated the annual

PM2.5 standard. However, the absence of a violating monitor does not automatically

disqualify a county from a PM2.5 nonattainment designation.

Connecticut recommended that the entire state be designated as attainment based on an

argument that the violating monitor is a “hot spot” (letter from CT DEP to EPA, February

10, 2004). As an alternative, if EPA does not accept the “hot spot” analysis, CT

recommended a nonattainment designation for a limited geographic area, such as the City

of New Haven or New Haven County. In addition, CT recommended that all CT

counties should be excluded from the nonattainment area associated with the New YorkNorthern New Jersey-Long Island, NY-NJ-CT-PA CMSA based on an argument that
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6.8 Region 8 Nonattainment Areas

6.8.1 EPA 9-Factor Analyses for Montana for the Designation of PM2.5

Nonattainment Areas

Based on air quality data for 2001-2003, the PM2.5 monitor at the Libby Courthouse

Annex is violating the annual PM2.5 standard. EPA utilized the 9 factors identified in

the April 1, 2003 “Designations for the Fine Particle National Ambient Air Quality

Standards” guidance to evaluate whether the surrounding rural counties around Lincoln,

MT should be included as part of the nonattainment area. However, due to the

topographical features and local meteorology within Lincoln County and more

specifically around the Libby, Montana vicinity, several of the 9 factors were not

significant for this particular nonattainment area when looking at adjacent counties to

Lincoln County, MT. Lincoln County is considered a rural county, according to EPA’s

April 1, 2003 “Designations for the Fine Particle National Ambient Air Quality

Standards” which defines a rural area as counties or areas not included in or adjacent to

urban areas (metropolitan statistical areas (MSA). The adjacent areas to Lincoln County

are the Canadian border to the North, Boundary and Bonner County, Idaho to the West,

Sanders County, MT to the South, and Flathead County, MT to the East. Lincoln County

contains a violating monitor located in the town of Libby. The Lincoln County PM2.5

nonattainment issue is unique in that the area of impact is localized within and around the

vicinity of the town of Libby due to topographical features and meteorology in the area

impacted by emissions.

Montana’s recommendation identifying the PM2.5 nonattainment area included part of

Lincoln County (the town of Libby and vicinity). EPA initially responded to Montana’s

recommendation stating that EPA agreed with Montana’s recommended nonattainment

designation for Lincoln County but that EPA intended to modify Montana’s

recommended boundary for the nonattainment area to cover all of Lincoln County.

However, based upon supplemental information provided by Montana, EPA is

identifying the boundary of this PM2.5 nonattainment area to include a part of Lincoln

County as described further below.

The following is a brief summary of the 9 factor criteria for the Lincoln County, MT area

and surrounding counties. These analyses were based on existing available data. The

counties recommended as nonattainment are in bold.

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

nonattainment area

For this factor, EPA looked at SO2, NOx, carbon and crustal PM2.5 emissions. A

weighted emissions score was applied to Lincoln County and the adjacent counties

reflecting the speciation profile of Lincoln County versus the adjacent counties. Counties

adjacent to the Lincoln County were assigned an emission score as a way to compare the

emissions from those counties against Lincoln County emissions. The following table

has the SO2, NOx, carbon, and crustal PM2.5 emissions and composite emission scores.
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This information is from the 2001 NEI. (The recommended nonattainment area is in

bold.)

County

SO2

(tons)

NOx

(tons)

Carbon

(tons)

Crustal

PM2.5

(tons)

Composite

Emission

Score

Lincoln 257 3286 862 275 100

Flathead 1919 6651 1788 1904 257

Bonner 313 5324 1411 730 159.5

Boundary 114 1886 1431 760 134.4

Sanders 328 4543 605 151 88.2

Since Lincoln County is considered to be a rural county as defined in EPA’s April 1,

2003 PM2.5 Designations Guidance and not a metropolitan statistical area, this factor did

not play a significant role in the decision making process. Also, due to the topographical

features and meteorology in Lincoln County (see factors 6 and 7 below) and more

specifically surrounding Libby, MT where the PM2.5 problem is, EPA feels the

surrounding counties emissions are not impacting the PM2.5 monitor located at the Libby

Courthouse Annex.

Factor 2: Air quality in potentially included versus excluded areas

County

PM2.5 2001-2003

design value

Lincoln 16.2*

Flathead 9.1

Bonner 8.0

Boundary 8.2

Sanders 6.2

* Lincoln County PM2.5 monitor is located at the Libby Courthouse Annex, Libby, MT.

All adjacent counties to Lincoln, MT are attaining the PM2.5 standard. This factor

played a significant role in the decision making process.
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Factor 3: Population density and degree of urbanization including commercial

development in included versus excluded areas

The following table has the population and population density for Lincoln County and the

adjacent counties.

County 2002 Population 2002 Population Density (pop.

per square mile)

Lincoln 18,665* 5**

Flathead 77,240 15

Bonner 38,205 22

Boundary 10,085 8

Sanders 10,367 4

* Town of Libby, MT population: 2,626;

** Town of Libby, MT population density: 2,020 persons/square mile

The town of Libby, where the PM2.5 problem is located has a much higher population

density than the remainder of Lincoln County or any of the surrounding counties. Also,

due to the commuting patterns, topographical features and meteorology in Lincoln

County (see factors 4, 6 and 7 below), EPA feels the adjacent county populations do not

impact the PM2.5 monitor located at the Libby Courthouse Annex. This factor played a

significant role in the decision making process.

Factor 4: Traffic and commuting patterns

Commuting Information:

Lincoln County, the design value county, has a total of 6,721 commuters.

- Commuters who remain in Lincoln County: 6,177

Flathead County, an adjacent county, has a total of 34,035 commuters.

- Commuters from Flathead County to Lincoln County: 85

- Commuters that remain in Flathead County: 32,956

Bonner County, an adjacent county, has a total of 15,570 commuters.

- Commuters from Bonner County to Lincoln County: 0

- Commuters that remain in Bonner County: 12,968

Boundary County, an adjacent county, has a total of 3,830 commuters.

- Commuters from Boundary County to Lincoln County: 10

- Commuters that remain in Boundary County: 3,310

Sanders County, an adjacent county, has a total of 3,903 commuters.

- Commuters from Sanders County to Lincoln County: 12
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- Commuters that remain in Sanders County: 3,337

The following table has the vehicle miles traveled (thousand miles) for Lincoln County

and the adjacent counties.

County VMT

Lincoln 231

Flathead 756

Bonner 442

Boundary 139

Sanders 93

Based on the analysis for this factor there are no adjacent counties impacting the PM2.5

monitor located at the Libby Courthouse Annex. This factor played a significant role in

the decision making process.

Factor 5: Expected growth

The following table has the population and population growth figures for Lincoln County

and the adjacent counties. (Nonattainment counties are in bold.)

County

2002

Population

Population

Density

Area

(sq. mile)

Growth

(90-00)

% Change

(90-00)

Lincoln 18665 5 3613 1356 8

Flathead 77240 15 5099 15253 26

Bonner 38205 22 1738 10213 38

Boundary 10085 8 1269 1539 18

Sanders 10367 4 2762 1558 18

Based on the analysis for this factor, there is no significant growth, on either an absolute

or a percentage basis, to indicate a contribution to the air quality in Lincoln County. This

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

Factor 6: Meteorology

Libby Montana is located in the northwestern part of the state in a narrow north-south

oriented valley. The ridgetops surrounding Libby are approximately 4,000 feet higher
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than the town. There are no other towns or large emissions sources immediately upwind,

so transport of high background concentrations into Libby is considered unlikely. The

highest PM2.5 concentrations in Libby generally occur during the months of November

through February. During the summer months concentrations typically average less than

half the level of the annual PM2.5 NAAQS, while winter concentrations may double the

NAAQS. The much higher concentrations in winter are related to stagnant weather

conditions dominated by light winds and strong temperature inversions. These

meteorological conditions may trap emissions within the valley for many days. No recent

meteorological data is available for Libby, however, data from Kalispell, MT show calm

wind conditions occur 35 percent of the time in the winter months and only 15 percent of

the time in the spring and summer. Vertical temperature soundings at Great Falls in

Western MT also show a very high frequency of surface temperature inversions in the

winter.

Due to the meteorology conditions in the town and surrounding vicinity of Libby and due

to the topographical features within Lincoln County and more specifically around Libby

(see factor 7 below), that create stagnant weather conditions, EPA feels the adjacent

counties do not impact the PM2.5 monitor located at the Libby Courthouse Annex and

that the nonattainment problem is a localized PM2.5 problem.

Prevailing Wind Directions (%)

County NW SW SE NE

Lincoln 14 37 22 26

Flathead 21 34 22 24

Bonner 14 42 20 24

Boundary 12 40 22 27

Sanders 26 28 24 22

This factor played a significant role in the decision making process.

Factor 7: Geography/topography

Lincoln County, MT

Lincoln County has a land area of 3,675 square miles. The area of concern showing high

PM2.5 concentrations is located within and around the Libby, Montana vicinity. Lincoln

County has numerous geographical or topographical boundaries limiting its airshed to a

very narrow valley including the surrounding vicinity of Libby. The town of Libby has a

total area of 1.3 miles. As of the 2000 census, there are 2,626 people, 1,132 households,

and 669 families residing in the city. The elevation for the town of Libby is 2,601 feet.

The ridgetops surrounding Libby are approximately 4,000 feet higher than the town. The

town sits in a narrow valley that runs in a north-south direction (48°23'17" North,
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115°33'13" West). The Kootenai River runs adjacent to the town in an east-west

direction. The Kootenai Basin is largely mountainous and dominated by three major

ranges. The Rocky Mountain Range and the Flathead Range constitute the eastern

boundary; the Purcell Range roughly bisects it from north to south. The Selkirk and

Cabinet Ranges mark the western boundary. Elevations reach a maximum of about

12,000 feet with most summit elevations between 6,000 and 7,500 feet. Except for a few

areas, the entire watershed is heavily forested (practically all of Lincoln County and a

large portion of the surrounding counties consists of National Forest land). The Kootenai

River has its origins in British Columbia's Kootenay National Park in Canada. From

there it flows 485 miles into northwest Montana and through the towns of Libby and

Troy. From there it flows into northern Idaho, then back into Canada and Kootenay

Lake. Ultimately it joins with the Columbia River. Sixteen miles north of Libby, the

river is held back by Libby Dam, creating a 90-mile long reservoir that reaches into

Canada. The river drops less than 1,000 feet (305 meters) in elevation from Canal Flats

to Kootenay Lake, a distance of over 300 miles (480 km). However, even along the

river’s slow meandering course, valley-bottom widths are generally less than two miles

and are characterized by tree-covered rolling hills with few grassland openings.

Due to the topographical features and meteorological data (see factor 6 above) within and

surrounding the vicinity of Libby resulting in stagnant weather conditions trapping

emissions in the valley, EPA feels the adjacent counties do not impact the PM2.5 monitor

located at the Libby Courthouse Annex. Emissions from adjacent counties would have to

traverse one or more major mountain ranges, in some cases against the prevailing wind

direction, in order to impact the town of Libby.

This factor played a significant role in the decision making process.

Factor 8: Jurisdictional boundaries

No areas in Montana or Idaho were designated nonattainment for the 8-hour ozone

standard on April 15, 2004.

The town of Libby and vicinity within Lincoln County are designated nonattainment for

PM10.

Due to the fact that the town and surrounding vicinity of Libby, Montana was designated

nonattainment for PM10 and did not include the surrounding counties around Lincoln,

MT, EPA believes this factor plays a significant role in the decision making process.

Factor 9: Level of control of emission sources

The following are sources located in Lincoln County, MT but are not considered major

PSD sources.

- Plum Creek Northwest Lumber, Inc. (Ksandka Sawmill), Fortine, MT

- Eureka Pellet Mills, Eureka, MT
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- Genesis Inc. (Troy Mine), Troy, MT

- Lone Pine Timber Industries, Eureka, MT

- Stimson Lumber Mill, Libby, MT (closed - Spring, 2003)

Due to the topographical features and meteorology in Lincoln County (see factors 6 and 7

below) and more specifically surrounding Libby, MT where the PM2.5 problem is

located, EPA believes this factor does not play a significant role in the decision making

process.

6.8.2 Justifications for Changes to EPA Recommendations Contained

in the June 29, 2004 Letters to States

Background: In a letter dated February 25, 2004, the Governor of Montana submitted to

EPA a letter recommending that the PM2.5 nonattainment boundary for Lincoln County,

MT be designated as a partial county. The Governor’s letter did not provide a specific

justification for a partial county recommendation or identify what the partial county

boundaries would be for Lincoln County. On June 29, 2004, EPA responded to

Montana’s recommendation stating that EPA agreed with Montana’s recommended

nonattainment designation for Lincoln County but that EPA intended to modify

Montana’s recommended boundary for the nonattainment area and designate the entire

Lincoln County area as nonattainment for the PM2.5 national ambient air quality

standards.1 In two follow-up letters from Montana dated June 25, 2004 and September 7,

2004, Montana identified specific PM2.5 nonattainment boundaries for Libby, MT along

with a technical justification for the less-than-county request.

EPA’s Recommended Change: Based upon EPA’s review of Montana’s letters dated

June 25, 2004 and September 7, 2004 and subsequent discussions EPA has had with the

Montana Department of Environmental Quality (MT DEQ), EPA is modifying our

original recommendation and identifying the PM2.5 nonattainment boundary area as

follows: 600,000mE, 5,370,000mN east to 620,000mE, 5,370,000mN south to

620,000mE, 5,340,000mN west to 600,000mE, 5,340,000mN north to 600,000mE,

5,370,000mN as identified in Montana’s September 7, 2004 letter. EPA believes these

boundaries are reasonable for the following reasons:

 1

 EPA’s April 1, 2003 “Designations for the Fine Particle National Ambient Air Quality Standards” which

states: “When a rural monitor violates the standard, EPA intends to apply a presumption that the

nonattainment area shall include the full county in which the monitor is located. EPA will consider

recommendations to adjust rural area nonattainment boundaries based on the same factors as it applies to

urban areas, as discussed in question 5 above. Using these factors, a State or Tribe that recommends that a

smaller area should be designated nonattainment should provide convincing evidence that the monitor is

not representative of the full county, that the excluded portions of the county are not source areas

contributing to the nonattainment, and that the excluded portions of the county are meeting the standard.

Similarly, a State or Tribe may recommend that a larger area be designated nonattainment based on

technical information relevant to these factors. Nevertheless, as discussed above, if nonattainment is

demonstrably very localized and is attributable to localized sources, EPA intends to establish nonattainment

area boundaries based on a case-specific evaluation of the nature and extent of the problem.”
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1. As stated under factors 6 and 7 of EPA’s factor analysis for Lincoln County,

meteorology and geographical/topographical features within and surrounding the

town of Libby played a significant role in the decision making process and in

EPA’s consideration to modify the nonattainment boundary to only include the

town of Libby and surrounding vicinity. (See Factors 6 and 7 for more details.)

2. The MT DEQ conducted a winter monitoring study in the Libby, Montana area

from November 2003 through March 2004. This information was submitted to

EPA in MT DEQ’s June 25, 2004 PM2.5 nonattainment boundary area

recommendation for the town of Libby. The monitoring study showed that within

the “T” shape basin where Libby Creek flows into the Kootenai River, significant

drops in PM2.5 occur along the northwestern edge of the Libby valley as well as

the northeastern edge of the valley. Wind speed results showed that there is very

little wind in the Libby area during winter confirming that much higher

concentrations in winter are related to stagnant weather conditions dominated by

light winds and strong temperature inversions. As a result, meteorological

conditions may trap emissions within the valley for many days. In MT DEQ’s

June 25, 2004 recommendation, MT DEQ acknowledged in the boundary analysis

that while monitoring was not conducted further south than 3 miles from the

town’s center, MT DEQ was confident that the boundary that they recommended

in their June 25 letter adequately surrounds the source area for the Libby PM2.5

nonattainment area. EPA disagreed with MT DEQ’s southern boundary

recommendation and in further discussions with MT DEQ, came to an agreement

to extend the southern boundary area to include an additional 20,000 meter UTM

Grids beyond what was recommended in MT DEQ’s June 25, 2004

recommendation. This new boundary agreement is reflected in MT DEQ’s letter

dated September 7, 2004.

Due to the geographical/topographical features and meteorological data within and

surrounding the vicinity of Libby and the study performed by MT DEQ, EPA feels the

surrounding Lincoln County area outside the recommended boundary area does not

impact the PM2.5 monitor located at the Libby Courthouse Annex. Emissions from the

surrounding area within Lincoln County would have to traverse one or more major

mountain ranges, in some cases against the prevailing wind direction, in order to impact

the town of Libby.