Appendix R 

Statement of Consideration 
1

STATEMENT OF CONSIDERATION 

RELATING TO SIP REVISION FOR THE KENTUCKY FINE PARTICULATE 

MATTER (PM2.5) ATTAINMENT DEMONSTRATION FOR THE KENTUCKY 

PORTION OF THE LOUISVILLE, KY-IN, CINCINNATI-MIDDLETOWN, OH-KY-IN, 

AND HUNTINGTON-ASHLAND, WV-KY-OH AREAS 

Amended After Comments 

Energy and Environmental Cabinet 

Department for Environmental Protection 

Division for Air Quality 

(1) The Kentucky Energy and Environment Cabinet conducted a public hearing on August 

13, 2008, at 1:30 p.m. (EDT) in the Conference Room of the Kentucky Division for Air 

Quality, 803 Schenkel Lane, Frankfort, Kentucky. This hearing is was held to receive 

comments on a proposed attainment demonstration for the Kentucky portion of the 

Louisville KY-IN, Cincinnati-Middletown OH-KY-IN, and Huntington-Ashland WVKY-OH PM2.5 Nonattainment Area. Written comments were received during the public 

comment period. 

(2) The following individuals attended and/or provided written comments: 

Name and Title Organization

 Jimmy Keeton Kentucky Power Co. 

Gary Revlett EON –US 

Jon Trout Lou-Metro APCD 

Lauren Anderson Lou-Metro APCD 

 

(3) The following individuals from the Kentucky Environmental and Public Protection 

Cabinet attended or responded to the comments: 

 John Gowins, Environmental Control Supervisor Division for Air Quality 

Shea Hogan, Environmental Technologist I* Division for Air Quality 

 Martin Luther, Division for Air Quality 

 Ty Martin, Environmental Technologist I Division for Air Quality 

 Susan Weaver, Environmental Technologist III Division for Air Quality 

 * Agency moderator 
2

Response to Comments on the proposed attainment demonstration for the Kentucky 

portion of the Northern Kentucky, Louisville, and Ashland areas as attainment for the 

National Ambient Air Quality Standard (NAAQS) for annual PM2.5

1. (a) Comment: The Court vacated the CAIR and its associated Federal Implementation Plan 

in their entirety. Pending the appeals process and until the courts mandate issues, EPA 

will not take any action on submitted SIPs. Therefore, EPA encourages you to examine 

options your state has to provide the required emissions reductions should the CAIR be 

officially vacated. 

Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet acknowledges this comment and is encouraged by the recent 

September 2008 petition filed by EPA, environmental groups, and industry organizations 

before the U.S. Court of Appeals for the D.C. Circuit seeking a rehearing of the court 

decision that vacated CAIR. Kentucky’s NOx SIP Call regulations are still in effect and 

can be utilized to maintain NOx reductions in the ozone season. 

2. (a) Comment: The State Implementation Plan (SIP) Narrative could document the specific 

controls, emission units, emission rates and reductions used in the modeling for the states 

in the multistate nonattainment areas (NAAs), not just for the Kentucky portion of the 

NAAs. 

Richard Schutt, USEPA, Region 4

 (b) Response: The Cabinet references, in Appendix O, the individual submittals for other 

states in the three nonattainment areas. 

3. (a) Comment: The SIP Narrative should document the likelihood of the NAA states’ CAIRrelated controls actually being implemented to achieve attainment and the mechanism 

that make the emission rates and operation of controls federally enforceable. 

Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet is encouraged by the recent September 2008 petition filed by 

EPA, environmental groups, and industry organizations before the U.S. Court of Appeals 

for the D.C. Circuit seeking a rehearing of the court decision that vacated CAIR. 

Expanded discussion regarding CAIR controls was added to Section 5.1.6. 

4. (a) Comment: Documentation of controls relied upon from upwind states and proposed to 

be subject to CAIR is recommended. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet listed and expanded, in Section 5, the federal control measures 

(e.g fuels and engines, MACTs, consent decrees), in addition to CAIR, relied upon by all 

states for reductions to particulates and precursors to fine particulates. As well, Section 5 

includes the open burning and fugitive dust emission regulations for the state and the local 

agency. 
3

5. (a) Comment: Any sensitivity modeling that documents the impact of CAIR-related controls 

in the formation of PM2.5 is recommended. And sensitivity analyses, if available, is 

recommended to document the improvement in PM2.5 formation and air quality, as 

expected from controls implemented in 2008 and 2009. 

Richard Schutt, USEPA, Region 4

 (b) Response: The Cabinet has added to the narrative a discussion provided by the 

contractor regarding CAIR controls and implications of CAIR vacatur based on available 

emissions sensitivity modeling. See the revised Section 5.1.6. 

6. (a) Comment: The Kentucky (VISTAS-ASIP) based modeling does not indicate attainment 

for the Cincinnati NAA. This modeling predicts a 15.4 ug/m3 design value for the 

nonattainment area. The Louisville and Huntington-Ashland nonattainment areas have 

design values of 14.9 ug/m3 and 14.8 ug/m3, respectively. All three areas require 

additional weight of evidence to support a control strategy of attainment. 

Richard Schutt, USEPA, Region 4

 (b) Response: Analysis has been added to the narrative to further substantiate the Cabinet’s 

position that the area will attain the standard. 

7. (a) Comment: Modeling results appear to contradict each other. The VISTAS-ASIP 

modeling predicts nonattainment in 2009 for the Cincinnati NAA and close to 

nonattainment for the Louisville and Huntington-Ashland areas. While the CMAQ 

modeling predicts attainment for Cincinnati and Huntington by 2010 and nonattainment 

for Louisville in 2010 and 2015. 

Richard Schutt, USEPA, Region 4 

(b) Response: The weight of evidence relies on the Lake Michigan Air Director Consortium 

(LADCO) modeling which predicts attainment for all three areas in 2009. 

8. (a) Comment: Contradicting results of attainment for the three multistate nonattainment 

areas are presented in the MRPO and VISTAS-ASIP modeling. With the contradictory 

modeling results and the uncertainty of expected reductions from CAIR, it is difficult to 

 determine how to assess the State’s conclusion for attainment for the three areas, or 

whether or not an extension of the attainment date is needed. 

 Richard Schutt, USEPA, Region 4

 

 (b) Response: The Cabinet’s position is that the LADCO modeling shows attainment in 

2009. See Section 6.3.2. The contradictory results are due to two separate base years 

used in the MRPO-LADCO modeling and the VISTAS-ASIP modeling. The VISTASASIP modeling relied on 2002 base year emissions. The MRPO-LADCO modeling 

relied on the more recent 2005 base year emissions. Overall the MRPO-LADCO 

modeling included more recent ambient data to predict future year design values. 

Additionally, LADCO used the CAMX model, and VISTAS used the CMAQ model. 

Areas that show nonattainment using the older base year also show attainment using the 
4

more recent updated data. 

9. (a) Comment: Air quality data (e.g. design value trends) are recommended to be included in 

the SIP for the Ohio, Indiana, and West Virginia monitors in the NAAs. Recommended 

as well is the addition of expanded discussion on emission trends analysis and especially 

reduction expected in the 2008-2009 period. 

Richard Schutt, USEPA, Region 4

(b) Response: The ambient air data for monitors in Ohio, Indiana, and Kentucky has been 

included in Section 6.3.3. 

10. (a) Comment: The NOx SIP Call was cited as a source of emission reductions for the 

controls modeled for attainment in 2009 for the three multistate NAAs. At a minimum, 

EPA recommends that the SIP reference the citations for the enforcement of this program 

in KY. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet has inserted into Section 5.2.1, the citation providing the legal 

authority for the enforcement of the NOx SIP Call program. The statutory authority to 

adopt and implement programs, and for promulgation of regulation, is granted to the 

Kentucky Energy and Environmental Cabinet by KRS 224.10-100 Powers and duties of 

cabinet found at www.lrc.ky.gov/KRS/224-10/100.PDF 

 

11. (a) Comment: Modeling results for the non-Kentucky monitors in the three PM2.5 NAAs 

need to be included in the documentation in the SIP Narrative, and Appendices C and L.

Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet added modeling results for the non-Kentucky monitors to Table 

6.3.2-2 in the SIP narrative. Appendix C contains the AQS ambient data for the 

nonattainment areas. Appendix L is the Attainment Test data for Kentucky. Appendix O 

will reference the Attainment Test narratives for the other states as available. 

 

12. (a) Comment: Modeled Attainment Software (MATS) incorporates updated procedures and 

information since the tool is used in the CAIR modeling. EPA recommends the State use 

the MATS tool in addressing the PM2.5 test. 

Richard Schutt, USEPA, Region 4

(b) Response: ENVIRON has now provided 2009 Best and Final results using MATS tool. 

The file is posted on the ENVIRON ftp site at ftp://ftp.environ.org/pub/webaccess/ASIP. 

The file name is VISTAS_PM12km_02gt2_09_12_18gt4_MATS2.01. The ASIP 

contractor provided the KY, IN, OH, and WV data spreadsheets now included in 

Appendix L. As well in Appendix L, there are unmonitored area maps for each of the 

three nonattainment areas to provide visual illustration of the MATS projections. The 

MATS tool predicts all KY sites will be below 14.5 in 2009. 
5

13. (a) Comment: The Executive Summary needs to provide supplemental weight of evidence 

analyses to explain why high 2009 model-predicted design values from Kentucky and 

Ohio monitors ranging from 14.8 to 15.6 are reflective of a control strategy that will 

achieve attainment in 2009. 

Richard Schutt, USEPA, Region 4

(b) Response: Control strategies are discussed in Section 5.0 with expanded discussion of 

CAIR and the boiler/process heater MACT. 

 

14. (a) Comment: With the vacatur of CAIR, it is unclear how the SIP could rely now on the 

assumption that CAIR equals RACT and not address all required PM2.5 precursor 

emissions. 

Richard Schutt, USEPA, Region 4

 (b) Response: The majority of Kentucky’s utilities have controls NOx, SOx and particulate 

matter. Several EGU sources will be adding additional controls in the future per BART 

and consent decrees. Section 5.1.6 was expanded to discuss the vacatur of CAIR. 

15. (a) Comment: EPA recommends including tables in an appendix to present the results of 

the RACT analysis performed by Louisville’s Fine Particle Air Quality Task Force. 

Richard Schutt, USEPA, Region 4

 (b) Response: The RACT analysis by Louisville entitled “Fine Particle Air Quality Task 

Force Report and Plan of Action, January 16, 2008” has been added to Appendix M, 

State and Local Control Measures. 

16. (a) Comment: The Fine Particle Air Quality Task Force studied the four companies 

mentioned on page 52 of the SIP Narrative, and EPA recommends including in the 

narrative the implementation date of the controls, the source reductions expected from the 

controls, and when controls representing RACT will be submitted for review and 

inclusion in the SIP. 

Richard Schutt, USEPA, Region 4

 (b) Response: The RACT analysis by Louisville entitled “Fine Particle Air Quality Task 

Force Report and Plan of Action, January 16, 2008” has been added to Appendix M, 

State and Local Control Measures. 

17. (a) Comment: Section 7.2 on page 52 states that RACM is addressed for certain controls 

in Chapter 5. EPA recommends identifying those measures that are considered RACM in 

Chapter 5 as it is currently unclear which measures the State is considering to be RACM. 

Richard Schutt, USEPA, Region 4

 (b) Response: The Cabinet acknowledges this comment. 

18. (a) Comment: The SIP does not clearly state what pollutants are considered precursor 

pollutants for the attainment demonstration in the SIP. 
6

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet considers NOx and SOx to be precursor pollutants and has 

inserted a statement into Section 2.3. 

19. (a) Comment: The title of Figure 1.3-1 states that the annual PM2.5 nonattainment 

 boundaries for Kentucky are presented. EPA recommends that, for completeness and 

 clarity, the non-Kentucky counties in the three multi-state NAAs are also presented. 

 Richard Schutt, USEPA, Region 4

(b) Response: For clarity the map in Figure 1 of the Executive Summary has been changed 

 to reflect entire nonattainment area counties. However Figure 1.3-1 continues to reflect 

 the associated narrative in Section 1.3.

20. (a) Comment: The end of Section 1.4 states that the conceptual description for the nature 

of the PM2.5 problem in Kentucky is presented in Appendices D and O. Unable to locate 

a conceptual description discussion in Appendix D or O, there is such a discussion in 

Appendix N. 

Richard Schutt, USEPA, Region 4

 (b) Response: The Cabinet edited the narrative to correctly reflect the location of the 

 conceptual description in Appendix N. 

21. (a) Comment: EPA recommends the SIP Narrative include a brief summary of the 

 conceptual description for the three NAAs. 

 Richard Schutt, USEPA, Region 4

(b) Response: Expanded discussion in the narrative is located in Section 1.4.1. The 

Kentucky conceptual description as provided by the VISTA contractor is located in 

Appendix N. Conceptual descriptions for other states in the nonattainment areas are in 

demonstrations developed by those states. 

22. (a) Comment: EPA recommends that the data presented in Figures 2.2-1, 2.2-2, and 

2.2-3 also be provided in tabular format. The inventory data for the non-Kentucky states 

should also be included. The data could be sub-totaled for each state and totaled for the 

entire multistate nonattainment areas. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The data numbers for bar graph Figures 2.2.1, 2.2.2, and 2.2.3 are located 

in Appendix E, where each pollutant and each source category for all nonattainment area 

counties for all states are both totaled and sub-totaled. A statement has been added to the 

narrative to reference the data being located in Appendix E. 

23. (a) Comment: EPA recommends that the units of the emissions presented in Tables 8.2-3 

through 8.2-5 should be added. 

Richard Schutt, USEPA, Region 4
7

(b) Response: The units of the emissions have been added to Tables 8.2-3 through 8.2-5. 

 

24. (a) Comment: EPA recommends section 3.5.1.1 on pages 23-24 provide a reference for the 

documentation of the application and results of the Integrated Planning Model (IPM) to 

develop electrical generating unit (EGU) emissions. We recommend this reference 

provides details on how CAIR was considered in the development of the EGU emissions. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The EGU emissions were developed and documented in Appendix H and I 

 of the “Documentation of the Base G2 and Best & Final 2002 Base Year, 2009 and 

 2018 Emission Inventories” provided by the contractor and included in Appendix F of 

 the SIP entitled “Emission Inventory Documentation”. This reference was added to the 

 narrative in Section 3.5.1.1. 

25. (a) Comment: Model performance for the attainment demonstration was completed in 2004 

with a much earlier version of the 2002 base year inventory than is currently used in the 

modeling. This information should be incorporated into in chapter 4. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet referenced this situation in the second paragraph of Section 4. 

26. (a) Comment: EPA recommends the SIP Narrative contain a summary of the model 

Performance for the three multistate nonattainment areas. Appendix J could still be 

referenced for the full presentation. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet acknowledges this comment. 

27. (a) Comment: EPA recommends including in the SIP narrative a brief summary of controls 

modeled from the non-Kentucky states in the three NAAs and that those modeled control 

reductions are further noted in tons per year for the individual nonattainment areas. 

Additionally, including a discussion of the implementation dates of the controls presented 

in Chapter 5 is recommended. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet acknowledges this comment. 

28. (a) Comment: It is unclear how the NOx SIP Call was modeled in the modeling domain in 

general and in the entire multi-state NAAs in particular. Clarification needs to be 

expanded beyond a description of the program. 

Richcard Schutt, USEPA, Region 4 

(b) Response: Implementation of the NOx SIP Call was projected by Integrated Planning 

 Model (IPM). The MACTEC emissions inventory report describes the IPM methods, 
8

 and in that same report in Table 2.1-5 the EGU NOx emissions by state in 2009. Link 

to MACTEC Emission Inventory report: 

 http://www.vistas-sesarm.org/documents/VISTABF2003-20-2008.pdf 

29. (a) Comment: Table 8.2-2 states that this mobile source emission is for the CincinnatiMiddletown OH-KY-IN area. Since this budget is only for the Kentucky portion of the 

area, please rename the table as such and also in the associated discussion that follows the 

table. 

Richard Schutt, USEPA, Region 4

 (b) Response: The Cabinet renamed Table 8.2-2 to reflect it refers only the Kentucky 

 portion of the NAA and modified the discussion following the table as well. 

30. (a) Comment: The SIP Narrative states that it expects EPA to re-promulgate the industrial 

boiler/process heater/reciprocating internal combustion engines (RICE) MACT by 2018. 

This does not address the state’s reliance reductions modeled from this MACT for 2009 

attainment. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet acknowledges this comment. Additional narrative has been 

provided to address the concerns with the vacating of the boiler MACT. 

31. (a) Comment: The SIP Narrative states that the MACT emissions represented only two 

percent of total PM emissions for Kentucky. EPA recommends the SIP details on how 

reductions from this vacated control program were allocated throughout the three 

nonattainment areas and their associated emissions. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet acknowledges this comment and has provided details that 

show the vacature does not impact the modeling result. The Cabinet removed the 

statement referring to two percent. 

32. (a) Comment: It is unclear how the SIP supports the conclusion that reductions amounting 

to only 2 percent for Kentucky would not affect the modeled results. The SIP should 

show the basis of this conclusion. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet acknowledges this comment. See response to comment 31 

above. 

33. (a) Comment: EPA recommends section 5.1.10 provide more details on the East KY 

Power Cooperative (EKPC) and the American Electric Power (AEP) plants’ PM2.5 

precursor emissions and their expected level of reductions that are subject to either a 

consent decree, best available retrofit technology (BART), or CAIR. We also 
9

recommend adding the implementation date(s) of the control(s) implementation that are 

being relied upon for attainment in a specific nonattainment area (identify the NAA). 

Richard Schutt, USEPA, Region 4

 (b) Response: The Cabinet acknowledges this comment and has revised the discussion in 

Section 5.1.10. 

34. (a) Comment: It is unclear what the phrase “without a permit” means at the bottom of 

page 35 and if this affects the federal enforceability of the consent decree. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet removed this statement. 

35. (a) Comment: Adding the locations of the Spurlock, Dale and Cooper EKPC power 

 plants and the nearest nonattainment area that is impacted by their respective reductions 

 is recommended. 

 Richard Schutt, USEPA, Region 4

 (b) Response: The locations of the power plants have been added to the narrative while 

 noting that the nearest impacted NAA is Huntington-Ashland, WV-KY-OH. Spurlock 

 is located in Mason County, Dale is in Clark County, and Cooper is in Pulaski County. 

36. (a) Comment: The vacatur of CAIR appears to require additional discussion on why CAIR 

is equal to SO2 reasonably available control technology (RACT) and no other PM2.5 

precursors need to be analyzed. 

Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet believes EPA will proceed with a substantive version of the 

 CAIR rule to address the issues of the Court. Therefore the controls implemented to meet 

 CAIR will be federally enforceable. The majority of Kentucky’s utilities have controls 

 NOx, SOx and particulate matter. Several EGU sources will be adding additional 

 controls in the future per BART and consent decrees. 

37. (a) Comment: Source-specific data are recommended for inclusion in the SIP. In addition 

to emission summary totals by counties in the SIP Narrative and Appendix E, EPA 

recommends that specific point source 2002 emissions be presented. Similarly, the area 

source and nonroad mobile source 2002 emissions are recommended to be presented by 

source category for the KY NAA counties. 

Richard Schutt, USEPA, Region 4

(b) Response: The 2002 and 2009 source-specific emissions, by county, by category, and 

 by nonattainment area are summarized in comprehensive tables in Appendix E. 

38. (a) Comment: Appendix L only addresses the application of the speciated monitored 

attainment test for the Kentucky PM2.5 monitors in the three nonattainment areas in all 

but two tables and figures. There is no discussion of the development of data for applying 
10

this test at the Indiana, Ohio and Illinois monitors in the three NAA as applicable to a 

specific nonattainment area. The SIP should document the application of the speciated 

monitored attainment test (SMAT) for each monitor in the entire multistate 

nonattainment area. 

Richard Schutt, USEPA, Region 4

 (b) Response: The ASIP contractor has provided maps illustrating the MATS tool results 

for 2002 for the entire southeast and 2009g4 for the individual nonattainment areas. 

These have been included in Appendix L. 

39. (a) Comment: It is unclear why 2001 was used as the base (“current”) year for the 

attainment demonstration modeling. Section IV.A on page 47. This is particularly 

confusing since 2002 is used in the spatial interpolation field’s discussion of section B on 

pages 35-38. 

Richard Schutt, USEPA, Region 4

(b) Response: This appears to be a typographical error in the draft CAIR SMAT document 

located in Attachment L1, in Appendix L to the Kentucky SIP document. The Cabinet 

has now included MATS projections in the current Kentucky SIP document. 

40. (a) Comment: Speciated profiles from the CAIR SMAT tool were used to speciate the 

FRM monitor data. This was done because EPA’s Model Attainment Test Software 

(MATS) was not available when the KY SIP was being developed. We recommend that 

the State provide the information and/or a reference for the location and documentation 

of the speciation profiles for the three nonattainment areas’ monitors and the CAIR 

SMAT. 

 Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet included the CAIR SMAT Attachment L1, in Appendix L to 

 the Kentucky SIP document. 

41. (a) Comment: Given the status of CAIR and the distribution of a new MATS tool by EPA, 

the state should consider using the EPA tool in their application of the attainment test. 

Many updates have been made in the speciation section of the tool since the CAIR 

SMAT tool. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet acknowledges this comment and added MATS results to the 

 SIP document. 

42. (a) Comment: Attachment L1 provides an in-depth description of the CAIR SMAT 

approach. A discussion of how it was actually used is recommended. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet acknowledges this comment. 
11

43. (a) Comment: Only one of the four metrics listed on Appendix L, page 13 and 

recommended by the EPA modeling guidance was modeled in the supplemental analyses. 

This was the percent improvement in the number of grid cells >= 15 ug/m3. It is unclear 

why Table 3-1 did not show the improvement of grid cell >= 15 ug/m3 instead of 

lumping the grid cells equal to 15 ug/m3 in with those cells less than 15 ug/m3. As 

presented, it appears to show that very little improvement in the reduction of grid cells 

with high concentrations actually resulted in the application of the control strategies for 

the three NAAs. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet acknowledges this comment. Whether the contractor grouped 

15.0 with values greater than or less than 15 does not change the conclusion. There are 

fewer hours greater than 15.0 and more hours less than 15.0. 

44. (a) Comment: Regarding Table 3.2, more information on why the 2010 and 2015 CAIR 

modeling should override the modeling results for the 2009 VISTAS-ASIP modeling is 

recommended. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet acknowledges this comment. CAIR SMAT should not override 

the 2009 ASIP modeling projections. The CAIR SMAT for 2010 and 2015 is provided 

as supplemental modeling perspective to the modeling results relied upon from the 

newer MATS tool, and to the results from LADCO using a more recent base year. 

CAIR SMAT provides additional support to the Huntington-Ashland, WV-KY-OH and 

the Cincinnati- Middletown, OH-KY-IN nonattainment areas. 

45. (a) Comment: Regarding Table 3.2, please cite the document and the location of the CAIR 

data presented. Labeling of the nonattainment areas is recommended. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet added citation for the location of the data to Table 3.2 in 

Appendix L page 18, and to the Narrative in Table 6.3.2-1. Additionally, the link to the 

website for the CAIR Modeling values for 2010 is: 

http://www.epa.gov/cair/pdfs/finaltech02.pdf

46. (a) Comment: Air quality from the non-Kentucky ambient air quality monitors in the 

multi-state NAAs should be discussed. At a minimum, Table 3.5 should include data 

from the non-Kentucky ambient air quality monitors. 

Richard Schutt, USEPA, Region 4

(b) Response: The Cabinet has provided comprehensive tables of emissions by county 

and by category for all counties in all three multistate nonattainment areas for 2002 and 

2009 in Appendix E Emission Inventory Summary. Ambient data for all monitors in 

the nonattainment areas is provided in the narrative in Section 6.3.3 Air Quality Trends 

and Additional Reductions in Tables 6.3.3-1 and Table 6.3.3-2. 
12

47. (a) Comment: The data in Appendix L, Table 3.5 does show that air quality trends are 

improving in Kentucky from 2000-2006. However, there appears to be an upward trend 

with the consideration of the 2007 data. We recommend that the State provide a 

discussion on what reductions are expected in the 2008-2009 period to assist in the 

improvement in air quality and attainment in 2009. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet acknowledges this comment. The Cabinet has provided 

 a discussion of reductions, both federal and state/local, in Section 5 Controls Applied. 

 Other states in the nonattainment areas are noting state/local reductions in their areas for 

 2008-2009. 

48 (a) Comment: There is no discussion of emissions in section 3.2. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet edited Appendix L, page 19 to address this comment. 

49. (a) Comment: It is not clear that the density of monitors in all of the NAAs justify not 

applying the unmonitored attainment test. EPA highly recommends that the State use the 

EPA MATS tool with their Base G4 2009 modeling results to address the unmonitored 

area analysis. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet has included in the narrative the updated EPA MATS with 

 Base G4 2009 results for the unmonitored attainment test in Section 6.4. 

50. (a) Comment: It is not clear if the unmonitored attainment test was used and what results 

were predicted, at a minimum, in all of the counties in the three nonattainment areas. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet has included in the narrative the updated EPA MATS with 

 Base G4 2009 results for the unmonitored attainment test in Section 6.4. 

51. (a) Comment: EPA recommends adding the names of each nonattainment area to the tables 

in Appendix E. As well, the units of the data in Appendix E should be provided. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet has modified the tables in Appendix E to reflect the 

 names of nonattainment areas and the units of the data. 

52. (a) Comment: Please clarify whether the 2002 and 2009 data represent emissions inventory 

totals that were used in the attainment modeling. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet re-titled the cover page for Appendix E to reflect the emissions 
13

 summary included was used for the VISTAS-ASIP Modeling. 

53. (a) Comment: On page 3, it is unclear what the “Base M” emissions represent. 

Richard Schutt, USEPA, Region 4 

(b) Response: The Cabinet added the Alpine Geophysics memorandum dated February 13, 

2008, to provide clarification regarding the “Base M” notation in the footnotes on the 

2009 Emissions Inventory Summary spreadsheet in Appendix E. Base M is basically the 

conversion of LADCO-MRPO Base M point source emissions into IDA format for 

SMOKE processing for the ASIP Best and Final modeling. 

54. (a) Comment: It does not appear that the EGU and non-EGU emissions were combined in 

the point source totals for the non-VISTAS states (i.e., Indiana and Ohio). This implies 

that the EGU and non-EGU emissions are separate for the Kentucky and West Virginia 

point source emissions. This statement should be revised. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The Cabinet acknowledges this comment and revised the footnote in the 

 summary spreadsheet. 

55. (a) Comment: It is unclear why the Kentucky open burning and fugitive dust regulations 

are included in the SIP in Appendix M. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The regulations are not new and were included because state controls 

 measures were discussed in the SIP. Louisville regulations have been added as well. 

56. (a) Comment: EPA recommends adding a table of contents and page numbering in 

Appendix H. 

Richard Schutt, USEPA, Region 4 

 (b) Response: The document in Appendix H was provided by the contractor in a locked 

 PDF format with no features that are able to be edited by the Cabinet. 

57. (a) Comment: EPA recommends that the SIP narrative discuss the archival and 

access of data and modeling files used to develop the attainment demonstration. 

Richard Schutt, USEPA, Region 4 

(b) Response: A statement has been added to Section 6.5 Data Access which includes the 

link to the VISTAS final work products which are relevant to the PM2.5 SIP attainment 

demonstration: 

http://www.vistas-sesarm.org/documents/FinalDocs.asp; 

 The LADCO\Midwest RPO information is at the below link: 

http://www.ladco.org/; 
14

and the link to the CAIR modeling values for 2010: 

http://www.epa.gov/cair/pdfs/finaltech02.pdf

58. (a) Comment: LMAPCD noted numerous minor grammatical inconsistencies and 

recommended editing the narrative further as noted in the marked-up copy. 

Lauren Anderson, LouMetro Air Pollution Control District

 

 (b) Response: The Cabinet has made additional edits for grammatical inconsistencies. 

59. (a) Comment: LMAPCD suggests that a few paragraphs be expanded to explain the role 

 that the District plays in developing information for Jefferson County. 

 Lauren Anderson, LouMetro Air Pollution Control District

 (b) Response: The Cabinet included language suggested by LMAPCD to describe the 

 role of the local agency in developing information for Jefferson County. 

60. (a) Comment: In Page vii, Table 1, Site 21-111-1041 was designated as industrial and 

therefore data from this site is not applicable to NAAQS determinations. It is suggested 

that references to this site be deleted from this document. 

Lauren Anderson, LouMetro Air Pollution Control District

 

 (b) Response: The Cabinet deleted references to this site. 

61. (a) Comment: Page 4,The paragraph states that Table 1.3-1 presents the 2001-2003 PM2.5 

 design values for FRM Monitors. The table actually contains the 2002-2004 data and 

 design values. 

 Lauren Anderson, LouMetro Air Pollution Control District 

 (b) Response: The Cabinet has corrected this reference. 

62. (a) Comment: Page 5, Table 1.3-1, The use of data from site 21-111-0043 is inconsistent 

 throughout the document. Although it is true the site was shutdown in 2001 due to 

 construction, sampling was resumed in 2002 and the site has met data recovery 

 requirements since that time. Therefore, data after 2001 is valid. It is suggested that the 

 data for this site be added to the table. 

Lauren Anderson, LouMetro Air Pollution Control District

County 

FRM 

Monitoring 

Site 

Year 

1st 

Quarter

(Q1) 

2nd 

Quarter

(Q2) 

3rd 

Quarter

(Q3) 

4th 

Quarter 

(Q4) 

Annual 

Average 

Design 

Value 

Jefferson 21-111-0043 

2002 12.0 16.4 26.4 13.9 17.2 

2003 14.6 16.3 20.9 12.0 16.0 15.9 

2004 12.5 14.5 18.0 13.0 14.5 

 (b) Response: The Cabinet added the data listed above to Table 1.3-1. 
15

63. (a) Comment: Page 38, Paragraphs 4 and 5 need further clarification on the use of 

quarterly means for SMAT. The use of “DVB,” “DVC,” “DV” and “Design Value” is 

inconsistent throughout the document. See page 38 (paragraph 5), page 43 (paragraph 2) 

and page 48 (paragraphs 4 and 5). See also Table 1, Table 6.3.2-2 and Table 6.3.3-3. 

Note: a base-year design value (DVB) is the average of 3 design values for a 5 year 

period that straddles the model base-year. A design value (DV or DVC) is the average of 

3 consecutive annual means.

Lauren Anderson, LouMetro Air Pollution Control District 

 (b) Response: The Cabinet does not agree. The use of the acronyms as noted above is 

 consistent and accurate as presented. 

64. (a) Comment: Page 44, Table 6.3.2-2, The table contains ASIP/VISTAS DVBs in addition 

 to ASIP/VISTAS and LADCO 2009 DVFs. It is suggested that the table’s title and 

 column headings be revised to accurately reflect the information presented in the table. 

 Lauren Anderson, LouMetro Air Pollution Control District 

 (b) Response: The Cabinet has edited this table in several aspects for clarification. 

65. (a) Comment: Page 44, Table 6.3.2-2, The table should also include the LADCO Round 5 

 2009 DVF for site 21-111-0043 (12.8) and the ASIP/VISTAS DVB for this same site 

 (16.8). It should be noted that ASIP/VISTAS did not model DVFs for this site due to 

 missing SMAT data (as reflected in Table 6.3.3-3 on page 50). 

 Lauren Anderson, LouMetro Air Pollution Control District

 (b) Response: The Cabinet has edited this table in several aspects for clarification. 

66. (a) Comment: Page 44, Table 6.3.2-2, Consider revising the table to include LADCO 

DVBs to better illustrate the relative changes from DVBs to 2009 DVFs for both 

models. Note that any changes to this table should also be reflected in Table 1 on page 

vii of the Executive Summary. 

 Lauren Anderson, LouMetro Air Pollution Control District

 (b) Response: The Cabinet has edited both tables for clarification, particularly to reflect 

 the newer ASIP MATS tool values 

67. (a) Comments: Page 45, Table 6.3.3-1, The table contains data for site 21-111-0043 for 

2001. Due to construction, the site was shutdown in March of 2001 and did not acquire 

enough data to meet the 75% data recovery requirement nor the minimum of 11 samples 

per quarter. Therefore the 17.1 value does not represent a valid annual average per 40 

CFR Part 50 Appendix N section 4.1(b). The value should either be removed or noted 

that it was calculated using incomplete data. 

Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet deleted reference to the 2001 data for this monitor. 
16

68. (a) Comments: Page 47, Table 6.3.3-2, Same comment as above. This would apply only 

 to the 2000-2002 and the 2001-2003 design values. 

 Lauren Anderson, LouMetro Air Pollution Control District

 (b) Response: The Cabinet adjusted Table 6.3.3-2 to address this comment. 

69. (a) Comments: Page 47, Paragraph 1 discusses the submission of exceptional events 

packages. The exceptional events packages have been reviewed by EPA and a portion 

of the data received concurrence with APCD’s submittal for 2004 through 2007. The 

approved and flagged data changes result in relatively small differences to the original 

annual averages in the attainment demonstration document. The table below reflects 

the differences in those data. The first numbers in each column are the annual averages 

using all certified data. The second numbers are the annual averages if exceptional 

events’ data that have been flagged for exceptional events are excluded from the 

calculations. 

Lauren Anderson, LouMetro Air Pollution Control District 

Site 2004 2005 2006 2007 

Southwick 14.5/14.5 16.7/16.6 15.0/14.9 15.1/15.1 

Wyandotte 14.1/14.0 16.5/16.4 15.2/15.1 14.9/14.9 

Barret 13.7/13.7 16.8/16.7 14.0/13.9 15.1/15.1 

Watson 12.6/12.6 16.5/16.4 13.7/13.4 15.7/15.7 

 (b) Response: The Cabinet acknowledges this comment. 

70. (a) Comment: Page 48, Paragraph 5 references DVC and DVF values that do not match 

data found in Table 6.3.3-3 (VISTAS-ASIP). The values match DVB and DVF values 

reported in Table 6.3.2-2 (LADCO) instead. 

Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The Cabinet has edited these tables for clarification and to reflect the newer 

MATS tool values. 

71. (a) Comment: Page 50, Table 6.3.3-3 contains 2002 Typical DVCs and 2009 DVFs with 

no explanation of how these values differ from those reported in Table 6.3.2-2. 

Explanation provided on page 48, paragraph 4 should be expanded. 

 Lauren Anderson, LouMetro Air Pollution Control District

 (b) Response: The Cabinet has edited these tables for clarification and to reflect the newer 

 MATS tool values. 

72. (a) Comment: Page 51, It should be noted that at the time the Fine Particle Air Quality 

 Task Force was created, ASIP/VISTAS modeling had not demonstrated compliance of 

 the annual PM2.5 standard for all monitors in the entire Louisville KY-IN nonattainment 
17

 area (namely Clark County, IN). Though later modeling would demonstrate compliance, 

 the Task Force was created with the understanding that additional local controls would 

 be needed. 

Lauren Anderson, LouMetro Air Pollution Control District 

 (b) Response: The narrative was taken verbatim from correspondence sent to the Cabinet 

by the district. However, the Cabinet has now made appropriate changes to the narrative 

to reflect your agency’s comment above. 

73. (a) Comment: Page 50, Table 6.3.3.3, The 2009 G4 modeled future design value for the 

Franklin County, Kentucky, monitor (21-073-0006) is 15.8 ug/m3

. 

Lauren Anderson, LouMetro Air Pollution Control District

(b) Response: The ambient data for Franklin County, Kentucky, does not support the 

predicted model value. The current design value for Franklin County data 2005-2007 is 

13.5 ug/m3

.