### 6-151 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Chattanooga MSA and some adjacent counties. (MSA counties are in bold.)

County PM SOx NOx VOC Amm Weighted Emissions

Score Cumulative Weighted Emissions

Score Hamilton 1,498 5,300 20,04827,150 1,022 49.5 49.5 Walker 856 632 2,798 4,516 958 17.9 67.4 Marion 679 477 3,156 2,640 501 14.1 81.5 Catoosa 617 167 3,085 3,601 680 11.9 93.4 Dade 302 107 2,415 1,574 285 6.5 99.9 Roane 4967 92331 30865 4300 285 296.9 Jackson, AL 4389 44333 31502 4742 1494 176.1 Floyd, GA 10057 31821 22736 7139 976 154.0 McMinn 3348 10216 10829 5546 1268 73.3 Whitfield, GA2732 1747 7283 7386 991 54.2 Rhea 1405 302 2625 3643 149 31.2 Loudon 804 4035 5899 5338 360 24.3 DeKalb, AL 1193 741 4776 5867 5765 21.3 Bradley 1233 419 4230 7551 1916 21.1 Warren 1164 1189 1869 3675 446 20.7 Monroe 743 154 2387 3420 554 16.4 Gordon, GA 872 200 3645 4019 2630 15.8 Fannin, GA 614 65 887 1266 283 14.2 Franklin 644 482 2100 2929 1512 13.4 Chattooga, GA450 1228 1834 1634 197 11.7 Murray, GA 576 130 2067 1700 910 11.4 Polk 295 2066 900 949 553 11.3 Cherokee, NC428 143 921 1753 111 10.6 Grundy 202 164 1000 1150 1170 4.8 Bledsoe 203 31 475 528 335 4.5 Meigs 198 112 885 871 118 4.3 Sequatchie 140 22 304 591 173 3.4 Van Buren 118 178 291 320 74 3.3 

### Based on the analysis for this factor there appears to be emissions in all MSA counties and the adjacent county of Jackson, AL, which show a potential to contribute. Other adjacent counties with large emissions (McMinn and Roane, TN and Floyd, GA) are included in other nonattainment areas.

### 6-152 Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001-2003 PM2.5 Design Values for all Chattanooga MSA Counties and adjacent counties. (MSA counties are in bold.)

County 2001-2003 design value Hamilton 16.1 Walker 15.6 Roane 14.2 Floyd, GA 15.7 McMinn 14.6 Loudon 15.4 * DeKalb, AL 14.7 

### * Incomplete data that is not sufficient to determine attainment/nonattainment. Data substitution does not apply. Based on this factor, Hamilton County, TN and Walker and Floyd Counties in GA are violating the PM 2.5 standard. Catoosa County, GA is located between violating monitors in Hamilton and Walker Counties. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Chattanooga MSA and some adjacent counties. Urban population figures were not available. (MSA counties are in bold.) County 2002 Population Percent of MSA Population (2002) 2002 Population Density (people/sq.mile) Hamilton 309,321 65.7 570 Walker 61,949 13.2 139 Marion 27,654 5.9 55 Catoosa 56,341 12.0 348 Dade 15,615 3.3 90 Roane 52,316 145 Jackson, AL 54,035 50 Floyd, GA 92,606 181 McMinn 50,051 116 Whitfield, GA 87,037 300 

### Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by the following MSA counties: Hamilton, Walker, and Catoosa. The five adjacent counties also have population with a potential to contribute.

### 6-153 Factor 4: Traffic and commuting patterns Commuting Information Hamilton has a working population of 146, 824 –Commuters who remain in Hamilton: 133,644 (91%) Marion has a working population 11766. –Commuters who remain in Marion: 5596 (48%) –Commuters from Marion to Hamilton: 4271 Dade has a working population of 6983. –Commuters who remain in Dade: 2363 –Commuters from Dade to Hamilton:3091 (44%) –Commuters from Dade to Walker: 747 Catoosa has a working population of 26710. –Commuters who remain in Catoosa: 7167 –Commuters from Catoosa to Hamilton: 12320 (46%) –Commuters from Catoosa to Walker:1937 Walker has a working population of 27223. –Commuters who remain in Walker: 11244 (41%) –Commuters from Walker to Hamilton: 9098 Whitfield, GA has a working population of 38,909 –Commuters who remain in Whitfield: 33,796 (87%) –Remaining commuters do not commute to the Chattanooga MSA DeKalb, AL has a working population of 7798 –Commuters who remain in DeKalb: 5179 (66%) –Remaining commuters do not commute to the Chattanooga MSA The following table contains the vehicle miles traveled (thousand miles) for the counties in the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are in bold.)

### 6-154 County 2002 VMT (thousand miles/year) Hamilton 3,743 Walker 742 Marion 654 Catoosa 810 Dade 512 Roane 784 Jackson, AL 786 Floyd, GA 948 McMinn 787 Whitfield, GA 1423 

### Based on the analysis for this factor the VMT for all MSA counties indicate a potential to contribute. Although Whitfield County has a relatively high VMT, none of the commuters go to the Chattanooga MSA. Factor 5: Expected growth The following table has the population and population growth figures for the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are in bold.)

County 2002 Population Growth (90-00) % Growth (90-00) Hamilton 309,321 22360 8 Walker 61,949 2713 5 Marion 27,654 2916 12 Catoosa 56,341 10818 25 Dade 15,615 2007 15 Roane 52,316 4683 10 Jackson, AL 54,035 6130 13 Floyd, GA 92,606 9314 11 McMinn 50,051 6632 16 Whitfield, GA 87,037 11063 15 

### Based on the analysis for this factor, there appears to be significant growth on a percentage basis in Catoosa County that indicates a contribution to the air quality in the Chattanooga MSA. Factor 6: Meteorology This factor did not play a significant role in the decision making process. Factor 7: Geography/topography The Chattanooga area does not have any geographical or topographical boundaries limiting its airshed.

### 6-155 Factor 8: Jurisdictional boundaries Hamilton and Meigs Counties, TN and Catoosa County, GA were designated nonattainment for the 8-hour ozone standard on April 15, 2004. This factor did not play a significant role in the decision making process.
Factor 9: Level of control of emission sources Sources in the Chattanooga area are subject to Prevention of Significant Deterioration (PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology (CTG RACT) - (Hamilton County only}, Maximum Achievable Control Technology (MACT) for Hazardous Air Pollutants (HAP), New Source Performance Standards (NSPS), and the NOx SIP call. This factor did not play a significant role in the decision making process. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Jackson County, AL: In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant in the nonattainment area. Jackson County, AL is one of those counties. Jackson County has 4,389 tons of PM, 4,333 tons of SO2 and 31,502 of NOx emissions, with the majority of emissions coming from the Widows Creek Power Plant.The commuting patterns show that 68% (16,642) of the working population in the county actually works in Jackson County with 8% (1,853) working in Madison County and another 8% (1,695) working in Dekalb County. The available data indicate that there are no identifiable commuting patterns between Jackson County and Chattanooga. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. The State of Alabama subsequently submitted two partial county recommendations, one included the Widows Creek Plant boundary as a contiguous area and the other was contiguous to the nearest county recommended as nonattainment.

### 6-156 After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free-standing portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier (StateFIPs-CoFIPs-Tract#-Block Group#) 01-071-9503-1 portion of Jackson County as part of the Chattanooga nonattainment area. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Chattanooga, TN-GA area: Jackson (Partial).
6.4.1.4 DeKalb and Etowah Counties Based on incomplete monitoring data and data substitution not being a viable alternative, it is EPA’s position that DeKalb and Etowah Counties be designated as unclassifiable. These two counties had monitoring data for 2000-2002 that was violating and have incomplete data for 2001-2003. Applying the data substitution policy will not confirm attainment. There is no distinction, regulatorily between attainment and unclassifiable.

Area EPA Recommendation State Recommendation De Kalb County Etowah County De Kalb County Etowah County



### Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as unclassifiable for the Dekalb County, ALarea: Dekalb. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as unclassifiable for the Gadsden, ALarea: Etowah

. 6.4.2EPA 9-Factor Analyses for Georgia for the Designation of PM2.5 Nonattainment Areas
6.4.2.1 Atlanta Area MSA The Atlanta MSA contains the counties of: Barrow, Bartow, Caroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Pickens, Rockdale, Spalding, and Walton.

### 6-157 On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification at that time. On June 17, 2004, the State submitted additional information and revised recommendations. The revision recommended the 20 county ozone nonattainment area, which includes the adjacent county of Hall, plus a partial county recommendation for Heard County adjacent to the Atlanta MSA which contains no monitor, but a power plant with large SO2 and NOx emissions. The State also recommended that Floyd County which is adjacent to the Atlanta MSA and has a violating monitor be designated as a separate nonattainment area. The adjacent counties of Hall, Jasper and Putnam have significant emissions with a potential to contribute to the violations in the Atlanta area. Putnam county contains a power plant with large SO2 and NOx emissions. We have included in our recommended nonattainment area Putnam County in your state that is contiguous to this CMSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility or facilities (e.g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of such contiguous county, encompassing the large facility or facilities, should be designated nonattainment. Based on emission levels and the other nine factors, EPA is modifying the Georgia submittal to a include Jasper and Putnam counties. EPA agrees with the partial county recommendation for Heard County, and Floyd County as a separate nonattainment area.

Area EPA Recommendation State Recommendation Atlanta, GA Full counties:Barrow, Bartow, Caroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Rockdale, Spalding, and Walton Adjacent:Floyd as a separate area; Hall, Heard as a partial, Jasper, Putnam Full counties:Barrow, Bartow, Caroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Rockdale, Spalding, and Walton Adjacent:Floyd as a separate area; Hall, Heard as a partial



### The following is a brief summary of the 9 criteria for the Atlanta MSA and surrounding counties. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted scores for the counties in the Atlanta MSA and some adjacent counties. (MSA counties are inbold.)

### 6-158 County PM SOx NOx VOC AmmWeighted score Cumulative Weighted

score Fulton 16,04111,819 48,166 44,184 1,948 18.7 18.7 Bartow 9,181 154,447 43,326 5,725 1,309 12.5 31.2 Cobb 3,767 26,411 27,948 27,219 969 9.6 40.8 Coweta 3,795 44,839 15,822 5,048 241 9.4 50.2 De Kalb 3,557 1,734 27,204 36,184 1,175 8.6 58.8 Cherokee 3,761 400 6,769 7,334 1,450 7.4 66.2 Clayton 2,727 612 9,808 10,776 437 6.1 72.3 Gwinnett 2,514 1,446 23,075 27,071 992 5.7 78.0 Henry 2,090 392 14,577 6,349 269 3.6 81.6 Forsyth 1,917 288 5,267 5,763 1,990 2.7 84.3 Carroll 1,629 293 5,536 7,224 2,808 2.6 86.9 Paulding 1,415 236 4,393 3,593 449 2.5 89.4 Douglas 822 239 4,565 4,342 163 1.8 91.2 Newton 1,147 226 4,109 5,047 240 1.8 93.0 Fayette 1,122 252 4,531 4,499 173 1.6 94.6 Walton 919 176 2,759 3,952 755 1.4 96.0 Spalding 795 180 3,251 3,839 212 1.1 97.1 Barrow 706 128 2,340 2,738 1,632 1.0 98.1 Rockdale 774 222 3,678 3,820 166 1.0 99.1 Pickens 463 83 1,116 1,769 1,204 0.9 100.0 Jasper 2,835 210 28,144 2,453 360 6.3 Putnam 3,726 65,560 34,202 1,175 399 6.3 Floyd 10,05731,821 22,736 7,139 976 6.1 Monroe 3,403 75,571 34,069 2,189 644 6.1 Heard 4,090 75,745 21,714 1,170 634 5.6 Hall 2,347 1,045 7,714 11,062 3,709 3.0 Troup 1,194 422 12,277 8,223 382 2.5 Lee 1,043 1,425 5,125 7,474 333 2.2 Meriwether 844 190 1,866 3,006 167 1.6 Gilmer 646 69 1,148 1,273 2,663 1.5 Walker 856 632 2,798 4,516 958 1.5 Tallapoosa 679 655 1,993 3,230 263 1.3 Gordon 872 200 3,645 4,019 2,630 1.3 Harris 590 104 2,856 1,748 128 1.3 Jackson 817 151 3,639 2,935 3,584 1.3 Chambers 579 527 2,350 2,882 124 1.2 Habersham 651 103 1,757 2,201 3,031 1.1 Polk 660 142 2,345 3,485 575 1.1 Jones 455 105 1,537 1,506 230 1.0 Cherokee 633 222 1,184 2,036 778 0.9 Randolph 404 223 9,276 1,891 1,294 0.9 Lumpkin 403 60 905 1,067 1,090 0.9 Taylor 398 76 966 622 833 0.9 Upson 476 84 1,568 1,926 286 0.9 White 449 58 1,000 1,190 1,462 0.9 Cleburne 331 130 2,057 1,091 1,227 0.8 Chattooga 450 1,228 1,834 1,634 197 0.8 Clarke 395 215 3,362 5,223 390 0.8 Haralson 410 96 1,768 3,071 371 0.8

### 6-159 Morgan 390 121 2,422 3,176 1,129 0.8 Talbot 288 70 903 520 74 0.8 Butts 357 112 1,609 1,438 88 0.7 Crawford 346 38 645 570 242 0.7 Dawson 324 58 915 1,246 1,142 0.7 Oconee 507 111 1,599 2,047 1,050 0.7 Banks 325 65 1,178 1,127 3,407 0.6 Pike 314 42 607 823 148 0.5 Lamar 257 59 812 1,090 491 0.4 

### Based on the emissions analysis the adjacent counties of Floyd, Hall, Heard, Jasper, and Putnam have significant emissions indicating potential contribution to the violations in the area. The Agency agrees that Floyd can be designated as a separate PM2.5 nonattainment area and with the partial county recommendation for Heard. The Agency also agrees with the State that Pickens is not contributing based on the low emissions levels. It was not included in the ozone nonattainment area based on noncontribution. Factor 2: Air quality in potentially included versus excluded areas County 2001-2003 Design Value Fulton 18.0 Cobb 16.1 De Kalb 16.1 Clayton 16.1 Gwinnett 15.6 Paulding 14.1 Floyd 15.7 Hall 14.9 Walker 15.6 Clarke 15.6 

### There are five counties containing violating monitors in the area recommended by the State and one violating in the adjacent county of Floyd recommended as a separate nonattainment area. Hall County contains an attaining monitor but was recommended by the State as contributing. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Atlanta MSA and some adjacent counties with significant emissions. (MSA counties are inbold.) County 2002 PopulationPercent Population of MSA Population Density Fulton 825,431 18.8 1,560 Bartow 82,607 1.9 180 Cobb 651,485 14.9 1,916 Coweta 97,771 2.2 221 De Kalb 676,996 15.4 2,526 Cherokee 159,295 3.6 376

### 6-160 Clayton 252,733 5.8 1,767 Gwinnett 650,771 14.8 1,503 Henry 139,699 3.2 433 Forsyth 116,924 2.7 517 Carroll 94,907 2.2 190 Paulding 94,184 2.1 300 Douglas 98,650 2.2 496 Newton 71,594 1.6 259 Fayette 96,611 2.2 490 Walton 67,069 1.5 204 Spalding 59,410 1.4 300 Barrow 51,016 1.2 315 Rockdale 73,558 1.7 562 Pickens 25,619 0.6 110 Jasper 12,283 33 Putnam 19,390 56 Floyd 92,606 181 Monroe 22,675 57 Heard 11,340 38 Hall 152,235 386 

### Pickens County has the lowest population of any of the MSA counties supporting the noncontributing determination. Although, Heard, Jasper and Putnam counties have small population, they contain sources with large emissions. Factor 4: Traffic and commuting patterns Commuting Information: Fulton County has a total of 385,442 commuters. - Commuters that remain in Fulton County: 265,870 - Commuters from Fulton County to Cobb County: 24,991 - Commuters from Fulton County to Dekalb County: 41,232 - Commuters from Fulton County to Clayton County: 9,722 - Commuters from Fulton County to Gwinnett County: 21,211 Bartow County has a total of 35,953 commuters. - Commuters that remain in Bartow County: 20,692 - Commuters from Bartow County to Fulton County: 1,882 - Commuters from Bartow County to Cobb County: 6,936 - Commuters from Bartow County to Dekalb County: 678 - Commuters from Bartow County to Gwinnett County: 392 - Commuters from Bartow County to Floyd County: 986 Cobb County has a total of 325,412 commuters. - Commuters that remain in Cobb County: 179,750 - Commuters from Cobb County to Fulton County: 92,014 - Commuters from Cobb County to Dekalb County: 18,098 - Commuters from Cobb County to Gwinnett County: 8,723

### 6-161 Coweta County has a total of 43,506 commuters. - Commuters that remain in Coweta County: 20,735 - Commuters from Coweta County to Fulton County: 8,855 - Commuters from Coweta County to Cobb County: 1,136 - Commuters from Coweta County to Dekalb County: 1,014 - Commuters from Coweta County to Clayton County: 3,097 Dekalb County has a total of 341,110 commuters. - Commuters that remain in Dekalb County: 149,919 - Commuters from Dekalb County to Fulton County: 121,921 - Commuters from Dekalb County to Cobb County: 13,448 - Commuters from Dekalb County to Clayton County: 5,644 - Commuters from Dekalb County to Gwinnett County: 34,747 Cherokee County has a total of 74,075 commuters. - Commuters that remain in Cherokee County: 26,239 - Commuters from Cherokee County to Fulton County: 17,494 - Commuters from Cherokee County to Cobb County: 18,911 - Commuters from Cherokee County to Dekalb County: 2,898 - Commuters from Cherokee County to Gwinnett County: 2,037 Clayton County has a total of 112,580 commuters. - Commuters that remain in Clayton County: 42,924 - Commuters from Clayton County to Fulton County: 40,271 - Commuters from Clayton County to Cobb County: 4,053 - Commuters from Clayton County to Dekalb County: 9,024 - Commuters from Clayton County to Gwinnett County: 2,785 Gwinnett County has a total of 309,797 commuters. - Commuters that remain in Gwinnett County: 169,000 - Commuters from Gwinnett County to Fulton County: 57,737 - Commuters from Gwinnett County to Cobb County: 8,648 - Commuters from Gwinnett County to Dekalb County: 51,481 Henry County has a total of 60,381 commuters. - Commuters that remain in Henry County: 18,751 - Commuters from Henry County to Fulton County: 14,157 - Commuters from Henry County to Cobb County: 1,365 - Commuters from Henry County to Dekalb County: 5,597 - Commuters from Henry County to Clayton County: 13,541 - Commuters from Henry County to Gwinnett County: 1,531 Forsyth County has a total of 51,224 commuters. - Commuters that remain in Forsyth County: 21,039 - Commuters from Forsyth County to Fulton County: 15,251

### 6-162 - Commuters from Forsyth County to Cobb County: 1,790 - Commuters from Forsyth County to Dekalb County: 3,067 - Commuters from Forsyth County to Gwinnett County: 5,663 Carroll County has a total of 39,730 commuters. - Commuters that remain in Carroll County: 24,611 - Commuters from Carroll County to Fulton County: 3,570 - Commuters from Carroll County to Cobb County: 2,044 - Commuters from Carroll County to Dekalb County: 700 - Commuters from Carroll County to Paulding County: 493 Paulding County has a total of 40,830 commuters. - Commuters that remain in Paulding County: 10,094 - Commuters from Paulding County to Fulton County: 7,432 - Commuters from Paulding County to Cobb County: 14,850 - Commuters from Paulding County to Dekalb County: 1,288 - Commuters from Paulding County to Clayton County: 440 - Commuters from Paulding County to Gwinnett County: 655 Douglas County has a total of 46,176 commuters. - Commuters that remain in Douglas County: 16,924 - Commuters from Douglas County to Fulton County: 14,253 - Commuters from Douglas County to Cobb County: 7,450 - Commuters from Douglas County to Dekalb County: 2,211 - Commuters from Douglas County to Clayton County: 1,196 - Commuters from Douglas County to Gwinnett County: 747 - Commuters from Douglas County to Paulding County: 596 Newton County has a total of 28,560 commuters. - Commuters that remain in Newton County: 11,545 - Commuters from Newton County to Fulton County: 2,399 - Commuters from Newton County to Cobb County: 411 - Commuters from Newton County to Dekalb County: 3,567 - Commuters from Newton County to Clayton County: 480 - Commuters from Newton County to Gwinnett County: 1,320 Fayette County has a total of 45,231 commuters. - Commuters that remain in Fayette County: 16,977 - Commuters from Fayette County to Fulton County: 14,745 - Commuters from Fayette County to Cobb County: 1,124 - Commuters from Fayette County to Dekalb County: 1,683 - Commuters from Fayette County to Clayton County: 6,048 Walton County has a total of 29,031 commuters. - Commuters that remain in Walton County: 11,204 - Commuters from Walton County to Fulton County: 1,666

### 6-163 - Commuters from Walton County to Dekalb County: 2,978 - Commuters from Walton County to Gwinnett County: 7,037 Spalding County has a total of 24,931 commuters. - Commuters that remain in Spalding County: 13,715 - Commuters from Spalding County to Fulton County: 1,917 - Commuters from Spalding County to Cobb County: 273 - Commuters from Spalding County to Dekalb County: 583 - Commuters from Spalding County to Clayton County: 2,113 Barrow County has a total of 22,616 commuters. - Commuters that remain in Barrow County: 7,751 - Commuters from Barrow County to Fulton County: 959 - Commuters from Barrow County to Dekalb County: 1,177 - Commuters from Barrow County to Gwinnett County: 8,229 Rockdale County has a total of 32,931 commuters. - Commuters that remain in Rockdale County: 14,378 - Commuters from Rockdale County to Fulton County: 4,792 - Commuters from Rockdale County to Cobb County: 570 - Commuters from Rockdale County to Dekalb County: 6,187 - Commuters from Rockdale County to Clayton County: 804 - Commuters from Rockdale County to Gwinnett County: 1,985 Pickens County has a total of 11,116 commuters. - Commuters that remain in Pickens County: 5,318 - Commuters from Pickens County to Fulton County: 741 - Commuters from Pickens County to Cobb County: 938 - Commuters from Pickens County to Dekalb County: 250 - Commuters from Pickens County to Gwinnett County: 218 Jasper County has a total of 5,123 commuters. - Commuters that remain in Jasper County: 1,910 - Commuters from Jasper County to Fulton County: 267 - Commuters from Jasper County to Dekalb County: 238 - Commuters from Jasper County to Clayton County: 105 - Commuters from Jasper County to Gwinnett County: 57 Putnam County has a total of 8,055 commuters. - Commuters that remain in Putnam County: 4,478 - Commuters from Putnam County to Fulton County: 177 - Commuters from Putnam County to Dekalb County: 129 - Commuters from Putnam County to Gwinnett County: 82 Floyd County has a total of 39,622 commuters. - Commuters that remain in Floyd County: 32,440

### 6-164 - Commuters from Floyd County to Fulton County: 528 - Commuters from Floyd County to Cobb County: 662 Monroe County has a total of 10,316 commuters. - Commuters that remain in Monroe County: 4,116 - Commuters from Monroe County to Fulton County: 318 - Commuters from Monroe County to Dekalb County: 140 - Commuters from Monroe County to Clayton County: 233 Heard County has a total of 4,488 commuters. - Commuters that remain in Heard County: 1,413 - Commuters from Heard County to Fulton County: 308 - Commuters from Heard County to Cobb County: 70 Hall County has a total of 65,402 commuters. - Commuters that remain in Hall County: 46,680 - Commuters from Hall County to Fulton County: 2,244 - Commuters from Hall County to Dekalb County: 1,716 - Commuters from Hall County to Gwinnett County: 7,189

### 6-165 The following table contains the vehicle miles traveled (thousand miles) for the counties in the Atlanta MSA and some adjacent counties with significant emissions. (MSA counties are in bold.) County 2002 VMT 2002-2010 VMT Growth Fulton 11,358 4,592 Bartow 1,322 -285 Cobb 7,015 4,008 Coweta 1,562 -596 De Kalb 9,356 4,119 Cherokee 1,795 222 Clayton 3,148 1,341 Gwinnett 6,736 1,600 Henry 1,744 -508 Forsyth 1,271 -328 Carroll 1,431 -255 Paulding 1,047 -157 Douglas 1,251 465 Newton 1,049 -300 Fayette 1,197 -324 Walton 684 -104 Spalding 796 -59 Barrow 590 -123 Rockdale 924 345 Pickens 237 90 Jasper 112 70 Putnam 179 37 Floyd 948 732 Monroe 572 -283 Heard 146 40 Hall 1,897 -181 

### Pickens County has a very low VMT and VMT growth thus supporting the attainment/unclassifiable recommendation. Approximately 82 percent of Floyd County commuters stay within the county. This commuting pattern supports Floyd County as a separate nonattainment area. Although Jasper and Putnam have low VMT, they have large emission sources.

### 6-166 Factor 5: Expected growth The following table has the population and population growth figures for the Atlanta MSA and some adjacent counties with significant emissions. (MSA counties are inbold.) County2002 PopulationGrowth 90-00Percent Growth Fulton 825,431 167,055 26 Bartow 82,607 20,108 36 Cobb 651,485 160,006 36 Coweta 97,771 35,362 66 De Kalb 676,996 120,028 22 Cherokee 159,295 51,699 57 Clayton 252,733 54,465 30 Gwinnett 650,771 235,538 67 Henry 139,699 60,600 103 Forsyth 116,924 54,324 123 Carroll 94,907 15,846 22 Paulding 94,184 40,067 96 Douglas 98,650 21,054 30 Newton 71,594 20,193 48 Fayette 96,611 28,848 46 Walton 67,069 22,101 57 Spalding 59,410 3,960 7 Barrow 51,016 16,423 55 Rockdale 73,558 16,020 30 Pickens 25,619 8,551 59 Jasper 12,283 2,973 35 Putnam 19,390 4,675 33 Floyd 92,606 9,314 11 Monroe 22,675 4,644 27 Heard 11,340 2,384 28 Hall 152,235 43,849 46 

### Pickens County has a high percent growth rate. However, the actual numbers of population growth are low which support it’s recommendation as attainment. Factor 6: Meteorology This factor did not constitute a significant role in the decision making process. Factor 7: Geography/topography This factor did not constitute a significant role in the decision making process.
Factor 8: Jurisdictional boundaries This factor did not constitute a significant role in the decision making process.
Factor 9: Level of control of emission sources

### 6-167 This factor did not constitute a significant role in the decision making process.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendations on June 29,2004, included Jasper County as part of the Atlanta nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Jasper County as attainment/unclassifiable, and a portion of Putnam County as nonattainment. The remainder of Putnam County will be designated attainment/unclassifiable. Jasper County: Jasper County emissions in tons per year are: PM (2,835), NOx (28,144), SO2 (210), VOC (2,453). Jasper County was added to the Altanta metropolitan area in the 2003 OMB definition, has no monitor, a low population (12,283), and a low population density (33 people/square mile), when compared to the Atlanta MSA. For example, Fulton County, which contains the design value monitor, has a population of (825,431), and a population density of (1,560 people/square mile). The county has low emissions when compared to the Atlanta MSA. The majority of the emissions in Jasper County come from a Georgia Pacific facility which is 45 miles from the nearest violating monitor. Additionally, Jasper County has a low number of commuters (5,123) and only 667 of those commuters commute to the Atlanta MSA. The 2002 VMT (112,000) for Jasper county is lower than any county in the Atlanta MSA. Putnam County: In the June 29,2004, letters from EPA to the State responding to their designation recommendations, EPA proposed the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Putnam County, GA is one of those counties. Putnam County is adjacent to Jasper County which was added to the Altanta metropolitan area in the 2003 OMB definition, and has no monitor. Putnam County emissions in tons per year and percent of MSA are: PM (3,726), SO2 (65,560), NOx (34,202), and VOC (1,175). The NOx and SO2 emissions are primarily from the Harlee Branch power plant which is approximately 67 miles from, and downwind of, the nearest violating monitor. Putnam County has a total of (8,055) commuters of which only (388) commute to the Atlanta MSA. The 2002 VMT (179,000) for Putnam County is lower than any county in the Atlanta MSA. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are

### 6-168 considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free-standing portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier (StateFIPs-CoFIPs-Tract#-Block Group#) 13-237-9603-1 portion of Putnam County as part of the Atlanta nonattainment area. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Atlanta, GA area: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Heard (Partial), Henry, Newton, Paulding, Putnam (Partial), Rockdale, Spalding, and Walton.

### 6-169 6.4.2.2 Macon Area MSA The Macon MSA contains the counties of: Bibb, Houston, Jones, Peach, and Twiggs. On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification. On June 17, 2004, the State submitted additional information and revised recommendations. The revision recommended that Bibb County be nonattainment and Monroe County as a partial county nonattainment area. EPA agrees with the State’s recommendation.

Area EPA Recommendation State Recommendation Macon, GA Full counties: Bibb, Monroe as partial Full counties: Bibb, Monroe as partial



### The following is a brief summary of the 9 criteria for the Macon MSA and surrounding counties. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted scores for the counties in the Macon MSA and some adjacent counties. (MSA counties are inbold.) County PM SOx NOx VOC AMM Weighted score Cumulative Weighted score Bibb 2,723 8,521 11,353 10,061 370 46.9 46.9 Houston 1,243 1,666 6,285 5,627 629 18.3 65.2 Twiggs 1,203 198 2,263 1,141 92 18.2 83.4 Jones 455 105 1,537 1,506 230 10.5 93.9 Peach 478 89 2,025 2,261 202 6.1 100.0 Monroe 3,403 75,571 34,069 2,189 644 104.3 Putnam 3,726 65,560 34,202 1,175 399 100.8 Jasper 2,835 210 28,144 2,453 360 69.0 Wilkinson 4,397 170 1,368 821 55 48.3 Laurens 1,222 2,674 4,717 3,688 444 28.6 Dooly 1,130 140 2,115 1,442 676 19.8 Macon 1,124 1,395 2,539 1,248 1,349 15.7 Upson 476 84 1,568 1,926 286 10.3 Taylor 398 76 966 622 833 9.7 Baldwin 451 122 2,007 2,949 203 8.9 Crawford 346 38 645 570 242 8.1 Butts 357 112 1,609 1,438 88 7.6 Pulaski 434 37 452 503 263 6.9 Bleckley 341 31 505 642 146 6.2 Lamar 257 59 812 1,090 491 4.9

### 6-170 Based on this analysis, Monroe County has significant emissions which contribute to the violations at the Bibb County monitor. Although Jasper and Putnam counties also have significant emissions, EPA believes those counties should be included in the Atlanta nonattainment area, rather than the Macon nonattainment area. For the counties in the Macon MSA, there is a natural break in the weighted emission score between Bibb and the remaining counties. Factor 2: Air quality in potentially included versus excluded areas County 2001-2003 Design Value Bibb 15.2 Houston 12.8 Wilkinson 14.9 

### There are two counties containing monitors in the Macon area. Bibb County contains a violating monitor while Houston County contains an attaining monitor. An adjacent county, Wilkinson, also contains an attaining monitor. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Macon MSA and some adjacent counties. Urban population figures were not available. (MSA counties are inbold.)

County 2002 Population Percent Population of MSA Population Density

Bibb 154,824 47 619 Houston116,768 35 310 Twiggs 10,545 3 29 Jones 24,492 7 62 Peach 24,224 7 160 Monroe 22,675 57 Putnam 19,390 56 Jasper 12,283 33 Wilkinson10,357 23 Laurens 45,890 56 Dooly 11,505 29 

### Twiggs, Jones, and Peach counties all have low populations with low populations densities which support their attainment recommendations. Houston County’s population density is approximately half that of Bibb County’s which supports it’s attainment recommendation. Factor 4: Traffic and commuting patterns Commuting Information: Bibb County, the design value county, has a total of 63,229 commuters. - Commuters who remain in Bibb County: 54, 125

### 6-171 Houston County has a total of 53,089 commuters. - Commuters that remain in Houston County: 39, 954 - Commuters from Houston County to Bibb County: 8,570 Twiggs County has a total of 4,086 commuters. - Commuters who remain in Twiggs County: 1,019 - Commuters from Twiggs County to Bibb County: 1,929 Jones County has a total of 10,543 commuters. - Commuters who remain in Jones County: 2,472 - Commuters from Jones County to Bibb County: 5,988 Peach County has a total of 9,731 commuters. - Commuters that remain in Peach County: 4,137 - Commuters from Peach County to Bibb County: 2,361 Monroe County, an adjacent county, has a total of 10,316 commuters. - Commuters that remain in Monroe County: 4,116 - Commuters from Monroe County to Bibb County: 3,262 Putnam County has a total of 8,055 commuters. - Commuters that remain in Putnam County: 4,479 - Commuters from Putnam County to Bibb County: 329 Jasper County has a total of 5,123 commuters. - Commuters that remain in Jasper County: 1,910 - Commuters from Jasper County to Bibb County: 112 Wilkinson County has a total of 4,060 commuters. - Commuters that remain in Wilkinson County: 1,933 - Commuters from Wilkinson County to Bibb County: 538 Laurens County has a total of 18,986 commuters. - Commuters that remain in Laurens County: 16,046 - Commuters from Laurens County to Bibb County: 501 Dooly County has a total of 4,160 commuters. - Commuters that remain in Dooly County: 2,399 - Commuters from Dooly County to Bibb County: 75 The commuting patterns support Bibb County as the only MSA county in the nonattainment area.

### 6-172 The following table contains vehicle miles traveled (thousand miles) for the counties in the Macon MSA and some adjacent counties with significant emissions. (MSA counties are in bold.) County 2002 VMTVMT Growth 02-10 Bibb 1,653 1,096 Houston 1,068 130 Twiggs 469 -270 Jones 283 129 Peach 496 -210 Monroe 572 -283 Putnam 179 37 Jasper 112 70 Wilkinson 152 68 Laurens 1,037 -527 Dooly 348 -185 

### Twiggs, Jones, and Peach counties have low VMTs with low VMT growth, or negative growth. Houston County has a low VMT growth. This information supports the attainment recommendations for these counties. Factor 5: Expected growth The following table has the population and population growth figures for the Macon MSA and some adjacent counties with significant emissions. (MSA counties are inbold.) County 2002 PopulationGrowth 90-00 Percent Growth Bibb 154,824 3,920 3 Houston 116,768 21,557 24 Twiggs 10,545 784 8 Jones 24,492 2,900 14 Peach 24,224 2,479 12 Monroe 22,675 4,644 27 Putnam 19,390 4,675 33 Jasper 12,283 2,973 35 Wilkinson 10,357 -8 -0 Laurens 45,890 4,886 12 Dooly 11,505 1,624 16 

### Twiggs, Jones, and Peach counties all have low populations with low growth rates. This supports their recommendations as attainment/unclassifiable. Factor 6: Meteorology This factor did not constitute a significant role in the decision making process. Factor 7: Geography/topography This factor did not constitute a significant role in the decision making process.

### 6-173 Factor 8: Jurisdictional boundaries This factor did not constitute a significant role in the decision making process.
Factor 9: Level of control of emission sources This factor did not constitute a significant role in the decision making process. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Macon, GA area: Bibb and Monroe (Partial).
6.4.2.3 Athens Area MSA The Athens MSA contains the counties of: Clarke, Madison, and Oconee. On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification. On June 17, 2004, the State submitted additional information and revised recommendations. The revision recommended that Clarke County be designated as nonattainment and that Oconee and Madison counties be designated as attainment.

Area EPA Recommendation State Recommendation Athens, GA Full counties: Clarke, Oconee, and Madison Full counties: Clarke



### The following is a brief summary of the 9 criteria for the Athens MSA and surrounding Counties. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted scores for the counties in the Athens MSA and some adjacent counties. (MSA counties are inbold.)

### 6-174 County PM SO2 NOx VOC AMM Weighted score Cumulative Weighted score Clarke 395 215 3,362 5,223 390 41.2 41.2 Oconee 507 111 1,599 2,047 1,050 30.5 71.7 Madison 543 70 1,449 1,219 3,013 28.3 100 Walton 919 176 2,759 3,952 755 57.1 Jackson 817 151 3,639 2,935 3,584 52.2 Greene 437 161 2,137 1,582 468 42.3 Barrow 706 128 2,340 2,738 1,632 40.2 Morgan 390 121 2,422 3,176 1,129 33.1 Franklin 449 84 2,068 1,813 4,128 27.6 Elbert 410 71 1,357 1,280 343 27.5 Wilkes 340 46 507 756 491 26.9 Oglethorpe 343 40 639 730 1,664 24.7 Hart 505 63 1,321 1,595 1,516 24.2 Banks 325 65 1,178 1,127 3,407 22.3 Taliaferro 131 32 718 355 89 13.1 

### Analysis of this factor indicates that Clarke, Oconee, and Madison counties have emissions with potential to contribute to the violation in Clarke County. Factor 2: Air quality in potentially included versus excluded areas County 2001-2003 Design Value Clarke 15.6 

### There is one violating monitor in Clarke County. Therefore, Clarke County is nonattainment. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Athens MSA and some adjacent counties with significant emissions. (MSA counties are inbold.) County2002 PopulationPercent Population of MSA Population Density Clarke 103,881 66 859 Oconee 27,264 17 147 Madison 26,717 17 94 Walton 67,069 204 Jackson 45,374 133 Greene 15,101 39 Barrow 51,016 315 Morgan 16,301 47 Franklin 20,778 79 Elbert 20,667 56 Wilkes 10,734 23 Ogelthorpe13,176 30 Hart 23,249 100 Banks 15,123 65 Taliafero 1,977 10

### 6-175 Walton County has appreciable population, but is population that is included in the Atlanta nonattainment area. Factor 4: Traffic and commuting patterns Commuting Information: Jackson County has total of 19,132 commuters. - Commuters that stay in Jackson County: 7,960 - Commuters that commute to Clarke County: 3,022 Clarke County, the design value county, has a total of 48,241 commuters. - Commuters that stay in Clarke County: 39,009 Oconee County has a total of 12,903 commuters. - Commuters that stay in Oconee County: 3,630 - Commuters that commute to Clarke County: 6,696 Madison County has a total of 12,257 commuters. - Commuters that stay in Madison County: 3,432 - Commuters that commute to Clarke County: 6,048 Greene County has a total of 5,609 commuters. - Commuters that stay in Greene County: 3,856 - Commuters that commute to Clarke County: 266 Morgan County has a total of 7,278 commuters. - Commuters that stay in Morgan County: 4,570 - Commuters that commute to Clarke County: 417 Franklin County has a total of 8,844 commuters - Commuters that stay in Franklin County: 4,766 - Commuters that commute to Clarke County: 461 Elbert County has a total of 8,576 commuters. - Commuters that stay in Elbert County: 6,238 - Commuters that commute to Clarke County: 417 Hart County has a total of 10,275 commuters. - Commuters that stay in Hart County: 6,768 - Commuters that commute to Clarke County: 272 Wilkes County has a total of 4,457 commuters. - Commuters that stay in Wilkes County: 3,464 - Commuters that commute to Clarke County: 181

### 6-176 More than 50 percent of the commuters in Oconee County and almost 50 percent of the commuters in Madison County commute to Clarke County. The following table contains vehicle miles traveled (thousand miles) for the counties in the Athens MSA and some adjacent counties with significant emissions. (MSA counties are in bold.) County 2002 VMT VMT Growth 02-10 Clarke 820 929 Oconee 330 43 Madison 351 96 Jackson 748 -226 Greene 354 -153 Morgan 514 -302 Madison 351 96 Franklin 546 -228 Elbert 259 43 Hart 269 59 Wilkes 95 53 

### Analysis of this factor indicates that Oconee and Madison counties have commuting patterns and VMT which contribute to the violation in Clarke County. Factor 5: Expected growth The following table has the population and population growth figures for the Athens MSA and some adjacent counties with significant emissions. (MSA counties are inbold.)

County2002 PopulationGrowth 90-00Percent Growth Clarke 103,881 13,895 16 Oconee 27,264 8,607 49 Madison26,717 4,680 22 Jackson45,374 11,584 39 Greene 15,101 2,613 22 Morgan 16,301 2,574 20 Franklin20,778 3,635 22 Elbert 20,667 1,562 8 Hart 23,249 3,285 17 Wilkes 10,734 90 1 

### Analysis of this factor indicates that Oconee and Madison counties contain growth patterns which potentially contribute to the violation in Clarke County. Factor 6: Meteorology This factor did not constitute a significant role in the decision making process.

### 6-177 Factor 7: Geography/topography This factor did not constitute a significant role in the decision making process.
Factor 8: Jurisdictional boundaries This factor did not constitute a significant role in the decision making process.
Factor 9: Level of control of emission sources This factor did not constitute a significant role in the decision making process. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendations on June 29,2004, included the counties of Oconee and Madison as part of the Athens nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Oconee and Madison as attainment/unclassifiable. Oconee County: Oconee County emissions in tons per year and percent of MSA emissions are: SO2 (111 /28%), NOx (1,599/25%), PM (507/35%) and VOC (2,047/24%). These emissions are low when compared to Clarke County which has over half of the SO2, NOx, and VOC emissions for the MSA. Oconee County also has a low population (27,264/17% of MSA), and a low population density (147 people/square mile) when compared to Clarke County which has a population of (103,881/66%) and a high population density (859 people/square mile). Oconee County has a low total number of commuters (12,903) of which 6,696 commute to Clarke County. This is a low number of commuters compared to Clarke County’s (48,241) of which 80 percent (39,009) remain in Clarke County. Of the daily VMT in the MSA, 55 percent occurs in Clarke County. Oconee County does not contain a monitor. Madison County: Madison County emissions in tons per year and percent of MSA are: SO2 (70/18%), NOx (1,449/23%), PM (543/38%), and VOC (1,219/14%). These emissions are low when compared to Clarke County which has over half of the SO2, NOx, and VOC emissions for the MSA. Madison County also has a low population (26,717/17% of MSA), and a low population density (94 people/square mile) when compared to Clarke County which has a population of (103,881/66%) and a high population density (859 people/square mile). Madison County has a low total number of commuters (12,257) of which 6,048 commute to Clarke County. This is a low number of commuters compared to Clarke County’s (48,241) of

### 6-178 which 80 percent (39,009) remain in Clarke County. Of the daily VMT in the MSA, 55 percent occurs in Clarke County. Madison County does not contain a monitor. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Athens, GA area: Clarke 6.4.2.4 Chattanooga Area The Chattanooga MSA contains the following Tennessee counties: Marion and Hamilton; and the following Georgia Counties: Dade, Walker, and Catoosa. Based on air quality data for 2001- 2003, the monitor with the highest design value in Hamilton County has a design value of 16.1 and the monitor in Walker County has a design value of 15.6. No other counties in the MSA contain ambient air monitors. The State of Tennessee recommended as nonattainment the county of Hamilton and the State of Georgia recommended as nonattainment the county of Walker. The States have recommended that all other counties be designated attainment. The State of Tennessee submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. EPA is modifying the State of Tennessee’s recommendation and will review the additional information during the 120 day period following the notification letter. EPA has received some information from the State of Tennessee that Marion (MSA) County should be designated attainment for the PM2.5 standard and no justification from the State of Georgia indicating that any other counties should be included or excluded from the Chattanooga PM2.5 nonattainment area. Adjacent counties with significant emissions include McMinn and Roane Counties which are attached to the Knoxville nonattainment area and Floyd County which is a separate nonattainment area. Additionally we have included in our recommended nonattainment area Jackson County, AL, that is adjacent to the Chattanooga MSA, that is generally rural in character, and that contains an identifiable large emitting facility or facilities (e.g., power plants) which we believe contribute to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment. Therefore EPA is modifying the States’ recommendations to include all of the counties in the MSA and the adjacent county of Jackson, Alabama.

Area EPA Recommendation States Recommendations Chattanooga Full counties: Marion, Hamilton, TN; Dade, Walker, Catoosa, GA; Jackson, AL Full counties: Hamilton and Walker

### 6-179 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Chattanooga MSA and some adjacent counties. (MSA counties are in bold.)

County PM SOx NOx VOC Amm Weighted Emissions

Score Cumulative Weighted Emissions

Score Hamilton 1,498 5,300 20,04827,150 1,022 49.5 49.5 Walker 856 632 2,798 4,516 958 17.9 67.4 Marion 679 477 3,156 2,640 501 14.1 81.5 Catoosa 617 167 3,085 3,601 680 11.9 93.4 Dade 302 107 2,415 1,574 285 6.5 99.9 Roane 4967 92331 30865 4300 285 296.9 Jackson, AL 4389 44333 31502 4742 1494 176.1 Floyd, GA 10057 31821 22736 7139 976 154.0 McMinn 3348 10216 10829 5546 1268 73.3 Whitfield, GA2732 1747 7283 7386 991 54.2 Rhea 1405 302 2625 3643 149 31.2 Loudon 804 4035 5899 5338 360 24.3 DeKalb, AL 1193 741 4776 5867 5765 21.3 Bradley 1233 419 4230 7551 1916 21.1 Warren 1164 1189 1869 3675 446 20.7 Monroe 743 154 2387 3420 554 16.4 Gordon, GA 872 200 3645 4019 2630 15.8 Fannin, GA 614 65 887 1266 283 14.2 Franklin 644 482 2100 2929 1512 13.4 Chattooga, GA450 1228 1834 1634 197 11.7 Murray, GA 576 130 2067 1700 910 11.4 Polk 295 2066 900 949 553 11.3 Cherokee, NC428 143 921 1753 111 10.6 Grundy 202 164 1000 1150 1170 4.8 Bledsoe 203 31 475 528 335 4.5 Meigs 198 112 885 871 118 4.3 Sequatchie 140 22 304 591 173 3.4 Van Buren 118 178 291 320 74 3.3 

### Based on the analysis for this factor there appears to be emissions in all MSA counties and the adjacent county of Jackson, AL, which show a potential to contribute. Other adjacent counties with large emissions (McMinn and Roane, TN and Floyd, GA) are included in other nonattainment areas.

### 6-180 Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001-2003 PM2.5 Design Values for all Chattanooga MSA Counties and adjacent counties. (MSA counties are in bold.)

County 2001-2003 design value
Hamilton 16.1 Walker 15.6 Roane 14.2 Floyd, GA 15.7 McMinn 14.6 Loudon 15.4 * DeKalb, AL 14.7 

### * Incomplete data that is not sufficient to determine attainment/nonattainment. Data substitution does not apply. Based on this factor, Hamilton County, TN and Walker and Floyd Counties in GA are violating the PM 2.5 standard. Catoosa County, GA is located between violating monitors in Hamilton and Walker Counties. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Chattanooga MSA and some adjacent counties. Urban population figures were not available. (MSA counties are in bold.) County 2002 Population Percent of MSA Population (2002) 2002 Population Density (people/mile^2) Hamilton 309,321 65.7 570 Walker 61,949 13.2 139 Marion 27,654 5.9 55 Catoosa 56,341 12.0 348 Dade 15,615 3.3 90 Roane 52,316 145 Jackson, AL 54,035 50 Floyd, GA 92,606 181 McMinn 50,051 116 Whitfield, GA 87,037 300 

### Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by the following MSA counties: Hamilton, Walker, and Catoosa. The five adjacent counties also have population with a potential to contribute. Factor 4: Traffic and commuting patterns Commuting Information:

### 6-181 Hamilton has a working population of 146, 824 –Commuters who remain in Hamilton: 133,644 (91%) Marion has a working population 11766. –Commuters who remain in Marion: 5596 (48%) –Commuters from Marion to Hamilton: 4271 Dade has a working population of 6983. –Commuters who remain in Dade: 2363 –Commuters from Dade to Hamilton:3091 (44%) –Commuters from Dade to Walker: 747 Catoosa has a working population of 26710. –Commuters who remain in Catoosa: 7167 –Commuters from Catoosa to Hamilton: 12320 (46%) –Commuters from Catoosa to Walker:1937 Walker has a working population of 27223. –Commuters who remain in Walker: 11244 (41%) –Commuters from Walker to Hamilton: 9098 Whitfield, GA has a working population of 38,909 –Commuters who remain in Whitfield: 33,796 (87%) –Remaining commuters do not commute to the Chattanooga MSA DeKalb, AL has a working population of 7798 –Commuters who remain in DeKalb: 5179 (66%) –Remaining commuters do not commute to the Chattanooga MSA The following table contains the vehicle miles traveled (thousand miles) for the counties in the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are in bold.) County 2002 VMT (thousand miles/year) Hamilton 3,743 Walker 742 Marion 654 Catoosa 810 Dade 512 Roane 784 Jackson, AL 786 Floyd, GA 948 McMinn 787 Whitfield, GA 1423

### 6-182 Based on the analysis for this factor the VMT for all MSA counties indicate a potential to contribute. Although Whitfield County has a relatively high VMT, none of the commuters go to the Chattanooga MSA. Factor 5: Population Growth The following table has the population and population growth figures for the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are in bold.)

County 2002 Population Growth (90-00) % Growth (90-00) Hamilton 309,321 22360 8 Walker 61,949 2713 5 Marion 27,654 2916 12 Catoosa 56,341 10818 25 Dade 15,615 2007 15 Roane 52,316 4683 10 Jackson, AL 54,035 6130 13 Floyd, GA 92,606 9314 11 McMinn 50,051 6632 16 Whitfield, GA 87,037 11063 15 

### Based on the analysis for this factor, there appears to be significant growth on a percentage basis in Catoosa County that indicates a contribution to the air quality in the Chattanooga MSA. Factor 6: Meteorology This factor did not constitute a significant role in the decision making process. Factor 7: Geography/topography The Chattanooga area does not have any geographical or topographical boundaries limiting its airshed. This factor did not constitute a significant role in the decision making process.
Factor 8: Jurisdictional boundaries Hamilton and Meigs Counties, TN and Catoosa County, GA were designated nonattainment for the 8-hour ozone standard on April 15, 2004. This factor did not constitute a significant role in the decision making process.
Factor 9: Level of control of emission sources Sources in the Chattanooga area are subject to Prevention of Significant Deterioration (PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology (CTG

### 6-183 RACT) - (Hamilton County only), Maximum Achievable Control Technology (MACT) for Hazardous Air Pollutants (HAP), New Source Performance Standards (NSPS), and the NOx SIP call. This factor did not constitute a significant role in the decision making process. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendations on June 29,2004, included Dade County as part of the Chattanooga nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and designating Dade County as attainment/unclassifiable. Dade County: Dade County emissions in tons per year and percent of MSA are: PM (302/8%), SO2 (107/1.6%), NOx (2,415/7.7%), and VOC (1,574/4%). These are the lowest emissions of any county in the MSA. Dade County contains no major point sources of precursor emissions, has the lowest population in the MSA (15,615), and low population density 90 people/square mile. Dade County constitutes approximately 3 percent of the total MSA commuters. Dade County contains no monitor. In addition, the State’s topography analysis indicates that the Lookout Mountain Ridge (2,100 feet) separates the low level emissions in Dade County from the violating monitors. The County is located to the west of the ridge, while the violating monitors reside to the east of the ridge. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Chattanooga, TN-GA area: Catoosa and Walker.
6.4.2.5 Columbus Area MSA The following is the 9 factor analysis for Columbus MSA and surrounding Counties. Alabama’s submittal in February 2004, recommended that Russell County be designated nonattainment for the fine particulate matter (PM2.5), based on 2001 - 2003 monitoring data. Georgia’s submittal in June 2004, recommended that Harris, Muscogee and Chattahoochee Counties be designated attainment for PM2.5. Based on the following analysis EPA recommends that Lee and Russell counties in Alabama, and Harris, and Muscogee Counties in Georgia, should be included in the PM2.5 nonattainment area. Lee County is adjacent to the MSA, has high VMT and a large population. Russell County has a violating monitor and the State recommended it as nonattainment. Harris County has relatively high NOx and VOC emissions and relatively high VMT. Muscogee County has high NOx and VOC emissions, high VMT and a large population. Based on the following analysis, EPA agrees with the recommendation that Barbour, Chambers, Montgomery, Elmore and Tallapoosa Counties in Alabama, and Chattahoochee, Troup, Stewart,

### 6-184 Meriwether, Sumter Counties in Georgia, should be attainment/unclassifiable for PM2.5 based on low emissions, low VMT and low population.

Area EPA Recommendation State Recommendation Columbus, GA Full counties: Lee and Russell Counties in Alabama and Harris and Muscogee Counties in Georgia Full counties: Russell County, Alabama



### 9 Factor Analysis for the Columbus, Georgia MSA Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5

### , SO2

### , NOx, VOC, and NH3 emissions in tons, and weighted emissions scores for the Columbus Area and surrounding counties. The MSA counties are in bold

. Columbus MSA and Surrounding Counties Emissions County PM SO2 NOXVOCNH3Weighted Emissions

Score Cumulative Weighted Emissions

Score Russell, AL 1,344 2,550 5,7184,43417935.1 35.1 Harris, GA 590 104 2,8561,74812826.8 61.9 Muscogee, GA 513 803 5,9659,47632325.4 87.3 Chattahoochee, GA 208 43 387 482 1512.7 100 Troup, GA 1,194422 12,2778,22338248.7 Montgomery, AL 1,421 6,292 10,45414,96697343.3 Lee, AL 1,043 1,425 5,1257,47433342.8 Barbour, AL 874 419 2,2082,52949741.6 Sumter, GA 2,578 1,725 1,7262,26284740.5 Meriwether, GA 844 190 1,8663,00616733.7 Elmore, AL 1,014 517 4,4434,36832630.8 Tallapoosa, AL 679 655 1,9933,23026326.5 Chambers, AL 579 527 2,3502,88212423.9 Stewart, GA 429 32 360 464 18923.3 Taylor, GA 398 76 966 622 83318.3 Macon, AL 412 223 2,2421,87113317.1 Talbot, GA 288 70 903 520 74 15.9 Marion, GA 314 32 328 517 47015.4 Bullock, AL 273 93 407 570 21412.7 Webster, GA 303 128 358 201 11412.6 Schley, GA 192 14 195 290 1638.4 

### Based on the analysis for this factor, there appear to be emissions in Lee County, Alabama, that contribute to the violation in Russell County.

### 6-185 Factor 2:Air quality in potentially included versus excluded areas. Columbus MSA and Surrounding Counties Design Value (DV) County 2001-2003 DV Russell, AL 15.3 Muscogee, GA 14.7 Montgomery, AL 14.2 

### Muscogee and Montgomery Counties have monitors that show attainment of the PM2.5 standard while Russell County is violating the standard. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas. The following table has the populations for the Counties in the Columbus MSA and adjacent Counties

. 

### Columbus MSA and Surrounding Counties Population & Area County Population20 02 Percent in MSA Population Density 2002 Russell, AL 49,415 18 77 Harris, GA 25,092 9 54 Muscogee, GA 185,948 67 861 Chattahoochee, GA 15,440 6 62 Troup, GA 59,767 144 Montgomery, AL 223,346 283 Lee, AL 118,123 194 Barbour, AL 28,826 33 Sumter, GA 33,247 69 Meriwether, GA 22,623 45 Elmore, AL 68,771 111 Tallapoosa, AL 40,946 57 Chambers, AL 36,251 61 Stewart, GA 5,040 11 

### Lee County is adjacent to Russell County and its population (118,123) is about two and half times that of Russell County (49,415). Factor 4: Traffic and commuting patterns Commuting Information: Russell County, AL has a total of 19,859 commuters. - Commuters who remain in Russell County 7,051(36%) Harris County, GA has a total of 11,811 commuters. - Commuters from Lee County to Russell County 214 (2%)

### 6-186 - Commuters who remain in Harris County 2,867 (24%) Muscogee County, GA has a total of 82,977 commuters. - Commuters from Muscogee County to Russell County 2,479 (3%) - Commuters who remain in Muscogee County 71,862 (87%) Chattahoochee County, GA has a total of 8,538 commuters. - Commuters who remain in Chattahoochee County 5,482 (64%) Troup County, GA has a total of 26,339 commuters. - Commuters who remain in Troup County 22,074 (84%) Montgomery County, AL has a total of 96,943 commuters. - Commuters who remain in Montgomery County 90,943 (94%) Lee County, AL has a total of 52,119 commuters. - Commuters who remain in Lee County 35,549 (68%) - Commuters from Lee County to Russell County 2,682 (5%) Barbour County, AL has a total of 10,023 commuters. - Commuters who remain in Barbour County: 8,370(84%) - Commuters from Lee County to Russell County 335 (3%) Sumter County, GA has a total of 13,963 commuters. - Commuters who remain in Sumter County 11,652(83%) Meriwether County, GA has a total of 8,893 commuters. - Commuters who remain in Meriwether County 4,114 (46%) Elmore County, AL has a total of 28,143 commuters. - Commuters who remain in Elmore County 9,415 (33%) Tallapoosa County, AL has a total of 17,009 commuters. - Commuters who remain in Tallapoosa County 12,125 (71%) Chambers County, AL has a total of 15,480 commuters. - Commuters who remain in Chambers County 9,281 (60%) Stewart County, GA has a total of 1, 892 commuters. - Commuters who remain in Stewart County 965 (51%) There are no Counties that have significant commuters commuting toRussell County.

### 6-187 Columbus MSA and Surrounding Counties VMT County VMT 2002VMT Growth 02-10 Russell, AL 671 276 Harris, GA 547 -207 Muscogee, GA 1,594 534 Chattahoochee, GA 56 160 Troup, GA 1,454 -839 Montgomery, AL 2,565 642 Lee, AL 1,119 457 Barbour, AL 431 -129 Sumter, GA 405 -62 Meriwether, GA 271 138 Elmore, AL 615 168 Tallapoosa, AL 502 -56 Chambers, AL 378 -44 Stewart, GA 75 47 

### Over 50% of the VMT in the MSA is in Muscogee County, Georgia. As noted above, none of the adjacent Counties have appreciable commuting into the MSA. Factor 5: Expected growth The following table has the population and population growth figures for the Columbus MSA and surrounding Counties
. Columbus MSA and Surrounding Counties Population/Growth County Population 2002 Growth 90-00 Percent Growth Russell, AL 49,415 2,896 6 Harris, GA 25,092 5,907 33 Muscogee, GA 185,948 7,013 4 Chattahoochee, GA 15,440 -2,052 -12 Troup, GA 59,767 3,243 6 Montgomery, AL 223,346 14,425 7 Lee, AL 118,123 27,946 32 Barbour, AL 28,826 3,621 14 Sumter, GA 33,247 2,972 10 Meriwether, GA 22,623 123 1 Elmore, AL 68,771 16,664 34 Tallapoosa, AL 40,946 2,649 7 Chambers, AL 36,251 -293 -1 Stewart, GA 5,040 -402 -7 

### Harris County, Georgia has large growth on a percentage basis. Factor 6: Meteorology.

### 6-188 A wind analysis using wind data from the Columbus, Georgia Airport was completed to evaluate the predominant wind direction(s) in Phenix City over the 3-year period on all days. There is a large easterly component to the winds during the 3-year time period., but there is not sufficient information to use meteorology as a deciding factor for an annual average.. Factor 7: Geography/topography This factor did not constitute a significant role in the decision making process.
Factor 8 Jurisdictional boundaries. This factor did not constitute a significant role in the decision making process.
Factor 9 Level of control of emission sources. Reasonable Available Control Technology for VOC has been in place since 1979 Stage 1 Vapor Recovery has been in place since 1990 NOx SIP Call requires large reductions in NOx emissions from major utilities, large industrial boilers, gas turbines and cement kilns (seasonal for Macon, Tallapoosa, Chambers, Elmore and Lee Counties). Tier II National Fuel Standard (starting 2004) Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendations on June 29, 2004, included the Counties of Lee in Alabama and Harris in Georgia as part of the Columbus, GA nonattainment area. Upon further review of additional information provided by the states, EPA is revising its recommendation and is designating Lee County, AL and Harris County, GA as attainment/unclassifiable. Harris County: Harris County, Georgia, is being designated attainment/unclassifiable because it has low population in the MSA which is only 9% (25,092) as compared to 185,948 in Muscogee County, the most populated County. Only 214 of Harris County commuters commute into Russell County, where the violating monitor is located, and it has low VMT (547,000) as compared to 1,594,000 in Muscogee. Harris County has no major point sources of precursor emissions and comparatively low emissions of 590 tons of PM, 104 tons of SO2, and 2,856 tons of NOx. We considered the data in the request for spatial averaging for the Columbus area, which was denied, while evaluating the other factors and determined that Harris County is not contributing to the violations.

### 6-189 Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Columbus, GA-AL area:Muscogee. 6.4.2.6 Augusta Area On February 13, 2004, the State of Georgia submitted to EPA their PM 2.5 nonattainment recommendations. Georgia recommended only counties which contained a monitored violation and provided no further justification. On June 15, 2004, the State submitted additional information and revised recommendations for the Augusta area. The revision recommended that Richmond County be unclassifiable. Richmond County has two PM2.5 monitors with air quality data for 2001-2003. The data for one monitor demonstrates attainment and the other monitor has incomplete data for 2001-2003 that was violating. EPA’s analysis of all the available monitoring data indicates that the area should be designated as attainment/unclassifiable. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as attainment/unclassifiable for the Augusta, GA area: Richmond.
6.4.3EPA 9-Factor Analyses for Kentucky for the Designation of PM2.5 Nonattainment Areas
6.4.3.1 Cincinnati-Hamilton Area The MSA contains the Kentucky Counties of Boone, Campbell, Kenton, Grant, Pendleton, Gallatin; the Ohio Counties of Hamilton, Clermont, Butler, Warren, Brown; and the Indiana Counties of Dearborn and Ohio. The following counties are violating the PM2.5 standard: Hamilton County, Ohio; Butler County, Ohio; and Montgomery County, Ohio. In February 2004, Kentucky recommended that all Kentucky counties in the Cincinnati-Hamilton MSA be designated attainment for the PM2.5 standard. EPA is modifying Kentucky’s recommendation to include Boone, Campbell and Kenton Counties in the Cincinnati-Hamilton nonattainment area. Boone County has significant emissions, relatively high population growth, and a large (>10,000 tons per year SO2) power plant located in the County. Campbell and Kenton Counties have significant VMT, significant numbers of commuters into violating Hamilton County, and both counties part of the Cincinnati 1-hour ozone nonattainment area due to violating monitors. Kenton County also has monitoring data close to the standard. EPA agrees that the remaining KY MSA counties of Gallatin, Grant, and Pendleton should be designated as attainment/unclassifiable due to low emissions, very low population relative to the area, and very low numbers of commuters into the violating counties.

### 6-190 EPA agrees that the adjacent counties of Carroll and Mason should be designated attainment/classifiable for the PM2.5 standard, although they have significant emissions due to power plants. These counties have relatively low populations, low population growth, and low VMT . Further, their commuting patterns and distance from the violating monitors indicate that these counties do not contribute to the violations in the area. The other adjacent counties do not contribute and therefore, will be designated as attainment/unclassifiable.

Area EPA Recommendation State Recommendation Cincinnati-Hamilton, OH-KY-IN Full counties: Boone County Campbell County Kenton County Full counties: none



### The following is a brief summary of the nine criteria for the Cincinnati-Hamilton, OH-KY-IN area. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Cincinnati-Hamilton MSA and surrounding counties. (MSA counties are in bold; Kentucky MSA counties inbold italics.)

County PM SOx NOx VOC Amm Score Cum. Score Hamilton, OH 7,601 88,053 58,398 47,014 2,422 30.3 30.3 Clermont, OH 6,443 84,599 45,618 7,638 326 20.0 50.3 Dearborn, IN 3581 56,773 31,138 3,732 246 11.4 61.7 Butler, OH 3,153 13,204 19,735 14,228 1,363 9.9 71.6 Boone, KY 1,946 14,717 15,794 6,644 256 7.7 79.3 Warren, OH 1,844 895 7,565 7,003 417 6.9 86.2 Kenton, KY 741 1,573 8,365 7,392 285 4.2 90.4 Campbell, KY 590 860 5,294 4,421 267 2.8 93.2 Brown, OH 748 395 2,927 1,995 294 2.0 95.2 Grant, KY 381 210 2,664 1,364 257 1.8 97.0 Pendleton, KY 363 597 3,396 900 186 1.5 98.5 Gallatin, KY 367 350 2,365 904 192 1.0 99.5 Ohio, IN 142 113 682 380 238 0.5 100.0 Adams, OH 6,417 125,136 52,992 1,508 431 19.4 N/A Montgomery, OH 2,542 11,214 24,177 28,598 1,170 12.2 N/A Carroll, KY 3,547 53,086 26,269 3,249 159 10.3 N/A Mason, KY 2,316 38,142 16,071 1,640 520 7.0 N/A Greene, OH 1,516 1,895 8,841 5,827 538 4.0 N/A Preble, OH 963 428 2,765 2,638 762 2.2 N/A Ripley, IN 743 140 2,081 3,519 796 2.0 N/A Scott, KY 627 260 3,629 6,041 481 2.0 N/A Fayette, OH 883 309 2,136 2,100 310 1.9 N/A Decatur, IN 922 154 2,525 3,876 1,538 1.8 N/A Clinton, OH 788 375 2,490 2,572 329 1.8 N/A Rush, IN 1,003 140 1,274 1,839 1,227 1.6 N/A

### 6-191 Highland, OH 687 242 1,756 2,089 373 1.6 N/A Fayette, IN 561 150 1,426 2,609 387 1.4 N/A Franklin, IN 491 92 1,335 1,634 664 1.3 N/A Harrison, KY 354 290 1,786 1,158 303 1.1 N/A Owen, KY 236 57 572 566 245 1.1 N/A Switzerland, IN 257 251 1,554 776 364 1.0 N/A Bracken, IN 174 52 570 479 134 0.7 N/A Union, IN 343 58 548 705 266 0.6 N/A Robertson, KY 74 12 112 107 65 0.3 N/A 

### Based on the analysis for this factor for Kentucky only, Boone, Carroll, and Mason Counties have significant emissions which could indicate a potential emissions contribution to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties listed in this table. Factor 2: Air quality in potentially included versus excluded areas The following table contains the design value for the MSA and adjacent counties that contain PM2.5 monitors. Design values followed by “a” indicate that the value is based on incomplete monitoring data. (MSA counties are in bold; Kentucky MSA counties inbold italics.)

County 2001-2003 design value Hamilton, OH 17.8 Butler, OH 16.2 Kenton, KY 15.0 Campbell, KY 14.5 Montgomery, OH 15.2 Greene, OH 9.5a Preble, OH 13.5a 

### Based on an analysis of this factor for Kentucky only, the Campbell and Kenton County monitors are attaining. The Kenton County monitor reading of 15.0 indicates that there may be a potential emissions contribution from the County to the area. This factor is not significant for the remaining Kentucky counties. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Cincinnati-Hamilton MSA and some adjacent counties with violating monitors and those with significant emissions. The total MSA 2002 population is 2,009,679. (MSA counties are in bold; Kentucky MSA counties in bold italics.) County 2002 Population Percent of Population of MSA 2002 Population Density Hamilton, OH 833,721 41.49 2,048 Clermont, OH 183,352 9.12 406 Dearborn, IN 47,333 2.36 155

### 6-192 Butler, OH 340,543 16.95 729 Boone, KY 93,290 4.64 379 Warren, OH 175,133 8.71 438 Kenton, KY 152,164 7.57 934 Campbell, KY 88,604 4.41 583 Brown, OH 43,464 2.16 88 Grant, KY 23,620 1.18 91 Pendleton, KY 14,815 0.74 53 Gallatin, KY 7,836 0.39 79 Ohio, IN 5,804 0.29 67 Adams, OH 27,804 48 Montgomery, OH 554,470 1,200 Carroll, KY 10,223 79 Mason, KY 16,916 70 

### Based on the analysis for this factor, the populations for the Kentucky counties are much smaller than those in the Ohio Counties of Hamilton, Butler, and Montgomery. The Kentucky Counties of Boone, Kenton, and Campbell have population values of some significance as compared to the much smaller MSA Kentucky Counties of Grant, Gallatin, and Pendleton. This factor is not significant for the remaining Kentucky counties in this table. Factor 4: Traffic and commuting patterns Commuting Information Total number of workers in Boone County, KY: 44,507 Commuters in Boone County, KY who work in Boone County, KY: 23,589 (53%) Commuters from Boone County, KY to Hamilton County, OH: 8,351 (19%) Commuters from Boone County, KY to Butler County, OH: 641 (1%) Total number of workers in Kenton County, KY: 76,169 Commuters in Kenton County, KY who work in Kenton County, KY: 30,771 (40%) Commuters from Kenton County, KY to Boone County, KY: 17,053 (22%) Commuters from Kenton County, KY to Hamilton County, OH: 20,200 (27%) Commuters from Kenton County, KY to Butler County, OH: 908 (1%) Total number of workers in Campbell County, KY: 42,820 Commuters in Campbell County, KY who work in Campbell County, KY: 15,474 (36%) Commuters from Campbell County, KY to Boone County, KY: 4,062 (9%) Commuters from Campbell County, KY to Hamilton County, OH: 14,946 (35%) Commuters from Campbell County, KY to Butler County, OH: 652 (2%) Total number of workers in Gallatin County, KY: 3,589 Commuters in Gallatin County, KY who work in Gallatin County, KY: 1,317 (37%) Commuters from Gallatin County, KY to Boone County, KY: 1,038 (29%) Commuters from Gallatin County, KY to Hamilton County, OH: 196 (5%) Total number of workers in Grant County, KY: 10,262

### 6-193 Commuters in Grant County, KY who work in Grant County, KY: 4,181 (41%) Commuters from Grant County, KY to Boone County, KY: 2,852(28%) Commuters from Grant County, KY to Hamilton County, OH: 716 (7%) Total number of workers in Pendleton County, KY: 6,467 Commuters in Pendleton County, KY who work in Pendleton County, KY: 2,482 (38%) Commuters from Pendleton County, KY to Boone County, KY: 789 (12%) Commuters from Pendleton County, KY to Hamilton County, OH: 785 (12%) Commuters from Pendleton County, KY to Butler County, OH: 101 (2%) Total number of workers in Carroll County, KY: 4,466 Commuters in Carroll County, KY who work in Carroll County, KY: 3,475 (78%) Commuters from Carroll County, KY to Boone County, KY: 54 (1%) Commuters from Carroll County, KY to Hamilton County, OH: 48 (1%) Total number of workers in Mason County, KY: 7,560 Commuters in Boone County, KY who work in Boone County, KY: 5,978 (79%) Commuters from Mason County, KY to Hamilton County, OH: 95 (1%) A notable number of commuters from Kenton and Campbell Counties commute into violating Hamilton County. Although these numbers are far less than the number of commuters in Hamilton County, in conjunction with VMT data analyzed below, they indicate some potential for contributing to the mobile source emissions in the area. Although 47% of Boone’s 44,507 workers commute into other counties in the MSA, a relatively small number commute into the violating counties. In Carroll County, 78% of the 4,466 workers commute within the County. Similarly, in Mason County, 79% of the 7,560 workers commute within the County. Thus, onroad mobile source emissions from commuting patterns for Boone, Carroll, and Mason Counties do not appear to be contributing to violations in the area. This factor is not significant for the remaining Kentucky counties listed above. Vehicle Miles Traveled: The following table has the vehicle miles traveled (thousand miles) for the counties in the Cincinnati-Hamilton MSA and some adjacent counties with significant emissions. (MSA counties are in bold; Kentucky MSA counties inbold italics.)

County 2002 VMT (thousand miles/year) Hamilton, OH 8,420 Clermont, OH 1,649 Dearborn, IN 607 Butler, OH 2,610 Boone, KY 842 Warren, OH 1,354 Kenton, KY 1,816 Campbell, KY 1,097

### 6-194 Brown, OH 417 Grant, KY 379 Pendleton, KY 169 Gallatin, KY 254 Ohio, IN 56 Adams, OH 283 Montgomery, OH 5,668 Carroll, KY 213 Mason, KY 178 

### Based on an analysis of this factor for Kentucky only, the VMT for Boone, Kenton, and Campbell Counties are in the relatively moderate to high range as compared to the counties listed above, with the exception of the the violating Ohio counties of Hamilton, Butler, and Montgomery. Boone, Kenton, and Campbell VMT data indicate some potential to contribute to the PM2.5 violations in the area. VMT values for Carroll and Mason are very low and do not indicate a potential contribution. This factor is not significant for the remaining Kentucky counties listed in this table. Factor 5: Expected growthThe following table has the population and population growth figures for the CincinnatiHamilton MSA and some adjacent counties with significant emissions. (MSA counties are in bold; Kentucky MSA counties inbold italics.)

County 2002 Population growth (90-00) % growth (90-00) Hamilton, OH 833,721 -20,925 -2 Clermont, OH 183,352 27,790 19 Dearborn, IN 47,333 7,274 19 Butler, OH 340,543 41,328 14 Boone, KY 93,290 28,402 49 Warren, OH 175,133 44,474 39 Kenton, KY 152,164 9,433 7 Campbell, KY 88,604 4,750 6 Brown, OH 43,464 7,319 21 Grant, KY 23,620 6,647 42 Pendleton, KY 14,815 2,354 20 Gallatin, KY 7,836 2,477 46 Ohio, IN 5,804 308 6 Adams, OH 27,804 1,959 8 Montgomery, OH 554,470 -14,747 -3 Carroll, KY 10,223 863 9 Mason, KY 16,916 134 1 

### While the Kentucky Counties of Boone, Grant, and Gallatin have the highest population growth rates from 1990-2000 than all of the counties in the MSA, only Boone County’s resulting population increase of 28,402, (third highest increase in the MSA), is significant enough to indicate a potential to contribute to violations in the area. The population growth rates of Carroll and Mason Counties are relatively very low and thus, do not indicate a potential to contribute to

### 6-195 the area’s violations. This factor is not significant for the remaining Kentucky counties listed in this table. Factor 6: Meteorology The following meteorological information was provided by Kentucky for the MSA Kentucky Counties of Boone, Campbell, Kenton, Gallatin, Pendleton, and Grant. (The figure referenced is a wind rose for April 1-October 31 for the 1988-1992 period that is provided in Kentucky’s PM2.5 recommendations submittal.) Meteorological Information “Due to the close proximity of Cincinnati, Ohio, meteorological data from Cincinnati was used for this Kentucky area. Wind speed/wind direction information shows that the majority of the time for the period 1988–1992, the wind in the...County area came from the southwest and typically from 7- 10 knots. (See figure 1-A) The mean high temperature for July for the area from 1961 through 1990 was 86EF, the mean low was 66EF. The mean precipitation for the same period was 3.8 inches.”(Source: Kentucky PM2.5 submittal) Based on an analysis of this factor, the information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds. This information was provided only for the summertime winds. Factor 7: Geography/topography Based on an analysis of this factor, there are no significant topographical issues associated with this MSA. For the adjacent Carroll and Mason Counties in Kentucky with significant emissions, both counties are two counties removed from the nearest county with a violating monitor (Hamilton, Ohio), with attaining monitors in between in Kenton and Campbell Counties in Kentucky.
Factor 8: Jurisdictional boundaries The following MSA counties were designated nonattainment for the 8-hour ozone standard on April 15, 2004: the Kentucky Counties of Boone, Campbell, and Kenton; the Indiana County of Dearborn; and the Ohio Counties of Hamilton, Clermont, Butler, Warren, Montgomery, Greene, Clinton. This factor did not play a significant role in the decision-making process.
Factor 9: Level of control of emission sources The following information was provided by Kentucky for Boone, Campbell, Kenton, Grant, Gallatin and Pendleton Counties. “Point sources located within...County are subject to PSD requirements, CTG RACT requirements, Maximum Achievable Control Technology (MACT) requirements for sources of Hazardous Air Pollutants, and New Source Performance Standards (NSPS). Any controls imposed as a result of previous nonattainment designations are required to remain in...County.”

### 6-196 For Boone County only: “Additionally, substantial NOx reductions have occurred during the last year from East Bend Power Plant which would further lower the contribution of NOx emissions from Boone County.” This factor did not play a significant role in the decision-making process. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to StatesNo Changes Made to June 29, 2004, Recommendations.

Boone County, KY: Boone County contains one major point source, the Cinergy East Bend (Cincinnati Gas & Electric) power plant. Kentucky provided the following information on controls at this facility: scrubber with 85% control efficiency; ESP with > 99% control efficiency; and low NOx burners and SCR with annual efficiency 69%. NOx controls have been in place since 2002. The NOx SCR controls are seasonal. The installation of SCR in 2002 gained 2,534 tpy of NOx reductions.

Corrections to TSD for Cincinnati-Hamilton MSA:
6.4.3.1- Factor 1: The following corrections are made to the third paragraph in this section as follows: Insert redlined phrase: “...and both counties were previously designated part of the Cincinnati 1-hour ozone nonattainment area...” Add an “s” to: “...very low populations relative to the area...”
6.4.3.1 - Factor 2: The 2001-2003 design values in the Factor 2 table for Campbell and Kenton Counties are corrected to read as follows:

County 2001-2003 design value Kenton, KY 14.9 Campbell, KY 13.9 

### 6.4.3.1- Factor 4: The following correction is made to the section, “Commuting Information,” for Mason County:

### 6-197 Replace “Boone” with “Mason” as noted: “Commuters in MasonBooneCounty, KY who work in MasonBooneCounty, KY...” Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Cincinnati–Hamilton, OH-KY-IN area: Boone, Campbell, and Kenton.

6.4.3.2 Louisville Area The Louisville MSA contains the Kentucky Counties of Jefferson, Bullitt, and Oldham; and the Indiana Counties of Floyd, Clark, Harrison, and Scott. Jefferson County, Kentucky and Clark County, Indiana are violating the PM2.5 standard. The adjacent Kentucky County of Carroll has relatively high emissions for the area, however, it was evaluated as part of the Cincinnati area. In February 2004, Kentucky recommended that Jefferson County be designated nonattainment and that Bullitt and Oldham Counties be designated attainment for the PM2.5 standard for the Louisville MSA. EPA agrees that the Kentucky MSA County of Oldham be designated attainment/unclassifiable due to low emissions and relatively low population. EPA agrees that Jefferson County be designated nonattainment due to four violating monitors in the County and is modifying Kentucky’s recommendation to include Bullitt County in the Louisville nonattainment area due to a relatively high number of commuters into violating Jefferson County, a monitored PM2.5 value of 15.0 that is very close to the standard, and relatively high population growth. EPA agrees that the adjacent counties should be designated as attainment/unclassifiable due to low population growth, a low percentage of workers commuting into the Louisville MSA, relatively low emissions, and large distance from the violating monitors in the area.

Area EPA Recommendation for KY State Recommendation Louisville, KY Full counties: Jefferson County Bullitt County Full counties: Jefferson


### The following is a brief summary of the nine criteria for the Louisville, KY area. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Louisville MSA and surrounding counties. (MSA counties are inbold; Kentucky MSA counties inbold italics.)

County PM SOx NOx VOC Amm Score Cum. Score

### 6-198 Jefferson, KY 7,385 62,52681,398 55,376 1,539 51.5 51.5 Floyd, IN 3,826 47,796 10,282 4,789 346 16.4 67.9 Clark, IN 1,612 484 4,960 7,125 498 12.2 80.1 Bullitt, KY 829 343 3,463 5,817 210 7.3 87.4 Harrison, IN 794 419 3,677 2,702 2,632 5.3 92.7 Oldham, KY 770 529 3,707 2,168 224 4.7 97.4 Scott, IN 397 100 1,515 2,426 318 2.6 100.0 Carroll, KY 3,547 53,08626,269 3,249 159 15.2 Jefferson, IN 2,247 39,599 33,990 2,921 302 11.2 Hardin, KY 1,207 1,774 7,695 6,713 1,114 9.1 Lawrence, IN 1,544 4,330 5,707 3,330 543 6.5 Jackson, IN 919 260 3,427 4,721 898 5.8 Nelson, KY 781 497 2,134 7,923 1,147 5.0 Trimble, KY 869 7,998 8,458 520 182 4.6 Breckinridge, KY 566 321 2,592 1,273 757 4.4 Grayson, KY 593 412 1,532 1,796 1,166 4.0 Meade, KY 692 661 4,551 2,272 556 4.0 Shelby, KY 699 397 2,906 2,778 842 4.0 Franklin, KY 506 601 3,059 4,396 217 3.8 Jennings, IN 640 233 1,589 2,274 256 3.5 Perry, IN 518 789 3,102 2,018 403 3.4 Hart, KY 391 162 1,839 1,499 662 3.2 Washington, IN 580 136 1,452 2,448 3,468 3.1 Taylor, KY 408 632 3,642 1,609 461 3.1 Crawford, IN 319 536 3,842 1,237 192 2.9 Orange, IN 475 86 2,017 2,599 313 2.9 Anderson, KY 335 443 1,535 2,648 164 2.5 Marion, KY 381 143 801 1,400 775 2.5 Henry, KY 424 156 1,465 1,246 420 2.1 Owen, KY 236 57 572 566 245 2.1 Larue, KY 294 186 768 646 573 1.8 Washington, KY273 115 618 1,051 584 1.8 Green, KY 261 104 507 586 331 1.7 Spencer, KY 281 31 393 574 221 1.7 

### Based on the analysis for this factor for Kentucky only, the Kentucky Counties of Jefferson and Carroll have significant emissions. Bullitt County has emissions with a potential to contribute to the PM2.5 violations in the area.This factor is not significant for the remaining Kentucky counties listed in this table.

### 6-199 Factor 2: Air quality in potentially included versus excluded areas

County 2001-2003 design value Jefferson, KY 16.9 Floyd, IN 14.9 Clark, IN 16.2 Bullitt, KY 15.0 Franklin, KY 13.6 Hardin, KY 14.1 

### There are four counties in the MSA with PM2.5 monitors, two of which have violating design values (Jefferson County, Kentucky and Clark, Indiana). Bullitt County, Kentucky has an attaining monitor whose design value is close to the standard (15.0), which indicates that there is a potential to contribute to the PM2.5 violations in area. The adjacent Kentucky Counties of Hardin and Franklin are monitoring attainment and thus, do not indicate emissions contributions. This factor is not significant for the remaining Kentucky counties listed in this table. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Louisville MSA and adjacent counties with significant emissions. The total MSA 2002 population is 1,039,599. (MSA counties are inbold; Kentucky MSA counties are inbold italics.) County 2002 Population % of MSA Population (%) Population Density Jefferson, KY 698,080 67.15 1,813 Floyd, IN 71,633 6.89 484 Clark, IN 98,198 9.45 262 Bullitt, KY 63,800 6.14 213 Harrison, IN 35,244 3.39 73 Oldham, KY 49,310 4.74 261 Scott, IN 23,334 2.24 123 Hardin, KY 95,724 N/A 152 

### Based on the analysis for this factor for Kentucky only, Jefferson County’s population of 698,080 is approximately 6-30 times higher than all the other MSA counties. Hardin County’s population is the third largest of the counties analyzed, however, it is still relatively insignificant in comparison to Jefferson County’s population. Thus, this factor is not significant for the Kentucky counties listed in this table with the exception of Jefferson County. Factor 4: Traffic and commuting patterns Commuting Information: Total number of workers in Jefferson County, KY: 329,091 Commuters in Jefferson County, KY who work in Jefferson County, KY: 303,624 (92%) Commuters from Jefferson County, KY to Clark County, IN: 7,047 (2%)

### 6-200 Total number of workers in Bullitt County, KY: 30,648 Commuters in Bullitt County, KY who work in Bullitt County, KY: 8,419 (27%) Commuters from Bullitt County, KY to Jefferson County, KY: 19,730 (64%) Commuters from Bullitt County, KY to Clark County, IN: 418 (1%) Total number of workers in Oldham County, KY: 27,716 Commuters in Oldham County, KY who work in Oldham County, KY: 7,207 (33%) Commuters from Oldham County, KY to Jefferson County, KY: 12,684 (58%) Commuters from Oldham County, KY to Clark County, IN: 326 (1%) Total number of workers in Hardin County, KY: 44,815 Commuters in Hardin County, KY who work in Hardin County, KY: 36,030 (80%) Commuters from Hardin County, KY to Jefferson County, KY: 5,347 (12%) Based on the commuting data for the Kentucky counties listed above, there appears to be potentially significant on-road mobile source emissions contributions from Bullitt and Oldham to Jefferson County, which has over 300,000 resident commuters. A large percent (78%-80%) of the workers in Carroll and Hardin Counties, respectively, commute within their resident counties. Thus, with the exception of Bullitt, Jefferson, and Oldham Counties, this factor is not significant for the remaining Kentucky counties listed above. Vehicle Miles Traveled (VMT): The following table has the vehicle miles traveled (thousand miles) for the counties in the Louisville MSA and the adjacent county of Hardin due to its relatively high VMT and population. (MSA counties are in bold; Kentucky MSA counties are inbold italics.) County 2002 VMT (thousand miles/year) Jefferson, KY 7,149 Floyd, IN 843 Clark, IN 1,262 Bullitt, KY 849 Harrison, IN 528 Oldham, KY 507 Scott, IN 364 Hardin, KY 1,333 

### Based on the analysis for this factor, the VMT for Jefferson County far exceeds the VMT of the MSA and surrounding counties. Although Hardin County has a relatively high VMT, 80% of its workers commute within the County, with an additional 12% commuting into Jefferson County, Kentucky. Based on the analysis for this factor, Hardin County does not appear to significantly contribute on-road mobile source emissions to Jefferson County.Thus, with the exception of Jefferson County, this factor is not significant for the remaining Kentucky counties listed in this table.

### 6-201 Factor 5: Expected growth The following table has the population and population growth figures for the Louisville MSA and the adjacent Hardin County due to its relatively high VMT and population. (MSA counties are inbold; Kentucky MSA counties are inbold italics.)

County 2002 Population growth (90-00) % growth (90-00) Jefferson, KY 698,080 28,667 4 Floyd, IN 71,633 6,419 10 Clark, IN 98,198 8,695 10 Bullitt, KY 63,800 13,669 29 Harrison, IN 35,244 4,435 15 Oldham, KY 49,310 12,915 39 Scott, IN 23,334 1,969 9 Hardin, KY 95,724 4,934 6 

### Based on the analysis for this factor for Kentucky only, the population growth in Bullitt and Oldham Counties indicate that these counties may contribute to the PM2.5 issues in Jefferson County. Although Jefferson County’s growth rate is fairly low, the magnitude of its population increase is the highest in the MSA and is approximately twice that of the increases in Bullitt and Oldham. Although Hardin County’s population is the third largest of the counties analyzed above, its population growth is relatively low.Thus, with the exception of Bullitt, Jefferson, and Oldham Counties, this factor is not significant for the remaining Kentucky counties listed in this table. Factor 6: Meteorology The following meteorological information was provided by Kentucky for Jefferson, Bullitt, and Oldham. Wind speed/wind direction information shows that the majority of the time for the period 1988–1992, the wind in the...County area came from the south southwest and typically at 7-10 knots. The mean high temperature for July for the area from 1961 through 1990 was 87EF and the mean low was 70EF. The mean precipitation for the same period was 4.3 inches. The information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds. The information provided was based only on summertime winds. Factor 7: Geography/topography Based on an analysis of this factor, there are no significant geographical or topographical issues associated with this MSA. boundary.

### 6-202 Factor 8: Jurisdictional boundaries The following MSA counties were designated nonattainment for the 8-hour ozone standard on April 15, 2004: the Kentucky Counties of Jefferson, Bullitt, and Oldham; and the IndianaCounties of Floyd, Clark, and Jackson. This factor did not play a significant role in the decisionmaking process for these counties. Factor 9: Level of control of emission sources The following information was provided by Kentucky for Bullitt, Oldham, and Jefferson Counties:“Point sources located within...County are subject to Prevention of Significant Deterioration (PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology (CTG RACT) requirements, Maximum Achievable Control Technology (MACT) requirements for sources of Hazardous Air Pollutants (HAP), and New SourcePerformance Standards (NSPS).” This factor did not play a significant role in the decisionmaking process for these counties. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to StatesNo Changes Made to June 29, 2004, Recommendations.

Corrections to TSD for Louisville MSA:
6.4.3.1- Factor 2: The 2001-2003 design value in the Factor 2 table for Bullitt County is corrected to read as follows:

Bullitt, KY 14.9 Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for theLouisville, KY-IN area: Bullitt and Jefferson.

6.4.3.3 Lexington Area The Lexington MSA contains the Counties of Fayette, Bourbon, Clark, Jessamine, Madison, Scott, and Woodford. Fayette County is violating the PM2.5 standard. In February 2004, Kentucky recommended that Fayette County be designated attainment for the PM2.5 standard for the Lexington, KY MSA, and the remaining MSA counties be designated attainment. EPA agrees that Fayette County should be designated nonattainment for PM2.5 due to a violating monitor (South Limestone). EPA is modifying Kentucky’s recommendation to

### 6-203 include the MSA counties of Clark, Madison and Woodford and the adjacent county of Mercer in the Lexington nonattainment area. Clark and Madison Counties are included significant emissions. Madison County also has relatively high population and population growth, and relatively high VMT. Woodford County as nonattainment due to the level of emissions. We have included in our recommended nonattainment area Mercer County that is adjacent to the Lexington MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility (e.g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such a large facility, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility, should be designated nonattainment. EPA agrees that the remaining MSA Counties of Bourbon, Jessamine, and Scott in Kentucky be designated attainment/unclassifiable due to their relatively low emissions, low populations, low VMT, low numbers of commuters into the violating counties, and small point sources. EPA agrees that the adjacent county of Pulaski should be designated attainment/classifiable for the PM2.5 standard, although it has significant emissions due to a power plant. This county has relatively low population, low population growth, and low VMT. Further, the commuting patterns and distance from the violating monitors indicate that this county does not contribute to the violations in the area. The other adjacent counties do not contribute and therefore, will be designated as attainment/unclassifiable. The recommendations of EPA and Kentucky are summarized in the table below.

Area EPA Recommendation State Recommendation Lexington, KY Full counties: Fayette County Clark County Madison County Mercer County Woodford County Full counties: Fayette Drop: Bourbon, Clark, Madison, Jessamine, Woodford and Scott Counties 

### The following is a brief summary of the nine criteria for the Lexington, KY area. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and Weighted Emissions Scores for the counties in the Lexington MSA and surrounding counties. (MSA counties in Kentucky are inbold.)

County PM SOx NOx VOC Amm Score Cum. Score Fayette (KY) 1703 3925 13620 15720 606 31.4 31.4 Clark (KY) 1132 9647 6622 2374 398 25.7 57.1

### 6-204 Madison (KY) 867 1189 5512 4215 641 13.6 70.7 Woodford (KY) 559 2663 3530 2852 427 9.5 80.2 Scott (KY) 627 260 3629 6041 481 7.9 88.1 Jessamine (KY) 504 323 2189 2436 242 7.6 95.7 Bourbon (KY) 444 147 1424 1352 597 4.3 100.0 Mercer (KY) 3136 49269 9145 1686 409 83.8 N/A Pulaski (KY) 2403 25156 10996 3901 877 56.8 N/A Laurel (KY) 770 1044 4564 3823 439 14.6 N/A Nelson (KY) 781 497 2134 7923 1147 10.3 N/A 

### Based on the analysis for this factor, the following counties appear to have significant emissions (over 10,000 tons per year of any pollutant): Fayette, Mercer and Pulaski. Clark, Madison, and Woodford also have significant level of emissions. Although Pulaski County This factor did not appear significant for the remaining counties listed in this table. Factor 2: Air quality in potentially included versus excluded areas

County 2001-2003 design value Fayette (KY) 15.7 Madison (KY) 13.5 Laurel (KY) 12.6 

### Based on the analysis for this factor, only Fayette County’s South Lomestone monitoring data exceeds the standard. The Newtown Pike monitor, also in Fayette County, is attaining at 14.9. Madison County and the adjacent county of Laurel have monitors with readings well below the standard.This factor is not significant for the remaining counties listed in the area. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Lexington MSA and adjacent counties with significant emissions. The total MSA 2002 population is 489,717. (MSA counties are inbold.) County 2002 Population Percent of Total MSA Population Population Density Fayette (KY) 263,618 53.83 925 Clark (KY) 33,726 6.89 133 Madison (KY) 73,334 14.97 166 Woodford (KY) 23,403 4.78 123 Scott (KY) 35,320 7.21 124 Jessamine (KY) 40,740 8.32 235 Bourbon (KY) 19,576 4.0 67 Mercer (KY) 21,047 84 Laurel (KY) 54,313 125 Nelson (KY) 38,823 92 

### Fayette County’s population is roughly 3-11 times higher than the other counties listed. Madison County has the second highest of the MSA counties and surrounding counties with significant

### 6-205 weighted emissions scores. Based on an analysis of this factor, no other Kentucky counties, with the exception of Madison County, have populations significant to indicate a potential contribution to the PM2.5 violations in Fayette County. Factor 4: Traffic and commuting patterns Commuting Information Total number of workers in Fayette County, KY: 136,793 Commuters in Fayette County, KY who work in Fayette County, KY: 117,584 (86%) Total number of workers in Bourbon County, KY: 9,103 Commuters in Bourbon County, KY who work in Bourbon County, KY: 4,764 (52%) Commuters from Bourbon County, KY to Fayette County, KY: 2,600 (29%) Total number of workers in Clark County, KY: 15,487 Commuters in Clark County, KY who work in Clark County, KY: 8,492 (55%) Commuters from Clark County, KY to Fayette County, KY: 4,777 (31%) Total number of workers in Jessamine County, KY: 18,885 Commuters in Jessamine County, KY who work in Jessamine County, KY: 8,721 (46%) Commuters from Jessamine County, KY to Fayette County, KY: 8,748 (46%) Total number of workers in Madison County, KY:34,494 Commuters in Madison County, KY who work in Madison County, KY: 24,061 (70%) Commuters from Madison County, KY to Fayette County, KY: 6,870 (20%) Total number of workers in Scott County, KY: 16,536 Commuters in Scott County, KY who work in Scott County, KY: 10,148 (61%) Commuters from Scott County, KY to Fayette County, KY: 4,287 (26%) Total number of workers in Woodford County, KY: 12,377 Commuters in Woodford County, KY who work in Woodford County, KY: 5,591 (45%) Commuters from Woodford County, KY to Fayette County, KY: 4,308 (35%) Total number of workers in Laurel County, KY: 21,180 Commuters in Laurel County, KY who work in Laurel County, KY: 16,286 (77%) Total number of workers in Mercer County, KY:9,610 Commuters in Mercer County, KY who work in Mercer County, KY: 5,235 (54%) Commuters from Mercer County, KY to Fayette County, KY: 1,319 (14%) Total number of workers in Nelson County, KY:17,594 Commuters in Nelson County, KY who work in Nelson County, KY: 11,189 (64%)

### 6-206 Madison County has the largest number of workers commuting into Fayette County (6,870 commuters), which is relatively insignificant for such a large county as Fayette. Laurel and Nelson County workers do not commute into the Lexington MSA at all. Based on the analysis for this factor, there are no counties with commuting data showing a potential to contribute to the PM2.5 violations in Fayette County. Vehicle Miles Traveled: The following table has the vehicle miles traveled (thousand miles) for the counties in the Lexington MSA and adjacent counties with significant emissions. (Kentucky MSA counties are inbold.)

County 2002 VMT

Fayette (KY) 2764 Clark (KY) 523 Madison (KY) 944 Woodford (KY) 311 Scott (KY) 645 Jessamine (KY) 362 Bourbon (KY) 204 Mercer (KY) 224 Laurel (KY) 852 Nelson (KY) 427 

### Fayette County’s VMT is substantially higher than the other MSA counties. Although Madison and Laurel Counties have the second and third highest VMT of the counties analyzed, commuting data do not indicate significant (or any) contributions to Fayette County. Further, Laurel County is a significant distance from Fayette County and does not contribute to Fayette County through its commuting patterns. Based on the analysis for this factor, no other Kentucky counties, with the exception of Madison County, have VMT and commuting data with a potential to contribute to the PM2.5 violations in Fayette County. Factor 5: Expected growth The following table has the population and population growth figures for the Lexington MSA and adjacent counties with significant emissions. (MSA counties are inbold.)

County 2002 Population growth (90-00) % growth (90-00) Fayette (KY) 263618 35,146 16 Clark (KY) 33726 3,648 12 Madison (KY) 73334 13,364 23 Woodford (KY) 23403 3,253 16 Scott (KY) 35320 9,194 39 Jessamine (KY) 40740 8,533 28 Bourbon (KY) 19576 124 1 Mercer (KY) 21047 1,669 9

### 6-207 Laurel (KY) 54313 9,277 21 Nelson (KY) 38823 7,767 26 

### Fayette County’s population is substantially higher than the MSA counties and adjacent counties with significant weighted emissions scores, and grew the most during the 1990-2000 time period. Madison County is the third fastest growing county in the MSA based on a percent growth rate with the second largest population and the second largest population increase. Thus, Madison County’s population growth is significant enough to contribute to PM2.5 violations in Fayette County. None of the other MSA and adjacent counties listed above have population characteristics which appear to be contributing to the PM2.5 violations in Fayette County. Factor 6: Meteorology The following meteorological information was provided by Kentucky. The figure referenced is a wind rose for April 1-October 31 for the 1988-1992 period that is provided in Kentucky’s PM2.5 recommendations submittal. The text below is the same for Fayette, Bourbon, Clark, Jessamine, Scott, and WoodfordCounties. “Wind speed/wind direction information shows that the majority of the time for the period 1988–1992, the wind in the...County area came from the southwest and typically from 7- 10 knots. (See figure 1-A) The mean high temperature for July for the area from 1961 through 1990 was 86EF and the mean low was 66EF. The mean precipitation for the same period was 4.8 inches.” (Source: KY submittal) For Madison County, the following statement preceded the excerpted paragraph above: Due to the close proximity of Lexington, Kentucky, meteorological data from Lexington was used for the Madison county area.” This factor did not play a significant role in the decision making process. The submitted information was only for the summertime winds. Factor 7: Geography/topography Based on an analysis of this factor, there are no significant topographical issues associated with this MSA.
Factor 8: Jurisdictional boundaries No county in the Lexington MSA was designated nonattainment for the 8-hour ozone standard on April 15, 2004. This factor did not play a significant role in the decision making process.

### 6-208 Factor 9: Level of control of emission sources The following information was provided by Kentucky for Fayette, Bourbon, Clark, Jessamine, Madison, Scott, Woodford Counties. “Point sources located within...County are subject to PSD requirements, CTG RACT requirements, Maximum Achievable Control Technology (MACT) requirements for sources of Hazardous Air Pollutants, and New Source Performance Standards (NSPS).” (Source: KY PM2.5 submittal) This factor did not play a significant role in the decision making process. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendations on June 29, 2004, include the MSA counties of Clark, Madison, and Woodford and the adjacent county of Mercer. Upon further review of additional information provided by Kentucky, EPA is revising its recommendations and designating Clark, Madison, and Woodford Counties as attainment/unclassifiable. EPA is designating a portion of Mercer County as nonattainment and the remainder of the county as attainment/unclassifiable. The additional analysis provided by Kentucky indicated that there is a strong localized effect on the violating monitor in Fayette County. Fayette County has two monitors located in Lexington, Kentucky which are 1.9 miles apart, with one violating at a design value of 15.6 and one attaining at a design value of 14.9. The supplemental submittals from Kentucky provided additional data and analysis to demonstrate that the monitor located on the University of Kentucky’s (UK) campus is violating due to localized impacts. These local impacts include: emissions from 112 UK boilers fueled by coal and natural gas; 13 major construction projects on the UK campus which began as early as December 1999 and have just been completed or are in process; and several, nearby downtown construction projects in Lexington. All of the construction projects in the area are one to six blocks from the violating monitor. Clark County, KY: Clark County’s population of 33,726 people and VMT of 523,000 are very small in comparison to those of Fayette County, whose population, commuters, and VMT are substantially higher than those of the other MSA counties. In contrast, Fayette County, with one violating monitor, has a population of 263,618 and VMT of 2,764,000. Clark County has no monitor. Clark County’s population comprises only 6.9% of the total MSA population. In addition, Clark County has a low number of workers (4,777) commuting to the violating MSA County of Fayette and whose 15,487 workers account for just 6.4% of the total number of MSA workers. Clark County’s total emissions are, in tpy (and % of the MSA emissions): 1,132 PM (19.4%), 9,647 SO2 (53.1%), 6,622 NOx (18.1%), and 2,374 VOC (6.8%). Clark County does contain a small outlying power plant, East Kentucky Power, with 2001 emissions of 6,846 tpy of SO2 and

### 6-209 1,910 tpy of NOx. These factors in combination with Kentucky’s localized impact analysis indicate Clark County’s emissions are not contributing to the PM2.5 violation at the one monitor in Fayette County. Madison County, KY: Madison County has no large point sources and the design value of its attaining monitor is 13.4. The County has a relatively small population of 73,334 and a low number of VMT of 944,000 in comparison to Fayette, the violating county, whose population is 263,618 and VMT is 2,764,000. Madison County workers account for only 14.2% of the total number of commuters in the MSA. In addition, 70% of the County’s workers commute within Madison County. Woodford County, KY: Woodford County has relatively low emissions and no monitor. Specifically, County emission totals are, in tpy (and % of the MSA emissions): 559 tpy PM (9.6%), 2,663 tpy SO2 (14.7%), 3,530 tpy NOx (9.7%), and 2,852 tpy VOC (8.2%). While there is a small Kentucky Utilities power plant, the highest emissions from this plant are only 1,117 tpy NOx and 2,087 tpy SO2. In addition, the County has a very small population of 23,403 and accounts for only 5.1% of all the commuters in the MSA. Only 5,020 workers from Woodford County commute to other counties in the MSA. These factors in combination with Kentucky’s localized impact analysis indicate Woodford County’s emissions are not contributing to the PM2.5 violation at the one monitor in Fayette County. Mercer County, KY: In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Mercer County is one of those counties. Mercer County has low population (21,047 compared to 263,618 in Fayette County where the city of Lexington is located), low population density (84 people per square mile compared to 925 in Fayette County), low VMT (224,000 compared to 2,764,000 in Fayette County), and the only large point source is Kentucky Utilities’ E.W. Brown facility. Mercer County has no monitor. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. The

### 6-210 Commonwealth of Kentucky subsequently submitted a partial county recommendation that included the E.W. Brown facility. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free-standing portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier (StateFIPs-CoFIPs-Tract#-Block Group#) 21-167-9605-1 portion of Mercer County as part of the Lexington nonattainment area.

Corrections to TSD for Lexington MSA: 6.4.3.3 - Preamble: The following corrections are noted to the preamble to the factors text above: “In February 2004, Kentucky recommended that Fayette County be designated attainment nonattainment ...” “Clark and Madison Counties are included due to significant emissions...” “Woodford County is recommended as nonattainment...”
6.4.3.3 - Factor 1 The following corrections are noted to the text after the emissions table: “...have significant levels of emissions. Although Pulaski CountyThis factor...”
6.4.3.3 - Factor 2 The following correction is noted to the text after the design value table: “...South LomestoneLimestone monitoring...”
6.4.3.3 - Factor 2 The 2001-2003 design values in the Factor 2 table for Fayette and Madison Counties are corrected to read as follows:

### 6-211 County 2001-2003 design value Fayette (KY) 15.6 Madison (KY) 13.4 

### Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Lexington, KYarea: Fayette and Mercer (Partial).

6.4.3.4 Huntington-Ashland Area The Huntington-Ashland MSA contains the Kentucky Counties of Boyd, Carter, and Greenup; the West Virginia Counties of Cabell and Wayne; and Lawrence County, Ohio. The following MSA and adjacent counties are violating the PM2.5 standard: Cabell County, West Virginia (MSA) and Lawrence (MSA) and Scioto (adjacent) Counties, Ohio. In February 2004, Kentucky recommended that the PM2.5 designation for Boyd County bedeferred and that Greenup and Carter Counties be designated attainment for the HuntingtonAshland MSA. EPA is modifying Kentucky’s recommendeation to include Boyd County and Lawrence Counties in Kentucky in the Huntington-Ashland nonattainment area. The following factors played a significant role in this decision for Boyd County: attaining monitor reading of 15.0, at the standard;significant SOx, NOx, and PM emissions; proximity to the violating MSA counties; controls with anticipated, substantial SOx, NOx, and PM emission reductions will not be implemented until the end of 2005, well after designations are made. Lawrence County, Kentucky is included due to significant emissions of SOx and NOx from a power plant and its close proximity to the violating counties in the MSA. We have included in our recommended nonattainment area this County that is adjacent to the Huntington-Ashland MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility (e.g., power plant) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such a large facility, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility, should be designated nonattainment. EPA agrees that Greenup and Carter Counties in Kentucky should be designated attainment/unclassifiable due to their relatively low emissions, low populations, low VMT, low numbers of commuters into the violating counties, and small point sources. The recommendations of EPA and Kentucky are summarized in the table below.

### 6-212 Area EPA Recommendation for KY State Recommendation Huntington-Ashland,WVKY-OH Full counties: Boyd County Lawrence County (adjacent) Full counties: Boyd (Defer Designation)


### The following is a brief summary of the nine criteria for the Kentucky portion of the HuntingtonAshland, WV-KY-OH area. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons per year and weighted emissions scores for the counties in the Huntington-Ashland MSA and surrounding counties. (MSA counties are inbold; Kentucky MSA counties are inbold italics.)

County PM SOx NOx VOC Amm Score Cum. Score Cabell (WV) 2,365 5,155 27,903 7,080 181 40.3 40.3 Boyd (KY) 2,314 11,740 13,478 8,620 467 25.2 65.5 Wayne (WV) 550 1,023 6,485 2,620 56 9.6 75.1 Greenup (KY) 477 2,519 4,336 1,795 156 9.5 84.6 Lawrence (OH) 770 841 4,399 4,366 207 8.6 93.2 Carter (KY) 506 237 2,615 1,996 223 6.8 100.0 Gallia (OH) 10,010 164,984 61,079 1,839 300 141.4 Adams (OH) 6,417 125,136 52,992 1,508 431 102.4 Putnam (WV) 4,395 80,150 39,795 3,752 97 72.7 Mason (WV) 3,610 70,053 31,327 2,831 264 60.0 Lawrence (KY) 2,903 56,066 21,265 919 56 48.3 Scioto (OH) 1,053 2,790 5,566 4,703 350 12.5 Lewis (KY) 429 469 2,873 990 222 8.1 Pike (OH) 425 4,203 2,081 1,311 149 6.8 Rowan KY 336 313 1,691 1,535 91 5.7 Mingo (WV) 437 281 2,842 1,379 150 5.5 Jackson (OH) 404 461 1,320 1,717 165 4.7 Martin (KY) 281 661 1,236 706 762 4.0 Lincoln (WV) 259 67 1,314 1,128 37 4.0 Elliott (KY) 164 115 393 313 42 3.1 

### Based on the analysis for this factor, the following Kentucky counties appear to have significant emissions (over 10,000 tons per year of any pollutant): Boyd and Lawrence. This factor is not significant for the remaining Kentucky counties listed in this table.

### 6-213 Factor 2: Air quality in potentially included versus excluded areas

County 2001-2003 design value Cabell (WV) 16.6 Boyd (KY) 15.0 Lawrence (OH) 15.8 Carter (KY) 12.2 Scioto (OH) 17.2 

### There are four monitors in the MSA, with two of them in the Kentucky Counties of Boyd and Carter. The Kentucky monitors are monitoring attainment. Three monitors in the MSA and surrounding counties are violating: Cabell County, West Virginia; Lawrence County, Ohio; and the adjacent Scioto County, Ohio. Based on the analysis for this factor for Kentucky only, Boyd County has attaining monitoring data very close to the standard, thus indicating a potential to contribute to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Huntington-Ashland MSA and adjacent counties with significant emissions. The total MSA 2002 population is 313,239. (MSA counties are inbold; Kentucky MSA counties are inbold italics.) County 2002 Population Percent of Total MSA Population 2002 Population Density Cabell (WV) 95,266 30.41 338 Boyd (KY) 49,603 15.84 310 Wayne (WV) 42,382 13.53 84 Greenup (KY) 36,761 11.74 106 Lawrence (OH) 62,172 19.85 137 Carter (KY) 27,055 8.64 66 Gallia (OH) 31,301 67 Adams (OH) 27,804 48 Putnam (WV) 52,230 151 Mason (WV) 26,004 60 Scioto (OH) 78,041 128 

### Based on the analysis for this factor for Kentucky only, Boyd County has the third largest population in the MSA and the second largest population density, indicating a potential to contribute to the PM2.5 violations in the area. This factor is not significant for the remaining Kentucky counties. Factor 4: Traffic and commuting patterns Commuting Information Total number of workers in Boyd County, KY: 19,106

### 6-214 Commuters in Boyd County, KY who work in Boyd County, KY: 13,816 (72%) Commuters from Boyd County, KY to Cabell County, WV: 1,157 (6%) Commuters from Boyd County, KY to Lawrence County, OH: 540 (3%) Total number of workers in Carter County, KY: 10,258 Commuters in Carter County, KY who work in Carter County, KY: 5,641 (55%) Commuters from Carter County, KY to Boyd County, KY: 1,401 (14%) Commuters from Carter County, KY to Cabell County, WV: 237 (2%) Total number of workers in Greenup County, KY: 13,798 Commuters in Greenup County, KY who work in Greenup County, KY: 5,930 (43%) Commuters from Greenup County, KY to Boyd County, KY: 4,147 (30%) Commuters from Greenup County, KY to Cabell County, WV: 473 (3%) Commuters from Greenup County, KY to Lawrence County, OH: 443 (3%) Commuters from Greenup County, KY to Scioto County, KY: 1,252 (9%) Total number of workers in Lawrence County, KY: 4,899 Commuters in Lawrence County, KY who work in Lawrence County, KY: 2,483 (51%) Commuters from Lawrence County, KY to Boyd County, KY: 575 (12%) Commuters from Lawrence County, KY to Cabell County, WV: 193 (4%) Commuters from Lawrence County, KY to Lawrence and Scioto Counties, OH: 0 (0%) Based on commuting data above, none of the Kentucky counties appear to be contributing a significant level of onroad mobile source emissions to the area. Vehicle Miles Traveled: The following table has the vehicle miles traveled (thousand miles) for the counties in the Huntington-Ashland MSA and some adjacent counties with significant emissions. (MSA counties are inbold; Kentucky MSA counties are inbold italics.)

County 2002 VMT (thousand miles/year) Cabell (WV) 1,030 Boyd (KY) 411 Wayne (WV) 377 Greenup (KY) 264 Lawrence (OH) 796 Carter (KY) 665 Gallia (OH) 266 Adams (OH) 283 Putnam (WV) 578 Mason (WV) 270 Scioto (OH) 633 

### Based on the total VMT of the Kentucky counties only, there appears to be a potential contribution of onroad mobile source emissions to the area from Boyd and Carter Counties.

### 6-215 However, the analysis of the commuting data above shows that a low number of workers commute from these Kentucky counties into the violating counties.Thus, this factor is not significant for the Kentucky counties listed above when VMT and commuting data are analyzed together. Factor 5: Expected growthThe following table has the population and population growth figures for the HuntingtonAshland MSA and adjacent counties with significant emissions. (MSA counties are inbold; Kentucky MSA counties are inbold italics.)

County 2002 Population growth (90-00) % growth (90-00) Cabell (WV) 95,266 -43 -0 Boyd (KY) 49,603 -1,398 -3 Wayne (WV) 42,382 1,267 3 Greenup (KY) 36,761 149 0 Lawrence (OH) 62,172 485 1 Carter (KY) 27,055 2,549 10 Gallia (OH) 31,301 115 0 Adams (OH) 27,804 1,959 8 Putnam (WV) 52,230 8,754 20 Mason (WV) 26,004 779 3 Scioto (OH) 78,041 -1,132 -1 

### Based on an analysis of this factor for Kentucky only, there appears to be relatively significant population growth in Carter County to indicate a potential air quality contribution. However, Carter County’s population is low. Boyd and Greenup Counties have a negative or zero population growth rate. Thus, this factor is not significant for the Kentucky counties. Factor 6: Meteorology The following meteorological information was provided by Kentucky.The text below is the same for Boyd, Carter, and Greenup Counties in Kentucky. The figure referenced is a wind rose for April 1-October 31 for the 1988-1992 period that is provided in Kentucky’s PM2.5 recommendations submittal. Meteorological Information “Due to the close proximity of Huntington, West Virginia, meteorological data from Huntington was used for this Kentucky area. Wind speed/wind direction information shows that the majority of the time for the period 1988–1992, the wind in the Huntington-Ashland area came from the southwest and typically from 4-6 knots. (See figure 1-A) The mean high temperature for July for the area from 1961 through 1990 was 85EF and the mean low was 65EF. The mean precipitation for the same period was 4.5 inches.”(Source: Kentucky PM2.5 submittal)

### 6-216 Based on an analysis of this factor, the information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds. The information provided was for only the summertime winds. Factor 7: Geography/topography Based on an analysis of this factor, there are no significant topographical issues associated with this MSA.
Factor 8: Jurisdictional boundaries The following MSA counties were designated nonattainment for the 8-hour ozone standard on April 15, 2004: Boyd County, Kentucky; the West Virginia Counties of Cabell, Wayne, andPutnam; and no counties in Ohio. This factor did not play a significant role in the decisionmaking process.
Factor 9: Level of control of emission sources The following information was provided by Kentucky for Boyd, Carter, and Greenup Counties.

“Point sources located within...County are subject to PSD requirements, CTG RACT requirements, Maximum Achievable Control Technology (MACT) requirements for sources of Hazardous Air Pollutants, and New SourcePerformance Standards (NSPS).” This factor did not play a significant role in the decisionmaking process for these counties Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Lawrence County, KY: In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Lawrence County, Kentucky, is one of those counties. Lawrence County, Kentucky, has low population (15,784 compared to 95,266 and 62,172 in the violating MSA counties of Cabell, West Virginia and Lawrence, Ohio, respectively), low population density (38 people per square mile compared to 338 in Cabell, West Virginia and 137 in Lawrence, Ohio), low VMT (163,000 compared to 1,030,000 and 796,000 in Cabell, West Virginia and Lawrence, Ohio), and the only large point source is the Big Sandy Power Plant. Lawrence County, Kentucky, has no monitor.

### 6-217 A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. The Commonwealth of Kentucky subsequently submitted a partial county recommendation that included the Big Sandy Power Plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free-standing portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier (StateFIPs-CoFIPs-Tract#-Block Group#) 21-127-9901-6 portion of Lawrence County, Kentucky as part of the Huntington-Ashland nonattainment area and the remainder of the county as attainment/unclassifiable.

Corrections to TSD to Huntington-Ashland MSA:
6.4.3.4 - Factor 1: Deletion: (over 10,000 tons per year of any pollutant)
6.4.3.4 - Factor 2: The design value for Boyd County is corrected to read as follows:

County 2001-2003 design value Boyd, KY 14.9

6

### .4.3.4 - Factor 3: The following information is inserted into the population data table:

County 2002 Population Percent of Total MSA Population 2002 Population Density
Lawrence (KY) 15,784 38 

### 6.4.3.4 - Factor 4: The following information is inserted into the VMT data table:

### 6-218 County 2002 VMT (thousand miles/year) Lawrence (KY) 163



### 6.4.3.4 - Factor 5: The following information is inserted into the population growth table:

County 2002 Population growth (90-00) % growth (90-00) Lawrence (KY) 15,784 1,571 11 Insert the following statements regarding Lawrence County, KY as follows (additionsare in italics, deletions are in strikeout). Based on an analysis of this factor for Kentucky only, there appears to be relatively significant population growth in Carterand Lawrence Countyies in Kentuckyto indicate a potential air quality contribution. However,the populations of Carterand LawrenceCountyiespopulationisarelow. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Huntington–Ashland, WV- KY-OH area: Boyd and Lawrence (Partial). 

### 6.4.3.5 Boyd County Area Kentucky anticipates that emissions of PM2.5, SOx, and NOx will decrease substantially within Boyd County over the next two years. These anticipated emission decreases are due to source modernization and new controls being implemented at two major sources in Boyd County: the Marathon-Ashland Refinery and Calgon Carbon Corporation. For the Marathon-Ashland Refinery, the facility modifications are anticipated to be completed by the end of 2005. According to Kentucky, based on 2002 emissions data, this would mean an approximate reduction of 1,571 tons per year of SO2, a 761 ton per year reduction in NOx, and a 32 ton per year reduction in particulate matter. For Calgon Carbon Corporation, the May 2003 shutdown of two of their activator lines resulted in SO2 emissions being reduced from this facility by approximately 187 tons in 2003. Before these lines can be reactivated, scrubbers, with SO2 and PM control efficiencies of 90% will be required to be installed on these units. If brought back into operation, these units will have controls in place to reduce emissions of SO2 from these two lines to approximately 32 tons per year. Based on an analysis of this factor, these controls will not be implemented in a timeframe early enough to influence the decision for Boyd County on PM2.5 designations. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following

### 6-219 counties as nonattainment for the Huntington–Ashland, WV- KY-OH area: Boyd and Lawrence (Partial). 6.4.4 EPA 9-Factor Analyses for North Carolina for the Designation of Nonattainment Areas for PM2.5
6.4.4.1Greensboro-Winston-Salem-High Point Area In February 2004, North Carolina recommended that the entire county of Davidson, be designated as nonattainment for the Fine Particulate Matter Standard. The table below shows the State recommendations and EPA modifications for the Particulate Matter(PM 2.5) nonattainment area inGreensboro-Winston-Salem-High Point, NC. EPA is recommending Davidson County be designated nonattainment because it has a violating PM 2.5 monitor. The MSA counties of Guilford, Stokes, Forsyth and Randolph are also being recommended as nonattaiment. Guilford, Forsyth and Randolph counties are adjacent to Davidson County and have large populations and large emissions. Stokes has significant power plant emissions. EPA agrees that Alamance, Davie, Yadkin, Rowan, Chatham, Rockingham, and Iredell Counties be designated attainment/unclassifiable. Alamance is an MSA county with an attaining monitor of 13.7 micrograms per cubic meter (mg/m3

### ), 75 % of the commuters remain in Alamance County and the county has low emissions. Davie and Yadkin are MSA counties that do not contain PM 2.5 monitors, have low populations, and low commuting into Davidson. There is significant distance between the violating monitor and the counties of Iredell and Yadkin. Rowan and Iredell areadjacent to the MSA, do not contain PM 2.5 monitors and are a part of the Charlotte-GastoniaRock Hill nonattainment area for ozone. Rowan and Rockingham both have small power plants and there are attaining monitors in counties between the SO2

### /NOx sources in Rowan and Rockingham counties and the violating monitor. Chatham is an adjacent county to the Greensboro-Winston-Salem-High Point MSA with an attaining monitor of 12.2mg/m3

### , has low population, and part of the county is in the Raleigh-Durham-Chapel Hill nonattainment area for ozone. The remaining adjacent counties all have low emissions, low population and low VMT, indicating they should be attainment/unclassifiable.

Area EPA Recommendation State Recommendation Greensboro-Winston-Salem-High Point, NC Full Counties:Stokes, Guilford, Davidson, Forsyth, and Randolph Full Counties:Davidson

### 6-220 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5

### , SO2

### , NOx, VOC, and Ammonia (Amm) emissions in tons, and weighted emissions scores for the Greensboro-Winston-Salem-High Point Area and surrounding counties. The MSA counties are inbold

. PM 2.5SO2 NOx VOC Amm Weighted emissions

score Cumulative Weighted emissions score NCStokes 4,821 83,40935,9362,566 357 32.8 32.8 NCGuilford 2,4182,833 19,06834,464 1,178 17.6 50.4 NCDavidson 1,951 1,398 11,281 14,970632 12.9 63.3 NCForsyth 1,559 5,885 14,552 20,679722 11.7 75.0 NCRandolph 1,370 907 5,898 10,3074,014 9.5 84.5 NCAlamance 1,181 749 5,618 8,967 730 8.2 92.7 NCYadkin 606 318 2,061 2,247 896 4.0 96.7 NCDavie 508 205 1,959 3,278 448 3.3 100.0 NCRowan 2,012 12,46511,681 11,323 726 13.4 NCChatham 1,714 11,6055,823 4,734 3,012 11.7 NCRockingham1,555 6,263 12,227 8,770 523 11.2 NCIredell 1,537 1,365 11,065 10,3462,090 10.8 NCSurry 1,224 1,238 5,055 7,478 1,811 8.5 VAPittsylvania 980 1,828 7,490 4,149 581 7.2 NCMoore 956 409 3,197 6,519 2,396 6.9 NCWilkes 966 647 2,890 5,097 5,300 6.6 NCOrange 857 756 6,264 6,751 572 6.4 VAHenry 818 535 3,811 10,517 197 5.6 NCStanly 795 3,129 2,891 4,581 1,460 5.3 NCMontgomery516 484 1,631 4,175 1,246 3.6 NCCaswell 483 199 1,071 1,622 155 3.2 VAPatrick 408 176 1,039 1,363 214 2.8 VACarroll 378 509 2,305 1,986 441 2.7 VAGrayson 291 95 819 952 405 2.0 NCAlleghany 217 190 379 590 425 1.4 

### Based on the analysis for this factor, there appears to be emissions in Stokes, Guilford, Forsyth, and Randolph counties that contribute to the air quality in Davidson County, resulting in a violating monitor there. This analysis shows that the adjacent counties of Rowan, Chatham, Rockingham, and Iredell have emissions that may contribute to the violation in Davidson County. However, these counties are more distant from the violating monitor. Chatham County has an attaining monitor and is part of the Raleigh MSA. Rowan and part of Iredell County are in the Charlotte ozone nonattainment area.

### 6-221 Factor 2: Air Quality in potentially included versus excluded areas 2001-2003 Design Value NCGuilford 14.1 NCDavidson 15.8 NCForsyth 14.6 NCAlamance 13.7 NCChatham 12.2 NCOrange 13.1 NCMontgomery12.1 NCCaswell 13.3 

### There are six monitors in the MSA (two in Guilford, and two in Forsyth counties and one in Davidson, and Alamance counties) and five monitors in the adjacent counties. The monitor in Davidson County, is violating the Particulate Matter Standard of 15.0 micrograms per cubic meter (mg/m3

### ). All other monitors in this area are attaining the Particulate Matter Standard. Factor 3: Population Density and Degree of Urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Greensboro-Winston-Salem-High Point area and adjacent counties with significant weighted emissions scores.

2002 Population % Population of MSA Population Density (pop./ mi2)
NCStokes 44,984 3.5 100 NCGuilford 430,937 33.5 663 NCDavidson 151,238 11.6 274 NCForsyth 314,933 24.5 768 NCRandolph 134,217 10.4 170 NCAlamance 135,893 10.6 315 NCYadkin 37,329 2.9 111 NCDavie 36,734 2.9 139 NCRowan 133,359 261 NCChatham 53,893 79 NCRockingham92,778 164 NCIredell 130,178 227 

### Based on the analysis for this factor, there appears to be significant populations in Guilford, Forsyth, Davidson, Rowan, Iredell, Randolph and Alamance counties, indicating potential contribution. Factor 4: Traffic and commuting patterns Commuting Information Total commuters in Davidson County: 72,893

### 6-222 Commuters in Davidson County, NC, who work in Davidson County: 40,621 (56%) Total commuters in Forsyth County: 147,838 Commuters in Forsyth County, NC, who work in Forsyth County: 119,233 (81%) Commuters from Forsyth County, NC to Davidson County, NC: 4,136 (3%) Total commuters in Guilford County: 213,079 Commuters in Guilford County, NC, who work in Guilford County: 187,150 (88%) Commuters from Guilford County, NC to Davidson County, NC: 2,982 (1%) Total commuters in Randolph County: 65,803 Commuters in Randolph County, NC, who work in Randolph County: 38,637 (59%) Commuters from Randolph County, NC to Davidson County, NC: 2,607 (4%) Total commuters in Stokes County: 21,709 Commuters in Stokes County, NC, who work in Stokes County: 6,330 (29%) Commuters from Stokes County, NC to Davidson County, NC: 252 (1%) The counties of Davie and Rowan have a small number of commuters and very few of them commute to Davidson County. Chatham, Yadkin, Iredell, and Rockingham counties have a low number of commuters and most of them stay within their counties. Based on commuting patterns, Forsyth and Guilford appear to have the most impact on the violating monitor in Davidson County. However, the impact on the monitor from commuting appears to be small. The following table contains the vehicle miles traveled (VMT) for the counties in the Greensboro-Winston-Salem-High Point area and some adjacent counties with significant emissions. (MSA counties are inbold).

2002 VMT (thousands of miles) NCStokes 415 NCGuilford 5,096 NCDavidson 1,765 NCForsyth 3,832 NCRandolph 1,486 NCAlamance 1,575 NCYadkin 520 NCDavie 476 NCRowan 1,654 NCChatham 434 NCRockingham923 NCIredell 1,901 

### Based on total VMT, there appears to be contribution to air quality in Davidson County from Guilford, Davidson, Forysth, Rowan, Iredell, Randolph and Alamance counties. However, there

### 6-223 is very low or no commuting into Davidson County from Rowan. Iredell, and Alamance Counties Factor 5: Expected growth The following table has the population and population growth on a percentage basis figures for counties in theGreensboro-Winston-Salem-High Point MSA and some adjacent counties with significant emissions

.As noted above, Chatham County is part of the Raleigh MSA, and Iredell and Rowan Counties are in the Charlotte rather than the Greensboro ozone nonattainment area.

2002 Population Growth '90-'00 % Change '90-'00 NCStokes 44,984 7,488 20 NCGuilford 430,937 73,628 21 NCDavidson 151,238 20,569 16 NCForsyth 314,933 40,189 15 NCRandolph 134,217 23,908 22 NCAlamance 135,893 22,587 21 NCYadkin 37,329 5,860 19 NCDavie 36,734 6,976 25 NCRowan 133,359 19,735 18 NCChatham 53,893 10,570 27 NCRockingham 92,778 5,864 7 NCIredell 130,178 29,729 32 

### Based on the analysis for this factor, there appears to be significant growth in Davidson, Guilford, Forsyth, Alamance, Randolph, Rowan, Chatham, and Iredell counties indicating a potential contribution to the air quality in Davidson County. Factor 6: Meteorology The following meteorological information was provided by North Carolina. This summarizes the wind directions for the MSA during the time periods when PM2.5 values are the highest. Summertime: southwesterly winds and recirculating patterns dominate. Main urban areas of influence include Charlotte, the Triad, and Hickory. Wintertime: More northerly and stronger northwesterly winds observed that during the summer. High PM2.5 is generally observed prior to frontal passages when high pressure is in control or during strong nocturnal low-level temperature inversions. Year-round trajectories indicate influence from nearby states. The information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds. Factor 7: Geography/topography

### 6-224 There are no significant topographical issues associated with this MSA. Chatham, Iredell, and Rockingham counties are one or more counties away from Davidson county. Additionally, there is one or more attaining monitors between the major emissions sources in these counties and the violating monitor, indicating no contribution.
Factor 8: Jurisdictional boundaries The 8-hour nonattainment boundary designation for the Greensboro-Winston-Salem-High Point area includes the entire counties of Davidson, Davie, Forsyth, Guilford, Alamance, Caswell, Randolph, and Rockingham. Davie, Alamance, Caswell, and Rockingham were designated nonattainment for ozone because they contained violating monitors not because they were found to be contributing. Rowan county and a portion of Iredell county were designated nonattainment for the ozone standard as apart of the Charlotte-Gastonia-Rock Hill MSA area. Due to significant NOx controls, Stokes County was determined not to contribute to the ozone violations.
Factor 9: Level of control of emission sources Belews Creek is the largest coal-burning station owned by Duke Power located in Stokes County, NC. Duke Power completed the first phase of its massive Selective Catalytic Reduction (SCR) project at Belews Creek Steam Station that will reduce the power plant's nitrogen oxide emissions by over 90 percent. No scrubbers are installed at this time, but are scheduled to be installed in 2009. The state initiatives are listed below: NOx SIP Call The Clean Smokestacks Act Clean Air Bill On Board Diagnostics II Emissions Inspection Program PM2.5

### Forecasting Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial recommendations on June 29, included Forsyth, Randolph and Stokes Counties as part of the Greensboro nonattainment area. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Forsyth, Randolph and Stokes Counties as attainment/unclassifiable. The State of North Carolina has taken a proactive approach to solving its air pollution problems. Several programs have been implemented and will continue to be implemented to control PM2.5 precursors. The State has a robust PM2.5 monitoring network. The Clean Smokestacks Act requires NOx SIP Call controls to be operated year round and requires significant emission reductions of SO2 from power plants. These NOx and SO2 reductions must occur within the boundaries of North Carolina. As a statewide effort, several mobile source controls have been implemented. The On Board Diagnostics II Emissions Inspection and Maintenance (I/M)

### 6-225 program has expanded to now encompass 48 counties, including all MSA counties and covering 82% of all statewide vehicles. EPA and State grants have been used to support of their efforts to reduce emissions from mobile sources which include Alternate Fuel Vehicle Infrastructure, Compressed Natural Gas Stations, bike racks on buses, and a Mobile Source Abatement Program. The Greensboro area Early Action Compact (EAC) includes the counties of Alamance, Caswell, Davidson, Davie, Forsyth, Guilford, Randolph, Rockingham, Stokes, Surry and Yadkin. As an EAC area, all 11 counties are adopting policies to encourage and promote diesel retrofits. Less polluting vehicles area expected to result in a reduction in emissions of 1.1 tpy of VOC and 0.9 tpy of NOx. An increase in ridership on regional bus services is projected to decrease VOC emissions by 8.9 tpy and NOx emissions by 7.3 tpy. All diesel vehicles will be converted to biodiesel. In addition, an increase in telecommuting is expected to lead to a decrease of VOC and NOx emissions by 189 tpy and 155 tpy, respectively. Through the use of non-motorized transportation, all Triad EAC Counties are also expected to decrease VOC emissions by 279 tpy and NOx by 229 tpy. As part of Duke Energy’s initiative to cleaner air, implementation of a Meter Reading Optimizing program will reduce Vehicle Miles Traveled (VMT) in all 11 EAC Counties. Stokes County, NC: The Belews Creek Steam Station is the major source of the County’s emissions. However, Duke Power, as part of the NOx SIP Call, has completed the Selective Catalytic Reduction (SCR) project and began operation on unit one in 2003 and unit two in 2004. Additionally, unit two had burner technology installed. NOx emissions at the Belews Creek Steam Station were reduced by 36,545 tons per year (tpy) to 7,022 TPY by the end of 2004. Per the Clean Smokestacks Legislation, SCR must be operated year round by 2009. In addition, the Belews Creek Power Plant will complete the installation of state of the art scrubbers on both units by 2008, reducing sulfur dioxide (SO2) emissions by 90% to 10,805 TPY and achieve an emission rate of 0.15 lb/mmBTU emission rate. Stokes County rates low for other factors, such as population, population density, commuting patterns, and VMT. Duke Power has committed to work with the State of North Carolina to expeditiously place the schedule for compliance with the Clean Smokestacks requirements (SO2 & NOx) into the title V permit. This schedule will include installation of state of the art scrubbers by 2008. Forsyth County, NC: Forsyth Countyhas two attaining monitors at14.0 and 14.6 micrograms/cubic meter. Forsyth emissions in tons per year are as follows: PM emissions 1,559 tpy (11% of MSA), SO2 emissions 5,885 tpy (6% of MSA), NOx emissions 14,552 TPY (15% of MSA). Even though Forsyth County has the second highest MSA population with 314,933 people representing 24.5% of the MSA, it is substantially less than Guilford County with a population of 430,937. Of 147,838 commuters in Forsyth County, 119,233 (80.7%) commuters stay within the county. The majority of emissions are from mobile sources. These emissions are controlled (or addressed) as described above.

### 6-226 Wind direction and pollution roses for the Greensboro area were more predominant in the direction of Guilford County than Forsyth County.

Randolph County, NC: Randolph County’s emissions represent a small percentage of the total emissions for the MSA. Randolph County’s total emissions in tons per year (tpy) are: PM 1,370 (9.5% of the MSA), SO2 907 (0.9% of the MSA), NOx 5,898 (6.1% of the MSA). The population of Randolph County, 134,217, is low compared to Guilford County with a population of 430,937 and Randolph County’s VMT of 1,486 is one of the lowest in the MSA as compared to 5,096 thousands of miles. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for theGreensboro-Winston Salem–High Point, NC area: Davidson and Guilford .

6.4.4.2 Hickory-Morganton-Lenoir AreaThe following is the nine factor analysis for Hickory-Morganton-Lenoir, NC. The HickoryMorganton-Lenoir, NC Metropolitan Statistical Area (MSA) contains the counties of Catawba, Caldwell, Burke, and Alexander. In February 2004, North Carolina recommended that the Unifour Metropolitan Planning Organization’s (MPO) Planning Boundary in Catawba County, be designated as nonattainment. The table below shows State Recommendations and EPA recommended modifications for the Particulate Matter 2.5 (PM 2.5) nonattainment area in the Hickory-Morganton-Lenoir area. EPA is modifying the recommendation to include the entire county of Catawba and partial county boundaries in Burke and Caldwell Counties. Catawba County has a violating PM 2.5 monitor. The partial county boundaries in Burke and Caldwell Counties follow the MPO boundary lines which were the boundaries determined in the 8-hour ozone designation in April 2004 for the two counties. Over 20 percent of the commuters from Burke and Caldwell counties commute to Catawba County and both counties contain population levels that indicate contribution. EPA agrees that the MSA county of Alexander and the adjacent counties of Rutherford, Iredell, Cleveland, and Wilkes be designated attainment/unclassifiable. These counties have low population, and are low commuting into Catawba County, distant from the violating monitor in Catawba County. The remaining adjacent counties all have low emissions and low population, indicating they should be attainment/unclassifiable.

Area EPA Recommendation State Recommendation

### 6-227 Hickory-Morganton-Lenoir Full Counties:Catawba
Partial Counties: Burke and Caldwell Full Counties:None
Partial Counties:Catawba


### The following is a brief summary of the 9 criteria for the Hickory-Morganton-Lenoir MSA and surrounding counties. These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5

### , SO2, NOx, VOC, and Ammonia (Amm) emissions in tons, and weighted emissions scores for the Hickory-Morganton-Lenoir Area and surrounding counties. The Metropolitan Statistical Area (MSA) counties are inbold

.
PM 2.5 SO2 NOx VOC Amm Weighted emissions

score Cumulative Weighted emissions score

Catawba 5,153 78,620 27,968 19,760886 59.7 59.7
Caldwell 1,104 634 3,530 11,122391 18.1 77.8
Burke 1,198 877 4,601 7,721 562 17.0 94.8
Alexander 365 349 988 3,312 1,217 5.1 99.9 Rutherford 2,323 30,023 12,135 4,847 254 28.4 Iredell 1,537 1,365 11,065 10,3462,090 25.3 Cleveland 1,258 1,261 4,975 6,591 1,240 18.4 Wilkes 966 647 2,890 5,097 5,300 15.3 Mc Dowell 751 373 3,675 4,230 214 13.6 Lincoln 785 513 2,880 4,556 645 10.8 Watauga 541 352 1,523 2,370 341 8.5 Avery 269 163 730 985 77 4.4


### Based on the analysis for this factor, there appears to be emissions in the MSA counties of Caldwell and Burke, counties that contribute to the violation in Catawba County. Although there are large SO2

### emissions in Rutherford county, adjacent to Burke, the source is distant from the violating monitor.

### 6-228 Factor 2: Air Quality in potentially included versus excluded areas
2001-2003 Design Value
Catawba 15.5 Mc Dowell 14.2 Watauga 10.9


### There is one monitor in this area, in Catawba County, which is violating the particulate matter standard of 15.0 micrograms per cubic meter (mg/m3

### ). Two adjacent counties contain monitors attaining the standard. Factor 3: Population Density and Degree of Urbanization The following table has the populations for the counties in the Hickory-Morganton-Lenoir area and adjacent counties with significant emissions. (MSA counties are inbold.)

2002 Population% Population of MSA Population Density (pop./ mi2)

Catawba 146,690 42.0 367
Caldwell 78,513 22.5 166
Burke 89,638 25.7 177
Alexander 34,400 9.8 132 Rutherford 63,287 112 Iredell 130,178 227 Cleveland 97,960 211 Wilkes 66,773 88


### Based on the analysis for this factor, there appears to significant populations in Catawba, Iredell, Cleveland, Caldwell and Burke counties, indicating potential contribution. Factor 4: Traffic and commuting patterns Commuting Information Total commuters in Catawba County: 73, 984 Commuters in Catawba County, NC, who work in Catawba County: 62, 459 (84%)

### 6-229 Total commuters in Rutherford County: 27, 673 Commuters in Rutherford County, NC, who work in Rutherford County: 21, 812 (79%) Commuters from Rutherford County, NC to Burke County, NC: 305 (1%) Total commuters in Caldwell County: 38, 970 Commuters in Caldwell County, NC, who work in Caldwell County: 26, 932 (69 %) Commuters from Caldwell County, NC to Catawba County, NC: 8,011 (21 %) Total commuters in Burke County: 42,214 Commuters in Burke County, NC, who work in Burke County: 29, 123 (69%) Commuters from Burke County, NC to Catawba County, NC: 8,366 (20%) Total commuters in Alexander County: 31, 041 Commuters in Alexander County, NC, who work in Alexander County: 24, 270 (51%) Commuters from Alexander County, NC to Catawba County, NC: 5,679 (32%) Most of the commuters in Iredell, Cleveland and Wilkes counties commute within their counties and very few of them commute to Davidson County. Based on commuting patterns, Caldwell, Alexander and Burke counties appear to have the most potential impact on the violating monitor in Catawba county. The following table contains the vehicle miles traveled (VMT) for the counties in theHickoryMorganton-Lenoir MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are inbold.)

2002 VMT (thousands of miles) Catawba 2,048
Caldwell 738
Burke 1,112
Alexander229 Rutherford606 Iredell 1,901 Cleveland 1,125 Wilkes 619


### Based on the analysis for this factor, Burke County has VMT that appears to contribute to the air quality in Catawba County. Although the adjacent counties of Iredell and Cleveland have significant levels of VMT, there is little commuting to Catawba County from these counties.

### 6-230 Factor 5: Expected growth The following table has the population and population growth figures for counties in the Hickory-Morganton-Lenoir MSA and some adjacent counties with significant emissions

. 2002 Population Growth '90-'00 Pct change '90-'00

Catawba 146,690 23,273 20
Caldwell 78,513 6,706 9
Burke 89,638 13,404 18
Alexander 34,400 6,059 22 Rutherford 63,287 5,981 11 Iredell 130,178 29,729 32 Cleveland 97,960 11,573 14 Wilkes 66,773 6,239 11


### Based on the analysis for this factor, there appears to be significant growth on a percentage in Catawba and Alexander Counties in the MSA and adjacent Iredell County, indicating a potential contribution to the air quality in Catawba County. Although the percentage growth is high for the Iredell County, it is more closely associated with the Charlotte area. Factor 6: Meteorology The following meteorological information was provided by North Carolina. This summarizes the wind directions for the MSA during the time periods when PM2.5

### values are the highest. Summertime: southwesterly winds and recirculating patterns dominate. Main urban areas of influence include Charlotte, the Triad, and Hickory. Wintertime: More northerly and stronger northwesterly winds observed that during the summer. High PM2.5 is generally observed prior to frontal passages when high pressure is in control or during strong nocturnal low-level temperature inversions. Year-round trajectories indicate influence from nearby states. The information provided is not sufficient to provide a compelling argument to exclude counties based on prevailing winds.

Factor 7: Geography/topography

### 6-231 There are no significant topographical issues associated with this MSA.
Factor 8: Jurisdictional boundaries The 8-hour nonattainment boundary designation for the Hickory-Morganton-Lenoir area includes the entire counties of Alexander and Catawba and partial counties of Burke and Caldwell. The nonattainment designation in Burke and Caldwell counties are along the Unifour Metropolitan Planning Organization boundaries. Catawba County is located geographically between Alexander and Lincoln Counties, which both have monitors violating the 8-hour ozone standard. In Catawba County, a second monitor was operated approximately 10 miles southwest of the current violating Hickory monitor. This monitor was further removed from a major highway. The location of this monitor at a rescue squad and was not able to continue at that location. While in existence for seven quarters, this monitor showed an average of 1.89mg/m3

### lower than the current violating monitor. Therefore, the state believes that this monitor would have continued to show attainment/unclassifiable if it remained in existence to collect three years of data.
Factor 9: Level of control of emission sources Duke Power - Marshall Steam Station (Catawba County) No scrubbers are installed at this time. However, in 2004, Duke Power began installation of flue gas desulfurization (scrubber) equipment. This equipment will lower sulfur dioxide emissions by approximately 90 percent. The project is scheduled for completion in 2007. The state initiatives are listed below: NOx SIP Call The Clean Smokestacks Act Clean Air Bill On Board Diagnostics II Emissions Inspection Program PM2.5

### Forecasting Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendations on June 29, 2004, included a portion of Burke and Caldwell Counties. Upon further review of additional information provided by the State, EPA is revising its recommendation and is designating Burke and Caldwell Counties as attainment/ unclassifiable. The State of North Carolina has taken a proactive approach to solving its air pollution problems. Several programs have been implemented and will continue to be implemented to control PM2.5 pollution. The State has a robust PM2.5 monitoring network. The Clean Smokestacks Act requires NOx controls to be operated year round and requires substantial SO2 reductions from

### 6-232 power plants. The NOx and SO2 reductions must be generated within the State. As a statewide effort, several mobile source controls have been implemented including I/M programs in Burke and Caldwell Counties beginning July 1, 2005. Burke County has expected decreases in NOx of 1.29 tpd and VOC of 0.23 tpd while Caldwell County has expected decreases in NOx of 0.20 tpd and VOC of 0.17 tpd. Additionally, Burke and Caldwell Counties are in the Unifour Early Action Compact and this area shows attainment of the 8-hour ozone NAAQS with 2004 data. Burke County, NC: Most of the MSA emissions are generated in Catawba County. Burke emissions in tons per year are as follows: PM emissions 1,198 TPY (15.3% of MSA), SO2 emissions 877 TPY (only 1.1% of MSA), NOx emissions 4,601 TPY (12.4% of MSA). Burke County has a population of 89,638 as compared to Catawba County’s population of 146,690 people. In addition, Burke has a VMT of 1,112 thousand miles as compared to Catawba County’s VMT of 2,048. Of42,214 (24% of MSA) commuters in Burke County, 29,123 (69.0%) commuters stay within the county. There are no large point sources of precursor emissions and the majority of emissions are due to mobile emissions, which are controlled as described above. Caldwell County, NC: Most of the MSA emissions are generated in Catawba County. Caldwell emissions in tons per year are as follows: PM emissions 1,104 TPY (14.1% of MSA), SO2 emissions 634 TPY (only 0.8% of MSA), NOx emissions 3,530 TPY (9.5% of MSA). Caldwell County has a population of 78,513 as compared to Catawba County’s population of 146,690 people. In addition, Caldwell has a VMT of 738 thousands of miles as compared to Catawba County’s VMT of 2,048. Of38,970 (23% of MSA) commuters in Caldwell County, 26,932 (69.1%) commuters stay within the county. There are no large point sources and the majority of emissions are due to mobile emissions, which are controlled as described above. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Hickory–Morganton–Lenoir, NCarea: Catawba

. 

### 6.4.5 EPA 9-Factor Analyses for South Carolina for the Designation of Nonattainment Areas for PM2.5 6.4.5.1 Greenville-Spartanburg-Anderson Area In February 2004, South Carolina recommended that the entire state be designated attainment. Currently, all monitors with three years of complete data are attaining the Particulate Matter standard of 15.0 micrograms per cubic meter (mg/m3). However, Greenville County has a monitor that has not been in operation for three years, but is indicating potential to violate the PM 2.5 standard. Anderson and Spartanburg counties have emissions and population levels that potentially contribute to the high levels at the Greenville monitor in question. Therefore, EPA is modifying the State’s recommendation to designate Anderson, Greenville and Spartanburg counties as unclassifiable. Once the monitor has operated for three full years, EPA in

### 6-233 conjunction with the State will reassess the situation and revise the designation based on three years of data.

Area EPA Recommendation State Recommendation Greenville-Spartanburg-Anderson, SC Full Counties: Anderson, Greenville, and Spartanburg as unclassifiable Full Counties: None



### Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area Region 4’s analysis for factor 1 looks primarily at PM2.5, SOx, NOx, VOC, ammonia emissions and weighted emissions data. A score is assigned for each county reflecting the speciation profile of the urban increment and the corresponding weighted emissions of the MSA/CMSA. These scores add to 100 for the MSA/CMSA counties and are referred to as weighted emissions scores. Counties adjacent to the CSA can then be assigned an weighted emissions score based on the MSA/CMSA as a way to compare the emissions from those counties the MSA/CMSA counties. The following table has 2001 PM2.5, SO2, NOx, VOC and Ammonia (Amm) emissions in tons, and weighted emissions scores for the Greenville-Spartanburg-Anderson Area and surrounding counties. The Metropolitan Statistical Area (MSA) counties are inbold

. PM SO2 NOx VOC AmmWeighted emissions

score Cumulative Weighted emissions

score SC Spartanburg30702351 19046 23897 821 29.7 29.7 SC Greenville 27933369 15407 28867 861 27.4 57.1 SC Anderson 29049903 11559 13621 1090 22.9 80.0 SC Pickens 14281239 5153 7489 274 12.5 92.5 SC Cherokee 834 1270 4121 3538 301 7.4 SC York 25259714 12206 15064 1325 22.5 NC Rutherford 23233002312135 4847 254 17.0 NC Cleveland 12581261 4975 6591 1240 11.4 SC Newberry 979 353 3682 3813 1357 11.0 SC Laurens 1027597 5262 4846 414 10.2 NC Henderson 1068419 4088 7066 358 10.1 SC Greenwood 1095624 3680 4353 404 10.0 SC Oconee 1058298 3561 4867 1457 9.7 NC Jackson 588 303 1344 1846 216 6.7 NC Macon 555 307 1164 1798 262 6.3 SC Union 549 849 2027 2047 197 5.8 GAHabersham 651 103 1757 2201 3031 5.6 NC Transylvania449 3259 2824 3388 106 5.4 GARabun 455 66 943 1606 341 5.1 SC Abbeville 474 208 1384 1538 203 4.7 GAElbert 410 71 1357 1280 343 3.8 GAFranklin 449 84 2068 1813 4128 3.7 GA Stephens 406 277 1480 2075 976 3.5 GAHart 505 63 1321 1595 1516 3.2

### 6-234 NC Polk 266 105 1299 1149 256 3.1 

### Based on the analysis for this factor, there appears to be emissions in Spartanburg and Anderson counties that contribute to the air quality in Greenville County. The emissions in Pickens and Cherokee Counties are much less and father from the Greenville monitor with potential violation. Factor 2: Air Quality in potentially included versus excluded areas

2001-2003 Design Value SCSpartanburg13.7 SCGreenville 14.5 SCYork 14.0 SCGreenwood 13.1 SCOconee 10.6 NCJackson 13.0 

### All of the monitors in this area with three years of complete data are attaining the particulate matter standard. However, there is a monitor in Greenville County, SC with less than three years of data that indicates a potential to violate the stardard of 15.0mg/m3. Factor 3: Population Density and Degree of Urbanization The following table has the populations for the counties in the Greenville-Spartanburg-Anderson area and adjacent counties with significant weighted emissions scores.

2002 Population % Population

of MSA Population Density (pop./mi2)
SCSpartanburg259,322 26.3 320 SCGreenville 391,334 39.6 494 SCAnderson 170,578 17.3 238 SCPickens 113,097 11.4 228 SCCherokee 53,524 5.4 136 SCYork 173,755 254 NCRutherford 63,287 112 

### Based of the analysis for this factor, there appears to be significant populations to indicate a contribution by Spartanburg and Anderson counties. Factor 4: Traffic and commuting patterns Commuting Information Total commuters in Greenville County: 185,461 Commuters in Greenville County, SC who work in Greenville County: 24,270 (87%) Total commuters in Spartanburg County: 117,096 Commuters in Spartanburg County, SC, who work in Spartanburg County: 95,496 (82%)

### 6-235 Commuters from Spartanburg County, SC to Greenville County, SC: 14,586 (12%) Total commuters in Anderson County: 76,098 Commuters in Anderson County, SC, who work in Anderson County: 52,133 (69%) Commuters from Anderson County, SC to Greenville County, SC: 13,766 (18%) Total commuters in Pickens County: 52,130 Commuters in Pickens County, SC, who work in Pickens County: 28,951 (56%) Commuters from Pickens County, SC to Greenville County, SC: 15,095 (29%) Total commuters in Cherokee County: 22,999 Commuters in Cherokee County, SC, who work in Cherokee County: 16,052 (70%) Commuters from Cherokee County, SC to Greenville County, SC: 431 (2%) Greenville County has the largest number of commuters in Greenville-Spartanburg-Anderson MSA. There appears to be significant commuting from Spartanburg, Anderson, and Pickens Counties to indicate a contribution to the monitor in Greenville County. The following table has the vehicle miles traveled (thousands of miles) for the counties in the Greenville-Spartanburg-Anderson area and some adjacent counties with significant weighted emissions scores. (MSA counties are inbold).

2002 VMT SCSpartanburg3,509 SCGreenville 3,664 SCAnderson 2,163 SCPickens 1,180 SCCherokee 754 SCYork 1,860 NCRutherford 606 

### Based on the analysis for this factor, there is contribution to air quality in Spartanburg, Greenville, Anderson, Pickens, and York counties. Factor 5: Expected Growth The following table has the population and population growth figures for counties in the Greenville-Spartanburg-Anderson area and some adjacent counties with significant weighted emissions scores.

2002 Population Growth ’90-‘00 % Change ’90-‘00 SCSpartanburg259,322 26,991 12 SCGreenville 391,334 59,449 19 SCAnderson 170,578 20,544 14 SCPickens 113,097 16,863 18 SCCherokee 53,524 8,031 18

### 6-236 SCYork 173,755 33,117 25 NCRutherford 63,287 5,981 11 

### Based on the analysis for this factor, there appears to be significant growth in Greenville, Spartanburg, Anderson, Pickens and York counties indicating a potential contribution to the air quality in Greenville County. Factor 6: Meteorology No meteorological information was provided by South Carolina. This factor did not play a significant role in the decision making process. Factor 7: Geography/topography The counties of Greenville, Spartanburg, Pickens, and York are located on the northern border of South Carolina, which borders the state of North Carolina. No geographical or topographical data was provided by South Carolina. This factor did not play a significant role in the decision making process.
Factor 8: Jurisdictional boundaries This factor did not play a significant role in the decision making process.
Factor 9: Level of control of emission sources South Carolina is subject to the NOx SIP Call and the Greenville-Spartanburg-Anderson MSA is participating in Early Action Compacts. This factor did not play a significant role in the decision making process. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as unclassifiable for theGreenville-Spartanburg, SC area: Anderson, Greenville, and Spartanburg. 6.4.6 EPA 9-Factor Analyses for Tennessee for the Designation of Nonattainment Areas for PM2.5 6.4.6.1 Chattanooga Area The Chattanooga MSA contains the following Tennessee counties: Marion and Hamilton; and the following Georgia Counties: Dade, Walker, and Catoosa. Based on air quality data for 2001- 2003, the monitor with the highest design value in Hamilton County has a design value of 16.1 and the monitor in Walker County has a design value of 15.6. No other counties in the MSA contain ambient air monitors. The State of Tennessee recommended as nonattainment the county

### 6-237 of Hamilton and the State of Georgia recommended as nonattainment the county of Walker. The States have recommended that all other counties be designated attainment. The State of Tennessee submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. EPA is modifying the State of Tennessee’s recommendation and will review the additional information during the 120 day period following the notification letter. EPA has received some information from the State of Tennessee that Marion (MSA) County should be designated attainment for the PM2.5 standard and no justification from the State of Georgia indicating that any other counties should be included or excluded from the Chattanooga PM2.5 nonattainment area. Adjacent counties with significant emissions include McMinn and Roane Counties which are attached to the Knoxville nonattainment area and Floyd County which is a separate nonattainment area. Additionally we have included in our recommended nonattainment area Jackson County, AL, that is adjacent to the Chattanooga MSA, that is generally rural in character, and that contains an identifiable large emitting facility or facilities (e.g., power plants) which we believe contribute to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment. Therefore EPA is modifying the States’ recommendations to include all of the counties in the MSA and the adjacent county of Jackson, Alabama.

Area EPA Recommendation States Recommendations Chattanooga Fullcounties:Marion, Hamilton,TN;Dade,Walker, Catoosa, GA; Jackson, AL Fullcounties:Hamiltonand Walker



### Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons and weighted emissions scores for the counties in the Chattanooga MSA and some adjacent counties. (MSA counties are in bold.)

### 6-238 County PM SOx NOx VOC Amm Weighted Emissions

Score Cumulative Weighted Emissions

Score Hamilton 1,498 5,300 20,04827,150 1,022 49.5 49.5 Walker 856 632 2,798 4,516 958 17.9 67.4 Marion 679 477 3,156 2,640 501 14.1 81.5 Catoosa 617 167 3,085 3,601 680 11.9 93.4 Dade 302 107 2,415 1,574 285 6.5 99.9 Roane 4967 92331 30865 4300 285 296.9 Jackson, AL 4389 44333 31502 4742 1494 176.1 Floyd, GA 10057 31821 22736 7139 976 154.0 McMinn 3348 10216 10829 5546 1268 73.3 Whitfield, GA2732 1747 7283 7386 991 54.2 Rhea 1405 302 2625 3643 149 31.2 Loudon 804 4035 5899 5338 360 24.3 DeKalb, AL 1193 741 4776 5867 5765 21.3 Bradley 1233 419 4230 7551 1916 21.1 Warren 1164 1189 1869 3675 446 20.7 Monroe 743 154 2387 3420 554 16.4 Gordon, GA 872 200 3645 4019 2630 15.8 Fannin, GA 614 65 887 1266 283 14.2 Franklin 644 482 2100 2929 1512 13.4 Chattooga, GA450 1228 1834 1634 197 11.7 Murray, GA 576 130 2067 1700 910 11.4 Polk 295 2066 900 949 553 11.3 Cherokee, NC428 143 921 1753 111 10.6 Grundy 202 164 1000 1150 1170 4.8 Bledsoe 203 31 475 528 335 4.5 Meigs 198 112 885 871 118 4.3 Sequatchie 140 22 304 591 173 3.4 Van Buren 118 178 291 320 74 3.3 

### Based on the analysis for this factor there appears to be emissions in all MSA counties and the adjacent county of Jackson, AL, which show a potential to contribute. Other adjacent counties with large emissions (McMinn and Roane, TN and Floyd, GA) are included in other nonattainment areas. Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001-2003 PM2.5 Design Values for all Chattanooga MSA Counties and adjacent counties. (MSA counties are in bold.)

County 2001-2003 design value Hamilton 16.1 Walker 15.6 Roane 14.2 Floyd, GA 15.7

### 6-239 McMinn 14.6 Loudon 15.4 * DeKalb, AL 14.7 

### * Incomplete data that is not sufficient to determine attainment/nonattainment. Data substitution does not apply. Based on this factor, Hamilton County, TN and Walker and Floyd Counties in GA are violating the PM 2.5 standard. Catoosa County, GA is located between violating monitors in Hamilton and Walker Counties. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Chattanooga MSA and some adjacent counties. Urban population figures were not available. (MSA counties are in bold.) County 2002 Population Percent of MSA Population (2002) 2002 Population Density (people/mile^2) Hamilton 309,321 65.7 570 Walker 61,949 13.2 139 Marion 27,654 5.9 55 Catoosa 56,341 12.0 348 Dade 15,615 3.3 90 Roane 52,316 145 Jackson, AL 54,035 50 Floyd, GA 92,606 181 McMinn 50,051 116 Whitfield, GA 87,037 300 

### Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by the following MSA counties: Hamilton, Walker, and Catoosa. The five adjacent counties also have population with a potential to contribute. Factor 4: Traffic and commuting patterns Commuting Information Hamilton has a working population of 146, 824 –Commuters who remain in Hamilton: 133,644 (91%) Marion has a working population 11766. –Commuters who remain in Marion: 5596 (48%) –Commuters from Marion to Hamilton: 4271 Dade has a working population of 6983. –Commuters who remain in Dade: 2363 –Commuters from Dade to Hamilton:3091 (44%) –Commuters from Dade to Walker: 747

### 6-240 Catoosa has a working population of 26710. –Commuters who remain in Catoosa: 7167 –Commuters from Catoosa to Hamilton: 12320 (46%) –Commuters from Catoosa to Walker:1937 Walker has a working population of 27223. –Commuters who remain in Walker: 11244 (41%) –Commuters from Walker to Hamilton: 9098 Whitfield, GA has a working population of 38,909 –Commuters who remain in Whitfield: 33,796 (87%) –Remaining commuters do not commute to the Chattanooga MSA DeKalb, AL has a working population of 7798 –Commuters who remain in DeKalb: 5179 (66%) –Remaining commuters do not commute to the Chattanooga MSA The following table contains the vehicle miles traveled (thousand miles) for the counties in the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are in bold.)

County 2002 VMT (thousand miles/year) Hamilton 3,743 Walker 742 Marion 654 Catoosa 810 Dade 512 Roane 784 Jackson, AL 786 Floyd, GA 948 McMinn 787 Whitfield, GA 1423 

### Based on the analysis for this factor the VMT for all MSA counties indicate a potential to contribute. Although Whitfield County has a relatively high VMT, none of the commuters go to the Chattanooga MSA. Factor 5: Population Growth

### 6-241 The following table has the population and population growth figures for the Chattanooga MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are in bold.)

County 2002 Population Growth (90-00) % Growth (90-00) Hamilton 309,321 22360 8 Walker 61,949 2713 5 Marion 27,654 2916 12 Catoosa 56,341 10818 25 Dade 15,615 2007 15 Roane 52,316 4683 10 Jackson, AL 54,035 6130 13 Floyd, GA 92,606 9314 11 McMinn 50,051 6632 16 Whitfield, GA 87,037 11063 15 

### Based on the analysis for this factor, there appears to be significant growth on a percentage basis in Catoosa County that indicates a contribution to the air quality in the Chattanooga MSA. Factor 6: Meteorology This factor did not play a significant role in the decision making process. Factor 7: Geography/topography The Chattanooga area does not have any geographical or topographical boundaries limiting its airshed.
Factor 8: Jurisdictional boundaries Hamilton and Meigs Counties, TN and Catoosa County, GA were designated nonattainment for the 8-hour ozone standard on April 15, 2004. This factor did not play a significant role in the decision making process.
Factor 9: Level of control of emission sources Sources in the Chattanooga area are subject to Prevention of Significant Deterioration (PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology (CTG RACT) - (Hamilton County only), Maximum Achievable Control Technology (MACT) for Hazardous Air Pollutants (HAP), New Source Performance Standards (NSPS), and the NOx SIP call. This factor did not play a significant role in the decision making process. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States

### 6-242 EPA’s initial nonattainment recommendation on June 29, 2004 included Marion County, TN as part of the Chattanooga nonattainment area. Upon further analysis, including the review of additional material submitted by the state, EPA is revising its recommendation and designating Marion County as attainment/unclassifiable. Marion County, TN Marion County has a small population (27,654) and population density (55 people/mile2

### ). There are no large point sources and the County only contributes 17.2 percent of the total MSA PM2.5 emissions (679 tpy), 7.1 percent of the total SO2 emissions (477 tpy), and 10.0 percent of the total NOx emissions (3156 tpy). In addition, the topography analysis indicates that the Lookout Mountain Ridge (2100 feet) separates the Marion County emissions from the violating monitors. The County is located to the west of the ridge while the violating monitors reside to the east of the ridge. McMinn County, TN See the McMinn County Section in the Knoxville, TN TSD. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Chattanooga, TN-GAarea: Hamilton.
6.4.6.2 Knoxville Area The Knoxville, TN MSA contains the counties of Anderson, Blount, Knox, Loudon, Sevier and Union. Based on air quality data for 2001-2003 the following MSA counties contain PM2.5 ambient air monitors (Design values are included in parenthesis): Knox County (16.8), Blount County (14.4), and Loudon County (15.4). Two adjacent Tennessee counties also contain PM2.5 monitors: Roane County (14.2), and McMinn County (14.6). In a February 12, 2004 letter, the State recommended that Knox, Roane, and McMinn Counties be designated nonattainment based on 2000-2002 monitoring data. The State revised its recommendation on May 7, 2004, to recommend that McMinn and Roane Counties be designated attainment due to 2001-2003 data. Therefore, the State’s current recommendation for the Knoxville MSA PM2.5 nonattainment area only includes Knox County and recommends that all other MSA and adjacent counties be designated attainment. The State submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. Union County has very small amounts of PM2.5 and precursor emissions, indicating no contribution. Therefore, EPA agrees that Union County should be designated attainment/unclassifiable. Roane and McMinn, counties adjacent to the MSA, currently contain attaining ambient air monitors, however, Roane and McMinn counties have significant SO2 and NOx emissions which contribute to the violations. EPA is modifying the State’s recommendation and will review the additional information during the 120 day period following the notification letter.

### 6-243 We have included in our recommended nonattainment area Roane County that is adjacent to the Knoxville MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility or facilities (e.g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of the county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment. Based on EPA’s analysis of the available information, EPA is modifying the recommended nonattainment area to include all of the MSA counties, except Union, and the adjacent counties of Roane and McMinn.

Area EPA Recommendation State Recommendation Knoxville, TN Fullcounties:Anderson,Blount, Knox,Loudon,Sevier,Roane,and McMinn Full counties: Knox



### Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table contains the 2001 PM2.5, SOx, NOx, VOC, and ammonia emissions in tons per year and weighted emissions scores for the counties in the Knoxville MSA and some adjacent counties. (MSA counties are in bold.)

County PM SOx NOx VOC Amm Weighted Emissions

Score Cumulative Weighted Emissions

Score

### 6-244 Knox 19953005 23648 29966 1220 28.6 28.6 Anderson 289145986 23020 5328 265 27.5 56.1 Blount 35352999 5282 8250 606 22.4 78.5 Sevier 711 433 2838 4756 472 9.4 87.9 Loudon 804 4035 5899 5338 360 8.8 96.7 Union 325 156 1057 1067 184 3.2 99.9 Roane 496792,331 30865 4300 285 38.0 McMinn 334810216 10829 5546 1268 27.0 Rhea 1405302 2625 3643 149 18.1 Haywood, NC12188701 8669 4923 547 14.8 Jefferson 1407183 3220 4194 662 14.4 Scott 1113122 1338 1813 294 11.1 Monroe 743 154 2387 3420 554 9.6 Cumberland 682 181 3682 3989 532 8.6 Whitley, KY 521 675 3646 3017 171 8.1 Campbell 527 268 3323 3323 161 7.5 Claiborne 509 165 1420 2554 475 6.0 McCreary, KY346 188 1414 904 52 5.8 Cocke 400 247 2507 2361 357 5.5 Swain, NC 12.93 28 141 567 1210 199 5.3 Morgan 288 98 1252 929 222 4.3 Graham, NC 209 70 377 981 47 3.2 Grainger 288 80 893 1647 287 3.2 Meigs 198 112 885 871 118 2.4 

### Based on the analysis of emissions, there appears to be very small emissions in Union County for all the relevant pollutants. The other counties in the MSA and the counties of McMinn and Roane have significant emissions of some or all of the relevant pollutants, indicating contribution to the violations. Factor 2: Air quality in potentially included versus excluded areas The following table contains the 2001-2003 PM2.5 Design Values for all Knoxville MSA Counties and adjacent counties. (MSA counties are in bold.)

### 6-245 County 2001-2003 design value
Knox 16.8 Blount 14.4 Loudon 15.4 * Roane 14.2 McMinn 14.6 Haywood, NC 13.6 Swain, NC 12.9 

### * Incomplete data that is not sufficient to determine attainment/nonattainment. Data substitution does not apply. There are two monitors in the MSA that are violating and one MSA monitor (Blount County) that is attaining. The four monitors in adjacent counties are attaining. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table contains the populations for the counties in the Knoxville MSA and some adjacent counties with significant weighted emissions scores. (MSA counties are in bold.) County 2002 Population Percentof MSA Population (2002) Population Density (People/ mile2) Knox 389327 55.3 765 Anderson 71627 10.2 212 Blount 109849 15.6 197 Sevier 74456 10.6 126 Loudon 40631 5.8 177 Union 18541 2.6 83 Roane 52316 145 McMinn 50051 116

### 6-246 Based on the analysis for this factor, there appears to be population sufficient to indicate a contribution by Knox, Anderson, Blount, and Sevier Counties and the adjacent counties of Roane and McMinn. Union County has very low population and population density supporting an attainment/unclassifiable designation. Factor 4: Traffic and commuting patterns Commuting Information - Following is an analysis of the commuting in the Knoxville MSA. Knox County has the most commuters of any of the MSA counties. As described below, 86 % of the Knox County commuters remain in Knox County, contributing 79 % of the commuting in Knox County. People from Blount and Anderson Counties commute to Knox County contributing approximately 7% and 4 %, respectively, with the remaining MSA counties contributing 3 % or less. Union County has the smallest number of commuters and the least contribution to the Knox County monitor. Knox County, the core MSA county, has a total of 184,824 commuters. - Commuters who remain in Knox County: 158,292 Anderson County, an MSA county has a total of 30,688 commuters - Commuters that remain in Anderson County: 20,029 - Commuters from Anderson County to Knox County: 8,115 Blount County, an MSA county, has a total of 49,250 commuters - Commuters that remain in Blount County: 31,298 - Commuters from Blount County to Knox County: 13,611 Loudon County, an MSA county, has a total of 17,671 commuters. - Commuters who remain in Loudon County: 8,951 - Commuters from Loudon County to Knox County: 4,580 Sevier County, an MSA county, has a total of 34,389 commuters - Commuters who remain in Sevier County: 25,388 - Commuters from Sevier County to Knox County: 6,522 Union County, an MSA county, has a total of 7,302 commuters - Commuters who remain in Union County: 2,573 - Commuters from Union County to Knox County: 3,873 The following table contains the vehicle miles traveled (thousands of miles) for the counties in the Knoxville MSA and some adjacent counties.

### 6-247 County 2000 VMT (thousand miles/year) Knox 5135 Anderson 875 Blount 1205 Sevier 724 Loudon 728 Union 126 Roane 784 McMinn 787 

### Knox and Blount counties contain 58 % and 14 % of the VMT of the MSA VMT, respectively. The remaining counties contribute less than 10 % each of the MSA VMT with Union County contributing 1 %. The small contribution from Union County supports an attainment/unclassifiable designation. The adjacent counties each contribute an amount equivalent to 9 % of the total MSA VMT. (The VMT from the adjacent counties was not used to calculate the total MSA VMT.) Factor 5: Expected growth The following table has the population and population growth figures for the Knoxville MSA counties and some adjacent counties with significant weighted emissions scores. County 2002 Population Growth (90-00) % Change (90-00) Knox 389327 46283 14 Anderson 71627 3080 5 Blount 109849 19854 23 Sevier 74456 20127 39 Loudon 40631 7831 25 Union 18541 4114 30 Roane 52316 4683 10 McMinn 50051 6632 16 

### The population growth has been relatively high for all of the MSA counties on a percentage basis, except Anderson, indicating potential contribution to the particulate matter levels in the MSA. Anderson County contributed only 3 % of the MSA growth. Although the percent growth in Union County was 30 %, its contribution to the MSA growth was only 4 %. McMinn and Roane Counties (adjacent) have a percent growth of 16 % and 10 %, respectively.

### 6-248 Factor 6: Meteorology This factor did not play a significant role in the decision making process. Factor 7: Geography/topography This factor did not play a significant role in the decision making process.
Factor 8: Jurisdictional boundaries Knox, Anderson, Blount, Jefferson, Loudon, Sevier Counties and a portion of Cocke County were designated nonattainment for the 8-hour ozone standard. This factor did not play a significant role in the decision making process
. Factor 9: Level of control of emission sources Anderson, Blount, Jefferson, Loudon, Sevier-Subject to Prevention of Significant Deterioration (PSD) requirements, Control Technology Guidelines Reasonable Available Control Technology (CTG RACT, Maximum Achievable Control Technology (MACT) for Hazardous Air Pollutants (HAP), New Source Performance Standards (NSPS) This factor did not play a significant role in the decision making process. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendation on June 29, 2004 included McMinn, Roane, and Sevier Counties, TN as part of the Chattanooga nonattainment area. Upon further analysis, including the review of additional material submitted by the state, EPA is revising its recommendation and designating McMinn County as unclassifiable and Sevier County as attainment/unclassifiable. EPA is designating a portion of Roane County that encompasses the TVA Kingston power plant as nonattainment. The remainder of Roane County will be designated as attainment/unclassifiable. McMinn County, TN The McMinn County emissions, represented in the table below, indicate that the county does not contribute to the violations in Knoxville. The county is located outside of the Metropolitan Statistical Area, has a small population (50,051), and low population density (116 people/mile2

### ). McMinn County and the State of Tennessee submitted additional information, correcting the emissions for Bowater Newsprint and for McMinn County. The corrected emissions data for McMinn County emissions are represented in tons per year in the following table:

County PM 2.5 SO2 NOx VOC Ammonia McMinn 1479 5775 10701 5004 1250

### 6-249 Based on incomplete monitoring data and data substitution not being a viable alternative, EPA has changed its June 2004 recommendation of nonattainment and is designating McMinn County unclassifiable. The county had monitoring data for 2000-2002 that was violating and has incomplete data for 2001-2003. Applying the data substitution policy will not confirm attainment. Sevier County, TN Sevier County has low emissions. The data indicate that the county only contributes 7.0 percent of the total MSA PM2.5 emissions (711 tpy), 0.8 percent of the total SO2 emissions (433 tpy), and 4.6 percent of the total NOx emissions (2838 tpy). The County is located within the Metropolitan Statistical Area, however it has a small population (74,456), 10.6 percent of the MSA population. Additionally, the County has a population density of 126 people/mile2

### which is low compared to Knox County that has a population density of 765 people/mile2



### . Roane County, TN In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant to include it in the nonattainment area. Roane County, Tennessee is one of those counties. Roane County has low population (52,316 compared to 389,327 in Knox County, the predominant county in the Knoxville MSA), low population density (145 people per square mile compared to 765 in Knox County), low VMT (784,000 miles compared to 5,135,000 in Knox County ), and the only large point source is the Kingston Fossil Plant. Additionally, Roane County has a monitor that is indicating attainment with a design value of 14.2 (2001-2003). A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. The State of Tennessee subsequently submitted a partial county recommendation that included the Kingston Fossil Plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free-standing portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not

### 6-250 be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifier (StateFIPs-CoFIPs-Tract#-Block Group#) 47-145-0307-2 portion of Roane County as part of the Knoxville nonattainment area. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for theKnoxville, TN area: Anderson, Blount, Knox, Loudon, and Roane (Partial). Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as unclassifiable for the McMinn County, TN area: McMinn.

### 6- 251 

## 6.5 Region 5 Nonattainment Areas
6.5.1EPA 9-Factor Analyses for Illinois for Designation of PM2.5 Nonattainment Areas The following table identifies the individual areas and counties comprising those areas in Illinois that EPA is designating as nonattainment for the fine particulate matter ("PM2.5") air quality standard. Where EPA is including only part of a county in a nonattainment area, we have indicated the boundaries of the portion of the county that will be included. Following this table is a description of the data EPA examined and a discussion of each area and the basis for EPA's designations. EPA is designating as attainment/unclassifiable all other Illinois counties or parts thereof not identified in the table below.

Area Illinois Counties in Metropolitan AreaIllinois Recommended Nonattainment Counties Counties EPA is Designating NonattainmentChicago-GaryKenosha, IL-INWI Cook Du Page Kane Lake Mc Henry Will Grundy Kendall De Kalb Kankakee Cook Du Page Kane Lake Mc Henry Will Grundy: Aux Sable Township Goose Lake Township Kendall: Oswego Township Cook Du Page Kane Lake Mc Henry Will Grundy: Aux Sable Township Goose Lake Township Kendall: Oswego TownshipSaint Louis, MOIL Madison Monroe St Clair Clinton Jersey Madison Monroe St Clair Madison Monroe St Clair Randolph: Baldwin Township



### 6.5.1.1 Chicago-Gary-Kenosha Area Discussion: EPA reviewed the nine factors for the thirteen counties within the metropolitan area (including ten counties in Illinois) as well as all counties adjacent to the metropolitan area in order to determine the appropriate nonattainment area. There are violating monitors in Cook County and in Lake County, Indiana. EPA agrees with the Illinois EPA to include Cook, Du Page, Kane, Lake, Mc Henry, and Will counties, Aux Sable and Goose Lake Townships in Grundy County, and Oswego Township in Kendall County in the Chicago nonattainment area. The bulk of emissions and population are captured without including DeKalb, Grundy, Kankakee and Kendall Counties, since these counties have limited emissions and population. Nevertheless, we support the recommendation by the Illinois EPA to include the three townships in Grundy and Kendall counties in the nonattainment area to maintain consistency with the ozone designations and thereby facilitate planning.

### 6- 252 There are eight Illinois counties adjacent to the metropolitan area, including Boone, Ford, Iroquois, LaSalle, Lee, Livingston, Ogle, and Winnebago Counties. Emissions are relatively low for these counties, and no other factor warranted designating these counties nonattainment. Therefore, the following data summaries for factors 3 through 9 do not address these counties. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area County SO2 NOx Carbon Crustal Composite emissions score Cook 61,676 195,428 10,110 8,268 33.0 De Kalb 445 4,885 384 1,875 1.0 Du Page 2,990 29,479 1,731 1,229 4.9 Grundy 6,149 9,589 563 1,235 2.1 Kane 1,395 9,490 1,047 2,326 2.8 Kankakee 551 6,628 490 1,720 1.4 Kendall 292 2,941 265 961 0.7 Lake 14,223 24,488 2,092 1,777 6.7 Mc Henry 637 5,834 564 1,992 1.6 Will 80,847 37,518 1,447 4,120 11.7 Lake, IN 50,110 72,142 5,708 7,588 19.5 Porter, IN 21,601 41,315 2,702 5,587 9.2 Kenosha, WI 33,122 27,469 770 1,236 5.4 Boone 849 2,188 215 834 

### 0.6 Ford 219 1,462 216 1,280 

### 0.6 Iroquois 458 4,177 452 2,290 

### 1.3 La Salle 2,140 13,984 845 3,352 

### 2.5 Lee 3,978 4,793 345 1,722 

### 1.3 Livingston 503 4,686 485 2,413 

### 1.3 Ogle 672 4,985 335 1,536 

### 1.1 Winnebago 1,100 10,496 656 1,405 

### 1.9 Benton, IN 101 1,326 215 724 

### 0.5 Berrien, IN 1,390 10,269 740 1,340 

### 0.6

### 6- 253 Jasper, IN 34,435 23,020 668 1,838 

### 5.2 La Porte, IN 10,974 19,681 826 1,643 

### 3.3 Newton, IN 89 1,321 160 642 

### 0.4 Pulaski, IN 111 1,187 196 667 

### 0.5 St Joseph, IN 2,850 13,690 1,482 1,825 

### 4.0 Starke, IN 100 2,852 188 551 

### 0.5 White, IN 188 2,495 292 1,185 

### 0.8 Racine, WI 2,309 7,252 662 890 

### 1.9 Walworth, WI 866 5,693 470 908 1.3



### Urban increment: Total mass= 3.6 μg/m3 

### 25% sulfates; 8% nitrates; 65% carbon; 2% crustal. Urban site= 170310076; Rural site= BOND1 (Bondville) Factor 2:Air quality in potentially included versus excluded areas County 2001-2003 Design Value Cook 17.3 μg/m3 Du Page 14.4 μg/m3
Kane 14.2 μg/m3
Lake 12.8 μg/m3 Mc Henry 12.7 μg/m3
Will 12.8 μg/m3 Lake, IN 15.2 μg/m3 Porter, IN 13.8 μg/m3 Kenosha, WI 11.7 μg/m3
La Porte 

### 13.6 μg/m3 La Salle 

### 14.1 μg/m3 Winnebago 

### 13.6 μg/m3 St Joseph, IN 

### 14.3 μg/m3 Berrien, MI 12.7 μg/m3

### 6- 254 Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas County 2003 Population Population Density Cook 5,377,507 5,684 De Kalb 91,561 144 Du Page 924,589 2,768 Grundy 38,839 92 Kane 443,041 850 Kankakee 104,657 154 Kendall 61,222 191 Lake 674,850 1,506 Mc Henry 277,710 460 Will 559,861 669 Lake, IN 487,016 980 Porter, IN 150,403 360 Kenosha, WI 154,433 566


### Factor 4: Traffic and commuting patterns County County VMT Percent Number Cook 44,107,000 12 274,167 De Kalb 729,000 31 13,894 Du Page 6,609,000 40 186,686 Grundy 530,000 46 8,431 Kane 841,000 43 82,968 Kankakee 889,000 19 9,122 Kendall 278,000 67 19,070 Lake 3,549,000 32 100,810 Mc Henry 792,000 47 62,415 Will 2,136,000 55 131,834 Lake, IN 5,012,000 25 52,922 Porter, IN 1,680,000 36 25,819

### 6- 255 Kenosha, WI 1,228,000 28 20,506


### Factor 5: Expected growth County Percent growth 1990-2000 Cook 5 De Kalb 14 Du Page 16 Grundy 16 Kane 27 Kankakee 8 Kendall 38 Lake 25 Mc Henry 42 Will 41 Lake, IN 2 Porter, IN 14 Kenosha, WI 17 

### Factor 6: Meteorology Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Cook 26 37 16 21 De Kalb 27 34 19 21 Du Page 26 37 17 21 Grundy 26 36 17 21 Kane 26 35 18 21 Kankakee 25 38 17 19 Kendall 26 36 17 21 Lake 26 `37 17 20 Mc Henry 28 32 19 20 Will 26 37 17 21

### 6- 256 Lake, IN 25 38 17 19 Porter, IN 25 38 18 19 Kenosha, WI 28 35 18 20


### Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Illinois has no features that significantly influenced EPA’s intended nonattainment areas.

Factor 8: Jurisdictional boundaries The Chicago Area Transportation Study (CATS) Policy Committee is the Metropolitan Planning Organization (MPO) for the northeastern Illinois region. -source: CATS web page,http://www.catsmpo.com/ The Illinois portion of the Chicago ozone nonattainment area consists of the following counties: Cook, Du Page, Kane, Lake, Mc Henry, Will, Aux Sable and Goose Lake Townships in Grundy County, and Oswego Township in Kendall County.
Factor 9: Level of control of emission sources The state provided no information about the level of control of emission sources for this area. 

## 6.5.1.2 Saint Louis Area
Discussion: EPA reviewed the nine factors for the counties within the metropolitan area as well as counties adjacent to the metropolitan area in order to determine the appropriate nonattainment area. There are violating monitors in Madison and St. Clair counties as well as in the City of Saint Louis. EPA agrees with the Illinois EPA to include Madison, Monroe and St. Clair counties in the Illinois portion of the St. Louis nonattainment area. In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA proposed the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area.

### 6- 257 Illinois recommended a designation of unclassified for a portion of Randolph County, specifically Baldwin Township, which contains the Baldwin power plant. EPA is designating Baldwin Township in Randolph County nonattainment as part of the Saint Louis nonattainment area. EPA notes that the Baldwin plant has recently reduced its emissions significantly. The Illinois submission did not indicate whether these emission reductions are enforceable or how much potential exists for further emission reductions at this facility such as annual operation of its NOx emission controls. Randolph County adjoins a county that is monitoring a violation of the standard, and the most significant emissions are located in Baldwin Township, the portion of the county closest to the violation. These emissions are located where winds would commonly blow the emissions toward the observed violations. Emissions are moderately high even after the recent reductions. EPA concludes that these emissions are sufficient to contribute to violations in the Saint Louis area. There are 11 other Illinois counties adjacent to the Metropolitan Area, namely Bond, Calhoun, Fayette, Greene, Macoupin, Marion, Montgomery, Morgan, Pike, Sangamon, and Washington Counties. Emissions for these counties are relatively low and no other factor warranted designating the adjacent counties nonattainment. Therefore, the following data summaries for factors 3 through 9 do not address these counties. Besides Randolph County, Illinois also recommended a designation of unclassifiable for Jersey County, and recommended attainment for all other counties in the state that are not part of the recommended Saint Louis or Chicago nonattainment areas. EPA is designating as attainment/unclassifiable all counties that are not part of the Saint Louis or Chicago nonattainment areas. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area County SO2 NOx Carbon Crustal Composite emissions score Clinton 624 3,717 238 1,067 2.0 Jersey 246 1,755 165 544 1.2 Madison 69,938 37,593 1,563 4,425 16.8 Monroe 244 2,489 206 647 1.6 St Clair 4,471 11,813 863 1,996 6.8 Franklin, MO 45,216 15,482 918 2,864 9.1 Jefferson, MO 52,671 13,612 1,160 3,291 10.4 Lincoln, MO 221 2,935 273 1,358 2.1 St Charles, MO 40,596 25,793 896 2,415 10.2 St Louis, MO 30,400 53,358 3,456 2,897 27.4 Warren, MO 324 1,803 205 674 1.5 St Louis (City), MO 14,647 27,193 1,214 958 11.0 Bond 177 1,883 137 628 

### 1.1 Calhoun 192 1,162 88 170 

### 0.7 Fayette 290 2,795 223 786 

### 1.7 Greene 196 1,409 159 771 

### 1.2 Macoupin 281 3,123 344 1,415 

### 2.5

### 6- 258 Marion 297 3,879 290 891 

### 2.3 Montgomery 38,079 18,254 625 2,230 

### 7.6 Morgan 24,066 6,713 500 1,725 

### 4.7 Pike 6,252 4,850 259 901 

### 2.4 Randolph 23,984 33,023 559 1,863 

### 8.9 Sangamon 16,411 19,811 900 2,742 

### 8.7 Washington 167 2,045 199 814 

### 1.5 Crawford, MO 110 2,199 183 396 

### 1.4 Dent, MO 100 521 121 431 

### 0.8 Gasconade, MO 248 1,727 132 393 

### 1.0 Iron, MO 34,225 1,851 140 291 

### 2.1 Madison, MO 47 727 86 143 

### 0.6 Montgomery, MO 364 1,740 145 719 

### 1.2 Perry, MO 349 2,776 218 531 

### 1.7 Phelps, MO 754 2,990 244 645 

### 1.9 Pike, MO 15,205 10,931 206 773 

### 3.3 St Francois, MO 697 4,204 328 825 

### 2.5 Ste Genevieve, MO 3,666 7,315 255 940 

### 2.7 Washington, MO 152 1,161 137 322 1.0 

### Urban increment: Total mass= 6.2 μg/m3 

### 8% sulfates; 29% nitrates; 58% carbon; 5% crustal. Urban site= 295100085; Rural site= MING1 (Mingo) According to information provided in Illinois’ submittal of September 1, 2004, the Baldwin Plant in Baldwin Township represents approximately 96% of the SOX

### emissions and 86% of the NOX

### emissions for Randolph County. Therefore, designating Baldwin Township as nonattainment will capture the bulk of emissions from Randolph County. Factor 2: Air quality in potentially included versus excluded areas County 2001-2003 Design Value Madison 17.5 μg/m3
St Clair 16.2 μg/m3 Jefferson, MO 14.5 μg/m3 St Charles, MO 14.3 μg/m3 St Louis, MO 14.0 μg/m3 St Louis (City), MO 15.2 μg/m3 Randolph 

### 12.4 μg/m3

### 6- 259 Sangamon 

### 13.3 μg/m3 Ste Genevieve, MO 13.6 μg/m3


### Factor 3:Population density and degree of urbanization including commercial development in included versus excluded areas County 2003 Population Population Density Clinton 35,855 76 Jersey 21,858 59 Madison 261,409 361 Monroe 29,058 75 St Clair 257,904 388 Franklin, MO 95,890 104 Jefferson, MO 203,993 310 Lincoln, MO 42,280 67 St Charles, MO 303,030 540 St Louis, MO 1,018,102 2,004 Warren, MO 26,193 61 St Louis (City), MO 338,353 5,457 Randolph 33,641 58 

### Factor 4: Traffic and commuting patterns County County VMT Percent Number Clinton 375,000 35 5,915 Jersey 196,000 51 5,259 Madison 2,768,000 35 43,125 Monroe 264,000 57 8,172 St Clair 2,857,000 36 40,389 Franklin, MO 1,391,000 36 16,422 Jefferson, MO 2,511,000 63 61,991 Lincoln, MO 493,000 52 9,622 St Charles, MO 2,738,000 52 77,347 St Louis, MO 11,553,000 27 134,153 Warren, MO 348,000 54 6,414 St Louis (City), MO 4,178,000 40 56,734 Randolph 278,000 20 2,798 

### Factor 5: Expected growth County Percent growth 1990-2000 Clinton 5 Jersey 5 Madison 4 Monroe 23 St Clair

-3 Franklin, MO 16

### 6- 260 Jefferson, MO 16 Lincoln, MO 35 St Charles, MO 33 St Louis, MO 2 Warren, MO 26 St Louis (City), MO

-12 Randolph

-2 

### Factor 6: Meteorology Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Clinton 28 29 29 15 Jersey 28 28 29 15 Madison 28 28 29 15 Monroe 28 28 29 15 St Clair 28 28 29 15 Franklin, MO 27 27 31 15 Jefferson, MO 28 27 31 15 Lincoln, MO 27 27 31 15 St Charles, MO 29 27 30 15 St Louis, MO 29 27 30 15 Warren, MO 27 27 31 16 St Louis (City), MO 29 27 30 15 Randolph 28 28 29 15 

### Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Illinois has no features that significantly influenced EPA’s intended nonattainment areas.
Factor 8: Jurisdictional boundaries The East-West Gateway Council of Governments (EWGCC) is the Metropolitan Planning Organization (MPO) for the bi-state St. Louis area. -source: EWGCC web page,http://www.ewgateway.org/ The Illinois portion of the Saint Louis ozone nonattainment area consists of the following counties: Jersey, Madison, Monroe, and St. Clair.
Factor 9: Level of control of emission sources The State has provided no information about the level of control of emission sources for this area. Although EPA is aware that the Baldwin Generating Station is purchasing low sulfur coal and has installed NOx emission controls on some of its units, EPA does not

### 6- 261 have information as to the permanence of those reductions and whether the NOx emission controls are operated on an annual basis.
6.5.2EPA 9-Factor Analyses for Indiana for Designation of PM2.5 Nonattainment Areas The following table identifies the individual areas and counties comprising those areas in Indiana that EPA is designating as nonattainment for the fine particulate matter ("PM2.5") air quality standard. Following this table is 1) discussion of the general issue of the size of nonattainment areas, 2) a description of the data EPA examined, and 3) a discussion of each area and the basis for EPA's designations. EPA is designating as attainment/unclassifiable all counties or portions of counties not identified in the table below, except that EPA is designating Delaware County in the Muncie area as unclassified because it has insufficient information to justify either a nonattainment or an attainment designation for this area.

Area Indiana Counties in Metropolitan Area Indiana Recommended Nonattainment Counties Counties EPA is Designating Nonattainment Chicago-Northwest Indiana 

### Lake Porter 

### Lake Lake Porter Cincinnati 

### Dearborn Ohio None 

### Dearborn: Lawrenceburg Township Elkhart Elkhart Elkhart 

### Elkhart Saint Joseph Evansville 

### Vanderburgh Warrick Posey Vanderburgh Dubois 

### Dubois Vanderburgh Warrick Gibson: Montgomery Township Pike: Washington Township Spencer: Ohio Township Indianapolis 

### Boone Hamilton Hancock Hendricks Johnson Madison Marion Morgan Shelby Marion 

### Hamilton Hendricks Johnson Marion Morgan

### 6- 262 Louisville 

### Clark Floyd Harrison Scott Clark 

### Clark Floyd Jefferson: Madison Township 

### General Issue of Size of Nonattainment Areas Indiana’s recommendations for nonattainment areas included only counties that monitored nonattainment and did not include any additional counties that contributed to nonattainment. Indiana’s submissions noted several areas where relatively nearby monitors showed differing concentrations, for example Lake County monitoring nonattainment and Porter County monitoring attainment. Indiana deduces from this that the impacts of emissions within an area added to large "background concentrations" arising from long range transport are very localized. Therefore, Indiana concludes, counties lacking a monitored violation may be considered not to contribute to monitored violations in other counties. EPA’s guidance recommends a presumption for nonattainment areas that include entire metropolitan areas, reflecting a presumption that violations in a metropolitan area reflect contributions from the entire area. EPA’s guidance recognizes that violations of the PM2.5 standard reflect both regional scale impacts from contributions originating outside the metropolitan area and more local scale impacts. Indeed, the different components of PM2.5 have different ranges of impacts, with some components showing greatest impacts very close to the emissions sources, some components showing peak impacts at a moderate distance from the emissions (such as from rapid photochemical reactions), and some components showing similar impacts over distance ranges of hundreds of kilometers. Consequently, the existence of neighboring counties with somewhat different concentrations, like Lake County observing design values up to 15.2 μg/m3 versus the Porter County site having a design value of 13.8 μg/m3, does not signify that emissions in the county with lower concentrations fails to contribute to the higher concentrations in the neighboring county. Further considerations apply to mobile sources. By definition, these sources can be associated with a residence or business in one county but emit PM2.5 and its precursors in another county. Some of the relevant control measures address the “home” of these vehicles. This consideration supports including counties that are the origin of sizable numbers of vehicles in the nonattainment area. Indiana has not provided convincing evidence to rebut EPA’s general presumption or the underlying view of the typical characteristics of the PM2.5 problem, nor has Indiana demonstrated that the presumption does not apply in any Indiana areas. Therefore, EPA is including the additional counties that it believes contribute to the observed violations in the nonattainment areas it is promulgating.

### 6- 263 6.5.2.1 Chicago-Northwest Indiana Area DiscussionThe following is the nine-factor analysis for the Indiana portion of the ChicagoNorthwest Indiana area including adjacent counties in Indiana. The Chicago-GaryKenosha Metropolitan Area includes 10 counties in Illinois, two in Indiana and one in Wisconsin. Indiana recommended that Lake County, which has a violating monitor, be designated as nonattainment for PM2.5, and that Porter County, which has a monitor showing attainment, be designated as attainment/unclassified. However, EPA is designating both Lake and Porter Counties as nonattainment. Lake and Porter Counties both have high composite emissions scores. Although Porter County has a monitor which shows attainment, its emissions contribute to over 9% of the Chicago area composite emissions score largely as a result of significant power plant coal combustion and steel mill emissions as well as some emissions from mobile sources and other sources. The composite emissions scores from the adjacent counties are all modest. La Porte County, adjacent to the metropolitan area, is monitoring attainment of theannual PM2.5 standard and is judged not to contribute to nonattainment in the ChicagoNorthwest Indiana area. In addition, Porter has a sizeable population with over 150,000 residents, and over 21,000 workers travel into Lake County on a daily basis, thereby contributing to Lake County monitored PM levels. There is limited commuting from Jasper, La Porte, and Newton Counties into the metropolitan area. Lake County experienced very little growth from 1990 to 2000. During this time, Porter County added nearly 18,000 people. Jasper County growth rate was high, but even with the increase of 5,000 people, its population is still quite small for the area. EPA considered the emissions, population, and vehicle miles traveled (VMT) from Newton, Jasper, and La Porte Counties, which are adjacent to Lake and Porter Counties. Based upon the emissions, populations, and VMT, EPA is designating these three counties as attainment/unclassified. Other factors EPA reviewed are meteorology, geography, jurisdictional boundaries, and emission controls. The wind data presented below shows no dominant wind direction for Northwest Indiana. There are no geographical features in this area that would effect the distribution of PM2.5. Lake and Porter Counties are both included in the Chicago ozone nonattainment area. La Porte County is in a separate ozone nonattainment area. All three counties make up the area’s metropolitan planning organization. The state has not submitted any information on emission controls in Northwest Indiana.

### 6- 264 Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emissions score Lake, IN 50,110 72,142 5,708 7,588 19.5 Porter, IN 21,601 41,315 2,702 5,587 9.2 Cook, IL 61,676 195,428 10,110 8,268 33.0 De Kalb, IL 445 4,885 384 1,875 1.1 Du Page, IL 2,990 29,479 1,731 1,229 4.9 Grundy, IL 6,149 9,589 563 1,235 2.1 Kane, IL 1,395 9,490 1,047 2,326 2.8 Kankakee, IL 551 6,628 490 1,720 1.4 Kendall, IL 292 2,941 265 961 0.7 Lake, IL 14,223 24,488 2,092 1,777 6.7 McHenry, IL 637 5,834 564 1,992 1.6 Will, IL 80,847 37,518 1,447 4,120 11.7 Kenosha, WI 33,122 27,469 770 1,236 5.4 Benton 101 1,326 215 724 

### 0.6 Jasper 34,435 23,020 668 1,838 

### 5.2 La Porte 10,974 19,681 826 1,643 

### 3.3 Newton 89 1,321 160 642 

### 0.4 Pulaski 111 1,187 196 667 

### 0.5 Starke 100 2,852 188 551 

### 0.5 White 188 2,495 292 1,185 

### 0.8 Boone, IL 849 2,188 215 834 

### 0.6 Ford, IL 219 1,462 216 1,280 

### 0.6 Iroquois, IL 458 4,177 452 2,290 

### 1.3 La Salle, IL 2,140 13,984 845 3,352 

### 2.5 Lee, IL 3,978 4,793 345 1,722 

### 1.3 Livingston, IL 503 4,686 485 2,413 

### 1.3 Ogle, IL 672 4,985 335 1,536 

### 1.1 Winnebago, IL 1,100 10,496 656 1,405 

### 1.9

### 6- 265 Racine, WI 2,309 7,252 662 890 

### 1.9 Walworth, WI 866 5,693 470 908 1.3


### All emissions are from the 2001 NEI and are in tons. Metropolitan area counties are shown in bold. Speciation profile for Chicago: 25% Sulfates, 8% Nitrates, 65% Carbon, and 2% Crustal derived by comparing data from site number 170310076 in Chicago against data from the Bondville monitor. Factor 2: Air quality County 2001-03 Design Value Lake, IN 15.2 μg/m3 Porter, IN 13.8 μg/m3 Cook, IL 17.3 μg/m3 Du Page, IL 14.4 μg/m3 Kane, IL 14.2 μg/m3 Lake, IL 12.8 μg/m3 McHenry, IL 12.7 μg/m3 Will, IL 14.7 μg/m3 Kenosha, WI 11.7 μg/m3 La Porte, IN 13.6 μg/m3 

### Metropolitan area counties are shown in bold. Jasper and Newton Counties do not have monitors. Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Lake, IN 487,016 980 Porter, IN 150,403 360 Cook, IL 5,377,507 5684 De Kalb, IL 91,561 144 Du Page, IL 924,589 2768 Grundy, IL 38,839 92

### 6- 266 Kane, IL 443,041 850 Kankakee, IL 104,657 154 Kendall, IL 61,222 191 Lake, IL 674,850 1506 Mc Henry, IL 277,710 460 Will, IL 559,861 669 Kenosha, WI 154,433 566 Jasper 30,815 

### 55 La Porte 110,384 185 

### Metropolitan area counties are shown in bold. Factor 4: Traffic and commuting patterns County VMT Growth % Change Lake, IN 5,012,000 1,235,000 

### 25 % Porter, IN 1,680,000 38,000 14 % Cook, IL 44,107,000 12,254,000 28 % De Kalb, IL 729,000

-176,000

-24 % Du Page, IL 6,609,000 1,971,000 30 % Grundy, IL 530,000

-175,000

-33 % Kane, IL 841,000 309,000 37 % Kankakee, IL 889,000 281,000 32 % Kendall, IL 278,000 34,000 12 % Lake, IL 3,549,000 1,479,000 42 % Mc Henry, IL 792,000 234,000 29 % Will, IL 2,136,000 240,000 11 % Kenosha, WI 1,228,000 318,000 26 % Jasper, IN 722,000

-261,000 

### -36 % La Porte, IN 1,536,000

-343,000 -22 % 

### Metropolitan area counties are shown in bold. Commuting Information:

### 6- 267 Porter Jasper La Porte Illinois Into Lake County 21,654 2,817 1,783 

### 11,672 From Lake County 5,066 270 1,200 34,263

Jasper La Porte Illinois Into Porter County 988 4,238 

### 524 From Porter County 363 3,390 5,273



### Factor 5: Growth County % Population Change Lake 2 % Porter 14 % Cook, IL

-2 % De Kalb, IL 5 % Du Page, IL 1 % Grundy, IL 2 % Kane, IL 4 % Kankakee, IL 7 % Kendall, IL
-8 % Lake, IL
-1 % Mc Henry, IL 8 % Will, IL 9 % Kenosha, WI
-1 % Jasper 

### 20 % La Porte 3 % 

### Metropolitan area counties are shown in bold.

### 6- 268 Factor 6: Meteorology Year-round average wind direction for: Lake County, Indiana: 25% NW, 38% SW, 17% SE, 19% NE; Porter County:25% NW, 38% SW, 18% SE, 19% NE; Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA’s intended nonattainment areas.
Factor 8: Jurisdictional boundaries Lake and Porter Counties are both designated as nonattainment in the Chicago ozone nonattainment area. La Porte County is also designated as ozone nonattainment in its own area. Northwestern Indiana Regional Planning Commission is the MPO for Lake (Indiana), La Porte, and Porter Counties.
Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in Northwest Indiana.
6.5.2.2 Cincinnati Area Discussion The Cincinnati Metropolitan Area includes five Ohio counties, six Kentucky counties, and two Indiana counties: Dearborn and Ohio. Indiana did not recommend either of their counties for nonattainment in the Cincinnati area. After considering all nine factors for both counties, EPA is designating Lawrenceburg Township in Dearborn County as nonattainment. All other Dearborn County townships are being designated as attainment/unclassified. In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA proposed the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area.

### 6- 269 Data are provided for full counties only. Dearborn County’s main emissions sources including the Tanners Creek power plant are found in Lawrenceburg Township. Dearborn County has significant emissions yielding a composite emissions score of 11.4. This score ranks third in the three State, 13 county metropolitan area.The wind, with a westerly component 63% of the time, commonly transports Dearborn County emissions east into the rest of the Cincinnati area. Considering its modest population, a significant number of Dearborn County workers commute into the Ohio and Kentucky portions of the area. This shows that it is an integral part of the area. Dearborn County’s Lawrenceburg Township is also included as a partial county in the Cincinnati ozone nonattainment area. The county is in Cincinnati’s metropolitan planning organization as well. Because emissions are relatively low for the counties adjacent to the metropolitan area, and no other factor warranted designating these counties nonattainment, the following data summaries for factors 3 through 9 do not display these counties. Indiana noted some further emission reductions at the Tanners Creek power plant in Lawrenceburg Township of Dearborn County. However, EPA determined that these reductions reduced the composite emission score only from 11.4 to 10.2. EPA thus continues to believe that Lawrenceburg Township of Dearborn County contributes to violations in the Cincinnati area.
Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emission score Dearborn, IN 56,773 31,138 900 2,121 11.4 Ohio, IN 113 682 49 89 0.5 Boone, KY 14,717 15,794 721 1,068 7.7 Campbell, KY 860 5,294 285 260 2.8 Gallatin, KY 350 2,365 100 234 1.0 Grant, KY 210 2,664 182 191 1.8 Kenton, KY 1,573 8,365 415 301 4.2 Pendleton, KY 597 3,396 139 207 1.5 Brown, OH 395 2,927 208 520 2.0 Butler, OH 13,204 19,735 956 1,752 9.9 Clermont,OH 84,599 45,618 1,693 3,916 20.0 Hamilton, OH 88,053 58,398 2,780 3,873 30.3

### 6- 270 Warren, OH 895 7,565 743 1,063 6.9 Decatur 154 2,525 190 717 

### 1.8 Fayette 150 1,426 156 392 

### 1.4 Franklin 92 1,335 143 341 

### 1.3 Ripley 140 2,081 221 507 

### 2.0 Rush 140 1,274 177 814 

### 1.6 Switzerland 251 1,554 101 145 

### 1.0 Union 58 548 68 272 0.6



### All emissions are from the 2001 NEI and are in tons. Speciation profile for Cincinnati: 7% Sulfates, 15% Nitrates, 78% Carbon, 0% Crustal based on a comparison of data from site number 211170007 against data from the Livonia monitor. Factor 2: Air quality There are no PM2.5 monitors in the Indiana portion of the Cincinnati area. The design value for the metropolitan area is 17.8 μg/m3

### from Hamilton County, Ohio. The following are design values for Cincinnati area counties in Ohio and Kentucky with monitors.

County 2001-2003 Design Value Butler, OH 16.2 μg/m3 Hamilton, OH 17.8 μg/m3 Campbell, KY 14.5 μg/m3 Kenton, KY 15.0 μg/m3 Preble, OH 13.5 μg/m3 

### Factor 3: Population density and degree of urbanization including commercial development

County 2002 Population Population Density Dearborn, IN 47,333 

### 155 Ohio, IN 5,804 

### 67

### 6- 271 Boone, KY 93,290 

### 379 Campbell, KY 88,604 

### 583 Gallatin, KY 7,836 

### 79 Grant, KY 23,620 

### 91 Kenton, KY 152,164 

### 934 Pendleton, KY 14,815 

### 53 Brown, OH 43,464 

### 88 Butler, OH 340,543 

### 729 Clermont, OH 183,352 

### 406 Hamilton, OH 833,721 

### 2048 Warren, OH 175,133 438


### Factor 4: Traffic and commuting patterns County VMT Growth % Change Dearborn 607,000

-55,000 

### -9 % Ohio 56,000 64,000 114 % 

### Commuting Information:

Ohio Ripley Hamilton, OHButler, OH Boone, KY Kenton, KY Into Dearborn 906 1,082 1,335 163 350 

### 244 From Dearborn 311 1,095 7,672 750 1,466 459

Hamilton, OH Boone, KY Switzerland Into Ohio County 87 25 

### 393 From Ohio County 463 135 74



### Factor 5: Growth County % Population Change Dearborn 

### 19% Ohio 6%

### 6- 272 Factor 6: Meteorology Year-round average wind direction for Dearborn County, Indiana: 23% NW, 40% SW, 18% SE, 19% NE; Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA’s intended nonattainment areas.
Factor 8: Jurisdictional boundaries Lawrenceburg Township in Dearborn County is designated nonattainment for ozone as part of the Cincinnati ozone nonattainment area. The rest of this county and Ohio County are designated as attainment/unclassified for ozone. The Ohio-Kentucky-Indiana Regional Council of Governments (OKI) is the Metropolitan Planning Organization (MPO) for Butler, Warren, Clermont, and Hamilton Counties in Ohio; Campbell, Kenton, and Boone Counties in Kentucky; and Dearborn County, Indiana.
Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in this area.
6.5.2.3 Elkhart Area Discussion The Elkhart, Indiana Metropolitan Area consists solely of Elkhart County, which has a violating monitor. As a result of the violating monitor, Indiana recommended that it be designated as nonattainment. EPA also considered the impact of the surrounding seven counties. These counties in Indiana include Saint Joseph, Kosciusko, Marshall, Noble, Lagrange Counties, which Indiana recommended be designated as attainment for PM2.5 and in Michigan include Saint Joseph and Cass Counties. Of the surrounding counties, EPA is designating Saint Joseph County, Indiana, as nonattainment and the remaining six counties as attainment/unclassified. Over half of the composite emissions score for the eight counties is from Elkhart and Saint Joseph (Ind.) Counties. In fact, Saint Joseph County has the highest emissions score with emissions comparable to Elkhart County. In addition, Saint Joseph County has a large population with Elkhart County’s population being slightly less. The vehicle miles traveled (VMT) was significant in both counties. There are a large number of Elkhart County workers commuting from Saint Joseph County. Although Saint Joseph

### 6- 273 County has a monitor showing attainment, the particulate matter emissions from Saint Joseph County would reasonably be expected to contribute to concentrations in Elkhart County. This is because Saint Joseph County is directly west of Elkhart County and the winds are from the northwest or southwest 64% of the time. Elkhart and Saint Joseph Counties are designated as a single nonattainment for the ozone standard. Also, both counties are in the same metropolitan planning organization, the Michiana Area Council of Government. EPA is designating the remaining six counties as attainment/unclassified because they have much lower emissions, population, and VMT than Elkhart and Saint Joseph Counties.
Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emission score Elkhart 1,409 12,549 1,828 2,228 100.0 Kosciusko 428 5,387 679 1,682 

### 36.5 Lagrange 809 3,259 326 755 

### 28.8 Marshall 463 3,569 621 1,322 

### 33.6 Noble 390 3,740 457 1,302 

### 26.6 Saint Joseph 2,850 13,690 1,482 1,825 

### 114.1 Cass, MI 325 2,080 263 814 

### 17.1 St Joseph, MI 744 4,212 427 1,775 32.5


### Speciation profile for Elkhart: 25% Sulfates, 8% Nitrates, 65% Carbon, and 2% Crustal based on a comparison of data from site 170310076 (in Chicago) against data from the Bondville monitor. Adequate speciation data were not available from Elkhart. Factor 2: Air quality County 2001-03 Design Value Elkhart 

### 15.2 μg/m3 Saint Joseph 14.3 μg/m3


### Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Elkhart 186,465 

### 402 Saint Joseph 267,120 585

### 6- 274 Factor 4: Traffic and commuting patterns County VMT Growth % Change Elkhart 2,087,000 615,000 

### 29 % Saint Joseph 2,304,000 1,037,000 45 % 

### Commuting Information: 29,756 people commuted into Elkhart County in 2002. 107,500 people lived and worked in Elkhart County in 2002. Saint Joseph Into Elkhart County 

### 10,850 From Elkhart County 3,722



### Factor 5: Growth County % Growth 1990-2000 Elkhart 

### 17 % Saint Joseph 7 %


### Factor 6: Meteorology Year-round average wind direction for Elkhart County: 25% NW, 39% SW, 19% SE, 16% NE; 

### Saint Joseph County: 25% NW, 39% SW, 20% SE, 16% NE; Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA’s intended nonattainment areas.
Factor 8: Jurisdictional boundaries Elkhart and Saint Joseph counties are designated as a joint nonattainment area for the ozone air quality standard. The Michiana Area Council of Government is the MPO for Elkhart and Saint Joseph Counties.

### 6- 275 Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in the Elkhart area.
6.5.2.4 Southwest Indiana (Evansville Area) Discussion: The Evansville Metropolitan Area includes Warrick, Posey, and Vanderburgh Counties in Indiana and Henderson County in Kentucky. Dubois County is not part of a metropolitan area, according to 1999 Office of Management and Budget metropolitan area definitions. EPA also considered numerous other adjacent counties, particularly Gibson, Pike, and Spencer Counties. Both Vanderburgh and Dubois Counties have violating monitors and were recommended by Indiana to be designated as nonattainment for the PM2.5 standard. For the Evansville Area, EPA is designating a nonattainment area that includes Dubois, Vanderburgh, and Warrick Counties as well as portions of Gibson, Pike, and Spencer Counties. In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA proposed the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hourozone nonattainment areas). For purposes of consistency, EPA has decided that freestanding portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, Montgomery Township in Gibson County, Washington Township in Pike County, and Ohio Township in Spencer County are partial county areas included in the Evansville nonattainment area.

### 6- 276 Gibson, Spencer, Pike, and Warrick Counties have the highest emission levels in Southwest Indiana. Emissions of both direct PM2.5 and precursors are high for these counties, resulting in their high composite emission scores. Dubois and Vanderburgh Counties have design values exceeding the PM2.5 standard of 15.0 μg/m3

### , despite their more modest emissions. Spencer County, Indiana, and Daviess County, Kentucky are monitoring below the standard while the rest of the area including the adjacent counties have no monitors. Vanderburgh County is home to a majority of the Evansville area population. Commuting patterns show a connection between Vanderburgh and Warrick Counties. Population growth was modest for all counties being considered. Gibson and Pike Counties are located north of Vanderburgh County and west of Dubois County. Spencer and Warrick Counties are east of Vanderburgh County and south of Dubois County. The meteorological data presented under Factor 6 indicates no prevailing wind direction. The location of the area counties and the varied wind directions mean that Vanderburgh County or Dubois County will commonly be downwind from at least some of the high emissions sources in these counties. EPA believes that the high emissions in several counties in the area contribute to the violations recorded in Vanderburgh and Dubois Counties. Gibson, Pike, Spencer, and Warrick Counties all contain power plants with significant emissions that contribute to the violations in Dubois and Vanderburgh Counties. The townships identified above include these power plants.

Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emission score Posey 18,715 14,866 595 1,308 19.5 Vanderburgh 1,421 9,538 1,550 1,337 17.5 Warrick 102,206 28,647 1,655 4,940 52.3 Henderson, KY 6,308 8,075 418 971 10.7 Crawford 536 3,842 161 137 

### 4.3 Daviess 328 1,542 179 621 

### 24.2 Dubois 1,694 5,665 1,037 995 

### 11.3 Gibson 148,808 46,937 1,767 6,093 

### 76.3 Martin 110 797 193 252 

### 1.9 Perry 789 3,102 195 257 

### 4.0 Pike 63,626 28,567 745 2,209 

### 39.4

### 6- 277 Spencer 57,983 38,521 1,107 3,124 

### 49.5 Webster, KY 19,201 15,934 551 2,035 20.8 

### All emissions are from the 2001 NEI and are in tons. Metropolitan area counties are shown in bold. Speciation profile for Southwest Indiana: 20% Sulfates, 51% Nitrates, 23% Carbon, and 6% Crustalbased on a comparison of data from site number 210590014 (in Owensboro) against data from the Mammoth Cave monitor. The Indiana Power and Light Company Petersburg facility and the Hoosier Energy Ratts Station together represent approximately 99% of the SO2

### , 96% of the NOX

### , 83% of the carbonaceous particles and 88% of the crustal emissions for Pike County. Designating Washington Township as nonattainment captures these emissions and therefore the bulk of the emissions for Pike County. The Indiana Michigan Power Rockport facility and AK Steel Rockport Works together represent approximately 99% of the SO2

### , 91% of the NOX

### , 77% of the carbonaceous particles and 81% of the crustal emissions for Spencer County. Designating Ohio Township as nonattainment will capture the bulk of the emissions for Spencer County. The PSI Gibson facility represents approximately 99% of the Gibson County NOx and SO2

### emissions. Montgomery Township is in the Evansville nonattainment area because it captures most of the Gibson County emissions. Factor 2: Air quality County 2001-03 Design Value Vanderburgh 15.5 μg/m3 Henderson, KY 14.0 μg/m3
Dubois 

### 16.2 μg/m3 Spencer 

### 14.4 μg/m3 Daviess, KY 14.9 μg/m3


### There are no monitors in Gibson, Pike, Posey, or Warrick Counties. Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Posey 26,990 66 Vanderburgh 171,744 731 Warrick 53,624 140

### 6- 278 Henderson, KY 44,995 102 Dubois 40,015 

### 93 Gibson 32,590 

### 67 Pike 12,908 

### 38 Spencer 20,353 51 

### Metropolitan area counties are shown in bold. Factor 4: Traffic and commuting patterns County VMT Growth % Change Posey 508,000

-63,000 -12 % Vanderburgh 1,732,000 552,000 32 % Warrick 828,000

-166,000 -20 % Henderson, KY 510,000 271,000 53 % Dubois 479,000 39,000 

### 8 % Gibson 429,000 70,000 

### 17 % Pike 178,000 104,000 

### 58 % Spencer 392,000 47,000 12 % 

### Metropolitan area counties are shown in bold. Commuting Information: 29,553 people commuted into Vanderburgh County in 2002. 104,660 people lived and worked in Vanderburgh County in 2002.

Warrick Posey Gibson Spencer Pike Dubois Into Vanderburgh 14,522 5,484 3,509 1,056 393 

### 178 From Vanderburgh 1,891 1,355 1,696 103 39 84 

### 8,101 people commuted into Dubois County in 2002. 26,873 people lived and worked in Dubois County in 2002. Spencer Pike Gibson Warrick Into Dubois 1,494 1,653 236 

### 293 From Dubois 393 124 173 48

### 6- 279 Factor 5: Growth County % Growth 1990-2000 Posey 4 % Vanderburgh 4 % Warrick 17 % Henderson, KY 4 % Dubois 

### 8 % Gibson 

### 2 % Pike 

### 3 % Spencer 5 % 

### Metropolitan area counties are shown in bold. Factor 6: Meteorology Year-round average wind direction for Vanderburgh County:30% NW, 30% SW, 21% SE, 19% NE; Dubois County: 27% NW, 30% SW, 22% SE, 20% NE; 

### Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA’s intended nonattainment areas.
Factor 8: Jurisdictional boundaries Vanderburgh and Warrick Counties are designated as nonattainment for the ozone NAAQS. All other area counties are designated as attainment/unclassified. The MPO for the Evansville area, the Evansville Urban Transportation Study, covers Vanderburgh, Gibson, Posey, and Warrick Counties.
Factor 9: Level of control of emission sources The Indiana Michigan Power Rockport facility in Spencer County has installed low NOX 

### burners and over-fire air to reduce NOX

### and SO2

### emissions. Facility emissions information for the years 1999-2003 show an approximate reduction in NOX

### and SO2

### 6- 280 emissions of 10% and 15 %, respectively. For the years 2001-2003 the reductions are approximately 3% and 1% for NOX

### and SO2

### , respectively. 6.5.2.5 Indianapolis Area Discussion The Indianapolis Metropolitan Area includes nine Indiana counties: Boone, Hamilton, Hancock, Hendricks, Johnson, Madison, Marion, Morgan, and Shelby. Indiana recommended designating Marion County as nonattainment of the PM2.5 standard. The monitors in Marion County are showing a violation of the standard. Madison County’s monitor indicates concentrations below the annual PM2.5 standard of 15.0 μg/m3

### . No other area counties have monitored air quality data. The Indianapolis area has one central county, Marion County, ringed by the other eight counties. The eight outlying counties are all a similar distance from the central county with no intermediate counties. This configuration allows the EPA to consider a combination of emissions and wind data to estimate each county's potential contributions to violation of the annual PM2.5 standard in Marion County. A description of the methods for assessing this information is given along with the Indianapolis area emissions data below. EPA believes that this approach provides a fine tuned comparison of the potential of each of the counties surrounding Marion County to contribute to the violations recorded in Marion County. Marion County contributes about 50 percent of the emissions of the metropolitan area on a composite emissions basis. Consistent with its intended designations elsewhere, EPA believes that this indicates that more than just Marion County contributes to the violations, and that the planning area for evaluating strategies must include a greater fraction of emissions in the area. The wind-weighted emissions information suggests that Hamilton, Hendricks, Johnson, Madison, Morgan and Shelby Counties have significant potential to contribute to violations in Marion County. Conversely, this information suggests that Boone and Hancock have somewhat limited potential to contribute to violations in Marion County. EPA further examined the proximity of the emissions in the surrounding to the violations in Marion County and commuting and growth information. None of the Indianapolis urbanized area as defined by the U.S. Census Bureau is in Madison or Shelby Counties. As a result, Madison and Shelby Counties have less growth and less commuting into Marion County than other counties that are more integrally part of the Indianapolis area. Much of the population and emissions in Madison and Shelby Counties are in Anderson and Shelbyville, respectively. Thus, these emissions are at a greater distance from the violations in Marion County than the other counties, for which population and emissions tend to be concentrated at the edge of Marion County. Indiana stated that significant emission reductions have occurred in Hamilton County due to conversion of the Noblesville power plant to natural gas. However, EPA finds that

### 6- 281 even were this plant’s emissions to be eliminated, the remaining emissions in Hamilton County would still be sufficient to be considered to be contributing to violations in Marion County. For these reasons, EPA believes that Hamilton, Hendricks, Johnson, Marion, and Morgan Counties contribute to the violations in Marion County. This is why EPA is designating them as nonattainment. EPA believes that Boone, Hancock, Madison, and Shelby Counties do not contribute and were designated attainment/unclassified. EPA also concluded that none of the numerous counties that are outside but adjacent to the Indianapolis Metropolitan Area should be considered to contribute to the violations in Marion County.
Factor 1: Emissions Given the unique geography of the Indianapolis area, EPA calculated a wind-weighted emissions score as well as a composite emissions score for the Indianapolis area. The wind data used in calculating the wind-weighted score reflect the frequency of winds in the Indianapolis area from each of 16 directions. This data is provided under factor 6 below. The wind-weighted score is calculated as follows: for each of the eight counties surrounding Marion County, EPA identified the direction for which the winds would blow most directly over Marion County, and tabulated the sum of the frequency of winds for that direction and the two adjacent directions among the set of 16 directions. This frequency of being upwind was multiplied times the composite score to obtain a preliminary wind-weighted composite emissions score. These eight preliminary scores added up to 8.7. For Marion County, EPA retained the unweighted composite emissions score of 50.6. EPA then normalized the scores of the surrounding scores to add up to 49.4. Each county score was multiplied by 49.4/8.7, yielding the wind-weighted emissions score. The total of the wind-weighted emissions scores for all 9 counties is 100. The EPA derived wind-weighted emissions scores reflect the variability of frequency of winds from different directions. This process seeks to assess more precisely the relative potential impacts of the counties in the Indianapolis area. The following table has the SO2

### , NOx, carbon, and crustal emissions, the composite emissions scores, along with the wind-weighted emissions scores for the nine counties in the Indianapolis area. Emissions data and composite emissions scores are also provided for counties adjacent to the Indianapolis Metropolitan Area. All emissions are from the 2001 NEI and are in tons. County SO2 NOx Carbon Crustal Composite emissions score Wind-weighted emissions score
Boone 224 3,468 297 988 3.1 

### 3.1 Hamilton 5,215 9,251 730 1,635 8.0 

### 6.2

### 6- 282 Hancock 338 3,936 395 1,022 3.8 

### 2.8 Hendricks 773 5,802 593 1,596 5.7 

### 6.8 Johnson 338 5,165 416 918 4.4 

### 5.0 Madison 934 8,106 884 1,548 8.3 

### 6.0 Marion 49,549 52,848 4,891 4,429 50.6 

### 50.6 Morgan 17,343 8,303 554 1,362 7.0 

### 11.3 Shelby 329 6,212 1,141 1,277 9.1 

### 8.2 Bartholomew 520 5,309 659 1,382 5.9



### — Brown 46 828 132 131 1.1



### — Clay 243 2,057 209 641 2.0



### — Clinton 411 2,614 246 1,061 2.5



### — Decatur 154 2,525 190 717 2.1



### — Delaware 1,548 6,353 593 1,019 5.9



### — Fayette 150 1,426 156 392 1.5



### — Fountain 167 2,109 395 1,311 3.1



### — Grant 1,280 5,341 381 1,135 4.3



### — Henry 291 3,919 707 1,243 5.7



### — Jackson 260 3,427 341 533 3.3



### — Jefferson 39,599 33,990 549 1,368 11.2



### — Jennings 233 1,589 208 408 1.8



### — Monroe 2,168 4,852 545 647 5.1



### — Montgomery 1,072 4,099 691 1,213 5.7



### — Owen 100 1,052 118 273 1.1



### — Parke 125 3,140 389 571 3.5



### — Putnam 2,643 6,116 230 548 3.7



### — Randolf 494 2,731 232 968 2.4



### — Ripley 140 2,081 221 507 2.1



### — Rush 140 1,274 177 814 1.5



### — Scott 100 1,515 151 236 1.5



### — Tippecanoe 11,434 9,922 1,632 2,345 13.8



### —

### 6- 283 Tipton 81 1,040 158 730 1.3



### — Wayne 13,919 5,951 589 1,498 6.2

— 

### Speciation profile for Indianapolis: 3% Sulfates, 38% Nitrates, 59% Carbon, and 0% Crustal based on a comparison of data from site 180970078 against data from the Livonia monitor. Factor 2: Air quality County 2001-03 Design Value Madison 

### 14.6 μg/m3
Marion 16.7 μg/m3


### There are no monitors in Boone, Hamilton, Hancock, Hendricks, Johnson, Morgan, and Shelby Counties. Factor 3: Population density and degree of urbanization including commercial development County 2002 Population Population Density Boone 48,277 

### 114 Hamilton 205,610 

### 517 Hancock 58,343 

### 191 Hendricks 114,301 

### 280 Johnson 121,604 

### 380 Madison 132,068 

### 292 Marion 863,429 

### 2,180 Morgan 67,791 

### 167 Shelby 43,674 106



### Factor 4: Traffic and commuting patterns County VMT Growth % Change Boone 752,000

-160,000 

### -21 % Hamilton 1,807,000

-81,000 

### -5 %

### 6- 284 Hancock 732,000

-2,000 

### 0 % Hendricks 1,240,000 6,000 

### 0 % Johnson 1,368,000

-8,000 

### -1 % Madison 1,601,000 457,000 

### 29 % Marion 9,983,000 3,260,000 

### 33 % Morgan 913,000 17,000 

### 2 % Shelby 641,000

-30,000 -5 % 

### Commuting Information: 189,804 people commuted into Marion County in 2002. 489,449 people lived and worked in Marion County in 2002.

Into Marion From Marion Boone 9,905 

### 990 Hamilton 46,440 

### 10,958 Hancock 15,700 

### 1,487 Hendricks 33,009 

### 4,602 Johnson 29,458 

### 4,917 Madison 6,603 

### 755 Morgan 15,749 

### 807 Shelby 5,664 663



### Factor 5: Growth County %Growth 1990-2000 Boone 

### 21 % Hamilton 

### 68 % Hancock 

### 22 % Hendricks 

### 37 % Johnson 

### 31 % Madison 

### 2 % Marion 

### 8 % Morgan 

### 19 %

### 6- 285 Shelby 8 %


### Factor 6: Meteorology Indianapolis Airport wind data for 1984 to 1992 (9 year average, all seasons):

N 

### 5.07 % NNE 

### 4.11 % NE 

### 4.35 % ENE 

### 4.31 % E 

### 3.76 % ESE 

### 4.96 % SE 

### 5.95 % SSE 

### 4.94 % S 

### 7.22 % SSW 

### 7.76 % SW 

### 11.38 % WSW 

### 9.20 % W 

### 5.82 % WNW 

### 6.13 % NW 

### 6.27 % NNW 

### 5.43 % Calm 3.34 % 

### Wind directions for each county used in computing wind-weighted emissions scores: County Wind Directions Boone NNW NW 

### WNW Hamilton N NNE 

### NE Hancock ENE E 

### ESE Hendricks WSW W 

### WNW Johnson SSE S 

### SSW Madison NNE NE 

### ENE

### 6- 286 Morgan SSW SW 

### WSW Shelby ESE SE SSE


### Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The State of Indiana has no features that significantly influenced EPA’s intended nonattainment areas.
Factor 8: Jurisdictional boundaries Boone, Hamilton, Hancock, Hendricks, Johnson, Madison, Marion, Morgan, and Shelby Counties are all designated as nonattainment for the ozone air quality standard. The Indianapolis Metropolitan Planning Organization (MPO) serves Boone, Hamilton, Hancock, Hendricks, Johnson, Marion, Morgan, and Shelby Counties.
Factor 9: Level of control of emission sources The PSI Energy Noblesville power plant in Hamilton County was converted from burning coal to natural gas in 2003. This conversion significantly reduced NOX

### and SO2 

### emissions at this facility. However, when EPA recalculated composite emission scores assuming the complete elimination of emissions from this facility, the composite emission score declined only from 8.0 to 7.2.
6.5.2.6 Louisville Area Discussion The Louisville Metropolitan Area includes three Kentucky counties and Clark, Floyd, Harrison, and Scott Counties in Indiana. Several counties adjacent to the metropolitan area were evaluated, especially Jefferson County, Indiana. Indiana recommended designating Clark County as nonattainment of the PM2.5 standard. EPA is designating Clark and Floyd Counties and Madison Township in Jefferson County as non-attainment. In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA proposed the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area.

### 6- 287 A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hourozone nonattainment areas). For purposes of consistency, EPA has decided that freestanding portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, Madison Township in Jefferson County is a partial county area included in the Louisville nonattainment area. The monitor in Clark County is showing a violation of the standard. Floyd County’s monitor is just below the annual PM2.5 standard of 15 μg/m3

### . The emissions from both Floyd and Clark Counties are significant, with Floyd County’s emissions being greater. Jefferson County, Indiana also has a substantial level of emissions, the bulk of which is captured by designating Madison Township as nonattainment. There are relatively low emissions from Harrison and Scott Counties. The population in Clark and Floyd Counties dominates the Indiana population in the area. All metropolitan area counties had a similar growth rate. There is significant commuting between Clark and Floyd Counties and from both counties into the Kentucky portion of the Louisville area. Commuting from Harrison and Scott Counties to the rest of the metropolitan area is modest. There is very limited commuting from Jefferson County, Indiana. Meteorological data shows the wind is from the northeast about 21% of the time. Jefferson County, Indiana is located northeast of Clark and Floyd Counties. EPA believes that winds blow sufficiently frequent from the northeast and emissions from Jefferson County, Indiana, are sufficient that Jefferson County should be considered to contribute to violations in Louisville. Clark and Floyd Counties are included in the Louisville area ozone designations and with its metropolitan planning organization. The state did not provided any information on emission controls in the Indiana portion of the Louisville area. Jefferson County is adjacent to the Louisville Metropolitan Area and contains a power plant with significant emissions that contribute to the violations in the Louisville Metropolitan Area. These emissions are captured by designating Madison Township as nonattainment.

### 6- 288 Factor 1: Emissions County SO2 NOx Carbon Crustal Composite emissions score Clark 484 4,960 725 773 12.2 Floyd 47,796 10,282 954 2,301 16.4 Harrison 419 3,677 305 466 5.3 Scott 100 1,515 151 236 2.6 Bullitt, KY 343 3,463 433 379 7.3 Jefferson, KY 62,526 81,398 2,817 3,816 51.5 Oldham, KY 529 3,707 271 475 4.7 Crawford 536 3,842 161 137 

### 2.9 Jefferson 39,599 33,990 549 1,368 

### 11.2 Jennings 233 1,589 208 408 

### 3.5 Lawrence 4,330 5,707 376 909 

### 6.5 Orange 86 2,017 171 286 

### 2.9 Perry 789 3,102 195 257 

### 3.4 Washington 136 1,452 380 119 

### 3.1 Anderson, KY 443 1,535 144 180 

### 2.5 Breckinridge, KY 321 2,592 260 288 

### 4.4 Carroll, KY 53,086 26,269 821 2,177 

### 15.2 Franklin, KY 601 3,059 217 273 

### 3.8 Grayson, KY 412 1,532 235 341 

### 4 Green, KY 104 507 103 151 

### 1.7 Hardin, KY 1,774 7,695 524 644 

### 2.1 Hart, KY 162 1,839 188 193 

### 3.2 Henry, KY 156 1,465 125 288 

### 1.8 Larue, KY 186 768 108 180 

### 4.0 Marion, KY 143 801 147 225 

### 2.5 Meade, KY 661 4,551 227 439 

### 5.0 Nelson, KY 497 2,134 296 463 

### 4.0

### 6- 289 Owen, KY 57 572 126 105 

### 2.1 Shelby, KY 397 2,906 231 446 

### 1.7 Spencer, KY 31 393 102 174 

### 4.6 Taylor, KY 632 3,642 172 221 

### 3.1 Trimble, KY 7,998 8,458 249 506 

### 2.9 Washington, KY 115 618 110 157 1.8


### All emissions are from the 2001 NEI and are in tons. Metropolitan area counties are in bold. Speciation profile for Louisville: 0% Sulfates, 7% Nitrates, 93% Carbon, and 0% Crustal based on a comparison of data from site number 211110043 (in Louisville) against data from the Livonia monitor. The Clifty Creek Station in Madison Township represents approximately 99% of the SO2

### , 92% of the NOX

### , 62% of the carbonaceous particles and 76% of the crustal emissions for Jefferson County. Therefore, designating Madison Township as nonattainment will capture the bulk of Jefferson County’s emissions. Factor 2: Air quality

### 6-290 County 2001-03 Design Value Clark 16.2 μg/m3 Floyd 14.9 μg/m3 Bullitt, KY 15.0 μg/m3 Jefferson, KY 16.9 μg/m3


### There are no monitors in Harrison, Scott, and Jefferson Counties in Indiana. Factor 3: Population density and degree of urbanization including commercial development

County 2002 Population Population Density Clark 98,198 262 Floyd 71,633 484 Harrison 35,244 73 Scott 23,334 123 Bullitt 63,800 213 Jefferson 698,080 1813 Oldham 49,310 261 Jefferson 32,113 89


### Factor 4: Traffic and commuting patterns

County VMT Growth % Change Clark 1,262,000 144,000 11 % Floyd 843,000 292,000 35 % Harrison 528,000 79,000 15 % Scott 364,000

-89,000 -25 % Bullitt, KY 849,000

-178,000

-21 % Jefferson, KY 7,149,000 4,398,000 62 % Oldham, KY 507,000 2,000 0 % Jefferson 331,000 26,000 8 % 

### Commuting Information:

### 6-291 Floyd Harrison Scott Jefferson, IN Kentucky Into Clark County 5,224 1,376 866 198 

### 780 From Clark County 4,591 530 316 775 16,582

Harrison Scott Jefferson, IN Kentucky Into Floyd County 2,073 223 39 

### 466 From Floyd County 921 66 492 12,647



### Factor 5: Growth

County % Growth 1990-2000 Clark, IN 10% Floyd, IN 10% Harrison, IN 15% Scott, IN 9% Bullitt, KY 29% Jefferson, KY 4% Oldham, KY 39% Jefferson, IN 6%


### Factor 6: Meteorology Year-round average wind direction for Clark County, Indiana: 22% NW, 33% SW, 24% SE, 21% NE; Floyd County, Indiana: 22% NW, 32% SW, 25% SE, 21% NE; Factor 7: Geography/topography The geography/topography analysis looks at physical features of the land that might have an effect on the airshed, and therefore, the distribution of particulate matter over an area. The States of Indiana and Kentucky have no features that significantly influenced EPA’s intended nonattainment areas.

### 6-292 Factor 8: Jurisdictional boundaries Clark and Floyd Counties are designated as nonattainment in the Louisville ozone nonattainment area. Harrison, Scott, and Jefferson Counties in Indiana are designated as attainment/ unclassified. The Kentuckiana Regional Planning and Development Agency serves as the Metropolitan Planning Organization (MPO) for Clark and Floyd Counties in Indiana.
Factor 9: Level of control of emission sources Indiana has not submitted any information on emission controls in this area. 

## 6.5.2.7 Muncie Area
Discussion The Muncie area consists of Delaware County, Indiana. EPA is designating Delaware County as unclassifiable for the PM2.5 standard. This represents a modification of the State’s recommendation that this county be designated attainment/unclassifiable. Data must be collected for at least 75% of the scheduled days in a calendar quarter to meet the completeness criteria for showing attainment. Muncie has a single PM2.5 monitor that is scheduled to sample on every third day. In the first quarters of 2001 and 2003, this monitor recorded less than 75 percent of the scheduled values but more than 11 samples. EPA policy states that this quantity of data is insufficient to label an area as attainment, insofar as the data are considered complete. On the other hand, EPA policy states that this quantity of data is sufficient to label an area nonattainment, with the data being considered complete in this case. The following are the 3-year average values recorded at this site.

County 2000-02 Design Value 2001-03 Design Value Delaware 15.1 μg/m3 14.3 μg/m3 

### The annual PM2.5 standard is 15.0 μg/m3



### . Under EPA policy, the data for 2000 to 2002 are considered complete, and the data for 2001 to 2003 are considered incomplete. On the other hand, the most recent data suggest that the area is attaining the standard. Therefore, EPA concludes that it cannot currently judge the most appropriate designation for this area. EPA intends to promulgate either a nonattainment or an attainment/unclassifiable designation for this area once further data are available. EPA will consult further with the State once the necessary data become available.

### 6-293 6.5.3EPA 9-Factor Analyses for Michigan for Designation of PM2.5 Nonattainment Areas The following table identifies the individual areas and counties comprising those areas in Michigan that EPA is designating as nonattainment for the fine particulate matter ("PM2.5") air quality standard. EPA is designating as attainment/unclassifiable all other Michigan counties not identified in the table below.

Area Michigan Counties in Metropolitan Area Michigan Recommended Nonattainment Counties Counties EPA is Designating Nonattainment Detroit-Ann Arbor-Flint 

### Monroe Wayne Livingston Macomb Oakland St Clair Washtenaw Genesee Lapeer Lenawee 

### Monroe Wayne 

### Monroe Wayne Livingston Macomb Oakland St Clair Washtenaw



### 6.5.3.1 Detroit-Ann Arbor-Flint Area
Discussion: 

### EPA reviewed the nine factors for the counties within the metropolitan area as well as counties adjacent to the metropolitan area in order to determine the appropriate nonattainment area. There are violating monitors in Monroe and Wayne counties. EPA agrees with the Michigan DEQ to designate Monroe and Wayne counties as nonattainment. However, based upon our nine-factor analysis, EPA believes that in addition to Monroe and Wayne counties, the Detroit nonattainment area should also include Livingston, Macomb, Oakland, St. Clair, and Washtenaw counties as one contiguous area. These counties have significant emissions and the population, population density, and vehicle miles traveled (VMT) are at sufficient levels to be part of the designated area. This is consistent with the national approach of capturing the majority of emissions and population in a metropolitan area. Genesee, Lapeer, and Lenawee counties are also in the Metropolitan area but were excluded upon review of the 9 factors. Except for Genesee County, which is discussed below, these counties have lower emissions, population, population density, and VMT. Michigan supported its recommendation of attainment for most counties by attributing the violations in Wayne County predominantly to high emissions in Wayne County, and attributing the violation in Monroe County to emissions in Toledo, Ohio. Michigan notes the monitored attainment in Macomb County, and observes that trajectories for high and low concentration days in Wayne County indicate that the highest concentrations occur when winds are from the south and west. Michigan concludes from this evidence that the

### 6-294 Wayne County violations arise from a combination of long-range transport and very localized emissions, and that counties other than Wayne County do not contribute to violations in Wayne County. EPA disagrees with Michigan’s analysis. EPA’s guidance includes a presumption that the entire metropolitan area contributes to the nonattainment problem, reflecting evidence that the various types of emissions that lead to PM2.5 concentrations have impacts on many distance scales including metropolitan scale. Michigan has not provided a convincing demonstration that EPA’s presumption and the underlying understanding of the nature of PM2.5 is invalid or inapplicable to the Detroit area. The design value in Macomb County is 15.0 micrograms per cubic meter, just barely attaining the standard. While it is evident that Macomb County does not by itself cause violations in Wayne County, thewind data shown for factor 6 below demonstrate that winds often blow from Macomb County into Wayne County. While the wind blows from the southwest quadrant more frequently than other quadrants, the wind blows from the northwest or northeast quadrants about 40 percent of the time. Trajectory information can often be misleading; since a high fraction of observed PM2.5 concentrations are attributable to long range transport, trajectories for high concentration days tend to be a better measure of whether distant contributions to transported “background” concentrations are high rather than indicating high local contributions. Michigan’s analysis also does not address the contributions to Wayne County concentrations from mobile sources that originate in other counties. Although different components of PM2.5 have different geographic scales of impact, EPA continues to believe that emissions throughout a metropolitan area can contribute significantly to observed violations. Since a significant fraction of the Detroit area’s emissions occur in Livingston, Macomb, Oakland, St. Clair, and Washtenaw Counties, EPA believes that these contribute to nonattainment in Wayne and Monroe Counties. The composite emissions score for Genesee County is somewhat higher than that of Washtenaw County. EPA nevertheless believes that Washtenaw County contributes to violations in Wayne and Monroe Counties and Genesee County does not. Washtenaw County is upwind of Wayne and Monroe Counties somewhat more frequently than Genesee County. More importantly, Washtenaw County is closer to Wayne and Monroe Counties and the observed violations, which means that the emissions are likely to have a greater impact and mobile sources are more likely to be traveling into the violating counties. Finally, Washtenaw County is part of the Detroit ozone nonattainment area whereas Genesee County is part of a separate ozone nonattainment area, and the Detroit area metropolitan planning organization includes Washtenaw County and not Genesee County. Therefore, including Washtenaw County in the PM2.5 nonattainment area will facilitate coordinated ozone and PM2.5 planning. Michigan requested that Wayne and Monroe Counties each be treated as single county nonattainment areas. Michigan has not justified a conclusion that either of these counties may be considered single county nonattainment areas. While Monroe County may sometimes be considered part of the Toledo area (along with Lucas and Wood Counties, Ohio), particularly when winds are from the south, on such occasions Monroe County

### 6-295 also contributes to violations in Wayne County. The Detroit area also contributes to violations in Monroe County. Therefore, EPA intends to designate a single Detroit area nonattainment area that includes Monroe County. There are seven counties adjacent to the metropolitan area that are not a part of another violating metropolitan area. These counties have relatively low emissions, and no other factors warrant including these counties in the nonattainment area. Therefore, no data are provided for these counties under factors 3 to 9 below. Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emissions score Genesee 3,010 20,648 1,377 1,914 7.5 Lapeer 895 5,202 389 1,109 2.1 Lenawee 642 4,496 554 1,488 2.5 Livingston 701 8,024 852 1,695 4.0 Macomb 4,602 33,482 1,413 1,282 9.5 Monroe 126,037 62,432 1,565 4,834 15.1 Oakland 8,277 44,171 2,264 1,829 13.6 St. Clair 72,450 40,659 1,248 2,687 10.4 Washtenaw 2,163 14,980 944 1,502 5.3 Wayne 59,884 107,604 4,435 2,823 29.9 Hillsdale 1,286 3,270 245 812 

### 1.4 Ingham 13,381 17,912 648 1,126 

### 4.9 Jackson 1,093 7,895 599 1,269 

### 3.2 Saginaw 2,812 9,755 978 2,457 

### 4.8 Sanilac 397 2,893 422 1,429 

### 1.9 Shiawassee 768 3,749 318 1,024 

### 1.7 Tuscola 531 3,162 417 1,404 

### 1.9 Fulton, OH 878 5,105 336 692 

### 1.9 Lucas, OH 31,000 36,975 1,370 1,702 10.0 

### Urban increment: Total mass= 4.3 μg/m3 

### 0% sulfates; 54% nitrates; 42% carbon; 4% crustal. Urban site= 261630001; Rural site= MKGO1 (M.K. Goddard) Factor 2. Air quality in potentially included versus excluded areas:

County 2001-2003 Design Value Genesee 12.6 Macomb 13.3 Monroe 15.1 Oakland 14.8

### 6-296 St. Clair 13.9 Washtenaw 14.6 Wayne 19.5 Ingham 

### 13.4 Saginaw 

### 11.0 Lucas, OH 15.2 

### Factor 3. Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2003 Population Population Density Genesee 441,423 690 Lapeer 90,776 139 Lenawee 100,145 133 Livingston 168,862 297 Macomb 808,529 1684 Monroe 149,253 271 Oakland 1,202,721 1378 St. Clair 167,712 231 Washtenaw 334,351 471 Wayne 2,045,540 3331 

### Factor 4. Traffic and commuting patterns: County County VMT (Thousands) Percent Number
Genesee 4,842 18 33,966 Lapeer 1,139 50 20,118 Lenawee 908 22 10,026 Livingston 1,804 54 42,858 Macomb 6,964 41 156,343 Monroe 1,679 28 19,372 Oakland 10,758 28 167,943 St. Clair 2,029 35 26,992 Washtenaw 3,521 21 35,525 Wayne 20,171 24 201,563 

### Factor 5. Expected growth:

County Percent growth 1990-2000 Genesee 1 Lapeer 18 Lenawee 8 Livingston 36 Macomb 10 Monroe 9 Oakland 10 St Clair 13 Washtenaw 14 Wayne -2

### 6-297 Factor 6. Meteorology: Average percent of wind direction by quadrant County Northwest Southwest Southeast Northeast Genesee 24 42 18 16 Lapeer 25 40 18 17 Lenawee 25 40 16 19 Livingston 26 40 18 17 Macomb 26 39 18 18 Monroe 25 40 16 19 Oakland 25 39 18 18 St. Clair 25 39 18 18 Washtenaw 26 39 17 19 Wayne 26 38 17 19 

### Factor 7. Geography/topography: There are no geographical features (mountain ranges, abrupt changes in land elevation, etc.) that affect this area. The state provided no information about geography/topography for this area.
Factor 8. Jurisdictional boundaries: The Southeast Michigan Council of Governments (SEMCOG ) is the Metropolitan Planning Organization (MPO) for Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and Wayne counties. -source: SEMCOG web page,http://www.semcog.org/ This metropolitan area is divided into two ozone nonattainment areas. The Detroit area includes the following counties: Lenawee, Livingston, Macomb, Monroe, Oakland, St Clair, Washtenaw, and Wayne. The Flint area includes the following counties: Genesee and Lapeer.
Factor 9. Level of control of emission sources: The state provided no information about the level of control of emission sources for this area. 6.5.4 EPA 9-Factor Analyses for Ohio for Designation of Nonattainment Areas for PM2.5 The following table identifies the individual areas and counties comprising those areas in Ohio that EPA is designating as nonattainment. Ohio provided two options of recommendations: Option 1 only includes counties monitoring nonattainment, and Option 2 includes the Option 1 counties plus additional counties recommended as contributing to nonattainment. EPA finds the Option 2 recommendations generally to reflect a proper review of nonattainment areas in accordance with EPA guidance, and so this table

### 6-298 compares EPA's recommendations to Ohio's Option 2 recommendations. Following this table is a description of the data EPA examined and a discussion of each area and the basis for EPA's designations. EPA is designating as attainment/unclassifiable all counties not identified in the table below.

Area Ohio Counties in Metropolitan Area Ohio Recommended Nonattainment Counties (Option 2) Counties EPA is Designating Nonattainment Canton-Massillon, OH

### Stark Carroll Stark 

### Stark Cincinnati-Hamilton, OH-KY-IN 

### Butler Clermont Hamilton Warren Brown 

### Butler Clermont Hamilton Warren 

### Butler Clermont Hamilton Warren
Cleveland-AkronLorain, OH 

### Cuyahoga Lake Lorain Medina Portage Summit Ashtabula Geauga 

### Cuyahoga Lake Lorain Medina Portage Summit 

### Cuyahoga Lake Lorain Medina Portage Summit Ashtabula Ashtabula Township Columbus, OH 

### Delaware Fairfield Franklin Licking Madison Pickaway 

### Delaware Fairfield Franklin Licking 

### Delaware Fairfield Franklin Licking Coshocton Franklin Township Dayton-Springfield, OH 

### Clark Greene Montgomery Miami 

### Clark Greene Montgomery 

### Clark Greene Montgomery Huntington-Ashland, WV-KY-OH 

### Lawrence Lawrence Scioto 

### Lawrence Scioto Adams Monroe Township Sprigg Township Gallia Cheshire Township Parkersburg-Marietta, WV-OH Washington 

### Washington Steubenville-Weirton, OH-WV Jefferson Jefferson 

### Jefferson Toledo, OH 

### Lucas Wood Fulton 

### Lucas Wood 

### Lucas Wood

### 6-299 Wheeling, WV-OH Belmont 

### Belmont Youngstown-Warren, OH 

### Columbiana Mahoning Trumbull 

### Columbiana Mahoning Trumbull 

### Columbiana Mahoning Trumbull 

### 6.5.4.1 Canton-Massillon, OH Discussion: There are two counties in this metropolitan area, Stark County and Carroll County. EPA agrees with the Ohio EPA that the Canton-Massillon area should include only Stark County. The majority of the emissions and population are located in Stark County, which contains a monitor that is violating the standard. Stark County also represents the ozone nonattainment area for the Canton-Massillon Metropolitan Area. There are four counties that are adjacent to the metropolitan area, Harrison, Holmes, Tuscarawas and Wayne Counties that are not part of other metropolitan areas. Of these counties, only Wayne County required further review due to the population and emissions in the county. Wayne County is adjacent to both the Cleveland and Canton Metropolitan areas. It does not appear appropriate to associate this county with the Canton-Massillon Metropolitan Area. There is limited commuting from Wayne County to the Canton-Massillon Metropolitan Area and there does not appear to be additional interaction that would indicate a need to include Wayne County in the nonattainment area. In addition, Wayne County has relatively low emissions when compared to emissions in the Cleveland Metropolitan Area. Because emissions are relatively low for Harrison, Holmes, and Tuscarawas Counties, and no other factor warranted designating these counties nonattainment, the following data summaries for factors 3 through 9 do not address these counties. Factor 1. Emissions in areas potentially included versus excluded from the nonattainment area:

County SOx NOx Carbon Crustal Composite emission score
Carroll 386 1,886 120 234 10.0
Stark 2,736 14,968 1,255 2,158 90.0
Harrison 258 712 70 116 

### 5.2
Holmes 272 1,687 141 448 

### 10.8

Tuscarawas 3,970 6,333 354 553 

### 40.5 Wayne 21,450 8,911 702 1,849 126.4

### 6-300 Urban increment: Total mass = 4.2 μg/m3 

### 11% sulfates; 30% nitrates; 49% carbon; 10% crustal. Urban site = 390990014; Rural site = MKGO1 (M.K. Goddard) Factor 2. Air quality in potentially included versus excluded areas:

County 2001-2003 Design Value
Stark 17.3 μg/m3 

### Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas:

County 2002 Population Population Density
Carroll 29,166 74
Stark 377,940 656 Wayne 112,704 203 

### Factor 4: Traffic and commuting patterns:

County Number Percent County VMT (Thousands)
Carroll 5,125 40 193
Stark 956 1 3,135 Wayne 1,681 3 1,039 

### Factor 5: Expected growth

County Percent growth 1990-2000
Carroll 9
Stark 3 Wayne 10 

### Factor 6: Meteorology