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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 20,048 27,150 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, GA 2732 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, GA 450 1228 1834 1634 197 11.7

Murray, GA 576 130 2067 1700 910 11.4

Polk 295 2066 900 949 553 11.3

Cherokee, NC 428 143 921 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.
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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.
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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.)
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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.
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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, AL area: 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, AL area: Etowah.

6.4.2 EPA 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 in bold.)
6-158

County PM SOx NOx VOC Amm Weighted

score

Cumulative

Weighted

score

Fulton 16,041 11,819 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 10,057 31,821 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 in bold.)

County 2002

Population

Percent 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
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- 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
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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.
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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 in bold.)

County 2002 Population Growth 90-00 Percent 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
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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
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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.
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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 in bold.)

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
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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 in bold.)

County 2002

Population

Percent

Population of

MSA

Population Density

Bibb 154,824 47 619

Houston 116,768 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

Wilkinson 10,357 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
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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.
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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 VMT VMT 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 in bold.)

County 2002 Population Growth 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.
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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 in bold.)
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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 in bold.)

County 2002 Population Percent 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

Ogelthorpe 13,176 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
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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 in bold.)

County 2002 Population Growth 90-00 Percent Growth

Clarke 103,881 13,895 16

Oconee 27,264 8,607 49

Madison 26,717 4,680 22

Jackson 45,374 11,584 39

Greene 15,101 2,613 22

Morgan 16,301 2,574 20

Franklin 20,778 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
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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 20,048 27,150 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, GA 2732 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, GA 450 1228 1834 1634 197 11.7

Murray, GA 576 130 2067 1700 910 11.4

Polk 295 2066 900 949 553 11.3

Cherokee, NC 428 143 921 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:
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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 NOX VOC NH3 Weighted

Emissions

Score

Cumulative

Weighted

Emissions

Score

Russell, AL 1,344 2,550 5,718 4,434 179 35.1 35.1

Harris, GA 590 104 2,856 1,748 128 26.8 61.9

Muscogee, GA 513 803 5,965 9,476 323 25.4 87.3

Chattahoochee, GA 208 43 387 482 15 12.7 100

Troup, GA 1,194 422 12,277 8,223 382 48.7

Montgomery, AL 1,421 6,292 10,454 14,966 973 43.3

Lee, AL 1,043 1,425 5,125 7,474 333 42.8

Barbour, AL 874 419 2,208 2,529 497 41.6

Sumter, GA 2,578 1,725 1,726 2,262 847 40.5

Meriwether, GA 844 190 1,866 3,006 167 33.7

Elmore, AL 1,014 517 4,443 4,368 326 30.8

Tallapoosa, AL 679 655 1,993 3,230 263 26.5

Chambers, AL 579 527 2,350 2,882 124 23.9

Stewart, GA 429 32 360 464 189 23.3

Taylor, GA 398 76 966 622 833 18.3

Macon, AL 412 223 2,242 1,871 133 17.1

Talbot, GA 288 70 903 520 74 15.9

Marion, GA 314 32 328 517 470 15.4

Bullock, AL 273 93 407 570 214 12.7

Webster, GA 303 128 358 201 114 12.6

Schley, GA 192 14 195 290 163 8.4

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 to Russell County.
6-187

Columbus MSA and Surrounding Counties VMT

County VMT 2002 VMT 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.

6.4.3 EPA 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 in bold 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 in bold 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 in bold 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
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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 growth

The 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 in bold 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 86E F, the mean low was 66E F. 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.”
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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 States

No 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:
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Replace “Boone” with “Mason” as noted: “Commuters in MasonBoone County, KY

who work in MasonBoone County, 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 in bold; Kentucky MSA counties in bold italics.)

County

PM SOx NOx VOC Amm Score Cum.

Score
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Jefferson, KY 7,385 62,526 81,398 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 53,086 26,269 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, KY 273 115 618 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.
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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 in bold; Kentucky MSA counties are in bold 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%)
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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 in bold 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 in bold; Kentucky MSA counties are in bold 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 87E F and

the mean low was 70E F. 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 Indiana

Counties 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 Source

Performance 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

No 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 the Louisville, 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 in bold.)

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
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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 in bold.)

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

in bold.)

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 in bold.)

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
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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 Woodford Counties.

“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 86E F and the mean low was 66E F. 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.
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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
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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
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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 County This 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:
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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, KY area: 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 be

deferred 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.
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Area EPA Recommendation for KY State Recommendation

Huntington-Ashland, WVKY-OHFull 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 in bold; Kentucky MSA counties are in bold 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.
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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 in bold; Kentucky MSA counties are in bold 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 
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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 in bold; Kentucky MSA counties are in bold 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.
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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 growth

The following table has the population and population growth figures for the HuntingtonAshland MSA and adjacent counties with significant emissions. (MSA counties are in bold;

Kentucky MSA counties are in bold 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 85E F and the mean low was 65E F. The mean precipitation for the same period was

4.5 inches.” (Source: Kentucky PM2.5 submittal)
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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, and

Putnam; 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 Source

Performance 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.
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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:
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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 (additions are 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 Carter and Lawrence Countyies in Kentucky to indicate a potential air quality contribution.

However, the populations of Carter and Lawrence Countyies population is are low.

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
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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

6.4.4.1 Greensboro-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 in Greensboro-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 are

adjacent 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 12.2 mg/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
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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 in bold.

PM 2.5 SO2 NOx VOC Amm Weighted

emissions

score

Cumulative

Weighted

emissions score

NC Stokes 4,821 83,409 35,936 2,566 357 32.8 32.8

NC Guilford 2,418 2,833 19,068 34,464 1,178 17.6 50.4

NC Davidson 1,951 1,398 11,281 14,970 632 12.9 63.3

NC Forsyth 1,559 5,885 14,552 20,679 722 11.7 75.0

NC Randolph 1,370 907 5,898 10,307 4,014 9.5 84.5

NC Alamance 1,181 749 5,618 8,967 730 8.2 92.7

NC Yadkin 606 318 2,061 2,247 896 4.0 96.7

NC Davie 508 205 1,959 3,278 448 3.3 100.0

NC Rowan 2,012 12,465 11,681 11,323 726 13.4

NC Chatham 1,714 11,605 5,823 4,734 3,012 11.7

NC Rockingham 1,555 6,263 12,227 8,770 523 11.2

NC Iredell 1,537 1,365 11,065 10,346 2,090 10.8

NC Surry 1,224 1,238 5,055 7,478 1,811 8.5

VA Pittsylvania 980 1,828 7,490 4,149 581 7.2

NC Moore 956 409 3,197 6,519 2,396 6.9

NC Wilkes 966 647 2,890 5,097 5,300 6.6

NC Orange 857 756 6,264 6,751 572 6.4

VA Henry 818 535 3,811 10,517 197 5.6

NC Stanly 795 3,129 2,891 4,581 1,460 5.3

NC Montgomery 516 484 1,631 4,175 1,246 3.6

NC Caswell 483 199 1,071 1,622 155 3.2

VA Patrick 408 176 1,039 1,363 214 2.8

VA Carroll 378 509 2,305 1,986 441 2.7

VA Grayson 291 95 819 952 405 2.0

NC Alleghany 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.
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Factor 2: Air Quality in potentially included versus excluded areas

2001-2003 Design

Value

NC Guilford 14.1

NC Davidson 15.8

NC Forsyth 14.6

NC Alamance 13.7

NC Chatham 12.2

NC Orange 13.1

NC Montgomery 12.1

NC Caswell 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)

NC Stokes 44,984 3.5 100

NC Guilford 430,937 33.5 663

NC Davidson 151,238 11.6 274

NC Forsyth 314,933 24.5 768

NC Randolph 134,217 10.4 170

NC Alamance 135,893 10.6 315

NC Yadkin 37,329 2.9 111

NC Davie 36,734 2.9 139

NC Rowan 133,359 261

NC Chatham 53,893 79

NC Rockingham 92,778 164

NC Iredell 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
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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 in bold).

2002 VMT

 (thousands of miles)

NC Stokes 415

NC Guilford 5,096

NC Davidson 1,765

NC Forsyth 3,832

NC Randolph 1,486

NC Alamance 1,575

NC Yadkin 520

NC Davie 476

NC Rowan 1,654

NC Chatham 434

NC Rockingham 923

NC Iredell 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
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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 the Greensboro-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

NC Stokes 44,984 7,488 20

NC Guilford 430,937 73,628 21

NC Davidson 151,238 20,569 16

NC Forsyth 314,933 40,189 15

NC Randolph 134,217 23,908 22

NC Alamance 135,893 22,587 21

NC Yadkin 37,329 5,860 19

NC Davie 36,734 6,976 25

NC Rowan 133,359 19,735 18

NC Chatham 53,893 10,570 27

NC Rockingham 92,778 5,864 7

NC Iredell 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
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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)
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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 County has two attaining monitors at 14.0 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.
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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 the Greensboro-Winston Salem–High Point, NC area: Davidson

and Guilford .

6.4.4.2 Hickory-Morganton-Lenoir Area

The 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
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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 in bold.

PM

2.5

SO2 NOx VOC Amm Weighted

emissions

score

Cumulative

Weighted

emissions score

Catawba 5,153 78,620 27,968 19,760 886 59.7 59.7

Caldwell 1,104 634 3,530 11,122 391 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 10,346 2,090 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.
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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 in bold.)

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%)
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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 the HickoryMorganton-Lenoir MSA and some adjacent counties with significant weighted emissions scores.

(MSA counties are in bold.)

2002 VMT

 (thousands of miles)

Catawba 2,048

Caldwell 738

Burke 1,112

Alexander 229

Rutherford 606

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.
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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
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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 1.89 mg/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
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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. Of 42,214

(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. Of 38,970 (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, NC area: 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
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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 in bold.

PM SO2 NOx VOC Amm Weighted

emissions

score

Cumulative

Weighted

emissions

score

SC Spartanburg 3070 2351 19046 23897 821 29.7 29.7

SC Greenville 2793 3369 15407 28867 861 27.4 57.1

SC Anderson 2904 9903 11559 13621 1090 22.9 80.0

SC Pickens 1428 1239 5153 7489 274 12.5 92.5

SC Cherokee 834 1270 4121 3538 301 7.4

SC York 2525 9714 12206 15064 1325 22.5

NC Rutherford 2323 30023 12135 4847 254 17.0

NC Cleveland 1258 1261 4975 6591 1240 11.4

SC Newberry 979 353 3682 3813 1357 11.0

SC Laurens 1027 597 5262 4846 414 10.2

NC Henderson 1068 419 4088 7066 358 10.1

SC Greenwood 1095 624 3680 4353 404 10.0

SC Oconee 1058 298 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

GA Habersham 651 103 1757 2201 3031 5.6

NC Transylvania 449 3259 2824 3388 106 5.4

GA Rabun 455 66 943 1606 341 5.1

SC Abbeville 474 208 1384 1538 203 4.7

GA Elbert 410 71 1357 1280 343 3.8

GA Franklin 449 84 2068 1813 4128 3.7

GA Stephens 406 277 1480 2075 976 3.5

GA Hart 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

SC Spartanburg 13.7

SC Greenville 14.5

SC York 14.0

SC Greenwood 13.1

SC Oconee 10.6

NC Jackson 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 15.0 mg/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)

SC Spartanburg 259,322 26.3 320

SC Greenville 391,334 39.6 494

SC Anderson 170,578 17.3 238

SC Pickens 113,097 11.4 228

SC Cherokee 53,524 5.4 136

SC York 173,755 254

NC Rutherford 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 in bold).

2002

VMT

SC Spartanburg 3,509

SC Greenville 3,664

SC Anderson 2,163

SC Pickens 1,180

SC Cherokee 754

SC York 1,860

NC Rutherford 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

SC Spartanburg 259,322 26,991 12

SC Greenville 391,334 59,449 19

SC Anderson 170,578 20,544 14

SC Pickens 113,097 16,863 18

SC Cherokee 53,524 8,031 18
6-236

SC York 173,755 33,117 25

NC Rutherford 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 the Greenville-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 Full counties: Marion,

Hamilton, TN; Dade, Walker,

Catoosa, GA;

Jackson, AL

Full counties: Hamilton and

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 20,048 27,150 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, GA 2732 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, GA 450 1228 1834 1634 197 11.7

Murray, GA 576 130 2067 1700 910 11.4

Polk 295 2066 900 949 553 11.3

Cherokee, NC 428 143 921 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-GA area: 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 Full counties: 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 1995 3005 23648 29966 1220 28.6 28.6

Anderson 2891 45986 23020 5328 265 27.5 56.1

Blount 3535 2999 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 4967 92,331 30865 4300 285 38.0

McMinn 3348 10216 10829 5546 1268 27.0

Rhea 1405 302 2625 3643 149 18.1

Haywood, NC 1218 8701 8669 4923 547 14.8

Jefferson 1407 183 3220 4194 662 14.4

Scott 1113 122 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, KY 346 188 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 Percent of 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 the Knoxville, 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

6.5.1 EPA 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 Area

Illinois Recommended

Nonattainment Counties

Counties EPA is Designating

Nonattainment

Chicago-GaryKenosha, IL-INWICook

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 Township

Saint Louis, MOILMadison

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.

6.5.2 EPA 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

Discussion

The 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 the

annual 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
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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
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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:
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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.
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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.
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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
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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, OH Butler, 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%
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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
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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
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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-hour

ozone 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
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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% Crustal based 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
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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
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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
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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
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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 —
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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 %
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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
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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.
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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-hour

ozone 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.
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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
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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
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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:
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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.
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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.
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6.5.3 EPA 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
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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, the wind 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
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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
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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
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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
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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