UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4

The Honorable Matt Bevin · Governor of Kentucky 700 Cap ito l Ave. , Suite 100 Frankfort , Kentucky 40601
Dear Governor Bevin: ATLANTA FEDERAL CENTER 61 FORSYTH STREET ATLANTA , GEORGIA 30303-8960 

# F

EB 1 6 2016

We are sending this l etter in response to a letter that was sent to the U.S. Environmental Protection Agency by the fonner Secretary of Kentucky's Energy and Environment Cab in et, Leonard Peters , dated September 16 , 20 15 , w ith upd ated recommendations on air quality designations for the Commo n wealth of Kentucky for the 2010 revision to the primary National Ambient Air Quality Standard (NAAQS) for su lfur dioxide (S02). Reducing levels of S02 po llu tion is an important pat1 of the U.S. Environmental Protection Agency ' s commitment to a clean , healthy environment. E xposure to S0 2 can cause a range of adverse health effects , including narrowing of the ai rways which can cause difficulty breathing and increased asthma symptoms. This letter is to notify you of the EPA ' s preliminary intentions regarding your recommended designations.
On June 3 , 2010, the EPA strengthened the health-based or " primary " standard for S0 2 by estab li sh in g a standard for 1-hour average S0 2 concentrations at a leve l of 75 parts per billion. Within 1 year after a new or revised standard is e stablished , the Clean Air Act requires the Governor of each state to submit to the EPA a li st of a ll areas in the Commonwealth , with recommendations for whether each area meets the standard. Through an interacti ve process , the EPA considers the recommendations and then promulgat e s designations for all areas across the country. On Jul y 25,2013 , the EPA designated 29 areas in 1 6 s tates as nonattainment, but did not at that time designate other areas. Pursuant to a March 2 , 20 1 5 , court-ordered schedu le , 1 the EPA must complete the remaining S0 2 designations by three specific deadlines: July 2 , 2016, December 31 , 2017 , and December 31 , 2020.
This curre nt round of designations , to be comp l eted by July 2 , 20 1 6 , address e s two groups of areas : (l) areas that have newly monitored violations of the 2010 S0 2 NAAQS based on the most recent three calendar years of certified monitored ambient air quality data , and (2) areas that contain any stationary sourc e that had not been announced as of March 2 , 2015 , for retirement and that according to the EPA ' s Ai r Market s Database emitted in 20 1 2 e ither : (i) more than 16 , 000 tons ofS02 or (ii) more than 2 , 600 tons of S02 w ith an annual average emission rate of at least 0.45 pounds of S0 2/mmBTU.

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### Sie rra Club v. M cC arthy, No. 3-13

- cv - 3953 (SI) (N.D. Cal. Mar. 2 , 20 1 5).

Internet Address (URL) • http://www.epa

. gov Recycled/ Recyclable • Printed with Vegetable O il Based I nks on Recycled Paper (Minim u m 30% Postconsumer)Because the EP A has insufficient infonnation to detennine w h ethe r th e following areas are meeting or not meeting th e S02 NAAQS, the EPA intends to designate the se areas as unclassifiable:
In te nd ed U nclass ifi ab l e Area Pulaski County , KY* Ohio County , KY* Intended U ncl ass ifi ab l e Co unti es Pulaski County , KY Ohio County , KY
T he asterisk (*) indicates the designation for these in te nd ed unclassifiable a reas represent a modification to the designation of attainment that Kentucky has r ecommended.
We understand th at the Commonwealth is working w i th the affected sources to put in place fede ra ll y e n forceab le emissions limits that might be creditab le towards unclassifiable/attainment designations, assumin g that no outstan din g teclmical modeling i ssues remain , and a ll other conditions in the impac ted areas as id e nti fied in the e nclosed technical s upp ort document a re resolved. It will be necessary for these fede ra ll y-e nforceab le em i ssio n s limits to be in place earl y e noug h to be cons id e red for the EPA's final designation whic h is court-ordered to hap pen no later than July 2, 20 16.
The e nclo sed Techn ical S up port Document provides a detailed analysis th at supports our intended designation decisions. I ft he Commo n wealth has add iti ona l inf onnatio n that the EP A s hou ld cons id e r prior to fi n ali z ing these des ig nat ion s, please sub mit it to u s by April 19 , 20 16. We a l so w ill be publishing a notice in th e Federal Register announcing a 30 -d ay period for the public to provide input on th e EPA's intended designation decisions. We will promulgate the designations for these areas by July 2, 2 016. We wi ll designate all other previously und esignated areas in the Commo nwealth on a sc hedu le co n s is te nt w ith the p resc rib ed t imin g of the cour t o rd e r, i. e., by December 3 1 , 2017, o r D ecember 3 1 , 2020

. We look forward to a continued di alogue with you and your staff as we work together to complete the area designations and imp lement the 20 1 0 prim ary S02 s tandard. For ad diti o na l infonnation regarding designations und e r the S02 stand ard , p lease vis it o ur website at www.epa.gov /

so2des i gnati ons . Sho uld you have any questions , please do not hesitate to call me, or have yo ur staff contact Beverly H. Banister, Director , Air, Pesticides and Toxics Management Division at (404) 562-9070 or banister.beverly @ epa.gov.

Enclos ure

cc: C h arl es G. Snave l y

# ~ Heather McTeer Toney Regional Adminis trator

Sec reta ry , Kentucky E ne r gy a nd Env iro nm ent CabinetSean A lteri Director, Kentucky Divi s ion of Air Quality
J anet G. McCabe , Acting Assistant Adm ini strator for A ir a nd Radiation Stephen D. Page, Director, Office of Air Quality Planning and Standard s