UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

The Honorable Matt Bevin · 

Governor of Kentucky 

700 Capitol Ave., Suite 100 

Frankfort, Kentucky 40601 

Dear Governor Bevin: 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303-8960 

FEB 1 6 2016 

We are sending this letter 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 Cabinet, Leonard Peters, dated 

September 16, 20 15, with updated recommendations on air quality designations for the Commonwealth 

of Kentucky for the 2010 revision to the primary National Ambient Air Quality Standard (NAAQS) for 

sulfur dioxide (S02). Reducing levels of S02 pollution is an important pat1 of the U.S. Environmental 

Protection Agency's commitment to a clean, healthy environment. Exposure to S02 can cause a range of 

adverse health effects, including narrowing of the airways 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 S02 by establishing a 

standard for 1-hour average S02 concentrations at a level of 75 parts per billion. Within 1 year after a 

new or revised standard is established, the Clean Air Act requires the Governor of each state to submit 

to the EPA a list of all areas in the Commonwealth, with recommendations for whether each area meets 

the standard. Through an interactive process, the EPA considers the recommendations and then 

promulgates designations for all areas across the country. On July 25,2013, the EPA designated 29 

areas in 16 states as nonattainment, but did not at that time designate other areas. Pursuant to a March 2, 

2015, court-ordered schedule, 

1 the EPA must complete the remaining S02 designations by three specific 

deadlines: July 2, 2016, December 31 , 2017, and December 31 , 2020. 

This current round of designations, to be completed by July 2, 2016, addresses two groups of areas: (l) 

areas that have newly monitored violations of the 2010 S02 NAAQS based on the most recent three 

calendar years of certified monitored ambient air quality data, and (2) areas that contain any stationary 

source that had not been announced as of March 2, 2015, for retirement and that according to the EPA's 

Air Markets Database emitted in 2012 either: (i) more than 16,000 tons ofS02 or (ii) more than 2,600 

tons of S02 with an annual average emission rate of at least 0.45 pounds of S02/mmBTU. 

1 Sierra Club v. McCarthy, No. 3-13-cv-3953 (SI) (N.D. Cal. Mar. 2, 2015). 

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

Recycled/Recyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
Because the EPA has insufficient infonnation to detennine whether the following areas are meeting or 

not meeting the S02 NAAQS, the EPA intends to designate these areas as unclassifiable: 

Intended Unclassifiable Area 

Pulaski County, KY* 

Ohio County, KY* 

Intended Unclassifiable Counties 

Pulaski County, KY 

Ohio County, KY 

The asterisk (*) indicates the designation for these intended unclassifiable areas represent a modification 

to the designation of attainment that Kentucky has recommended. 

We understand that the Commonwealth is working with the affected sources to put in place federallyenforceable emissions limits that might be creditable towards unclassifiable/attainment designations, 

assuming that no outstanding teclmical modeling issues remain, and all other conditions in the impacted 

areas as identified in the enclosed technical support document are resolved. It will be necessary for these 

federally-enforceable emissions limits to be in place early enough to be considered for the EPA's final 

designation which is court-ordered to happen no later than July 2, 2016. 

The enclosed Technical Support Document provides a detailed analysis that supports our intended 

designation decisions. Ifthe Commonwealth has additional infonnation that the EPA should consider 

prior to finalizing these designations, please submit it to us by April 19, 2016. We also will be 

publishing a notice in the Federal Register announcing a 30-day period for the public to provide input 

on the EPA's intended designation decisions. We will promulgate the designations for these areas by 

July 2, 2016. We will designate all other previously undesignated areas in the Commonwealth on a 

schedule consistent with the prescribed timing of the court order, i.e., by December 31, 2017, or 

December 31, 2020. 

We look forward to a continued dialogue with you and your staff as we work together to complete the 

area designations and implement the 2010 primary S02 standard. For additional infonnation regarding 

designations under the S02 standard, please visit our website at www.epa.gov/so2designations. Should 

you have any questions, please do not hesitate to call me, or have your staff contact Beverly H. Banister, 

Director, Air, Pesticides and Toxics Management Division at (404) 562-9070 or 

banister.beverly@epa.gov. 

Enclosure 

cc: Charles G. Snavely 

H

Regional 

eather McTeer 

Adminis

Toney 

trator 

~ 

Secretary, Kentucky Energy and Environment Cabinet 
Sean Alteri 

Director, Kentucky Division of Air Quality 

Janet G. McCabe, Acting Assistant Administrator for Air and Radiation 

Stephen D. Page, Director, Office of Air Quality Planning and Standards