IDEM INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

We Protect Hoosiers and Our Environment.

Mitchell E. Daniels Jr. 100 North Senate Avenue

Governor Indianapolis, Indiana 46204

(317) 232-8603

Thomas W. Easterly Toll Free (800) 451-6027

Commissioner www.idem.lN.gov

April 20, 2011

Ms. Susan Hedman

Regional Administrator

U.S. Environmental Protection Agency

Region 5

77 West Jackson Boulevard

Chicago, IL 60604-3950

Re: Request to Parallel Process the Draft

Request for Redesignation Petition

and Maintenance Plan for the Indiana

Portion (Madison Township, Jefferson

County and Clark and Floyd counties)

of the Louisville KY-IN Nonattainment

Area for Fine Particles

Dear Ms. Hedman:

The Indiana Department of Environmental Management (IDEM) submits a draft

Redesignation Petition and Maintenance Plan for the Indiana Portion (Madison Township,

Jefferson County and Clark and Floyd counties) of the Louisville KY-IN Nonattainment

Area, which was designated as nonattainment of the annual standard for fine particles on

April 5, 2005. IDEM will conduct a public hearing concerning the Redesignation Petition

and Maintenance Plan on May 26, 2011, and the public comment period will conclude on

May 29,2011. IDEM requests the United States Environmental Protection Agency (U.S.

EPA) to parallel process this draft submittal.

The attached document consists of the following:

Redesignation Petition and Maintenance Plan

• A formal request that the Indiana Portion (Madison Township, Jefferson County

and Clark and Floyd counties) of the Louisville KY-IN Nonattainment Area for Fine

Particles be redesignated to attainment and reclassified as maintenance. It

contains and meets the requirements set forth in Section 107 of the Clean Air Act

and in U.S. EPA Redesignation Guidance.

• A maintenance year of 2025 is established and 2015 and 2020 are analyzed as

interim years.

• The appendices of the document contain historical air quality trend data, projected

emission inventory data and thorough documentation of the mobile emissions

analysis.

I?ecycled Paper*

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Ms. Hedman, Page 2

Motor Vehicle Emissions Budgets

• Contained in the Redesignation Petition is a new Motor Vehicle Emissions Budget

for 2015 and 2025. The Kentuckiana Regional Planning and Development

Agency's (KIPDA's) travel demand forecasting model and the U.S. EPA software

program referred to as Motor Vehicle Emission Simulator (MOVES) were used to

determine mobile emissions for the annual fine particle nonattainment area.

• A conservative margin of safety was applied to the 2015 and 2025 projected

emissions.

• The travel demand model was updated with the best available assumptions.

• Vehicle registration data gathered from the Indiana Bureau of Motor Vehicles were

used to replace the MOBILE6.2 default vehicle age distribution.

Upon completion of the public participation process and documentation, IDEM will

forward the official transcript and a summary and response to substantive oral and written

comments under separate cover.

IDEM requests that the U.S. EPA proceed with review and approval of this

submittal. If you have any questions or need additional information, please contact Scott

Deloney, Chief, Air Programs Branch, at (317) 233-5694.

Sincerely,

t;fi- B~r

Keith Baugues

Assistant Commissioner

Office of Air Quality

KB/sad/ghf

Enclosures:

Draft Request for Redesignation Petition and Maintenance Plan Under the Annual

National Ambient Air Quality Standard for Fine Particles for the Indiana Portion of

the Louisville KY-IN Nonattainment Area

Cc: John Summerhays, U.S. EPA Region 5 (wI enclosures)

Matt Rau, U.S. EPA Region 5 (wI enclosures)

John Mooney, U.S. EPA Region 5 (no enclosures)

Cheryl Newton, U.S. EPA Region 5 (no enclosures)

Pat Morris, U.S. EPA Region 5 (no enclosures)

Cynthia Lee, LMAPCD (wI enclosures)

John Gowins, KDEP (wI enclosures)

Randy Simon, KIPDA (wI enclosures)

Jesse Mayes, KYTC (wI enclosures)

Scott Deloney, IDEM (no enclosures)

Christine Pedersen, IDEM (no enclosures)

Gale Ferris, IDEM (wI enclosures)