LANce R. LEFLEUR 

DIRECTOR AlE RoBERT J. BeNTLEY 

GovERNOR 

Alabama Department of Environmental Management 

adem.alabama.gov 

October 3, 2014 1400 Coliseum Blvd. 3611(}2400 • Post Office Box 301463 

Montgomery, Alabama 36130·1463 

(334) 271-7700 • FAX (334) 271-7950 

Ms. Heather McTeer Toney 

Regional Administrator, EPA Region 4 

Atlanta Federal Center 

61 Forsyth Street, S.W. 

Atlanta, Georgia 30303-8960 

Dear Ms. McTeer Toney: 

On August 19, 2014, after considering Alabama's March 3, 2014, designation recommendations, 2011-

2013 air quality data and other relevant technical information pertaining to the 2012 annual PM2.5 

NAAQS , EPA sent ADEM a letter stating its intent to designate the entire State of Alabama as 

unclassifiable/attainment, with the exception of Russell County, Alabama. The letter states that EPA has 

insufficient data to make a determination for Russell County because of insufficient monitoring data 

from the Georgia monitors in the Columbus, Georgia - Phenix City, Alabama area. Therefore, EPA 

intends to use its authority under section 107{d)(1)(B) of the Clean Air Act (CAA) to defer the designation 

for Russell County in order to gain an additional year of monitoring data from the Georgia monitors. 

In response to EPA's intentions regarding designations for the 2012 annual PM2.5 NAAQS, ADEM has the 

following comments: 

Birmingham Branch 

1. The process for designating areas following promulgation of a new or revised NAAQS is 

contained in CAA section 107(d)(1)(A)(i), (ii) and (iii) (42 U.S.C. 7407). This section of the CAA 

identifies three potential classifications: nonattainment, attainment, and unclassifiable. Given 

that EPA's desired designation of "unclassifiable/attainment" is not included in the CAA as a 

potential classification, ADEM recommends that the entire State of Alabama, including Russell 

County, be designated as attainment in December 2014. We believe this classification is 

consistent with the intent of the CAA, as 2011 through 2013 data for all monitors in the State, 

including the monitor in Russell County, indicate attainment of the 2012 annual PM2.5 NAAQS. 

2. As was the case in our initial designation recommendations from March 2014, we again request 

that the entire State, including Russell County, be designated as attainment. In December 2014, 

EPA will be basing designations on the 2011-2013 monitoring period. The design value for the 

Russell County monitor for this period is 11.2 llg/m3. While we understand that the Columbus, 

Georgia, monitors have insufficient data to make a designation determination for the 2011-2013 

monitoring period, the data from the Russell County monitor for this period has been quality 

assured and accepted by EPA as valid and in compliance with the 2012 annual PM2.5 NAAQS. 

For this reason, we continue to request that EPA designate Russell County as attainment, with 

the understanding that the designation may need to be revised if the Columbus, Georgia, 

monitors fail to comply with the standard for the 2012-2014 monitoring period. 

Decatur Branch Mobile Branch Mobile-Coastal 

110 Vulcan Road 

Birmingham, AL 35209-4702 

1205) 942-6168 

2715 Sandlin Road, S. W. 

Decatur, AL 35603-1333 

(256) 353-1713 

2204 Perimeter Road 

Mobile, AL 36615-1131 

(251) 450-3400 

4171 Commanders Drive 

Mobile, AL 36615-1421 

(251) 432-6533 

(205) 941-1603 (FAX) (256) 340-9359 (FAX) (251) 479-2593 (FAX) (251) 432-6598 (FAX) 
Please let me know if clarification is needed. 

Sin~,d#,J~ 

Ronald W. Gore, Chief 

Air Division 

cc: Beverly Banister, EPA