### LANce 

### R. LEFLEUR
DIRECTOR 

# AlE RoBERT

### J. BeNTLEY GovERNOR

Alabama Departmentof Environmental Management adem.alabama.gov October3, 2014 1400Coliseum Blvd. 3611(}2400 • Post Office Box 301463 Montgomery,Alabama 36130·1463 (334) 271-7700 • FAX (334) 271-7950 Ms. Heather McTeerToney Regional Administrator, EPA Region 4 Atlanta Federal Center 61 Forsyth Street, S.W. Atlanta, Georgia 30303-8960

Dear Ms. McTeerToney:
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 ofRussell County, Alabama. The letterstates 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 intendsto use its authority undersection 107{d)(1)(B)ofthe Clean AirAct (CAA) todeferthe designation for Russell County in ordertogain an additionalyearofmonitoringdata from the Georgia monitors.

In response to EPA's intentions regarding designationsforthe 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 ofAlabama, including Russell County, be designated as attainment in December 2014. We believe this classification is consistent with the intent ofthe CAA, as 2011 through 2013 data for all monitors in the State, includingthe monitorin Russell County, indicate attainmentofthe 2012 annual PM2.5 NAAQS.

2. As was the case in our initial designation recommendations from March 2014, we again request thatthe 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 monitorforthis period is 11.2 llg/m3. While we understand thatthe Columbus, Georgia, monitors have insufficientdata to make adesignation determinationforthe 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, monitorsfail to complywith the standard forthe 2012-2014 monitoring period.

Decatur Branch Mobile Branch Mobile-Coastal
110Vulcan Road Birmingham, AL 35209-4702 1205) 942-6168 2715Sandlin 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 ifclarification is needed.

# Sin~,d#,J~
Ronald W. Gore, Chief Air Division

cc: Beverly Banister, EPA