The Honorable Bill Haslam 

Governor of Tennessee 

State Capitol, First Floor 

600 Charlotte Avenue 

Nashville, Tennessee 37243-0001 

Dear Governor Haslam: 

Thank you for the letter dated December 9, 2013, from Robert J. Martineau, Jr., Commissioner, 

Tennessee Department of Environment and Conservation (TDEC), providing your recommendations 

of air quality designations for the 2012 revised primary annual fine particle (PM2.s) National Ambient 

Air Quality Standard (NAAQS) throughout Tennessee. I appreciate the information Tennessee shared 

with the U.S. Environmental Protection Agency as we move forward to improve PM2.s air quality. This 

letter is to notify you of the EPA's preliminary response to Tennessee's recommendation and to inform 

you of our approach for completing the initial area designations for the 2012 revised primary annual 

PM2.s standard. 

On December 14, 2012, the EPA promulgated a revised primary annual PM2.s NAAQS (78 FR 3086, 

January 15, 2013). In that action, the EPA revised the primary annual PM2.s standard, strengthening it 

from 15.0 micrograms per cubic meter (J.lglm3) to 12.0 J.lg/m3; retained the existing 24-hour PM2.s 

standard at 35 J.lg/m3; retained the existing 24-hour PM to (coarse particle) standard at 150 J.lg/m3; and 

retained the current suite of secondary PM standards. The EPA revised the primary annual PM2.s 

standard based on an integrated assessment of an extensive body of new scientific evidence, which 

substantially strengthens our body of knowledge regarding PM2.s-related health effects. The revised 

primary annual PM2.s standard will provide increased protection for children, older adults, persons with 

pre-existing heart and lung disease, and other at-risk populations against an array ofPM2.s-related 

adverse health effects, including premature mortality, increased hospital admissions and emergency 

department visits, and development and exacerbation of chronic respiratory disease. 

History shows us that better health and cleaner air go hand-in-hand with economic growth. Working 

closely with the states and tribes, the EPA is implementing the standards using a commonsense 

approach that improves air quality and minimizes the burden on state, local, and tribal governments. 

As part of this routine process, the EPA is working with the states and tribes to identify areas in the 

country that meet the standards and those that need to take steps to reduce PM2.5 air pollution. Within 

one year of promulgating a new or revised air quality standard, the Clean Air Act (CAA) requires the 

Governor of each state to submit to the EPA a list of all areas in the state, with a designation 

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

Recyled/Recyclable ,. Printed With Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
recommendation for each area. As a first step in implementing the 2012 annual PM2.s standard, 

Governors were to submit their designation recommendations, including appropriate area boundaries, 

by December 13,2013. 

As required by the CAA, the EPA then promulgates designations for all areas across the country. The 

EPA designates an area as "nonattainment, if it is violating the 2012 annual PM2.s NAAQS or if it is 

contributing to a violation of the NAAQS in a nearby area Consistent with designations for previous 

PM2.s standards, the EPA intends to use a designation category of '\mclassifiablelattainment, for areas 

that are monitoring attainment or do not have monitors, but for which the EPA has reason to believe 

are likely attaining the NAAQS and are not contributing to nearby violations. Additionally, the EPA 

intends to designate as ''unclassifiable, those areas where the EPA cannot determine based on 

available information whether the area is meeting the NAAQS or where the EPA has not determined 

that the area contributes to a nearby violation. At this time, the EPA is proceeding with intended initial 

area designations using quality-assured, certified air quality monitoring data for most areas from 2011 

to 2013. 

The EPA has considered the annual PM:z.s designation recommendation submitted by Tennessee on 

December 9, 2013, and have reviewed other relevant technical information, including 201 1-2013 air 

quality data The EPA has determined that insufficient air quality data exists to make designation 

determinations for all areas in the State of Tennessee, except for the Chattanooga area. The EPA did 

fmd complete and valid data for monitors in Hamilton County in the Chattanooga area. Because of the 

data completeness issues, the EPA cannot determine whether the counties with the incomplete 

monitoring data are meeting or not meeting the NAAQS or whether counties nearby to those counties 

with incomplete monitoring data contribute to a nearby violation. Accordingly, EPA intends to accept 

in part and modify in part Tennessee's recommended area designations. Specifically, EPA will 

designate Hamilton, Marion and Sequatchie counties in the Chattanooga area as 

unclassifiable/attainment, consistent with the recommendation from Tennessee. EPA also intends to 

accept Tennessee's recommendation to designate Knox County as unclassifiable and will modify 

Tennessee's recommendation for the rest of the state, designating those areas as unclassifiable. A 

Technical Support which provides additional detail regarding the status of data for 

Tennessee and the rationale to support the EPA's unclassifiable designation, is enclosed and is also 

available on the EPA's website at http://www.epa.gov/pmdesignations/2012standards/state.htm. If 

Tennessee has additional information for the EPA to consider, please submit it to us by October 29, 

2014. 

The EPA will make its preliminary designation decisions and supporting documentation available to 

the general public for review and comment. We will be announcing a 30-day public comment period 

shortly in the Federal Register. After considering the additional information we receive, the EPA plans 

to promulgate final annual PM2.s designations in December of 2014. 
J

6

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e Regional Administrator 

cc: Robert J. Martineau, Jr., Commissioner, IDEC 

Barry Stephens, Director, Division of Air Pollution Control, IDEC 

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

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