MAR-19-2009 08:38 US EPA 617 918 1505 P.01

At- o1-0(0.3" 3

State of Rhode Island and Providence Plantations

State House

Providence, Rhode Island 02903-1196

401-222.2080

RECEIVED

Donald L Carcieri

Governor

Ira W. Leighton

Acting Regional Administrator

EPA Region I

1 Congress Street, (Suite 1100-RAA)

Boston, MA 02 1 1 4-202

Dear Mr. Leighton:

March 12, 2009

E2009 AR I

OFFICE OF THE REGIONAL ADMINISTRATOR

Pursuant to the requirements of Section 107(d)(1) of the Clean Air Act Amendments of 1990,

Rhode Island is hereby submitting its recommendation for the State's attainment status

designation for the 2008 revised National Ambient Air Quality Standard (NAAQS) for ozone.

Section 107(d)(1) defines nonattainment areas as areas that do not meet , or that contribute to

ambient air quality in a nearby area that does not meet , the NAAQS for a pollutant.

A site is in violation of the eight-hour NAAQS if the monitored design value for that site is

greater than 75 ppb. The design value is calculated by averaging the fourth highest maximum

daily eight-hour ozone concentration measured at a site each year in three consecutive years. The

eight-hour ozone design values for the three node Island ozone monitoring sites for the two

most recent three-year periods, 2005 -- 2007 and 2006 - 2008, are as follows:

Site County Design Value (122b) ^

2005-2007

-

2006-2008

W. Greenwich Kent 86 80 --

Narragansett Washington 84

^

81

E. Providence Providence 84 82
MAR-19-2009 08:39 US EPA

Ira W. Leighton

March 12, 2009

Page Two

617 918 1505 P.02

Since the design values for all three of the Rhode Island monitoring sites exceed 75 ppb, the

entire State of Rhode Island is in monitored violation of the 2008 ozone NAAQS.

EPA's guidance for designating areas for the 2008 revised ozone NAAQS 1 states that the Core

Based Statistical Area (CBSA) associated with the violating monitor should be used to determine

the presumptive boundaries of a nonattainment area. All of the Rhode Island monitors arc

located in the Providence-New Bedford-.Fall River RI-MA CBSA, which includes all five of the

Rhode Island counties and Bristol County in Massachusetts.

For ease of administration, I am recommending that, as with previous ozone NAAQS, the Rhode

Island 2008 ozone nonattainment area be defined by the boundaries of the State of Rhode Island,

rather than the boundaries of the CBSA. Bristol County, Massachusetts would continue to be

included in the Eastern Massachusetts nonattainment area, which has similar design values as

those in Rhode Island.

Although I am not asking that upwind areas be included in the Rhode Island nonattainment areas,

Rhode Island is keenly aware that the State's ozone levels are strongly influenced by upwind

states' emissions, Therefore, if Rhode Island is to come into attainment with the 2008 ozone

NAAQS, it is essential for EPA to adequately address long-range transport of ozone and ozone

precursors.

If you have any questions about this issue , please feel free to contact Barbara Morin at the Rhode

Island Department of Environmental Management's Office of Air Resources at (401) 222-4700,

extension 7012.

Very truly yours,

Donad Carrcfeeri

Governor

I Memo from Robert J Meyers, Principal Deputy Assistant Administrator, US EPA, to Regional Administrators.,

"Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards," December 4, 2008.

TOTAL P.02