# State of North Carolina’s

Recommendation on Boundaries

of 8-Hour Ozone

Nonattainment Areas

March 12, 2009 Governor Beverly Perdue

## (This Page Is Intentionally Blank)

## Table of Contents

Introduc tion..................................................................................................................1

Backgro und...................................................................................................................1

Summary of Reco mmendations..................................................................................3

Area Specific Recommendations on Boundaries for 8-hour Ozone

Nonattain ment............................................................................................................10

Area Specific Recommendations on Boundaries for 8-hour Ozone

Nonattain ment............................................................................................................11

Snow Bird Mountains – Joyce Kilmer-Slickrock Wilderness Area Nonattainment Area

Discussion..................................................................................................................... ..................12

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................12

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................12

Discussion:.................................................................................................................... ...............12

Emissions Data: ................................................................................................................ ...........13 Population Density And Degree Of Urbanization:......................................................................14 Traffic And Commuting Patterns: ...............................................................................................1 4

Growth Rates And Patterns: ..................................................................................................... ...14 Geography / Topography:........................................................................................................ ....14

Jurisdictional Boundaries: ..................................................................................................... ......15

Level of Control of Emission Sources:........................................................................................15

Great Smoky Mountains National Park Nonattainment Area Discussion..............................16

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................16

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................16

Discussion:.................................................................................................................... ...............16 Air quality data: .............................................................................................................. .............17

Emissions Data: ................................................................................................................ ...........17 Population Density And Degree Of Urbanization:......................................................................17 Traffic And Commuting Patterns: ...............................................................................................1 8

Growth Rates And Patterns: ..................................................................................................... ...18 Meteorology: ................................................................................................................... ............18 Geography / Topography:........................................................................................................ ....18

Jurisdictional Boundaries: ..................................................................................................... ......19

Level of Control of Emission Sources:........................................................................................19

Great Balsam Mountains – Shining Rock Wild erness Area Nonattainment Area Discussion

............................................................................................................................... ..........................20

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................20

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................20

Discussion:.................................................................................................................... ...............20Emissions Data: ................................................................................................................ ...........21 Population Density And Degree Of Urbanization:......................................................................22 Traffic And Commuting Patterns: ...............................................................................................2 2

Growth Rates And Patterns: ..................................................................................................... ...22 Meteorology: ................................................................................................................... ............22 Geography / Topography:........................................................................................................ ....22

Jurisdictional Boundaries: ..................................................................................................... ......23

Level of Control of Emission Sources:........................................................................................23

Black Mountains Nonattainment Area Discussion ....................................................................24

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................24

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................24 Air quality data: .............................................................................................................. .............25

Emissions Data: ................................................................................................................ ...........25 Population Density And Degree Of Urbanization:......................................................................26 Traffic And Commuting Patterns: ...............................................................................................2 6

Growth Rates And Patterns: ..................................................................................................... ...26 Geography / Topography:........................................................................................................ ....26

Jurisdictional Boundaries: ..................................................................................................... ......27

Level of Control of Emission Sources:........................................................................................27

Hickory-Lenoir-Morganton Nonattainment Area Discussion..................................................28

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................28

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................28 Air quality data: .............................................................................................................. .............28

Emissions Data: ................................................................................................................ ...........29 Population Density And Degree Of Urbanization:......................................................................29 Traffic And Commuting Patterns: ...............................................................................................2 9

Growth Rates And Patterns: ..................................................................................................... ...30 Meteorology: ................................................................................................................... ............30 Geography / Topography:........................................................................................................ ....30

Jurisdictional Boundaries: ..................................................................................................... ......30

Level of Control of Emission Sources:........................................................................................30

Charlotte-Gastonia-Rock Hill No nattainment Area Discussion...............................................32

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................32

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................32 Iredell County ................................................................................................................. .............33 Cleveland County ............................................................................................................... .........34 Anson County ................................................................................................................... ...........36 Stanly County .................................................................................................................. ............37

Greensboro-Winston-Salem-High Point Nonattainment Area Discussion..............................39

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................39

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................39 Stokes County.................................................................................................................. ............40 Yadkin County.................................................................................................................. ...........41 Surry County................................................................................................................... .............42 Randolph County................................................................................................................ .........43 Orange County.................................................................................................................. ...........45Raleigh-Durham-Cary Nonattainment Area Discussion ..........................................................46 EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................46

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................46 Harnett County ................................................................................................................. ...........47 Johnston County ................................................................................................................ ..........48 Chatham County ................................................................................................................. .........49 Orange County.................................................................................................................. ...........51

Fayetteville Nonattainment Area Discussion..............................................................................53

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................53

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................53

Greenville Nonattainment Area Discussion................................................................................56

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................56

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................56 Pitt County.................................................................................................................... ...............58 Greene County.................................................................................................................. ...........59

Virginia Beach-Norfolk-Newport News Nonattainment Area Discussion...............................61

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: ......................................................61

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:...............................61 Currituck County ............................................................................................................... ..........62



## Table of Figures

Figure 1: North Carolina’s 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Ar e In Parts Per Billion (ppb) To Conserve Space On The Map. 76 ppb = 0.076 ppm.)...................................................................................2 Figure 2: North Carolina’s Recommendation On 8-Hour Ozone Nonattain ment Area Boundaries...5 Figure 3: Potential 8-hour Ozone Nonattainme nt Areas Map Following EPA’s Presumptive Full CSA/MSA and Full County Boundaries (As Presen ted at Governmental and Public Meetings)

............................................................................................................................... ......................10 Figure 4: North Carolina’s Proposed 8-hour Ozone Nonattainment Areas Map (As Presented at Governmental and Public Meetings) ...........................................................................................10 Figure 5: Recommended Nonattainment Areas. S now Bird Mountains – Joyce Kilmer-Slickrock Wilderness Area nonattainment area shaded in orange...............................................................12 Figure 6: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Are In Parts Per Billio n (ppb) To Conserve Space On The Map. 76 ppb = 0.076 ppm.).................................................................................13 Figure 7: Diurnal Ozone Profile Comparison (Ri dge Top, Valley, and Large Metropolitan Sites) .15 Figure 8: Recommended Nonattainment Areas. Great Smoky Mountai ns National Park nonattainment area shaded in orange...........................................................................................1 6 Figure 9: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Are In Parts Per Billio n (ppb) To Conserve Space On The Map. 76 ppb = 0.076 ppm.).................................................................................17 Figure 10: Diurnal Ozone Profile Comparison (Ri dge Top, Valley, and Large Metropolitan Sites)19Figure 11: Recommended Nonatta inment Areas Great Balsam Mountains – Shining Rock Wilderness Area nonattainment area shaded in orange...............................................................20 Figure 12: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Are In Parts Per Billio n (ppb) To Conserve Space On The Map. 76 ppb = 0.076 ppm.).................................................................................21 Figure 13: Diurnal Ozone Profile Comparison (Ri dge Top, Valley, and Large Metropolitan Sites)23 Figure 14: Recommended Nonattain ment Areas. Black Mountains nonattainment area shaded in

orange. ........................................................................................................................ .................24 Figure 15: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Are In Parts Per Billio n (ppb) To Conserve Space On The Map. 76 ppb = 0.076 ppm.).................................................................................25 Figure 16: Diurnal Ozone Profile Comparison (Ri dge Top, Valley, and Large Metropolitan Sites)27 Figure 17: Recommended Nonattainment Area................................................................................28 Figure 18: Unifour Regional 2006-2 008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Ar e In Parts Per Billion (ppb) To Conserve Space On The Map. 76 ppb = 0.076 ppm.).................................................................................29 Figure 19: Metrolina NC Regional 2006-2008 8-Hour Ozone Design Values Map ........................32 Figure 20: Triad NC Regional 2006-2008 8-Hour Ozone Design Values Map................................39 Figure 21: Triangle NC Regional 2006-2008 8-Hour Ozone Design Values Map...........................46 Figure 22: Fayetteville NC Regional 2006-2008 8-Hour Ozone Design Values Map .....................53 Figure 23: Greenville NC Regional 2006-2008 8-Hour Ozone Design Values Map .......................56 Figure 24: Three-year design values of monitors surround ing the Greenville area..........................56 Figure 25: Spatially allocated m odeled design values for 2009........................................................57 Figure 26: Currituck NC Regional 2006-2008 8-Hour Ozone Design Values Map.........................61



## Table of Tables

Table 1: North Carolina – Ozone (8-Hour Standard)..........................................................................6 Table 2: Snow Bird Mountains – Joyce Kilm er-Slickrock Wilderness Area Regional Ozone Design

Value Table.................................................................................................................... ..............13 Table 3: Great Smoky Mountai ns National Park Regional Oz one Design Value Table ..................17 Table 4: Great Balsam Mountains – Shining Rock Wilderness Area Regional Ozone Design Value

Table .......................................................................................................................... ..................21 Table 5: Black Mountains Regi onal Ozone Design Value Table .....................................................25 Table 6: Hickory Regional Ozone Design Value Table....................................................................29 Table 7: Charlotte/Metrolina Regi onal Ozone Design Value Table .................................................32 Table 8: Greensboro-Winston-Salem-High Point (Triad) Regional Ozone Design Value Table.....39 Table 9: Raleigh-Durham-Cary (Triangl e) Regional Ozone Design Value Table............................46 Table 10: Fayetteville Regional Ozone Design Value Table............................................................53 Table 11: Greenville Regional Ozone Design Value Table..............................................................57 Table 12: Fayetteville Regional Ozone Design Value Table............................................................61

## Table of Appendices

Appendix A: North Carolina’s 2006-2008 8- Hour Ozone Design Values Map & Table

Appendix B: Local Government and Public Comments Received

Appendix C: U.S. National Park Service a nd U.S. Forest Service Comments Received

Appendix D: Area Designations for the 2008 Re vised Ozone National Ambient Air Quality

Standards – December 2008 U.S. EPA Memorandum

Appendix E: North Carolina’s Existing and Pr evious Nonattainment Areas Boundaries Map

Appendix F: North Carolina’s Vehicle Emissi ons Testing (OBD) and Safety Inspection Map

Appendix G: North Carolina’s Jurisdictional Information: North Carolina County Map Core Base Statistical Area (CBSA) a nd Combined Statistical Area (CSA) Map North Carolina Regional and Metropolitan Planning Organizations (RPO & MPO) Map Select County Township Maps and Stat ewide County Township Population Table

Appendix H: North Carolina’s 2006 NOx a nd VOC Emissions Data Maps and Tables

Appendix I: North Carolina’s 2000 P opulation and Population Density Maps

Appendix J: North Carolina’s 2007 & 2020 Dail y Vehicle Miles Traveled Maps and Table

Appendix K: Commuting Patterns for Larg er Urbanized Counties in North Carolina

Appendix L: North Carolina’s Population Gr owth Rates and Proj ections Description

Appendix M: Backward Wind Trajectories and Wind Roses On 8-Hour Ozone Exceedance Days

### Introduction

The purpose of this document is to provide the State of North Carolina’s recommendations

on boundaries for the 8-hour ozone standard nonattain ment areas. This package is in response to the promulgation of a revised 8-hour ozone nation al ambient air quality standard (NAAQS) by the United States Environmental Protection Agency (EPA) on March 12, 2008.

EPA has instructed the States to subm it their recommendations for nonattainment boundaries for any monitors violating this revi sed 8-hour ozone standard by March 12, 2009. EPA will then provide comments back to the States by no later than November 12, 2009. These written comments from EPA begin a 120-day period during wh ich the States and EPA will attempt to work out any issues on the nonattainment boundaries. EPA will make the final decision on boundaries by March 12, 2010. This final decision on 8-hour oz one nonattainment areas will subsequently be published in the Federal Regist er and codified in 40 CFR 81

.


### Background

The Clean Air Act (CAA) requires EPA to desi gnate areas as attainment or nonattainment following the promulgation of a new NAAQS. Th e nonattainment boundaries are to be based on the data collected at the ambient air monitoring st ations. The State and lo cal air programs operate the ozone monitoring sites. The data is quality assured, and then submitted to EPA where it becomes part of a national database. The CAA re quires that the monitoring data be evaluated to

determine which monitors meet the standard and which monitors violate the standard. For the 8- hour ozone standard, three years worth of data fo r each monitor is evaluated. The fourth highest daily maximum 8-hour ozone value for each of th e three years is averaged together, and the resulting average is then compared to the standar d. The three-year average is referred to as the design value. With their acti on on March 12, 2008, EPA revised the 8-hour ozone standard to 0.075 parts per million (ppm). Therefore, a monitored th ree-year average of 0.075 ppm is considered to meet or attain the standard, wh ile a three-year average of 0.076 pp m or greater is considered to

violate the ambient standard.

North Carolina has evaluated the ozone monito ring data for the State for the most recent three-year period of 2006-2008, and has determined th at a total of 27 out of 40 monitors currently

violate the new 8-hour ozone standard. Additiona lly, the discontinuation of a monitor in western Pitt County in 2007 and the subsequent establishmen t of a new monitor in central Pitt County in

2008 have resulted in insufficient data to calculat e an appropriate 2006-2008 design value at either

location and therefore these sites are unclassifiable at this time. A map showing the 8-hour ozone design values across North Carolina is included as Figure 1. This map and a table used for calculating the respective design values are included in Appendix A. The highest design value in the State at 0.094 ppm is observed at a monitor lo cated in northeastern Mecklenburg County. The lowest design value in the Stat e at 0.065 ppm is observed at the Bryson City monitor in central Swain County. The higher design values tend to occur along the I-85/ I-40 corridor stretching throughout the Piedmont Crescent from Charlotte through the Triad and to the Triangle. This is the most heavily urbanized and industria lized region of North Carolina. There are also four monitors in the North Carolina Mountains that are minimally violating the standard. All of the violating

monitors in the mountains ar e located above 4500 feet and experience the highest ozone concentrations during the middle of the night, which is indicative of transported pollution and not

the result of local emissions sources.Figure 1: North Carolina’s 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Are In PartsPer Billion (ppb) To Conserve SpaceOn The Map. 76ppb = 0.076 ppm.)

### Summary of Recommendations

The State of North Carolina’s recommendations for the designation of areas of the state for

the new 8-hour ozone standard is demonstrated in the attached map entitled, “North Carolina’s Proposal on Potential 8-hour Ozone Nonattainment Boundaries” (Figure 2). The recommendations include: full county nonattainme nt designation for Alamance, Alexander, Cabarrus, Caswell, Catawba, Cumberland, Davidson, Davie, Durh am, Edgecombe, Forsyth, Franklin, Gaston, Granville, Guilford, Lincoln, Mecklenburg, Nas h, Orange, Person, Rockingham, Rowan, Union, and Wake Counties; partial coun ty nonattainment designation fo r Buncombe, Burke, Caldwell, Chatham, Cherokee, Graham, Haywood, Hende rson, Iredell, Jackson, Johnston, Madison, McDowell, Randolph, Swain, Transylvania, and Yan cey Counties; unclassifiable designation for Pitt County, and attainment designation for the remain ing full or partial counties in North Carolina. These various designation recommendations are further reflected in Table 1.

From November 2008 through February 2009, 22 meetings or presentations were held across North Carolina with local government electe d officials, local and regional transportation planners, other State agencies, and Federal agencies. Additiona lly, five public meetings were conducted in each of the five most populous regions of North Carolina in January and early February 2009. At all of these meetings, bac kground information concerning the promulgation of

the revised 8-hour ozone standa rd and the implications to North Carolina based on current monitoring data were presented. Central to the discussion during th ese meetings were two maps: one map demonstrating the poten tial nonattainment areas following EPA’s presumptive boundaries of full county designations of en tire Core Based Statistical Areas (CBSA - which is either a metropolitan or micropolitan statistical area) or entir e Combined Statistical Areas (CSA - which is a combination of adjacent CBSA’s) with monitors vi olating the ozone standar d, counties outside of a CBSA or CSA with violating monitors, and countie s believed to contribute to the ozone problem (Figure 3); and one map demonstrating the poten tial nonattainment areas based on a proposal by the North Carolina Division of Air Quality (Figure 4).

This designation recommendation takes into consideration comments received during the 22 governmental meetings, during the five public mee tings, and during the public comment period that ended on February 9, 2009. Appendix B contains th e comments received. The basic rationale for the designation recommendations is that in the co re urban areas of a CBSA or CSA, whole counties are selected where the violating ozone design values are observed. In the le ss urbanized areas of a CBSA or CSA, partial counties are selected wher e the population and vehicle miles traveled are relatively low and where the monitoring data demonstr ates attainment of the 8-hour ozone standard. In most instances, the partial county designations were repr esented by Metropolitan Planning Organization (MPO) or township bo undaries that are immediately c onnected with the core of the CBSA or CSA. In the mountain areas (B uncombe, Cherokee, Graham, Haywood, Henderson, Jackson, Madison, McDowell, Swain, Transylvania , and Yancey Counties), the North Carolina portion of the Great Smoky Mountains National Park, the North Carolin a portion of the Joyce Kilmer-Slickrock Area, the Shini ng Rock Wilderness Area, and elev ations above 4000 feet in the Snow Bird, Great Balsams, and Bl ack Mountains are being recommended for designation. This is due to the before mentioned violations occurring onl y at high elevation monito rs in these areas. A

letter from the U.S. National Park Service is attached in Appendix C s upporting the nonattainment boundary recommendation for the Great Smoky Mount ains National Park. This letter was submitted in 2000 during an earlier boundary recommendation process, but recent discussions withthe U.S. National Park Service revealed that they continue to believe th at the entire Great Smoky

Mountains National Park should be designated as nonattainment. Additionally, a correspondence

from the U.S. Forest Service is attached in Appendix C supporting the nonattainment boundary recommendations for both the Joyce-Kilmer – Slic krock and the Shining Ro ck Wilderness Areas. The full discussion of the partial county designations, including a discussion on the mountain area designations, is provided later.

These recommendations address the designati on area boundaries criteria laid out in the December 4, 2008 memo from Robert J. Meyers, Pr incipal Deputy Assistant Administrator entitled, “Area Designations for the 2008 Re vised Ozone National Ambient Air Quality Standards”. This guidance is attached in Appendix D. The designa tion recommendations are also consistent with the methodology behind the establishment of all existi ng and previous 8-hour ozone nonattainment area boundaries in North Carolina. A map of North Caro lina’s existing and prev ious nonattainment area boundaries is provided in Appendix E.

The final designation by EPA of the nonattainment areas is only the first step in the implementation of the revised 8-hour ozone standard. The next major requirement is the development of the State Implementation Plan th at contains the necessary strategies to be implemented by the state so that all areas can attain the standard by th e attainment date. In order to accomplish this requirement, North Carolina is in the process of beginning a modeling analysis to conclude what control strategies are necessary to address the current 8-hour violations in the State. This modeling analysis will be coordinated thro ugh a collaboration amongst states throughout the Southeast, Midwest, and Mid-Atlantic. This multi -state and multi-region collaboration ensures that North Carolina is accurately projecting future emissions and air quality scenarios in the modeling analysis and is appropriately developing control stra tegies that will ultimately lead to expeditious

statewide attainment of the re vised 2008 8-hour ozone standard.

North Carolina has already undertaken subs tantial and progressive emissions reduction strategies over the past decade. These strategi es have allowed North Carolina to achieve almost

statewide attainment of the 1997 8-hour ozone st andard. The North Carolina General Assembly adopted the Clean Air Bill of 1999 that changed the State’s vehi cle inspection and maintenance (I/M) program to an on-board di agnostic (OBD) program and expa nded the program to 48 counties that captured greater than 80% of the vehicles in North Carolina. This OBD based I/M program is one of the most expansive in the country. Appe ndix G contains a county map of where the I/M program is currently required for cars and light-duty trucks. Additional actions taken by North Carolina include the adoption of the NOx SIP call rules and the North Carolina General Assembly approval of an aggressive multi-pollutant bill (Clean Smokestacks Act) in 2002 that has resulted in significant reductions in sulfur dioxide, as well as year round reductions in nitrogen oxides from the State's two largest utilities. Both of the legislative actions demonstrate North Carolina’s willingness and statutory authority to establish emissions control programs regardless of a Federal nonattainment designation status. Finally, North Carolina maintains a nationally recognized air quality action day program in the six most populous regions of the state. This program advises citizens of upcoming air quality events so that th e public can better protect their health and take

action to reduce their own em ission producing activities.Figure 2: North Carolina’s Recommendation On 8-Hour OzoneNonattainment Area BoundariesFollowing in Table 1 is North Carolina’s recommenda tion of areas as nonatta inment, unclassifiable,

or attainment under the revi sed 8-hour ozone standard.

Table 1: North Carolina – Ozone (8-Hour Standard)

Designated Area Designation Type Classification Type

Snow Bird Mountains – Joyce KilmerSlickrock Wilderness Area: Graham County

Above 4000 feet elevation in the Snow Bird Mountains range Joyce Kilmer-Slickrock Wilderness Area boundary Cherokee County

Above 4000 feet elevation in the Snow Bird Mountains range

Great Smoky Mountains National Park: Haywood County Park boundary Swain County Park boundary

Great Balsam Mountains – Shining Rock

Wilderness Area: Buncombe County

Above 4000 feet elevation in this mountain range Haywood County

Above 4000 feet elevation in this mountain range Shinning Rock Wilderness Area boundary Henderson County

Above 4000 feet elevation in this mountain range Jackson County

Above 4000 feet elevation in this mountain range Transylvania County

Above 4000 feet elevation in this mountain range Nonattainment

Nonattainment

NonattainmentDesignated Area Designation Type Classification Type

Black Mountains: Buncombe County

Above 4000 feet elevation in this mountain range Madison County

Above 4000 feet elevation in this mountain range McDowell County

Above 4000 feet elevation in this mountain range Yancey County

Above 4000 feet elevation in this mountain range

Hickory-Lenoir-Morganton Area: Alexander County Burke County Unifour Metropolitan Planning Organization boundary Caldwell County Unifour Metropolitan Planning Organization boundary Catawba County

Charlotte-Gastonia-Salisbury Area: Cabarrus County Gaston County Iredell County Davidson Township Coddle Creek Township Lincoln County Mecklenburg County Rowan County Union County Nonattainment

Nonattainment

NonattainmentDesignated Area Designation Type Classification Type

Greensboro-Winston-Salem-High Point

Area: Alamance County Davidson County Forsyth County Guilford County Caswell County Davie County Orange County Burlington-Graham Metropolitan Planning Organization boundary Randolph County High Point Metropolitan Planning Organization boundary Rockingham County

Raleigh-Durham-Cary Area: Chatham County Baldwin Township Center Township New Hope Township Williams Township Durham County Franklin County Granville County Johnston County Capital Area Metropolitan Planning Organization boundary Orange County Outside Burlington-Graham Metropolitan Pla nning Organization boundary Person County Wake County

Fayetteville Area: Cumberland County Nonattainment

Nonattainment

NonattainmentDesignated Area Designation Type Classification Type

Rocky Mount Area: Edgecombe County Nash County

Greenville Area: Pitt County

Rest of State Nonattainment

Unclassifiable

AttainmentFigure 3: Potential 8-hour Ozone Nonattainment A reas Map Following EPA’s Presumptive Full CSA/MSA and Full County Boundaries (As Presented at Governmen tal and Public Meetings)

Figure 4: North Carolina’s Proposed 8-hour Ozone No nattainment Areas Map (As Presented at Governmental and Public Meetings)

### Area Specific Recommendations on Boundaries for 8-hour Ozone

Nonattainment

The purpose of the remainder of this document is to address the criteria that EPA established for considering boundaries less than the full CBS A or CSA for nonattainm ent designation. These

criteria are outlined in the before mentione d “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards” memo, which is attached in Appendix D. The remaining documentation only addresses in detail those areas where North Carolina’s recommendation is less than the full CBSA or CSA, where additiona l areas beyond a CBSA or CSA are recommended for nonattainment designation, or wher e there is incomplete air quali ty data and an unclassifiable designation is recommended.

### Snow Bird Mountains – Joyce Kilm er-Slickrock Wilderness Area

Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: Graham County

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary: Elevations above 4000 feet elevation in the Snow Bird Mountains range (Cherokee and Graham Counties) and the Joyce Kilmer-S lickrock Wilderness Area (Graham County)

Discussion: Graham County is not a porti on of a CBSA or CSA. There are not any major urban areas within Graham County, and it is co nsidered one of North Carolina’s most rural counties. There is only one ozone monitor in Graham County (reference Figure 6), and this s ite is located above 4000

feet elevation in the Snow Bird Mountains range that straddle s the Cherokee and Graham County line. This monitoring site was originally establis hed to help understand the air quality impacting the nearby Joyce Kilmer-Slickrock Wild erness Area without having to di sturb land specifically within this Wilderness Area. With this in mind, th e nonattainment boundary re commendation includes all of the Joyce Kilmer-Slickrock Wilderness Area de spite being geographically separated from the violating monitor (see Figure 5). The additiona l rationale for the recommended 8-hour ozone nonattainment boundary is outlined in the following 9 factors.

Figure 5: Recommended Nonattainmen t Areas. Snow Bird Mountains – Joyce Kilmer-Slickrock Wilderness

Area nonattainment area shaded in orange

.Air quality data: The Joanna Bald monitor, located above 4000 f eet, at elevation 4688 feet, in the Snow Bird Mountains has a design value of 0.078 ppm. The readings at the ri dge top monitors experience the highest ozone concentrations duri ng the middle of the night, whic h is indicative of transported pollution. The Bryson City monitor, located in a va lley at 2159 feet just eas t of Graham County and

outside of the recommended nonattai nment area, has a design value of 0.065 ppm, the lowest design value in the state. The readings at the valley monitors below 4000 feet show that local precursor sources are not significantly cont ributing to the ozone violations at monitors above 4000 feet.

Figure 6: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design

Value Concentrations Presented Above Are In Parts Per Billion (ppb) To Cons erve Space On The Map. 76 ppb = 0.076 ppm.)

Table 2: Snow Bird Mountains – Joyce Kilmer-Slickrock Wild erness Area Regional Ozone Design Value Table

Emissions Data:

There are minimal emissions sources of eith er precursor pollutants (NOx and VOC) in the

recommended nonattainment area. The surroundi ng region has minimal anthropogenic emissions sources of either precursor pollutants (NOx and VOC). The only significant point emissions source in Graham County is Stanley Fu rniture, with 21 tons/year of NOx and 337 tons/year of VOC. 2005 2006 2007 2008 05-07 06-08

Snow Bird Mountains - Joyce

Kilmer-Slickrock

Wilderness Area Joanna Bald 37-075-0001 0.079 0.076 0.081 0.078 0.078 0.078 Region Annual 4th Highest 8-Hour Average Design Value Monitoring Sites AIRS IDPopulation Density And Degree Of Urbanization: Graham County has a population of 8,144 (2007 estimate) and a population density of 27 people per square mile. This is one of the leas t densely populated countie s in North Carolina and

the entire eastern United Stat es. Surrounding counties also have low population density. Nearby valley monitors below 4000 feet have design va lues well below the NAAQS, which shows that local precursor sources are not si gnificantly contributing to the ozone violations at monitors above

4000 feet. The recommended nonattainment area has very low population, estimated around 350 people and possibly as low as 0-5 people. (Pl ease see Appendix I for ma ps of population density)

Traffic And Commuting Patterns: There are not any significan t roadways within the reco mmended nonattainment area. Practically all of the VMT in Graham County is outside of the recommended nonattainment area boundary.

Growth Rates And Patterns: Population growth in Graham County from 2000-2010 is 2.7% and from 2010-2020 is 1.6%. The population growth in the recommended nonattai nment area is expected to be negligible.

Meteorology: The violating ridge top monitors are located above the nocturn al boundary layer and are near or within the subsidence inversion at the top of the daytime mixed layer. Because of this stratification, the air at elevations above 4000 feet is charact erized by long range transport and has different diurnal patterns than locations within th e valleys. Backward tr ajectories in Appendix M show that air parcels on days with ozone at or above 76 ppb originat e from areas outside the region including the western piedmont of North Carolina, Tennessee, and the Ohio River Valley, suggesting that the inclusion of elevations be low 4000 feet in the nonattainment area would have little impact on the violating m onitors located above 4000 feet.

Geography / Topography:

The Joanna Bald ozone monitor is considered a high-elevation or ridge top monitor. Much like all the other ridge top ozone monitors in West ern North Carolina, Joanna Bald does not have a normal diurnal ozone response profil e similar to ozone monitors in the valleys of th e Mountains and throughout the balance of the Pied mont, Sandhills, and Coastal Pl ains. Instead of recording

exceedances of the 8-hour ozone standard dur ing the middle of the afternoon when ozone production and photochemistry is at a maximum, the ozone exceedances at Joanna Bald and other ridge top monitors occur during the nighttime hours. This timing of the exceedances is indicative of transport and not local generation of ozone, sin ce the ozone chemistry stops once the sun sets. Figure 7 demonstrates a typical comparison between a mountain ridge top monitor (red line), a mountain valley monitor (blue), and a larg e metropolitan area monitor (yellow).Figure 7: Diurnal Ozone Profile Comparison (Ridge Top, Valley, and Large Metropolitan Sites)

Jurisdictional Boundaries: Parts of the Qualla Boundary, also known as the Eastern Cherokee Indian Reservation, are located in Graham County. These sections of the Qualla Boundary ar e non-contiguous and are separate from the primary part of the Qualla Bo undary located in Swain and Jackson counties. The Cherokees who live in Graham County form th e Snowbird Cherokee community. Although there are the described tribal lands in Graham County, the Snowbird Mountains at elevation 4000 feet and above that are recommended to be designated nonatta inment are not on any tribal lands. Also the area recommended to be designated nonattainment ha s never been part of a nonattainment area, is not in a CSA, and does not have an MPO.

Level of Control of Emission Sources: No OBD-based I/M program exists in this c ounty; however, an annual visual inspection of emissions equipment for tampering is required. Other Federal and stat e (North Carolina and surrounding states) mobile and point strategies to reduce emissions wi ll have a much greater impact in reducing ozone levels belo w the NAAQS above 4000 feet.

• DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designation. North Carolina believ es this is an important consideration for setting nonattainment boundaries. The new in spection and maintenance program that requires on-board diagnostic testing in 48 coun ties (phased in between 2002 and 2006) is an example of North Carolina’s ability to cont rol sources in counties regardless of the nonattainment designations. The ne w I/M program was adopted in 1999.

### Great Smoky Mountains National Park Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: Haywood County (as a part of a larger As heville nonattainment area also including Buncombe, Henderson County, Madison, Tr ansylvania, and Yancey Counties)

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary: Haywood County Park boundary Swain County Park boundary

Discussion: The Great Smoky Mountains National Park is not a portion of a CBSA or CSA. There are not any major settlements within the park, and being a national park it can be considered an undeveloped tract of land. There is only one ozon e monitor within the park boundaries in the North Carolina portion of the park (ref erence Figure 6), and this site is located above 4000 feet elevation in Haywood County. Since nearby low elevation sites are in attainment, North Carolina agrees with the presumptive nonattainment boundary of the Gr eat Smoky Mountains National Park (see Figure 8). The additional rational for the recommende d 8-hour ozone nonattainmen t boundary is outlined in the following 9 factors.

Figure 8: Recommended Nonattainment Areas. Great Smoky Mountains Na tional Park nonattainment area shaded in orange.Air quality data: The Purchase Knob monitor, located above 4000 feet at elevation 5085 feet in the Great Smoky Mountains National Park, has a design value of 0.077 ppm. The near est monitors to the

Park outside of the recommended nonattainment ar ea are at Waynesville, with a design value of 0.071 ppm, and Bryson City, with a design value of 0.065 ppm. The readings at the ridge top monitors experience the highest ozone concentrat ions during the middle of the night, which is indicative of transported pollution.

Figure 9: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design

Value Concentrations Presented Above Are In Parts Per Billion (ppb) To Cons erve Space On The Map. 76 ppb = 0.076 ppm.)

Table 3: Great Smoky Mountai ns National Park Regional Ozone Design Value Table

Emissions Data:

There are minimal emissions sources of eith er precursor pollutants (NOx and VOC) in the

recommended nonattainment area. The surroundi ng region has minimal anthropogenic emissions sources of either precursor pollutant (NOx and VOC).

Population Density And Degree Of Urbanization: There are approximately 183 people, which is le ss than 0.3 percent of the total population in

the counties where the recommended nonattainment area is located, living in the North Carolina 2005 2006 2007 2008 05-07 06-08

Purchase Knob (Ridge Top) 37-087-0036 0.084 0.073 0.078 0.080 0.078 0.077

Waynesville (Valley) 37-087-0004 0.074 0.069 0.074 0.071 0.072 0.071

Bryson (Valley) 37-173-0002 0.070 0.063 0.066 0.068 0.066 0.065 Region Monitoring Sites AIRS ID Annual 4th Highest 8-Hour Average Design Value

Great Smoky

Mountains National

Parkportion of the Great Smoky Mount ains National Park. (Please see Appendix I for maps of population density)

Traffic And Commuting Patterns:

The minimal amount of the VMT within the r ecommended nonattainment area is associated

with the US441. Given the remote nature of th e Great Smoky Mountains National Park, the vast majority of the VMT in Haywood and Swain Countie s is outside of the Pa rk jurisdictional boundary and the recommended nonattainment area boundary.

Growth Rates And Patterns: Population growth within the Great Smoky Mountain s National Park is projected to be minimal.

Meteorology: The violating ridge top monitors are located above the nocturn al boundary layer and are near or within the subsidence inversion at the top of the daytime mixed layer. Because of this stratification, the air at elevations above 4000 feet is charact erized by long range transport and has different diurnal patterns than locations within th e valleys. Backward tr ajectories in Appendix M show that air parcels on days w ith ozone at or above .076 ppm or iginate from areas outside the region including the western Piedmont of North Carolina, Tennessee, and the Ohio River Valley, suggesting that the inclusion of elevations be low 4000 feet in the nonattainment area would have little impact on the violating m onitors located above 4000 feet.

Geography / Topography:

The Purchase Knob ozone monitor is consider ed a high-elevation or ridge top monitor. Much like all the other ridge top ozone monitors in Western North Carolina, Purchase Knob does not have a normal diurnal ozone response profile si milar to ozone monitors in the valleys of the Mountains and throughout the bala nce of the Piedmont, Sandhills, and Coastal Plains. Instead of recording exceedances of the 8-hour ozone standard during the middle of the afternoon when ozone production and photochemistry is at a maximum, the ozone exceedances at Purchase Knob and other ridge top monitors occur during the nigh ttime hours. This timing of the exceedances is indicative of transport and not local generation of ozone, since the ozone chemistry stops once the sun goes sets. Figure 10 demonstrates a typical comparison between a m ountain ridge top monitor (red line), a mountain valley mon itor (blue), and a large metropo litan area monitor (yellow).Figure 10: Diurnal Ozone Profile Comparison (Ridge Top, Valley, and Large Metropolitan Sites)

Jurisdictional Boundaries: The Great Smoky Mountains National Park define s the boundary of the nonattainment area. Haywood County, one of the counties where the Park is located, was one of the counties in the Mountain Early Action Compact (EAC) under th e 1997 8-hour ozone standard. Haywood and Swain counties are currently atta ining the standard and a redesi gnation submittal is in process.

Level of Control of Emission Sources: Other Federal and state (North Carolina and surrounding states) mobile and point strategies to reduce emissions will have a much greater im pact in reducing ozone levels below the NAAQS above 4000 feet. Haywood County currently has an OBD based I/M program. Swain County does not have an OBD-based program, bu t requires an annual visual inspection of emissions equipment for tampering.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designation. North Carolina believ es this is an important consideration for setting nonattainment boundaries. The new in spection and maintenance program that requires on-board diagnostic testing in 48 coun ties (phased in between 2002 and 2006) is an example of North Carolina’s ability to cont rol sources in counties regardless of the nonattainment designations. The new OBD based I/M program was adopted in 1999.

### Great Balsam Mountains – Shining Rock Wilderness Area Nonattainment Area

Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: Buncombe, Haywood, Henderson, and Transylvania Counties (as part of a larger Asheville nonattainment area also including Madison and Yancey Counties)

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:

Elevations above 4000 feet elevation in th e Great Balsam Mountai ns range (includes portions of Buncombe County, Haywood C ounty, Henderson County, Jackson County, Transylvania County) and all of th e Shining Rock Wilderness Area

Discussion:

The Great Balsam Mountains and Slick Rock Wild erness area are part of the Asheville CSA.

There are 5 ozone monitors in the Asheville area (reference Figure 12), and one located nearby (Purchase Knob). All of the viol ating monitors are located above 4000 feet with all monitors below 4000 feet easily within attainment. The different ozone distribution with elevation and corresponding back trajectory analys is shows that ozone is generate d outside the Asheville area and transported into the region above 4000 feet with the upper level winds primarily from Tennessee, Georgia, Northern South Carolina, and central North Carolina. Additionally, ozone and ozone precursors may be transported longer distances from major sources within th e Ohio River Valley. Since very little ozone is generated locally, we recomm end the nonattainment boundary encompassing areas above 4000 feet around the viol ating monitor, in th is case the Frying Pan

monitor. The additional rationale for the re commended 8-hour ozone nonattainment boundary is outlined in the following 9 factors.

Figure 11: Recommended Nonattainmen t Areas Great Balsam Mountains – Shining Rock Wilderness Area nonattainment area shaded in orange.Air quality data: The Frying Pan monitor, located above 4000 feet at elevation 5200 feet in the Great Balsam Mountains, has a design value at 0.078 ppm. The Waynesville monito r, located in a valley at 2641 feet in Haywood County to the west outside of the recommended nonattainment area, has a design value of 0.071 ppm. The Bent Creek monitor, located in a valley at 2215 feet in Buncombe County

to the east outside of the recommended nonattainm ent area, also has a design value of 0.071 ppm. The readings at the ridge top monitors experien ce the highest ozone concentrations during the middle of the night, which is indicative of tr ansported pollution. The readings at the valley monitors below 4000 feet show that local precursor sources are not significan tly contributing to the

ozone violations at monitors above 4000 feet.

Figure 12: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design

Value Concentrations Presented Above Are In Parts Per Billion (ppb) To Cons erve Space On The Map. 76 ppb = 0.076 ppm.)

Table 4: Great Balsam Mountains – Shining Rock Wilderness Area Regional Ozone Design

Value Table

Emissions Data:

There are minimal emissions sources of eith er precursor pollutants (NOx and VOC) in the

recommended nonattainment area. There are 3 NOx sources above 100 tons/year in Buncombe and Haywood Counties outside the recommended nonattainment area. There are 6 VOC sources above 2005 2006 2007 2008 05-07 06-08

Frying Pan (Ridge Top) 37-087-0035 0.082 0.079 0.077 0.080 0.079 0.078

Waynesville (Valley) 37-087-0004 0.074 0.069 0.074 0.071 0.072 0.071

Bryson (Valley) 37-173-0002 0.070 0.063 0.066 0.068 0.066 0.065 Design Value Region Monitoring Sites AIRS ID Annual 4th Highest 8-Hour Average

Great Balsam Mountains - Shining

Rock Wilderness

Area100 tons/year and 2 sources from 50-100 tons /year in Buncombe, Haywood, and Henderson

Counties outside the recommended n onattainment area. Trajectory analysis in Appendix M shows that these nearby sources have little impact on days with ozone violations.

Population Density And Degree Of Urbanization:

The recommended nonattainment area contains at most 2,074 people, though it may be as low as 100 people. Most of the surrounding area has low population density, with the cities of

Asheville and Hendersonville ha ving the highest population dens ities in the region. Valley

monitors below 4000 feet located in and near these cities have design values well below the NAAQS, which shows that local precursor sources in the higher density ar eas are not significantly contributing to the ozone violations at monitors above 4000 feet. (Please see Appendix I for maps of population density)

Traffic And Commuting Patterns:

The minimal amount of the VMT within the r ecommended nonattainment area is associated with the Blue Ridge Parkway, NC Route 215, and US Route 276. Given the remote nature of the Great Balsam Mountains – Shining Rock Wilder ness Area, the vast majority of the VMT in Buncombe, Haywood, Henderson, and Transylvania Counties is outside of the recommended nonattainment boundary.

Growth Rates And Patterns: Population growth within the Great Balsam Mountains and the Sh ining Rock Wilderness area is projected to be negligible. Grow th in surrounding counties ranges from 5-15%.

Meteorology: The violating ridge top monitors are located above the nocturn al boundary layer and are near or within the subsidence inversion at the top of the daytime mixed layer. Because of this stratification, the air at elevations above 4000 feet is charact erized by long range transport and has different diurnal patterns than locations within th e valleys. Backward tr ajectories in Appendix M show that air parcels on days w ith ozone at or above .076 ppm or iginate from areas outside the region including the western pied mont of North Carolina, Tennessee, and the Ohio River Valley, suggesting that the inclusion of elevations be low 4000 feet in the nonattainment area would have little impact on the violating m onitors located above 4000 feet.

Geography / Topography: The Frying Pan ozone monitor is considered a high-elevation or ridge top monitor. Much like all the other ridge top ozone monitors in We stern North Carolina, Frying Pan does not have a normal diurnal ozone response profil e similar to ozone monitors in the valleys of th e Mountains and throughout the balance of the Pied mont, Sandhills, and Coastal Pl ains. Instead of recording

exceedances of the 8-hour ozone standard dur ing the middle of the afternoon when ozone production and photochemistry is at a maximum, the ozone exceedances at Frying Pan and other ridge top monitors occur during the nighttime hours. This timing of the exceedances is indicative of transport and not local generation of ozone, since the ozone chemistry stops once the sun goes sets. Figure 13 demonstrates a typical comparison betwee n a mountain ridge top monitor (red line), a mountain valley monitor (blue), and a larg e metropolitan area monitor (yellow).Figure 13: Diurnal Ozone Profile Comparison (Ridge Top, Valley, and Large Metropolitan Sites)

Jurisdictional Boundaries: Haywood and Buncombe counties are part of the Mountain Area Early Action Compact (EAC) under the 1997 8-hour ozone. Shining Rock Wilderness Area boundary defines a portion of

the recommended nonattainment area.

Level of Control of Emission Sources:

Mobile emissions are the la rgest anthropogenic source in the recommended nonattainment area. Henderson, Buncombe, and Haywood Counties all have OBD-based I/M programs. Jackson and Transylvania counties do not have OBD-based I/M programs, but an annual visual inspection of emission equipment is required. Other Federal a nd state (North Carolina and surrounding states) mobile and point strategies to reduce emissions w ill have a much greater impact in reducing ozone levels below the NAAQS above 4000 feet.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designation. North Carolina believ es this is an important consideration for setting nonattainment boundaries. The new in spection and maintenance program that requires on-board diagnostic testing in 48 coun ties (phased in between 2002 and 2006) is an example of North Carolina’s ability to cont rol sources in counties regardless of the nonattainment designations. The ne w I/M program was adopted in 1999.

### Black Mountains Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: Yancey County (as part of a larger Ashevi lle nonattainment area also including Buncombe, Haywood, Henderson, Madison, and Transylvania Counties)

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:

Elevations above 4000 feet elevation in th e Black Mountains range (Buncombe, McDowell, Madison, and Yancey Counties).

Discussion: The Black Mountains area is part of the Asheville CSA. There are 5 ozone monitors in the Asheville area (reference Figure 15), and 2 locate d nearby (Purchase Knob and Barnett Knob). All of the violating monitors are located above 4000 feet with all monitors below 4000 feet easily

within attainment. The different ozone distribution with elevati on shows that ozon e is generated

outside the Asheville area and tr ansported into the region above 4000 feet with the upper level winds primarily from Tennessee, Georgia, Northern South Carolina, and central North Carolina. Additionally, ozone and ozone precu rsors may be transported longer distances from major sources within the Ohio River Valley. Since very little ozone is generated locally, we recommend the nonattainment boundary encompassing areas above 4000 feet within the Bl ack Mountains around the violating monitor, in this case the Mount Mitchell monitor (see Figure 14). The additional rational for the recommended 8-hour ozone nonattainment boundary is outline in the following 9

factors.

Figure 14: Recommended Nonattainmen t Areas. Black Mountains nonatta inment area shaded in orange.Air quality data: The Mount Mitchell monitor, located above 4000 feet at elevation 6502 feet in the Black Mountains, has a design value at 0.077 ppm. The read ings at the ridge top m onitors experience the highest ozone concentrations duri ng the middle of the night, whic h is indicative of transported pollution. The Bent Creek monitor, located in a valley at 2215 feet in Buncombe County to the

southwest outside of the recommended nonattainm ent area, also has a design value of 0.071 ppm. The Linville monitor, located at 3238 feet in Avery County to the northeast outside of the recommended nonattainment area, has a design valu e of 0.067 ppm. The readings at the valley monitors below 4000 feet show that local precursor sources are not significan tly contributing to the

ozone violations at monitors above 4000 feet.

Figure 15: Western NC Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design

Value Concentrations Presented Above Are In Parts Per Billion (ppb) To Cons erve Space On The Map. 76 ppb = 0.076 ppm.)

Table 5: Black Mountains Regional Ozone Design Value Table

Emissions Data:

There are minimal emissions sources of either precursor pollutants (NOx and VOC) in this region. 2005 2006 2007 2008 05-07 06-08

Mt. Mitchell (Ridge Top) 37-199-0004 0.080 0.075 0.079 0.078 0.078 0.077

Bent Creek (Valley) 37-021-0030 0.079 0.071 0.073 0.071 0.074 0.071 Annual 4th Highest 8-Hour Average Design Value Region Monitoring Sites AIRS ID

Black MountainsPopulation Density And Degree Of Urbanization: Approximately 2500 people live in the recomm ended nonattainment area. Most of the surrounding area has low population de nsity. The city of Ashevill e has the highest population density in the region. Valley monito rs below 4000 feet located in a nd near Asheville are well below the NAAQS, which shows that local precursor sour ces are not significantly contributing to the ozone violations at monitors above 4000 feet. (Please see Appendix I for maps of population density)

Traffic And Commuting Patterns:

Most of the traffic within the recommended non attainment area is asso ciated with the Blue Ridge Parkway. Yancey County, which includes th e largest portion of the nonattainment area, has 454,640 Daily VMT and contributes 0.62% of the commu ters that drive to Buncombe County to work each day. This pattern shows that the Bl ack Mountains above 4000 feet nonattainment area should not be expanded to include wider area.

Growth Rates And Patterns: Population growth within the Black Mountains is projected to be negligible. Growth in surrounding counties ranges from 5-15%.

Meteorology: The violating ridge top monitors are located above the nocturn al boundary layer and are near or within the subsidence inversion at the top of the daytime mixed layer. Because of this stratification, the air at elevations above 4000 feet is charact erized by long range transport and has different diurnal patterns than locations within th e valleys. Backward tr ajectories in Appendix M show that air parcels on days w ith ozone at or above 0.076 ppm or iginate from areas outside the region including the western Piedmont of North Carolina, Tennessee, and the Ohio River Valley, suggesting that the inclusion of elevations be low 4000 feet in the nonattainment area would have little impact on the violating m onitors located above 4000 feet.

Geography / Topography:

The Mount Mitchell ozone monitor is consider ed a high-elevation or ridge top monitor. Much like all the other ridge top ozone monitors in Western North Carolina, Mount Mitchell does not have a normal diurnal ozone response profile si milar to ozone monitors in the valleys of the Mountains and throughout the bala nce of the Piedmont, Sandhills, and Coastal Plains. Instead of recording exceedances of the 8-hour ozone standard during the middle of the afternoon when ozone production and photochemistry is at a maximum, the ozone exceedances at Mount Mitchell and other ridge top monitors occur during the nighttim e hours. This timing of the exceedances is indicative of transport and not local generation of ozone, since the ozone chemistry stops once the sun goes sets. Figure 16 demonstrates a typical comparison between a m ountain ridge top monitor (red line), a mountain valley mon itor (blue), and a large metropo litan area monitor (yellow).Figure 16: Diurnal Ozone Profile Comparison (Ridge Top, Valley, and Large Metropolitan Sites)

Jurisdictional Boundaries: Buncombe County is one of the counties in the Mountain Area Early Action Compact (EAC) under the 1997 8-hour standard. The recomme nded nonattainment area is defined by the

elevation of 4000 feet in the counties where the Black Mount ains are located (Buncombe, McDowell, and Yancey). These counties have no t previously been designated nonattainment.

Level of Control of Emission Sources: Buncombe County, which encompasses the western portion of the recommended nonattainment area, has an OBD-based I/M program . McDowell and Yancey counties do not have an OBD-based I/M program, but annual visual in spection of emissions equipment is required. Other Federal and state (North Carolina and surrounding states) mobile and point strategies to reduce emissions will have a much greater imp act in reducing ozone levels below the NAAQS

above 4000 feet.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designation. North Carolina believ es this is an important consideration for setting nonattainment boundaries. The new in spection and maintenance program that requires on-board diagnostic testing in 48 coun ties (phased in between 2002 and 2006) is an example of North Carolina’s ability to cont rol sources in counties regardless of the nonattainment designations. The ne w I/M program was adopted in 1999.

### Hickory-Lenoir-Morganton Nona ttainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: Alexander, Burke, Caldwell, and Catawba Counties

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary: The Unifour Metropolitan Planning Organi zation Planning Boundary within Burke and Caldwell Counties, and the whole of Catawba and Alexander Counties

Discussion: Point and mobile emissions are sparse out side the Metropolitan Planning Organization (MPO) boundary within in western Burke and Cald well Counties. Additionally, population density is substantially lower in the same area compared to areas within the MPO. An analysis of trajectories shows little impact from western Burke and Caldwell Counties on high ozone days. Thus, we recommend that areas outside the MPO boundaries in western Caldwell and Burke Counties be designated attainment.

Figure 17: Recommended Nonattainment Area.

Air quality data: There are two monitoring sites located in the Hickory-Lenoir-Morganton MSA, one in Lenoir in Caldwell County and one in Taylorsville in Alexander C ounty. The Taylorsville site has a marginal violation at 0.076 ppm, while the Leno ir site is under the NAAQS at 0.075 ppm. A site close to the western border of Burke county in Linville is well under the NAAQS, at 0.067 ppm. A wind analysis suggests that on the majority days with higher ozone at these monitors, Charlotte is having the most impact on these sites. There ar e also a number of days when these sites are impacted by transport from the west and northwest, and that pollution comes over the mountains and mixes down into the valleys where the monitors are located. For these reasons, we recommend

a smaller area than the full MSA.Figure 18: Unifour Regional 2006-2008 8-Hour Ozone Design Values Map (Please Note That All Design Value Concentrations Presented Above Are In Parts Per Billion (p pb) To Conserve Space On The Map. 76 ppb = 0.076 ppm.)

Table 6: Hickory Regional Ozone Design Value Table

Emissions Data: There are no significant point sources in western Burke and Caldwell counties, outside the MPO boundary. Hence, the recommended nonatt ainment boundary should not include areas outside the MPO boundary in wester n Burke and Caldwell Counties.

Population Density And Degree Of Urbanization: As of July 2007 estimates, there are 1 53,404 people in Catawba County, 88,439 people in Burke County, 79,376 in Caldwell County, and 36,656 in Alexander County. North Carolina’s recommended nonattainment boundary captures 318,837 people, of the total 357,875 people living in the four county MSA, or 89 percent of the population is represente d in the MPO planning boundary. In the recommended partial counties (Burke and Caldwell), the MPO boundary captures 69.8% or 61,466 people and 84.8% or 67,311 people in Burke and Caldwell counties, respectively. Population density is much lower outside th e MPO boundary in western Burke and Caldwell Counties (see Appendix I).

Traffic And Commuting Patterns: Caldwell County has 1,699,900 Daily VMT and c ontributes 8.45% of the commuters that drive to Catawba County to work each day. Daily VMT are expected to increase to 1,904,030 in 2005 2006 2007 2008 05-07 06-08

Waggin Trail 37-003-0004 0.080 0.076 0.081 0.076 0.079 0.077

Lenoir 37-027-0003 0.075 0.076 0.077 0.072 0.076 0.075 Region Monitoring Sites AIRS ID Annual 4th Highest 8-Hour Average Design Value

Unifour2020. Burke County has 2,685,230 Daily VMT and contributes 8.83% of the commuters that drive to Catawba County to work each day. Daily VMT are expected to increase to 2,938,960 in 2020. The amount of daily commuters originating from western Burke and Caldwell counties and outside

the MPO is small.

Growth Rates And Patterns: Population growth from 2000-2007 is 4.7%, well below the statewide average of 8.3%. Catawba county population is projected to grow 11.5% from 2000-2010, and 12.6% from 2010 to 2020. Burke county population is projected to decline 0.9% from 2000-2010, and 0.7% from 2010 to 2020. Caldwell county population is projected to grow 3.2% from 2000-2010, and 2.0% from 2010 to 2020. Alexander county population is pr ojected to grow 11.9% from 2000-2010, and 8.0%

from 2010 to 2020.

Meteorology: On the days when these monitors exceed the 8- hour standard, they appear to be measuring pollution from several other areas, mainly Charlo tte and the Triad but al so including eastern Tennessee, and the Ohio River Valley. As the po llution in these areas is reduced, these monitors should observe lower ozone levels. Currently, th e design value for the Lenoir monitor is 0.075 ppm and the Taylorsville monitor is 0.076 ppm. The tr ajectory analysis included in Appendix K shows

that the last 5-6 hours of the tr ajectories cross eastern portions of the 4 counties. Very few trajectories pass through wester n Burke and Caldwell Counties on their way to the monitors.

Geography / Topography: The mountains in the western part of the Burk e and Caldwell Counties need to be factored in to the nonattainment designation. These areas coincide with areas within the Pisgah National

Forest.

Jurisdictional Boundaries: The western parts of Burke and Caldwell Countie s are within the Pisgah National Forest.

The recommended nonattainment area matches the MPO boundaries in Burke and Caldwell Counties. Alexander, Burke, Caldwell and Ca tawba counties make up the Unifour Early Action Compact (EAC) Area under the 1997 8-hour ozone.

Level of Control of Emission Sources: The majority of the emissions are genera ted from mobile sources. An OBD-based inspection and maintenance program is active in Catawba, Cald well, and Burke Counties. Although Alexander County does not have and OBD based I/M program, annual visual inspection of emission equipment is required. Other Federal and state mobile strategies will also re duce these emissions. Low sulfur diesel and gasoline is required statewide. The Ma rshall Steam Station in Catawba County is now required to reduce the NOx emissi ons to meet the NOx SIP Call and the Clean

Smokestacks Act.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designation. North Carolina believ es this is an important consideration for setting nonattainment boundaries. The new in spection and maintenance program that requires on-board diagnostic testing in 48 coun ties (phased in between 2002 and 2006) is anexample of North Carolina’s ability to cont rol sources in counties regardless of the nonattainment designations. The ne w I/M program was adopted in 1999.

### Charlotte-Gastonia-Rock Hill Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary: The whole counties of Iredell, Mecklenbur g, Lincoln, Gaston, Clev eland, Union, Anson, Stanly, Cabarrus, and Rowan.

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary: The whole counties of Cabarrus, Gaston, Linc oln, Mecklenburg, Rowan and Union and the partial county of Iredell.

Figure 19: Metrolina NC Regional 2006-2008 8-Hour Ozone Design Values Map

Table 7: Charlotte/Metrolina Re gional Ozone Design Value Table

2005 2006 2007 2008 05-07 06-08

County Line 37-119-1009 0.090 0.093 0.096 0.093 0.093 0.094

Enochville 37-159-0022 0.088 0.089 0.095 0.082 0.090 0.088

Rockw ell 37-159-0021 0.086 0.085 0.096 0.084 0.089 0.088

Garinger 37-119-0041 0.088 0.091 0.093 0.085 0.090 0.089

Crouse 37-109-0004 0.082 0.082 0.085 0.079 0.083 0.082

Monroe 37-179-0003 0.082 0.080 0.082 0.080 0.081 0.080

Arrow ood 37-119-1005 0.085 0.078 0.087 0.073 0.083 0.079

York (South Carolina) 45-091-0006 0.079 0.078 0.080 0.075 0.079 0.077 Annual 4th Highest 8-Hour Average Design Value Region Monitoring Sites AIRS ID

MetrolinaThe monitors in the Charlotte-Gastonia-Rock Hill MSA currently measure the highest ozone values in the State. North Carolina recommends, relati ve to the North Carolina counties, that the whole counties of Cabarrus, Gaston, Lincoln, Mecklenburg, Rowan and Union and the partial county of Iredell be designated as nonattainment. The co unties not recommended and the partial county recommendations are discussed below, along wi th the 9 criteria EPA identified in their nonattainment boundary guidance that should be addressed.

Iredell County This is an MiSA county within the Charlotte-Gastoni a-Salisbury CSA, but it does not have a monitor located in the county. This is a high co mmuter county into the Ch arlotte area along the I77 corridor. The northern portion of the county is rural, so the reco mmendation is for a smaller area than the entire county.

The recommendation is that the two townships in the southern portion of Iredell County, Coddle Creek and Davidson Townships, as defined by th e 2000 Census, be designated as nonattainment.

Air Quality Data: As shown in Figure 19 above, this area has 7 monitors with design values ranging from 0.079 ppm to 0.094 ppm. The monitor located nearest Iredell County is in neighboring Rowan County in Enochville with a design value of 0.088 ppm. However, on days when this monitor has the highest readings, the winds are generally out of the southwest, indicating that the emissions from southern Ired ell County are not likely to contribute to the Enochville monitor’s high ozone levels.

Emissions Data: Based on 2005 emissions inventories, Iredell Co unty has 2012.88 tons per year of pointsource NOx and the county has 768.55 tons per year of point-source VOC . There are some industrial sources in the county, including a natural gas pumping st ation, which is subject to

the NOx SIP call.

Population Density and Degree of Urbanization: 122,660 people live in Iredell County, 39,885 people live in the two townships

recommended as nonattainment. The northern portion of Iredell County has low population density, with 2 tracts containing 50-100 people per square mile, and 5 tracts with 100-250 people per square mile. The northern portion also includes Statesville, with 1 tract containing 250-500 people per square mile, and 5 small tracts w ith 500-2500 people per square mile. The portion that is recommended to be designated nonattainment has 1 tract with 250-500 people per square mile, and 2 small tracts with 500-1000 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Iredell County has 5,208,390 Daily VMT, acco rding to 2007 data. Iredell County contributes 2.02 percent of the commuters who drive in to Mecklenburg County to work each day. Iredell ranks number 5 in the commuting counties into Mecklenburg. These VMT are expected to increase to 6,236,920 by 2020.Growth Rates and Patterns: The population in Iredell County is expected to grow between 2000 and 2010, with a total

increase of 32.0%.

Meteorology: Winds across Iredell County are climatological ly from the southwest. With this climatological wind pattern, the emissions in the southern part of the county will likely impact the Triad area. On days when the winds are from the north, the emissions will add to the Charlotte area’s pollution.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The existing 1997 8-hour ozone standard nonatt ainment area includes th e southern portion of Iredell County, which is also included in North Carolina’s recommendation as

nonattainment for the new 8-hour ozone standard.

Level of control of emissions sources: Iredell County currently has 2 major point sources for NOx and one major point source for VOCs. One fuel pumping stati on is subject to the NOx SIP Ca ll. However, controls for additional large point sources are handled on a case-by-case basis. Additional NOx emissions are from mobile sources, and the combined Federal and state control programs

will address these emissions. Iredell County currently has an OBD based I/M program and low-sulfur gasoline is required statewide.

DENR’s ability to control sources throughout the state: The North Carolina General Statute allows sources anywhere in the st ate to be controlled under an attainment strategy, regardless of desi gnation. North Carolina believes this is an important

consideration for setti ng nonattainment boundaries. The new inspection and maintenance program that requires on- board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Cleveland County This is an MiSA county within the Charlotte-Gastoni a-Salisbury CSA, but it does not have a monitor located in the county. This is a mostly rural county with a low impact from commuting

traffic into the urbanized core of the CSA. Therefore, North Carolina is recommending no portion of the county be designated as nonattainment.

Air Quality Data : As shown in Figure 19 above, this area has 7 monitors with design values ranging from 0.079 ppm to 0.094 ppm. The monitor located n earest Cleveland County is in neighboring Lincoln County in Crouse with a design value of 0.082 ppm. However, on days when this monitor has the highest readi ngs with winds generally out of the southwest, Cleveland County has no additional impact on th e air quality within the CSA.Emissions Data : Based on 2005 emissions inventories, Clevela nd County has 184.87 tons per year of pointsource NOx and the county has 793.60 tons pe r year of point-source VOC. There are two major point sources in the county (1 each for NOx and VOC).

Population Density and Degree of Urbanization : 96,408 people live in Cleveland County. The no rthern portion of Cl eveland County has low population density, with 9 tracts of less than 250 people per s quare mile. Two small tracts of 250-1000 people per square mile and 3 sma ller tracts of 1000-2500 people per square mile are in the southeastern portion of the county. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns : Cleveland County has 2,727,700 Daily VMT, accor ding to 2007 data. Cleveland County contributes less than 1 percent of the commute rs who drive in to Mecklenburg County to work each day. These VMT are expected to increase to 3,087,880 by 2020.

Growth Rates and Patterns : The population in Cleveland County is expect ed to grow slightly between 2000 and 2010,

with a total in crease of 0.8%.

Meteorology : Winds across Cleveland County are climatologi cally from the southwest. With this climatological wind pattern, the em issions in the southern part of the county will likely not impact the air quality within the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries : The existing 1997 8-hour ozone standard nona ttainment area does not include Cleveland County and it is not included in North Carolin a’s recommendation as nonattainment for the

new 8-hour ozone standard.

Level of control of emissions sources : Cleveland County currently has 1 major point source for NOx and one major point source for VOCs. However, these sources are non-EG Us and controls for each facility will be handled on a case-by-case basis. Additional NOx emissions are from mobile sources, and the combined Federal and state control progr ams will address these emissions. Cleveland County currently has an OBD ba sed I/M program and low-sulf ur gasoline is required

statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability tocontrol sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Anson County This is an MSA county within the Charlotte-Gastonia- Salisbury CSA, but it does not have a monitor located in the county. This is a mostly rural county with a low impact from commuting

traffic into the urbanized core of the CSA. Therefore, North Carolina is recommending no portion of the county be designated as nonattainment.

Air Quality Data : As shown in Figure 19 above, this area has 7 monitors with design values ranging from 0.079 ppm to 0.094 ppm. The monitor located nearest Anson County is in neighboring Union County in Monroe with a design value of 0.080 ppm. However, on days when this monitor has the highest readings with winds generally out of the southwest, Anson County has no additional impact on the air quality within the CSA.

Emissions D ata: Based on 2005 emissions inventories, Anson Co unty has 171.82 tons per year of pointsource NOx and the county has 58.61 tons per year of point-source VOC. There are no major point sources loca ted within the county.

Population Density and Degree of Urbanization : 25,321 people live in Anson County. The norther n portion of Anson C ounty is a largely rural county with no tracts ha ving a population density fewer than 250 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns : Anson County has 829,870 Daily VMT, according to 2007 data. Anson County contributes less than half of 1 percent of the commuters who drive in to Mecklenburg County to work each day. These VMT are expected to increase to 944,060 by 2020.

Growth Rates and Patterns : The population in Anson County is expected to decrease sligh tly between 2000 and 2010,

with a total decrease of 1.7%. A further decrease is e xpected from 2010 to 2020, falling by

4.3%.

Meteorology: Winds across Anson County are climatological ly from the southwest. With this climatological wind pattern, the em issions in the southern part of the county will have no impact on the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The existing 1997 8-hour ozone standard nonatt ainment area does not include Anson County

and it is not included in North Carolina’s re commendation as nonattainment for the new 8-

hour ozone standard.Level of control of emissions sources : There are no major point sources to consider controls within the county. Additional NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Anson County does not currently have an OBD based I/M program, but requires an annua l visual inspection of emissi ons equipment. Low-sulfur gasoline is required statewide.

DENR’s ability to control sour ces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Stanly County This is an MiSA county within the Charlotte-Gastoni a-Salisbury CSA, but it does not have a monitor located in the county. This is a mostly rural county with a low impact on commuting traffic

into the urbanized core of the CSA. Therefor e, North Carolina is recommending no portion of the county be designated as nonattainment.

Air Quality Data : As shown in Figure 19 above, this area has 7 monitors with design values ranging from 0.079 ppm to 0.094 ppm. The monitor located nearest Stanly Count y is in neighboring Rowan County in Rockwell with a design value of 0.088 ppm. However, on days when this monitor has the highest readings with winds generally out of the southwest, Stanly County has no additional impact on the air quality within the CSA.

Emissions Data : Based on 2005 emissions inventories, Stanly County has 363.74 tons per year of pointsource NOx and the county has 340.35 tons pe r year of point-source VOC. There is one major point source of NOx emissions in Stanly County.

Population Density and Degree of Urbanization : 58,277 people live in Stanly County. The norther n portion of Stanly C ounty is a largely rural county with 7 tracts ha ving a population density fewer than 250 people per square mile, 2 tracts with a density of 250-500 peopl e per square mile and 1 tract each of 500-1000 and 1000-2500 people per square mile. (Pl ease see Appendix I for maps of population density)

Traffic and Commuting Patterns : Stanly County has 1,418,410 Daily VMT, according to 2007 data. Stanly County contributes less than 1 percent of the commute rs who drive in to Mecklenburg County to work each day. These VMT are expected to increase to 1,495,570 by 2020.Growth Rates and Patterns : The population in Stanly County is expected to increase slightly between 2000 and 2010,

with a total decr ease of 2.3%.

Meteorology: Winds across Stanly County are climatologi cally from the southwest. With this climatological wind pattern, the em issions in the southern part of the county will have no additional impact on the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The existing 1997 8-hour ozone standard nonatt ainment area does not include Stanly County

and it is not included in North Carolina’s re commendation as nonattainment for the new 8-

hour ozone standard.

Level of control of emissions sources: There is one major point source to consider within the county, but this source is not subject to the NOx SIP Call. Therefore, controls ar e handled on a per-case basis. Additional NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Stanly County does not currently have an OBD based I/M program, but requires an annua l visual inspection of emissi ons equipment. Low-sulfur gasoline is required statewide.

DENR’s ability to control sources throughout the state: The North Carolina General Statute allows sources anywhere in the st ate to be controlled under an attainment strategy, regardless of desi gnation. North Carolina believes this is an important

consideration for setti ng nonattainment boundaries. The new inspection and maintenance program that requires on- board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

### Greensboro-Winston-Salem-High Point Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary:
Surry, Stokes, Rockingham, Caswell, Yadkin, Forsyth, Guilford, Alamance, Davie, Davidson and Randolph

Counties

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:
Forsyth, Guilford, Alamance, Davidson, Caswell, Davie, Rockingham and the partial counties of Randolph and Orange

Figure 20: Triad NC Regional 2006-2008 8-Hour Ozone Design Values Map

Table 8: Greensboro-Winston-Salem-High Point (Triad) Regional Ozone Design Value Table

2005 2006 2007 2008 05-07 06-08

Cooleemee 37-059-0002 0.084 0.080 0.085 0.081 0.083 0.082

Mendenhall 37-081-0013 0.082 0.080 0.086 0.081 0.082 0.082

Union Cross 37-067-1008 0.080 0.082 0.083 0.078 0.081 0.081

Hattie Ave. 37-067-0022 0.074 0.082 0.082 0.081 0.079 0.081

Bethany 37-157-0099 0.078 0.075 0.082 0.084 0.078 0.080

Cherry Grove 37-033-0001 0.076 0.075 0.082 0.080 0.077 0.079

Clemmons 37-067-0030 0.075 0.077 0.078 0.078 0.076 0.077

Shiloh Church 37-067-0028 0.078 0.067 0.076 0.077 0.073 0.073 Region Monitoring Sites AIRS ID Annual 4th Highest 8-Hour Average Design Value

TriadThe monitors in the Greensboro/ Winston Salem/High Point CSA currently measure the second highest ozone values in the State. North Carolin a recommends that the whole counties of Forsyth, Guilford, Alamance, Davidson, Caswell, Davie, Rockingham and the part ial counties of Randolph and Orange be designated as nonattainment. Counties for which recommendations differ from EPA’s presumptive boundaries are di scussed below, along with the 9 cr iteria EPA identified in their nonattainment boundary guidance th at should be addressed.

Stokes County This is an MSA county within the Greensbor o-Winston Salem-High Point CSA, but there is no monitor located here. This is a rural county, so the recommendation is that no portion of the county be designated nonattainment.

Air Quality Data: As shown in Figure 20 above, the Triad area has 8 monitors with design values ranging from 0.073 ppm to 0.082 ppm. While Stokes County has no monitor, the nearest is located in Forsyth County with a design value of 0.073, and the second nearest mo nitor is located in Rockingham County with a design value of 0.080.

Emissions Data: Based on 2002 emissions inventories, Stokes C ounty has 21017.08 tons per year of NOx and the county has 95367.89 tons per year of VOC (a nthropogenic only). The large source of NOx emissions are from the Duke Energy Belews Creek facility, which has reduced and will

continue to reduce the NOx emissions to a bout 31 tons per day under the NOx SIP call.

Population Density and Degree of Urbanization: 44,711 people live in Stokes County. The county in general has a relatively low population density, with most tracts having 250 or fewer pe ople per square mile. Two small tracts have a population density of 250-500 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Stokes County has 889,040 Daily VMT and contributes 6.03 percent of the commuters that drive to Forsyth County to work each day. These VMT are expected to increase to 1,039,980 in 2020.

Growth Rates and Patterns: The population in Stokes County is expected to grow slightly between 2000 and 2010, with

a total increase of 5% or less.

Meteorology: Winds across Stokes County are climatological ly from the southwest. With this climatological wind pattern, the co unty is not in an upwind sect or that would routinely have an impact on air quality in a ny portion of the CSA or North Carolina. The exception is in the case of northerly winds.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.Jurisdictional Boundaries: Stokes County is one of several counties in the Triad Early Action Compact area under the

1997 8-hour ozone standard. The counties in th e Triad EAC were designated attainment April 15, 2008.

Level of control of emissions sources: Currently there is one major po int source in Stokes County to control and this facility is subject to the NOx SIP call. The remaining NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Stokes County currently has an OBD-ba sed I/M program and low-sulf ur gasoline is required

statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The OBDbased I/M program was adopted in 1999.

Yadkin County This is an MSA county within the Greensbor o-Winston Salem-High Point CSA, but there is no monitor located here. This is a rural county, so the recommendation is that no portion of the county be designated nonattainment.

Air Quality Data: As shown in Figure 20 above, this area has 8 monitors with design values ranging from 0.073 ppm to 0.082 ppm. There is no monitor in Yadkin County, but the closest monitor is located in Forsyth County and ha s a design value of 0.077 ppm.

Emissions Data: There are no large poin t sources in the county.

Population Density and Degree of Urbanization: 36,348 people live in Yadkin County. The county in general has a relatively low population density, with most tracts having 100 or fewer pe ople per square mile. Two small tracts have a population density of 100-250 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Yadkin County has 1,381,260 Daily VMT as of 2007. Yadkin County contributes 3.23 percent of the commuters that drive to Fors yth County to work each day. These VMT are expected to increase to 1,635,170 by 2020.

Growth Rates and Patterns: The population in Yadkin County is expected to grow moderately between 2000 and 2010,with a total in crease of 6.1%.

Meteorology: Winds across Yadkin County are climatological ly from the southwest. With this climatological wind pattern, the majority of the county is not in an upwind sector that would routinely have an impact on air qual ity in the urban portion of the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: Yadkin County is one of several counties in th e Triad Early Action Compact area under the

1997 8-hour ozone standard. The counties in th e Triad EAC were designated attainment April 15, 2008.

Level of control of emissions sources: There are no major point sources in the c ounty needing control. The remaining NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Yadkin County cu rrently has no OBD-based I/M program, but it has an annual safety inspection program re quiring a visual check of emissions control devices for tampering. Low-sulfur gasoline is required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Surry County This is not an MSA county but rather a Mi cropolitan Statistical Ar ea (MiSA) within the Greensboro-High Point-Winston Salem CSA and there is no monitor located here. This is a rural county, so the recommendation is that no portio n of the county be designated nonattainment.

Air Quality Data: As shown in Figure 20 above, this area has 8 monitors with design values ranging from 0.073 ppm to 0.082 ppm. There is no monitor in Surry County, but the closest monitor is located in Forsyth County and ha s a design value of 0.073 ppm.

Emissions Data: Based on 2002 point source emissions inventories, Surry County has 326.49 tons per year of NOx and the county has 1222.35 tons per year of VOC. The largest point sources in Surry County are the True Textiles, Weyerhaeu ser Company and Vaughan-Bassett Furniture Company manufacturing facilities.Population Density and Degree of Urbanization: 71,219 people live in Surry County. The entire County has fairly low population density, with 2 tracts containing 50-100 people per sq uare mile, 6 tracts containing 100-250 people per square mile, 3 small tracts containing 250- 1000 people per square mile and one minor tract containing 1000-2500 people per square mi le. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Surry County has 2,396,290 Daily VMT. Surry County contributes 2.54 percent of the commuters that drive to Forsyth County to work each day. These VMT are expected to decrease to 2,359,680 by 2020.

Growth Rates and Patterns: The population in Surry County is expected to grow between 2000 and 2010, with a total

increase of 4.0%.

Meteorology: Winds across Surry County are climatological ly from the southwest. With this climatological wind pattern, the northwestern portion of the county is not in an upwind sector that would routinely ha ve an impact on air quality in the urban portion of the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: Surry County is one of several counties in the Triad Early Action Compact area under the

1997 8-hour ozone standard. The counties in th e Triad EAC were designated attainment April 15, 2008.

Level of control of emissions sources: As discussed there are 3 non-EGU major point sources in Surry County. Controls for nonEGUs are regulated on a case-by-case basis. The remaining NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Surry County currently has an OBD-based I/M pr ogram and low-sulfur gasoline is required

statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Randolph County This is an MSA county within the Greens boro-Winston Salem-High Point CSA, but it does not have a monitor and is a mostly rural county. Therefore, North Carolina’s recommendation is fora smaller area of the county to be designated as nonattainment.

The recommendation is that the High Point Me tropolitan Planning Or ganization portion of Randolph County be designated as nonattainment.

Air Quality Data As shown in Figure 20 above, this area has 8 monitors with design values ranging from 0.073 ppm to 0.082 ppm. The nearest monitor to this region is in southeastern Forsyth County with a design value of 0.081 ppm.

Emissions Data: Based on 2002 point-source emissions inventor ies, Randolph County has 55.09 tons per year of NOx and the county has 747.49 tons per year of VOC. The largest point source (VOC emissions) in the county is the Oliver Rubber Company.

Population Density and Degree of Urbanization: 130,454 people live in Randolph County. Much of the County has low population density, with 10 tracts of 250 people or less per square mile, 5 tracts containing 250-500 people per square mile, 3 small tracts of 500-1000 peopl e per square mile and 5 smaller tracts containing 1000-2500 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Randolph County has 3,742,370 Daily VMT. Ra ndolph County contributes 7.54 percent of the commuters that drive to Guilford County to work each day. These VMT are expected to increase to 4,253,460 by 2020.

Growth Rates and Patterns: The population in Randolph County is expected to grow moderately between 2000 and 2010, with a total increase of 9.2%.

Meteorology : Winds across Randolph County are climatologica lly from the southwest. With this climatological wind pattern, the portion of th e county to be excluded from designation as nonattainment would not serve as an upwind sect or that would routinely have an impact on air quality in the urban portion of the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: Randolph County is one of several counties in the Triad Early Action Compact area under

the 1997 8-hour ozone standard. The counties in the Triad EAC were designated attainment April 15, 2008. The High Point Metropolitan Pl anning Organization boundary as of March 12, 2009, defines the portion of Randolph County that is recommended to be designated

nonattainment.Level of control of emissions sources: As discussed there are 3 non-EGU major point sources (VOC) in Randolph County with no major NOx point sources. Controls for non-E GUs are regulated on a case-by-case basis. The remaining NOx emissions are from mobile sources, and the combined Federal and statecontrol programs will address these emissions. Randolph County currently has an OBDbased I/M program and low-sulfur gasoline is required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Orange County This is not a county within the Triad CSA; however, a portion of the county is part of the Burlington-Graham Metropolitan Planning Orga nization. In order to avoid duplication of transportation conformity exercises, this por tion of Orange County is recommended to be considered part of the Triad nonattainment area. B ecause the bulk of the county is included in the Raleigh-Durham-Cary CSA, the nine factors ar e addressed in the Raleigh-Durham-Cary Area

discussion rather than here.

The recommendation is that the Burlington-Graham Metropolitan Planning Organization portion of Orange County be designated as nonattainment for the Greensboro-Winston-Salem-High Point Nonattainment Area for the purposes of transportation conformity.

### Raleigh-Durham-Cary Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary:
Wake, Johnston, Harnett, Orange, Durham, Chat ham, Person, Granville and Franklin Counties.

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:
Wake, Orange, Durham, Person, Granville, and Frank lin counties and the partial counties of Chatham and

Johnston.

Figure 21: Triangle NC Regional 2006-2008 8-Hour Ozone Design Values Map

Table 9: Raleigh-Durham-Cary (Triangl e) Regional Ozone Design Value Table

2005 2006 2007 2008 05-07 06-08

Millbrook 37-183-0014 0.082 0.078 0.084 0.078 0.081 0.080

Butner 37-077-0001 0.085 0.076 0.083 0.081 0.081 0.080

Durham Armory 37-063-0015 0.076 0.078 0.080 0.076 0.078 0.078

Franklinton 37-069-0001 0.080 0.074 0.080 0.078 0.078 0.077

Bushy Fork 37-145-0003 0.079 0.075 0.079 0.078 0.077 0.077

W. Johnston 37-101-0002 0.083 0.072 0.078 0.076 0.077 0.075

Fuquay-Varina 37-183-0016 0.085 0.073 0.080 0.078 0.079 0.077

Pittsboro 37-037-0004 0.079 0.070 0.075 0.072 0.074 0.072 Annual 4th Highest 8-Hour Average Design Value Region Monitoring Sites AIRS ID

TriangleThe monitors in the Raleigh-Durham-Cary CSA curre ntly measure the third highest ozone values in

the State. North Carolina recommends that th e whole counties of Wake, Orange, Durham, Person, Granville, and Franklin counties and the partial counties of Chatham and Johnston be designated as nonattainment. In addition North Carolina recommends that portions of Orange County be

associated with two different nonattainment areas for the purposes of transportation conformity. The

counties not recommended and the partial county recommendations are discussed below, along with

the 9 criteria EPA identified in their nonattainment boundary guid ance that should be addressed.

Harnett County This is an MiSA county within the Raleigh-Durham-Cary CSA, but it does not have a monitor located in the county. This is a mostly rural county with no larg e commuting impact on the urbanized core. Therefore, North Carolina is recommending no portion of the county be designated

as nonattainment.

Air Quality Data As shown in Figure 21 above, this area has 8 monitors with design values ranging from 0.072 ppm to 0.080 ppm. The monitor located nearest Harnett Count y is in neighboring Wake County in Fuquay with a design value of 0.077 ppm. Though the winds are climatologically out of the southwest, the limite d emissions from this county are such that they do not significantly impact th e air quality within the CSA.

Emissions Data: Based on 2005 emissions inventories, Harnett Co unty has 1.08 tons per year of point-source NOx and the county has 34.43 tons per year of point-source VOC. There are no major point sources of either NOx or VOC throughout the county.

Population Density and Degree of Urbanization: 91,085 people live in Harnett County as of 2000. Th e county is almost entirely rural, with no tracts with population density greater than 250 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Harnett County has 2,541,190 Daily VMT, according to 2007 data. Harnett County contributes 2.45 percent of the commuters who dr ive in to Wake County to work each day. These VMT are expected to in crease moderately to 2,946,700 by 2020.

Growth Rates and Patterns: The population is expected to increase by 23.5% by 2010 and by 20.1% between 2010 and 2020. These high percentages are exaggerate d because of the small base population.

Meteorology: Winds across Harnett County are climatologically from the southwest. Even with this climatological wind pattern, emissions from Ha rnett County are such that they have no significant impact on air quality de gradation within the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.Jurisdictional Boundaries: Harnett County is not included in any existing nonattainment area nor has it previously been designated nonattainment. The recommendation is that no portion within the county boundary be designated nonattainment.

Level of control of emissions sources: Harnett County has no major point sources for NOx and VOC emissions. Additional NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Harnett County currently has an OBD-based I/M program and low-sulfur gasoline is required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Johnston County This is an MSA county within the Raleigh- Durham-Cary CSA with an attaining monitor located in the more populated, far western portion of the county. Mo st of the eastern portion of Johnston County is rural, with th e western portion commuting into Wake County. Therefore, North Carolina is recommending that a smaller portion than the entire county be designated as

nonattainment.

The recommendation is that the area within the Capital Area Metropolita n Planning Organization boundary be designated as nonattainment.

Air Quality Data As shown in Figure 21 above, this area has 8 monitors with design values ranging from 0.072 ppm to 0.080 ppm. The monitor located within the county currently has a design value of 0.075 ppm, which is attainment both for the previous and current 8-hour ozone

standard.

Emissions Data: Based on 2005 emissions inventories, Johnston County has 43.35 tons per year of pointsource NOx and the county has 253.87 tons pe r year of point-sour ce VOC. There are no major point sources of NOx or VOC.

Population Density and Degree of Urbanization: 121,965 people live in Johnston County as 2000, 60,605 of which live in the portion recommended for nonattainment. The eastern por tion of the county is mostly rural with 7 tracts of 250 or fewer people per square m ile and 1 small tract of 1000-2500 people. The

area recommended for nonattainment is more ur banized with 4 tracts of population density between 100-500 people per square mile. (Pl ease see Appendix I for maps of population density)Traffic and Commuting Patterns: Johnston County has 5,225,390 Daily VMT, according to 2007 data. Johnston County contributes 6.56 percent of the commuters who dr ive in to Wake County to work each day, most of which live in the western portion of the county. These VMT are expected to increase to 6,131,270 by 2020.

Growth Rates and Patterns: The population in Johnston County is expected to grow between 2000 and 2010, with a total

increase of 40.1%. An increase of 31.1% is expected between 2010 and 2020.

Meteorology: Winds across Johnston County are climatological ly from the southwest. With this climatological wind pattern, the limited emissi ons from the county have no significant impact on the degradation of the air quality within the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The Capital Area Metropolitan Planning Orga nization includes the Wilders, O’Neal, Clayton, Cleveland, Pleasant Grove and Elevatio n Townships. These areas were part of a previous ozone nonattainment area that was redesignated as attainment December 26, 2007.

Level of control of emissions sources: Johnston County currently has no major point source of NOx or VOCs. Additional NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Johnston County currently has an OBD-based I/M program and low-sulfur gasoline is required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Chatham County This is an MSA county within the Raleigh- Durham-Cary CSA with one attaining monitor located in the northwest portion of the county. This is a mostly ru ral county with a low impact on commuting traffic into the urbanized core of the CSA. Therefore, North Carolina is recommending a smaller portion than the entire coun ty be designated as nonattainment.

The recommendation is that the Baldwin, Cent er, New Hope and Williams Townships be designated as nonattainment.Air Quality Data: As shown in Figure 21 above, this area has 8 monitors with design values ranging from 0.072 ppm to 0.080 ppm. The monitor located within Chatham County currently has the lowest design value of 0.072 ppm, which is in attainment for both the previous and current

8-hour ozone standards.

Emissions Data:Based on 2005 emissions inventories, Chatham County has 2494.81 tons per year of pointsource NOx and the county has 239.23 tons pe r year of point-sour ce VOC. There are 2 major point sources of NOx emissions and 2 major point sources for VOC emissions. One of the point sources is Progre ss Energy’s Cape Fear plant, which is subject to the NOx SIP

Call.

Population Density and Degree of Urbanization: 49,329 people live in Chatham County, with 21,320 people living in the area recommended for nonattainment. The county is largely rural, with the area recommended for nonattainment having 3 tracts, all with 250 peopl e or fewer per square mile. The western portion of the county has 1 small tract with 500-1000 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Chatham County has 1,906,160 Daily VMT, accord ing to 2007 data. Chatham County contributes less than 1 percent of the commuters who drive in to Wake County to work each day. These VMT are expected to increase to 2,502,830 by 2020.

Growth Rates and Patterns: The population in Chatham County is expected to increase between 2000 and 2010, with a

total decrease of 27.3%. A fu rther increase is expected from 2010 to 2020, growing by

22.3%.

Meteorology: Winds across Chatham County are climatologica lly from the southwest. With this climatological wind pattern, only the emissions in the eastern portion of the county would have significant impact on the air quality within the CSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The Baldwin, Center, New Hope and Williams townships define the area recommended as the nonattainment boundary. These areas were part of a previous ozone nonattainment area that was redesignated as attainment December 26, 2007.

Level of control of emissions sources: There are 2 major point sources of NOx and 2 major point sources for VOC emissions. The largest NOx point source is Pr ogress Energy’s Cape F ear plant, which as mentioned before, is subject to the NOx SIP Call and Clean Sm okestacks Act. Other major non-EGU source controls are handled on a case-by-case basis. Additional NOx emissions are from mobilesources, and the combined Federal and state control programs will address these emissions. Chatham County currently has an OBD-based I/ M program. Low-sulfur gasoline is required

statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

Orange County This is an MSA county within the Raleig h-Durham-Cary CSA; however, a portion of the county is under the jurisdiction of the Burlingt on-Graham Metropolitan Pl anning Organization. In order to avoid duplication of tran sportation conformity exercises, this portion of Orange County is recommended to be considered part of the Triad nonattainment area that ha s a higher design value. The remainder of the county is recommended to be considered part of the Raleigh-Durham-Cary nonattainment area because a portion of the rema inder of the county is covered by the DurhamChapel Hill-Carrboro Metropolitan Planning Orga nization. Because the county is included in the Raleigh-Durham-Cary CSA, the nine factors are a ddressed here for the whole county rather than duplicated in the Greensboro-Winston Salem-High Point discussion.

The recommendation is that the Burlington-Graham Metropolitan Planning Organization portion of Orange County be designated as nonattainment for the Greensboro-Winston-Salem-High Point Nonattainment Area for the purposes of transportation conformity.

Air Quality Data: As shown in Figure 21 above, this area has 8 monitors with design values ranging from 0.073 ppm to 0.082 ppm. The monitor nearest to this region is in southwestern Person County and has a design value of 0.077 ppm.

Emissions Data: Based on 2002 point-source emissions inventorie s, Orange County has 561.28 tons per year of NOx and the county has 152.08 tons per year of VOC. The largest point source of NOx emissions in the county is not within the Burlington-Graham MPO, but exists in the southeastern portion of the county at the Univ ersity of North Carolina at Chapel Hill.

Population Density and Degree of Urbanization: 118,227 people live in Orange County. Much of the County has low population density, with 8 tracts of 250 people or less per square mile, 2 tracts containing 250-500 people per square mile, 2 small tracts of 500-1000 people pe r square mile, 6 smaller tracts containing 1000-2500 people per square mile, and 4 minor tracts containing more than 5000 people per square mile. Most of the dens ely populated tracts are located in the southeastern portion of Orange County. (Please see Appendi x I for maps of population density)Traffic and Commuting Patterns: Orange County has 3,921,360 Daily VMT. Or ange County contributes 1.17% of the commuters that drive to Wake County daily and 9.92% of the commuters that drive to Durham County daily. These VMT are expe cted to increase to 4,653,190 by 2020. Orange County contributes 0.2% of the commuters that drive to Guilford County in the GreensboroWinston Salem-High Point CSA daily and 0.05% to Forsyth County in the same CSA.

Growth Rates and Patterns: The population in Orange County is expected to grow moderately between 2000 and 2010,

with a total in crease of 13.7%.

Meteorology: Winds across Orange County are climatological ly from the southwest. Most of the emissions within the county will have an impact on the northern portion of the RaleighDurham-Cary nonattainment.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: Orange County was part of a previous ozone nonattainment area that was redesignated as attainment December 26, 2007.

Level of control of emissions sources: The major NOx point source in Or ange County is the University of North Carolina, which is not within Burlington-Graham MPO. The remaining NOx emissions are from mobile

sources and the combined Federal and state c ontrol programs will address these emissions. Orange County currently has an OBD based I/M program and low-sulfur gasoline is required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

### Fayetteville Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary:

Cumberland and Hoke Counties

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:
Cumberland County

Figure 22: Fayetteville NC Regional 200 6-2008 8-Hour Ozone Design Values Map

Table 10: Fayetteville Region al Ozone Design Value Table

2005 2006 2007 2008 05-07 06-08

Wade 37-051-0008 0.084 0.072 0.080 0.075 0.078 0.075

Golfview 37-051-1003 0.091 0.074 0.082 0.075 0.082 0.077 Region Monitoring Sites AIRS ID Annual 4th Highest 8-Hour Average Design Value

Fayetteville

The monitors in the Fayetteville MSA currently m easure the fourth highest ozone values in the

State. North Carolina recommends that the whole county of Cumberland be designated as nonattainment. Cumberland County was one of four Early Action Compact areas under the 1997 8- hour ozone standard and was designated attain ment April 15, 2008. The county not recommended is discussed below, along with the 9 criteria EPA identified in their nonatta inment boundary guidance

that should be addressed.

Hoke County This is a Fayetteville MSA county, but it does not have a monitor located in the county.This is a minor commuting county into the urbanized core and is also mos tly rural. Therefore, North Carolina is recommending no portion of th e county be designated as nonattainment.

Air Quality Data: As shown in Figure 22 above, this area has 2 monitors with design values of 0.075 ppm to 0.077 ppm. The monitor located nearest H oke County is in Cumberland County in Golfview with a design value of 0.077 ppm. Though the winds are climatologically out of the southwest, the limited emissions from this co unty are such that they do not significantly impact the air quality within the Fayetteville MSA.

Emissions Data: Based on 2005 emissions inventories, Hoke Coun ty has 63.38 tons per year of point-source NOx and the county has 10.18 tons per year of point-source VOC. There are no major point sources of either NOx or VOC throughout the county.

Population Density and Degree of Urbanization: 33,646 people live in Hoke County as of 2000. Th e county is almost entirely rural, with 4 tracts with population density of 100 people or fewer per square mile. One small tract with population density of 500-1000 is in the center of the county. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Hoke County has 807,740 Daily VMT, according to 2007 data, with no major commuting contribution to the Fayetteville MSA. These VMT are expected to increase moderately to 1,140,050 by 2020.

Growth Rates and Patterns: The population is expected to increase by 40.0% by 2010 and by 31.3% between 2010 and 2020. This growth rate is exaggerated by the small base population.

Meteorology: Winds across Hoke County are climatologically from the southwest. Even with this climatological wind pattern, emissions from Hoke County are such that they have no significant impact on air quality degrada tion within the Fayetteville MSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The Fort Bragg Military Reservation extends from northwestern Cumberland Ccounty through the northern half of Hoke County. Th ere is also the Faye tteville Metropolitan Planning Organization covering Cumberland C ounty and a portion of southern Harnett County and eastern Hoke County. The prev ious 8-hour ozone nonattainment area North

Carolina’s recommended nonattainment area.

Level of control of emissions sources: Hoke County has no major point sources for NOx and VOC emissions. Additional NOx emissions are from mobile sources, and the combined Federal and state control programswill address these emissions. Hoke County currently does not have an OBD-based I/M program, but a visual check of emissions equipm ent is required. Low-sulfur gasoline is also required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.

### Greenville Nonattainme nt Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary:

Pitt and Greene Counties

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:
Unclassifiable, defer designation.

Figure 23: Greenville NC Regional 2006-2008 8-Hour Ozone Design Values Map

Figure 24: Three-year design values of monitors surrounding the Greenville area.Figure 25: Spatially allocated modeled design values for 2009.

Table 11: Greenville Regional Ozone Design Value Table

2005 2006 2007 2008 05-07 06-08

Farmville 37-147- 0099 0.080 0.072 0.079 0.077

Pitt County Ag Center 37-147-0006 0.077

Lenoir College (Nearby) 37-107-0004 0.081 0.071 0.077 0.074 0.076 0.074

Jamesville (Nearby) 37-117-0001 0.079 0.070 0.075 0.074 0.074 0.073 Region Monitoring Sites AIRS ID Annual 4th Highest 8-Hour Average Design Value

Greenville

This area has a single ozone monitor, which was relocated prior to the start of the 2008 ozone season. Its fourth highest va lue in 2008 was 0.077 ppm; howev er, it is recommended that

classification of the area be deferred until after the ozone seas on of 2010 when three consecutive years of data will be available at this monitor. This area has never been designated nonattainment, there are no major NOx sources in the area, an OBD-based I/M program was implemented in Pitt County by 2006, and the nearest upwind and downwind m onitors are both in attainment of the new ozone standard (see Lenoir County and Martin County, respectively, in Figure 23) and both are trending downward (cleaner). Additionally, future -year 8-hour ozone State Implementation Plan air quality modeling has shown that th e area under consideration is expect ed to be within attainment by 2009. If a request for deferral is denied, North Carolina recommends Pitt County be designated as nonattainment and no portion of Greene County is designated as nonattainment. The counties associated with the request for deferral and th ose not recommended are disc ussed below, along with

the 9 criteria EPA identified in their nonattainment boundary guid ance that should be addressed.Pitt County This is a Greenville MSA county with one monitor. This is a mostly rural county with an urbanized core. The monitor within the county has rece ntly moved approximately 14.5 miles, which is beyond the distance that would allo w the data from the two monitori ng sites to be considered a

continuous record.

Air Quality Data As shown in Figure 23 above, this area has 1 m onitor with no calculable design value. The monitor was previously located in Farmville, but has moved to the Pitt County Ag Center, in the western part of the county. As shown in Figure 24, monitoring trends at the surrounding

ozone monitors indicate a downwar d progression in the design values, within attainment. Additionally, air quality modeling data shown in Figure 25 in dicates the Greenville area will be within attainment by 2009. This future-year modeling has proven to be highly accurate at recreating design values for a given area. Us ing this information, North Carolina expects

the Greenville area monitor to show attainme nt upon obtaining sufficient data for a design

value to be calculated.

Emissions Data: Based on 2005 emissions inventories, Pitt Count y has 139.59 tons per year of point source NOx from and the county has 623.40 tons per year of point source VOC from 9 sources. There is one major point source of VOC located in the southeastern part of the county.

Population Density and Degree of Urbanization: 134,107 people live in Pitt County as of 2000. The county is largely rural, with the exception of the urbanized core in Greenville. There are 9 tracts of 250 or fewer people per square mile, 4 tracts of 250 to 500 people per square mile, 1 tract of 500 to 1000 people per square mile, 3 tracts of 1000-2500 people per sq uare, 4 small tracts of 2500-5000 people per square mile and 1 smaller tract of more than 5000 people per square mile. This dense urban core can mostly be attributed to East Carolin a University, located in downtown Greenville. (Please see Appendix I for ma ps of population density)

Traffic and Commuting Patterns: Pitt County has 3,377,830 Daily VMT, according to 2007 data, with most commuting occurring within the county. These VMT ar e expected to increase moderately to 4,065,700 by 2020.

Growth Rates and Patterns: The population is expected to increas e by 19.9% between 2000 and 2010 and by 16.3%

between 2010 and 2020.

Meteorology: Winds across Pitt County are climatologically from the southwest. On days where the monitor experiences the highest leve ls of ozone, this is mostly at tributable to recirculation of emissions within the county. Additional emi ssions from an EGU downwind also aids in high ozone concentrations.Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The Greenville Metropolitan Planning Organizati on is located within the central portion of Pitt County. This MPO is also within the la rger Mideast Rural Planning Organization. Pitt County was not previously de signated as nonattainment.

Level of control of emissions sources: Pitt County has no major point sources for NOx, but does have one major point source for VOC. Large point sources that are non-EGUs are controlled on a case-by-case basis.

Additional NOx emissions are from mobile s ources, and the combined Federal and state control programs will address these emissions. Pitt County currently has an OBD-based I/M program. Low-sulfur gasoline is also required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was enacted in 1999 by the General Assembly.

Greene County This is a Greenville MSA county, but there is no monitor located within this county. This county is entirely rural, with no large commuting impact on the urbanized core. The monitor nearest the county has recently m oved beyond the distance that would allow the data from the two monitoring sites to be considered a continuous record. The second nearest monitor is located in Lenoir County at Lenoir Commun ity College in Kinston, with a design value of 0.074 ppm. Based on the rural characteristics, lack of emissions a nd surrounding monitors indi cating attainment, North Carolina recommends no portion of Green e County be designated nonattainment.

Air Quality Data: As shown in Figure 23 above, this area has 1 mo nitor with no calculable design value. The monitor was previously located in Farmville, but has moved to the Pitt County Ag Center, in the western part of Pitt C ounty. Monitoring trends at the surrounding ozone monitors indicate a downward progression in the desi gn values, within atta inment. Upon obtaining sufficient data for a design value to be calcu lated for the monitor located in Greene County, North Carolina expects this monitor to also show attainment.

Emissions Data: Based on 2005 emissions inventories, Greene C ounty has 1.4 tons per year of point-source NOx and the county has 0.07 tons per year of point-source VOC. There are no major point sources in this county.

Population Density and Degree of Urbanization: 18,976 people live in Greene County as of 2000. Th e county is entirely rural. There are notracts with population densiti es greater than 250 people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Greene County has 585,250 Daily VMT, according to 2007 data, comprising 2.98% of the commuting traffic into Pitt County for wor k. These VMT are expected to increase moderately to 731,000 by 2020.

Growth Rates and Patterns: The population is expected to increas e by 13.5% between 2000 and 2010 and by 8.8%

between 2010 and 2020.

Meteorology: Winds across Greene County are climatologically from the southwest. Given the lack of emissions within the county, North Carolina asserts that this county has no appreciable impact on the air quality within the Greenville MSA.

Geography/Topography: There are no special geography or topogra phy issues to consider in this region.

Jurisdictional Boundaries: The Eastern Carolina Rural Planning Organiza tion includes the counties of Greene, Wayne, Lenoir and Duplin. Greene County has never been designa ted nonattainment.

Level of control of emissions sources: Greene County has no major point sources fo r either NOx or VOCs. Additional NOx emissions are from mobile sources, and the combined Federal and state control programs will address these emissions. Greene County cu rrently has no OBD-based I/M program, but a visual inspection of emissions equipment is required. Low-sulfur gasoline is also required

statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was enacted in 1999 by the General Assembly.

### Virginia Beach-Norfolk-Newport News Nonattainment Area Discussion

EPA Presumptive 8-Hour Ozone Nonattainment Boundary:
Currituck County

North Carolina’s Recommended 8-Hour Ozone Nonattainment Boundary:
No portion of Currituck County designated as nonattainment

Figure 26: Currituck NC Regional 2006-2008 8-Hour Ozone Design Values Map

Table 12: Fayetteville Region al Ozone Design Value Table

2005 2006 2007 2008 05-07 06-08

Jamesville (Nearby) 37-117-0001 0.079 0.070 0.075 0.074 0.074 0.073

Sulfolk (Virginia) 51-800-0005 0.078 0.071 0.078 0.078 0.075 0.075

Sulfolk (Virginia) 51-800-0004 0.077 0.077 0.076 0.077 0.076 0.076

Hampton (Virginia) 51-650-0004 0.078 0.076 0.076 0.079 0.076 0.077 Annual 4th Highest 8-Hour Average Region Monitoring Sites AIRS ID

Currituck County,

Tidewater VA Design Value

EPA is recommending Currituck County be incl uded in the 8-hour ozon e nonattainment boundary within the Virginia Beach-Norfolk-Newport News nonattainment area. North Carolina recommends not designating any portion of Curri tuck County as nonattainment. The county not recommendation is discussed below, along with the 9 criteria EPA identified in their nonattainment boundary guidance that should be addressed.Currituck County This is an MSA county, but it does not have a monitor located in the county. This is a mostly rural county with no impacts on commuting in to the urbanized core of the Virginia BeachNorfolk-Newport News MSA. Therefore, No rth Carolina is recommending no portion of the county be designated as nonattainment.

Air Quality Data: As shown in Figure 26 above, this area has 3 monitors with design values ranging from 0.075 ppm to 0.077 ppm. The monitor located nearest Currituck County is in Suffolk County in Holland with a design value of 0.075 pp m. On days where this area experiences its highest ozone concentrations, winds ar e predominantly out of the north, whereas Currituck County is located downwind of the Virginia Beach-Norfolk-Newport News MSA

Emissions Data: Based on 2005 emissions inventories, CurrituckCounty has 10.59 tons per year of pointsource NOx and the county has 0.22 tons per ye ar of point-source VOC. There are no major point sources of either NOx or VOC throughout the county.

Population Density and Degree of Urbanization: 18,297 people live in Currituck County as of 2000. The county is entire ly rural, with all tracts having 100 or fewer people per square mile. (Please see Appendix I for maps of population density)

Traffic and Commuting Patterns: Currituck County has 971,830 Daily VMT, according to 2007 data, with no major commuting contribution to the Virginia Beach-Newport News-Norfolk MSA. These VMT are expected to increas e moderately to 1,571,790 by 2020.

Growth Rates and Patterns: The population is expected to increase by 41.7% by 2010 and by 30.4% between 2010 and 2020. This high rate is exaggera ted by the small base population.

Meteorology: Winds across Currituck County are climatologica lly variable from th e west-southwest and east-northeast. However, on days where ozone values in the county are highest, the winds are generally northerly, indica ting Currituck County is downwind of the Virginia BeachNewport News-Norfolk MSA. Therefore, Currituck County has no impact on the

nonattainment of the aforementioned MSA.

Geography/Topography: Currituck County is located in close proximity to the Atlantic Ocean. As such, the county is subject to the diurnal shifts in wind directi on. Also, because of the variability of wind direction, the atmosphere is typi cally kept clean and well-mixed.

Jurisdictional Boundaries: The Albemarle Rural Planning Organization enco mpasses the northeast po rtion of the North Carolina coastline. The Hampton Roads (VA) Metropolitan Planning Organization includesthe aforementioned nonattainment area. Currituck County has not been designated nonattainment previously.

Level of control of emissions sources: Currituck County has no major point sources for NOx and VOC emissions. Additional NOx emissions are from mobile sources, and the combined Federal and state control programs

will address these emissions. Currituck Count y currently does not have an OBD-based I/M program, but a visual check of emissions equipm ent is required. Low-sulfur gasoline is also required statewide.

DENR’s ability to control so urces throughout the state: The North Carolina General Statute allows sources anywhere in the state to be controlled under an attainment strategy, regardless of designati on. North Carolina believes this is an important consideration for setting nona ttainment boundaries. The new inspection and maintenance program that requires on-board diagnostic testing in 48 counties (phased in between 2002 and 2006) is an ex ample of North Carolina’s ability to control sources in counties regardless of the nonattain ment designations. The new I/M program was adopted in 1999.