PEGGY M. HATCH 

SECRETARY 

.$Mate of Ljr-ouis'iana 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

OFFICE OF THE SECRETARY 

Dr. Al Armendariz, Administrator 

US EPA Region 6 (6RA) 

1445 Ross Ave, Suite 1200 

Dallas, TX 75202-2733 

RE: State of Louisiana 

Recommendations for Designation 

2010 NO2 National Ambient Air Quality Standards (NAAQS) 

Dear Dr. Annendariz: 

In accordance with Section 1107(d) of the Clean Air Act Amendments of 1990, the state of Louisiana is pleased 

to provide its recommendations for area designations for the 2010 NO2 NAAQS. 

The unavailability of any timely implementation guidance from EPA complicated the recommendation 

development process and suggests a certain negligence and lack of foresight. The federal rule was finalized on 

April 12,2010 and no implementation guidance has been issued by EPA. Additionally, your November 24,2010 

letter to Governor Jindal indicates EPA's preference to drive the entire state of Louisiana into the designation of 

"unclassifiable". This approach neglects the exemplary efforts put forth by monitored areas of our state to 

maintain NO2 values that are one half to one third of the value of the new standard. As such, we have developed a 

prudent and logical approach to the recommendations under this standard. To do anything to the contrary would 

be a disservice to the residents of our state. 

Using information taken from the new NO2 rules that were published on January 22,20 10, we have developed the 

following recommendations for area designations: 

For Parishes that have monitored NO2 values that are below both the 53ppb annual average and 1OOppb Ihour standard, and where no near-road monitoring is required, we recommend a designation of 

"attainment". 

For Parishes that are not monitored, we recommend a designation of "unclassifiable". 

For Parishes that have monitored NO2 values that are below both the 53 ppb annual average and 100 ppb 

I-hour standard, and where near-road monitoring is required, we recommend a designation of 

"attainment'' for the Parish except for that area where near-road monitoring will be required which is 

recommended as "unclassifiable". 
Dr. Armendariz 

N4 Designation Letter 

January 24,20 1 1 

Page 2 

Delineation of the near-road "unclassifiable" areas is made according to the EPA monitoring rule's sighting 

requirements. The EPA monitoring rule requires that two (2) new NO2 monitors be added to our existing network 

of nine (9) monitoring sites; one near-road monitor added in the Baton Rouge CBSA and one in the New Orleans 

CBSA. DEQ has collaborated with the Department of Transportation and Development (DOTD) to evaluate the 

highway segments with the highest vehicular traffic counts. Linear boundaries along stretches of highway where 

traffic counts are the highest were drawn. The highest traffic count location was used as a starting point and then 

the boundary moved in each direction along the highway until reaching the fM traffic monitored location with a 

count of less than 50% of the highest location. Boundary widths were based upon the rule's premise that 

concentrations fall off very quickly at more than 50 meters from the edge of the traffic lane. 

Based on a review of the quality-assured NO2 monitoring data for the period 2008-2010, Louisiana recommends 

the following designahons: 

Designation of "attainment" for 5 monitored parishes in the state - Iberville, Ascension, Livingston, 

Calcasieu and West Baton Rouge. 

Designation of "attainment" for 2 monitored parishes in the state with "unclassifiable" areas denoted 

within their boundaries 

o East Baton Rouge with the "unclassifiable" area extending along 1-10 from mile marker 155 to 

marker 164, along 1-12 from mile marker 0 to marker 5 and to a distance no greater than 50 

meters from the outer edge of the East and West travel lanes, and 

o Jefferson with the "unclassifiable" area extending along 1-10 from mile marker 224 to the Orleans 

Parish line and to a distance no greater than 50 meters from the outer edge of the East and West 

travel lanes. 

A designation of "unclasstfiable" for the remaining parishes as there is no monitored data for them. 

Attached please fmd a complete list of the 64 Louisiana Parishes by Air Quality Control Region and the 

recommended designations. 

If you have any questions, please contact Tegan Treadaway, Administrator of the Air Permits Division, Office of 

Environmental Services at 225-219-3408 

c : Thomas Diggs, EPA 

Guy Donaldson, EPA 

Attachment 
Designated Area 

Caldwell Parish 

Catahoula Parish 

Concordia Parish 

East Carroll Parish 

Franklin Parish 

Grant Parish 

La Salle Parish 

Madison Parish 

Ouachita Parish 

Richland Parish 

Tensas Parish 

Union Parish 

West Carroll Parish 

State of Louisiana 

2010 NO2 Designation Recommendations 

Designated Area 

Avoyelles Parish 

Bienville Parish 

Bossier Parish 

Caddo Parish 

Claiborne Parish 

DeSoto Parish 

Jackson Parish 

Lincoln Parish 

Natchitoches Parish 

Rapides Parish 

Red River Parish 

Sabine Parish 

Vernon Parish 

Webster Parish 

Winn Parish 

AQCR 019: Monroe-El Dorado Interstate 

Recommended Designation 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

AQCR 022: Shreveport-Texarkana-Tyler Interstate 

Recommended Designation 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 

Unclassifiable 
State of Louisiana 

2010 NO2 Designation Recommendations 

AQCR 106: S. Louisiana-SE Texas Interstate 

Designated Area Recommended Designation 

Acadia Parish Unclassifiable 

Allen Parish Unclassifiable 

Ascension Parish Attainment 

Assumption Parish Unclassifiable 

Beauregard Parish Unclassifiable 

Calcasieu Parish Attainment 

Cameron Parish Unclassifiable 

East Baton Rouge Parish Attainment (exeefor mar road) 

o 1-10 from Mile 155 to 164,50 meters from edge Unclassifiable ~d.t~...~~.. tor .ear road) 

o 1-12 from Mile 0 to 5,SO meters from edge Unclassifiable ldel#nea!#on tor 

East Feliciana Parish Unclassifiable 

Evangeline Parish Unclassifiable 

Iberia Parish Unclassifiable 

lbewille Parish Attainment 

Jefferson Davis Parish Unclassifiable 

Jefferson Parish Attainment lelcept for near 

1-10 from Mile 224 to Orleans Parish Line, 50 meters from edge Unclassifiable ldellnea~on tor ...w road) 

Lafayette Parish Unclassifiable 

Lafourche Parish Unclassifiable 

Livingston Parish Attainment 

Orleans Parish Unclassifiable 

1-10 from Jefferson Parish Line to Mile 237, 50 meters from edge Unclassifiable (delrneat80nforncarroadl 

Plaquemines Parish Unclassifiable 

Pointe Coupee Parish Unclassifiable 

St. Bernard Parish Unclassifiable 

St. Charles Parish Unclassifiable 

St. Helena Parish Unclassifiable 

St. James Parish Unclassifiable 

St. John the Baptist Parish Unclassifiable 

St. Landry Parish Unclassifiable 

St. Martin Parish Unclassifiable 

St. Mary Parish Unclassifiable 

St. Tammany Parish Unclassifiable 

Tangipahoa Parish Unclassifiable 

Terrebonne Parish Unclassifiable 

Vermilion Parish Unclassifiable 

Washington Parish Unclassifiable 

West Baton Rouge Parish Attainment 

West Feliciana Parish Unclassifiable