North Carolina Department of Environment and Natural Resources 

Division of Air Quality 

Beverly 

Governor 

Perdue B. Keith Overcash, P.E. 

A. Stanley Meiburg 

Acting Regional Administrator 

USEP A Region 4 

Atlanta Federal Center 

61 Forsyth Street, SW 

Atlanta, GA 30303-8960 

Dear Mr. Meiburg: 

Director 

November 12, 2009 

Dee Freeman 

Secretary 

Attached is are-submittal of the June 15, 2007, attainment demonstration State 

Implementation Plan (SIP) for the North Carolina portion of the Charlotte-Gastonia-Rock Hill, 

North Carolina-South Carolina 1997 8-hour ozone nonattainment area (referred to as the 

Metrolina area). This SIP was withdrawn on December 19, 2008, by the North Carolina 

Division of Air Quality (NCDAQ). All of the ambient monitors in the Metrolina area have 

recorded clean data for the 1997 8-hour ozone standard during the 2009 ozone season and it is 

the intention of this agency to request a one-year extension of the attainment date. 

This submittal went through the p1Jblic hearing process in April 2007, and is unchanged from 

the original submittal. Enclosed is otle hard copy of the complete package containing the 

attainment demonstration and the supporting documentation, as well as an exact duplicate 

electronic copy on compact disk. 

On November 17, 2008, the United States Environmental Protection Agency (USEPA) gave 

the North Carolina Department of Environment and Natural Resources (NCDENR) the option of 

either voluntarily requesting a reclassification to Serious or the USEP A would disapprove the 

SIP. The USEPA did not believe that the Metrolina area would attain the 1997 8-hour ozone 

standard considering the 2007 and 2008 ambient air quality data and that the area would not 

qualify for a one-year extension of the attainment date. On December 19, 2008, the NCDENR 

withdrew the Metrolina attainment demonstration SIP, citing concerns with the two options and 

the belief that it was possible for the region to qualify for the one-year extension of the 

attainment date. In the withdrawal letter, the NCDENR committed to revise the modeling and 

submit an updated SIP by the end of November 2009. 

In January 2009, the NCDAQ notified the transportation partners of its intention to re-model 

the attainment demonstration and requested revised data for 2011, which, at that time, was 

believed to be the projected attainment year given the 2007 and 2008 ambient data. Your office 

was copied on this correspondence to keep the USEP A informed of our intentions and progress 

164 i Mail Service Center, Raleigh, North Carolina 27699-1641 

2728 Capital Blvd., Raleigh, NC 27604 

Phone: 919-733-3340\ F:Ax: 919-715-7175\ Internet: www.daq.state.nc.us/ 

An Equal Opportunity\ Affirmative Action Employer 
Mr. Meiburg 

November 12, 2009 

Page 2 

on the re-modeling effort. Additionally, there were monthly conformity calls with the Metrolina 

transportation partners, monthly calls for the statewide interagency consultation meetings, and 

monthly calls between the Region 4 SIP staff and the NCDAQ Planning staff, all of which had 

updates on the modeling progress. 

On August 14, 2009, the NCDAQ shared an internal draft of the revised attainment 

demonstration with the USEP A and the transportation partners for a 30-day comment period. 

The NCDAQ learned at the end of the comment period that the USEPA had issues with the 

attainment year being 2011. After several weeks of discussions within the USEP A, the NCDAQ 

was given two options on November 4, 2009: 

• Option 1 - The State could re-submit the original attainment demonstration and then 

submit supplemental information. The supplemental information would include the 2009 

ambient air quality data showing the area qualifies for a one-year extension and the 2011 

modeling as weight of evidence that the Metrolina region would attain the standard by 

June 15, 2011. 

• Option 2 - The State could use the original 2009 modeling and the revised 2011 

modeling to develop a plan to demonstrate the area would attain the standard by 

June 15, 2011. 

The NCDAQ has chosen Option 1, to re-submit the original attainment demonstration SIP. 

The NCDAQ will coordinate with the USEPA, Region 4 staff as to what will be needed in the 

supplemental information and submit the necessary information as quickly as possible. 

When the NCDAQ withdrew the original attainment demonstration SIP, the USEPA issued a 

"Finding of Failure to Submit" on May 8, 2009. With this submittal, the NCDAQ believes it has 

fulfilled the requirements of Section 172(c), 182(a) and 182(b) of the Federal Clean Air Act as 

amended and thus satisfies the requirements of the Finding of Failure to Submit. 

North Carolina is committed to ensuring cleaner air for our citizens. This has been clearly 

demonstrated by proactive efforts at both the state and local levels. The North Carolina General 

Assembly has passed legislation that increase the number of counties required to have vehicle 

inspection and maintenance well beyond what was federally mandated and has passed legislation 

that capped the emissions from public utilities in our State. Locally there have been programs 

established to decrease the emissions from diesel engines as well as outreach efforts to educate 

the public about air quality issues. Air quality has a direct impact on public health and the 

environment. It is our opinion that the air quality in the area has improved over the last several 

years. The 2009 ozone monitoring data was in line with what was modeled in the attainment 

demonstration submitted in 2007. In its preliminary review of the 2009 meteorology, the 

NCDAQ has determined that the average temperature and precipitation were in line with the 30-

year average values. Although there were not many stagnation events which can lead to elevated 

ozone levels, on days when the weather patterns were conducive for ozone formation, 
Mr. Meiburg 

November 12, 2009 

Page 3 

exceedances of the 1997 ozone standard were not observed. The NCDAQ believes that the final 

installation of nitrogen oxide controls to meet the Clean Smokestacks Act, the implementation of 

the Clean Air Interstate Rule regionally, and emission reductions due to the federal tailpipe and 

fuel standards have lowered background ozone levels and ozone transport to the area. 

The NCDAQ appreciates the efforts of Region 4 to bring resolution to this issue. I 

respectfully request that you commence the federal approval process for the Charlotte-GastoniaRock Hill, North Carolina-South Carolina 1997 8-hour ozone nonattainment area attainment 

demonstration. If you should have any questions, please contact Laura Boothe of my staff at 

(919) 733-1488 or Laura.Boothe@ncdenr.gov. 

BKO:lab 

Enclosure 

cc: Carol Kemker, USEP A 

Dick Schutt, USEP A 

Sheila Holman, NCDAQ 

Laura Boothe, NCDAQ 

Myra C. Reese, SCDHEC