### North Carolina Department of Environment and Natural Resources Division of Air Quality Beverly Governor Perdue B. Keith Overcash, P.E.

A. StanleyMeiburg Acting Regional Administrator USEPA Region 4 AtlantaFederal Center 61 Forsyth Street, SW Atlanta, GA 30303-8960 DearMr. Meiburg: Director November 12, 2009 Dee Freeman Secretary

Attached is are-submittal ofthe June 15, 2007, attainment demonstration State Implementation Plan (SIP) for the North Carolinaportion ofthe Charlotte-Gastonia-RockHill, North Carolina-South Carolina 1997 8-hour ozone nonattainment area (referred to as the Metrolina area). This SIP was withdrawn on December 19, 2008, bythe North Carolina Division ofAir Quality (NCDAQ). All ofthe ambient monitors in the Metrolina area have recorded clean data for the 1997 8-hour ozone standard during the 2009 ozone season and itis the intention ofthis agency to request a one-year extension ofthe attainment date. This submittal went through the p1Jblic hearing process in April 2007, and is unchanged from the original submittal. Enclosedis otle hard copy ofthe completepackage containing the attainment demonstration and the supporting documentation, as well as an exact duplicate electronic copyon compactdisk. On November 17, 2008, the United StatesEnvironmental Protection Agency (USEPA) gave the North CarolinaDepartment ofEnvironment and Natural Resources (NCDENR) the option of either voluntarily requesting a reclassification to Serious or the USEPA would disapprove the SIP. TheUSEPA did notbelievethat 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 ofthe attainment date. On December 19, 2008, the NCDENR withdrew the Metrolina attainment demonstration SIP, citing concerns with the two options and the beliefthat it was possible for the region to qualify for the one-yearextension ofthe attainment date. In the withdrawal letter, the NCDENR committed to revise the modeling and submit an updated SIPbythe end ofNovember2009. In January 2009, the NCDAQnotified the transportation partners ofits intention to re-model the attainment demonstration and requested revised data for 2011, which, at that time, was believedto be the projected attainment year given the 2007 and 2008 ambient data. Your office was copied on this correspondenceto keep the USEPA informed ofour intentions and progress

164i 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 EmployerMr. 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 Region4 SIP staffand the NCDAQ Planning staff, all ofwhichhad updates on the modeling progress. On August 14, 2009, the NCDAQ shared an internal draft ofthe revised attainment demonstration with the USEPA and the transportation partners for a 30-day comment period. The NCDAQ learned at the end ofthe comment periodthat the USEPA had issues with the attainment yearbeing 2011. After several weeks ofdiscussions within the USEPA, the NCDAQ was given two options on November4, 2009:

• Option 1

- The State couldre-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-yearextension and the 2011 modeling as weight ofevidence that the Metrolinaregion 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 aplan to demonstrate the area would attain the standardby June 15, 2011. The NCDAQ has chosen Option 1, to re-submit the original attainment demonstration SIP. The NCDAQ will coordinate withthe USEPA, Region 4 staffas 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 ofFailure to Submit" on May 8, 2009. With this submittal, the NCDAQbelieves ithas fulfilled the requirements ofSection 172(c), 182(a) and 182(b) ofthe Federal Clean Air Act as amended and thus satisfies the requirements ofthe Finding ofFailure to Submit. North Carolinais committedto ensuring cleaner air for ourcitizens. This has been clearly demonstratedbyproactive efforts at both the state and local levels. The North Carolina General Assembly has passed legislation that increase the number ofcounties 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 havebeen 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. Itis 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 ofthe 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 weatherpatterns were conducive for ozone formation,Mr. Meiburg November 12, 2009 Page 3

exceedances ofthe 1997 ozone standard were not observed. TheNCDAQ believes that the final installation ofnitrogen oxide controls to meet the Clean Smokestacks Act, the implementation of the Clean Air Interstate Rule regionally, and emission reductions dueto the federal tailpipe and fuel standards have loweredbackground ozone levels and ozonetransport to the area. The NCDAQ appreciates the efforts ofRegion 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-hourozonenonattainment area attainment demonstration. Ifyou should have any questions, please contactLauraBoothe ofmy staffat (919) 733-1488 or Laura.Boothe@ncdenr.gov.

BKO:lab Enclosure

cc: Carol Kemker, USEPA Dick Schutt, USEPA Sheila Holman, NCDAQ Laura Boothe, NCDAQ Myra C. Reese, SCDHEC