Responses to Comments Received on the Proposed SIP Revision for the 15-

county Atlanta Nonattainment Area Emissions Inventory for the 2008 8-Hour 

Ozone NAAQS

On November 7, 2014, Georgia EPD issued a public notice requesting comments on

Georgia’s proposed SIP revision for the 15-county Atlanta nonattainment area 

emissions inventory for the 2008 8-Hour ozone NAAQS. No comments were received 

during the public hearing on December 9, 2014. Written comments were received from 

USEPA Region 4 and GreenLaw, on behalf of the Sierra Club. USEPA Region 4’s 

comments, GreenLaw’s comments, and EPD’s responses are presented below.

Written Comments, USEPA Region 4 

Comment: EPA asked EPD to “clarify the total emissions on page 11, tables 4, 5 and 6. 

It appears the Point EGU emissions were not included in the calculations”. 

EPD Response: Tables 4, 5, and 6 on page 11 were updated to include Point EGU 

emissions that were inadvertently left off. In addition, Column J in the Appendix F Excel 

spreadsheet (Appendix_F_Emission_Summary.xls) was updated to include Point EGU 

emissions that were inadvertently left off.

Written Comments, GreenLaw, on behalf of the Sierra Club 

Comment: GreenLaw states “Georgia EPD should include plants Hammond and 

Wansley in the Emissions Inventory because they emit large amounts of ozone-causing 

pollutants, and lack modern controls to reduce this pollution.” In addition, GreenLaw 

states “EPA has stated that a nonattainment area inventory should include both sources 

within the nonattainment area, as well as sources located outside of nonattainment area 

that may affect nonattainment areas. See, e.g., EPA, Guidance for 1-Hour SO2 

Nonattainment Area SIP Submissions (Apr. 2014) (“[T]he air agency should also 

address sources located outside the nonattainment area which may affect attainment in 

the area.”). For ozone nonattainment areas, EPA has further stated that any major 

emissions source within 25 miles of the nonattainment area must be included within the 

inventory. EPA, Emissions Inventory Requirements for Ozone State Implementation 

Plans (Mar. 1991), at section 3.2.3; see also Emissions Inventory Guidance for 

Implementation of Ozone and Particulate Matter NAAQS and Regional Haze 

Regulations (Aug. 2005), at page 25. Georgia EPD must follow EPA’s guidance in order 

to create an accurate and comprehensive Emissions Inventory.”

EPD Response: EPD does not agree that plants Hammond and Wansley need to be 

included in the Emissions Inventory. The first reference (EPA, Guidance for 1-Hour

SO2 Nonattainment Area SIP Submissions, Apr. 2014) applies to SO2 nonattainment 

areas and does not apply to ozone nonattainment areas. The next two references 

(EPA, Emissions Inventory Requirements for Ozone State Implementation Plans, Mar. 
Responses to Comments – Proposed SIP Revision for the 15-county Atlanta 

Nonattainment Area Emissions Inventory for the 2008 8-Hour Ozone NAAQS

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1991, section 3.2.3; EPA, Emissions Inventory Guidance for Implementation of Ozone 

and Particulate Matter NAAQS and Regional Haze Regulations, Aug. 2005, page 25) 

are outdated and have been replaced with more recent guidance (EPA, Emissions 

Inventory Guidance for Implementation of Ozone [and Particulate Matter] National 

Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations, Apr. 2014). 

This guidance document states in Section 4.4, Spatial Extent (page 53), “The spatial 

extent of an inventory refers to counties, states, or other geographic regions covered by 

the emissions data. As described in previous sections, inventories needing to be 

included in SIPs are either for the NAA area only (for ozone and PM2.5) or are for the 

entire state (for regional haze and ozone or PM2.5 when modeled attainment 

demonstrations are needed).” Since a modeled attainment demonstration is not 

required, an emission inventory is needed for the nonattainment area only.