North Carolina Department of Environment and Natural Resources

Beverly Eaves Perdue

Governor

Dee Freeman

Secretary

December 16,2010

Gwen Keyes Fleming

Regional Administrator

USEPA Region 4

Atlanta Federal Center

61 Forsyth Street, SW

Atlanta, GA 30303-8960

Re: North Carolina's Recommendations for Air Quality Designations

for the Nitrogen Dioxide Standard

Dear Ms. Fleming:

I am writing on behalf of Governor Beverly E. Perdue to recommend air quality designation status

and related boundaries of areas in North Carolina for the national ambient air quality standard

(NAAQS) for nitrogen dioxide (N02), pursuant to Section 107( d)(l )(A) ofthe Clean Air Act as

amended.

The United States Environmental Protection Agency (USEPA) is requiring monitoring in urban areas

with a population greater than or equal to one million people to assess community-wide

concentrations. In North Carolina, community scale monitoring will be required in Charlotte and

Raleigh. A community scale N02 monitor is currently operating in Charlotte (Mecklenburg County)

and has a design value of 49.3 parts per billion (Ppb). Additionally, a community scale N02 monitor

is operating in Winston-Salem (Forsyth County) with a design value of 54.3 ppb. Both of these

monitors are well below the new l-hour N02 standard of 100 ppb.

The USEP A is also requiring monitoring near a major road in urban areas with a population greater

than or equal to 500,000 people. The North Carolina Division of Air Quality (NCDAQ) currently

does not operate any roadside N02 monitors, but anticipates that roadside monitoring will be required

in four areas: Charlotte, Durham (Durham County), Greensboro (Guilford County) and Raleigh

(Wake County).

Based on the available monitoring data, North Carolina recommends that Forsyth and Mecklenburg

Counties be designated as attainment. Monitoring will not be established in Durham, Guilford and

Wake Counties until 2013. Since monitoring data will not be available from those monitors until

2016, North Carolina recommends that these counties, as well as all other counties in the state, be

designated as attainmentlunclassifiable.

1601 Mail Service Center, Raleigh, North Carolina 27699-1601

Phone: 919-733-4984 \ FAX: 919-715-3060 Internet: www.enr.state.nc.us N~rthCarolina

An Equal Opportunity \ Affirmative Action Employer - 50% Recycled \ 10% Post Consumer Paper lValufallll
Gwen Keyes Fleming

December 16, 2010

Page 2

Like many states, North Carolina faces a challenging budget situation due to the economic

downturn. At the same time, the North Carolina Division of Air Quality anticipates additional

program costs associated with establishing the new N02 monitoring network, meeting monitoring

requirements for the new lead NAAQS, complying with ozone monitoring requirements and

replacing an aging fleet of ozone monitors. NCDAQ has already been required to expend

significant state resources to implement and enforce the area source generally available control

technology (GACT) regulations. Implementation of climate change regulations will create another

demand on program resources in the near future.

North Carolina, like many other states, will be hard-pressed to meet all of these new requirements

without additional federal support. We believe that the USEP A needs to fund the cost of

implementing the N02 monitoring requirements by making Section 103 grant monies available for

that purpose. In the current budget environment, the NCDAQ will not be able to meet the matching

fund requirements for Section 105 grant monies.

North Carolina is committed to protecting the health of our citizens and solving our air quality

problems. We believe that improving our air quality is critical to the health of our citizens and

that our future growth, prosperity and quality of life will be threatened if we do not remain

diligent. We look forward to continuing to work with the USEPA to establish appropriate

boundaries for nonattainment areas and a sufficient monitoring network.

Sincerely,

S)RQag4~~

Dee Freeman

DF/lab

cc: The Honorable Beverly E. Perdue

Ms. Sheila C. Holman

Mr. Jamie Kritzer

Mr. Dick Schutt