### 6-1 

## 6.0 NINE-FACTOR ANALYSES OF INDIVIDUAL NONATTAINMENT AREAS Chapter 6 contains the rationale for EPA’s PM2.5 designations sorted by EPA Region. The first section under each Region contains the 9-Factor Analyses for any nonattainment areas that was sent in the 120 day letters from EPA to the states and tribes. These letters, sent on June 28 and 29, 2004 responded to the states and tribes recommendations for areas meeting and not meeting the PM2.5 NAAQS. The second section contains justifications for any modifications made to the intended designations found in the 120 day letters. 

## 6.1 Region 1 Nonattainment Areas
6.1.1 EPA 9-Factor Analyses for Southern New England for the Designation of PM2.5 Nonattainment Areas The following is a 9-factor analysis for New England counties that are candidates for nonattainment status for the PM2.5 air-quality standard. EPA guidance establishes the metropolitan area (i.e., MSA or C/MSA where one exists) as the presumptive boundary for PM2.5 nonattainment areas. (See memo from Jeffrey R. Holmstead to EPA Regional Administrators, April 1, 2003). OMB issued revised urban-area definitions on June 6, 2003. Although states were not asked to use the 2003 urban-area definitions when recommending PM2.5 nonattainment areas to EPA, EPA is using the 2003 definitions in its review of state recommendations. Therefore, this 9-factor analysis considers all counties in New England that are in the 2003 New York-Newark-Bridgeport, NY-NJ-CT CSA, and any counties in New England that are adjacent to this CSA. (A list of the 2003 metropolitan area definitions is available at: www.census.gov/population/www/estimates/metroarea.html). In New England, the New York-Newark-Bridgeport, NY-NJ-CT-PA CSA counties include Fairfield, New Haven, and Litchfield counties in CT. Adjacent counties to the CSA include Middlesex and Hartford counties in CT, and Berkshire and Hampden counties in MA. The only monitor in the New England portion of this CSA that violated the annual PM2.5 standard based on 2001-2003 data is located in New Haven, CT. Additionally, there are no monitors in the adjacent counties that violated the annual PM2.5 standard. However, the absence of a violating monitor does not automatically disqualify a county from a PM2.5 nonattainment designation. Connecticut recommended that the entire state be designated as attainment based on an argument that the violating monitor is a “hot spot” (letter from CT DEP to EPA, February 10, 2004). As an alternative, if EPA does not accept the “hot spot” analysis, CT recommended a nonattainment designation for a limited geographic area, such as the City of New Haven or New Haven County. In addition, CT recommended that all CTcounties should be excluded from the nonattainment area associated with the New YorkNorthern New Jersey-Long Island, NY-NJ-CT-PA CMSA based on an argument that

### 6-2 Connecticut does not significantly contribute to PM2.5 violations in the New York City metropolitan area. The Massachusetts Department of Environmental Protection (MA DEP) recommended that all of Massachusetts be designated as attainment/unclassifiable for PM2.5 based on air quality data measured at the monitors within the state (letter from MA DEP to EPA, February 13, 2004). This designation is appropriate for areas where monitors have insufficient data, but where available data support attainment of standards. Based on EPA's 9-factor analysis, EPA proposes that Fairfield and New Haven Counties in Connecticut be considered for a designation of nonattainment of PM2.5 air-quality standard as part of the New York City nonattainment area.

NY-NJ-CT-PA CMSA Area State Recommended Nonattainment Counties EPA Proposed Nonattainment Counties Connecticut None New Haven County Fairfield County Massachusetts None None



### The following is a brief summary of the 9-factor analysis for the New England portion of the New York-N. New Jersey-Long Island, NY-NJ-CT-PA Area.

Factor 1: Emissions For this factor, EPA looked at primary PM2.5, SO2

### , NOx, carbon, and crustal PM2.5 emissions. The weighted emissions score serves as an indicator of the local PM2.5 contribution. The emissions score (also called “composite” or “cumulative” emissions score) was derived as follows:

Emissions score = [(county SO2

### tons/ CSA SO2 tons) * (% sulfate of urban excess PM2.5)] + [(county NOx tons/ CSA NOx tons) * (% nitrate of urban excess PM2.5)] + [(county carbon tons/ CSA carbon tons) * (% carbon of urban excess PM2.5)] + [(county crustal PM tons/ CSA crustal PM tons) * (% crustal of urban excess PM2.5)] For the NY-NJ-CT-PA CSA, “urban excess” was estimated using data from speciation monitors in Newark, NJ (urban site) and in Brigantine National Wildlife Refuge, NJ (regional site) for the period from April 2002 to March 2003. For the Newark speciation monitor, the total PM mass for this period was 17.5 _g/m3

### ; for the Brigantine IMPROVE monitor, the total PM mass was 10.9mg/m3

### . Therefore, the urban excess was estimated to be 6.6mg/m3

### , composed of 6% SO2

### , 25% NOx, 67% carbon, and 3% crustal material. The table below shows total emissions (in tons) and emissions scores for counties that are included in the NY-NJ-CT-PA CSA and for those that are adjacent to the CSA. The counties that are in the 2003-defined CSA are in bold; other counties are adjacent to the CSA counties. (Data source: 2001 NEI). Following this table is a histogram showing

### 6-3 total 2001 emissions of NOx and carbon, the major “local” PM2.5 components for the CSA counties and adjacent counties. Emissions scores for all counties in the NY-NJ-CT-PA CSA add to 100 (see "Cumulative Emissions Score" on table). Counties adjacent to the CSA are assigned an emissions score based on the emissions scores of counties in the CSA so that emissions from those counties can be compared to the CSA counties.County State Recommended Nonattainment Design Values 2001-2003

(mg/m3) Direct PM2.5 (tons) SO2 (tons) NOx (tons) Carbon PM2.5 (tons) Crustal PM2.5 (tons) Emissions Score Cumulative Emissions

Score

Suffolk, NY No 12.3 9,834 45,379 42,938 5,894 3,455 10.8 10.8 Nassau, NY No 12.4 7,289 12,587 30,695 4,665 2,370 7.9 18.7 Queens, NY Yes 13.6 5,443 21,315 57,013 3,203 1,539 7.0 25.7 New York, NY Yes 17.7 4,531 29,811 45,611 2,701 1,269 6.1 31.8 Orange, NY No 11.6 4,410 30,875 22,978 2,091 2,058 4.5 36.3 Kings, NY Yes 14.9 3,039 14,163 42,392 1,800 973 4.4 40.7 Fairfield, CT No 13.3 3,154 20,031 36,762 1,779 1,008 4.3 45.0 New Haven, CT No1 16.7 3,170 17,771 31,345 1,903 1,009 4.2 49.2 Middlesex, NJ Yes 12.7 3,430 5,663 26,425 1,960 1,269 3.9 53.1 Westchester, NY No 12.5 3,229 9,680 20,815 1,923 1,154 3.7 56.8 Bergen, NJ Yes 13.8 2,691 7,945 27,835 1,451 1,726 3.6 60.4 Monmouth, NJ Yes 3,143 3,028 18,971 1,820 1,226 3.4 63.8 Essex, NJ Yes 14.5 2,435 8,114 27,325 1,466 808 3.2 67.0 Ocean, NJ No 11.7 3,291 1,500 13,754 1,802 1,404 3.1 70.1 Mercer, NJ Yes 14.0 2,950 16,426 27,098 1,113 1,608 3.0 73.1 Hudson, NJ Yes 14.8 2,529 22,745 25,572 1,004 1,241 2.9 76.0 Union, NJ Yes 15.7 2,092 5,393 21,149 1,263 688 2.7 78.7 Morris, NJ Yes 12.6 2,038 3,753 16,208 1,301 648 2.5 81.2 Dutchess, NY No 11.0 2,804 4,786 11,471 1,387 1,330 2.5 83.7 Bronx, NY Yes 15.8 1,460 6,723 20,299 849 503 2.1 85.8 Rockland, NY No 1,762 9,541 10,621 928 625 1.9 87.7 Somerset, NJ Yes 1,523 2,490 9,743 816 610 1.6 89.36-4Passaic, NJ Yes 13.3 994 4,349 13,645 658 260 1.5 92.3 Litchfield, CT No 1,574 934 5,062 852 670 1.4 93.7 Richmond, NY Yes 12.2 1,776 1,079 8,399 708 1,009 1.4 95.1 Hunterdon, NJ No 1,490 1,158 8,494 628 809 1.3 96.4 Sussex, NJ No 1,225 872 5,191 612 574 1.1 97.5 Warren, NJ No 13.5 1,204 975 6,358 600 530 1.1 98.6 Putnam, NY No 1,040 548 3,083 505 512 0.9 99.5 Pike, PA No 739 355 2,997 402 317 0.7 100.2 Hartford, CT No 13.1 3,145 4,326 29,590 1,947 1,058 3.9 Northampton, PA No 14.8 5,646 55,105 24,051 1,212 3,374 3.9 Bucks, PA Yes2 14.6 3,100 6,870 16,852 1,443 1,444 2.8 Burlington, NJ No 2,298 2,330 15,113 1,326 836 2.5 Hampden, MA No 13.5 1,965 16,077 19,050 994 781 2.4 Ulster, NY No 2,328 3,818 8,417 1,025 1,235 1.9 Middlesex, CT No 1,417 4,751 9,520 731 563 1.5 Berkshire, MA No 12.2 1,641 3,702 6,382 826 711 1.5 Monroe, PA No 1,758 1,367 6,222 881 811 1.5 Sullivan, NY No 1,200 612 2,875 625 544 1.0 Greene, NY No 936 3,836 7,511 375 503 0.9 Columbia, NY No 1,018 585 3,497 420 574 0.8 Delaware, NY No 996 879 2,705 496 475 0.8 Wayne, PA No 765 746 1,786 374 365 0.6 1. Only recommended NA under scenario that EPA disagrees with “hotspot” argument. 2. Recommended to be part of Philadelphia nonattainment area.



### 2.

### 6-6 NYC CMSA - NOx and Carbon by County

0 10,000 20,000 30,000 40,000 50,000 60,000

Suffolk, NY

Nassau, NY

Queens, NY

New York, NY

Orange, NY

Kings, NY

Fairfield, CT

New Haven, CT

Middlesex, NJ

Westchester, NY Bergen, NJ

Monmouth, NJ Essex, NJ

Ocean, NJ

Mercer, NJ

Hudson, NJ

Union, NJ

Morris, NJ

Dutchess, NY

Bronx, NY Rockland, NY

Somerset, NJ

Passaic, NJ

Litchfield, CT

Richmond, NY

Hunterdon, NJ

Sussex, NJ

Warren, NJ

Putnam, NY

Pike, PA Hartford, CT Northampton, PA Bucks, PA New London, CT

Burlington, NJ

Hampden, MA

Ulster, NY

Middlesex, CT

Berkshire, MA

Monroe, PA

Sullivan, NY

Greene, NY

Columbia, NY

Delaware, NY

Wayne, PANOx (tons)

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000Carbon (tons) NOx Carbon
Counties in NYC CMSA Adjacent Counties

CT Counties State recommended counties



### EPA developed a national process for assessing emissions based on emissions scores to identify candidate counties for a PM2.5 nonattainment designation. This process flags CSA and adjacent counties with relatively high cumulative emissions scores. For the NY-NJ-CT-PA CSA, counties with cumulative emissions scores of≤80% (as well as adjacent counties that have emissions scores that are≥the emissions score of the 80% CSA county) were considered to be counties with relatively high emissions. The 80% CSA cutoff counties are Morris, NJ and Dutchess, NY (cum emissions scores = 81.2 and 83.7, respectively; emissions scores = 2.5). This process applied to the New England counties identifies Fairfield, New Haven, and Hartford Counties in Connecticut as candidates for a PM2.5 nonattainment designation (i.e., counties with emissions scores≥2.5), and, therefore, requiring further analysis. Litchfield and Middlesex Counties in Connecticut, and Hampden and Berkshire Counties in Massachusetts are dropped from further analysis because (1) none of these counties contain violating PM2.5 monitors, (2) none were recommended for a nonattainment designation by the state, and (3) all have emissions scores≤2.5. Factor 2: Air quality PM2.5 Design Values (inmg/m3

### ) for the three-year period from 2001 to 2003 are given in the table above for all counties in and adjacent to the NY-NJ-CT-PA CSA. In New England, only one county, New Haven, shows a violation of the annual PM2.5 standard. However, this factor alone is not sufficient to eliminate the other New England counties as candidates for nonattainment status.

### 6-7 Factors 3 (Population Density and Urbanization) and 4 (Traffic and commuting patterns) The table below shows population, VMT and commuting data for counties that are included in the NY-NJ-CT-PA CSA and for those that are adjacent to the CSA. The ranking of the counties is based on the number of people commuting to other counties from highest to lowest. The counties that are in the 2003-defined CSA are in bold; other counties are adjacent to the CSA counties.

County State Recommended

NA 2002 Popula-tion 2002 Pop Density (pop/sq

mi) 2002 VMT (1000 mi) Commuting to Other

Metro Counties (%) Commuting to Other

Metro Counties (#) Queens, NY Yes 2,237,815 20,530 10,441 60 557,383 Kings, NY Yes 2,488,194 35,045 12,313 51 463,551 Nassau, NY No 1,344,892 4,686 6,875 41 256,588 Bronx, NY Yes 1,354,068 32,240 6,440 59 243,970 Bergen, NJ Yes 895,091 3,825 6,732 42 178,468 Suffolk, NY No 1,458,655 1,601 7,414 26 175,244 Middlesex, NJ Yes 775,549 2,494 5,794 43 157,177 Westchester, NY No 937,279 2,165 4,964 36 154,322
Essex, NJ Yes 798,301 6,336 6,356 46 150,496 Hudson, NJ Yes 611,439 13,009 4,518 53 141,386 Union, NJ Yes 530,763 5,153 4,034 52 123,905 Passaic, NJ Yes 496,646 2,685 3,568 54 113,164 Monmouth, NJ Yes 629,836 1,334 5,146 39 112,634

New York NY Yes 1,546,856 55,245 7,961 15 111,765 Richmond, NY Yes 457,383 7,752 2,030 54 104,042 Morris, NJ Yes 478,730 1,021 3,939 41 98,930 Somerset, NJ Yes 309,886 1,016 2,209 55 82,696 Fairfield, CT No 896,202 1,432 7,889 19 78,180 Ocean, NJ No 537,065 844 3,641 37 76,620

New Haven, CT No1 835,657 1,379 6,989 19 72,261

### 6-8 Rockland, NJ No 291,835 1,677 1,413 45 59,116 Orange, NY No 356,773 437 3,628 32 48,241 Sussex, NJ No 148,680 285 1,323 58 42,375 Mercer, NJ Yes 359,463 1,591 3,869 24 38,571 Hartford, CT No 867,332 1,178 8,105 9 35,469 Bucks, PA Yes2 610,440 1,004 3,830 11 34,474 Putnam, NY No 98,257 424 781 71 34,078 Dutchess, NJ No 287,752 359 2,905 27 34,054 Hunterdon, NJ No 125,795 293 1,893 54 33,861 Burlington, NJ No 437,871 544 3,748 14 29,263 Litchfield, CT No 186,515 203 1,170 30 27,825 Warren, NJ No 107,537 300 1,473 52 26,228 Ulster, NY No 179,986 160 1,850 30 24,275 Northampton, PA No 273,324 731 2,132 15 18,557 Middlesex, CT No 159,679 433 1,560 18 14,700 Monroe, PA No 148,839 245 1,434 22 13,830 Pike, PA No 50,095 92 722 46 8,820 Sullivan, NY No 74,273 77 683 27 7,999 Columbia, NY No 63,532 100 754 12 3,532 Greene, NY No 48,538 75 643 7 1,487 Berkshire, MA No 133,462 143 1,850 2 1,291 Wayne, PA No 48,889 67 334 6 1,269 Hampden, MA No 459,116 742 3,708 1 1,016 Delaware, NY No 47,302 33 508 4 846 1. Only recommended NA under scenario that EPA disagrees with “hotspot” argument. 2. Recommended to be part of Philadelphia nonattainment area. 

### The three candidate counties in CT (i.e. Fairfield, New Haven, and Hartford Counties) have moderately sized populations and population densities relative to other counties in the NY-NJ-CT-PA CSA and adjacent counties. Although there is a much smaller number of commuters in the three Connecticut counties than in some NY counties in the NY-NJ-CT-PA CSA, the numbers of commuters in

### 6-9 Fairfield and New Haven Counties are moderately high, each with more than twice as many commuters as Hartford County. CT DEP used 2000 Census Bureau data on work-trip origins and destinations to assess Connecticut contribution (i.e., from Fairfield, New Haven, and Litchfield counties) to traffic levels in the New York portion of the CMSA. CT DEP concluded that the Connecticut contribution is 0.7% overall, with 0.1% in the NJ portion and 1.0% in the New York portion of the CMSA. However, heavy-duty truck traffic from Connecticut to both New York and New Jersey may not have been adequately taken into account in this analysis. All three counties score relatively high for VMT when compared to the rest of the CSA and adjacent counties. Factor 5: Expected growth The table below shows population, population growth, VMT and VMT growth for counties that are included in the NY-NJ-CT-PA CSA. The ranking of the counties is based on the VMT growth in thousand of miles between 1996 and 2002 from highest to lowest.

County 2002 Population Population Growth (90-00) % growth (90-00) 2002 VMT (1000 mi) VMT Growth (1000 mi)

(96-02) VMT % chng (96-02)

Kings, NY 2,488,194 164,662 7 12,313 1,011 39 Westchester, NY 937,279 48,593 6 4,964 755 13 Monmouth, NJ 629,836 62,177 11 5,146 739 17 Middlesex, NJ 775,549 78,382 12 5,794 721 14 New Haven, CT 835,657 19,789 2 6,989 714 11 Essex, NJ 798,301 15,427 2 6,356 713 13 Fairfield, CT 896,202 54,922 7 7,889 656 9 Suffolk, NY 1,458,655 97,505 7 7,414 595 9 Warren, NJ 107,537 10,830 12 1,473 578 65 Bergen, NJ 895,091 58,738 7 6,732 540 12 Mercer, NJ 359,463 24,937 8 3,869 526 16 Hudson, NJ 611,439 55,876 10 4,518 506 13 Hunterdon, NJ 125,795 14,213 13 1,893 481 34

### 6-10 Passaic, NJ 496,646 35,989 8 3,568 466 15 Ocean, NJ 537,065 77,713 18 3,641 464 15 Union, NJ 530,763 28,722 6 4,034 452 13 Dutchess, NY 287,752 20,688 8 2,905 408 12 Pike, PA 50,095 18,336 66 722 406 128 Somerset, NJ 309,886 57,211 24 2,209 336 18 Litchfield, CT 186,515 8,101 5 1,170 232 25 Orange, NY 356,773 33,720 11 3,628 213 2 Queens, NY 2,237,815 277,781 14 10,441 180 2 New York, NY 1,546,856 49,659 3 7,961 137 2 Putnam, NY 98,257 11,804 14 781 134 21 Nassau, NY 1,344,892 47,196 4 6,875 117 2 Bronx, NY 1,354,068 128,861 11 6,440 111 2 Morris, NJ 478,730 48,859 12 3,939 97 3 Sussex, NJ 148,680 13,223 10 1,323 74 6 Richmond, NY 457,383 64,751 17 2,030 35 2 Rockland, NY 291,835 21,278 8 1,413 24 2



### Based on analysis of this factor, Fairfield and New Haven counties had low population growth between 1990 and 2000. However, they both had a sizable increase in vehiclemiles traveled from 1996-2002, an increase above most other counties in the NY-NJ-CTPA CSA. Factor 6: Meteorology

County Prevailing Wind Direction %

NW SW SE NE Fairfield, CT 34 30 12 24 New Haven, CT 34 30 13 24 Hartford, CT 35 29 13 23

### 6-11 Individual 24

-hour FRM data (2001

- 2003) paired with daily resultant WS/WD (includes event

-flagged data) 

## “Bubble Rose” of Wind and PM2.5 data for New York Urban Area

DV = 15.8



### PM Station: Bronx, New York MET Station: Central Park, NY

PM Station:Roosevelt School Park Ave, Bridgeport, CT MET Station:Sikorsky Memorial Airport, Bridgeport DV = 13.3

### 6-12 DV = 16.7



### PM Station:Stiles Street, New Haven, CT MET Station: Sikorsky Memorial Airport, Bridgeport

PM Station:715 State Street, New Haven, CT MET Station: Sikorsky Memorial Airport, Bridgeport DV = 14.1

### 6-13 Connecticut did studies to assess whether emissions from Connecticut sources are contributing significantly to violations in other parts of the New York City metropolitan area. These studies included use of the ISCST3 (Industrial Source Complex Simple Terrain) area source model and HYSPLIT4 (HYbrid Single-Particle Lagrangian Integrated Trajectory) model. Results from the ISCST3 model show that primary PM2.5 emissions have low impact on New York City and Hudson Co, NJ. The model estimates the Connecticut source contribution to New York City to be between 1.7 and 2.3%. For receptors in the cities of Bridgeport and New Haven; Connecticut sources contributed > 50% primary PM2.5 totals. For the HYSPLIT4 model, Connecticut obtained maximum daily PM2.5 concentrations from January 1999 to September 2003 from a monitor in New York City, rank-ordered them from high to low, and recorded dates of the top and bottom 10 percentiles. They then ran back-trajectory winds once a day for each of those days at three height levels (10m, 500m, and 1000m). Results of this modeling show that air mass during highest PM2.5 days originated from and passed through locations in a sector from SSW and SW through W and WNW from New York City, and not from directions that pass over Connecticut. Although the meteorological data make a strong case that CT is not frequently a significant contributor to elevated PM2.5 levels in the New York City urban area, EPA notes that PM2.5 is a year-round standard with some contributions during all seasons from many directions, as shown in the “bubble roses” above for monitors in the Bronx, Fairfield and New Haven counties. These roses show that, although not a frequent occurrence, some component of elevated PM2.5 measured at the monitor in the Bronx does originate from a northeastern direction (i.e., direction of CT). The roses also show the need to consider the contribution of NJ and NY to the violating monitor in Connecticut. This is also supported by modeling done for the CAIR (seeEPA'sJanuary 30, 2004 (69 FR 4566) notice of proposed rulemaking (NPR)), which showed that both NJ and NY “contribute significantly” to New Haven County. Based on analysis of this factor, EPA is not convinced that Fairfield and New Haven counties should be excluded from the New York City nonattainment area. However, Hartford County, which is an adjacent county to the NY-NJ-CT-PA CSA, is further removed geographically and meteorologically from the NYC area. Based on this fact, plus the absence of a violating PM2.5 monitor in Hartford County, EPA concludes that Hartford County can drop from further consideration as a nonattainment county. Factor 7: Geography/topography The New England portion of the NY-NJ-CT-PA CSA and adjacent counties do not have any geographical or topographical boundaries limiting its airshed. This factor did not play a significant role in the decision making process.

### 6-14 Factor 8: Jurisdictional boundariesFrom a New England perspective, the major jurisdictional boundary in the NY-NJ-CTPA CSA (and adjacent counties) is the state line between New York and Connecticut. Violating counties in the NY-NJ-CT-PA CSA include New York County (Manhattan), Bronx County, and Union County, NJ. The State of Connecticut has no jurisdictional say in the air quality regulations and policies developed by either New York or New Jersey to address PM2.5 emissions in the areas with the violating monitors. In addition, State of Connecticut has very limited influence in the transportation policies developed to address traffic and vehicle miles traveled in the New York City metropolitan area. On the other hand, areas designated as 8-hour ozone nonattainment areas are also important boundaries for state air-quality planning. Fairfield, New Haven, and Middlesex counties in Connecticut were included in the ozone nonattainment area associated with the New York City metropolitan area. Other counties included in this 9- factor analysis are also designated as 8-hour ozone nonattainment areas, but are not associated with the New York City area. A goal in designating PM2.5 nonattainment areas is to achieve a degree of consistency with ozone nonattainment areas. Comparison of ozone areas with potential PM2.5 nonattainment areas, therefore, gives added weight to designation of Fairfield and New Haven counties, but not to the other CSA and adjacent counties considered herein.

Factor 9: Level of control of emission sources The emissions used to prepare the composite emissions scores are for 2001. These emission estimates include any control strategies implemented by the states in the CSA prior to 2001 that may influence emissions of primary PM2.5, SO2

### , NOx, carbon, and crustal PM2.5 emissions. In CT, however, there may be some emission reductions of SO2

### subsequent to 2001 that are not accounted for pursuant to the SO2

### rule Connecticut adopted pursuant to state legislation (seehttp://dep.state.ct.us/air2/regs/mainregs/sec19a.pdf ). This rule basically requires compliance with 0.55 lbs/mm BTU by January 1, 2002 and 0.33 lbs/mm BTU by January 1, 2003. To date, this rule has resulted in a significant reduction is statewide SO2 

### emissions. However, in the New York City metropolitan area, only a small percentage of the urban increment is from SO2

### (i.e., about 6%). Thus, incorporating the additional SO2 

### emission reductions from Connecticut sources in the composite emissions score analysis for the CSA is not expected to change the outcome significantly. Furthermore, the Connecticut SO2

### rule is currently not part of the federally-approved State Implementation Plan, and thus is not federally enforceable. Thus, this factor analysis generally considered the emissions controls currently in place.

### 6-15 6.1.2 Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States

Connecticut EPA does not intend to modify its recommendations concerning nonattainment designations and boundaries that were listed in the June 29, 2004 letter to Connecticut.

New Haven and Fairfield EPA is recommending that New Haven and Fairfield Counties be designated nonattainment. This decision is based on consideration of nine factors, including emissions, air quality, population density, traffic and commuting patterns, expected growth, meteorology, geography/topography, jurisdictional boundaries, and level of control of emission sources. EPA compared emissions, population, and traffic levels in all counties within and adjacent to the New York-Newark-Bridgeport, NY-NJ-CT-PA Combined Statistical Area (CSA). New Haven and Fairfield Counties had similar, or sometimes greater levels for all these factors than other New York counties (e.g., Westchester, Nassau, Suffolk, and Orange) and New Jersey counties (e.g., Middlesex, Bergen, and Monmouth) for which EPA is designating nonattainment. In addition, EPA notes that Fairfield and New Haven Counties are a conduit for a large percentage of the truck traffic that flows throughout New England. As such, this presents an opportunity for Connecticut to work with New York and New Jersey to identify measures to help reduce diesel emissions and, thus, help monitors in the New York urban area to meet PM2.5

### standards. Based on these considerations, EPA is including New Haven and Fairfield Counties in the New York-N. New Jersey-Long Island, CT-NJ-NY PM2.5 

### nonattainment area.

### 6-16 

## 6.2 Region 2 Nonattainment Areas

6.2.1 EPA 9-Factor Analyses for New Jersey for the Designation of PM2.5 Nonattainment Areas Modifications to New Jersey’s Recommendations

Gloucester New Jersey did not recommend Gloucester County as a nonattainment county. EPA is modifying the New Jersey recommendation by designating Gloucester County as nonattainment. Gloucester County ranks high for emissions, population, traffic, and commuting patterns. Gloucester is also adjacent to a county with a violating monitor. Point sources are also located near the county with the violating monitor.

Camden New Jersey did not recommend Camden County as a nonattainment county. EPA is modifying the New Jersey recommendation by designating Camden County as nonattainment. Camden County ranks high for emissions, population, traffic, and commuting patterns. Camden is also adjacent to a county with a violating monitor. Point sources are also located near the county with the violating monitor. Burlington New Jersey did not recommend Burlington County as a nonattainment county. EPA is modifying the New Jersey recommendation by designating Burlington County as nonattainment. Burlington County ranks high for emissions, population, traffic, and commuting patterns. Burlington is also adjacent to a county with a violating monitor. Point sources are also located near the county with the violating monitor. Analysis of the New Jersey portion of the PA-NJ-MD C/MSA and adjacent counties The New Jersey portion of this area includes the counties of Gloucester, Camden, Burlington, Cape May, Atlantic, Cumberland, Salem, Mercer, Monmouth, Ocean, Hunterdon, and Warren. Violating monitors (based on 2001-2003 data) are present in Philadelphia and Delaware Counties in Pennsylvania, and in New Castle in Delaware. Based on EPA’s nine-factor analysis, EPA is recommending that additional counties should be added to the nonattainment area for the New Jersey portion of the PA-NJ-MD C/MSA and adjacent counties.

### 6-17 EPA Recommendation State Recommendation Gloucester, Camden, and Burlington None


### The following is a brief summary of the 9 criteria for the New Jersey portion of the PA-NJ-MD C/MSA and adjacent counties. Although listed in the tables for comparison purposes, Monmouth and Mercer counties are not specifically discussed in the analysis since they have been recommended for nonattainment by New Jersey. Factor 1: Emissions in the PA-NJ-MD C/MSA and for those that are adjacent to the C/MSA The following table shows total emissions (in tons) and emission scores for Pennsylvania, New York and Maryland, and Delaware included in the PA-NJ-MD C/MSA and for those that are adjacent to the C/MSA. (Data source: 2001 National Emissions Inventory (NEI)).

County direct PM 2.5 (tons) SO2 (tons) NOx (tons) Carbon PM2.5 (tons) Crustal PM2.5 (tons) Emission Score Cumulative Score New Castle, DE 4,558 61,499 34,640 2,276 15,147 18.6 18.6 Philadelphia, PA 3,944 16,681 55,011 2,116 1,200 14.0 32.6 Delaware, PA 3,173 24,882 33,259 1,458 1,225 11.1 43.7 Montgomery, PA 3,910 8,721 21,191 1,905 1,700 8.7 52.4 Chester, PA 3,716 11,391 16,909 1,228 2,226 6.9 59.3 Bucks, PA 3,100 6,870 16,852 1,443 1,444 6.8 66.1 Gloucester, NJ 1,909 9,154 21,849 1,035 697 6.5 72.6 Camden, NJ 2,154 4,120 17,025 1,286 727 5.9 78.5 Burlington, NJ 2,298 2,330 15,113 1,326 836 5.6 84.1 Cape May, NJ 2,157 14,578 7,894 938 1,044 5.5 89.6 Atlantic, NJ 1,404 1,905 8,676 773 563 3.3 92.9 Cumberland, NJ 1,374 1,941 7,054 638 669 2.8 95.7 Salem, NJ 1,243 4,485 5,457 487 653 2.6 98.3 Cecil, MD 950 948 5,502 401 518 1.8 100.1 Northampton, PA 5,646 55,105 24,051 1,212 3,374 13.9 Berks, PA 4,806 17,143 21,834 1,520 2,821 9.1 Lancaster, PA 5,673 10,786 20,901 1,746 3,569 8.8 Mercer, NJ 2,950 16,426 27,098 1,113 1,608 8.4 Monmouth, NJ 3,143 3,028 18,971 1,820 1,226 7.4 Ocean, NJ 3,291 1,500 13,754 1,802 1,404 6.6 Lehigh, PA 1,844 6,027 12,154 624 1,018 3.9 Kent, DE 1,503 5,124 8,512 618 818 3.4 Harford, MD 1,517 1,946 8,662 754 705 3.3 Hunterdon, NJ 1,490 1,158 8,494 628 809 2.8 Warren, NJ 1,204 975 6,358 600 530 2.5 Kent, MD 438 228 1,009 170 259 0.6 

### Applied to New Jersey, the process identifies Mercer, Monmouth, Gloucester, Camden, Burlington, and Ocean Counties as having elevated emissions relative to the remainder of the C/MSA.

### 6-18 Gloucester, Camden, Burlington, and Salem Counties in New Jersey have multiple large point sources which are concentrated along the border of Philadelphia, Delaware and New Castle Counties. In contrast, Ocean County does not have any significant point sources. The bulk of mobile source emissions from Gloucester, Camden, and Burlington counties would be concentrated along the border of eastern Pennsylvania since the population of the New Jersey counties is concentrated along the border of Philadelphia and Delaware counties. In contrast, the population for Ocean County is concentrated in the northeast section of the county. Factor 2: Air quality

County PM 2.5 2001- 2003 Design Value (_g/m3) New Castle, DE 16.2 Philadelphia, PA 16.4 Delaware, PA 15.6 Montgomery, PA 14.3 Chester, PA 15.1 Bucks, PA 14.6 Gloucester, NJ 13.8 Camden, NJ 14.6 Burlington, NJ No monitor Cape May, NJ No monitor Atlantic, NJ 11.6 Northampton, PA 14.8 Berks, PA 16.4 Lancaster, PA 17.0 Mercer, NJ 14.0 Monmouth, NJ No monitor Ocean, NJ 11.7 Lehigh, PA 14.6 Kent, DE 13.1 Harford, MD 13.1 Hunterdon, NJ No monitor Kent, DE 13.1

### 6-19 Cumberland, NJ No monitor Salem, NJ No monitor Cecil, MD No monitor



### New Jersey does not have any design values above the standard in the area. Gloucester and Camden counties have design values approaching the standard. The following New Jersey counties are adjacent to counties with violating monitors: Burlington, Camden, Salem and Gloucester. Factor 3: Population/ Population density
County 2002 Population 2002 Population Density (population per sq mi) New Castle, DE 512,370 1,203 Philadelphia PA 1,492,231 11,054 Delaware, PA 553,435 3,008 Montgomery PA 766,517 1,587 Chester, PA 450,160 595 Bucks, PA 610,440 1,004 Gloucester, NJ 262,049 806 Ocean, NJ 537,065 844 Camden, NJ 511,957 2,306 Burlington, NJ 437,871 544 Cape May, NJ 102, 013 400 Atlantic, NJ 259,423 462 Northampton, PA 273,324 731 Berks, PA 382,108 445 Lancaster, PA 478,561 504 Lehigh, PA 317,533 915 Kent, DE 131,069 222 Harford, MD 227,713 518 Mercer, NJ 359,463 1,591 Monmouth, NJ 629,836 1,334

### 6- 20 Cumberland, NJ 147,768 302 Salem, NJ 64,438 191 Cecil, MD 90,335 260


### The analysis for this factor looks at population data from 2002. Population data indicates the likelihood of population-based emissions to contribute to monitored violations. Due to its large concentrated population and relative land size area, the county of Philadelphia dominates the remainder of the C/MSA. To a much lesser extent, Camden County is also more urbanized than the majority of the remaining counties in the C/MSA. The population of Gloucester, Camden, and Burlington are concentrated along the border of Philadelphia and Delaware counties. In contrast, the population of Ocean County is concentrated in the northeastern most section of the county. Factor 4: Traffic and commuting patterns
County VMT1 (1000 miles) #Commuters to Philadelphia, PA #Commuters to Delaware, PA #Commuters to New Castle, DE New Castle, DE 4,957 5,386 8,150 209,742 Philadelphia, PA 10,213 429,667 21,802 1,856 Delaware, PA 3,513 48,151 137,988 9,002 Montgomery, PA 4,677 54,576 11,758 1,201 Chester, PA 3,128 10,568 17,870 12,976 Bucks, PA 3,830 31,892 2,754 493 Gloucester, NJ 2,312 13,778 3,179 1,662 Ocean, NJ 3,641 491 118 45 Camden, NJ 4,332 32,961 3,232 1,286 Burlington, NJ 3,748 17,661 1,771 597 Cape May, NJ 749 716 224 109 Atlantic, NJ 2,236 1,359 314 175 Northampton, PA 2,132 244 66 16 Berks, PA 3,952 702 505 157 Lancaster, PA 4,004 607 615 523

### 6- 21 Lehigh, PA 2,738 578 171 22 Kent, DE 1,633 37 125 6,058 Harford, MD 2,208 88 35 1,033 Monmouth, NJ 5,146 622 66 40 Mercer, NJ 3,869 1,574 244 139 Cumberland, NJ 1,166 618 105 171 Cecil, MD 1,340 254 373 14,059 Salem, NJ 734 615 486 3,258

1Vehicle Miles Traveled within county in 2002 

### The analysis of this factor looks at the number of commuters who drive to counties within the metropolitan area with violating monitors, as well as total Vehicle Miles Traveled (VMT) for each county in thousands of miles. The largest numbers of commuters are from Pennsylvania and Delaware counties. Camden, Burlington, and Gloucester Counties also have large numbers of people who commute to Philadelphia. All other New Jersey counties are low for the number of commuters. Ocean County has a very low number of commuters to Philadelphia. After Philadelphia, there does not appear to be a significant difference in VMT between the remainder of the counties in the CMSA. Factor 5: Expected growth
County 2002 Population % growth (90-00) Population Growth (90-00) New Castle, DE 512,370 13 58,319 Philadelphia, PA 1,492,231 -4 -68,027 Delaware, PA 553,435 1 3,213 Montgomery, PA 766,517 11 71,986 Chester, PA 450,160 15 57,105 Bucks, PA 610,440 10 56,461 Gloucester, NJ 262,049 11 24,591 Ocean, NJ 537,065 18 77,713 Camden, NJ 511,957 1 6,108 Burlington, NJ 437,871 10 28,328 Cape May, NJ 102,013 8 7,237

### 6- 22 Atlantic, NJ 259,423 13 28,225 Northampton, PA 273,324 8 19,961 Berks, PA 382,108 11 37,115 Lancaster, PA 478,561 11 47,836 Lehigh, PA 317,533 7 20,960 Kent, DE 131,069 14 15,704 Harford, MD 227,713 20 36,458 Monmouth, NJ 629,836 11 62, 177 Mercer, NJ 359,463 8 24,937 Cumberland, NJ 147,768 6 8,385 Salem, NJ 64,438 -2 -1,009 Cecil, NJ 90,335 20 14,604


### Ocean, Gloucester, and Burlington Counties experienced moderate growth in New Jersey. Factor 6: Meteorology This factor did not play a significant role in the decision making process for New Jersey counties with the exception of Ocean, Cape May, and Atlantic Counties.
County Prevailing Wind Direction %

NW SW SE NE Philadelphia, PA 35 31 15 20 Delaware, PA 35 30 15 20 New Castle, DE 38 28 15 19


### The prevailing wind direction to counties with violating monitors is predominantly from the NW and SW. Ocean, Cape May, and Atlantic Counties had a negligible contribution based upon analysis of pollution roses. Further analysis of 24 hour back trajectories (HYSPLIT model) calculated and plotted for twenty-two high PM days in Philadelphia indicate that emissions from Ocean County have a very low impact on Philadelphia. The HYSPLIT model was used with 80 KM EDAS data to calculate 24-hour back trajectories ending at an elevation of 500 meters over Philadelphia ending at 07 UTC, 13 UTC, 19 UTC, and 01 UTC (next day). Back trajectories passed through Ocean County only on four days. Further review of those trajectories indicate the following:

### 6- 23 January 13, 2001 One out of the four trajectories plotted (i.e. back trajectory ending at 19 WTC) passed through the northwesternmost section of the county. That section of the county has a low population density. The trajectory continued through Camden and Gloucester and looped through heavily populated sections of Philadelphia (entered the city from the west). Dec 10, 2002 Light and variable winds were observed which would indicate the impact of local emissions from the Philadelphia area. One out of the four trajectories plotted (i.e., back trajectory ending at 07 WTC) passed through the center of the county. The trajectory looped through Kent and New Castle and then entered Philadelphia from the west. Jan 30, 2003 One out of the four trajectories plotted (i.e., back trajectory ending at 19 WTC) passed through the northwesternmost section of the county. That section of the county has a low population density. Oct 27, 2000 Two out of the four trajectories plotted (i.e., back trajectory ending at 07 and 13 WTC) passed through the southernmost section of the county. That section of the county has a low population density. The trajectory ending at 01 WTC on October 28th was from the west. Factor 7: Geography/topography The area does not have any geographical or topographical boundaries limiting its airshed in the
areas.
Factor 8: Jurisdictional boundaries EPA is striving to achieve consistency with the 8-hour ozone nonattainment areas for purposes of state air quality planning. Although this factor is considered as part of the analysis, this factor is not a dominant factor in the decision making process. All counties in New Jersey were designated nonattainment for the 8-hour ozone standard on April 15, 2004.

Factor 9: Level of control of emission sources This factor did not play a significant role in the decision making. The level of control of emission is reflected in factor 1.

6.2.2 EPA 9-Factor Analyses for New York for the Designation of Nonattainment Areas for PM2.5

### 6- 24 Modifications to New York’s Recommendations

Westchester New York did not recommend Westchester County as a nonattainment county. EPA is modifying the New York recommendation by designating Westchester County as nonattainment. Westchester County ranks high for emissions, population, traffic, and commuting patterns. Westchester is also adjacent to a county with a violating monitor. In addition, an analysis of pollution roses and back trajectories to New Haven, CT showed a contribution from Westchester County.

Nassau New York did not recommend Nassau County as a nonattainment county. EPA is modifying the New York recommendation by designating Nassau County as nonattainment. Nassau County ranks high for emissions, population, traffic, and commuting patterns. In addition, an analysis of pollution roses and back trajectories to New Haven, CT showed a contribution from Nassau County.

Suffolk New York did not recommend Suffolk County as a nonattainment county. EPA is modifying the New York recommendation by designating Suffolk County as nonattainment. Suffolk County ranks high for urban excess emissions, population, traffic, and commuting patterns. In addition, an analysis of pollution roses and back trajectories to New Haven, CT showed a contribution from Suffolk County. Orange New York did not recommend Orange County as a nonattainment county. EPA is modifying the New York recommendation by designating Orange County as nonattainment. Orange County ranks high for emissions. Orange County also has several large point sources. In addition, an analysis of pollution roses and back trajectories to New Haven, CT showed a contribution from Orange County.

Rockland New York did not recommend Rockland County as a nonattainment county. EPA is modifying the New York recommendation by designating Rockland County as nonattainment. This county is recommended because it is contiguous to both Orange and Westchester Counties, and an analysis of pollution roses and back trajectories to New Haven, CT showed a contribution from Rockland County.

### 6- 25 Analysis of the New York and New Jersey portions of the NY-NJ-CT-PA C/MSA and adjacent counties The New York portion of this area includes the counties of Suffolk, Nassau, Queens, New York, Orange, Kings, Westchester, Dutchess, Bronx, Rockland, Richmond, Putnam, Ulster, Sullivan, Greene, Columbia, and Delaware. Violating monitors (based on 2001-2003 data) in New York State are present in New York and the Bronx counties. The New Jersey portion of the area includes Middlesex, Bergen, Monmouth, Essex, Ocean, Mercer, Hudson, Union, Morris, Somerset, Passaic, Hunterdon, Sussex, Warren, and Burlington. A violating monitor (based on 2001-2003 data) in New Jersey is present in Union County. A violating monitor (based on 2001-2003 data) is also present in New Haven, Connecticut. New York State has recommended that the most effective boundary for the New York portion of this nonattainment area would consist of the five counties comprising New York City which includes New York, the Bronx, Kings, Queens, and Richmond Counties. New Jersey’s recommendation includes Hudson, Union, Middlesex, Bergen, Monmouth, Essex, Mercer, Morris, Somerset, and Passaic counties. Based on EPA’s nine-factor analysis, EPA is recommending that additional counties should be added to the nonattainment area for the New York portion of the NY-NJ-CT-PA C/MSA and adjacent counties. EPA is not recommending that any additional counties be added to the New Jersey portion of the NY-NJ-CT-PA C/MSA and adjacent counties.

NY-NJ-CT-PA Area EPA Recommendation State Recommendation New York New York, the Bronx, Kings, Queens, Richmond, Suffolk, Nassau, Orange, Westchester, and Rockland. New York, the Bronx, Kings, Queens, and Richmond Counties.

New Jersey Hudson, Union, Middlesex, Bergen, Monmouth, Essex, Mercer, Morris, Somerset, Passaic counties. Hudson, Union, Middlesex, Bergen, Monmouth, Essex, Mercer, Morris, Somerset, Passaic counties.



### The following is a brief summary of the 9 criteria for the New York State and New Jersey portions of the NY-NJ-CT-PA C/MSA including adjacent counties. Counties that are in the C/MSA are in bold. Burlington, NJ was not evaluated since it was recommended for nonattainment by us based on our 9-factor analysis for the New Jersey portion of the PA-NJ-MD C/MSA area.Factor 1: Emissions for New York and New Jersey Counties included in the NY-NJ-CTPA and for those that are adjacent to the C/MSA

### 6- 26 The following table shows total emissions (in tons) and Emission Scores for New York and New Jersey Counties included in the NY-NJ-CT-PA and for those that are adjacent to the C/MSA. (Data source: 2001 National Emissions Inventory (NEI)).

County direct PM 2.5 (tons) SO2 (tons) NOx (tons) Carbon PM2.5 (tons) Crustal PM2.5 (tons) Emission Score Cumulative Score Suffolk, NY 9,834 45,379 42,938 5,894 3,455 10.8 10.8 Nassau, NY 7,289 12,587 30,695 4,665 2,370 7.9 18.7 Queens, NY 5,443 21,315 57,013 3,203 1,539 7.0 25.7 New York, NY 4,531 29,811 45,611 2,701 1,269 6.1 31.8 Orange, NY 4,410 30,875 22,978 2,091 2,058 4.5 36.3 Kings, NY 3,039 14,163 42,392 1,800 973 4.4 40.7 Middlesex, NJ 3,430 5,663 26,425 1,960 1,269 3.9 53.1 Westchester, NY 3,229 9,680 20,815 1,923 1,154 3.7 56.8 Bergen, NJ 2,691 7,945 27,835 1,451 1,726 3.6 60.4 Monmouth, NJ 3,143 3,028 18,971 1,820 1,226 3.4 63.8 Essex, NJ 2,435 8,114 27,325 1,466 808 3.2 67.0 Ocean, NJ 3,291 1,500 13,754 1,802 1,404 3.1 70.1 Mercer, NJ 2,950 16,426 27,098 1,113 1,608 3.0 73.1 Hudson, NJ 2,529 22,745 25,572 1,004 1,241 2.9 76.0 Union, NJ 2,092 5,393 21,149 1,263 688 2.7 78.7 Morris, NJ 2,038 3,753 16,208 1,301 648 2.5 81.2 Dutchess, NY 2,804 4,786 11,471 1,387 1,330 2.5 83.7 Bronx, NY 1,460 6,723 20,299 849 503 2.1 85.8 Rockland, NY 1,762 9,541 10,621 928 625 1.9 87.7 Somerset, NJ 1,523 2,490 9,743 816 610 1.6 89.3 Passaic, NJ 994 4,349 13,645 658 260 1.5 92.3 Richmond, NY 1,776 1,079 8,399 708 1,009 1.4 95.1 Hunterdon, NJ 1,490 1,158 8,494 628 809 1.3 96.4 Sussex, NJ 1,225 872 5,191 612 574 1.1 97.5 Warren, NJ 1,204 975 6,358 600 530 1.1 98.6 Putnam, NY 1,040 548 3,083 505 512 0.9 99.5 Burlington, NJ 2,298 2,330 15,113 1,326 836 2.5 Ulster, NY 2,328 3,818 8,417 1,025 1,235 1.9 Sullivan, NY 1,200 612 2,875 625 544 1.0 Greene, NY 936 3,836 7,511 375 503 0.9 Columbia, NY 1,018 585 3,497 420 574 0.8 Delaware, NY 996 879 2,705 496 475 0.8 

### Applied to New York, this process identifies Suffolk, Nassau, Queens, New York, Orange, Kings, Westchester, and Dutchess as having elevated emissions relative to the remainder of the C/MSA. Applied to New Jersey, the process identifies Middlesex, Bergen, Monmouth, Essex, Ocean, Mercer, Hudson, Union, and Morris as having elevated emissions relative to the remainder of the C/MSA. Putnam, Sussex, and Ocean Counties do not have any significant point sources.

### 6- 27 Factor 2: Air quality
County PM2.5 2001- 2003 Design Value (_g/m3) Suffolk, NY 12.3 Nassau, NY 12.4 Queens, NY 13.6 New York, NY 17.7 Orange, NY 11.6 Kings, NY 14.9 Middlesex, NJ 12.7 Fairfield, CT 13.3 New Haven, CT 16.7 Westchester, NY 12.5 Bergen, NJ 13.8 Monmouth, NJ No monitor Essex, NJ 14.5 Ocean, NJ 11.7 Mercer, NJ 14.0 Hudson, NJ 14.8 Union, NJ 15.7 Morris, NJ 12.6 Dutchess, NY 11.0 Bronx, NY 15.8 Rockland, NY NA Somerset, NJ No monitor Passaic, NJ 13.3 Richmond, NY 12.2 Hunterdon, NJ No monitor Sussex, NY No monitor Warren, NJ No monitor Putnam, NY No monitor

### 6- 28 Ulster, NY No monitor Sullivan, NY No monitor Greene, NY No monitor Columbia, NY No monitor Delaware, NY No monitor



### All counties with design values above the standard have been recommended for nonattainment designation by New York and New Jersey. Suffolk, Nassau, Westchester, Queens, Kings, Westchester, and Richmond counties in New York had design values approaching the standard. Middlesex, Bergen, Essex, Mercer, Hudson, Morris, and Passaic had design values approaching the standard in New Jersey. The following New York counties are adjacent to counties with violating monitors: Westchester, Queens, Kings, and Richmond. The following New Jersey counties are adjacent to counties with violating monitors: Bergen, Essex, Hudson, Middlesex, Somerset, and Morris. Factor 3: Population/ Population density
County 2002 Population 2002 Population Density (population per sq mi) Suffolk, NY 1,458,655 1601 Nassau, NY 1,344,892 4686 Queens, NY 2,237,815 20,530 New York, NY 1,546,856 55,245 Orange, NY 356,773 437 Kings, NY 2,488,194 35,045 Middlesex, NJ 775,549 2,494 Westchester, NY 937,279 2165 Bergen, NJ 895,091 3,825 Monmouth, NJ 629,836 1,334 Essex, NJ 798,301 6,336 Ocean, NJ 537,065 844 Mercer, NJ 359,463 1,591 Hudson, NJ 611,439 13,009 Union, NJ 530,763 5,153 Morris, NJ 478,730 1,021

### 6- 29 Dutchess, NY 287,752 359 Bronx, NY 1,354,068 32,240 Rockland, NY 291,835 1677 Richmond, NY 457,383 7,752 Somerset, NJ 309,886 1,016 Passaic, NJ 496,646 2,685 Ulster, NY 179,986 160 Hunterdon, NJ 125, 795 293 Sussex, NJ 148,680 285 Warren, NJ 107,537 300 Putnam, NY 98,257 424 Sullivan, NY 74,273 77 Greene, NY 48,538 75 Columbia, NY 63,532 100 Delaware, NY 47,302 33


### Due to their large concentrated population and relative land area size, the counties within New York City (i.e., New York, Bronx, Kings, Queens, and Richmond counties) are high for this factor (i.e., high population densities, high population relative to the remainder of the CMSA and adjacent counties). Suffolk, Nassau, and Westchester counties in New York; and Middlesex, Essex, Hudson, and Union in New Jersey also score moderately high for this factor. Factor 4: Traffic and commuting patterns
County VMT1 (1000 miles) #Commuters to New York Co. #Commuters to Bronx Co. # Commuters to Union Co. # Commuters to New Haven, CT Suffolk, NY 7,414 41,121 2,614 180 113 Nassau, NY 6,875 94,485 6,274 187 90 Queens, NY 10,441 346,268 18,373 780 138 New York, NY 7,961 631,132 20,775 967 178 Orange, NY 3,628 9,610 2,414 147 29 Kings, NY 12,313 341,155 11,365 1,567 112 Middlesex, NJ 5,794 25,765 355 26,653 51 Westchester, NY 4,964 79,643 27,053 327 343

### 6- 30 Bergen, NJ 6,732 61,253 5,353 5,124 74 Monmouth, NJ 5,146 22,425 313 8,319 32 Essex, NJ 6,356 28,076 782 24,052 10 Ocean, NJ 3,641 2,964 115 4,567 13 Mercer, NJ 3,869 5,654 147 1,291 15 Hudson, NJ 4,518 58,423 1,214 6,740 23 Union, NJ 4,034 16,305 417 113,263 11 Morris, NJ 3,939 11,516 268 8,755 15 Dutchess, NY 2,905 3,963 1,085 22 199 Bronx, NY 6,440 159,664 168,903 586 56 Rockland, NY 1,413 17,025 6,245 350 56 Somerset, NJ 2,209 6,243 87 11,835 14 Passaic, NJ 3,568 8,402 473 2,943 5 Richmond, NY 2,030 53,249 1,095 1,486 11 Ulster, NY 1,850 1,565 1,565 0 11 Fairfield, CT 7,889 24,831 1,258 56 21,900 New Haven, CT 6,989 1,584 183 23 290,098 Hartford, CT 8,105 460 36 11 16,948 New London, CT 2,958 126 19 9 1,638 Hunterdon, NJ 1,893 1,176 7 3,069 0 Sussex, NJ 1,323 1,449 94 967 13 Warren, NJ 1,473 562 5 991 0 Putnam, NY 781 4,416 2,021 30 181 Sullivan, NY 683 829 110 6 0 Greene, NY 643 305 10 8 0 Columbia, NY 754 610 37 0 4 Delaware, NY 508 248 9 0 4 Note: CT counties shown for comparison purposes

1Vehicle Miles Traveled within county in 2002 

### The largest number of commuters to counties with violating monitors in New York and New Jersey are from the following counties within New York City: New York, Queens, Kings, and

### 6- 31 the Bronx. A slightly smaller but still significant number of commuters are also traveling into New York, Bronx, and Union counties from Nassau, Westchester, Suffolk, and Richmond Counties in New York; and Middlesex, Bergen, Monmouth, Essex, Hudson, and Union Counties in New Jersey. The remaining counties in New York and New Jersey have low numbers of commuters to counties in the C/MSA with violating monitors. Suffolk, Nassau, Queens, New York, Kings, and the Bronx in New York; and Middlesex, Bergen, and Essex in New Jersey score the highest for VMT when compared to the rest of the CMSA and adjacent areas. Both New York and New Jersey counties have a very low number of commuters to New Haven County, CT. Factor 5: Expected growth
County 2002 Population % growth (90-00) Population Growth (90-00) Suffolk, NY 1,458,655 7 97,505 Nassau, NY 1,344,892 4 47,196 Queens, NY 2,237,815 14 277,781 New York, NY 1,546,856 3 49,659 Orange, NY 356,773 11 33,720 Kings, NY 2,488,194 7 164,662 Middlesex, NJ 775,549 12 78,382 Westchester, NY 937,279 6 48,593 Bergen, NJ 895,091 7 58,738 Monmouth, NJ 629,836 11 62,177 Essex, NJ 798,301 2 15,427 Ocean, NJ 537,065 18 77,713 Mercer, NJ 359,463 8 24,937 Hudson, NJ 611,439 10 55,876 Union, NJ 530,763 6 28,722 Morris, NJ 478,730 12 48,859 Dutchess, NY 287,752 8 20,688 Bronx, NY 1,354,068 11 128,861 Rockland, NY 291,835 8 21,278

### 6- 32 Somerset, NJ 309,886 24 57,211 Passaic, NJ 496,646 8 35,989 Richmond, NY 457,383 17 64,751 Ulster, NY 179,986 8 12,445 Hunterdon, NJ 125,795 13 14,213 Sussex, NJ 148,680 10 13,223 Warren, NJ 107,537 12 10,830 Putnam, NY 98,257 14 11,804 Sullivan, NY 74,273 7 4,689 Greene, NY 48,538 8 3,456 Columbia, NY 63,532 0 112 Delaware, NY 47,302 2 830



### Based upon an analysis of this factor, the counties of Queens, Kings, the Bronx, and Somerset counties have been identified as experiencing either significant recent growth on a percentage or absolute basis. Orange, Richmond, Ocean, Suffolk, Middlesex, Monmouth, Hudson, Morris, Richmond, Hunterdon, Sussex, Warren, and Putnam counties experienced moderate growth. The remaining counties have very low growth. Factor 6: Meteorology This factor did not play a significant role in the decision making process for Queens, New York, Kings, Bronx, Richmond in New York. Meteorology did not play a significant role in the decision making process for New Jersey Counties with the exception of Ocean County.

County Prevailing Wind Direction %

NW SW SE NE New York, NY 34 29 11 26 Bronx, NY 33 30 12 25 Union, NJ 31 32 14 23 New Haven, CT 34 30 13 24


### The prevailing wind direction to counties with violating monitors is predominantly from the northwest, southwest, and northeast. Analysis of pollution roses and back trajectories to New Haven, CT showed a contribution from Suffolk, Nassau, Orange, Westchester, Dutchess, Rockland, and Ulster Counties.

### 6- 33 EPA REMSAD (Regional Modeling System for Aerosols and Deposition) model used during the analysis for the Interstate Air Quality Rule demonstrated that the maximum contribution from New York State to the monitor in New Haven was 0.85 _g/m3

### , or above the 0.15 _g/m3

### threshold for determining whether emissions in a State make a significant contribution to PM2.5 nonattainment in another state. Ocean County had a negligible contribution based upon the analysis of pollution roses and back trajectory analysis to New York City. Analysis of back trajectories (HYSPLIT model) calculated and plotted for the thirty-nine high PM days in New York City indicate that emissions from Ocean County have a very low impact on New York City. Back trajectories passed through Ocean County on only two days. Further review of these trajectories indicate the following: August 28, 2001 Two out of the four trajectories plotted for this day passed through Ocean County. It is not likely that Ocean County was the source of the high PM on this day. The analysis from the Bronx speciation monitor showed that the particulate matter was mostly sulfate. Ocean County is a very low emitter of sulfur dioxide (i.e. 1,500 released in 2001) October 6, 2000 One out of four trajectories plotted for this day passed through Ocean County. This trajectory also passed through areas with a heavy concentration of point sources in the Camden/ Philadelphia and northeastern New Jersey areas before entering New York City from the west. Factor 7: Geography/topography The area does not have any geographical or topographical boundaries limiting its airshed in the
areas.
Factor 8: Jurisdictional boundaries EPA is striving to achieve consistency with the 8-hour ozone nonattainment areas for purposes of state air quality planning. Although this factor is considered as part of the analysis, this factor is not a dominant factor in the decision making process. All counties in New Jersey were designated nonattainment for the 8-hour ozone standard on April 15, 2004. All counties within the New York portion of the NY-NJ-CT-PA C/MSA and adjacent counties, with the exception of Ulster, Sullivan, Columbia, and Delaware, were also designated nonattainment for ozone.

Factor 9: Level of control of emission sources This factor does not play a significant role in the decision making process. The level of control of emission sources is reflected in factor 1. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States

### 6- 34 New Jersey EPA does not intend on modifying its recommendations concerning nonattainment designations and boundaries which were listed in the June 29, 2004 letter to New Jersey. EPA provides further explanation for not including Cape May, Cumberland, Salem, Ocean, Sussex, Hunterdon and Warren counties in New Jersey in this section. Cape May. EPA is recommending that Cape May County be designated attainment/unclassifiable. Although the county does not have a PM2.5 monitor, the nearby monitor in Atlantic County is attaining. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the Philadelphia metropolitan area: the county has low emissions, low population and low population density, low growth, low VMT and a low number of commuters to nonattainment counties within the metropolitan area. Analysis of meteorology (pollution and wind roses, and back trajectories) also shows low impact to counties with nonattainment monitors.

Cumberland.EPA is recommending that Cumberland County be designated as attainment/unclassifiable. Although the county does not have a PM2.5 monitor, nearby monitors in Atlantic and Gloucester Counties are attaining. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the Philadelphia metropolitan area: the county has low emissions, low growth, low population and population density, low VMT and a low number of commuters to nonattainment counties within the metropolitan area. Analysis of meteorology (pollution and wind roses, and back trajectories) also shows low impact to counties with nonattainment monitors.

Salem.EPA is recommending that Salem County be designated as attainment/unclassifiable. Although the county does not have a PM2.5 monitor, the nearby monitor in Gloucester County is attaining. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the Philadelphia metropolitan area: the county has low overall emissions, low population and population density, low growth, low VMT and a low number of commuters to nonattainment counties within the metropolitan area.

Ocean.EPA is recommending that Ocean County be designated attainment/unclassifiable. The PM2.5 monitor in the county is monitoring below the standard. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the New York and Philadelphia metropolitan areas: the county does not have significant point sources and has a low number of commuters to nonattainment counties within the New York and Philadelphia metropolitan areas. Analysis of meteorology (pollution and wind roses, and back trajectories) shows low impact from emissions to nearby counties with nonattainment monitors.

Sussex. EPA is recommending that Sussex County be designated attainment/unclassifiable. Although the county does not have a PM2.5 monitor, the nearby monitors in Passaic and Morris counties are attaining. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the New York metropolitan area: the county has very

### 6- 35 low emissions, low growth, low population and population density, low VMT and a low number of commuters to nonattainment counties within the metropolitan area.

Hunterdon. EPA is recommending that Hunterdon County be designated attainment/unclassifiable. Although the county does not have a PM2.5 monitor, the nearby monitors in Morris County are attaining. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the New York metropolitan area: the county has very low emissions, low population and population density, low VMT and a low number of commuters to nonattainment counties within the metropolitan area.

Warren. EPA is recommending that Warren County be designated attainment/unclassifiable. The PM2.5 monitor in the county is monitoring below the standard. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the New York metropolitan area: the county has very low emissions, low population and population density, low VMT and a low number of commuters to nonattainment counties within the metropolitan area.

New York EPA does not intend on modifying its recommendations concerning nonattainment designations and boundaries which were listed in the June 29, 2004 letter to New York. EPA provides further explanation for nonattainment designations for Orange and Rockland Counties. EPA also provides further explanation for not including Dutchess, Putnam, Ulster counties in the New York metropolitan nonattainment area. Orange. EPA has determined that the violating monitor in New Haven County is not representative of community exposure. Notwithstanding that fact, EPA believes that Orange County contributes to PM 2.5 levels in the New York metropolitan area. Specifically, EPA has determined that emissions from Orange County are significant.. EPA also took into consideration that there are large power plants located in the county and that they contribute to the problem in the New York metropolitan area. Rockland. EPA has determined that the violating monitor in New Haven County is not representative of community exposure. Notwithstanding that fact, EPA believes that Rockland County contributes to PM 2.5 levels in the New York metropolitan area. Specifically, EPA has determined that the number of commuters from Rockland County into the New York metropolitan area are significant. EPA also took into consideration that there are large power plants located in the county and that they contribute to the problem in the New York metropolitan area.

Dutchess. EPA is recommending that Dutchess County be designated attainment/unclassifiable. The PM2.5 monitor in the county is monitoring below the standard. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the New York: the county has a low population and population density, low growth, low VMT and a

### 6- 36 low number of commuters to nonattainment counties within the metropolitan area. Analysis of meteorology (pollution and wind roses, and back trajectories) shows low impact from emissions to nearby counties with nonattainment monitors. Putnam. EPA is recommending that Putnam be designated attainment/unclassifiable. Although the county does not have a PM2.5 monitor, the nearby monitor in Westchester and Orange counties are attaining. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the New York metropolitan area: the county has very low emissions, a low population and population density, low VMT and a low number of commuters to nonattainment counties within the metropolitan area. Analysis of meteorology (pollution and wind roses, and back trajectories) shows low impact from emissions to nearby counties with nonattainment monitors.

Ulster

.EPA is recommending that Ulster be designated attainment/unclassifiable. Although the county does not have a PM2.5 monitor, the nearby monitors in Dutchess and Orange counties are attaining. Analysis of the 9 factors provides sufficient evidence that the county does not contribute to nonattainment monitors in the New York metropolitan area: the county has low emissions, a low population and population density, low growth, low VMT and a low number of commuters to nonattainment counties within the metropolitan area. Analysis of meteorology (pollution and wind roses, and back trajectories) shows low impact from emissions to nearby counties with nonattainment monitors.

### 6-37 

## 6.3 Region 3 Nonattainment Areas

6.3.1 EPA 9-Factor Analyses for Delaware for the Designation of Nonattainment Areas for PM2

## .5

Enclosure A The fourth column of the following table identifies the individual county within Delaware that EPA intends to designate as nonattainment.

Area Delaware Counties in 1999 Metropolitan Statistical Area State of Delaware Recommendation PM2.5 Designation

Philadelphia PA-NJ-DE-MD New Castle New Castle* New Castle
Total Number of Counties 1 1 1


### * Delaware recommended New Castle County not be included as part of the Philadelphia CMSA State Summary The State of Delaware, in a Governor Minner letter datedFebruary, 17, 2004, recommended New Castle County as nonattainment. The state suggested that New Castle should be designated as a separate nonattainment area from the Philadelphia metropolitan area. Philadelphia Area- New Castle County

Discussion The Philadelphia Metropolitan Statistical Area (MSA) is comprised of five counties in Pennsylvania, New Castle County in Delaware, and additional counties in Maryland and New Jersey. The table below lists the counties in the MSA. Four counties in this MSA have monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Philadelphia MSA is considered a presumptive nonattainment area. New Castle County monitored a violation. Philadelphia County monitored 16.4 _g/m3

### for the time period 2001-2003. This value is being considered the Design Value for the Philadelphia nonattainment area. The State of Delaware recommended New Castle County, part of the Philadelphia MSA, be designated as a separate nonattainment area. EPA has reviewed the State's recommendations and intends, based on the national guidance and the information reviewed, to designate New Castle County as nonattainment with the Philadelphia nonattainment area.

### 6-38 Summary of Evaluation of the Philadelphia MSA The New Jersey counties have been evaluated and are discussed in a separate document prepared by Region 2. New Castle County, DE and Chester and Montgomery Counties in Pennsylvania have moderate to high emissions contribution to the area, based on the weighted emissions factor. Therefore, EPA has reviewed these counties based on the remaining 8 factors to determine the appropriate designation. The population density, growth and commuting patterns when compared to the core MSA counties in this area support including these counties in the nonattainment area. Existing EPA National Policy suggests retaining at least the MSA boundaries as the nonattainment area. The tables below summarize the data used to determine the designation status of New Castle County. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Although additional information was provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating New Castle County as part of the Philadelphia MSA.

PHILADELPHIA, PA MSA Status of Counties: Alphabetical by State

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

3 DE New Castle NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 MDCecil Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJ Atlantic Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJ Burlington Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJ Camden Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJ Cape May Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJ Cumberland Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJ Gloucester Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJ Salem Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PA Bucks NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PA Chester Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PA Delaware NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PA Montgomery Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PA Philadelphia NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD

### 6-39 SUMMARY OF FACTOR 1: EMISSIONS PHILADELPHIA, PA MSA

** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOC AmmCarbonCrustalWeighted Emissions Factor PM2.5 Designation 3 DE New Castle 4,55861,49934,64024,0882,6052,276 1,645 18.6 Nonattainment 3 PA Philadelphia 3,94416,86155,01150,4393,5062,116 1,200 14.0 Nonattainment 3 PA Delaware 3,17324,88233,25919,071903 1,458 1,225 11.1 Nonattainment 3 PA Montgomery 3,9108,721 21,19132,5451,2931,905 1,700 8.7 Nonattainment 3 PA Chester 3,71611,39116,90917,6972,2671,228 2,226 6.9 Nonattainment 3 PA Bucks 3,1006,870 16,85223,0241,1241,443 1,444 6.8 Nonattainment 2 NJ Gloucester 1,9099,154 21,84915,087741 1,035 697 6.5 Nonattainment 2 NJ Camden 2,1514,120 17,02520,904887 1,286 727 5.9 Nonattainment 2 NJ Burlington 2,2982,330 15,11318,139913 1,326 836 5.6 Nonattainment 2 NJ Cape May 2,15714,5787,894 11,886206 938 1,044 5.5 Attainment 2 NJ Atlantic 1,4041,905 8,676 11,906437 773 563 3.3 Attainment 2 NJ Cumberland 1,3741,941 7,054 9,279 423 638 669 2.8 Attainment 2 NJ Salem 1,2434,485 5,457 8,229 534 487 653 2.6 Attainment 3 MD Cecil 950 948 5,502 4,441 505 401 518 1.8 Attainment

### 6-40 SUMMARY OF FACTOR 2: AIR QUALITY PHILADELPHIA MSA ** Counties Listed by Highest DV **Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01

3 PA Philadelphia 16.4NA16.8NA16.6NA 3 DE New Castle 16.2NA16.5NA16.6NA 3 PA Delaware 15.6NA15.7NA15.0a 3 PA Chester 15.1na14.6a 2 NJ Camden 14.6a 14.8a 14.6a 3 PA Bucks 14.6A 14.3a 13.4a 3 PA Montgomery 14.3A 14.2A 13.8a 2 NJ Gloucester 13.8a 14.2A 14.3a 3 MD Cecil 13.0a 13.4A 12.5a 2 NJ Atlantic 11.6a 11.4a 11.2a 2 NJ Burlington No Monitor 2 NJ Cape May No Monitor 2 NJ Cumberland No Monitor 2 NJ Salem No Monitor

SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF URBANIZATION PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Population Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02PM2.5 Designation

3 PA Philadelphia 1,492,231 135 11,054 Nonattainment 3 PA Montgomery 766,517 483 1,587 Nonattainment 3 PA Bucks 610,440 608 1,004 Nonattainment 3 PA Delaware 553,435 184 3,008 Nonattainment 3 DE New Castle 512,370 426 1,203 Nonattainment 2 NJ Camden 511,957 222 2,306 Nonattainment 3 PA Chester 450,160 756 595 Nonattainment 2 NJ Burlington 437,871 805 544 Nonattainment 2 NJ Gloucester 262,049 325 806 Nonattainment 2 NJ Atlantic 259,423 561 462 Attainment 2 NJ Cumberland 147,768 489 302 Attainment 2 NJ Cape May 102,013 255 400 Attainment 3 MD Cecil 90,335 348 260 Attainment 2 NJ Salem 64,438 338 191 Attainment

### 6-41 SUMMARY FACTOR 4: COMMUTING PATTERNS PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Number of Commuters VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number PM2.5 Designation

3 PA Philadelphia 10,213 23 129,902 Nonattainment 3 PA Montgomery 4,677 32 120,472 Nonattainment 3 PA Delaware 3,513 44 111,594 Nonattainment 2 NJ Camden 4,332 43 98,432 Nonattainment 3 PA Bucks 3,830 31 93,563 Nonattainment 3 PA Chester 3,128 32 70,486 Nonattainment 2 NJ Gloucester 2,312 51 62,141 Nonattainment 2 NJ Burlington 3,748 29 60,278 Nonattainment 3 DE New Castle 4,957 11 27,598 Nonattainment 3 MD Cecil 1,340 39 16,195 Attainment 2 NJ Atlantic 2,236 13 14,237 Attainment 2 NJ Salem 734 48 13,922 Attainment 2 NJ Cumberland 1,166 22 12,911 Attainment 2 NJ Cape May 749 26 11,360 Attainment

SUMMARY FACTOR 5: EXPECTED GROWTH PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Growth Rate Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 PM2.5 Designation

3 MD Cecil 90,335 14,604 20 60 4 Attainment 3 PA Chester 450,160 57,105 15 785 25 Nonattainment 3 DE New Castle 512,370 58,319 13 1,273 26 Nonattainment 2 NJ Atlantic 259,423 28,225 13 805 36 Nonattainment 2 NJ Gloucester 262,049 24,591 11 262 11 Nonattainment 3 PA Montgomery 766,517 71,986 11 1,344 29 Nonattainment 3 PA Bucks 610,440 56,461 10 957 25 Nonattainment 2 NJ Cape May 102,013 7,237 8 179 24 Nonattainment 2 NJ Burlington 437,871 28,328 7 388 10 Nonattainment 2 NJ Cumberland 147,768 8,385 6 227 19 Attainment 2 NJ Camden 511,957 6,108 1 782 18 Attainment 3 PA Delaware 553,435 3,213 1 1,022 29 Attainment 2 NJ Salem 64,438 -1,009 -2 139 19 Attainment 3 PA Philadelphia 1,492,231 -68,027 -4 2,763 27 Nonattainment

### 6-42 Factor 8: Jurisdictional Boundaries The Philadelphia MSA was designated Subpart (Basic) 1 nonattainment for the 8-hour ozone standard. Delaware has provided information supporting a designation as a separate area. Based on EPA guidance issued April 1, 2003, EPA intends to designate New Castle County with the Philadelphia MSA.

Factor 9: Level of Control of emission sources There are many sources in the metropolitan area; the level of control of sources was not a significant issue.

6.3.2 EPA 9-Factor Analyses for the District of Columbia for the Designation of Nonattainment Areas for PM2.5

Enclosure A The fourth column of the following table identifies the individual counties and cities that EPA intends to designate as nonattainment.

### 6-43 Area Washington DC MSA in 1999 Metropolitan Statistical Area District of Columbia/Maryland/ Virginia Recommendations EPA Designating Nonattainment

Washington, DC MSA (Part of the Washington-Baltimore CMSA) District of Columbia District of Columbia District of Columbia

Maryland portion of the Washington DC MSA Calvert Charles Frederick Montgomery Prince Georges Prince Georges Charles Frederick Montgomery Prince Georges Virginia portion of the Washington DC MSA Alexandria (City) Arlington Clarke Culpeper Fairfax Fairfax (City) Falls Church (City) Fauquier Fredericksburg King George Loudoun Manassas (City) Manassas Park (City) Prince William Spotsylvania Stafford Warren None Recommended Arlington Alexandria (City) Fairfax Fairfax (City) Falls Church (City) Loudoun Manassas (City) Manassas Park (City) Prince William

Total Number of Areas 23 2 14



### Enclosure B Washington DC Area State Summary Washington DC’s recommendation was submitted on February 13, 2004, by Mayor Anthony Williams. Washington DC recommended that the entire MSA be designated as nonattainment.

Discussion The Baltimore-Washington CMSA has been split into three smaller MSA areas for planning purposes and for consistency with the 8-hour ozone designations. The Washington DC MSA is comprised of 23 areas: 5 in Maryland, 17 in Virginia, and the District of Columbia. Washington DC and Prince Georges County in Maryland have monitored violations of the fine particulate (PM2.5) standard of 15.0 _g/m3

### . Based on the monitored violations, the Washington DC MSA is considered a presumptive nonattainment area. The Washington DC monitor is intended to be used as the Design Value monitor for this MSA.

### 6-44 EPA’s recommendations for the Maryland and Virginia portions of the MSA are summarized in the above table. Summary of Evaluation EPA agrees with Washington DC’s recommendation of nonattainment for the District based on the air quality data for the years 2001-2003. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating the District of Columbia as part of the Washington DC nonattainment area. 6.3.3 EPA 9-Factor Analyses for Maryland for the Designation of Nonattainment Areas for PM2.5 The fourth column of the following table identifies the counties within Maryland that EPA intends to designate as nonattainment.

Area Maryland Counties in 1999 Metropolitan Statistical Area State of Maryland Recommendation EPA Designating Nonattainment Baltimore MSA (Part of Washington-Baltimore CMSA) Anne Arundel Baltimore City Baltimore Carroll Harford Howard Queen Anne’s Anne Arundel Baltimore City Baltimore Anne Arundel Baltimore City Baltimore Carroll Harford Howard Washington DC MSA (Part of Washington- Baltimore CMSA Calvert Charles Frederick Montgomery Prince Georges Prince Georges Charles Frederick Montgomery Prince Georges Hagerstown-Martinsburg * Washington (Also Berkeley, WV and Morgan, WV) None Washington

Total number of areas in Maryland 13 4 11

* Washington County was included as part of the Hagerstown-Martinsburg 2003 CBSA. 

### Enclosure B State Summary

### 6-45 Governor Robert Ehrlich, Jr. submitted Maryland’s initial recommendation on February 23, 2004. The submission identified two options for designation. The first option recommended 14 counties as nonattainment and 10 counties as attainment, consistent with the ozone nonattainment areas. The second option recommended only four nonattainment areas. Maryland’s subsequent letter of May 28, 2004, from Thomas Snyder, recommended Option 2 as the State’s preferred option. Based on the air quality data for the years 2001-2003, there are three presumptive fine particulate (PM2.5) nonattainment areas consisting of 13 counties in Maryland. EPA agrees with Maryland’s recommended designation of attainment for the Cecil County portion of the Philadelphia CMSA. However, in addition to the four counties the State has recommended to be designated as nonattainment, EPA recommends that three additional counties in the Baltimore MSA, three additional counties in the Washington DC MSA, and one additional county in the Hagerstown-Martinsburg CBSA also be designated as nonattainment. The following discussion provides EPA’s rationale for considering the modification to Maryland’s recommendation. 6.3.3.1 Philadelphia Area

Discussion Cecil County is part of the Philadelphia Area presumptive nonattainment area. Maryland’s revised recommendation for the Philadelphia CMSA included Cecil County as attainment for the PM2.5 standard. Summary of Evaluation Cecil County has monitored attainment of 13.0 _g/m3

### compared to the National Ambient Air Quality Standard of 15.0 _g/m3

### . A review of the remaining factors indicates that the county is well below the other counties of the Philadelphia Area, and provides sufficient evidence to modify the nonattainment boundary to exclude Cecil County.

PHILADELPHIA, PA MSA Status of Counties: Alphabetical by State

EPA RegSTCOUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

3 DENew Castle NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 MDCecil Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJAtlantic Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJBurlington Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJCamden Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJCape May Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJCumberland Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJGloucester Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJSalem Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PABucks NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD

### 6-46 3 PAChester Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PADelaware NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PAMontgomeryAttainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PAPhiladelphia NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD

### 6-47 SUMMARY OF FACTOR 1: EMISSIONS PHILADELPHIA, PA MSA

** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOC AmmCarbonCrustalWeighted Emissions Factor PM2.5 Designation 3 DE New Castle 4,55861,49934,64024,0882,6052,276 1,645 18.6 Nonattainment 3 PA Philadelphia 3,94416,86155,01150,4393,5062,116 1,200 14.0 Nonattainment 3 PA Delaware 3,17324,88233,25919,071903 1,458 1,225 11.1 Nonattainment 3 PA Montgomery 3,9108,721 21,19132,5451,2931,905 1,700 8.7 Nonattainment 3 PA Chester 3,71611,39116,90917,6972,2671,228 2,226 6.9 Nonattainment 3 PA Bucks 3,1006,870 16,85223,0241,1241,443 1,444 6.8 Nonattainment 2 NJ Gloucester 1,9099,154 21,84915,087741 1,035 697 6.5 Nonattainment 2 NJ Camden 2,1514,120 17,02520,904887 1,286 727 5.9 Nonattainment 2 NJ Burlington 2,2982,330 15,11318,139913 1,326 836 5.6 Nonattainment 2 NJ Cape May 2,15714,5787,894 11,886206 938 1,044 5.5 Attainment 2 NJ Atlantic 1,4041,905 8,676 11,906437 773 563 3.3 Attainment 2 NJ Cumberland 1,3741,941 7,054 9,279 423 638 669 2.8 Attainment 2 NJ Salem 1,2434,485 5,457 8,229 534 487 653 2.6 Attainment 3 MD Cecil 950 948 5,502 4,441 505 401 518 1.8 Attainment

SUMMARY OF FACTOR 2: AIR QUALITY PHILADELPHIA MSA ** Counties Listed by Highest DV **Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01 PM2.5 Designation

3 PA Philadelphia 16.4NA16.8NA16.6NANonattainment 3 DE New Castle 16.2NA16.5NA16.6NANonattainment 3 PA Delaware 15.6NA15.7NA15.0a Nonattainment 3 PA Chester 15.1na14.6a Nonattainment 2 NJ Camden 14.6a 14.8a 14.6a Nonattainment 3 PA Bucks 14.6A 14.3a 13.4a Nonattainment 3 PA Montgomery 14.3A 14.2A 13.8a Nonattainment 2 NJ Gloucester 13.8a 14.2A 14.3a Nonattainment 3 MD Cecil 13.0a 13.4A 12.5a Attainment 2 NJ Atlantic 11.6a 11.4a 11.2a Attainment 2 NJ Burlington No Monitor Nonattainment 2 NJ Cape May No Monitor Attainment 2 NJ Cumberland No Monitor Attainment 2 NJ Salem No Monitor Attainment

### 6-48 SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF URBANIZATION PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Population Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02PM2.5 Designation

3 PA Philadelphia 1,492,231 135 11,054 Nonattainment 3 PA Montgomery 766,517 483 1,587 Nonattainment 3 PA Bucks 610,440 608 1,004 Nonattainment 3 PA Delaware 553,435 184 3,008 Nonattainment 3 DE New Castle 512,370 426 1,203 Nonattainment 2 NJ Camden 511,957 222 2,306 Nonattainment 3 PA Chester 450,160 756 595 Nonattainment 2 NJ Burlington 437,871 805 544 Nonattainment 2 NJ Gloucester 262,049 325 806 Nonattainment 2 NJ Atlantic 259,423 561 462 Attainment 2 NJ Cumberland 147,768 489 302 Attainment 2 NJ Cape May 102,013 255 400 Attainment 3 MD Cecil 90,335 348 260 Attainment 2 NJ Salem 64,438 338 191 Attainment

SUMMARY FACTOR 4: COMMUTING PATTERNS PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Number of Commuters VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number PM2.5Designation

3 PA Philadelphia 10,213 23 129,902 Nonattainment 3 PA Montgomery 4,677 32 120,472 Nonattainment 3 PA Delaware 3,513 44 111,594 Nonattainment 2 NJ Camden 4,332 43 98,432 Nonattainment 3 PA Bucks 3,830 31 93,563 Nonattainment 3 PA Chester 3,128 32 70,486 Nonattainment 2 NJ Gloucester 2,312 51 62,141 Nonattainment 2 NJ Burlington 3,748 29 60,278 Nonattainment 3 DE New Castle 4,957 11 27,598 Nonattainment 3 MD Cecil 1,340 39 16,195 Attainment 2 NJ Atlantic 2,236 13 14,237 Attainment 2 NJ Salem 734 48 13,922 Attainment 2 NJ Cumberland 1,166 22 12,911 Attainment 2 NJ Cape May 749 26 11,360 Attainment

### 6-49 SUMMARY FACTOR 5: EXPECTED GROWTH PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Growth Rate Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 PM2.5 Designation

3 MD Cecil 90,335 14,604 20 60 4 Attainment 3 PA Chester 450,160 57,105 15 785 25 Nonattainment 3 DE New Castle 512,370 58,319 13 1,273 26 Nonattainment 2 NJ Atlantic 259,423 28,225 13 805 36 Nonattainment 2 NJ Gloucester 262,049 24,591 11 262 11 Nonattainment 3 PA Montgomery 766,517 71,986 11 1,344 29 Nonattainment 3 PA Bucks 610,440 56,461 10 957 25 Nonattainment 2 NJ Cape May 102,013 7,237 8 179 24 Nonattainment 2 NJ Burlington 437,871 28,328 7 388 10 Nonattainment 2 NJ Cumberland 147,768 8,385 6 227 19 Attainment 2 NJ Camden 511,957 6,108 1 782 18 Attainment 3 PA Delaware 553,435 3,213 1 1,022 29 Attainment 2 NJ Salem 64,438 -1,009 -2 139 19 Attainment 3 PA Philadelphia 1,492,231 -68,027 -4 2,763 27 Nonattainment



### Factor 8: Jurisdictional Boundaries The entire Philadelphia MSA has recently been designated nonattainment for the 8-hour ozone standard. Cecil County was included with the Philadelphia MSA in the ozone designation.

Factor 9: Level of Control of emission sources EPA identified large sources greater than 1000 tons per year for any pollutant and evaluated its distance to a violating monitor for fine particulate.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Cecil County is not a significant contributor to the Philadelphia nonattainment area. Therefore, EPA is designating Cecil County, MD as attainment.

### 6-50 6.3.3.2 Baltimore Area

Discussion The Baltimore Metropolitan Statistical Area (MSA) is part of the Washington DC Consolidated Metropolitan Statistical Area (CMSA). Because of the large size of the CMSA, it has been split into three smaller areas to be more consistent with the ozone designations and to facilitate planning in the areas. Maryland has recommended that the smaller MSA be the basis for the Maryland designations. The Baltimore MSA is comprised of 6 counties and one city: Anne Arundel, Baltimore (City), Baltimore, Carroll, Harford, Howard, and Queen Anne’s. Baltimore County, Anne Arundel County, and Baltimore City have monitored violations of the fine particulate (PM2.5) standard of 15.0 _g/m3

### . Based on the monitored violations, the Baltimore MSA is considered a presumptive nonattainment area. The Baltimore City monitor is intended to be used as the Design Value monitor for this MSA. Maryland’s revised recommendation included only Anne Arundel, Baltimore, and Baltimore (City) as nonattainment. Summary of Evaluation EPA reviewed the 9 factors for the counties within the Metropolitan area as well as counties adjacent to the Metropolitan area in order to determine the appropriate nonattainment area. Based on analysis of the factors, EPA agrees with the State’s recommendation that Queen Anne’s be designated as attainment, and excluded from the presumptive nonattainment area. EPA also agrees with the State that Anne Arundel, Baltimore and Baltimore (City) should be designated as nonattainment; however, EPA intends to designate three additional counties as nonattainment: Carroll, Harford, and Howard. Carroll and Howard counties have low to moderate emissions, and Harford has monitored attainment for 2001 -2003 (13.1 _g/m3

### ). However, these counties have significant population and are the areas showing the highest population growth in the MSA. They also have high commuting into other areas of the metropolitan area. The combined factor analysis shows the potential for these counties to contribute to nonattainment of the area, thus EPA intends to designate them as nonattainment. Carroll, Harford, and Howard have recently been designated as nonattainment for 8-hour ozone.

### 6-51 SUMMARY OF BALTIMORE, MD MSA/ PART OF WASHINGTON DC CMSA

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

3 MD Anne Arundel Nonattainment Nonattainment Baltimore, MD 3 MD Baltimore Nonattainment Nonattainment Baltimore, MD 3 MD Baltimore (City) Nonattainment Nonattainment Baltimore, MD 3 MD Carroll Attainment Nonattainment Baltimore, MD 3 MD Harford Attainment Nonattainment Baltimore, MD 3 MD Howard Attainment Nonattainment Baltimore, MD 3 MD Queen Annes Attainment Attainment Baltimore, MD

SUMMARY OF FACTOR 1: EMISSIONS BALTIMORE, MD MSA ** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOCAmmCarbonCrustalWeighted Emissions Factor/ CMSA 3 MD Baltimore 8,51042,71943,46426,2171,6073,370 3,935 11.8 3 MD Anne Arundel 5,57271,43936,71518,182962 2,228 2,715 9.4 3 MD Baltimore (City) 2,44610,68634,81021,2561,5811,473 726 4.8 3 MD Carroll 2,5633,266 12,1656,312 1,776754 1,517 2.5 3 MD Harford 1,5171,9468,6628,606 1,008754 705 2.4 3 MD Howard 1,1792,7029,9879,467435 776 361 2.4 3 MD Queen Annes 879 428 2,1492,636 1,128289 572 0.9

SUMMARY OF FACTOR 2: AIR QUALITY BALTIMORE MSA Design Values EPA RegST COUNTY '01-'03 '00-'02 '99-'01

3 MD Anne Arundel 15.4 NA15.8 NA15.9 na 3 MD Baltimore 15.3 NA15.1 NA16.0 na 3 MD Baltimore (City) 16.7 NA17.0 NA17.8 NA 3 MD Carroll No Monitor 3 MD Harford 13.1 a 14.0 a 14.5 a 3 MD Howard No Monitor 3 MD Queen Annes No Monitor

### 6-52 SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF URBANIZATION BALTIMORE, MD MSA Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
3 MD Anne Arundel 508,388 416 1,210 3 MD Baltimore 638,614 599 1,286 3 MD Baltimore (City) 770,298 81 7,884 3 MD Carroll 159,025 449 354 3 MD Harford 227,713 440 518 3 MD Howard 260,117 252 1,032 3 MD Queen Annes 42,835 372 115

SUMMARY FACTOR 4: COMMUTING PATTERNS BALTIMORE, MD MSA
VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 MD Anne Arundel 4,394 43 108,856 3 MD Baltimore 6,912 46 172,129 3 MD Baltimore (City) 6,707 37 92,988 3 MD Carroll 1,614 53 41,060 3 MD Harford 2,208 44 49,021 3 MD Howard 2,184 61 82,322 3 MD Queen Annes 514 42 8,681

### 6-53 SUMMARY FACTOR 5: EXPECTED GROWTH BALTIMORE, MD MSA Population VMT EPA Reg ST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 3 MD Anne Arundel 503,388 62,417 15 751 17 3 MD Baltimore 770,298 62,158 9 1,448 21 3 MD Baltimore (City) 638,614 -84,860 -12 1,651 25 3 MD Carroll 159,025 27,525 22 134 8 3 MD Harford 227,713 36,458 20 -28 -1 3 MD Howard 260,117 60,514 32 211 10 3 MD Queen Annes 42,835 6,610 19 171 33 

### Factors 6, 7, 8 and 9 are addressed together with the Washington DC MSA below. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating Anne Arundel, Baltimore City, Baltimore, Carroll, Harford and Howard counties as nonattainment as the Baltimore nonattainment area. 6.3.3.3 Washington DC Area

Discussion As noted above, the Washington DC MSA has been split from the larger Baltimore-Washington CMSA for planning purposes and for consistency with the 8-hour ozone designations. The Washington DC MSA is comprised of 23 areas, five of which are located in Maryland. These counties are: Calvert, Charles, Frederick, Montgomery, and Prince Georges. Washington DC and Prince Georges County have monitored violations of the fine particulate (PM2.5) standard of 15.0 _g/m3

### . Based on the monitored violations, the Washington DC MSA is considered a presumptive nonattainment area. The Washington DC monitor is intended to be used as the Design Value monitor for this MSA. Maryland’s revised recommendation for the Washington DC MSA included only Prince Georges County as nonattainment. Summary of Evaluation EPA reviewed the 9 factors for the counties within the Metropolitan area as well as counties adjacent to the Metropolitan area in order to determine the appropriate nonattainment area. EPA agrees with the State that Calvert County should be designated as attainment. Based on weighted emissions screening, this county has a fairly low contribution to the nonattainment area and

### 6-54 should be excluded from the presumptive nonattainment area. The low levels of the other factors further support this. EPA agrees with the State that Prince Georges should be designated as nonattainment. EPA also intends to recommend that three additional counties be designated as nonattainment: Charles, Frederick, and Montgomery. Charles County has emissions associated with the Chalk Point Power Plant, and along with Frederick, has population and commuting levels that contribute to nonattainment in the MSA. Montgomery County has high population and high commuting levels into the metropolitan area, and has the highest VMT growth in the MSA. The combined factor analysis of these three areas indicates contribution to nonattainment of the MSA.

SUMMARY OF WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

3 DC Washington NonattainmentNonattainmentWashington, DC-MD-VA-WV 3 MD Calvert Attainment Attainment Washington, DC-MD-VA-WV 3 MD Charles Attainment NonattainmentWashington, DC-MD-VA-WV 3 MD Frederick Attainment NonattainmentWashington, DC-MD-VA-WV 3 MD Montgomery Attainment NonattainmentWashington, DC-MD-VA-WV 3 MD Prince Georges NonattainmentNonattainmentWashington, DC-MD-VA-WV 3 MD Washington Attainment NonattainmentHagerstown-Martinsburg 3 VA Alexandria Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Arlington Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Clarke Attainment Attainment Washington, DC-MD-VA-WV 3 VA Culpeper Attainment Attainment Washington, DC-MD-VA-WV 3 VA Fairfax Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Fairfax (City) Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Falls Church Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Fauquier Attainment Attainment Washington, DC-MD-VA-WV 3 VA Fredericksburg Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA King George Attainment Attainment Washington, DC-MD-VA-WV 3 VA Loudoun Attainment Attainment Washington, DC-MD-VA-WV 3 VA Manassas Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Manassas Park Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Prince William Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Spotsylvania Attainment Attainment Washington, DC-MD-VA-WV 3 VA Stafford Attainment Attainment Washington, DC-MD-VA-WV 3 VA Warren Attainment Attainment Washington, DC-MD-VA-WV 3 WV Berkeley NonattainmentNonattainmentHagerstown-Martinsburg** 3 WV Jefferson Attainment Attainment Washington, DC-MD-VA-WV **Note: Berkeley County in West Virginia and Washington County in Maryland are included in the Washington MSA; However, due to existing planning boundaries, Berkeley and Washington will be designated nonattainment in the Hagerstown-Martinsburg Area (2003 CBSA)

### 6-55 SUMMARY OF FACTOR 1: EMISSIONS WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA ** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOC Amm CarbonCrustalWeighted Emissions Factor DC C/MSA 3 MD Montgomery 7,414 41,024 32,890 30,4241,108 3,478 3,254 12.0 3 MD Prince Georges 6,880 44,813 34,698 24,8781,122 3,083 2,918 11.0 3 MD Charles 7,916 79,120 20,928 5,146 204 1,974 4,773 9.0 3 VA Fairfax 3,213 3,428 33,000 37,5331,172 2,201 877 6.8 3 MD Frederick 2,523 10,114 12,701 8,765 2,270 988 1,347 3.4 3 MD Washington 1,822 6,256 13,064 7,379 1,556 713 938 3.2 3 VA Prince William 1,942 22,555 16,359 10,150528 817 881 3.3 3 DC Washington 1,839 8,200 14,823 17,7501,398 895 767 3.0 3 WV Berkeley 1,390 2,554 9,099 4,303 319 558 738 1.8 3 VA Spotsylvania 864 296 4,278 4,625 223 525 316 1.6 3 VA Alexandria 996 15,627 10,693 4,378 280 305 552 1.5 3 VA Loudoun 1,286 530 5,987 6,381 518 466 787 1.5 3 VA Stafford 889 359 5,562 4,591 204 485 378 1.5 3 VA Arlington 577 748 7,460 6,753 1,160 408 139 1.3 3 MD Calvert 870 647 3,146 3,342 153 377 465 1.2 3 VA Fauquier 830 239 4,082 3,711 935 401 409 1.2 3 WV Jefferson 758 906 2,918 2,105 321 255 488 0.8 3 VA Culpeper 488 143 1,818 2,133 441 216 243 0.7 3 VA Warren 345 160 2,441 2,299 190 194 140 0.6 3 VA Clarke 228 68 760 927 230 95 126 0.3 3 VA King George 263 514 1,436 942 107 106 141 0.3 3 VA Manassas 155 52 944 1,021 26 82 60 0.3 3 VA Fairfax (City) 113 39 417 941 28 56 55 0.2 3 VA Fredericksburg 83 108 1,383 1,300 40 55 22 0.2 3 VA Falls Church 59 17 250 580 9 36 20 0.1 3 VA Manassas Park 23 11 247 236 5 13 9 0.0

### 6-56 SUMMARY OF FACTOR 2: AIR QUALITY '01-'03 MSA Design Value = 16.3 Counties Sorted by Highest to Lowest Monitored or Estimated Value Design Values EPA Reg ST COUNTY '01-'03 '00-'02'99-'01

3 MD Prince Georges 17.7na17.4NA17.3na 3 WV Berkeley 16.3NA16.2NA16.0NA 3 DC Washington 15.8NA16.4NA16.6NA 3 VA Arlington 14.6A 14.9A 14.5a 3 MD Washington 14.0A 14.8A 13.5a 3 VA Fairfax 14.1A 13.9A 14.6a 3 VA Loudoun 13.6A 13.8A 13.6a 3 MD Montgomery 12.6A 13.4A 13.5a 3 WV Jefferson No monitor 3 MD Frederick No monitor 3 VA Alexandria No monitor 3 VA Clarke No monitor 3 VA Fauquier No monitor 3 MD Charles No monitor 3 VA Prince William No monitor 3 VA Warren No monitor 3 MD Calvert No monitor 3 VA King George No monitor 3 VA Stafford No monitor 3 VA Spotsylvania No monitor 3 VA Culpeper No monitor 3 VA Fairfax (City) No monitor 3 VA Falls Church No monitor 3 VA Fredericksburg No monitor 3 VA Manassas No monitor 3 VA Manassas Park No monitor

### 6-57 SUMMARY OF FACTOR 3A: POPULATION DENSITY AND DEGREE OF URBANIZATION WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties sorted by highest to lowest Actual Population Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
3 VA Fairfax 997,580 396 2519 3 MD Montgomery 910,156 495 1839 3 MD Prince Georges 833,084 486 1,714 3 DC Washington 570,898 61 9,359 3 VA Prince William 311,892 338 923 3 MD Frederick 209,125 663 315 3 VA Loudoun 204,054 520 392 3 VA Arlington 189,927 26 7305 3 MD Washington 134,246 458 293 3 VA Alexandria 130,804 15 8720 3 MD Charles 129,040 461 280 3 VA Stafford 104,823 270 388 3 VA Spotsylvania 102,570 401 256 3 WV Berkeley 81,262 321 253 3 MD Calvert 80,906 215 376 3 VA Fauquier 59,245 650 91 3 WV Jefferson 44,926 210 214 3 VA Manassas 37,288 10 3729 3 VA Culpeper 36,893 381 97 3 VA Warren 32,910 214 154 3 VA Fairfax (City) 22,055 6 3,676 3 VA Fredericksburg 20,076 11 1,825 3 VA King George 17,657 180 98 3 VA Clarke 13,290 177 75 3 VA Manassas Park 10,909 2 5,455 3 VA Falls Church 10,659 2 5,330

### 6-58 SUMMARY OF FACTOR 3B: POPULATION DENSITY/ DEGREE OF URBANIZATION Counties sorted by highest to lowest Population Density Population & Area EPA Reg ST COUNTY 2002 Area (sq miles)Density '02
3 DC Washington 570,898 61 9,359 3 VA Alexandria 130,804 15 8,720 3 VA Arlington 189,927 26 7,305 3 VA Manassas Park 10,909 2 5,455 3 VA Falls Church 10,659 2 5,330 3 VA Manassas 37,288 10 3,729 3 VA Fairfax (City) 22,055 6 3,676 3 VA Fairfax 997,580 396 2,519 3 MD Montgomery 910,156 495 1,839 3 VA Fredericksburg 20,076 11 1,825 3 MD Prince Georges 833,084 486 1,714 3 VA Prince William 311,892 338 923 3 VA Loudoun 204,054 520 392 3 VA Stafford 104,823 270 388 3 MD Calvert 80,906 215 376 3 MD Frederick 209,125 663 315 3 MD Washington 134,246 458 293 3 MD Charles 129,040 461 280 3 VA Spotsylvania 102,570 401 256 3 WV Berkeley 81,262 321 253 3 WV Jefferson 44,926 210 214 3 VA Warren 32,910 214 154 3 VA King George 17,657 180 98 3 VA Culpeper 36,893 381 97 3 VA Fauquier 59,245 650 91 3 VA Clarke 13,290 177 75

### 6-59 SUMMARY FACTOR 4: COMMUTING PATTERNS WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties sorted by highest VMT VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 VA Fairfax 10,532 46 242,944 3 MD Prince Georges 7,120 60 238,274 3 MD Montgomery 7,398 41 184,513 3 VA Prince William 2,786 65 98,427 3 VA Arlington 1,807 69 79,757 3 DC Washington 3,802 26 67,157 3 VA Alexandria 978 73 56,449 3 VA Loudoun 1,431 57 52,719 3 MD Frederick 2,508 39 40,199 3 MD Charles 1,006 56 34,316 3 VA Stafford 1,430 68 33,083 3 VA Spotsylvania 1,270 57 25,808 3 MD Calvert 848 50 18,711 3 VA Fauquier 1,005 56 15,753 3 VA Manassas 130 75 13,576 3 MD Washington 2,249 22 13,268 3 WV Berkeley 852 34 12,098 3 WV Jefferson 362 51 10,665 3 VA Fairfax (City) 124 76 9,014 3 VA Culpeper 405 40 6,393 3 VA Warren 339 39 6,019 3 VA Fredericksburg 451 54 5,188 3 VA Manassas Park 17 89 4,925 3 VA Falls Church 32 83 4,868 3 VA King George 263 41 3,329 3 VA Clarke 252 41 2,701

### 6-60 SUMMARY FACTOR 4: COMMUTING PATTERNS WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties Sorted by Highest Number of Commuters VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 VA Fairfax 10,532 46 242,944 3 MD Prince Georges 7,120 60 238,274 3 MD Montgomery 7,398 41 184,513 3 VA Prince William 2,786 65 98,427 3 VA Arlington 1,807 69 79,757 3 DC Washington 3,802 26 67,157 3 VA Alexandria 978 73 56,449 3 VA Loudoun 1,431 57 52,719 3 MD Frederick 2,508 39 40,199 3 MD Charles 1,006 56 34,316 3 VA Stafford 1,430 68 33,083 3 VA Spotsylvania 1,270 57 25,808 3 MD Calvert 848 50 18,711 3 VA Fauquier 1,005 56 15,753 3 VA Manassas 130 75 13,576 3 MD Washington 2,249 22 13,268 3 WV Berkeley 852 34 12,098 3 WV Jefferson 362 51 10,665 3 VA Fairfax (City) 124 76 9,014 3 VA Culpeper 405 40 6,393 3 VA Warren 339 39 6,019 3 VA Fredericksburg 451 54 5,188 3 VA Manassas Park 17 89 4,925 3 VA Falls Church 32 83 4,868 3 VA King George 263 41 3,329 3 VA Clarke 252 41 2,701

### 6-61 SUMMARY FACTOR 5: EXPECTED GROWTH WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties Sorted by Highest Growth Rate Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 3 VA Loudoun 204,054 83,470 97 -217 -15 3 VA Spotsylvania 102,570 32,992 57 204 16 3 VA Manassas Park 10,909 3,556 53 3 VA Stafford 104,823 31,210 51 -225 -16 3 MD Calvert 80,906 23,191 45 144 17 3 VA Prince William 311,892 65,127 30 999 36 3 MD Frederick 209,125 45,069 30 -311 -12 3 WV Berkeley 81,262 16,652 28 -111 -13 3 VA Manassas 37,288 7,178 26 3 VA King George 17,657 3,276 24 50 19 3 VA Culpeper 36,893 6,471 23 46 11 3 VA Warren 32,910 5,442 21 -1 0 3 MD Charles 129,040 19,392 19 -77 -8 3 VA Fairfax 997,580 151,165 18 1,653 16 3 WV Jefferson 44,926 6,264 17 123 34 3 MD Montgomery 910,156 116,314 15 2,258 31 3 VA Alexandria 130,804 17,100 15 649 66 3 VA Fauquier 59,245 6,398 13 16 2 3 VA Arlington 189,927 18,517 11 693 38 3 MD Prince Georges 833,084 72,247 10 2,023 28 3 VA Fairfax (City) 22,055 1,876 10 163 131 3 MD Washington 134,246 10530 9 4,754 4 3 VA Falls Church 10,659 799 8 3 VA Clarke 13,290 551 5 -41 -16 3 VA Fredericksburg 20,076 252 1 3 DC Washington 570,898 -34,841 -6 738 19



### Factor 8: Jurisdictional Boundaries The Baltimore-Washington CMSA has recently been designated nonattainment for the 8-hour ozone standard. In those designations, the CMSA was divided along MSA boundaries. These boundaries will also be used for PM2.5 designations. These areas are the Baltimore MSA, the Washington DC MSA, and the Hagerstown-Martinsburg MSA. These three areas are under the jurisdiction of separate planning organizations. The nonattainment boundaries that EPA intends to use will facilitate planning for ozone and PM2.5 by these separate organizations.

Factor 9: Level of Control of emission sources EPA identified large sources greater than 1000 tons per year for any pollutant and evaluated its distance to a violating monitor for fine particulate.

### 6-62 Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating Charles, Frederick, Montgomery and Prince Georges counties as nonattainment as the Maryland portion of the Washington, DC nonattainment area. 6.3.3.4 Hagerstown - Martinsburg

Discussion As noted above, this area is part of the Baltimore-Washington CMSA, which has been split into the smaller MSA areas for planning purposes and for consistency with the 8-hour ozone designations. The Hagerstown-Martinsburg Area is comprised of two counties in West Virginia, and one county in Maryland. Berkeley County in West Virginia has monitored violations of the fine particulate (PM2.5) standard of 15.0 _g/m3

### . Based on the monitored violations, the Hagerstown-Martinsburg area is considered a presumptive nonattainment area. The Berkeley County monitor is intended to be used as the Design Value monitor for this MSA. Washington County is part of the Hagerstown-Martinsburg CBSA, as defined by OMB in 2003. In its letter of February 23, 2004, Maryland recommended that Washington County be designated as nonattainment; however, in its revised recommendation of May 28, 2004, Maryland recommended a designation of attainment. Summary of Evaluation Washington County has monitored attainment for 2001 -2003 (14.0 _g/m3

### ). However, weighted emissions screening indicates that this county potentially contributes to the nonattainment area. Despite low population growth, population is the highest compared to other areas of the CBSA. VMT and VMT growth are also high compared to the other counties in the CBSA. The combined factor analysis indicates potential contribution to the nonattainment area; therefore EPA intends to designate Washington County as nonattainment.
Our analysis of Morgan County shows that it is low in all areas of the combined factor analysis Allegany County is an adjacent area that has low population, negative growth, and negligible commuting into the CBSA, and was therefore excluded. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Please see tables in Section 6.3.5.1 (Washington, DC area) for specific data on Berkeley and Washington County. After consideration of all information provided, EPA has

### 6-63 determined that the recommendation of June 29, 2004 as described above is still valid. EPA is designating Washington County, MD and Berkeley County, WV as the Hagerstown- Martinsville nonattainment area. 6.3.4 EPA 9-Factor Analyses for Pennsylvania for the Designation of Nonattainment Areas for PM2.5
Enclosure A The fourth column of the following table identifies the counties in Pennsylvania that EPA intends to designate as nonattainment.

Area Counties included in the 1999 MSA Pennsylvania Recommended Nonattainment Counties Nonattainment Counties

Harrisburg Cumberland Dauphin Lebanon Perry Cumberland Dauphin Cumberland Dauphin Lebanon

Johnstown Cambria Somerset Cambria Cambria Indiana Lancaster Lancaster Lancaster Lancaster Philadelphia PA-NJ-DE-MD Philadelphia Delaware Montgomery Chester Bucks Philadelphia Delaware Chester Philadelphia Delaware Montgomery Chester Bucks Pittsburgh Allegheny Beaver Westmoreland Washington Butler Fayette Allegheny Beaver Westmoreland Washington Allegheny Beaver Butler Westmoreland Washington Armstrong Greene Lawrence Reading Berks Berks Berks York York York York Youngstown, OH Mahoning, OH Trumbull, OH Mercer, PA

Total 21 13 22


### *We have included in our recommended nonattainment areas counties in your state that are contiguous to a CMSA or MSA with a violating monitor, that are generally rural in character, and that contain an identifiable large emitting facility or facilities (e.g., power plants) which we believe contribute to the nearby nonattainment problem. We have included these counties in our initial recommendations in order to ensure that a sufficient portion of those counties, including

### 6-64 such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of such contiguous counties, encompassing the large facility or facilities, should be designated nonattainment. The county or counties in your state that we have included for this purpose are: Indiana, Armstrong and Greene.

Enclosure B State Summary The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, 16 counties to be designated nonattainment. On June 2, 2004, Secretary McGinty revised the recommendation to exclude three metropolitan counties: Bucks, Montgomery and Lebanon counties. Based on the air quality data for the years 2001-2003, there are eight presumptive fine particulate (PM2.5) nonattainment areas consisting of 21 counties in Pennsylvania. EPA agrees with Pennsylvania on the 13 counties recommended to be designated nonattainment. Based on the review of the recommendation as well as the additional information described below, EPA intends to designate nine additional counties as nonattainment: one additional county in the Harrisburg MSA, one additional county in the Johnstown MSA, two additional counties in the Philadelphia CMSA, four additional counties in the Pittsburgh CMSA and one county in the Youngstown, OH MSA. The following discussion provides our rationale for considering the modification to Pennsylvania’s recommendation. 6.3.4.1 Harrisburg Area
Discussion The Harrisburg Metropolitan Statistical Area (MSA) is comprised of four counties: Cumberland, Dauphin, Lebanon and Perry. Two counties in this MSA have monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Harrisburg MSA is considered a presumptive nonattainment area. Cumberland County has monitored 17.6 _g/m3

### for the time period 2001-2003. The data, however, are incomplete at this time so this value will not be used as the Design Value. Dauphin County has monitored 15.8 _g/m3

### for the 2001-2003 time period. The Dauphin County monitor is intended to be used as the Design Value monitor for the Harrisburg nonattainment
area. The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, three counties to be included in the Harrisburg nonattainment area: Cumberland, Dauphin, and Lebanon. On June 2, 2004, Pennsylvania indicated a revised recommendation including only two counties for this area: Cumberland and Dauphin. EPA has reviewed the Commonwealth’s recommendations as well as additional data and agrees with the original recommendation. EPA intends, based on the information reviewed, to

### 6-65 designate three counties as nonattainment in the Harrisburg area: Cumberland, Dauphin, and Lebanon. Summary of Evaluation Based on a review of the nine factors, EPA supports Pennsylvania’s attainment recommendation for Perry County even though it is part of the presumptive nonattainment area (as described in the April 2003 and February 2004 EPA guidance). As seen in the tables below, Perry County is among the lowest ranking counties in the Harrisburg area, for most of the nine criteria. The county has monitored attainment at 12.0 _g/m3

### . The emissions are very low, when compared with other counties in the area. Considering the meteorology and distance to the monitor, the weighted emissions factor slightly rises; but the emission factor is still one-third of the larger emissions contributing counties in the area. The population and urban density data are among the lowest in the MSA. The commuting data indicates significant commuting, compared to population, but the relative vehicle miles traveled is low. Comparatively, this county is lower in vehicle miles than the other 3 metropolitan counties as well as several of the surrounding attainment counties. Inclusion of the county is not supported by the analysis of the 9 factors. Therefore, EPA intends to designate Perry County, part of the metropolitan area, as attainment/unclassifiable. In addition to the counties included in the MSA, EPA has reviewed the counties adjacent to the MSA. Berks, Lancaster, and York Counties are adjacent to the MSA and are each single-county MSA’s with monitored violations of the PM2.5

### NAAQS. The Commonwealth recommended nonattainment for these counties. They will be discussed separately. The adjacent counties of Franklin, Adams, Schuylkill, Northumberland and Juniata were evaluated for potential contribution to the nonattainment area. Northumberland and Juniata were similar to Perry County ranking very low in all factors. Although the weighted emissions score showed moderate contribution to the area from Franklin, Adams, and Schuylkill, review of the remaining criteria, including an attaining monitor in Adams County, support Pennsylvania’s recommendation of attainment. EPA intends, based on this review, not to add any surrounding counties to the Harrisburg MSA nonattainment area. Lebanon County is part of the Harrisburg metropolitan area. Unlike Perry County, it is located adjacent to several other nonattainment areas. The inclusion of Lebanon County completes a contiguous nonattainment boundary. A summary of the data that supports the intended designations is provided below.

### 6-66 SUMMARY OF HARRISBURG, PA MSA

EPA RegST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

C/MSA Total (excluding surrounding) = 4 counties 3 PA Cumberland NonattainmentNonattainmentHarrisburg-Lebanon-Carlisle, PA 3 PA Dauphin NonattainmentNonattainmentHarrisburg-Lebanon-Carlisle, PA 3 PA Lebanon Attainment NonattainmentHarrisburg-Lebanon-Carlisle, PA 3 PA Perry Attainment Attainment Harrisburg-Lebanon-Carlisle, PA 3 PA Lancaster NonattainmentNonattainmentLancaster, PA 3 PA Berks NonattainmentNonattainmentReading, PA 3 PA York NonattainmentNonattainmentYork, PA 3 PA Adams Attainment Attainment 3 PA Franklin Attainment Attainment 3 PA Juniata Attainment Attainment 3 PA Northumberland Attainment Attainment 3 PA Schuylkill Attainment Attainment

SUMMARY OF FACTOR 1: EMISSIONS HARRISBURG, PA MSA ** Counties Listed by Percent Contribution to Area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOC Amm CarbonCrustalWeighted Emissions Factor 3 PA York 7,251 60,065 32,847 22,101 3,029 1,991 4,166 82.8 3 PA Lancaster 5,673 10,786 20,901 27,383 17,154 1,746 3,569 66.7 3 PA Berks 4,806 17,143 21,834 21,506 4,133 1,520 2,821 60.8 3 PA Cumberland 2,638 3,265 14,246 11,526 2,050 1,020 1,393 40.5 3 PA Dauphin 1,8124,079 13,425 13,695 1,703 786 913 33.1 3 PA Franklin 1,827 1,501 6,280 7,423 4,558 591 1,154 22.0 3 PA Adams 1,608 793 3,645 4,518 2,617 641 901 21.4 3 PA Schuylkill 1,441 8,390 7,857 7,212 1,311 483 833 20.0 3 PA Lebanon 1,451 2,758 6,284 6,931 4,593 468 903 18.4 3 PA Northumberland 1,1562,004 4,143 6,046 1,229 441 644 16.0 3 PA Perry 561 647 2,750 1,925 1,709 206 330 8.1 3 PA Juniata 337 351 1,873 1,314 2,121 123 198 5.0

### 6-67 SUMMARY OF FACTOR 2: AIR QUALITY HARRISBURG MSA

Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01

3 PA Cumberland 17.6 na 15.8 na 15.8 na 3 PA Dauphin 15.8NA 15.6NA 15.5NA 3 PA Lebanon No Monitor 3 PA Perry 13.0 A 12.7 A 12.5 a

SUMMARY OF FACTOR 3A: POPULATION Sorted Highest to Lowest EPA Reg STCounty 2002 Area (sq miles) Density '02 EPA Designation

3 PADauphin 252,933 525 482 Nonattainment 3 PACumberland 217,743 550 396 Nonattainment 3 PASchuylkill 148,505 779 191 Attainment 3 PAFranklin 131,598 772 170 Attainment 3 PALebanon 121,199 362 335 Nonattainment 3 PAAdams 94,437 520 182 Attainment 3 PANorthumberland 93,371 460 203 Attainment 3 PAPerry 43,876 554 79 Attainment 3 PAJuniata 22,760 392 58 Attainment

SUMMARY OF FACTOR 3B: Population Density Sorted Highest to Lowest EPA Reg ST County 2002 Area (sq miles) Density '02 EPA Designation

3 PA Dauphin 252,933 525 482 Nonattainment 3 PA Cumberland 217,743 550 396 Nonattainment 3 PA Lebanon 121,199 362 335 Attainment 3 PANorthumberland 93,371 460 203 Attainment 3 PA Schuylkill 148,505 779 191 Nonattainment 3 PA Adams 94,437 520 182 Attainment 3 PA Franklin 131,598 772 170 Attainment 3 PA Perry 43,876 554 79 Attainment 3 PA Juniata 22,760 392 58 Attainment

### 6-68 Factor 4: Commuting Patterns: Sorted by VMT Highest to Lowest VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number EPA Designation

3 PA Dauphin 2,869 16 19,284 Nonattainment 3 PA Cumberland 2,594 22 23,237 Nonattainment 3 PA Schuylkill 1,463 6 3,964 Attainment 3 PA Franklin 1,419 6 3,971 Attainment 3 PA Lebanon 1,136 24 14,209 Nonattainment 3 PA Northumberland 797 4 1,802 Attainment 3 PA Adams 734 6 2,738 Attainment 3 PA Perry 397 63 13,452 Attainment 3 PA Juniata 205 26 2,667 Attainment

SUMMARY FACTOR 4B: COMMUTING PATTERNS Sorted by Number of Commuters Highest to Lowest VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number EPA Designation

3 PA Cumberland 2,594 22 23,237 Nonattainment 3 PA Dauphin 2,869 16 19,284 Nonattainment 3 PA Lebanon 1,136 24 14,209 Nonattainment 3 PA Perry 397 63 13,452 Attainment 3 PA Franklin 1,419 6 3,971 Attainment 3 PA Schuylkill 1,463 6 3,964 Attainment 3 PA Adams 734 6 2,738 Attainment 3 PA Juniata 205 26 2,667 Attainment 3 PA Northumberland 797 4 1,802 Attainment

SUMMARY FACTOR 5: EXPECTED GROWTH: HARRISBURG, PA MSA Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 EPA Designation

3 PA Northumberland93,371 -2,215 -2 -54 -7 Attainment 3 PA Schuylkill 148,505 -2,249 -1 -139 -10 Attainment 3 PA Lebanon 252,933 13,985 6 46 4 Nonattainment 3 PA Perry 121,199 6,583 6 227 57 Attainment 3 PA Cumberland 635,751 41,415 7 59 2 Nonattainment 3 PA Franklin 131,598 8,231 7 -94 -7 Attainment 3 PA Dauphin 217,743 18,417 9 857 30 Nonattainment 3 PA Juniata 22,760 2,196 11 90 44 Attainment 3 PA Adams 94,437 13,018 17 213 29 Attainment

### 6-69 Factor 8: Jurisdictional Boundaries The Harrisburg area has recently been designated nonattainment for the 8-hour ozone standard. Included with the four MSA counties, Franklin, Adams and Perry were included in the ozone nonattainment area. In the ozone review, Franklin County monitored violations of the ozone standard. For fine particulate, there are no monitored violations in the surrounding counties. Lebanon County is part of the Harrisburg metropolitan area. Unlike Perry County, it is located adjacent to several other nonattainment areas. The inclusion of Lebanon County completes a contiguous nonattainment boundary.

Factor 9: Level of Control of emission sources PA identified large sources greater than 1000 tons per year for any pollutant and evaluated its distance to a violating monitor for fine particulate. This screening identified a source in Schuylkill County as 37 miles from a violating monitor. The wind and direction analysis, however, confirmed that this source is not significantly contributing to the nonattainment area. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Pennsylvania presented additional comments that Lebanon County should not be included. EPA reviewed the information but disagrees. Lebanon County is part of the core metropolitan area. The population density is similar to that of Dauphin and Cumberland Counties. Twenty four percent of the population commutes within the nonattainment area. In addition, the juxtaposition of two nonattainment areas suggests Lebanon County is not only contributing to, but is estimated to have elevated air quality similar to the nonattainment counties in Eastern Pennsylvania. After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating Cumberland, Dauphin, and Lebanon Counties as the Harrisburg nonattainment area.

6.3.4.2 Johnstown Area

Discussion The Johnstown Metropolitan Statistical Area (MSA) is comprised of two counties: Cambria and Somerset. Cambria County has monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Johnstown MSA is considered a presumptive nonattainment area. Cambria has monitored 15.8 _g/m3

### for the time period 2001-2003. This monitor is intended to be used as the Design Value monitor for the Johnstown nonattainment area. The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, Cambria County to be included in the Johnstown nonattainment area. EPA has reviewed the Commonwealth’s recommendations as well as additional data provided on June 1, 2004. EPA agrees with the recommendation of Cambria as nonattainment and Somerset

### 6-70 County as attainment. EPA intends, based on the information reviewed, to designate an adjacent county, Indiana, as nonattainment in the Johnstown area. Summary of Evaluation EPA has identified Somerset County part of the metropolitan area, as well as the adjacent counties of Blair and Bedford Counties in Pennsylvania and Garrett County, MD to have very low contribution from all factors to the metropolitan area. There is sufficient evidence to alter the presumptive boundaries the nonattainment area to exclude Somerset County. EPA has reviewed the adjacent counties to the Johnstown MSA. There are no distinguishing characteristics for the area when comparing the population density, growth and commuting patterns. Indiana County is adjacent to the MSA and shows a large emissions contribution to the area. Indiana County contributes a comparatively large portion of emissions to the Johnstown area. The disproportionate amount of emissions provides substantial evidence to include Indiana County in the nonattainment area. Moderate emissions contribution from Clearfield County, PA and Allegany County, MD counties suggested possible inclusion, however, the inclusion of these counties is not supported by analysis of the nine factors. The weighted emissions factor, considering meteorology and distance, is less than half the value for Cambria. This difference highlights the significance of geography and meteorology in this designation analysis. Geography and topography, however, provide justification for the intended nonattainment boundaries. The topography of the area isolates the city from inter-urban transport of low-level emissions. Over 34 square miles of mountain upland drains down into the City and then out the deepest river gap in the eastern United States. The city itself is in the approximately two-mile wide flood plane formed by the junction of the Stonycreek and Little Conemaugh Rivers, and the narrow Conemaugh River Gap where water flows out of the City. The Conemaugh River Gap is over 1600 feet deep when measured from the top of Rager Mountain and the level of the river at its outfall from the Gap in Robinson, Indiana County. The basin within which the city lies is about 300 feet below the surrounding ridgelines. The city is effectively isolated from inter-urban transport of low level emissions. Geography also plays a role. The emissions from the Shawville Power Plant, suggest a moderate emissions contribution from Clearfield County. This plant, however, is located 60 miles, predominantly downwind, from the nearest violating monitor. This distance, along with a low frequency of potential impact, provides additional justification for considering Clearfield attainment. Based on review of the factors, EPA intends to add Indiana County alone to the nonattainment area boundaries

.

### 6-71 The data supporting the modification to the Pennsylvania recommendation to include Indiana County is provided in the tables below.

SUMMARY OF JOHNSTOWN, PA MSA

EPA RegST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

3 PA Cambria NonattainmentNonattainment Johnstown, PA 3 PA Somerset Attainment Attainment Johnstown, PA 3 MD Allegany Attainment Attainment Cumberland, MD-WV 3 PA Bedford Attainment Attainment 3 PA Blair Attainment Attainment Altoona, PA 3 PA Clearfield Attainment Attainment 3 MD Garrett Attainment Attainment 3 PA Indiana Attainment Nonattainment Adjacent County

### 6-72 ** Counties Listed by Percent Contribution to Johnstown MSA** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOX VOC AmmCarbonCrustalWeighted Emissions Factor 3 PA Indiana 10,981 158,311 52,5504,683 692 2,428 6,868 629.7 3 PA Clearfield 3,466 43,394 11,4375,124 344 1,000 2,020 111.2 3 PA Westmoreland 3,320 3,593 18,461 17,371 1,1191,533 1,564 68.4 3 MD Allegany 3,041 20,453 12,2624,991 393 943 1,636 119.5 3 PA Cambria 1,594 8,716 8,287 7,229 490 679 804 181.5 3 PA Fayette 1,600 2,053 6,788 6,625 458 641 856 31.6 3 PA Blair 1,044 4,434 6,395 6,456 1,203461 523 46.6 3 PA Somerset 1,139 1,548 4,706 4,769 1,494415 659 43.9 3 PA Bedford 730 888 4,869 3,927 1,440307 389 25.0 3 MD Garrett 571 709 4,445 2,424 719 275 268 22.2

SUMMARY OF FACTOR 2: AIR QUALITY Johnstown, PA MSA Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01

3 PA Cambria 15.8NA 15.8NA 15.3NA 3 PA Somerset No Monitor 3 PA Indiana No Monitor 3 PA Clearfield No Monitor

SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF URBANIZATION JOHNSTOWN, PA MSA Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02 PM2.5 Designation

3 PA Westmoreland 368,428 1,023 360 Nonattainment 3 PA Cambria 150,452 688 219 Nonattainment 3 PA Fayette 146,654 790 186 Attainment 3 PA Blair 127,840 526 243 Attainment 3 PA Indiana 88,780 830 107 Nonattainment 3 PA Clearfield 83,203 1,147 73 Attainment 3 PA Somerset 79,456 1,075 74 Attainment 3 MD Allegany 74,203 425 175 Attainment 3 PA Bedford 49,944 1,015 49 Attainment 3 MD Garrett 29,878 648 46 Attainment

### 6-73 SUMMARY FACTOR 4A: Vehicle Miles Traveled: Sorted Highest to Lowest
VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 PA Westmoreland 3,217 1 1,223 3 MD Allegany 1,297 0 17 3 PA Blair 1,220 2 1,205 3 PA Cambria 1,176 4 2,649 3 PA Fayette 1,139 1 431 3 PA Clearfield 1,056 1 519 3 MD Garrett 963 2 243 3 PA Bedford 943 3 563 3 PA Somerset 932 15 5,174 3 PA Indiana 727 5 1,804

SUMMARY FACTOR 4B: Percent of Commuters: Sorted Highest to Lowest
VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 PA Somerset 932 15 5,174 3 PA Indiana 727 5 1,804 3 PA Cambria 1,176 4 2,649 3 PA Bedford 943 3 563 3 PA Blair 1,220 2 1,205 3 MD Garrett 963 2 243 3 PA Westmoreland3,217 1 1,223 3 PA Fayette 1,139 1 431 3 PA Clearfield 1,056 1 519 3 MD Allegany 1,297 0 17

### 6-74 SUMMARY FACTOR 5: EXPECTED GROWTH: JOHNSTOWN, PA MSA Population VMT EPA Reg ST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 3 PA Clearfield 83,203 5,285 7 -180 -17 3 PA Fayette 146,654 3,293 2 431 38 3 PA Bedford 49,944 2,065 4 -300 -32 3 PA Somerset 79,456 1,805 2 8 1 3 MD Garrett 29,878 1,708 6 -380 -39 3 MD Allegany 74,203 -16 -0 -370 -29 3 PA Westmoreland 368,428 -328 -0 762 24 3 PA Indiana 88,780 -389 -0 306 42 3 PA Blair 127,840 -1,398 -1 95 8 3 PA Cambria 150,452 -10,431 -6 513 44


### Factor 8: Jurisdictional Boundaries The Johnstown MSA was designated Subpart (Basic) 1 nonattainment for the 8-hour ozone standard. Indiana and Clearfield were included in the ozone designation. Clearfield County was included in the ozone nonattainment boundary as it had a violating monitor. Clearfield is estimated to be within the fine particulate standard.

Factor 9: Level of Control The Shawville Power Plant, located in the northern portion of Clearfield County, has installed a wet limestone scrubber on one of its three units. The plant is located over 100 kilometers to the northeast of the violating monitor in the Johnstown area. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA expressed intent to designate a number of counties nonattainment primarily because of high pollutant emissions from power plants. Most of these plants were located in counties outside but near to the metropolitan area. EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant.

### 6-75 After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas), or where the source is not located close enough to where the partial county boundary could be contiguous to the rest of the nonattainment area. Such free-standing portions of nonattainment areas should only be established based on a pre-existing boundary for a minor civil division such as a township, tax district, or other defined boundary recognized for other governmental use. Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Indiana County; an adjacent county proposed to be added to the Johnstown area has been evaluated with information provided by the Commonwealth of Pennsylvania. The emissions in Indiana County are predominantly from three power plants, Seward, Conemaugh and Homer City. EPA, after consultation with the Commonwealth of Pennsylvania, has defined partial county boundaries which include the power plants and are associated with the Johnstown nonattainment area. In Indiana County, the Townships of Center, East Wheatfield and West Wheatfield are nonattainment and the remainder of Indiana County is attainment/unclassifiable. EPA is designating Cambria County and part of Indiana County as the Johnstown nonattainment area.
6.3.4.3 Lancaster Area

Discussion The Lancaster Metropolitan Statistical Area (MSA) is a single county area. Lancaster County has monitored violations of the fine particulate (PM2.5

### ) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Lancaster MSA is considered a presumptive nonattainment area. Lancaster has monitored 17.0 _g/m3

### for the time period 2001- 2003. This monitor is intended to be used as the Design Value monitor for the Lancaster nonattainment area. The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, Lancaster County to be designated nonattainment as a single county MSA. EPA agrees with the Commonwealth’s recommendation for this area. Counties in other MSAs surround Lancaster County. Therefore, additional review of this area is unnecessary. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating Lancaster County as the Lancaster nonattainment area.

### 6-76 6.3.4.4 New York Area Pike County, PA has been included in the New York Metropolitan Area. A review of the area, however, shows that Pike and the next closest county in New Jersey are not contributing to the area. EPA agrees with Pennsylvania’s recommendation that this county not be included with the New York nonattainment area. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. As Pike County is not a significant contributor to the New York nonattainment area, EPA is designating Pike County as attainment. 6.3.4.5 Philadelphia Area

Discussion The Philadelphia Metropolitan Statistical Area (MSA) is comprised, in part, of five counties in Pennsylvania. Additional counties in Delaware, Maryland, and New Jersey are included in the MSA. The table below lists the counties in the MSA. Four counties in this MSA have monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Philadelphia MSA is considered a presumptive nonattainment area. The three Pennsylvania Counties monitoring violations are Philadelphia, Delaware and Chester Counties. In addition, New Castle County, DE monitored a violation. Philadelphia County monitored 16.4 _g/m3

### for the time period 2001- 2003. This value is being considered the Design Value for the nonattainment area. The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, five metropolitan counties to be included in the Philadelphia nonattainment area: Philadelphia, Delaware, Montgomery, Chester and Bucks Counties. On June 1, 2004, Pennsylvania indicated a revised recommendation excluding two counties from this area: Bucks and Montgomery. EPA has reviewed the Commonwealth’s recommendations as well as additional data and agrees with the original recommendation. EPA intends, based on the information reviewed, to designate five counties as nonattainment in the Philadelphia area: Philadelphia, Delaware, Montgomery, Chester and Bucks Counties. Summary of Evaluation EPA has identified Cecil County, MD, part of the presumptive area, as having very low contribution to the area. The county has an attaining monitor (13.0 _g/m3

### compared to the National Standard of 15.0 _g/m3

### ). A review of the remaining factors provides sufficient evidence to modify the nonattainment boundary to exclude Cecil County, MD. The New Jersey counties have been evaluated and are discussed in a separate document prepared by EPA Region

### 6-77 2. New Castle County, DE and Chester and Montgomery Counties in Pennsylvania have moderate to high emissions contribution to the area, based on the weighted emissions factor. EPA has reviewed these counties based the nine factors to determine the appropriate designation. The population density, growth and commuting patterns when compared to the core MSA counties in this area support including these counties in the nonattainment area. The tables below summarize the data used support the modification of Pennsylvania’s recommendation to include Bucks and Montgomery Counties with the three Pennsylvania violating counties in the MSA.

### 6-78 PHILADELPHIA, PA MSA Status of Counties: Alphabetical by State

EPA RegSTCOUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

3 DENew Castle NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 MDCecil Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJAtlantic Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJBurlington Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJCamden Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJCape May Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJCumberland Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJGloucester Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 2 NJSalem Attainment Attainment Philadelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PABucks NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PAChester Attainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PADelaware NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PAMontgomeryAttainment NonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD 3 PAPhiladelphia NonattainmentNonattainmentPhiladelphia-Wilmington-Atlantic City, PA-NJ-DE-MD

SUMMARY OF FACTOR 1: EMISSIONS PHILADELPHIA, PA MSA

** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOX VOC AmmCarbonCrustalWeighted Emissions Factor PM2.5 Designation 3 DE New Castle 4,55861,49934,64024,0882,6052,276 1,645 18.6 Nonattainment 3 PA Philadelphia 3,94416,86155,01150,4393,5062,116 1,200 14.0 Nonattainment 3 PA Delaware 3,17324,88233,25919,071903 1,458 1,225 11.1 Nonattainment 3 PA Montgomery 3,9108,721 21,19132,5451,2931,905 1,700 8.7 Nonattainment 3 PA Chester 3,71611,39116,90917,6972,2671,228 2,226 6.9 Nonattainment 3 PA Bucks 3,1006,870 16,85223,0241,1241,443 1,444 6.8 Nonattainment 2 NJ Gloucester 1,9099,154 21,84915,087741 1,035 697 6.5 Nonattainment 2 NJ Camden 2,1514,120 17,02520,904887 1,286 727 5.9 Nonattainment 2 NJ Burlington 2,2982,330 15,11318,139913 1,326 836 5.6 Nonattainment 2 NJ Cape May 2,15714,5787,894 11,886206 938 1,044 5.5 Attainment 2 NJ Atlantic 1,4041,905 8,676 11,906437 773 563 3.3 Attainment 2 NJ Cumberland 1,3741,941 7,054 9,279 423 638 669 2.8 Attainment 2 NJ Salem 1,2434,485 5,457 8,229 534 487 653 2.6 Attainment 3 MD Cecil 950 948 5,502 4,441 505 401 518 1.8 Attainment

### 6-79 SUMMARY OF FACTOR 2: AIR QUALITY PHILADELPHIA MSA

** Counties Listed by Highest DV **

Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01 PM2.5 Designation

3 PA Philadelphia 16.4NA16.8NA16.6NANonattainment 3 DE New Castle 16.2NA16.5NA16.6NANonattainment 3 PA Delaware 15.6NA15.7NA15.0a Nonattainment 3 PA Chester 15.1na14.6a Nonattainment 2 NJ Camden 14.6a 14.8a 14.6a Nonattainment 3 PA Bucks 14.6A 14.3a 13.4a Nonattainment 3 PA Montgomery 14.3A 14.2A 13.8a Nonattainment 2 NJ Gloucester 13.8a 14.2A 14.3a Nonattainment 3 MD Cecil 13.0a 13.4A 12.5a Attainment 2 NJ Atlantic 11.6a 11.4a 11.2a Attainment 2 NJ Burlington No Monitor Nonattainment 2 NJ Cape May No Monitor Attainment 2 NJ Cumberland No Monitor Attainment 2 NJ Salem No Monitor Attainment

### 6-80 SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF URBANIZATION PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Population Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02PM2.5 Designation

3 PA Philadelphia 1,492,231 135 11,054 Nonattainment 3 PA Montgomery 766,517 483 1,587 Nonattainment 3 PA Bucks 610,440 608 1,004 Nonattainment 3 PA Delaware 553,435 184 3,008 Nonattainment 3 DE New Castle 512,370 426 1,203 Nonattainment 2 NJ Camden 511,957 222 2,306 Nonattainment 3 PA Chester 450,160 756 595 Nonattainment 2 NJ Burlington 437,871 805 544 Nonattainment 2 NJ Gloucester 262,049 325 806 Nonattainment 2 NJ Atlantic 259,423 561 462 Attainment 2 NJ Cumberland 147,768 489 302 Attainment 2 NJ Cape May 102,013 255 400 Attainment 3 MD Cecil 90,335 348 260 Attainment 2 NJ Salem 64,438 338 191 Attainment

SUMMARY FACTOR 4: COMMUTING PATTERNS: PHILADELPHIA, PA MSA Counties Listed Highest to Lowest Number of Commuters VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number PM2.5 Designation

3 PA Philadelphia 10,213 23 129,902 Nonattainment 3 PA Montgomery 4,677 32 120,472 Nonattainment 3 PA Delaware 3,513 44 111,594 Nonattainment 2 NJ Camden 4,332 43 98,432 Nonattainment 3 PA Bucks 3,830 31 93,563 Nonattainment 3 PA Chester 3,128 32 70,486 Nonattainment 2 NJ Gloucester 2,312 51 62,141 Nonattainment 2 NJ Burlington 3,748 29 60,278 Nonattainment 3 DE New Castle 4,957 11 27,598 Nonattainment 3 MD Cecil 1,340 39 16,195 Nonattainment 2 NJ Atlantic 2,236 13 14,237 Attainment 2 NJ Salem 734 48 13,922 Attainment 2 NJ Cumberland 1,166 22 12,911 Attainment 2 NJ Cape May 749 26 11,360 Attainment

### 6-81 SUMMARY FACTOR 5: EXPECTED GROWTH: PHILADELPHIA, PA MSA

Counties Listed Highest to Lowest Growth Rate Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 PM2.5 Designation

3 MD Cecil 90,335 14,604 20 60 4 Nonattainment 3 PA Chester 450,160 57,105 15 785 25 Nonattainment 3 DE New Castle 512,370 58,319 13 1,273 26 Nonattainment 2 NJ Atlantic 259,423 28,225 13 805 36 Nonattainment 2 NJ Gloucester 262,049 24,591 11 262 11 Nonattainment 3 PA Montgomery 766,517 71,986 11 1,344 29 Nonattainment 3 PA Bucks 610,440 56,461 10 957 25 Nonattainment 2 NJ Cape May 102,013 7,237 8 179 24 Nonattainment 2 NJ Burlington 437,871 28,328 7 388 10 Nonattainment 2 NJ Cumberland 147,768 8,385 6 227 19 Attainment 2 NJ Camden 511,957 6,108 1 782 18 Attainment 3 PA Delaware 553,435 3,213 1 1,022 29 Attainment 2 NJ Salem 64,438 -1,009 -2 139 19 Attainment 3 PA Philadelphia 1,492,231 -68,027 -4 2,763 27 Nonattainment



### Factor 8: Jurisdictional Boundaries The Philadelphia MSA was designated Subpart (Basic) 1 nonattainment for the 8-hour ozone standard.

Factor 9: Level of Control of emission sources There are many sources in the metropolitan area; the level of control of sources was not a significant issue. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Pennsylvania has refuted the nonattainment designation of Bucks and Chester counties. EPA disagrees. Bucks and Montgomery counties are part of the core metropolitan area. Both counties are among the highest population and commuting in the Philadelphia area. Bucks County has experienced a 10 percent growth rate. EPA is designating Philadelphia, Bucks, Montgomery, Delaware and Chester as the Pennsylvania portion of the Philadelphia area.

### 6-82 6.3.4.6 Pittsburgh Area

Discussion The Pittsburgh Metropolitan Statistical Area (MSA) is comprised of six counties. The MSA was adjusted in 2003 to add Armstrong County to the metropolitan area. Also in 2003, the Pittsburgh-New Castle, PA Combined Statistical Area was formed with the addition of Lawrence County. Four counties in this MSA have monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Pittsburgh MSA is considered a presumptive nonattainment area. The four counties monitoring violations are Allegheny, Beaver, Westmoreland and Washington. Allegheny County monitored 21.2 _g/m3

### for the time period 2001-2003. This value is being considered the Design Value for the nonattainment area. The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, the four violating metropolitan counties to be included in the Pittsburgh nonattainment area. EPA has reviewed the Commonwealth’s recommendations as well as additional data and agrees with the recommendation of the four MSA counties. EPA also agrees with the recommendation that Fayette County, although part of the presumptive nonattainment area be excluded from the nonattainment boundary. EPA intends, based on the information reviewed, to designate an additional MSA county, Butler, with Allegheny, Beaver, Westmoreland and Washington as nonattainment in the Pittsburgh area. In addition, EPA intends to add three adjacent counties, Armstrong, Greene and Lawrence to the nonattainment area. Summary of Evaluation EPA has identified Fayette County part of the presumptive area as having very low contribution to the area. A review of the factors provides sufficient evidence to modify the nonattainment boundary to exclude these counties. The adjacent counties of Armstrong and Greene showed high emissions contribution to the area, based on the weighted emissions factor. EPA has reviewed these counties based on all the factors to determine the appropriate designation. The population density, growth and commuting patterns when compared to the core MSA counties in this area support including these counties in the nonattainment area. In addition, a review of the data suggests contribution to the area from Lawrence County as well. The tables below summarize the data used support the modification of Pennsylvania’s June 1 revision to the recommendations to include Armstrong, Butler, Greene and Lawrence as nonattainment with the four violating counties in the MSA.

### 6-83 SUMMARY OF PITTSBURGH, PA MSA

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5 DESIGNATIONArea - '99 C/MSA

3 PA Allegheny ** NonattainmentNonattainment Pittsburgh, PA 3 PA Beaver NonattainmentNonattainment Pittsburgh, PA 3 PA Westmoreland NonattainmentNonattainment Pittsburgh, PA 3 PA Washington NonattainmentNonattainment Pittsburgh, PA 3 PA Butler Attainment Nonattainment Pittsburgh, PA 3 PA Fayette Attainment Attainment Pittsburgh, PA 3 PA Armstrong Attainment Nonattainment 3 PA Greene Attainment Nonattainment 3 PA Indiana Attainment Nonattainment 3 WV Marshall NonattainmentNonattainment Wheeling, WV-OH 3 WV Monongalia NonattainmentNonattainment 3 PA Lawrence Attainment Nonattainment 3 WV Preston Attainment Attainment 3 WV Hancock NonattainmentNonattainment Steubenville-Weirton, OH-WV 5 OH Mahoning NonattainmentNonattainment Youngstown-Warren, OH 3 PA Cambria NonattainmentNonattainment Johnstown, PA 5 OH Columbiana Attainment Attainment Youngstown-Warren, OH 3 PA Mercer Attainment Nonattainment Sharon, PA 3 PA Somerset Attainment Attainment Johnstown, PA 3 PA Venango Attainment Attainment 3 PA Clarion Attainment Attainment 3 MD Garrett Attainment Attainment 3 PA Jefferson Attainment Attainment 3 WV Brooke NonattainmentNonattainment Steubenville-Weirton, OH-WV 3 WV Ohio NonattainmentNonattainment Wheeling, WV-OH ** Note: In the final designations, EPA is designating 4Glassport, Liberty, Lincoln, andPortvue Boroughs and the City of Clairton in Allegheny County as a separate Liberty-Clairton Nonattainment area. The remaining portions of the county will be included with the Pittsburgh nonattainment area.

### 6-84 SUMMARY OF FACTOR 1: EMISSIONS PITTSBURGH, PA MSA Counties sorted by Largest Weighted Emissions Contribution Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOCAmmCarbonCrustalWeighted Emissions Factor PM2.5 DESIGNATION 3 PA Armstrong 12,338191,07026,6703,531555 2,701 7,726 60.3 Nonattainment 3 PA Greene 11,626186,48131,8322,756256 2,548 7,223 59.2 Nonattainment 3 PA Indiana 10,981158,31152,5504,683692 2,428 6,868 55.1 Nonattainment 3 PA Allegheny 10,83761,16881,16654,8212,6554,570 4,576 46.6 Nonattainment 3 WVMarshall 5,596113,92144,5214,125122 1,319 3,417 38.2 Nonattainment 3 WVMonongalia 5,45981,413 17,5455,606185 1,320 3,331 27.3 Nonattainment 3 PA Beaver 4,94840,38039,5648,738543 1,368 2,900 21.3 Nonattainment 3 PA Lawrence 3,17335,62013,0654,890647 681 1,833 13.2 Nonattainment 3 PA Westmoreland3,3203,593 18,46117,3711,1191,533 1,564 10.7 Nonattainment 3 PA Washington 3,0118,221 22,0979,392813 1,190 1,505 10.6 Nonattainment 3 WVPreston 1,71521,8646,5281,874271 465 1,021 8.1 Attainment 3 WVHancock 4,3351,982 4,9613,585571 1,243 1,747 7.2 Nonattainment 5 OH Mahoning 1,8493,511 12,21015,043845 920 804 6.8 Nonattainment 3 PA Butler 2,1664,798 9,7068,697751 806 1,224 6.4 Nonattainment 3 PA Cambria 1,5948,716 8,2877,229490 679 804 6.4 Nonattainment 3 PA Fayette 1,6002,053 6,7886,625458 641 856 4.5 Attainment 5 OH Columbiana 1,1871,291 5,8255,881 1,250442 696 3.3 Attainment 3 PA Mercer 1,271874 7,4598,1101,095412 760 3.3 Nonattainment 3 PA Somerset 1,1391,548 4,7064,7691,494415 659 3.0 Attainment 3 PA Venango 661 3,261 3,8963,945232 284 332 2.6 Attainment 3 PA Clarion 790 1,629 4,0313,030435 291 396 2.3 Attainment 3 MDGarrett 571 709 4,4452,424719 275 268 2.1 Attainment 3 PA Jefferson 691 936 4,0442,906425 253 341 2.0 Attainment 3 WVBrooke 527 1,663 2,5004,358439 191 277 1.6 Nonattainment 3 WVOhio 351 514 3,6092,779123 192 135 1.5 Nonattainment

### 6-85 SUMMARY OF FACTOR 2: AIR QUALITY PITTSBURGH, PA MSA Counties Sorted by Highest Monitored and Estimated Air Quality Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01

3 PA Allegheny 21.2 NA 21.4 NA 21.0 NA 3 WV Hancock 17.4 NA 17.5 NA 17.4 NA 3 PA Beaver 16.0 NA 16.0 NA 16.4 na 3 PA Cambria 15.8 NA 15.8 NA 15.3 NA 3 WV Marshall 15.7 NA 16.0 NA 16.5 NA 3 PA Westmoreland 15.5 NA 15.6 NA 15.6 NA 3 PA Washington 15.5 NA 15.7 NA 15.5 NA 5 OH Mahoning 15.2 NA 15.7 NA 16.4 NA 3 WV Monongalia 14.9 A 15.0 A 15.0 A 3 PA Mercer 14.3 A 14.6 a 14.9 a 5 OH Columbiana No Monitor 3 PA Fayette No Monitor 3 PA Armstrong No Monitor 3 PA Greene No Monitor 3 PA Indiana No Monitor 3 PA Lawrence No Monitor 3 PA Butler No Monitor 3 WV Preston No Monitor

### 6-86 Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
3 PA Allegheny 1,269,904 730 1,740 3 PA Westmoreland 368,428 1,023 360 5 OH Mahoning 253,308 415 610 3 PA Washington 204,110 857 238 3 PA Beaver 179,351 435 412 3 PA Butler 178,078 789 226 3 PA Cambria 150,452 688 219 3 PA Fayette 146,654 790 186 3 PA Mercer 119,514 672 178 5 OH Columbiana 111,806 533 210 3 PA Lawrence 94,104 361 261 3 PA Indiana 88,780 830 107 3 WV Monongalia 82,895 361 230 3 PA Armstrong 71,673 654 110 3 PA Greene 40,520 576 70 3 WV Marshall 34,898 307 114 3 WV Hancock 32,082 83 387 3 WV Preston 29,460 648 45

### 6-87 SUMMARY FACTOR 4: COMMUTING PATTERNS PITTSBURGH, PA MSA Counties sorted by VMT - Highest to Lowest VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number DESIGNATION

3 PA Allegheny 10,522 6 35,095 Nonattainment 3 PA Westmoreland 3,217 31 51,192 Nonattainment 5 OH Mahoning 2,576 1 842 Nonattainment 3 PA Washington 2,057 36 32,606 Nonattainment 3 PA Butler 1,634 29 23,908 Nonattainment 3 PA Beaver 1,582 36 29,617 Nonattainment 3 PA Mercer 1,410 4 2,100 Nonattainment 3 PA Cambria 1,176 2 990 Nonattainment 3 PA Fayette 1,139 30 17,491 Attainment 5 OH Columbiana 928 5 2,676 Nonattainment 3 PA Lawrence 822 18 7,307 Nonattainment 3 WV Monongalia 810 2 601 Nonattainment 3 PA Indiana 727 11 4,008 Nonattainment 3 PA Armstrong 624 34 10,096 Nonattainment 3 PA Greene 560 24 3,605 Nonattainment 3 WV Preston 294 1 177 Attainment 3 WV Marshall 233 4 495 Nonattainment 3 WV Hancock 212 16 2,281 Nonattainment

### 6-88 VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 PA Westmoreland 3,217 31 51,192 3 PA Allegheny 10,522 6 35,095 3 PA Washington 2,057 36 32,606 3 PA Beaver 1,582 36 29,617 3 PA Butler 1,634 29 23,908 3 PA Fayette 1,139 30 17,491 3 PA Armstrong 624 34 10,096 3 PA Lawrence 822 18 7,307 3 PA Indiana 727 11 4,008 3 PA Greene 560 24 3,605 5 OH Columbiana 928 5 2,676 3 WV Hancock 212 16 2,281 3 PA Mercer 1,410 4 2,100 3 PA Cambria 1,176 2 990 5 OH Mahoning 2,576 1 842 3 WV Monongalia 810 2 601 3 WV Marshall 233 4 495 3 WV Preston 294 1 177

### 6-89 SUMMARY FACTOR 5: EXPECTED GROWTH PITTSBURGH, PA MSA Counties sorted by Growth Rate - Highest to Lowest Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 EPA INTENDED PM2.5 DESIGNATION 3 PA Allegheny 1,269,904 -54,783 -4 3,233 31 Nonattainment 3 PA Beaver 179,351 -4,681 -3 420 27 Nonattainment 3 PA Westmoreland368,428 -328 -0 762 24 Nonattainment 3 PA Washington 204,110 -1,687 -1 264 13 Nonattainment 3 PA Butler 178,078 22,070 15 -156 -10 Nonattainment 3 PA Fayette 146,654 3,293 2 431 38 Attainment 3 PA Armstrong 71,673 -1,086 -1 280 45 Nonattainment 3 PA Greene 40,520 1,122 3 -52 -9 Nonattainment 3 PA Indiana 88,780 -389 -0 306 42 Nonattainment 3 WV Marshall 34,898 -1,837 -5 241 103 Nonattainment 3 WV Monongalia 82,895 6,357 8 -180 -22 Nonattainment 3 PA Lawrence 94,104 -1,603 -2 59 7 Nonattainment 3 WV Preston 29,460 297 1 71 24 Attainment 3 WV Hancock 32,082 -2,566 -7 192 91 Nonattainment 5 OH Mahoning 253,308 -7,251 -3 242 9 Nonattainment 3 PA Cambria 150,452 -10,431 -6 513 44 Nonattainment 5 OH Columbiana 111,806 3,799 4 215 23 Nonattainment 3 PA Mercer 119,514 -710 -1 -182 -13 Nonattainment



### Factor 8: Jurisdictional Boundaries The Pittsburgh MSA was designated Subpart (Basic) 1 nonattainment for the 8-hour ozone standard. Butler and Mercer County were included in the ozone nonattainment area. Lawrence County was designated attainment.

Factor 9: Level of Control of emission sources There are a number of significant emission sources in the Pittsburgh metropolitan area. Many do not have state of the art controls. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA expressed intent to designate a number of counties nonattainment primarily because of high pollutant emissions from power plants. Most of these plants were located in counties outside but near to the metropolitan area. EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area.

### 6-90 A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas), or where the source is not located close enough to where the partial county boundary could be contiguous to the rest of the nonattainment area. Such free-standing portions of nonattainment areas should only be established based on a pre-existing boundary for a minor civil division such as a township, tax district, or other defined boundary recognized for other governmental use. Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. All of the adjacent counties in the proposed nonattainment area are predominantly rural in nature. The primary reason for including the adjacent counties of Armstrong, Greene and Lawrence is the contribution of emissions from power plants The Commonwealth of Pennsylvania has submitted, as requested, an identification of partial counties to include the Armstrong, Keystone, Hatfields Ferry and New Castle power plants. In Armstrong County the Townships of Plumcreek and Washington are nonattainment. The remainder of Armstrong County is attainment/unclassifiable. In Greene County the Township of Monongahela is nonattainment. The remainder of Greene County is attainment/unclassifiable. In Lawrence County the Township of Taylor is nonattainment. The remainder of Lawrence County is attainment/unclassifiable. Justifications for Separate Nonattainment Area (Liberty-Clairton) The Commonwealth of Pennsylvania provided extensive documentation to support a recommendation that a separate, distinctively local-source impacted, nonattainment area be designated within the Pittsburgh nonattainment area. The recommended Liberty Borough area is specified as the five municipalities which comprise the area in the vicinity of the Clairton Coke Works which were previously designated nonattainment for PM-10. The complexity of the largest metallurgical coke plant in the United States contributes a combination of particulates, sulfur dioxide , ammonia, and hundreds of volatile organic chemicals, in an atmosphere actually created by the large plant — high humidity, gases and materials discharged at temperatures well above 1000 degrees. Although the coke plant is well-controlled, the combination of low-level emissions in a narrow river valley creates a local air quality problem which is uniquely different from the remainder of the area. The analysis of speciation data, initiated in October 2003, demonstrates that the sulfate and

### 6-91 nitrate components are consistent with the larger area but the elemental and organic carbon fractions are consistently much greater than the regional data. The excess of carbon is, on average, approximately equal to the difference between the Liberty Borough design concentration and the average PM2.5

### concentration for the remainder of Allegheny County. The Commonwealth of Pennsylvania conducted an analysis of the meteorology of the more than 200 days during a three-year period when the concentration at the Liberty Borough monitor was at least one standard deviation greater than the regional average. On more than 80% of the days the wind flows from the southwest which would cause the coke plant to impact the Liberty Borough monitor. EPA agrees with the Commonwealth’s recommendation is designating Glassport, Liberty, Lincoln and Port Vue Boroughs and the City of Clairton as the separate Liberty/Clairton nonattainment area. The remainder of Allegheny County is in the Pittsburgh nonattainment area.

### 6-92 6.3.4.7 Reading Area

Discussion The Reading Metropolitan Statistical Area (MSA) is a single county area. Berks County has monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Reading MSA is considered a presumptive nonattainment area. Berks has monitored 16.4 _g/m3

### for the time period 2001- 2003. This monitor is intended to be used as the Design Value monitor for the Reading nonattainment area. The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, Berks County to be designated nonattainment as a single county MSA. EPA agrees with the Commonwealth’s recommendation for this area. EPA reviewed the surrounding counties of Lehigh and Northampton. The other surrounding counties were reviewed as part of other potential nonattainment areas. Based on the review of the factors, EPA intends to designate Lehigh and Northampton counties as attainment. The tables below substantiate Pennsylvania’s recommendation for the Reading area.

SUMMARY OF Reading, PA MSA EPA RegST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA C/MSA Total (excluding surrounding) = 1 county 3 PA Berks Nonattainment Nonattainment Reading, PA 3 PA Chester Attainment Nonattainment Philadelphia, PA-NJ 3 PA Lancaster Nonattainment Nonattainment Lancaster, PA 3 PA Lebanon Nonattainment Nonattainment Harrisburg-Lebanon-Carlisle, PA 3 PA Lehigh Attainment Attainment Allentown-Bethlehem-Easton, PA 3 PA Montgomery Attainment Nonattainment Philadelphia, PA-NJ 3 PA Northampton Attainment Attainment Allentown-Bethlehem-Easton, PA 3 PA Schuylkill Attainment Attainment

### 6-93 SUMMARY OF FACTOR 3A: POPULATION Sorted Highest to Lowest2002 Area (sq miles)Density '02
3PAMontgomery 766,517 483 1,587 3PALancaster 478,561 949 504 3PAChester 450,160 756 595 3PABerks 382,108 859 445 3PALehigh 317,533 347 915 3PANorthampton 273,324 374 731 3PASchuylkill 148,505 779 191 3PALebanon 121,199 362 335 SUMMARY OF FACTOR 1: EMISSIONS READING, PA MSA ** Counties Listed by Percent Contribution to Area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOC Amm CarbonCrustalWeighted Emissions Factor 3 PA Berks 4,806 17,143 21,834 21,506 4,133 1,520 2,821 100 3 PA Chester 3,716 11,391 16,909 17,697 2,267 1,228 2,226 77.5 3 PA Lancaster 5,673 10,786 20,901 27,383 17,154 1,746 3,569 99.5 3 PA Lebanon 1,451 2,758 6,284 6,931 4,593 468 903 28.2 3 PA Lehigh 1,844 6,027 12,154 14,418 792 624 1,018 47.7 3 PA Montgomery 3,910 8,721 21,191 32,545 1,293 1,905 1,700 102.8 3 PA Northampton 5,646 55,105 24,051 10,401 805 1,212 3,374 3 PA Schuylkill 1,441 8,390 7,857 7,212 1,311 483 833 35.8

SUMMARY OF FACTOR 2: AIR QUALITY READING MSA
Design Values

EPA RegST COUNTY '01-'03 '00-'02 '99-'01

3 PA Berks 16.4 NA16.7 NA15.6 NA 3 PA Chester 15.1 na 14.6 a 3 PA Lancaster 17.0 NA17.1 NA16.9 NA 3 PA Lebanon 3 PA Lehigh 14.6 a 14.3 A 13.8 a 3 PA Montgomery 14.3 A 14.2 A 13.8 a 3 PA Northampton 14.8 A 14.6 a 14.0 a 3 PA Schuylkill

### 6-94 SUMMARY OF FACTOR 3B: POPULATION DENSITY Sorted Highest to Lowest EPA RegST 2002 Area (sq miles)Density '02

3 P A Montgomery 766,517 483 1,587 3 P A Lehigh 317,533 347 915 3 P A Northampton273,324 374 731 3 P A Chester 450,160 756 595 3 P A Lancaster 478,561 949 504 3 P A Berks 382,108 859 445 3 P A Lebanon 121,199 362 335 3 P A Schuylkill 148,505 779 191

2002 Percent Number 3 PA Montgomery 4,677 1 4,231 3 PA Lancaster 4,004 2 4,074 3 PA Berks 3,952 3 PA Chester 3,128 1 1,916 3 PA Lehigh 2,738 2 3,266 3 PA Northampton 2,132 3 3,766 3 PA Schuylkill 1,463 9 5,790 3 PA Lebanon 1,136 5 2,799

Factor 4:Commuting Patterns: Sorted by VMT Highest VMT Commuting to Other EPA Reg ST COUNTY

2002 Percent Number 3 PA Berks 3,952 3 PA Schuylkill 1,463 9 5,790 3 PA Montgomery 4,677 1 4,231 3 PA Lancaster 4,004 2 4,074 3 PA Northampton 2,132 3 3,766 3 PA Lehigh 2,738 2 3,266 3 PA Lebanon 1,136 5 2,799 3 PA Chester 3,128 1 1,916 Factor 4B:Commuting Patterns: Sorted by Number of Commuters Highest to Lowest VMT Commuting to Other EPA Reg ST COUNTY

### 6-95 2,002 Growth '90-'00 Pct chng '90-'00 2002 Projected Growth '02-'10 Pct chng '02-'10 3 PA Montgomery 766,517 71,986 11 4,677 1,344 29 3 PA Chester 450,160 57,105 15 3,128 785 25 3 PA Lancaster 478,561 47,836 11 4,004 850 21 3 PA Berks 382,108 37,115 11 3,952 -230 -6 3 PA Lehigh 317,533 20,960 7 2,738 517 19 3 PA Northampton 273,324 19,961 8 2,132 631 30 3 PA Lebanon 121,199 6,583 6 1,136 46 4 3 PA Schuylkill 148,505 -2,249 -1 1,463 -139 -10 Summary Factor 5: Expected Growth: Sorted by '90-'00 Growth Highest to Lowest VMT Population EPA Reg ST COUNTY



### Factor 8: Jurisdictional Boundaries The Reading MSA was designated Subpart (Basic) 1 nonattainment for the 8-hour ozone standard.

Factor 9: Level of Control of emission sources The Martins Creek Power Plant has a state order to shut down coal units by the year 2007. This conversion will greatly reduce the emissions from Northampton County. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating Berks County as the Reading nonattainment area.

6.3.4.8 York Area The York metropolitan Statistical Area (MSA) is a single county area. York County has monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on monitored violations, the York MSA is considered a presumptive nonattainment area. York has monitored 17.3 _g/m3

### for the time period 2001-2003. This monitor is intended to be used as the Design Value monitor for the York nonattainment area. The Commonwealth of Pennsylvania recommended, in the Governor Edward Rendell correspondence of March 5, 2004, York County to be designated nonattainment as a single county MSA. EPA agrees with the Commonwealth’s recommendation for this area.

### 6-96 Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating York County as the York nonattainment area. 6.3.4.9 Youngstown Area

Discussion The Youngstown, OH Metropolitan Statistical Area (MSA) was adjusted by OMB in 2003 to include, in part, one county in Pennsylvania. The core metropolitan counties, Trumbull, Mahoning and Columbiana counties in Ohio, have been reviewed by EPA Region 5 and are discussed in a separate document. Two Ohio counties in this MSA have monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3



### . Based on the monitored violations, the Youngstown MSA is considered a presumptive nonattainment area. Review of the factors for Mercer County have identified that although emissions contribution is comparatively low, there is moderate population and commuting. The inclusion of this county in the 2003 urban area adds additional evidence to the conclusion that Mercer is part of the metropolitan area. The factors suggest inclusion of Mercer County with the Youngstown area.

### 6-97 SUMMARY OF Youngstown, OH MSA

EPA Reg ST COUNTY State Recommend PM2.5 Designation Region 3 INTENDED PM2.5 DESIGNATIONArea - '99 C/MSA

5 OH Trumbull NonattainmentNonattainmentYoungstown-Warren, OH 5 OH Mahoning NonattainmentNonattainmentYoungstown-Warren, OH 5 OH Columbiana Attainment NonattainmentYoungstown-Warren, OH 3 PA Mercer Attainment Nonattainment Sharon, PA 3 PA Lawrence Attainment Nonattainment 3 PA Crawford Attainment Attainment

SUMMARY OF FACTOR 1: EMISSIONS Youngstown, OH MSA Counties sorted by Largest Weighted Emissions Contribution Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOCAmmCarbonCrustalWeighted Emissions Factor 5 OHTrumbull 2,88230,327 19,01017,417808 1,217 1,365 52.9 3 PA Lawrence 3,17335,620 13,0654,890647 681 1,833 41.2 5 OHMahoning 1,8493,511 12,21015,043845 920 804 31.2 3 PA Crawford 1,367 1,231 8,0345,665 1,370413 772 17.3 3 PA Mercer 1,271 874 7,4598,110 1,095412 760 16.7 5 OHColumbiana1,1871,291 5,8255,881 1,250442 696 15.9

### 6-98 SUMMARY OF FACTOR 2: AIR QUALITY Counties Sorted by Highest Monitored and Estimated Air Quality Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01 5 OH Jefferson 17.8 NA18.2 NA18.9 5 OH Stark 17.3 NA17.9 NA18.3 NA 3 PA Beaver 16.0 NA16.0 NA16.4 na 5 OH Mahoning 15.2 NA15.7 NA16.4 NA 5 OH Trumbull 15.0 A 15.6 NA16.2 NA 3 PA Mercer 14.3 A 14.6 a 14.9 a 5 OH Portage 14.2 A 15.1 NA15.3 NA 3 PA Lawrence No monitor 3 PA Crawford No monitor 5 OH Columbiana No monitor

SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF URBANIZATION PITTSBURGH, PA MSA Counties Sorted by Population - Highest to Lowest Population & Area EPA Reg ST COUNTY 2002 Area (sq miles)Density '02 5 OH Jefferson 72,402 410 177 3 PA Beaver 179,351 435 412 5 OH Trumbull 223,518 616 363 3 PA Lawrence 94,104 361 261 5 OH Mahoning 253,308 415 610 3 PA Crawford 89,856 1,013 89 3 PA Mercer 119,514 672 178 5 OH Columbiana 111,806 533 210

### 6-99 SUMMARY FACTOR 4A: COMMUTING PATTERNS YOUNGSTOWN, PA MSA Counties sorted by VMT - Highest to Lowest VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 5 OH Stark 3,135 1 1,970 5 OH Mahoning 2,576 21 22,894 5 OH Trumbull 2,108 13 12,347 5 OH Portage 1,796 3 2,234 3 PA Butler 1,634 0 249 3 PA Beaver 1,582 1 689 3 PA Mercer 1,410 8 3,949 5 OH Ashtabula 1,107 1 636 3 PA Crawford 981 0 168 5 OH Columbiana 928 18 9,090

SUMMARY FACTOR 4B: COMMUTING PATTERNS YOUNGSTOWN, PA MSA Counties sorted by Number of Commuters: Highest to Lowest
VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 5 OH Mahoning 2,576 21 22,894 5 OH Trumbull 2,108 13 12,347 5 OH Columbiana 928 18 9,090 3 PA Mercer 1,410 8 3,949 5 OH Jefferson 741 3 726 3 PA Beaver 1,582 1 689 3 PA Crawford 981 0 168

SUMMARY FACTOR 5: EXPECTED GROWTH YOUNGSTOWN MSA Counties sorted by Growth Rate - Highest to Lowest Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 3 PA Butler 178,078 22,070 15 -156 -10 3 PA Crawford 89,856 4,197 5 -29 -3 5 OH Columbiana111,806 3,799 4 215 23 5 OH Trumbull 223,518 -2,697 -1 428 20 3 PA Mercer 119,514 -710 -1 -182 -13 3 PA Lawrence 94,104 -1,603 -2 59 7 3 PA Beaver 179,351 -4,681 -3 420 27 5 OH Mahoning 253,308 -7,251 -3 242 9

### 6-100 6.3.5 EPA 9-Factor Analyses for Virginia for the Designation of Nonattainment Areas for PM2.5 The fourth column of the following table identifies the counties and cities in Virginia that EPA intends to designate as nonattainment.

Area Virginia Counties and Cities in 1999 Metropolitan Statistical Area State of Virginia Recommendation EPA Recommendation of Virginia Counties and Cities

Washington, DC MSA(Part of the WashingtonBaltimore CMSA) Alexandria (City) Arlington Clarke Culpeper Fairfax Fairfax (City) Falls Church (City) Fauquier Fredericksburg King George Loudoun Manassas (City) Manassas Park (City) Prince William Spotsylvania Stafford Warren None Recommended Arlington Alexandria (City) Fairfax Fairfax (City) Falls Church (City) Loudoun Manassas (City) Manassas Park (City) Prince William

Total number of areas 17 0 9



### State Summary 6.3.5.1 Washington DC Area The Commonwealth of Virginia’s recommendation was submitted on February 13, 2003, in a letter from Robert B. Burnley. Based on the air quality data for the years 2001-2003, the Washington DC fine particulate (PM2.5) nonattainment area consists, in part, of the 17 northern counties/cities in Virginia. Virginia has recommended that all areas in the State be designated as attaining the PM2.5 standard. While EPA agrees with the State’s recommendations in part, we intend to modify the recommendations for the Virginia portion of the Washington DC MSA. EPA has identified five counties and four cities in Virginia that we recommend as nonattainment. The following discussion provides EPA’s rationale for considering the modification to Virginia’s recommendation.

Discussion The Washington DC Metropolitan Statistical Area (MSA) is part of the Washington DC Consolidated Metropolitan Statistical Area (CMSA). Because of the large size of the CMSA, it

### 6-101 has been split into three smaller areas to be more consistent with the ozone designations and to facilitate planning in the areas. The Washington DC MSA is comprised of 23 areas: 5 in Maryland, 17 in Virginia, and the District of Columbia. Washington DC and Prince Georges County in Maryland have monitored violations of the fine particulate (PM2.5) standard of 15.0 _g/m3

### . Based on the monitored violations, the Washington DC MSA is considered a presumptive nonattainment area. The Washington DC monitor is intended to be used as the Design Value monitor for this MSA. Summary of Evaluation EPA reviewed the 9 factors for the counties within the Metropolitan area as well as counties adjacent to the Metropolitan area in order to determine the appropriate nonattainment area. EPA agrees with Virginia’s recommendation of attainment for the following counties in the Washington DC MSA: Clarke, Culpeper, Fauquier, Fredericksburg, King George, Spotsylvania, Stafford, and Warren. Based on weighted emissions screening, EPA considers these counties to have low contribution to the nonattainment area. The combined factor analysis supports exclusion of these counties from the presumptive boundaries of the nonattainment area. The 9-factor analysis for Arlington, Alexandria, Fairfax, Fairfax (City), Falls Church, Loudoun, Manassas, Manassas Park, and Prince William support a designation of nonattainment, thus EPA intends to designate these counties as nonattainment. Arlington and Alexandria have significant populations and commuting into the nonattainment area (despite monitored attainment in Arlington), Fairfax has the highest population and commuting levels in the MSA and has moderate levels of emissions. Prince William has a high level of emissions, high population and population growth. Fairfax (City), Falls Church, Manassas, and Manassas Park are small areas (10 square miles or less) with high density populations that are entirely within the nonattainment area. The combined factor analysis for these areas indicate potential contribution to the violations in the nonattainment area, therefore EPA intends to designate them as nonattainment. Loudoun County has low emissions and has monitored attainment for 2001-2003 (13.6 _g/m3

### ). However, Loudoun County has experienced high growth, having had the highest population growth percentage in the MSA. The amount of population growth ranks third in the MSA from 1990-2000, and there is high population density in the eastern portion of the county. VMT growth is moderate, and a large percentage of the commuters are entering the other areas of the MSA. The combined factor analysis for Loudoun indicates potential contribution to the violations in the nonattainment area, therefore EPA intends to designate Loudoun County as nonattainment.

### 6-102 SUMMARY OF WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

3 DC Washington NonattainmentNonattainmentWashington, DC-MD-VA-WV 3 MD Calvert Attainment Attainment Washington, DC-MD-VA-WV 3 MD Charles Attainment NonattainmentWashington, DC-MD-VA-WV 3 MD Frederick Attainment NonattainmentWashington, DC-MD-VA-WV 3 MD Montgomery Attainment NonattainmentWashington, DC-MD-VA-WV 3 MD Prince Georges NonattainmentNonattainmentWashington, DC-MD-VA-WV 3 MD Washington Attainment NonattainmentHagerstown MD 3 VA Alexandria Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Arlington Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Clarke Attainment Attainment Washington, DC-MD-VA-WV 3 VA Culpeper Attainment Attainment Washington, DC-MD-VA-WV 3 VA Fairfax Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Fairfax (City) Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Falls Church Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Fauquier Attainment Attainment Washington, DC-MD-VA-WV 3 VA Fredericksburg Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA King George Attainment Attainment Washington, DC-MD-VA-WV 3 VA Loudoun Attainment Attainment Washington, DC-MD-VA-WV 3 VA Manassas Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Manassas Park Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Prince William Attainment NonattainmentWashington, DC-MD-VA-WV 3 VA Spotsylvania Attainment Attainment Washington, DC-MD-VA-WV 3 VA Stafford Attainment Attainment Washington, DC-MD-VA-WV 3 VA Warren Attainment Attainment Washington, DC-MD-VA-WV 3 WV Berkeley NonattainmentNonattainmentHagerstown, MD 3 WV Jefferson Attainment Attainment

### 6-103 SUMMARY OF FACTOR 1: EMISSIONS WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA ** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOC Amm CarbonCrustalWeighted Emissions Factor DC C/MSA 3 MD Montgomery 7,414 41,024 32,890 30,4241,108 3,478 3,254 12.0 3 MD Prince Georges 6,880 44,813 34,698 24,8781,122 3,083 2,918 11.0 3 MD Charles 7,916 79,120 20,928 5,146 204 1,974 4,773 9.0 3 VA Fairfax 3,213 3,428 33,000 37,5331,172 2,201 877 6.8 3 MD Frederick 2,523 10,114 12,701 8,765 2,270 988 1,347 3.4 3 MD Washington 1,822 6,256 13,064 7,379 1,556 713 938 3.2 3 VA Prince William 1,942 22,555 16,359 10,150528 817 881 3.3 3 DC Washington 1,839 8,200 14,823 17,7501,398 895 767 3.0 3 WV Berkeley 1,390 2,554 9,099 4,303 319 558 738 1.8 3 VA Spotsylvania 864 296 4,278 4,625 223 525 316 1.6 3 VA Alexandria 996 15,627 10,693 4,378 280 305 552 1.5 3 VA Loudoun 1,286 530 5,987 6,381 518 466 787 1.5 3 VA Stafford 889 359 5,562 4,591 204 485 378 1.5 3 VA Arlington 577 748 7,460 6,753 1,160 408 139 1.3 3 MD Calvert 870 647 3,146 3,342 153 377 465 1.2 3 VA Fauquier 830 239 4,082 3,711 935 401 409 1.2 3 WV Jefferson 758 906 2,918 2,105 321 255 488 0.8 3 VA Culpeper 488 143 1,818 2,133 441 216 243 0.7 3 VA Warren 345 160 2,441 2,299 190 194 140 0.6 3 VA Clarke 228 68 760 927 230 95 126 0.3 3 VA King George 263 514 1,436 942 107 106 141 0.3 3 VA Manassas 155 52 944 1,021 26 82 60 0.3 3 VA Fairfax (City) 113 39 417 941 28 56 55 0.2 3 VA Fredericksburg 83 108 1,383 1,300 40 55 22 0.2 3 VA Falls Church 59 17 250 580 9 36 20 0.1 3 VA Manassas Park 23 11 247 236 5 13 9 0.0

### 6-104 SUMMARY OF FACTOR 2: AIR QUALITY '01-'03 MSA Design Value = 16.3 Counties Sorted by Highest to Lowest Monitored or Estimated Value Design Values EPA Reg ST COUNTY '01-'03 '00-'02'99-'01

3 MD Prince Georges 17.7na17.4NA17.3na 3 WV Berkeley 16.3NA16.2NA16.0NA 3 DC Washington 15.8NA16.4NA16.6NA 3 VA Arlington 14.6A 14.9A 14.5a 3 MD Washington 14.0A 14.8A 13.5a 3 VA Fairfax 14.1A 13.9A 14.6a 3 VA Loudoun 13.6A 13.8A 13.6a 3 MD Montgomery 12.6A 13.4A 13.5a 3 WV Jefferson No monitor 3 MD Frederick No monitor 3 VA Alexandria No monitor 3 VA Clarke No monitor 3 VA Fauquier No monitor 3 MD Charles No monitor 3 VA Prince William No monitor 3 VA Warren No monitor 3 MD Calvert No monitor 3 VA King George No monitor 3 VA Stafford No monitor 3 VA Spotsylvania No monitor 3 VA Culpeper No monitor 3 VA Fairfax (City) No monitor 3 VA Falls Church No monitor 3 VA Fredericksburg No monitor 3 VA Manassas No monitor 3 VA Manassas Park No monitor

### 6-105 SUMMARY OF FACTOR 3A: POPULATION DENSITY AND DEGREE OF URBANIZATION WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties sorted by highest to lowest Actual Population Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
3 VA Fairfax 997,580 396 2519 3 MD Montgomery 910,156 495 1839 3 MD Prince Georges 833,084 486 1,714 3 DC Washington 570,898 61 9,359 3 VA Prince William 311,892 338 923 3 MD Frederick 209,125 663 315 3 VA Loudoun 204,054 520 392 3 VA Arlington 189,927 26 7305 3 MD Washington 134,246 458 293 3 VA Alexandria 130,804 15 8720 3 MD Charles 129,040 461 280 3 VA Stafford 104,823 270 388 3 VA Spotsylvania 102,570 401 256 3 WV Berkeley 81,262 321 253 3 MD Calvert 80,906 215 376 3 VA Fauquier 59,245 650 91 3 WV Jefferson 44,926 210 214 3 VA Manassas 37,288 10 3729 3 VA Culpeper 36,893 381 97 3 VA Warren 32,910 214 154 3 VA Fairfax (City) 22,055 6 3,676 3 VA Fredericksburg 20,076 11 1,825 3 VA King George 17,657 180 98 3 VA Clarke 13,290 177 75 3 VA Manassas Park 10,909 2 5,455 3 VA Falls Church 10,659 2 5,330

### 6-106 SUMMARY OF FACTOR 3B: POPULATION DENSITY/ DEGREE OF URBANIZATION Counties sorted by highest to lowest Population Density Population & Area EPA Reg ST COUNTY 2002 Area (sq miles)Density '02
3 DC Washington 570,898 61 9,359 3 VA Alexandria 130,804 15 8,720 3 VA Arlington 189,927 26 7,305 3 VA Manassas Park 10,909 2 5,455 3 VA Falls Church 10,659 2 5,330 3 VA Manassas 37,288 10 3,729 3 VA Fairfax (City) 22,055 6 3,676 3 VA Fairfax 997,580 396 2,519 3 MD Montgomery 910,156 495 1,839 3 VA Fredericksburg 20,076 11 1,825 3 MD Prince Georges 833,084 486 1,714 3 VA Prince William 311,892 338 923 3 VA Loudoun 204,054 520 392 3 VA Stafford 104,823 270 388 3 MD Calvert 80,906 215 376 3 MD Frederick 209,125 663 315 3 MD Washington 134,246 458 293 3 MD Charles 129,040 461 280 3 VA Spotsylvania 102,570 401 256 3 WV Berkeley 81,262 321 253 3 WV Jefferson 44,926 210 214 3 VA Warren 32,910 214 154 3 VA King George 17,657 180 98 3 VA Culpeper 36,893 381 97 3 VA Fauquier 59,245 650 91 3 VA Clarke 13,290 177 75

### 6-107 SUMMARY FACTOR 4: COMMUTING PATTERNS WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties sorted by highest VMT VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 VA Fairfax 10,532 46 242,944 3 MD Prince Georges 7,120 60 238,274 3 MD Montgomery 7,398 41 184,513 3 VA Prince William 2,786 65 98,427 3 VA Arlington 1,807 69 79,757 3 DC Washington 3,802 26 67,157 3 VA Alexandria 978 73 56,449 3 VA Loudoun 1,431 57 52,719 3 MD Frederick 2,508 39 40,199 3 MD Charles 1,006 56 34,316 3 VA Stafford 1,430 68 33,083 3 VA Spotsylvania 1,270 57 25,808 3 MD Calvert 848 50 18,711 3 VA Fauquier 1,005 56 15,753 3 VA Manassas 130 75 13,576 3 MD Washington 2,249 22 13,268 3 WV Berkeley 852 34 12,098 3 WV Jefferson 362 51 10,665 3 VA Fairfax (City) 124 76 9,014 3 VA Culpeper 405 40 6,393 3 VA Warren 339 39 6,019 3 VA Fredericksburg 451 54 5,188 3 VA Manassas Park 17 89 4,925 3 VA Falls Church 32 83 4,868 3 VA King George 263 41 3,329 3 VA Clarke 252 41 2,701

### 6-108 SUMMARY FACTOR 4: COMMUTING PATTERNS WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties Sorted by Highest Number of Commuters VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 VA Fairfax 10,532 46 242,944 3 MD Prince Georges 7,120 60 238,274 3 MD Montgomery 7,398 41 184,513 3 VA Prince William 2,786 65 98,427 3 VA Arlington 1,807 69 79,757 3 DC Washington 3,802 26 67,157 3 VA Alexandria 978 73 56,449 3 VA Loudoun 1,431 57 52,719 3 MD Frederick 2,508 39 40,199 3 MD Charles 1,006 56 34,316 3 VA Stafford 1,430 68 33,083 3 VA Spotsylvania 1,270 57 25,808 3 MD Calvert 848 50 18,711 3 VA Fauquier 1,005 56 15,753 3 VA Manassas 130 75 13,576 3 MD Washington 2,249 22 13,268 3 WV Berkeley 852 34 12,098 3 WV Jefferson 362 51 10,665 3 VA Fairfax (City) 124 76 9,014 3 VA Culpeper 405 40 6,393 3 VA Warren 339 39 6,019 3 VA Fredericksburg 451 54 5,188 3 VA Manassas Park 17 89 4,925 3 VA Falls Church 32 83 4,868 3 VA King George 263 41 3,329 3 VA Clarke 252 41 2,701

### 6-109 SUMMARY FACTOR 5: EXPECTED GROWTH WASHINGTON, DC MSA/ PART OF WASHINGTON DC CMSA MSA Counties Sorted by Highest Growth Rate Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 3 VA Loudoun 204,054 83,470 97 -217 -15 3 VA Spotsylvania 102,570 32,992 57 204 16 3 VA Manassas Park 10,909 3,556 53 3 VA Stafford 104,823 31,210 51 -225 -16 3 MD Calvert 80,906 23,191 45 144 17 3 VA Prince William 311,892 65,127 30 999 36 3 MD Frederick 209,125 45,069 30 -311 -12 3 WV Berkeley 81,262 16,652 28 -111 -13 3 VA Manassas 37,288 7,178 26 3 VA King George 17,657 3,276 24 50 19 3 VA Culpeper 36,893 6,471 23 46 11 3 VA Warren 32,910 5,442 21 -1 0 3 MD Charles 129,040 19,392 19 -77 -8 3 VA Fairfax 997,580 151,165 18 1,653 16 3 WV Jefferson 44,926 6,264 17 123 34 3 MD Montgomery 910,156 116,314 15 2,258 31 3 VA Alexandria 130,804 17,100 15 649 66 3 VA Fauquier 59,245 6,398 13 16 2 3 VA Arlington 189,927 18,517 11 693 38 3 MD Prince Georges 833,084 72,247 10 2,023 28 3 VA Fairfax (City) 22,055 1,876 10 163 131 3 MD Washington 134,246 10530 9 4,754 4 3 VA Falls Church 10,659 799 8 3 VA Clarke 13,290 551 5 -41 -16 3 VA Fredericksburg 20,076 252 1 3 DC Washington 570,898 -34,841 -6 738 19

### 6-110 Factor 8: Jurisdictional Boundaries The Baltimore-Washington CMSA has recently been designated nonattainment for the 8-hour ozone standard. In those designations, the CMSA was divided along MSA boundaries. These boundaries will also be used for the PM2.5

### designations. These areas are the Baltimore MSA, the Washington DC MSA, and the Hagerstown-Martinsburg MSA. These three areas are under the jurisdiction of separate planning organizations. The nonattainment boundaries that EPA intends to use will facilitate planning for ozone and PM2.5 by these separate organizations.

Factor 9: Level of Control of emission sources Virginia submitted additional information on the control of emissions in Prince William County. EPA reviewed the additional information. The emissions contribution from point sources have been reduced based on control technology installed in 2002. Population and commuting patterns, however, still indicate that Prince William is a significant contributor to the violations in the DC nonattainment area. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is nine Virginia Counties and cities as the Virginia portion of the Washington, DC nonattainment area. 6.3.6 EPA 9-Factor Analyses for West Virginia for the Designation of PM2.5 Nonattainment Areas The fourth column of the following table identifies the individual counties within West Virginia that EPA intends to designate as nonattainment.

Area West Virginia Counties in 1999 Metropolitan Statistical Area State of West Virginia Recommendation PM2.5 Designation

Charleston Kanawha Putnam Kanawha Putnam Kanawha Putnam
Huntington, WV-KY-OH Cabell Wayne Cabell Wayne Cabell Wayne Mason * Marion County, WV (Fairmont) Marion Marion Marion Monongalia * Harrison * Parkersburg, WV-OH Wood Wood Wood Pleasants * Steubenville, OH-WV Brooke Hancock Brooke Hancock Brooke Hancock

### 6-111 Hagerstown, MD Berkeley (Washington,MD) Berkeley Berkeley

Wheeling, WV-OH Marshall Ohio Marshall Ohio Marshall Ohio Total Number of Counties 11 11 15 *Portions of these counties are being designated as nonattainment. * We have included in our recommended nonattainment areas a county or counties in your state that are contiguous to a CMSA or MSA with a violating monitor, that are generally rural in character, and that contain an identifiable large emitting facility or facilities (e.g., power plants) which we believe contribute to the nearby nonattainment problem. We have included these counties in our initial recommendations in order to ensure that a sufficient portion of those counties, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of such contiguous counties, encompassing the large facility or facilities, should be designated nonattainment. The counties in your state, which we have included for this purpose, are Mason, Harrison, Monongalia, andPleasants. 

### State Summary The State of West Virginia, in the Secretary Timmermeyer correspondence of February 13, 2004, recommended 12 counties as nonattainment. Additional data was provided by West Virginia on June 3, 2004. In the June 3 correspondence, West Virginia revised its recommendation to 11 counties; excluding Jefferson County from the nonattainment recommendation. Based on the air quality data for the years 2001-2003, there are seven presumptive fine particulate (PM2.5) nonattainment areas consisting of 11 counties in West Virginia. EPA agrees with the recommendation that all 11 counties be designated nonattainment. In addition, EPA intends to modify the recommendations for the Charleston, Marion County, and Parkersburg areas with the addition of four adjacent counties. The following provides a rationale for EPA’s intended modification to the West Virginia recommendations.

6.3.6.1 Charleston Area

Discussion The Charleston Metropolitan Statistical Area (MSA) is comprised of two counties: Putnam and Kanawha. Kanawha County, part of the MSA has monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Charleston MSA is considered a presumptive nonattainment area. Kanawha County has monitored 17.1 _g/m3

### for the time period 2001-2003. This monitor is intended to be used as the Design Value monitor for the Charleston nonattainment area. The State of West Virginia, in the Secretary Timmermeyer correspondence of February 13, 2004, recommended the two MSA counties to be included in the Charleston nonattainment area. EPA has reviewed the State’s recommendations as well as additional data provided by West Virginia on June 3, 2004 and agrees with the original recommendation. EPA agrees with the recommendation to include these two counties. EPA, however, intends to add an adjacent county, Mason, to the nonattainment area

.

### 6-112 Summary of Evaluation Based on weighted emissions screening, EPA has identified Jackson, Roane, Clay, Nicholas, Fayette, Raleigh, Boone and Lincoln to have relatively low emissions contribution to the metropolitan area. A review of the remaining factors, including monitored attainment in Raleigh County, provides additional evidence for the designation of attainment for these surrounding counties. Mason and Putnam Counties, however, show higher contributions to the area, based on the weighted emissions factor. Therefore, EPA has reviewed these counties based on the remaining 8 factors to determine the appropriate designation. Putnam County, part of the MSA, and Mason, an adjacent county, show comparable emissions and similar air quality estimates. The population density and commuting patterns of Mason when compared to the core MSA counties in this area are not, however, substantial. As seen in the attached data summary, considering wind and distance, Mason County has twice the estimated emission contribution as the next highest attainment county. Mason County is located between the Huntington presumptive nonattainment area and the Charleston presumptive nonattainment area. The addition of Mason County to the Charleston area creates a contiguous area. As seen in the topographic map below, the natural advective air flow along the Kanawha River valley may also enhance the contribution of emissions from Mason County into the nonattainment area.

### 6-113 EPA intends, based on this review, to modify the West Virginia recommended nonattainment boundary and include Mason County with the Charleston MSA. A summary of the data that supports the addition of Mason County to the State’s recommendation is provided below.

### 6-114 SUMMARY OF CHARLESTON, WV MSA

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5 DESIGNATION Area - '99 C/MSA

3 WV Putnam NonattainmentNonattainment Charleston, WV 3 WV Kanawha NonattainmentNonattainment Charleston, WV 3 WV Mason Attainment Nonattainment (Huntington) 3 WV Fayette Attainment Attainment 3 WV Raleigh Attainment Attainment 3 WV Jackson Attainment Attainment 3 WV Nicholas Attainment Attainment 3 WV Boone Attainment Attainment 3 WV Lincoln Attainment Attainment 3 WV Roane Attainment Attainment 3 WV Clay Attainment Attainment 3 WV Logan Attainment Attainment 3 WV Wyoming Attainment Attainment 3 WV Mingo Attainment Attainment 3 WV Braxton Attainment Attainment 3 WV Calhoun Attainment Attainment

### 6-115 SUMMARY OF FACTOR 1: EMISSIONS CHARLESTON, WV MSA Counties sorted by Largest Weighted Emissions Contribution Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOx VOC AmmCarbonCrustalWeighted Emissions Factor 3 WVPutnam 4,39580,15039,7953,752 97 1,165 2,604 20.3 3 WVKanawha 2,68324,10927,11916,506396 1,266 1,182 18.0 3 WV Cabell 2,3655,155 27,9037,080 181 1,318 774 17.7 3 WV Mason 3,61070,05331,3272,831 264 899 2,162 16.2 3 WV Fayette 1,5364,485 5,065 3,134 100 479 950 6.3 3 WV Raleigh 930 456 4,595 5,220 170 472 417 6.0 3 WV Jackson 1,7803,464 3,947 2,394 158 451 1,128 5.9 3 WV Wayne 550 1,023 6,485 2,620 56 317 199 4.2 3 WV Logan 410 152 1,620 2,158 49 214 181 2.7 3 WV Nicholas 434 193 1,102 1,720 84 206 208 2.6 3 WV Wyoming 470 430 3,981 1,807 142 197 238 2.6 3 WV Boone 412 118 1,571 1,298 30 197 190 2.5 3 WV Mingo 437 281 2,842 1,379 150 191 217 2.5 3 WV Braxton 312 138 2,265 1,597 91 185 109 2.4 3 WV Lincoln 259 67 1,314 1,128 37 143 108 1.8 3 WV Roane 213 106 1,083 1,108 99 119 87 1.5 3 WV Clay 155 41 533 542 28 94 57 1.2 3 WV Calhoun 114 43 937 512 35 68 42 0.9

SUMMARY OF FACTOR 2: AIR QUALITY CHARLESTON ,WV MSA Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01

3 WV Putnam NO MONITOR 3 WV Kanawha 17.1NA17.8NA18.4NA 3 WV Mason NO MONITOR 3 WV Fayette NO MONITOR 3 WV Raleigh 13.1A 13.5A 14.0A 3 WV Jackson NO MONITOR 3 WV Nicholas NO MONITOR 3 WV Boone NO MONITOR 3 WV Lincoln NO MONITOR 3 WV Roane NO MONITOR 3 WV Clay NO MONITOR

### 6-116 SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF URBANIZATION CHARLESTON, WV MSA Counties Sorted by Population - Highest to Lowest Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
3 WV Kanawha 195,790 903 217 3 WV Raleigh 78,899 607 130 3 WV Putnam 52,230 346 151 3 WV Fayette 47,129 664 71 3 WV Jackson 28,204 466 61 3 WV Nicholas 26,404 649 41 3 WV Mason 26,004 432 60 3 WV Boone 25,554 503 51 3 WV Lincoln 22,256 438 51 3 WV Roane 15,267 484 32 3 WV Clay 10,357 342 30

SUMMARY FACTOR 4: COMMUTING PATTERNS CHARLESTON, WV MSA Counties sorted by VMT - Highest to Lowest VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 WV Kanawha 2,600 4 3,500 3 WV Raleigh 1,028 2 643 3 WV Fayette 605 12 1,904 3 WV Putnam 578 48 11,367 3 WV Jackson 511 19 2,152 3 WV Nicholas 359 5 468 3 WV Boone 300 35 2,972 3 WV Mason 270 8 763 3 WV Roane 183 25 1,319 3 WV Lincoln 154 33 2,324 3 WV Clay 116 30 925

### 6-117 SUMMARY FACTOR 5: EXPECTED GROWTH CHARLESTON, WV MSA Counties sorted by Growth Rate - Highest to Lowest Population VMT EPA RegST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 3 WV Putnam 52,230 8,754 20 53 9 3 WV Jackson 28,204 2,062 8 -231 -45 3 WV Mason 26,004 779 3 23 9 3 WV Raleigh 78,899 2,401 3 -199 -19 3 WV Lincoln 22,256 726 3 141 92 3 WV Clay 10,357 347 3 21 19 3 WV Roane 15,267 326 2 26 14 3 WV Fayette 47,129 -373 -1 -18 -3 3 WV Nicholas 26,404 -213 -1 -50 -14 3 WV Boone 25,554 -335 -1 24 8 3 WV Kanawha 195,790 -7,546 -4 432 17



### Factor 8: Jurisdictional Boundaries The 1999 MSA was expanded in 2003 to include Lincoln, Boone and Clay counties. The review of these counties, however, did not provide sufficient evidence to include these counties in the nonattainment area. The Charleston area has recently been designated nonattainment for the 8-hour ozone standard. Similar to the fine particulate monitoring, Kanawha monitored a violation of the 8-hour ozone standard. Kanawha and Putnam were included in the ozone nonattainment area.

Factor 9: Level of Control EPA identified large sources greater than 1000 tons per year for any pollutant and evaluated its distance to a violating monitor for fine particulate. This screening identified the closest large source to be 37 miles from the Kanawha violating monitor. West Virginia has provided additional information on the level of control of the Mountaineer and Philip Sporn power plants. There was a reduction in NOx in 2002 due to installation of NOx controls on the Mountaineer plant (1300 MW). Additional SO2

### controls are also planned in 2007 for this plant. The Philip Sporn plant (1050 MW) does not currently, nor has plans to install, state-of-the-art controls. A review of the reductions from the controls added to Mountaineer does not substantially change the estimated emissions contribution to the nonattainment area. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Mason County was an adjacent county proposed to be included with the nonattainment area largely because of the emissions from two power plants. The State of West Virginia has provided additional information and rationale for including a portion of the County containing the power plants to the adjacent Huntington-Ashland nonattainment area. The

### 6-118 two power plants, Mountaineer and Philip Sporn, are located at the northern edge of Mason County. Apart from the emissions of the power plants the County is mostly rural and the parameters of the factors relating to population, vehicle miles traveled and commuting rank well below the factors for the two counties in the Charleston MSA. The partial county associated with the Huntington-Ashland area is described in section 6.3.6.2. EPA is designating Putnam and Kanawha as the Charleston nonattainment area. 6.3.6.2 Huntington Ashland (KY-WV-OH) Area

Discussion The Huntington Metropolitan Statistical Area (MSA) is comprised of six counties including two counties in West Virginia. Two counties in this MSA have monitored violations of the fine particulate (PM2.5) National Ambient Air Quality Standard (NAAQS) of 15.0 _g/m3

### . Based on the monitored violations, the Huntington MSA is considered a presumptive nonattainment area. Cabell County, WV is part of the MSA and monitored 16.6 _g/m3

### for the time period 2001-2003. This value is being considered the Design Value for the nonattainment area. The State of West Virginia, in the Secretary Timmermeyer correspondence of February 13, 2004, recommended the two MSA counties to be included in the Huntington nonattainment area. EPA has reviewed the State’s recommendations as well as additional data provided by West Virginia on June 3, EPA agrees with the recommendation to include Cabell and Wayne Counties. Additional counties in Kentucky and Ohio have been reviewed and designated by EPA Regions 4 and 5, respectively. A summary of the designations is found in the table below; however, data and analysis on those counties are found in separate documents generated by each respective region. Summary of Evaluation Based on weighted emissions, EPA estimates that Mingo and Lincoln counties, adjacent to the Huntington MSA have relatively low emissions contribution to the metropolitan area. A review of the remaining factors provided additional evidence for the designation of attainment for these surrounding counties. Data supporting EPA’s intended designation for the West Virginia counties as part of the Huntington nonattainment area is provided below.

### 6-119 Summary Huntington-Ashland, WV-KY-OH MSA

EPA RegST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

4 KY Boyd "Defer" Nonattainment Huntington-Ashland, WV-KY-OH 3 WV Cabell NonattainmentNonattainment Huntington-Ashland, WV-KY-OH 4 KY Carter Attainment Attainment Huntington-Ashland, WV-KY-OH 4 KY Greenup Attainment Attainment Huntington-Ashland, WV-KY-OH 5 OH Lawrence NonattainmentNonattainment Huntington-Ashland, WV-KY-OH 3 WV Wayne NonattainmentNonattainment Huntington-Ashland, WV-KY-OH 5 OH Adams Attainment Nonattainment 4 KY Elliott Attainment Attainment 5 OH Gallia Attainment Nonattainment 5 OH Jackson Attainment Attainment 4 KY Lawrence Attainment Nonattainment 4 KY Lewis Attainment Attainment 3 WV Lincoln Attainment Attainment Adjacent County 4 KY Martin Attainment Attainment 3 WV Mingo Attainment Attainment Adjacent County 5 OH Pike Attainment Attainment 4 KY Rowan Attainment Attainment 5 OH Scioto NonattainmentNonattainment Adjacent County with Violating Monitor

### 6-120 SUMMARY OF FACTOR 1: EMISSIONS Huntington-Ashland, WV-KY-OH MSA ** Counties Listed by Percent Contribution to Harrisburg CMSA** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOX VOCAmmCarbonCrustalWeighted Emissions Factor PM2.5Designation

5 OH Gallia 10,010164,98461,0791,839300 2,171 6,238 141.4 Nonattainment 5 OH Adams 6,417 125,13652,9921,508431 1,435 3,973 102.4 Nonattainment 5 KY Lawrence 2,903 56,066 21,265919 56 745 1,718 48.3 Nonattainment 3 WV Cabell 2,365 5,155 27,9037,080181 1,318 774 40.3 Nonattainment 5 KY Boyd 2,314 11,740 13,4788,620467 689 1,242 25.2 Nonattainment 5 OH Scioto 1,053 2,790 5,566 4,703350 400 559 12.5 Nonattainment 3 WV Wayne 550 1,023 6,485 2,62056 317 199 9.6 Nonattainment 5 KY Greenup 477 2,519 4,336 1,795156 295 160 9.5 Attainment 5 OH Lawrence 770 841 4,399 4,366207 293 379 8.6 Nonattainment 5 KY Lewis 429 469 2,873 990 222 285 121 8.1 Attainment 5 KY Carter 506 237 2,615 1,996223 242 249 6.8 Attainment 5 OH Pike 425 4,203 2,081 1,311149 172 237 6.8 Attainment 5 KY Rowan 336 313 1,691 1,53591 204 123 5.7 Attainment 3 WV Mingo 437 281 2,842 1,379150 191 217 5.5 Attainment 5 OH Jackson 404 461 1,320 1,717165 164 219 4.7 Attainment 5 KY Martin 281 661 1,236 706 762 136 131 4.0 Attainment 3 WV Lincoln 259 67 1,314 1,12837 143 108 4.0 Attainment 5 KY Elliott 164 115 393 313 42 114 46 3.1 Attainment

SUMMARY OF FACTOR 2: AIR QUALITY Huntington-Ashland, WV-KY-OH MSA Design Values EPA RegST COUNTY '01-'03 '00-'02 '99-'01

4 KY Boyd 15.0A 15.7NA15.5NA 3 WV Cabell 16.6NA17.3NA17.8NA 4 KY Carter 12.2A 13.1A 12.9A 4 KY Greenup No Monitor 5 OH Lawrence 15.8NA16.7NA17.4na 3 WV Wayne No Monitor 5 OH Scioto 17.2NA17.5NA20.0NA

Region III in agreement with West Virginia Recommendation for Huntington MSA

### 6-121 Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA expressed intent to designate a number of counties nonattainment primarily because of high pollutant emissions from power plants. Most of these plants were located in counties outside but near to the metropolitan area. EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas), or where the source is not located close enough to where the partial county boundary could be contiguous to the rest of the nonattainment area. Such free-standing portions of nonattainment areas should only be established based on a pre-existing boundary for a minor civil division such as a township, tax district, or other defined boundary recognized for other governmental use. Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. As noted in section 6.3.6.1 above, after consultation with the State of West Virginia EPA has added the portion of Mason County which contains the Mountaineer and Philip Sporn power plants to the Huntington-Ashland area. Mason County has population, vehicle miles traveled and commuting factors which are lower than the factors for the six counties in the three-state MSA. The primary reason for including the adjacent county of Mason is the contribution of emissions from two power plants. The state of West Virginia has submitted, as requested, an identification of a partial county to include the Mountaineer and Philip Sporn power plants. In Mason County the Tax District of Graham is nonattainment. The remainder of Mason County is attainment/unclassifiable. Tax District Boundaries were selected as the minor civil division to identify partial county areas. Tax district boundary lines were adopted by the West Virginia Legislature in 1978 as a general reference to delineate rural tax district boundaries. The boundaries were drawn from 1:24,000-scale USGS topographic maps in 1978 and coincide with county magisterial districts as of July 1, 1973. Unlike magisterial districts that are realigned every ten years following the census, the tax district boundary does not follow equal representation requirements.

### 6-122 6.3.6.3 Marion Area (Fairmont CSA)

Discussion The Marion area is a county that is not part of a 1999 Metropolitan Statistical area. In 2003, however, the Office of Management and Budget (OMB) delineated new boundaries using the 2000 Census Data. Marion was included in the Fairmont CBSA in 2003. Harrison and Preston Counties, part of the 2003 Clarksburg CBSA are included with Marion in the larger 2003 Combined Statistical Area (CSA). Marion County has monitored violations of the fine particulate (PM2.5

### ) National Ambient Air Quality Standard (NAAQS) of 15.0 μg/m_. Based on the monitored violations, the Fairmont CSA is considered a presumptive nonattainment area. Marion County has monitored 15.4 μg/m3

### for the time period 2001-2003. This monitor is intended to be used as the Design Value monitor for the Marion nonattainment area. The State of West Virginia, in the Secretary Timmermeyer correspondence of February 13, 2004, recommended the single county as a nonattainment area EPA has reviewed the State’s recommendations as well as additional data provided by West Virginia on June 3, 2004. EPA agrees with the recommendation for Marion County, however, EPA intends to add two adjacent counties, Harrison and Monongalia, to the nonattainment area. Summary of Evaluation Based on weighted emissions screening, EPA has identified Wetzel County and Taylor County to have relatively low emissions contribution to the metropolitan area. Review of the remaining factors, provides additional evidence for the designation of attainment for these surrounding counties. Harrison, Preston and Monongalia counties, however, show higher contribution to the area, based on the weighted emissions factor. Population density and commuting patterns are relatively small in this rural area. Although both Harrison and Monongalia have monitored attainment, estimates show potential exceedances of the standard in other parts of Monongalia County. The actual emissions from Harrison and Monongalia counties, are estimated to substantially contribute to the monitored violations in Marion County when reviewed with topography and meteorology. EPA intends to modify the West Virginia recommended nonattainment boundary and include Harrison and Monongalia counties with the Marion MSA. A summary of the data that supports the modification of the State’s recommendation is provided below.

### 6-123 SUMMARY OF MARION, WV AREA

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA N/A 2003 CBSA Area Listed

! 3 WV Marion NonattainmentNonattainmentFairmount CBSA 3 WV Monongalia Attainment NonattainmentMorgantown, WV CBSA 3 WV Harrison Attainment NonattainmentClarksburg, WV CBSA 3 WV Wetzel Attainment Attainment 3 WV Taylor Attainment Attainment Clarksburg, WV CBSA

### 6-124 SUMMARY OF FACTOR 1: EMISSIONS MARION, WV AREA ** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOX VOC AmmCarbonCrustalWeighted Emissions Factor 3 WV Monongalia 5,459 81,413 17,545 5,606 185 1,320 3,331 54.7 3 WV Harrison 2,781 7,671 35,477 4,641 240 657 1,748 28.1 3 WV Preston 1,715 21,864 6,528 1,874 271 465 1,021 17.4 3 WV Marion 777 7,953 6,069 3,075 102 295 413 10.0 3 WV Wetzel 260 698 4,323 1,720 45 160 79 4.8 3 WV Lewis 244 372 4,095 1,795 123 143 87 4.3 3 WV Upshur 342 141 1,583 1,676 90 178 150 4.0 3 WV Barbour 294 84 800 740 200 131 145 2.8 3 WV Tyler 292 176 1,233 1,869 44 122 126 2.8 3 WV Taylor 253 416 2,595 721 67 73 128 2.5 3 WV Ritchie 166 118 713 636 75 97 63 2.1 3 WV Gilmer 122 24 1,088 640 47 73 44 1.8 3 WV Doddridge 123 30 798 434 39 73 46 1.7

SUMMARY OF FACTOR 2: AIR QUALITY MARION, WV AREA Design Values EPA RegST COUNTY '01-'03 '00-'02 '99-'01

3 WV Marion 15.4 NA15.7 NA15.9 na 3 WV Monongalia 14.9 A 15.0 A 15.0 A 3 WV Harrison 14.0 A 14.5 A 14.8 A

SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF UBANIZATION MARION, WV AREA Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
3 WV Marion 56,433 310 182 3 WV Monongalia 82,895 361 230 3 WV Harrison 67,856 416 163

### 6-125 SUMMARY FACTOR 4: COMMUTING PATTERNS MARION, WV AREA
VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 WV Marion 475 3 WV Monongalia 810 3 1,234 3 WV Harrison 707 6 1,651

SUMMARY FACTOR 5: EXPECTED GROWTH MARION, WV AREA Population VMT EPA Reg ST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 3 WV Marion 56,433 -651 -1 95 20 3 WV Monongalia 82,895 6,357 8 -180 -22 3 WV Harrison 67,856 -719 -1 -47 -7


### Factor 8: Jurisdictional Boundaries The 1999 MSA was expanded in 2003 to include Harrison, Taylor and Doddridge Counties. The review of Taylor and Doddridge Counties, however, did not provide sufficient evidence to include these counties in the nonattainment area.

Factor 9: Level of Control EPA identified large sources greater than 1000 tons per year for any pollutant and evaluated its distance to a violating monitor for fine particulate. There are large uncontrolled sources in Monongalia and Harrison counties. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA expressed intent to designate a number of counties nonattainment primarily because of high pollutant emissions from power plants. Most of these plants were located in counties outside but near to the metropolitan area. EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant.

### 6-126 After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas), or where the source is not located close enough to where the partial county boundary could be contiguous to the rest of the nonattainment area. Such free-standing portions of nonattainment areas should only be established based on a pre-existing boundary for a minor civil division such as a township, tax district, or other defined boundary recognized for other governmental use. Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. All of the counties in the proposed Marion County (AKA Fairmont CBSA) nonattainment area are predominantly rural in nature. The primary reason for including the adjacent counties of Monongalia and Harrison is the contribution of emissions from power plants. The state of West Virginia has submitted, as requested, an identification of partial counties to include the Fort Martin and Harrison power plants. In Monongalia County the Tax District of Cass is nonattainment. The remainder of Monongalia County is attainment/unclassifiable. In Harrison County the Tax District of Clay and Eagle is nonattainment. The remainder of Harrison County is attainment/unclassifiable. Tax District Boundaries were selected as the minor civil division to identify partial county areas. Tax district boundary lines were adopted by the West Virginia Legislature in 1978 as a general reference to delineate rural tax district boundaries. The boundaries were drawn from 1:24,000-scale USGS topographic maps in 1978 and coincide with county magisterial districts as of July 1, 1973. Unlike magisterial districts that are realigned every ten years following the census, the tax district boundary does not follow equal representation requirements. 6.3.6.4 Parkersburg Area
Discussion The Parkersburg Metropolitan Statistical Area (MSA) is comprised of two counties: Wood County, WV and Washington County, OH. Wood County, part of the MSA has monitored violations of the fine particulate (PM2.5

### ) National Ambient Air Quality Standard (NAAQS) of 15.0 μg/m_. Based on the monitored violations, the Parkersburg MSA is considered a presumptive nonattainment area. Wood County has monitored 16.0 μg/m3

### for the time period 2001-2003. This monitor is intended to be used as the Design Value monitor for the Parkersburg nonattainment area. Review of the Ohio counties has been done by EPA Region 5 and is specified in documentation generated by that Region. The EPA intended designation for Ohio counties is provided in the table below. The State of West Virginia, in the Secretary Timmermeyer correspondence of February 13, 2004, recommended Wood County to be included in the Parkersburg nonattainment area. EPA has reviewed the State’s recommendations as well as additional data provided by West Virginia on June 3, 2004 and agrees with the recommendation for Wood County, however, EPA intends to add an adjacent county, Pleasants County, WV, to the nonattainment area.

### 6-127 Summary of Evaluation Based on weighted emissions screening, EPA has identified Tyler, Ritchie, and Roane and Calhoun counties in West Virginia to have relatively low emissions contribution to the metropolitan area. Review of the remaining factors provided additional evidence for the designation of attainment for these surrounding counties. Pleasants and Wirt counties were added to the Parkersburg metropolitan area in the revised 2003 OMB metropolitan definition. Closer examination highlights the emissions contribution by Pleasants County to the area. Wirt County, in contrast, has low estimated emissions contribution to the area. Wood County, part of the MSA, and Pleasants County, an adjacent county, show comparable emissions and similar air quality estimates. The population density and commuting patterns of Pleasants when compared to the core MSA counties in this area are not, however, substantial. The geography, however, does provide supporting information for designation of nonattainment as a contributing county. A small portion of Pleasants County juts into the metropolitan area. This portion of the county contains a major emitting source. EPA intends, based on this review, to modify the West Virginia recommended nonattainment boundary and include Pleasants County with the Parkersburg MSA. A summary of the data that supports the addition of Pleasants County to the State’s recommendation is provided below.

Parkersburg WV-OH MSA

EPA RegST COUNTY State Recommend PM2.5 Designation PM2.5 Designation Area - '99 C/MSA

5 OH Washington Attainment NonattainmentParkersburg-Marietta, WV-OH 3 WV Wood NonattainmentNonattainmentParkersburg-Marietta, WV-OH 5 OH Athens Attainment Attainment 3 WV Calhoun Attainment Attainment 3 WV Jackson Attainment Attainment 5 OH Meigs Attainment Attainment 5 OH Monroe Attainment Attainment 5 OH Morgan Attainment Attainment 5 OH Noble Attainment Attainment 3 WV Pleasants Attainment Nonattainment Parkersburg 2003 CBSA 3 WV Ritchie Attainment Attainment 3 WV Roane Attainment Attainment 3 WV Tyler Attainment Attainment 3 WV Wirt Attainment Attainment Parkersburg 2003 CBSA

### 6-128 SUMMARY OF FACTOR 1: EMISSIONS PARKERSBURG WV-OH MSA ** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOX VOC AmmCarbonCrustalWeighted Emissions Factor 5 OH Washington 10,743 173,312 37,020 5,274 565 2,415 6,711 48.4 3 WV Pleasants 2,602 68,264 23,398 1,337 29 823 1,411 17.7 3 WV Wood 1,144 6,514 6,943 7,148 243 591 482 10.3 3 WV Jackson 1,780 3,464 3,947 2,394 158 451 1,128 7.7 5 OH Athens 417 733 3,166 2,400 204 176 222 3.1 5 OH Monroe 715 4,532 2,809 1,166 230 162 504 3.0 5 OH Meigs 309 375 2,244 1,051 164 147 145 2.5 3 WV Tyler 292 176 1,233 1,869 44 122 126 2.1 3 WV Ritchie 166 118 713 636 75 97 63 1.6 5 OH Morgan 217 81 558 921 228 88 122 1.5 5 OH Noble 219 144 1,622 1,377 197 87 127 1.5 3 WV Wirt 84 19 206 406 45 46 36 0.8 3 WV Roane 213 106 1,083 1,108 99 119 87 2.0 3 WV Calhoun 114 43 937 512 35 68 42 1.2

SUMMARY OF FACTOR 2: AIR QUALITY PARKERSBURG WV-OH MSA Design Values EPA RegST COUNTY '01-'03 '00-'02 '99-'01

5 OH Washington No monitor 3 WV Wood 16.0NA17.0 NA17.6NA 3 WV Pleasants No monitor 3 WV Wirt No monitor

SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF UBANIZATION PARKERSBURG WV-OH MSA Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
5 OH Washington 62,561 635 99 3 WV Wood 87,306 367 238 3 WV Pleasants 7,579 131 58 3 WV Wirt 5,935 233 25

### 6-129 SUMMARY FACTOR 4: COMMUTING PATTERNS PARKERSBURG WV-OH MSA
VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 5 OH Washington 737 21 5,927 3 WV Wood 911 9 3,316 3 WV Pleasants 78 35 1,026 3 WV Wirt 44 54 1,215

SUMMARY FACTOR 5: EXPECTED GROWTH PARKERSBURG WV-OH MSA Population VMT EPA Reg ST COUNTY 2002 Growth '90- '00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 5 OH Washington 62,561 997 2 19 3 3 WV Wood 87,306 1,071 1 108 12 3 WV Pleasants 7,579 -32 -0 26 33 3 WV Wirt 5,935 681 13 28 64


### Factor 8: Jurisdictional Boundaries The 1999 MSA was expanded in 2003 to include Pleasants and Wirt counties. The review of Wirt County, however, did not provide sufficient evidence to include these counties in the nonattainment area. The Parkersburg area has recently been designated nonattainment for the 8-hour ozone standard. Wood County, WV and Washington County, OH both monitored violations of the ozone standard.

Factor 9: Level of Control EPA identified large sources greater than 1000 tons per year for any pollutant and evaluated its distance to a violating monitor for fine particulate. This screening identified the Pleasants Power Plant 13 miles from the violating monitor. West Virginia has provided additional information on the level of control of the Pleasants plant. Additional NOX controls have recently been added to the power plant. The 1200 MW plant is now well controlled. There is a 15% scrubber bypass currently operating on the plant, however. The much smaller Willow Island power plant (228 MW) is located in Pleasants County and is not well controlled. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States In the June 2004 letters from EPA to the States responding to their designation recommendations, EPA expressed intent to designate a number of counties nonattainment primarily because of high pollutant emissions from power plants. Most of these plants were

### 6-130 located in counties outside but near to the metropolitan area. EPA suggested that a State could provide a partial county boundary that would extend to the relevant power plant to include it in the nonattainment area. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas), or where the source is not located close enough to where the partial county boundary could be contiguous to the rest of the nonattainment area. Such free-standing portions of nonattainment areas should only be established based on a pre-existing boundary for a minor civil division such as a township, tax district, or other defined boundary recognized for other governmental use. Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. All of the counties in the proposed Parkersburg nonattainment area are predominantly rural in nature. The primary reason for including the adjacent county of Pleasants is the contribution of emissions from the Pleasants power plant The state of West Virginia has submitted, as requested, an identification of partial counties to include the power plant. In Pleasants County the Tax District of Grant is nonattainment. The remainder of Pleasants County is attainment/unclassifiable. Tax District Boundaries were selected as the minor civil division to identify partial county areas. Tax district boundary lines were adopted by the West Virginia Legislature in 1978 as a general reference to delineate rural tax district boundaries. The boundaries were drawn from 1:24,000-scale USGS topographic maps in 1978 and coincide with county magisterial districts as of July 1, 1973. Unlike magisterial districts that are realigned every ten years following the census, the tax district boundary does not follow equal representation requirements. EPA is designating Wood and part of Pleasants counties as the West Virginia portion of the Parkersburg nonattainment area.
6.3.6.5 Steubenville OH-WV Area

Discussion The Steubenville-Weirton MSA includes three counties. Two counties in West Virginia, Brooke and Hancock, as well as Jefferson County, OH. The surrounding counties have been evaluated and designated as part of the Pittsburgh and Wheeling nonattainment areas. Hancock and Brooke counties both monitored violations of the fine particulate (PM2.5

### ) National Ambient Air

### 6-131 Quality Standard (NAAQS) of 15.0 μg/m_. Based on the monitored violations, the Steubenville MSA is considered a presumptive nonattainment area. Jefferson County, OH has monitored 17.8 μg/m3

### for the time period 2001-2003. This monitor is intended to be used as the Design Value monitor for the Steubenville nonattainment area. The State of West Virginia, in the Secretary Timmermeyer correspondence of February 13, 2004, recommended Hancock and Brooke counties as part of the Steubenville nonattainment area. EPA has reviewed the State’s recommendations as well as additional data provided by West Virginia on June 3, 2004. EPA agrees with the recommendation. Summary of Evaluation Both counties recommended by the State have monitored violations of the standard. Adjacent counties are for the most part have been analyzed under other metropolitan areas. Data supporting EPA’s intended nonattainment boundaries and West Virginia’s recommendation is provided below.

STATUS OF STEUBENVILLE MSA AND SURROUNDING AREA

EPA Reg ST COUNTY State Recommend PM2.5 Designation PM2.5DesignationArea - '99 C/MSA

eparegionstpostal county_name state_rec msa_name C/MSA Total (excluding surrounding) = 3 counties 3 WV Brooke NonattainmentNonattainment Steubenville-Weirton, OH-WV 3 WV Hancock NonattainmentNonattainment Steubenville-Weirton, OH-WV 5 OH Jefferson NonattainmentNonattainment Steubenville-Weirton, OH-WV 3 PA Beaver NonattainmentNonattainment Pittsburgh, PA 5 OH Belmont Attainment Nonattainment Wheeling, WV-OH 5 OH Columbiana Attainment Nonattainment Youngstown-Warren, OH 3 WV Ohio NonattainmentNonattainment Wheeling, WV-OH 3 PA Washington NonattainmentNonattainment Pittsburgh, PA 5 OH Carroll Attainment Attainment Canton-Massillon, OH 5 OH Harrison Attainment Attainment

### 6-132 SUMMARY OF FACTOR 1: EMISSIONS STEUBENVILLE MSA ** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOX VOC AmmCarbonCrustalWeighted Emissions Factor 5 OH Jefferson 12,247 217,794 61,402 4,082 287 2,723 7,529 39.9 3 PA Beaver 4,948 40,380 39,564 8,738 543 1,368 2,900 18.8 3 PA Washington 3,011 8,221 22,097 9,392 813 1,190 1,505 12.5 5 OH Belmont 2,797 51,374 13,036 4,211 464 734 1,667 9.6 3 WV Hancock 4,335 1,982 4,961 3,585 571 1,243 1,747 9.4 5 OH Columbiana 1,187 1,291 5,825 5,881 1,250 442 696 4.2 3 WV Ohio 351 514 3,609 2,779 123 192 135 1.9 3 WV Brooke 527 1,663 2,500 4,358 439 191 277 1.8 5 OH Carroll 363 386 1,886 1,422 375 120 234 1.2 5 OH Harrison 191 258 712 786 254 70 116 0.6

SUMMARY OF FACTOR 2: AIR QUALITY STEUBENVILLE MSA Design Values EPA Reg ST COUNTY '01-'03 '00-'02 '99-'01 3 WV Brooke 16.8 NA 16.8 NA 17.4 NA 3 WV Hancock 17.4 NA 17.5 NA 17.4 NA 5 OH Jefferson 17.8 NA 18.2 NA 18.9 NA The two Region 3 counties to be evaluated as part of the Steubenville MSA have monitored violations of the PM2.5 Standard. Evaluation of the remaining factors is not necessary.



### Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating Brooke and Hancock counties as the West Virginia portion of the Steubenville nonattainment area.

6.3.6.6 Hagerstown-Martinsville Area

Discussion Berkeley County, WV has monitored violations of the fine particulate (PM2.5

### ) National Ambient Air Quality Standard (NAAQS) of 15.0 μg/m_. Based on the monitored violations, this county is considered a presumptive nonattainment area. Berkeley County has monitored 16.3 μg/m3

### for the time period 2001-2003. This monitor is intended to be used as the Design Value monitor for the Hagerstown nonattainment area.

### 6-133 Berkeley County is actually part of the large Washington-Baltimore CMSA. For planning purposes and consistency with existing ozone boundaries, EPA intends to separate Berkeley from the CMSA. The existing ozone nonattainment boundary includes Berkeley and Jefferson counties as an independent area, referred to as the Eastern WV panhandle. Berkeley County was defined by OMB in 2003 as part of the Hagerstown-Martinsville CBSA with Washington County, MD. West Virginia recommended both Jefferson and Berkeley counties as nonattainment in the February 13, 2004 recommendation letter. On June 1, 2004, the state revised its recommendation to exclude Jefferson County. Washington County, MD has also been recommended attainment by the state of Maryland. Berkeley County has monitored violations, EPA agrees with the West Virginia recommendation of nonattainment for Berkeley County; however, EPA intends to designate Berkeley County with the Hagerstown-Martinsville CBSA following EPA April 1, 2003 guidance suggesting that single counties be included with the nearest metropolitan area.

Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Please see tables in Section 6.3.5.1 (Washington, DC area) for specific data on Berkeley and Washington County. After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. EPA is designating Washington County, MD and Berkeley County, WV as the Hagerstown- Martinsville nonattainment area. 6.3.6.7 Wheeling, WV-OH Area

Discussion The Wheeling Metropolitan Statistical Area (MSA) is comprised of three counties including two counties in West Virginia. The table below lists the counties in the MSA. Two counties in this MSA, Marshall and Ohio counties in West Virginia have monitored violations of the fine particulate (PM2.5

### ) National Ambient Air Quality Standard (NAAQS) of 15.0 μg/m_. Based on the monitored violations, the Wheeling MSA is considered a presumptive nonattainment area. Marshall County, WV is part of the MSA and monitored 15.7 μg/m3

### for the time period 2001- 2003. This value is being considered the Design Value for the nonattainment area. The State of West Virginia, in the Secretary Timmermeyer correspondence of February 13, 2004, recommended the two MSA counties to be included in the Wheeling nonattainment area. EPA has reviewed the State’s recommendations as well as additional data provided by West Virginia on June 3, EPA agrees with the State recommendation to include Marshall and Ohio Counties in the Wheeling nonattainment area. Belmont, Ohio has been reviewed and designated nonattainment by EPA Region 5.

### 6-134 SUMMARY OF FACTOR 1: EMISSIONS WHEELING, WV AREA ** Counties Listed by Percent Contribution to area** Total Emissions, 2001 (tons) EPA Reg ST COUNTY PM SO2 NOX VOC AmmCarbonCrustalWeighted Emissions Factor 5 OH Jefferson 12,247217,79461,402 4,082 287 2,723 7,529 119.6 3 PA Greene 11,626186,48131,832 2,756 256 2,548 7,223 99.2 3 WV Marshall 5,596 113,92144,521 4,125 122 1,319 3,417 65.0 3 PA Washington 3,011 8,221 22,097 9,392 813 1,190 1,505 35.4 5 OH Belmont 2,797 51,374 13,036 4,211 464 734 1,667 29.5 5 OH Guernsey 503 1,164 5,643 3,602 367 229 261 7.3 5 OH Monroe 715 4,532 2,809 1,166 230 162 504 5.5 3 WV Ohio 351 514 3,609 2,779 123 192 135 5.5 3 WV Brooke 527 1,663 2,500 4,358 439 191 277 5.3 3 WV Wetzel 260 698 4,323 1,720 45 160 79 5.2 5 OH Noble 219 144 1,622 1,377 197 87 127 2.5 5 OH Harrison 191 258 712 786 254 70 116 1.8

SUMMARY OF FACTOR 2: AIR QUALITY WHEELING, WV AREA Design Values EPA RegST COUNTY '01-'03 '00-'02 '99-'01

5 OH Jefferson 17.8 NA18.2 NA18.9 NA 3 WV Brooke 16.8 NA16.8 NA17.4 NA 3 WV Marshall 15.7 NA16.0 NA16.5 NA 3 PA Washington 15.5 NA15.7 NA15.5 NA 5 WV Ohio 15.2 NA15.3 NA15.7 NA 5 OH Harrison No Monitor 5 OH Belmont No Monitor 3 PA Greene No Monitor 3 OH Monroe No Monitor 3 WV Wetzel No Monitor 5 OH Guernsey No Monitor 5 OH Noble No Monitor

### 6-135 SUMMARY OF FACTOR 3: POPULATION DENSITY AND DEGREE OF UBANIZATION WHEELING, WV AREA Population & Area EPA Reg ST COUNTY 2002 Area (sq miles) Density '02
3 PA Washington 204,110 857 238 5 OH Jefferson 72,402 410 177 5 OH Belmont 69,448 537 129 3 WV Ohio 46,126 106 435 5 OH Guernsey 40,987 522 79 3 PA Greene 40,520 576 70 3 WV Marshall 34,898 307 114 3 WV Brooke 25,179 89 283 3 WV Wetzel 17,363 359 48 5 OH Harrison 15,890 404 39 5 OH Monroe 14,973 456 33 5 OH Noble 14,088 399 35

SUMMARY FACTOR 4: COMMUTING PATTERNS WHEELING, WV AREA
VMT Commuting to Other Metro Counties EPA Reg ST COUNTY 2002 Percent Number 3 PA Washington 2,057 0 386 5 OH Belmont 1,066 20 5,667 5 OH Guernsey 1,026 2 365 5 OH Jefferson 741 7 2,045 3 PA Greene 560 1 101 3 WV Ohio 437 15 2,964 5 OH Noble 362 2 103 3 WV Brooke 313 9 962 3 WV Marshall 233 37 5,233 5 OH Harrison 143 7 473 5 OH Monroe 142 15 852 3 WV Wetzel 111 8 519

### 6-136 SUMMARY FACTOR 5: EXPECTED GROWTH WHEELING, WV AREA Population VMT EPA Reg ST COUNTY 2002 Growth '90-'00 Pct chng '90-'00 Growth '02-'10 Pct chng '02-'10 5 OH Noble 14,088 2,722 24 229 172 5 OH Guernsey 40,987 1,768 5 636 163 3 PA Greene 40,520 1,122 3 161 40 5 OH Harrison 15,890 -229 -1 3 2 5 OH Monroe 14,973 -317 -2 2 1 5 OH Belmont 69,448 -848 -1 290 37 3 WV Brooke 25,179 -1,545 -6 94 43 3 WV Wetzel 17,363 -1,565 -8 4 4 3 PA Washington 204,110 -1,687 -1 168 9 3 WV Marshall 34,898 -1,837 -5 -57 -20 3 WV Ohio 46,126 -3,444 -7 -83 -16 5 OH Jefferson 72,402 -6,404 -8 -48 -6



### Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States After consideration of all information provided, EPA has determined that the recommendation of June 29, 2004 as described above is still valid. Therefore, EPA is designating Marshall and Ohio counties as the West Virginia portion of the Wheeling nonattainment area.

### 6-137 

## 6.4 Region 4 Nonattainment Areas

6.4.1 EPA 9-Factor Analyses for Alabama for the Designation of PM2.5 Nonattainment Areas 6.4.1.1 Birmingham Area MSA The following is the 9 factor analysis for Birmingham MSA and surrounding Counties. Alabama’s submittal in February 2004, recommended Jefferson County be designated nonattainment for the fine particulate matter (PM2.5), based on 2001 - 2003 monitoring data. Based on the following analysis EPA believes that Jefferson, Shelby and Walker Counties should be included in the PM2.5 nonattainment area. Jefferson County has a violating monitor and the State recommended it as nonattainment. Shelby County is within the MSA, has high PM, SOx, NOx, and VOC emissions, approximately 52 percent of its commuters commute to Jefferson County, has relatively high population and VMT, and has a power plant within the County. Walker County has high SOx and NOx emissions from a power plant. We have included in our recommended nonattainment area Walker County that is contiguous to the MSA with a violating monitor, that is generally rural in character, and that contains an identifiable large emitting facility or facilities (e.g., power plants) which we believe contributes to the nearby nonattainment problem. We have included this County in our initial recommendations in order to ensure that a sufficient portion of this County, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of Walker County, encompassing the large facility or facilities, should be designated nonattainment. Based on the following analysis, EPA agrees that Blount, St. Clair, Calhoun, Talladega, Tuscaloosa and Morgan Counties should be recommended attainment/unclassifiable for PM2.5. Blount County has no major sources, has relative low emissions and has the lowest population and VMT in the Birmingham area. St. Clair County has relatively low SOx and PM emissions and has a small population. Calhoun County has no major sources, 84 percent of its commuters commute within its County and it is adjacent to the MSA. Talladega County has a small population, an attaining monitor (14.7 DV), low VMT and it is adjacent to the MSA. Tuscaloosa County has no major sources, 89 percent of its commuters commute within its County, has an attaining monitor (11.6 DV) and it is adjacent to the MSA. Morgan County has an attaining monitor, is part of another MSA, 72 percent of its commuters commute within its County and is several Counties away from Jefferson County

.

Area EPA Recommendation State Recommendation Birmingham, AL Full Counties:Jefferson, Shelby and Walker Full Counties:Jefferson



### The following is a brief summary of the 9 criteria for the Birmingham MSA and surrounding Counties. These analyses were based on existing available data.

### 6-138 Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5

### , SO2

### , NOx, VOC, and NH3 emissions in tons, and weighted emissions scores for the Birmingham Area and surrounding counties. The MSA counties are in bold

. Birmingham MSA and Surrounding Counties Emissions
County PM SO2 NOX VOC NH3 Weighted Emissions

Score Cumulative Weighted Emissions

Score Jefferson 12,772 56,703 69,364 44,782 1,198 50.3 27.5 Shelby 8,780 126,125 42,095 9,650 386 40.9 91.2 St Clair 976 1,087 7,159 4,673 1,395 4.8 96.0 Blount 937 454 3,054 2,781 4,049 3.9 99.9 Walker 3,916 59,256 23,982 4,750 1,491 19.2 Tuscaloosa 2,065 5,183 11,252 14,752 915 12.8 Morgan 2,386 10,949 12,012 17,639 2,183 11.0 Etowah 2,193 11,850 8,487 7,089 1,842 9.9 Calhoun 2,000 2,271 7,115 9,452 1,098 9.5 Talladega 1,968 12,270 8,593 6,065 769 9.1 Dallas 1,505 3,296 4,124 3,670 411 6.2 Cullman 1,459 1,004 5,433 6,612 8,408 6.0 Marshall 1,294 1,525 4,749 7,283 4,275 5.5 Autauga 1,069 2,569 4,897 3,099 249 5.3 Lawrence 1,429 2,422 5,981 2,946 1,649 5.3 Elmore 1,014 517 4,443 4,368 326 4.8 Chilton 777 486 3,621 3,260 300 4.3 Bibb 613 189 1,260 1,433 169 3.8 Winston 574 320 1,547 3,311 1,336 3.4 Marion 567 450 2,835 3,151 742 3.1 Fayette 456 306 1,246 1,509 346 2.8 Coosa 408 152 791 1,410 102 2.4 Hale 430 156 2,373 1,462 215 2.3 Perry 415 218 589 799 166 2.3 

### Based on the analysis for this factor, there appears to be emissions in Shelby and Walker, Counties that contribute to the air quality in Jefferson County, resulting in a violating monitor there.

### 6-139 Factor 2: Air quality in potentially included versus excluded areas Birmingham MSA and Surrounding Counties Design Value (DV)

County 2001-2003 DV Jefferson 18.0 Shelby 14.4 Walker 12.8 Tuscaloosa 11.6 **Morgan 17.6 Etowah 14.8 Talladega 14.7 

### Jefferson County has 6 monitors, only one monitor exceeded the PM2.5 standard (North Birmingham/Wylam). Shelby, Walker, Tuscaloosa, Etowah, and Talladega counties all have monitors that show attainment of the PM2.5 standard. ** Morgan County has a violating monitor, however, the Decatur, Alabama, fine particulate matter (PM2.5) monitoring site (AQS #01-103-0010) began operating in January 1999, and was terminated in August 2001. A new site (AQS # 01-103-0011) was selected in the Decatur area and monitoring begain in August 2001. The State of Alabama requested and received Region 4 concurrence for these network design changes. The changes were approved due to a local diesel source impacting the initial monitoring site. The data from the initial monitoring site was left in the Air Quality System (AQS) database and is in the current calculations for the Decatur area. Data sets from each of the sites are incomplete when considered individually. When the data sets are combined the calculations demonstrate the Decatur area to be below the level of the PM2.5 NAAQS. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the counties in the Birmingham MSA and adjacent Counties

. 

### Birmingham MSA and Surrounding Counties Population & Area

County Population 2002 Percent in MSA Population Density 2002 Jefferson 661,153 71 594 Shelby 153,832 16 193 St Clair 67,215 7 106 Blount 59,968 6 82 Walker 70,655 89 Tuscaloosa 166,512 126 Morgan 111,725 192 Etowah 103,105 193 Calhoun 111,616 183 Talladega 80,638 109

### 6-140 Of the MSA population, 87 percent resides in Jefferson County (661,153) and Shelby County (153,832). Blount and St. Clair Counties have a much lower population and population density than Jefferson and Shelby Counties. Factor 4: Traffic and commuting patterns Commuting Information - Following is an analysis of the commuting in the Birmingham MSA and adjacent Counties. Jefferson County, an MSA county, has a total of 288,136 commuters. - Commuters who remain in Jefferson County 265,661 (92%) Shelby County, an MSA county, has a total of 70,873 commuters. - Commuters from Shelby County to Jefferson County 37,119 (52%) - Commuters who remain in Shelby County: 32,573(46%) St. Clair County has a total of 27,773 commuters. - Commuters from St. Clair County to Jefferson County 12,870 (46%) - Commuters who remain in St. Clair County: 10,648 (38%) Blount County has a total of 22,255 commuters. - Commuters from Blount County to Jefferson County 9,669 (43%) - Commuters who remain in Blount County: 8,966 (40%) Walker County has a total of 27,448 commuters. - Commuters from Walker County to Jefferson County 6,746 (25%) - Commuters who remain in Walker County: 17,293(63%) Tuscaloosa County has a total of 73,292 commuters. - Commuters from Tuscaloosa County to Jefferson County 4,385 (6%) - Commuters who remain in Tuscaloosa County: 65,331 (89%) Morgan County has a total of 49,769 commuters. - Commuters who remain in Morgan County: 36,005 (72%) Etowah County has a total of 42,636 commuters. - Commuters from Etowah County to Jefferson County 1,658 (4%) - Commuters who remain in Etowah County: 32,181 (75%) Calhoun County has a total of 47,181 commuters. - Commuters from Calhoun County to Jefferson County 842 (2%) - Commuters who remain in Calhoun County: 39,856 (84%) Talladega County has a total of 31,443 commuters. - Commuters from Talladega County to Jefferson County 2,292 (7%) - Commuters who remain in Talladega County: 20,563 (65%)

### 6-141 The following Counties have significant commuters commuting to Jefferson County on a percentage basis: Shelby (52%), Walker (25%), St. Clair (46%) and Blount County (43%). Although a relatively high percentage of commuters in Blount and St. Clair Counties go to Jefferson County, they only contribute 3% and 4% respectively. Birmingham MSA and Surrounding Counties VMT

County VMT 2002 VMT Growth 02-10 Jefferson 8,242 3,485 Shelby 1,449 345 St. Clair 1,111 -331 Blount 594 134 Walker 851 212 Tuscaloosa 2,430 176 Morgan 1,296 816 Etowah 1,235 500 Calhoun 1,525 431 Talladega 801 39 

### Jefferson County has over 70% of the VMT in the MSA

### 6-142 Factor 5: Expected growth. The following table has the population and population growth figures for the Birmingham MSA and Surrounding Counties

. Birmingham MSA and Surrounding Counties Population/Growth

County Population Growth 90-00 Percent Growth Jefferson 661,153 10,522 2 Shelby 153,832 43,935 44 St. Clair 67,215 14,733 29 Blount 59,968 11,776 30 Walker 70,655 3,043 4 Tuscaloosa 166,512 14,353 10 Morgan 111,725 11,021 11 Etowah 103,105 3,619 4 Calhoun 111,616 -3,785 -3 Talladega 80,638 6,214 8 

### Blount County had one of the higher population growth (30 percent) in the MSA, however, its population (59,968) is small compared to that of the entire CMSA (942,168) or to either Jefferson County (661,153) and Shelby County (153,832).St. Clair County had a fairly high population growth (29 percent), its population (67,215) is small compared to that of the entire CMSA (942,168) and is only one-tenth the population of Jefferson County (661,153) and less than half the population of Shelby County (153,832).Shelby County had a high population growth (44 percent). Factor 6: Meteorology Not a significant factor in the analyses. Factor 7: Geography/topography Not a significant factor in the analyses.

Factor 8: Jurisdictional boundaries The Birmingham 8-hour ozone nonattainment area consist of Jefferson and Shelby Counties.

Factor 9: Level of control of emission sources Reasonable Available Control Technology for VOC has been in place since 1979 Stage 1 Vapor Recovery has been in place since 1990 1-Hour Attainment Demonstration required further NOx reductions from electric generating plants Gorgas and Miller, totaling 68.2 tons per day of NOx reductions (seasonal). Tier II National Fuel Standard (starting 2004)

### 6-143 NOx SIP Call requires large reductions in NOx emissions from major utilities, large industrial boilers, gas turbines and cement kilns (seasonal). As a result Gaston, Gorgas and Miller power plants have/will install the following controls: Miller Units 1 & 2 Selective Catalytic Reduction (SCR) Gaston Units 1 - 4 overfire air Gaston Unit 5 advanced low NOx burners The following controls are being or have been placed on Gorgas and Miller power plants to meet the requirements of the Birmingham attainment SIP: Gorgas Unit 10 SCR Gorgas Units 6, 7, and 8 low NOx burners Miller Units 3&4 SCR There is only one significant NOX source in St. Clair County, a cement kiln (National Cement Co. 1,851 tpy), which is implementing significant controls which have been determined to be reasonable and highly cost effective to meet the Alabama’s NOX SIP requirements. Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States Walker County, AL: In the June 29, 2004, letters from EPA to the States responding to their designation recommendations, EPA recommended the designation of a number of counties primarily because of high pollutant emissions from power plants. Most of these plants were located in nearby counties adjacent to the metropolitan area (as defined either by the 1999 or 2003 OMB metropolitan area definitions). EPA suggested that a State could provide a partial county boundary that would encompass the relevant power plant in the nonattainment area. Walker County, AL is one of those counties. Walker County has low population (70,655 compared to 661,153 in Jefferson County where the city of Birmingham is located), low population density (89 people per square mile compared to 594 in Jefferson County), low VMT (851,000 compared to 8,242,000 in Jefferson County ), and the only large point source is the Gorgas Steam Plant. A number of states responded to this suggestion with a series of connected townships or other unique boundaries. Some states also suggested an alternative approach in which partial county areas for power plants in some cases could be small “free-standing” boundaries that are considered part of the nearby nonattainment area. In this way, it would not be necessary to include additional townships or other minor civil divisions comprising an odd-shaped “land connector” extending from the main part of the nonattainment area to the power plant. The State of Alabama subsequently submitted two partial county recommendations, one included the Gorgas Steam Plant boundary as a noncontiguous area and the other was contiguous to the Birmingham area.

### 6-144 After considering these comments from the States, EPA agrees that such an approach is preferable in cases where a partial county nonattainment boundary has not already been established for that source (e.g. partial county boundaries recently established for 8-hour ozone nonattainment areas). For purposes of consistency, EPA has decided that free-standing portions of nonattainment areas should be based on a pre-existing boundary for a minor civil division (such as a township or tax district) or other boundary defined for governmental use (such as a census block group or census tract). Accordingly, this kind of partial county boundary should not be defined simply as the boundary of the facility. Therefore, EPA is designating the census block group identifiers (StateFIPs-CoFIPs-Tract#-Block Group#) 01-127-214-5, 01-127-0215-4, and 01-127-0216-2 portion of Walker County as part of the Birmingham nonattainment area. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following counties as nonattainment for the Birmingham, AL area: Jefferson, Shelby, and Walker (Partial).

6.4.1.2 Columbus Area MSA The following is the 9 factor analysis for Columbus MSA and surrounding Counties. Alabama’s submittal in February 2004, recommended that Russell County be designated nonattainment for the fine particulate matter (PM2.5), based on 2001 - 2003 monitoring data. Georgia’s submittal in June 2004, recommended that Harris, Muscogee and Chattahoochee Counties be designated attainment for PM2.5. Based on the following analysis EPA recommends that Lee and Russell counties in Alabama, and Harris, and Muscogee Counties in Georgia, should be included in the PM2.5 nonattainment area. Lee County is adjacent to the MSA, has high VMT and a large population. Russell County has a violating monitor and the State recommended it as nonattainment. Harris County has relatively high NOx and VOC emissions and relatively high VMT. Muscogee County has high NOx and VOC emissions, high VMT and a large population. Based on the following analysis, EPA agrees with the recommendation that Barbour, Chambers, Montgomery, Elmore and Tallapoosa Counties in Alabama, and Chattahoochee, Troup, Stewart, Meriwether, Sumter Counties in Georgia, should be attainment/unclassifiable for PM2.5 based on low emissions, low VMT and low population.

Area EPA Recommendation State Recommendation Columbus, GA Lee and Russell Counties in Alabama and Harris and Muscogee Counties in Georgia Russell County, Alabama

### 6-145 The following is a brief summary of the 9 criteria for the Columbus MSA and surrounding Counties . These analyses were based on existing available data. Factor 1: Emissions in areas potentially included versus excluded from the nonattainment area The following table has 2001 PM2.5

### , SO2

### , NOx, VOC, and NH3 emissions in tons, and weighted emissions scores for the Columbus Area and surrounding counties. The MSA counties are in bold

. Columbus MSA and Surrounding Counties Emissions County PM SO2 NOX VOC NH3 Weighted Emissions

Score Cumulative Weighted Emissions

Score Russell, AL 1,344 2,550 5,718 4,434 179 35.1 35.1 Harris, GA 590 104 2,856 1,748 128 26.8 61.9 Muscogee, GA 513 803 5,965 9,476 323 25.4 87.3 Chattahoochee, GA 208 43 387 482 15 12.7 100 Troup, GA 1,194 422 12,277 8,223 382 48.7 Montgomery, AL 1,421 6,292 10,454 14,966 973 43.3 Lee, AL 1,043 1,425 5,125 7,474 333 42.8 Barbour, AL 874 419 2,208 2,529 497 41.6 Sumter, GA 2,578 1,725 1,726 2,262 847 40.5 Meriwether, GA 844 190 1,866 3,006 167 33.7 Elmore, AL 1,014 517 4,443 4,368 326 30.8 Tallapoosa, AL 679 655 1,993 3,230 263 26.5 Chambers, AL 579 527 2,350 2,882 124 23.9 Stewart, GA 429 32 360 464 189 23.3 Taylor, GA 398 76 966 622 833 18.3 Macon, AL 412 223 2,242 1,871 133 17.1 Talbot, GA 288 70 903 520 74 15.9 Marion, GA 314 32 328 517 470 15.4 Bullock, AL 273 93 407 570 214 12.7 Webster, GA 303 128 358 201 114 12.6 Schley, GA 192 14 195 290 163 8.4 

### Based on the analysis for this factor, there appear to be emissions in Lee County, Alabama, that contribute to the violation in Russell County. Factor 2: Air quality in potentially included versus excluded areas. Columbus MSA and Surrounding Counties Design Value (DV)

County 2001-2003 DV Russell, AL 15.3 Muscogee, GA 14.7 Montgomery, AL 14.2

### 6-146 Muscogee and Montgomery Counties have monitors that show attainment of the PM2.5 standard while Russell County is violating the standard. Factor 3: Population density and degree of urbanization including commercial development in included versus excluded areas The following table has the populations for the Counties in the Columbus MSA and adjacent Counties. Columbus MSA and Surrounding Counties Population & Area County Population20 02 Percent in MSA Population Density 2002 Russell, AL 49,415 18 77 Harris, GA 25,092 9 54 Muscogee, GA 185,948 67 861 Chattahoochee, GA 15,440 6 62 Troup, GA 59,767 144 Montgomery, AL 223,346 283 Lee, AL 118,123 194 Barbour, AL 28,826 33 Sumter, GA 33,247 69 Meriwether, GA 22,623 45 Elmore, AL 68,771 111 Tallapoosa, AL 40,946 57 Chambers, AL 36,251 61 Stewart, GA 5,040 11 

### Lee County is adjacent to Russell County and its population (118,123) is about two and half times that of Russell County(49,415). Factor 4: Traffic and commuting patterns Commuting Information - Following is an analysis of the commuting in the Columbus MSA and adjacent Counties. Russell County, AL has a total of 19,859 commuters. - Commuters who remain in Russell County 7,051(36%) Harris County, GA has a total of 11,811 commuters. - Commuters from Lee County to Russell County 214 (2%) - Commuters who remain in Harris County 2,867 (24%) Muscogee County, GA has a total of 82,977 commuters. - Commuters from Muscogee County to Russell County 2,479 (3%) - Commuters who remain in Muscogee County 71,862 (87%) Chattahoochee County, GA has a total of 8,538 commuters. - Commuters who remain in Chattahoochee County 5,482 (64%)

### 6-147 Troup County, GA has a total of 26,339 commuters. - Commuters who remain in Troup County 22,074 (84%) Montgomery County, AL has a total of 96,943 commuters. - Commuters who remain in Montgomery County 90,943 (94%) Lee County, AL has a total of 52,119 commuters. - Commuters who remain in Lee County 35,549 (68%) - Commuters from Lee County to Russell County 2,682 (5%) Barbour County, AL has a total of 10,023 commuters. - Commuters who remain in Barbour County: 8,370(84%) - Commuters from Lee County to Russell County 335 (3%) Sumter County, GA has a total of 13,963 commuters. - Commuters who remain in Sumter County 11,652(83%) Meriwether County, GA has a total of 8,893 commuters. - Commuters who remain in Meriwether County 4,114 (46%) Elmore County, AL has a total of 28,143 commuters. - Commuters who remain in Elmore County 9,415 (33%) Tallapoosa County, AL has a total of 17,009 commuters. - Commuters who remain in Tallapoosa County 12,125 (71%) Chambers County, AL has a total of 15,480 commuters. - Commuters who remain in Chambers County 9,281 (60%) Stewart County, GA has a total of 1, 892 commuters. - Commuters who remain in Stewart County 965 (51%) There are no Counties that have significant commuters commuting toRussell County. Columbus MSA and Surrounding Counties VMT

County VMT 2002 VMT Growth 02-10 Russell, AL 671 276 Harris, GA 547 -207 Muscogee, GA 1,594 534 Chattahoochee, GA 56 160 Troup, GA 1,454 -839 Montgomery, AL 2,565 642 Lee, AL 1,119 457 Barbour, AL 431 -129 Sumter, GA 405 -62 Meriwether, GA 271 138

### 6-148 Elmore, AL 615 168 Tallapoosa, AL 502 -56 Chambers, AL 378 -44 Stewart, GA 75 47 

### Over 50% of the VMT in the MSA is in Muscogee County, Georgia. As noted above, none of the adjacent Counties have appreciable commuting into the MSA. Factor 5: Expected growth The following table has the population and population growth figures for the Columbus MSA and surrounding Counties

. Columbus MSA and Surrounding Counties Population/Growth

County Population 2002 Growth 90-00 Percent Growth Russell, AL 49,415 2,896 6 Harris, GA 25,092 5,907 33 Muscogee, GA 185,948 7,013 4 Chattahoochee, GA 15,440 -2,052 -12 Troup, GA 59,767 3,243 6 Montgomery, AL 223,346 14,425 7 Lee, AL 118,123 27,946 32 Barbour, AL 28,826 3,621 14 Sumter, GA 33,247 2,972 10 Meriwether, GA 22,623 123 1 Elmore, AL 68,771 16,664 34 Tallapoosa, AL 40,946 2,649 7 Chambers, AL 36,251 -293 -1 Stewart, GA 5,040 -402 -7 

### Harris County, Georgia has large growth on a percentage basis. Factor 6: Meteorology A wind analysis using wind data from the Columbus, Georgia Airport was completed to evaluate the predominant wind direction(s) in Phenix City over the 3-year period on all days. There is a large easterly component to the winds during the 3-year time period., but there is not sufficient information to use meteorology as a deciding factor for an annual average.. Factor 7: Geography/topography Not a significant factor in the analyses.

Factor 8: Jurisdictional boundaries Not a significant factor in the analyses.

### 6-149 Factor 9: Level of control of emission sources Reasonable Available Control Technology for VOC has been in place since 1979 Stage 1 Vapor Recovery has been in place since 1990 NOx SIP Call requires large reductions in NOx emissions from major utilities, large industrial boilers, gas turbines and cement kilns (seasonal for Macon, Tallapoosa, Chambers, Elmore and Lee Counties). Tier II National Fuel Standard (starting 2004) Justifications for Changes to EPA Recommendations Contained in the June 29, 2004 Letters to States EPA’s initial nonattainment recommendations on June 29, 2004, included the Lee County, Alabama, and Harris County, Georgia, as part of the Columbus, GA nonattainment area. Upon further review of additional information provided by the states, EPA is revising its recommendation and is designating Lee County, AL and Harris County, GA as attainment/unclassifiable. Lee County, AL: Lee County, Alabama, is being designated attainment/unclassifiable because it has no major point sources of precursor emissions with 40% (7,474 tons) of its total VOC and 87% (5,125 tons) of its total NOx emissions coming from mobile sources. Lee County is adjacent to the MSA. The majority of the commuting population remains inside Lee County, with only 5 percent commuting to Russell County where the violating monitor is located. We considered the data in the request for spatial averaging for the Columbus area, which was denied, while evaluating the other factors and determined that Lee County is not contributing to the violations. Based on the analysis EPA conducted as described in the June 29, 2004 letter, and review of additional information received after our initial analysis, EPA is designating the following county as nonattainment for the Columbus, GA-AL area:Russell. 

## 6.4.1.3 Chattanooga Area The Chattanooga MSA contains the following Tennessee counties: Marion and Hamilton; and the following Georgia Counties: Dade, Walker, and Catoosa. Based on air quality data for 2001- 2003, the monitor with the highest design value in Hamilton County has a design value of 16.1 and the monitor in Walker County has a design value of 15.6. No other counties in the MSA contain ambient air monitors. The State of Tennessee recommended as nonattainment the county of Hamilton and the State of Georgia recommended as nonattainment the county of Walker. The States have recommended that all other counties be designated attainment. The State of Tennessee submitted some justification for this recommendation, however, they indicated that the detailed emission information would be provided at a later date. EPA is modifying the State

### 6-150 of Tennessee’s recommendation and will review the additional information during the 120 day period following the notification letter. EPA has received some information from the State of Tennessee that Marion (MSA) County should be designated attainment for the PM2.5 standard and no justification from the State of Georgia indicating that any other counties should be included or excluded from the Chattanooga PM2.5 nonattainment area. Adjacent counties with significant emissions include McMinn and Roane Counties which are attached to the Knoxville nonattainment area and Floyd County which is a separate nonattainment area. Additionally we have included in our recommended nonattainment area Jackson County, AL, that is adjacent to the Chattanooga MSA, that is generally rural in character, and that contains an identifiable large emitting facility or facilities (e.g., power plants) which we believe contribute to the nearby nonattainment problem. We have included this county in our initial recommendations in order to ensure that a sufficient portion of this county, including such large facilities, is included within the boundaries of the nonattainment area as part of the final designations. We invite you to submit to us a recommendation as to what portion of this adjacent county, encompassing the large facility or facilities, should be designated nonattainment. Therefore EPA is modifying the States’ recommendations to include all of the counties in the MSA and the adjacent county of Jackson, Alabama.

Area EPA Recommendation State Recommendation Chattanooga TN-GA Full counties: Marion, Hamilton,TN;Dade,Walker, Catoosa, GA; Jackson, AL Fullcounties:Hamiltonand Walker Drop: Marion