1 

### Pennsylvania Area Designations for the

20 08 Ozone National Ambient Air Q uality Standard s

The t able below identifies the areas and associated counties or parts of counties in Pennsylvania

that EPA intends to designate as no n attain ment for the 2008 o zone n ational ambient air quality

standard s (20 08 NAAQS) . In accordance with section 107(d) of the Clean Air A ct, EPA must designate an area “nonattainment” if it is violating the 2008 ozone NAAQS or if it is contributing

to a violation of the 2008 ozone NAAQS in a nearby area. The technical analyses supporting the boundaries for the individual nonattainment areas are provided below.

Intended Nonattainment Areas in Pennsylvania

Area Pennsylv a nia Recommended

Nonattainment Counties EPA’s Intended

Nonattainment Counties

Allentown

- Bethlehem

Easton Lehigh Carbon, Lehigh, Northampton

Lancaster Lancaster Lancaster Philadelphia

- Wilmington

Atlantic City Bucks, Montgomery, Philadelphia Bucks, Chester, Delaware, Montgomery, Philadelphia

Pittsburgh

- Beaver Valley Alleg heny Allegheny, Armstrong, Beaver, Butler, Fayette, Washington, Westmoreland Reading Berks Berks

The Philadelphia

- Wilmington

- Atlantic City Area is a multi

- state nonattainment area. Table 1 in

the Technical Analysis for the Philadelphia

- Wilmington

- Atlant ic City Area, below, identifies the counties in the other states that EPA intends to designate as part of the nonattainment area.

EPA intends to designate the remaining counties in Pennsylvania that are not listed in the table

above as “ unclassifiable/ att ainment ” for the 2008 ozone NAAQS.

The analysis below provides the basis for intended nonattainment area boundar ies. It relies on our analysis of whether and which monitors are violating the 20 08 o zone NAAQS

, based on

certified air quality monitoring d ata from 2008

- 2010 and an evaluation of whether nearby areas are contributing to such violations. EPA has evaluated contribution s from nearby areas based on a weight of evidence analysis considering the factors identified below. EPA issued guidance on

De cember 4, 2008 that identified these factors as ones EPA would consider in determining

nonattainment area boundaries and recommend ed that s tates consider these factors in making

their designations recommendations to EPA. 1

1. Air quality data ( including the design value calculated for each FRM or FEM monitor in

the area );

1 The December 4, 2008 guidance memorandum “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards” refers to 9 factors. In this technical support d ocument we have grouped the emissions

related factors together under the heading of “Emissions and Emissions

- Related Data

, ” which results in 5 categories

of factors.2

2. Emissions and emissions

- related data (including location of sources and population

, amount of emissions and emissions controls , and urban growth patterns);

3. Meteorology (weather/transport pa tterns) ; 4. Geography and topography (mountain ranges or other basin boundaries) ; 5. Jurisdictional boundaries (e.g., counties, air districts, existing nonattainment areas, Indian

country , metropolitan planning organizations (MPOs))

Ground

- level ozone is not em itted directly into the air, but is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compounds (VOC) in the presence of sunlight. Because NOx and VOC emissions from a broad range of sources over a wide area typically con tribute to violations of the ozone standard s , EPA believes it is important to consider whether there are contributing emissions from a broad geographic area. Accordingly, EPA chose to examine the 5 factors with respect to the larger of the Combined Statis tical Area (CSA) or Core Based Statistical Area (CBSA) within which is located the violating monitor(s)

. 2 All data and information used by EPA in this evaluation are the latest available to EPA and/or provided to EPA by states or tribes.

In EPA’s designa tions guidance for the 2008 ozone NAAQS 3 EPA recommended examining

CSA/CBSA s because certain factors (such as population) used to establish CSAs and CBSAs are similar to the factors EPA is using in this technical analysis to determine if a nearby area is

c ontributing to a violation of the 20 08 ozone NAAQS. EPA used the same basic approach in the designation process for the 1997 o zone NAAQS. Where a violating monitor is not located in a

CSA or C BS A, EPA ’s guidance recommended using the boundary of the coun ty containing the violating monitor as the starting point for considering th e nonattainment area’s boundary.

2 Lists of CBSAs and CSAs and their geographic components are provided at www.census.gov/population/www/metroareas/metrodef.html . The lists are periodically updated by the Office of Management and Budget. EPA used the most recent update, based on 2008 population es timates, issued on December 1, 2009 (OMB Bulletin No. 10

- 02).3

Technical A nalysis for the Allentown

- Bethlehem

- Easton Area

Figure 1 is a map of the Allentown

- Bethlehem

- Easton intended nonattainment area . The m ap provides other relevant information including the locations and design values of air quality

monitors , county and other jurisdictional boundaries, census

- defined metropolitan statistical area boundary, existing maintenance area boundary for the 1997 ozo ne NAAQS, and EPA’s intended nonattainment boundary for the 2008 ozone NAAQS.

Figure 1

For purposes of the 1997 ozone NAAQS, portions of this area were designated nonattainment. The boundary for the nonattainment area for the 1997 o zone NAAQS includ ed the entire counties of Carbon, Lehigh, and Northampton Counties. Warren County, NJ, which is part of the census

defined metropolitan statistical area was designated nonattainment for the 1997 ozone NAAQS as part of the separate New York

- Northern New Je rsey

- Long Island

, NY

- NJ

- CT n onattainment a rea

.

In March 2009, the Commonwealth of Pennsylvania recommended that the same three counties in Pennsylvania be designated as nonattainment in the Allentown

- Bethlehem

- Easton Area for the 2008 ozone NAAQS based on air quality data from 2006

- 2008. Pennsylvania provided an update d4

recommendation o n November 22, 2011

, based on more recent air quality data from 2009

- 2011. That recommendation was to designate only Lehigh County as nonattainment (as it has a violating monitor) and to designate nearby Carbon and Northampton Counties as attainment. The same county, Lehigh County, is violating based on the 2008

- 2010 and 2009

- 2011 monitoring data. Th is

data comes from FRM monitors or FEM monitors sited and operated in acc ordance with 40 CFR

Part 58. (See the March 17, 2009 and November 22, 2011 letter s from the Pennsylvania Department of Environmental Pro tection to EPA.)

In April 2009, the State of New Jersey recommended the same nonattainment boundary for the

twelve N ew Jersey counties (including Warren County) for the 2008 ozone NAAQS as was the case for the 1997 ozone NAAQS (i.e., that Warren County be part of the New York

- Northern New Jersey

- Long Island, NY

- NJ

- CT nonattainment area). These data are from FRM monitor s or FEM monitors sited and operated in accordance with 40 CFR Part 58. (See the April 1, 2009 letter from the New Jersey D epartment o f Environmental Protection to EPA.)

After considering these recommendations and b ased on EPA's technical analysis descri bed below,

EPA intends to designate three counties in Pennsylvania as “ nonattainment ” for the 20 08 o zone NAAQS as part of the Allentown

- Bethlehem

- Easton nonattainment area

.

Table 1. States’ Recommended and EPA’s Intended Designated Nonattainment Count ies for

Allentown

- Bethlehem

- Easton.

Allentown

- Bethlehem

Easton State

- Recommended

Nonattainment Counties EPA Intended

Nonattainment Counties

Pennsylvania Lehigh Carbon, Lehigh, Northampton New Jersey None None

Factor Assessment

EPA has determined that it is appropriate to place the nearby counties of Berks, Montgomery, and Bucks in Pennsylvania and Hunterdon and Morris in New Jersey, in separate nonattainment areas for the 2008 ozone NAAQS from the Allentown

- Bethlehem

- Easton Metropolitan Statistical Are a. See EPA’s respective technical analyses for these adjacent nonattainment areas for EPA’s rationale for our intended nonattainment designation for these counties. To the extent that emissions from those counties may contribute to ozone concentrations i n the Allentown

- Bethlehem

- Easton nonattainment area, that contribution will be lessened by emission controls put in place in those separate nonattainment areas. Therefore, EPA is not including Berks, Montgomery, and Bucks,

Hunterdon and Morris in this anal ysis for the Allentown

- Bethlehem

- Easton nonattainment area.



### Factor 1: Air Quality Data

For this factor , we considered 8

- hour o zone design values (in parts per billion ( pp b) ) for air quality

monitors in counties in the Allentown

- Bethlehem

- Easton area b ased on data for the 2008

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with fully

- certified air quality data

. A monitor’s DV is the metric or statistic that indicates whether that monitor attains a specified air qualit y standard. The 2008 o zone NAAQS are met when the annual f ourth

- highest5

daily maximum 8

- hour average concentration, averaged over 3 years is 0.075 ppm or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where several monitors are located in a county (or a designated nonattainment area or maintenance area ),

the DV for the county or area is determined by the monitor with the highest level.

The 2010 DVs for the o zone NAAQS for counties in the Allentown

- Bethlehem

- Easton and nearby surrounding area are shown in Table 2

. We did not include neighboring counties to the south of the area, which have been recommended as intended nonattainment as part of separate areas from this

area.

Table 2. Air Quality Data

.

County State

Recommended

Nonattainment? EPA

Recommended

Nonattainment? 2010 8

- hour

Ozone DV (ppb) Preliminary 2011

8

- hour Ozone DV (ppb)
Carbon, PA No Yes

-- -- Lehigh, PA Yes Yes 76 76 Northampton, PA No Yes 75 75

Warren, NJ Yes, other area Yes, other area

-- -- Schuylkill, PA No No

-- -- Luzerne, PA No No 69 65
Lackawanna, PA No No 72 71
Monroe, PA No No 70 70

Note : Counties with no ozone monitor are identified with “

-- “ in the 2010 and 2011 8

- hour Ozone DV columns.

In accordance with section 107(d) of the Clean Air Act, EPA must designate an area “nonattainment” if it is violating the 2008 ozone NAAQS. Lehigh County shows a violation of the

2008 o zone NAAQS , t herefore this county must be included in a nonattainment area. A county (or partial county) must also be designated nonattainment if it contributes to a violation in a nearby

area. Each county without a violating monitor that is located near a county with a violating monitor

has been evaluated based on the wei ght of evidence of the five factors and other relevant

information to determine whether it contributes to the nearby violation

.



### Factor 2: Emissions and Emissions

- Related Data

EPA evaluated emissions of ozone precursors ( NO

x and VOC ) and other emissio ns

- related data that provide information on areas contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NO

x and VOC derived from the 200 8 National Emissions Inventory (NEI), version 1.5

. This is the most recentl y available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a nearby area indicate the potential for the area to contribute to monitored vio lations. We will also consider any additional information we receive on changes to emissions levels that are not reflected in recent inventories. These changes include emissions reductions due to permanent and enforceable

emissions controls that will be i n place before final designations are issued and emissions increases

due to new sources.6

Table 3 shows emissions of NO

x and VOC (given in tons per year) for violating and potentially contributing counties in the Allentown

- Bethlehem

- Easton area.

Table 3 . Total 2008 NO

x and VOC E missions

.

County State

Recommended

Nonattainment? EPA Recommended

Nonattainment? NO

x (tpy) VOC (tpy)

Carbon, PA No Yes 3,302 3,452
Lehigh, PA Yes Yes 11,160 12,147
Northampton, PA No Yes 17,082 8,499

Warren, NJ Yes, other area Yes, other area 4,483 3,925
Schuylkill, PA No No 6,554 5,922

Luzerne, PA No No 12,045 13,183

Lackawanna, PA No No 7,118 7,233

Monroe, PA No No 5,761 8,017

Of the counties in the Allentown

- Bethlehem

- Easton Metropolitan Statistical Area, N orthampton has the highest total NOx emissions, and Lehigh has the highest total VOC emissions. Lehigh also has high NOx emissions, and Northampton has relatively high VOC emissions. Carbon County and Warren County, by comparison, have much lower NOX and VOC emissions. Of the nearby counties outside this metropolitan statistical area, Luzerne has the highest NOx and VOC emissions. Monroe, Lackawanna, and Schuylkill have lower emissions by comparison, than Lehigh and Northampton, however, they are simil ar to Carbon County.

Population density and degree of urbanization

EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozo ne

- creating

emissions from on

- road and off

- road vehicles and engines, consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial development are an indicator of area source and mobile source NO

x and VOC emissions that may contribute to ozone formation. Rapid population or VMT growth (see below) in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the associated area

source and mobile source emis sions may be appropriate to include in the nonattainment area. Table

4 shows the population, population density, and population growth information for each county in

the area.

Of the counties that are part of the Allentown

- Bethlehem

- Easton Metropolitan St atistical Area, Lehigh and Northampton have the highest populations, with Carbon having the lowest population and population density (followed closely by Warren County). Lehigh is also the fastest growing county and has the largest population change. Car bon, Lehigh, and Northampton all experienced double digit population growth in the prior decade, but by comparison, are fairly sparsely populated. Of the counties nearby to, but outside of this, metropolitan statistical area, Luzerne has the highest popul ation, very nearly as large as Lehigh, distantly followed by Lackawanna County.7

Table 4. Population and G rowth

County State Recommended

Nonattainment? EPA

Recommended

Nonattainment? 2010

Population 2010

Population Density (1000 pop/sq mi) Absolu te

change in population (2000

- 2010) Population

% change (2000

- 2010)

Carbon, PA No Yes 65,249 0.17 6,417 +11%
Lehigh, PA Yes Yes 349,497 1.00 36,843 +12%
Northampton, PA No Yes 297,735 0.79 30,295 +11%

Warren, NJ Yes, other area No 108,692 0.30 5,7 45 +6%
Schuylkill, PA No No 148,289 0.19

- 1,798

- 1.2%

Luzerne, PA No No 320,918 0.35 2,363 +0.7%

Lackawanna, PA No No 214,437 0.46 1,524 +0.7%

Monroe, PA No No 169,842 0.28 30,077 +22%
Sources: U.S. Census Bureau population estimates for 2010 as of Au gust 4, 2011 ( http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTPL2.STO5&prod Type=table )

Figure 2 . Population Distribution of Allentown

- Bethlehem

- Easton.

Source: US Census ( http://2010.census.gov/2010census/popmap/ )

The counties neighboring the Allentown

- Bethlehem

- E aston Metropolitan Statistical Area, have comparatively low population growth, with the exception of Monroe County. Monroe County has a population that is more than four times larger than Carbon County, with a population growth rate8

twice that of Carbon C ounty. These adjacent counties are comparatively sparsely populated, with population densities ranging from a high of 460 to a low of 190 persons per square mile. Figure 2 illustrates how the population centers of this area are clustered primarily in the urban centers, with very sparse populations in the surrounding communities.

T raffic and VMT data

EPA evaluated the total Vehicle Miles Traveled (VMT) and the com muting patterns of residents for each county in the area of analysis. In combination with t he population/population density data and the location of main transportation arteries (see Figure 1 above), this information helps identify the probable location of non

- point source emissions. A county with high VMT and/or a high num b er of commuters is ge nerally an integral part of an urban area and indicates the presence of motor vehicle emissions that may contribute to ozone formation. Rapid population or VMT growth in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the

associated area source and mobile source emissions may be appropriate to include in the

nonattainment area. Table 5 shows traffic and commuting pattern data, including total 2008 VMT

and 10

- year VMT growth. Table 6 shows the number of com muters in each county who travel within that county or to another county in the area of analysis.

Table 5. Traffic and VMT Data.

C ounty State

Recommended

Nonattainment? EPA Recommended

Nonattainment? 2008 VMT

(million miles) Percent VMT

G rowth (2002

- 2008)

Carbon, PA No Yes 740 0.8%
Lehigh, PA Yes Yes 2,893 2.9%
Northampton, PA No Yes 1,997 0.7%

Warren, NJ No No 1,530 1.1%

Luzerne, PA No No 2,963 4.2%

Lackawanna, PA No No 1,994 5.9%

Monroe, PA No No 1,621 2.5%
Schuylkill, PA No No 1,394

- 3.4%
* MOBILE model VMTs are those inputs into the NEI version 1.5.

Table 6. County to County Worker Flow

Residence County Carbon,

PA Lehigh, PA Northampton,

PA Warren,

NJ Monroe,

PA Lackawanna,

PA Luzerne,

PA Schuylkill,

PA
Workplace County
Carbon, PA 12,341 550 390 8 614 38 634 1,014

Lehigh, PA 4,663 110,302 30,180 602 1618 193 678 1,742

Northampton, PA 1,975 18,040 68,449 1,803 3,467 46 142 258

Warren, NJ 88 682 7,192 21,034 1,359 4 7 15

Monroe, PA 1,185 410 2,137 200 39,829 2,536 1,664 98

Lackawanna, PA 100 80 92 0 579 79,507 8,105 72

Luzerne, PA 2,224 207 97 12 639 6,847 120,645 3,588

Schuylkill, PA 1,435 268 61 0 31 76 1,179 43,979

Source: U.S. Census Bureau estimates for 2000 County

- to

- County Worker Flow (http://www.census.gov/hhes/commuting/data/commuting.html )9

Of the counties in the Allentown

- Bethlehem

- Easton Metropol itan Statistical Area, Lehigh County has the highest overall VMT, and the highest proportion commuting to violating counties, with most of that commuting occurring within Lehigh County (see Table 6). Northampton County has significant VMT, with a sizable portion commuting to Lehigh County (the location of the violating monitor). Warren County has lower overall VMT, and comparatively lower commuting contribution to Lehigh County (or any of the nearby counties). Carbon County has extremely low

VMT and com muting levels to a violating county. Of the counties in the area of analysis, Luzerne and Lackawanna have comparatively high overall VMT, and Lackawanna has the highest recent VMT growth. Table 6 illustrates how little commuting contribution these (or an y of the neighboring counties) contribute to the Allentown

- Bethlehem

- Easton area.



### Factor 3: Meteorology (weather/transport patterns)

EPA evaluate d any available meteorological data to help determine how meteorological conditions, such as weather, tra nsport patterns and stagnation conditions, would affect the fate and transport of precursor emissions contributing to ozone formation.

The prevailing winds during the summer ozone season for Lehigh County come predominately from the southwest, and to a l esser degree the west and south direction. The violating monitor for this area is located near the center of Lehigh County, close to the eastern edge of the county. On this basis, the neighboring Scranton

- Wilkes

- Barre area to the northeast is less likely to contribute to a violation of the Lehigh County monitor, particularly in light of the topography separation between the areas (i.e., the Blue Mountain Ridge). Based solely on historical prevailing winds, the violating monitor in Lehigh County is unlike ly to be impacted by downwind contribution from Monroe County and Warren County. However, the prevailing historical wind data analyzed is not specific to the violating monitor or the meteorological episodes when the ozone exceedances actually

occurred.

Figure 3 . Prevailing Wind Direction for Lehigh County.10



### Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might affect the airshed and, ther efore, the distribution of ozone over the area

.

The Allentown

- Bethlehem

- Easton area does ha ve several geographical and topographical barriers that impact air pollution generation and transport within its air shed. The region is bounded on the north by Poc ono Mountains, and in particular by the Blue Mountain Ridge that runs west

- southwest

to north

- northeast, creating a significant physical barrier to air movement from north to south and south to north. The Lehigh River crosses the area, with a broad valley that runs from east to west connecting both Lehigh and Northampton Counties. The Delaware River divides Northampton and Warren Counties. Elevation changes run from lows of just over 100 feet above sea level to nearly 1600 feet on the Blue Ridge Mountain Ridge, with the elevation at the Lehigh Valley Airport near Allentown falling at approximately 300 feet. The area lies approximately 80 miles west of the

Atlantic Ocean. Warren County is mountainous, with the Kittatinny Ridge bounding the county on the west. Warren County is also part of the Lehigh Valley on its southern edge, and the Kittatinny Valley in the northern part of the county.

Figure 4. Allentown

- Bethlehem

- Easton Topography (Northampton and Lehigh Counties).

Source: Lehigh Valley Planning Commission11



### Factor 5: Jurisdictional boundaries

Once the general areas to b e included in the nonattainment area were determined, EPA consider ed existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and carrying out the air quality planning and enforcement functions for nonattainment are as. Examples of jurisdictional boundaries include existing/prior nonattainment areas for ozone or other urban

scale pollutants, counties, air districts, townships, metropolitan planning organizations, state lines, Reservations, urban growth boundary, etc. Where existing jurisdictional boundaries are not adequate to describe the nonattainment area, other clearly defined and permanent landmarks or geographic c oordinates are considered.

The Allentown

- Bethlehem

- Easton area has previously established nonattai nment boundaries

associated with the 1997 ozone N AAQS, with Carbon, Lehigh, and Northampton Counties forming

the Allentown

- Bethlehem

- Easton nonattainment area. The Commonwealth initially recommended the same nonattainment area boundary for the 2008 ozone NAAQS in March 2009, but subsequently recommended that only Lehigh County be nonattainment in a November 2011 revised recommendation to EPA. Warren County, New Jersey was part of the separate New York

- Northern New Jersey

- Long Island

, NY

- NJ

- CT n onattainmen t a rea under the 1997 ozone NAAQS, and New Jersey has recommended the same nonattainment boundary for the 2008 ozone NAAQS.

The counties comprising the Allentown

- Bethlehem

- Easton area historically ha ve strong planning

and economic ties. Maintaining the 1 997 ozone NAAQS boundary promotes continuity of planning. Lehigh and Northampton counties comprise the metropolitan transportation planning organization, while Carbon County is part of a five

- county rural planning organization. However, the Pennsylvania Department of Transportation supports Carbon County with respect to air quality

related technical work, and Pennsylvania concedes that past inclusion of Carbon County in the nonattainment area has not proven problematic from a jurisdictional perspective.

Warren County, NJ is part of the Allentown

- Bethlehem

- Easton census

- defined metropolitan statistical area, but is covered by a separate transportation planning organization, and has historically been part of a separate nonattainment area for ozone, as wel l as for particulate matter NAAQS. New Jersey has recommended it for inclusion under the 2008 NAAQS as part of the nearby New York

- Northern New Jersey

- Long Island, NY

- NJ

- CT area, which has a higher overall design value than it would if included in the All entown

- Bethlehem

- Easton nonattainment area.

Luzerne and Lackawanna Counties have are part of the Scranton

- Wilkes

- Barre, PA Metropolitan Statistical Area, and have social and economic times associated with that area. They also have a separate transportati on planning agency from the Allentown

- Bethlehem

- Easton area. Scranton was nonattainment under the 1997 ozone NAAQS, but the area is currently monitoring attainment of the 2008 ozone NAAQS. The topography of the region separates Allentown

- Bethlehem

- Easton from this and other nearby areas to the west and north of the area.

Monroe County is part of the East Stroudsburg Micropolitan Statistical Area . Schuylkill County is part of the one

- county Pottsville Micropolitan Statistical Area. Neither of these tw o counties has strong economic or social ties to the Allentown

- Bethlehem

- Easton area.

The Allentown

- Bethlehem

- Easton Air Basin defined in 25 Pa. Code §121.1 covers portions of Lehigh and Northampton Counties (see Figure 5 ). These basins were developed fo r purposes of the12

sulfur compound controls outlined in 25 Pa. Code § 123.22, yet they represent existing local boundaries for emission controls in the areas of the Commonwealth where they exist.

Figure 5 . Pennsylvania Air Basins

.



### C onclusion

Based on the assessment of factors described above, EPA has preliminarily concluded that the following counties meet the CAA criteria for inclusion in the Allentown

- Bethlehem

- Easton

nonattainment area: Carbon, Lehigh, and Northampton. These are the same counti es that are

included in the Allentown

- Bethlehem

- Easton nonattainment area for the 1997 ozone NAAQS.

The air quality monitor in Lehigh County indicates a violation of the 2008 ozone NAAQS based on the 2010 DV, therefore this county is included in the no nattainment area. Carbon and Northampton are nearby counties that do not have violating monitors, but EPA has concluded that these areas contribute to the ozone concentrations in violation of the 2008 ozone NAAQS through ozone precursor emissions. Northa mpton and Lehigh Counties have among the highest NOx and VOC emissions in the area. Lehigh and Northampton Counties contain the cities of Allentown, Bethlehem, and Easton, where the highest population concentrations in the area are located.13

Vehicle miles of travel are highest in Lehigh and Northampton Counties, and Lehigh County also has the highest percentage of commuters travelling to a county with a violating monitor. Prevailing winds and topography support exclusion of the Scranton

- Wilkes

- Barre area c ounties of Luzerne and Lackawanna, as well as the downwind counties of Monroe and Warren.

In 2009, Pennsylvania recommended that the Allentown

- Bethlehem

- Easton nonattainment area maintain the same boundaries as were in place for the 1997 ozone NAAQS. I n November 2011, Pennsylvania revised its recommendation to shrink the area to only Lehigh County (the location of the violating monitor), setting aside past jurisdictional factors for inclusion of Carbon and Northampton counties as part of the nonattainme nt area. EPA’s believes this jurisdictional argument is a prominent reason for recommending the same intended nonattainment area boundary for the 2008 ozone NAAQS. New Jersey recommends inclusion of Warren County in the New

York

- Northern New Jersey

- Long Island nonattainment area, as it was under the 1997 ozone NAAQS, rather than including Warren County in the Allentown

- Bethlehem

- Easton area. Although Warren County lies in the Allentown

- Bethlehem

- Easton CSA, there are strong jurisdictional arguments for m aintaining the nonattainment boundaries of the 1997 ozone standard for the 2008 ozone standard. EPA there recommends that Warren County not be part of the Allentown

Bethlehem

- Easton nonattainment area.

The adjacent counties to the Allentown

- Bethlehem

- Ea ston area eastern and southern boundary are being recommended by EPA (and the states) as part of separate nonattainment areas with equal or higher classification as EPA recommends for this area. Finally, past ozone NAAQS boundaries and jurisdictional ties support keeping the prior nonattainment boundaries for Allentown

- Bethlehem

Easton, to include Carbon, Lehigh, and Northampton Counties.14

Technical A nalysis for the Lancaster Area

Figure 1 is a map of the Lancaster intended nonattainment area

. The map provides other relevant

information including the locations and design values of air quality monitors , county and other jurisdictional boundaries, metropolitan statistical area boundary, existing maintenance area boundary for

the 1997 ozone NAAQS, and EPA ’s intended nonattainment area boundar y for the 2008 ozone NAAQS

.

Figure 1

For purposes of the 1997 8

- hour ozone NAAQS, this area was designated nonattainment. The boundary

for the nonattainment area for the 1997 o zone NAAQS included the ent ire county of Lancaster.

In March 2009, the Commonwealth of Pennsylvania recommended that Lancaster County be designated

as nonattainment as the Lancaster Area for the 2008 ozone NAAQS based on air quality data from 2006

- 2008, keeping the same boundaries as the 1997 ozone NAAQS nonattainment area. Pennsylvania provided an update to the original recommendation in November 2011 based on air quality data from

2009

- 2011. Based on this updated information, the Commonwealth once more recommended that

Lancaste r County be designated nonattainment under the 2008 ozone NAAQS. The 2008

- 2010 and preliminary 2009

- 2011 monitoring data both show that the same county (Lancaster) is violating the 2008 ozone NAAQS. The recommendations are based on monitoring data from F RM monitors or FEM monitors sited and operated in accordance with 40 CFR Part 58. (See the March 17, 2009 and November 22, 2011 letter s from the Pennsylvania Department of Environmental Pro tection to EPA.)15

After considering these recommendations and b a sed on EPA's technical analysis described below, EPA intends to designate Lancaster County, Pennsylvania (identified in Table 1 below) as “ nonattainment ”

for the 20 08 o zone NAAQS as a single

- county nonattainment area

.

Table 1. State's Recommended and E PA’s Intended Designated Nonattainment Counties for Lancaster

.

Lancaster State

- Recommended

Nonattainment Counties EPA Intended

Nonattainment Counties Pennsylvania Lancaster Lancaster

Factor Assessment

EPA intends to include the nearby counties of Berks , Chester, Cecil, and Harford as part of separate nonattainment areas for the 2008 ozone NAAQS from Lancaster County. Based on EPA's five

- factor analyses, EPA has preliminarily concluded that Berks County should be designated nonattainment as the Reading Area, Chester, and Cecil Counties should be designated nonattainment in the Philadelphia

Wilmington

- Atlantic City Area, and Harford County should be designated nonattainment as part of the Baltimore Area. See EPA’s respective technical analyses for these adjacent nonattainment areas for EPA’s rationale for our intended nonattainment designation for these counties. To the extent that emissions from those counties may contribute ozone concentrations in the Lancaster nonattainment area,

that contribution wil l be lessened by emission controls put in place in those separate nonattainment areas. Therefore, EPA is not including Berks, Chester, Cecil, and Harford Counties in this analysis for

the Lancaster nonattainment area.



### Factor 1: Air Quality Data

For thi s factor , we considered 8

- hour o zone design values (in parts per billion ( pp b) ) for air quality

monitors in counties in the Lancaster area based on data for the 2008

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with ful ly

- certified air quality data

. A monitor’s DV is

the metric or statistic that indicates whether that monitor attains a specified air quality standard. The

2008 o zone NAAQS are met when the annual f ourth

- highest daily maximum 8

- hour average concentration, averaged over 3 years is 0.075 ppm or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where several monitors are located in a county (or a designated nonattainment area or maintenance area ), the DV for the county or area is determined by the monitor with the highest level.

The 2010 DVs and preliminary 2011 DVs for the o zone NAAQS for counties in the Lancaster area and certain nearby surrounding counties are shown in Table 2.

Table 2 . Air Quality Data

.

County State

Recommended

Nonattainment? EPA

Recommended

Nonattainment? 2008

- 2010

Design Value ( ppb ) 2009

- 2011

Preliminary Design Value (ppb)
Lancaster, PA Yes Yes 77 77 York, PA No No 74 72 Lebanon, PA No No

-- -- Dauphin, PA No No 73 73

Note : Counties with no ozone monitor are identified with “

-- “ in the 2010 and 2011 8

- hour Ozone DV columns.16

In accordance with section 107(d) of the Clean Air Act, EPA must designate an area “nonattainment” if it is violating the 2008 ozone NAAQS. Lancaster Cou nty shows a violation of the 2008 o zone NAAQS

, t herefore this county must be included in a nonattainment area. A county (or partial county) must also be designated nonattainment if it contributes to a violation in a nearby area. Each county without a

vio lating monitor that is located near a county with a violating monitor has been evaluated based on the weight of evidence of the five factors to determine whether it contributes to the nearby violation

.



### Factor 2: Emissions and Emissions

- Related Data

E PA evaluated emissions of ozone precursors ( NO

x and VOC ) and other emissions

- related data that provide information on areas contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NO

x and VOC derived from the 200 8 National Emissions Inventory (NEI), version 1.5

. This is the most recently available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a near by area indicate the potential for the area to contribute to observed violations. We will also consider any additional information we receive on changes to emissions levels that are not reflected in recent inventories. These changes include emissions redu ctions due to permanent and enforceable emissions controls that will be in place before final designations are issued and emissions increases due to new

sources.

Table 3 shows emissions of NO

x and VOC (given in tons per year) for violating and nearby pote ntially contributing counties in the Lancaster area.

Table 3. Total 2008 NO

x and VOC Emissions.

County State Recommended

Nonattainment? EPA Recommended

Nonattainment? NO

x (tpy) VOC (tpy)

Lancaster, PA Yes Yes 18,217 22,877

York, PA No No 35,616 15,72 3

Lebanon, PA No No 6,166 5,367

Dauphin, PA No No 10,848 11,760

York County has much higher NOx emissions than the other nearby counties, having nearly as much total NOx emissions as all the other counties listed in Table 3. Lancaster has the highest VOC emissions, followed closely by York. Lebanon and Dauphin have comparatively lower emissions of

both NOx and VOCs.

Population density and degree of urbanization

EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozone

- creating

emissions from on

- road and off

- road vehicles and engines, consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial development are an indicator of area source and mobile source NO

x and VOC emissions that may contribute to ozone17

formation. Table 4 shows the population, population density, and population growth information for each county in th e area.

Table 4 . Population and Growth.

County State

Recommended

Nonattainment? EPA

Recommended

Nonattainment? 20 10

Population 20 10 Population

Density (1000 pop/sq mi) Absolute

change in population (2000

- 2010) Population

% change (2000

- 20 10 )

Lancaster, PA Yes Yes 519,445 0.53 47,669 +10%

York, PA No No 434,972 0.48 52,263 +14%

Lebanon, PA No No 133,568 0.37 13,151 +11%
Dauphin, PA No No 268,100 0.48 16,303 +6%
Sources: U.S. Census Bureau population estimates for 2010 as of August 4, 2011 ( http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTPL2.STO5&prodType

=table )

Figure 2. Population Distribution for Lancaster, York, Harrisburg, and Reading

Source: US Census Bureau (http://2010.census.gov/2010census/popmap/)

Lancaster County has the highest population of any of the counties in the Lancaster and surrounding

areas , followed by York County. Dauphin and Lebanon have much lower populations. All of these counties have similar population densities, ranging from 370 to 530 persons per square mile, however, these populations of the cities and towns are distributed uneve nly between small, dense urban cores and outlying towns and rural areas. As can be seen in the Census map in Figure 2, the Cities of Lancaster,18

York (and to a lesser extent Reading and Harrisburg) all have small dense urban centers surrounded by sparsely populated areas with smaller towns interspersed.

Nearly all of the counties in Table 4 have experienced double digit growth between 2000 and 2010, but the overall population growth numbers for all four counties total just over a hundred thousand persons over the past decade.

Traffic and commuting patterns

EPA evaluated the total Vehicle Miles Traveled (VMT) in the area and VMT growth, as well as

commuter movement within and between counties . This information, in combination with the population/popula tion density data and the location of main transportation arteries (see Figure 1, above), helps in identifying the probable location of non

- point source emissions. A county with high VMT

and/or a high num b er of commuters is generally an integral part of an urban area and indicates the presence of motor vehicle emissions that may contribute to ozone formation. Rapid population or VMT growth in a county on the urban perimeter signifies increasing integration with the core urban area, and

indicates that the a ssociated area source and mobile source emissions may be appropriate to include in

the nonattainment area. Table 5 shows traffic and commuting pattern data, including total 2005 VMT, growth in VMT for the period between 2002

- 2008, and the total vehicle mi les traveled (VMT) for each

county. Table 6 shows the number of commuters traveling within and between the counties in the area of analysis.

Table 5 . Traffic and VMT data.

County State

Recommended

Nonattainment? EPA

Recommended

Nonattainment? 200 8 VMT *

(million miles) Percent VMT Growth

2002

- 2008
Lancaster, PA Yes Yes 4,245 9.0%

York, PA No No 3,275 6.1%

Lebanon, PA No No 1,210 4.5%

Dauphin, PA No No 3,062 2.0%

* MOBILE model VMTs are those inputs into the NEI version 1.5.

Table 6. County to County Worker Flow.

Residence County Lancaster, PA York, PA Lebanon, PA Dauphin, PA

Workplace County

Lancaster, PA 201,608 5,485 3,770 2,585

York, PA 4,018 142,104 266 2,365

Lebanon, PA 1,952 332 36,677 2,508

Dauphin, PA 6,927 9,848 12,853 9 3,958

Source: U.S. Census Bureau estimates for 2000 County

- to

- County Worker Flow (http://www.census.gov/hhes/commuting/data/commuting.html

Lancaster County has the highest overall VMT and historical growth in VMT of the counties in the area of analysis, followed by York and Dauphin Counties. Table 6 shows the county to county commu ter worker flow. Lancaster has the highest number of commuters, most of whom travel within Lancaster County, which has the only violating monitor in the area of analysis. Similarly, York County commuters travel predominantly inside York County, with only 10% travelling to any county with a19

violating monitor. Dauphin and Lebanon Counties also contribute very few commuters to Lancaster County, with most commuting inside their home county.



### Factor 3: Meteorology (weather/transport patterns)

EPA evaluat e d any available meteorological data to help determine how meteorological conditions, such as weather, transport patterns and stagnation conditions, would affect the fate and transport of precursor emissions contributing to ozone formation.

Figure 3. Pr evailing Summertime Wind Direction for Lancaster

.

The prevailing winds during the ozone season predominate from the west

- northwest, indicating that

emissions from the Harri s burg

- Lebanon

- Carlisle metropolitan area c ounties of L ebanon and Dauphin

may have a n impact on the Lancaster violating monitor. To a lesser extent, York County emissions may also contribute to the violating monitor, dependent upon the wind direction during an ozone episode. The emissions impact from Berks, Chester, Cecil, and even Harford Counties appear to be lower, on the basis of prevalent wind direction alone, than the counties to the west of Lancaster. Note that the

counties of Chester, Berks, and Harford, MD are downwind (based on prevalent wind direc tion) of

Lancaster and have highe r 2010 DVs than the monitors in York, Cumberland, and Dauphin Counties,20

which are are upwind of Lancaster. Wind data alone is inconclusive, but it is possible the upwind counties are contributing emissions affecting Lancas ter, and also that pollution is transported as it moves downwind along the MSAs in the Northeast Corridor. There may be local as well as long range impacts, but further meteorological modeling or source apportionment would be necessary to prove the impact between these nearby areas.



### Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might affect the airshed and, therefore, the distribution of ozone over the area

.

Figure 4. Topographic Map of Lancaster.

Source: US Geologic Society (www.usgs.gov)21

The Lancaster area does not have any geographical or topographical barriers significantly limiting air pollution transport within its air shed. Therefore, this factor did not play a significant role in this

evaluation

.



### Factor 5: Jurisdictional boundaries

Once the general areas to be included in the nonattainment area were determined, EPA consider ed existing jurisdictional boundaries for the pu rposes of providing a clearly defined legal boundary and carrying out the air quality planning and enforcement functions for nonattainment areas. Examples of jurisdictional boundaries include existing/prior nonattainment areas for ozone or other urban

- sca le pollutants, counties, air districts, townships, metropolitan planning organizations, state lines, Reservations, urban growth boundary, etc. Where existing jurisdictional boundaries are not adequate to describe the nonattainment area, other clearly defi ned and permanent landmarks or geographic

c oordinates are used.

The single

- county Lancaster MSA area has previously established nonattainment boundaries associated

with the 1997 8

- hour ozone N AAQS.

The Commonwealth has recommended the same boundary for the 2008 ozone NAAQS, with Lancaster County to be designated nonattainment as a single

- county area for the 2008 ozone NAAQS. Lancaster County is a single

- county metropolitan statistical area based on economic, political and commuting patterns. This area is served by a single

- county transportation

- planning agency.

Figure 5 . Pennsylvania Air Basins22

The Lancaster Air Basin defined in 25 Pa. Code §121.1 covers portions of Lancaster County (see Figure

5 ). These basins were developed for purposes of the sulfur compound controls outlined in 25 Pa. Code § 123.22, yet they represent existing local boundaries for emission controls in the areas of the Commonwealth where they exist.



### Conclusion

Based on the assessment of factors described above, EPA has pr eliminarily concluded that the following

counties meet the CAA criteria for inclusion in the Lancaster nonattainment area: Lancaster.

This is the same county that is included in the Lancaster nonattainment area for the 1997 ozone NAAQS. The air quality monitor in Lancaster County indicates violations of the 2008 ozone NAAQS based on the 2010 DVs, therefore this county must be included in the nonattainment area. Chester, Harford, Cecil, and Berks are nearby counties that have violating monitors, but ar e part of nearby CSAs and are being recommended for nonattainment as part of separate areas. York, Cumberland, Dauphin, and Lebanon Counties do not have violating monitors, but EPA has concluded

that these areas do not contribute to the ozone concentratio ns in violation of the 2008 ozone NAAQS of Lancaster County enough to warrant their inclusion in the Lancaster nonattainment area.

York Count y ha s the highest NOx emissions of the counties evaluated and has the second highest VOC

emissions

. York County ha s the second highest population and the largest population growth over the past decade. York County has the second highest VMT, but most York County commuters remain within York County and do not travel to Lancaster County (where the violating monitor i s located). Meteorology indicates that emissions from York County may contribute little to violations of the ozone standard as prevalent wind patterns come predominantly from the west and northwest, and York County

is to the west/southwest of Lancaster Co unty and its violating monitor. Meteorology indicates that Lebanon and Dauphin may contribute to violations in Lancaster, because prevalent wind patterns come from the west and northwest, and those counties lie in that direction. However, the magnitude o f NOx and VOCs from those counties is comparatively smaller than Lancaster or York Counties.

Lancaster has the highest VMT of all the counties being compared here (followed by York), and has by far the highest number of commuters, most of whom commute within Lancaster County, where the violating monitor is located

.

There are strong jurisdictional arguments for making Lancaster a single county nonattainment area. The county has is a single

- county metropolitan statistical area based on economic, po litical and commuting patterns. Lancaster County was a single county nonattainment area under the 1997 ozone NAAQS, and the prior 1

- hour ozone NAAQS. The area is served by a single

- county transportation

planning agency, and has a unique political and cul tural identity of its own.

The Commonwealth has recommended the same single

- county boundary for the 2008 ozone NAAQS,

with Lancaster County to be designated nonattainment for the 2008 ozone NAAQS. This area is served by a single

- county transportation

- p lanning agency. Designating it as a single

- county nonattainment area maintains continuity of planning since the county has an approved maintenance plan for the 1997 ozone NAAQS.23

Technical A nalysis for the Philadelphia

- Wilmington

- Atlantic City Area

Fig ure 1 is a map of the Philadelphia

- Wilmington

- Atlantic City intended nonattainment area (the Philadelphia Area) . The map provides other relevant information including the locations and design values of air quality monitors , county and other jurisdictional boundaries

. The map shows the boundaries of the Philadelphia

- Camden

- Vineland CSA, the existing nonattainment area boundary for the 1997 ozone NAAQS, and EPA’s intended nonattainment boundary for the 2008 ozone NAAQS.

Figure 1.

For purposes of the 199 7 8

- hour ozone NAAQS, this area was designated nonattainment. The Philadelphia

- Wilmington

- Atlantic City nonattainment area included the entire counties of Kent, Ne w Castle, and Sussex in Delaware; Cecil in Maryland ; Atlan tic, Burlington, Camden, Cape May, Cumberland, Gloucester, Mercer, Ocean, and Salem in New Jersey; and Bucks, Chester, Delaware, Montgomery, and Philadelphia in Pennsylvania.

In March 2009, the State of Delaware recommended that no counties in Delaware be included in the Philadelphia Are a for the 2008 ozone NAAQS based on air quality data from 2006

- 2008. Instead, Delaware recommend a large, multi

- state nonattainment area, covering the entire States of Delaware, Maryland, Michigan, New Jersey, New York, North Carolina, Ohio, Pennsylvania, Virginia, and West Virginia, and the District of Columbia. Alternatively, Delaware recommended that the entire State of Delaware be designated as a stand

- alone nonattainment area. In October 2011, Delaware updated its recommendations. In that letter, D elaware expanded its recommended large multi

- state nonattainment24

area to include the States of Kentucky, Indiana, Illinois, Missouri, Tennessee, and Wisconsin. In addition, in its October 2011 letter, the State of Delaware specified that if EPA did not acc ept either of its designation options, then Kent County should not be designated nonattainment. This recommendation is

based on 2008

- 2010 data and preliminary 2009

- 2011 data. The recommendations were based on data from Federal Reference Method (FRM) monit ors or Federal Equivalent Method (FEM) monitors sited and operated in a ccordance with 40 CFR Part 58. (See the March 18, 2009 letter from Governor Jack A. Markell to EPA, received on April 3, 2009; and the October 28, 2011 letter from the Delaware Departm ent o f Natural Resources a nd Environmental Control

. )

In March 2009, the State of Maryland recommended that Cecil County be designated as nonattainment as part of the Philadelphia Area for the 2008 ozone NAAQS based on air quality data from 2006

- 2008.

Thi s is the same Maryland County that was included in the Philadelphia

- Wilmington

- Atlantic City nonattainment area for the 1997 ozone NAAQS. This recommendation was based on data from FRM

monitors or FEM monitors sited and operated in accordance with 40 CFR Part 58. (See the March 10,

2009 letter from Governor M artin O’M alley to EPA, rece i v ed on March 16, 2009.)

In April 2009, the State of New Jersey recommended that the same nine counties in New Jersey that were included in the Philadelphia

- Wilmington

- Atla ntic City nonattainment area for the 1997 ozone NAAQS be designated as nonattainment in the Philadelphia Area for the 2008 ozone NAAQS based on air quality data from 2006

- 2008. This recommendation was based on data from FRM monitors or FEM

monitors sited and operated in accordance with 40 CFR Part 58. (See the April 1, 2009 letter from the New Jersey D epartment o f Environmental Protection to EPA.)

In March 2009, the Commonwealth of Pennsylvania recommended that the same five counties in Pennsylvania that were included in the Philadelphia

- Wilmington

- Atlantic City nonattainment area for the 1997 ozone NAAQS be designated as nonattainment in the Philadelphia Area for the 2008 ozone NAAQS based on air quality data from 2006

- 2008. Pennsylvania provided an upd ate to the original

recommendation in November 2011 based on air quality data from 2009

- 2011. That recommendation was to remove Chester and Delaware Counties from the Philadelphia Area, and designate those counties

as attainment. This recommendation was based on data from FRM monitors or FEM monitors sited and operated in accordance with 40 CFR Part 58. (See the March 17, 2009 and November 22, 2011 letter s from the Pennsylvania Department of Environmental Pro tection to EPA.)

After considering these re commendations and based on EPA's technical analysis described below, EPA intends to designate 16 counties in Delaware, Maryland, New Jersey, and Pennsylvania (identified in Table 1 below) as “nonattainment” for the 2008 ozone NAAQS as the Philadelphia Area nonattainment

area.

Table 1. State's Recommended and EPA’s Intended Designated Nonattainment Counties for the Philadelphia Area.

Philadelphia State

- Recommended

Nonattainment Counties EPA Intended

Nonattainment Counties

Delaware None New Castle Maryl and Cecil Cecil

New Jersey Atlan tic, Burlington, Camden, Cape May, Cumberland, Gloucester, Mercer, Ocean, and Salem Atlan tic, Burlington, Camden, Cape May, Cumberland, Gloucester, Mercer, Ocean, and Salem

Pennsylvania Bucks, Montgomery, and Philadelphia Bucks, Chester, Delaware, Montgomery, and Philadelphia25

Factor Assessment

The counties evaluated in this analysis include all counties in the Philadelphia

- Camden

- Vineland CSA plus the counties outside the CSA that were included in the Philadelphia

- Wilming ton

- Atlantic City nonattainment area for the 1997 ozone NAAQS.



### Factor 1: Air Quality Data

For this factor , we considered 8

- hour o zone design values (in parts per billion (ppb)) for air quality

monitors in counties in the Philadelphia Area based on data for the 2008

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with fully

- certified air quality data

. A monitor’s

DV is the metric or statistic that indicates whether that monitor attains a specified air quality standard.

The 2008 o zone NAAQS are met when the annual f ourth

- highest daily maximum 8

- hour average concentration, averaged over 3 years is 0.075 ppm or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where s everal monitors are located in a county (or a designated nonattainment area or maintenance area ), the DV for the county or area is determined by the monitor with the highest level.

Note: Monitors that are eligible for providing design value data generall y include State and Local Air Monitoring Stations (SLAMS) that are sited in accordance with 40 CFR Part 58, Appendix D (Section 4.1) and operating with a federal reference method (FRM) or federal equivalent method (FEM) monitor that meets the requirements of 40 CFR part 58, appendix A. All data from a special purpose monitor (SPM) using an FRM or FEM which has operated for more than 24 months is eligible for comparison to the NAAQS unless the monitoring agency demonstrates that the data came from a particul ar period during which the requirements of appendix A (quality assurance requirements) or appendix E (probe and monitoring path siting criteria) were not met.

The 2010 DVs for the o zone NAAQS for counties in the Philadelphia

- Camden

- Vineland CBSA and

sever al nearby surrounding area are shown in Table 2

.

Table 2 . Air Quality Data

.

County State Recommended

Nonattainment? 2010 8

- hour Ozone DV (ppb)

Atlantic, NJ Yes 74

Berks, PA Yes, other area 79

Bucks, PA Yes 83

Burlington, NJ Yes

-- Camden, NJ Yes 8 0

Cape May, NJ Yes

-- Cecil, MD Yes 80

Chester, PA No 76

Cumberland, NJ Yes 76

Delaware, PA No 74

Gloucester, NJ Yes 81

Kent, DE No 74

Mercer, NJ Yes 78

Montgomery, PA Yes 7826

New Castle, DE Yes, other area 76

Ocean, NJ Yes 81
Philadelphia, PA Y es 82

Salem, NJ Yes

-- Sussex, DE Yes, other area 77

Note: Counties with no ozone monitor are identified with “

-- “ in the 2010 8

- hour Ozone DV column

.

In accordance with section 107(d) of the Clean Air Act, EPA must designate an area nonattainment if it is violating the 2008 ozone NAAQS. New Castle and Sussex Counties in Delaware, Cecil County, Maryland; Berks, Buck s , Montgomery, and Philadelphia Counties in Pennsylvania; and several counties in New Jersey show violations of the 2008 ozone NAAQS . The refore , these counties must be included

in a nonattainment area. A cou nty (or partial county) must also be designated nonattainment if it contributes to a violation in a nearby area. Each county without a violating monitor that is located near a

county w ith a violating monitor has been evaluated based on the weight of evidence of the five factors

and other relevant information to determine whether it contributes to the nearby violation

.



### Factor 2: Emissions and Emissions

- Related Data

EPA evaluated em issions of ozone precursors ( NO

x and VOC ) and other emissions

- related data that provide information on areas contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NO

x and VOC derived from the 200 8 National Emissi ons Inventory (NEI), version 1.5

. This is the most recently available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a nearby area

indicate the potential for the area to contribute to observed violations. We will also consider any additional information we receive on changes to emissions levels that are not reflected in recent inventories. These changes include emissions reductions due to per manent and enforceable emissions controls that will be in place before final designations are issued and emissions increases due to new

sources.

Table 3 shows emissions of NO

x and VOC (given in tons per year) for violating and potentially contributing cou nties in the Philadelphia Area

.

Table 3. Total 2008 NO

x and VOC Emissions.

County State Recommended

Nonattainment? NO

x (tpy) VOC (tpy)

Atlantic, NJ Yes 6,143 10,713

Berks, PA Yes, other area 18,908 15,918

Bucks, PA Yes 17,736 21,160
Burlington, NJ Yes 10,919 12,909

Camden, NJ Yes 12,725 10,731
Cape May, NJ Yes 6,407 7,774

Cecil, MD Yes 4,763 3,715

Chester, PA No 16,806 16,351

Cumberland, NJ Yes 4,916 5,72727

Delaware, PA No 28,118 15,881

Gloucester, NJ Yes 18,335 11,756

Kent, DE No 7,667 5,38 1

Mercer, NJ Yes 9,909 8,160
Montgomery, PA Yes 22,741 26,372

New Castle, DE Yes, other area 22,633 14,133

Ocean, NJ Yes 9,909 19,572
Philadelphia, PA Yes 33,176 32,021

Salem, NJ Yes 6,106 3,308

Sussex, DE Yes, other area 14,870 9,972

Philadelphia County, PA has the highest NOx and VOC emissions in the area of analysis. Other

counties with comparat ively high emissions are New Castle County in Delaware; and Delaware and Montgomery Counties in Pennsylvania. Counties with comparatively low emissions are Kent County,

Delaware ; Cecil County, Maryland ; and several counties in New Jersey

.

P opulation density and degree of urbanization

EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the probable locat ion and magnitude of non

- point source emissions . These include ozone

- creating

emissions from on

- road and off

- road vehicles and engines, consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial develop ment are an indicator of area source and mobile source NO

x and VOC emissions that may contribute to ozone

formation

. Table 4 shows the population, population density, and population growth information for each county in the area.

Table 4 . Population and Growth.

County State

Recommended

Nonattainment? 2010

Population 2010 Population

Density (1000 pop/sq mi) Absolute change

in population (2000

- 2010) Population %

change (2000

- 2010)

Atlantic, NJ Yes 274,549 0.45 21,569 +9%

Berks, PA Yes, other area 41 1,442 0.48 36,945 +10%

Bucks, PA Yes 625,249 1.01 25,841 +4%
Burlington, NJ Yes 448,734 0.55 24,255 +6%

Camden, NJ Yes 513,657 2.26 6,064 +1%
Cape May, NJ Yes 97,265 0.34 (5,043)

- 5%

Cecil, MD Yes 101,108 0.27 14,643 +17%

Chester, PA No 4 98,886 0.66 63,107 +14%

Cumberland, NJ Yes 156,898 0.31 10,547 +7%

Delaware, PA No 558,979 2.93 6,938 +1%

Gloucester, NJ Yes 288,288 0.86 31,962 +12%

Kent, DE No 162,310 0.27 35,200 +28%

Mercer, NJ Yes 366,513 1.60 14,979 +4%

Montgomery, PA Yes 799,874 1.64 48,936 +7%

New Castle, DE Yes, other area 538,479 1.11 36,620 +7%

Ocean, NJ Yes 576,567 0.76 62,913 +12%
Philadelphia, PA Yes 1,526,006 10.71 12,194 +1%28

Salem, NJ Yes 66,083 0.19 1,867 +3%

Sussex, DE Yes, other area 197,1 45 0.20 39,710 +25%
Sources: U.S. Census Bureau population estimates for 2010 as of August 4, 2011. ( http://factfinder2. census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTPL2.STO5&prodType

=table )

Philadelphia County, Pennsylvania has the highest population and population density in the area of analysis. Bucks, Chester, Montgomery, and Delaware C ounties, in Pennsylvania and New Castle County in De laware also have comparatively large populations compared to Kent County, Delaware and several counties in New Jersey with comparatively small populations and population densities. Most

counties in the a nalysis have experienced some population growth.

Traffic and commuting patterns

EPA evaluated the total Vehicle Miles Traveled (VMT) for each county in the area . In combination with the population/population density data and the location of main transpo rtation arteries (see Figure 1, above), this information helps identify the probable location of non

- point source emissions. A county

with high VMT is generally an integral part of an urban area and indicates the presence of motor vehicle

emissions that ma y contribute to ozone formation. Rapid population or VMT growth in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the

associated area source and mobile source emissions may be appropriate to in clude in the nonattainment

area. Table 5 shows total 2008 VMT for each county.

Table 5 . Traffic (VMT) Data

.

County State Recommended

Nonattainment? 2008 VMT*

(million miles)

Atlantic, NJ Yes 2,863

Berks, PA Yes, other area 3,335

Bucks, PA Yes 5,021

Burlington, NJ Yes 4,524

Camden, NJ Yes 3,923

Cape May, NJ Yes 1,040

Cecil, MD Yes 1,350

Chester, PA No 4,410

Cumberland, NJ Yes 1,163

Delaware, PA No 3,782

Gloucester, NJ Yes 2,645

Kent, DE No 1,565

Mercer, NJ Yes 3,306

Montgomery, PA Yes 6,883

New Castle, DE Yes, other area 5,266

Ocean, NJ Yes 3,834
Philadelphia, PA Yes 5,955

Salem, NJ Yes 992

Sussex, DE Yes, other area 2,122
* MOBILE model VMT are those inputs into the NEI version 1.5.29

New Castle County, Delaware; and Bucks, Montgomer y, and Philadelphia Counties in Pennsylvania have the highest VMT in the area of analysis. Kent County, Delaware; Cecil County, Maryland; and several counties in New Jersey have relatively low VMT.

Ta ble 6. County to County Worker Flow.

Residence Count y Kent,

DE New Castle,

DE Sussex,

DE Cecil,

MD Berks,

PA Bucks,

PA Chester,

PA Delaware,

PA Montgomery,

PA Philadelphia,

PA Workplace County
Kent, DE 47,455 3,927 5,704 186 157 18 131 112 41 65
New Castle, DE 6,058 209,742 1,119 14 ,059 493 12,976 9,002 1,201 1,856
Sussex, DE 3,779 319 52,073 33 29 15 6 39
Cecil, MD 243 3,379 42 18,446 18 557 192 52
Atlantic, NJ 11 142 31 4 172 73 231 181 831 Burlington, NJ 40 475 25 27 40 4,250 426 1,306 1,559 5,087
Camden, NJ 55 434 10 7 2 27 2,039 539 2,287 1,844 7,196 Cape May, NJ 27 20 13 54 81 118 95 324
Cumberland, NJ 26 164 5 19 42 24 103 66 140
Gloucester, NJ 750 19 82 16 362 411 1,251 405 1,502
Mercer, NJ 10 78 12 7 37 20,812 222 345 1,298 1,676
Ocean, NJ 13 30 8 5 220 23 10 13 86
Salem, NJ 32 1,841 11 139 37 155 245 59 84
Berks, PA 4 48 5 140,819 410 1,916 187 4,231 243
Bucks, PA 12 261 12 22 675 168,090 1,133 2,060 23,722 23,248
Chester, PA 37 4,738 33 941 5,596 3,036 137,678 18,504 25,006 7,810
Delaware, PA 125 8 ,150 61 373 505 2,754 17,870 137,988 11,758 21,802 Montgomery, PA 27 1,851 53 176 12,727 48,414 25,673 28,144 245,619 59,970 Philadelphia, PA 83 5,386 131 254 702 31,892 10,568 48,151 54,576 429,667 Source: US Census Bureau County

- To

- County Worker Flo w Files http://www.census.gov/population/www/cen2000/commuting/index.html

Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties in Pennsylvania have the highest numbers of commuters to other counties in the Philadelphia

- Camden

- Vineland CSA

. Ne w Castle County, Delaware, Cecil County, Maryland, and Berks County, Pennsylvania have moderate numbers of commuters into other counties in the CSA. Sussex and Kent Counties in Delaware, which are not in the Philadelphia

- Camden

- Vineland CSA, have the fewe st commuters into the CSA

.



### Factor 3: Meteorology (weather/transport patterns)

EPA evaluate d available meteorological data , consisting of 30

- year average s ummertime w ind d irections

from the National Weather Service

, to help determine how meteorological conditions, such as weather, transport patterns and stagnation conditions, would affect the fate and transport of precursor emissions contributing to ozone formation.

The highest ozone design values, over 80 ppb, are in Bucks and Philadelphia Counties, i n Pennsylvania, and Ocean County in New Jersey. The winds during the ozone season come predominantly from the

south west

. This indicates that emissions from Chester and Delaware Counties in Pennsylvania; New Castle County, Delaware; Cecil County, Maryland ; and counties in southwest New Jersey contribute to the downwind violations in Bucks and Philadelphia Counties during most of the ozone season. Considering prevailing wind patterns and the location of the highest violating monitors, Berks County, Pennsyl vania and Kent and Sussex Counties in Delaware are unlikely to contribute to downwind violations during most of the ozone season.30 

### Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might affect the airshed and, therefore, the distribution of ozone over the area

.

The Philadelphia Area does not have any geographical or topographical barriers significantly limiting air pollution transport within its air shed. Therefore, there are no barriers to contribution from upwind

areas.



### Factor 5: Jurisdictional boundaries

EPA consider s existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and so that areas de signated nonattainment have the legal authority and cooperative planning

necessary to carrying out the air quality planning and enforcement functions for nonattainment areas. Examples of jurisdictional boundaries include existing/prior nonattainment areas for ozone or other

urban

- scale pollutants, counties, air districts, townships, metropolitan planning organizations, state lines, Reservations, urban growth boundary, etc. Where existing jurisdictional boundaries are not adequate to

describe the nonattain ment area, other clearly defined and permanent landmarks or geographic

c oordinates are used.

T he major jurisdictional boundaries in the Philadelphia

- Wilmington

- Atlantic area are the state lines between Pennsylvania, Delaware, and New Jersey. A ir

- quality monitors that violate the 2008 8

- hour

ozone NAAQS in the Philadelphia Area are located in Delaware, Maryland, New Jersey, and Pennsylvania.

The Philadelphia

- Camden

- Vineland CSA consists of New Castl e County, Delaware; Cecil County, Maryland; Burlington

, Camden

, Cumberland, Gloucester, and Salem Counties in New Jersey, and Berks, Bucks , Chester, Delaware, Montgomery, and Philadelphia Counties in Pennsylvania. All those counties, except for Berks County, Pennsylvania are included in the Philadelphia

- Wilmi ngton

- Atlantic City nonattainment area for the 1997 8

- hour ozone NAAQS. The nonattainment area also includes Kent and Sussex Counties, Delaware and Atlan tic, Cape May, Mercer, and Ocean Counties, New Jersey.

Mercer and Ocean Counties, New Jersey are pa rt of the New York

- Newark

- Bridgeport, NY

- NJ

- CT

- PA CSA. Atlantic County makes up the Atlantic City

- Hammonton, NJ MSA. Cape May County makes up the Ocean City, NJ MSA

. In Delaware, Kent County, Delaware makes up the Dover MSA and Sussex County makes up th e Seaford Micropolitan Statistical Area.

T he Delaware Valley Regional Planning Commission (DVRPC)

, the metropolitan planning organization (MPO) in the Philadelphia Area, serves Bucks, Chester, Delaware, Montgomery

, and Philadelphia Counties in Pennsylva nia, and Burlington, Camden, Gloucester

, and Mercer Counties in New Jersey. New Castle County, DE and Cecil County, Maryland are in a separate MPO, the Wilmington Area Planning Council (WILMAPCO)

.

Delaware New Castle County has historically been part o f the P hiladelphia nonattainment area for ozone (1

- hour

and 8

- hour) and fine p articulate matter (PM 2.5 ). New Castle County is part of the Wilmington, DE

- MD

-31

NJ Metropolitan Division of the Philadelphia

- Camden

- Wilmington Metropolitan Statistical Area ( MSA ) in the Philadelphia

- Camden

- Vineland CSA

. Being part of a statistical area indicates that counties are linked through employment and commuting. According to the Office of Management and Budget’s

“ Standards for Defining Metropolitan and Micropolitan Stati stical Areas,” published in the Federal Register on December 27, 2000 (65 FR 82228) , the “general concept of a Metropolitan Statistical Area or a Micropolitan Statistical Area is that of an area containing a recognized population nucleus and adjacent commu nities that have a high degree of integration with that nucleus.” D elaware, Pennsylvania, Maryland and New Jersey have a long history of working cooperatively through the Ozone Transport Commission ( OT C) and the Mid

- Atlantic Northeast Visibility Union (MA NE

- VU) with ozone attainment planning. Furthermore, the two local MPOs, DVRPC and WILMAPCO , have worked together for decades.

Kent and Sussex Counties are less connected to the Philadelphia Area. They are not part of the Philadelphia

- Camden

- Vineland CS A . Kent County makes up the Dover MSA, and Sussex County makes up the Seaford Micropolitan Statistical Area. The Dover/Kent County MPO is the planning organization for Kent County, Delaware. This MPO covers 20 municipalities including all of Smyrna,

whi ch is also in New Castle County and all of Milford, which is also in Sussex County. Planning for Sussex County is done by the Sussex County Planning and Zoning Commission While Kent County was part of the Philadelphia

- Wilmington

- Trenton nonattainment area for the 1

- hour ozone NAAQS, Sussex County was a separate nonattainment area.

Maryland Cecil County has historically been part of the P hiladelphia nonattainment area for ozo ne (1

- hour and 8

- hour) and PM 2.5

. Cecil County is part of the Wilmington, DE

- M D

- NJ Metropolitan Division of the Philadelphia

- Camden

- Wilmington MSA in the Philadelphia

- Camden

- Vineland CSA

. Maryland,

D elaware, Pennsylvania, and New Jersey have a long history of working cooperatively through the OT C

and MANE

- VU and with ozone attainme nt planning. Furthermore, the two local MPOs, DVRPC and

WILMAPCO , have worked together for decades.

Pennsylvania Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties have historically been part of the

P hiladelphia nonattainment area for ozon e (1

- hour and 8

- hour) and PM 2.5

. These five counties are part
of the Philadelphia, PA Metropolitan Division of the Philadelphia

- Camden

- Wilmington MSA in the Philadelphia

- Camden

- Vineland CSA

. These counties are part of DVRPC, the main MPO for the

Philade lphia Area.

Berks County is less connected to Philadelphia. While it was added to the Philadelphia

- Camden

Vineland CSA in December 2005, it’s in a separate MSA, the Reading, PA MSA. Berks County has historically not been part of the Philadelphia nonatta inment area for 8

- hour ozone and PM 2.5 , but has been designated separately as the Reading area. Berks County was designated attainment/unclassifiable

for 1

- hour ozone. In addition, Berks County is covered by a separate MPO, the Berks County Planning

Comm ission

.



### Conclusion

Based on the assessment of factors described above, EPA has preliminarily concluded that the following

counties meet the CAA criteria for inclusion in the Philadelphia

- Camden

- Atlantic City nonattainment

area: New Castle County, Del aware; Cecil County, Maryland; Atlan tic, Burlington, Camden, Cape32

May, Cumberland, Gloucester, Mercer, Ocean, and Salem Counties in New Jersey; and Bucks, Chester, Delaware, Montgomery, and Philadelphia Counties in Pennsylvania. The Philadelphia

- Wilmingto n

Atlantic City nonattainment area for the 1997 8

- hour ozone NAAQS included these same counties, plus

Kent and Sussex Counties in Delaware. New Castle Count y in Delaware ; Cecil County in M aryland; and Berks, Bucks , Montgomery, and Philadelphia Counties in Pennsylvania show violations of the 2008 ozone NAAQS. 4 Maryland and Pennsylvania have requested that these violating counties in their respective States be included as part of the Philadelphia nonattainment area, which is consistent with

their inclusion o f that area for the 1

- hour and 1997 8

- hour NAAQS and the PM2.5 NAAQS. Additionally, we think the factors above support inclusion of these counties in that nonattainment area. Therefore, we intend to include them as part of the Philadelphia nonattainment a rea for the 2008 ozone NAAQS.

New Castle County, Delaware has relatively high emissions, high population, and high VMT. Considering prevailing winds from the southwest, this county likely contributes to downwind violations of the ozone NAAQS in the Phi ladelphia Area

. Furthermore, New Castle County is part of the Philadelphia

- Wilmington

- Atlantic City 8

- hour ozone nonattainment area and the Philadelphia

- Camden

Vineland CSA. New Castle County has a moderate degree of commuting into the other counties in the CSA, including over 24,000 commuters into Cecil, Chester, Delaware, Montgomery, and Philadelphia Counties. Therefore, EPA intends to designate New Castle County as nonattainment as part of the Philadelphia Area.

Chester and Delaware Counties in Penns ylvania are part of the Philadelphia, PA Metropolitan Division of the Philadelphia

- Camden

- Wilmington MSA in the Philadelphia

- Camden

- Vineland CSA. These counties have been historically part of the Philadelphia nonattainment areas for ozone (8

- hour and 1

- ho ur) and PM 2.5 and are linked together with significant commuting throughout the 5 counties. These counties have relatively high populations and population densities. Delaware County has the second highest NOx emissions in the areas of analysis and among the highest VOC emissions. Taking into

account the prevailing winds during the ozone season are predominantly from the south west, emissions from Chester and Delaware Counties likely contribute to downwind violations in Bucks and Philadelphia Counties durin g most of the ozone season. Considering all these factors, EPA has

concluded that Chester and Delaware Counties should be included in the Philadelphia Area.

In addition, monitors in Sussex County, Delaware and Berks County, Pennsylvania show violations o f the 2008 ozone NAAQS and must be designated nonattainment. We believe that Sussex County, Delaware and Berks County, Pennsylvania should be designated as in separate nonattainment areas, and explained below.

Berks County, Pennsylvania has a violating m onitor, but relatively moderate emissions, population, and VMT. There is some commuting from Berks County to the other counties in the Philadelphia Area, and Berks County is part of the Philadelphia

- Camden

- Vineland CSA. However, Berks County has

historic ally been a separate ozone and PM2.5 nonattainment area. The County’s MPO, the Berks County Planning Commission, is separate from the Philadelphia Area’s MPO, DVRPC. Furthermore, meteorology indicates that on typical summer days when the violating monito rs are experiencing exceedances of the ozone NAAQS, emissions from Berks County are not upwind of those monitors in the Philadelphia Area and thus we believe emissions from Berks County do not significantly contribute

to nonattainment at those monitors. T herefore, EPA has preliminarily concluded that Berks County

4 We discuss our conclusions as to the New Jersey counties in a Technical Analysis for the Philadelphia

- Wilmington

- Atlantic City Area sent to the State of New Jersey from EPA Region II.33

should not be included in the Philadelphia Area, and should be designated as nonattainment in a separate

area 5

.

Sussex County, Delaware has a monitor that is violating the 2008 ozone NAAQS. It h as moderate emissions and population in the area as compared with the other counties in the area of analysis. It is not part of the Philadelphia

- Camden

- Vineland CSA. Furthermore, c onsidering prevailing winds from

the southwest and the location of the hig hest violating monitors in the Philadelphia Area, it is not likely

that Sussex County is contributing significantly to the Philadelphia Area. Therefore, EPA has preliminarily concluded that Sussex County should not be included in the Philadelphia Area, an d should be designated as nonattainment in a separate area 6

.

Kent County, Delaware has a monitor that meets the 2008 8

- hour ozone NAAQS. This county has comparatively low emissions, population and VMT, and is not part of the Philadelphia

- Camden

Vineland CSA. Therefore, EPA has preliminarily concluded that Kent County should not be included in the Philadelphia Area, and should be designated as unclassifiable/attainment.

5 See E PA’s Technical Analysis for the Reading Area, sent to the Commonwealth of Pennsylvania by EPA Region III.

6 See EPA’s Technical Analysis for the Seaford Area, sent to the State of Delaware by EPA Region III.34

Technical A nalysis for the Pittsburgh

- Beaver Valley Area

Figure 1 is a map of the Pi ttsburgh

- Beaver Valley EPA intended nonattainment area

. T he map provides

other relevant information including the locations and design values of air quality monitors , county and other jurisdictional boundaries , CSA/CBSA boundary, existing nonattainment or maintenance boundary for 1997 ozone NAAQS, and EPA’s recommended boundaries.

Figure 1

For purposes of the 1997 8

- hour ozone NAAQS, the Pittsburgh

- Beaver Valley area was designated nonattainment. The boundary for the nonattainment area for the 1997 o zone NAAQS included the entire counties of Allegheny, Armstrong, Beaver, Butler, Fayette, Washington, and Westmoreland.

In March 2009, Pennsylvania recommended that the same counties be designated as “nonattainment” for the 2008 ozone NAAQS based on air quality data from 2006

- 2008. Pennsylvania provided an update to the original recommendation on November 22, 201 1 based on updated certified air quality data from

2009

- 2011. Pennsylvania’s 2011 updated recommendation also revised the recommendation to lim it the nonattainment area (for all areas in the Commonwealth) to only the county with the violating monitor. In the case of Pittsburgh, the Commonwealth recommends nonattainment for only Allegheny County, which continues to violate the 2008 ozone NAAQS ba sed on 2009

- 2011 preliminary monitoring data. The preliminary data for 2009

- 2011 shows that Armstrong County is no longer violating the 2008 NAAQS.35

Th is monitoring data is from Federal Reference Method (FRM) monitors or Federal Equivalent Method (FEM) m onitors sited and operated in accordance with 40 CFR Part 58 ( s ee the March 17, 2009 and November 22, 2011 letter s from the Pennsylvania Department of Environmental Pro tection to EPA.)

A fter considering these recommendations and b ased on EPA's technical analysis described below, EPA intends to designate seven counties in Pennsylvania (identified in Table 1 below) as “ nonattainment ” for

the 20 08 o zone NAAQS as part of the Pittsburgh

- Beaver Valley nonattainment area

.

Table 1. State's Recommended and EPA ’s Intended Designated Nonattainment Counties for Pittsburgh

Beaver Valley

. Pittsburgh

- Beaver Valley State

- Recommended

Nonattainment Counties EPA Intended

Nonattainment Counties Pennsylvania Allegheny Allegheny, Armstrong, Beaver Butler, Fayette, Washingt on, and

Westmoreland

Factor Assessment



### Factor 1: Air Quality Data

For this factor , we considered 8

- hour o zone design values (in parts per billion (ppb) ) for air quality

monitors in counties in the Pittsburgh

- New Castle area based on data for the 200 8

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with fully

- certified air quality data

. A

monitor’s DV is the metric or statistic that indicates whether that monitor attains a specified air quality

standard. The 2008 o z one NAAQS are met when the annual f ourth

- highest daily maximum 8

- hour average concentration, averaged over 3 years is 0.075 ppm or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P

. W here several monit ors are located in a county (or a designated nonattainment area or maintenance area ), the DV for the county or area is determined by the monitor with the highest level.

The 2010 and 2011 DVs for the o zone NAAQS for counties in the Pittsburgh

- New Castle CS A are shown in Table 2

. Pennsylvania submitted a letter to revise its nonattainment area recommendations based on updated certified monitoring data for the three

- year period 2009

- 2011. Based on the preliminary 2009

- 2011 monitoring data provided by Pennsy lvania in its November 2011 revised recommendation, two of the three monitors that violated based on 2008

- 2010 data are attaining the 2008 NAAQS (one of the monitors in Allegheny County and the monitor in Armstrong County)

Table 2. Air Quality Data

.

C ounty State

Recommended

Nonattainment? EPA

Recommended

Nonattainment? 2010 8

- hour Ozone DV (ppb) Preliminary 2011

8

- hour Ozone DV (ppb)
Allegheny, PA Yes Yes 81 79
Armstrong, PA No Yes 76 73

Beaver, PA No Yes 73 72

Butler, PA No Yes

-- -- Fayette, PA No Yes

-- -- Lawrence, PA No No 66 6636

Washington, PA No Yes 71 69

Westmoreland, PA No Yes 72 69

Note : Counties with no ozone monitor are identified with “

-- “ in the 2010 and 2011 8

- hour Ozone DV columns.

One monitor in Allegheny County and one monito r in Armstrong County show ed a violation of the 2008

o zone NAAQS based on 2008

- 2010 data. Pennsylvania updated its recommendations using 2009

- 2011 monitoring data via a letter to EPA dated November 22, 2011. Based on this more recent data, only the

Harri son monitor in Allegheny County shows a violation of the 2008 ozone NAAQS. T herefore Allegheny C ounty must be included in the nonattainment area. However, a county (or partial county) must also be designated nonattainment if it contributes to a violation in a nearby area. Each county without a violating monitor that is located nearby a county with a violating monitor has been evaluated based on the weight of evidence of the five factors and other relevant information to determine whether

it contributes t o the nearby violation

.



### Factor 2: Emissions and Emissions

- Related Data

EPA evaluated emissions of ozone precursors ( NO

x and VOC ) and other emissions

- related data that provide information on areas contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NO

x and VOC derived from the 200 8 National Emissions Inventory (NEI), version 1.5

. This is the most recently available NEI. (See http://www.ep a.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a nearby area indicate the potential for the area to contribute to observed violations. We will also consider any additional information we receive on changes to emissions levels tha t are not reflected in recent inventories. These changes include emissions reductions due to permanent and enforceable emissions controls that will be in place before final designations are issued and emissions increases due to new

sources.

Table 3 shows emissions of NO

x and VOC (given in tons per year) for violating and potentially contributing counties in the Pittsburgh

- New Castle CSA

.

Table 3. Total 2008 NO

x and VOC Emissions

County State

Recommended

Nonattainment? EPA

Recommended

Nonattainment? NO

x (tpy) VOC (tpy)
Allegheny, PA Yes Yes 52,399 37,506
Armstrong, PA No Yes 21,140 3,253

Beaver, PA No Yes 35,714 6,030

Butler, PA No Yes 7,789 7,856
Fayette, PA No Yes 4,639 6,149

Lawrence, PA No No 8,960 3,814
Washington, PA No Yes 14,304 7,256

Westmoreland, PA No Yes 14,827 13,54837

Allegheny County has the highest NOx and VOC emissions in the area. Beaver and Armstrong Counties NOx emissions are somewhat higher than the remaining count ies in the area, although Beaver County has fairly low VOC emissions. Westmoreland County has higher emissions than the remaining counties. Lawrence and Fayette Counties have relatively low emissions of NOx and VOC, by comparison to the other counties.

Population density and degree of urbanization

EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozone

- creating

emissions from mobile sources, such as on

- road and off

- road vehicles and engines, and area sources, such as consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial development are an indicator of area source an d mobile source NO

x and VOC emissions that may contribute to ozone formation. Rapid population or vehicle miles travelled ( VMT ) growth (see below) in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the associated area source and mobile source emissions may be appropriate to include in the nonattainment area. Table 4 shows the population, population density, and population growth information for each county in the area.

Table 4. Population and G rowth

.

County State

Recommended

Nonattainment? EPA

Recommended

Nonattainment? 2010

Population 2010

Population Density (1000 pop /sq mi) Absolute

change in population (2000

- 2010) Population

% change (2000

- 2010)
Allegheny, PA Yes Yes 1,223,348 1.64 (56,566 )

- 4%
Armstrong, PA No Yes 68,941 0.10 (3,374)

- 5%

Beaver, PA No Yes 170,539 0.38 (10,576)

- 6%
Butler, PA No Yes 183,862 0.23 9,343 +5%
Fayette, PA No Yes 136,606 0.17 (11,908)

- 8%

Lawrence, PA No No 91,108 0.25 (3,514)

- 4%
Washingto n, PA No Yes 207,820 0.24 4,873 +2%

Westmoreland, PA No Yes 365,169 0.35 (4,521)

- 1%
Sources: U.S. Census Bureau population estimates for 2010 as of August 4, 2011 ( http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTPL2.STO5&prodType

=table ) and U.S. Census Bureau GIS files for the county boundaries

Allegheny County has by far the largest overall 2010 population (and population density), with its population nearly totaling the combined population of the other seven counties in the CSA. All of the counties are relatively sparsely populated in comparison to Allegheny County, with Armstrong, Fayette, Butler, Washington, and Lawrence being the most sparsely populated (having population densities of less than 250 persons per square mile). In terms of population change, only Butler and Washington Counties have exhibited any popul ation growth since 2000, with all remaining area counties exhibiting declining population.38

T raffic and VMT data

EPA evaluated the total Vehicle Miles Traveled (VMT) for each county , as well as VMT growth. In combination with the population/population d ensity data and the location of main transportation arteries (see above), this information helps identify the probable location of non

- point source emissions. A county with high VMT and/or a high num b er of commuters is generally an integral part of an urba n area and indicates the presence of motor vehicle emissions that may contribute to ozone formation. Rapid population or VMT growth in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the associ ated area source and mobile source emissions may be appropriate to include in the nonattainment area. Table 5 shows total 2008 VMT and 2002

- 2008 VMT growth for each county.

Table 5. Traffic and Commuting P atterns

County EPA Recommended

Nonattainment ? 2008 VMT (million miles) Percent VMT Growth (2002

- 2008)
Allegheny, PA Yes 9,227

- 0.6

Armstrong, PA Yes 621

- 1.0

Beaver, PA Yes 1,434

- 2.6

Butler, PA Yes 1,747 2.8

Fayette, PA Yes 1,062 5.7

Lawrence, PA No 781

- 0.6

Washington, PA Yes 2,114

- 7.2

We stmoreland, PA Yes 3,430

- 4.4
* MOBILE model VMTs are those inputs into the NEI version 1.5.

Table 6. County to County Worker Flow

Residence County Allegheny Armstrong Beaver Butler Fayette Washington Westmoreland Lawrence

Workplace County

Allegheny 536,655 4,582 23,946 21,403 5,151 27,645 43,536 2,043

Armstrong 635 16,279 14 1,013 25 22 2,197 12

Beaver 5,235 106 47,074 1,372 136 556 561 2,717

Butler 7,868 2,609 4,885 51,572 168 370 1,231 2,366

Fayette 732 12 28 35 35,915 1,317 2,39 1 25

Washington 9,211 68 467 267 25 53,268 3,473 53

Westmoreland 12,049 2,719 291 831 3,051 2,718 106,01 5 103

Lawrence 736 44 2,003 1013 8,985 69 165 27,536

Source: U.S. Census Bureau estimates fo r 2000 County

- to

- County Worker Flow (http://www.census.gov/hhes/commuting/data/commuting.html

Allegheny County has by far the highest VMT, totaling nearly the combined VMT of the next five highest counties VMT. Allegheny County also has by far the lar gest number of commuters travelling to or within violating counties, as of 2008. Fayette and Butler are the only counties in the area with appreciable VMT growth. Table 6 depicts commuter flow within and between the respective counties.39

It is clear from Table 6 that Allegheny County draws the greatest number of commuters from all counties, but also that most of the counties have at least some contribution to each other. Lawrence County is a notable exception, as very few commuters travel to Allegheny Co unty, or to any county in the Pittsburgh MSA.

Figure 2 is a map depicting the arterial highway network for the Pittsburgh CSA. Figure 3 depicts the key interstate and arterial highways, focusing on Allegheny County, where the preponderance of the

total a rea VMT and commuter traffic flow.

Figure 2

Figures 2 and 3 depict the arterial highway network for Pittsburgh, with figure 3 focusing on Allegheny County and the City of Pittsburgh downtown area . The main interstates for the region are: Interstate 37 6 (the main east

- west route), Interstate 279 (the main north

- south artery extending from downtown Pittsburgh north to meet with I

- 79), and Interstate 579 ( a short freeway spur from Interstate 279 south )

. I

- 79 skirts the Pittsburgh downtown district to the west (passing north

- south through Butler, Allegheny, and Washington Counties before leaving Pittsburgh to West Virginia). The Pennsylvania Turnpike (Interstate 76) skirts the Pittsburgh downtown district to the North and East (passing through

Westmoreland , Allegheny, Beaver, and Lawrence Counties before passing into Ohio).

With most of these interstates looping outside the Pittsburgh downtown, Pittsburgh relies on an inner beltway system of smaller highways within Allegheny County. Figure 4 depicts the Be ltway system of

six color

- coded loops surround the City of Pittsburgh and link the city and surrounding communities, highways, and airports.40

Figure 3

Source: AA Roads (www.aaroads.com)

Figure 4

Source: Highway Route Markers of the United States (ww w.routemarkers.com)

From Table 5, it is clear that much of the total commuting for the area consists of Allegheny commuters commuting within Allegheny County. The commuting totals from the remaining counties are much smaller in comparison (in spite of s ome of the large percentages of commuters), due to their lower VMT41

totals and lower population densities. The high percentage of commuters in Armstrong County traveling to a county with a violating monitor is a function of that county having been in viola tion of the 2008 ozone NAAQS prior to the 2009

- 2011 period. It is clear that the remaining Pittsburgh CSA counties have lower total commuters and smaller total VMT, and likely have a higher proportion of their VMT associated with the regional interstate h ighway network depicted in Figures 2 and 3 (although some of those may be regional commuters that are moving to the inner ring highways depicted in Figure 4).

Of all the CSA counties, Lawrence and Armstrong have the lowest overall 2008 VMT, and Lawrence

h as the lowest number of commuters to a violating county, based on 2008 data.



### Factor 3: Meteorology (weather/transport patterns)

EPA evaluate d any available meteorological data to help determine how meteorological conditions, such as weather, transp ort patterns and stagnation conditions, would affect the fate and transport of precursor emissions contributing to ozone formation.

The highest ozone design value for the period 2008

- 2010 is 81 ppb in Allegheny County, followed by 76 ppb in Armstrong Cou nty. For the period 2009

- 2011, the highest ozone design value was 79 ppb in Allegheny County. The prevailing winds during the ozone season have strong westerly and southwesterly component s

. This indicates the potential contribution to violations from we stern Counties in the CSA and potentially from transport from areas in Ohio and West Virginia. However, a number of monitors in counties on both sides of the Pennsylvania

- Ohio and Pennsylvania

- West Virginia border are currently measuring attainment of the ozone standard.

Further analysis of backward trajectories could prove helpful in resolving the affect of meteorology on this area. Pennsylvania’s March 2009 ozone recommendation did contain some NOAA HYSPLIT model backward trajectory information, b ut not for monitors in the Pittsburgh area. The supplied information for a monitor in eastern Pennsylvania indicated that HYSPLIT 24

- hour period back trajectories were highly variable based upon the episode in question. Therefore, this information was

no t useful in determining the impact of meteorology on the Pittsburgh

- New Castle CSA.



### Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might affect the airshed and, therefore, the distribution of ozone over the area

.

Pittsburgh lies on the Appalachian Plateau extending westward from the Allegheny Front, which is an escarpment that makes the western part of Pennsylvania higher than the eastern p art of the Commonwealth. The City of Pittsburgh itself is defined by the river valleys of the Allegheny, the Monongahela, and the Ohio.

Elevations in the Pittsburgh region range from around 700 feet above sea level where the rivers meet, to
1,200 to 1,30 0 feet at the highest points, with dramatic hills and valleys often separating neighborhoods and communities. The highest land is at the prevailing level of the Appalachian Plateau, with the river valleys forming the low points, and varying slopes connect ing it together.42

Figure 5

Source: US Geologic Society, National Historic Map, Eastern United States

While this topography may not form a geographic or topographic barrier significantly limiting air pollution within the airshed, the topography may impa ct weather patterns in the area, result in atmospheric inversions or other conditions that affect local emissions transport or monitored ozone levels. Pennsylvania did not submit data as part of its recommendation indicating that topography plays a signif icant role in distribution of ozone across the Pittsburgh

- Beaver Valley area.



### Factor 5: Jurisdictional boundaries

Once the general areas to be included in the nonattainment area were determined, EPA consider ed existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and carrying out the air quality planning and enforcement functions for nonattainment areas. Examples of jurisdictional boundaries include existing/prior nonattainment areas for ozone or other urban

- scale pollutants, counties, air districts, townships, metropolitan planning organizations, state lines, Reservations, urban growth boundary, etc. Where existing jurisdictional boundaries are not adequate to describe the nonattainment area, other clearly d efined and permanent landmarks or geographic

c oordinates were considered.43

The Pittsburgh

- Beaver Valley area has previously established nonattainment boundaries associated with

both the 1

- hour and 1997 8

- hour ozone N AAQS. In its March 2009 recommendation to EPA, the Commonwealth recommended the same nonattainment area boundary for the 2008 ozone NAAQS. However, in a letter sent to EPA on November 22, 2011, Pennsylvania revised its recommendation to include as nonattainment only those counties having monit ored violations of the 2008 ozone standard. In the case of the Pittsburgh

- Beaver Valley area, Pennsylvania is now recommending that only Allegheny County be designated as nonattainment.

EPA relied on the Pittsburgh

- New Castle CSA as its analytical sta rting point for determining nonattainment area boundaries. The Pittsburgh

- New Castle CSA includes the 7

- county Pittsburgh Metropolitan Statistical Area, as well as the one

- county New Castle Micropolitan Statistical Area (comprised of Lawrence County).

Figure 6

As Pennsylvania indicated in its March 2009 recommendation to EPA, the counties in the Pittsburgh Metropolitan Statistical Area are part of one single transportation

- planning agency as designated by the U.S. Department of Transportation (U.S. D OT) based on economic and commuting patterns. Retaining the existing boundary for this nonattainment area will allow the area to benefit from continuity of planning for the 1997 8

- hour standard. Also, the 1997 Pittsburgh ozone nonattainment area has two

e mission control programs that pertain only to this area and not to surrounding counties: a requirement for cleaner gasoline during the ozone season and a requirement for gasoline pumps to control fumes when vehicles are refueling. Finally, the recommended nonattainment area includes three air basins (as defined in 25 Pa.Code § 121.1): the Lower Beaver Valley Air Basin, the Allegheny County Air Basin and the Monongahela Valley Air Basin. These basins were developed for purposes of the sulfur compound contro ls outlined in 25 Pa. Code § 123.22, yet they represent existing44

local boundaries for emission controls in the areas of the Commonwealth where they exist.

In November 2011, Pennsylvania submitted a revised recommendation letter to EPA to alter its March 2009 recommendation to reflect only the county violating the 2008 ozone NAAQS (i.e. Allegheny County), dismissing its jurisdiction

- based arguments set forth in the Commonwealth’s prior March 2009

recommendation.

Pennsylvania did not recommend inclusion of Lawrence County in its March 2009 or November 2011

area recommendation letters to EPA. The Commonwealth’s rationale in the March 2009 letter was that

Lawrence C ounty has a monitor that is monitoring well below the 2008 ozone NAAQS, that the area has

t raditionally been a stand

- alone planning area, and that the county’s micropolitan statistical area status indicates a lower level of social and economic ties to the Pittsburgh metropolitan area counties than counties within the Pittsburgh metropolitan stat istical area.



### Conclusion

Based on the assessment of factors described above, EPA has preliminarily concluded that the following counties meet the CAA criteria for inclusion in the Pittsburgh

- Beaver Valley nonattainment area: Allegheny, Armstrong, Beave r, Butler, Fayette, Washington, and Westmoreland

On the basis of the factor discussion above, there is cause to extend the nonattainment boundary beyond the county having a violating monitor, i.e., Allegheny County. With respect to emissions and emission s

related data, Armstrong, Beaver, Washington, and Westmoreland Counties have relatively high emissions. Although the area is facing low to negative population growth (with the exception of Butler and Washington Counties) and many of the counties are spar sely populated, Washington, Westmoreland, Beaver, Butler, and Fayette Counties continue to have populations over 100,000 persons. Westmoreland, Washington, Beaver, and Butler Counties have high VMT, even relative to more densely populated Allegheny Count y.

With respect to jurisdictional boundaries, it is clear that the counties in the Pittsburgh Metropolitan Statistical Area are socially and economically intertwined. The Pittsburgh metropolitan area counties utilize a single transportation

- planning ag ency, and have emission control programs unique from neighboring counties and metropolitan areas. Historically, this Pittsburgh metropolitan area has been the ozone nonattainment boundary.

Based on this factor assessment, EPA contends that the Pittsbur gh Metropolitan Statistical Area be the boundary for the 2008 nonattainment area, as it was for the 1997 ozone NAAQS nonattainment area.

Based on the most recent 2009

- 2011 monitoring data, Allegheny County is the only county monitoring a

violation of the 2008 NAAQS, and under the Clean Air Act must be designated nonattainment. However, we disagree with Pennsylvania’s recommendation to exclude the remaining Pittsburgh area counties from the nonattainment area and believe the nearby counties in the Pittsbu rgh Metropolitan Statistical Area contribute to nonattainment of the 2008 ozone NAAQS. Therefore, these nearby counties must also be designated nonattainment. EPA agrees with Pennsylvania that there is sufficient

evidence on the basis of the above factor assessment to exclude Lawrence County from the EPA intended nonattainment area. Therefore, EPA recommends that the intended nonattainment area for 2008 ozone NAAQS for the Pittsburgh

- Beaver Valley area be the same as the 7

- county nonattainment

area bound ary under the prior 1997 ozone NAAQS.45

Technical A nalysis for the Reading Area

Figure 1 is a map of the Reading intended nonattainment area , Berks County, Pennsylvania . The map provides other relevant information including the locations and design values of air quality monitors, major transportation arteries, and cou nty and other jurisdictional boundaries . This map shows the

former Reading nonattainment area for the 1997 ozone NAAQS

, now a maintenance area, which

consists of Berks County , Pennsylvania. It also shows the Philadelphia

- Camden

- Vineland CSA.

Figure 1

.

For purposes of the 1997 8

- hour ozone NAAQS

, th e Reading Area was designated nonattainment. The boundary for the nonatt ainment area for the 1997 o zone NAAQS included the entire count y of Berks in Pennsylvania

.

In March 2009, the Commonwealth of Pennsylvania recommended that the same count y , Berks

, be designated as nonattainment in the Reading Area for the 2008 ozone NAAQS based on air quality data

from 2006

- 2008. Pennsylvania provided an update to the original recommendation in November 2011

based on air quality data f rom 2009

- 2011. That recommendation update did not make any modification to the Reading area boundar y

. The recommendations are based on data from Federal Reference Method (FRM) monitors or Federal Equivalent Method (FEM) monitors sited and operated in a ccordance with

40 CFR Part 58

. (See the March 17, 2009 and November 22, 2011 letter s from the Pennsylvania Department of Environmental Pro tecti on to EPA.)46

Af ter considering these recommendations and b ased on EPA's technical analysis described below, EPA intends to designate Berks County, Pennsy lvania as “ nonattainment ” for the 20 08 o zone NAAQS as the Reading nonattainment area

.

Table 1 . State's Recommended and EPA ’s Intended Designated Nonattainment Counties for Reading

Area.

Reading State

- Recommended

Nonattainment Counties EPA Intended

Nonattainm ent Counties Pennsylvania Berks Berks

Factor Assessment

EPA has determined that it is appropriate to include Bucks, Chester, Montgomery, Lancaster, and Lehigh Counties in other separate nonattainment areas for the 2008 ozone NAAQS. Based on EPA’s

five

- factor analyses, EPA has preliminary; determined that Bucks, Chester, and Montgomery Counties should be designated as nonattainm ent in the Philadelphia

- Wilmington

- Atlantic City Area, Lancaster County should be designated as nonattainment in the Lancaster Area, and Lehigh County should be designated nonattainment as part of the Allentown

- Bethlehem

- Easton Area. See EPA’s respective technical analyses for these adjacent nonattainment areas for EPA’s rationale for our intended nonattainment designation for these counties. To the extent that emissions from the Bucks, Chester, Montgomery, Lancaster, and Lehigh Counties may contribute oz one concentrations in the Reading nonattainment area, that contribution will be lessened by emission controls put in place in those separate

nonattainment areas

. Therefore, EPA is not including Bucks, Chester, Montgomery, Lancaster, and Lehigh Counties in this analysis for the Reading nonattainment area.



### Factor 1: Air Quality Data

For this factor , we considered 8

- hour o zone design values (in parts per billion ( pp b ) ) for air quality

monitors in counties in the Reading area based on dat a for the 2008

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with fully

- certified air quality data

. A monitor’s DV is

the metric or statistic that indicates whether that monitor attains a specified air quality standard. The

2008 o zone NAAQS are met when the annual f ourth

- highest daily maximum 8

- hour average concentration, averaged over 3 years is 0.075 ppm or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where several monitors are located in a county (or a designated nonattainment area or maintenance area ), the DV for the county or area is determined by the monitor with the highest DV

.

Note: Monitors that are eligible for providing design value data genera lly include State and Local Air Monitoring Stations (SLAMS) that are sited in accordance with 40 CFR Part 58, Appendix D (Section 4.1) and operating with a federal reference method (FRM) or federal equivalent method (FEM) monitor that meets the requirement s of 40 CFR part 58, appendix A. All data from a special purpose monitor (SPM) using an FRM or FEM which has operated for more than 24 months is eligible for comparison to the NAAQS unless the monitoring agency demonstrates that the data came from a partic ular period during which the requirements of appendix A (quality assurance requirements) or appendix E (probe and monitoring path siting criteria) were not met.47

The 2010 DVs for the ozone NAAQS for Berks County and nearby surrounding counties are shown in

Table 2

.

Table 2 . Air Quality Data

. County State Recommended

Nonattainment? 2008

- 2010 Design Value (ppb)

Berks , PA Yes 79

Lebanon , PA No

-- Sch uylkill , PA No

-- Note: Counties with no ozone monitor are identified with “

-- “ in the 2010 8

- hour Ozone DV column

.

In accordance with section 107(d) of the Clean Air Act, EPA must designate an area nonattainment if it is violating the 2008 ozone NAAQS. Berks County show s a violation of the 2008 o zone NAAQS

, t herefore this county must be included in a nonattainment area. Note that the absence of a violating

monitor is not a sufficient reason to el iminate nearby counties as candidates for nonattainment status based upon contribution to violations in other nearby areas . Each county is be i n g evaluated based on the weight o f evidence of the five factors.



### Factor 2: Emissions and Emissions

- Related Data

EPA evaluated emissions of ozone precursors ( NO

x and VOC ) and other emissions

- related data that provide information on areas po tentially contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NO

x and VOC derived from the 200 8 National Emissions Inventory (NEI), version 1.5

. This is the most recently available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a nearby area indicate the potential for the area to contribute to observed violations

. We will also consider any

additi onal information we receive on changes to emissions levels that are not reflected in recent inventories. These changes include emissions reductions due to permanent and enforceable emissions controls that will be in place before final designations are iss ued and emissions increases due to new

sources.

Table 3 shows emissions of NO

x and VOC (given in tons per year) potentially contributing counties in

the Reading A rea.

Table 3. Total 2008 NO

x and VOC Emissions.

County State Recommended

Nonatt ainment? NO

x (tpy) VOC (tpy)

Berks , PA Yes 18,908 15,918

Lebanon , PA No 6,166 5,367 Schuylkill , PA No 6,554 5,922

Berks County has the h ighest NOx and VOC emissions in the area of analysis. In fact, the emissions from Berks County are nearly three times h igher than the emissions in Lebanon and Schuylkill Counties

. This indicates that emissions from Lebanon and Schuylkill Counties are not likely to contribut e to ozone
violation s in Berks County

.48

Population density and degree of urbanization

EPA evaluated the population and vehicl e use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozone

- creating

emissions from on

- road and off

- road vehicles and engines, consumer products, residential fuel

com bustion, and consumer services. Areas of dense population or commercial development are an indicator of area source and mobile source NO

x and VOC emissions that may contribute to ozone

formation. Table 4 shows the population, population densi ty, and population growth information for each county in the area of analysis

.

Table 4 . Population and Growth.

County State

Recommended

Nonattainment? 20 10 Population 20 10 Population Density (1000 pop/sq mi) Absolute change

in population (2000

- 2010) Popu lation %

change (2000

- 20 10 ) Berks, PA Yes 411,442 0.48 36,945 +10%
Lebanon, PA No 133,568 0.37 13,151 +11% Schuylkill, PA No 148,289 0.19

- 1,798

- 1.2% Sources: U.S. Census Bureau population estimates for 2010 as of August 4, 2011 ( http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTP L2.STO5&prodType=table )

.

Berks County has the highest population in the area of analysis. In fact, the population in Berks County

is nearly three times h igher than the populations of Lebanon and Schuylkill Counties . This indicates

that non

- point source emissions from Lebanon or Schuylkill Counties a re not likely to contribut e to

ozone violation s in Berks County

.

Traffic and commuting patterns

EPA evaluated the commuting patt erns of residents in the area, as well as the total Vehicle Miles Traveled (VMT) for each county . In combination with the population/population density data and the location of main transportation arteries (see Figure 1, above), this information helps ide ntify the probable location of non

- point source emissions. A county with high VMT and/or a high num b er of commuters is generally an integral part of an urban area and indicates the presence of motor vehicle emissions that may contribute to ozone formation

. Rapid population or VMT growth in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the

associated area source and mobile source emissions may be appropriate to include in the nonattainment

ar ea. Table 5 shows the total vehicle miles traveled (VMT) for each county in 2008

.

Table 5 . Traffic (VMT) Data

.. County State Recommended

Nonattainment? 200 8 VMT * (million miles)

Berks , PA Yes 3,335

Lebanon , PA No 1,210 Schuylkill , PA No 1,394 * MOBILE model VMTs are those inputs into the NEI version 1.5.

VMT in Berks County is more than twice as high as VMT in Lebanon and Schuylkill Counties.
However, as s hown in Table 6, below, Lebanon and Schuylkill Counties do have commuters into Berks County. Therefore, there is come contribution of VMT and mobile source emissions from Lebanon and Schuylkill Counties to Berks County.49

Table 6

. County to County Worker Flow

. Residence County Berks, PA Lebanon, PA Schuylkill , PA

Workplace County

Berks , PA 140,819 2,799 5,790

Lebanon , PA 2

, 053 36,677 1,482

Schuylkill , PA 619 188 43,979

Source: US Census Bureau County

- To

- County Worker Flow Files http://www.census.gov/population/www/cen2000/commuting/index.html



### Factor 3: Meteorology (weather/transport patterns)

EPA evaluate d available meteorological data , consisting of 30

- year average s ummertime w ind d irections

from the National Weather Service

, to help determine how meteorological conditions, such as weather,

transport p atterns and stagnation conditions, would affect the fate and transport of precursor emissions

c ontributing to ozone formation.

In the summertime, the predominant winds in Berks County come from the west, with the largest components from the west

- southwest (20%) and west

- northwest (20%). There is also a high frequency

of winds from the south

- southwest (15%). As shown in Figure 2, below, this indicates that Lebanon County is upwind of the violating monitor in Berks County. Therefore, emissions from Lebano n County likely contribute to ozone concentrations in Berks County. However, since emissions in Lebanon County are relatively low, the contribution to ozone concentrations in Berks County is also relatively

low.

Figure 2. 30

- Year Average Summertime Wind Directions in Berks County, Pennsylvania50 

### Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis evaluates the physical features of the land that might affect t he airshed and, therefore, the distribution of ozone over the area

.

The Reading area does not have any geographical or topographical barriers significantly limitin g air pollution transport within its air shed. Therefore, there are no barriers to contribution from upwind

areas.



### Factor 5: Jurisdictional boundaries

EPA consider s existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and carrying out the air quality planning and enforcement functions for nonatt ainment areas. Examples of jurisdictional boundaries include existing/prior nonattainment areas for ozone or other

urban

- scale pollutants, counties, air districts, townships, metropolitan planning organizations, state lines, Reservations, urban growth bou ndary, etc. Where existing jurisdictional boundaries are not adequate to describe the nonattainment area, other clearly defined and permanent landmarks or geographic

c oordinates are used

.

The three counties in the area of analysis are in t he same state, but otherwise are not connected jurisdictionally. They are served by different metropolitan planning organizations (MPOs); the Berks County Planning Commission, the Lebanon County MPO, and the Schuylkill County Planning and Zoning Commissio n . They are historically in separate nonattainment areas for ozone and fine particulate matter (PM 2.5 ). Finally, they are in separate statistical areas, as defined by the US Census

Bureau.

The Reading area has a previously

- established nonattainment boundary associated with the 1997 8

- hour

ozone N AAQS, which is the single county of Berks. Pennsylvania has recommended the same boundary for the 2008 ozone NAAQS. The Rea ding area for the 1997 PM 2.5 .NAAQS also consists of the single county of Berks. Lebanon and Schuylkill Counties have historically been included in nonattainment areas other than the Reading area for ozone and/or PM 2.5 . Lebanon County is part of the

Harri sburg area for ozone (1

- hour and 8

- hour) and PM 2.5

. Schuylkill County was a single

- county
nonattainment area for the 1

- hour ozone NAAQS, and was designated attainment/unclassifiable for the

1997 8

- hour NAAQS and PM 2.5

.

According to the Office of Manageme nt and Budget’s “ Standards for Defining Metropolitan and Micropolitan Statistical Areas,” published in the Federal Register on December 27, 2000 (65 FR 82228)

, the “ general concept of a Metropolitan Statistical Area or a Micropolitan Statistical Area is th at of an area containing a recognized population nucleus and adjacent communities that have a high degree of integration with that nucleus. ” Being part of a statistical area indicates that counties are linked through employment and commuting. Conversely, being in separate statistical areas implies little

interconnection. As stated above, Berks, Lebanon, and Schuylkill Counties are in separate statistical

areas. Lebanon County makes up the Lebanon MSA, which is part of the Harrisburg

- Carlisle

- Lebanon,

CS A. Schu y l kill County makes up the Pottsville Micropolitan Statistical Area

. Berks County makes up the Reading MSA, which is part of the Philadelphia

- Camden

- Vineland CSA. However, EPA’s51

preliminary recommendation is to not include Berks County in the Phi ladelphia

- Wilmington

- Atlantic City Area for the 2008 ozone NAAQS, as supported by EPA’s five

- factor analysis for that area 7

.



### Conclusion

Based on the assessment of factors described above, EPA has preliminarily concluded that the following

counties meet the CAA criteria for inclusion in the Reading nonattainment area: Berks County. This is the same county that was included in the Reading nonattainment area for the 1997 ozone NAAQS (now the Reading maintenance area). An air quality monitor in Berks Coun ty is violating the 2008 ozone NAAQS based on the 2010 DV , therefore this county must be included in a nonattainment area . EPA has preliminary concluded that Berks County should be included in the Reading Area.

EPA has concluded that the other counties i n this analysis, Lebanon and Schuylkill Counties, do not contribute to ozone violations in Berks County. These counties do not have ozone monitors

. These counties have relatively low emissions, populations, and VMT. Dominant ozone season winds in Berks County come from the west and west

- southwest. Therefore, Lebanon County is upwind of the violating monitor in Berks County. However, since emissions in Lebanon County are relatively low, the contribution to ozone concentrations in Berks County from upwin d emissions in Lebanon County is also relatively low. Furthermore, Lebanon and Schuylkill Counties are not linked jurisdictionally to the Reading area. They are served by different MPOs and they are in separate statistical areas. Therefore,

Lebanon and Schuylkill Counties should not be included in the Reading nonattainment area.

7 See EPA’s Technical Analysis for the Philadelp hia

- Wilmington

- Atlantic City nonattainment area.