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Table of Contents 

Guidance Document: 11/18/2002, Lydia Wegman and Peter Tsirigotis, “2002 Base Year 

Emissions Inventory SIP Planning: 8-Hr Ozone, PM2.5 and Regional Haze Programs” .....1 

Guidance Document: 4/3/2003, Jeffrey R. Holmstead, “Designations for the Fine Particulate 

National Ambient Air Quality Standards” ...........................................................................7

Guidance Document: 2/13/2004, Lydia N. Wegman, “Additional Guidance On Defining Area 

Boundaries for PM-2.5 Designations” ...............................................................................20

Letter: 2/17/2004, William G. Ross, Jr., North Carolina’s recommendations for PM2.5

nonattainment designations ................................................................................................22 

Letter: 6/21/2004, William G. Ross, Jr., Letter to Administrator Leavitt expressing concern to 

USEPA changing methodology for setting nonattainment boundaries .............................25 

Letter: 6/29/2004, J. I. Palmer, Jr., The USEPA’s comments to North Carolina’s 2/17/2004 

recommendations for PM2.5 nonattaiment designations ....................................................27 

Letter: 9/8/2004, William G. Ross, Jr., Response to the USEPA’s 6/29/2004 letter .....................46 

Letter: 9/9/2004, Governor Michael F. Easley, Response to the USEPA’s 6/29/2004 letter ........50 

Guidance Document: 12/14/2004, Stephen D. Page, “Clean Data Policy for the Fine Particulate 

National Ambient Air Quality Standards” .........................................................................52 

Letter: 12/17/2004, Administrator Michael O. Leavitt, The USEPA PM2.5 nonattainment 

boundaries designation.......................................................................................................58

Letter: 2/22/2005, William G. Ross, Jr., Request to designate Guilford County as attainment for 

PM2.5 based on 12/14/2004 clean data policy ....................................................................61 

Letter: 12/5/2005, Stephen L. Johnson, Response to William G. Ross, Jr. 2/22/2005 letter .........64 

Guidance Document: 10/2/2007, William T. Harnett, “ Guidance on SIP Elements Required 

Under Sections 110(a)(1) and (2) for the 1997 8-hour Ozone and PM2.5 National Ambient 

Air Quality Standards” ......................................................................................................68 
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1

 Memorandum from Jeffrey R. Holmstead, Assistant Administrator, to EPA Regional

Administrators, “Designations for the Fine Particle National Ambient Air Quality Standards,”

April 1, 2003.

2

 A list of the 2003 OMB metropolitan area definitions and associated information may

be found at: http://www.census.gov/population/www/estimates/metroarea.html.

MEMORANDUM

SUBJECT: Additional Guidance On Defining Area Boundaries for PM-2.5 Designations

FROM: Lydia N. Wegman, Director

Air Quality Strategies and Standards Division (C504-01) 

TO: Air Division Directors, Regions I-X

This memorandum provides additional guidance for determining boundaries of PM-2.5

areas in the PM-2.5 designations process. Our April 2003 boundary guidance establishes the

metropolitan area (i.e. the larger of the Consolidated Metropolitan Statistical Area (CMSA) or

Metropolitan Statistical Area (MSA)) as the presumptive boundary for PM-2.5 nonattainment

areas1

. The boundaries of CMSAs and MSAs, which were delineated by the Office of

Management and Budget (OMB) in 1999, include populated areas associated with core urban

areas. Our April 2003 guidance recognized that OMB planned to publish revised urban area

definitions sometime in 2003, but, because the specific release date was not known at that time,

the guidance stated that the Environmental Protection Agency (EPA) anticipated using the 1999

definitions for the PM-2.5 designation process. 

OMB subsequently issued revised urban area definitions on June 6, 2003. The

definitions established core-based statistical areas (CBSAs) (or CBSAs, comprised of

“metropolitan” and “micropolitan” areas), and combined statistical areas (CSAs) (or CSAs,

comprised of two or more core-based statistical areas)2. While we are not requiring States and

Tribes to use the recently-defined CSA and CBSA as the presumptive boundaries for

determining PM-2.5 nonattainment areas, we ask that in your review of State and Tribal

recommendations that you assess all counties included in any relevant CSA or CBSA under the

2003 definitions, as well as 

any adjacent counties, using the 9 factors identified in the April 1, 2003 guidance. We believe

this approach is appropriate because the new OMB definitions group together counties having a

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3

 The Consolidated Appropriations Bill for FY-2004 (Public Law 108-199), signed by

the President on January 23, 2004, codifies the dates for State recommendations and final EPA

action on PM-2.5 designations.

high degree of social and economic integration with a central core area, reflecting the latest

technical information available about significant growth and commuting rates. While EPA is not

requiring that States use the 2003 OMB boundary definitions as the presumptive boundaries,

please ask that your respective States and Tribes fully document the basis for their

recommendations, using the 9 factors identified in the April 2003 guidance.

All other information contained in the April boundary guidance continues to apply, and

States and Tribes should continue to follow the guidance in making the boundary

recommendations by February 15, 2004, as required in our guidance and the Consolidated

Appropriations Bill for FY-2004.3

 In addition, as we requested in the April 2003 guidance we

encourage States and Tribes to make every effort to process the 4th quarter 2003 air quality data

as quickly as possible so it can be taken into account in the February recommendations. Also, 

stated in the April 2003 guidance, EPA will make available on our website information

submitted in connection with designation recommendations. Therefore, we request that each

State and Tribe submit to EPA its designation recommendations, description of the proposed

area boundaries, associated maps, and other supporting documentation in electronic format as

well as in a hard-copy format. 

The Regional Offices should share this additional guidance with States and Tribes and

work closely with them to resolve any issues related to the submittal of their area

recommendations and supporting information. Staff in OAQPS are available to provide

assistance and consultation throughout the designation process. Questions related to this

memorandum may be directed to Larry Wallace of my staff at 919-541-0906 or Rich Damberg at

919-541-5592.

cc: Stephen D. Page, OAQPS

Margo Oge, OTAQ

Joe Paisie, OAQPS

Kevin McLean, OGC

Geoffrey Wilcox, OGC

Air Program Managers, Regions I-X

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STATE OF NORTH CAROLINA

OFFICE OF THE GOVERNOR

20301 MAIL SERVICE CENTER

RALEIGH, NC 27699-0301

MICHAEL F. EASLEY

GOVERNOR

September 9, 2004

The Honorable Michael Leavitt 

Administrator

US Environmental Protection Agency

1200 Pennsylvania Ave., N.W.

Washington, D.C. 20460

Dear Administrator Leavitt:

I am writing concerning your agency’s response to North Carolina’s PM 2.5 nonattainment boundary recommendations. As you know, North Carolina has been a leader among 

states in improving air quality through aggressive programs to cut emissions from both coal-fired 

power plants and mobile sources. No state in America is more committed to solving the 

problems posed by particulate emissions and other harmful pollutants. But we are committed to 

doing so wisely, in a manner that does not unnecessarily harm our state’s favorable business 

climate. 

In its letter of June 29, 2004, EPA has provided flawed analysis to support far-reaching 

PM 2.5 nonattainment designations surrounding two isolated, non-attaining monitors in Hickory 

and Lexington, North Carolina. According to North Carolina’s analysis, which is included in 

the attached letter from Secretary of Environment Bill Ross, these broad designations will not 

help solve the non-attainment problem at these two monitors. In fact, they are unlikely to have 

an appreciable effect on North Carolina’s efforts to improve air quality. 

These excessive non-attainment designations will, however, have a significant 

dampening effect on economic development efforts in the Triad and further west in the 

Hickory/Morganton/Lenoir area. These two areas of our state have been hit particularly hard by 

manufacturing job losses associated with unfair federal trade policies. Both areas are turning a 

corner now, but they can ill afford non-attainment designations that can undermine their ability 

to bring jobs to their communities – particularly when there is no beneficial effect. 

 

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September 9, 2004

With this in mind, I urge you to narrow your non-attainment designation to Davidson 

County and the MPO portion of Catawba County surrounding the Hickory monitor. Thank you 

for your attention to this request. If there is anything that my office can do to assist you in your 

decisionmaking process in the coming months, I trust that you will let me know. 

With kindest regards, I remain

Very truly yours,

Michael F. Easley

MFE: rht

cc: North Carolina Congressional Delegation

James I. Palmer, Regional Administrator, US EPA 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460 

December 17, 2004 

THE ADMINISTRATOR

The Honorable Michael Easley 

Governor, State of North Carolina 

20301 Mail Service Center 

Raleigh NC 27699-0301 

Dear Governor Easley: 

Thirty-four years ago this month, the first Clean Air Act signaled the beginning of our 

country’s resolve to dramatically improve air quality. Today, we celebrate our accomplishments 

which have enabled us to breathe the cleanest air we have ever measured. As 2004 comes to a 

close, I am pleased to report that this has been a remarkable year for protecting and improving 

the country’s air quality. 

The Bush Administration has made implementation of a national clean air strategy a top 

priority by implementing more protective air quality standards for ozone and fine particles and 

designing national tools to help meet those standards. Legislation and regulation will be the 

centerpiece of the President’s clean air and clean energy strategy as we move forward. Together, 

we are on the path to make this generation one of the most productive periods of air quality 

improvement in our nation’s history. 

An important part of our nation’s commitment to clean, healthy air is reducing the levels 

of fine-particle or PM2.5 pollution. Fine-particle pollution represents one of the most significant 

barriers to clean air facing our nation today. These tiny particles, about 1/30th the diameter of a 

human hair, lodge deep in our lungs, and have been associated with heart attacks, chronic 

bronchitis, asthma attacks and missed days of school and work. 

Key to the reduction of particle pollution is implementation of the fine particle standards 

and identification of the areas of the country needing additional work to meet the standards. We 

take the first of those important steps today, identifying the areas in your state that do not meet 

the fine particle standards. Those parts of your state designated as “nonattainment” will require 

more actions to achieve a common goal of cleaner, healthier air (a list of nonattainment areas is 

attached). For areas in your state that attain the standard you will need to continue your progress 

to sustain clean air. 

Internet Address (URL)  http://www.epa.gov

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To assist you, we have both proposed and instituted rules as part of our national clean air 

strategy that will bring the vast majority of the country into attainment with the standards over 

the next decade. Our clean air/clean energy strategy, including Clear Skies legislation and the 

Clean Air Rules, will cut power plant emissions of sulfur dioxides, nitrogen oxides and mercury 

by nearly 70 percent when fully implemented, and will reduce emissions from off-road diesel 

fuels, vehicles and engines by over 90 percent — those black puffs of exhaust smoke are going 

to be a thing of the past. Together, these Clean Air Rules will build on the tremendous progress 

made in previous decades, and do it in record time. 

The last several decades have seen a growing commitment to clean air coupled with a 

progression of science and technology that has informed our decision-making and driven our 

actions. I think of our clean air history as a relay where a baton is passed from generation to 

generation and from Administration to Administration. This Administration has made a 

commitment to accelerate our clean air progress so that all Americans live healthier, longer, 

more productive and prosperous lives. 

 Sincerely, 

 /s/ 

 Michael O. Leavitt 

cc (with attachment): 

 Mr. William G. Ross, Jr. 

 Secretary 

 North Carolina Environment and Natural 

 Resources Department 

 

 Ms. Robin Smith 

 Assistant Secretary for Environmental Protection 

 North Carolina Environment and Natural 

 Resources Department 

 

 Mr. James I. Palmer, Jr. 

 Regional Administrator, Region IV 

Internet Address (URL)  http://www.epa.gov

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Attachment 

Nonattainment Areas 

State Area Name Counties 

North Carolina Greensboro-Winston Salem–High 

Point, NC 

Davidson 

Guilford 

Hickory–Morganton–Lenoir, NC Catawba 

 

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