# Appendix A

Policy and MemorandumsPolicy and Memorandums i The Hickory And Greensboro-Winston Salem-High Point, NC PM2.5 Appendix A North Carolina Attainment Demonstration August 21, 2009 

### (This page intentionally left blank)Policy and Memorandums ii The Hickory And Greensboro-Winston Salem-High Point, NC PM2.5 Appendix A North Carolina Attainment Demonstration August 21, 2009 

## Table of Contents

Guidance Document: 11/18/2002, Lydia Wegman and Peter Tsirigotis, “2002 Base Year Emissions Inventory SIP Planning: 8-Hr Ozone, PM 2.5 

### and Regional Haze Programs” .....1

Guidance Document: 4/3/2003, Jeffrey R. Holmstea d, “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 PM 2.5 

### 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 US EPA’s comments to North Carolina’s 2/17/2004

recommendations for PM 2.5 

### nonattaiment designations ....................................................27

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

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

Guidance Document: 12/14/2004, Stephen D. Page, “C lean 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 Count y as attainment for

PM 2.5 

### 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 PM 2.5 

### National Ambient Air Quality Standards” ......................................................................................................6 8Policy and Memorandums iii The Hickory And Greensboro-Winston Salem-High Point, NC PM2.5 Appendix A North Carolina Attainment Demonstration August 21, 2009 

### (This page intentionally left blank)**1** 

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

**Ad m**  **inistrators, “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 f**  **ound at: http://www.census.gov/population/www/estimates/metroar**  **e a.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** 

**areas 1**  

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

**Ma n**  **agement 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

**Tri b**  **es 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** **-2-**

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

**th e**  **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** 

**e n**  **c ourage States and Tribes to make every effort to process the 4**  **th quarter 2003 air quality data** 

**as q**  **uickly 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** 

### 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 non

attainment 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 sou

rces. 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 analy sis, 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 Carol ina’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 t o their communities

– particularly when there is no beneficial effect.

### The Honorable Michael Leavitt

Page 2 September 9, 2004

With this in mind, I urge you to narrow your non

- attainment designation to Davidson County and the MPO portion of Cata wba 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 reg

ards, I remain

Very truly yours,

Michael F. Easley

MFE: rht

cc: North Carolina Congressional Delegation James I. Palmer, Regional Administrator, US EPAUNITED 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 b een a remarkable year fo r protecting and improving the country’s air quality.

The Bush Administration has made implementa tion 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 sta ndards. 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 polluti on. Fine-particle pollution represen ts one of the most significant barriers to clean air facing our nation today. These tiny particles, about 1/30 th the diameter of a human hair, lodge deep in our lungs, and have been associated with heart a ttacks, 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, iden tifying 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 Recycled/Recyclable  Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper2

To assist you, we have both proposed and institu ted rules as part of our national clean air strategy that will bring the vast majority of the country into a ttainment with the standards over the next decade. Our clean air/clean energy st rategy, including Clear Sk ies legislation and the Clean Air Rules, will cut power plant emissions of sulfur dioxides, nitr ogen 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. Toge ther, 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 grow ing commitment to clean air coupled with a progression of science and tec hnology 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 Administ ration 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 Recycled/Recyclable  Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled PaperInternet Address (URL)  http://www.epa.gov Recycled/Recyclable  Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper Attachment

Nonattainment Areas

State Area Name Counties

North Carolina Greensboro-Winston Salem–High Point, NC Davidson

Guilford

Hickory–Morganton–Lenoir, NC Catawba