Appendix C

Public Notice Report, Comments 

Received and Responses
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Public Notice Report, Comments Received and Responses 1

Charlotte-Gastonia-Salisbury, NC 2008 8-Hour Ozone Nonattainment Area Appendix C

Redesignation Demonstration and Maintenance Plan April 16, 2015

Public Notice Report

For the 

Redesignation Demonstration and Maintenance Plan for the Charlotte-GastoniaSalisbury, North Carolina 2008 8-Hour Ozone Marginal Nonattainment Area, and

Clean Air Act Section 110(l) Non-Interference Demonstration to Support the 

Gasoline Reid Vapor Pressure (RVP) Standard Relaxation in Gaston and 

Mecklenburg Counties

Introduction

On March 9, 2015, a pre-hearing version of the “Redesignation Demonstration and Maintenance 

Plan for Charlotte-Gastonia-Salisbury, North Carolina 2008 8-Hour Ozone Marginal 

Nonattainment Area ” and the “Clean Air Act Section 110(l) Non-Interference Demonstration to 

Support the Gasoline Reid Vapor Pressure (RVP) Standard Relaxation in Gaston and 

Mecklenburg Counties” were released for public comment. A request for public hearing, in 

accordance with 40 CFR 51.102, and the public comment period were published on the North 

Carolina Division of Air Quality (DAQ) website, as well as to email distribution lists managed 

by the DAQ. The public comment period was open from March 9, 2015 through April 10, 2015. 

No requests for a public hearing were received. The public comment period elicited comments 

from the United States Environmental Protection Agency (EPA) and the North Carolina 

Petroleum and Convenience Marketers (NCPCM).

Background

The area surrounding Charlotte-Gastonia-Salisbury, North Carolina, called the Charlotte 

nonattainment area, was designated as marginal nonattainment for the 2008 8-hour ozone 

National Ambient Air Quality Standard (NAAQS) on May 21, 2012 (77 Federal Register (FR) 

30088). The Charlotte nonattainment area includes the entire county of Mecklenburg and parts 

of Cabarrus, Gaston, Iredell, Lincoln, Rowan and Union counties in North Carolina, and the 

portion of York County, South Carolina that is adjacent to the Charlotte nonattainment area for 

the 2008 8-hour ozone NAAQS. The nonattainment designation was an action taken by the EPA

under Section 107(d) of the Clean Air Act (CAA). The CAA requires that some area be 

designated as nonattainment if a monitor is found to be in violation of a NAAQS. The EPA took 

designation action in 2012 based on 2009-2011 design values. At that time, the design value for 

the Charlotte area was 0.079 parts per million (ppm); which exceeded the 8-hour ozone standard

of 0.075 ppm.

There are currently six ozone monitors located throughout the Charlotte nonattainment area and 

one monitor located in York County, South Carolina, just outside of the nonattainment area. The 

latest design value for the nonattainment area is 0.073 ppm based on the data from 2012-2014, 

and is therefore in attainment of the 2008 8-hour ozone NAAQS, and the area is eligible to be 

considered for redesignation to attainment. 
Public Notice Report, Comments Received and Responses 2

Charlotte-Gastonia-Salisbury, NC 2008 8-Hour Ozone Nonattainment Area Appendix C

Redesignation Demonstration and Maintenance Plan April 16, 2015

The State of North Carolina has implemented permanent and enforceable reductions in ozone 

precursor emissions in the Charlotte area. In addition, Mecklenburg County Air Quality 

(MCAQ) has implemented actions to reduce ozone precursor emissions. This combination of 

state, federal, and local actions has resulted in cleaner air in the Charlotte nonattainment area, 

and the anticipated future benefits from these programs are expected to result in continued 

maintenance of the 2008 8-hour ozone NAAQS in this region. State actions include the Clean 

Smokestacks Act; the on-board diagnostic vehicle inspection and maintenance program that 

began on July 1, 2002; and voluntary programs to reduce emissions from diesel engines. 

Several federal actions have resulted in lower emissions throughout the eastern portion of the 

country. For on-road and nonroad vehicles, federal actions include the Tier 2 engine standards 

for light- and medium-duty vehicles, heavy-duty engine standards, the low-sulfur gasoline and 

diesel requirements, and off-road engine standards. For stationary sources, federal actions 

include the Mercury and Air Toxics rule for electricity generating units (EGUs) and the National 

Emissions Standards for Hazardous Air Pollutants for industrial, commercial and institutional 

boilers and reciprocating internal combustion engines. In addition, there are several federal 

actions that will be implemented starting in 2015. These actions will provide for additional 

nitrogen oxide (NOx) emissions reductions in and near the Charlotte nonattainment area. For 

EGUs, the future federal actions include compliance with the Cross State Air Pollution Rule and 

the Tennessee Valley Authority consent decree. For on-road vehicles, the future federal actions 

include compliance with the Tier 3 vehicle emissions and fuel standards and corporate average 

fuel economy standards for on-road vehicles.

North Carolina is requesting that the EPA redesignate the Charlotte nonattainment area to 

attainment. The monitoring data clearly shows that the region has attained the 2008 8-hour 

ozone standard, and the maintenance demonstration shows that the future emission inventories 

are expected to be lower than the base year inventory through the implementation of the various 

control measures listed above.

In addition, the DAQ has included a separate request for the EPA to consider relaxation of the 

current 7.8 psi RVP requirement for Mecklenburg and Gaston Counties subject to the 

summertime (June 1 through September 15) gasoline volatility standard contained in 40 CFR 

80.27(a)(2). Approval of this request will enable 9.0 psi gasoline to be distributed in the entire 

Charlotte maintenance area throughout the summer. The current requirement of 7.8 psi RVP 

standard was put in place by the EPA to control emissions of volatile organic compounds. 

Current science tells us that the most effective method to control ozone formation in the 

Southeast is through reductions in NOx emissions. The current RVP standard results in higher 

fuel cost that adversely affects businesses and consumers, while providing limited environmental 

benefits in this area. 

The redesignation request and maintenance plan presents the results of an in-depth DAQ 

analysis, which indicates that relaxation of the RVP standard in the Charlotte maintenance area 

would not interfere with the attainment or maintenance of the NAAQS. Ambient air quality data 

for the most recent three year period (2012-2014) demonstrate that the Charlotte maintenance 

area has continued to maintain the 1997 8-Hour ozone standard and has now measured 
Public Notice Report, Comments Received and Responses 3

Charlotte-Gastonia-Salisbury, NC 2008 8-Hour Ozone Nonattainment Area Appendix C

Redesignation Demonstration and Maintenance Plan April 16, 2015

attainment of the 2008 8-hour ozone standard. The area also continues to meet the NAAQS for 

all other criteria air pollutants.

Summary of Public Comment Period

The public notice comment period was open from March 9, 2015 through April 10, 2015. There 

were no requests for a public hearing. Comments were received from the EPA and the NCPCM, 

which are attached following this report. 

The following is a summary of the pertinent comments raised during the public comment period, 

along with the DAQ’s response. 

EPA comment: We have completed our review of the prehearing submittal and offer no 

comments at this time.

DAQ response: The DAQ acknowledges this comment. No revisions are required.

NCPCM comment: The NCPCM supports the DAQ’s request to the EPA to relax the 

summertime RVP standard from 7.8 psi to 9.0 psi in Gaston and Mecklenburg Counties. 

DAQ response: The DAQ acknowledges this comment. No revisions are required.

Attachments to Public Notice Report

1) Written comments from R. Scott Davis, Chief of the Air Planning and Implementation 

Branch, EPA, dated April 7, 2015.

2) Written comments received from Gary F. Harris on behalf of the North Carolina Petroleum 

and Convenience Marketers, dated March 25, 2015.

3) Public Notice Announcement by the North Carolina Department of Environment and 

Natural Resources.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

Sheila C. Holman, Director 

Division of Air Quality 

North Carolina Department of 

Environment and Natural Resources 

1641 Mail Service Center 

Raleigh, North Carolina 27699-1641 

Dear Ms. Holman: 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303·8960 

April 7, 2015 

Thank you for your letter dated March 11, 2015, transmitting a prehearing package regarding the 

Charlotte-Gastonia-Salisbury 2008 8-hour ozone marginal nonattainment and the 110(1) NonInterference Demonstration to support the Gasoline Reid Vapor Pressure Standard relaxation in Gaston 

and Mecklenburg Counties. These revisions are the subject of a public comment period beginning 

March 9, 2015, with written comments due by the close of business on AprillO, 2015. We have 

completed our review of the prehearing submittal and offer no comments at this time. 

We look forward to continuing to work with you and your staff. If you have any questions. please 

contact Ms. Lynorae Benjamin, Chief. Air Regulatory Management Section at (404) 562-9040, or have 

your staff contact Nacosta C. Ward at (404) 562-9140. 

Sincerely, 

R. Scott Davis 

Chief 

Air Planning and Implementation Branch 

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

Recycled/Recydable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumet) 
NCPCM 

North Carolina Petroleum 

& Convenience Marketers 

Fltding North Carolina's F11t11re 

7300 Glenwood Avenue 

Raleigh, NC 27612 

Phone 919-782-4411 

Fax 919-782-4414 

www.ncpcm.org 

March 25, 2015 

Mr. Randy Strait 

NC Division of Air Quality 

1641 Mail Service Center 

Raleigh, NC 27699-1641 

RE Clean Air Act Section 11 0(1) Non-Interference Demonstration to Support the Gasoline Reid Vapor 

Pressure (RVP) Standard Relaxation in Gaston and Mecklenburg Counties 

Dear Mr. Strait: 

The North Carolina Petroleum & Convenience Marketers (NCPCM) supports the North Carolina 

Department of Air Quality (NCDAQ) in requesting that the United States Environmental Protection Agency 

(US EPA) relax the current 7.8 psi Reid Vapor Pressure (RVP) motor gasoline volatility requirement for 

two Metrolina counties during the summertime ozone season. The NC DAQ maintenance plan document 

demonstrates that the current federal gasoline standard is unnecessary to maintain the ozone standard, 

and the RVP relaxation to 9.0 psi gasoline will not interfere with attainment of the current ozone standard. 

In North Carolina, an abundance of biogenic Volatile Organic Compounds (VOCs-90%) makes the 

majority of the State a nitrogen oxides (NOx) limited environment for the formation of ozone. Since 

reductions in man-made VOC emissions do not reduce ozone levels, having a lower Reid Vapor Pressure 

(RVP) motor gasoline during the summer months from June-September is not an effective control 

measure for ozone. In addition, it results in higher fuel costs, impacting government, businesses and 

consumers at the pump. 

Please know that our Board and staff are ready to assist the Department in any way necessary to 

continue this effort. Thank you again. 

Via electronically: daq.publiccomments@ncdenr.gov 
NORTH CAROLINA DEPARTMENT OF ENVIRONMENT & NATURAL RESOURCES 

PUBLIC NOTICE 

PURPOSE: 

COMMENT 

PROCEDURES: 

REQUESTS FOR A 

PUBLIC HEARING: 

INFORMATION: 

Date: ~ J le l \5' 

The North Carolina Department of Environment and Natural Resources, Division of Air Quality 

(NCDAQ), hereby gives notice regarding its Pre-hearing Draft of the following two items: 

I. Redesignation Demonstration and Maintenance Plan for the Charlotte-Gastonia-Salisbury, 

North Carolina 2008 8-Hour Ozone Marginal Nonattainment Area for North Carolina, and 

2. Clean Air Act Section 110{1) Non-Interference Demonstration to Support the Gasoline Reid 

Vapor Pressure (RVP) Standard Relaxation in Gaston and Mecklenburg Counties. 

Persons wishing to submit comments or request a public hearing are invited to do so. 

Any person wishing to comment may submit a written statement for inclusion in 

the record of proceedings regarding the Pre-hearing Draft of the Redesignation Demonstration and 

Maintenance Plan for the Charlotte-Gastonia-Salisbury, North Carolina 2008 8-Hour Ozone 

Marginal Nonattainment Area for North Carolina, and/or the Clean Air Act Section 11 0(1) NonInterference Demonstration to Support the Gasoline Reid Vapor Pressure (RVP) Standard 

Relaxation in Gaston and Mecklenburg Counties. 

Written comments should be received by no later than Friday, April10, 2015. 

Requests for a public hearing must be in writing and include a statement supporting the need 

for such a hearing, an indication of your interest in the subject, and a brief summary of the 

information intended to be offered at such hearing. A public hearing will be scheduled if 

requested. A separate notice will be announced for the hearing including the date, time and 

location. Written requests for a public hearing should be received no later than Friday, April10, 

2015, and addressed to Randy Strait, Division of Air Quality, 1641 Mail Service Center, Raleigh, 

North Carolina 27699-1641. 

Copies of the Pre-hearing Draft of the Redesignation Demonstration and Maintenance Plan for the 

Charlotte-Gastonia-Salisbury, North Carolina 2008 8-Hour Ozone Marginal Nonattainment Area 

for North Carolina, and the Clean Air Act Section 11 0(1) Non-Interference Demonstration to 

Support the Gasoline Reid Vapor Pressure (RVP) Standard Relaxation in Gaston and 

Mecklenburg Counties may be downloaded from the NCDAQ website at 

http://www.ncair.org/planning/charlotte _ 2008 _ 8hr _ sip.shtml. 

Comments can be submitted electronically to: 

daq.publiccomments@ncdenr.gov 

(Please type "Charlotte 2008 8-Hour Ozone SIP" in the subject line) 

Comments can be mailed or faxed to: 

Randy Strait 

NC Division of Air Quality 

1641 Mail Service Center 

Raleigh, NC 27699-1641 

Fax: (919) 707-8721 

The Pre-hearing Draft of the Redesignation Demonstration and Maintenance Plan for the 

Charlotte-Gastonia-Salisbury, North Carolina 2008 8-Hour Ozone Marginal Nonattainment Area 

for North Carolina, and the Clean Air Act Section 110(1) Non-Interference Demonstration to 

Support the Gasoline Reid Vapor Pressure (RVP) Standard Relaxation in Gaston and 

Mecklenburg Counties may be reviewed in person during normal business hours at the following 

North Carolina Department of Environment and Natural Resources, Division of Air Quality 

offices: 

Raleigh Central Office, Planning Section 

Mooresville Regional Office 

(919) 707-8403 

(704) 663-1699 

Sheila C. Holman, Director