Appendix F

Public Participation Documentation

and 

Statement of Consideration
STATEMENT OF CONSIDERATION

RELATING TO SIP REVISION FOR THE ASHLAND AREA COUNTIES OF BOYD

AND A PORTION OF LAWRENCE COUNTY, KENTUCKY, REDESIGNATION TO 

ATTAINMENT

FOR THE ANNUAL PM2.5 STANDARD

Amended After Comments

Energy and Environment Cabinet

Department for Environmental Protection

Division for Air Quality

A public hearing on the State Implementation Plan (SIP) revision for redesignation of 

Boyd County and a portion of Lawrence County to attainment for the annual PM2.5

standard was scheduled for 6 p.m., December 22, 2011. The public hearing was 

cancelled after this agency received no requests by December 15th to conduct the hearing. 

Written comments were received during the public comment period.

The following individuals from the Kentucky Environmental and Public Protection 

Cabinet drafted responses to comments received during the public review period.

John Gowins, Environmental Control Supervisor Division for Air Quality

Susan Weaver, Internal Policy Analyst III Division for Air Quality

Response to Comments for the proposed revision to the State Implementation Plan (SIP) to 

redesignate Boyd County and a portion of Lawrence County as attainment for the National 

Ambient Air Quality Standard (NAAQS) for annual PM2.5 .

1. Comment: The Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS) 2005 referenced under the Demonstration section appears to be a typo. It is 

our understanding that VISTAS did not develop a 2005 emissions inventory. Please 

confirm.

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The reference to the 2005 

VISTAS inventory has been deleted from Chapter 4, Base Year Emissions Inventory, and 

all inventory details have been clarified in the background and demonstration. 
2

2. Comment: The first paragraph (page 32) of the State Implementation Plan (SIP) 

narrative appears to imply a connection between VISTAS’ projection growth and control 

files discussed in Appendix D in a VISTAS report that was used to develop the 2009 and 

2018 inventories, and the 2015 and 2022 projection inventories used in this redesignation 

SIP. However, this is not the case, since interpolation was used to develop the 2015 

inventory from the VISTAS data and extrapolation was used to develop the 2022 

inventory.

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The Cabinet added description 

of the interpolation calculation used for 2015 and 2022 to the inventory narration of 

Chapter 4, Emission Inventory Demonstration. The nonroad and area emissions 

inventory spreadsheets have been added to Appendix B.

3. Comment: It is not clear how extrapolation was used to develop the 2022 inventory. 

Can you provide detail on how extrapolation was used to develop 2022 inventory? 

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The descriptions of calculations

developing the inventory numbers has been added to the narrative of Chapter 4, Emission 

projections, and are included in the spreadsheets of Appendix B regarding pollutant by 

type and county. Interpolation and extrapolation was used for nonroad and area sources,

and spreadsheets have been added to Appendix B of this submittal.

4. Comment: It is not clear how interpolation was used to develop the 2015 inventory 

for stationary and mobile sources. It is not clear if the on-road and mobile source 

inventories for 2009 and 2018 were developed using the MOVES model. Please explain.

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The Cabinet added a clarifying 

statement that MOVES was used for all mobile numbers. It is further discussed on page 

A-2 of Appendix C in the KYOVA document that all mobile inventory years were 

developed using MOVES. Kentucky used our own KyEIS numbers for stationary 

sources and extrapolated to 2015 and 2022. Chapter 4, Emission Projections, 

Background and Demonstration, for the KYOVA and KYTC Travel Demand Model, 

were updated to reflect these clarifications.

5. Comment: All 2008 attainment emissions inventory source categories for the PM2.5 

precursor pollutants are not presented in specific detail in Appendix B and the VISTAS 

report. Emissions inventory specifics for the area, non-road and on-road sources specific 

to the Kentucky nonattainment counties must be presented. 

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The Cabinet has included

specific details for all nonroad and area inventories in Appendix B. There are also 

summary tables for nonroad and area regarding by pollutant type and county. 
3

6. Comment: The SIP does not discuss the quality control procedure with respect to the 

inventory development. Please explain what quality control measures were used with 

respect to the inventory.

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The Cabinet added a clarifying 

statement which explains that this agency has developed and submitted a point source 

emissions inventory quality assurance project plan (QAPP) which was approved in a 

letter from EPA dated August 18, 2010 from the Chief of Air Quality Modeling and 

Transportation Section, R. Scott Davis. This reference was added to Chapter 4, Base Year 

Emission Inventory Background and to Appendix B.

7. Comment: Chapter 2 indicates there is a modeling component required to address 

Clean Air Act (CAA) section 107(d)(3)(E)(i) and that this is discussed in Chapter 3. 

However, such discussion does not appear to be included in Chapter 3 and would be 

helpful. The ambient monitoring data may be sufficient without modeling.

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The Cabinet modified the 

reference in Chapter 2 (i) to reflect that no modeling was required and not considered in 

the redesignation request. 

8. Comment: Each requirement listed throughout the narrative is delineated as being one 

out of a number of requirements for a particular aspect of the submittal (e.g., 1 of 4, 2 of 

4, 3 of 4, 4 of 4 ). Please clarify what the source of the requirements numbering is. 

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The overall requirements are 

taken from the U.S. EPA Procedures for Processing Requests to Redesignate Areas to 

Attainment, John Calcagni, September 4, 1992, as stated in Chapter 2.

9. Comment: Below the titles of Chapter 3, 4, 5 and 6 are references to sections for the 

CAA. These references appear to be intended to indicate which section of the CAA the 

discussion in the chapter addresses. Please review to ensure the references shown are the 

ones intended. For example:

a) Chapter 4 lists 107(d)(3)(E)(iii), which is the requirement to show permanent 

and enforceable improvement in air quality. It seems 107(d)(3)(E)(iv) should 

also be indicated here since Chapter 4 also addresses elements of that section, 

such as the attainment inventory, maintenance demonstration, and verification 

of continued attainment (i.e, part of the maintenance plan).

b) Listed below the title of Chapter 5 are references to the CAA sections 

107(d)(3)(E)(ii), (iv) and (v). However it appears this chapter only addresses 

requirements from CAA section 107(d)(3)(E)(v).
4

c) Listed below the title of Chapter 6 is a reference to CAA section 

107(d)(3)(E)(v). However, the contingency plan is a requirement of section 

107(d)(3)(E)(iv) (i.e., it is part of the maintenance plan).

(R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The narrative has been 

corrected for each chapter.
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~~~~ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

REGION 4 

"t, <:J ~ '<' «; it 

"'~'1 .._.!;5 

( PR01~o-G 

Leonard K. Peters, Secretary 

Energy and Environment Cabinet 

Office of Secretary 

500 Metro Street 

12th Floor, Capital Plaza Tower 

Frankfurt, Kentucky 40601 

Dear Mr. Peters: 

ATLANTA FEDERAL CENTER 

61 FORSYTH STREET 

ATLANTA, GEORGIA 30303·8960 

December 22, 2011 

Thank you for your letter dated November 9, 2011, transmitting a prehearing package regarding the 

Redesignation Request of the Huntington Ashland Nonattainment Area. These rules were the subject of 

a public hearing held December 15, 2011, with written comments due by the close of business on 

December 22, 2011. We have completed our review of the prehearing submittal and offer suggested 

clarifications in the enclosure. 

1. The Visibility Improvement State and Tribal Association ofthe Southeast (VISTAS) 2005 

referenced on page 21 under the Demonstration section appears to be a typo. It is our 

understanding that VISTAS did not develop a 2005 emissions inventory. Please confirm. 

2. The first paragraph (page 32) of the State Implementation Plan (SIP) Narrative appears to 

imply a connection between the VISTAS' projection growth and control files discussed in 

Appendix Din a VISTAS report that was used to develop the 2009 and 2018 inventories and 

the 2015 and 2022 projection inventories used in this redesignation SIP. However, this is 

not the case, since interpolation was used to develop the 2015 inventory from the VISTAS 

data and extrapolation was used to develop the 2022 inventory. 

3. It is not clear how extrapolation was used to develop the 2022 inventory. Can you provide 

detail on how extrapolation was used to develop 2022 inventory? 

4. It is not clear how interpolation was used to develop the 2015 inventory for stationary and 

mobile sources. It is not clear if the on-road and mobile source inventories for 2009 and 

2018 were developed using the MOVES model. Please explain. 

5. All2008 attainment emissions inventory source categories for the PM2.5 precursor 

pollutants are not presented in specific detail in Appendix B and the VISTAS report. 

Emissions inventory specifics for the area, non-road and on-road sources specific to the 

Kentucky nonattainment counties must be presented. 

6. The SIP does not discuss the quality control procedure with respect to the inventory 

development. Please explain what quality control measures were used with respect to the 

inventory. 

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

Recycled/Recyclable • Printed wtth Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer) 
7. Chapter 2 indicates there is a modeling component required to address Clean Air Act (CAA) 

section 107 ( d)(3 )(E)(i) and that this is discussed in Chapter 3. However, such discussion 

does not appear to be included in Chapter 3 and would be helpful. The ambient monitoring 

data may be sufficient without modeling. 

8. Each requirement listed throughout the narrative is delineated as being one out of a number 

of requirements for a particular aspect of the submittal (e.g., 1 of 4, 2 of 4, 3 of 4, 4 of 4 ). 

Please clarify what the source of the requirements numbering is. 

9. Below the titles of Chapters 3, 4, 5 and 6 are references to sections for the CAA. These 

references appear to be intended to indicate which section of the CAA the discussion in the 

chapter addresses. Please review to ensure the references shown are the ones intended. For 

example: 

a) Chapter 4 lists 107(d)(3)(E)(iii), which is the requirement to show permanent and 

enforceable improvement in air quality. It seems 107(d)(3)(E)(iv) should also be 

indicated here since Chapter 4 also addresses elements of that section, such as the 

attainment inventory, maintenance demonstration, and verification of continued 

attainment (i.e., parts of the maintenance plan). 

b) Listed below the title of Chapter 5 are references to CAA sections 1 07( d)(3)(E)(ii), 

(iv) and (v). However, it appears this chapter only addresses requirements from CAA 

section 107(d)(3)(E)(v). 

c) Listed below the title of Chapter 6 is a reference to CAA section 107(d)(3)(E)(v). 

However, the contingency plan is a requirement of section 1 07( d)(3 )(E)(iv) (i.e., it is 

part of the maintenance plan). 

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

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

staff contact Mr. Zuri Farngalo at (404) 562-9152. 

Sincerely, 

'S~~~~ R. Scott Davis 

Chief 

Air Planning Branch 
KENTUCKY DIVISION FOR AIR QUALITY 

NOTICE OF PUBLIC HEARING 

 TO REVISE KENTUCKY'S STATE IMPLEMENTATION PLAN 

The Kentucky Energy and Environment Cabinet will conduct a public hearing on December 22, 2011, at 10:00 a.m. 

(ET) in the Conference Room of the Ashland-Boyd County Health Department, 2916 Holt Street, Ashland, 

Kentucky. This hearing is being held to receive comments on a proposed State Implementation Plan (SIP) revision 

to redesignate the Kentucky portion of the Huntington-Ashland, Ohio-Kentucky-Indiana area from nonattainment 

to attainment for the 1997 annual PM2.5 National Ambient Air Quality Standard to address sections 107 and 175A 

of the Clean Air Act (CAA). This revision, when approved by the U.S. EPA, will redesignate the counties of Boyd 

and a portion of Lawrence to attainment, and document that the ambient monitoring data for annual PM2.5 indicates 

attainment of the standard. 

This hearing is open to the public and all interested persons will be given the opportunity to present testimony. The 

hearing will be held, if requested, at the date, time and place given above. It is not necessary that the hearing be 

held or attended in order for persons to comment on the proposed submittal to EPA. To assure that all comments 

are accurately recorded, the Division requests that oral comments presented at the hearing also be provided in 

written form, if possible. To be considered part of the hearing record, comments must be received by the close of 

the hearing. Comments should be sent to the contact person. If no request for a public hearing is received, the 

hearing will be cancelled, and notice of the cancellation will be posted at the website listed below. Request for a 

public hearing must be received no later than December 15, 2011 while all comments must be submitted no later 

than December 22, 2011. 

The full text of the proposed SIP revision is available for public inspection and copying during regular business 

hours (8:00 a.m. to 4:30 p.m.) at the locations listed below. Any individual requiring copies may submit a request 

to the Division for Air Quality in writing, by telephone, or by fax. Requests for copies should be directed to the 

contact person. In addition, an electronic version of the proposed SIP revision document and relevant attachments 

can be downloaded from the Division for Air Quality’s website at: 

http://air.ky.gov/Pages/PublicNoticesandHearings.aspx. 

The hearing facility is accessible to people with disabilities. An interpreter or other auxiliary aid or service will be 

provided upon request. Please direct these requests to the contact person. 

CONTACT PERSON: Susan Weaver, Internal Policy Analyst III, Division for Air Quality, 200 Fair Oaks Lane, 

Frankfort, Kentucky 40601. Phone (502) 564-3999; Fax (502) 564-4666; E-mail susan.weaver@ky.gov. 

The Environmental and Public Protection Cabinet does not discriminate on the basis of race, color, national origin, 

sex, age, religion, or disability and provides, upon request, reasonable accommodation including auxiliary aids and 

services necessary to afford an individual with a disability an equal opportunity to participate in all services, programs, 

and activities. 

Ashland Regional Office Bowling Green Regional Office Florence Regional Office Frankfort Regional Office 

1550 Wolohan Drive, Suite 1 1508 Westen Avenue 8020 Veterans Mem Dr, Suite 110 200 Fair Oaks, 3rd Floor 

Ashland, KY 41102-8942 Bowling Green, KY 42104-3356 Florence, KY 41042 Frankfort, KY 40601-1758 

Hazard Regional Office London Regional Office Owensboro Regional Office Paducah Regional Office 

233 Birch Street, Suite 2 875 S Main Street 3032 Alvey Park Dr W, Suite 700 130 Eagle Nest Drive 

Hazard, KY 41701-2179 London, KY 40741 Owensboro, KY 42303-2191 Paducah, KY 42003-0823 

Boyd County Clerk Lawrence County Clerk 

2800 Louisa St #106 122 South Main Cross Street 

Catlettsburg, KY 41129 Louisa, KY 41230 

 

 
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natural resources. · 

page that calls for a boycott than her iusband. She's 

· of J:LC because of the· se- outspoken and funnY, disries, which it calls "an at- · pelling . ·:image of subtempt to make America ac- mi!) · · ness the hijab may 

cept Islam without showing esent to outsiders. · · 

the truth about what Isl " · 

is all about." .ii 

Mike Mosallam, a television producer from Dearborn, didn't have. to cast a 

widenetwhenhe sought participants from within his 

close-knit community. (i)ne 

cast member is his cousin, 

another is an old schoolmate. 

Still, the. contrasts he highlights make for interesting, 

even educational television. 

Nawal. Aoude, for iiistance, wears the traditional hijab, or headsca.If, and 

does not touch a man other . 

KENTUCKY DIVISION FOR AIR QUALITY 

NOTICE OF PUBLIC HEARING 

, TO REVISE KENTUCKY'S STATE IMPLEMENTATION PLAN . . . The Kentucky Energy and Environment ~binetwill conduct a public hearing on December 22, 2011, at 10:00 a.m. (E'I}in the Conference Room of the Ashl_and-Boyd Gounty Health Department, 

2916 Holt Street, Ashland, Kentuck'}'. This hearing is being held to. 

reeeive comments on a proposed State. Implementation Plan (SIP) r~vision to .redesignate the Kentucky portion of the HuntingtonAShland, Ohio-Kentucky-Indiana area from nonattainment.to at- . . tai.pm.ent f.orthe 1997 annual PM2.5 National Ambient Air Quality 

Standard to address sections 107 and 175A of the Clean Air Act 

( CAA)~ This revision, when approved by the U.S. EPA, will redesigil.ate the counties of Boyd and a portion of Lawrence to attainment, and:'document that the ambient monitoring data for annual 

PM2.5 indicates attainment of the standard. 

This hearing is open to the public. and all interested persons will be 

given the opportUnity to present testimony. The hearing will be 

held, if requested, at the date, time and place given above. It is not 

necessary that the hearing be held or attended in order for persons 

to comment on the proposed submittal to EPA To assure that all 

comments are accurately recorded, the Division requests that oral 

curity benefits or pro;· C()~ents presented at th~ hearing also ',he pi:o~ded in written · · .· form, if ~ssible. To be considered part of tp.e hearmg reco;rd, com- grams, call the Ashland of- ments mUst be received by the close of.the hearing. Comments 

flee to speak to a represen- sho~d·~e sen~ to the contact pe:;son. If ~o request for. a public . . ; hearmg IS· received, the heanng will be cancelled, and notice of the 

tative m the office on the cancellation will be posted at the website listed below. Request for 

· first floor of the Carl D. · a p~blic ~g must be received !lo later tlj.an December 15, 2011 . . . while all comments must be subnutted no later than December 22, Perkins Federal Building 2011. · · 

on Greenup Avenue in . The full teXt of the proposed SIP revision is aVailable for public in-

. Ashland. You also may call spection ru;td .copying during regular busines~ hours (8:ooa.m. to · . .• · ; 4:30p.m~) at the locations listed below .. Anyljndividual requiring (866) 269-3993. copies may submit a request to the Division for Air Quality in writ-

-------.-:--. -. -- ing, bytelephone, or by fax. Requests for copies .should be directed 

BERNARIHJ'NANis dtstrtct to the contact person. In addition, an~!E~ctronicversion of the promanager for the Ashland Social posed SIP revision document and relev?-Ut attachments can be 

Seeuritu.office. downloaded from the Division for Air Quality's website. at: · · http:/ f~.ky.gov/Pages/PqblicNotice.SandH~arfu.gs.aspx. 

The hearing facility is accessible to people. With disabilities; An in- . . . terpreter o.ruther auxiliary aid or service will' be provided upon re- dinner, Sign up at counter. quest. Please Q.irect these requests to the contact person. 1 Thursday: Lunch: salad . · · . I potluck CONT.A,CI' PERSON: Susan Weaver, Internal Policy Analyst !II, Dl- i · vision for Air Quality, 200 Fair Oaks Lane, Frankfort, KentuckY ~ . 40601. Pho.ne (502) 564-3999; Fax (502). 564-4666; E-mail 

I<! flatwoods susan.weaver@ky.gov. . . . r Events this week at the . ~e ~nviro~ental :md. Public Protec~on Cab~n.et does not di~- i Flatwoods 'Senior Citizens · c:;rmmateoJ?. th~ ~asrs ofrace, c?lor,pational ongm, sex, age,.reli-: • Center on Reed Street The gron, or di~ab~ty ~d pro:v!-des, . upon requ_est, reasonable 

•l · . • . • accommodation mcluding auxiliary ruds and servrces necessary to 

U center IS open from 9 a.m. · afford aD. individual with a disability an equal opportunitY to par~ 

~ to 2 p.m.l.Y,I~:mday; Wednes- ticipate in an services, programs, and activities. 

~ · -day and ~day. Telephone: -Ashland Regional Office . Bowling Green Regional Office 

r (606) 494 2362. . . 1.550 Wolo~an Drive Suite 1 1508 Western Avenue . T9day: 9 a.m.-Coffee ·· Ashland, KY41102-S942 Bowling Green, KY42104~3356 

1 

(. 

and doughnuts. 10 a.m.- . ·· · · · · Hazard ~egional Qffice 

233 Birch-Street, Suite 2 

Hazard.:1KY' 4170i-2179 

London R~gion,al Office 

875 S. Main Street 

London, KY 40741 

Hecilth department. U:15 

t a.m. -:-Lunch. 

t Wednesday: 9 a.m.-:-

Coffe~ and doughnuts. 10 · ·. 

·a.m . ..:... Bible study. 11:15 

e a.m . ..:_ Lunch- gold for 

cash. 

Friday: 9-a.m. -Coffee 

and dougb.nutS.10 a.m..-

Bingo; 11:15 a.m.-Lunch. 

. Nov. 21: 9 a.m.-Coffee 

'and doughnuts. 10 a.m: 

Rita Spence; 11:15 a.m. 

lY Lunch. 

Boyd COtmty Clerk 

2.Soo Louisa St. #106 

Catlettsburg, KY 41129 

Lawrence County Clerk 

122 South Main Cross Street 

LouiSa, KY 41230 

Florence Regional Office Frankfort Regional Office ~.020 Veterans Mem Dr., Suite 110 200 Fair Oaks, 3rd F1oor 

Florence, KY 41042 Frankfort, KY 40601-1758 

Owensboro Regional Office Paducah Regional Office 

3032 Alvey Park Dr. W., Suite 700 130 Eagle Nest Drive 

Owensboro, KY42303-2191 Paducah, KY 42003-0823 _ 

Published: November14, 2011 

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