# Appendix F

Public Participation Documentation

and

Statement of Consideration

### STATEMENT OF CONSIDERATION

RELATING TO SIP REVISION FOR THE ASHLAND AREA COUNTIES OF BO YD AND A PORTION OF LAWRENCE COUNTY, KENTUCKY, REDESIGNATION TO ATTAINMENT FOR THE ANNUAL PM 2.5 

### STANDARD Amended After Comments



# E nergy and E nvironment Cabinet Department for Environmental Protection

Division for Air Quality

A public hearing on the State Implementation Plan (SIP) revision for redesignation of
Bo yd County and a portion of Lawrence County to attainment for the annual PM 2.5 

### standard was sch eduled for 6 p.m., December 22 , 201 1 . The public hearing was cancelled after this agency received no requests by December 15 th 

### to conduct the hearing. Written comments were received during the public comment period.

The following individuals from the Ken tucky 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 Q uality

Response to Comments for the proposed revision to the State Implementation Plan (SIP) to redesignate Bo yd County and a portion of Lawrence County as attainment for the National Ambient Air Quality Standard (NAAQS) for annual PM 2.5 

### .
1. Comment: The Visibility Improvement State and Tribal Association of the Sou theast (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 an d 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 description s of calculation s developing the inventory numbers has been added to the narrative of Chapter 4, Emission projections, and are included in the spreadsheets of Appen dix 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 20 15 inventory for stationary and mobile source s. It is not clear if the on

- road and mobile source inventories for 2009 and 2018 were developed us ing the MOVES model. Please explain

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

Response: The Cabinet acknowledges this co mment. The Cabinet added a clarifying
statement that MOVES was used for all mobile numbers

. It is further discussed on page A

- 2 of A ppendix C in the KYOVA d ocument that all mobile inventory years were d ev eloped using MOVES. Kentucky used our own K y EIS nu mbers 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 s ources specific to the Kentuck y nonattainment counties must be presented

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

Response: T he Cabinet acknowledges this comment. T he Cabinet has include d specific details for all nonroad and area inventories in Appendix B

. The re are also summary tables for nonroad and area reg arding 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 Ca binet added a clarifying
statement which explains that t his 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 monito ring data may be sufficient without modeling. (R. Scott Davis, U.S. EPA)

Response: The Cabinet acknowledges this comment. The Cabinet modified the ref erence 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 requir ements 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 Attainmen t , J ohn 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 requir ement 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 verificat ion 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 Cab inet acknowledges this comment. The narrative has been corrected for each chapter

.

### 0.,.,,to**sr-'~r~**

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## ~~~~ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 4

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«; 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 BranchKENTUCKY DIVISION FOR AIR QUALITY NOTICE OF PUBLIC HEARING TO REVISE KENTUCKY'S ST ATE 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 C ounty Health Department, 2916 Holt Street, Ashland, Kentucky. This hearing is being held to receive comme nts 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 PM 2.5 National Ambient Air Quality Standa rd to address sections 107 and 175A of the Clean Air Act (CAA). This revision, when appr oved by the U.S. EPA, will redesignate the counties of Boyd and a portion of Lawrence to attainment, and docu ment that the ambient monitoring data for annual PM 2.5 indicates attainment of the standard.

This hearing is open to the public and all interested pers ons will be given the opportunity to present testimony. The hearing will be held, if requested, at the date, time and pl ace given above. It is not necessary that the hearing be held or attended in order for persons to comment on th e 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 pers on. 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 belo w. 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 Divisi on 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 Analys t 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 ba sis 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 Bowl ing Green Regional Office Florence Regional Office Frankfort Regional Office 1550 Wolohan Drive, Suite 1 1508 Westen Avenue 8020 Veterans Mem Dr, Suit e 110 200 Fair Oaks, 3 rd Floor Ashland, KY 41102-8942 Bowling Green, KY 42104 -3356 Florence, KY 41042 Frankfort, KY 40601-1758

Hazard Regional Office L ondon Regional Office Owensboro Region al Office Paducah Regional Office 233 Birch Street, Suite 2 875 S Main Street 3032 Alve y Park Dr W, Suite 700 130 Eagle Nest Drive Hazard, KY 41701-2179 London, KY 40741 Owe nsboro, 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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. agenffor airicl.uture ro;:d 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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