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Lisa P. Jackson, Administrator 

United States Environmental Protection Agency Headquarters 

Ariel Rios Building 

1200 Pennsylvania Avenue NW 

Mail Code hUlA 

Washington, DC 20460 

Dear Administrator Jackson: 

On April 30, 2012, the U.S. Environmental Protection Agency (EPA) designated the eastern part of 

York County, South Carolina "nonattaimnent" for the 2008 8-hour ozone National Ambient Air Quality 

Standard (NAAQS). The EPA included this portion of York County in the 

Charlotte-Gastonia-Salisbury, NC-SC (Charlotte) nonattainment area based on their belief that this part 

of York County contributed to the ozone violations in Charlotte. We respectfully request that the EPA 

reconsider this decision, 

In its package submitted on February 29, 2012, the Department of Health and Environmental Control 

(Di-IEC) concluded that York County is not a significant contributor to Charlotte's nonattainment. 

Current data continues to show that ozone concentrations at the York monitor, and across South Carolina, 

have been trending downward over the past decade. The 2011 ozone design value at the York monitor 

is well below the standard, at 0.064 parts per million. Furthennore, supporting documentation submitted 

by the Department shows that emissions from this portion of York County do not contribute to ozone 

concentrations in the Charlotte region. A back trajectory modeling analysis indicates that emissions 

from Charlotte, not emissions from eastern York County, are impacting the Charlotte area monitors. The 

EPA should strongly consider this scientific evidence when making this important determination. The 

evidence does not support adding York County to the Charlotte nonattainment area. Furthermore, this 

designation decision is based on an inconsistent application of the factors used to determine 

designations. The EPA should consistently apply its rationale for this and any future decision. 

The Department and York County stakeholders are already taking a proactive approach to air quality 

management. As demonstrated in the past when previously faced with possible nonattainment status, 

South Carolina stakeholders created "Clean Air Coalitions" that continue to focus on multi-pollutant 

strategies to reduce ozone, particulate matter, air toxics concentrations. These coalitions have improved 

air quality and have had a positive impact on public health and the environment. The proposed EPA 

designation for violations not present in York County may discourage future stakeholder involvement. 

A nonattainnient designation would not bring significant environmental benefits. A nonattainment 

designation fur the 2008 ozone NAAQS would not require any further review, controls, or 

implementation of emission reductions in York County. There are no significant environmental benefits 

associated with the EPA's action, only paperwork requirements that would continue the burdensome SIP 

process in York County. Most importantly, a nonattainment designation would have unnecessary 

economic impacts. As President Obama noted in Executive Order 13563, federal agencies should 

consider the costs and benefits of regulations. The Department has shown that this action would have 

negligible benefits, and it would have significant economic impacts. Nonattainroent designations 

generally deter economic development, and the EPA should not sacrifice South Carolina jobs. 

We encourage EPA to make decisions based on the best available science. The designation process for the 

2008 ozone NAAQS presents EPA and the states with an opportunity to work together to allow a common 

sense approach that adequately addresses air quality using the most recent air quality data. This is especially 

important given the fact that EPA is expected to release a revised ozone NAAQS in 2013. Setting this 

precedent nol;v will pay dividends in the future. 

PRINTED ON RECYCLED PAPER
07/19/2012 16:26 FAX 

We are concerned about the direction it appears that the EPA is taking and we are equally concerned that this 

nonattainment designation will disproportionately harm South Carolina's economy without guaranteeing 

effective improvements in air quality. It is for these reasons, on behalf of our constituents, we urge the 

EPA to carefully reconsider this designation and commit to continued discussion with stakeholders to 

evaluate a more appropriate and consistent outcome.