NIKKI R. HALEY GOVERNOR 

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January 25, 2011 Gwendolyn Keyes Fleming, Esq. Regional Administrator US EPA Region 4 Atlanta Federal Center 61 Forsyth Street, S.W. Atlanta, GA 30303-8909 Re: South Carolina Recommendations forNitrogen Dioxide (N02) Boundary Designations Dear Ms. Fleming: I am writing this letter in response to the United States Environmental Protection Agency's (EPA) request to submitboundary recommendations forthe revised I-hour primary National Ambient Air Quality Standard (NAAQS) forNitrogen Dioxide establishedby the EPA via 75 Federal Register 6474, February 9, 2010. Section 107(d)(l) provides that, "By such date as the Administratormay reasonably require, but not laterthan 1 year after promulgation of a new or revised NAAQS for any pollutant under section 109,the Governor of each State shall * * * submit to the Administrator a list ofall areas (orportions thereof) in the State" that should be designated as nonattainment, attainment, or unclassifiable forthe new NAAQS..
..Accordingly, Governors must submittheir initial N02 designationrecommendations to EPA no later than January [25]12011 (75 FR 6520). Given the text ofthe final rule and the deployment of a new N02 near-road monitoring network, the EPA discusses the issue ofboundary recommendations specifically: A near-roadway monitoring network is not expected to be fully deployed until January 2013 therefore, EPA must proceed with initial designations using air quality data from the existing N02 monitoring network. Because none ofthe current N02 monitors are sited to measure near-roadway ambient air, we expect that most areas in the country with currentN02 monitors will not violate the new N02 NAAQS (75 FR 6521).

1Date included in November 12,2010, letter ITomEPA Region 4 Administratorto Governor requesting submission ofN02 Recommendations.

-- --In fact, according to the EPA's websiteZ, there are currently no areas in the U.S. that are designated as nonattainment for the NOzNAAQS. To be sure, after a review ofthe most recent quality-assured air quality data from the current monitoring networkby the staffofthe South Carolina Department of Health and Environmental Control, I am pleased to report that our state is in full compliance with the I-hour primary NAAQS forNOz. With regard to the planned near-roadNOzmonitoring network, South Carolina would like to again3take this opportunityto express its concern. South Carolina, as well as many other states, has fallen upon hard economic times and funding for the essential services that are provided for its citizens is dwindling. The proposedNOzmonitoring network will require adding new monitors or replacing ones already in place that may be serving a specific need orpriority for our state. The siting requirements forthese monitors and the cost to service these monitors will likely lead to further cuts in monitoring of other critical pollutants in order to establish a monitoring networkthat the EPA has not fullyjustified. Based on the aforementionedNOz monitoring information, and the myriad of concerns expressed by its own Clean Air Scientific Advisory Committee (CASAC)4,it would seemprudent forthe EPA to postpone the implementation ofthe newNOz monitoring network. However, should postponement ofthe network notbe an option, at the very least, I am again recommending that the entire State of South Carolinabe designated as "attainment" forthe I-hour primary NAAQS forNOz until such time as certified data demonstrates otherwise. Should you have any questions regarding our recommendation, please contact Myra Reece, Chief, Bureau ofAir Quality, SC Department ofHealth and Environmental Control, at (803) 898-4123 or by email atreecemc@dhec.sc.gov.

NH/mw

cc: C. Earl Hunter, Commissioner, SCDHEC Robert W. King, Jr., P. E. Deputy Commissioner, SCDHEC, EQC Myra C. Reece, Chief, SCDHEC, BAQ

2http://www.epa.gov/airQualitv/greenbook/nindex.html, Accessed November 30,2010. 3 September 9, 2009, DHEC letter, Docket ID No. EPA-HQ-OAR-2006-0922-0378.1 4 Statements made during the August 10, 2009, CASAC Oxides of Nitrogen Primary NAAQS Panel Teleconferenceto Provide Comments Concerning EP A's Proposed Rule on the N02 NAAQS, http://yosemite.epa.gov/sab/sabproduct.nsf/MeetingCaVFBC63 7D2C1B97500852575EF005DBBA9?Ope nDocument, Accessed November 30,2010.