# Recommendations for Designation of Non-Attainment Areas for the 8-Hour Ozone NAAQS

Prepared by: Alabama Department of Environmental Management
March 2009

### ATTACHMENT 1§81.301 Alabama--Ozone (8-Hour Standard)

______________________________________________________________________________ Designation Classification Designated Area Type Type Birmingham Area Jefferson County........... Shelby County.............. Nonattainment Nonattainment
Huntsville Area

Madison County............ Nonattainment

Mobile Area

Mobile County............. Baldwin County........... Nonattainment Nonattainment

Rest of State Autauga County Barbour County Bibb County Blount County Bullock County Butler County Calhoun County Chambers County Cherokee County Chilton County Choctaw County Clarke County Clay County Cleburne County Coffee County Colbert County Conecuh County Coosa County Covington County Crenshaw County Cullman County Dale County Dallas County DeKalb County Elmore County Escambia County Etowah County Fayette County Franklin County Geneva County Greene County Hale County Henry County Houston County Jackson County Lamar County Unclassifiable/Attainment§81.301 Alabama--Ozone (8-Hour Standard) Cont'd

______________________________________________________________________________ Lauderdale County Lawrence County Lee County Limestone County Lowndes County Macon County Marengo County Marion County Marshall County Monroe County Montgomery County Morgan County Perry County Pickens County Pike County Randolph County Russell County St. Clair County Sumter County Talladega County Tallapoosa County Tuscaloosa County Walker County Washington County Wilcox County Winston County Unclassifiable/Attainment

### Alabama Ozone Monitor Locations

## OZONE DATA (2006 to 2008) FO R THE STATE OF ALABAMA

County AIRS ID Site 2006 4 th Max (ppb) 2007 4 th Max (ppb) 2008 4 th Max (ppb) 3 Year Average (ppb)

Sumter 01-119-0002 Gaston 67 69 60 65 Shelby 01-117-0004 Helena 87 94 82 87 Montgomery 01-101-1002 Montgomery 74 80 69 74
Mobile 01-097-2005 Bay Road 80 81 70 77
Mobile 01-097-0003 Chickasaw 85 77 76 79
Baldwin 01-003-0010 Fairhope 81 78 72 77
Elmore 01-051-0001 Wetumpka 72 74 68 71
Jefferson 01-073-1003 Fairfield 84 88 74 82
Jefferson 01-073-2006 Hoover 89 93 79 87
Jefferson 01-073-1005 McAdory 84 91 75 83
Jefferson 01-073-5002 Pinson 78 81 79 79
Jefferson 01-073-6002 Tarrant 88 95 76 86
Jefferson 01-073-5003 Corner 81 90 77 82
Jefferson 01-073-1009 Providence 81 87 74 80
Jefferson 01-073-0023 North Bham 86 93 78 85
Jefferson 01-073-1010 Leeds 75 81 72 76
Madison 01-089-0014 Huntsville 79 82 73 78 Morgan 01-103-0011 Decatur 78 81 68 75

Houston 01-069-0004 Dothan 74 71 66 70
Colbert 01-033-1002 Muscle Shoals 76 76 66 72

Russell 01-113-0002 Phenix City 75 79 69 74
Tuscaloosa 01-125-0010 Tuscaloosa 77 80 68 75
Etowah 05-055-0011 Southside 74 75 64 71 

### Current 8-hour NAAQS for ozone is 75ppb

### Estimated Impact of “On the Way Controls” On 8-Hour Ozone Design Values in Alabama ASIP (Association of Southeastern Integrated Planning) has performed CMAQ Modeling to estimate the impact of various “on the way controls” on future 8- hour ozone levels in 10 Southeastern states including Alabama. The controls include CAIR (Clean Air Interstate Rule) which caps emissions of SO2 and NOx on EGU’s by 2015, the NOx SIP Call, North Carolina CSA (capped SO2 and NOx emissions from two EGU’s), Consent Agreements on several EGU’s, 1-hour Ozone SIPS for Atlanta / Birmingham / N. Kentucky, 2007 emission standards for heavy duty diesel, Tier 2 tailpipe rule for onroad vehicles, large spark ignition and recreational vehicle rule, nonroad diesel rule and VOC 2-, 4-, 7-, 10 year MACT standards. The results show that when the predicted changes in ozone concentrations resulting from these controls are applied to current design values, resulting future year design values in Alabama are below the 8-hour standard. Thus, significant emissions reductions resulting from national and regional initiatives will likely enable all areas of Alabama to attain the 8-hour ozone standard without additional local controls. Since additional local controls are unlikely to be required in order for local areas to meet the NAAQS, it seems unnecessary to designate any counties as non-attainment areas except those with monitored data exceeding the standard. These results are discussed in more detail below. Model Assumptions

• CMAQ (version 4.5.1)

• Episodes modeled- contiguous year 2012

• 2012 Base Modeling

• Grid Resolution (MM5)

• 36 kilometer grid/with 12 kilometer grid

• 19 vertical layers up to 15 kilometers

• CAIR

• NOx SIP Call

• North Carolina CSA

• Consent Agreements (APCO Plant Miller)

• One-hour Ozone SIPs (Atlanta / Birmingham / N. Kentucky)

• Heavy Duty Diesel Engine Standard (2007) for onroad trucks and buses

• Tier 2 Tailpipe (Onroad vehicles)

• Large Spark Ignition and Recreational Vehicle Rule

• Nonroad Diesel Rule

• VOC 2-, 4-, 7- and 10-year MACT Standards Projected 2012 design values were calculated using relative reduction factors obtained from the ASIP modeling and the current design values*. The resulting 2012 design values for the entire state of Alabama are below the new 8-hour

### ozone standard (75 ppb) and demonstrate no need for further local controls. The results of this analysis are presented in the table below, which shows new design values for the base year 2012 calculated using the current design values* and the relative reduction factor (RRF) obtained by modeling the base year with the controls listed previously.

County Monitor Current Design Value (ppb)* 2012 Base RRF New Design Value 2012(ppb) Baldwin Fairhope 78 0.8857 69 Elmore Wetumpka 76.7 0.8249 63.2 Etowah Southside 75 0.8474 63.5 Jefferson N. Birmingham 77 0.8389 64.5 Jefferson Fairfield 79 0.8306 65.6 Jefferson McAdory 80 0.8247 65.9 Jefferson Providence 81.3 0.7865 63.9 Jefferson Leeds 72.5 0.8408 60.9 Jefferson Hoover 83.7 0.8434 70.5 Jefferson Pinson 78.7 0.8397 66 Jefferson Corner 79.7 0.7773 61.9 Jefferson Tarrant 78.7 0.8514 67 Lawrence Sipsey 76.3 0.815 62.1 Madison Huntsville 79.7 0.8145 64.9 Mobile Chickasaw 77.7 0.8727 67.8 Mobile Bay Road 79 0.8772 69.2 Montgomery Montgomery 75 0.8318 62.3 Morgan Decatur 82 0.8149 66.8 Shelby Helena 88 0.8338 73.3 Sumter Sumter 71.7 0.8139 58.3 Tuscaloosa Tuscaloosa 75.5 0.8061 60.8 Muscogee, GA Columbus Airport 75 0.8542 64 Muscogee, GA Columbus Crime Lab 75 0.8575 64.3 *The current year 8-hour ozone Design Value (DVC) is based on the average of three years of Design Values from 2000-2002, 2001-2003 and 2002-2004.

## 8-Hour Ozone Concentrations in Areas Adjoining Alabama

As indicated in the table below, there are several counties bordering Alabama monitoring nonattainment for the 8-hour ozone standard. The map on the following page details the location of these counties in relation to the State. According to EPA’s guidance (Dec. 4, 2008), presumptive bounda ries for NAA designations are based on Combined Statistical Area boundaries. The violating monitor locations provided below are not included in any CSA in Alabama, wi th the exception of Muscogee Co. GA, to which discussion has been provided in Appendix D.

County Site 3 Year Average(ppb) Muscogee Co, GA Columbus Airport 78 Muscogee Co, GA Columbus Crime Lab 72 Escambia Co, FL Ellyson 79 Escambia Co, FL NAS 79 Escambia Co, FL Warrington 77 Santa Rosa Co, FL Holly Navarre 81 Jackson Co, MS Pascagoula 78 Lauderdale Co, MS Meridian 71 Chattooga Co, GA Summerville 73 Holmes Co, FL Bonifay 71

## Appendix A

### ADEM recommends that the Birmingham Nonatta inment Area (NAA) for the 8-hour NAAQS for ozone exclude the following counties in the Birmingham CSA: Bibb, Blount, Walker, Cullman, Chilton, and St. Clair Counties. EPA guidance (dated December 4, 2008) states that if a State wishes to propose a nonattainment area boundary smaller than the CSA boundary, the State must address how certain factors affect the drawing of the nonattainment boundary. Full discussion of each of these factors for the Birmingham NAA is provided in this Appendix. The factors that provide the most compelling evidence to exclude Blount, Walker, Cullman, Chilton, Bibb, and St. Clair Counties are listed below:

• Total annual emissions of NO x 

### and VOC in comparison to Jefferson and Shelby Counties

• Population density and degree of urbanization in comparison to Jefferson and Shelby Counties

• Location of emission sources (i.e. the lack of significant point sources)

• Limited expected growth

• Traffic (Daily VMT)

• Meteorology

• Level of control of emission sources

• Regional emission reductions

A-1

### A. Emissions in the Birmingham CSA The counties in the Birmingham CSA are depicted in Figure 1. To evaluate emissions for these counties, ADEM obtained the 2005 annual NO x 

### and VOC emission estimates from the National Emissions Inventory (NEI). Table 1 lists these emissions which include all anthropogenic sources (i.e. point, area, mobile, and nonroad mobile) for the counties in the Birmingham CSA.

Figure 1 Birmingham CSA

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### Table 1 Annual Emissions for the Birmingham CSA County 2005 Annual VOC Emissions (Tons) Ranking for VOC 2005 Annual NO x 

### Emissions (Tons) Ranking for NO x 

### Bibb 1,579 8 941 8 

### Blount 3,364 7 2,500 7 

### Chilton 3,586 6 2,594 6 

### Cullman 7,775 3 3,508 5 

### St.Clair 5,657 4 6,375 4 

### Walker* 5,023 5 16,558 3 

### Shelby* M 10,492 2 38,692 2 

### Jefferson* M 44,015 1 56,520 1 

### *County has one or more utility plants located within its boundary M 

### County has an ozone monitor

As shown in Table 1, the total emissions in Bibb, Blount, Chilton, Cullman, Walker and St.Clair Counties are significantly less than the emissions in Jefferson and Shelby Counties. Given the total amount of emissions in these counties, it is unlikely that these emissions contribute significantly to the air quality outside their boundaries. Bibb, Blount, Chilton, Cullman, Walker and St.Clair Counties account for only 33% of the total VOC emissions and only 25% of the NO x 

### emissions in the CSA. The impact of Walker County NOx emissions has been lessened by controls placed on Gorgas Steam Plant beginning in May 2003. These contro ls, which include low NOx burners installed on Units 6 and 7 and a SCR installed on the largest unit, Unit 10, were mandated by the 1-hour Ozone Attainment SIP for the Birmingham NAA and the Clean Air Interstate Rule (CAIR). Plant Gorgas also has permitted ozone season NOx limits based on a 30-day rolling average NOx emission rate averaged across all units. The only ozone monitors in the Birmingham CSA are located in Jefferson and Shelby Counties. Because of the lack of monitored air quality data for Bibb, Blount, Chilton, Cullman, Walker, and St. Clair, no conclusion can be made as to the air quality in these individual counties. Several other factors will be used in this Appendix to demonstrate that these counties do not significantly impact the violating monitors in Jefferson and Shelby Counties.

A-3

### B. Population Density and degree of urbanization including commercial development (significant diffe rence from surrounding areas) To evaluate the various aspects of population, ADEM obtained the 2000 to 2007 population estimates for the Birmingham CSA from the Alabama State Data Center 1 

### . Information on business data (i.e. retail employment and manufacturing employment) was obtained from the U.S. Census Bureau's County Business Patterns

. Population densities were calculated by dividing the population estimates by the land area of each county (in square miles). Figure 2 depicts the population densities for the counties in the Birmingham CSA. Bibb, Blount, Chilton, and, Walker Counties have much smaller population densities than either Jefferson or Shelby County. While Cullman and St. Clair Counties contribute values slightly less than Shelby County, they both are largely insignificant in comparison to Jefferson County. This population density factor fortifies the recommendation to exclude Bibb, Blount, Chilton, Cullman, St.Clair and Walker from the Birmingham Nonattainment Area

. Population trends/data are presented as Figures 3 and 4. Figure 3 demonstrates that Bibb, Blount, Chilton, Cullman, Walker and St. Clair Counties each have a population that has remained less than 45% of Shelby County's population and less than 13% of Jefferson County's population over the years. In addition, Figure 4 demonstrates that the combined population of Bibb, Blount, Cullman, Chilton, Walker and St. Clair Counties only represents approximately 29% of the total population for the entire Birmingham CSA. These population factors fortify the recommendation to exclude Bibb, Blount, Cullman, Chilton, Walker, and St. Clair Counties from the Birmingham Nonattainment Area

. The amount and percentage of urban population in the Birmingham CSA is presented in Table 2. This data clearly shows that Bibb, Blount, Ch ilton, Cullman, Walker and St. Clair Counties have an insignificant urban population in comparison to that of Jefferson and Shelby. In addition, the combined urban population of Bibb, Blount, Cullman, Chilton, Walker and St. Clair Counties only represents approximately 40% of the total urban population for the entire Birmingham CSA. This factor fortifies the recommendation to exclude Bibb, Blount, Chilton, Cullman, St. Clair, and Walker Counties from the Birmingham Nonattainment Area

. Table 2 Urban Population for the Birmingham CSA

2007 % Urban 2007 Urban Area % of CSA Total 2007 Urban Population

. Bibb Co 21,535 19% 4,092 0.5%

. Blount Co 56,614 9% 5,095 0.7%

. Chilton Co 42,299 12% 5,076 0.7%

. Cullman Co 80,554 24% 19,333 2.5%

. Jefferson Co 658,779 89% 586,313 76.9%

. St. Clair Co 78,054 13% 10,147 1.3%

. Shelby Co 182,113 64% 116,552 15.3%

. Walker Co 68,816 23% 15,828 2.1% CSA Total 1,188,764 64% 762,436 100.0%

1 The Alabama State Data Center (ASD C) is a network of 27 public agencies working together through a cooperative agreement with the U.S. Bureau of the Census to facilitate use and delivery of Census and other data to the public. Internet site: http://cber.cba.ua.edu/est_prj.html

2 Based on 2000 U.S. Census 

### A-4

### Figure 2 Population Density for the Birmingham CSA

0 100 200 300 400 500 600 700Population per Square Mile Birmingham CSA Population Density

Bibb Co 35 34 34 34 34 34 34 32 Blount Co 88 86 85 84 83 82 81 79 Chilton Co 61 60 60 59 59 58 58 57 Cullman Co 109 108 107 107 106 105 105 105 Jefferson Co 592 593 592 593 593 593 594 595 St. Clair Co 123 118 114 110 108 106 104 103 Shelby Co 229 223 214 207 200 193 188 182 Walker Co 87 87 87 87 88 88 89 89 2007 2006 2005 2004 2003 2002 2001 2000

0 100,000 200,000 300,000 400,000 500,000 600,000 700,000Population Birmingham CSA Population Trends

Bibb Co 19,939 20,947 20,994 21,051 21,227 21,397 21,341 21,535 Blount Co 51,184 51,996 52,767 53,705 54,441 54,983 55,811 56,614 Chilton Co 39,777 40,029 40,463 40,778 41,161 41,482 41,750 42,299 Cullman Co 77,581 77,672 77,835 78,126 78,718 79,368 79,790 80,554 Jefferson Co 662,201 661,399 659,535 660,074 659,340 658,638 659,777 658,779 St. Clair Co 65,079 66,015 67,100 68,303 69,984 72,025 74,954 78,054 Shelby Co 144,540 149,073 153,520 158,981 164,828 170,490 177,305 182,113 Walker Co 70,685 70,594 70,132 69,561 69,216 69,203 69,133 68,816 2000 2001 2002 2003 2004 2005 2006 2007



### Figure 3 Population Data for the Birmingham CSA

A-5Birmingham CSA Population Trends

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Population

Walker Co 70,685 70,594 70,132 69,561 69,216 69,203 69,133 68,816 Shelby Co 144,540 149,073 153,520 158,981 164,828 170,490 177,305 182,113 St. Clair Co 65,079 66,015 67,100 68,303 69,984 72,025 74,954 78,054 Jefferson Co 662,201 661,399 659,535 660,074 659,340 658,638 659,777 658,779 Cullman Co 77,581 77,672 77,835 78,126 78,718 79,368 79,790 80,554 Chilton Co 39,777 40,029 40,463 40,778 41,161 41,482 41,750 42,299 Blount Co 51,184 51,996 52,767 53,705 54,441 54,983 55,811 56,614 Bibb Co 19,939 20,947 20,994 21,051 21,227 21,397 21,341 21,535 2000 2001 2002 2003 2004 2005 2006 2007



### Figure 4 Population Distribution for the Birmingham CSA

Tables 3, 4, and 5 show the trends in Total Em ployment, Manufacturing Employment, and Retail Employment, respectively, for the counties in th e Birmingham CSA. Figure 5 demonstrates that the number of Total Employees for Bibb, Blount, Cullman, Chilton, Walker and St. Clair Counties is not substantial in comparison to Jefferson and Shelby Counties. This factor fortifies the recommendation to exclude Bibb, Blount, Chilton, Cullman, Walker, and St. Clair Counties from the Birmingham Nonattainment Area

. All counties in the Birmingham CSA experienced slight growth in total employment, with the exception of Blount County (-5%). 74% of manufacturing employees are located in Jefferson and Shelby Counties while the remaining counties in the Birmingham CSA combine to contribute only 26%. This trend is also mirrored in retail employment for the Birmingham CSA, with Jefferson and Shelby accounting for 80% and Bibb, Blount, Chilton, Cullman, St. Clair and Walker Counties supplying just 20%. These facts further fortify the recommendation to exclude Bibb, Blount, Chilton, Cullman, Walker and St. Clair Counties from the Birmingham Nonattainment Area.

A-6

### Table 3 Total Employees

2002 2003 2004 2005 2006 % Change 2002-2006 % of 2006 CSA Total Bibb 2,586 2,999 3,202 3,142 3,132 21% 1% Blount 6,973 6,640 6,441 6,741 6,629 -5% 1% Chilton 6,495 6,741 7,104 7,216 7,588 17% 2% Cullman 22,437 22,952 22,764 22,859 23,753 6% 5% Jefferson 346,939 339,294 349,712 347,274 350,744 1% 71% Shelby 61,665 64,871 66,058 68,712 71,240 16% 14% St.Clair 11,197 11,771 12,988 11,799 12,765 14% 3% Walker 15,070 15,515 15,557 16,469 16,641 10% 3%

MSA Total 473,362 470,783 483,826 484,212 492,492 4% 100%



### Table 4 Manufacturing Employees

2002 2003 2004 2005 2006 % Change 2002-2006 % of 2006 CSA Total Bibb 302 429 353 383 424 40% 1% Blount 1,655 1,334 1,148 1,214 1,216 -27% 3% Chilton 1,197 1,385 1,493 1,585 1,726 44% 4% Cullman 4,981 4,779 4,583 4,659 5,023 1% 10% Jefferson 30,650 29,659 28,582 29,369 29,447 -4% 61% Shelby 5,577 5,728 5,758 5,937 6,223 12% 13% St.Clair 2,625 2,594 2,816 2,419 2,312 -12% 5% Walker 1,454 1,646 1,539 1,603 1,640 13% 3% CSA Total 48,441 47,554 46,272 47,169 48,011 -1% 100%



### Table 5 Retail Employees

2002 2003 2004 2005 2006 % Change 2002-2006 % of 2006 CSA Total Bibb 518 552 541 548 569 10% 1% Blount 1,264 1,221 1,233 1,248 1,273 1% 2% Chilton 1,543 1,405 1,483 1,469 1,557 1% 2% Cullman 3,781 3,678 3,605 3,631 3,706 -2% 5% Jefferson 42,374 42,346 44,302 43,066 43,609 3% 65% Shelby 7,787 8,111 9,648 9,437 10,365 33% 15% St.Clair 1,464 1,618 1,930 1,774 2,526 73% 4% Walker 3,705 3,729 3,702 3,719 4,002 8% 6% CSA Total 62,436 62,660 66,444 64,892 67,607 8% 100%



### A-7

### A-8 Birmingham CSA Employee Trends

0 50,000 100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000Number of Total Employees

Walker 15,070 15,515 15,557 16,469 16,641 St.Clair 11,197 11,771 12,988 11,799 12,765 Shelby 61,665 64,871 66,058 68,712 71,240 Jefferson 346,939 339,294 349,712 347,274 350,744 Cullman 22,437 22,952 22,764 22,859 23,753 Chilton 6,495 6,741 7,104 7,216 7,588 Blount 6,973 6,640 6,441 6,741 6,629 Bibb 2,586 2,999 3,202 3,142 3,132 2002 2003 2004 2005 2006



### Figure 5 Total Employees for the Birmingham CSA

### C. Monitoring data representing ozone con centrations in local areas and larger areas (urban or regional scale) Table 6 demonstrates that all of the ozone moni tors in Jefferson and Shelby Counties exceed the 8-hour NAAQS for ozone. Figure 6 identifies the ozone monitoring sites which provided the 2006, 2007, and 2008 data for the Birmingham CSA. During this time period, all ozone monitoring sites were located in Jefferson and Shelby Counties. The recommendation to exclude Bibb, Blount, Chilton, Cullman, Walker, and St. Clair was not influenced by monitoring data because of the lack of ozone monitoring data outside of Jefferson and Shelby Counties.
Table 6 Birmingham CSA Ozone Monitoring Data

County AIRS ID Site 2006 4 th Max (ppm) 2007 4 th Max (ppm) 2008 4 th Max (ppm) 3 Year Average (ppm)
Jefferson 01-073-1003 Fairfield 0.084 0.088 0.074 0.082 Jefferson 01-073-2006 Hoover 0.089 0.093 0.079 0.087 Jefferson 01-073-1005 McAdory 0.084 0.091 0.075 0.083 Jefferson 01-073-5002 Pinson 0.078 0.081 0.079 0.079 Jefferson 01-073-6002 Tarrant 0.088 0.095 0.076 0.086 Jefferson 01-073-5003 Corner 0.081 0.090 0.077 0.082 Jefferson 01-073-1009 Providence 0.081 0.087 0.074 0.080 Jefferson 01-073-0023 North Bham 0.086 0.093 0.074 0.084 Jefferson 01-073-1010 Leeds 0.075 0.081 0.072 0.076 Shelby 01-117-0004 Helena 0.087 0.094 0.082 0.087



### Figure 6 Ozone Monitoring Sites in the Birmingham CSA

A-9

### D. Location of Emission Sources Figure 7 depicts the location of large point sources in the Birmingham CSA and surrounding counties. The base map was created using G eographical Information Systems (GIS) with coordinates supplied by the facilities. Tables 7 and 9 present the distribution of NO x 

### emissions (in tons per year) among point, area, non-road and mobile sources in the Birmingham CSA. Tables 8 and 10 present the same information for VOC emissions. Figures 9 and 10 illustrate this data. Figure 8 presents the emission densities for the counties in the Birmingham CSA. Bibb, Blount, Chilton, Cullman, Walker and St. Clair Counties account for only 25% of the total annual NO x 

### emissions and 33% of the total annual VOC emissions in the Birmingham CSA. Each county also has a smaller emissions density than Jefferson and Shelby Counties. The lack of large point sources of NO x 

### or VOC emissions located in Bibb, Blount, Chilton, Cullman, and St. Clair Counties, the minimal area and mobile source emissions, and the smaller emissions densities fortify the recommendation to exclude Bibb, Blount, Chilton, Cullman, Walker and St. Clair Counties from the Birmingham NAA

.

Figure 7 Location of Large Points Sources in the Birmingham CSA

A-10

### Table 7 NOx Annual Emissions (Tons)

FIPs County Point Area Mobile Non-Road Total Emissions 01007 Bibb Co 26 0% 118 2% 551 2% 246 2% 941 1% 01021 Chilton Co 271 0% 291 5% 1,661 5% 371 2% 2,594 2% 01043 Cullman Co 216 0% 537 8% 2,142 7% 612 4% 3,508 3% 01115 St.Clair Co 1,590 2% 370 6% 2,741 9% 1,674 11% 6,375 5% 01117 Shelby Co 31,969 43% 725 11% 3,470 11% 2,527 16% 38,692 30% 01127 Walker Co 13,009 17% 558 9% 1,792 6% 1,199 8% 16,558 13% 01009 Blount Co 0 0% 476 7% 1,479 5% 545 3% 2,500 2% 01073 Jefferson Co 28,000 37% 3,348 52% 16,721 55% 8,451 54% 56,520 44%

CSA Total Emissions 75,082 6,423 30,557 15,625 127,688 

### Table 8 VOC Annual Emissions (Tons)

FIPs County Point Area Mobile Non-Road Total Emissions 01007 Bibb Co 70 1% 1,077 2% 304 1% 128 1% 1,579 2% 01021 Chilton Co 415 6% 2,024 5% 890 4% 257 3% 3,586 4% 01043 Cullman Co 489 7% 4,998 11% 1,221 6% 1,066 11% 7,775 10% 01115 St.Clair Co 275 4% 3,133 7% 1,493 7% 756 8% 5,657 7% 01117 Shelby Co 466 7% 5,050 11% 2,181 11% 2,795 28% 10,492 13% 01127 Walker Co 277 4% 3,083 7% 1,155 6% 507 5% 5,023 6% 01009 Blount Co 0 0% 2,332 5% 788 4% 243 2% 3,364 4% 01073 Jefferson Co 4,726 70% 22,711 51% 12,305 61% 4,272 43% 44,015 54% CSA Total Emissions 6,718 44,409 20,339 10,025 81,492



### Figure 8 Emission Density for the Birmingham CSA

Emission Density (Based on 2005 Emissions)

3 5 11 9 13 6 5 40

2 4 5 10 49 21 4 51

0 1 0 2 0 3 0 4 0 5 0 6 Bibb Co Chilton Co Cullman Co St.Clair Co Shelby Co Walker Co Blount Co Jefferson Co

Annual Tons per Square Mile 0

VOC Emission Density NOx Emission Density 

### T A-11

### Table 9 Cumulative NOx Contributions

County Name Factor Annual 2005 Emissions (Tons) % of CSA Total Emissions Cumulative % Shelby Co Point Source NO x Emissions 31,969 25.04% 25.04%
Jefferson Co Point Source NO x Emissions 28,000 21.93% 46.97%
Jefferson Co Mobile Sources NO x Emissions 16,721 13.10% 60.06%
Walker Co Point Source NO x Emissions 13,009 10.19% 70.25%
Jefferson Co Non-Road NO x Emissions 8,451 6.62% 76.87% Shelby Co Mobile Sources NO x Emissions 3,470 2.72% 79.59%
Jefferson Co Area Source NO x Emissions 3,348 2.62% 82.21%
St. Clair Co Mobile Sources NO x Emissions 2,741 2.15% 84.36% Shelby Co Non-Road NO x Emissions 2,527 1.98% 86.34%
Cullman Co Mobile Sources NO x Emissions 2,142 1.68% 88.01%
Walker Co Mobile Sources NO x Emissions 1,792 1.40% 89.42%
St. Clair Co Non-Road NO x Emissions 1,674 1.31% 90.73%
Chilton Co Mobile Sources NO x Emissions 1,661 1.30% 92.03%
St.Clair Co Point Source NO x Emissions 1,590 1.25% 93.27%
Blount Co Mobile Sources NO x Emissions 1,479 1.16% 94.43%
Walker Co Non-Road NO x Emissions 1,199 0.94% 95.37% Shelby Co Area Source NO x Emissions 725 0.57% 95.94%
Cullman Co Non-Road NO x Emissions 612 0.48% 96.42%
Walker Co Area Source NO x Emissions 558 0.44% 96.86%
Bibb Co Mobile Sources NO x Emissions 551 0.43% 97.29%
Blount Co Non-Road NO x Emissions 545 0.43% 97.71%
Cullman Co Area Source NO x Emissions 537 0.42% 98.14%
Blount Co Area Source NO x Emissions 476 0.37% 98.51%
Chilton Co Non-Road NO x Emissions 371 0.29% 98.80%
St.Clair Co Area Source NO x Emissions 370 0.29% 99.09%
Chilton Co Area Source NO x Emissions 291 0.23% 99.32%
Chilton Co Point Source NO x Emissions 271 0.21% 99.53%
Bibb Co Non-Road NO x Emissions 246 0.19% 99.72%
Cullman Co Point Source NO x Emissions 216 0.17% 99.89%
Bibb Co Area Source NO x Emissions 118 0.09% 99.98%
Bibb Co Point Source NO x Emissions 26 0.02% 100.00%
Blount Co Point Source NO x Emissions 0 0.00% 100.00%
CSA Total Emissions 127,689



### A-12

### Table 10 Cumulative VOC Contributions

County Name Factor Annual 2005 Emissions (Tons) % of CSA Total Emissions Cumulative %
Jefferson Co Area Source VOC Emissions 22,711 27.87% 27.87%
Jefferson Co Mobile Source VOC Emissions 12,305 15.10% 42.97% Shelby Co Area Source VOC Emissions 5,050 6.20% 49.17%
Cullman Co Area Source VOC Emissions 4,998 6.13% 55.30%
Jefferson Co Point Source VOC Emissions 4,726 5.80% 61.10%
Jefferson Co Non-Road VOC Emissions 4,272 5.24% 66.34%
St.Clair Co Area Source VOC Emissions 3,133 3.84% 70.19%
Walker Co Area Source VOC Emissions 3,083 3.78% 73.97% Shelby Co Non-Road VOC Emissions 2,795 3.43% 77.40%
Blount Co Area Source VOC Emissions 2,332 2.86% 80.26% Shelby Co Mobile Source VOC Emissions 2,181 2.68% 82.94%
Chilton Co Area Source VOC Emissions 2,024 2.48% 85.42%
St. Clair Co Mobile Source VOC Emissions 1,493 1.83% 87.26%
Cullman Co Mobile Source VOC Emissions 1,221 1.50% 88.75%
Walker Co Mobile Source VOC Emissions 1,155 1.42% 90.17%
Bibb Co Area Source VOC Emissions 1,077 1.32% 91.49%
Cullman Co Non-Road VOC Emissions 1,066 1.31% 92.80%
Chilton Co Mobile Source VOC Emissions 890 1.09% 93.89%
Blount Co Mobile Source VOC Emissions 788 0.97% 94.86%
St. Clair Co Non-Road VOC Emissions 756 0.93% 95.79%
Walker Co Non-Road VOC Emissions 507 0.62% 96.41%
Cullman Co Point Source VOC Emissions 489 0.60% 97.01% Shelby Co Point Source VOC Emissions 466 0.57% 97.58%
Chilton Co Point Source VOC Emissions 415 0.51% 98.09%
Bibb Co Mobile Source VOC Emissions 304 0.37% 98.47%
Walker Co Point Source VOC Emissions 277 0.34% 98.81%
St.Clair Co Point Source VOC Emissions 275 0.34% 99.14%
Chilton Co Non-Road VOC Emissions 257 0.32% 99.46%
Blount Co Non-Road VOC Emissions 243 0.30% 99.76%
Bibb Co Non-Road VOC Emissions 128 0.16% 99.91%
Bibb Co Point Source VOC Emissions 70 0.09% 100.00%
Blount Co Point Source VOC Emissions 0 0.00% 100.00%
CSA Total Emissions 81,491



### A-130 10,000 20,000 30,000 40,000 50,000 60,000Tons per Year Birmingham CSA - NO x Emissions Distribution (2005)

Non-Road 8,451 2,527 1,199 1,674 371 612 246 545 Mobile 16,721 3,470 1,792 2,741 1,661 2,142 551 1,479 Area 3,348 725 558 370 291 537 118 476 Point 28,000 31,969 13,009 1,590 271 216 26 0 Jefferson Co Shelby Co Walker Co St.Clair Co Chilton Co Cullman Co Bibb Co Blount Co



### Figure 9 NO x 

### Emissions for the Birmingham CSA

0 5,000 10,000 15,000 20,000 25,000 30,000 35,000 40,000 45,000Tons per Year Birmingham CSA - VOC Emissions Distribution (2005)

Non-Road 4,272 2,795 1,066 257 507 756 128 243 Mobile 12,305 2,181 1,221 890 1,155 1,493 304 788 Area 22,711 5,050 4,998 2,024 3,083 3,133 1,077 2,332 Point 4,726 466 489 415 277 275 70 0 Jefferson Co Shelby Co Cullman Co Chilton Co Walker Co St.Clair Co Bibb Co Blount Co



### Figure 10 VOC Emissions for the Birmingham CSA

A-14

### E. Traffic and Commuting Patterns Estimates of the Daily Vehicle Miles Traveled (DVMT) were obtained from the Alabama Department of Transportation and the commuting patterns were obtained from the U.S. Census Bureau web site. The commuting patterns were based on the 2000 U.S. Census. Table 11 presents the 1997 and 2007 Daily VMT estimates for the counties in the Birmingham CSA, and Figure 11 demonstrates the trends from 1997 to 2007 for each county. Figure 12 presents the breakdown of 2007 DVMT into urban and rural. Figure 13 presents the commuting patterns among the counties in the Birmingham CSA. Table 11 shows that the DVMT for Bibb, Blount, Chilton, Cullman, Walker and St. Clair Counties combined comprise approximately 32% of the Daily VMT for the Birmingham CSA. Figure 12 demonstrates that Bibb, Blount, and Chilton Counties have no urban DVMT and Cullman, St. Clair, and Walker Counties have only a minimal amount of urban DVMT. The low percentage of DVMT and the limited amount of urban DVMT fortify the recommendation to exclude Bibb, Blount, Cullman, Chilton, Walker and St. Clair Counties from the Birmingham Nonattainment Area

. Table 11 Daily VMT for the Birmingham CSA

County 1997 Daily VMT 2007 Daily VMT Daily VMT Change (1997-2007) % Change % of CSA 2007 Daily VMT

Blount 1,493,996 1,736,551 242,555 16% 4% Jefferson 21,156,010 23,956,173 2,800,163 13% 56%

Shelby 3,651,901 4,843,841 1,191,940 33% 11% St.Clair 2,585,118 3,326,548 741,430 29% 8% Walker 2,119,281 2,557,783 438,502 21% 6% Chilton 1,717,290 2,194,979 477,689 28% 5% Cullman 2,429,603 3,029,867 600,264 25% 7%

Bibb 621,840 807,212 185,372 30% 2% CSA Total 35,775,039 42,452,954 6,677,915 19% 100% 

### Figure 11 Daily VMT Trend for the Birmingham CSA

A-15 Birmingham CSA Daily VMT

0 5,000,000 10,000,000 15,000,000 20,000,000 25,000,000Vehicle Miles Traveled

Blount 1,493,996 1,542,384 1,571,675 1,579,631 1,576,698 1,590,667 1,594,687 1,552,548 1,557,438 1,563,617 1,736,551

Jefferson 21,156,010 21,690,292 21,951,545 21,953,933 22,148,272 22,462,846 22,617,315 20,400,020 21,028,626 21,185,334 23,956,173 Shelby 3,651,901 3,779,696 3,855,247 3,906,718 4,098,753 4,135,243 4,235,533 4,412,909 4,524,384 4,489,334 4,843,841 St.Clair 2,585,118 2,791,197 2,894,061 2,886,654 2,962,332 2,996,080 3,078,935 2,990,525 2,994,832 1,604,914 3,326,548 Walker 2,119,281 2,250,681 2,251,511 2,249,780 2,193,250 2,201,665 2,187,722 2,481,539 2,605,589 2,179,480 2,557,783 Chilton 1,717,290 1,753,198 1,799,589 1,794,546 1,858,548 1,765,198 1,847,508 1,839,756 1,831,512 1,850,964 2,194,979 Cullman 2,429,603 2,478,120 2,565,204 2,590,801 2,549,781 2,644,284 2,674,220 2,612,987 2,659,238 2,665,832 3,029,867 Bibb 621,840 631,766 624,276 644,770 669,694 650,576 652,121 621,517 637,874 630,291 807,212 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007Birmingham CSA Daily VMT Distribution (2007)

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Vehicle Miles Traveled

Urban Daily VMT 2007 0 43,472,501 6,037,066 1,258,463 1,257,672 0 2,012,217 0 Rural Daily VMT 2007 1,736,551 4,439,845 3,650,615 5,394,633 3,857,893 2,194,979 4,047,517 807,212 Blount Jefferson Shelby St.Clair Walker Chilton Cullman Bibb



### Figure 12 Rural vs. Urban Daily VMT for the Birmingham CSA

Birmingham CSA Commuting Patterns (Based on 2000 Census Data)

0% 20% 40% 60% 80% 100%

Works in Jefferson Co. 1,849 9,669 2,552 2,851 265,661 37,119 12,870 6,746 Works in Walker Co. 33 75 0 198 735 28 11 17,293 Works in St. Clair Co. 9 237 14 9 1,363 321 10,648 68 Works in Shelby Co. 1,116 312 3,747 219 17,351 32,573 1,256 245 Works in Cullman Co. 0 820 16 24,760 405 36 13 353 Works in Chilton Co. 183 16 8,115 23 73 249 13 20 Works in Blount Co. 13 8,966 15 522 550 27 290 47 Works in Bibb Co. 3,199 2 149 0 114 112 2 2 Resides in Bibb Co. Resides in Blount Co. Resides in Chilton Co. Resides in Cullman Co. Resides in Jefferson Co. Resides in Shelby Co. Resides in St. Clair Co. Resides in Walker Co.



### Figure 13 Commuting Patterns for the Birmingham CSA Although Figure 13 i nd St. Clair ndicates that there is significant commuting from Blount a Counties into Jefferson County, the impact of this commuting is lessened by Tier II and the national low sulfur fuel standards. Therefore, this factor was not considered to play a significant role in the recommendation to exclude Blount and St. Clair Counties from the Birmingham

A-16

### Nonattainment Area. This factor fortifies the recommendation to exclude Bibb, Chilton, Cullman, and Walker Counties from t he Birmingham Nonattainment Area.



### F. Expected Growth (i ncluding extent, pattern, and rate of growth) There is little information available about expec ted growth. Table 12 provides population growth estimates that were supplied by the Alabama Data Center. The estimates show significant growth expected for Bibb, Blount, Chilton, St. Clair and Shelby Counties, with the most significant growth expected in Shelby County. Since no other information about expected growth is available, and population growth estimates are not enough to influence a decision about designating a nonattainment area, this factor presents no compelling reason to include Bibb, Blount, Chilton, Cullman, Walker and St. Clair Counties in the Birmingham Nonattainment Area. Table 12 Population Projections for the Birmingham CSA County Name 2000 2007 2015 2025 % Change 2000-2007 % Change 2007-2015 % Change 2015-2025 Bibb Co 20,826 21,535 26,910 30,749 3.4% 25.0% 14.3% Blount Co 51,024 56,614 70,005 81,713 11.0% 23.7% 16.7% Chilton Co 39,593 42,299 51,347 59,022 6.8% 21.4% 14.9% Cullman Co 77,483 80,554 91,341 98,897 4.0% 13.4% 8.3% Jefferson Co 662,047 658,779 682,336 701,651 -0.5% 3.6% 2.8% St. Clair Co 64,742 78,054 87,614 102,121 20.6% 12.2% 16.6% Shelby Co 143,293 182,113 216,308 265,083 27.1% 18.8% 22.5% Walker Co 70,713 68,816 73,529 73,970 -2.7% 6.8% 0.6%


### G. Meteorology It is known that meteorology plays a major role in the formation and transport of ozone. In the Birmingham area, wind direction and speed are important indicators to where ozone forms and travels. In the 2006-2008 ozone seasons, ozone levels exceeded the new 8-hour standard (75 ppb) on sixty four days over the three-year period. A wind analysis was accomplished to determine the extent to which wind directions could be correlated with high ozone. During the last three ozone seasons, the May – September winds in the Birmingham area had a predominant wind direction out of the north, and a marked minimum frequency of winds blowing from the northwest (see Figure A-1). In addition, there are two secondary wind directions, one from the east and one from the west. When one considers only the daytime (6AM-6PM) winds (Figure A-2), the general pattern changes very little. However, on those days when the 8-hour ozone standard was exceeded in the Birmingham area, the wind blew overwhelmingly from the north with the east to south directions showing up somewhat as well. This phenomenon is clearly seen in Figure A-3 (all hours) and Figure A-4 (daytime hours only). Also of note is the number of calms during the daytime on exceedance days. It’s almost twice as much as it is on a non-exceedance day. In addition to the wind roses, back trajectories were run using the National Oceanic and Atmospheric Administration HYSPLIT model to verify the wind directions on exceedance days and to show any other important wind patterns observed in and around the Birmingham area. As illustrated in the modeled back trajectories in Figures A-5 through A-15, the predominant north wind is present along with the east and south directions. The westerly wind illustrated in the wind roses is also observed but more importantly this west wind shows up mostly when

A-17

### there is recirculation. This recirculation plays a huge role in the build up of ozone in and around the Birmingham monitors on high ozone days.


### H. Geography/Topography (mountain ranges or other air basin boundaries) The geography/topography of an area can influence the creation and transport of ozone. The Birmingham CSA is located in North Central Alabama in both Jefferson and Shelby counties. The city is situated in the foothills of the Appalachians, about 300 miles inland from the Gulf of Mexico. With the hills running northeast to southwest, the city itself lies in the Birmingham-Big Canoe Valley. Off to the north and west the terrain levels out to the Cumberland Plateau. To the south and east, there is rougher terrain, such as the Cahaba Ridge and Valley and the Coosa Ridge and Valley. The northwestern half of Jefferson County is included in the Cumberland Plateau, while all of Shelby County consists of several ridges and valleys.



### I. Jurisdictional Boundaries Within the Birmingham Combined Statistical Area, Jefferson and Shelby Counties are currently violating the 8-hour ozone NAAQS. The Jefferson County Department of Health holds jurisdiction within the county boundaries of Jefferson County for which 2006-2008 monitoring data demonstrates the county to be violating the eight-hour standard. The ADEM holds jurisdiction for Bibb, Blount, Chilton, Cullman, Walker, St. Clair and Shelby Counties. The 2006- 2008 data from the State's monitor in Shelby Count y supports the inclusion of Shelby County in the Birmingham Nonattainment Area. Discussion el sewhere in this document demonstrates the State's recommendations for exclusion of Bibb, Blount, Chilton, Cullman, Walker and St. Clair Counties as a part of the 8-hour nonattainment boundary.



### J. Level of Control of Emission Sources Since 1979, statewide reasonably available control technology (RACT) has been in place for volatile organic compounds (VOCs) as found under ADEM Admin. Code Chapter 335-3-6. Also in place since 1990 has been the institution of statewide regulations for the control of evaporative emissions in the gasoline marketing chain, commonly referred as 'Stage I' vapor recovery. Over the 31 year history of Alabama' s air pollution control program, the State has been delegated the authority to implement other standards of performance such as the New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPs), and the federal Prevention of Significant Deterioration regulations for protection of degradation of clean air areas. In addition, the Jefferson County Department of Health has in place a level of VOC regulations within its boundaries that are more stringent than state requirements. Under the 1-hour attainment demonstration plan for the Birmingham area, which was approved by EPA on November 7, 2001, the state required further nitrogen oxide reductions from electric generating plants beyond that required by the Acid Rain program, as well as, the continuance of cleaner gasoline being sold in the area. Additionally, as discussed under regional emission reductions, the EPA required a NO X 

### SIP Call for 22 states, including Alabama that, by 2004, was to result in large reductions in NO X 

### emissions from major utilities, large industrial boilers and gas turbines, and cement kilns. Alabama’s NOx SIP was approved by EPA on July 16, 2001. Further, EPA recently issued a rule known as the Clean Air Interstate Rule (CAIR) for 28 states, including Alabama. CAIR requires additional reductions in NOx and SO2 emissions from

A-18

### utilities. Phase I of CAIR begins in 2009 and Phase II in 2015. Alabama’s CAIR SIP was approved by EPA on October 1, 2007. At the national level, EPA has finalized the Tier 2 vehicle/national fuel standards, which took effect beginning in 2004. However, the States had already begun to realize the benefits of cleaner vehicles with the National Low Emission Vehicle standards with the 2001 model year vehicles.



### K. Regional Emission Reductions ASIP has performed CMAQ Modeling to estimate the impact of implementing several “on the books” regional and local controls. These controls include: CAIR, NOX SIP Call, North Carolina Clean Smokestacks Act, Consent Agreements, One-Hour Ozone SIPs, Heavy duty diesel engine standards, highway diesel fuel control, Large Spark Ignition and Recreational Vehicle Rule, Nonroad Diesel Rule, VOC MACT Standards and Tier II national fuel standards. EPA recently promulgated a rule known as the Clean Air Interstate Rule (CAIR) for 28 states, including Alabama. Phase I of CAIR begins in 2009 and Phase II in 2015. Alabama’s CAIR SIP was approved by EPA on October 1, 2007. All of these programs will collectively result in substantial reductions in emissions of NOx and VOC.
The results obtained from ASIP for Alabama demonstrate that the reductions in 8-hour ozone resulting from these national programs will be sufficient to bring all monitored areas of Alabama into attainment of the 8-hour standard beginning in 2012. These results are documented in Attachment 1. Since additional local controls are unlikely to be required in order for Birmingham to meet the NAAQS, it is unnecessary to designate Counties as nonattainment beyond those with monitoring data exceeding the standard. Further, the lack of a nonattainment designation in a county does not preclude ADEM from requiring controls in the county if controls are deemed necessary

A-19

### Figure A-1

Joint Frequency Distribution Birmingham May-Sept, All Hours : 2006-2008

N

S W E

90 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 26.54 14.73

3.62

3.27

3.22

6.01

4.45

4.75

3.72 4.70 3.29 3.35 4.64 5.41

2.97 2.88 2.45

Wind Speed ( Knots) 0 3 6 10 16 21



### A-20

### Figure A-2

Joint Frequency Distribution Birmingham May-Sept, 6AM-6PM : 2006-2008

N

S W E

47 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 12.04 21.33

3.85

2.79

3.04

6.39

4.36

5.34

3.94 5.25 3.33 3.55 5.61 7.13

4.56 3.97 3.53

Wind Speed ( Knots) 0 3 6 10 16 21



### A-21

### Figure A-3

Joint Frequency Distribution Birmingham Exceedence Days, All Hours : 2006-2008

N

S W E

5 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 37.75 16.79

3.85

3.79

4.11

5.88

4.05

3.40

3.20 3.20 1.83 1.83 2.35 3.00

1.44 1.83 1.70

Wind Speed ( Knots) 0 3 6 10 16 21



### A-22

### A-23 Figure A-4

Joint Frequency Distribution Birmingham Exceedence Days, 6AM-6PM : 2006-2008

N

S W E

2 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 10% intervals. Calms included at center. 21.20 27.71

3.98

2.65

3.37

6.75

4.22

3.98

3.25 4.10 1.20 2.89 3.25 3.74

2.17 3.25 2.29

Wind Speed ( Knots) 0 3 6 10 16 21Figure A-5Figure A-6A-1Figure A-7Figure A-8A-2Figure A-9Figure A-10A-3Figure A-11Figure A-12A-4Figure A-13Figure A-14A-5A-6Figure A-15

## Appendix B

### B-1 ADEM recommends that the Huntsville Nona ttainment area for the 8-hour NAAQS for ozone not include the following counties in the Huntsville CSA: Morgan, Limestone, and Lawrence. EPA guidance (dated December 4, 2008) states that a State must address how certain factors affect the drawing of the nonattainment boundary. Therefore, a discussion of these factors for the Huntsville CSA is provided in this Appendix. The Huntsville CSA consists of four counties: Madison, Morgan, Limestone, and Lawrence. The factors that provide the most compelling evidence to exclude Morgan County from the Huntsville Nonattainment area are listed below:

• Monitoring data

• Commuting Patterns

• Location of emission sources (i.e. the lack of significant area, mobile, and nonroad sources)

• Level of control of emission sources

• Regional emission reductions The factors that provide the most com pelling evidence to exclude Limestone and Lawrence County from the Huntsville Nonattainment area include:

• Total annual emissions of NOx and VOC

• Population density

• Location of emission sources (i.e. the lack of significant area, mobile, and nonroad sources)

• Daily VMT

• Level of control of emission sources

• Regional emission reductions

### A. Emissions in the Huntsville CSA The Huntsville CSA’s location is depicted in Figure 1. To evaluate emissions for the Huntsville CSA, ADEM obtained the 2005 annual NOx and VOC emission estimates from the EPA’s NEI website. Table 1 lists these emissions which include all anthropogenic sources (i.e. point, area, mobile, and non-road mobile) for the Huntsville CSA.

Figure 1 Huntsville CSA

B-2

### B-3 Table 1 Annual Emissions for Huntsville CSA

County 2005 Annual VOC Emissions (Tons) Ranking for VOC 2005 Annual NOx Emissions (Tons) Ranking for NOx Lawrence 3,654 4 4,615 3 Limestone 7,185 3 4,574 4 Madison M 17,120 1 11,176 1 Morgan M 13,165 2 8,591 2

M County has an ozone monitor 

### As shown in Table 1, emissions in Lawrence and Limestone Counties are less than half of the emissions in Madison County. Further, emissions in Lawrence and Limestone Counties do not appear to be substantial enough to produce exceedances of the NAAQS for ozone. Madison County has a design value above the 8-hour NAAQS for ozone based on monitoring data for 2006, 2007, and 2008, while the design value for Morgan County meets the 8-hour NAAQS for ozone based on the same years of data. Evaluating the emissions and air quality in adjacent areas provides no directly compelling indicator as to whether Lawrence, Limestone, and Morgan Counties should be included or excluded in an 8-hour ozone nonattainment area. There are no factors that indicate contribution of emissions from adjacent areas.

### B. Population Density and degree of urbanization including commercial development (significant differe nce from surrounding areas) To evaluate the various aspects of population, ADEM obtained the 2000 to 2007 population estimates for the Huntsville CSA from the Alabama State Data Center 1



### . Information on business data (i.e. retail employment and manufac turing employment) was obtained from the U.S. Census Bureau's County Business Patterns

. Population densities were calculated by dividing the population estimates by the land area of each county (in square miles). Figure 2 depicts the population densities for the counties in the Huntsville CSA. No significant changes in population density are indicated. The population density factor fortifies the recommendation to exclude Morgan, Limestone and Lawrence Counties from the Huntsville nonattainment area.

0 50 100 150 200 250 300 350 400Population per Square Mile Huntsville CMSA Population Density

Morgan 198 196 194 193 193 191 191 191 Madison 388 380 372 366 361 355 349 345 Lawrence 49 49 49 49 50 50 50 50 Limestone 130 126 123 120 119 118 117 116 2007 2006 2005 2004 2003 2002 2001 2000



### Figure 2 Population Density for the Huntsville CSA

1 The Alabama State Data Center (ASDC) is a net work of 27 public agencies working together through a cooperative agreement wi th the U.S. Bureau of the Census to facilitate use and delivery of Census and other data to the public. Internet site: 

### http://cber.cba.ua.edu/est_prj.html B-4

### Table 2 compares the 2000 and 2007 population estimates. Population data is also presented in Figure 3. This data reveals that there has been some growth in the Huntsville CSA; in fact, population is growing at about the same rate in Madison and Limestone Counties, although Madison County makes up 58.1% of the CSA population while Limestone County makes up only 13.7%.

Table 2 Huntsville CSA Population
County 2000 2007 Population Change (2000-2007) % Change % of CSA 2007 Population Morgan 111,197 115,050 3,853 3.47% 21.4% Madison 277,864 312,734 34,870 12.55% 58.1% Lawrence 34,851 34,229 -622 -1.78% 6.4% Limestone 65,913 73,898 7,985 12.11% 13.7% Area Total 491,825 537,918 46,093 9.37% 100.0%

Huntsville CMSA P opulation Trends

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Population

Limestone 73,898 71,777 69,824 68,429 67,692 67,105 66,628 65,913 Law rence 34,229 33,936 34,316 34,221 34,405 34,653 34,837 34,851 Madison 312,734 306,277 299,662 294,399 290,484 285,880 281,193 277,864 Morgan 115,050 114,099 112,814 112,123 112,224 111,359 111,470 111,197 2007 2006 2005 2004 2003 2002 2001 2000



### Figure 3 Population Data for the Huntsville CSA

The amount and percent of urbanized population in the Huntsville CSA is presented in Table 3. This data clearly shows that there has been some growth in the Huntsville CSA’s urban population. Madison County comprises greater than 50% of the Huntsville CSA’s population, which is predominantly urban.

B-5

### B-6 Table 3 Urban Population for the Huntsville CSA

County % Urban 2007 Population 2007 Urban Population % of CSA Total 2007 Urban Population Madison County 77% 312,734 240,805 72.5% Morgan County 56% 115,050 64,428 19.4% Limestone County 33% 73,898 24,386 7.3% Lawrence County 7% 34,229 2,396 0.7% CSA Total 62% 535,911 332,016 100.0%



### Tables 4, 5, and 6 show the trends in Tot al Employment, Manufacturing Employment, and Retail Employment, respectively, for the Huntsville CSA. Madison and Lawrence Counties show similar growth trends in em ployment; however, Madison County dwarfs all of the CSA counties in total employees. Figure 4 demonstrates that there has not been substantial growth in the number of Total Employees for Morgan and Limestone Counties. Figure 5 demonstrates that on ly Madison experienced any growth in manufacturing. These factors fortify the recommendation to exclude Limestone, Lawrence, and Morgan Counties from the 8-hour ozone nonattainment area

.
Table 4 Total Employees

2002 2003 2004 2005 2006 % Change 2002-2006 % of 2006 CSA Total Morgan 45,184 45,456 46,608 45,418 45,179 -1.10% 21% Madison 129,354 133,106 135,587 138,753 146,536 13.30% 68.10% Lawrence 4,334 4,382 4,538 4,767 4,914 13.40% 2.30% Limestone 15,496 16,690 16,491 16,380 16,423 6% 7.60% CSA Total 196,370 201,637 205,228 207,32 3 215,058 9.5% 100%



### Table 5 Manufacturing Employees

2002 2003 2004 2005 2006 % Change 2002-2006 % of 2006 CSA Total Morgan 12,664 12,492 12,543 12,106 12,131 -4.2% 30% Madison 20,848 20,651 19,274 19,102 21,474 3.0% 53.1% Lawrence 2,499 2,499 2,499 2,499 1,376 -44.9% 3.4% Limestone 5,953 6,119 5,485 5,538 5,424 -8.9% 13.4% CSA Total 41,964 41,761 39,801 39,245 40,405 -3.7% 100%



### Table 6 Retail Employees

2002 2003 2004 2005 2006 % Change 2002-2006 % of 2006 CSA Total Morgan 6,235 6,175 6,299 5, 906 6,072 -2.61% 21.3% Madison 17,383 17,767 18,914 18,712 18,938 8.95% 66.3% Lawrence 671 694 680 880 796 18.63% 2.8% Limestone 2,456 2,456 2, 707 2,695 2,751 12.01% 9.6% CSA Total 26,745 27,092 28,600 28,193 28,557 6.78% 100%Huntsville CSA Employee Trends

0 50,000 100,000 150,000 200,000 250,000Population

Limestone 15,496 16,690 16,491 16,380 16,423 Law rence 4,334 4,382 4,538 4,767 4,914 Madison 129,354 133,106 135,587 138,753 146,536 Morgan 45,184 45,456 46,608 45,418 45,179 2002 2003 2004 2005 2006



### Figure 4 Total Employees for the Huntsville CSA

B-7

### C. Monitoring data representing ozone concentrations in local areas and larger areas (urban or regional scale) Table 7 presents the ozone monitoring data for the Huntsville CSA. The table shows that the Madison County monitor exceeds the 8-hour NAAQS for ozone while the Morgan County monitor meets the 8-hour NAAQS for ozone. Figure 5 maps these ozone monitoring sites which provided the 2006, 2007, and 2008 data for the Huntsville CSA. The recommendation to exclude Morgan County is supported by monitoring data that shows Morgan is meeting the 8-hour NAAQS for ozone.

Table 7 Huntsville CSA Ozone Monitoring Data

County AIRS ID Site 2006 4th Max (ppm) 2007 4th Max (ppm 2008 4th Max (ppm 3 Year Average

(ppm) Morgan 01-103-0011 Decatur 0.078 0.081 0.068 0.075 Madison 01-089-0014 Huntsville 0.079 0.082 0.073 0.079



### Figure 5 Ozone Monitoring Sites in Huntsville CSA

B-8

### D. Location of Emission Sources Figure 6 depicts the location of large point sources in the Huntsville CSA and surrounding counties. The base map was created in GIS using coordinates supplied by the facilities. Tables 8 and 9 present the distribution of NOx emissions (in tons per year) among point, area, mobile, and non-road sources in the Huntsville CSA. Tables 10 and 11 present the same information for VOC emissions. Figures 7 and 8 illustrate this data. Figure 9 presents the emission densities for the Huntsville CSA. Madison County’s larger population contributes to the greater percentage of area, mobile, and non-road sources, subsequently giving Madison County the greatest number in total annual NOx emissions at 39%. Although Morgan County has the largest amount of point sources at 55%, overall the annual emission total for point for Morgan County is comparably low. Lawrence and Morgan Counties account for most of the point source NOx and VOC emissions in the CSA. However, as discussed in Section G, the wind infrequently blows from the direction of Lawrence or Morgan counties on high ozone days in Huntsville. The total annual emissions for Lawrence and Limestone Counties are half the total of annual emissions for Madison County. The lack of large point sources of NOx or VOC located in Lawrence and Limestone Counties fortifies the recommendation to exclude these counties from the Huntsville NAA

.

Figure 6 Location of Large Point Sources in the Huntsville CSA

Table 8 NOx Annual Emissions (Tons) FIPS Code County Point Area Mobile Non-Road Total Emissions
01079 Lawrence Co 2,693 39.1% 208 5.8% 962 7.8% 752 12.2% 4,615 15.9% 01083 Limestone Co 20 0.3% 407 11.4% 2,380 19.3% 1,768 28.7% 4,574 15.8% 01089 Madison Co 375 5.4% 2,100 58.9% 6,428 52.1% 2,273 36.9% 11,176 38.6% 01103 Morgan Co 3,797 55.1% 851 23.9% 2,576 20.9% 1,367 22.2% 8,591 29.7% CMSA Total Emissions 6,884 3,566 12,346 6,160 28,956


### B-9

### Table 9 Cumulative NOx Contributions

B-10 r C % County Name Facto Annual 2005 Emissions (Tons) % of Area Total Emissions umulative
Madison Co 22 2 Mobile NOx Emissions (Tons) 6,428 .2% 2.2% Morgan Co 13 3 Point NOx Emissions (Tons) 3,797 .1% 5.3% Lawrence Co 9 4 Point NOx Emissions (Tons) 2,693 .3% 4.6% Morgan Co 8 5 Mobile NOx Emissions (Tons) 2,576 .9% 3.5% Limestone Co 8 6 Mobile NOx Emissions (Tons) 2,380 .2% 1.7% Madison Co 7 6 Non-Road NOx Emissions (Tons) 2,273 .9% 9.6% Madison Co 7 7 Area NOx Emissions (Tons) 2,100 .3% 6.8% Limestone Co 6 8 Non-Road NOx Emissions (Tons) 1,768 .1% 2.9% Morgan Co 4 8 Non-Road NOx Emissions (Tons) 1,367 .7% 7.7% Lawrence Co 3% 9 Mobile NOx Emissions (Tons) 962 1.0% Morgan Co 2 9 Area NOx Emissions (Tons) 851 .9% 3.9% Lawrence Co 2 9 Non-Road NOx Emissions (Tons) 752 .6% 6.5% Limestone Co 1 9 Area NOx Emissions (Tons) 407 .4% 7.9% Madison Co 1 9 Point NOx Emissions (Tons) 375 .3% 9.2% Lawrence Co 0 9 Area NOx Emissions (Tons) 208 .7% 9.9% Limestone Co 0 10 Point NOx Emissions (Tons) 20 .1% 0.0% Area Total Emissions 28,956

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000Tons per Year Huntsville CSA -NOx Emissions Distribution (2005)

Non-Road 752 1,768 2,273 1,367 Mobile 962 2,380 6,428 2,576 Area 208 407 2,100 851 Point 2,693 20 375 3,797 Lawrence Co Limestone Co Madison Co Morgan Co



### Figure 7 NOx Emissions for the Huntsville CSA

### B-11 Table 10 VOC Annual Emissions (Tons) FIPs County Point Area Mobile Non-Road Total Emissions 01079 Lawrence 258 7.2% 2,542 10.1% 522 6% 632 15.4% 3,955 9.5% 01083 Limestone 15 0.4% 4,570 18. 2% 1,434 17% 1,166 28.3% 7,185 17.3% 01089 Madison 34 0.9% 10,927 43.4% 4,665 55% 1,494 36.3% 17,120 41.3% 01103 Morgan 3,305 91.5% 7,139 28. 4% 1,897 22% 823 20.0% 13,165 31.8% CMSA Total Emissions 3,613 25,178 8,517 4,115 41,424



### Table 11 Cumulative VOC Contributions
County Name Factor Annual 2005 Emissions (Tons) % of Area Total Emissions Cumulative % Madison Area VOC Emissions (Tons) 10,927 26.4% 26.0% Morgan Area VOC Emissions (Tons) 7,139 17.2% 43.2% Madison Mobile VOC Emissions (Tons) 4,665 11.3% 54.5% Limestone Area VOC Emissions (Tons) 4,570 11.0% 65.5% Morgan Point VOC Emissions (Tons) 3,305 8.0% 73.5% Lawrence Area VOC Emissions (Tons) 2,542 6.1% 79.6% Morgan Mobile VOC Emissions (Tons) 1,897 4.6% 84.2% Madison Non-road VOC Emissions (Tons) 1,494 3.6% 87.8% Limestone Mobile VOC Emissions (Tons) 1,434 3.5% 91.3% Limestone Non-road VOC Emissions (Tons) 1,166 2.8% 94.1% Morgan Non-road VOC Emissions (Tons) 823 2.0% 96.1% Lawrence Non-road VOC Emissions (Tons) 632 1.5% 97.6% Lawrence Mobile VOC Emissions (Tons) 522 1.3% 98.9% Lawrence Point VOC Emissions (Tons) 258 0.6% 99.5% Madison Point VOC Emissions (Tons) 34 0.1% 99.6% Limestone Point VOC Emissions (Tons) 15 0.0% 100.0% Area Total Emissions 41,4240 1,000 2,000 3,000 4,000 5,000 6,000 7,000 8,000 9,000 10,000 11,000 12,000Tons per Year Huntsville CMSA-VOC Emissions Distribution (2005)

Non-Road 632 1,166 1,494 823 Mobile 522 1,434 4,665 1,897 Area 2,542 4,570 10,927 7,139 Point 258 15 34 3,305 Lawrence Limestone Madison Morgan



### Figure 8 VOC Emissions for the Huntsville CSA

Emission Density (Based on 2005 Emissions)

23 21 6 13

15 14 7 8

0 5 10 15 20 25 Morgan Co Madison Co Lawrence Co Limestone Co

Annual Tons per Square Mile

VOC Emission Density NOx Emission Density (568 sq. miles)

(693 sq. miles)

(805 sq. miles)

(582 sq. miles)



### Figure 9 Emission Densities for the Huntsville CSA

B-12

### B-13 

### E. Traffic and Commuting Patterns Estimates of the Daily Vehicle Miles Traveled (DVMT) were obtained from the Alabama Department of Transportation and the commuting patterns were obtained from the US Census Bureau web site. The commuting patterns available were based on the 2000 US Census. Table 12 presents the 1997 and 2007 DVMT estimates for the Huntsville CSA, and Figure 10 demonstrates the DVMT trend from 1997 to 2007 for each county. Figure 11 presents the rural and urban distribution of DVMT for the Huntsville CSA. Figure 12 presents the commuting patterns between the counties within the Huntsville CSA. Table 12 shows that the DVMT for the Huntsville CSA has increased over the period of eleven years. Figure 11 demonstrates the DVMT for rural and urban areas. DVMT in Madison County comprises almost 50% of the entire CSA’s VMT and is largely urban. Figure 12 indicates that there is relative ly insignificant commuting from Lawrence, Limestone, or Morgan Counties into Madison County. This factor fortifies the recommendation to exclude Lawrence, Limestone, and Morgan Counties from the Huntsville 8-hour ozone nonattainment area

.
Table 12 Daily VMT for the Huntsville CSA
County 1997 Daily VMT 2007 Daily VMT Daily VMT Change (1998-2007) % Change % of Area 2007 Daily VMT Lawrence 1,028,400 1,351,016 322,616 31.4% 9.1% Limestone 2,322,121 2,859,290 537,169 23.1% 19.3% Madison 6,435,827 6,837,199 401,372 6.2% 46.2% Morgan 3,431,346 3,752,627 321,281 9.4% 25.4% CSA Total 13,217,694 14,800,132 1,582,438 12.0% 100.0%Huntsville CSA Daily VMT

0 1,000,000 2,000,000 3,000,000 4,000,000 5,000,000 6,000,000 7,000,000 8,000,000 9,000,000Vehicle Miles Traveled

Lawrence Co 1,028,400 1,050,174 106,221 1,062,989 1,065,238 1,119 ,112 1,406,941 1,270,483 1,1 16,270 1,126,198 1,351,016 Limestone Co 2,322,121 2,394,971 2,476,678 2,448,828 2,349,040 2,520 ,331 2,551,926 2,312,093 2,4 28,751 2,631,272 2,859,290 Madison Co 6,435,827 6,312,085 6,344,420 6,362,897 6,278,132 7,943 ,851 8,039,973 6,132,881 6,4 31,487 6,628,390 6,837,199 Morgan Co 3,431,346 3,459,809 3,507,750 3,528,052 3,447,434 3,430 ,554 3,421,549 3,243,551 3,2 30,781 3,237,642 3,752,627 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007



### Figure 10 Daily VMT Trend for the Huntsville CSA

Huntsville CSA Daily VMT 2007

0% 20% 40% 60% 80% 100%Vehicle Miles Traveled

Rural Daily VMT 1,351,016 1,900,659 1,112,299 1,414,701 Urban Daily VMT - 958,631 5,724,900 2,337,926 Lawrence Co 2007 Limestone Co 2007 Madison Co 2007 Morgan Co 2007


### Figure 11 Rural vs. Urban Daily VMT for the Huntsville CSA

B-14Huntsville CSA Commuting Patterns

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Work in Madison Co 431 8,878 7,459 126,240 Work in Morgan Co 6,522 2,868 36,005 2,052 Work in Limestone Co 705 15,783 2,380 1,901 Work in Lawrence 5,435 122 816 35 Reside in Lawrence Co Reside in Limestone Co Reside in Morgan Co Reside in Madison Co



### Figure 12 Commuting Patterns for the Huntsville CSA

B-15

### B-16 

### F. Expected Growth (i ncluding extent, pattern, and rate of growth) There is little information available about expected growth. Table 13 provides population growth estimates that were obtained from the Alabama Data Center. The estimates do not show that significant growth is expected in either county. Since no other information about expected growth is available, and population growth estimates are not enough to influence a decision about designating a nonattainment area, this factor did not play a role in the recommendation to exclude Morgan, Lawrence, and Limestone from the Huntsville 8-hour ozone nonattainment area

.
Table 13 Population Projections for the Huntsville CSA
County Name 2000 2007 2015 2025 Percent Change

2000- 2007 Percent Change 2007-2015 Percent Change 2015-2025 Lawrence 34,803 34,229 38,347 39,664 -1.6% 12.0% 3.4% Limestone 65,676 73,898 81, 747 90,865 12.5% 10.6% 11.2% Madison 276,700 312,734 324,15 3 349,713 13.0% 3.7% 7.9% Morgan 111,064 115,050 124,358 131,112 3.6% 8.1% 5.4%



### G. Meteorology It is known that meteorology plays a major role in the formation and transport of ozone. In the Huntsville area, wind direction and speed are important indicators to where ozone forms and travels. In the 2006-2008 ozone seasons, ozone levels exceeded the new 8- hour standard (75 ppb) on 17 days over the three-year period. A wind analysis was accomplished to determine the extent to which wind directions could be correlated with high ozone. During the last three ozone seasons, the May – September winds in the Huntsville area had a predominant wind direction out of the north, and a marked minimum number of winds blowing from the northwest and northeast directions. In addition there was a high occurrence of winds blowing from theeast to south quadrant (see Figure B-1). When one considers only the daytime (6AM6PM) winds (Figure B-2), the general pattern changes very little. However, on those days when the 8-hour ozone standard was exceeded in the Huntsville area, the wind blew overwhelmingly from the north with the east to south directions showing up as well. This phenomenon is clearly seen in Figure B- 3 (all hours) and Figure B-4 (daytime hours only). Also note the number of calms dur ing the daytime on exceedence days is more than twice as much as it is on a non-exceedence day. In addition to the wind roses, back trajectories were run using the National Oceanic and Atmospheric Administration HYSPLIT model to verify the wind directions on exceedence days and to show any other important wind patterns observed in and around theHuntsville area. As illustrated in the modeled back trajectories in Figures B-5 through B16, the trajectories show the dominant wind blowing from the north and to a lesser amount the east to south direction as shown in the wind roses. In addition, a couple of the trajectories illustrate recirculation in the lowest level.

### B-17 

### H. Geography/Topography (mountain ranges or other air basin boundaries) The geography/topography of an area definitely influences the creation and transport of ozone. The Huntsville area is located in far northern Alabama (Madison County) about 20 miles south of the Alabama/Tennessee border. It lies in the southern extremities of the Appalachians on the Cumberland Plateau. The area is surrounded by hills, and a few mountains and the Tennessee River runs through the southern part of Madison County.



### I. Jurisdictional Boundaries The Department has received and shared data with the Tennessee Department ofEnvironment and Conservation (40 CFR, §81.72). Within the Tennessee River ValleyCumberland Mountains Interstate air quality control region, there are no MSAs shared between the states of Tennessee and Alabama. The City of Huntsville is the local air program whose jurisdictional boundaries are the Huntsville city limits. The remainder of Madison County and the adjoining counties (Limestone, Lawrence, and Morgan) in the Huntsville CSA are in the jurisdiction of the State air program under the purview of the ADEM. Adjacent to the Huntsville MSA is the Decatur MSA consisting of Morgan and Lawrence Counties. The Huntsville CSA consists of the following four counties: Lawrence, Limestone, Morgan, and Madison. The State of Alabama holds jurisdiction within Madison County, in which the State’s monitor is located, which supports representative data for Madison County being recommended as the 8-hour nonattainment boundary. The monitor in Decatur supports representative data for the recommendation that Morgan County be excluded as an 8-hour ozone nonattainment area. Discussion elsewhere in this document demonstrates the State's recommendations for exclusion of the Lawrence and Limestone counties of the Huntsville CSA as a part of the 8-hour nonattainment boundary.



### J. Level of Control of Emission Sources Since 1979, statewide reasonably available control technology (RACT) has been in place for volatile organic compounds (VOCs) as found under ADEM Admin. Code Chapter 335-3-6. Also in place since 1990 has been the institution of statewide regulations for the control of evaporative emissions in the gasoline marketing chain, commonly referred as 'Stage I' vapor recovery. Throughout the history of Alabama's air pollution control program, the State has been delegated the authority to implement other standards of performance such as the New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPs), and the federal Prevention of Significant Deterioration (PSD) regulations for protection of degradation of clean air areas. Additionally, the EPA required a NO X 

### SIP Call for 22 states, including Alabama that beginning in 2004, resulted in large reductions in NO X 

### emissions from major utilities, large industrial boilers, gas turbines and cement kilns. Alabama’s NOx SIP was approved by EPA on July 16, 2001. EPA recently issued a rule known as the Clean Air Interstate Rule (CAIR) for 28 states, including Alabama, that, when fully implemented, will reduce SO2 emissions in these states by over 70 percent and NOx emissions by over 60 percent from 2003 levels. Phase I of CAIR begins in 2009 and Phase II in 2015. Alabama’s CAIR SIP was approved by EPA on October 1, 2007. At the national level, EPA has finalized the Tier 2 vehicle/national fuel standards, which took effect beginning in 2004. The States have already begun to realize the benefits of cleaner vehicles with the National Low Emission Vehicle standards with the 2001 MY vehicles.

### B-18 

### K. Regional Emission Reductions ASIP has performed CMAQ Modeling to estimate the impact of implementing several “on the books” regional and local controls. These controls include: CAIR, NOX SIP Call, North Carolina Clean Smokestacks Act, Consent Agreements, One-Hour Ozone SIPs, Heavy duty diesel engine standards, highway diesel fuel control, Large Spark Ignition and Recreational Vehicle Rule, Nonroad Diesel Rule, VOC MACT Standards and Tier II national fuel standards. EPA recently promulgated a rule known as the Clean Air Interstate Rule (CAIR) for 28 states, including Alabama. Phase I of CAIR begins in 2009 and Phase II in 2015. Alabama’s CAIR SIP was approved by EPA on October 1, 2007. All of these programs will collectively result in substantial reductions in emissions of NOx and VOC. The results obtained from ASIP for Alabama demonstrate that the reductions in 8-hour ozone resulting from these national programs will be sufficient to bring all monitored areas of Alabama into attainment of the 8-hour standard beginning in 2012. These results are documented in Attachment 1. Since additional local controls are unlikely to be required in order for Huntsville to meet the NAAQS, it is unnecessary to designate Counties as nonattainment beyond those with monitoring data exceeding the standard. Further, the lack of a nonattainment designation in a county does not preclude ADEM from requiring controls in the county if controls are deemed necessary.Figure B-1

Joint Frequency Distribution Huntsville May-Sept, All Hours – 2006-2008

N

S W E

39 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 22.26 11.92

4.11

2.93

1.79

6.63

8.29

6.37 4.62

6.47 3.86 3.69 4.06 3.82

2.64 2.87 3.67

Wind Speed ( Knots) 0 3 6 10 16 21



### B-19Figure B-2

Joint Frequency Distribution Huntsville May-Sept, 6AM-6PM – 2006-2008

N

S W E

27 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 14.01 16.55

4.26

2.78

1.82

4.56

6.99

6.25

4.53 6.80 4.53 4.76 5.66 5.62

3.60 3.28 4.01

Wind Speed ( Knots) 0 3 6 10 16 21



### B-20Figure B-3

Joint Frequency Distribution Huntsville Exceedence Days, All Hours – 2006-2008

N

S W E

No observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 31.86 12.25

1.96

0.49

0.25

8.33

7.60

5.15

6.13

7.84 2.70 2.70 4.17 1.96

3.19 2.21 1.23

Wind Speed ( Knots) 0 3 6 10 16 21



### B-21Figure B-4

Joint Frequency Distribution Huntsville Exceedence Days, 6AM-6PM – 2006-2008

N

S W E

No observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 23.53 20.36

0.91

0.91

0.00

2.72

5.43

5.43

9.05 5.88 3.62 2.26 6.33 3.17

5.43 3.62 1.36

Wind Speed ( Knots) 0 3 6 10 16 21



### B-22Figure B-5Figure B-6B-23Figure B-7Figure B-8B-24Figure B-9Figure B-10B-25Figure B-11Figure B-12B-26Figure B-13Figure B-14B-27Figure B-15Figure B-16B-28B-29Figure B-17

## Appendix C

### ADEM recommends that the Mobile Nonattainment Area for the 8-hour NAAQS for ozone include Mobile and Baldwin Counties, which combine to create the Mobile-Daphne-Fairhope, AL Combined Statistical Area (CSA) as defined by the Office of Management and Budget in November 2007. This CSA includes the Mobile, AL Metropolitan Statistical Area and the Daphne-Fairhope, AL Micropolitan Statistical Area. In the Robert J. Meyers memo dated December 4, 2008, titled, “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards,” it is recommended that the Core Based Statistical Area (CBSA), which includes both metropolitan statistical areas and micropolitan areas, or CSAs (which include d 2 or more adjacent CBSAs) serve as the presumptive boundary when considering the boundaries of an ozone nonattainment area. EPA recommends this as the presumptive area boundary because the factors used to establish these statistical areas are similar to those factors EPA will use to decide whether a nearby area is contributing to violations of the NAAQS when making nonattainment designations.Based on 2006-2008 monitoring data, the three monitors located in the Mobile-DaphneFairhope, AL CSA all violated the 8-hour ozone NAAQS. Two of the monitors are located in Mobile County and one of the monitors is located in Baldwin County. Monitoring data for the area is shown in the table below. Therefore, ADEM submits that by recommending the entire two-county CSA, EPA’s recommendations for adequate and appropriate nonattainment area recommendations have been met. It should be noted that Baldwin County is the largest county in the State of Alabama in terms of geographic coverage

. 

### Table 1 Mobile CSA Ozone Monitoring Data

County AIRS ID Site 2006 4 th 

### Max (ppm) 2007 4 th 

### Max (ppm) 2008 4 th 

### Max (ppm) 3 Year Average

(ppm) Mobile 01-097-2005 Bay Road 0.08 0.081 0.07 0.077 Mobile 01-097-0003 Chickasaw 0.085 0.077 0.076 0.079 Baldwin 01-003-0010 Fairhope 0.081 0.078 0.072 0.077



### C-1

### Figure 1 Mobile CSA



### C-2

### Figure 2 Ozone Monitoring Site in the Mobile



### C-3

### Figure 3 Locations of Large Point Sources in the Mobile CSA



### C-4

## Appendix D

### The Columbus-Auburn-Opelika, GA-AL CSA contains the Columbus MSA (Russell County, AL, Muscogee County, GA, Chattahoochee County, GA, Harris County, GA, and Marion County, GA), the Auburn-Opelika MSA (Lee County, AL) and the Tuskegee μSA (Micropolitan Statistical Area) (Macon County, AL). There are three ozone monitors located in the Columbus-Auburn-Opelika, GA-AL CSA, with the monitor in noncompliance being the Columbus Airport monitor (13-215-0008) in Muscogee County, GA (See Figure 1). The only Alabama county in the Columbus-Auburn-Opelika GA-AL CSA with an ozone monitor is Russell County, which is in complianc e with the 8-hour Ozone standard. EPA guidance dated December 4, 2008, recommends that the Core Based Statistical Area (CBSA, which is a MSA or a μSA) or Combined Statistical Area (CSA, which includes 2 or more adjacent CBSA’s) serve as the starting point or “presumptive” boundary for establishing the geographic boundaries of an ozone nonattainment area. Accordingly, ADEM recommends that the Columbus nonattainment area for the 8-hour ozone NAAQS not include the following Alabama counties: Macon, Lee, or Russell. The December 4, 2008, guidance requires states to address how certain factors affect the drawing of the nonattainmentboundary. Therefore, a discussion of these factors for the Columbus-Auburn-Opelika GAAL CSA is provided in this Appendix. The factors that provide the most compelling evidence to exclude Russell County, AL from the Columbus nonattainment area are listed below:

• Air Quality Monitoring data (Russell County has an attaining Ozone Monitor)

• Level of control of emission sources

• Emissions Data (Locations of sources and contribution to ozone concentrationsRussell County, AL has less NO x 

### and VOC emissions than Muscogee County, GA where the violating ozone monitor is located)

• Regional emission reductions The factors that provide the most compelling evidence to exclude Macon County, AL from the Columbus nonattainment area include:

• Population density and degree of urbanization (Including commercial development)

• Emissions Data (Locations of sources and contribution to ozone concentrationsMacon has no major Point Sources)

• Location of emission sources (i.e. the lack of significant area, mobile, and non-road sources)

• Daily VMT

• Level of control of emission sources

• Regional emission reductions The factors that provide the most compelli ng evidence to exclude Lee County from the Columbus nonattainment area include:

• Total annual emissions of NOx and VOC

• Population density and degree of urbanization (Including commercial development)

• Daily VMT

• Level of control of emission sources

• Regional emission reductions

D-1

### Figure 1 The Columbus-Auburn-Opelika GA-AL CSA (units are ppm)

D-2

### A. Emissions data for the Columbus-Auburn-Opelika GA-AL CSA The counties in the Columbus-Auburn-Opelika GA -AL CSA are depicted in Figure 2. To evaluate emissions for the Columbus-Auburn- Opelika GA-AL CSA, ADEM obtained the 2005 NEI version 1 annual NOx and VOC emission estimates from EPA. Table 1 liststhese emissions, which include all anthropogenic sources (i.e. point, area, mobile, and nonroad mobile) for the Columbus-Auburn-Opelika GA-AL CSA. Further discussion of the location of the emission sources can be found in Section D.

Figure 2 The Columbus-Auburn-Opelika GA-AL CSA

D-3

### Table 1 Annual Emissions for the Columbus-Auburn-Opelika GA-AL CSA

County 2005 Annual VOC Emissions (Tons) Ranking for VOC 2005 Annual NOx Emissions (Tons) Ranking for NOx Muscogee M 12,385 1 6,540 1

Russell M 8,552 2 4,977 2
Lee 6,650 3 4,490 3
Macon 4,186 4 1,740 4
Harris 2,246 5 1,593 5
Chattahoochee 1,246 6 576 6
Marion 901 7 435 7

M 

### County has an ozone monitor

As shown in Table 1, NO x 

### and VOC emissions in Muscogee County, GA, where the violating ozone monitor (the Columbus Airport monitor) is located, ranked number one of the counties in the Columbus-Auburn-Opelika GA-AL CSA. Russell County, AL ranks number two, but its ozone monitor is in compliance with the 8-hour ozone NAAQS. As noted in Attachment 1 and seen in Figure 1, the Muscogee County ozone monitor located at the Columbus Crime Lab is also in compliance. Lee County, AL and Macon County, AL have NO x 

### and VOC emissions that are even less than those of Russell County. Section G of this appendix concludes that winds infrequently blow from the direction of Russell, Lee and Macon counties on high ozone days in Columbus and Phenix City. This suggests that regional emissions are more important than local emissions in the formation of ozone in the local area. Further, it is unlikely that emissions in Lee and Macon Counties are substantial enough to produce an exceedance of the ozone NAAQS or to significantly contribute to nonattainment in nearby counties.

D-4

### B. Population Density and degree of urbanization including commercial development (significant diffe rence from surrounding areas) To evaluate the various aspects of population, ADEM obtained the 2000 to 2007 population estimates for the Columbus-Auburn-Opelika GA-AL CSA from the Alabama State Data Center 1 

### and the State of Georgia. Information on business data (i.e. retail employment and manufacturing employment) was obtained from the U.S. Census Bureau's County Business Patterns

. Population densities were calculated by dividing the population estimates by the land area of each county (in square miles). Figure 3 depicts the population densities for the counties in the Columbus-Auburn-Opelika GA-AL CSA. Muscogee County, GA ranks highest with all the other CSA counties being much lower. The population density factor fortifies the recommendation to exclude Russell, Lee, and Macon Counties from the Columbus nonattainment area.

Figure 3 Population Densities for the Columbus-Auburn-Opelika GA-AL CSA

0 100 200 300 400 500 600 700 800 900Population per Square Mile Columbus-Auburn-Opelika, GA-AL CSA Population Density

Russell 77 77 77 76 76 77 77 78 Macon 39 39 39 38 38 37 37 37 Lee 190 192 194 196 200 206 210 214 Muscogee 863 864 861 847 865 873 888 866 Harris 51 52 54 56 57 59 61 63 Chattahoochee 60 64 77 53 53 48 54 38 Marion 20 19 19 19 19 19 19 19 2000 2001 2002 2003 2004 2005 2006 2007

1 The Alabama State Data Center (ASDC) is a network of 27 public agencies working together through a cooperative agreem ent with the U.S. Bureau of the Census to facilitate use and delivery of Census and other data to the public. Internet site: 

### http://cber.cba.ua.edu/est_prj.html

D-5

### Table 2 compares the 2000 and 2007 population estimates. Population data is also presented in Figures 4 and 5. Muscogee County makes up 42.9% of the CSA population while Russell and Macon AL Counties make up only 11.5% and 5.1%. This factor supports excluding Russell and Macon Counties from the NAA. With the exception of Muscogee County, GA, Lee County's population is higher than the other counties in the CSA; however, it is important to note that Auburn University is located in Lee County. In 2007, student enrollment was 24,137, and the number of university employees was 9,554. While population figures for Lee County are higher than that of Russell or Macon County, it is important to note that 33,691 members of the population in Lee County could be attributed to this institution, and most do not commute outside of the area on a regular basis. Also, this institution is located in the western portion of Lee County. It should also be noted that the land area of Lee County is 2.8 times larger than the land area of Muscogee County.

. Table 2 Columbus-Auburn-Opelika GA-AL CSA Population

County 2000 2007 Population Change (2000-2007) % Change % of CSA 2007 Population Muscogee 186,502 187,046 544 0.3% 42.9%
Lee 115,540 130,516 14,976 13.0% 30.0%
Russell 49,663 50,183 520 1.0% 11.5%
Harris 23,796 29,073 5,277 22.2% 6.7%
Macon 24,076 22,336 -1,740 -7.2% 5.1%
Chattahoochee 14,993 9,430 -5,563 -37.1% 2.2%
Marion 7,179 7,024 -155 -2.2% 1.6%
Total 421,749 435,608 13,859 3.3% 100.0%

D-6Columbus-Auburn-Op elika, GA-AL CSA Population Trends

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000Population

Russell 49,663 49,377 49,161 48,654 48,949 49,059 49,661 50,183 Macon 24,076 23,982 23,657 23,480 23,054 22,752 22,558 22,336 Lee 115,540 116,768 118,196 119,609 121,661 125,272 128,033 130,516 Muscogee 186,502 186,637 185,969 182,877 186,812 188,634 191,840 187,046 Harris 23,796 24,323 24,976 25,753 26,541 27,363 28,313 29,073 Chattahoochee 14,993 15,979 19,196 13,147 13,192 11,966 13,485 9,430 Marion 7,179 7,150 7,082 7,035 7,007 7,015 7,048 7,024 2000 2001 2002 2003 2004 2005 2006 2007



### Figure 4 Columbus-Auburn-Opelika GA-AL CSA Population Trends

Columbus-Auburn-Opelika, GA-AL CSA Population Trends

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Population

Marion 7,179 7,150 7,082 7,035 7,007 7,015 7,048 7,024 Chattahoochee 14,993 15,979 19,196 13,147 13,192 11,966 13,485 9,430 Harris 23,796 24,323 24,976 25,753 26,541 27,363 28,313 29,073 Muscogee 186,502 186,637 185,969 182,877 186,812 188,634 191,840 187,046 Lee 115,540 116,768 118,196 119,609 121,661 125,272 128,033 130,516 Macon 24,076 23,982 23,657 23,480 23,054 22,752 22,558 22,336 Russell 49,663 49,377 49,161 48,654 48,949 49,059 49,661 50,183 2000 2001 2002 2003 2004 2005 2006 2007



### Figure 5 Population Data for the Columbus-Auburn-Opelika GA-AL CSA

D-7

### The amount and percent of urbanized population in the Columbus-Auburn-Opelika GA-AL CSA is presented in Table 3. Muscogee County is 97% urban and comprises 42.9% of the Columbus-Auburn-Opelika GA-AL CSA’s population, which is predominantly urban. Russell, Lee and Macon Counties are only 64%, 67%, and 50% urban, respectively. This factor fortifies the recommendation to exclude Macon, Russell, and Lee Counties from the Columbus nonattainment area. Table 3 Urban Population for the Columbus-Auburn-Opelika GA-AL CSA

Land Area 2007 % of CSA Urban Population in Urban Area County Name



### Tables 4, 5, and 6 show the trends in Total Employment, Manufacturing Employment, and Retail Employment, respectively, for the c ounties in the Columbus-Auburn-Opelika GA-AL CSA. Figure 6 demonstrates that Muscogee County, GA has 57% of the total employees for the CSA, which is twice as much the nex t county (Lee County, AL). As previously documented, Auburn University is the largest em ployer in Lee County. The number of total employees for Russell (7%) and Macon (4%) Counties is not substantial in comparison to Muscogee County. This factor fortifies the recommendation to exclude Russell, Macon, and Lee Counties from the Columbus nonattainment area

. Muscogee County, GA had 46% of the manufacturing employees and 55% of the retail employees in the CSA, which ranks them as number one. Russell and Macon Counties together only accounted for 9% of the manufacturing employees and 11% of the retail employees in the CSA. These facts further fortify the recommendation to exclude Russell County, AL and Macon County, AL from the Columbus nonattainment area. (sq mi) Urban % Population Population 2007
Muscogee 216 97.0% 187,046 42.9% 181,435

Lee 609 67.0% 130,516 30.0% 87,446

Russell 641 64.0% 50,183 11.5% 32,117

Macon 611 50.0% 22,336 5.1% 11,168

Chattahoochee 249 79% 9430 2.2% 7,450

Harris 464 3.0% 29,073 6.7% 872

Marion 367 0% 7024 1.6% 0

3157 435,608 100.0% 320,487



### D-8

### Table 4 Total Employees

2002 2003 2004 2005 2006 % Change

2002- 2006 % of 2006 CSA Total Muscogee 80,129 80,677 81,332 83,964 82,738 3% 57% Lee 33,307 36,189 37,540 38,315 39,325 18% 27% Russell 9,437 9,024 9,540 9,507 9,752 3% 7% Macon 5,033 5,048 5,353 5,964 6,230 24% 4% Harris 4,362 4,439 4,021 3,974 3,744 -14% 3% Marion 1,943 1,805 1,510 1,445 1,500 -23% 1% Chattahoochee 636 602 685 757 749 18% 1% MSA Total 134,847 137,784 139,981 143,926 144,038 7% 100%

Table 5 Manufacturing Employees

2002 2003 2004 2005 2006 % Change

2002- 2006 % of 2006 CSA Total Muscogee 12,043 11,573 10,815 9,940 9,391 -22% 46% Lee 6,567 7,062 7,116 7,502 8,095 23% 40% Russell 1,473 1,428 1,833 1,796 1,538 4% 8% Harris 1,543 1,410 1,089 1,057 719 -53% 4% Marion 1,750 750 676 750 540 -69% 3% Macon 56 55 20-99 111 206 268% 1% Chattahoochee 0 0 0 10 0 0% 0%

CMSA Total 23,432 22,278 21,529 21,166 20,489 -13% 100%

Table 6 Retail Employees

2002 2003 2004 2005 2006 % Change

2002- 2006 % of 2006 CSA Total Muscogee 11,431 11,223 11,855 13,640 11,936 4% 55% Lee 5,430 5,420 5,837 6,227 6,447 19% 30% Russell 1,964 1,967 2,040 1,888 2,046 4% 9% Macon 899 460 470 460 454 -49% 2% Harris 266 320 321 353 306 15% 1% Marion 230 190 201 246 289 26% 1% Chattahoochee 65 64 51 69 62 -5% 0%

CMSA Total 20,285 19,644 20,775 22,883 21,540 6% 100%

D-9

### Columbus-Auburn-Opelika, GA-AL CSA Employee Trends

0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000Number of Total Employees

Chattahoochee 636 602 685 757 749 Marion 1,943 1,805 1,510 1,445 1,500 Harris 4,362 4,439 4,021 3,974 3,744 Macon 5,033 5,048 5,353 5,964 6,230 Russell 9,437 9,024 9,540 9,507 9,752 Lee 33,307 36,189 37,540 38,315 39,325 Muscogee 80,129 80,677 81,332 83,964 82,738 2002 2003 2004 2005 2006



### Figure 6 Total Employees for the Columbus-Auburn-Opelika GA-AL CSA

D-10

### C. Monitoring data representing ozone concentrations in local areas and larger areas (urban or regional scale) Table 7 presents the ozone monitoring data for the Columbus-Auburn-Opelika GA-AL CSA. The table shows that the Muscogee County Airport monitor exceeds the 8-hour ozone NAAQS, while the Russell County monitor meets the 8-hour ozone NAAQS. Figure 7 maps these ozone monitoring sites which provided the 2006, 2007, and 2008 data for the Columbus-Auburn-Opelika GA-AL CSA. The recommendation to exclude Russell County is supported by monitoring data that shows Russell County is meeting the 8-hour ozone NAAQS.

Table 7 Columbus-Auburn-Opelika GA-AL CSA Ozone Monitoring Data

County AIRS ID Site 2006 4th Max (ppm) 2007 4th Max (ppm) 2008 4th Max (ppm) 3 Year Average (ppm)
Russell 01-113-0002 Phenix City 0.075 0.079 0.069 0.074 Muscogee 13-215-0008 Columbus Air Port 0.080 0.083 0.073 0.078 Muscogee 13-215-1003 Columbus Crime Lab 0.073 0.074 0.072 0.073



### Figure 7 Ozone Monitoring Sites in Columbus-Auburn-Opelika GA-AL CSA (units in ppm)

D-11

### D. Location of Emission Sources Figure 8 depicts the location of large point sources in the Columbus-Auburn-Opelika GA-AL CSA. The base map was created in GIS using coordinates supplied by the facilities. Figure 9 presents the emission densities for the Columbus-Auburn-Opelika GA-AL CSA. Tables 8 and 9 present the distribution of NOx emissions (in tons per year) among point, area, mobile, and non-road sources in the Columbus-Auburn-Opelika GA-AL CSA. Tables 10 and 11 present the same information for VOC emissions. Figures 7 and 8 illustrate this data.

Figure 8 Locations of Large Point Sources in the Columbus-Auburn-Opelika GA-AL CSA

D-12

### Columbus-Auburn-Opelika CSA Emission Density (Based on 2005 Emissions)

57 13 11 7 5 5 2

30 8 7 3 3 2 1

0 1 0 2 0 3 0 4 0 5 0 6 0 Muscogee

Russell Lee Macon Harris Chattahoochee Marion

Annual Tons per Square Mile 7 0 

### VOC Emission Density NOx Emission Density



### Figure 9 Emission Densities for the Columbus-Auburn-Opelika GA-AL CSA

Muscogee County, GA has the CSA’s highest total annual NOx emissions at 32% of the CSA total, the highest total annual VOC emissions at 34% of the CSA total, and the highest NO x 

### and VOC emission densities. Russell County’s relatively large annual emissions total may be misleading because Fort Benning’s (located in Muscogee and Chattahoochee counties in Georgia) emissions may not hav e been totally accounted for. The 2008 NEI will begin accounting for emissions from military bases and airports as point sources. The majority of the NOx emissions in Lee County ar e from mobile sources. Any impacts from mobile source emissions will be mitigated at the national level by rules requiring cleaner vehicles and fuels. The emissions density data supports the exclusion of Macon, Lee, and Russell Counties from the Columbus nonattainment area. Further, the lack of large point sources of NOx or VOC in Macon County, AL fortifies the recommendation to exclude it from the Columbus nonattainment area

.

D-13

### Table 8 NOx Annual Emissions (Tons)
County Point Point % Area Area % Mobile Mobile % NonRoad NonRoad

% Total Emissions % of Total Emissions Muscogee 21 1% 1,187 35% 4, 319 40% 1,013 30% 6,540 32%

Russell 2,581 89% 543 16% 1,285 12% 569 17% 4,977 24%

Lee 311 11% 727 22% 2,284 21% 1,168 34% 4,490 22% Macon 0 0% 318 9% 1, 155 11% 268 8% 1,740 9% Harris 0 0% 199 6% 1,146 11% 248 7% 1,593 8% Chattahoochee 0 0% 263 8% 241 2% 72 2% 576 3% Marion 3 0% 121 4% 254 2% 57 2% 435 2% CSA Total Emissions 2,915 3,358 10,683 3,395 20,351

0 1,000 2,000 3,000 4,000 5,000 6,000 7,000Tons per Year Columbus-Auburn Opelika CSA - NO x Emissions Distribution (2005)

Non-Road 1,013 569 1,168 268 248 72 57 Mobile 4,319 1,285 2,284 1,155 1,146 241 254 Area 1,187 543 727 318 199 263 121 Point 21 2,581 311 3 Muscogee Russell Lee Macon Harris Chattahoochee Marion



### Figure 7 NOx Emissions for the Columbus-Auburn-Opelika GA-AL CSA

D-14

### Table 9 Cumulative NOx Contributions

County Name Factor Annual 2005 Emissions

(Tons) % of CSA Total Emissions Cumulative % Muscogee Co, GA Mobile Sources NO x Emissions 4319 21.22% 21.22%

Russell Co, AL Point Source NO x Emissions 2581 12.68% 33.90%

Lee Co, AL Mobile Sources NO x Emissions 2284 11.22% 45.12% Russell Co, AL Mobile Sources NO x Emissions 1285 6.31% 51.44% Muscogee Co, GA Area Source NO x Emissions 1187 5.83% 57.27% Lee Co, AL Non-Road NO x Emissions 1168 5.74% 63.01% Macon Co, AL Mobile Sources NO x Emissions 1155 5.68% 68.68% Harris Co, GA Mobile Sources NO x Emissions 1146 5.63% 74.31% Muscogee Co, GA Non-Road NO x Emissions 1013 4.98% 79.29% Lee Co, AL Area Source NO x Emissions 727 3.57% 82.87% Russell Co, AL Non-Road NO x Emissions 569 2.80% 85.66% Russell Co, AL Area Source NO x Emissions 543 2.67% 88.33% Macon Co, AL Area Source NO x Emissions 318 1.56% 89.89%

Lee Co, AL Point Source NO x Emissions 311 1.53% 91.42% Macon Co, AL Non-Road NO x Emissions 268 1.32% 92.73% Chattahoochee Co, GA Area Source NO x Emissions 263 1.29% 94.02% Marion Co, GA Non-Road NO x Emissions 254 1.25% 95.27% Harris Co, GA Non-Road NO x Emissions 248 1.22% 96.49% Chattahoochee Co, GA Mobile Sources NO x Emissions 241 1.18% 97.67% Harris Co, GA Area Source NO x Emissions 199 0.98% 98.65% Marion Co, GA Mobile Sources NO x Emissions 121 0.59% 99.25% Chattahoochee Co, GA Non-Road NO x Emissions 72 0.35% 99.60% Marion Co, GA Area Source NO x Emissions 57 0.28% 99.88% Muscogee Co, GA Point Source NO x Emissions 21 0.10% 99.99%

Marion Co, GA Point Source NO x Emissions 3 0.01% 100.00% Macon Co, AL Point Source NO x Emissions 0 0.00% 100.00% Harris Co, GA Point Source NO x Emissions 0 0.00% 100.00% Chattahoochee Co, GA Point Source NO x Emissions 0 0.00% 100.00% CMSA Total Emissions 20,351



### D-15

### Table 10 VOC Annual Emissions (Tons)

County Point Point % Area Area % Mobile Mobile % NonRoad NonRoad

% Total Emissions % of Total Emissions Muscogee 82 3% 7,863 35% 3,725 45% 715 28% 12,385 34%

Russell 1,886 71% 5,343 24% 1,048 13% 276 11% 8,552 24%

Lee 583 22% 3,725 16% 1,729 21% 613 24% 6,650 18% Macon 0 0% 3,281 14% 615 7% 289 11% 4,186 12% Harris 0 0% 952 4% 781 9% 512 20% 2,246 6% Chattahoochee 0 0% 995 4% 172 2% 79 3% 1,246 3% Marion 108 4% 528 2% 192 2% 73 3% 901 2% CSA Total Emissions 2,658 22,686 8,262 2,559 36,165

0 2,000 4,000 6,000 8,000 10,000 12,000 14,000Tons per Year Columbus-Auburn Opelika CSA - VOC Emissions Distribution (2005)

Non-Road 715 276 613 289 512 79 73 Mobile 3,725 1,048 1,729 615 781 172 192 Area 7,863 5,343 3,725 3,281 952 995 528 Point 82 1,886 583 108 Muscogee Russell Lee Macon Harris Chattahoochee Marion



### Figure 8 VOC Emissions for the Columbus-Auburn-Opelika GA-AL CSA

D-16

### Table 11 Cumulative VOC Contributions

County Name Factor Annual 2005 Emissions

(Tons) % of CSA Total Emissions Cumulative % Muscogee Co, GA Area Source VOC Emissions 7863 21.74% 21.74%

Russell Co, AL Area Source VOC Emissions 5343 14.77% 36.51% Muscogee Co, GA Mobile Source VOC Emissions 3725 10.30% 46.81% Lee Co, AL Area Source VOC Emissions 3725 10.30% 57.11% Macon Co, AL Area Source VOC Emissions 3281 9.07% 66.18% Russell Co, AL Point Source VOC Emissions 1886 5.21% 71.40%

Lee Co, AL Mobile Source VOC Emissions 1730 4.78% 76.18% Russell Co, AL Mobile Source VOC Emissions 1048 2.90% 79.08% Chattahoochee Co, GA Area Source VOC Emissions 996 2.75% 81.83% Harris Co, GA Area Source VOC Emissions 953 2.63% 84.46% Harris Co, GA Mobile Source VOC Emissions 781 2.16% 86.62% Muscogee Co, GA Non-Road VOC Emissions 716 1.98% 88.60%

Macon Co, AL Mobile Source VOC Emissions 616 1.70% 90.30%

Lee Co, AL Non-Road VOC Emissions 614 1.70% 92.00% Lee Co, AL Point Source VOC Emissions 583 1.61% 93.61% Marion Co, GA Mobile Source VOC Emissions 528 1.46% 95.07% Harris Co, GA Non-Road VOC Emissions 513 1.42% 96.48% Macon Co, AL Non-Road VOC Emissions 290 0.80% 97.28% Russell Co, AL Non-Road VOC Emissions 277 0.76% 98.05% Marion Co, GA Non-Road VOC Emissions 193 0.53% 98.58% Chattahoochee Co, GA Mobile Source VOC Emissions 172 0.47% 99.05% Marion Co, GA Point Source VOC Emissions 108 0.30% 99.35% Muscogee Co, GA Point Source VOC Emissions 83 0.23% 99.58% Chattahoochee Co, GA Non-Road VOC Emissions 79 0.22% 99.80% Marion Co, GA Area Source VOC Emissions 73 0.20% 100.00% Macon Co, AL Point Source VOC Emissions 0 0.00% 100.00% Harris Co, GA Point Source VOC Emissions 0 0.00% 100.00% Chattahoochee Co, GA Point Source VOC Emissions 0 0.00% 100.00% CMSA Total Emissions 36,165



### D-17

### E. Traffic and Commuting Patterns Estimates of the Daily Vehicle Miles Trav eled (DVMT) were obtained from the Alabama Department of Transportation and the State of Georgia and the commuting patterns were obtained from the US Census Bureau web site. The available commuting patterns were based on the 2000 US Census. Table 12 presents the 1997 and 2007 DVMT estimates for the Columbus-Auburn-Opelika GA-AL CSA, and Figure 10 demonstrates the DVMT trend from 1997 to 2007 for each county. Figure 11 presents the rural and urban distribution of DVMT for the Columbus-Auburn-Opelika GA-AL CSA. Figure 12 presents the commuting patterns between the counties within the Columbus-Auburn-Opelika GA-AL CSA. Table 12 shows that the DVMT for the Columbus-Auburn-Opelika GA-AL CSA has increased 51% since 1997. Figure 11 demonstrates the DVMT for rural and urban areas. DVMT in Muscogee County comprises 32% of the entire CSA’s VMT and is 100% urban. The DVMT for Russell County comprises 17% of the CSA’s VMT and is a little over one-half of the DVMT for Muscogee County. In addition, the land area of Russell County is almost 3 times that of Muscogee County. This factor fortifies the recommendation to exclude Russell County from the Columbus 8-hour ozone nonattainment area. Figure 12 indicates that there is relatively insignificant commuting from Macon and Lee Counties into Muscogee County, GA. The impact of commuting is negligible and will be further lessened by the national cleaner fuel and vehicle standards. This factor fortifies the recommendation to exclude Macon and Lee Counties from the Columbus 8-hour ozone nonattainment area

.
Table 12 Daily VMT for the Columbus-Auburn-Opelika GA-AL CSA

County 1997 Daily VMT 2007 Daily VMT Daily VMT Change (1997-2007) % Change % of MSA 2007 Daily VMT Muscogee 3,750,440 4,288,796 538,356 14% 32%
Macon 1,057,681 2,847,880 1,790,199 169% 21%
Lee 740,206 2,283,129 1,542,923 208% 17%
Russell 1,692,891 2,204,989 512,098 30% 17%
Harris 1,029,371 1,182,016 152,645 15% 9%
Marion 251,506 259,748 8,242 3% 2%
Chattahoochee 274,590 250,927 -23,662 -9% 2%
CMSA Total 8,796,684 13,317,485 4,520,801 51% 100%



### D-18Columbus-Auburn-Opelika, GA-AL CSA Daily VMT

0 500,000 1,000,000 1,500,000 2,000,000 2,500,000 3,000,000 3,500,000 4,000,000 4,500,000 5,000,000Vehicle Miles Traveled

Russell 1,692,891 1,738,179 1,780,570 1,824,485 1,806,545 1,806,544 1,821,199 1,878,447 1,848,114 1,638,605 2,204,989 Macon 1,276,891 1,315,153 1,355,484 1,353,712 1,375,462 1,407,434 1,462,577 1,392,203 1,406,210 1,439,972 1,755,993 Lee 2,827,060 2,882,779 2,963,166 2,946,022 3,036,790 3,048,529 3,117,276 2,798,256 2,857,793 2,897,531 3,640,079 Muscogee 3,750,440 3,940,756 3,992,865 4,078,925 4,213,229 4,067,534 4,102,504 3,948,933 4,172,136 4,425,629 4,288,796 Harris 1,029,371 999,377 1,124,959 1,226,665 1,277,783 1,241,912 1,195,290 1,121,857 1,161,527 1,209,902 1,182,016 Chattahoochee 274,590 245,988 277,308 266,835 285,562 257,840 260,640 246,469 255,255 253,059 250,927 Marion 251,506 262,641 269,756 298,916 298,399 293,800 295,724 216,246 269,232 256,384 259,748 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007



### Figure 10 DVMT Trend for the Columbus-Auburn-Opelika CSA

Columbus-Auburn-Opelika, GA-AL CMSA Daily VMT Distribution (2007)

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%Vehicle Miles Traveled

Urban Daily VMT 2007 2,605,226 664,105 4,997,029 4,288,796 0 0 0 Rural Daily VMT 2007 1,804,752 2,847,880 2,283,129 0 1,182,016 250,927 259,748 Russell Macon Lee Muscogee Harris Chattahoochee Marion



### Figure 11 Rural vs. Urban DVMT for the Columbus-Auburn-Opelika GA-AL CSA

D-19Columbus-Auburn-Opelika GA-AL CSA Commuting Patterns (Based on 2000 Census Data)

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Work in Marion Co. GA 0 0 7 106 55 14 1380 Work in Harris Co. GA 0 89 131 1,123 5 2867 12 Work in Chattahoochee Co. GA 0 668 981 3,748 5,482 304 95 Work in Muscogee Co. GA 68 7,597 9,623 71,862 2,523 6087 793 Work in Russell Co. AL 102 2,682 7,051 2,479 72 214 34 Work in Lee Co. AL 1,789 35,549 1,048 514 0 67 0 Work in Macon Co. AL 4,203 478 53 9 0 0 0 Reside in Macon Co. AL Reside in Lee Co. AL Reside in Russell Co. AL Reside in Muscogee Co. GA Reside in Chattahoochee Co. GA Reside in Harris Co. GA Reside in Marion Co. GA



### Figure 12 Commuting Patterns for the Columbus-Auburn-Opelika GA-AL CSA

D-20

### F. Expected Growth (i ncluding extent, pattern, and rate of growth) There is little information available about ex pected growth. Table 13 provides population growth estimates that were obtained from the Alabama Data Center and the State of Georgia. Since no other information about expected growth is available, and population growth estimates are not enough to influence a decision about designating a nonattainment area, this factor presents no compelling reason to include Russell, Lee, or Macon Counties in the Columbus nonattainment area.

Table 13 Population Projections for the Columbus-Auburn-Opelika CSA
County

Name 2000 2007 2015 2025 Percent Change

2000- 2007 Percent Change

2007- 2015 Percent Change

2015- 2025 Lawrence 34,803 34,229 38,347 39,664 -1.6% 12.0% 3.4% Limestone 65,676 73,898 81,747 90,865 12.5% 10.6% 11.2% Madison 276,700 312,734 324,153 349,713 13.0% 3.7% 7.9% Morgan 111,064 115,050 124,358 131,112 3.6% 8.1% 5.4%



### G. Meteorology It is known that meteorology plays a major role in the formation and transport of ozone. In the Phenix City/Columbus, Georgia area, wind direction and speed are important indicators to where ozone forms and travels. In the 2006-2008 ozone seasons, ozone levels exceeded the new 8-hour standard (75 ppb) on 8 days in Phenix City and 10 days in Columbus, Georgia, over the three-year period. A wind analysis was accomplished to determine the extent to which wind directions could be correlated with high ozone. During the last three ozone seasons, the May – September winds in the Phenix City/Columbus, Georgia, area had two predominant wind directions. One was from the north and the other out of the east. In addition to these two predominant wind directions, there was a third direction from the west that stood out as well (see Figures D-1 and D-5). When one considers only the daytime (6AM-6PM) winds (Figures D-2 and D-6), the general pattern changes very little. However, on those days when the 8-hour ozone standard was exceeded, the wind blew overwhelmingly from the north. This phenomenon is clearly seen in Figure D-3 (all hours) and Figure D-4 (daytime hours only). Also of note is the number of calms during the daytime on exceedance days. It’s more than twice as much as it is on a non-exceedance day for Phenix City and three and a half times as much for Columbus. In addition to the wind roses, back trajectories were run using the National Oceanic and Atmospheric Administration HYSPLIT model to verify the wind directions on exceedance days and to show any other important wi nd patterns observed in and around the PhenixCity/Columbus, Georgia, area. As illustrated in the modeled back trajectories in Figures D7 through D-18, the trajectories back up the wind roses showing the dominant wind blowing from the north as well as stagnation conditions.

D-21

### H. Geography/Topography (mountain ranges or other air basin boundaries) Phenix City is located in Eastern Alabama in Russell County and is about 70 miles east of Montgomery and 183 miles inland from the Gulf of Mexico. The northern part of the county is somewhat hilly but becomes flatter as one moves west or south away from the influence of the Appalachian foothills. The C hattahoochee River traverses the county from the northeast to southeast through a flat plain along the Alabama /Georgia state border.



### I. Jurisdictional Boundaries As stated in the opening paragraph of this Appendix, the Columbus-Auburn-Opelika, GA-AL CSA contains the Columbus Metropolitan Statistical Area (MSA), the Auburn-Opelika MSA and the Tuskegee Micropolitan Statistical Area (μSA). The Columbus MSA contains Russell County, AL, Muscogee County, GA, Chattahoochee County, GA, Harris County, GA, and Marion County, GA. The Auburn-Opelika MSA contains Lee County, AL and the Tuskegee μSA contains Macon County, AL. Russell, Lee, and Macon Counties are in the jurisdiction of the State of Alabama under the purview of t he ADEM. Alabama's ozone monitor located in Russell County supports representative data for Russell County being recommended for attainment status for the new 8- hour ozone standard with a design value of 

### 0.074 ppm.



### J. Level of Control of Emission Sources Since 1979, statewide reasonably available control technology (RACT) has been in place for volatile organic compounds (VOCs) as found under ADEM Admin. Code Chapter 335-3- 6. Also in place since 1990 has been the institution of statewide regulations for the control of evaporative emissions in the gasoline marketing chain, commonly referred as 'Stage I' vapor recovery. Throughout the history of Alabama's air pollution control program, the State has been delegated the authority to implement other standards of performance such as the New Source Performance Standards (NSPS), National Emission Standards for Hazardous Air Pollutants (NESHAPs), and the federal Prevention of Significant Deterioration (PSD) regulations for protection of degradation of clean air areas. Additionally the EPA required a NO X 

### SIP Call for 22 states, including Alabama that, beginning in 2004, resulted in large reductions in NO X 

### emissions from major utilities, large industrial boilers and gas turbines, and cem ent kilns. Alabama’s NOx SIP was approved by EPA on July 16, 2001. Further, EPA recently issued a rule known as the Clean Air Interstate Rule (CAIR) for 28 states, incl uding Alabama, that, when fully implemented, will reduce SO2 emissions in these states by over 70 percent and NOx emissions by over 60 percent from 2003 levels. Phase I of CAIR begins in 2009 and Phase II in 2015. Alabama’s CAIR SIP was approved by EPA on October 1, 2007. At the national level, EPA has finalized the Tier 2 vehicle/national fuel standards, which took effect beginning in 2004. However, the States had already begun to realize the benefits of cleaner vehicles with the National Low Emission Vehicle standards with the 2001 model year vehicles. 

### K. Regional Emission Reductions ASIP has performed CMAQ Modeling to estimate the impact of implementing several “on the books” regional and local controls. These controls include: CAIR, NOX SIP Call, North Carolina Clean Smokestacks Act, Consent Agreements, One-Hour Ozone SIPs, Heavy duty diesel engine standards, highway diesel fuel control, Large Spark Ignition and

D-22

### Recreational Vehicle Rule, Nonroad Diesel Rule, VOC MACT Standards and Tier II national fuel standards. EPA also promulgated a rule known as the Clean Air Interstate Rule (CAIR) for 28 states, including Alabama. Phase I of CAIR begins in 2009 and Phase II in 2015. Alabama’s CAIR SIP was approved by EPA on Oct ober 1, 2007. All of these programs will collectively result in substantial reduc tions in emissions of NOx and VOC. The results obtained from ASIP for Alabama demonstrate that the reductions in 8-hour ozone resulting from these national programs will be sufficient to bring all monitored areas of Alabama into attainment of the 8-hour standard beginning in 2012. These results are documented in Attachment 1. Since additional local controls are unlikely to be required in order for the CSA to meet the NAAQS, it is unnecessary to designate counties as nonattainment beyond those with monitoring data exceeding the standard. Further, the lack of a nonattainment designation in a county does not preclude ADEM from requiring controls in the county if controls are deemed necessary.

D-23D-1

Joint Frequency Distribution Columbus Airport May-Sept, All Hours – 2006-2008

N

S W E

160 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 24.09 10.54

2.51

2.43

4.85

11.83

4.74

2.27

1.99 3.31 3.44 3.78 4.81 7.52 4.27 3.89 3.76

Wind Speed ( Knots) 0 3 6 10 16 21



### D-24D-2

Joint Frequency Distribution Columbus Airport May-Sept, 6AM-6PM – 2006-2008

N

S W E

88 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 15.97 14.78

2.74

2.09

4.32

11.11

5.31

2.87

2.42 3.86 3.47 3.50 4.80 9.02 5.34 4.46 3.95

Wind Speed ( Knots) 0 3 6 10 16 21



### D-25D-3

Joint Frequency Distribution Columbus Airport Exceedence Days, All Hours – 2006-2008

N

S W E

4 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 43.22 17.37

2.12

3.39

2.97

1.27

2.54

0.85

2.97 3.81 2.54 0.42 2.54 5.93

3.39 1.69 2.97

Wind Speed ( Knots) 0 3 6 10 16 21



### D-26D-4

Joint Frequency Distribution Columbus Airport Exceedence Days, 6AM-6PM – 2006-2008

N

S W E

4 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 54.58 13.90

1.69

2.71

2.37

1.02

2.03

0.68

2.37 3.05 2.03 0.34 2.03 4.75

2.71 1.36 2.37

Wind Speed ( Knots) 0 3 6 10 16 21



### D-27D-5

Joint Frequency Distribution Phenix City Exceedence Days, All Hours – 2006-2008

N

S W E

5 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 48.66 13.90

1.07

2.67

3.74

3.74

3.21

2.14

3.74 2.67 2.14 0.00 1.07 3.74

4.28 0.53 2.67

Wind Speed ( Knots) 0 3 6 10 16 21



### D-28D-6

Joint Frequency Distribution Phenix City Exceedence Days, 6AM-6PM – 2006-2008

N

S W E

2 observations were missing. Wind flow is FROM the directions shown. Rings drawn at 5% intervals. Calms included at center. 38.24 21.57

1.96

1.96

2.94

3.92

4.90

3.92

3.92 2.94 1.96 0.00 0.98 4.90

3.92 0.00 1.96

Wind Speed ( Knots) 0 3 6 10 16 21



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