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) FOR THE STATE OF ALABAMA 

County AIRS ID Site 2006 4th Max 

(ppb) 

2007 4th Max 

(ppb) 

2008 4th 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 boundaries for NAA designations are based on 

Combined Statistical Area boundaries. The violating monitor locations provided below 

are not included in any CSA in Alabama, with 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 Nonattainment 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 NOx 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 NOx 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 

A-2 
Table 1 Annual Emissions for the Birmingham CSA 

County 2005 Annual VOC 

Emissions (Tons) 

Ranking 

for VOC 

2005 Annual NOx

Emissions (Tons) 

Ranking 

for NOx 

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 NOx

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 controls, 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 difference 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 Center1

. 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, Chilton, 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 (ASDC) 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

700

Population per Square Mile

Birmingham CSA Population Density

Bibb Co 32 34 34 34 34 34 34 35

Blount Co 79 81 82 83 84 85 86 88

Chilton Co 57 58 58 59 59 60 60 61

Cullman Co 105 105 105 106 107 107 108 109

Jefferson Co 595 594 593 593 593 592 593 592

St. Clair Co 103 104 106 108 110 114 118 123

Shelby Co 182 188 193 200 207 214 223 229

Walker Co 89 89 88 88 87 87 87 87

2000 2001 2002 2003 2004 2005 2006 2007

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

Population

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-5 
Birmingham 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 Employment, Manufacturing Employment, and Retail 

Employment, respectively, for the counties in the 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

500,000

Number 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 concentrations in local areas and larger 

areas (urban or regional scale) 

Table 6 demonstrates that all of the ozone monitors 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 

4thMax 

(ppm) 

2007 

4thMax 

(ppm) 

2008 

4thMax 

(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 Geographical Information Systems (GIS) with 

coordinates supplied by the facilities. Tables 7 and 9 present the distribution of NOx 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 NOx 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 NOx 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 10 20 30 40 50 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 NOx Emissions 31,969 25.04% 25.04% 

Jefferson Co Point Source NOx Emissions 28,000 21.93% 46.97% 

Jefferson Co Mobile Sources NOx Emissions 16,721 13.10% 60.06% 

Walker Co Point Source NOx Emissions 13,009 10.19% 70.25% 

Jefferson Co Non-Road NOx Emissions 8,451 6.62% 76.87% 

Shelby Co Mobile Sources NOx Emissions 3,470 2.72% 79.59% 

Jefferson Co Area Source NOx Emissions 3,348 2.62% 82.21% 

St. Clair Co Mobile Sources NOx Emissions 2,741 2.15% 84.36% 

Shelby Co Non-Road NOx Emissions 2,527 1.98% 86.34% 

Cullman Co Mobile Sources NOx Emissions 2,142 1.68% 88.01% 

Walker Co Mobile Sources NOx Emissions 1,792 1.40% 89.42% 

St. Clair Co Non-Road NOx Emissions 1,674 1.31% 90.73% 

Chilton Co Mobile Sources NOx Emissions 1,661 1.30% 92.03% 

St.Clair Co Point Source NOx Emissions 1,590 1.25% 93.27% 

Blount Co Mobile Sources NOx Emissions 1,479 1.16% 94.43% 

Walker Co Non-Road NOx Emissions 1,199 0.94% 95.37% 

Shelby Co Area Source NOx Emissions 725 0.57% 95.94% 

Cullman Co Non-Road NOx Emissions 612 0.48% 96.42% 

Walker Co Area Source NOx Emissions 558 0.44% 96.86% 

Bibb Co Mobile Sources NOx Emissions 551 0.43% 97.29% 

Blount Co Non-Road NOx Emissions 545 0.43% 97.71% 

Cullman Co Area Source NOx Emissions 537 0.42% 98.14% 

Blount Co Area Source NOx Emissions 476 0.37% 98.51% 

Chilton Co Non-Road NOx Emissions 371 0.29% 98.80% 

St.Clair Co Area Source NOx Emissions 370 0.29% 99.09% 

Chilton Co Area Source NOx Emissions 291 0.23% 99.32% 

Chilton Co Point Source NOx Emissions 271 0.21% 99.53% 

Bibb Co Non-Road NOx Emissions 246 0.19% 99.72% 

Cullman Co Point Source NOx Emissions 216 0.17% 99.89% 

Bibb Co Area Source NOx Emissions 118 0.09% 99.98% 

Bibb Co Point Source NOx Emissions 26 0.02% 100.00% 

Blount Co Point Source NOx 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-13 
0

10,000

20,000

30,000

40,000

50,000

60,000

Tons per Year

Birmingham CSA - NOx 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 NOx Emissions for the Birmingham CSA 

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

45,000

Tons 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

25,000,000

Vehicle 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 2007
Birmingham 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 indicates that there is significant commuting from Blount and St. Clair 

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 the Birmingham Nonattainment Area. 

F. Expected Growth (including extent, pattern, and rate of growth) 

There is little information available about expected 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 County supports the inclusion of Shelby County in 

the Birmingham Nonattainment Area. Discussion elsewhere 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 NOX SIP Call for 22 states, including Alabama that, by 2004, 

was to result in large reductions in NOX 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 21
Figure A-5 Figure A-6 
Figure A-7 Figure A-8 
Figure A-9 Figure A-10 
Figure A-11 Figure A-12 
Figure A-13 Figure A-14 
Figure A-15 

Appendix B

B-1

ADEM recommends that the Huntsville Nonattainment 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 compelling 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 

MadisonM 17,120 1 11,176 1 

MorganM 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 difference 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 Center1

. 

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 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

400

Population 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 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

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 Population 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 Total Employment, Manufacturing Employment, 

and Retail Employment, respectively, for the Huntsville CSA. Madison and Lawrence 

Counties show similar growth trends in employment; 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 only 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 196,370 201,637 205,228 207,323 215,058 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

250,000

Population

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 2005Emissions (Tons)

% of Area Total 

Emissions 

umulative 

Madison Co Mobile NOx Emissions (Tons) 6,428 22.2% 22.2%

Morgan Co Point NOx Emissions (Tons) 3,797 13.1% 35.3%

Lawrence Co Point NOx Emissions (Tons) 2,693 9.3% 44.6%

Morgan Co Mobile NOx Emissions (Tons) 2,576 8.9% 53.5%

Limestone Co Mobile NOx Emissions (Tons) 2,380 8.2% 61.7%

Madison Co Non-Road NOx Emissions (Tons) 2,273 7.9% 69.6%

Madison Co Area NOx Emissions (Tons) 2,100 7.3% 76.8%

Limestone Co Non-Road NOx Emissions (Tons) 1,768 6.1% 82.9%

Morgan Co Non-Road NOx Emissions (Tons) 1,367 4.7% 87.7%

Lawrence Co Mobile NOx Emissions (Tons) 962 3% 91.0%

Morgan Co Area NOx Emissions (Tons) 851 2.9% 93.9%

Lawrence Co Non-Road NOx Emissions (Tons) 752 2.6% 96.5%

Limestone Co Area NOx Emissions (Tons) 407 1.4% 97.9%

Madison Co Point NOx Emissions (Tons) 375 1.3% 99.2%

Lawrence Co Area NOx Emissions (Tons) 208 0.7% 99.9%

Limestone Co Point NOx Emissions (Tons) 20 0.1% 100.0%

Area Total Emissions 28,956 

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

10,000

Tons 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 41,424 
0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

10,000

11,000

12,000

Tons 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 relatively 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

9,000,000

Vehicle 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 1,116,270 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 2,428,751 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 6,431,487 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 3,230,781 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-14
Huntsville 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 (including 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 276,700 312,734 324,153 349,713 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 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 the 

east 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 during 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 the 

Huntsville 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 of 

Environment 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 NOX SIP Call for 22 states, including Alabama that 

beginning in 2004, resulted in large reductions in NOX 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-19
Figure 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-20
Figure 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-21
Figure 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-22
Figure B-5 Figure B-6 

B-23
Figure B-7 Figure B-8 

B-24
Figure B-9 Figure B-10 

B-25
Figure B-11 Figure B-12 

B-26
Figure B-13 Figure B-14 

B-27
Figure B-15 Figure B-16 

B-28
B-29

Figure 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 included 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 

4th Max

(ppm) 

2007 

4th Max

(ppm) 

2008 

4th 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 compliance 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 nonattainment 

boundary. 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 NOx 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 compelling 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 lists 

these 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, NOx 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 NOx 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 difference 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 

Center1

 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

900

Population 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 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

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-6 
Columbus-Auburn-Opelika, GA-AL CSA Population Trends

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

200,000

Population

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 counties 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 next county (Lee County, AL). As previously 

documented, Auburn University is the largest employer 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

160,000

Number 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 10 20 30 40 50 60

Muscogee

Russell

Lee

Macon

Harris

Chattahoochee

Marion

Annual Tons per Square Mile

70

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 

NOx 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 have 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 are 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

7,000

Tons per Year

Columbus-Auburn Opelika CSA - NOx 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 NOx Emissions 4319 21.22% 21.22% 

Russell Co, AL Point Source NOx Emissions 2581 12.68% 33.90% 

Lee Co, AL Mobile Sources NOx Emissions 2284 11.22% 45.12% 

Russell Co, AL Mobile Sources NOx Emissions 1285 6.31% 51.44% 

Muscogee Co, GA Area Source NOx Emissions 1187 5.83% 57.27% 

Lee Co, AL Non-Road NOx Emissions 1168 5.74% 63.01% 

Macon Co, AL Mobile Sources NOx Emissions 1155 5.68% 68.68% 

Harris Co, GA Mobile Sources NOx Emissions 1146 5.63% 74.31% 

Muscogee Co, GA Non-Road NOx Emissions 1013 4.98% 79.29% 

Lee Co, AL Area Source NOx Emissions 727 3.57% 82.87% 

Russell Co, AL Non-Road NOx Emissions 569 2.80% 85.66% 

Russell Co, AL Area Source NOx Emissions 543 2.67% 88.33% 

Macon Co, AL Area Source NOx Emissions 318 1.56% 89.89% 

Lee Co, AL Point Source NOx Emissions 311 1.53% 91.42% 

Macon Co, AL Non-Road NOx Emissions 268 1.32% 92.73% 

Chattahoochee Co, GA Area Source NOx Emissions 263 1.29% 94.02% 

Marion Co, GA Non-Road NOx Emissions 254 1.25% 95.27% 

Harris Co, GA Non-Road NOx Emissions 248 1.22% 96.49% 

Chattahoochee Co, GA Mobile Sources NOx Emissions 241 1.18% 97.67% 

Harris Co, GA Area Source NOx Emissions 199 0.98% 98.65% 

Marion Co, GA Mobile Sources NOx Emissions 121 0.59% 99.25% 

Chattahoochee Co, GA Non-Road NOx Emissions 72 0.35% 99.60% 

Marion Co, GA Area Source NOx Emissions 57 0.28% 99.88% 

Muscogee Co, GA Point Source NOx Emissions 21 0.10% 99.99% 

Marion Co, GA Point Source NOx Emissions 3 0.01% 100.00% 

Macon Co, AL Point Source NOx Emissions 0 0.00% 100.00% 

Harris Co, GA Point Source NOx Emissions 0 0.00% 100.00% 

Chattahoochee Co, GA Point Source NOx 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

14,000

Tons 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 Traveled (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-18 
Columbus-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

5,000,000

Vehicle 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-19 
Columbus-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 (including 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 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 wind patterns observed in and around the Phenix 

City/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 Chattahoochee 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 the 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 NOX SIP Call for 22 states, including Alabama that, 

beginning in 2004, resulted in large reductions in NOX 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, 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 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 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-23 
D-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-24 
D-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-25 
D-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-26 
D-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-27 
D-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-28 
D-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

D-29 
D-7 D-8 
D-9 D-10 
D-11 D-12 
D-13 D-14 
D-15 D-16 
D-17 D-18