1 

### Georgia Area Designations f

or the

20 08 Ozone National Ambient Air Quality Standard s

The t able below identifies the area and associated counties in Georgia that EPA intends to designate as

no n attain ment for the 2008 o zone national ambient air quality stan dard s (20 08 NAAQS)

. In accordance with section 107(d) of the Clean Air Act, EPA must designate an area “nonattainment” if it is violating the 2008 ozone NAAQS or if it is contributing to a violation of the 2008 ozone NAAQS in a nearby

area. The technical analys i s supporting the intended boundaries for the nonattainment areas is provided

below.

Intended Nonattainment Areas in Georgia

Area Georgia ’s Recommended

Nonattainment Counties EPA’s Intended Nonattainment

Counties

Atlanta

- Sandy Springs

Gainesvill e , GA Cobb

DeKalb

Fulton Henry Barrow

Bartow

Cherokee Clayton

Cobb

Coweta

DeKalb

Dou glas Fayette Forsyth

Fulton

Gwinnett Henry

Newton

P aulding

Rockdale Spalding

Walton

EPA intends to designate the remaining counties in Georgia that are not listed in t he table above as

“ unclassifiable/ attainment ” for the 20 08 ozone NAAQS

.

The analysis below provides the basis for intended Atlanta nonattainment area boundar y . It relies on our analysis of whether and which monitors are violating the 20 08 o zone NAAQS

, based on certified air quality monitoring data from 2008

- 2010 and an evaluation of whether nearby areas are contributing to

such violations. EPA has evaluated contribution s from nearby areas based on a weight of evidence analysis considering the factors i dentified below. EPA issued guidance on December 4, 2008 that

identified these factors as ones EPA would consider in determining nonattainment area boundaries and recommended that states consider these factors in making their designations recommendations to EPA. 1

1 The December 4, 2008 guidance memorandum “Area Designations for the 2008 Revised Ozone National Ambient Air Quality Standards” refers to 9 factors. In this technical support document we have grouped the emissions

- related factors together under the heading of “Emissions and Emissions

- Related Data

, ” which results in 5 categories of factors.2

1. Air quality data (including the design value calculated for each Federal Reference Method (FRM) or Federal Equivalent Method (FEM) monitors in the area); See 40 CFR part 58

2. Emissions and emissions

- related data (including location of sources a nd population, amount of emissions and emissions controls, and urban growth patterns);

3. Meteorology (weather/transport patterns);

4. Geography and topography (mountain ranges or other basin boundaries);

5. Jurisdictional boundaries (e.g., counties , air districts, existing nonattainment areas, Indian

country , metropolitan planning organizations (MPOs))

Ground

- level ozone generally is not emitted directly into the air, but is created by chemical reactions between oxides of nitrogen (NOx) and volatile organic compou nds (VOC) in the presence of sunlight.

Because NOx and VOC emissions from a broad range of sources over a wide area typically contribute to

violations of the ozone standard s , EPA believes it is important to consider whether there are contributing

emission s from a broad geographic area. Accordingly, EPA chose to examine the 5 factors with respect

to the larger of the Combined Statistical Area (CSA) or Core Based Statistical Area (CBSA) associated with the violating monitor(s)

. 2 All data and information use d by EPA in this evaluation are the latest available to EPA and/or provided to EPA by states or tribes.

In EPA’s designations guidance for the 2008 ozone NAAQS EPA recommended examining

CSA/CBSA s because certain factors used to establish CSAs and CBSAs ar e similar to the factors EPA is using in this technical analysis to determine if a nearby area is contributing to a violation of the 20 08 ozone NAAQS. Congress required a similar approach in 1990 for areas classified as serious or above

for the 1

- hour ozo ne standard and EPA used the same basic approach in the designation process for the

1997 o zone NAAQS. Where a violating monitor is not located in a CSA or C BS A, EPA ’s guidance recommended using the boundary of the county containing the violating monitor a s the starting point for considering the nonattainment area’s boundary.

2 Lists of CBSAs and CSAs and their geographic components are provided at www.census.gov/population/www/metroareas/metrodef.html . The lists are periodically updated by the Office of Management and Budget. EPA used the most recent update, based on 2008 population estimates, issued on December 1, 2009 ( OMB Bulletin No. 10

- 02).3

Technical Analysis for Atlanta

- Sandy Springs

- Gainesville , GA

Figure 1 is a map of the Atlanta

- Sandy Springs

- Gainesville , GA area intended nonattainment area . The

map identifies the locations and design values of air quality monitors , county and other jurisdictional boundaries, the nonattainment boundary for the 1997 8

- hour ozone NAAQS and major transportation

arteries.

For purposes of the 1997 8

- hour ozone NAAQ S EPA designated the following 20 counties

nonattainment in their entirety: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Newton, Paulding, Rockdale, Spalding, and

Walton.

In M arch 2009

, Georgia recommended that the 20 counties previously designated nonattainment for the

1997 8

- hour ozone NAAQS and a portion of Heard County be designated as “nonattainment” for the 2008 ozone NAAQS based on air quality data from 2006

- 2008. Georg ia p rovided an update to the original recommendation in October 2011 based on preliminary air quality data from 200 9

- 201 1

. In its updated recommendation, Georgia recommended that only 4 counties (i.e., Cobb, DeKalb, Fulton and Henry) be designated “nonatt ainment” for the 2008 ozone NAAQS. These data are from FEM monitors sited and operated in accordance with 40 CFR Part 58. (Georgia Department of Natural Resources (GDNR) letters dated March 12, 2009 and October 25, 2011).4

After considering these recomme ndations and based on EPA's technical analysis described below, EPA intends to designate 18 counties in Georgia (identified in Table 1 below) as “nonattainment” for the 2008 ozone NAAQS as part of the Atlanta

- Sandy Spring s

- Gainesville nonattainment area. EPA is not intending to include Carroll and Hall Counties in the nonattainment area. These counties were designated as part of the previous nonattainment area for the 1997 ozone NAAQS.

Table 1. State's Recommended and EPA’s Intended Designated Nonattainm ent Counties for Atlanta

Sandy Springs

- Gainesville, GA

.

Atlanta

- Sandy Spring s

Gainesville , GA State

- Recommended

Nonattainment Counties EPA Intended

Nonattainment Counties Georgia Cobb

DeKalb

Fulton Henry Barrow

Bartow

Cherokee Clayton

Cobb

Coweta

DeKalb

Dou glas Fayette Forsyth

Fulton

Gwinnett Henry

Newton

P aulding

Rockdale Spalding

Walton

Factor Assessment



### Factor 1: Air Quality Data

For this factor , we considered 8

- hour o zone design values (in p arts per billion (p p b) ) for air quality

monitors i n counties in the Atlanta

- Sandy Springs

- Gainesville , GA area based on data for the 2008

- 2010 period (i.e., the 2010 design value, or DV) , which are the most recent years with fully

- certified air quality data

. A monitor’s DV is the metric or statistic that indicates whether that monitor attains a specified air quality standard. The 2008 o zone NAAQS are met at a monitor when the annual f ourth

highest daily maximum 8

- hour average concentration, averaged over 3 years is 75 ppb or less

. A DV is only valid if minimum data completeness criteria are met. See 40 CFR part 50 App endix P . Where several monitors are located in a county (or a designated nonattainment area or maintenance area ), the

DV for the county or area is determined by the monitor with the highes t level.

The 2010 DVs for the o zone NAAQS for counties with monitors in the Atlanta

- Sandy Springs

Gainesville , GA area and nearby surrounding area are shown in Table 2

. (Counties not identified do not have monitors)5

Table 2 . Air Quality Data

. County * State Recommended

Nonattainment? 2008

- 2010 Design Value (ppb) Cobb, GA Yes 76
Coweta, GA No 68 DeKalb, GA Yes 79 Douglas, GA No 75 Fulton, GA Yes 80 Gwinnett, GA No 74 Henry, GA Yes 79 Paulding, GA No 70 Rockdale, GA No 78

*Counties with viola ting monitors are shown in bold.

Cobb, DeKalb, Fulton

, Henry and Rockdale Counties show a violation of the 2008 ozone NAAQS,

therefore these counties are included in the nonattainment area. A county (or partial county) must also be designated nonattainme nt if it contributes to a violation in a nearby area. Each county without a violating monitor that is located near a county with a violating monitor has been evaluated , as discussed below, based on the five factors and other relevant information to determ ine whether it contributes to the nearby violation

. Bartow, Clayton , Cherokee, Coweta , Douglas, Fayette, Forsyth, Gwinnett, Newton, Paulding, Spalding and Walton Counties are next to counties with violating monitors. A small portion of Carroll County con nects to a county with a violating monitor

, however, Carroll County is adjacent to three other counties with attaining monitors of closer proximity. Hall County is adjacent to two counties with attaining monitors and Barrow Count y is adjacent to a county with a n attaining monitor.



### Factor 2: Emissions and Emissions

- Related Data

EPA evaluated emissions of ozone precursors nitrogen oxide (NOx) emissions tot al, and volatile organic compounds (VOC) and other emissions

- related data that provide information on areas contributing to violating monitors.

Emissions Data

EPA evaluated county

- level emission data for NOx and VOC derived from the 2008 National Emissions Inventory (NEI), version 1.5. This is the most recently available NEI. (See http://www.epa.gov/ttn/chief/net/2008inventory.html ) Significant emissions levels in a nearby area indicate the potential for the area to contribute to observed violations. We will also consider a ny additional information we receive on changes to emissions levels that are not reflected in recent inventories. These changes include emissions reductions due to permanent and enforceable emissions controls that will be in place before final designations are issued and emissions increases due to new

sources

. The precursor emission source

- category percentages used below and throughout the document

were derived from emissions data from the 2008 NEI version 1.5 referenced above.

Table 3 shows emissions of NO x and VOC (given in tons per year (tpy) ) for violating and nearby

counties in the Atlanta

- Sandy Springs

- Gainesville , GA

- AL CSA that we considered for inclusion in the

Atlanta

- Sandy Springs

- Gainesville , GA area.6

Table 3. Total 2008 NO x and VOC Emis sions.

County * State Recommended

Nonattainment? NO x (tpy) VOC (tpy)

Barrow No 1,765 2,291

Bartow No 31,560 6,165

Butts No 1,231 1,200

Carroll No 3,757 4,617 Chambers, AL No 1,408 1,644

Cherokee No 4,908 6,189 Clayton No 16,105 9,528

Cobb Yes 20,87 4 22,494

Coweta No 15,852 3,723

Dawson No 626 1,058

DeKalb Yes 17,356 22,937 Douglas No 3,368 3,968 Fayette No 2,732 3,556 Forsyth No 3,823 5,753

Fulton Yes 28,630 31,707

Gwinnett No 18,569 24,506

Hall No 5,756 8,815

Haralson No 1,116 2,118

Hear d No 15,093 1,177 Henry Yes 7,584 6,015 Jasper No 526 850

Lamar No 656 858

Meriwether No 1,481 1,369

Newton No 3,307 4,248 Paulding No 2,780 3,037

Pickens No 888 1,366

Pike No 412 661

Polk No 1,429 2,279

Rockdale No 2,483 2,961 Spalding No 1,828 2,862 Troup No 2,966 4,232 Upson No 926 1,897

Walton No 2,245 3,137

Areawide: 224,040 199,218 *Counties that EPA intends to designate as nonattainment are shown in bold.

NOx Emissions: Bartow, Clayton, Cobb, Coweta, DeKalb, Fulton, Gwinnett and Hea rd Counties have over 15,000 tons of NOx emissions annually. Bartow, Clayton

, Coweta and Heard Counties have over

60 percent of NOx emissions coming from point sources.

Barrow, Carroll, Cherokee, Douglas, Fayette, Forsyth, Hall, Henry, Newton, Paulding , Rockdale, Spalding, Troup and Walton Counties have between 1,700 and 8,000 tons of NOx emissions annually.7

Barrow, Butts, Carroll, Chambers, Cherokee, Cobb, Dawson, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Haralso n, Henry, Jasper, Lama r, Meriwether, Newton, Paulding, Pickens, Pike, Poke, Rockdale, Spalding Troup, Upson and Walton Counties have over 30 percent of NOx emissions being emitted by mobile sources.

VOC Emissions: Cobb

, DeKalb, Fulton and Gwinnett Counties have over 20,000 tons of VOC emissions annually. Barrow, Bartow, Butts, Carroll, Cherokee, Clayton, Cobb, Coweta, Dawson, DeKalb, Douglas, Fayette, Fulton, Gwinnett, Hall, Henry, Lamar, Meriwether, Newton, Paulding, Pickens, Pike, Rockdale, Spalding Troup, and Walton Coun ties have over 30 percent of VOC emissions being emitted by mobile sources.

Barrow, Bartow, Butts, Carroll, Chambers, Cherokee, Clayton, Cobb, Coweta, Dawson, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Haralson, Henry, Jasper, Lamar, Mer iwether, Newton, Paulding, Pickens, Pike, Poke, Rockdale, Spalding Troup, Upson and Walton Counties have over 30 percent of VOC emissions being emitted by area sources.

Based upon this factor and the close proximity to counties with violating monitors

, the following

counties could not be excluded from consideration: Barrow, Bartow, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Rockdale, Spalding

and Walton.

Population density and degree o f urbanization

EPA evaluated the population and vehicle use characteristics and trends of the area as indicators of the probable location and magnitude of non

- point source emissions . These include ozone

- creating

emissions from on

- road and off

- road vehicl es and engines, consumer products, residential fuel combustion, and consumer services. Areas of dense population or commercial development are an indicator of area source and mobile source NOx and VOC emissions that may contribute to counties

with violati ng monitors

. Rapid population or vehicle miles travelled (VMT) growth (see below) in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that it may be appropriate to include the area associated with t he area source and mobile source emissions as part of the nonattainment area. Table 4 shows the population, population density, and population growth information for each county in the area.

Table 4 . Population and Growth.

County * State

Recommended

Nona ttainment? 20 10 Population 20 10 Population Density (1000 pop/sq mi) Absolute change

in population (2000

- 2010) Population %

change (2000

- 20 10 )
Barrow No 69,367 426 22,806 49

Bartow No 100,157 213 23,456 31

Butts No 23,655 125 3,926 20

Carroll No 110,52 7 219 22,526 26

Chambers , AL No 34,215 57

- 2,347

- 6

Cherokee No 214,346 493 70,603 49 Clayton No 259,424 1,797 21,056 9

Cobb Yes 688,078 1,996 75,436 12

Coweta No 127,317 285 37,168 41

Dawson No 22,330 104 6,031 378

DeKalb Yes 691,893 2,546 23,078 3 Douglas No 132,403 661 39,700 43 Fayette No 106,567 536 14,494 16 Forsyth No 175,511 709 75,013 75

Fulton Yes 920,581 1,721 103,429 13

Gwinnett No 805,321 1,844 208,978 35

Hall No 179,684 419 38,805 28

Haralson No 28,780 102 2,947 11

Heard No 11,83 4 39 749 7 Henry Yes 203,922 627 82,342 68 Jasper No 13,900 37 2,413 21

Lamar No 18,317 99 2,347 15

Meriwether No 21,992 43

- 535

- 2

Newton No 99,958 358 37,074 59 Paulding No 142,324 452 59,329 71

Pickens No 29,431 127 6,072 26

Pike No 17,869 81 4, 071 30

Polk No 41,475 133 3,226 8

Rockdale No 85,215 645 14,657 21 Spalding No 64,073 320 5,591 10
Troup No 67,044 150 8,121 14 Upson No 27,153 83

- 462

- 2

Walton No 83,768 254 22,207 36

Areawide: 5,618,431 Average 536 1,034,307 874

*Counties that E PA intends to designate as nonattainment are shown in bold.

Source s : U.S. Census Bureau population estimates for 20 10 as of August 4, 2011 ( http://factfinder2.census.gov/faces/tableservices/jsf/pages/productview.xhtml?pid=DEC_10_PL_GCTPL2.STO5&
prodType=table )

.

Cobb, DeKalb, Fulton and Gwinnett Counties are the most populated with each county having over 650,000 population and a population density of over 1,700 people per square mile. Bartow, Carroll, Cherokee, Clayton, Coweta, Douglas, Fayette, Forsyth, Hall, Henry and Paulding Counties have over a 100,000 population. Barrow, Cherokee, Douglas, Fayette, Forsyth, Hall, Hen ry, Newton, Paulding, Rockdale and Spalding Counties have between 300 and 750 people per square mile. Barrow, Butts, Clayton, Douglas, Fayette, Lamar, Rockdale and Spalding Counties are 200 square miles or less in size.

Gwinnett County had a population g rowth over 200,000 between 2000 and 2010. Cherokee, Cobb, Forsyth, Fulton, Henry and Paulding Counties had over 59,000 population growth between 2000 and

2010.

Forsyth, Henry, Newton and Paulding Counties had a population growth rate over 5 0 percent bet ween 2000 and 2010. Barrow, Cherokee, Coweta, Dawson, Douglas, Gwinnett and Walton Counties had a population growth rate over 30 percent between 2000 and 2010.

Based upon this factor and the close proximity to counties with violating monitors, the follow ing counties could not be excluded from consideration: Barrow, Bartow, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry , Newton, Paulding

, Rockdale, Spalding

and Walton.9

Traffic VMT data and commuting patterns

E PA evaluated the commuting patterns of residents in the area, as well as the total VMT for each

county . In combination with the population/population density data and the location of main transportation arteries (see above), this information helps identif y the probable location of non

- point

source emissions. A county with high VMT and/or a high num b er of commuters is generally an integral part of an urban area and indicates the presence of motor vehicle emissions that may contribute to ozone

formation that contributes to nonattainment in the area. Rapid population or VMT growth in a county on the urban perimeter signifies increasing integration with the core urban area, and indicates that the associated area source and mobile source emissions may be appropr iate to include in the nonattainment

area. Table 5 shows total 2008 VMT.

Table 5 . Traffic and VMT Data

County * State

Recommended

Nonattainment? 200 8 VMT **

(million miles)

Barrow No 552

Bartow No 1,663

Butts No 302

Carroll No 1,117

Chambers , AL No 4 19

Cherokee No 1,813 Clayton No 2,600

Cobb Yes 6,601

Coweta No 1,297

Dawson No 190

DeKalb Yes 7,410 Douglas No 1,520 Fayette No 1,028 Forsyth No 1,310

Fulton Yes 11,414

Gwinnett No 7,064

Hall No 1,507

Haralson No 339

Heard No 105 Henry Yes 2 ,153 Jasper No 129

Lamar No 232

Meriwether No 290

Newton No 1,021 Paulding No 1,112

Pickens No 297

Pike No 145

Polk No 365

Rockdale No 960 Spalding No 588 Troup No 879 Upson No 252

Walton No 72010 Areawide: 57,394

* Counties that EPA intends to designate as nonattainment are shown in bold.

* * MOBILE model VMTs are those inputs into the NEI version 1.5.

Cobb, DeKalb and Fulton Counties had over six billion VMT in 2008. Bartow, Carroll, Cherokee, Clayton, Coweta, Douglas, Fayette, Fo rsyth, Gwinnett, Hall, Henry, Newton and Paulding Counties had

over a billion VMT in 2008.

Based upon this factor, the following counties could not be excluded from consideration: Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette , Forsyth, Fulton, Gwinnett, Hall, Henry, Newton and Paulding

.



### Factor 3: Meteorology (weather/transport patterns)

For this factor, EPA analyzed 30

- years of National Weather Service (NWS) wind speed and wind

direction data collected at the Atlanta Intern ational Airport to help determine transport patterns and source contributions. EPA assessed wind direction and speed for the 2008

- 2010 “ozone season” (March through October) in the Atlanta

- Sandy Springs

- Gainesville , G eorgia Area

. These analyses were

cond ucted to better understand the fate and transport of precursor emissions contributing to ozone

formation. EPA’s analysis of the NWS data indicate predominate east, northwest and west direction, component for the Atlanta

- Sandy Springs

- Gainesville , G eorgia Area

.

The predominant winds in the Atlanta

- Sandy Springs

- Gainesville , G eorgia Area blow from the east, northwest and west direction, indicating counties from east (Coweta, Douglas and Paulding), northwest (Bartow) and west (Barrow, Gwinnett, Newton and Wa lton) direction could not be excluded for contributing to violations at the monitors in Cobb, DeKalb, Fulton

, Henry and Rockdale Counties

.



### Factor 4: Geography/topography (mountain ranges or other air basin boundaries)

The geography/topography analysis e valuates the physical features of the land that might affect the airshed and, therefore, the distribution of ozone over the area

.

The Atlanta

- Sandy Springs

- Gainesville , GA area does not have any geographical or topographical barriers significantly limitin g air pollution transport within its air shed. Therefore, this factor did not play a significant role in this evaluation

.



### Factor 5: Jurisdictional boundaries

Once we identified the general areas we anticipated we would recommend should be included in the nonattainment area, we then consider ed existing jurisdictional boundaries for the purposes of providing a clearly defined legal boundary and to help identify the areas appropriate for carrying out the air quality planning and enforcement functions for nonattainment areas. Examples of jurisdictional boundaries include existing/prior nonattainment area boundarie s for ozone or other urban

- scale pollutants, county

lin es, air district boundarie s, township boundarie s, area covered by a MPOs , state lines, Are as of Indian Country

, and urban growth boundary. Where existing jurisdictional boundaries were not adequate or appropriate to describe the nonattainment area, other clearly defined and permanent landmarks or geographic c oordinates were considered.11

The At lanta

- Sandy Springs

- Gainesville , GA area has previously established nonattainment boundaries

associated with the both the 1

- hour and the 1997 8

- hour ozone N AAQS. The Atlanta nonattainment boundary for the 1

- hour ozone NAAQS included 13 counties in Georgia in their entireties: Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Fo rsyth, Fulton, Gwinnett, Henry, Paulding, and

Rockdale . Whereas the Atlanta nonattainment boundary for the 1997 8

- hour ozone NAAQS included 20 counties in Georgia in their entireties: Barrow, Bartow, Carroll, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Hall, Henry, Newton, Paulding, Rockdale, Spal ding, and Walton

. The EPA recommended Atlanta

- Sandy Springs

- Gainesville , GA nonattai nment boundary for the 2008 ozone NAAQS differs from the previous nonattainment boundary for the 1997 ozone NAAQS by the e xclusion of Carroll and Hall Counties. The State ha s recommended a different boundary for the 2008 ozone NAAQS.



### Conclusion

Based on the assessment of factors described above, EPA has preliminarily concluded that the following

counties should be included as part of the Atlanta

- Sandy Springs

- Gainesville , GA nonattainment area because they are either violating the 2008 ozone NAAQS or c ontributing to a violation in a nearby area : Barrow, Bartow, Cherokee, Clayton, Cobb, Coweta, DeKalb, Douglas, Fayette, Forsyth, Fulton, Gwinnett, Henry, Newton, Paulding, Rockdale, Spalding, and Walton in Georgia

. All of these counties

are included in t he Atlanta nonattainment area for the 1997 ozone NAAQS. The air quality monitors in Cobb, DeKalb, Fulton , Henry and Rockdale Counties in Georgia indicate violations of the 2008 ozone NAAQS based on 2010 DVs, therefore these counties are preliminarily incl uded in the nonattainment

area. Barrow, Bartow, Cherokee, Clayton, Coweta, Douglas, Fayette, Forsyth, Gwinnett , Newton, Paulding, Spalding, and Walton Counties in Georgia are nearby counties that do not have violating monitors, but EPA has preliminarily c oncluded that these areas contribute to the ozone concentrations in violation of the 2008 ozone NAAQS as summarized below. Two additional counties (i.e., Carroll and Hall Counties, Georgia) are included in the nonattainment area for the 1997 ozone NAAQS b ut are not being included in the preliminary 2008 ozone area. The EPA is not recommending including these two counties in the nonattainment area because both counties: had over 30 percent reduction in NOx and VOC emissions; less than 30 percent populatio n growth between 2000 and 2010; distance from counties with violating monitors limits the impact due to meteorological conditions and both counties have several attaining monitors between them and a violating monitor. Carroll County has a small portion

co nnecting to a county with a violating monitor; however, Carroll County is adjacent to three other counties with attaining monitors of closer proximity. Hall County is not adjacent to any county with a violating monitor but is adjacent to two counties with attaining monitors.

Barrow County: is adjacent to a county with an attaining monitor; has 1765 tons of NOx emissions and 2,291 tons of VOC emissions annually; 65 percent of NOx emissions are being emitted by mobile sources, 48 percent of VOC emissions b y area sources and 43 percent emitted by mobile sources; there

are 426 people per square mile with a county size of only 163 square miles; has a 2010 population of 69,367 with a growth rate 49 percent between 2000 and 2010

.

Bartow County: is adjacent to county with a violating monitor; has 31,560 tons of NOx emissions and 6,165 tons of VOC emissions annually; 81 percent of NOx emissions are being emitted by point sources, 45 percent of VOC emissions by mobile sources and 37 percent of VOC emissions by ar ea sources; has a 2010 population over 100,000; has over a billion VMT in 2008.

Cherokee County: is adjacent to county with a violating monitor, has 4,908 tons of NOx emissions and 6,189 tons of VOC emissions annually; 65 percent of NOx emissions are be ing emitted by mobile12

sources, 35 percent of VOC emissions by mobile sources and 42 percent of VOC emissions by area sources; has a 2010 population of 214,346; there are 493 people per square mile; had a 57 percent population growth between 2000 and 2010; had over a billion VMT in 2008

.

Clayton County: is adjacent to county with a violating monitor; has 16,105 tons of NOx emissions and 9,528 tons of VOC emissions annually; 63 percent of NOx emissions are being emitted by point sources, 32 percent of VOC emissions by mobile sources and 34 percent of VOC emissions by area sources; has a 2010 population of 259,424; there are 1,797 people per square mile with a county size of only 144 square miles; had over two billion VMT in 2008.

Coweta County: is adja cent to county with a violating monitor; has 15,852 tons of NOx emissions and 3,723 tons of VOC emissions annually; 79 percent of NOx emissions are being emitted by point sources, 37 percent of VOC emissions by mobile sources and 45 percent of VOC emission s by area sources; had a 2010 population of 127,317; had a population growth rate of 41 percent between 2000 and 2010; had

over a billion VMT in 2008.

Douglas County: is adjacent to county with a violating monitor; has 3,368 tons of NOx emissions and
3, 968 tons of VOC emissions annually; 75 percent of NOx emissions are being emitted by mobile sources, 45 percent of VOC emissions by mobile sources and 49 percent of VOC emissions by area sources; had a 2010 population of 132,403; has a population density of 661 people per square mile with a county size of only 200 square miles; had a 43 percent population growth rate between 2000 and 2010;

over a billion VMT in 2008

.

Fayette County: is adjacent to county with a violating monitor; has 2,732 tons of NOx em issions and 3,556 tons of VOC emissions annually; 64 percent of NOx emissions are being emitted by mobile sources, 37 percent of VOC emissions by mobile sources and 50 percent of VOC emissions by area sources; has a 2010 population of over a 106,567; has a population density of 536 people per square mile with a county size of only 199 square miles; over a billion VMT in 2008.

Forsyth County: is adjacent to county with a violating monitor; has 3,823 tons of NOx emissions and 5,753 tons of VOC emissions an nually; 60 percent of NOx emissions are being emitted by mobile sources, 50 percent of VOC emissions by area sources and 29 percent of VOC emissions by mobile sources; had a 2010 population of 175,511; has a population density of 709 people per square mile ; had a 75 percent population growth between 2000 and 2010; over a billion VMT in 2008

.

Gwinnett County: is adjacent to county with a violating monitor; has 18,569 tons of NOx emissions and 24,506 tons of VOC emissions annually; 60 percent of NOx emissio ns are being emitted by mobile sources, 34 percent of VOC emissions by mobile sources and 47 percent of VOC emissions by area sources; had a 2010 population of 805,321; has a population density of 1,844 people per square mile; population growth rate of 35 percent between 2000 and 2010; had seven billion VMT in 2008.

Newton County: is adjacent to county with a violating monitor; has 3,307 tons of NOx emissions and 4,248 tons of VOC emissions annually; 67 percent of NOx emissions are being emitted by mobile sources, 49 percent of VOC emissions by mobile sources and 37 percent of VOC emissions by area sources; had a 2010 population of 99,958; has a population density of 358 people per square mile; 59 percent population growth between 2000 and 2010; over a bil lion VMT in 2008.

Paulding County: is adjacent to county with a violating monitor; has 2,780 tons of NOx emissions and 3,037 tons of VOC emissions annually; 66 percent of NOx emissions are being emitted by mobile13

sources, 47 percent of VOC emissions by m obile sources and 44 percent of VOC emissions by area sources; had a 2010 population of 142,324; has a population density of 452 people per square mile; 71 percent population growth between 2000 and 2010; over a billion VMT in 2008.

Spalding County: is adjacent to county with a violating monitor; has 1,828 tons of NOx emissions and 2,862 tons of VOC emissions annually; 71 percent of NOx emissions are being emitted by mobile sources, 41 percent of VOC emissions by mobile sources and 46 percent of VOC emis sions by area sources; had a 2010 population of 64,073; 10 percent population growth between 2000

- 2010 with a county size of only 200 people per square mile

.

Walton County: is adjacent to county with a violating monitor; has 2,245 tons of NOx emissions and 3,137 tons of VOC emissions annually; 69 percent of NOx emissions are being emitted by mobile sources, 43 percent of VOC emissions by mobile sources and 44 percent of VOC emissions by area sources; had a 2010 population of 83,768; a population growth r ate of 36 percent between 2000 and

2010

.