Responses to Significant Comments on the State and
Tribal Designation Recommendations for the 2012
Annual PM2.5 National Ambient Air Quality Standard
(NAAQS)
Docket Number the EPA-HQ-OAR-2012-0918
U.S. Environmental Protection Agency
December 2014
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Responses to Significant Comments 2012 Annual PM2.5 NAAQS
December 17, 2014
Table of Contents
List of Acronyms 3
1.0 Introduction 5
2.0 Background 5
3.0 Responses to Significant Comments on the State and Tribal Designation
Recommendations for the 2012 annual PM2.5 National Ambient Air Quality Standard
(NAAQS) 6
3.1 General Issues 6
3.1.1. Data Considerations 6
3.1.2. Requests to Extend the Public Comment Period 9
3.1.3. Other General Comments 9
3.2 Area-Specific Issues 10
3.2.1. EPA Region III 10
3.2.2. EPA Region IV 22
3.2.3. EPA Region V 27
3.2.4. EPA Region VI 54
3.2.5. EPA Region IX 57
3.2.6. EPA Region X 58
3.2.7. Multi-Region Areas 63
3.2.7.1. Louisville, KY-IN. 63
3.2.7.2. Cincinnati-Hamilton, OH-KY 65
3.2.7.3. St. Louis, MO-IL 67
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List of Acronyms
APCD
Air Pollution Control District
AQS
Air Quality System
CAA
Clean Air Act
CBS A
Core Based Statistical Areas
CFR
Code of Federal Regulations
CSA
Combined Statistical Area
CSPAR
Cross-state Air Pollution Rule
DFW
Dallas-Fort Worth, Texas
EER
Exceptional Events Rule
EGU
Electric Generating Unit
EPA
Environmental Protection Agency
FR
Federal Register
GAEPD
Georgia Environmental Protection Division
HGB
Houston-Galveston-Brazoria, Texas
HYSPLIT
Hybrid Single Particle Lagrangian Integrated Trajectory Model
IEPA
Illinois Environmental Protection Agency
I/M
(Vehicle) Inspection and Maintenance
[j,g/m3
Micrograms per cubic meter
MPO
Metropolitan Planning Organization
MSA
Metropolitan Statistical Area
NAA
Nonattainment Area
NAAQS
National Ambient Air Quality Standard
NEI
National Emissions Inventory
NFR
Notice of Final Rulemaking
NLLJ
Nocturnal Low Level Jet
NO A A
National Oceanic and Atmospheric Administration
NOx
Oxides of Nitrogen
NSPS
New Source Performance Standards
NSR
New Source Review
OAQPS
EPA Office of Air Quality Planning and Standards
OMB
Office of Management and Budget
PM2.5
Fine Particulate Matter
PSD
Prevention of Significant Deterioration
QAPP
Quality Assurance Project Plan
QA/QC
Quality Assurance/Quality Control
RICE
Reciprocating Internal Combustion Engine
SC DEHC
South Carolina Department of Health and Environmental Control
SIP
State Implementation Plan
SLAMS
State and Local Air Monitoring Stations
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TCEQ
Texas Commission on Environmental Quality
TPY
Tons per Year
TSD
Technical Support Document
TVA
Tennessee Valley Authority
VMT
Vehicle Miles Traveled
VOC
Volatile Organic Compounds
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1.0 Introduction
This document, together with the preamble to the final rule, and the Technical
Support Documents (TSDs) for the designations, presents the EPA's responses to the
significant comments we received on our proposed designations. The responses presented
in this document are intended to augment the responses to comments that appear in the
preamble to the final rule and the TSDs or to address comments not discussed in those
documents. Commenters can find TSDs in the electronic docket for this action
(www.regulations.gov, docket number the EPA-HQ-OAR-2012-0918) and at the EPA's
PM Designations Web Page
(http://www.epa.gov/pmdesignations/2012standards/index.htm).
2.0 Background
On December 14, 2012, the EPA promulgated a revised primary annual PM2.5 NAAQS
(78 FR 3086, January 15, 2013). In that action, the EPA revised the primary annual PM2.5
standard, strengthening it from 15.0 micrograms per cubic meter (|ig/m3) to 12.0 (J,g/m3;
retained the existing 24-hour PM2.5 standard at 35 (J,g/m3; retained the existing 24-hour
PM10 (coarse particle) standard at 150 |ig/m3; and retained the current suite of secondary
PM standards. The EPA revised the primary annual PM2.5 standard based on an integrated
assessment of an extensive body of new scientific evidence, which substantially
strengthens our body of knowledge regarding PIVfo.s-related health effects. The revised
primary annual PM2.5 standard will provide increased protection for children, older adults,
persons with pre-existing heart and lung disease, and other at-risk populations against an
array of PIvfc.s-related adverse health effects, including premature mortality, increased
hospital admissions and emergency department visits, and development and exacerbation
of chronic respiratory disease.
History shows us that better health and cleaner air go hand-in-hand with economic
growth. Working closely with the states and tribes, the EPA is implementing the standard
using a commonsense approach that improves air quality and minimizes the burden on
state, local, and tribal governments. As part of this routine process, the EPA is working
with the states and tribes to identify areas in the country that meet the standard and those
that need to take steps to reduce PM2.5 air pollution. Within 1 year of promulgating a new
or revised air quality standard, the Clean Air Act requires the Governor of each state to
submit to the EPA a list of all areas in the state, with a designation recommendation for
each area. As a first step in implementing the 2012 annual PM2.5 standard, Governors
(and tribal leaders, if they chose) were to submit their designation recommendations,
including appropriate area boundaries, by December 13, 2013.
On August 19, 2014, the EPA sent letters (the "120-day letters") to state and tribal
representatives responding to their recommendations and identifying those areas
anticipated to meet the 2012 annual PM2.5 standards and those that do not. States, tribes,
and the public had the opportunity to comment on the EPA's proposed decisions before
the Agency issued final area designations, and to provide new information and analyses
to the EPA, if appropriate. Following are summaries of significant comments received on
the 2012 annual PM2.5 designation recommendations and the EPA's responses to those
comments.
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3.0 Responses to Significant Comments on the State and Tribal
Designation Recommendations for the 2012 annual PM2.5 National
Ambient Air Quality Standard (NAAQS)
The following sections address the comments received by the EPA on the state and tribal
PM2.5 designation recommendations for the 2012 annual PM2.5 NAAQS. Comment
summaries and responses are presented below.
3.1 General Issues
3.1.1. Data Considerations
Comment: Several states, including Georgia, Indiana, Ohio, and Pennsylvania, believe
that data for one or more of the areas violating the 2012 annual PM2.5 NAAQS based on
2011-2013 air quality data may show attainment based on 2012-2014 air quality data.
Because the EPA is promulgating initial area designations in December 2014, which is
very close to the end of the 2014 data year, these states asked the EPA to consider 2012-
2014 data in their designation decisions, or to defer the designations process until after
2014 data are complete and state and federal regulators have an opportunity to consider
areas that may have come into attainment. One commenter noted that deferring
designations to allow consideration of 2014 data would constitute a minimal delay in the
designations process and would eliminate needlessly subjecting these areas to further
nonattainment requirements and burdening the states and the federal government with
developing plans, redesignation requests and maintenance plans for areas that allegedly
do not necessitate these activities.
EPA Response: The EPA is basing initial area designation decisions for most areas for
the 2012 annual PM2.5 NAAQS on air quality monitoring data for the 2011-2013 time
period because these data represent the most recent certified data available in August
2014 at the time the EPA notified states of any intended revisions to the states' and
tribes' designation recommendations. However, because the EPA is making final
designation decisions in December 2014, we believe it is appropriate to allow interested
states and tribes to early certify their 2014 data ahead of the May 1, 2015 deadline
specified in 40 CFR part 58.15(a)(2). States and tribes wishing to certify and submit their
2014 data for consideration in final designation decisions, should submit the certified
2014 data for all monitors in the desired area by February 27, 2015. The EPA established
this deadline to ensure that we would have adequate time to evaluate the new technical
information and complete the interactive process between the EPA and the states, as
contemplated by the Act, as we determine the final area designations.
Comment: State commenters, including Alabama and Texas, note that through the
regulatory provisions in 40 CFR Sections 50.13 and 50.18, the EPA establishes the
requirements for operating state ambient air quality monitoring networks. The EPA then
verifies through technical systems audits that air agencies are following these
requirements. The EPA also uses these monitoring data to determine when the primary
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and secondary PM2.5 NAAQS are met. The commenters believe that unless these criteria
are not met, areas with monitor values that meet the specified criteria should be
designated attainment. The commenters believe a designation of "attainment" is further
supported by the definitions in the Clean Air Act. CAA sections 107(d)(l)(A)(i), (ii) and
(iii) (42 U.S.C. 7407) which provide definitions for "attainment," "nonattainment," and
"unclassifiable," but do not include a definition for "unclassifiable/attainment."
Commenters note that the EPA uses the category "unclassifiable/attainment" "without
clear definition, criteria, or statutory basis" to designate those areas that are monitoring
attainment and for areas that do not have monitors but for which the EPA has reason to
believe are likely attainment and are not contributing to nearby violations. The state
commenters recommend that areas monitoring attainment should be designated as
attainment in December 2014.
EPA Response: In the April 16, 2013, guidance Initial Area Designations for the 2012
Revised Primary Annual Fine Particle National Ambient Air Quality Standard, the EPA
said that states could submit recommendations identifying areas as "attainment," but that
the EPA expected to continue to use the "unclassifiable/attainment" category for
designations for the 2012 annual PM2.5 NAAQS. (See footnote 2 at page 2). As we have
done with past initial area designation efforts for other NAAQS, for these designations,
the EPA is using a designation category of "unclassifiable/attainment" for areas that are
monitoring attainment and for areas that do not have monitors but for which the EPA has
reason to believe are likely attainment and are not contributing to nearby violations. The
EPA is using "unclassifiable" for those areas where the EPA was not able to determine
based on available information whether the area is meeting or not meeting the NAAQS,
or where the EPA was not able to determine that the area contributes to a nearby
violation.
Comment: One commenter expresses concern about the EPA's proposal to designate
numerous areas as "unclassifiable" based on data quality and completeness issues. The
commenter notes that because the EPA has historically treated unclassifiable areas as
though they meet the standard and are not subject to the stronger protections required for
nonattainment areas, the EPA is effectively denying millions of people the protection
they deserve under the standard. The commenter adds that under previous designations
efforts, the EPA has taken the position that once it has designated an area as
unclassifiable, the Agency had no obligation to redesignate the area, even if adequate
data showing nonattainment become available. The commenter adds that following this
course of action encourages states to "follow sloppy or deficient data collection and
analyses" because it results in the "reward" of avoiding a nonattainment designation.
The commenter recommends that the EPA pursue the following:
• For historically nonattaining areas (i.e., Chicago, St. Louis, Atlanta, and
Knoxville) with invalid or incomplete 2011-2013 data, use the most recent prior
years for which adequate, quality-controlled data show violation of the 2012
annual PM2.5 NAAQS unless the EPA provides evidence showing that air quality
has improved and no longer violates the standard (treating such areas as anything
other than nonattainment is arbitrary and unlawful).
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• Alternatively, extend the time for promulgating final designations by the additional
year provided under 42 U.S.C. §7407(d)(l)(B)(i) for the portions of the eight
states/territories for which the EPA is proposing unclassifiable designations based
on data quality/completeness issues (Puerto Rico; U.S. Virgin Islands; Atlanta,
Glynn County and Dougherty County, Georgia; Tennessee (except Chattanooga);
Illinois; St. Louis, Missouri; and areas of Indian Country, CA). Commenter notes
that the EPA has proposed to provide such an additional year for designations in
Georgia, and there is no reason to take a different approach as to the other areas
with data adequacy and quality issues.
• As was done with the recent 1-hour sulfur dioxide standard, develop a plan to
designate areas with insufficient monitoring data based on modeling or additional
monitoring.
• The EPA must also put in place steps to work with the states and tribes to review
the available data and to expeditiously update the laboratory systems to restore the
quality controls needed for the data measurement.
EPA Response: The EPA appreciates the commenter's concerns and acknowledges that
the extent of incomplete/invalid data associated with the initial area designations for the
2012 annual PM2.5 NAAQS is unprecedented. The EPA also agrees with the commenter
that it makes sense to extend the time for promulgating designations using the authority
provided under section 107(d)(1)(B) of the CAA. As such, the EPA is deferring initial
area designations for ten areas where currently available data, including air quality
monitoring data, are insufficient to determine whether the areas are meeting or are not
meeting the NAAQS. For these areas (i.e., Atlanta, GA; Albany, GA; Augusta, GA-SC;
Brunswick, GA; Columbus, GA-AL; Savannah, GA; Valdosta, GA; Washington Co, GA;
the entire state of Florida; and the entire state of Tennessee, excluding three counties in
the Chattanooga area), the EPA believes that additional air quality monitoring data will
result in complete and valid data sufficient to inform a designation determination.
In this action, the EPA is finalizing a designation of unclassifiable for those remaining
areas identified as "unclassifiable" in the 120-day letters (i.e. Puerto Rico; US Virgin
Islands; and the entire state of Illinois, including two counties in Indiana as part of the
Chicago area and four counties and one city in Missouri as part of the St. Louis area)
because these areas have ambient air quality monitoring sites that lack complete data for
the period 2011-2013. After reviewing the ambient air quality monitoring data for these
areas for 2012, 2013 and 2014, the EPA believes that near-term data will continue to be
insufficient to determine valid design values and, therefore, that deferring designations
would not be helpful. Additionally, a review of data prior to 2013 indicates similar data
quality and/or completeness issues such that the EPA lacks the confidence in historical
data needed to support a designation based on recent prior years. The EPA is working
closely with the appropriate air agencies to ensure that complete, quality-assured data are
gathered moving forward and will continue to conduct technical systems audits of each
ambient air monitoring organization every 3 years as required under 40 CFR part 50,
Appendix A. The EPA will evaluate complete and valid data for "unclassifiable" areas
when they become available.
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3.1.2. Requests to Extend the Public Comment Period
Comment: Two commenters requested that the EPA extend the deadline for the public
comment period beyond September 29, 2014, to allow interested parties additional time
to review docket materials and provide substantive comments.
EPA Response: In its August 29 Federal Register notice (79 FR 51517) announcing the
availability of the EPA's responses to state and tribal designation recommendations for
the 2012 annual PM2.5 NAAQS, the EPA invited public comment through September 29,
2014. In the "120-day" letters, the EPA asked states and tribes to provide any additional
comments by October 29, 2014. The EPA established these staggered deadlines to allow
the states and tribes to address any public comments and to allow the EPA to review and
respond to all significant public, state, and tribal comments in advance of promulgating
the initial area designations in December 2014 according to our statutory designations
deadlines. For these reasons we were unable to extend the comment period.
3.1.3. Other General C omments
Comment: One commenter noted that the regulatory burden associated with the EPA's
process of designating nonattainment areas will negatively affect areas by causing
economic harm.
EPA Response: Section 107(d)(1) of the CAA directs the EPA to designate an area
"nonattainment" if it is violating the NAAQS or if it is contributing to a violation of the
NAAQS in a nearby area. The first step in designating nonattainment areas is to identify
air quality monitoring sites with 2011-2013 data that show a violation of the 2012 annual
PM2.5 NAAQS. To determine whether a nearby area is contributing to a violation, the
EPA recommended that states conduct a technical analysis based on a number of factors
listed in the designation guidance for the 2012 annual PM2.5 NAAQS, including air
quality, emissions and emissions-related data, meteorology, geography/topography, and
jurisdictional boundaries. In evaluating whether to modify a state's designation
recommendation, the EPA also considered those factors as documented in the EPA's
technical support document for the identified nonattainment area. In determining whether
an area should be designated nonattainment under section 107(d), the EPA did not
consider economic impacts because they are not relevant for determining whether an area
is violating the NAAQS or is contributing to a nearby violation.
Control obligations in areas designated nonattainment for the 2012 annual PM2.5 NAAQS
will be addressed through a separate implementation rulemaking. As the EPA considers
the required components of implementation plans for the 2012 annual PM2.5 NAAQS, the
Agency intends to provide states flexibility and opportunities to maximize efficiency to
the extent such approaches are consistent with the CAA and will not jeopardize
expeditious attainment of the public health and welfare goals of the CAA. In addition, the
EPA is exploring ways that it can provide assistance to the states on this issue. Finally, to
the extent the CAA does not mandate specific control measures, states may consider
economic concerns in development of their state implementation plans to address air
quality.
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3.2 Area-Specific Issues
3 .2.1. EPA Region III
Comment: Pennsylvania Department of Environmental Protection (PADEP) and
Allegheny County Health Department (ACHD) urged the EPA to reconsider its intended
boundary from that of Allegheny County to the historical five borough Liberty-Clairton
boundary that has served as the boundary for this area in the past PM2.5 designations,
given that the only violating monitor is the same monitor the EPA relied upon for its past
designations under the annual and 24-hr PM2.5 NAAQS designations. All other monitors
located in the County are not only currently attaining the standard, but demonstrating a
historical downward trend that provides confidence in continuing attainment of the
standard.
Commenters stated that it is inappropriate for the EPA to expand its nonattainment
boundary for the Liberty-Clairton area to include the entirety of Allegheny County and
that the historical boundary for Liberty-Clairton is appropriate given that the only
violating monitor is located within the historical boundary.
The commenters noted that the Liberty monitor is located in an area that has historically
demonstrated a very significant localized industrial impact that requires separate planning
approach that the EPA has recognized in past designation processes. However,
commenters claimed that in the initial TSD for Allegheny County, the EPA ignored
precedent and attempted to link sources in other parts of the County including the
urbanized area of the City of Pittsburgh to a violating monitor that is subject to a unique
mix of meteorology topography and localized emissions. The Commenters argued that
the EPA's justification for the entire County is confusing, because in several instances the
EPA cited the "dominant" influence of local emissions on the Liberty monitor.
EPA Response: Section 107(d)(1) requires the EPA to designate as nonattainment not
only any area that violates the NAAQS, but also any area that contributes to ambient air
quality in a nearby area violating the NAAQS. The EPA has therefore always based its
nonattainment decisions upon a full comprehensive factor-based analysis, taking into
consideration all aspects that drive violations of the standard both in areas violating the
NAAQS and also in nearby areas contributing to areas violating the NAAQS. However,
the EPA must also evaluate contribution from all nearby areas portion of the area of in
the analysis.
Our current Allegheny County boundary decision for the 2012 PM2.5 NAAQS is based on
only a single violating monitor — the Liberty monitor which also formed the basis for
past Liberty-Clairton PM nonattainment areas. Though there is only one violating
monitor in the larger Pittsburgh CBS A, all nearby emissions sources in the area must be a
evaluated for potential contribution to the violating monitor. Based on the EPA's five
factor analysis and additional analysis performed in response to the commenters'
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analysis, sources within Allegheny County outside the local Liberty-Clairton area are
contributing to the violating Liberty monitor.
The EPA reviewed the commenters' supplemental information and analysis, and agrees
with the commenters, to some degree, with their technical analysis as it relates to
conditions affecting the violating Liberty monitor, particularly in light of its proximity to
an industrial source that contributes significantly to the violation, and in light of
topographical and meteorological conditions present at the monitor site. These conditions
and the EPA's additional analysis of the commenters' information provided and further
explained in responses throughout this section and in the TSD.
Although the EPA agrees to some extent with the commenters' supplemental analysis
with respect to the significant contributor to the violation, the commenters' analysis
focuses on a significant contribution and does not address or disprove potential
contribution to the violation from nearby sources in the remainder of the county (e.g.,
mobile, area, and point emission sources). The commenter primarily notes that the
localized Liberty-Clairton area is a "significant contributor" to the violating monitor;
however, the statute is clear in providing for inclusion in nonattainment areas of areas
that "contribute" to the violations. The EPA interprets the term "contributes" to mean
contributes sufficiently to justify inclusion in the nonattainment area, and the EPA's
multifactor test with the various analytical tools is intended to assure an objective
evaluation of the appropriate facts on a case by case basis in each area. The EPA has
considered multiple factors of analysis, and has applied the same analysis to all counties
considered in the area of analysis as outlined in the TSD. The EPA's decision is not
contingent on only one part of the analysis, but the analysis as a whole especially given
that PM is a complex pollutant with contribution from multiple source categories as well
as multiple pollutants. Hence, the EPA's use of the weight of evidence approach
evaluating the facts and circumstances in each area on a case by case basis, and was done
consistently with decision principles to assure comparable treatment in all the
designations.
As demonstrated by the five factor analysis in the TSD for the Allegheny County area
and supplemental analyses performed in light of the commenters' additional information,
the EPA has determined that though there is significant contribution from the local
sources to the violating monitor, there is also contribution from sources within the
remainder of Allegheny County impacting the violating monitor.
The commenters' focus on data from the violating Liberty monitor furthermore does not
assess what is happening on all days versus high days for the annual PM2.5 NAAQS. To
further assess this potential for broader contribution, the EPA conducted its own
additional analysis of monitor concentrations and wind directions for all days in a period
between 2011 and 2013. This analysis, further explained in the TSD, shows that under
certain conditions on a large number days that there is some degree of contribution from
sources in the surrounding Allegheny County area to the violating Liberty monitor.
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Comment: PADEP and ACHD are concerned that inclusion of the entirety of Allegheny
County in the nonattainment area would subject all sources therein to Reasonable Further
Progress (RFP) requirements, increasing the baseline for RFP and resulting in a greater
emission reduction required to meet RFP. Commenters assert that there are limited
remaining emission controls available in the remainder of the County, and that ACHD
has limited control over emissions from transportation sources in the county.
The commenters state that designation of the entire county as nonattainment for the 2012
PM2.5 NAAQS would result in three different nonattainment boundary areas in the same
County (1997/2006 PM2.5, 2012 S02, and 2012 PM2.5 NAAQS). The commenters allege
this is not consistent with the EPA's recent SIP improvement outreach efforts and would
place a considerable burden on resources for the ACHD. It is also important to note that
the significant stationary sources in other areas of the County besides the Liberty-Clairton
area will be subject to any controls that are required to meet the 2012 SO2NAAQS.
EPA Response: The EPA notes its willingness and capability to work closely with state
partners in their development of attainment plans. The EPA also acknowledges the
commenters' concern regarding attainment planning, however the statutory basis for area
designations is not one of whether sources are controlled or controlled adequately at the
time of designations. The issue is also not whether sources can or should be controlled for
purposes of implementing the NAAQS. That question is something that is evaluated in
the context of the attainment plan that the state will develop once an area is designated as
nonattainment. Whether sources in an area are already adequately controlled for a prior
PM2.5 NAAQS because of existing attainment plan SIP measures for that NAAQS is also
not a singular deciding factor in determining designations for a new NAAQS because the
emissions from sources (controlled or uncontrolled) may still be contributing to a
violation of the more stringent 2012 PM2.5 NAAQS. With respect to the commenters'
contention regarding expanded RFP requirements as a result of a broader nonattainment
boundary, each NAAQS must be evaluated on the basis of violations of that standard,
current ambient air quality, and the contribution to the violation from within the
established nonattainment boundaries., Designations determinations are therefore
irrespective of RFP consequences which are statutorily addressed in separate, subsequent
attainment planning.
With respect to the selection of jurisdictional boundaries for the area, each NAAQS must
be evaluated independently of the other. The EPA does consider the historical
jurisdictional boundaries in our intended designations while we attempt to align
boundaries and overlap jurisdictional control when determining boundaries for a new
NAAQS. Boundaries however may vary for different NAAQS based on the source
contribution and location of violations specific to each NAAQS. The EPA has given
consideration to jurisdiction issues in the Allegheny County designation, but based on its
analysis of the potential for sources in the area to contribute to the violating monitor, the
EPA has determined the Allegheny County designation is appropriate though it may
differ from the historical jurisdictional boundaries for this area. The EPA acknowledges
and appreciates that PM2.5 planning for this area is under ACHD and PADEP's
jurisdiction, and that both agencies have a long history of cooperation for planning in the
Allegheny County area.
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Comment: PADEP and ACHD assert that the EPA dismissed the influence of industrial
(stack) emissions from Washington County including two nearby power plants due to
complex terrain, but ignored the same complex terrain in an attempt to link ground level,
urban emissions from the City of Pittsburgh from a greater distance as a contributor to the
Liberty monitor. Commenters further allege this is also despite the fact that the Liberty
monitor only violates the standard when the prevailing wind is from the South or
Southwest and not from the Northwest which is the direction of the City of Pittsburgh.
Commenters also argue that there is a monitor located only 3.5 miles from the Liberty
monitor in Clairton that consistently reads 3 to 4 [j,g/m3 lower than Liberty (among the
lowest readings in the County) which does not demonstrate urban influence on the area.
Commenters argue that the EPA is inconsistent in its reasoning for Pittsburgh's influence
on the Liberty monitor while ignoring the gradient between the nearby, upwind Clairton
monitor, which reinforces the well understood localized emission impact of the local
source on the Liberty monitor.
EPA Response: As explained in the TSD, the EPA has analyzed contribution from the
entire CBSA for this area. The EPA's decisions for inclusion of Allegheny County and
not Washington County are set forth in the TSD, and have not changed based on
supplemental analysis submitted by commenters in response to the intended designations.
Emissions in Washington County are relatively low, less than a quarter of Allegheny
County's emissions. Washington County also has relatively low population, population
density, and VMT. Furthermore, POM and EC, the largest components of the urban
increment at the violating monitor, are low in Washington County. As explained in the
TSD, the two point sources with emissions of greater than 500 tpy in Washington County
have very low direct PM2.5 and VOC emissions, which indicates that any potential
contribution to the POM and EC in the urban increment at the Liberty monitor is
relatively low.
The surrounding Allegheny County area is the largest source of relevant emissions in the
area of analysis, and other factors such as meteorology and topography as further
explained in the TSD justify inclusion of Allegheny County in the nonattainment area. In
response to PADEP's and ACHD's supplemental analysis, the EPA conducted additional
analysis to evaluate contribution from Allegheny County to the Liberty monitor. This
additional analysis shows that based on a review of all days, as is appropriate for an
annual NAAQS, rather than only high concentration days, there is contribution on some
days and wind conditions from the surrounding Allegheny County area on the violating
monitor.
With respect to the commenters' contention regarding concentration gradients between
the nearby Clairton and Liberty monitors, the EPA agrees that this shows evidence of
significant local contribution. However, as explained in detail in a previous response, the
statute is clear in providing for inclusion in nonattainment areas of areas that "contribute"
to the violations. A high or low monitored concentration at an attaining monitor does not
by necessity preclude contribution from the surrounding area of analysis. This
contribution is measured through a consideration of all available information, through a
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five-factor analysis. The overwhelming local contribution from Liberty-Clairton sources
does not preclude possible contribution from surrounding areas, and as further explained
in the TSD, the five factor analysis indicates contribution from the remainder of
Allegheny County outside the local Liberty-Clairton area.
Comment: In response to the EPA's August 19, 2014 120-day letter, PADEP and ACHD
submitted information on historic trends for monitored annual means and design values
for monitors in Allegheny County. The commenters contend that the information shows
that the Liberty monitor is unique compared to all other monitors in Allegheny County,
exhibiting both higher PM2.5 quarterly means and design values and poor correlation to all
other county monitors, indicating local impact on this monitor by the nearby Clairton
Coke Works. Commenters argue that the Liberty monitor is unique from other Allegheny
County monitors due to this downwind proximity to the source, as well as
microclimatological and topographical impacts related to the monitor's location on a
bluff over the river valley and the source.
EPA Response: The EPA acknowledges the commenters assertion that the provided
annual means and annual design value graphs for the Allegheny County monitors show
that the Liberty monitor is higher than the other monitors in the county and follows a
similar downward trend as the other monitor. This supports the EPA's quarterly means
analysis and conclusion that the Liberty monitor is influenced by the same seasonal
patterns as the rest of the area but an additional local component is causing the
exceedance in PM2.5 concentrations. However, section 107(d) of the CAA directs the
EPA to designate an area nonattainment if it is violating the NAAQS, or if it is
contributing to a violation of the NAAQS in a nearby area. Though the EPA agrees with
the commenters that a local component is causing the exceedance of the NAAQS, the
commenters do not disprove that emissions from Allegheny County are not contributing
to the exceedance. As explained throughout the TSD, the EPA's five factor analysis
demonstrates contribution from Allegheny County to the violating Liberty monitor. The
EPA acknowledges the topography and temperature inversions in the Liberty-Clairton
area also probably cause local emissions to be trapped in this area and drive the violation
of the NAAQS at this monitor. However, the statue compels the EPA to consider
contribution to a violation of the NAAQS and not necessarily causation. In an attempt to
better understand the meteorological impacts at the Liberty monitor, the EPA performed
additional analysis of conditions at this site (see PA TSD pages 111-115). The EPA's
analysis also shows that under certain conditions on a large number days there is some
degree of contribution from sources in the surrounding Allegheny County area to the
violating Liberty monitor, therefore the topography and inversions do not preclude
transport of emissions from outside this small area and that emissions from Allegheny
County are capable of bypassing these features to impact the violating monitor.
Comment: As part of their supplemental analysis submitted in response to the EPA's
August 19, 2014 120-day letter, PADEP and ACHD examined speciation data for select
tri-state monitoring sites (both inside and outside the area of analysis) for the period
between 2011-2013, in an attempt to characterize PM2.5 contribution at the violating
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Liberty monitor. Commenters used a number of area monitors to assign allegedly
incremental contribution from various parts of the area of analysis as regional
background, the surrounding Pittsburgh MSA, the Pittsburgh urban area, and local
sources within the Liberty-Clairton area.
The commenters assert that the results of that analysis show that the Liberty monitor sees
higher levels of elemental carbon and chlorine than other area monitors while other
species, including sulfates and organic carbon, are more normalized in comparison of
Liberty monitor levels to those seen at other tri-state monitors. Commenters assert that
the allegedly incremental contribution analysis indicates that the surrounding MSA
monitors show a large increment of organic carbonaceous material, indicative of a large,
widespread contribution of area, mobile and point source emissions and that the rural
background sites show large contributions of sulfate, nitrates and a portion of organic
carbonaceous material, indicative of widespread regional transport. Commenters also
assert that the Pittsburgh urban area contributes only an incrementally small portion of
the total from the tri-state area to the Liberty monitor, and that the excess contribution
generated nearby to the Liberty monitor contains high levels of carbon, sulfates and
elemental carbon PM2.5 components, which can be attributed to the nearby industrial
sources, such as the Clairton Coke Works source.
EPA Response: The EPA's approach to designations is to evaluate the entire CBSA and
not differentiate between the MSA and the urban area within the CBSA. In addition, the
EPA notes that the entire CBSA is appropriate for evaluating whether sources in this area
are contributing to a violation within the County or within a nearby area.
The EPA's SANDWICH speciation data supports the commenters' assertions with
respect to some unique speciation results at the Liberty monitor in comparison to other
area monitors. The EPA agrees that the commenters' analysis of component speciation at
the Liberty monitor compared to other area monitors shows heavy local industrial
contribution of elemental carbon and chlorine components not seen at other monitors, as
well as similar presence of components likely representing regional background (e.g.,
ammonium sulfates and ammonium nitrates). However, the analysis done by PADEP and
ACHD does not account for high organic carbon and sulfate components at Liberty in
comparison to these other area monitors which likely result from contribution to the
Liberty monitor from sources outside the Liberty-Clairton local area and within
Allegheny County. There are other mobile, area and point sources in Allegheny County
with organic carbon and sulfate emissions that have the potential to contribute to the
Liberty monitor.
The commenters' area contribution analysis appears to show some increment from within
the Pittsburgh urban area to the violating Liberty monitor, indicating the existence of
contribution to the violation from within Allegheny County. The commenters describe
this contribution as an "incrementally small portion of the total," but the EPA through its
five factor analysis has determined that there is contribution from the Allegheny County
area to the Liberty monitor sufficient to justify inclusion of the entire county in the
nonattainment area, and the commenters have not rebutted this determination.
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After review of the commenters' supplemental analysis to the EPA's intended
designation, while there is clearly contribution from local sources in the Liberty-Clairton
area, it still appears from the evidence provided that there is some degree of contribution
to the violation at the Liberty monitor from emission sources in Allegheny County based
upon speciation data, emissions data, meteorology, and other factors as described in this
TSD.
Comment: In response to the EPA's August 19, 2014 120 day letter, PADEP and ACHD
provided updated 2013 emissions for sources generating over 500 tons per year in
Allegheny County. Seven of the nine of these sources have decreased particulate matter
and PM precursor emissions from 2011 to 2013, while emissions across the entire county
were reduced emissions by 26.3%. Conversely, the Clairton Coke Works (e.g., the
nearest major emissions source to the violating Liberty monitor) increased its emissions
between 2011 and 2013, as a result of ongoing issues with some of its newer emissions
controls. The nearby U.S. Steel Irvin Plant (2 miles from the Liberty monitor) also
increased emissions, to a lesser degree, over that same period. Further, five coal-fired
power plants inside the EPA's area of analysis, but outside Allegheny County (two in
Washington County, one in Greene County, and one in Preston County, WV) have
deactivated since 2011.
EPA Response: The EPA agrees with PADEP and ACHD that the most recent updated
emissions data for sources in Allegheny County indicates that major point source facility
emissions in Allegheny County have decreased, in their totality (except for the Clairton
Coke Works and U.S. Steel Irvin facilities). However, while their impact on total
emissions for Allegheny County are less in relation to total county emissions, these major
facility revised emissions likely have some impact on the violating monitor
Comment: PADEP and ACHD also provided Modeled Attainment Test Software
(MATS) unmonitored area PM2.5 impacts from a baseline year of 2007 to a projected
2014 (performed for the 2006 24-hour PM2.5 NAAQS SIP) to support their position.
Commenters assert that the modeling results show distinct border for the extent of urban
impacts in the Pittsburgh area compared to Liberty-Clairton impacts. To further
demonstrate the allegedly unique emissions and the source of these emissions at the
Liberty monitor, PADEP and ACHD submitted updated PMF source modeling. The
commenters assert the Liberty monitor shows a large carbon-rich industrial source which
is not present at other sites, and that the Liberty monitor also shows little motor vehicle
emissions and that motor vehicle emissions from the Pittsburgh area are not transporting
to the Liberty monitor.
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EPA Response: The EPA notes it does not rely on modeling forecasts when making
decisions regarding NAAQS designations, as designations are based upon recent ambient
air quality data and not future projections of air quality. The MATS modeling provided
by PADEP and ACHD for 2007 and 2014 does support the commenters' contention that
ambient PM2.5 is concentrated in two separate plumes - one centered over the urban core
of Pittsburgh and another separate plume over Liberty-Clairton area. However, the
MATS modeling does not actually prove that there is no contribution from the remainder
of Allegheny County to the Liberty monitor - instead it shows only that the largest
sources of contribution at Liberty is from the local source. For reasons explained
throughout the TSD, the five factor analysis demonstrates there is contribution from the
remainder of Allegheny County to the violating monitor.
The EPA acknowledges that a carbon-rich industrial source contributes to the Liberty
monitor as shown in the PMF common source model analysis. The commenters'
provided PMF common source factor modeling analysis also demonstrates that the
Liberty monitor detects source types similar to other area monitors for PM2.5 components
typically associated with regional background (e.g., sulfates, nitrates and crustal).
However, the PMF source factors for the Liberty monitor also show the appearance of
PM2.5 components from motor vehicle and burning/cooking sources at levels similar to
other area monitors. Given the lower population and vehicle-related activity in the
vicinity of the Liberty monitor in comparison to other area monitors, the presence of
motor vehicle and burning/cooking sources at levels similar to other area monitors does
not disprove and actually could indicate contribution from outside the Liberty-Clairton
area from at least those two source types. While the PMF modeling clearly shows a
contribution from a local industrial sources, it does not rule out contribution from other
sources in the County, particularly burning and motor vehicle sources.
Comment: PADEP and ACHD provided additional Allegheny County population
information in response to the EPA's 120 day letter, focusing on population spatial
allocation and population density. The agencies assert population in the metropolitan area
is further removed from the violating monitor than is indicated by countywide data, and
that the populations in the Liberty-Clairton area have been in decline by 13.4% for the
period between 2000 and 2010. Commenters assert that this newly provided population
data show that the majority of urban population-based area source and mobile source
emissions created in the urban Pittsburgh portion of Allegheny County do not contribute
significantly to violation at the Liberty monitor.
EPA Response: While the commenters updated population data shows a more recent
decline for the Liberty-Clairton area and that mobile emissions in this area contribute to a
much lesser degree than local industrial sources, this does not eliminate the potential for
emissions contribution to the violating Liberty monitor from the much larger source of
population-based emissions from the more populous and heavily trafficked remainder of
Allegheny County. Allegheny County has by far the largest population and population
density, and vehicle miles travelled, relative to all other areas within the area of analysis
for the violating Liberty monitor. As previously discussed, the statute is clear in
providing for inclusion in nonattainment areas of areas that "contribute" to the violations.
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The EPA interprets the term "contributes" to mean contributes sufficiently to justify
inclusion in the nonattainment area. As demonstrated by the five factor analysis in the
TSD for the Allegheny County area and supplemental analyses performed in light of the
commenters' additional information, the EPA has determined that though there is
significant contribution from the local sources to the violating monitor, there is also
contribution from sources within the remainder of Allegheny County impacting the
violating monitor justifying inclusion of the entire county in the nonattainment area.
Comment: PADEP and ACHD provided additional meteorology data in response to the
EPA's 120 day letter. Commenters provided updated wind rose and temperature
inversion information at the Liberty monitor site as well as several HYSPLIT trajectories
for the area. Commenters assert that the EPA's TSD only looked at airport data and did
not evaluate local meteorological site at the Liberty Borough site. Commenters
emphasize that the newly provided 2009-2013 wind rose at the Liberty Borough site
demonstrates a preponderance of winds from the south through west with a dominant
southwest component, further supporting their contention that the Liberty monitor is
largely influenced by the Clairton Coke Works facility. PADEP and ACHD argue that the
EPA did not address stagnation conditions at the Liberty monitor from frequent local
inversion conditions that trap PM2.5 emissions at the monitor. The commenters provided
inversion statistics for 2009-2013 to support this position that shows 40% of the days
when data is available are impacted by inversions.
EPA Response: The EPA agrees with the commenters that the regional wind direction
closest to the Liberty monitor is from the south and the west with southwesterly
components, however, there is still contribution from other sources as winds come from
other directions. As discussed in the TSD, the wind rose closest to the Liberty monitor
shows strong southerly and westerly components, with southwesterly and northwesterly
components. The northwesterly component indicates that the highly urbanized Pittsburgh
area is upwind of, and therefore contributing to, the Liberty monitor. Further, as
discussed in previous responses, the EPA's additional analysis (see PA TSD pages 111-
115) also shows that under certain conditions on a large number days there is some
degree of contribution from sources in the surrounding Allegheny County area to the
violating Liberty monitor. In addition, meteorological data from the Liberty Borough
monitor is not regularly uploaded or quality assured by the EPA. Airport meteorological
data has a higher level of quality assurance and the EPA must rely on highest quality
available data when determining nonattainment boundaries.
As explained in previous responses as well as in the TSD, the EPA acknowledges the
low level, diurnal inversions in the Liberty-Clairton area also probably cause local
emissions to be trapped in this area and drive the violation of the NAAQS at this monitor.
However, the statue compels the EPA to consider contribution to a violation of the
NAAQS and not necessarily causation. The EPA's analysis (see PA TSD pages 111-
115) also shows that under certain conditions on a large number days there is some
degree of contribution from sources in the surrounding Allegheny County area to the
violating Liberty monitor, therefore the topography and inversions do not preclude
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transport of emissions from outside this small area and that emissions from Allegheny
County are capable of bypassing these features to impact the violating monitor.
Comment: A letter from the Allegheny Conference on Community Development to
Dana Aunkst, Acting Secretary, at PADEP was submitted by PADEP. Allegheny
Conference states that the EPA has inexplicably reversed its position recognizing the
unique meteorology, topography and localized emissions in the Liberty monitoring area
without justification. The commenter asserts that the EPA's intended designation of all of
Allegheny County is not supported by evidence. Allegheny Conference believes
designating the entire county of Allegheny County as nonattainment would place
unwarranted requirements on areas that do meet the 2012 PM2.5 NAAQS standard and
urges the EPA to keep the nonattainment area to the current Liberty-Clairton boundaries.
EPA Response: The EPA disagrees with the commenter's contention that we have
inexplicably reversed our historic position regarding the allegedly unique conditions
affecting the Liberty monitor. Based on the evidence and its analysis regarding
meteorology, topography, and other factors as explained in the TSD, the EPA has
determined that sources within all of Allegheny County are contributing to the violating
Liberty monitor and therefore justify inclusion of the entire county in the nonattainment
area. Therefore, the requirements that result from this designation are warranted based
upon the EPA's determination that sources from within the entire Allegheny County
contribute to the violating monitor.
Comment: The Pennsylvania Department of Environmental Protection (PADEP)
disagrees with the EPA's intended two-county Allentown nonattainment area
(Northampton and Lehigh Counties), instead arguing that the boundary should be limited
to the county with the violating monitor (Northampton County) — per PADEP's July
2014 updated recommendation. PADEP maintains that the violation at the Freemansburg
monitor in Northampton County (Northampton County violating monitor) was caused by
a fine particulate problem of an "extreme local nature" that was impacted by construction
associated with the redevelopment of nearly 1,800 acres of the former Bethlehem Steel
Corp site located 1.5 miles south of the Freemansburg monitor. PADEP conducted an
additional analysis of available data and submitted supporting information to support its
case on October 28, 2014. This includes updated air quality data, including an analysis of
Allentown area monitors design value and annual means trends dating back to 2001, and
correlation data comparing design values at the violating monitor with other area
monitors. Finally, PADEP submitted updated 2013 emissions data for large point sources
(over 500 tons per year) in the Allentown area and additional aerial photographs showing
the Bethlehem Steel redevelopment site and its proximity to the violating Freemansburg
monitor.
PADEP contends that the spike in annual mean values at the Freemansburg monitor in
2010 and 2011 is both temporary in nature and anomalous compared with data from other
Allentown area monitors. PADEP argues that if the violation was the result of emissions
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contribution from Lehigh County to the nearby Lehigh Valley monitor would show
similar results to the violating Freemansburg monitor.
In an attempt to demonstrate a unique set of circumstances at the Freemansburg monitor,
PADEP also provided design value correlation data comparing that monitor to five other
monitors in the EPA's area of analysis. This data shows the strongest correlation between
Freemansburg and Lehigh Valley monitors, however the relationship is much weaker in
2011 (during the period of peak earth disturbance and construction activity at the former
Bethlehem Steel site that lies just south of the Freemansburg monitor) versus in 2013
after the conclusion of major site construction.
EPA Response: PADEP has provided only anecdotal evidence that the construction
activity at the Bethlehem Steel site is causing the spike in 2010 and 2011 design values at
the nearby Freemansburg monitor, leading to the violation of the 2012 PM2.5 NAAQS for
the 2011-2013 period. Speciation data and urban increment data set forth in the TSD
clearly indicate that organic mass and elemental carbon are the main components of
PM2.5 at the Freemansburg violating monitor. High organic mass and elemental carbon
suggest that the sources of PM2.5 at the monitor are local in nature, likely due in large part
to locally generated emissions from mobile, area or industrial sources, and not necessarily
construction activity as the commenter contends. Given the proximity of the construction
site to the violating monitor, the EPA would expect to see a higher proportion of crustal
material as a result of the soil disturbance and construction activity.
Furthermore, insofar as the commenter seeks to advance an argument that a local source
was the cause or significant contributor to the violating monitor, section 107(d)(1)
requires the EPA to designate area that are either violating the NAAQS or contributing to
a violation of the NAAQS in a nearby area. The statute does not require the EPA to
designate as nonattainment only those areas with sources that are causing a violation of
the NAAQS. Also, the EPA has interpreted "contribution" to encompass a concept that is
broader than just "significant contribution." The EPA interprets the term "contributes" to
mean contributes sufficiently to justify inclusion in the nonattainment area, and the
EPA's multifactor test with the various analytical tools is intended to assure an objective
evaluation of the appropriate facts on a case by case basis in each area. The EPA has
considered multiple factors of analysis, and has applied the same analysis to all counties
considered in the area of analysis as outlined in the TSD. The EPA's analysis justifies
inclusion of the Northampton and Lehigh counties in the nonattainment area, as
emissions in these counties are contributing sufficiently to the violating monitor.
Additionally, Pennsylvania argues that its submitted monitor design value trends for three
area monitors exhibit similar patterns dating back to 2001 (except for the 2010 and 2011
peak construction period, during which time the violating Freemansburg shows a 3 ug/m3
peak above the Lehigh Valley monitor). However, the Allentown monitor discontinued
operation in 2005 and the Lehigh Valley monitor only commenced operation in 2010,
leaving the period between 2005 and 2010 with no other monitor in the Allentown area
with which to compare values to Freemansburg. Given the lack of continuously operating
monitors in the area, it is impossible to draw the types of comparisons that Pennsylvania
is attempting to draw between design values for the 2010-11 period.
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Pennsylvania states that if emissions from the nearby Lehigh County were contributing to
the Freemansburg monitor violation, then they would expect the Lehigh Valley monitor
annual means would also have increased significantly. The EPA contends that the lack of
more than one violating monitor in an area is not dispositive evidence of whether a
nearby area or county contributes to the violation of another monitor, as the violation
may be the result of cumulative or aggregate impacts from the surrounding area.
Pennsylvania argues that its correlation comparisons between regional monitors in and
around the Allentown area to the Freemansburg monitor show the strongest correlation
between the Freemansburg monitor and the 1.5 mile distant Lehigh Valley monitor,
followed closely by the 35 mile distant Reading monitor. Further, PADEP argues that the
correlations between Freemansburg and each of these monitors is much stronger in 2013
than it was in 2011, during the height of the Bethlehem Steel site construction. The EPA
would expect a high proportion of crustal PM2.5 emissions components at the violating
monitor if the 2010-2011 spike (based on the state's provided historic trend analysis)
were the result of earth disturbance construction-related activity. Speciation data for the
Freemansburg monitor provided by the EPA in the TSD does not show high levels of
crustal material and PADEP's additional speciation analysis show high crustal material
on only a small number of high monitor value days.
The Commonwealth's analysis of correlations between Freemansburg and other area
monitors establishes a similar correlation relationship between Freemansburg to the
distant Reading monitor with that of Freemansburg to the nearby Lehigh Valley monitor,
including a similarly strong relationship in 2013 versus that of the 2011, during the time
representing heavy construction activity near the Freemansburg monitor. The EPA
believes such a similarly strong correlation between Reading and Freemansburg
(compared with that of Freemansburg to Lehigh Valley) should not exist, if the
Commonwealth's hypothesis that the cause of the spike in monitor values in 2010-2011
is the result of only local construction activity. Instead the state argues that the 35-mile
distant Reading monitor exhibits similar design value relationships to Freemansburg due
to its topographical similarity to the Freemansburg site. Given the primary nature of
crustal ejecta (i.e., a lack of secondary PM2.5 component formation) and its tendency
towards dispersion and dilution over distance, the EPA believes the correlation
relationships further support our contention that the violating monitor is showing regional
level contribution of organic and elemental carbon, most likely associated with mobile,
area, and industrial sources.
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The Commonwealth also provided updated 2013 emissions data for large point sources
(emitting more than 500 tons per year) in Northampton and Lehigh Counties. However,
the provided data shows that the preponderance of emissions reductions from major point
sources in the area come from Northampton County sources, with the exception of one
source in Lehigh County. The reduction of point source emissions in Northampton
County does not negate the EPA's position in the TSD that there is a significant
contribution of non-point (area and mobile) emissions from both Northampton and
Lehigh Counties.
After consideration of the analyses provided by PADEP, the EPA continues to believe the
nonattainment boundary for the Allentown area should remain the two counties of
Northampton and Lehigh.
Comment: Northampton County is expected to attain the PM2.5 standard, based on 2014
design values, prior to the effective date of the EPA's final designations. Once the 2014
data is received, PADEP will request withdrawal of the Allentown area as attaining the
2012 PM2.5 NAAQS.
EPA Response: The designation decision is based on available, certified data at the
current time and reflects air quality at the current time, rather than projections of future
air quality. The 2012 PM2.5 NAAQS designations utilize the most recent certified design
value data which is for 2011-2013. See Data Considerations under General Issues above.
The EPA notes requests from the State to withdraw an area from the nonattainment
designation will be considered through the appropriate redesignations process.
3 .2.2. EPA Region IV
Comment: Alabama Department of Environmental Management (ADEM) requested that
the entire State, including Russell County, be designated as attainment, consistent with
their March 2014 initial designation recommendation. They identified that the EPA will
be basing designations on the 2011-2013 monitoring period. The design value for the
Russell County monitor for this period is 11.2 |ig/m3. They note that while they
understand that the Columbus, Georgia, monitors have insufficient data to make a
designation determination for the 2011-2013 monitoring period, the data from the Russell
County monitor for this period has been quality assured and accepted by the EPA as valid
and in compliance with the 2012 annual PM2.5 NAAQS. For this reason, they continue to
request that rather than defer designations for Russell County, the EPA designate Russell
County as attainment, with the understanding that the designation may need to be revised
if the Columbus, Georgia, monitors fail to comply with the standard for the 2012-2014
monitoring period.
EPA Response: The EPA appreciates ADEM's response to the EPA's intended
designations for Alabama areas as identified in the EPA's August 19, 2014, letter. The
EPA acknowledges that Alabama has valid monitoring data for the Russell County
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monitor for 2011-2013 indicating an attaining design value for the 2012 primary annual
PM2.5 NAAQS at that monitoring location. However, Russell County is located in the
core-based statistical area (CBSA) for the Columbus-Phenix City Area, and the Georgia
monitor within this CBSA does not have sufficient data for the 2011-2013 time period for
the EPA to make a determination that this part of Georgia is in compliance with the 2012
primary annual PM2.5 NAAQS. Furthermore, based on the EPA's technical analysis (see
the memorandum entitled "Georgia Deferred Areas - Air Quality Designations for the
2012 PM2.5 National Ambient Air Quality Standard (SAN 5706)" in the EPA's docket for
this rulemaking) for the Columbus-Phenix City Area and the fact that there is currently
not enough data for the EPA to make a determination on whether the monitors in the
Georgia portion of this area would have design values below the 2012 primary annual
PM2.5 standard, at this time the EPA lacks sufficient information to determine whether
Russell County is contributing to a potential violation in the Columbus-Phenix City Area.
For these reasons, and because there are indications that this area will have sufficient data
in the near future which will allow the agency to make a determination, the EPA is
deferring the designation for Russell County while we await forthcoming data.
Comment: Georgia Environmental Protection Division (GEPD) agrees with the EPA's
intention stated in the 120-day letter to defer initial area designations under the 2012
annual PM2.5 NAAQS for Georgia counties in the Augusta, Columbus, Savannah,
Valdosta, and Washington County areas (with the exception of Dougherty County, which
is part of the Albany, GA area and was incorrectly included as a "deferred" county in the
August 19, 2014 letter but not in supporting documentation). GEPD also requests that the
EPA similarly defer initial area designations for Georgia counties in the Atlanta,
Brunswick, and Albany areas that were identified in the August 19, 2014, letter as
intended "unclassifiable" areas. GEPD also respectfully requests that the non-Georgia
counties associated with the Augusta and Columbus areas be designated attainment.
EPA Response: The EPA appreciates GEPD's response to the EPA's intended
designations for Georgia areas as identified in the EPA's August 19, 2014, letter. The
EPA agrees with GEPD's response and is now deferring designations for the Georgia
counties in the Albany, Atlanta and Brunswick Areas as well as the Georgia counties
identified in the Augusta, Columbus, Savannah, Valdosta, and Washington County
Areas. Currently, there is not enough data to support a conclusion regarding the
likelihood that these counties are not violating the 2012 annual PM2.5 NAAQS or not
contributing to nearby areas that may be violating the NAAQS. However, there are
indications that these areas will have sufficient data to make a determination in the near
future.
The deferred designation of the Albany Area includes Dougherty County. Although the
EPA identified Dougherty County in the deferred Albany Area in the Agency's August
19, 2014, letter, the EPA intended to designate Dougherty County as "unclassifiable" in
that letter. Given the lack of complete data from the Dougherty County monitor, the EPA
has now decided to defer the designation for this county while the EPA awaits
forthcoming data that will allow the EPA to determine the extent to which portions of the
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Albany Area are violating the 2012 primary annual PM2.5 NAAQS, or contributing to any
nearby areas that may be violating that NAAQS.
Regarding GEPD's request for the EPA to designate as "attainment" the non-Georgia
counties associated with Augusta and Columbus Areas, the EPA lacks sufficient
information at this time to assess the likelihood that these non-Georgia counties are
potentially contributing to violations that may exist in either the Augusta or Columbus
Areas. Accordingly, the EPA is deferring designations for Richmond County, South
Carolina (in association with the Augusta Area) and Russell County, Alabama (in
association with the Columbus Area). The EPA is deferring these counties based on the
EPA's technical assessment (see the memorandum entitled "Georgia Deferred Area Air
Quality Designations for the 2012 PM2.5 National Ambient Air Quality Standard (SAN
5706) in the EPA's docket for this rulemaking) of the likelihood of contribution to
potential violations in the Augusta and Columbus Areas, on the fact that there is currently
not enough data for the EPA to make a determination regarding whether certain areas
comply with the 2012 primary annual PM2.5 NAAQS, and on indications that these areas
will have sufficient data in the near future that will allow the Agency to make these
determinations. South Carolina provided a letter of support for the EPA's use of its
deferral authority in this case.
Comment: The South Carolina Department of Health and Environmental Control
(DHEC) agrees with the EPA's intention stated in the 120-day letter to defer initial area
designations under the 2012 annual PM2.5 NAAQS for Aiken County, South Carolina as
part of the deferred area of Augusta, GA-SC. DHEC expects that 2014 monitoring data
will show that the area meets the standard.
EPA Response: The EPA appreciates the commenters' support.
Comment: The Tennessee Department of Environment and Conservation recommends
that the EPA defer initial area designations for all areas in Tennessee, except for
Hamilton, Marion and Sequatchie Counties in the Chattanooga area that the EPA
identified in the August 19, 2014 letter as intended "unclassifiable/attainment."
EPA Response: The EPA appreciates TDEC's response to the intended designations for
Tennessee areas as identified in the EPA's August 19, 2014, letter. The EPA agrees with
TDEC's response and based on its analysis of the information available, the EPA is now
deferring designations for all counties in Tennessee, except for Hamilton, Marion and
Sequatchie Counties in the Chattanooga Area. Currently, there is not enough data in these
areas to make determinations regarding the areas' compliance with the 2012 primary
annual PM2.5 NAAQS. However, there are indications that these areas will have sufficient
data in the near future which will allow the Agency to make these determinations. As
indicated in the EPA's August 19, 2014 letter and as recommended by TDEC, the EPA is
designating the Hamilton, Marion, and Sequatchie Counties in the Chattanooga Area as
"unclassifiable/attainment" for the 2012 primary annual PM2.5 NAAQS. The EPA is
making the final designation of "unclassifiable/attainment" for these counties because the
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EPA has sufficient data for the counties in the CBSA for the Chattanooga Area (i.e.,
Hamilton, Marion, and Sequatchie Counties in Tennessee and Catoosa, Dade, and Walker
Counties in Georgia) to make this final designation.
Comment: Sierra Club opposes the EPA's proposal to designate the Atlanta and
Columbus Areas in Georgia as unclassifiable and believes that the EPA must designate
these areas as nonattainment. According to Sierra Club, the EPA cannot designate these
areas as unclassifiable because doing so would be against available data, the EPA
regulations, and the EPA guidance and would subject Georgians to considerable health
risks, including risks of increased mortality rates. In support of its position, Sierra Club
states that:
"The Atlanta and Columbus areas have a 2010-2012 design value that is valid and shows
nonattainment, and no valid design value that contradicts this finding. Further, these areas
include some of the most densely populated areas of the state.
"Georgia's Recommendation concludes that that the entire state be classified
attainment/unclassifiable. However, that suggestion relies on both an incorrect period to
determine the design value and inappropriate predictions on the part of the state. Further,
it misrepresents the data available to the state. On December 13, 2013, the only complete
three years of data that was available to the Georgia Environmental Protection Division
was the data from 2010, 2011, and 2012. Under the 2012 Design Value, monitors in the
Atlanta and Columbus areas violate the NAAQS. Although Georgia tries to hide this fact
by performing a series of educated guesses as to 2013 monitor readings, the data is clear
that these areas violated the NAAQS under the 2012 design value.
"The April 2013 the EPA Memo directs states to use 2010-2012 data for state
recommendations. That same memo then states that that 2013 monitor data may be used
by the EPA to determine NAAQS designations only if valid data is available to inform
the 2013 design value. In Georgia's case, there is not enough data for the EPA to rely on
the 2013 design value. As a result, the EPA's use of the 2013 design value would be
contrary to its own regulations and guidance. Further, it is the EPA's directive under the
Clean Air Act to protect both human health and the environment. As indicated in the
EPA's decision to defer designation for other parts of Georgia, it is appropriate to take
cautionary approach to protect human health.
"To err on the side of protecting human health and provide for an adequate margin of
safety, the EPA's data conventions require less stringency to determine that an area is
nonattainment when there is incomplete data. Under Appendix N to 40 CFR Part 50,
"years with at least 11 creditable samples in each quarter shall [] be considered valid if
the resulting annual mean or resulting annual PM2.5 NAAQS quarter shall [] be
considered valid if the resulting annual mean or resulting annual PM2.5 NAAQS [design
value] (rounded according to the conventions of section 4.3 of this appendix) is greater
than the level of the applicable primary or secondary annual PM2.5 NAAQS. " 40 C.F.R.
Part 50, Appendix N, at 4.1(b). Put another way, so long as the mean results in a violation
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of the NAAQS, a year's data is considered valid if there are at least 11 creditable samples
in each quarter of that year.
"It is clear that areas in Georgia violated the NAAQS under the 2012 design value, and
that the 2013 design value is not valid due to data completeness issues. However, both
the Georgia Recommendation and the EPA Response contain discussions about trends on
PM2.5 emissions and PM2.5 precursor emissions. To the extent that either agency relies on
these general trends to inform NAAQS designations, that reliance is inappropriate and
misguided.
"Georgia's assertion that lower PM2.5 levels are due to real and permanent emission
reductions for PM2.5 and PM2.5 precursors is completely contrary to recent permitting
actions taken by the State, which found that such reductions were not permanent. For
example, when it applied to convert Plant Yates to natural gas in 2013, Georgia Power
asked the Georgia Environmental Protection Division ("GaEPD") to adjust its baseline
emissions rate time period because of decreased use of its coal units. Georgia Power
claimed the decreased use was due to the Great Recession, which "officially began
December 2007," and natural gas prices, which "reached historic lows and [caused] the
use of many coal-fired plants [to] decline[] drastically." Id. at 2. Georgia EPD concurred
with Georgia Power's assessment. Georgia EPD cannot credibly claim that emissions
reductions are permanent, or even that general trends can be assumed going forward,
after finding that the same reductions are due to cyclical changes in the economy and
natural gas prices. Further, Georgia relies on Georgia Rule 391-3-l-.02(2)(sss) ('Georgia
Rule (sss)'). However, Georgia Rule (sss) has not been formally incorporated into the
State Implementation Plan as approved by the EPA. If Georgia does intend to rely on this
rule to avoid nonattainment, it must make the rule federally enforceable by incorporating
it into the SIP."
EPA Response: In the information that the Agency released on August 19, 2014,
providing the intended designations for the Atlanta and Columbus Areas (amongst other
areas nationwide), the EPA stated its intention to designate the Atlanta Area as
unclassifiable and to defer the designation of the Columbus Area. The EPA is now
deferring designations for a number of Georgia counties in the Atlanta Area, as well as
for the Alabama and Georgia counties in the Columbus-Phenix City Area. The EPA does
not currently have enough data to make determinations regarding either the areas'
compliance with the 2012 primary annual PM2.5 NAAQS, or the relative likelihood that
portions of these areas are contributing to potential nearby violations. However, because
the EPA expects that all monitors within these areas will have sufficient data to
promulgate designations in the near future, the Agency is merely deferring designations
for these areas.
For the reasons discussed above, the EPA is deferring initial area designations for both
the Atlanta and Columbus Areas pursuant to its authority under section 107(d)(1)(B) of
the Clean Air Act. The EPA expects that complete data for these areas are forthcoming,
and will promulgate designations for these areas when it has sufficient information to do
so. Designations for these Areas will be based on actual data reflecting conditions during
the period relevant to the designation process; they will not be based on projected
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emission trends. The EPA provided information regarding emissions trends in its August
19, 2014, letter to the State of Georgia and associated technical support documents to
better inform the public of the levels of particulate matter pollution in the Atlanta and
Columbus-Phenix City Areas over time. Any forward-looking reductions relied upon in
the designation process will have to be based on actual, enforceable, and permanent
reductions. Finally, the EPA did not rely on Georgia Rule (sss) in making the decision to
defer these areas.
3.2.3. EPA Region V
Comment: Ohio EPA believes that Lake County should be designated as attainment. The
monitoring ID 39-085-0007 in Lake County is in attainment. Lake County is located east
of Cuyahoga County where the nonattainment monitors are located. Therefore, an
easterly wind pattern would be necessary to cause emissions in Lake County to contribute
to violations in the Cleveland area. However, as indicated by the meteorological wind
data US EPA reported "there is a pattern across the area of predominantly south to west
winds, mostly at mid-level speeds of 4 to 10 meters per second, suggesting that potential
emission sources in the south through-west upwind direction should be considered for
analysis." In addition, the eastern monitor in Cuyahoga County is also in attainment
(located between Lake County and the nonattainment monitor).
The EPA also reported that Lake County emits the greatest amount of direct PM2.5 and
precursors in the Cleveland area including 44% of the SO2 emissions. The Cleveland
Electric Illuminating Company Eastlake Plant (Eastlake Power Plant) contributed
approximately 93% of the total point source emissions evaluated for Lake County and is
located 18 miles from the nearest nonattainment monitor. For nearly 2 years (2013 and
2014 emission reporting years) the largest units at the Eastlake Power Plant, units 4 (240
MW) and 5 (597 MW), have been shutdown (generators have been removed and cannot
resume operation). The facility has already made significant reductions in PM2.5 and
PM2.5 precursors to date. A proposed shutdown of the remaining units 1, 2 and 3 (132
MW each) by April 2015 has been submitted for approval to PJM Interconnection
Regional Transmission Organization (RTO). The proposed shut down of the remaining
units is included in the PJM Interconnection RTO Generator Deactivation Summary
Sheets available at http://www.pim.com/planning/generation-
deactivation/gdsummaries.aspx and will result in further dramatic reductions in direct
PM2.5 and precursor emissions prior to the impending PM2.5 annual NAAQS attainment
date. Eastlake Power Plant has also informed Ohio EPA they are in agreement with
zeroing out their SO2 emissions for the purpose of future attainment demonstration
modeling for the 2010 S02 NAAQS SIP document due in spring of 2015.
Ohio EPA's recommendation that all of Lake County should be designated as attainment
is further supported by HYSPLIT KDE (HYbrid Single-Particle Lagrangian Integrated
Trajectory Kernel Density Estimation) plots presented in the US EPA Cleveland TSD.
The KDE plots show that for each quarter evaluated (2010-2012) Carmeuse Lime,
Incorporated - Grand River Operations, which is 28 miles away from the nearest
nonattainment monitor, is not located within a KDE grid with a frequency of 75% or
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higher of observed trajectory endpoints. Painesville Municipal Electric Plant, which is
also 28 miles from the nearest nonattainment monitor, only had an estimated density in
the 75% or higher range during the second quarter of years 2010-2012, when the
quarterly average at all of the Cuyahoga County monitoring sites was below 12.0 [j,g/m3.
If the EPA insists on including Lake County in the Cleveland nonattainment area, Ohio
EPA strongly urges that only the western portion that encompasses the area including and
west of the Eastlake Power Plant. Although Ohio EPA disagrees commuter travel
between Lake County and Cuyahoga County would warrant including Lake County in the
nonattainment area, designating only the following townships in the western portion of
Lake County would capture the majority of commuter VMT emission between Lake and
Cuyahoga Counties: Eastlake, Lakeline, Timberlake, Wickliffe and Willowick. These
townships also surround the Eastlake Power Plant. However, as presented in Ohio EPA's
original recommendations, although the number of commuters traveling into Cuyahoga
from Lake County was among the highest evaluated, only 5.2% of the workers working
in Cuyahoga County commute in from Lake County. Ohio EPA believes this small
percentage of vehicle source emissions does not warrant inclusion of any portion of Lake
County in the Cleveland nonattainment area.
EPA Response: The EPA agrees with Ohio's conclusion that Lake County should not be
designated nonattainment based on contribution to violations of the NAAQS in Cuyahoga
County. The EPA's preliminary conclusion to include Lake County as nonattainment was
primarily because the EPA believed at the time that Lake County emitted the greatest
amount of direct PM2.5 and precursors in the Cleveland area - over 5,000 tpy more than is
emitted in Cuyahoga County. This was primarily because the EPA believed at the time
that Cleveland Electric Illuminating Company Eastlake Power Plant (Eastlake) had the
highest combined emissions of any source in the Cleveland area, and also because it was
only 18 miles from the design value monitor in Cleveland. However, for nearly two years
the two largest units have been shut down and the generators have been removed and
cannot resume operation. These shutdowns are permanent and enforceable. As a result of
these shutdowns, NOx emissions have been reduced by 6,204 tons per year and SO2
emissions have been reduced by 43,264 tons per year since 2013. In addition, the
remaining three smaller units are scheduled to be shut down by April 2015, although this
likely future reduction did not factor into the EPA's analysis. This reduction in emissions
from the already shut down units makes Lake County go from being the county with the
greatest amount of direct PM2.5 and precursors in the Cleveland area to one of the
counties with below average emissions in the Cleveland area.
Lake County is east of and downwind from the violating monitors in Cleveland, based on
wind roses generated by the EPA for the Cleveland area, which show a pattern of
predominantly south to west winds - mostly at mid-level speeds of 4 to 10 meters per
second. HYSPLIT KDE plots for the Cleveland area indicate a greater frequency of
trajectories passing over grid cells to the west and south. In addition, only 5.2% of
Cuyahoga workers commute from Lake County. While the EPA previously believed that
emissions from the Eastlake Power Plant were substantial enough to overcome these
countervailing factors and warrant Lake County's inclusion in the Cleveland
nonattainment area, the updated information from Ohio indicates that this is no longer the
case.
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In conclusion the EPA agrees with Ohio that Lake County should be designated as
attainment because of the very large, permanent, and enforceable decrease in point source
emissions identified by Ohio, because Lake County is downwind of the violating
monitors in Cleveland, and because there are only a moderate number of Lake County
workers commuting to Cleveland.
Comment: Ohio EPA recommends that Lorain County be designated as attainment.
Lorain County is located west of Cuyahoga County and the Cleveland area nonattainment
monitors. Monitor 39-093-3002 located centrally along the northern border of Lorain
County (6 miles from Avon Lake Power Plant) and monitor 39-035-1002 on the west side
of Cuyahoga County between Lorain and the violating monitors are both in attainment.
Avon Lake Power Plant is the only major point source in Lorain County. It is located in
northeast corner of Lorain County approximately 19 miles from the nearest
nonattainment monitor. Avon Lake Power Plant announced June 30, 2013 that it will be
converting to natural gas; Ohio EPA granted a Mercury Air Toxics Toxic Standards
(MATS) extension to April 16, 2016 for the facility. Ohio EPA expects that this
conversion will result in dramatic PM2.5 and PM2.5 precursor emissions from the Avon
Lake Power Plant, therefore Ohio EPA believes Lorain County should be designated as
attainment.
The VMT in Lorain County (2,787,828,581) were the second highest in the evaluation
area, but still significantly lower than those of Cuyahoga County (8,534,134,941).
However, as presented in Ohio EPA's original recommendations, only 5.9% of the
workforce in Cuyahoga County commutes in from Lorain County. Ohio EPA believes
this small percentage of vehicle source emissions does not warrant inclusion of any
portion of Lorain County in the Cleveland nonattainment area.
EPA Response: The EPA disagrees that Lorain County should be designated as
attainment. Lorain County is west of and upwind of the violating moni tors in Cleveland.
This is evidenced by the wind roses that the EPA generated for the Cleveland area, which
show a pattern of predominantly south to west winds - mostly at mid-level speeds of 4 to
10 meters per second. In addition, HYSPLIT KDE plots for the Cleveland area indicate a
greater frequency of trajectories passing over grid cells to the west and south. Therefore,
all of the direct PM2.5 and precursor emissions from point, area and mobile sources can
impact the Cleveland monitors.
Although the Avon Lake Power Plant (Avon Lake) will be converting to natural gas this
will not occur until April, 2016 and there will still be significant NOx emissions after the
conversion occurs. Unlike the shutdown which has actually occurred in Lake County, this
scheduled conversion will not take place until well after the designation process and it is
therefore difficult to establish the impact of this conversion on Cleveland PM2.5 levels.
Although only 5.9% of the workforce in Cuyahoga County commutes in from Lorain
County, the VMT in Lorain County, at 2.8 million, is one of the highest in the Cleveland
area. This is significant because, unlike for Lake County, the vehicular emissions in
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Lorain County will have an impact on the Cleveland monitors because Lorain is
commonly upwind of Cuyahoga County and Cleveland.
In summary, Lorain should be designated as nonattainment for PM2.5 because it has the
third highest amount of direct PM2.5 and precursors in the Cleveland area, the conversion
to natural gas at Avon Lake will not take place until April, 2016, it is commonly upwind
of the violating monitors in Cleveland and has significant VMT.
Comment: Ohio EPA believes that Summit County should be designated as attainment.
Both of the monitoring sites (monitor 10391530017, 391530023) located in Summit
County are in attainment. US EPA considered Summit County in the nonattainment
analysis for the Cleveland, Ohio area as well as the Canton Massillon, Ohio area. The
previous Ohio EPA recommendation and analysis submitted on December 13, 2013 still
holds true for Summit's impact on violations in the Cleveland nonattainment area.
While Ohio EPA agrees that Summit County is best suited in the Canton-Massillon
nonattainment area as opposed to the historically designated Cleveland area, Ohio EPA
still asserts that Summit County should not be designated nonattainment. The three major
point sources located in Summit are within 4 miles of the two Summit County attaining
monitors. Wind data indicates that the majority of the winds near these three major point
sources are westerly to southerly which would move pollutants away from the
nonattainment monitor in Stark County. The majority of the northerly winds observed in
Summit County are low speed ranging from 2-6 mph. Back-trajectories of the first,
second, third and fourth maximum concentration days over three years (2010-12) at the
Stark County nonattainment monitor 39-151-0017 were analyzed using NOAA's Model,
HYSPLIT. The back trajectory simulations also included the trajectories of exceedance
days of 24-hr PM2.5 standard for years 2010-12 at the same monitor. The purpose of
trajectory analyses was to determine the cause of violation by simulating the flow of 24-
hour air trajectory patterns in the backward mode. The analysis indicates that none of the
24 hour backward trajectory patterns originated from areas directly north or northeast of
the monitor indicating that the trajectories were not influenced by Summit County
sources. Although Summit County has the highest VMT for the counties evaluated in the
Canton-Massillon area, as indicated in Ohio EPA's original recommendations, only 5.5%
of the workers commuting into Stark County travel from Summit County. Ohio EPA
believes that this small percentage of commuters in combination with the wind trends and
beck trajectory data support a Summit County attainment designation.
EPA Response: The fact that the Summit County monitors are attaining the annual
PM2.5 standard does not prove that there is no contribution from the area to violations in
Cleveland or Canton. Summit County has both significant emissions and VMT, with the
second highest total emissions, third highest direct PM2.5 emissions and highest VMT
among the counties in the area of analysis for Canton, and the third highest total
emissions and second highest VMT among the counties in the area of analysis for
Cleveland.
Further, the HYSPLIT modeling provided by Ohio EPA was limited in that it only
considered trajectories for the four highest concentration days and the 24-hour
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exceedance days for the 2010-2012 time period. For the 2012 annual NAAQS, the
monitoring data for the entire calendar year (including on days that are below the level of
the NAAQS) are part of the mathematical calculation of whether a monitor is
nonattainment or not. Therefore, wind directions during periods that do not have high
ambient levels are also relevant. Nevertheless, it can be informative to evaluate the days
with monitored concentrations that exceed the value of the standard, 12.0 |ig/m3, since
those are the days that make a larger contribution towards a violation. The EPA analyzed
all of the days with concentrations exceeding 12.0 |ig/m3 during the 2011-2013 time
period at the Canton design monitor, using the HYSPLIT model to simulate back
trajectories. Of the days with concentrations exceeding the value of the annual standard at
the Canton monitor, 37% of the days have trajectories passing over Summit County. In
conjunction with the emissions, meteorology, and VMT data for Summit County, this
data indicate that Summit County contributes to the violations monitored in both Canton
and Cleveland. Therefore, the EPA continues to conclude that Summit County should be
designated as nonattainment because it contributes to violations of the NAAQS in nearby
areas.
Ohio EPA indicates that Summit County is best suited for the Canton nonattainment area.
The EPA agrees that Summit County is more appropriately included in the Canton-
Massillon nonattainment area than the Cleveland area. The major point sources in
Summit County are in the southern portion of the county, closer to the violating monitor
in Canton than to the violating monitor in Cleveland. In addition, kernel density plots for
Canton show a high density of trajectories covering the southern portion of Summit
County. For these reasons, the EPA is designating Summit County as part of the Canton-
Massillon area even though Summit County also contributes to the Cleveland area.
Comment: Ohio EPA believes that the entire Wayne County should be designated as
attainment. The cumulative VMT in Wayne County (1,192,145,098 miles in 2012) is less
than 1/3 of the VMT in Stark County (3,838,738,336 miles in 2012), and as shown in
Table 5 of the Ohio TSD, only 1.3% of the workers commuting into Stark County
commute in from Wayne County. Ohio EPA believes this small percentage of vehicle
source emissions does not warrant inclusion of Warren County in the nonattainment area.
The major point sources in Wayne County are located approximately 18-24 miles west-
northwest of the nonattainment monitor in Stark County. Ohio EPA believes that point
sources located at this great of a distance are not significantly contributing to violations at
the Stark County monitors, especially when considering there are two major Stark
County point sources located within 3 miles of the nonattainment monitor. As reported by
US EPA, the Department of Public Utilities, City of Orrville (Orville Power Plant)
contributes 74% of the major point source total direct PM2.5 and precursor emissions
evaluated in Wayne County. This facility is subject to the Boiler Maximum Achievable
Control Technology (MACT) rules established in 40 CFR 63 Subpart DDDDD. It is also
likely that the Orville Power Plant will be evaluated under the SO2 NAAQS. Under these
regulations, Ohio EPA believes that the Orville Power Plant will experience significant
reductions in PM2.5 and PM2.5 precursors prior to the impending PM2.5 attainment date. If
US EPA insists on designating Wayne County as nonattainment, Ohio EPA believes that
only Orrville Township in Wayne County should be designated as nonattainment similar
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to the approach used for designating Ashtabula Township as nonattainment for the 2006
PM2.5 NAAQS. In this approach the emissions in Ashtabula Township (a portion of
Ashtabula County, Ohio) were found to be primarily attributable to Cleveland Electric
Illuminating's Ashtabula plant and therefore only Ashtabula Township (rather than all of
Ashtabula County) was designated as nonattainment. Using this approach, Orrville
Township would be the only portion designated as nonattainment in Warren County.
EPA Response: The EPA disagrees that Wayne County should be designated as
attainment. Wayne County is west of the monitor in Stark County and wind roses,
pollution roses and HYSPLIT modeling all indicate that sources in Wayne County
contribute to monitored PM2.5 levels at the Stark County monitor. While VMT may not
be particularly high in Wayne County, total emissions are higher in Wayne County than
in Stark County. The majority of the emissions can be attributed to three point sources.
These sources are located in the north-east quarter of the county comprised of Baughman,
Chippewa, Green, and Milton townships and the portion of Norton City located within
Wayne County.
Comment: We oppose the EPA's proposal to override Indiana Department of
Environmental Management (IDEM's) recommendation. The EPA cites no issues with
IDEM's data, which is complete and shows attainment across all monitors in both
counties. Instead, the EPA proposes to change the designation for Lake and Porter
counties to "unciassifiable" due to irregularities with Illinois' sampling program.
Specifically, the EPA proposes to designate Lake and Porter counties as "unci assifi able"
on the premise that it cannot determine whether those counties may be contributing to a
violation in Illinois, if such a violation exists. All monitors in both Indiana counties
demonstrate compliance with the 2012 PM2.5 NAAQS. The EPA has not challenged the
validity of that data. Nor has the EP A identified a single violating monitor where it
contends Lake and Porter counties are "contributing" to nonattainment. Under these
circumstances, the CAA mandates an "attainment" designation for both counties.
The EPA lacks authority to designate Lake and Porter counties as "unclassifiable." The
CAA provides three NAAQS designation categories: (1) nonattainment, (2) attainment,
and (3) unclassifiable. By explicitly defining each category. Congress limited the
discretion of states and the EPA in making designations. The EPA must designate as
nonattainment "any area that does not meet (or that contributes to ambient air quality in a
nearby area that does not meet) the [NAAQS] for the pollutant." The EPA must designate
as attainment "any area (other than an area identified in clause (i)) that meets the
[NAAQS] for the pollutant." Areas may be designated "unclassifiable" only when the
area "cannot be classified on the basis of available information as meeting or not meeting
the [NAAQS] for the pollutant." Lake and Porter counties are meeting the NAAQS and
have not been linked to any nonattaining monitor, making nonattainment and
unclassifiable designations improper. Therefore the only designation category the CAA
allows for Lake and Porter counties is "attainment."
The EPA correctly concluded that Lake and Porter counties do not meet either criterion
for a "nonattainment" designation. Without either (1) a nonattaining monitor in Lake
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and/or Porter counties or (2) a nonattaining monitor outside Lake and Porter counties to
which these counties are contributing. Lake and Porter counties do not fit the definition
of "nonattainment" Similarly, Lake and Porter counties do not meet the criteria for
"unclassifiable." An "unciassiliable" area is defined as one in which a lack of information
prevents the EPA from determining if the area is "meeting or not meeting the [NAAQS]."
There is no lack of information on the attainment status of Lake and Porter counties.
Unlike the definition of "nonattainment." the statute does not allow the EPA to designate
an area as unci assi liable because of its potential to contribute to an unci assi liable area.
The plain statutory text tellingly omits any reference to contribution, instead focusing
only on whether the county itself is meeting the NAAQS. There is no lack of data or
ambiguity on that point to support an unci assi 11 able designation. Pursuant to CAA §
107(d)(l)(A)(ii), the EPA must designate an area as "attainment" if it "meets the
[NAAQS] for the pollutant" and does not satisfy the criteria for nonattainment. That is
precisely the situation in Lake and Porter counties. The EPA has undisputed information
demonstrating that all monitors in Lake and Porter counties are attaining the 2012 PM2.5
NAAQS. The EPA has not identified a single nearby monitor that is demonstrating
nonattainment, and therefore cannot conclude that Lake and Porter counties are
contributing to nonattainment elsewhere.
Only an attainment designation is con si stent with the CAA's provisions for adjusting
designations as new information becomes available. Specifically, CAA § 107(d)(3)-(4)
allows the redesignation of Lake and Porter counties if valid data from Illinois later
indicates a NAAQS violation and /'/the EPA demonstrates that Lake and/or Porter
counties are contributing to that violation. In the meantime, the EPA must make
designations based on the information it has. That information permits only one
designation for Lake and Porter counties: attainment.
EPA Response: The commenter properly quotes the criteria in Clean Air Act section 107
for designating areas nonattainment, attainment, or unclassifiable, but the commenter
misinterprets the criteria for being designated attainment. At issue is two counties that
themselves attain the air quality standard but that contribute to concentrations nearby that
may be violating the standard. The commenter argues that a particular portion of the
Chicago area (Lake and Porter Counties, Indiana) should be designated attainment
because the two counties a) meet the standard and b) have not been identified as a
nonattainment area. However, the EPA believes that a more appropriate interpretation of
the criteria for an attainment designation is whether the entire area (including any portion
of the area with emissions that contribute to concentrations in the area) is attaining the
standard. Since the Chicago area cannot be determined to be an area that is meeting the
standard, the Chicago area (including all portions that contribute to concentrations in the
Chicago area) does not quality for designation as attainment.
The EPA designates entire areas as nonattainment, attainment, or unclassifiable; the EPA
does not promulgate separate designations for separate portions of areas. For example, in
2005, the EPA designated a Chicago PM2.5 nonattainment area that included Lake and
Porter Counties in Indiana as well as part or all of eight Illinois counties as a single
combined area. This designation defined a planning area, triggering the applicability of
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an assortment of planning requirements under Section 172 and other sections of Part D
among other things to provide a unified plan by which control measures throughout the
area would be considered and adopted as appropriate to pursue attainment throughout the
area. Thus, interpreting the word "area" in Section 107 as meaning the entire area that is
designated as a unit is more consistent with the manner in which the EPA has historically
promulgated designations and is more consistent with other elements of the Clean Air
Act that apply planning requirements to areas as a whole. Addressing areas as a whole
also provides a more logical outcome to the designation process in cases like this: where,
as here, the area does not warrant a nonattainment designation because the area cannot be
classified as violating the standard, and the area does not warrant an attainment
designation because the area cannot be classified as attaining the standard, the area
clearly warrants a designation that the area "cannot be classified on the basis of available
information as meeting or not meeting" the standard.
Nothing in the Clean Air Act suggests either that the EPA should designate separate
portions of the Chicago area separately or that the provisions of 107 should be interpreted
as yielding a large area if the area is violating the standard but a small area if the area is
attaining the standard or if the area is unclassifiable. To the contrary, once a
nonattainment area is defined, the planning provisions apply to the nonattainment area as
a whole, wherein the planning addresses a unified area that includes all the
interconnected locations within an area that are experiencing violations and contributing
to those violations. The commenter evidently envisions balkanizing these areas into an
unlimited number of separate pieces, with each piece designated without regard to the
interconnections between these pieces, but this approach is inconsistent with the use of
the word "area" and the planning process provided in the Clean Air Act. Similarly, the
provisions for redesignating nonattainment areas ("or portions thereof') to attainment are
contingent on satisfaction of various prerequisites, where the relevant provisions must
address air quality across the entire area. For example, the EPA cannot redesignate a
portion of a nonattainment area if permanent and enforceable measures are yielding
attainment in only a portion of the area. By the same logic, Section 107(d)(1) must be
interpreted to provide for an attainment designation only if the entire area is attaining the
standard and to provide for an unclassifiable designation if the full area cannot be
determined to be violating or attaining the standard.
The commenter highlights the absence of reference to contributing area in the criteria for
an unclassifiable designation. However, this has significance only with the commenter's
use of the word "area." Interpreting "area" to mean just one of several interconnected
locations, and accepting the commenter's interpretation that areas contributing to a
potentially contributing to violations cannot be designated unclassifiable unless air
quality is uncertain in those particular locations, yields the illogical result that the size of
unclassifiable areas would generally be much smaller than the size of the area if it were
designated nonattainment. In contrast, interpreting "area" to mean all of the locations that
collectively influence whether the collective set of locations meets the air quality
standard yields a more coherent interpretation of the three designations in Section
107(d)(1) that is more consistent with the terminology and planning requirements
elsewhere in the Clean Air Act that result from these designations. With this broader
interpretation of the word "area," Section 107(d)(l)(i) clarifies that nonattainment areas
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must include contributing locations as well as violating locations, Section 107(d)(l)(ii)
clarifies that locations that are meeting the standard but are part of a broader area that is
violating the standard cannot be designated attainment, and Section 107(d)(l)(iii)
specifies that any area (which in context would include all the interconnected source and
receptor locations) that cannot be determined to be violating or attaining the standard
would be designated unclassifiable. The EPA believes that Lake and Porter Counties
contribute to concentrations in Cook County and elsewhere in the Chicago area, and the
EPA believes more generally that the set of locations with source-receptor relationships
that warrant being included in the area that could be called the Chicago area would
include Lake and Porter Counties. Since the EPA is unable to determine whether this area
meets or does not meet the standard, the EPA believes that Section 107(d)(1) provides for
the Chicago area, including Lake and Porter Counties, to be designated as unclassifiable.
Comment: The EPA may not invalidate data for one purpose and rely on it for another.
The EPA suggests that "the available air quality data suggest that the spatial distribution
of exposure to PM2.5 is similar to the distribution the EPA found in 2005, when it
promulgated the Chicago 1997 PM2.5 nonattainment area." However, the EPA already
determined that the "available air quality data" in Illinois is invalid. The EPA may not
invalidate data for designating Illinois counties and at the same time arbitrarily use that
invalid data as the basis for designating Indiana's counties. Once the EPA determined that
the Illinois data was invalid, that data could no longer be considered. It would be
arbitrary for the EPA to second-guess Indiana's detailed and carefully considered
recommendation based on data the EPA has already deemed unreliable.
EPA Response: The commenter is misreading the EPA's statements regarding the
available air quality data. The EPA's technical support document for its intended actions
for Illinois and associated areas stated, "While the Illinois air quality data are not
sufficiently complete to provide a reliable indication of the magnitude of concentrations,
the available air quality data suggest that the spatial distribution of exposure to PM2.5 is
similar to the distribution the EPA found in 2005." Thus, as is clear from the technical
support document, the EPA believes that insufficient air quality data are available to
determine whether a violation exists at any site in Illinois, but the EPA believes that
sufficient air quality data are available to assess the spatial distribution of concentrations
in the Chicago area. (Indeed, the EPA makes these data available for purposes such as
these under parameter code 88501 in its Air Quality Subsystem (AQS).) Furthermore,
even if the EPA were to disregard recent air quality data, the similarity of the distribution
of emissions in 2002 (as examined in 2005) and in 2011 (examined more recently) lend
further support to the view that the distribution of concentrations recently is similar to the
distribution in 2002 to 2004. As a result, and given that "a review of the distribution of
emissions, population, and vehicle travel also shows a similar distribution" in the older
and newer data sets, the EPA continues to believe that the same locations are contributing
to high annual average concentrations now that contributed to high concentrations in
2002 to 2004. While the EPA has insufficient information to determine whether the high
concentrations are above or below the standard, the EPA has sufficient information to
identify the range of locations that may be considered either to be experiencing
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concentrations potentially above the standard or to be contributing to these concentrations
potentially above the standard.
Comment: One commenter notes that the EPA's proposed designation of Lake and
Porter Counties as "unclassifiable" is arbitrary and capricious. The EPA's sole basis for
designating Lake and Porter counties as "unclassifiable" is theory that "if the Chicago
area is violating the NAAQS, the area that the EPA finds would likely be contributing to
that violation would likely be the same area as the EPA found in 2005 to contribute to
violations of the 1997 PM2.5 NAAQS [which includes Lake and Porter counties]." That
speculation is unsupported by any facts in the record and ignores the fact (noted in Table
2 of the Illinois TSD) that the western most Lake County PM2.5 monitor (site number 18-
089-2010), which is less than five-thousand feet from the Illinois and Indiana border, had
PM2.5 design values of I 1.0 and 10.6 [^g/m3 during 2010-2012 and 201 1-2013,
respectively. These values are well under the PM2.5 NAAQS of 12 (,ig/nr\ The EPA has
failed to demonstrate that current attainment levels in Lake and Porter counties are linked
to any non-attaining monitor.
The EPA may not rely on a 2005 NAAQS analysis when updated guidance and data are
available. The EPA's claim that "a review of the distribution of emissions, population,
and vehicle travel also shows a similar distribution of these parameters [to 2005]"
similarly fails to support an unclassifiable designation for Lake and Porter counties.
Stating conclusively that some characteristics in the region appear similar to those in
2005, without providing any citations or support, falls far short of demonstrating that
Lake and Porter counties are responsible for unidentified potential air quality problems in
Illinois. First, the current "distribution of emissions" cannot be determined without valid
monitoring data in Illinois. Second, having similar population and vehicle travel profiles
in 2014 and 2005 does not demonstrate that Lake and Porter counties are "likely"
contributing to a potential NAAQS violation in Illinois. That is particularly true because
no specific Illinois monitor exists that would allow the EPA to evaluate such links. In
addition, the EPA's proposed designations fail to address how the factors relied on in
2005 relate to U.S. EPA's 2013 guidance on Area Designations for the 2012 Revised
Annual Fine Particle National Ambient Air Quality Standard ("2013 Guidance"). The
2013 Guidance includes factors such as air quality data, location of sources, growth rate
and patterns, weather, geography and jurisdictional boundaries, none of which are
addressed in the Illinois TSD. The EPA has made no mention of whether these other
factors are comparable to 2005, and indeed has done no analysis whatsoever to determine
the present-day impacts of Lake and Porter counties on Cook County, Illinois. In fact, the
EPA's assumptions fail to take into account important developments affecting the
concentration and distribution of PM2.5 in this region, such as the closing of the massive
coal-fired State Line Generating Plant in 2012 and the continual decrease in PM2.5
ambient concentrations since 2009. The EPA cannot ignore such developments. The EPA
is required to demonstrate a rational connection between the facts found and the choices
made when making NAAQS determinations. The EPA has not analyzed the actual
relationship between emissions in Lake and Porter counties and PM2.5 concentrations in
Illinois, nor has the EPA even identified a NAAQS violation in Illinois that would
warrant such an inquiry. Basing designations on unfounded speculation over what
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impacts Lake and Porter counties might have on a potential NAAQS issue in Illinois
when those counties specifically show attainment would result in an arbitrary and
capricious designation.
EPA Response: The EPA's technical support document for its PM2.5 designations for
Illinois and associated areas provides the EPA's rationale for defining the Chicago area
for purposes of these designations. The commenter is incorrect in claiming that the EPA
has not analyzed the relationship between emissions in Lake and Porter Counties and
PM2.5 concentrations in Illinois and in claiming that the EPA's designation is based on
"unfounded speculation." Nevertheless, in alleging the absence of the information that is
provided in the docket for the proposed rulemaking, the commenter mostly chooses not to
provide comments on the merits of the analysis the EPA did provide and fails to identify
objections to the specific elements of the analysis that the EPA did conduct.
The commenter objects to the approach of defining an unclassifiable area based on
hypothesizing a violation and reviewing the locations that would contribute to such a
violation, but the commenter does not suggest any alternative approach for defining the
contributing portions of an area that might violate the standard or express views on how
the EPA might better determine the boundaries of an area with the potential to violate the
standard, including the associated locations that contribute to concentrations where the
standard may be violated. (Comments interpreting Clean Air Act Section 107 to provide
for the exclusion of contributing areas from areas designated unclassifiable are addressed
above.) The EPA continues to believe that we have properly designated as unclassifiable
both the locations with the potential for violating the standard and the locations that
contribute to concentrations where violations may be occurring, and the EPA continues to
believe that the most appropriate means of defining the contributing portions of such
areas is to examine available information, including information on air quality, emissions,
meteorology, jurisdictional considerations, and topography, to determine what locations
might be expected to contribute to the violations if in fact they are occurring.
The commenter asserts that the EPA's conclusion ignores the existence of data in Lake
County, less than a mile from Cook County, showing concentrations somewhat below the
standard. The commenter does not explain his concept of linking monitoring data, and the
commenter provides no explanation as to why concentrations at about 90 percent of the
standard should be treated as evidence that Lake and Porter Counties do not contribute to
concentrations in Cook County that may exceed the standard. The EPA need not identify
a specific monitor in Cook County as violating the standard to conclude that if a monitor
in Cook County is violating the standard, Lake and Porter Counties are contributing to
the violation.
The commenter questions whether the analysis that the EPA completed in 2005 addresses
the criteria that the EPA identified in its 2013 guidance. In fact, though the 2013
guidance uses a different organization of its recommended factors than the 2003 guidance
used in preparing the 2005 designations, the underlying information and analytical
approaches recommended in the 2013 guidance are very similar to those recommended in
the 2003 guidance. Thus, the analyses completed in 2005 effectively address the factors
identified in the 2013 guidance. In addition, the EPA reviewed more recent data,
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concluding that these data (reviewed in accordance with the 2013 guidance) justified the
same area definition as the EPA promulgated in 2005.
Although the relevant recent data are available in the docket, for convenience the key
relevant data are repeated here, organized according to the factors identified in the 2013
guidance. As will be discussed below, the EPA finds that these data support the same
boundaries of the Chicago area as the EPA promulgated in 2005.
Factor 1, Air quality: Although the data are insufficient to provide an adequately reliable
indication of whether the air quality standards are being violated in the Chicago area, the
data indicate that the highest concentrations are observed in Cook County. Therefore, the
greatest potential for violations exists in Cook County, and the EPA may reasonably
promulgate an unclassifiable area that identifies a planning area that includes Cook
County and the area around Cook County that contributes to PM2.5 concentrations in
Cook County, so long as this area also includes the Chicago area locations with the
potential to violate the standard.
The EPA agrees as a general matter that air quality has been improving in much of the
Midwest, but that does not mean that Lake and Porter Counties are not contributing to
any violation that may be occurring elsewhere in the Chicago area.
Factor 2, Emissions: For this factor, the EPA reviewed data from the 2011 National
Emissions Inventory (NEI) version 1 (see
http://www.epa.gov/ttn/chief/net/2011inventory.html). For each county in the area of
analysis, the EPA examined the magnitude of county-level emissions reported in the NEI.
These county-level emissions represent the sum of emissions from the following general
source categories: point sources, non-point (i.e., area) sources, nonroad mobile, on-road
mobile, and fires. The EPA also looked at the geographic distribution of major point
sources of the relevant pollutants.1 Significant emissions levels from sources in a nearby
area indicate the potential for the area to contribute to monitored violations.
To further analyze area emissions data, the EPA also developed a summary of direct
PM2.5, components of direct PM2.5, and precursor pollutants, which is available at
http://www.epa.gov/pmdesignations/2012standards/docs/nei201 Ivlpointnei2008v3count
y.xlsx.
Evaluating the components of direct PM2.5 and precursor gases can help identify specific
sources or source types contributing to elevated concentrations at violating monitoring
sites and thus assist in identifying appropriate area boundaries. In general, directly
emitted particulate organic carbon (POC) and VOCs2 contribute to PM2.5 organic mass
1 For purposes of this designations effort, "major" point sources are those whose sum of PM precursor
emissions (PM2 5 + NOx + S02 + VOC + NH3) are greater than 500 tons per year based on NEI 201 lv 1.
2 As previously mentioned, nearby VOCs are presumed to be a less important contributor to PM2 5 OM than
POC.
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(OM); directly emitted EC contributes to PM2.5EC; NOx, NH3 and directly emitted
nitrate contribute to PM2.5 nitrate mass; SO2, NH3 and directly emitted sulfate contribute
to PM2.5 sulfate mass; and directly emitted crustal material and metal oxides contribute to
PM2.5 crustal matter.3-4 The EPA believes that the quantities of those nearby emissions as
potential contributors to the PM2.5 violating monitors are somewhat proportional to the
PM2.5 chemical constituents in the estimated urban increment. Thus, directly emitted POC
is more important per ton than SO2, partially because POC emissions are already PM2.5
whereas SO2 must convert to PM2.5 and not all of the emitted SO2 undergoes this
conversion.
This review of emissions information addresses annual emissions rather than seasonal
emissions for several reasons. First, emissions of significant pollutants are relatively
constant throughout the year, so that there are insufficient seasonal emission variations to
warrant a season-by-season review. Second, as noted above, except for the seasonal
variations in nitrate concentrations, the composition of the urban increment appears to be
relatively constant throughout the year. The cold month concentrations of nitrate are
linked to cold month emissions of NOx, but warm month emissions of NOx are also
significant due to their contribution to the photochemical reactions that form secondary
particulate matter. For these reasons, the EPA analyzed annual emissions and concluded
that analysis of seasonal emissions was unnecessary.
Table 1 provides a county-level emissions summary (i.e., the sum of emissions from the
following general source categories: point sources, non-point (i.e., area) sources, nonroad
mobile, on-road mobile, and fires) of directly emitted PM2.5 and precursor species for the
county with the violating monitoring site and nearby counties considered for inclusion in
the Chicago area. Table 2 summarizes the directly emitted components of PM2.5 for the
same counties in the area of analysis for the Chicago area.
Table 1. County-Level Emissions of Directly Emitted PM2.5 and Precursors
(tons/year)
County
NH3
NOX
PM25
S02
voc
Cook Co, IL
3307
108980
14387
16883
87924
Lake Co, IN
976
37838
6539
24464
16249
Will Co, IL
1694
28003
5646
34592
14309
Du Page Co, IL
751
23194
2731
566
19215
Lake Co, IL
623
20107
3197
10747
19148
Porter Co, IN
2852
17222
3737
16745
6283
3 See, Seinfeld J. H. and Pandis S. N. (2006) Atmospheric Chemistry and Physics: From Air Pollution to
Climate Change, 2nd edition, J. Wiley, New York. See also, Seinfeld J. H. and Pandis S. N. (1998)
Atmospheric Chemistry and Physics: From Air Pollution to Climate Change, 1st edition, J. Wiley, New
York.
4 USEPA Report (2004), The Particle Pollution Report: Current Understanding of Air Quality and
Emissions through 2003, found at: http://www.epa.gov/airtrends/aqtrnd04/pm.html.
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Kane Co, IL
994
11808
2068
290
9761
Jasper Co, IN
2955
9960
2041
19513
2872
La Porte Co, IN
1832
8069
1945
13419
5016
La Salle Co, IL
1895
7680
2932
713
5024
Mc Henry Co, IL
1116
6605
1494
130
5845
Kenosha Co, WI
1228
6493
1197
1029
4249
Kankakee Co, IL
1315
4325
1777
163
3859
Grundy Co, IL
688
3780
1158
157
2263
Kendall Co, IL
745
3065
964
56
3191
Key:
NH3 - Ammonia
NOx - Nitrogen Oxides
PM2.5 - Directly emitted PM2.5
S02 - Sulfur Dioxide
VOC - Volatile Organic Compounds
Table 2 breaks down the direct PM2.5 emissions value from Table 1 into their
components. Table 2 summarizes the directly emitted components of PM2.5 for the same
counties in the area of analysis for the Chicago area.
Table 2. County-Level Emissions for Components of Directly Emitted PM2.5
(tons/year) 5
County, State
POM
EC
PS04
PN03
Crustal
Residual
Direct
Cook Co, IL
4538
2695
447
51
2675
3982
14387
Lake Co, IN
1343
763
771
32
1488
2143
6539
Will Co, IL
1033
665
339
14
1548
2047
5646
Du Page Co, IL
1178
658
55
11
326
503
2731
Lake Co, IL
982
498
108
10
669
931
3197
Porter Co, IN
792
610
218
26
954
1137
3737
Kane Co, IL
682
380
32
7
463
504
2068
Jasper Co, IN
284
110
90
2
732
824
2041
La Porte Co, IN
511
207
60
3
553
611
1945
La Salle Co, IL
551
198
112
6
1101
964
2932
Mc Henry Co, IL
456
222
19
4
399
394
1494
5 Data are based on the 2011 and 2018 Emissions Modeling Platform Data Files and Summaries
(ftp://ftp.epa.gov/Emislnventory/201 lv6/v 1 platform) available at:
http://www. epa.gov/ttn/chief/emch/index.html#2011 (accessed 02/26/14).
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Kenosha Co, WI
622
130
26
2
190
226
1196
Kankakee Co, IL
446
141
16
3
660
511
1777
Grundy Co, IL
231
115
27
3
376
406
1158
Kendall Co, IL
219
108
12
3
329
293
964
Key:
PN03 - Primary Nitrate
PS04 - Primary Sulfate
EC - Elemental Carbon
POM - Primary Organic Matter
Crustal - Crustal Material
Using the previously described relationship between directly emitted and precursor gases
and the measured mass to evaluate data presented in Tables 1 and 2, the EPA identified
the following components warranting additional review: directly emitted organic matter,
elemental carbon, NOx, and SO2. The EPA then looked at the contribution of these
constituents of interest from each of the counties included in the area of analysis as
shown in Tables 3a-d.
Table 3a. County-Level Particulate Organic Matter Emissions (tons/year)
State
County
POM
% of Area
Cum %
Illinois
Cook, IL
4538
33%
33%
Indiana
Lake, IN
1343
10%
42%
Illinois
DuPage, IL
1178
8%
51%
Indiana
Will, IL
1033
7%
58%
Illinois
Lake, IL
982
7%
65%
Illinois
Porter, IN
792
6%
71%
Illinois
Kane, IL
682
5%
76%
Wisconsin
Kenosha Co
622
4%
81%
Illinois
LaSalle, IL
551
4%
85%
Indiana
La Porte, IN
511
4%
88%
Indiana
McHenry, IL
456
3%
91%
Illinois
Kankakee, IL
446
3%
95%
Illinois
Jasper, IN
284
2%
97%
Illinois
Grundy, IL
231
2%
98%
Illinois
Kendall, IL
219
2%
100%
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Table 3b. County-Level Elemental Carbon Emissions (tons/year)
County
EC
% of Area
Cum %
Cook, IL
2695
36%
36%
Lake, IN
763
10%
46%
Will, IL
665
9%
55%
DuPage, IL
658
9%
64%
Porter, IN
610
8%
72%
Lake, IL
498
7%
79%
Kane, IL
380
5%
84%
McHenry, IL
222
3%
87%
La Porte, IN
207
3%
89%
LaSalle, IL
198
3%
92%
Kankakee, IL
141
2%
94%
Kenosha, WI
130
2%
96%
Grundy, IL
115
2%
97%
Jasper, IN
110
1%
99%
Kendall, IL
108
1%
100%
Table 3c. County-Level Nitrogen Oxides Emissions (tons/year)
County
NOx
% of Area
Cum %
Cook, IL
108980
37%
37%
Lake, IN
37838
13%
49%
Will, IL
28003
9%
59%
DuPage, IL
23194
8%
67%
Lake, IL
20107
7%
73%
Porter, IN
17222
6%
79%
Kane, IL
11808
4%
83%
Jasper, IN
9960
3%
87%
La Porte, IN
8069
3%
89%
LaSalle, IL
7680
3%
92%
McHenry, IL
6605
2%
94%
Kenosha, WI
6493
2%
96%
Kankakee, IL
4325
1%
98%
Grundy, IL
3780
1%
99%
Kendall, IL
3065
1%
100%
Table 3d. County-Level Sulfur Dioxide Emissions (tons/year)
County
S02
% of Area
Cum %
Will, IL
34592
25%
25%
Lake, IN
24464
18%
42%
Jasper, IN
19513
14%
56%
Cook, IL
16883
12%
68%
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Porter, IN
16745
12%
80%
La Porte, IN
13419
10%
90%
Lake, IL
10747
8%
98%
Kenosha, WI
1029
1%
99%
LaSalle, IL
713
1%
99%
DuPage, IL
566
0%
99%
Kane, IL
290
0%
100%
Kankakee, IL
163
0%
100%
Grundy, IL
157
0%
100%
McHenry, IL
130
0%
100%
Kendall, IL
56
0%
100%
In addition to reviewing county-wide emissions of PM2.5 and PM2.5 precursors in the area
of analysis, the EPA also reviewed emissions from major point sources located in the
area of analysis. The magnitude and location of these sources can help inform
nonattainment boundaries. Table 4 provides facility-level emissions of direct PM2.5,
components of direct PM2.5, and precursor pollutants (given in tons per year) from major
point sources located in the area of analysis for the Chicago area. Table 4 also shows the
distance from the facility to the DV monitor for the area.
Table 4. NEI2011 vl Point Source Emissions (tons/year)
County
Facility Name
Distance
to
Monitor
(mi)
NH3
NOx
PM 2 5
S02
voc
Total
Cook, IL
Corn Products
International Inc (031012ABI)
13
1
665
463
1,569
511
3,208
Cook, IL
Fisk Electric
Generating Station (031600AMI)
14
0
1,098
199
4,133
1
5,432
Cook, IL
OHare Airport (ORD)
2
5,261
139
578
961
6,939
Cook, IL
Midway Airport (MDW)
14
1,150
22
133
195
1,499
Cook, IL
Ford Motor Co (031600AAR)
26
1
18
27
0
650
696
Cook, IL
Saint-Gobain
Containers Inc (031069AAI)
26
1
412
78
158
21
670
Cook, IL
Crawford Electric
Generating Station (031600AIN)
12
0
1,893
281
6,545
1
8,721
Cook, IL
Koppers Inc (031300AAJ)
12
1
115
4
857
106
1,083
Grundy, IL
Equistar Chemicals LP
(063800AAC)
45
0
549
178
19
454
1,200
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County
Facility Name
Distance
to
Monitor
(mi)
NH3
NOx
PM 2 5
S02
voc
Total
Kankakee,
IL
Natural Gas Pipeline
Co of America (091811AAB)
65
0
495
10
0
32
537
Lake, IL
Waukegan Electric
Generating Station (097190AAC)
29
1
2,563
718
9,931
2
13,214
La Salle, IL
Pilkington North America
(099825AAG)
68
0
625
107
303
10
1,045
La Salle, IL
Owens-Brockway
Glass Container Inc (099490AAD)
76
0
308
65
138
22
533
La Salle, IL
Illinois Cement Co (099030AAZ)
76
3
897
32
89
32
1,052
Will, IL
Oxbow Midwest
Calcining LLC (197803AAK)
23
145
130
7,003
0
7,278
Will, IL
Exxon Mobil Oil Corp
(197800AAA)
41
207
1,720
249
1,317
429
3,922
Will, IL
Midwest Generation LLC
(197809AAO)
35
1
6,314
1,391
17,034
5
24,745
Will, IL
Will County Electric
Generating Station (197810AAK)
25
1
2,227
392
8,301
2
10,922
Will, IL
CITGO Petroleum Corp
(197090AAI)
24
232
685
144
513
443
2,017
Jasper, IN
NIPSCO - R.M. SCHAHFER
(00008)
68
1
7,367
747
19,352
161
27,627
Lake, IN
STATE LINE ENERGY LLC
(00210)
26
1
7,005
412
8,044
83
15,544
Lake, IN
Indiana Harbor East (00316)
31
19
4,813
526
2,874
1,123
9,355
Lake, IN
MITTAL STEEL (ISG INDIANA
HARBOR WEST) (00318)
31
14
1,601
711
860
84
3,270
Lake, IN
COKENERGY INC. (00383)
31
85
4,892
4,977
Lake, IN
BP PRODUCTS NORTH
AMERICA, WHITING R (00003)
29
17
2,548
427
697
2,118
5,806
Lake, IN
ANR PIPELINE NAT GAS CO
ST. JOHN STATION (00069)
42
482
12
0
26
520
Lake, IN
INDIANA HARBOR COKE
(00382)
31
17
859
154
1,898
2
2,930
Lake, IN
U S STEEL CO GARY WORKS
(00121)
38
103
4,313
1,529
4,202
1,168
11,315
Lake, IN
CARMEUSE LIME INC (00112)
33
1,688
31
313
13
2,045
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County
Facility Name
Distance
to
Monitor
(mi)
NH3
NOx
PM 2 5
S02
VOC
Total
La Porte, IN
NIPSCO - MICHIGAN CITY
(00021)
53
24
1,433
388
13,353
88
15,287
Porter, IN
ArcelorMittal Burns Harbor (00001)
44
29
8,289
2,065
13,843
497
24,723
Porter, IN
NIPSCO - BAILLY STATION
(00002)
45
20
1,975
187
2,560
67
4,809
Kenosha,
WI
Wisconsin Electric Power
Pleasant Prairie Power Plant
(230006260)
40
636
2,498
130
928
124
4,316
The commenter observes that the State Line plant shut down in 2012. Although the
commenter has not provided evidence as to whether this shutdown is permanent or
enforceable, the EPA has reviewed this information. The EPA notes that other facilities
(such as the ArcelorMittal Burns Harbor facility) in Lake and Porter Counties have
greater emissions, and the EPA concludes that emissions even with that plant shutdown
are sufficient to conclude that Lake and Porter Counties are a contributing portion of the
Chicago area.
The EPA also 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.
Rapid population growth 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 county associated with area source and mobile source emissions as part of the
nonattainment area. Table 5 shows the 2000 and 2010 population, population growth
since 2000, and population density for each county in the area.
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December 17, 2014
Table 5. Population Growth and Population Density.
County
Population
2000
Population
2010
%
Change
from
2000
Land
Area
(Sq.
Miles)
Population
Density
(per Sq.
Mile)
% of
Area
Cumulative
%
Cook, IL
5,376,741
5,199,377
-3.3%
946
5,498
54%
54%
DuPage, IL
904,161
918,186
1.6%
334
2,752
9%
63%
Lake, IL
644,356
704,303
9.3%
448
1,574
7%
70%
Will, IL
502,266
678,883
35.2%
837
811
7%
77%
Kane, IL
404,119
516,034
27.7%
520
992
5%
83%
Lake, IN
484,564
496,112
2.4%
497
998
5%
88%
McHenry, IL
260,077
309,223
18.9%
604
512
3%
91%
Kenosha, WI
149,577
166,632
11.4%
273
611
2%
93%
Porter, IN
146,798
164,565
12.1%
418
394
2%
94%
Kendall, IL
54,544
115,257
111.3%
321
360
1%
96%
La Salle, IL
111,509
113,816
2.1%
1,135
100
1%
97%
Kankakee, IL
103,833
113,502
9.3%
677
168
1%
98%
LaPorte, IN
110,106
111,432
1.2%
598
186
1%
99%
Grundy, IL
37,535
50,103
33.5%
420
119
1%
100%
Jasper, IN
30,043
33,531
11.6%
560
60
0%
100%
Source: U.S. Census Bureau population estimates for 2000 and 20
Table 6. 2011 VMT for the Chicago Area
2011 VMT
% of Area
Cum. %
County
Total
Cook, IL
31,705,270,056
45%
45%
DuPage, IL
8,059,051,190
11%
57%
Will, IL
5,518,889,913
8%
64%
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Responses to Significant Comments 2012 Annual PM2.5 NAAQS
December 17, 2014
2011 VMT
% of Area
Cum. %
County
Total
Lake, IL
5,436,289,715
8%
72%
Lake, IN
4,664,891,193
7%
79%
Kane, IL
3,547,189,906
5%
84%
McHenry, IL
2,106,689,997
3%
87%
Porter, IN
1,836,723,893
3%
89%
La Porte, IN
1,702,002,112
2%
92%
La Salle, IL
1,333,020,018
2%
94%
Kenosha, WI
1,313,367,247
2%
96%
Kankakee, IL
969,019,995
1%
97%
Kendall, IL
768,299,498
1%
98%
Jasper, IN
710,369,578
1%
99%
Grundy, IL
693,739,990
1%
100%
70,364,814,301
Factor 3: Meteorology
The EPA evaluated available meteorological data to determine how meteorological
conditions, including, but not limited to, weather, transport patterns, and stagnation
conditions, could affect the fate and transport of directly emitted particulate matter and
precursor emissions from sources in the area of analysis. The EPA used two primary
tools for this assessment: wind roses and kernel density estimation (KDE). When
considered in combination with area PM2.5 composition and county-level and facility
emissions source location information, wind roses and KDE can help to identify nearby
areas contributing to violations at violating monitoring sites.
Wind roses are graphic illustrations of the frequency of wind direction and wind speed.
Wind direction can indicate the direction from which contributing emissions are
transported; wind speed can indicate the force of the wind and thus the distance from
which those emissions are transported. The EPA constructed wind roses from hourly
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December 17, 2014
observations of wind direction and wind speed using 2009-2012 data from National
Weather Service locations archived at the National Climate Data Center.6 When
developing these wind roses, the EPA also used wind observations collected at
meteorological sampling stations collocated at air quality monitoring sites, where these
data were available. Figure 1 shows wind roses that the EPA generated from data relevant
in the Chicago area.
Figure 1. Wind Roses in the Chicago Area
May 28, 2014
~ Daily • 0.0-12.0 Q 2.0-4.0 Q 8.0-10.0 Q County Boundaries
~ Annual • 121 -19.0 ~ 4.0-6.0 ~ 10.0-12.0
~ Both ~ 0.5-2.0 ¦ 6.0-8.0 ~ >12.0
As shown in Figure 1, while winds from the west and south are somewhat more frequent
than winds from other directions, all directions have sufficient frequency of winds that
emissions in all directions may be considered to contribute to violations at the violating
monitor.
6 ftp.ncdc.noaa.gov/pub/data/hoaa or
http:Sgis.ncdc.noaa.goy/mapMewer:ittapp=cdo&cfg=cdo&theme=hourly&layers=l&node=gis Quality
assurance of the National Weather Service data is described here:
http://www 1. ncdc. noaa.gov/pub/data/inventories/ish-qc.pdf
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Factor 4: Geography/topography
To evaluate the geography/topography factor, the EPA assessed physical features of the
area of analysis that might define the airshed and thus affect the formation and
distribution of PM2.5 concentrations over the area. The Chicago area does not have any
geographical or topographical barriers significantly limiting air pollution transport within
its airshed. Therefore, this factor did not play a significant role in this evaluation.
Factor 5: Jurisdictional boundaries
In defining the boundaries of the intended Chicago nonattainment area, the EPA
considered existing jurisdictional boundaries, which can provide easily identifiable and
recognized boundaries for purposes of implementing the NAAQS. Existing jurisdictional
boundaries often signify well recognized boundaries that the state can easily administer
and for which the state has the necessary legal authority for carrying out air quality
planning and enforcement functions. Examples of such jurisdictional boundaries include
existing/prior nonattainment area boundaries for particulate matter, county lines, air
district boundaries, township boundaries, areas covered by a metropolitan planning
organization, state lines, and Reservation boundaries, if applicable. Where existing
jurisdictional boundaries were not adequate or appropriate to describe the nonattainment
area, the EPA considered other clearly defined and permanent landmarks or geographic
coordinates for purposes of identifying the boundaries of the intended designated areas.
The Chicago area was previously designated nonattainment for the 1997 annual PM2.5
NAAQS. The EPA's intended nonattainment area for the 2012 NAAQS is identical to
area that was designated nonattainment for the 1997 NAAQS. Furthermore, the Illinois
portion of the EPA's intended nonattainment area matches the identical Illinois
recommendations with respect to both the 2012 NAAQS and the 1997 NAAQS. On the
other hand, the area within Indiana that the EPA designated nonattainment for the 1997
standard exceeded Indiana's recommendation for that standard (by including Porter
County in addition to Lake County) and differs by two counties from Indiana's
recommendation that the nonattainment area for the 2012 NAAQS include no area within
Indiana.
Recent Chicago nonattainment areas for PM2.5 and for ozone have included the two
townships in Grundy County and the one township in Kendall County that are included in
the EPA's intended 2012 PM2.5 NAAQS nonattainment area. Townships are well
established and well recognized jurisdictional boundaries in Illinois, and so the use of
these county subdivisions as boundaries for the nonattainment should provide for suitable
ease of administration of nonattainment area requirements. These townships reflect the
more urbanized portions of these otherwise relatively rural counties, and inclusion of
these townships is consistent with Illinois' recommendations and provides for a definition
of the nonattainment area that is consistent with other nonattainment area boundaries for
other NAAQS.
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This information demonstrates that a review of the most recent available information on
the five factors identified in the 2013 guidance in accordance with that guidance supports
defining the Chicago area as having the same boundaries as the EPA established in 2005.
Comment: We believe that while the EPA and Illinois the EPA (IEPA) work to
determine the cause and extent of any invalid PM2.5 data and appropriate remedies, there
is sufficient technical evidence to support the exclusion of Grundy County townships
from the Chicago PM2.5 nonattainment area. We ask that as you move forward with IEPA
to clarify Illinois nonattainment boundaries, you exclude portions of Grundy County
(specifically the townships of Aux Sable and Goose Lake) from consideration as part of
the nonattainment area. Inclusion of counties that do not materially contribute to
nonattainment can have severe negative economic consequences for that county. In
addition to the potential of costly new regulations that do not improve air quality at the
violating monitor, employers and manufacturers evaluating areas consider an area's
attainment/non-attainment classification before making decisions on expansions or new
facilities.
In the case of Grundy County, IEPA's recommendation appears to have weighted
meteorology, specifically prevailing wind direction, over all other factors. IEPA and the
EPA should now reexamine the data, weight monitored air quality data and emissions-
related data more appropriately, and remove Grundy County from any further
nonattainment classification discussion.
While the EPA has declared much if not all of IEPA's PM2.5 data invalid for technical
reasons having to do with data collection and processing, this does not necessarily mean
that the data is wholly inaccurate. IEPA's data tracks regional levels and trends observed
by the CASTNET monitors in Illinois. For this reason, we believe that our earlier data
analysis provided to IEPA in November 2013 is still appropriate to consider.
Due to its small population, limited urban area, and moderate point source emissions
potential, Grundy County is not required to have a PM2.5 monitor located in the county.
However, adjacent Will County, which is downwind of Grundy County particularly on
days when the violating Chicago monitor experienced higher PM2.5 levels, has two
monitors. The annual average levels experienced by these monitors can be used to
understand whether high PM2.5 levels are being emitted in Grundy County and making
their way through transport to the violating monitor. The Joliet monitor in Will County
downwind of Grundy County shows an annual average concentration of 11 (J,g/m3, which
is below the new 12 [j,g/m3 NAAQS level. The Braidwood monitor, located immediately
adjacent to Grundy County, shows an annual average concentration of 9.9 |ig/m3. It
should be noted that the Joliet monitor in Will County is located in close proximity to a
large electric generating unit, or EGU, which is much more likely to contribute to the
annual average concentration at this monitor rather than the much smaller, more distant
emissions from Grundy County. Both the Joliet and Braidwood monitors have shown
improved air quality in recent years. In the three-year period ending in 2009, the last
period that the Joliet monitor exceeded the new NAAQS, its annual average was 12
[j,g/m3. It has continued to show declining PM2.5 concentrations, and as mentioned above,
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Responses to Significant Comments 2012 Annual PM2.5 NAAQS
December 17, 2014
most recently measured 11 [j,g/m3. The Braidwood monitor last exceeded the NAAQS in
the 3-year period ending in 2004. PM2.5 concentrations have also decreased at this
monitor, from 10.4 [j,g/m3 in the three-year period ending in 2009 to 9.9 [j,g/m3 in the
most recent 3-year period. This analysis demonstrates suggests that the air flowing from
Grundy County towards the Chicago region has some of the lowest PM2.5 concentrations
in the region. Furthermore, trends in PM2.5 levels at these two closest monitors to Grundy
County show decreasing amounts of PM2.5 levels, which supports this assertion.
Additionally, predicted concentrations of PM2.5 for a portion of Grundy County, and
several adjacent counties, represent some of the predicted lowest PM2.5 concentration in
the Midwest.
IEPA staff have over-relied on one factor—wind direction—in the five factor analysis.
The exceedance concentrations experienced by one monitor in the Chicago region do not
have a significant contribution from emissions in a county like Grundy that is predicted to
experience low PM2.5 levels based on regional air quality monitors. Rather, they are much
more likely to be emitted closer to the source of the sole exceeding monitor.
From the available air quality data, then, it does not appear that emissions from Grundy
County, as they may make their way toward the violating monitor, contribute in any
material way to high PM2.5 levels at their closest monitors. We recognize that a recent
technical systems audit of IEPA's monitoring program has invalidated much if not all of
their recent PM2.5 monitoring data. However, Illinois also has Clean Air Status and
Trends Network (CASTNET) monitors in Bondville (located near Champaign) and in
Stockton (west of Chicago) which have independent analysis procedures, and which have
not been invalidated. The Clean Air Status and Trends Network (CASTNET) is a national
air quality monitoring network designed to provide data to assess trends in air quality,
atmospheric deposition, and ecological effects due to changes in air pollutant emissions.
CASTNET provides long-term monitoring of air quality in rural areas to determine trends
in regional atmospheric nitrogen, sulfur, and ozone concentrations and deposition fluxes
of sulfur and nitrogen pollutants in order to evaluate the effectiveness of national and
regional air pollution control programs. A review of national CASTNET data indicates
that significant reductions in SO2, SO4, HNO3, total NO3, and NFU have been realized in
the Eastern US. For example, between 1990-1992 and 2010-2012, SO2 concentrations
were reduced from 8.9 [j,g/m3to 2.1 (j,g/m3, a 76% reduction. Therefore, we believe that
an analysis of CASTNET recent measurements and trends lends independent support to
the IEPA data showing low predicted PM2.5 emissions and precursors in rural areas such
as Grundy County. Both Illinois CASTNET monitors demonstrate an observed
downward trend (air quality improvement) in combined quarterly sulfate and nitrate from
2001 through 2013. This trend is consistent with average and maximum annual and 24-hr
PM2.5 concentration trends seen in other monitoring networks. Emissions of PM2.5 and its
precursors and constituents from Grundy County represents the lowest category of
emissions of any of the counties being considered for inclusion in the nonattainment area.
In addition, according to 2011 NEI data, consistent with measured trends in constituent,
precursor and PM2.5 concentrations, emissions of key constituent and precursors of PM2.5,
as well as direct emissions of PM2.5 are lower in 2011 than in 2008, in some cases
dramatically so.
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Emissions from key constituents, precursors and direct PM2.5 have decreased
significantly. A slight increase in SO2 emissions is insignificant in the context of the total
overall tons per year decrease demonstrated by the other emissions categories and in
context of the overall SO2 emissions inventory for the proposed non-attainment area
(Grundy County's SO2 emissions account for approximately 0.08% of the nine-county
total SO2 emissions of 63,110.10 tpy). Furthermore, as IEPA notes in its designation
recommendation, Grundy County contributes only 1.7% to the total emissions in the
nine-county regions' PM2.5 total. This updated information further supports our
conclusion that emissions from Grundy County are an extremely small fraction of the
total emissions in the proposed nonattainment area. The significant decreases in these
emissions from 2008 to 2011 further supports this conclusion.
In light of the decreasing emissions from 2008 to 2011, we contend the IEPA's analyses
of emission related factors do not support inclusion of Grundy County townships in a
Chicago PM2.5 nonattainment area. Emissions-related factors are intended to place
context around the emissions data, such as whether an emissions category is expected to
grow in the future. A strong pattern of growth in population, vehicle miles traveled,
industrial expansion, or nonroad transit might bolster an argument that a county with
relatively insignificant current emissions should be included in a nonattainment area. In
the case of Grundy County, analysis of emission-related factors do not make this case.
IEPA's analysis first discusses population density. In the case of Grundy County, the
2010 population density was 119 people per square mile. In Cook County, the county
with the sole violating monitor, the population density is 5,491 persons per square mile.
The 50,063 residents of Grundy County make up 0.05% of the region's total population,
the smallest fraction of any county being considered for inclusion in the nonattainment
area. By 2012, the Grundy County population density increased by one person per square
mile. By contrast, Cook County added 39 people per square mile.
The document then provides population growth projections between 2000 and 2030.
While Grundy County is predicted to add between 10,000-50,000 persons over that time
period, four other counties in the region are predicted to add over 200,000 persons each.
Clearly population growth in the region will not be driven by projected new inhabitants
of Grundy County.
The document then turns to VMT per county, and further breaks out the VMT for Aux
Sable and Goose Lake townships. The combined VMT for those two townships
represents 0.56% of that of Cook County, the county with the sole violating monitor. This
comparison does not even include the VMT from the other counties being considered for
inclusion in the region. Again, Grundy County has the smallest VMT of any county in the
proposed nonattainment area. Grundy County does have a moderate percentage of its
residents commuting out of the county for work. However, when one is dealing with the
commuting habits of a county with 50,063 total inhabitants, the impact of their commute
is dwarfed by the emissions and VMT of inhabitants of far more populous counties, such
as Cook County, which has over 5 million residents. Therefore, the relative weight one
gives to commuting patterns for Grundy County, especially as emissions from motor
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vehicles continues to decline as a result of federal fuel and engine standards, should be
extremely small.
Wind roses and summary back trajectory data presented in the IEPA document show that
on high PM2.5 days, winds most frequently originate in the South, South/South West, and
South West sectors, which comprise Cook, Kankakee, Will and Grundy Counties.
Interestingly, on the two days when the highest PM2.5 concentrations were experienced at
the violating monitor, daily back trajectories demonstrate that wind directions were not
from this sector. IEPA makes a case that winds were from a sector that includes Grundy
County townships during several high PM2.5 days. However, it appears to weight that
evidence far more strongly than it does the more compelling ambient air quality data and
emissions and emissions related data. On some high PIVh.sdays, air parcels travel through
Grundy County, and then through Will County and Cook County to reach the sole
violating monitor some 50 miles downwind. But all available evidence suggests that the
air that is being transported from Grundy County on those days does not contain a
significant amount of PM2.5, its constituents or precursors. Therefore, meteorology, when
viewed in the appropriate context with ambient air data and emissions data, should not be
given the pre-eminent weight that it apparently has been given in this analysis.
Geography and topography are not expected to be key drivers in the nonattainment
boundary designation analysis.
Grundy County is not contained in the Chicago Metropolitan Agency for Planning
(CMAP). This organization is responsible for regional planning, including transportation
and environmental planning. It is the designated Metropolitan Planning Organization
(MPO) for the region, and is responsible for transportation planning to achieve
transportation conformity with the State Implementation Plan. Grundy County's lack of
inclusion in the organization charged with transportation, environmental planning, and
the transportation conformity analysis creates a jurisdictional incompatibility that both
highlights its lack of contribution of significant motor vehicle emissions to the region's
total, and its inability to participate in future transportation planning decisions in the
region.
EPA Response: The EPA is designating the Chicago area as unclassifiable, not as
nonattainment. Consequently, this designation will not create the "potential of costly new
regulations" that the commenter fears, and the EPA presumes that a designation as
unclassifiable does not significantly alter "decisions on expansions or new facilities" as
compared to designation as attainment/unclassifiable. In any case, the EPA is presently
obliged to determine boundaries of the Chicago area, an area that may or may not be
violating the PM2.5 standard, but if subsequent data show the existence of violations of
the standard, the EPA will conduct a new review of the area that contributes to the
violations that will not necessarily be the same as the area the EPA currently believes to
represent the Chicago area. For that matter, the EPA is designating the entire State of
Illinois as unclassifiable, so the EPA believes that Grundy County should be designated
unclassifiable regardless of whether portions of the county are or are not judged to be part
of the Chicago unclassifiable area.
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The commenter provides substantial useful information for evaluating the potential of
Grundy County to contribute to violations of the PM2.5 standard in the Chicago area.
However, the EPA continues to believe that the relevant two townships in the county
(Aux Sable and Goose Lake Townships) warrant being included in the Chicago
unclassifiable area. Given the regional nature of PM2.5 concentrations, the air quality in
Grundy County and neighboring Will and Kankakee Counties is not a good indicator of
the potential of emissions elsewhere in the Chicago area where violations are more likely
occurring. The commenter acknowledges that winds are prone to carry emissions from
Grundy County into Cook County and elsewhere in the Chicago area where the potential
for violations of the PM2.5 standard are greater, but the commenter argues that emissions
in Grundy County are too low relative to emissions in other nearby counties to warrant
including Grundy County as a contributing part of the Chicago area. The EPA
acknowledges that the contributions of other nearby counties to potential violations in the
Chicago area are likely to be greater than that of Grundy County, but the EPA believes
that Grundy County has the potential for a sufficient impact on concentrations elsewhere
in the area to warrant being designated as a contributing part of the Chicago
unclassifiable area. The fact that Grundy County is not part of the Chicago Metropolitan
Agency for Planning does not warrant excluding Grundy County as a contributing portion
of the Chicago area. Nevertheless, as noted above, if the Chicago area is subsequently
determined to be violating the PM2.5 standard, the EPA and Illinois will reassess the
appropriate boundaries of the area, including reassessing whether Grundy County should
be designated as part of the area.
Comment: Indiana Department of Environmental Management (IDEM) believes that the
certified, attaining 2011-2013 data collected by monitoring sites in Indiana's monitoring
network within Lake and Porter Counties, IN, should be sufficient to designate Lake and
Porter Counties as "attainment" versus the intended "unclassifiable" designation
associated with the Chicago, IL area (including Lake and Porter Counties, IN) as
indicated in the EPA's August 19, 2014 letter.
EPA Response: The EPA believes that areas designated as unclassifiable must include all
locations that are contributing to concentrations that may be above the standard. The
Chicago area may be violating the standard, and Lake and Porter Counties have sufficient
emissions that are transported to relevant portions of the Chicago area with sufficient
frequency to warrant designating these two counties as contributing to potential
violations. That is, the EPA is designating a Chicago unclassifiable area that includes
both those portions of the area that may or may not be violating the standard and those
portions of the area (including Lake and Porter Counties) that would reasonably be
expected to be contributing to a violation if in fact a violation is occurring.
3 .2.4. EPA Region VI
Comment: Sierra Club states that for the reasons outlined in their comment letter,
including the allegedly capricious nature of the 201 I -2013 time period for the design
value, the problems with the state's exceptional events requests, and the community
based monitoring showing nonattainment levels of PM2.5 in certain Houston
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communities, the commenters respectfully oppose the designation of Houston as
attainment and recommend a designation of nonattainment. Sierra Club states that the
levels of PM2.5 in the Houston area during the 2010-2012 three year period, and the dates
evaluated by the State of Texas for its November 26, 2013 recommendation letter to the
EPA, indicate that people in Houston are breathing unhealthy air. Despite the State's
evaluation of air quality and exceptional events issues during 2010-2012, and Sierra
Club's participation in that process and in particular the issue of exceptional events.
Sierra Club asserts the EPA has inappropriately proposed to change the basis for the
decision to the 201 I -2013 three year period. Sierra Club states the selection of another
three year period different than the one that the State of Texas evaluated for its
recommendation follows a recent pattern by the EPA, and that the allegedly capricious
nature of these kinds of changes is inappropriate and leads to poor policy. Sierra Club
explains the Clean Air Act describes a particular process for designation decisions and
the EPA should not deviate from that process in a capricious manner by selecting time
periods to avoid nonattainment designations, and thus minimize its own workload or the
workload of the states. Sierra Club states the nonattainment SIP process can bring
important public health benefits in cities with poor air quality and avoiding workload or
political pushback are poor reasons for selecting time periods for evaluation. Sierra Club
contends the EPA should not shift this time period, or in the alternative, should allow
another period of notice and comment to allow the public and the State to evaluate this
new time period.
EPA Response: The EPA disagrees with the Sierra Club statement that using data from
201 I to 2013 is capricious in nature, is inappropriate and leads to poor policy. As stated
on page 3 of the EPA's April 16, 2013 Memorandum from Gina McCarthy to Regional
Administrators: "We expect that in providing designations recommendations to the EPA
by December 13, 2013, states and tribes will also review air quality data from 2010 to
2012. However, prior to EPA making final designations decisions, quality-assured,
certified air quality monitoring data from 2013 may be available. If so, EPA's final
designations decisions will be based on data from 201 I to 2013." This guidance memo
was shared with the states and tribal governments and other stakeholders and made
available to the public. The EPA has followed this policy of relying on the most recently
available certified data in numerous initial area designations for multiple NAAQS,
including most recently the area designations for the 2008 ozone NAAQS. The EPA
believes that it is important to base area designation decisions on the most recently
available certified monitoring data specifically for pollutants, such as PM2.5, where the
emissions inventories are trending upward or downward, signaling the potential for 3-
year design values to shift above or below the level of the NAAQS. In the case of the
Houston area, the emissions of the precursor pollutants oxides of nitrogen and sulfur
dioxide are declining, and we see these emissions trends reflected in the monitored
ambient concentrations.
Comment: The com 111 enters provided an extensive set of concerns about the TCEQ's use
of exceptional events data exclusion requests.
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EPA Response: The EPA based its intended and final area designation for the Houston
area on certified and quality-assured monitoring data for the period from 2011 to 2013.
The 3-year design value on which we based our decision was calculated without
excluding dates flagged as exceptional events. Therefore, the comment is moot.
Comment: The commenters questioned whether the monitoring data obtained at the
Clinton Drive Monitor site is representative for the Galena Park community and
submitted monitoring data gathered from five monitoring sites operated by Air Alliance
Houston at various locations within the community (see Figure 2 below). The
commenters believe the Air Alliance monitoring data demonstrated that the Clinton Drive
monitor was not representative of area air quality and that the area could be in violation
of the NAAQS.
EPA Response: We first note that we must consider all valid data within the relevant 3-
year time frame that is collected in conformance with the Federal Reference Methods and
siting requirements in our designation decision. As discussed below, the Clinton Drive
monitoring site meets these requirements and therefore, must be considered. The location
of the Clinton Drive monitor conforms to all applicable siting criteria, as set forth in 40
CFR Part 58, Appendix D and E, and has been approved by the EPA as part of TCEQ's
most recent Annual Monitoring Network Plan and 5-year Monitoring Network
Assessment. The Clinton Drive monitor is approximately 1.5 miles from Galena Park, as
shown in Figure 2. At Clinton Drive, TCEQ operates PM2.5 Federal Reference Method
(FRM) and non-FRM continuous monitors.
Note: Clinton Drive Monitor (Location A), and Galena Park Monitors (Locations B - F).
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With regard to whether the data collected by Air Alliance Houston indicates a violation,
Region 6 evaluated the monitoring data submitted by the commenter. Approximately 29
discrete samples were collected in the Galena Park community over a 16-month period
from May 2012 through September 2013, thus the data is limited in scope compared to
the data collected by regulatory monitors over a 3-year period and subject to data
completion criteria. Additionally, these data were also not monitored and collected
according to the requirements of the federal reference method for PM2.5 found in 40 CFR
part 50, Appendix L. Our designations must be based on valid 3-year design values, and
even if the monitoring data submitted by the commenters fully complied with the siting
and data quality criteria, there are not sufficient data on which to derive a valid, 3-year
design value.
Therefore, these data do not affect our decision to designate the area as Unclassifiable/
Attainment.
3.2.5. EPA Region IX
Comment: Nevada Bureau of Air Quality Planning has received the EPA's August 19,
2014, letter indicating the intended designation of unclassifiable/attainment for the entire
state of Nevada. Nevada agrees with this intended designation and requests that final
designations subdivide the state according to hydrographic areas.
EPA Response: The EPA appreciates the commenters' support and is designating areas
in Nevada based on hydrographic areas.
Comment: The California Air Resources Board (CARB) appreciates the time, effort, and
collaborative approach U.S. EPA staff took to identify the proposed nonattainment areas
as well as surrounding areas that may contribute to the high measured values. CARB also
notes that the extensive analysis contained in the preliminary Technical Support
Document matches CARB's recommendations for PM2.5 nonattainment areas in the State
and appropriately captures the areas of high measured PM2.5 and the surrounding areas
from which emissions can contribute to the high measured levels. CARB looks forward
to continued collaboration with U.S. EPA in protecting public health for all Californians.
EPA Response: The EPA appreciates the commenters' support.
Comment: The Pechanga Band of Luiseno Mission Indians submits a revised
recommendation of "unclassifiable/attainment" based on complete, certified 2011 -2013
monitoring data that indicate that areas of Indian country are attaining the 2012 annual
PM2.5 standard. The Tribe also requests consultation regarding final designations.
EPA Response: The EPA appreciates the updated and revised recommendation from the
Pechanga tribe. The EPA's preliminary review of monitoring data agrees with the Tribe's
conclusions and the EPA agrees with the Tribe's revised recommendation to designate
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their portion of Indian country as "unclassifiable/attainment" for the 2012 annual PM2.5
standard.
Comment: The Soboba Band of I.uiseno Indians requests consultation to address
questions related to the technical analyses included in the preliminary California
Technical Support Document that support inclusion of the Soboba Indian Reservation in
the Los Angeles-South Coast Air Basin nonattainment area for the 2012 annual PM2.5
standard.
EPA Response: The EPA welcomes the Soboba tribe's request for consultation and has
initiated consultation with the tribe.
3.2.6. EPA Region X
Comment: The December 6, 2013, state recommendation letter from Idaho Department
of Environmental Quality (IDEQ) to the EPA Region 10 showed that according to the
2012 standards, the Pinehurst monitor had not exceeded the standard. In August 2014, the
EPA Region Administrator Dennis McLerran sent a letter to Governor Otter stating that
the EPA is proceeding with intended initial area designations using quality-assured,
certified air quality monitoring data from 2011-2013. The letter from the EPA further
stated that after "extensive collaborative discussions with IDEQ, and consideration of
other relevant technical information, including 2011-2013 air quality data and 2014
technical analyses, the EPA intends to designate a partial area of Shoshone County
(limited to areas surrounding the towns of Pinehurst, Smelterville, and Kellogg) as non-
attainment."
The commenter believes that this letter defied the Governor and IDEQ's
recommendations, did not specifically state what was collaborated upon, and used a 2014
technical analysis which has either not been finalized or is not available to the public.
EPA Response: The EPA and IDEQ have worked together to review the data and
develop the technical analyses in the West Silver Valley (WSV) Technical Support
Document (TSD). The EPA's final 2012 Annual PM2.5 NAAQS revision provided that,
pursuant to section 107(d)(1) of the CAA, states were to submit initial designation
recommendations by December 13, 2013 (78 FR 3086, 3250 Jan. 15, 2013). Such a
designation recommendation would necessarily be based on air quality data from 2010-
2012 because data for 2013 was not yet be available. The final rule also acknowledged,
however, that if data from 2013 became available before the EPA finalized the area
designations, the EPA's designation decision would be based on air quality data from
2011-2013, which are the most recent three consecutive years of data (78 FR 3259-51),
The WSV TSD was available to the public for review in its draft form, and was part of
the rulemaking docket for the proposed area designations for the 2012 PM2.5 Annual
NAAQS. The TSD was finalized after consideration of comments received during the
public process provided for the area designation. The purpose of proposing a draft
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document as opposed to a final document was to provide an open and transparent process
that allowed for meaningful input from both the state and the public at large.
Comment: The commenter states that pages 7, 29, and 31 of the Idaho TSD state include
the design values based on 2010-2012 data, and that the figures will be updated in the
final TSD with 2011-2013 data. The commenter believes that this will deprive the state
and public from being able to adequately comment without a final document.
The commenter states that the technical analysis gives the West Silver Valley a 12.8
[j,g/m3 design value after excluding only 4 days of exemptions due to exceptional events,
and that while additional exceptional event days may exist, exclusion of those days could
not lower the design value enough to amount to meet the standard. The commenter states
that the EPA has left out 31 days that were requested by the IDEQ and that this could
bring the design value down to 12.0 [j,g/m3.
The commenter further states that the technical analysis includes data from surrounding
//0/7-regulatory monitors and areas outside of the Area of Concern, while only one other
monitor is listed as being in the Area of Concern. The commenter states that charts in the
TSD are complicated and difficult to read due to font-size and color choice. Finally, the
commenter states that the analysis omits reference to any established or estimated PM2.5
concentrations on either a mean or seasonal basis, or to short-term peak background
levels PM2.5, and points to a 2006 study in British Columbia, Canada, which the
commenter is noteworthy for assessing true PM concentrations.
EPA Response: The figures referred to on pages 7, 29, and 31 were generated using a
mapping tool that used the 2010-2012 design value as opposed to the 2011-2013 DV
data. However, this did not affect the content and purpose of the figures in the TSD as
they were used to for the purpose of depicting the area of analysis, population, and
vehicle miles traveled respectively and did not reference or use the design value in the
figures. The data underlying these figures did not change in the final TSD and several
disclaimers were for maps generated using the tool that incorporated the 2010-2012
design value. As noted above, because the inclusion of these figures in the TSD was for
informational purposes unrelated to the design value, the ability for the public to
comment on the figures was unaffected by the mapping tool's reference the 2010-2012
design value.
The design value has been correctly calculated and Table 2a on page 10 of the Idaho TSD
provides this information. The IDEQ submitted to the EPA four exceptional event days at
the Pinehurst, Idaho monitor for concurrence. The EPA has concurred on all four of these
submitted days and the resulting final 2011-2013 design value for the Pinehurst, ID
monitor is 12.8 [j,g/m3. The IDEQ has indicated that there are additional days that may
potentially qualify as exceptional events days. However, both the EPA and IDEQ have
independently confirmed that even if these additional potential exceptional events days
were approved and their values were removed for purposes of calculating the design
value, the monitor's design value for 2011-2013 would still be above the 12.0 [j,g/m3
standard. Information supporting this conclusion may be found in the docket. The IDEQ
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has indicated that it may submit additional exceptional event days for the EPA
concurrence in the future.
The use of multiple monitors within the area of analysis, regulatory and non-regulatory,
allows for a more detailed understanding of potential contributors to the violation
registered at the Pinehurst monitor for 2011-2013. Detailed graphs and emissions
inventories are important for understanding emissions sources in the nonattainment area.
Unfortunately, this can cause difficulty with the color keys and overall complexity even
though we attempt to make the documentation as readable as possible. In the document
background emissions are discussed and considered through the urban increment, and
seasonal and monthly emissions trends are essential to understand when emissions are
affecting the monitor. The 2006 British Columbia cited by this commenter does not
provide additional relevant information justifying a departure from the EPA's method of
analysis for this annual PM2.5 standard.
Comment: The commenter notes that the EPA's technical analysis for Illinois is just 8
pages, and does not agree with the Illinois Environmental Protection Agency's
recommendation. The commenter states that the EPA has used its discretion in the area
designation process, and that the West Silver Valley has been unfairly treated.
The commenter states that the EPA has identified that Residential Wood Stoves are the
reason for non-attainment in the West Silver Valley. The commenter inquires about the
contribution from fireplaces and identifies that fireplaces are not being considered in the
upcoming regulations on strengthening the standards on "residential wood heaters".
The commenter states that most homes the WSV use fireplaces with inserts, and
insinuates that the attainment plan is to replace wood heaters with new devices through a
loan & tax credits. The commenter cites that they will be out of the EPA compliance in 5-
7 years, and that many wood heat manufacturers may not be able to meet the
requirements, http://www.newsmax.com/Newsfront/epa-wood-
stoveban/2014/02/23/id/554234/
EPA Response: The EPA strives to maintain a nationally consistent process for
designating areas when there is a new or revised air quality standard. The area
designations require three consecutive years of certified air quality monitoring data. The
technical analysis for Illinois was for a designation of "unclassifiable," due to pervasive
problems affecting monitoring data in the entire state. These pervasive data problems
prevented the EPA from being able to determine whether Illinois (and parts of adjacent
states) met the NAAQS. Further details can be found elsewhere in this Response to
Comments document. The same deficiencies were not present with respect to Idaho.
The WSV TSD identifies residential wood combustion as a leading contributor to
exceedances of the standard. Residential wood heating encompasses a wide variety of
home heating sources including, but not limited to woodstoves and fireplaces.
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A common misconception is that the designations process addresses control strategies.
For proposed nonattainment areas, this action only identifies the areas violating the
NAAQS, or contributing to such nearby violations. Once the nonattainment area
designation becomes finalized, the state and/or local air quality agency will work with the
affected community to identify strategies to reduce the emissions in the finalized
nonattainment areas. This would be part of the attainment plan development.
The EPA is only considering comments related to the proposed area designations for the
2012 Annual PM2.5NAAQS. The EPA accepted and is currently reviewing comments on
the proposed NSPS for new woodstoves. This comment period is now closed.
Information on this action can be found at the docket for Revised NSPS for new
Residential Wood Heaters - EPA-HQ-OAR-2009-0734.
Comment: The commenter states that the EPA's views regarding the health impacts of
wood heaters are based on only a handful of old, peer-reviewed studies. Furthermore, the
commenter claims that none of these studies consider short-term human health impacts.
The commenter states that the EPA does not use proper science, peer-reviewed studies, or
cross-benefit analyses in the designations process.
EPA Response: Significant research forms the basis for the national ambient air quality
standards prior to promulgation. The multiyear process includes planning, integrated
science assessment, risk/exposure assessment, and policy assessment. For the 2012 PM2.5
annual standard revision, the EPA initiated its review in June 2007. Between 2007 and
2011, the EPA prepared draft and final Integrated Science Assessments, Risk and
Exposure Assessments, and Policy Assessments. Multiple drafts of all of these
documents were subject to review by the public and were peer reviewed by the EPA's
Clean Air Scientific Advisory Committee (CASAC).
All NAAQS are set to protect public health and the environment for all populations
nationwide. The 2012 PM2.5 standard was adopted in response to a court ruling that
remanded the primary annual PM2.5 standard to the EPA finding the Agency had failed to
explain adequately why the standard provided the requisite protection from both short-
and long-term exposures to fine particles, including protection for at-risk populations
such as children. The resulting 2012 PM2.5 annual NAAQS provides increased protection
for children, older adults, persons with pre-existing heart and lung disease, and other at-
risk populations against an array of PM2.5 related adverse health effects that include
premature mortality, increased hospital admissions and emergency department visits, and
development of chronic respiratory disease.
All of the information generated from this process for the particulate matter standards is
publicly available at http://www.epa.gOv/ttn/naaqs/standards/pm/s pm index.html.
Comment: The Idaho Department of Lands (IDL) concurs with many statements made by
the EPA in the proposal, including with respect to topographical influences on PM2.5
concentrations in and around the Pinehurst area. However, IDL believes any increase in
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the non-attainment boundary from the existing PM10 boundary should be supported by
technical data from multiple monitors exceeding the NAAQS.
The commenter prefers a boundary for the 2012 annual PM2.5 nonattainment area that is
coterminous with the existing PM10 boundary, and that thus would include a smaller
portion of Shoshone County. The commenter questions the appropriateness of the
proposed WSV boundary, specifically to the North of Interstate 90, and believes that the
proposed boundary lacked sufficient supporting technical information:
"Pinehurst is in the center of a convergence zone of multiple large mountain drainages.
The typical diurnal flow of air referenced in the EPA and DEQ studies do exist. One
issue that Pinehurst has is a small pinch point on the North side of town where Interstate
90 passes over Pine Creek. This point hence the city of Pinehurst. commonly becomes a
stagnant air mass because of the larger influential drainage of the South Fork of the
Coeur d'Alene which is the Interstate 90 corridor to the East. This stagnancy in
combination with local valley inversions creates a bottle neck for air flow.
"The times of high accumulation of particulates fall within the months of December,
January and February. These are the months which cause the area to exceed the annual
PM2.5 standards. Focused community outreach during these periods of air stagnation
would help to improve community education, support and reduce air quality degradation.
There is insufficient technical data which supports the influence of PM2.5 contributors
outside of the Pine Creek drainage.
"The IDL believes it is reasonable to delay the implementation of the proposed boundary
and increase monitoring for two years. This data would be able to provide the technical
reference on making a more reliable decision on boundary placement. The standard
changed in 2012, not the topography."
This commenter included data with their submission, including Wind Ninja modeling
runs for diurnal flow, and wind roses for Pinehurst. The commenter concluded with a
suggestion for:
"...the addition of three temporary smoke particulate monitors, one in the South Fork of
the Coeur d'Alene River drainage in Smelterville, one in Kingston to the West of
Pinehurst and one at the confluence of the West/ East Fork of Pine Creek, South of
Pinehurst. Data from these three additional locations would be able to clearly define what
the main influences are. where they come from and what the focus should be for
increasing the health standards for Pinehurst Idaho."
EPA Response:
The EPA believes that the proposed nonattainment area boundary is appropriate based on
a weight of evidence analysis that included multiple sophisticated modeling tools. The
Wind Ninja modeling results submitted with this comment complement the suite of
modeling results in this proposal, but do not contradict those results. It is important to
point out that the area is in violation of an annual standard, so analyses are needed to
address potential sources impacting the monitor throughout the full year rather than
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focusing only on sources during the most impactful months for PM2.5. Regardless of the
PM10 boundary, modeling results leading to the proposed (now finalized) nonattainment
boundary showed that prescribed fires and slash fires were potential contributers to PM2.5
at the violating monitor during the fall and spring seasons. These fires were within the
current proposed nonattainment boundaries but beyond the more limited boundaries
suggested in this comment.
As identified in the WSV TSD, the area has been analyzed using a five factor analysis.
This includes review of air quality data from the Pinehurst monitor as well as data from
monitors in surrounding areas. The decision was also supported by emissions inventory
information along with modeling across a multi-county domain in Northern Idaho. The
weight of evidence from the various analyses identified that the majority of emissions
affecting the area were generated within close proximity of the monitor during the
wintertime. It also identified that during the shoulder seasons, fall and spring, there are
emissions from prescribed and slash burning affecting the monitor. There is sufficient
weight of evidence based on current monitoring data to support the nonattainment area at
issue here, and to ensure that all emissions contributing to the monitor are within the
nonattainment area.
3.2.7. Multi-Region Areas
3.2.7.1. Louisville, KY-IN
Comment: The Kentucky Energy and Environment Cabinet (KEEC) comments that the
EPA is inconsistent in applying and evaluating PM2.5 air quality in the Louisville, KY-IN
Area. KEEC states that the EPA intends to use 2011-2013 data from a monitoring site in
Indiana with a violating design value as the basis for a nonattainment designation for the
2012 annual PM2.5 NAAQS, but has not acted on a pending redesignation request for the
1997 annual PM2.5 NAAQS due to data quality issues with air quality monitors in
Jefferson County, Kentucky. KEEC believes that if the EPA is willing to use the ambient
air monitoring data from the Clark County, Indiana, monitor for the PM2.5 nonattainment
designation for the 2012 standard, then the EPA should also use the data to finalize the
attainment designation for the 1997 standard, particularly since the Clark County,
Indiana, monitor has been the design value monitor for the Louisville KY-IN Area since
2007.
EPA Response: The EPA must consider the monitoring data from all monitors in an area
in making a designation decision. While it only takes one monitor in an area to indicate
that an area is violating a standard, it takes all of the monitors in an area to provide
assurance that an area is in compliance with that standard. The only complete, quality-
assured data from the Louisville, KY-IN Area is from the Clark County, Indiana, monitor
which shows a violation of the standard based on 2011-2013 data. Because data are not
available for the monitors in Jefferson County, Kentucky, it is not apparent to the EPA
that the Clark County, Indiana, monitor is the design value monitor for the Area or what
the monitors in Jefferson County, Kentucky, would indicate if these monitors had
complete, quality-assured data. The EPA notes that the highest reading monitor in the
Area when the EPA finalized the Louisville, KY-IN Area designation for the 1997 PM2.5
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NAAQS in 2005 was in Jefferson County, Kentucky. For all of these reasons, the EPA is
designating the Area as nonattainment. However, as the EPA has previously indicated,
areas may opt to early certify monitoring data for the EPA's consideration. In its response
letter to the EPA, Indiana stated that the Clark County, Indiana, monitor is expected to
show attainment at that monitor based on 2012-2014 data and that Indiana intends to
early certify this data for the EPA's consideration. The EPA agrees with Indiana, that in
the event that the Clark County, Indiana, monitor has complete, quality-assured data that
shows attainment for 2012-2014 at that monitor, it is appropriate for the EPA to designate
the Louisville, KY-IN Area as unclassifiable because of the incomplete data in Jefferson
County, Kentucky, for 2011, 2012, and 2013. Additionally, it is not anticipated that the
monitors in Jefferson County, Kentucky will have complete data for the 2012-2014 time
period.
While the EPA's evaluation of the redesignation request for the Louisville KY-IN Area
for the 1997 PM2.5 standard is outside of the scope of the designation process for the 2012
PM2.5 standards, the EPA notes that complete, quality-assured data for the entire area
(i.e., monitors in Indiana and Kentucky) are required to support the redesignation.
Comment: The Kentucky Energy and Environment Cabinet (KEEC) notes that the
preliminary Technical Support Document for the Louisville, KY-IN Area that the EPA
developed and included in its 120-day letter to Kentucky Governor Steven Beshear on
August 19, 2014, relied upon emissions data from 2011 and 2012. KEEC notes that
additional reductions in PM2.5, SO2, and NOx will occur in the Louisville KY-IN Area as
a result of two emission reduction projects at the Louisville Gas & Electric's (LG&E)
Mill Creek and Cane Run facilities that are scheduled for completion by the end of 2016.
KEEC asks that the EPA designate the Louisville KY-IN Area as
unclassifiable/attainment based on the anticipated emissions reductions from these
projects and on Indiana's expected early certification of 2014 data.
EPA Response: The EPA appreciates the information regarding the upcoming emissions
reductions in PM2.5, SO2, and NOx at the LG&E's Mill Creek and Cane Run facilities
and is aware of Indiana's belief that the Clark County, Indiana, monitor will show
attainment of the PM2.5 NAAQS from 2012-2014 at that monitor once 2014 data is
certified. For designations, the EPA must base its determination on the air quality data
and emissions for the area at the time of the final designations. As discussed above, the
EPA will consider the 2012-2014 data from this monitor if Indiana early certifies
complete, quality-assured data for 2014. The Agency agrees with Indiana that in the
event that the Clark County, Indiana, monitor has complete, quality-assured data showing
attainment for 2012-2014 at that monitor, it is appropriate for the EPA to designate the
Louisville, KY-IN Area as unclassifiable because of the incomplete data in Jefferson
County, Kentucky for the time period of designations.
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3.2.7.2. Cincinnati-Hamilton, OH-KY
Comment: Ohio EPA (OEPA) commented that the intended boundary for the
Cincinnati-Hamilton area should not include the intended partial Warren County. OEPA
notes that the EPA's analysis included demonstrating the percent of total pollutants that
Warren county contributes compared to other counties in the intended nonattainment
area, including VMT, but due to the fact that the wind direction is predominantly from
the south/southwest, while Warren County is east/northeast of the violating monitors, the
area is not contributing to the violation, or is a "weak contributor" and therefore should
be designated attainment, rather than nonattainment based on contribution to the violating
monitors.
EPA Response: In fact, the wind roses shown in Figure 8 of the TSD indicate winds
blowing from the northeast direction during a moderate fraction of the 2010-2012 3-year
period. Additionally, the EPA's KDE plots included in the TSD (Figure 9) show a high
frequency (greater than 50% of the maximum frequency) of trajectories passing over grid
cells that include the portions of Warren County that were included as the intended
boundary. The EPA also notes that for the 2012 annual NAAQS, the monitor data for the
entire calendar year (including on days that are below the level of the NAAQS) are part
of the mathematical calculation of whether a monitor is nonattainment or not. Thus,
contribution is still relevant even during a single season, during days that wind directions
are coming from the east/northeast, or during periods that do not have high ambient
levels. Accordingly, this was one of the factors used when including Warren County in
the nonattainment area.
The EPA also notes that during the multifactor analysis the EPA also considered Warren
County's contribution to direct PM from mobile sources moving into Hamilton County
(the area with the violating monitors), and furthermore assessed contribution from the
population and urban area of Warren County that is part of the continuous Cincinnati-
metro area. The mobile sources in particular move into the area where the violations are
being monitored, leading to direct contribution regardless of wind direction. While the
commenter notes that only 5.2% of the area's commuters are from Warren County, the
number of VMT for 2011 in Warren County is over 2 billion miles, and it had the third
highest VMT for the intended nonattainment area, as noted in the TSD sent to the state
and posted as part of the FR notice.
The commenter also notes that the area is a "weak contributor" as far as precursors due to
wind direction and the lack of major point sources in the county; however, the statute is
clear in providing for inclusion in nonattainment areas of areas that "contribute" to the
violations. The EPA interprets the term "contributes" to mean contributes sufficiently to
justify inclusion in the nonattainment area, and the EPA's multifactor test with the
various analytical tools is intended to assure an objective evaluation of the appropriate
facts on a case by case basis in each area. The EPA has considered multiple factors of
analysis, and has applied the same analysis to all counties considered in the area of
analysis as outline in the TSD. The EPA's decision is not contingent on only one part of
the analysis, but the analysis as a whole especially given that PM is a complex pollutant
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with contribution from multiple source categories as well as multiple pollutants. Hence,
the EPA's use of the weight of evidence approach evaluating the facts and circumstances
in each area on a case by case basis, and was done consistently with decision principles to
assure comparable treatment in all the designations.
Comment: The Kentucky Energy and Environment Cabinet (KEEC) provided comments
regarding the Kentucky portion of the intended Cincinnati-Hamilton nonattainment area,
the partial counties of Boone, Kenton, and Campbell. KEEC comments that they believe
the monitored violations are due to local sources only, and that monitors measuring
attainment both upwind and downwind of the violating monitor's shows that the
violations are from local sources only. The comments point to local rail yards, rail lines,
and highways as the sources that are causing the violation given their location to the
violating monitors. The comments also cite the EPA's TSD enclosed with the 120-day
letters, noting that the Kentucky counties each account for less than 10% of the emissions
for each pollutant or precursor within the area of analysis.
EPA Response: The commenter has not provided emissions associated with these
sources allegedly causing the violations, nor has the commenter provided any additional
evidence that emissions from these sources would be the only contributors of PM
monitored at the violating monitors. Very localized sources may contribute to the
violation, along with other sources in the nonattainment area. As a general matter, single
sources cause concentrations that are only a fraction of the standard, even in their
immediate vicinity, and violations instead reflect the contributions of numerous sources
throughout an urban area (in addition to significant "background concentrations" from
more distant sources). To determine the contribution of nearby areas, the EPA provided a
multiple factor analysis that looked at the various sources of PM in the area, their total
emissions, as well as wind direction impacting the monitors, and the source of the air
mass that cover the continuous nonattainment area through back trajectories (noted as
KDEs in the TSD). The three counties (Boone, Kenton, and Campbell) in Kentucky were
found to be commonly upwind of the violating monitor based on the wind roses and
KDEs (see Figures 8 and 9 of the TSD), and to have emissions that the EPA considers
contributing to the violation due to both magnitude - as measured in tons per year - as
well as composition, with the VMT and population in the Kentucky areas contributing to
higher upwind emissions. The EPA's multifactor test with the various analytical tools is
intended to assure an objective evaluation of the appropriate facts on a case by case basis
in each area, and the EPA has determined through the weight-of- evidence presented in
the TSD that the areas in Kentucky contribute to the violations in Hamilton County.
Moreover, the fact that there are monitors showing attainment does not prove that there is
no contribution from the area, since the nature of PM2.5 is that a group of sources that
may not be causing a violation in one location may in combination with other nearby
sources be contributing to violations elsewhere nearby.
The commenter also notes that emissions from sources in each of the Kentucky areas are
10% or less. The statute does not require the EPA to establish or use a bright line test or
threshold (in this case an emissions percentage) to define what constitutes contribution.
Indeed, the EPA has said that to do so would potentially result in arbitrary and capricious
decisions in areas where such a test would make no sense by including or excluding areas
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without regard to other more relevant information. Hence, the EPA's use of the weight of
evidence approach evaluating the facts and circumstances in each area on a case by case
basis, but done consistently with decision principles to assure comparable treatment in all
the designations. In this case the emissions from these counties' sources, plus the
meteorology, and the amount of VMT and population were all noted as part of the
analysis the EPA conducted in the TSDs that resulted in the determination that these
counties contribute to the violations in Hamilton County and should be included in the
nonattainment area.
3.2.7.3. St. Louis, MO-IL
Comment: The Missouri Department of Natural Resources (MO DNR) reiterates their
recommendation that the EPA designate all portions of Missouri, including those areas in
the St. Louis area, as unclassifiable/attainment. MO DNR is concerned that if the EPA
designates the City of St. Louis and St. Louis, St. Charles, Franklin, and Jefferson
Counties as "unclassifiable" because of uncertainty with the Illinois monitoring data as
indicated in the August 19, 2014 letter to Missouri Governor Nixon, then the
unclassifiable designation may leave the St. Louis area open to a potential future
nonattainment area designation when Illinois resolves its PM2.5 monitoring issues. MO
DNR further states that an unclassifiable/attainment designation is appropriate regardless
of the uncertainty of Illinois data because all monitors in Missouri attain the 2012 annual
PM2.5 NAAQS and are trending downward.
EPA Response: The EPA must consider the monitoring data from all monitors in an area
to inform the appropriate designation decision. While it only takes one monitor in an area
to indicate that an area is violating a standard, it takes all of the monitors in an area to
provide assurance that an area is in compliance with that standard. In the case of St. Louis
MO-IL, the monitoring data on the IL portion of the area is invalid, thus the EPA can't
verify if the area would be attaining. The IL monitors have historically been the design
value monitors for the area so relying on attaining monitors in Missouri is not appropriate
as these Missouri monitors have not historically had the highest design values in the area.
The EPA is using "unclassifiable" for those areas where the EPA was not able to
determine based on available information whether the area is meeting or not meeting the
NAAQS or where the EPA was not able to determine that the area contributes to a nearby
violation. In this case the EPA cannot determine if the area meets the NAAQS or
determine if the MO area contributes to a nearby violation, thus the EPA is designating
all portions of St. Louis Missouri as unclassifiable.
Comment: MO DNR notes that it is inappropriate to include areas in Missouri in an IL-
MO unclassifiable area based on the TSD for the 1997 annual PM2.5 NAAQS because at
the time that TSD was developed, monitors in Missouri were violating the 1997 standard
of 15 |ig/m3 and the TSD analysis was based on assessing contribution to a violating
Missouri monitor.
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EPA Response: The EPA is including areas in Missouri because of the uncertainty in
both monitored values and potential contributions to possible violations of the NAAQS.
Because the area has a history of nonattainment the EPA did review past analysis to help
inform the unclassifiable boundary determination. The EPA does not believe it is
inappropriate to consider past analyses to help inform this decision. The EPA also
believes that the current distribution of emissions and wind patterns are similar to the
historic distribution of emissions and wind patterns, and other factors (recognizing the
limitations in the available air quality data) suggest a similar area to be contributing to
potential violations in Illinois as the EPA found in promulgating designations for the
1997 NAAQS. We agree with Missouri that future attainment/nonattainment boundaries
may be different than those found in the TSD for the 1997 NAAQS, and inclusion as
unclassifiable in this designation does not necessarily indicate this area would contribute
to a future violation should one be found to exist.
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