Indiana and Kentucky Submit Initial Designation Recommendations to EPA for the Revised Primary Annual PM2.5 NAAQS
By Jennifer K. Thompson and Kelly D. Bartley, Attorneys, Bingham Greenebaum Doll LLP
As reported elsewhere in this as well as previous issues of the Air Quality Letter, on Jan. 15, 2013, EPA published a final rule revising the primary annual PM2.5 National Ambient Air Quality Standard (NAAQS) from 15 µg/m3 to 12 µg/m3. In that rulemaking, EPA established a deadline of Dec. 13, 2013 for states to submit recommended initial designations for the revised standard. In accordance with that deadline, the Indiana Department of Environmental Management (IDEM) and the Kentucky Division for Air Quality (KDAQ) submitted recommendations for Indiana and Kentucky on Dec. 12, 2013, and Dec. 5, 2013, respectively.
Recommended Designations for Indiana
Relying on quality assured monitoring data from 2010 through 2012 and preliminary data for the first quarter of 2013, IDEM reported that six monitors in five counties in Indiana have monitored PM2.5 concentrations above the 2012 annual standard of 12.0 µg/m3, which became effective March 18, 2013. However, IDEM’s submittal focused on the fact that PM2.5 monitored concentrations in these counties have decreased over time and all five counties will likely be in attainment with the standard prior to the effective date of the final designations. Thus, IDEM strongly encouraged EPA to take 2013 and 2014 data into consideration when issuing its preliminary and final designations.
The following Indiana counties monitored PM2.5 values above the 2012 annual standard from 2010-2012: Clark, Dubois, Lake, Marion and Vanderburgh counties. However, IDEM asserts that, once the first quarter 2013 monitoring data is quality assured and is included in the air quality assessment, only Clark County will likely remain above the new standard, by just 0.1 µg/m3. Furthermore, because the three-year design values for Clark County have been declining by an average of 0.6 µg/m3 per year over the past five years, IDEM expects Clark County will meet the 2012 annual standard before final designations become effective under EPA’s current schedule.
Based on the assessment, IDEM recommended that all of the monitored counties (Allen, Clark, Delaware, Dubois, Elkhart, Floyd, Greene, Henry, LaPorte, Lake, Marion, Monroe, Porter, St. Joseph, Spencer, Tippecanoe, Vanderburgh, Vigo and Whitley counties) be designated as attainment with the PM2.5 Annual Standard and all other counties in Indiana be designated as unclassifiable.
Recommended Designations for Kentucky
Relying on quality assured monitoring data from 2010 through 2012, KDAQ recommended that all areas of Kentucky be designated as either attainment or attainment/unclassifiable. The design values at all Kentucky monitors with certified data were below the 12 µg/m3 standard. In addition, KDAQ noted that the most recent Kentucky monitoring data available (2011-2013) shows a further downward trend in emission levels.
To view a complete PDF of the Fourth Quarter 2013 issue of the Air Quality Letter, click HERE.