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State Says Hamilton County Out Of Attainment On New Ozone Standards
Could Cause Restrictions On New Industry Here
posted March 13, 2009

The state is recommending that Hamilton County be listed as not in attainment of new lower federal ozone air quality standards.

Bob Colby, director of the Air Pollution Control Bureau, said he expects that the EPA will follow that recommendation and rule the county out of compliance on the standard - that has been reduced from 85 parts per billion to 75 parts per billion.

He said, "That would restrict us from getting another large manufacturing facility unless that company was able to offset the new emissions with pollution credits they acquire."

Mr. Colby added, "We would not be able to add another auto manufacturer."

But he said it would not affect the $1 billion Volkswagen plant that is already under construction at the Enterprise South Industrial Park. He also said it should not affect VW suppliers, who are expected to be clean industries.

Mr. Colby said, "We keep getting cleaner and cleaner, but the standards keep getting tighter and tighter."

When the ozone standard was dropped to 85 parts per billion five years ago, Hamilton County had to join in an Early Action Compact. Several vehicle emission stations were set up and restrictions were placed on open burning.

In meeting the lowered ozone standard, Mr. Colby said, "We will have to look at the situation to see if there is anything more we can do locally."

He said much of the ozone in the air in Hamilton County drifts in from North Georgia, Atlanta and from coal-fired plants.

Mr. Colby noted that the local situation should improve as new emission controls are placed on coal-fired plants and as vehicles and fuels get cleaner and cleaner.

On March 12, 2008, the U.S. Environmental Protection Agency promulgated the new ozone standard of 0.075 ppm. Pursuant to the Clean Air Act, the states have one year from issuance of the new standard to recommend areas of the state as non-attainment or attainment with the new standard.

The state of Tennessee on Thursday issued its recommendations.

The state is recommending that 14 other counties be designated non-attainment as well as Hamilton County, including one county partially with the new ozone standard and the remaining 80 counties be designated as attainment.

The recommendations are based on the Nine-Factor analysis, which was outlined in the EPA guidance dated December 4, 2008.

This is the section dealing with the Chattanooga area:

(1) Chattanooga, TN-GA Metropolitan Statistical Area The Chattanooga, TN-GA Metropolitan Statistical Area (hereinafter referred to as the Chattanooga MSA) includes 3 TN counties. The TAPCD is recommending that one county be classified as nonattainment and two counties be classified as attainment. The single non-attainment county is Hamilton and was formerly classified as attainment. The air monitoring data in this county (Hamilton) showed a design value for 2006-8 data that exceeded the new Ozone standard. The two attainment counties are Marion and Sequatchie and have no air monitoring data. Figure 1 – Chattanooga MSA
Chattanooga MSA:
Tennessee 8-Hour Ozone Nonattainment March 10, 2009
Designations – Nine-Factor Analysis

The following is a county-by-county summary of the factors that were considered in the inclusion/exclusion evaluation for the Chattanooga MSA 8-hour ozone nonattainment area. These factors include precursor emissions, air quality data, population, urbanization, commuter/traffic patterns (―connectivity‖), meteorology, growth, and jurisdictional boundaries. All factors in the applicable EPA guidance were considered.

Hamilton County
Recommendation: non-attainment Jurisdictional boundaries: Hamilton County was previously classified as attainment for ozone. Air Quality Data: There are two ozone monitors in Hamilton County. Both ozone monitors in Hamilton County showed a design value for 2006-8 data that is greater than the new standard of 0.075 ppm. Emissions: 17,533 tons per year of NOx and 19,880 tons per year of VOC. Only 15.6% of NOx emissions are from point sources, 78.3% from mobile sources and 6% from area sources. VOC emissions are split primarily between area sources (52.5%) and mobile (39%) sources. Population: 330,168 people and 568.1 people per square mile. Traffic: 9,986,801 DVMT. Growth: The population grew 7.2% between 2000 and 2007. The DVMT grew 15% between 2000 and 2007. Meteorology: The winds are climatologically from the south, southwest, and south-southwest. Geography/topography: Most of County is located in the Valley and Ridge Geographic Region. The topography of the Valley and Ridge consists of long linear ridges and parallel lowland valleys that trend in a northeast to southwest direction. The ridges usually have high elevations of 1100 to 1500 feet while adjacent valley floors vary from 700 feet to 1000 feet. A thin north-south strip of the County is located in the Cumberland Plateau Region having a different topography, like in places, the surface has been cut by stream valleys and precipitous gorges that are 200 to 400 feet deep. Level of control of emissions sources: There are 76 point sources in Hamilton County that reported for the Hamilton County local program. Control information not available at this time. Stage 1 vapor recovery is required for gasoline dispensing facilities.

Summary: The TAPCD recommends that Hamilton County be designated as non-attainment for Ozone. The County contribution to the Chattanooga MSA remains to be determined for the entire MSA, which includes counties from Georgia. For the three county TN part of Chattanooga MSA, the county contribution for VOC is 20%, of which the majority (68%) is from mobile sources. It is to be noted that the point source emission contribution of VOC to the MSA emission level is less than 3%. About 88.8% of the population, 81.3% of the DVMT contributes to the three county TN part of the MSA. The population density is 568.1 per square mile. The county is a mixed urban (City of Chattanooga) and mostly sparsely populated mountainous region.

Marion County
Recommendation: Attainment. Jurisdictional boundaries: Marion County was previously classified as attainment for ozone. Air Quality Data: There is no ozone monitor in Marion County. Emissions: 5503 tons per year of NOx and 2239 ton per year of VOC. Almost all of the (98.4%) NOx emissions are from mobile sources and 0.2% from point sources. VOC emissions are split primarily between area sources (44.4%) and mobile sources (55.1%). Population: 28,138 people and 55.8 people per square mile. Traffic: 1,892547 DVMT. Growth: The population grew 1.3% between 2000 and 2007. The DVMT grew 8% between 2000 and 2007. Meteorology: The winds are climatologically from the south, southwest, and south-southwest. Geography/topography: The County is located in the Cumberland Plateau Geographic Region. The Plateau’s topography varies in different parts of the region; like in places, the surface has been cut by stream valleys and precipitous gorges that are 200 to 400 feet deep. In Marion and Hamilton Counties, the elevations range from 2000 to 2100 feet, while relief varies from 100 feet to as much as 400 feet. Level of control of emissions sources: There is one point source in Marion County that was reported for the 2005 NEI. There is no I/M program. Stage 1 vapor recovery is required for gasoline dispensing facilities.
Summary: The TAPCD recommends that Marion County be designated as attainment for Ozone. The County contribution to the Chattanooga MSA remains to be determined for the entire MSA, which includes counties from Georgia. For the three county TN part of Chattanooga MSA, the county contribution for VOC is 9.8%, of which the majority (55.2%) is from mobile sources. It is to be noted that the point source emission contribution of VOC and NOx to the MSA emission level is less than 0.06% 0.2%, respectively. Only 7.5% of the population, 15.4% of the DVMT contributes to the three county TN part of the MSA. The population density is 55.8 per square mile. The county is mostly rural and agrarian and mostly a sparsely populated mountainous region.

Sequatchie County
Recommendation: Attainment Jurisdictional boundaries: Sequatchie County was previously classified as attainment for ozone. Air Quality Data: There is no ozone monitor in Sequatchie County. Emissions: 630 tons per year of NOx and 712 tons per year of VOC. Almost all of NOx (90.5%) emissions are from mobile sources; 0% from point sources. VOC emissions are split primarily between area sources (41.3%) and mobile sources (38%). Population: 13,369 people and 42.7 people per square mile. Traffic: 392,886 DVMT Growth: The population grew 17.6% between 2000 and 2007. The VMT grew 20% between 2000 and 2007. Meteorology: The winds are climatologically from the south, southwest, and south-southwest. Geography/topography: The County is located in the Cumberland Plateau Geographic Region. The Plateau’s topography varies in different parts of the region; like in places, the surface has been cut by stream valleys and precipitous gorges that are 200 to 400 feet deep. The tableland part of the Cumberland Plateau has an average elevation of 1800.

Level of control of emissions sources: There is one point source in Sequatchie County that was reported for the 2005 NEI. There is no I/M program. Stage 1 vapor recovery is not required for all gasoline dispensing facilities.
Summary: The TAPCD recommends that Sequatchie County be designated as attainment for Ozone. The County contribution to the Chattanooga MSA remains to be determined for the entire MSA, which includes counties from Georgia. For the three county TN part of Chattanooga MSA, the county contribution for VOC and NOx are only 3.1% and 2.7%, respectively. It is to be noted that the point source emission contribution of VOC and NOx to the MSA emission level is less than 0.65% and 0.0%, respectively. Only 3.6% of the population and 3.2% of the DVMT contributes to the three county TN part of the MSA. The population density is 17.6 per square mile. The county is rural and a sparsely populated mountainous region.


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