201 Annandale Drive

Cary, NC 27511

box4411-envirodata@yahoo.com

December 12, 2006

Kathleen D\'Agostino

Environmental Engineer

Criteria Pollutant Section

Air Programs Branch (AR-18J)

Environmental Protection Agency

77 West Jackson Boulevard

Chicago, Illinois 60604

Dear Ms. D\'Agostino,

I have a question concerning the December 7, 2006 proposal notice -

Approval and Promulgation of Implementation Plans and

Designation of Areas for Air Quality Planning Purposes;

MI; Redesignation of Grand Rapids, Kalamazoo-Battle Creek,

Lansing-East Lansing, Benzie County, Huron County, and

Mason County 8-Hour Ozone Nonattainment Areas to

Attainment for Ozone

The notice states that you should receive such questions.

\"FOR FURTHER INFORMATION CONTACT: Kathleen D\'Agostino, Environmental

Engineer, Criteria Pollutant Section, Air Programs Branch (AR-18J),

Environmental Protection Agency, Region 5, 77 West Jackson Boulevard,

Chicago, Illinois 60604, (312) 886-1767, dagostino.kathleen@epa.gov.\"

The notice states under \"3. The Improvement in Air Quality Is Due to
Permanent and Enforceable Reductions in Emissions Resulting From
Implementation of the SIP and

Applicable Federal Air Pollution Control Regulations and Other Permanent
and Enforceable Reductions. (Section 107(d)(3)(E)(iii))\":

In making this demonstration, the State has calculated the change

in emissions between 1999 and 2002, one of the years the Grand Rapids,

Kalamazoo-Battle Creek, Lansing-East Lansing, Benzie County, Huron

County, and Mason County areas monitored attainment. The reduction in

emissions and the corresponding improvement in air quality over this

time period can be attributed to a number of regulatory control

measures that Michigan and upwind areas have implemented in recent

years. The Grand Rapids, Kalamazoo-Battle Creek, Lansing-East Lansing,

Benzie County, Huron County, and Mason County areas are all impacted,

in varying degrees, by the transport of ozone and ozone precursors from

upwind areas. Therefore, local controls as well as controls implemented

in upwind counties are relevant to the improvement in air quality in

the Grand Rapids, Kalamazoo-Battle Creek, Lansing-East Lansing, Benzie

County, Huron County, and Mason County areas.

Let\'s look at the air quality from 1997 through 2003

4th Max (daily 8hr avg) in ppb

MONROE 14 MILE RD 28TH AVE

1997 79 82 86

1998 79 87 85

1999 85 94 91

2000 68 73 77

2001 83 85 86

2002 87 88 93

2003 85 93 90

See the attached PDF file showing a line graph of the trend.

The values are going up not down (see 2001-2003).

Days Greater than 84 ppb

MONROE 14 MILE RD 28TH AVE

1997 2 1 6

1998 1 5 5

1999 4 11 8

2000 2 3 2

2001 3 4 5

2002 7 6 10

2003 4 6 5

The values are going up not down (see 2001-2003).

Why would the State choose a time period that we used to designate the
area nonattainment? I would use their data in our designations (during
2004) to show their regulations were not doing an adequate job and
needed to be stronger. In other words, their analysis seems to show the
opposite of what they intend.

I look forward to your reply.

Sincerely,

Barry Gilbert

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