# Maintenance Plan for the

Metro

- East St. Louis Ozone Nonattainment Area

f or the 1997 8

- Hour Ozone National Ambient Air Quality Standard

(Revised)

AQPSTR 1 1

- 0 5

August 18 , 20 1 1

Illinois Environmental Protection Agency

1021 North Grand Avenue East Springfield, Illinois 62794

- 9276i TABLE OF CONTENTS

Page

LIST OF TABLES

. . . . . . . . . iii

LIST OF FIGURES

. . . . . . . . . iv

EXECUTIVE SUMMARY

. . . . . . . . 5

1.0 INTRODUCTION

. . . . . . . . 6

1.1 Regulatory Background

. . . . . . 6

1.2 Status of Air Quality

. . . . . . . 8

2.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS 9

3.0 OZONE MONITORING

. . . . . . . 11

3.1 Monitored Design Values

. . . . . . 11

3.2 Qua lity Assurance

. . . . . . . 13

3.3 Continu ed Monitoring

. . . . . . 13

4.0 EMISSIONS INVENTORY

. . . . . . . 14

4.1 Attainment Year Inventory

– 200 8

. . . . . 14

4.2 Air Quality Improvements and Emissions Controls

. . . 15

4.3 Emissions Projections

. . . . . . . 16

4.4 Demonstration of Ma intenance

. . . . . 16

4.5 Provisions for Future Updates

. . . . . 1 8

5.0 CONTROL MEASURES AND REGULATIONS

. . . 1 9

5.1 Attainment Demonstration Control Measures

. . . 1 9

5. 2 Reasonable Further Progress (RFP)

. . . . 20

5. 3 Reasonably Available Control Technology (RACT)

. . . 20

5. 4 Controls to Remain in Effect

. . . . . . 2 1

5. 5 Provisions for Permitting New or Modified Emissions Sources

. 2 2

5. 6 Transport ation Conformity

. . . . . . 2 2

6.0 CONTINGENCY MEASURES

. . . . . . 2 4

6.1 Contingency Measure s

. . . . . . 2 4

6.2 Commitmen t to Revise Plan

. . . . . . 2 6

6.3 Public Participation

. . . . . . . 2 6

6.4 Legal Authority to Implement and Enforce

. . . . 2 7

7 .0 CONCLUSIONS

. . . . . . . . 2 8ii TABLE OF CONTENTS (Continued)

APPENDIX A Summary of Ambient Air Monitoring Data ( 200 7

- 200 9 )

. . . 2 9

APPENDIX B Transportation Conformity

. . . . . . . . 3 1iii LIST OF TABLES

Page

Table 4.1 200 8 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 14

Table 4. 2 20 02 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 15

Table 4.3 201 5 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 16

Table 4.4 2020 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 1 7

Table 4. 5 202 5 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 1 7

Table 4.6 Comparison of 2008, 2015, 2020. and 202 5 Emissions Estimates

Metro

- East Nonattainment Area

. . . . . 17

Table 5.1 Proposed 2008 and 202 5 Motor Vehicle Emissions Budgets

Metro

- East 8

- Hour Ozone Maintenance Plan

. . . 2 3

Table 6.1 Contingency Plan for the Metro

- East 8

- Hour Ozone

Nonattainment Area

. . . . . . . 2 5iv LIST OF FIGURES Page

Figure 1.1 8

- Hour Ozone Nonattainment Area St. Louis, MO

- IL

. . . 7

Figure 3.1 Ozone Monitors in the St. Louis Metropolitan Area

. . . 11

Figure 3. 2 Comparison of 8

- Hour Ozone Design Values for the

St. Louis Region Between 2001

- 2003 and 200 7

- 200 9

. . 125

EXECUTIVE SUMMARY

This document describes Illinois’ Maintenance Plan for the Illinois portion of the St.

Louis ozone nonattainment area (NAA), hereafter referred to as the Metro

- East NAA . A Maintenance Plan is required before an area can be redesignated from nonattainment to

attainment of a National Ambient Air Quality Standard (NAAQS). This document provides technical information required to support a request to redesignate the Metro

East NAA to attainment of the 1997 8

- hour ozone NAAQS

. This revision incorporates motor vehicle emissions estimates developed using the U.S

. EPA’s MOVES model. The Illinois Environmental Protection Agency ( Illinois EPA) has prep ared this plan in

c o nsultation with the Missouri Departm ent of Natural Resources (MDNR) and the U.S.

EPA. The MDNR is preparing a similar plan for the Missouri portion of the St. Louis

nonattainment area.

Ozone air quality has dramatically improved in th e St. Louis region as a result of implementation of State and Federal control measures since the designation of the St.

Louis area as nonattainment in 2004. T he entire St. Louis nonattainment area has at least three years of complete, quality assured ambi ent air quality monitoring data for 2007

- 2009 that demonstrates compliance with the 1997 8

- hour ozone NAAQS . These air quality improvements are due to permanent and enforceable emissions control measures.

This Maintenance Plan provides for continued atta inment of the 1997 8

- hour ozone air quality standard for the Metro

- East nonattainment area for a period of at least ten years after U.S. EPA has formally redesignated the area to attainment. The Plan also provides assurances that, even if there is a subsequent violation of the air quality standard, measures listed in the Plan will prevent any future occurrences through contingency measures that would be triggered upon such an occurrence. Finally, the Plan includes on

road motor vehicle emissions budg ets for the years 2008 and 202 5 for use in transportation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of the 8

- hour ozone standard during the maintenance period.6

1.0 INTRODU CTION

This document describes Illinois’ 8

- hour ozone M aintenance P lan for the Metro

- East

NAA

. This M aintenance P lan is required before the area can be redesignated from nonattainment to attainment of the National Ambient Air Quality Standard (NAAQS) for

ozone promulgated by the U.S. Environmental Protection Agency (U.S. EPA) in 1997

. Illinois intends to submit such a request to the U.S. EPA in conjunction with this

Maintenance Plan. The Illinois E PA has prepared this plan in co nsulta tion with the

Missouri Department of Natural Resources ( M DNR) and U.S. EPA. The MDNR is preparing a similar plan for the Missouri portion of the St. Louis nonattainment area

. T he

entire S t . Louis nonattainment area has at least three years of complete, quality assured ambient air quality monitoring data for 200 7

- 200 9 , demonstrating attainment with the 0.080 pp m 8

- hour ozone NAAQS promulgated in 1997.

This document provides the technical information needed to support a request to redesignate the St. Louis area to attai nment

. Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for a nonattainment area to be considered for redesignation. Before an area can be reclassified to attainment, U.S. EPA

must make a determination that the area has attained the NAAQS based on at least three complete years of ambient monitoring data. U.S. EPA must have approved a State Implementation Plan (SIP) for the area under Section 110 and Part D of the CAA. The state must demonstrate that the improve ment in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. Finally, the state must submit, and U.S. EPA must approve, a

M aintenance P lan under Section 175(A) of the CAA, including provisions for contingency measures that will be implemented if future violations of the NAAQS are

measured.

This Maintenance Plan provides for the continued attainment of the 8

- hour ozone NAAQS for the Metro

- East NAA for a minimum of ten years after U.S. EPA has formally redesignated the area to attainment. The Plan also provides assurances that even if a subsequent violation of the ozone NAAQS occurs, provisions in the Plan will prevent any future occurrences through contingency measures that would be triggered upon such

occurrence.

This document addresses the M aintenance P lan requirements established by the CAA and U.S. EPA, and includes additional information to support continued compliance with the

8

- hour ozone NAAQS.

1.1 Regulatory Background

The CAA requires areas that fail to meet the NAAQS for ozone to develop SIPs to expeditiously attain and maintain the NAAQS. Historically, exceedances of the ozone NAAQS have been monitored in Madison and St. Clair counties in Illin ois and in the Missouri portion of the NAA

.

The Metro

- East NAA, which includes Madison, Monroe, St. Clair

, and Jersey counties in

Illinois , was originally designated as n onattainment in 2004 pursuant to the 199 77

revisions to the ozone N AAQS. Several coun ties in Missouri were also designated as nonattainment of the 8

- hour ozone NAAQS

. Figure 1.1 depicts the current St. Louis

Missouri

- Illinois NAA.



## Figure 1.18

The following is a list of the counties contained in the St. Louis Missouri

- Illinois 8

- hour

ozone nonattainment area:

Madison County, IL

St. Clair County, IL

Monroe County, IL Jersey County, IL

St. Louis County, MO St. Louis City

, MO
St Charles, MO

Jefferson County, MO

Franklin County, MO

As a result of the nonattainment designation and the ac companying classification as

moderate , these areas were subject to new requirements, including development of a plan demonstrating that the area would meet the federal 8

- hour ozone NAAQS by June 15,

20 10

.

Recognizing the need for a regional solution, the States of Illinois and Missouri have worked cooperatively to jointly develop a nd evaluat e an effective regional attainment strategy to enable the St. Louis region to attain the 8

- hour ozone NAAQS. The attainment strategy recognize s the importance of reducing both locally generated ozone precursor emissions

, volatile organic material ( VOM ) and oxides of nitrogen ( NOx )

, as well as incoming (transported) ozone and ozone precursor emissions. The emission s reductions needed to attain the 8

- hour ozone NAAQ S include both State and Federal measures that have reduced ozone precursor emissions both locally and regionally.

These measures have allowed the St. Louis Missouri

- Illinois NAA to attain the 8

- hour ozone standard by the attainment deadline established b y the U.S. EPA.

1.2 Status of Air Quality

Ozone monitoring data for the most recent three

- year period, 200 7 through 200 9

, demonstrates that air quality has met the 1997 8

- hour ozone NAAQS in the St. Louis

Missouri

- Illinois NAA

. Information regarding the air monitoring network and air quality monitoring data in included in Section 3.0 and Appendix A.9

2.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS

Sections 107 and 110 of the CAA list a number of requirements that must b e met by nonattainment areas prior to consideration for redesignation to attainment. One of those requirements is the development of a M aintenance P lan, which describes a state’s plan for maintaining the NAAQS for a minimum ten

- year period after redesigna tion to attainment. U.S. EPA has published guidance for the preparation of M aintenance P lans and redesignation requests

, contained in a document entitled ―Procedures for Processing Requests to Redesignate Areas to Attainment‖ (September 4, 1992).

Before a redesignation to attainment can be promulgated, U.S. EPA must:

Determine that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show that violations of the NAAQS are no longer occurring. This showing must rely on three consecutive years of data. The ambient air monitoring data must be quality assured in accordance with 40 CFR 58.10, recorded in U.S. EPA’s Air Quality System (A Q S) data base, and made available to the public.

Approve the state’s plan for de monstrating attainment. The attainment plan, which is based on air quality modeling, must contain enforceable control measures and must be submitted as a revision to the state’s SIP after a public hearing.

Determine that the improvement in air quality be tween the year violations occurred and the year that attainment was achieved is based on permanent and

enforceable emissions reductions

.

Approve the state’s M aintenance P lan. The requirements for the M aintenance

P lan are discussed below.

Determine that all other requirements applicable to nonattainment areas have been

met.

A M aintenance P lan provides for the continued attainment of the 8

- hour ozone NAAQS for a nonattainment area for a period of at least ten years after U.S. EPA has formally redesignated the area to attainment. The plan also provides assurances that even if a subsequent violation of the NAAQS occurs, provisions in the plan will prevent any future occurrences through contingency measures t hat would be triggered upon such occurrence. To be approvable, the state is required to have a public comment period and provide the opportunity for a public hearing on the M aintenance P lan prior to adoption.

The M aintenance P lan must contain the followi ng elements:

A comprehensive emissions inventory of the precursors of ozone completed for the ―attainment year‖ ;10 A projection of the emissions inventory forward to a year at least ten years after redesignation and a demonstration that the projected level of emissions is

sufficient to maintain attainment of the ozone NAAQS ;

A commitment that, once redesignated, the state will continue to operate an appropriate monitoring network to verify maintenance of the attainment status ;

A demonstration of legal aut hority to implement and enforce all control measures

contained in the SIP ;

Provisions for future updates of the inventory to enable tracking of emissions levels, including an annual emissions statement from major sources ;

Motor vehicle emissions budgets for transportation conformity for the maintenance period ;

A commitment to submit a revised M aintenance P lan eight years after redesignation ;

A commitment to enact and implement additional contingency control measures expeditiously in the event that futu re violations of the NAAQS occur ;

A list of potential contingency measures that would be implemented in such an

event.

Th is M aintenance P lan has been prepared in accordance with the requirements specified in U.S. EPA’s guidance document and additional guidance received from U.S. EPA staff.

The following sections of this document describe how U.S. EPA’s requirements have

been met.11

3.0 OZONE MONITORING

U.S. EPA’s published guidance document, ―Procedures for Processing Requests to Redesignate Areas to Attainment‖ (September 4, 1992), details specific requirements regarding the collection and use of ambient air monitoring data needed to support a redesigna tion request. Before the Metro

- East NAA can be redesignated, Illinois must

demonstrate that the 8

- hour ozone NAAQS has been attained. Ozone monitoring data must show that violations of the NAAQS are no longer occurring within the

nonattainment area . Thi s showing must rely on three complete, consecutive calendar years of quality assured data. Further, the air monitoring data must be quality assured in accordance with 40 CFR 58.10, recorded in U.S. EPA’s AQS data base, and made available to the public. F inally, Illinois must commit to continue to operate an appropriate monitoring network to verify the maintenance of the attainment status, once the area has been redesignated.

The following subsections describe how each of these requirements has been addre ssed.

3.1 Monitored Design Values

Currently there are 1 1 ozone monitors located in the nonattainment counties in the St.

Louis region; 6 are located in Missouri and 5 are in Illinois

. Missouri and Illinois also operate ozone monitors at locations upwind and downwind of the metropolitan area. Figure 3.1 shows the locations of these monitors.

Figure 3.1 Ozone Monitors in the St. Louis Area12

To determine whether the NAAQS is being exceeded, the 8

- hour ozone design value

must be calculated. The current U.S. EPA method for calculating the ozone design value

is to average each monitor’s 4 th highest daily maximum 8

- hour value for each year over the 3

- year period and compare the calcula ted design values to the 0.080 pp m (or 85 ppb) level of the NAAQS

. The calculated 8

- hour ozone design values for the monitors in the

St. Louis Missouri

- Illinoi s NAA for 200 7

- 200 9 are included as Appendix A of this

report. Figure 3. 2 compares the design values for the 2001

- 2003 period for monitoring

stations in the St. Louis region to the corresponding design values from 200 7

- 200 9 . The data demonstrate that ozone air quality has improved dramatically throughout the St.

Louis region and that the 1997 8

- ho ur ozone NAAQS has been attained for the 200 7

- 200 9 period at all locations

.

Figure 3. 2 Comparison of 8

- Hour Ozone Design Values (ppb) for the St. Louis Region

Between 2001

- 2003 and 200 7

- 200 9

2001

- 2003 200 7

- 200 913

3.2 Quality Assurance

Illinois EPA has quality assured all monitoring data shown in Appendix A for all sites

located in Illinois in accordance with 40 CFR 58.10 and the Illinois EPA ’s Quality
Assurance Plan, which describes Illinois EPA ’s standard operating procedures for operating the ambient monitoring network and validating the data. The Missouri DNR

has a similar quality assurance plan. Illinois EPA has recorde d the monitoring data in the

U.S. EPA’s A QS database , which is available to the public

.

3. 3 Continued Monitoring

Illinois commits to continue monitoring ozone levels according to a U.S. EPA approved monitoring plan, as required to ensure maintenance of t he ozone NAAQS. Should changes in the location of an ozone monitor become necessary, Illinois EPA will work with U.S. EPA to ensure the adequacy of the monitoring network. Illinois EPA will continue to quality assure the monitoring data to meet the requi rements of 40 CFR 58.

Illinois EPA will continue to enter all data into A QS on a timely basis in accordance with federal guidelines.14

4.0 EMISSIONS INVENTORY

A redesignation request must contain a demonstration that the improvement in air quality

betwe en the year that violations occurred and the year that attainment was achieved is based on permanent and enforceable emissions reductions . As described previously in Section 3.0, a three

- year monitoring period is used to evaluate whether attainment has

be en achieved. In this Section, the ―attainment year‖ refers to the mid

- point year ( 200 8 )

of the three

- year period ( 200 7

- 200 9 ) used to demonstrate attainment. The request should also include a projection of the emissions inventory to a year at least 10 years following redesignation, a demonstration that the projected level of emissions is sufficient to maintain the ozone NAAQS, and a commitment to provide future updates of the inventory to enable tracking of emissions lev els during the 10

- year maintenance period.

4.1 Attainment Year Inventory

- 200 8

Illinois EPA has prepared a comprehensive emissions inventory for the Metro

- East ozone nonattainment area, including point, area, and on

- road and off

- road mobile sources for precursors of ozone ( VOM and NOx) for the attainment year, 200 8 . This inventory is

based on actual or projected activity levels. Point source information was compiled from

200 8 annual emissions reports submitted to the Illinois EPA by emissions sources a nd the

U.S. EPA’s Clean Air Markets Division database for electric utilities . Area source

emissions were calculated using the most recently available methodologies and emissions

factors from U

. S

. EPA along with activity data (typically population, employm ent, fuel use, etc.) specific to 2008. On

- road mobile source emissions were calculated using U.S.

EPA’s MO VES emissions model with 2008 vehicle miles traveled (VMT) data provided by the Illinois Department of Transportation (IDOT)

. Off

- road mobile source emissions

were calculated for summer 2008 using U.S. EPA’s NONROAD emissions model. Biogenic emissions are not included in these summaries.

Table 4.1 summarizes the 200 8 e missions estimates for the Metro

- East ozone nonattainment area. This summary has been revised to incorporate emissions estimates

for on

- road mobile sources using U.S. EPA’s MOVES model.

Table 4.1

200 8 Metro

- East Ozone N onattainment Area

VOM and NOx Emissions (Emissions stated in tons per o zone season weekday)
Source Category VOM NOx

Point Sources 11.92 39.86

Area Sources 23.21 1.50

On

- Road Mobile Sources 1 7.27 52.57

Off

- Road Mobile Sources 12.66 39.25

Total 6 5.06 1 33

. 1815

4.2 Air Quality Improvement s and Emissions Controls

The Metro

- East area was designated as nonattainment of the 1997 8

- hour ozone NAAQS in 2004, based on ozone air quality monitoring data collected between 2001 and 2003

. Since that time, permanent and enforceable reductions of ozone precursor emissions have contributed to improvements in ozone air quality and to the attainment of the 8

- hour ozone NAAQS. Some of these emissions reductions were due to the application of tighter federal emissions standards on motor vehicles and fuels, and some due to the requirements of the federal NOx SIP Call. Section 5.0 of this report describes these reductions in more detail, along with an explanation of their regulatory status. In this subsection, the 2008 attainment year emissions levels are compared to the base y ear 2002

emissions levels

.

U.S. EPA’s 8

- hour O zone Implementation Rule required that states with ozone nonattainment areas prepare and submit a 2002 base year inventory of anthropogenic sources of ozone precursor emissions. This base year inventory inclu ded emissions from point, area, on

- road mobile and off

- road mobile emissions. Illinois EPA prepared and submitted this inventory i n June 2006. Table 4.2 summarizes 2002 emissions by major source category and by pollutant for the Metro

- East NAA

. This sum mary has been revised to incorporate emissions estimates for on

- road mobile sources using U.S. EPA’s

MOVES model.

Table 4.2

2002 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)
Source Category VOM NOx

Point Sources 17.41 53.24

Area Sources 29.86 1.40

On

- Road Mobile Sources 2 5.90 76.82

Off

- Road Mobile Sources 12.04 36.79

Total 8 5.21 1 6 8. 25

Comparing the 2002 inventory to that for 200 8 indicates that total VOM emissions in the

Metro

- East area decreased by 20.15 tons per day (tpd), due largely to reductions from point and on

- road mobile sources. NOx emissions in the Metro

- East area decreased significantly, 35.07 tpd, during the same time period. Again, these reductions were primarily from point and on

- road mobile sources. These sizeable emissions reductions in ozone precursor emissions

, and corresponding reductions in the Missouri portion of the
NAA, plus reductions in upwind areas in Illinois and other nearby states, resulted in a substantial improvement in ozone air quality in the St. Louis area, ultimately resulting in

attainment of the 1997 8

- hour ozone NAAQS.16

4.3 Emissions Projections

A M aintenance P lan must contain a demonstration that the level of emissions projected

for the ten

- year period following redesignation are sufficient to maintain the NAAQS. Accordingly, Illinois EPA has projected VOM and NOx emissions for the Metro

- East

NAA for 20 2 5

. Illinois EPA has also projected emissions to 20 1 5 and 2020 , to represent

two midpoint years during the maintenance period. Emissions for these t hree projection years are compared to emissions levels in 200 8 to determine if emissions are sufficient to

main tain the NAAQS during this period.

Metro

- East area point and area source emissions for 20 1 5, 2020, and 20 2 5 were estimated using the 200 8 base year inventory and growth factors appropriate for each

source category

. Off

- road emissions projections were dev eloped using the growth factors

contained in U.S. EPA’s NONROAD model. On

- road motor vehicle emissions were estimated using U.S. EPA ’s MO VES motor vehicle emissions model. The figures assume the continued use of reformulated gasoline

, the continued phase

- in of the Tier 2 motor vehicle emissions standards, and operation of an enhanced vehicle inspection and

maintenance (I/M) program. Total vehicle miles of travel (VMT) for 20 1 5, 2020, and

20 2 5 w ere assume d to increase at a rate of 1. 5 percent per year from 200 8

.

Tables 4.3

, 4.4 , and 4.5 include the VOM and NOx emissions estimates for the years

20 1 5, 20 20

, and 2025

, respectively, for the Metro

- East nonattainment area.

Table 4.3

201 5 Metro

- East Ozone Nonattainment Area

VOM and NOx Emi ssions (Emissions stated in tons per ozone season weekday)
Source Category VOM NOx

Point Sources 13. 70 31.86

Area Sources 23. 76 1.5 5

On

- Road Mobile Sources 9. 11 2 7.85

Off

- Road Mobile Sources 9.27 36.41

Total 55.84 97.67

4.4 Demonstration of Maintenance

Table 4. 6 demonstrates that the level of emissions projected for the ten

- year period following redesignation is sufficient to maintain the ozone NAAQS. As shown in the table, both VOM and NOx emissions within the nonattainment area are expect ed to decrease significantly between 2008 and 202 5 . P rojected VOM and NOx emissions for

the mid

- point year s , 201 5 and 2020 , are also less than the emissions levels in 2008.17

Based on these emissions trends it is expected that air quality will continue to meet the

1997 8

- hour ozone NAAQS throughout the maintenance period.

T able 4.4

2020 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)
Source Category VOM NOx

Point Sources 14.73 30.71

Area Sources 25.04 1.56

On

- Road Mobile Sources 4.99 16.32

Off

- Road Mobile Sources 7.73 33.56

Total 5 2.49 82.15

Table 4.5

202 5 Metro

- East Ozone Nonattainment Area

VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)
Source Category VOM NOx

Point Sources 15.78 32.12

Area Sources 26.32 1.58

On

- Road Mobile Sources 5.68 15.22

Off

- Road Mobile Sources 7.31 32.33

Total 55.09 81.25

T able 4. 6 Comparison of 2008, 201 5 , 2020, and 202 5 Emissions Estimates

Metro

- East Nonattainment Area (Emissions stated in tons per ozone season weekday)

2008 201 5 Difference

(2008

– 201 5 ) 202 0 Difference

(2008

– 20 20 ) 202 5 Difference

(2008

– 202 5 )

VOM 65.06 55.84 9.22 5 2.49 12.57 55.09 9.97

NOx 133.18 97.67 35.51 8 2.1 5 51.03 81.25 51.93

In addition to the overall emissions reductions projected to occur within the nonattainment area, significant reductions of statewide NOx emissions resulting from18

implementation of Illinois’ multi

- pollutant standards affecting electric utilities by 2012,

w ill also help to ensure continued attainment of the 8

- hour ozone NAAQS.

4.5 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Illinois commits to submit to U.S. EPA, eight years after redesignation, a revised version of this Maintenance Plan. The revision will contain Illinois’ plan for maintaining the 8

- hour ozone NAAQS for ten years b eyond

the first 10

- year period after redesignation

.19

5.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures implemented in the

Metro

- East nonattainment area, including the measures that were part of Illino is’
Attainment Demonstration, R easonable Further Progress (R F P) demonstration , CAA requirements, and other state and federal measures. The control measures required in past ozone SIP revisions have been fully implemented, and other, more recent control

pr ograms will continue to provide emissions reductions in future years. Illinois EPA

commits to keep these measures in effect after redesignation, or to provide equivalent emissions levels using alternate measures. Illinois’ SIP contains acceptable provisi ons to provide for preconstruction review of new emissions sources. After redesignation to
attainment , Prevention of Significant Deterioration (PSD) requirements will apply to the construction of new major sources and to significant modifications of exist ing sources. Illinois has accepted delegation from U.S. EPA of this program. Illinois further commits to continue to require that all future transportation plans in the St. Louis area conform

with the SIP.

5.1 Attainment Demonstration Control Measures

Illinois’ attainment demonstration for the Metro

- East nonattainment area identifie d

control measures that ha d been promulgated at either the state or federal level that are

sufficient to allow the region to meet the 1997 8

- hour ozone NAAQS by the required

attainment date. The attainment demonstration , which was submitted to U.S. EPA after a public hearing and public comment period, is described in the Illinois EPA’s document:

― 8

- Hour Ozone Attainment Demonstration for the Metro

- East Nonattainment Area‖ (R eport Number AQPSTR 07

- 02

, June 15, 2007 ). The primary emissions reduction measures for demonstrating attainment of the ozone standard are as follows:

NOx SIP Call and Clean Air Interstate Rule (CAIR)

New Source Performance Standards (NSPS) and Nation al Emissions Standards for Hazardous Air Pollutants (NESHAPS)/Maximum Achievable Control Technology (MACT) Standards

VO M Solvent Categories: Aerosol Coatings, Architectural and Industrial Maintenance (AIM) Coatings, Consumer Solvents

Vehicle I / M Program

Reformulated Gasoline

Tier 2 Motor Vehicle Emissions Standards and Gasol ine Sulfur Control Requirements20 On

- Highway Heavy

- Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements

Federal Emissions Standards for O ff

- Road Equipment (e.g., Nonroad Diesel Engine Rule, Evaporative Large Spark Ignition and Recreational Vehicle Standards) incorporated into NONROAD Model

Tier 4 Nonroad Diesel Engine Standards and Diesel Fuel Sulfur Content

Restrictions

Marine Compress ion

- Ignition Engine Standards and Locomotive Engine

Standards

Consent Decrees

--- Dynegy and ConocoPhillips

5.2 Reasonable Further Progress (RFP)

Since the Metro

- East area is classified as a moderate nonattainment area for the 8

- hour ozone standard, a 15 percent net reduction in ozone precursor emissions from 2002 levels

was required by 2008 in order to meet the RFP requirement. In the Metro

- East attainment demonstration, t he Illinois EPA relied on NOx substitution to meet the 15 percent RFP reduction requirement.

The control measures identified in the RFP document , including those listed above, w ere projected to result in a 6.48 percent reduction in VOM emissions and a 10.01 percent

reduction in NOx emissions from 2002 levels by the year 2008 , a to tal reduction of 16.49

percent

. All of the identified emissions control measures were implemented by 2008.

These emissions reductions achieve the 15 percent RFP target for the Metro

- East NAA

.

5.3 Reasonably Available Control Technology (RACT)

Pursuant to Sections 172, 182(b) and (f) of the CAA, RACT is required for all existing major sources of the applicable criteria pollutant and its precursors located in NAAs.

U.S. EPA defines RACT as the lowest emissions limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological feasibility and economic reasonableness (70 FR 71612; November 29, 2005). The major source threshold for moderate NAAs is defined as 100 tons per year ( tpy ) . A source generally consists of several units that emit pollutants. The

sum of emissions from all units at the source determines if a unit is major and thus subject to RACT requirements.

RACT is not a new requirement under the CAA. Illinois previously addressed RACT requirements in the Metro

- East area in developing attainment plans for the 1

- hour ozone standard. Illinois has previously ado pted RACT requirements for VOM emissions in the NAA. ( See 35 Ill. Adm. Code Part 219) T he Illinois EPA has evaluated the previously21

adopted regulations to determine if the RACT requirement is still being met for 8

- hour

ozone. The RACT requirement for N Ox was waived for the 1997 8

- hour ozone standard, based on U.S. EPA’s finding that additional NOx reductions were not needed for the area

to attain the standard.

Sections 172, 182(b)(2)

, and 182(f) of the C AA require implement ation of RACT for

sources th at are subject to Control Techniques Guidelines (CTGs) that are promulgated by U

. S

. EPA. The U.S. EPA has issued CTGs defining RACT for those categories of sources that emit the greatest amounts of VOM emissions

. Illinois EPA has proposed regulations to implement the revised CTG s issued by the U.S. EPA in 2006 , 2007, and

2008

. The 2006 CTG’s addressed industrial cleaning solvents, offset lithographic printing and letterpress printing, flexible package printing, and flat wood paneling coatings. The 2007 CTG’s address paper, film, and foil coatings, large appliance coatings, and metal furniture coatings. The 2008 CTG’s address miscellaneous metal and plastic parts coatings, fiberglass boat manufacturing materials, miscellaneous industrial

adhesiv es, and automobile and light

- duty truck assembly coatings

. Other than the above

mentioned CTGs, Illinois has adopted applicable rules addressing all CTGs published by U.S. EPA for which there are existing sources in the Metro

- East NAA.

Non

- CTG sources a re defined as major VOM sources which are not subject to CTGs, but for which RACT is required. All major sources of ozone precursors located in the ozone NAA that are not subject to individual RACT rules are subject to a generic RACT rule. These rules ap ply to non

- CTG sources that have the potential to emit 100 tons or more per year of VOM. Thus, Illinois has met the obligation to implement RACT on non

- CTG

VOM sources in the NAA.

It should be noted that other regulatory requirements also affect VOM emi ssions sources within the Metro

- East ozone NAA. These include MACT, federal NSPS, and NESHAP s

. T hese programs satisfy the RACT requirements for specific source categories because these rules are more stringent than RACT. It is concluded from this review that Illinois ’ existing VOM RACT rules f ulfill U.S. EPA’s RACT requirements for VOM sources in

the Metro

- East NAA.

As mentioned previously, the RACT requirement for NOx was waived under the 1997 8

- hour ozone NAAQS. Although t he Illinois EPA has adopted NOx RACT rules

, the attainment demonstration for the St. Louis NAA for the 1997 ozone NAAQS did not rely

on emissions reductions from the Illinois EPA’s NOx RACT rules. The reductions resulting from this program, when implemented, will help the ar ea to maintain the NAAQS in future years.

5.4 Controls to Remain in Effect

Illinois will maintain all of the control measures listed in this Section to ensure

maintenance of the 8

- hour ozone NAAQS. Any revisions to the control measures included as part of the Maintenance Plan will be submitted as a SIP revision to U.S. EPA22

for approval, and will be accompanied by a showing that such changes will not interfere with maintenance of the NAAQS.

Illinois EPA has the necessary resources to enforce any violati ons of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the

emissions of ozone precursors in the M etro

- E ast nonattainment area.

5. 5 Provisions for Permitting New or Modified Emissions Sources

Illinois has longstanding and fully implemented programs for the review of new major sources and significant modifications of existing sources. The PSD program

, which

include s requirements for Best Available Control Technology (BACT) on major new

sources or significant modifications of existing sources, will be applicable in the Metro

East area once the area has been redesignated to attainment . Illinois has been delegated full authority to implement the PSD program by U.S. EPA.

5. 6 Transportation Conformity

The purpose of this section is to describe and establish the Metro

- East nonattainment area motor vehicle emissions budgets associated with the 8

- hour ozone Maintenance Plan S IP.

A verage summer weekday motor vehicle emissions budgets are being proposed for the attainment year 2008 and for the final year of the Maintenance Plan, 20 2 5

, for the precursor pollutants VOM and NOx

. Although motor vehicle emissions were estimated for the milestone years of 2015 and 2020, only the 2008 and 2025 estimat es are being proposed as budgets.

A motor vehicle emissions budget is that portion of the total allowable emissions allocated to highway and transit vehicle use that are defined in the SIP for a certain year. The rules governing transportation conformity require certain transportation activities to be consistent with motor vehicle emissions budgets contained in control strategy implementation plans (40 CFR § 93.118). Section 93.101 of the rule defines a ―control strategy [State] implementation plan revis ion‖ as a ―plan which contains specific strategies for controlling the emissions and reducing ambient levels of pollutants in order to satisfy CAA requirements of reasonable further progress and attainment.‖ In order to demonstrate conformity to the motor vehicle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program must be less than or equal to the budget level (40 CFR § 93.118(a)).

The motor vehicle emissions budgets established and describe d herein were developed consistent with the methodology and control strategy assumptions used in the 8

- hour

ozone a ttainment d emonstration. The budgets reflect an emissions level determined using actual motor vehicle VMT for 2008 and VMT growth at an annu al rate of 1.5% from year 2008 levels to 2025. The effects of motor vehicle control measures are incorporated into the emissions factors produced by the U

. S

. EPA’s MO VES model.

These control measures include the implementation of national motor vehicle e missions standards, the operation of a vehicle I/M program, and the required use of reformulated23

gasoline and low sulfur gasoline and diesel fuel.

The motor vehicle emissions budgets, which reflect the VMT and control program assumptions and methodology described here

, are listed in Table 5.1.

Table 5 .1 Proposed 2008 and 202 5 Motor Vehicle Emissions Budgets

M etro

- East 8

- Hour Ozone Maintenance Plan (tons per ozone season weekday)

Year VOM NOx

2008 1 7.27 52.57

202 5 5.68 1 5.22

Additional detail s on the derivation of the motor vehicle emissions budgets, including

discussion of the MO VES model inputs and assumptions are included in Appendix B of this report

.24

6.0 CONTINGENCY MEASURES

6.1 Contingency Measures

Section 175(A) of the CAA specifies the requirements for M aintenance P lans, including provisions for contingency measures that will be implemented if violations of the 8

- hour ozone NAAQS are measured after redesignation to attainment. A list of potential contingency measures that would be implemented in such an event should also be included in the Maintenance Plan. Finally, the plan should provide a commitment to

submit a re vised M aintenance P lan eight years after redesignation to ensure continued

maintenance for the next ten

- year maintenance period.

Contingency measures are intended to provide further emissions reductions in the event

that violations of the 8

- hour ozone NAA QS occur after redesignation to attainment. While these measures do not need to be fully adopted by the Illinois Pollution Control Board ( I PCB ) prior to the occurrence of NAAQS violations, the contingency plan should ensure that the contingency measures a re adopted expeditiously once they are triggered. The Maintenance Plan must identify the triggers that determine when contingency measures will be adopted

, and the measures that the state will consider.

Illinois EPA ’s contingency plan for the Metro

- East NAA is described in Table 6.1

. Consistent with this plan, Illinois agrees to adopt and implement, as expeditiously as practicable, the necessary corrective actions in the event that violations of the 8

- hour ozone NAAQS occur within the Metro

- East maintena nce area after redesignation to

attainment. Further, Illinois commit s to continue to implement the control measures

identified in the attainment demonstration and R FP demonstration . As described in Section 5.0 of this report, Illinois has adopted and is continuing to implement a range of control measures that will greatly reduce precursor emissions, both locally and statewide. The contingency plan anticipates that these emissions reductions will be sufficient to mitigate exceedances or violations of the NAAQS that may occur in the coming years without further regulatory action.

The contingency plan provides for different levels of corrective responses should ambient

8

- hour ozone levels exceed the NAAQS in any year , if emissions in the NAA increase signi ficantly above current attainment levels, or if the NAAQS is violated. A Level I response would occur in the event that: 1) the fourth highest 8

- hour ozone concentration at any monitoring site in the St. Louis NAA (including sites in Missouri and Illinois) exceeds 84 ppb in any year, or 2) if VOM or NOx emissions increase more than 5% above the levels contained in the attainment year (200 8 ) emissions inventory. It should be noted that U.S. EPA does not require a s tate to implement contingency measures when

occasional exceedances are recorded. The Illinois EPA ’s voluntary commitment to initiate a Level I response is intended to prevent future violations of the NAAQS from ever occurring.

Illinois commits to compili ng VOM and NOx emissions inventories for the Metro

- East

area every three years for the duration of the Maintenance Plan to facilitate the25 T able 6.1 Contingency Plan for the Metro

- East 8

- Hour Ozone Nonattainment Area

Contingency Measure Trigger Action to be Taken List of Potential Contingency Measures

Level I Trigger

Fourth highest

m onitored 8

- hour

average ozone concentration exceeding 84 ppb in

any year at any monitoring station in

the St. Louis MO

- IL

maintenance area.

The Metro

- East
maintenance area’s

NOx or VOM

emissions inventories

increase more than

5% above the levels

included in the 2008

emissions inventories. IL will evaluate air quality , or determine if adverse emissions trends are likely to continue. If so, IL will

determi ne what and where controls may be required, as well as level of emissions reductions needed, to avoid a violation of the NAAQS. The study shall be completed within 9 months. If necessary, control measures shall be adopted within 18 months of

determinatio n and implemented as expeditiously as practicable, taking into

consideration the ease of implementation and the technical and economic feasibility of the selected

measures. Point Source Measures

IL Multi

- Pollutant Program for electric generating units

NOx RACT

C le an Air Transport R ule , after promulgation by USEPA

Best Available Retrofit Technology (BART) Broader geographic applicability of existing measures

Mobile Source Measures

Tier 2 Vehicle Standards and Low

Sulfur Fuel Heavy Duty Diesel Standards and

Low Sulfur Diesel Fuel High

- enhanced I/M (OBDII)

Federal railroad/locomotive

standards

Federal commercial marine vessel engine standards

Portable fuel containers

Area Source Measures

Architectural/Industrial Maintenance (AIM) Coatings

Commercial and Consumer

Products Aerosol coatings Level II Trigger

A violation of the NAAQS at any monitoring station in

the St. Louis MO

- IL

maintenance area. IL will conduct a thorough analysis to determine appropriate measures to

address the cause of the violation. Analysis shall be completed within 6

months. Selected measures shall be implemented within 18 months of a

violation.

emissions trends analysis included in the contingency plan under Level I. The Illinois

EPA will coordinate with the Missouri DNR to evaluate the causes of high ozone levels or the emissions trends and to determine appropriate control measures needed to assure

continued attainment of 8

- hour ozone NAAQS. Under Level I, measures that could be implemented in a short time would be sele cted so as to be in place quickly after the Illinois EPA is aware that corrective measures have been triggered. Control measures selected under Level I will be adopted in most cases within 18 months after a determination is made, and implemented, generall y, within 24 months of adoption by the

IPCB.

A Level II response would be implemented in the event that a violation of the 8

- hour ozone NAAQS were to be measured at a monitoring site within the St. Louis

maintenance area (including sites in Missouri and Illinois)

. In order to select appropriate26

corrective measures, the Illinois EPA will work with the Missouri DNR to conduct a comprehensive study to determine the causes of the violation and the control measures necessary to mitigate the problem. The anal ysis will examine the following factors:

the number, location, and severity of the ambient ozone exceedances ; the weather patterns contributing to the elevated ozone levels; potential contributing emissions sources; the geographic applicability of possibl e contingency measures; emissions trends, including timeliness of implementation of scheduled control

measures; current and recently identified control technologies; and air quality contributions from outside the maintenance area.

Contingency measures wil l be selected from those listed in Table 6.1 or from any other measure deemed appropriate and effective at the time the selection is made. I t is expected that implementation of only a few of these measures would be necessary . The

selection between measur es will be based upon cost

- effectiveness, emissions reduction potential, ease and timing of implementation, and other appropriate factors. Implementation of necessary controls in response to a Level II trigger will take place as expeditiously as possible, but in no event later than 18 months after the Illinois EPA makes a determination, based on quality

- assured ambient data, that a violation of the NAAQS has occurred.

Adoption of additional control measures is subject to necessary administrative and legal

processes. The I llinois EPA will solicit input from all interested and affected persons in the area prior to selecting appropriate control measures. No contingency measure will be implemented without providing the opportunity for full public participati on. This process will include publication of notices, an opportunity for public hearing, and other measures required by Illinois law.

6.2 Commitment to Revise Plan

As noted in Section 4.5 above, the Illinois EPA commits to review its Maintenance Plan eight years after redesignation, as required by Section 175(A) of the CAA

. The

Maintenance Plan revision is intended to ensure continued attainment of the 8

- hour ozone NAAQS for an additional ten

- year period.

6.3 Public Participation

In accordance with Section 110(a)(2) of the CAA, the Illinois EPA is required to have a public comment period and provide for the opportunity of a public hearing prior to adoption of this Maintenance Plan and submittal to U.S. EPA. Public participation in the SIP process wa s provided for as follows:

Notice of availability of the Metro

- East 8

- Hour Ozone Maintenance Plan document and the time and date of the public hearing w as published in the Illinois27 Edition of the St. Louis Post Dispatch on July 8, 2011.

If requested, t he public hearing to receive comments on the Metro

- East

Maintenance Plan w as scheduled for August 18, 2011, at 1:00 p.m. in the Sangamo Room at the Illinois EPA’s Headquarters at 1021 N. Grand Ave. East, Springfield, Illinois.

A 30

- day public comment period was also available after the public hearing to

receive comments on the Maintenance Plan. A summary of the comments

received and Illinois EPA’s responses thereto w ill be included as part of the

submittal to U.S. EPA.

6.4 Legal Authority to Implement and Enforce

The Maintenance Plan must contain a demonstration that the State of Illinois has the necessary legal authority to implement and enforce the measures relied upon to attain and maintain the NAAQS. Illinois has the l egal authority to implement and enforce the requirements of this SIP submittal pursuant to the Illinois Environmental Protection Act.28

7 .0 CONCLUSIONS

The Metro

- East nonattainment area has attained the 1997 0.080 pp m 8

- hour ozone NAAQS and has complied w ith the applicable provisions of the CAA required of

moderate ozone NAAs . Illinois has submitted an attainment demonstration that was based on air quality modeling and contains enforceable control measures. The attainment

demonstration included an RFP Pl an which demonstrated the required 15% reduction in ozone precursor emissions. Illinois has performed an analysis that demonstrates that the

Metro

- East NAA has attained the 1997 8

- hour ozone NAAQS and believes the air quality improvements are due to permanent and enforceable control measures. Supporting

documentation is contained herein.

The Illinois EPA has prepared a Maintenance Plan that meets the requirement of the

Clean Air Act. This Maintenance Plan provides for the continued attainment of the 1997

8

- hour ozone NAAQS for a period of ten years after U.S. EPA has formally redesignated the area to attainment. This Maintenance Plan provides adequate contingency measures for potentia l, additional emissions reductions in the event that future violations of the

1997 8

- hour ozone NAAQS are observed in the area.

The Illinois EPA has prepared a comprehensive emissions inventory of the precursors of ozone completed for the ―attainment‖ y ear 200 8 , and has prepared projection s of the

emissions inventory to 201 5, 2020, and 202 5

. These emissions projections indicate that

emissions levels in the Metro

- East nonattainment area will continue to remain much

lower than emissions from the attainmen t year 2008 levels , thereby maintaining the ozone NAAQS in future years. The Illinois EPA commits to continue to operate an appropriate air quality monitoring network to verify the maintenance of the attainment status once the area has been redesignated. T he Illinois EPA has the legal authority to implement and enforce all control measures.

Finally, the Metro

- East Maintenance Plan includes year 2008 and 202 5 on

- road motor vehicle emissions budgets for use in transportation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of

the 8

- hour ozone standard during the ten

- year maintenance perio d. Th e Metro

- East Maintenance Plan has been prepared in accordance with the requirements specified in U.S. EPA’s guidance document, and additional guidance received from U.S. EPA staff.29 

## APPENDIX A

Summary of Ambient Air Monitoring Data

( 200 7

- 200 9 )30 

### Table A.1

200 7

- 200 9 8

- hour Ozone Design Values

for Monitors in the St. Louis Region

State of Missouri
County AQS Code Site Name Design Value 4th High 200 7 4th High 200 8 4th High 200 9
St. Charles 291831004 Orchard Farm 7 5 83 72 72
St. Charles 291831002 West Alton 7 8 8 9 76 71 St. Louis City 295100085 Blair St 7 5 8 7 73 6 5
St. Louis 291890014 Mary land Hts 7 6 94 69 67
St. Louis 291890005 Pacific 7 1 85 64 6 4
Jefferson 290990019 Arnold/Arnold W 75 87 70 70

State of Illinois
County AQS Code Site Name Design Value 4th High 200 7 4th High 200 8 4th High 200 9 Jersey 170 831001 Jerseyville 70 75 69 68

Madison 17 1190008 Alton 72 81 68 67
Madison 17 1193007 Wood River 73 86 67 66
Madison 17 1191009 Maryville 77 87 70 74
St. Clair 17 1630010 E. St. Louis 70 77 64 6931 

## APPENDIX B

Transportation Conformity32

TRANSPORTATION CONFORMITY

This section describes the development of the Metro

- East nonattainment area motor vehicle emissions budgets associated with the revised Maintenance Plan for the 1997 8

- hour NAAQS. Average summer weekday motor vehicle emissions budget s are being proposed for the attainment year 2008 and for the Maintenance Plan year 202 5 for the

ozone precursor pollutants volatile organic material ( VOM ) and oxides of nitrogen ( NOx ) . These budgets were developed consistent with the motor vehicle activity assumptions and emissions control strategies incorporated into the Metro

- East 8

- hour

ozone A ttainment D emonstration analysis. The enclosed budgets were developed using

emission fac tors generated by the United States Environmental Protection Agency ’s (U.S.EPA) MOVES model. These emission factors were then multiplied by summer weekday vehicle miles of travel (VMT) converted by the model from actual and projected annual VMT levels.

B ackground

Section 176(c)(4) of the Clean Air Act Amendments of 1990 requires that transportation plans, programs, and projects which are funded or approved under Title 23 of the United States Code (USC) must be determined to conform with State or Federal a ir implementation plans. A motor vehicle emissions budget is that portion of the total allowable emissions allocated to highway and transit vehicle use that are defined in the SIP for a certain year. Section 93.101 of the rule defines a ―control strategy [State] implementation plan revision‖ as a ―plan which contains specific strategies for controlling the emissions and reducing ambient levels of pollutants in order to satisfy Clean Air Act (CAA) requirements of reasonable further progress and attainment. ‖ In order to demonstrate conformity to the motor vehicle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program (TIP) must be less than or equal to the budget level (40 CFR § 93.118(a)).

Tran sportation conformity will be determined based on these proposed on

- road motor vehicle emissions budgets after the U.S. Environmental Protection Agency (U.S. EPA) determines that the budgets meet the adequacy criteria of the transportation conformity

rule under §93.118(e). The motor vehicle emissions budgets in this submittal are adequate as each of the six criteria under §93.118(e) is satisfied. These six criteria

include:

1. The submitted control strategy implementation plan revision or M aintenance P lan

w as endorsed by the Governor (or his or her designee) and was subject to a State public hearing.

2. Before the control strategy implementation plan or M aintenance P lan was submitted to U.S. EPA, consultation among federal, State, and local agencies occurred; full implementation plan documentation was provided to U.S. EPA; and U.S. EPA’s stated concerns, if any, were addressed;

3. The motor vehicle emissions budgets(s) is clearly identified and precisely quantified;33

4. The motor vehicle emissions budget(s), when considered together with all other

emissions sources, is consistent with all applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given implementation plan submission);

5. The motor vehicle emissions budget(s) is consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan revision or M aintenance P lan, and

6. Revisions to previously submitted cont rol strategy implementation plans explain and document any changes to previously submitted budgets and control measures, impacts on point and area source emissions; any changes to established safety margins; and reasons for the changes (including the basis for any changes related to

emissions factors or estimates of vehicle miles traveled).

Regarding adequacy criterion #1, this State Implementation Plan and the associated motor vehicle emissions budgets have been developed by the Illinois Environmental Protection Agency (Illinois EPA), the designated air quality agency for the State of

Illino is. The public hearing to accept public comment on the original proposed

Maintenance Plan and budgets w as held on April 8, 2010 in Collinsville, Illinois. Notification of this hearing w as published in the Belleville News Democrat, East St. Louis Monitor, and Alton Telegraph on March 5, 2010 and in the Granite City Press Record Journal on March 7, 2010. Comments on the proposed Maintenance Plan and associated motor vehicle emissions budgets w ere accepted for 30 days after the public hearing. A ―Responsiv eness Summary‖ which addresse d the written comments received

w as prepared and included in the submission to the U.S.EPA

.

Regarding this revision to the Metro

- East St. Louis 8

- Hour Ozone Maintenance Plan and

MOVES

- based motor vehicle emissions budgets, n otice of a comment 30

- day comment period was posted on the Illinois EPA’s website and printed in the Illinois edition of the St. Louis Post Dispatch on July 8, 2011. A public hearing to discuss the revised

Maintenance Plan and associated motor vehicle emi ssions budgets was to be held on August 18, 2011, if it was requested. Comments were required to be postmarked by August 8, 2011, unless a public hearing was requested. No request for a public hearing

was received. All comments were addressed in the att ached Responsiveness Summary. None of the comments affected the proposed motor vehicle emissions budgets.

In compliance with criterion #2 above, an Inter

- Agency Conformity Consultation Team meeting was held at the offices of the East

- West Gateway Council of Governments on January 26, 2010. The Consultation Team includes representatives from the Federal Highway Administration, the U.S. EPA, the East

- West Gateway Council of Governments (EWGCOG) , the Missouri Department of Transportation, the Missouri D epa rtment of Natural Resources, the Illinois Department of Transportation (IDOT) , and the Illinois EPA. At this meeting the development of the proposed Maintenance Plan motor vehicle emissions budgets was discussed . The draft Maintenance Plan was also forwa rded to the U.S. EPA Region V representative for his review and comment. A follow

- up meeting of34

the Inter

- Agency Consultation Team to discuss the revised MOVES

- based motor vehicle emissions budgets was held on June 14, 2011.

The motor vehicle emissions b udgets propose d and described herein were , in compliance with adequacy criterion #5, developed consistent with the methodology and control strategy assumptions used in the Metro

- East 1997 8

- H our O zone A ttainment

D emonstration as well as the associated Reas onable Further Progress ( RFP ) plan. The effects of these controls are incorporated into the emissions factors produced by the U.S.

EPA’s MOVES model. In response to adequacy criteria 4 and 6, the narrative of the

Metro

- East 8

- Hour Ozone Maintenance Plan discusses the emissions estimates from other sectors and any changes in regulations. Following , in response to adequacy criteria #3, is a discussion of the inputs and assumptions incorporated into the development of the proposed Maintenance Plan motor veh icle emissions budgets.

Vehicle Miles Traveled : The proposed Metro

- East 8

- Hour O zone Maintenance Plan attainment year 2008 motor vehicle emissions budgets were developed using actual

annual 2008 county

- level vehicle miles travelled (VMT) data from the ID O T. The 2008

annual VMT for the 4

- county (Madison, Monroe, St. Clair and Jersey) Metro

- East St.

Louis 8

- hour ozone nonattainment area was 5.878 b illion miles. This figure was projected to the Maintenance Plan end year, 202 5 , using an annual growth rate of 1.5 percent, yielding an annual V MT of 7.57 b illion. These annual VMT figures are model inputs and converted to summer weekday levels.

Following is a summary of the information and MOVES model assumptions used in the development of the draft motor veh icle emissions budgets.

Meteorological Da ta : U.S. EPA guidance for the u se of the MOVES model requires

the use of local t emperature and a bsolute h umidity data. Average 2008 maximum and minimum monthly temperatures for the region were obtained from the National Weather Service observations for St. Louis Lambert Airport. Corre sponding absolute humidity levels were determined for the observed temperatures. These 2008 temperatures and absolute humidity values were used in the year 202 5 emissions modeling.

Motor Vehicle Emissions Controls: Beyond the U.S. EPA’s federal motor ve hicle control program emissions standards, t he primary local motor vehicle emissions control programs that were in place in the Metro

- East NAA in 2008 and are projected to still be required are a vehicle I/M program and the required use of Reformulated Gasoline.

Inspection and Maintenance (I/M): The Illinois I/M program in effect since 2007 requires biennial On

- Board Diagnostics II (OBD) testing on all model year (MY) 1996 and newer (MY96+) light

- duty gasoline vehicles, and biennial exhaust idle and gas cap testing on MY96+ heavy duty gasoline vehicles including gasoline

- powered buses, registered in the I/M testable area . Motorcycles and diesel vehicles are not subject to

I/M. The program include s a 4

- year grace period for new vehicles. This post

- 2007 I/M program was established when the Illinois legislature amended the Illinois Vehicle Inspection law in 2005 to (a) end dynamometer testing of vehicles, (b) require an OBD

based program beginning i n February 2007, and (c) remove the requirement for testing35

compliant pre

- MY96 vehicles.

The Metro

- East vehicle testing domain includes the urbanized areas in Madison

, Monroe and St. Clair Counties. There are no urbanized areas in Jersey County. An ― I/M Coverage‖ percentage was developed based on the amount of VMT from vehicles subject to the inspection program compared to total area VMT. The I/M Coverage percentage

for the Metro

- East 8

- hour ozone nonattainment area is 84%.

Fuels: The use of fed eral Reformulated Gasoline (RFG) has been required in the

Metro

- East St. Louis NAA since 2007 and the St. Louis, Missouri area since 2001. Since

the Metro

- East NAA is a part of the St. Louis NAA, classified a ―southern‖ area for purposes of motor fuel con trol programs, southern grade RFG is required and assumed to

be used in the Metro

- East area. The 8

- hour ozone Attainment Demonstration assumed the use of southern grade RFG in 2008 and beyond. RFG was assumed to contain 10%

ethanol. The MO VES model can account for other fuels, such as E85, natural gas, methanol, etc, but for all practical purposes the gallons of such alternative fuels and hence the number of vehicles using them is very small compared to the number of gasoline and diesel vehicles, therefo re, the use of such fuels was not considered.

Gasoline Sulfur: Th e federal Tier 2 regulations require gasoline sulfur levels to average no greater than 30 parts per million (ppm) with a maximum of 80 ppm beginning in 2007. There are no Illinois gasolin e sulfur requirements. Therefore, the MOVES gasoline sulfur levels were used in the emissions modeling.

Diesel Sulfur: Th e federal Tier 2 regulations limit the level of sulfur in diesel fuel requiring on

- highway diesel fuel to 15 ppm beginning in 2006 . There are no Illinois diesel sulfur requirements. Therefore, the MOVES diesel sulfur levels were used in the emissions modeling.

Fuel Volatility: The volatility of summer RFG, measured as Reid vapor pressure (RVP), is not specifically regulated. However, a fuels’ RVP is one of the primary characteristics controlled in order to meet the RFG performance standards. Therefore, the MOVES RVP levels were used in the emissions modeling.

Registration Distribution: The Registration Distribution (RD) is the fraction of vehicles of a given vehicle type and age in the fleet of vehicles of that type as a whole. Different vehicle types have different RDs A Metro

- East area

- specific vehicle registration distribution profile based upon 2008 information data was developed by Illinois EPA’s Division of Mobile Source Programs from data provided by the Illinois Secretary of State’s Department of Motor Vehicles. This profile is assumed to remain valid for 202 5.

Source Type Population represents the number of vehicles of each MOVES vehicle type

in the fleet as a whole within the area under consideration. Accurate local source

- type populations we re not availabl e; therefore the MOVES default fractions modified by VMTs by vehicle type were used.36

VMT Temporal Fractions are the VMT fractions of annual VMT by month of the year, of weekly VMT by day of the week, and daily VMT by hour of the day. The Illinois

EPA use s temporal fractions derived from data collected from continuous count stations and presented by IDOT. Temporal fractions vary by road type.

Speed distributions are the fractions of VMT on a given road type by given vehicle types in various speed ranges (bins). Thus, on a typical Urban Arterial, a small fraction of the vehicles are traveling at less than 10 mph (plus or minus 5 mph), more at 20 mph, more at 30mph , most at 40 mph, less at 50 mph, and so on. These fractions differ by hour of the day

— in more congested conditions during rush hours, the maximum fraction might be in the 30 mph range rather than the 40 mph range. The Illinois EPA relied on

the MOVES mo del default speed distributions when aggregating emissions (or emission rates) for vehicles at different speeds.

Ramp fraction is the fraction of total VMT on limited

- access highways such as

Interstates that is from on

- and off

- ramps to or from those hi ghways. Driving on limited

access highways is more or less at uniform speed, but driving on ramps involves considerable acceleration and deceleration; and these speed changes affect emissions. The default MOVES Ramp Fractions are 15% on Rural Interstates , 10% on Urban Interstates, and 2% on Other Freeways and Expressways. Illinois does not have actual or observed Ramp Fraction data; therefore the MOVES default values were used.

Road Type Distribution is the (fraction of) VMT on different road categories within an

area under consideration. The Illinois EPA uses VMT data by HPMS functional class (FC) published by IDOT as the basis of its emission calculations. The Road Type Distribution for Rural Interstates in a county is the county’s Rural In terstate VMT divided by the county’s total all

- road

- type VMT. Similar calculations can be made for MOVES road types and vehicle types.

Motor Vehicle Emissions Budgets Using the emissions factors and summer weekday VMT generated by the MOVES

model

, follow ing are the Attainment Year 2008 and Maintenance Plan Year 202 5 Metro

East S. Louis 8

- hour ozone motor vehicle emissions budgets for use in determining transportation conformity.

Proposed Metro

- East

8

- hour Ozone Maintenance Plan

2008 and 202 5

Motor Vehicle Emissions Budgets (tons per ozone season weekday)

Year VOM NOx

2008 1 7

. 27 52.57

202 5 5.68 15.2237ILLINOIS ENVIRONMENTA L PROTECTION AGENCY

Notice of Public Comment Period for State Implementation Plan (SIP) Submittals for the Chicago and Metro-East Ozone Nonattainment Areas and the Chicago PM 2.5 Nonattainment Area

The Illinois Environmental Protection Agency (Il linois EPA) Bureau of Air is accepting public comments on proposed revisions of the Maintenan ce Plans related to the 1997 8-hour ozone and

PM 2.5 National Ambient Air Quality St andards (NAAQS) and the associated draft motor vehicle emissions budgets. The Maintenance Plans contai n the State’s plans for maintaining the 8-hour

ozone and PM 2.5 NAAQS for at least 10 years after the U.S. EPA redesignates the areas to

attainment.

The Illinois EPA will accept written comments on th e revisions to the Maintenance Plans. The written comments must be postmarked by August 8, 2011, unless a Public Hearing is requested. Comments and requests for hearing should be mailed to:

Dean Studer, Hearing Officer

Illinois EPA 1021 North Grand Avenue, East

P.O. Box 19276 Springfield, Illinois 62794-9276 telephone number: 217/558-8280 or TDD: 217/782-9143.

If a timely request for a Public Hearing is received by August 11, 2011, a hearing will be held on August 18, 2011, at 1:00 p.m. in the Sangamo Ro om at the Illinois EPA’s Headquarters at 1021 N. Grand Ave. East, Springfield, Illinois, and the written public comment period will be extended to September 16, 2011.

The Public Hearing will be cancelled unless a written request for a Public Hearing is received by the Illinois EPA by U.S. Mail, carrier mail, or hand delivered by August 11,

2011. Verification or cancellation of the Publ ic Hearing will be posted on August 12, 2011 on

Illinois EPA’s website at: http://www.epa.state.i l.us/public-notices/

.

Copies of these draft SIP submittals may be vi ewed by the public during regular business hours (Monday through Friday 8:30 a.m. until 4:30 p.m, excep t for State holidays) at the Illinois EPA’s Headquarters at 1021 North Grand Avenue East, Springfield, Illinois, as well as on Illinois EPA’s website at http://www.epa.state.il.us. No wa lk-in requests for copies of this material will be accommodated, unless advance notice is prov ided. Requests and public inquiries, including

verification or cancellation of the Public Hearing, should be di rected to Dean Studer, the Illinois EPA’s Hearing Officer, at the addr ess and phone number listed above.

If a hearing request is received, th e hearing will be held in accorda nce with the provisions of the Illinois EPA’s “Procedures for Informational and Qu asi-Legislative Public Hearings,” set forth at 35 Ill. Adm. Code 164. Any questions about the h earing procedures, requests for copies of thehearing rules, or requests for speci al need interpreters should be directed to the Hearing Officer at the address above. Requests for special n eeds interpreters must be made by August 11, 2011.

Illinois EPA is proposing to revise the Maintena nce Plans to extend the maintenance period until 2025, and to establish new moto r vehicle emissions budgets for the years 2008 and 2025 for the nonattainment areas. When final, the Illinoi s EPA will submit the revised Maintenance Plans and the motor vehicle emissions budgets to th e U.S. EPA as SIP revisions to meet the requirements of the federal Clean Air Act (CAA). The hearing will satisfy the requirements of Section 110(l) of the CAA (42. U.S.C. 7401(l) (public notice for SIP submittals)).

On May 26, 2010, the Illinois EPA submitted a Maintenance Plan for the Metro-East

nonattainment area to the United States Envi ronmental Protection Agency (U.S. EPA) and requested that U.S. EPA redesign ate the Metro-East nona ttainment area to a ttainment of the 1997 8-hour ozone NAAQS. Similarly, on July 23, 2009, the Illinois EPA submitted a Maintenance Plan for the Chicago nonattainment area to the U.S. EPA and requested that U.S. EPA redesignate the Chicago nonattainment area to attainment of the 1997 8-hour ozone NAAQS. Finally, on October 15, 2010, the Illinois EPA subm itted a Maintenance Plan for the Chicago nonattainment area to the U.S. EPA and request ed that U.S. EPA redesignate the Chicago

nonattainment area to attainment of the 1997 PM 2.5 NAAQS. U.S. EPA is expected to act on the redesignation requests conc urrently with its final actions on the revised Maintenance Plans.

### Notice of Cancellation of Public Hearing

On July 8, 2011 the Illinois EPA had the Notice of Public Comment Period for State Implementation Plan Submittals for the Chicago and Metro

- East Ozone Nonattainment Areas and the Chicago PM 2 .5 Nonattainment Area published in the Chicago Sun Times and in the Illinois edition of the St. Louis Post Dispatch. Provision was also given in the notice for a public hearing to be held in this matter on August 18, 2011 conditioned on the receipt of a timel y request for Public Hearing.

Pursuant to the published notice, Illinois EP A is required to post either a Verification of the Public Hearing or a Cancellation of the Public Hearing on our website on August 12, 201l. Since no requests for public hearing h ave been received, the public hearing originally scheduled for August 18, 2011 has been cancelled. The public comment period has ended but the Illinois EP A will accept any public comments in this matter that have been postmarked on or before August 8, 201 1.

Dated: August 12, 2011

Dean Studer Hearing Officer1 ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

BUREAU OF AIR



### Responsiveness Summary for Public Questions and Comments on the State Implementation Plan Submittal s for the Chicago 8

- Hour Ozone Nonattainment Area

, the Chicago PM 2.5 

### Nonattainment Area , and the

Metro

- East 8

- Hour Ozone Nonattainment Area

September 1 6 , 201123

INTRODUCTION

The Illinois Environmental Protection Agency (Illinois EPA) has prepared Maintenance Plans for the Chicago and Metro

- East ozone nonattainment areas (NAA). The Maintenance Plans are required before the areas can be redesignated from nonattainment to attainment of the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) pr omulgated by the U.S. Environmental Protection Agency (U.S. EPA) in 1997. Similarly, the Illinois EPA has prepared a Maintenance Plan for the Chicago NAA, as required before the areas can be redesignated from nonattainment to attainment of the annual NAAQ S for f i n e p a r t i c u l a t e s ( PM 2.5 ) promulgated by the U.S. EPA in 1997. The Illinois EPA intends to submit requests to the U.S. EPA to redesignate the Chicago NAA to attainment for both ozone and PM 2.5 , and to redesignate the

Metro

- East NAA to attainment for ozone in conjunction with the submittal of these Maintenance

Plans.

Th e Maintenance Plan s provide for the continued attainment of the 1997 ozone NAAQS for the Chicago and Metro

- East NAAs, and for the continued attainment of the annual PM 2.5 NAAQS

for the Chi cago NAA for a period of at least ten years after U.S. EPA has formally redesignated

the area s to attainment. The Plan s also provide assurances that even if a subsequent violation of

the NAAQS occurs, provisions in the Plan will prevent any future occurre nces through the enactment of contingency measures that would be triggered upon such occurrence.

PUBLIC HEARING AND COMMENT PERIOD

On July 8, 2011

, the Illinois EPA had the Notice of Public Comment Period for State Implementation Plan Submittals for the Chicago and Metro

- East o zone NAAs and the Chicago

PM 2.5 NAA published in the Chicago Sun Times and in the Illinois edition of the St. Louis Post Dispatch. Provision was also given in the notice for a public hearing to be held on August 18,

2011

, conditioned on the receipt of a timely request for Public Hearing. Since there were no requests for a public hearing

, the public hearing originally sched uled for August 18, 2011 w as cancelled. The Illinois EP A post ed a notice of Cancellation of the Public Hearing on its website on August 12, 201 1

. As indicated in the Notice of Public Comment, t he public comment period began on July 8, 2011 and closed on August 8, 2011.

COMMENTS AND RESPONSES BY THE ILLINOIS EPA

A commenter suggested that the Chicago ozone maintenance plan may not be adequate to maintain the NAAQS , noting that U

. S

. EPA ’s Air Quality System (AQS) contains the following

footnote for the 2008

- 2010 period for the Chicago NAA: “One or more sites in this area has violated the NAAQS prior to 2008

- 2010 and does not have a valid 2008

- 2010 design value.”

The footnote in the cited AQS report occurs when one or more monitors in the NAA do not

mee t the completeness criteria established by U.S. EPA. For the 2008

- 2010 period, design values are not shown in AQS for two monitoring stations in the Chicago area, prompting the footnote cited by the commenter. The two sites are located at Wacker and Adams4

Streets in downtown Chicago (site ID: 17

- 031

- 0042) and 750 Dundee Road in Northbrook (site ID: 17

- 031

- 4201). The monitor at Wacker and Adams is located on the 90 th floor of the Willis Tower (Sears Tower) and is operated as a special purpose monitor durin g the summer months (typically June, July, and August). As a special purpose monitor, the measurements are not used for the purpose of determining the areas attainment status. At Northbrook, the Illinois EPA has historically operated two instruments to m easur e ozone at the same location. The data from the two instruments are distinguished in AQS by POC (Parameter Occurrence Code) Codes 1 and 2. One of the instruments located at

Northbrook (POC 2) was an experimental open path analyzer that was difficult and expensive to maintain , and routinely reported lower ozone values than the co

- located instrument. The experimental analyzer was discontinued in 2009. The other instrument operated at this location is the Federal Reference Method (FRM) ozone monitor ( POC 1). It has operated normally during 2008

- 2010, meeting U.S. EPA’s completeness criteria, and for which a valid design value for 2008

- 2010 has been calculated. U.S. EPA confirmed the validity and completeness of ozone measurements , and that all monitoring sites in the Chicago nonattainment area have three years of data showing attainment of the 1997 ozone NAAQS by publishing the Clean Data Determination on April 12, 2011.

A commenter pointed out that: “ Clean Air Act (CAA) Section 110( l ) pr ohibit s the U

. S

. EPA from approving any SIP revision that may interfere with another NAAQS. 42 U.S.C. § 7410(I).
However, I llinois EPA has presented no analysis at all to establish that re

- designating Chicago from nonattainment to attainment and that implementi ng the maintenance plan will not interfere

with the 2008 ozone NAAQS of 75 ppb or the 2010 1

- hour nitrogen dioxide NAAQS. ”

The Illinois EPA does not agree that a further analysis of the effects of redesignation on another NAAQS is required or that U.S. EP A cannot approve the SIP revision without such analysis. The Illinois EPA has prepared the Chicago ozone M aintenance P lan consistent with U.S. EPA’s published guidance. The document adequately demonstrate s that the 1997 NAAQS for ozone has been attained in the Chicago NAA based on three consecutive years of ambient air monitoring data . The plan contain s emission estimates of the precursors of ozone for the “attainment year” and multiple “projection years” that

demonstrate that the projected level of emissions is sufficient to maintain the NAAQS

. In fact, the emissions projections indicate that ozone precursor emissions will decrease substantially in future years, ensuring continued attainment and maintenance of the NAAQS. The Maintenance P lan provide s commitments to maintain and enforce the control measures that are already in place, to continue monitoring air quality in the NAAs, to prepare periodic updates of the emissions inventories, and to implement contingency

measures , if needed

, to correct future exceedances of the NAAQS. Based on these commitments, there is no basis to conclude that approval of the Maintenance Plan will cause backsliding of the air pollution control programs that have allowed the NAAs to
reach attainment with t he ozone NAAQS. As Illinois’ Maintenance Plan ha s been prepared in accordance with the requirements specified in U.S. EPA’s guidance document and additional guidance received from U.S. EPA staff , the plan is approvable as a SIP revision

.

Further, U.S. E PA has not implement ed the 2008 ozone NAAQS , and has decided not to tighten the standard before 2013

. Should U.S. EPA decide to implement the 2008 ozone5

standard, or to revise it in the future, Illinois is obligated to address the new ozone NAAQS, indepen dent of efforts to redesignate existing NAAs to attainment with the old standard.

With regard to the 2010 NO 2 NAAQS, all ambient monitors in Illinois, including the Chicago area , are meeting the standard and the Illinois EPA has recommended that all counties in Illinois be designated as attainment. U.S. EPA has not yet acted on Illinois’ recommendation. As shown in the Maintenance Plan, NOx emissions (a combination of compounds that includes NO 2 ) are expected to decrease significantly in future years, so

there is no basis to conclude that re

- designating the Chicago NAA from nonattainment to

attainment for the ozone NAAQS, and implementing the o z o n e maintenance plan will

interfere with a t t a i n m e n t o r m a i n t e n a n c e o f the 2010 1

- hour N O 2 NAAQS.

A commenter questioned whether air quality improvements were the result of permanent and

enforceable emission reductions since the NOx SIP Call and CAIR are cap and trade programs

, and because the NOx SIP Call is no longer in place and CAIR has been vacated by the U

. S

. Court of Appeals

.
Illinois EPA agrees that regional emission reductions provided by the NOx SIP Call and CAIR yielded significant air quality improvements, and that these progr ams combined with other emission reduction measures helped the Chicago area to meet the 8

- hour ozone NAAQS. The Illinois EPA does not agree, however, that these measures are not permanent

and enforceable. Illinois submitted

, and U.S. EPA approved

, SIP re visions addressing the requirements of the NOx SIP Call, and

, subsequently
, the CAIR program. Beginning in 2009, the CAIR program maintained the same emissions budgets as the NOx SIP Call program it replaced. In its decision to vacate the CAIR, the U.S C ourt of Appeals determined that the CAIR emissions budgets should remain in place, until U.S. EPA remedied the identified deficiencies. U.S. EPA recently promulgated the C r o s s

- S t a t e A i r P o l l u t i o n R u l e ( C S A P R ) to address the Court’s concerns. Sign i ficantly, the CSAPR

re quires that states meet emissions budgets that are more stringent than CAIR, and provides new requirements that ensure that emission reductions are achieved within each

affected state.

A commenter noted that I llinois EPA’s future emission projections did not consider U

. S

. EPA’s recent announcement that it is repealing the vapor capture requirements for gas stations.

Regarding the Stage II program, on July 15, 2011 the U.S. EPA issued a proposed rule determining that June 30, 2013 will be the date when the “widespread use” of onboard refueling vapor recovery (ORVR)

- equipped vehicles will occur. At this point the U.S. EPA expects “ORVR alone to achieve emissions reductions equal to Stage II alone” so no additional emissions would result from the cessation of the Stage II program. The widespread use determination would not obligate states to remove any existing Stage II vapor recovery requirements and the Chicago 8

- hour ozone Mai ntenance Plan does not propose to end the Stage II program. If at a later date, the Illinois EPA should wish to end the Stage II program in Chicago, a revision to the State Implementation Plan (SIP) would6

have to be adopted and approved by the U.S.EPA dem onstrating that no additional refueling e m i s s i o n s would result. As Stage II is not required in the Metro

- East St. Louis

area, U.S. EPA ’s widespread use determination would have no impact on either regional air quality or the Metro

- East St. Louis 8

- hour ozone Mainte nance Plan.

A commenter stated that I llinois EPA’s projection of future emissions decreases from on

- road

motor vehicles is unsupported , and that its emission s calculations from on

- road mobile sources

fail to consider U

. S

. EPA’s recent decision to allow 15% ethanol in all gas.

Illinois EPA used the U.S. EPA’s new MOVES2010 model to estimate motor vehicle emissions in both the Chicago and Metro

- East St. Louis areas. This model incorporates

emissions factors for all vehicl e category types. The model also incorporates local motor vehicle registration data and national fleet turnover rate statistics

. The reduction in estimated NOx emissions results from the introduction of new vehicles complying with the

Tier 2 motor vehicl e emissions standards and the retirement of older vehicles. The Tier 2 program, phased in beginning in 2004, established more stringent NOx emission s standard s

on cars , trucks
, and sport utility vehicles. Given the implementation of th ese significantly

m ore stringent emission standard s , the estimated reduction in motor vehicle NOx emissions

is reasonable

.

Regarding the comment regarding the U.S.EPA’s recent decision to allow the blending of up to 15% ethanol into conventional gasoline, the use of such fuel is limited to flexible

fueled vehicles and model year (MY) 2001 light

- duty cars and trucks, and medium

- duty passenger vehicles. In its “Notice of Decision Granting a Partial Waiver” (76 FR 4662), the U.S.EPA stated that Department of Energy (DOE) testing of MY 2001

- 2006 light duty motor vehicles “strongly supports a determination that E15 will not cause o r contribute to

MY2001

- 2006 light

- duty motor vehicles exceeding their applicable exhaust emission

standards.” The U.S.EPA further states that “MY 2001

- 2006 light duty motor vehicles should generally be able to meet evaporative emission standards when oper ated on E15 so long as the fuel does not exceed a RVP of 9.0 psi (pounds per square inch)in the summertime volatility control season.” The U.S.EPA goes on to state : “ ...i n fact, such vehicles should have somewhat lower evaporative emissions when operated on 9.0 psi E15 than when operated on currently available in

- use fuel.”

Regarding MY 2007 and newer vehicles, in its November 4, 2010 “Notice of Partial Waiver Decision” (75 FR 68094) the U.S. EPA states that DOE Catalyst Study and other

information befo re EPA adequately demonstrates that the impact of E15 on overall emissions, including both immediate and durability related emissions, will not cause or

contribute to violations of the emissions standards for these motor vehicle. Likewise, the

data and in formation adequately show that E15 will not lead to violations of the evaporative emissions standards, so long as the fuel does not exceed a Reid Vapor Pressure (RVP) of 9.0 psi in the summertime control season.”

The use of reformulated gasoline (RFG) is required in both the Chicago and Metro

- East St.

Louis areas. The summertime volatility of these fuels are in the range of 7.0 psi, well below the 9.0 psi level referenced by the U.S.EPA. Based on these statements from the U.S.EPA,7

the Illinois EPA believ es that the use of E15 gasoline blends will not result in any increase

in emissions in the ozone control season.

A commenter questioned whether ambient monitoring data is available to the public , since U

. S

. EPA and the Illinois EPA apparently do not have timely data available no their respective web

page s

.

The Illinois EPA submits all ambient monitoring data it collects to U.S. EPA’s Technology Transfer System (TTN) Air Quality System (AQS). The AQS Data Mart is a database containing all of the information from the AQS system and is available free of charge to the public

. The AQS Data Mart is available on the internet at :

http://www.epa.gov/ttn/airs/aqsdat amart

U.S. EPA also maintains the following web sites to disseminate air quality data to the public:

AirData @ http://www.epa.gov/air/data/index.html AirExplorer @ http://www.epa.gov/airexplorer/
AirNow @ http://www.airnow.gov/

A commenter pointed out that Chicago Ozone Maintenance Plan fail ed to consider climate change , noting that c limate change might cause existing pollution

- control measures to become inadequate in the future

.

The Illinois EPA understands that there is a clear relationship between meteorological conditions and ground level ozone levels, and that climate change may a ffect the frequency and severity of ozone

- conducive meteorological conditions in future years. Although climate change is not directly addressed in the Maintenance Plan, nor is it required to b e

a d d r e s s e d , the Maintenance Plan provides contingency measures that will b e triggered in the event of future NAAQS violations. The Illinois EPA has committed to maintain an adequate monitoring network in the Chicago area and to take corrective actions in the event of future NAAQS violations, whether caused by normal year

- to

- yea r meteorological variability, climate induced adverse conditions, or emissions changes that were not anticipated in the development of the Maintenance Plan. The Illinois EPA has also committed to revise the plan within the next ten years to ensure mainten ance of the NAAQS

.

A commenter stated that the Clean Air Act does not allow for alternative measures in the event that current control measures now in effect must be replaced with equivalent emission reduction

measures

.

I llinois EPA does not agree with the commenter’s statement. Section 110( l ) of the CAA provides for revisions of the SIP as long as the plan does not interfere with attainment or reasonable further progress, or other applicable requirements. To be clear, Illinois’8

Maintenance Plan does n ot rely on alternate measures. In fact, the plan clearly states Illinois’ commitment to keep existing control measures in place after the Chicago NAA has been redesignated to attainment. I n t h e e v e n t t h a t future revisions of Illinois’ SIP become necessary, the Main tenance Plan commits the state to provide equivalent emissions levels using alternate control measures

. Such revisions are subject to review and approval by

U.S. EPA.

A commenter noted that the summary of Illinois’ Reasonable Further Progress demonstration contained in the Chicago 8

- hour ozone Maintenance Plan states: “The control measures

identified in the RFP document

... will result in a 15.7 percent reduction in VOM emissions from 2002 emissions levels by the year 2008.” The commenter requested that I llinois EPA must prove that these reductions were actually achieved.

T he Illinois EPA does not agree that such a demonstration is require d for the Maintenance Plan, since there is no such requirement in any guidance published to date by U.S. EPA. Further, U.S. EPA has published a Clean Data Determination for the 1997 8

- hour ozone NAAQS for the Chicago NAA ( April 12, 2011), which waives CAA planning requirements, including RFP, as long as the nonattainment area continues to meet the NAAQS. However, based on this comment, the Illinois EPA has revised the 2002 VOM emission estimates contained in the Maintenance Plan (Table 4.2 on page 15). T he VOM emission estimates in the draft Maintenance Plan for 2002 did not properly account for changes in U.S. EPA’s emissions estimation guidance that occurred subsequent to preparation of the 2002 inventory. U.S. EPA’s guidance for computing emissions fr om certain area source categories, most significantly for graphic arts, consumer solvents, architectural coatings, and industrial coatings , changed between 2002 and 2008. Illinois EPA’s 2008 emissions estimates were performed using the revised methodology , but the 2002 estimates contained in the draft document were based on the earlier methodology. The final document has been revised to apply a consistent methodology for all years. Comparing VOM emissions in the Chicago NAA from 2002 to 2008 indicates th at VOM emissions decreased significantly during that period, about 210 tons per day. This amount equates to a reduction of about 21%, which exceeds the amount needed to demonstrate RFP.

Metro

- East St. Louis Ozone Maintenance Plan

A commenter suggested th at the Metro

- East ozone maintenance plan may not be adequate to maintain the NAAQS , noting that U

. S

. EPA ’s Air Quality System (AQS) contains the following

footnote for the 2008

- 2010 period for the St. Louis NAA: “One or more sites in this area has violated the NAAQS prior to 2008

- 2010 and does not have a valid 2008

- 2010 design value.”

The footnote in the cited AQS report occurs when one or more monitors in the NAA do not meet the completeness criteria establish ed by U.S. EPA. For the 2008

- 2010 period, design values are not shown in AQS for two monitoring stations (three samplers at two locations) in the St. Louis area, prompting the footnote cited by the commenter. The two sites are located at 4520 Margaretta i n St. Louis, MO (site ID: 29

- 510

- 0086) and 4580 South Lindbergh in Sunset Hills, MO (site ID: 29

- 189

- 004). The Missouri Department of Natural Resources (MDNR) discontinued these monitoring stations prior to the 2009 ozone season.9

These monitors were dete rmined by MDNR and U.S. EPA

– Region 7 to be redundant with other monitors in the metropolitan area, and did not measure the highest levels of ozone in the NAA during the years that they operated at those locations. U.S. EPA requires that changes in a sta te’s monitoring network be identified and approved in advance, and contained in the state’s monitoring network plan. MDNR’s 2009 network plan properly and timely identified and justified the need to discontinue these sites . By approving the changes to MD NR’s monitoring network plan, U.S. EPA determined that the revised network was still adequate to characterize ozone air quality in the St. Louis NAA.

A commenter pointed out that: “ Clean Air Act (CAA) Section 110( l ) prohibits the U

. S

. EPA from approving any SIP revision that may interfere with another NAAQS. 42 U.S.C. § 7410(I).
However, Illinois EPA has presented no analysis at all to establish that re

- designating Metro

- East from nonattainment to attainment and that implementing the maintenance plan will not interfere with the 2008 ozone NAAQS of 75 ppb or the 2010 1

- hour nitrogen dioxide NAAQS. ”

The Illinois EPA does not agree that a further analysis of the effects of redesignation on another NAAQS is required or that U.S. EPA cannot approve the SIP revision without such analysis. The Illinois EPA has prepared the Metro

- East ozone M aintenance P lan consistent with U.S. EPA’s published guidance. The document adequately demonstrate s that the 1997 NAAQS for ozone has been attained in the St. Louis NAA based on three consecutive years of ambient air monitoring data. The plan contain s emission estimates of the precursors of ozone for the “attainment year” and multiple “projection years” that demonstrate that the projected level of emissions is sufficient to maintain the NAAQS. In fact, the emissions projections indicate that ozone precursor emissions will decrease substantially in future years, ensuring continued attainment and maintenance of the NAAQS. The Maintenance Plan provides commitments to maint ain and enforce the control measures that are already in place, to continue monitoring air quality in the NAAs, to prepare periodic updates of the emissions inventories, and to implement contingency measures, if needed, to correct future exceedances of the NAAQS. Based on these commitments, there is no basis to conclude that approval of the Maintenance Plan will cause backsliding of the air pollution control programs that have allowed the NAAs to

reach attainment with the ozone NAAQS. As Illinois’ Mainten ance Plan ha s been prepared in accordance with the requirements specified in U.S. EPA’s guidance document and additional guidance received from U.S. EPA staff , the plan is approvable as a SIP revision

.

Further, U.S. EPA has not implemented the 2008 ozone NAAQS, and has decided not to tighten the standard before 2013. Should U.S. EPA decide to implement the 2008 ozone standard, or to revise it in the future, Illinois is obligated to address the new ozone NAAQS, independent of efforts to redesignate existing NAAs to attainment with the old standard.

With regard to the 2010 NO 2 NAAQS, all ambient monitors in Illinois, including the

Metro

- East area , are meeting the standard and the Illinois EPA has recomme nded that all counties in Illinois be designated as attainment. U.S. EPA has not yet acted on Illinois’ recommendation. As shown in the Maintenance Plan, NOx emissions (a combination of compounds that includes NO 2 ) are expected to decrease significantly in future years, so

there is no basis to conclude that re

- designating the Metro

- East NAA from nonattainment10

to attainment of the ozone NAAQS

, and implementing the maintenance plan will interfere

with the 2010 1

- hour nitrogen dioxide NAAQS.

A commenter questioned whether air quality improvements in the Metro

- East area were the result of permanent and enforceable emission reductions since the NOx SIP Call and CAIR are cap and trade programs , and because the NOx SIP Call is no longer in place a nd CAIR has been vacated by the U

. S

. Court of Appeals

.

The Illinois EPA believes that these comm ents have been addressed in its previous responses for the Chicago ozone nonattainment area.

A commenter pointed out that I llinois EPA ’s emission projections do not account for emissions

from the Prairie State Generating Station which should be in operation, and thus polluting, prior

to 2015.

The Prairie State Generating Station is located in Washington County, Illinois and is expected to be in operation by 2012. As require d, Illinois EPA’s emissions projections include only those emissions occurring or projected to occur within the boundaries of the nonattainment area, which includes Madison, Monroe, St. Clair, and Jersey counties in

Illinois. The Illinois EPA acknowledges that the Prairie State Generating Station is located in close proximity to the Metro

- East ozone nonattainment area and emissions from it will cause air quality impacts within the NAA. Before issuing a PSD permit to Prairie State, the Illinois EPA require d the company to address its potential impact on the St. Louis ozone nonattainment area. Prairie State adequately demonstrated that future emissions from the facility will not interfere with the area’s ability to attain and maintain the NAAQS.

A commen ter identified the same “defects” in the Metro

- East Ozone Maintenance Plan identified previously in comments on the Chicago Ozone Maintenance Plan

, includ ing : (1) failing to

consider increased emissions from U

. S

. EPA’s repealing the vapor capture requirements for gas

stations and allowing up to 15% ethanol in gasoline; (2) assuming that vehicle turn over will

reduce mass on

- road emissions even though purchasing larger new vehicles can offset this; (3) failing to m ake ambient monitoring data available to the public; (4) failing to consider climate change impacts on future ambient ozone levels; (5) relying on unidentified alternate measures with no legal authority to do so.

The Illinois EPA believes that these comm ents have been addressed in its previous responses for the Chicago ozone nonattainment area.

A commenter questioned whether PM 2.5 air quality improvements in Chicago were the result of permanent and enforceable emission reductions since the NOx SIP Call an d CAIR are cap and trade programs , and because the NOx SIP Call is no longer in place and CAIR has been vacated by the U

. S

. Court of Appeals

.11

The Illinois EPA believes that th is comment ha s been addressed in its previous responses for the Chicago ozone n onattainment area.

A commenter identified the same “defects” in the Chicago PM 2.5 Maintenance Plan identified previously in comments on the Chicago Ozone Maintenance Plan

, includ ing : (1) failing to

consider increased emission from U

. S

. EPA’s repealing the vapor capture requirements for gas stations and allowing up to 15% ethanol in gasoline; (2) assuming that vehicle turn over will

reduce mass on

- road emissions even though purchasing larger new vehicles offset this; and (3) failing to m ake ambient monitoring data available to the public.

The Illinois EPA believes that these comments have been addressed in its previous responses for the Chicago ozone nonattainment area.