State of Wisconsin 

DEPARTMENT OF NATURAL RESOURCES 

101 S. Webster Street 

Box 7921 

Madison WI 53707-7921 

May 30,2013 

Ms. Susan Hedman 

Regional Administrator 

U.S. Environmental Protection Agency (EPA) 

77 West Jackson Boulevard, R-19J 

Chicago IL 60604-3507 

Scott Walker, Governor 

Cathy Stepp, Secretary 

Telephone 608-266-2621 

Toll Free 1-888-936-7463 

TTY Access via relay - 711 

Subject: Milwaukee-Racine Redesignation Request- Supplemental Information 

Dear Ms. Hedman: 

The Wisconsin Department of Natural Resources (WDNR) hereby submits draft supplemental State Implementation 

Plan (SIP) information for Wisconsin's outstanding fine particulate matter (PM25) Milwaukee-Racine Nonattainment 

Area redesignation request. The WDNR originally submitted a redesignation request for this nonattainment area to 

the U.S. EPA on June 5, 2012 for the 2006 24-hour PM2.5 National Ambient Air Quality Standard (NAAQS). All of 

the PM2.5 monitors in this area have been measuring attainment of the 2006 24-hour PM25 NAAQS since 2010. 

The WDNR requests that the U.S. EPA begin parallel processing the regulatory review of this supplemental SIP 

information while the state completes the required public input and legislative review process. The WDNR will 

submit the fmal information to the U.S. EPA once the following regulatory steps are completed: 

• Conclusion of Wisconsin Legislative Review: July 1, 2013 

• Public Hearing: July 8, 2013, 11 :OOam, at WDNR Southeast Region Headquarters 

• Conclusion of Public Comment Period: July 10, 2013 

The WDNR has the legal authority under Wisconsin law to adopt and implement these requested SIP revisions. 

Section 285.11 (6), Wis. Stats., authorizes the WDNR to develop and revise the SIP for prevention, abatement, and 

control of air pollution. A copy of the public hearing notice is included as an attachment. In accordance with the 

April 6, 2011 McCabe Memo, one paper copy of the SIP revision documents is enclosed. In addition, an electronic 

copy of these documents is provided as well on an enclosed CD. If you have any questions regarding this submittal, 

please feel free to call Joseph Hoch at (608) 267-7543 or Ralph Patterson at (608) 267-7546. 

cc: WDNR: Patrick Stevens (AD/8), Joseph Hoch (AM/7), Ralph Patterson (AM/7) 

U.S. EPA Region V (77 West Jackson Boulevard, Chicago, IL 60604): 

George Czerniak (A-18J), John Mooney (A-18J), Douglas Aburano (AR-18J), Jacqueline Nwia (AT-18J) 

attachments: (1) EPA Region V SIP Submittal Checklist, (2) Public Hearing Notice, (3) Supplemental SIP Information 

dnr.wi.gov 

wisconsin.gov Naturally WISCONSIN PRINTED 

ON RECYCLED PAPER 
SUPPLEMENTAL INFORMATION FOR A JUNE 2012 REDESIGNATION 

REQUEST AND MAINTENANCE PLAN FOR THE 24-HOUR FINE 

PARTICULATE MATTER NATIONAL AMBIENT AIR QUALITY 

STANDARD 

FOR THE 

MILWAUKEE-RACINE 3-COUNTY 

NONATTAINMENT AREA 

WISCONSIN 

Developed By: 

The Wisconsin Department of Natural Resources 

May 2013 
Table of Contents 

Supplemental Emissions Inventory Information for Ammonia (NH3) 1 

Supplemental Design Value Modeling 3 
2007 Ammonia (NH3) Emissions in Milwaukee, Racine, and Waukesha Counties 

Sector

NH3Emissions(tons)

Percentof Total Sector

NH3Emissions(tons)

Percentof Total Sector

NH3Emissions(tons)

Peof 

EGU Point 1.82 0.07% Point 32.33 1.23% 

Stationary 1,960.58 74

Non-EGU Point 30.51 1.15% Area 613.34 23.22% Area 1,928.25 72.99% Agricultural NH3 1,314.91 49.78% Onroad 673.17 25.48% Onroad 673.17 25.48% Nonroad 7.08 0.27% Mobile 681.09 25

Nonroad 7.92 0.30% MAR 0.84 0.03% 

County NH3

Emissions(tons)

Percentof Total

Milwaukee 979.51 37.08% Racine 832.54 31.52% Waukesha 829.62 31.41% 

Notes These NH3 emissions were developed by the Lake Michigan Air Directors Consortium (LADCO). Documentation regardi

were calculated can be found at: http://www.ladco.org/tech/emis/basecv8/Base_C_Emissions_Documentation_Sept_12.pd

EGU = Electric Generating Unit MAR = Marine, Aircraft, and Rail 
Total Statewide Wisconsin Ammonia (NH3) Emissions – 2005, 2007, & 2018 Notes LADCO only provided onroad estimates (i.e., “MOVES”) for 2007 emissions. These emissions were assumed to be the saThese onroad emissions are less than 3% of the total estimated NH3 emissions for each of the three years shown. 

Agricultural NH3 emissions account for 95%, 94%, and 94% of total statewide NH3 emissions in 2005, 2007, and 2018, res

In 2007, the NH3 emissions in the Milwaukee-Racine Nonattainment Area were estimated to be 2,641.66 tons. This is only 

total NH3 emissions (120,941 tons) in 2007. 
3 

DAILY FINE PARTICULATE MATTER (PM2.5) DESIGN VALUE MODELING 

The Wisconsin Department of Natural Resources (WDNR) reviewed the latest future year design value modeling 

developed by the Lake Michigan Air Directors Consortium (LADCO) for PM2.5 in the Milwaukee-Racine 

Nonattainment Area. This information is summarized on Page 11 of “Appendix B – Regional Air Quality Analyses 

for Ozone, PM2.5, and Regional Haze” of a Final Technical Support Document dated September 25, 2008. LADCO 

provided design values for 2009, 2012, and 2018. The WDNR specifically considered the design values from the 

“with CAIR” scenarios for the discussion contained in this paper. 

2009 - 2012 

A comparison of modeled PM2.5 design values and air monitoring conducted by the WDNR for 2008 – 2012 is 

shown on the following page. The primary takeaways are as follows: 

 Design values calculated from WDNR air monitoring data are below LADCO modeled design values. 

 Downward trends from 2008 through 2012 for air monitoring sites where data is available from WDNR air 

monitoring are steeper than was anticipated by the 2008 LADCO modeling. 

2018 

LADCO also developed 2016 – 2018 PM2.5 design values as part of their 2008 PM2.5 modeling. The design values 

are as follows: 

Site Name Site Id 2016 – 2018 Design Value 

MILWAUKEE SIXTEENTH ST. HEALTH CENTER 550790010 33 μg/m3

MILWAUKEE SER DNR HDQRS 550790026 33 μg/m3

MILWAUKEE VIRGINIA STREET FIRE STATION 550790043 36 μg/m3

MILWAUKEE FIRE DEPT HDQRS 550790099 32 μg/m3

WAUKESHA CLEVELAND AVE 551330027 29 μg/m3

All of the 2016 – 2018 Milwaukee-Racine Nonattainment Area design values are below the 2006 24-Hour PM2.5

National Ambient Air Quality Standard (NAAQS) of 35 μg/m3

, except for the projected design value at the 

WDNR’s Milwaukee Virginia Street Fire Station air monitoring location. 

The U.S. Environmental Protection Agency (EPA) recently updated its Modeled Attainment Test Software (MATS) 

from Version 2.3.1 to 2.5.1. The 2008 LADCO modeling relied on the older MATS version to develop the 2016 – 

2018 PM2.5 design values. In consultation with the U.S. EPA and LADCO, the WDNR reproduced the 2008 

LADCO future year modeling using both MATS versions and found that the projected 2016 – 2018 design value 

dropped from 35.8 μg/m3

 to 33.0 μg/m3 at the WDNR’s Virginia Street Fire Station air monitoring location when 

using the latest software. The WDNR confirmed this result (i.e., lower design value) with the U.S. EPA. 
Milwaukee Virginia Street Fire Station (S

 2007 – 2009 (LADCO 2008 Modeling): 

 2008 – 2010 (LADCO 2008 Modeling): 

 2009 – 2011 (LADCO 2008 Modeling):  2010 – 2012 (LADCO 2008 Modeling): 

 2007 – 2009 (WDNR – Air Monitoring)

 This site was discontinued on 12/31/20

Milwaukee Fire Department Headquarte 2007 – 2009 (LADCO 2008 Modeling): 

 2008 – 2010 (LADCO 2008 Modeling): 

 2009 – 2011 (LADCO 2008 Modeling):  2010 – 2012 (LADCO 2008 Modeling): 

 2007 – 2009 (WDNR – Air Monitoring)

 This site was discontinued on 12/31/20

Note: 2008 – 2010 & 2009 – 2011 design values for the LADCO 2008 modeling are interpolated since only 2007 – 2009 & 2010 – 
BEFORE THE 

DEPARTMENT OF NATURAL RESOURCES 

Notice of Public Hearing 

Supplemental Information for Wisconsin’s Fine Particulate Matter (PM2.5) Redesignation Request 

for the Milwaukee-Racine Nonattainment Area 

NOTICE IS HEREBY GIVEN that pursuant to ss. 285.11(5) and (6) and 285.23(2) and (4), Wis. 

Stats., and ch. NR 401, Wis. Adm. Code, the Wisconsin Department of Natural Resources will hold a 

public hearing on supplemental information it plans to submit to the U.S. Environmental Protection 

Agency (EPA) in support of a redesignation request that was submitted on June 5, 2012. 

Background 

The Department submitted a redesignation request for the Milwaukee-Racine Nonattainment Area to the 

U.S. EPA on June 5, 2012 for the 2006 24-hour PM2.5 National Ambient Air Quality Standard (NAAQS). 

The Milwaukee-Racine Nonattainment Area includes the counties of Milwaukee, Racine, and Waukesha. 

In light of two recent decisions from the United States Court of Appeals for the District of Columbia 

(EME Homer City Generation, L.P. v. EPA issued on August 21, 2012 and Natural Resources Defense 

Council v. EPA issued on January 4, 2013), the U.S. EPA requested additional information before it could 

make a regulatory decision on the Department’s outstanding redesignation request. The Department is 

taking comment on an ammonia (NH3) emissions inventory and PM2.5 design value modeling for the 

Milwaukee-Racine Nonattainment Area. 

NOTICE IS HEREBY FURTHER GIVEN that the public hearing will be held on: 

 

 Monday, July 8, 2013 at 11:00 a.m.

 WI DNR Southeast Region Headquarters, Room 140 - 141 

 2300 N. Dr. Martin Luther King Jr. Drive 

 Milwaukee, WI 

NOTICE IS HEREBY FURTHER GIVEN that pursuant to the Americans with Disabilities Act, 

reasonable accommodations, including the provision of informational material in an alternative format, 

will be provided for qualified individuals with disabilities upon request. Please call Mr. Joseph Hoch at 

(608) 267-7543 with specific information on your request at least 10 days before the scheduled hearing. 

Written Comments and Copies of Documents 

Written comments on the PM2.5 redesignation request supplemental information may be submitted to Mr. 

Joseph Hoch, Bureau of Air Management AM/7, P.O. Box 7921, Madison, WI 53707 no later than July 

10, 2013. Comments may also be submitted electronically to joseph.hoch@wisconsin.gov. Written 

comments will have the same weight and effect as oral statements presented at the hearing. The PM2.5

redesignation request supplemental information may be obtained by contacting Mr. Joseph Hoch at (608) 

267-7543 or downloaded from http://dnr.wi.gov/topic/AirQuality/Particles.html. 

Dated at Madison, Wisconsin May 22, 2013 

 STATE OF WISCONSIN 

 DEPARTMENT OF NATURAL RESOURCES 

 By /s/ Matt Moroney for 

 Cathy Stepp, Secretary 
EPA Region V 

Wisconsin SIP Submittal 

Completeness Review

Submittal Letter 

1. Signed by Governor’s Designee (Bart Sponseller)? Yes X No 

2. Date of Submittal: May 30, 2013 

3. WDNR Person in charge of SIP submittal. 

Name: Ralph Patterson 

Telephone Number: (608) 267-7546 

 Fax Number: (608) 267-0560 

E-mail Address: Ralph.Patterson@wisconsin.gov 

4. WDNR Technical Person in charge of answering questions on SIP Submittal 

Name: Joseph Hoch 

Telephone: (608) 267-7543 

 Fax Number: (608) 267-0560 

E-mail Address: Joseph.Hoch@wisconsin.gov 

Incorporation Into Wisconsin Administrative Code

5. Is evidence that the State incorporated the revision into the Wisconsin Administrative Code supplied in this 

SIP package? 

 

Yes 

No X (if No, explain) 

Not applicable. This is not a rule submittal and therefore requires no incorporation into the Wisconsin 

Administrative Code. 

6. The effective date of the regulation is or was: Not applicable 

7. Are test methods/rules incorporated by reference correctly? (Has approval been obtained from the state 

Attorney General 

Yes 

No (if No, explain answer) 

 Not applicable X (if Not applicable, explain answer) 

 

This is not a rule submittal and therefore the Attorney General need not approve this submittal. 

8. Has WDNR provided evidence that it has necessary legal authority under State law to adopt and implement 

the revision? Provide additional explanation (if necessary). 

 Yes X 

 No 
2

9. Did the State include a copy of the actual regulation or document for USEPA review? Provide additional 

explanation (if necessary). 

 Yes X 

 No 

10. Did the State provide evidence that it followed all of the requirements of its Administrative Procedures Act 

(ch. 227, Wis. Stats., Administrative Procedure and Review) in conducting and completing 

adoption/issuance of the revision? Provide additional explanation (if necessary). 

 Yes 

 No X 

Not applicable. 

11. Did the State include evidence that Public Notice was given of the revision, including date of publication? 

Provide additional explanation (if necessary). 

 Yes X 

 No 

The state provided a copy of the public hearing notice and newspaper publication of the upcoming (July 8, 

2013) public hearing. 

12. Did the State provide a copy of the certification that public hearings were held in accordance with the 

information provided in the public notice (copy of notarized Class I paper proof). Provide additional 

explanation (if necessary). 

 Yes 

 No X 

This was not submitted yet because the state is asking the U.S. EPA for parallel processing of the 

supplemental SIP information and the public hearing has not yet occurred. This can be provided after the 

conclusion of the public hearing and comment period. 

13. Does the submittal contain a compilation of public comments and the State’s response? Provide additional 

explanation (if necessary). 

 Yes 

 No X 

This was not submitted yet because the state is asking the U.S. EPA for parallel processing of the 

supplemental SIP information and the public hearing has not yet occurred. This can be provided after the 

conclusion of the public hearing and comment period. 

Technical Issues 

14. Name all the regulated pollutants affected by the revision. 

Ammonia (NH3) 
3

15. Does the submittal identify the designation, status of the attainment plan and attainment date for the 

area(s)? Provide additional explanation (if necessary). 

 Yes X 

 No 

16. Does the submittal identify the location and types of affected sources? Provide additional explanation (if 

necessary). 

 Yes 

 No X 

Not applicable since this SIP submittal is not a rule. 

17. Does the submittal quantify the changes in SIP-allowable emissions and estimate or quantify the changes in 

actual emissions from affected sources? Provide additional explanation (if necessary). 

 Yes X 

 No 

NH3 emission inventories are presented for 2005, 2007, and 2018. 

18. Has the State demonstrated that the NAAQS/PSD Increment/RFP demonstration/visibility will be protected 

if the revision is approved and implemented? Provide additional explanation (if necessary). 

 Yes X 

 No 

19. Has the State provided modeling information to support the revision. 

Yes 

 No 

 Unnecessary X 

20. Has the State provided evidence that emission limitations are based on continuous emission reduction 

technology? Provide additional explanation (if necessary). 

 Yes 

 No X 

Not applicable. 

21. Has the State provided evidence that the revision contains emission limitations, work practice standards 

and record keeping/reporting requirements where necessary, to ensure emission levels? Provide additional 

explanation (if necessary). 

 Yes 

 No X 

Not applicable. 
4

22. Does the submittal contain enforcement/compliance strategies including how compliance will be 

determined in practice, and at what frequency? Provide additional explanation (if necessary). 

 Yes 

 No X 

Not applicable. 
5

STATE APPROVABILITY CHECKLISTENFORCEABILITY 

USEPA USE ONLY 

SIP Package Number ___________ 

Date Received by USEPA ________________ 

Date Due_____________________________ 

State: WISCONSIN 
6

WDNR Information 

Subject Matter: Ozone Redesignation Request and Maintenance Plan for the MilwaukeeRacine Nonattainment Area and the Sheboygan County Nonattainment Area 

Applicability 

USEPA Question USEPA Requirement State Response 

What sources are being 

regulated? Clear discussion No sources are being regulated under the SIP 

submittal. This is not a rulemaking. 

What are criteria for 

exemption? Clear discussion This is not applicable to this SIP submittal. 

Is calculation procedure 

for exemption clearly 

specified? 

Supply example calculation or 

clear explanation of how to 

determine exemption (line by 

line, etc.) 

This is not applicable to this SIP submittal. 

Is emission inventory 

listed in the background 

document of the 

attainment demonstration? 

Inventory including allowable 

and actual emissions in source 

category should be included, for 

enforcement purposes and 

independent of any Clean Air 

Act requirements, in the 

attainment demonstration if 

such data is necessary for 

determining baselines in 

regulations. 

Yes. Wisconsin is submitting 2005, 2007, and 

2018 NH3 emission inventories as part of this 

SIP submittal. 

Is the averaging time(s) 

used in the rule different 

from that of the ambient 

standard? 

The averaging time in the rule 

must be consistent with 

protecting the ambient standard 

in question. Normally, it should 

be equal to or shorter than the 

time associated with the 

standard. Longer term 

averaging is available only in 

limited instances provided that 

the ambient standard is not 

compromised. 

This is not applicable to this SIP submittal. 

What are the units of 

compliance (lbs VOC per 

gallon of solids applied 

less water, grains per 

standard cubic foot?) 

Clearly stated in the rule. This is not applicable to this SIP submittal. 
7

USEPA Question USEPA Requirement State Response 

Is bubbling or averaging 

of any type allowed? If 

yes, state criteria. Could a 

USEPA inspector 

independently determine 

if the criteria were met?? 

Does USEPA have to 

approve each case? 

Explicit description of how 

averaging, bubbling, or 

equivalency is to be determined. 

VOC equivalency must be on a 

“solids applied” basis. Any 

method must be independently 

reproducible. Provision must 

be explicit as to whether 

USEPA case-by-case approval 

is required. If provision 

intended to be “generic” then 

USEPA bubble policy must be 

met. 

This is not applicable to this SIP submittal. 

If there is a redesignation, 

will this change the 

emission limitations? If 

yes, which ones and how? 

Regulation may not 

automatically allow for self 

nullification upon redesignation 

of area to attainment. New 

maintenance demonstration 

required to order to drop 

regulation. 

This is not applicable to this SIP submittal. 

This is not a rulemaking. 

Compliance Dates 

USEPA Question USEPA Requirement State Response 

What is the compliance 

date? 

The compliance date must not 

be later than the approved or 

about to be approved date of 

attainment unless emission 

reductions are not necessary for 

attainment. In some cases, it 

will be necessary for the 

regulation to specify dates in 

compliance schedules that are 

required to be submitted by 

source to state. 

This is not applicable to this SIP submittal. 

This is not a rulemaking. 

What is the attainment 

date? Clearly defined. This is not applicable to this SIP submittal. 

This is not a rulemaking. 

Specificity of Conduct 

USEPA Question USEPA Requirement State Response 

What test method is 

required? 

Test method must be explicitly 

stated. This is not applicable to this SIP submittal. 

What is the averaging time 

in the compliance test 

method? 

Averaging time and application 

of limit must be explicit. This is not applicable to this SIP submittal. 

Is a compliance 

calculation or evaluation 

required? (i.e., daily 

weighted average for 

Clearly defined. This is not applicable to this SIP submittal. 
8

USEPA Question USEPA Requirement State Response 

VOC). 

If a compliance calculation 

is necessary, list the 

formula, period of 

compliance, and/or 

evaluation method. 

Formula must be explicit. This is not applicable to this SIP submittal. 

Incorporation by Reference

USEPA Question USEPA Requirement State Response 

What is the state authority 

for rulemaking. Clearly stated. This is not applicable to this SIP submittal. 

This is not a rulemaking. 

Are methods/rules 

incorporated by reference 

in the right manner? 

Clearly stated. This is not applicable to this SIP submittal. 

This is not a rulemaking. 

Recordkeeping

USEPA Question USEPA Requirement State Response 

What records are required 

to determine compliance? Clearly stated. This is not applicable to this SIP submittal. 

This is not a rulemaking. 

In what form or units 

(lbs/gal, gr/dscf, etc.) must 

the records be kept? On 

what time basis 

(instantaneously, hourly 

daily)? 

Records to be kept must be 

consistent with units of 

compliance in the performance 

requirements, including the 

applicable time period . 

This is not applicable to this SIP submittal. 

Does the rule affirmatively 

require the records be 

kept? 

There must be clearly defined 

and distinguishable from what 

constitutes a violation. 

This is not applicable to this SIP submittal. 

Exemptions

USEPA Question USEPA Requirement State Response 

List any exemptions 

allowed. 

Must be clearly defined and 

distinguishable from what 

constitutes a violation. 

This is not applicable to this SIP submittal. 

Is the criteria for 

application clear? Clearly stated. This is not applicable to this SIP submittal. 

Malfunction Provisions

USEPA Question USEPA Requirement State Response 

Are there any malfunction 

provisions in the rule? 

Rule must specify what 

exceedances may be excused, 

how the standard is to be 

applied, and who makes the 

determination. 

This is not applicable to this SIP submittal. 
9