**State of**  **Wisconsin**

**DEPARTMENT OF**  **NATURAL RESOURCES**  **101 S.**  **Webster Street**  **Box 7921**  **Madison WI**  **53707-7921**

**December 23,**  **2015**

**Dr. Susan**  **Hedman U.S.**  **Environmental Protection**  **Agency (EPA)** 

**- Region**  **5 77**  **West Jackson**  **Boulevard Mail**  **Code: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: Proposed**  **Revision to**  **the State**  **Implementation Plan**  **(SIP) for**  **the Milwaukee-Racine** 

**Waukesha County**  **Fine Particulate**  **(PM2.5) National**  **Ambient Air**  **Quality (NAAQS)**  **Area**

**Dear Regional**  **Administrator Hedman:** 

**The Wisconsin**  **Department of**  **Natural Resources**  **(WDNR) is**  **requesting approval**  **of the**  **enclosed revision**  **to the**  **motor vehicle emissions budgets**  **(MVEBs) for**  **the approved**  **Milwaukee- Racine- Waukesha**  **area maintenance**  **plan for**  **the 2006**  **24 -Hour**  **PM25 NAAQS.**  **The WDNR**  **is proposing**  **to allocate**  **a portion**  **of the**  **safety margin**  **for volatile**  **organic compounds**  **(VOCs) to**  **the area's**  **2020 and**  **2025 MVEBs**  **for transportation**  **conformity purposes.**  **This allocation**  **will still**  **maintain the**  **total emissions**  **for the**  **area at**  **or below**  **the attainment**  **level required**  **by the**  **transportation conformity regulations**  **while providing**  **for transportation**  **growth. The**  **transportation conformity**  **budget for**  **oxides of**  **nitrogen (NOx),**  **sulfur dioxide**  **(S02), and**  **direct PM**  **25 will**  **remain the**  **same as**  **the previously**  **approved MVEBs**  **in the**  **maintenance plan.** 

**In accordance**  **with ss.**  **285.11 (**  **5) and**  **( 6)**  **and ch.**  **NR 4 0**  **1, Wis.**  **Adm. Code,**  **the WDNR**  **collaborated with**  **the Wisconsin**  **Department of**  **Transportation (WisDOT),**  **the Southeast**  **Regional Planning**  **Commission (SEWRPC),**  **the EPA,**  **and the**  **Federal Highway**  **Administration (FHW**  **A) to**  **develop these**  **revised 2020**  **and 2025**  **MVEBs. These**  **MVEBs will**  **be used**  **to determine**  **conformity when**  **SEWRPC updates**  **its next**  **long term**  **transportation and**  **land use**  **plan in**  **the spring**  **of 2016.** 

**Should you**  **have any**  **questions or**  **comments on**  **this proposed**  **SIP revision,**  **please contact**  **Mike Friedlander**  **at (608)**  **267-0806 or**  **Michael.friedlander@wisconsin.gov. Thank**  **you for**  **your attention**  **to this**  **important air**  **quality matter.** 

**Sincerely,**

**Gail Good,**  **Director Air**  **Management Program** 

**dnr.wi.gov wisconsin.gov**  

### Naturally 

### WISCONSIN**cc: Pat**  **Stevens- AD/8**  **Aileen Switzer-**  **WisDOT Rebecca**  **Burkel**

**- WisDOT**  **Pat Trainer-**  **WisDOT Michael**  **Leslie**

**- USEPA**  **Christopher Bertch** 

**- FTA**  **Dwight McComb** 

**- FHW**  **A Christopher**  **Hiebert- SEWRPC** 

**Attachments**

**- Page**  **2**

**Attachment 1 -**  **WDNR Proposed**  **Revision to**  **the SIP**  **for the**  **2006 24**  **-Hour PM25**  **N AAQS**  **Maintenance Attachment**  **2- Public**  **hearing notice**  **for Proposed**  **Revision to**  **the SIP**  **for the**  **2006 24**  **-Hour PM2.5**  **NAAQS Maintenance**  **Area Attachment**  **3 - SIP**  **Revision Certification** 

## The State of Wisconsin’s Revision to the Motor Vehicle Emissions Budgets
Included in the Milwaukee

- Racine

- Waukesha County
Fine

- Particulate National Ambient Air Quality (NAAQS)
Maintenance Areas

Prepared by the Wisconsin Department of Natural Resources

September 201 5i



### Table of Contents

1. Introduction

................................ ................................ ................................ ................................ 1
2. Background and Purpose

................................ ................................ ................................ ........... 1 2.1 Fine Particulate Matter (PM 2.5 ) and Its Formation

................................ ............... 1 2.2 National Ambient Air Quality Standard for Fine Particulate Matter

...................... 1 2.3 Wisconsin’s 2006 PM 2.5 NAAQS Maintenance Area

................................ ........... 2 2.4 Transportation Conformity

................................ ................................ ..................... 4 2.5 Revised Motor Vehicle Emission Budgets for VOCs

................................ ............. 5
3. Public Participation

................................ ................................ ................................ .................... 6



### Figures and Tables
Figure 1 Wisconsin M aintenance Area under the 200 6 PM 2.5 NAAQS

Table 1 VOC Emissions Safety Margin under the 20 06 PM 2.5 Maintenance Plan

Table 2 Proposed Revised Motor Vehicle Emissions Budgets for VOCs1



### 1

. Introduction
This plan establishes revised motor vehicle emission budgets (MVEBs) for the 2006 PM 2.5 Milwaukee

- Racine

- Waukesha Maintenan ce Area

. The budgets are for VOC emissions for the year s 2020 and 2025 and would be used in Wisconsin’s regional transportation conformity determinations if they are approved by EPA

. The proposed revision s are consistent with continued maintenance of the 2006 PM 2.5 NAAQS and should be approved accordingly.



### 2

. Background and Purpose

2.1 Fine Particulate Matter (PM 2.5 ) and Its Formation
Particle pollution, also called particulate matter or PM, consists of solid particles or liquid droplets suspended in the air

. Fine particles (PM 2.5 ) may be emitted directly into the atmosphere but are more commonly created by reactions of other pollutants, such as nitrogen oxides (NO x ), sulfur dioxide (SO 2 ), organic carbon
, and ammonia

. Sources of the se precursor pollu tants include power plants, industries
, and automobiles

. Wind can carry these particles hundreds of miles from their sources

. PM 2.5 levels typically peak in winter but concentrations can also be high in summer.
Exposure to these fine particles and drople ts can cause serious health problems in humans, especially those with respiratory conditions such as asthma and cardiac disease

. PM 2.5 pollution scatters light and is the major cause of reduced visibility in the United States

. Many fine particles can als o cause acid rain and make lakes and streams more acidic

. Deposition of nitrogen

- containing particles may change the nutrient balance in lakes and rivers, affecting the diversity of ecosystems or damaging forests or crops

. In addition, particle pollution can damage statues, monuments , and buildings made of stone and other materials.
To reduce particle pollution, state and federal regulations target NO x and SO 2 emissions from pow er plants and industrial combustion sources

. Additionally, mobile source control programs help reduce organic carbon and NO x emissions through low

- emission vehicles and cleaner gasoline.

2.2 National Ambient Air Quality Standard for Fine Particulate Matte r

The Clean Air Act requires the U.S

. Environmental Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS) for pollutants considered harmful to public health and the environment

. There are two categories of NAAQS

. The primary stan dards establish limits to protect public health, and the secondary standards protect against environmental and welfare2

effects such as decreased visibility and damage to crops, animals, and buildings

. Currently, there are six pollutants with established NAAQS: carbon monoxide, lead, particulate matter (PM 10 and PM 2.5 ) , sulfur dioxide, nitrogen dioxide, and ozone

. These pollutants are referred to as “criteria” pollutants

. If an area violate s a standard, it is classified as a nonattainment area for that s pecific pollutant

. The states and/or tribes responsible for the affected area must then develop and implement strategies and control measures to attain the NAAQS

. The objective for designated nonattainment areas is to be reclassified to attainment by the EPA.

The NAAQS for fine particulate matter (PM 2.5 ) was established in 1997

. A primary and secondary 24

- hour standard was set at 65 μg/m 3 (micrograms per cubic meter of air), measured as the 98 th percentile concentration averaged over three years . P rimar y and secondary annual standard s were set at 15.0 μg/m 3 , measured as the annual arithmetic mean averaged over three years

. The CAA requires that the EPA carry out a periodic review of the NAAQS for the criteria pollutants

. The EPA reviewed the PM 2.5 NAAQS during the 2000s and determined based on the latest health studies that the 24

- hour standard must be strengthened to ensure protection of public health

. The updated standard of 35 μg/m 3 was finalized in October
, 2006

. In 2012, the EPA strengthened t he primary annual PM 2.5 standard to 12 μg/m 3 , but retained the secondary standard of 15.0 μg/m 3 and the 2006 24

- hour standard of 35μg/m 3

.

2 .3 Wisconsin’s 2006 PM 2.5 NAAQS Maintenance Area

Milwaukee, Racine, and Waukesha counties constitute Wisconsin’s 2006 PM 2.5 NAAQS maintenance area (Figure 1)

. In 2009, EPA determined that these counties were not meeting the 2006 24

- hour PM 2.5 standard. The nonattainment designation for the three

- county area in Wisconsin was established in a fin al rule published on November 13, 2009.

In June 2012, the Wisconsin Department of Natural Resources (W DNR ) submitted a request to EPA to redesignate the three counties from nonattainment to attainment based on monitoring data collected between 2008 and 2011

. The data showed that PM 2.5 concentrations were no longer exceeding the levels of the standard

. Measurements since 2011 continue to show attainment of the standard in the three

- county area as well as the rest of the state.
In light of a court decision ( Natural Resources Defense Council v. EPA )
, EPA requested that states, including Wisconsin, supplement their redesignation requests with additional information. DNR submitted this information in the fo llowing document: Supplemental Information for a June 2012 Redesignation Request and Maintenance Plan for the 24

- Hour Fine Particulate Matter National Ambient Air Qual ity Standard

.3

Figure 1

. Wisconsin Maintenance Area under the 2006 PM 2.5 NAAQS4

On February 18, 2014, EPA published a proposed rule to redesignate the three counties to attainm ent and approve all parts of Wisconsin's maintenance plan , the plan demonstrating how the state will ensure continued attainment of the PM 2.5 standard. On April 22, 2014, EPA published its final approval of the redesignation

.

2 .4 Transportation Conformity
Transportation conformity is required under CAA section 176 (c) (42 U.S.C 7506(c)) to ensure that federally funded or approved highway and transit activities are consistent with

– or “conform to”

– the purpose of the state air quality implementation plan ( SIP)

. “Conform to” the purpose of the SIP means that transportation activities will not cause or contribute to new air quality violations, worsen existing violations, or delay timely attainment of the relevant NAAQS or any interim milestones

. Transportat ion conformity applies to designated nonattainment and maintenance areas for transportation

- related criteria pollutants: ozone, PM 2.5
, PM 10 , carbon monoxide, and nitrogen dioxide

. EPA’s transportation conformity rule (40 CFRR Parts 51 and 93) establishes the criteria and procedures for determining whether metropolitan transportation plans, metropolitan transportation improvement programs, federally supported highways projects, and federally supported transit projects conform to the SIP.

The m aintenance pla n established motor vehicle emissions budgets (MVEBs) for volatile organic compounds (VOCs), sulfur dioxide ( SO 2 ), oxides of nitrogen (NO x ), and fine particulate matter (PM 2.5 ) for the years 2020 and 2025 for use in conducting transportation conformity det erminations

. These budgets were developed based on key motor vehicle parameters that reflect the most recent planning assumptions , such as vehicle age distribution, vehicle fuel inspection requirements, and maintenance plan requirements

. The transportat ion conformity rules require that planning assumptions are “current
, ” which

means no older than five years in the case of vehicle age distribution

. During the update of the dataset to the year 2014, the WDNR, Wisconsin Department of Transportation ( WisDOT ), and Southeastern Wisconsin Regional Planning Com m ission (SEWRPC) noted a significant reduction in the purchase of new motor vehicles beginning in 2008, reflecting the national economic recession

. This decrease in new car sales resulted in an increase i n the average age of the vehicle fleet as motorists continued to drive their vehicles longer

. Incorporating the 2014 vehicle age distribution in the MOVES2014 model resulted in an increase in projected emissions

. During the most recent conformity determi nation for the SEWRPC region, WDNR determined that the difference between the forecast ed VOC emissions for the transportation plan and the VOC MVEB was only 2 percent

. Another factor potentially affecting motor vehicle emissions estimates is the travel activity outputs from SEWRPC’s travel demand model

. These model outputs include miles and hours of vehicle travel, categorized by time of day, speed, vehicle type, and facility type

. A number of5

factors unrelated to changes in the region’s transportatio n plan and program can affect the model output

. Thus, changes can occur in emission estimates that do not reflect an actual change in the region’s emissions

. Such model changes include:

• Updated version of the model software;

• Changes to the network coding outside the region, reflecting choice of which roads to include in the model rather than changes to the actual road network;

• Changes in input file generation methods; and

• Changes in modeling methods, such as changes to traffic analysis zones ( e.g. , splitt ing or combining zones)

. Due to the emissions impact of the recent changes in vehicle age distribution, as well as potential variability in travel demand model outputs, the WDNR proposes to revise the MVEBs for VOCs by allocating safety margin emissions to the budgets , as described in the following section

. The MVEB revisions will facilitate transportation conformity determinations for the Milwaukee

Racine

- Waukesha area while remaining consistent with maintenance of the 2006 PM 2.5 standard

.

2.5 Revised Motor Vehicle Emission Budgets for VOCs
One of the critical components of a maintenance plan is the comparison of the area’s emissions in the attainment year to those projected for the final year of the maintenance plan

. Table 1 compare s the 2006 PM 2.5 M ilwaukee

- Racine

- Waukesha Maintenance Plan ’s attainment year total VOC emissions from point, area
, and mobile sources to the emissions projected for the year 2025

. The difference between the two values is referred to as a “safety margin

. ”

Table 1
VOC Emis sions Safety Margin under the 20 06 PM 2.5 Maintenance Plan

2010 Attainment Year Emissions (tons per winter day) 2025 Final Year Emissions Projection (tons per winter day) Total Safety Margin

(tons per winter day)
127.4 106.7 20.7

The EPA transportation conformity regulations (40 CFR 93.124) allow for the use of some or the entire safety margin in the development of MVEBs for maintenance plans (58 FR 62188)

. As indicated in Table 1, VOC emissions are projected to be 20.7 tons per d ay lower in 2025 than 2010 . The WDNR proposes to allocate a portion of the safety margin to the year 2020 and 2025 MVEBs established in the maintenance plan, as shown in Table 2 below.6

Table 2 Proposed Revised Motor Vehicle Emissions Budgets for VOCs

Emi ssion Budget Year Approved Emission Budget (tons per winter day) Proposed Allocation of Safety Margin (tons per winter day) Proposed Revised Emission Budget (tons per winter day)
2020 15.890 2

. 384 1 8 .2 74
2025 11.980 1.798 13.778



### 3

. Public Participation

In accordance with section 110(a) (2) of the CAA, the WDNR is required to hold a public hearing prior to the adoption of this plan and subsequent submittal to the EPA

. The Department will notify the public and other interested parties of an upcoming public hearing and public comment period 14 days prior to holding the hearing as follows:
Notice of availability of the Revision to the Motor Vehicle Emissions Budgets Included in the Milwaukee

- Racine

- Waukesha County Fine

- Particulate National Ambi ent Air Quality (NAAQS) Maintenance Areas was posted on the WDNR Air Management website on September 29 , 201 5 : http://dnr.wi.gov/topic/AirQuality/Input.html

• The public hearing was scheduled for October 9, 2015 beginning at 1:30p.m

. at the Wisconsin Department of Natural Resources Building, Conference Room 713, 101 South Webster Street, Madison, WI 53707

.

• The public comment period for the plan opened when it was posted on the Wisconsin Department of Natural Resources Air Management website on September 2 9 , 2014, and closes on October 2 8 , 201 5
, 19 d ays after the public hearing.BEFORE THE DEPARTMENT OF NATURAL RESOURCES
Notice of Public Hearing R evision to the Wisconsin State Implementation Plan (SIP) P roposal to Adjust the Motor Vehicle Emissions Budgets (MVEB) For the Milwaukee

- Racine

- Waukesha 2006 24

- Hour Fine Particulate Maintenance 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 (WDNR) will hold public hearing on its proposed adjustment to the MVEB for or the Milwaukee

- Racine

- Waukesha

m aintenance a rea for the 2006 24

- hour National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5 ).

Date and Time Location October 9 , 2015 State Natural Resources Building ( GEF II ) 1:30 PM Room 713 101 South Webster Street Madison, Wisconsin 53703

R easonable accommodations or informational ma terial in an alternative format will be provided for qualified individuals with disabilities upon request. To do so, make a request to M r

. Mike Friedlander using the contact information provided below. A request must include specific information and be received at least 10 days before the date of the scheduled hearing.
Availability of the Proposed SIP Documents Background information and proposed documents related to the proposed adjustment to the MVEB for Milwaukee

- Racine

- Waukesha m aintenance plan can be downloaded at http://dnr.wi.gov/topic/AirQuality/Input.html or hard copies, free of charge, by contacting M r

. Mike Friedlander below.
Background The U.S. Environmental Protection Agency (EPA) approved Wisconsin’s request to redesignate the Milwaukee

- Racine

- Waukesha nonattainment area to attainment for the 2006 24

- hour NAAQS for fine particulate on April 22 , 201 4 [ 7 9 FR 22415 ]. This redesignation approval established transportation conformity M VEB for the years 2020 and 2025. The maintenance plan revision establishes new Volatile Organic Compound (VOC) MVEB for the year s 20 20 and 2025 . The Department is proposing the allocation of a portion of the safety margin for VOCs to the area’s 20 20 and 2025 MVEB for transportation conformity purposes. This allocation will still maintain the total emissions for the area at or below the attainment level required by the transportation conformity regulations while providing for transportation growth. The tr ansportation conformity budget for oxides of nitrogen (NO x ), Sulfur Dioxide (SO 2 ), direct PM 2.5 will remain the same as the previously approved MVEB in the maintenance plan.
Action Subject to Comment The Department is soliciting comment on all elements regarding to the proposed adjustment to the MVEB for or the Milwaukee

- Racine

- Waukesha m aintenance a rea for the 2006 24

- hour National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2 .5 ).
Agency Contact and Submitting Comment Comments on the proposed MVEB adjustment for Milwaukee

- Racine

- Waukesha m aintenance plan should be received on or before October 2 8
, 2015. Written comments may be submitted by U.S. mail, fax, or email and will have the same weight and effect as oral statements presented at the public hearing.Questions or requests related to the hearing and written comments or questions on the proposed maintenance plan adju stment SIP should be submitted to:

M r

. Mike Friedlander Department of Natural Resources Bureau of Air Management (AM/7) 101 S. Webster Street, P.O. Box 7921, Madison WI 53703

- 7921 Phone: (608) 26 7

- 0806 Fax: (608) 266

- 0560 E

- mail: Michael.friedlander@wisconsin.gov

Dated at Madison, Wisconsin _

_ 09 / 22 /2015

_____ _________ _________

STATE OF WISCONSIN DEPARTMENT OF NATURAL RESOURCES

By

- /s/ Andrew M. Stewart Andrew M. Stewart Deputy Director Bureau of Air Management1 DATE: December 22, 2015

TO: File

FROM: Mike Friedlander, AM/7
SUBJECT: Revision to the Wisconsin State Implementa tion Plan (SIP); Proposal to Adjust the Motor Vehicle Emissions Budgets (MVEBs) for th e Milwaukee-Racine-Waukesha 2006 24-Hour Fine Particulate Maintenance Area

This memo confirms that the Wisconsin Department of Natural Resources (WDNR) held a public hearing on October 9, 2015 at 1:30 PM in the State Natura l Resources Building, Room 713, 101 South Webster Street, Madison, WI 53703. The WDNR solicited co mments regarding the proposed adjustment to the MVEB for the Milwaukee-Racine-Waukesha maintena nce area for the 2006 24-hour National Ambient Air Quality Standard (NAAQS) for fine particulate matter (PM 2.5 ).
The public comment period for the proposed adjust ment to the MVEB for the Milwaukee-RacineWaukesha maintenance area for the 2006 24-hour PM 2.5 NAAQS closed on October 28, 2015. No public comments were received during the public comment period. 

### State of Wisconsin 

### CORRESPONDENCE/MEMORANDUM