Law Office of Robert Ukeiley 

435R Chestnut Street, Suite l o Berea, Kentucky 40403 o tel.859-986-5402 o fax.866-618-l 017 

VIA NEXT DAY MAIL- RETURN RECEIPT REQUESTED 

Dean Studer, Hearing Officer 

Illinois EPA 

1021 North Grand Avenue, East 

P.O. Box 19276 

Springfield, Illinois 62794-9276 

telephone number: 217/558-8280 

August 8, 2011 

Robert Ukeiley 

rukeiley@igc.org 

Darin Schroeder 

darin@airadvocates.net 

RE: Comments on State Implementation Plan {SIP) Submittals for the 

Chicago and Metro-East Ozone Nonattainment Areas and the 

Chicago PM2.5 Nonattainment Area 

Dear Hearing Officer Studer: 

On behalf of my client, Sierra Club, and their thousands of members who are 

adversely impacted from air pollution from the Chicago and Metro-East 

Nonattainment areas, I am writing to submit comments on Illinois EPA's draft 

Maintenance Plans for the Chicago and Metro-East Nonattainment Areas for the 

1997 ozone National Ambient Air Quality Standard (NAAQS) and the Chicago 

Nonattainment Area for the 1997 particulate matter less than 2.5 microns (PM2.5) 

NAAQS. We appreciate the opportunity to comment on these Plans to make sure 

they are as strong as possible as ozone and PM2.5 have a variety of very serious 

adverse impacts including triggering asthma attacks and causing premature 

mortality. 

I. INTRODUCTION 

The Illinois Environmental Protection Agency (IEPA) is holding a public 

comment period on three maintenance plans: (1) The Metro-East Plan for the 1997 

ozone NAAQS, (2) the Chicago Plan for the 1997 ozone NAAQS and; (3) the Chicago 
Hearing Officer Studer 

August 8, 2011 

Page2 

Plan for the 1997 PM2.5 NAAQS. These maintenance plans are a required part of 

IEPA's attempt to have these nonattainment areas re-designated to attainment. 

42 U.S.C. § 7407(d)(3)(E)(iv). 

There are several flaws in these maintenance plans which are described 

below. The most serious is that the Chicago and Metro-East SIPs may not be 

currently adequate to maintain compliance with the ozone NAAQS. 

I EPA should remedy these flaws in order to better protect the public 

from the harmful effects of PM2.5 and ozone. PM2.5 is "produced chiefly by 

combustion processes and by atmospheric reactions of various gaseous 

pollutants," thus "[ s]ources of fine particles include ... motor vehicles, 

power generation, combustion sources at industrial facilities, and residential 

fuel burning." 71 Fed. Reg. 61,144, 61,146 (Oct. 17, 2006). The effects of 

PM2.5 on humans are profound. For example, short-term exposure to PM2.5 

is associated with "premature mortality, hospital admissions or emergency 

department visits for respiratory disease, and effects on lung function and 

symptoms." 71 Fed. Reg. 2619,2627 Uan. 17, 2006). Furthermore, PM2.5 

adversely affects our natural surroundings. Regional haze is caused in part 

by particulates in the air scattering sunlight. EPA, Haze- How Air Pollution 

Affects the View (available at 

http:ljwww.epa.gov/ttn/oarpq/tl/fr notices/haze.pdf). 

Ozone, often referred to as smog, has numerous harmful effects on 

human respiratory systems which include inducing asthma attacks and 

aggravating chronic lung diseases like emphysema and bronchitis. EPA, 

Smog-Who Does it Hurt?, 2-3 (available at 

http:ljwww.epa.gov/air/ozonepollution/pdfs/smog.pdf). Long-term exposure 

may result in the permanent scarring of lung tissue. EPA, Ozone and Your 

Health, U.S. Environmental Protection Agency (available at 

http:ljwww.epa.gov/air/ozonepollution/pdfs/health.pdf). Ozone can be 

particularly harmful to adolescents, as exposure to ozone can also lead to 

"chronic, adverse effects on lung development in children from the age of 10 

to 18 years .... " See Gauderman, W. james, et al., The Effect of Air Pollution 

on Lung Development from 10 to 18 Years of Age, N. Engl. J. Med. 351:11, at 

1057 (Sept. 9, 2004). However, the greatest harm "may occur later in life, 

since reduced lung function is a strong risk factor for complications and 

death during adulthood." /d. at 1063. 

II. ANALYSIS 

A. CHICAGO OZONE MAINTENANCE PLAN 

The most fundamental flaw with the Chicago ozone maintenance plan 

is that it may not be adequate to maintain the NAAQS. According to the US 
Hearing Officer Studer 

August 8, 20 II 

Page 3 

EPA, for the 2008-2010 period: "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." Ex. 1 at ftnt 4. Thus, I EPA cannot prove that its current SIP is 

maintaining the 1997 ozone NAAQS in the Chicago nonattainment area. 

Therefore, I EPA cannot say that the current SIP will maintain the NAAQS in 

the future. 

In addition, Clean Air Act Section 110(1) prohibits the US EPA for 

approving any SIP revision that may interfere with another NAAQS. 42 U.S.C. 

§ 7410(1). However, IEPA has presented no analysis at all to establish that 

re-designating Chicago from nonattainment to attainment and the 

implementing the maintenance plan will not interfere with the 2008 ozone 

NAAQS of 75 ppb or the 2010 1-hour nitrogen dioxide NAAQS. Without this 

analysis, US EPA will not be able to approve these proposed SIP changes. 

According to IEPA, several monitors in the Chicago nonattainment area 

monitored violations in 2006-2008 of the 2008 75 ppb NAAQS. See Chicago 

Maintenance Plan at 12. Thus, the Clean Air Act 110(1) analysis is even more 

critical. 

I EPA claims that the 2006-2008 ozone design value was the result of 

permanent and enforceable emission limits. Maintenance Plan for the Illinois 

Portion of the Chicago Ozone Nonattainment Area for the 1997 8-Hour Ozone 

Standard (Revised) ("Chicago Ozone Maintenance Plan") at 5. This 

statement is not correct. Much of the emission reductions that influenced 

the 2006-2008 design value were from tne NOx SIP Call and later reductions 

were from the Clean Air Interstate Rule (CAIR). See Chicago Ozone 

Maintenance Plan at 15, 19. Emissions reductions from the NOx SIP Call and 

CAIR are not permanent and enforceable because the NOx SIP Call and CAIR 

are cap and trade programs which means sources can decrease and increase 

their emissions on a yearly basis and because the NOx SIP Call is no longer in 

place and CAIR has been vacated by the US Court of Appeals for the U.S. 

Court of Appeals for the District of Columbia Circuit. I EPA presents no 

analysis of whether emission reductions from the Cross State Air Pollution 

Rule will have the same effect on ambient ozone levels as the NOx SIP Call 

and CAIR. In addition, the Cross State Air Pollution Rule also allows some 

trading so its emission reductions cannot be considered permanent. 

Another flaw is that I EPA's future emission projections fails to consider 

US EPA's recent announcement that it is repealing the vapor capture 

requirements for gas stations. US EPA has been clear that this will increase 

emissions because not all cars have on-board capture systems. 

I EPA's projection of future emissions are based on an unsupported claim that 

on-road NOx will decrease dramatically. This ignores the reality that vehicle 

standards allow larger vehicles to emit more NOx in terms of mass emissions. 
Hearing Officer Studer 

August 8, 2011 

Page4 

Thus, I EPA's reliance on vehicle turnover is not supported by evidence which 

justifies the claimed reduction in mass NOx emissions. Furthermore, IEPA's 

emission calculations from on-road mobile sources fail to consider US EPA's recent 

decision to allow 15% ethanol in all gas. See Chicago Ozone Maintenance Plan at 

36. This increased use of ethanol at levels for which many cars and light trucks, 

and particularly their pollution control devices, were not designed to deal with will 

increase NOx and VOC emissions. I EPA does not account for this increase. 

IEPA acknowledges that ambient monitoring data must be available to 

the public. US EPA no longer makes ambient monitoring data available to 

the public on its web page. I EPA claim to the contrary on page 13 is simply 

no longer true. See http:ljwww.epa.gov/air/data/monvals.html?st-IL-IIIinois 

(no data after 2008). 

The Chicago Ozone Maintenance Plan also fails to consider climate 

change. "A maintenance plan must take into account the sort of things, such 

as population growth and changes to the industrial base, that might cause 

existing pollution-control measures to become inadequate in the future even 

if they served well in the past." Sierra Club v. EPA, 375 F.3d 537 (7'h cir. 

2004). Climate change is just the sort of thing that might cause existing 

pollution-control measures to become inadequate in the future even if they 

served well in the past. 

US EPA has admitted that weather influences ozone formation. See 72 

Fed. Reg. 44781; 72 Fed. Reg. 44778, 44779. Climate change, which we are 

indisputably experiencing, means that weather patterns in the future are 

going to be more conducive to ozone formation than weather patterns in the 

past. US EPA is well aware of this issue. US EPA has recently stated: 

The report, "Assessment of the Impacts of Global Change on Regional 

U.S. Air Quality: A Synthesis of Climate Change Impacts on GroundLevel Ozone," concludes that there is a potential for climate change to 

make ozone pollution worse in some regions and that future ozone 

management decisions may need to account for the possible impacts 

of climate change. 

EPA News Brief, April17, 2009, Climate Change Impacts on Regional Air 

Quality Report just Released by EPA. The Report is entitled: U.S. EPA. 

Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A 

Synthesis of Climate Change Impacts on Ground-Level Ozone (An Interim 

Report of the U.S. EPA Global Change Research Program). U.S. 

Environmental Protection Agency, Washington, DC, 

EPA/600/R-07 /094F, 2009. This report is available at 

http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=203459 and is 

incorporated herein by reference. 
Hearing Officer Studer 

August 8, 20 II 

Page 5 

US EPA's Report further found: 

These climate-induced increases, averaged over the summer season, 

were in the range of approximately 2-8 parts per billion (ppb) for 

Maximum Daily 8-hour Average 03 concentration, a key metric for 

regulating U.S. air quality. The climate sensitivity of 03 was greatest 

for the peak pollution episodes that tend to occur over a number of 

days each summer, resulting in substantially larger increases for these 

times than for the overall seasonal average. 

/d. at xix. 

US EPA went on to find: 

A subset of results also suggests that climate change effects on 03 

grow continuously over time, with evidence for significant impacts (in 

the same direction as described above) emerging as early as the 

2020s. For example, the Columbia research group (which simulated 

only the eastern half of the United States) found significant 

summertime 03 increases across broad swathes of the Midwest and 

Mid-Atlantic by the 2020s, with greater increases by the 2050s and 

2080s. 

/d. at xxiv (emphasis added). 

Also, relevant, EPA stated: 

Air quality managers may also need to plan to extend the season over 

which they monitor 03 concentrations and be prepared to issue air 

quality alerts earlier in the spring and later into the fall. 

!d. at xxv. The proposed Chicago Ozone Maintenance Plan does not propose 

such an extension of the monitoring season. 

Furthermore, an EPA-funded study by Knowlton and colleagues1 

utilized the Goddard Institute for Space Studies (GISS) Global Climate Model, 

in combination with the Penn State/National Center for Atmospheric 

Research Mesoscale Model 5, and the Community Multiscale Air Quality 

(CMAQ) model to simulate climate-induced changes in ozone levels for the 

1 Knowlton K, Rosenthal JE, Hogrefe C, Lynn B, Gaffin S, Goldberg R, Rosenzweig, Civerolo K, 

Ku J-Y, Kinney PL. 2004. Assessing ozone-related health impacts under a changing climate. 

Environ Health Perspect 112:1557-1563. doi:10.1289/ehp.7163 available via 

http://dx.doi.org/ 
Hearing Officer Studer 

August 8, 20 II 

Page6 

purposes of conducting a health impact analysis. This study demonstrates 

the feasibility of integrating global and regional climate models with 

models that are typically used by air quality managers for the purposes of 

evaluating compliance with air quality standards. IEPA has not done this. 

A study of the New York metropolitan region found a 4.5% increase in 

summertime ozone-related premature deaths in 2050 relative to the 1990s.2 

A second study projected increased ozone smog concentrations in suburban 

counties downwind of New York City, demonstrating the potential of climate 

change to spread adverse health effects well beyond the city limits. 3 A third 

study detailed climate change effects on future ozone levels in 50 eastern US 

cities, projecting a 68% increase in the number of days exceeding the 8-hour 

03 standard and increases in mortality and respiratory disease hospital 

admissions.• The Jacobson 2008 report also directly links increases in carbon 

dioxide to increased mortality, hospitalization, asthma and cancer rates. 

These studies are integral to a meaningful assessment of the impacts of 

climate change on ozone. Yet with regard to the Chicago Ozone 

Maintenance Plan, there has been no consideration of climate changes 

impacts on ozone, either as to formation or as to consequences. 

Failure to consider this important aspect of the problem would lead to an 

arbitrary result. Therefore, we request that IEPA re-evaluate the 

Maintenance Plan in light of the increasing danger climate change will cause 

from ozone. 

I EPA also provides for alternative measures which are not permissible under 

the Clean Air Act. The Maintenance Plan states: "Illinois EPA commits to keep 

these measures in effect after redesignation, or to provide equivalent emissions 

levels using alternate measures." Chicago Ozone Maintenance Plan at 18. 

However, the Clean Air Act does not allow for alternative measures. 

Finally, IEPA states: "The control measures identified in the RFP document, 

including those listed above, will result in a 15.7 percent reduction in VOM 

emissions from 2002 emissions levels by the year 2008." Chicago Ozone 

Maintenance Plan at 20. Now that year 2008 has passed, I EPA must prove that 

these reductions were actually achieved. 

2 Knowlton K. eta! (2004). 

3 Kinney P, Rosenthal j, Rosenzweig C, Hogrefe C, Solecki W, Knowlton K, Small C, Lynn B, 

Civerolo K, Ku j, Goldberg R, Oliveri C. 2006. Assessing potential public health impacts of 

changing climate and land uses: the New York Climate and Health Project. In: Regional 

Climate Change and Variability: Impacts and Responses (Ruth M, Donaghy K, Kirsh en P, 

eds.). Cheltenham(UK):Edward Elgar, 161-189. 

4 jacobson (2008). jacobson, MZ. 2008. On the casual link between carbon dioxide and air 

pollution mortality. Geophysical Research Letters. 3S: L03809. 
Hearing Officer Studer 

August 8, 20 II 

Page7 

B. METRO-EAST ST. LOUIS OZONE MAINTENANCE PLAN 

Like the Chicago Ozone Maintenance Plan, the most fundamental flaw 

with the Metro-East ozone maintenance plan is that it may not be adequate 

to maintain the NAAQS. According to the US EPA, for the 2008-2010 period, 

"( o]ne or more sites in this area has violated the NAAQS prior to 2008-2010 

and does not have a valid 2008-2010 design value." Ex. 1 at ftnt 4. Thus, 

IEPA cannot prove that its current SIP is maintaining the 1997 ozone NAAQS 

in the Metro-East nonattainment area. Therefore, IEPA cannot say that the 

current SIP will maintain the NAAQS in the future. 

In addition, Clean Air Act Section 110(1) prohibits the US EPA for 

approving: any SIP revision that may interfere with another NAAQS. 42 U.S.C. 

§ 7410(1). · However, I EPA has presented no analysis at all to establish that 

re-designating Metro-East from nonattainment to attainment and the 

maintenance plan will not interfere with the 2008 ozone NAAQS of 75 ppb or 

the 2010 1-hour nitrogen dioxide NAAQS. Without this analysis, US EPA will 

not be able to approve these proposed SIP changes. According to IEPA, 

several monitors in the Metro-East nonattainment area monitored violations 

in 2007-2009 of the 2008 75 ppb NAAQS. See Metro-East Ozone 

Maintenance Plan at 12. Thus, the Clean Air Act 110(1) analysis is even more 

critical. 

IEPA claims that the 2006-2008 ozone design value was the result of 

permanent and enforceable emission limits. Metro-East Ozone Maintenance 

Plan at 5. This statement is not correct. Much of the emission reductions 

that influenced the 2006-2008 design value were from the NOx SIP Call and 

later reductions were from the Clean Air Interstate Rule (CAIR). See MetroEast Ozone Maintenance Plan at 19. Emissions reductions from the NOx SIP 

Call and CAIR are not permanent and enforceable because the NOx SIP Call 

and CAIR are cap and trade programs which means sources can decrease 

and increase their emissions on a yearly basis and because the NOx SIP Call 

is no longer in place and CAIR has been vacated by the US Court of Appeals 

for the DC Circuit. I EPA presents no analysis of whether emission reductions 

from the Cross State Air Pollution Rule will have the same effect. In addition, 

this new rule also allows some trading so its emission reductions cannot be 

considered permanent. 

IEPA's emission projections appear to be inaccurate. There is no 

indication that the emission projections considered emissions from Prairie 

State Generating Station which should be in operation, and thus polluting, 

prior to 2015. 

The Metro-East Ozone Maintenance Plan suffers from many of the 

defects described above in Section II.A regarding the Chicago Ozone 
Hearing Officer Studer 

August 8, 2011 

Page 8 

Maintenance Plan. These include: (1) failing to consider increased emissions 

from US 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 make 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. We will not repeat the detailed explanation 

of these flaws provided above but for the reasons provided above I EPA must 

fix these defects. 

C. CHICAGO PM2.5 MAINTENANCE PLAN 

Similar to the ozone maintenance plans, I EPA claims that the Chicago 

2007-2009 PM2.5 design value was the result of permanent and enforceable 

emission limits. Maintenance Plan for the Chicago Nonattainment Area for 

the 1997 PM2.5 National Ambient Air Quality Standard (Revised) ("Chicago 

PM2.5 Maintenance Plan") at 5. This statement is not correct. Much of the 

emission reductions that influenced the 2007-2009 design value were from 

the NOx SIP Call and later reductions were from the Clean Air Interstate Rule 

(CAIR). See Chicago PM2.5 Maintenance Plan at 15. Emissions reductions 

from the NOx SIP Call and CAIR are not permanent and enforceable because 

the NOx SIP Call and CAIR are cap and trade programs which means sources 

can decrease and increase their emissions on a yearly basis and because the 

NOx SIP Call is no longer in place and CAIR has been vacated by the US Court 

of Appeals for the DC Circuit. I EPA presents no analysis of whether emission 

reductions from the Cross State Air Pollution Rule will have the same effect. 

In addition, this new rule also allows some trading so its emission reductions 

cannot be considered permanent. 

The Chicago PM2.5 Maintenance Plan also suffers from many of the 

defects described above in Section II.A regarding the Chicago Ozone 

Maintenance Plan. These include: (1) failing to consider increased emissions 

from US 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; and (3) failing to make ambient monitoring data 

available to the public. We will not repeat the detailed explanation of these 

flaws provided above but for the reasons provided above I EPA must fix these 

defects. 

Ill. CONCLUSION 

It is imperative from a public health and welfare point of view that IEPA 

correct the above flaws in its maintenance plans. If you have any questions 
Hearing Officer Studer 

August 8, 20 II 

Page 9 

about these comments, please do not hesitate to contact me. Otherwise, we 

look forward to I EPA improving its maintenance plans to ensure the health 

and welfare of millions of Illinois inhabitants. 

Sincerely, 

Robert Ukeiley 

Counsel for Sierra Club 
' . 

EXHIBIT 1 
Table1 

Table I. Design Values in Areas Previously Designated Nonattainment for the 1997 8-Hour Ozone NAAQS 

AQS Data Query: 6/27/2011 Last Updated: 7/12/2011 

2008-2010 s. 

Hour Ozone Clean Data 

EPA Designation Design Value Determination Redesignation Designated Area Region(s) Status' Classification' (ppm)'~ MetNAAQS? Date Date Albany·Schenectady-Troy, NY 02 Nonattainment Former Subpart 1 0.072 Yes 3/25/2008 Allegan 

Allentown-Bethlehem-Easton, 

Co, Ml OS Maintenance Former Subpart I 0.074 Yes 9/25/2010 9/24/2010 

Altoona, 

PA 03 Maintenance Fonner Subpart 1 0.076 Yes 3/4/2008 PA 03 Maintenance Former Subpart 1 0.070 Yes 811/2007 Amador & Calaveras Cos (Central Mtn), CA 09 Nonattainment Former Subpart 1 0.083 Yes Atlanta, GA 04 Nonattainment Subpart 2/Moderate 0.080 see footnote 4 Baltimore, MD 03 Nonanainment Subpart 2/Moderate 0.089 No Baton Rouge, LA 06 Nonattainment Subpart 2/Moderate O.o78 Yes 10112/2010 Beaumont-Port Arthur, TX 06 Maintenance Subpart 2/Moderate 0.074 Yes 10/20/2010 Benton Harbor, Ml 05 Maintenance Former Subpart I 0.071 Yes 5/16/2007 Benzie Co, Ml 05 Maintenance Former Subpart I 0.069 Yes 5/16/2007 Berkeley & Jefferson Cos, WV 03 ' Attainment Fonner EAC 0.070 Yes Birmingham, AL 04 Maintenance Former Subpart 1 0.075 Yes 5/12/2006 Boston-Lawrence-Worcester (E. Mass), MA 01 Nonattainment Subpart 2/Moderate 0,075 Yes 4118/2011 Boston-Manchester-Portsmouth (SE), NH 01 Nonattainment Subpart 2/Moderate 0.069 Yes Buffalo-Niagara Falls, NY 02 Nonattainment Former Subpart I 0.071 Yes 1/612010 Canton·Massillon, OH 05 Maintenance Fonner Subpart I 0.073 see footnote 4 5116/2007 CassCo, Ml 05 Maintenance Subpart 2/MarginaJ 0.070 Yes 5/16/2007 Charleston, WV 03 Maintenance Fonner Subpart l 0.069 Yes 7111/2006 Charlotte-Gastonia-Rock Hill, NC-SC 04 Nonattainment Subpart 2/Moderate 0.082 Yes Chattanooga, TN-GA 04 Attainment Former EAC 0,075 Yes Chicago-Gary-Lake County, IL-JN 05 Nonattainment Subpart 2/Moderate 0.074 see footnote 4 4/12/2010 Chico,CA 09 Nonattainment Former Subpart 1 0.079 Yes Cincinnati-Hamilton, OH-K Y-IN 05,04 Maintenance Fonner Subpart I 0.079 Yes 511112010 5111/2010 Clarkesville-Hopkinsville, TN-KY 04 Maintenance Fonner Subpart 1 0.069 Yes 1125/2006 Clearfield & Indiana Cos, PA 03 Maintenance Former Subpart 1 0.074 Yes 311912009 Cleveland-Akron-Lorain, OH 05 Maintenance Subpart 2/Moderate 0.077 Yes 9/15/2009 9115/2009 Columbia, SC 04 Attainment FonnerEAC 0.070 Yes Columbus, OH 

Dallas-Fort Worth, 

05 Maintenance Former Subpart I 0.077 Yes 9115/2009 9/15/2009 TX 06 Nonanainment Subpart 2/Serious 0.086 No Dayton·Springfield, OH 05 Maintenance Former Subpart 1 0,075 see footnote 4 8113/2007 Denver-Boulder-Greeley-Ft Collins-Loveland, CO 08 Nonattainment Former Subpart I 0.077 Yes Detroit-Ann Arbor, Ml 

Door 

05 Maintenance Subpart 2/Marginal O.o75 Yes 6129/2009 6/29/2009 

Erie, 

Co. WI 05 Maintenance Fonner Subpart I 0.073 Yes 7112/2010 7/12/2010 PA 03 Maintenance Former Subpart I 0.072 Yes 10/9/2007 Essex Co (Whiteface Mtn), NY 02 Non attainment Former Subpart 1 0.072 see footnote 4 1/6/2010 Evansville, IN 05 Maintenance Fonner Subpart 1 0.070 Yes 12129/2005 Fayetteville, NC 04 Attainment FormerEAC 0.071 Yes 

Page 1 
Table1 

Flint, Ml 05 Maintenance Fonner Subpart I 0.068 Yes 511612007 Fort Wayne, IN 05 Maintenance Former Subpart I 0.067 Yes 1/11/2007 Franklin Co, PA 03 Maintenance Fonner Subpart I 0.067 Yes 712512007 Frederick Co, VA 03 Attainment FormerEAC 0.068 Yes Fredericksburg, VA 03 Maintenance Subpart 2/Moderate 0.070 Yes 1212312005 Grand Rapids, Ml 05 Maintenance Fonner Subpart I 0.069 Yes 5/1612007 Greater Connecticut. CT 01 Nonattainment Subpart 2/Moderate O.Q78 see footnote 4 9/3012010 Greene Co, IN 

Greene 

05 Maintenance Former Subpart 1 0.071 Yes 11/14/2005 Co, PA 03 Maintenance Former Subpart 1 0.072 Yes 3/19/2009 Greensboro-Winston Salem-High Point, NC 04 Attainment Former EAC 0.076 Yes Greenville-Spartanburg-Anderson, SC 04 Attainment FonnerEAC 0.076 Yes Hancock, Knox, Lincoln & Waldo Cos, ME 01 Maintenance Former Subpart J 0.074 Yes 12/1112006 Harrisburg-Lebanon-Carlisle, PA 03 Maintenance Former Subpart I 0.073 Yes 7125/2007 Haywood and Swain Cos (Great Smoky NP), NC 04 Maintenance Former Subpart I 0.072 Yes 12/712009 Hickory-Morganton-Lenoir, NC 04 Attainment FormerEAC 0.070 Yes Houston-Galveston-Brazoria, TX 06 Nonattainment Subpart 2/Scvere 15 0.084 see footnote 4 Huntington-Ashland, 

Huron 

WV -K Y 03,04 Maintenance Former Subpart I 0.070 Yes 813/2007 Co, Ml 05 Maintenance Former Subpart I 0.067 Yes 5116/2007 Imperial Co, CA 09 Nonattainment Subpart 2/Moderate O.o78 Yes 1/412010 Indianapolis, IN OS Maintenance Fonner Subpart I 0.073 Yes 10/19/2007 Jackson Co, IN 05 Maintenance Former Subpart I 0.067 Yes 11114/2005 Jamestown, NY 02 Nonattainment Fonner Subpart I 0.077 Yes 1/612010 Jefferson Co, NY 02 Nonattainment Subpart 2/Moderate 0.072 Yes 3/25/2008 Johnson City-Kingsport-Bristol, TN 04 Attainment Former EAC 0.071 Yes Johnstown, PA 03 Maintenance Former Subpart 1 0.067 Yes 8/112007 Kalamazoo-Battle Creek, Ml 05 Maintenance Former Subpart 1 0.069 Yes 5/16/2007 Kent & Queen Anne's Cos, MD 03 Maintenance Subpart 2/Marginal O.Q75 Yes 12122/2006 Kern Co (Eastern Kern), CA 09 Nonattainment Former SubpaJ1 1 0.083 Yes Kewaunee Co, WI 05 Maintenance Former Subpart I 0.071 Yes 5/21/2008 Knoxville, TN 04 Maintenance Former Subpart 1 0.077 see footnote 4 10/1212010 318/2011 La Porte, IN 05 Maintenance Subpart 2/Marginal 0.065 Yes 7/19/2007 Lancaster, PA 03 Maintenance Subpart 2/MarginaJ 0.077 Yes 7/6/2007 Lansing-East Lansing, MI 05 Maintenance Former Subpart I 0.068 Yes 5/1612007 Las Vegas, NV 09 Non attainment Fonner Subpart I 0.076 Yes 5/3112011 Lima,OH 05 Maintenance Former Subpart I 0.070 Yes 5/16/2007 Los Angeles South Coast Air Basin, CA 09 Nonattainment Subpart 2/Extreme 0.112 No Los Angeles-San Bernardino Cos (W. Mojave), CA 09 Nonattainment Subpart 2/Severe 15 0.099 No Louisville, 

Macon,GA 

KY-IN 04,05 Maintenance Former Subpart I O.Q75 Yes 7/19/2007 04 Maintenance Fonner Subpart I 0.073 Yes 9/1912007 Madison 

Manitowoc 

& Page Cos (Shenandoah NP), VA 03 Maintenance Former Subpart I 0.073 Yes 1/312006 Co, WI 05 Maintenance Former Subpart I 0.073 Yes 7/1212010 7/1212010 Mariposa & Tuolumne Cos (Southern Mtn), CA 09 Non attainment Former Subpart I 0.083 Yes MasonCo,MJ 

Memphis, 

05 Maintenance Fonner Subpart I 0.068 Yes 5/1612007 TN-AR 

Milwaukee-Racine, WI 

04,06 Maintenance Subpart 2/Moderate 0.076 Yes 3/24/2010 05 Nonattainment Subpart 2/Moderate 0.074 see footnote 4 3/3112011 Muncie, IN 

Murray 

05 Maintenance Fonner Subpart I 0.065 Yes 11/16/2005 Co (Chattahoochee NF), GA 04 Maintenance Former Subpart I 0.073 Yes 10/16/2007 

Page2 
Table1 

Muskegon, MI 05 Maintenance Subpart 2/Marginal 0.074 Yes 5/16/2007 Nashville, TN 04 Attainment FormerEAC 0.076 Yes Nevada Co (Western part), CA 09 Nonattainment Former Subpart I 0.084 Yes New York-N. New Jersey-Long Island, NY -NJ-CT 02,01 Nonattainment Subpart 2/Moderate 0.084 see footnote 4 Norfolk-Virginia Beach-Newport News (HR), VA 03 Maintenance Subpart 2/Marginal 0.072 Yes 611/2007 Parkersburg-Marietta. WV-OH 03,05 Maintenance Fonner Subpart I 0.073 Yes 5/16/2007 Philadelphia-Wilmington-Atlantic City, PA-NJ-MD-DE 03,02 Nonattainment Subpart 2/Moderate 0.083 see footnote 4 Phoenix-Mesa, AZ 09 Nonattainment Former Subpart I 0.077 Yes Pittsburgh-Beaver Valley, PA 03 Nonattainment Former Subpart I 0.081 Yes Portland, ME 01 Maintenm1ce Subpart 2/Marginal 0.072 Yes 12/11/2006 Poughkeepsie, NY 02 Nonattainment Subpart 2/Moderate O.o75 Yes 116/2010 Providence (all ofRI), Rl 01 Nonattainment Subpart 2/Moderate 0.076 Yes 11/22/2010 Raleigh-Durham-Chapel Hill, NC 04 Maintenance Fonner Subpart I 0.074 see footnote 4 12/26/2007 Reading, PA 03 Maintenance Former Subpart I 0.079 Yes 8/24/2007 Richmond·Petersburg, VA 03 Maintenance Subpart 2/Marginal 0.076 Yes 6/1/2007 Riverside Co (Coachella Valley), CA 09 Nonattainment Subpart 2/Severe 15 0.095 No Roanoke, VA 03 Attainment Former EAC 0.069 Yes Rochester, NY 02 Nonattainment Former Subpart I 0.069 Yes 3/25/2008 Rocky Mount, NC 04 Maintenance Fonner Subpart 1 0.071 Yes 11/6/2006 Sacramento Metro, CA 09 Nonattainment Subpart 2/Severe 15 0.102 No San Antonio, TX 06 Attainment Former EAC O.D75 Yes San Diego, CA 09 Nonattainment Former Subpart 1 0.088 No San Francisco Bay Area, CA 09 Nonattainment Subpart 2/Marginal 0.080 Yes San Joaquin Valley, CA 09 Nonattainment Subpart 2/Extreme 0.104 No 

Scranton·Wilkes·Barre, PA 03 Maintenance Former Subpart 1 0.072 Yes 11/19/2007 Sheboygan, WI 05 Nonattainment Subpart 2/Moderate O.o78 see footnote 4 3/31/2011 South Bend-Elkhart, IN 05 Maintenance Fonner Subpart 1 0.064 Yes 7/19/2007 Springfield (W. Mass), MA 01 Nonattainment Subpart 2/Moderate 0.077 see footnote 4 

St. Louis, MO·IL 07,05 Nonattainment Subpart 2/Moderate 0.077 see footnote 4 7/11/2011 State College, PA 03 Maintenance Fonner Subpart 1 0.070 Yes 11114/2007 Steubenville· Weirton, OH·WV 05,03 Maintenance Former Subpart 1 0.073 Yes 5/16/2007 Sutter Co (Sutter Buttes), CA 09 Nonattainment Former Subpart 1 0.076 Yes Terre Haute. IN 05 Maintenance Former Subpart 1 0.063 Yes 1/5/2006 Tioga Co, PA 03 Maintenance Former Subpart I 0.070 Yes 7/6/2007 Toledo, OH 05 Maintenance Former Subpart 1 0.072 Yes 8/9/2007 Ventura Co, CA 09 Nonattainment Subpart 2/Serious 0.086 No 

Washington Co (Hagerstown), MD 03 Attainment Former EAC 0.072 Yes 

Washington, DC-MD· VA 03 Nonattainment Subpart 2/Moderate 0.081 see footnote 4 

Wheeling, WV -OH 03,05 Maintenance Former Subpart I 0.073 Yes 5116/2007 York, PA 03 Maintenance Former Subpart I 0.074 Yes 1/14/2008 Youngstown·Warren·Sharon, PA.QH 05,03 Maintenance Former Subpart I 0.074 Yes 10/19/2007 

Notes: 

1. Area classification and designation status as of April 27, 2011 

Page 3 
Table1 

2. The level of the 1997 BRhour ozone NAAQS Is 0.08 parts per million (ppm). The design value is the 3-year average of the annual fourth-highest dally 

maximum 8Rhour ozone concentration. 

3. The design values shown here are computed for the latest design value period using Federal Reference Method or equivalent data reported by 

State, Tribal, and Local monitoring agencies to EPA's Air Quality System (AQS) as of May 9, 2011. Concentrations flagged by State, Tribal, or Local 

monitoring agencies as having been affected by an exceptional event (e.g., wildfire, volcanic eruption) and concurred by the associated EPA Regional 

Office are not included in these calculations. 

4. 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. Although a 2008-2010 

design value Is shown, this design value may not represent the worst 2008-2010 air quality in the area. Consequently, we have not used it to indicate 

''Yes" or "No" in the "Met NAAQS?" column. 

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