State of Wisconsin 

DEPARTMENT OF NATURAL RESOURCES 

101 S. Webster Street 

Box 7921 

Madison WI 53707-7921 

June 5, 2012 

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: Redesignation Request for Fine Patticulate Matter (PM25 ) 

Dear Ms. Hedman: 

The Wisconsin Depattment of Natural Resources (WDNR) hereby submits a redesignation request for the counties of 

Milwaukee, Racine and Waukesha for the 2006 PM2.5 National Ambient Air Quality Standard (NAAQS). The 

Depattment is happy to report that all counties in Wisconsin measured attainment of the PM2.5 NAAQS from 2008 

through 2010 and continue to measure attainment. 

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. The WDNR conducted a public hearing on May 7, 2012. 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. Ifyou have any questions 

regarding this submittal, please feel free to call Joseph Hoch at 608-267-7543 or Ralph Patterson at 608-267-7546. 

Sincerely, 

c-2-;:-:: Air Management BUI~au Director 

Wisconsin Department of Natural Resources 

cc: Patrick Stevens - AD/8 

Joseph Hoch- AM/7 

Ralph Patterson - AM/7 

George Czerniak - U.S. EPA Region V (A-18J), 77 West Jackson Boulevard, Chicago, IL 60604 

John Mooney- U.S. EPA Region V (A-18J), 77 West Jackson Boulevard, Chicago, lL 60604 

Douglas Aburano - U.S. EPA Region V (AR-1 8J), 77 West Jackson Boulevard, Chicago, IL 60604 

Jacqueline Nwia- U.S. EPA Region V (AT-18J), 77 West Jackson Boulevard, Chicago, IL 60604 

dnr.wi.gov 

wisconsin.gov Naturally WISCONSIN PRINTED ON RECYCLED 

PAPER 
Page 2. 

Summary of Attachments: Hard Copy aud Electronic 

• EPA Region V SIP Submittal Checklist 

• Public Hearing Notice 

• Public Comments and Response to Comments 

• PM2.

5 Redesignation Request and Appendices 
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: June 5, 2012 

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 

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 X 

 No 

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

additional explanation (if necessary). 

 Yes X 

 No 

Technical Issues 

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

Oxides of nitrogen (NOx) 

Sulfur dioxide (SO2) 

Fine Particulate Matter (PM2.5) 

Ammonia (NH3) 

Volatile organic compounds (VOCs) 

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). 
3

 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 

 Maintenance emission inventories are presented for 2020 and 2025. 

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. 

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. 
4

STATE APPROVABILITY CHECKLISTENFORCEABILITY 

USEPA USE ONLY 

SIP Package Number ___________ 

Date Received by USEPA ________________ 

Date Due_____________________________ 

State: WISCONSIN 
5

WDNR Information 

Subject Matter: Ozone Redesignation Request and Maintenance Plan for the 

Milwaukee-Racine 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 several 

inventories as a part of this SIP submittal. In 

the redesignation request documents, the 2006 

inventory serves as the nonattainment year 

inventory. The 2010 inventory serves as the 

attainment year inventory. Attainment year 

(maintenance) inventories are included for 

2020 and 2025, demonstrating decreasing NOx, 

PM2.5, SO2 and VOC emissions in the future. 

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. 
6

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. 
7

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. 
PROPOSED 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 

June 2012 
i

Table of Contents

List of Appendices ii 

List of Tables iii 

List of Figures iv 

1.0 INTRODUCTION 1 

 1.1 Background 1 

 1.2 Geographical Description 1 

 1.3 Status of PM2.5 Air Quality 1 

 1.4 Redesignation Requirements 2 

2.0 FEDERAL CAA REQUIREMENTS 3 

 2.1 Satisfying CAA Section 110(a) General SIP Requirements 3 

 2.2 Satisfying CAA Part D Requirements 3 

 2.3 Fully Approved SIP Under Section 110(k) 4 

3.0 WISCONSIN PM2.5 MONITORING DATA 5 

 3.1 Deriving PM2.5 Attainment / Nonattainment 5 

 3.2 Nonattainment Area FRM PM2.5 Monitoring Network 5 

 3.3 Quality Assurance 6 

 3.4 Data Completeness 6 

 3.5 24-Hour PM2.5 98th Percentile and Design Value Concentrations 7 

 3.6 Nonattainment Area FRM PM2.5 Trends (1999 – 2010) 7 

4.0 EMISSIONS INVENTORY 8 

 4.1 Overview 8 

 4.2 Years of Inventoried Emissions 8 

 4.3 Temporally-Resolved Emission Estimates 11 

 4.4 Base Year Inventory (Nonattainment Year Inventory) 12 

 4.5 Attainment Year Inventory 14 

 4.6 Emission Projections and Demonstration of Maintenance 16 

 4.7 Permanent and Enforceable Emission Reductions 16 

 4.8 Provisions for Future Updates 17 

5.0 TRANSPORTATION CONFORMITY BUDGETS 18 

 5.1 Motor Vehicle Emissions Model 18 

 5.2 Motor Vehicle Emission Budget (MVEB) 18 

6.0 CONTROL MEASURES AND REGULATIONS 19 

 6.1 Federal Control Measures 19 

 6.2 State Control Measures 21 

7.0 MAINTENANCE PLAN 22 

 7.1 Maintenance Inventory Methodology (2020 and 2025) 22 

 7.2 Demonstration of Maintenance (Comparison of Emissions) 25 

 7.3 Verification of Continued Attainment 26 

 7.4 Contingency Plan 26 

 7.5 List of Potential Additional Control Measures 27 

 7.6 Commitment to Revise Maintenance Plan 27 

8.0 PUBLIC PARTICIPATION 28 

9.0 CONCLUSION 29 

10.0 REFERENCES 30 
ii

List of Appendices 

Appendix 1 – Wisconsin Infrastructure State Implementation Plan (SIP) submittal 

Appendix 2 – Fine Particulate Matter (PM2.5) Clean Data Finding 

Appendix 3 – An Analysis of Characteristics and Precursors to Ambient PM2.5 Levels Southeastern 

 Wisconsin 

Appendix 4 – 2006 and 2010 Point Source Emission Calculations 

Appendix 5 – 2006, 2010, 2020, and 2025 Area Source Emissions 

Appendix 6 – Summary of MOVES Onroad Emissions 

Appendix 7 – 2020 and 2025 Point Source Emissions 

Appendix 8 – 2009 – 2011 PM2.5 Monitoring Data 1

 

1

 Note: Non-certified, quality-assured 2011 PM2.5 monitoring data became available after this draft was completed. 

However, this data is included as an appendix to show the continued decrease in PM2.5 concentrations. 
iii

List of Tables

Table 1 – FRM PM2.5 Monitors – Milwaukee, Racine, and Waukesha Counties 

Table 2 – Percentage Completeness 

Table 3 – Annual 98th Percentile FRM PM2.5 Concentrations and 24-Hour PM2.5 Design Values 

Table 4 – Total NOx Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Table 5 – Total PM2.5 Direct Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Table 6 – Total SO2 Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Table 7 – Total VOC Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Table 8 – Total NOx Emissions for Attainment Year 2010 (Tons per Winter Day) 

Table 9 – Total PM2.5 Direct Emissions for Attainment Year 2010 (Tons per Winter Day) 

Table 10 – Total SO2 Emissions for Attainment Year 2010 (Tons per Winter Day) 

Table 11 – Total VOC Emissions for Attainment Year 2010 (Tons per Winter Day) 

Table 12 – MVEB for Milwaukee, Racine, and Waukesha (2020 and 2025) 

Table 13 – Post-2002 Federal Control Programs 

Table 14 – Post-2002 State Control Programs 

Table 15 – Total NOx Emissions for 2020 and 2025 (Tons per Winter Day) 

Table 16 – Total PM2.5 Direct Emissions for 2020 and 2025 (Tons per Winter Day) 

Table 17 – Total SO2 Emissions for 2020 and 2025 (Tons per Winter Day) 

Table 18 – Total VOC Emissions for 2020 and 2025 (Tons per Winter Day) 

Table 19 – NOx Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 

Table 20 – PM2.5 Direct Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 

Table 21 – SO2 Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 

Table 22 – VOC Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 
iv

List of Figures

Figure 1 – FRM PM2.5 Monitors – Milwaukee, Racine, and Waukesha Counties 

Figure 2 – Design Value Trends 

Figure 3 – Average Month-of-Year Speciated 24-Hour PM2.5 Concentrations 

Figure 4 – Average Month-of-Year Speciated 24-Hour PM2.5 Concentrations as Percentage 

Figure 5 – Month-of-Year Average 24-Hour PM2.5 Concentrations in Milwaukee 

Figure 6 – Month-of-Year Average 24-Hour PM2.5 Concentrations in Waukesha 
1

1.0 INTRODUCTION 

1.1 Background 

The federal Clean Air Act (CAA) requires areas failing to attain a National Ambient Air 

Quality Standard (NAAQS) for a specified criteria pollutant to develop or revise its State Implementation 

Plan (SIP) for that criteria pollutant to expeditiously attain and maintain the violated NAAQS in the area 

where the air quality nonattainment has occurred. When attainment of a NAAQS in a nonattainment area 

has been achieved, Section 107(d)(3)(E) of the CAA allows states to request the nonattainment area to be 

redesignated to attainment provided that certain criteria are met. 

In October 2006, the U.S. EPA promulgated a revision to the 24-hour fine particulate (PM2.5) NAAQS, 

based upon available health studies (71 FR 61144). The updated (i.e.,"2006") 24-hour PM2.5 NAAQS was 

made more restrictive - 35 μg/m3

, reduced from the 1997 standard of 65 μg/m3. In this action the U.S. 

Environmental Protection Agency (EPA) retained the original annual PM2.5 standard at15.0 μg/m3

. 

On November 13, 2009 the U.S. EPA published final rulemaking that established initial air quality 

designations for the 2006 PM2.5 NAAQS (74 FR 58688). This rulemaking, which was done in accordance 

with Section 107(d) of the CAA, was based upon the Agency’s review of PM2.5 measurements collected 

during the 3-year period 2006 - 2008. This rulemaking included the designation that the counties of 

Milwaukee, Racine, and Waukesha were in nonattainment of the 2006 24-hour PM2.5 NAAQS. 

Based on supporting information provided in this document, the Wisconsin Department of Natural 

Resources (WDNR) asks the U.S. EPA to redesignate the counties of Milwaukee, Racine, and Waukesha 

to attainment for the 2006 24-hour PM2.5 NAAQS. 

1.2 Geographical Description 

The counties of Milwaukee, Racine, and Waukesha are located in southeastern Wisconsin (Figure 1). 

Milwaukee and Racine Counties border along the western shoreline of Lake Michigan. The topography 

of Milwaukee, Racine and Waukesha Counties is predominantly flat. 

Milwaukee County is a relatively small county in area (242 square miles, [NACO, 2011]) – but is 

significantly urbanized. Its official year 2010 U.S. Census population of 947,735 (U.S. Census, 2011) 

makes it the State’s most populous county. The city of Milwaukee had an estimated year 2010 population 

of 594,833 (U.S. Census, 2011), which is the most populous city in Wisconsin. 

The counties of Waukesha and Racine are both adjacent to the heavily-urbanized Milwaukee County. 

Consequently, these counties also have fairly substantial populations according to the U.S. Census 

(2011): Waukesha County: 389,891, Racine County: 195,408. However, both Racine County (333 square 

miles, [NACO, 2011]) and Waukesha County (556 square miles, [NACO, 2011]) are noticeably larger in 

area than Milwaukee County. These two counties, relative to Milwaukee County, have more of a mixture 

of suburban and rural areas – as well as some urban areas. The cities of Waukesha and Racine are the 

largest cities in their respective counties. 

1.3 Status of PM2.5 Air Quality 

For Milwaukee, Racine, and Waukesha Counties, the fully-validated federal reference method (FRM)-

derived PM2.5 monitoring data for the most recent three years, 2008 - 2010, demonstrate that air quality 

levels have attained the NAAQS for 24-hour PM2.5. A more complete discussion of these monitoring data 

is contained in Section 3 of this document. 
2

The monitoring data, accompanied by the decrease in estimated emission totals of those air pollutants that 

contribute to PM2.5 levels, help justify a redesignation to attainment for these counties based on Section 

107(d)(3)(D) of the CAA. 

1.4 Redesignation Requirements 

Once attainment has been achieved for a PM2.5 nonattainment area, Section 107(d)(3)(E) of the CAA 

establishes that the following criteria must be met in order for an area to be considered for redesignation 

from nonattainment to attainment: 

1. A determination by the U.S. EPA that the area has attained the NAAQS. 

2. A fully approved SIP under CAA Section 110(k). 

3. A determination by the U.S. EPA that the improvement in air quality is due to permanent and 

enforceable reductions in emissions. 

4. A determination that all applicable requirements for the area under Section 110 and Part D of the 

CAA have been met. 

5. A fully approved maintenance plan, including a contingency plan, for the area under Section 

175(A) of the CAA. 

This document addresses each of these criteria in providing technical support to the WDNR’s request that 

the counties of Milwaukee, Racine, and Waukesha be redesignated from nonattainment to attainment of 

the 2006 24-hour PM2.5 NAAQS. Additional information to support continued compliance (i.e., 

maintenance) with respect to the 2006 24-hour PM2.5 NAAQS is also provided. 
3

2.0 FEDERAL CAA REQUIREMENTS 

As a precondition to redesignating a nonattainment area to attainment, the CAA requires the U.S. EPA to 

determine that the state has met all applicable requirements under section 110 and part D of Title I of the 

CAA (per CAA Section 107(d)(3)(E)(v)) and that the state has a fully approved SIP under Section 110(k) 

for the area (per CAA Section 107(d)(3)(E)(ii)). 

2.1 Satisfying CAA Section 110(a) General SIP Requirements 

Section 110(a) of the CAA contains the general requirements for a SIP. Section 110(a)(2) provides that 

the implementation plan submitted by a state must have been adopted by the state after reasonable public 

notice and hearing, and, among other things, must: 

 Include enforceable emission limitations and other control measures, means or techniques 

necessary to meet the requirements of the CAA; 

 Provide for establishment and operation of appropriate devices, methods, systems, and procedures 

necessary to monitor ambient air quality; 

 Provide for implementation of a source permit program to regulate the modification and 

construction of any stationary source within the areas covered by the plan; 

 Include provisions for the implementation of part C, Prevention of Significant Deterioration 

(PSD), and part D, New Source Review (NSR) permit programs; 

 Include criteria for stationary source emission control measures, monitoring, and reporting; and 

 Include provisions for air quality modeling; and provide for public and local agency participation 

in planning and emission control rule development. 

Wisconsin submitted an “infrastructure SIP” for the 2006 24-hour PM2.5 NAAQS to the U.S. EPA on 

January 24, 2011, with a supplemental submittal on March 28, 2011, demonstrating compliance with the 

CAA Section 110 requirements. This prior submittal is included in Appendix 1. 

2.2 Satisfying CAA Part D Requirements 

CAA Title I, Part D, Subpart 1 sets forth the basic nonattainment requirements applicable to all 

nonattainment areas. For the 2006 PM2.5 NAAQS, these requirements are due to be met by December 

2012. However, as stipulated in 40 CFR 51.1004(c), a “clean data finding” by the U.S. EPA suspends the 

requirements to submit an attainment demonstration and associated reasonably available control measures 

(RACM) (CAA Section 172(c)(1) and (c)(6)), reasonable further progress (RFP) requirements (CAA 

Section 172(c)(2)), contingency measures (CAA Section 172(c)(9)), and other planning SIP elements 

related to attainment for so long as the area continues to attain the NAAQS. 

Wisconsin submitted a clean data finding to the U.S. EPA on March 7, 2011. On December 15, 2011, the 

U.S. EPA notified the WDNR of their intention of proposing approval of the clean data finding in the 

Federal Register. As of March 29, 2012, the U.S. EPA had still not published the proposal. Wisconsin’s 

PM2.5 clean data finding and the U.S. EPA’s preliminary indication of approval is included in Appendix 2. 

The WDNR expects approval of this finding before December 2012. Furthermore, the WDNR anticipates 

approval of this redesignation request before that date as well. 
4

Section 172(c)(4) requires the identification and quantification of allowable emissions for major new and 

modified stationary sources in an area, and section 172(c)(5) requires source permits for the construction 

and operation of new and modified major stationary sources in the nonattainment area. Wisconsin has an 

approved new source review (NSR) program that meets these requirements. Furthermore, after 

redesignation, prevention of significant deterioration (PSD) requirements will apply and Wisconsin has an 

approved PSD program. 

Section 172(c)(7) requires the SIP to meet the applicable provisions of CAA Section 110(a)(2). As noted 

in the previous section, Wisconsin submitted an affirmation of meeting the Section 110(a) requirements to 

the U.S. EPA on January 24, 2011, with a supplemental submittal on March 28, 2011. 

Section 176(c) of the CAA requires states to establish criteria and procedures to ensure that federally 

supported or funded activities, including highway projects, conform to the air quality planning goals in 

the applicable SIPs. The requirement to determine conformity applies to transportation plans, programs, 

and projects developed, funded, or approved under Title 23 of the U.S. Code and the Federal Transit Act 

(transportation conformity) as well as to all other federally-supported or funded projects (general 

conformity). EPA interprets the conformity SIP requirements as not applying for purposes of evaluating a 

redesignation request under Section 107(d) because state conformity rules are still required after 

redesignation and federal conformity rules apply where state rules have not been approved. Section 5.0 of 

this document includes transportation conformity budgets that, upon approval by the U.S. EPA, will be 

required for use in future transportation planning efforts. 

The only remaining Part D, Subpart 1 element that must be addressed for the 24-hour PM2.5 NAAQS is 

the CAA Section 172(c)(3) requirement for an inventory of actual emissions for the area. An emissions 

inventory is presented in Section 4.0 of this redesignation request. When the U.S. EPA approves this 

inventory, Wisconsin will meet all of the applicable SIP requirements for the purposes of redesignation. 

2.3 Fully Approved SIP Under Section 110(k) 

Consistent with the previous U.S. EPA rulemakings, when the U.S. EPA issues final approval of this 

redesignation request, Wisconsin will have a fully approved SIP under CAA Section 110(k) for all 

requirements applicable for purposes of redesignation. 
5

3.0 WISCONSIN PM2.5 MONITORING DATA 

3.1 Deriving PM2.5 Attainment / Nonattainment 

The U.S. EPA's requirements for PM2.5 air monitoring data are contained in Appendix N to 40 CFR Part 

50 (“Interpretation of the National Ambient Air Quality Standards for PM2.5”). An FRM PM2.5

monitoring site that meets the data completeness requirements for the most recent three calendar years is 

considered to have attained the 24-hour PM2.5 NAAQS when the site’s most current 24-hour PM2.5 

design value (DV) concentration is less than or equal to 35 μg/m3

. 

The ambient PM2.5 concentrations used to determine attainment/nonattainment status are daily, integrated 

24-hour (calendar day) measurements of PM2.5 mass collected on Teflon filters. The PM2.5 mass is 

weighed and validated in accordance with the FRM requirements established by the U.S. EPA. 

The WDNR commits to operating a federally-approved FRM PM2.5 monitoring network to ensure that the 

PM2.5 NAAQS is maintained in all of Wisconsin. 

3.2 Nonattainment Area FRM PM2.5 Monitoring Network 

There were a total of five FRM PM2.5 monitoring sites operated by the WDNR in the PM2.5 nonattainment 

counties during the 2008 - 2010 period (Table 1, Figure 1). Each of these sites, individually or combined, 

met the completeness requirements detailed in Appendix N to 40 CFR Part 50 during this period. 

Table 1 - FRM PM2.5 Monitors – Milwaukee, Racine, and Waukesha Counties 

County AQS # Site Name Start Date 

Milwaukee 550790010 Milw-16th St. Health Ctr 05-Jan-1999 

Milwaukee 550790026 Milw-SER HQ 01-Jan-1999 

Milwaukee 550790058 Milw-College Ave 4 Nov 2009 

Milwaukee 550790059 Milw-FAA 3 Jan 1999 

Waukesha 551330027 Waukesha-Cleveland St. 03-Jan-1999 

The Milw-FAA site ceased operation on October 28, 2009. However, a week later, on November 4, 

2009, the Milw-College Ave site commenced monitoring. The College Ave site began collecting PM2.5

data on the first scheduled sampling date after the FAA site took its final PM2.5 measurement. The 

College Ave site is located approximately 2 miles directly south of the now-discontinued FAA site. Both 

locations are situated east of and within a couple hundred meters of the heavily-traveled north-south I-94 

corridor. Both sites are also located very close to Milwaukee’s Mitchell Field Airport and about 3 miles 

west of the Lake Michigan shoreline. Based upon this information, the U.S. EPA has approved the 

WDNR’s May 25, 2010 request that it be allowed to combine the FRM PM2.5 data from the MilwaukeeFAA and Milwaukee-College Ave sites for purposes of deriving a combined-site 24-hour PM2.5 design 

value for the 2008-10 period. 

The Milw-16th St. Health Ctr site is located in a mixed commercial-residential neighborhood near the 

southern edge of the industrialized Menomonee River Valley, approximately 2 miles south-southwest of 

Milwaukee’s downtown area and 3 miles west of Lake Michigan’s shoreline. The Milw-SER HQ (DNR 

Southeast Region Headquarters) site is situated in a mixed residential-commercial neighborhood 

approximately one mile north of Milwaukee’s downtown area 1.5 miles west of Lake Michigan. The 

Waukesha-Cleveland St. site is located in a mixed industrial and residential setting approximately 15 

miles west of Lake Michigan and 14 miles west of downtown Milwaukee. 
6

Figure 1 - FRM PM2.5 Monitors – Milwaukee, Racine, and Waukesha Counties 

3.3 Quality Assurance 

WDNR follows the fully-approved Wisconsin PM2.5 Quality Assurance Plan in accordance with 40 CFR 

58.10, to assure that the quality of the FRM PM2.5 monitoring data submitted to the U.S. EPA’s Air 

Quality System (AQS) met federal criteria. All validated FRM PM2.5 measurement data collected during 

2008 - 2010 for the nonattainment sites listed in Table 1 have been archived in U.S. EPA’s AQS. In 

addition, these full data sets have been certified and are available to the public. 

3.4 Data Completeness 

Table 2 shows that the annual percentage of FRM PM2.5 sampling success for each site-year in 

Wisconsin’s PM2.5 nonattainment area during 2008 - 2010. The data completeness at these FRM PM2.5

monitoring sites easily meet the U.S. EPA data completeness requirement (minimum acceptable: 75%) 

that is listed in Appendix N to 40 CFR Part 50. 

Table 2 - Percentage Completeness 

Site Name: 16th St. 

Health Ctr SER HQ College Ave / FAA Cleveland St. 

County: Milwaukee Milwaukee Milwaukee Waukesha 

Site ID #: 550790010 550790026 550790058/59 551330027 

FRM PM2.5 

sample schedule Every 3rd day Every 3rd day Every 6th day Every 3rd day 

2008 # of valid samples 119 119 60 117 

2008 % FRM PM2.5 

Data Completeness 98% 98% 98% 96% 

2009 # of valid samples 115 120 61 115 

2009 % FRM PM2.5 

Data Completeness 94% 98% 100% 94% 

2010 # of valid samples 112 171 57 121 

2010 % FRM PM2.5 

Data Completeness 92% 100% 93% 99% 
7

3.5 24-Hour PM2.5 98th Percentile and Design Value Concentrations 

Table 3 displays the final-validated 24-hour PM2.5 98th percentile and subsequent design value 

concentrations for the FRM PM2.5 sites in the nonattainment area during 2008 - 2010. All of the sites 

have 24-hour PM2.5 design values that are 2-3 μg/m3

 below the 24-hour PM2.5 NAAQS of 35 μg/m3

during this period. 

Table 3 - Annual 98th Percentile FRM PM2.5 Concentrations and 24-Hour PM2.5 Design Values 

Site Name: 16th St. 

Health Ctr SER HQ College Ave / FAA Cleveland St. 

County: Milwaukee Milwaukee Milwaukee Waukesha 

Site ID #: 550790010 550790026 550790058/59 551330027 

2008 98th%-ile Conc.: 27.3 27.5 26.9 29.9 

2009 98th%-ile Conc.: 39.1 39.0 33.0 32.0 

2010 98th%-ile Conc.: 30.9 31.9 35.3 35.9 

2008 – 2010 Design Value 32 33 32 33 

3.6 Nonattainment Area FRM PM2.5 Trends (1999 – 2010) 

For the FRM PM2.5 sites that operated in the nonattainment area during 2008 - 2010, the following figure 

shows their design value trends from 2001 through 2010. All sites, excluding the Waukesha site, have 

been witnessing decreasing 24-hour PM2.5 design values beginning with the 3-year period 2006 - 2008. 

Figure 2 – Design Value Trends 
8

4.0 EMISSIONS INVENTORY 

4.1 Overview 

The CAA requires the submittal of a comprehensive inventory of actual emissions that contribute to 

levels of PM2.5. The WDNR must demonstrate that the improvement in PM2.5 air quality between the year 

that violations occurred and the year that attainment was achieved is based on permanent and enforceable 

emission reductions. The U.S. EPA requires that the base year (nonattainment year) emissions be used to 

construct the following other required emission inventory projections: 

1. a year in which the standard was attained; 

2. a year at least 10 years beyond the attainment year to demonstrate maintenance; and 

3. an intermediate year between the attainment year and maintenance year. 

4.2 Years of Inventoried Emissions 

The U.S. EPA allows some discretion regarding the exact year for which each of the emission inventories 

can be constructed. After some discussion with the U.S. EPA – Region V, the following inventory years 

were developed for this redesignation request: 

 Base Year (Nonattainment Year) Inventory: 2006 

 Attainment Year Inventory: 2010 

 Interim Year Inventory: 2020 

 Maintenance Year Inventory: 2025 

The WDNR has constructed emission inventories that pertain to direct (primary) PM2.5 and three gaseous 

precursors to secondary PM2.5 formation, as follows: 

1. Oxides of nitrogen (NOx), which is a precursor to nitrate (NO3) PM2.5; 

2. Sulfur dioxide (SO2), which is a precursor to sulfate (SO4) PM2.5 ;and 

3. Volatile organic compounds (VOCs) which are a precursor to organic carbon (OC) PM2.5. 

The emissions inventory for direct PM2.5 and SO2 are automatically required under 40 CFR 51.1004(c) 

("Pollutants contributing to fine particle concentrations"). 

The WDNR (2011 – see Appendix 3) conducted a long-term (2001-2009) analysis to assess if emissions 

of NOx and/or VOCs make a significant contribution to PM2.5 concentrations in the nonattainment area. 

The assessment of the impact on PM2.5 levels from these precursors is required under 40 CFR 51.1004(c). 

Figures 3 and 4, which are from the above-cited study, demonstrate that much of the PM2.5 profile is 

based upon the formation of secondary aerosols formed from gaseous precursors in the atmosphere. As 

demonstrated in Figures 3 and 4, both nitrates (NO3 – derived largely from NOx precursors) and organic 

carbon (OC – largely derived from heavier VOCs called aromatics [Damberg, 2007]) are substantial 

components to the overall PM2.5 profile in southeastern Wisconsin. Consequently, this redesignation 

request will also address emissions of both NOx and VOCs. Additionally, Figures 3 and 4 show that 

sulfates (SO4 – derived mostly from sulfur dioxide [SO2]) also comprises a sizable portion of PM2.5 levels 

in southeastern Wisconsin. 

The U.S. EPA regulation 40 CFR 1002 (c)(4) notes that “The State is not required to address ammonia 

[NH3] as a PM2.5 attainment plan precursor and evaluate sources of ammonia emissions from sources in 

the State for control measures, unless: (i) The State provides an appropriate technical demonstration for a 

specific area showing that ammonia emissions from sources in the State significantly contribute to PM2.5 
9

concentrations in the nonattainment area, and such demonstration is approved by EPA; or (ii) The EPA 

provides such a technical demonstration.” 

The WDNR has conducted almost no ambient NH3 monitoring in all of Wisconsin, especially in recent 

years. Consequently, the WDNR is not able to do an analysis of the long-term impact of NH3 levels on 

PM2.5 levels in southeastern Wisconsin – as it did for NOx, VOCs and SO2 (Appendix 3). 

However, the Illinois State Water Supply (ISWS) collected daily 24 hour-averaged NH3 measurements 

during January – March 2009 at the WDNR monitoring sites in Mayville (ID # 550270070) and 

Milwaukee SERHQ (ID# 550790026). The ISWS conducted this NH3 sampling as part of a LADCOsponsored study to evaluate the science of nitrate PM2.5 levels during the winter in southeastern Wisconsin 

(i.e., the “Winter Nitrate Study” [WNS]). The WDNR and several contractors (including ISWS) 

monitored a total of 25 parameters as part of the WNS field measurement program. 
10

Figure 3 

(a) All speciated PM2.5 concentrations, including OC, are unadjusted from final validated values. Figure 

from WDNR PM2.5 study (2011) - see Appendix 3. 

Figure 4 

(a) All speciated PM2.5 concentrations, including OC, are unadjusted from final validated values. Figure 

from WDNR PM2.5 study (2011) - see Appendix 3. 
11

4.3 Temporally-Resolved Emission Estimates 

The nonattainment violations occurred for 24-hour average time periods. Therefore, it was necessary to 

construct emission inventories for a time period that is most associated with elevated levels of 24-hour 

PM2.5 concentrations. The WDNR PM2.5 study (2011 – see Appendix 3) also evaluated the collective 

month-of-year profiles of average 24-hour FRM PM2.5 levels during 1999-2010. This assessment 

identified the meteorological winter months of December, January, and February as having both the 

highest monthly average PM2.5 concentrations and the highest monthly percentage of site-days with 24-

hour PM2.5 concentrations greater than 30 μg/m3

 (Figures 5 and 6). Accordingly, the WDNR designed 

and constructed emission inventories for this PM2.5 redesignation request to focus on pollution-related 

activity levels during the winter months (more specifically - for an average January weekday). 

Figure 5 

(a) The WDNR operated seven FRM PM2.5 monitoring sites in Milwaukee County during Jan 1999 - Dec 

2010 -- collecting a total of 9065 validated FRM 24-Hr PM2.5 samples. Figure from WDNR PM2.5 study 

(2011) - see Appendix 3. 
12

Figure 6 

(a) The WDNR operated two FRM PM2.5 monitoring sites in Waukesha County during Jan 1999 - Dec 2010 -- 

collecting a total of 6445 validated FRM 24-Hr PM2.5 samples. Figure from WDNR PM2.5 study (2011) - see 

Appendix 3. 

4.4 Base Year Inventory (Nonattainment Year Inventory) 

The WDNR has prepared a comprehensive inventory of actual emissions for Wisconsin’s PM2.5

nonattainment area (counties of Milwaukee, Racine, and Waukesha) for the base year 2006. The 

emission rates are set for activity levels during an average January weekday for reasons that are explained 

in Section 4.3. This base year inventory includes area, mobile, non-road, and point sources for direct 

PM2.5, NOx, SO2 and VOCs for 2006. The 2006 emission inventory, which represents the base year for 

eventual maintenance purposes, was developed as follows: 

Point Source Inventory

The 2006 point source emissions inventory was estimated using linear interpolation from 2005 and 2008 

emissions inventories. The 2005 and 2008 emissions inventories were created using annually reported 

point source emissions, the U.S. EPA’s Clean Air Markets Database (CAMD) and approved U.S. EPA 

techniques for emissions calculation (e.g., emission factors). Whenever feasible, federal, state and local 

controls were factored into the emission calculations. Emissions were estimated by collecting processlevel information from each facility that qualifies for inclusion into the state’s point source database. A 

table of the 2005 and 2008 point source emissions by county and facility id (FID) number, as well as the 

calculation of 2006 point source emissions is located in Appendix 4. 

Area Source Inventory

The 2006 area source emissions inventory was created by backcasting the Wisconsin 2008 base 

year emissions inventory submitted to the U.S. EPA in 2010 for the National Emissions 

Inventory (NEI). This same approach was used in the WDNR’s September 2009 ozone redesignation 

request to backcast 2005 to 2002 area source emissions and was approved by U.S. EPA on May 18, 2009. 

The backcasting factors were primarily based on growth factors from the Economic Growth and Analysis 
13

System (EGAS) model. The “Default REMI 6.0 SCC Configuration” for EGAS was used. If growth 

factors were not available for a certain SCC, population based growth factors were derived based on the 

Wisconsin Department of Administration’s Demographic Services Center population reports. A table of 

the EGAS growth factors and the 2006 area source emissions by county and SCC is located in Appendix 

5. 

Onroad Inventory

The 2006 onroad mobile emission estimates were created by using the U.S. EPA MOVES2010a model. 

All estimates were made in accordance with the Users Guide to MOVES (U.S. EPA, 

Office of Transportation and Air Quality, Assessment and Standards Division, August 2010, 

EPA 420-B-10-036) and Technical Guidance on the Use of MOVES2010 for Emission Inventory 

Preparation in State Implementation Plans and Transportation Conformity (U.S. EPA, Office of 

Transportation and Air Quality, Transportation and Regional Programs Division, April 2010, 

EPA-420-B-10-023). 

Nonroad Inventory

The 2006 nonroad mobile emission estimates were created by using the U.S. EPA National 

Mobile Inventory (NMIM) model (2009/05/04 Version). The 2006 aircraft, marine and rail emissions 

were estimated using linear interpolation from the 2005 and 2008 emissions inventories. Pechan provided 

marine and rail emission estimates via the Lake Michigan Air Directors Consortium (LADCO) for 

Wisconsin [LADCO, 2012]. Pechan is an independent contractor, which, through contracts with 

LADCO, has developed state specific emission inventory data, including growth factors, for the entire 

LADCO region. Aircraft emissions were calculated using the Federal Aviation Administration’s 

Emissions and Dispersion Modeling System (EDMS). 

Emissions Summary

The following tables summarize the 2006 NOx, PM2.5 direct, SO2 and VOC emissions. 

Table 4 - Total NOx Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 27.82 12.19 53.93 11.00 104.94

Racine County 0.78 2.25 10.48 3.18 16.69 

Waukesha County 0.84 5.61 28.69 7.48 42.62 

Three-County 

Nonattainment Area 29.44 20.05 93.10 21.66 164.25

Note: Point emissions include combined EGU and non-EGU emissions. 
14

Table 5 - Total PM2.5 Direct Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 0.76 9.93 2.74 0.60 14.03 

Racine County 0.16 3.57 0.49 0.17 4.39 

Waukesha County 0.13 5.12 1.39 0.47 7.11 

Three-County 

Nonattainment Area 1.05 18.62 4.62 1.24 25.53 

Note: Point emissions include combined EGU and non-EGU emissions. 

Table 6 - Total SO2 Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 60.63 2.62 0.88 1.00 65.13 

Racine County 0.64 0.53 0.16 0.35 1.68 

Waukesha County 0.16 1.41 0.45 0.63 2.65 

Three-County 

Nonattainment Area 61.43 4.56 1.49 1.98 69.46 

Note: Point emissions include combined EGU and non-EGU emissions. 

Table 7 - Total VOC Emissions for Nonattainment Year 2006 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 6.76 40.73 26.68 6.04 80.21 

Racine County 1.19 10.50 5.62 1.28 18.59 

Waukesha County 3.41 19.35 15.26 4.81 42.83 

Three-County 

Nonattainment Area 11.36 70.58 47.56 12.13 141.63

Note: Point emissions include combined EGU and non-EGU emissions. 

4.5 Attainment Year Inventory 

The 2010 emission inventory, which Wisconsin used to demonstrate attainment, was developed as 

follows: 

Point Source Inventory

The 2010 point source emissions inventory was estimated using linear interpolation from 2005 and 2008 

emissions inventories. The 2005 and 2008 emissions inventories were created using annually reported 

point source emissions, the U.S. EPA’s Clean Air Markets Database (CAMD) and approved U.S. EPA 

techniques for emissions calculation (e.g., emission factors). Whenever feasible, federal, state and local 

controls were factored into the emission calculations. Emissions were estimated by collecting processlevel information from each facility that qualifies for inclusion into the state’s point source database. A 

table of the 2005 and 2008 point source emissions by county and facility id (FID) number, as well as the 

calculation of 2010 point source emissions is located in Appendix 4. 
15

Area Source Inventory

The 2010 area source emissions inventory was created by projecting the Wisconsin 2008 base 

year emissions inventory submitted to the U.S. EPA in 2010 for the NEI. The forecasting factors were 

primarily based on growth factors from the EGAS model. The “Default REMI 6.0 SCC Configuration” 

for EGAS was used. If growth factors were not available for a certain SCC, population based growth 

factors were derived based on the Wisconsin Department of Administration’s Demographic Services 

Center population reports. A table of the EGAS growth factors and the 2010 area source emissions by 

county and SCC is located in Appendix 5. 

Onroad Inventory

The 2010 onroad mobile emission estimates were created by using the U.S. EPA MOVES2010a 

model. All estimates were made in accordance with the Users Guide to MOVES (U.S. EPA, 

Office of Transportation and Air Quality, Assessment and Standards Division, August 2010, 

EPA 420-B-10-036) and Technical Guidance on the Use of MOVES2010 for Emission Inventory 

Preparation in State Implementation Plans and Transportation Conformity (U.S. EPA, Office of 

Transportation and Air Quality, Transportation and Regional Programs Div., April 2010, 

EPA-420-B-10-023). 

Nonroad Inventory

The 2010 nonroad mobile emission estimates were created by using the U.S. EPA NMIM model 

(2009/05/04 Version). The 2010 aircraft, marine and rail emissions were estimated using linear 

extrapolation from the 2005 and 2008 emissions inventories. Pechan, an independent contractor, 

provided marine and rail emission estimates via the LADCO for Wisconsin [LADCO, 2012]. Aircraft 

emissions were calculated using the Federal Aviation Administration’s EDMS. 

Emissions Summary

The following tables summarize the 2010 NOx, PM2.5 direct, SO2 and VOC emissions. 

Table 8 - Total NOx Emissions for Attainment Year 2010 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 27.62 12.33 34.73 9.07 83.75 

Racine County 1.19 2.30 7.96 2.53 13.98 

Waukesha County 1.17 5.77 23.02 6.42 36.38 

Three-County 

Nonattainment Area 29.98 20.40 65.71 18.02 134.11

Note: Point emissions include combined EGU and non-EGU emissions. 
16

Table 9 - Total PM2.5 Direct Emissions for Attainment Year 2010 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 0.02 9.94 1.86 0.65 12.47 

Racine County 0.00 3.66 0.40 0.15 4.21 

Waukesha County 0.00 5.29 1.19 0.43 6.91 

Three-County 

Nonattainment Area 0.02 18.89 3.45 1.23 23.59 

Note: Point emissions include combined EGU and non-EGU emissions. 

Table 10 - Total SO2 Emissions for Attainment Year 2010 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 61.20 2.58 0.25 0.31 64.34 

Racine County 0.46 0.53 0.06 0.14 1.19 

Waukesha County 0.16 1.42 0.16 0.05 1.79 

Three-County 

Nonattainment Area 61.82 4.53 0.47 0.50 67.32 

Note: Point emissions include combined EGU and non-EGU emissions. 

Table 11 - Total VOC Emissions for Attainment Year 2010 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

Milwaukee County 4.23 41.59 19.17 4.83 69.82 

Racine County 1.22 10.80 4.63 1.00 17.65 

Waukesha County 2.67 19.88 13.44 3.94 39.93 

Three-County 

Nonattainment Area 8.12 72.27 37.24 9.77 127.40

Note: Point emissions include combined EGU and non-EGU emissions. 

4.6 Emission Projections and Demonstration of Maintenance 

Details for the projected emission inventories for 2020 and 2025 for the nonattainment counties can be 

found in Section 7 (Maintenance Plan). Emission trends are an important gauge for continued compliance 

with the PM2.5 NAAQS. 

4.7 Permanent and Enforceable Emission Reductions 

Permanent and enforceable reductions of NOx, VOC and SO2 have contributed to attaining the 24-hour 

PM2.5 NAAQS in the nonattainment counties of Milwaukee, Racine, and Waukesha. Some of these 

emission reductions were due to the implementation of the NOx SIP Call, VOC Reasonably Available 

Control Technology (RACT) limitations, NOx RACT limitations, as well the application of tighter federal 

standards on motor vehicles and fuels. 

 
17

Section 6 identifies the emission control measures specific to the Wisconsin's PM2.5 nonattainment area, 

as well as the implementation status of each measure. 

 

4.8 Provisions for Future Updates 

 

As required by Section 175A(b) of the CAA, WDNR commits to submit to the Administrator, eight years 

after redesignation, an additional revision of this SIP. The revision will contain Wisconsin's plan for 

maintaining the PM2.5 NAAQS for ten years beyond the first ten-year period after redesignation. 
18

5.0 TRANSPORTATION CONFORMITY BUDGETS 

U.S. EPA requirements outlined in 40 CFR 93.118(e)(4) stipulate that mobile source emission 

budgets for direct PM2.5 and NOx are established as part of a PM2.5 SIP. Motor vehicle emission budgets 

(MVEBs) are necessary to demonstrate conformance of transportation plans and improvement programs 

with the SIP. 

5.1 Motor Vehicle Emissions Model 

The MOVES model is used to derive emission factors, which are the average emissions (units: grams) per 

mile for direct PM2.5, and precursors NOx, SO2, and VOCs. Numerous variables can affect emission 

factors, especially vehicle-fleet (vehicles on the road), the fleet’s age, and vehicle types. After emission 

factors are determined they are multiplied by vehicle miles traveled (VMT) to determine the quantity of 

vehicle-related emissions. This information is derived from a travel demand model. A summary of 

onroad emissions from the MOVES model can be found in Appendix 6. 

5.2 Motor Vehicle Emission Budget (MVEB) 

Table 12 contains the MVEB for the entire nonattainment area for the years 2015 and 2025. Margins of 

safety are used to accommodate the wide array of assumptions that are factored into the calculation 

process. Since assumptions change over time, it is necessary to have a margin of safety that will 

accommodate the impact of refined assumptions in the process. 40 CFR 93.101 defines safety margin as 

the amount by which the total projected emissions from all sources of a given pollutant are less than the 

total emissions that would satisfy the applicable requirement for reasonable further progress, attainment, 

or maintenance. For the purposes of these emission budgets, a safety margin of 7.5 % has been applied to 

both 2020 and 2025. 

Table 12 – MVEB for Milwaukee, Racine, and Waukesha (2020 and 2025) (Tons per Winter Day) 

Location NOx PM2.5 SO2 VOC 

2020 

Milwaukee County 18.60 1.32 0.22 8.72 

Racine County 3.91 0.28 0.05 2.01 

Waukesha County 10.11 0.73 0.12 5.16 

Three-County 

Nonattainment Area 32.62 2.33 0.39 15.89 

2025 

Milwaukee County 16.32 1.22 0.21 6.63 

Racine County 3.45 0.26 0.05 1.52 

Waukesha County 8.92 0.68 0.12 3.83 

Three-County 

Nonattainment Area 28.69 2.16 0.38 11.98 
19

6.0 CONTROL MEASURES AND REGULATIONS 

CAA Section 107(d)(3)(E)(iv) specifies that a nonattainment area cannot be redesignated to attainment 

unless the U.S. EPA determines that the improvements in air quality are due to permanent and 

enforceable emission reductions. This section documents that reductions in direct PM2.5 and PM2.5

precursor emissions (e.g., SO2 and NOx) have occurred in Wisconsin as a result of permanent and 

enforceable federal and state control measures, accounting for the significant improvements realized in 

measured PM2.5 air quality. Descriptions of the federal and state measures follow. 

6.1 Federal Control Measures 

Improvements in Wisconsin’s ambient PM2.5 air quality are partially due to federal control programs that 

have reduced emissions in Wisconsin and other states. Post-2002 NOx, SO2 and PM2.5 federal control 

measures that have resulted in improvements in ambient PM2.5 levels are listed in Table 13. 

Table 13 – Post-2002 Federal Control Programs 

Control Measure PM NOx SO2

Tier 2 Vehicle Standards and 

Gasoline Sulfur Standards X X X 

Heavy-Duty Diesel and Gasoline 

Highway Vehicle Standards X X X 

Motorcycle Exhaust Standards X 

Large Non-road Diesel Engine Standards X X X 

NOx SIP Call X 

CAIR / CSAPR X X 

Tier 2 Vehicle Standards and Gasoline Sulfur Standards 

The federal Tier 2 rule, promulgated in February 2000, phased in more stringent vehicle emission 

standards between 2004 and 2009, resulting in lower emissions of NOx, PM and sulfur compounds from 

new cars and light duty trucks, including large sport utility and passenger vans. The final Tier 2 standards 

limit NOx levels for new vehicles to an average of 0.07 grams per mile (g/mi), requiring new vehicles to 

be 77% to 95% lower emitting than those on the road prior to the program. The Tier 2 standards also 

reduced the sulfur content of gasoline to 30 parts per million (ppm) by 2006, about an order of magnitude 

lower than 2002 levels. Sulfur in gasoline interferes with the operation of catalytic converters on vehicles 

resulting in higher NOx emissions. In addition to facilitating lower emissions from new Tier 2 equipped 

vehicles, the required lower sulfur levels also produced immediate emission reductions from older preTier 2 vehicles due to less poisoning of catalysts on those vehicles. Further reductions will occur through 

the maintenance period as vehicle turnover increases the proportion of Tier 2 vehicles in the fleet. 

Heavy-Duty Diesel and Gasoline Highway Vehicle Standards 

New U.S. EPA standards designed to reduce NOx and VOC emissions from heavy-duty diesel and 

gasoline highway vehicles took effect in 2004 and 2005, respectively. A second phase of standards, 

commencing in 2007, established tighter PM and NOx emission limits for heavy-duty diesel and gasoline 

highway engines and also required highway diesel fuel sulfur content to be reduced by 97% to 15 ppm to 

minimize potential damage to emission control devices. The U.S. EPA estimates that the total program 

achieves a 90% reduction in PM emissions and a 95% reduction in NOx emissions from new engines 

using low sulfur diesel, compared to previous generation engines using higher sulfur content diesel. The 
20

reduction in fuel sulfur content also provided additional immediate reductions in sulfate particle 

emissions from all on-road diesel vehicles. Further emission reductions will occur through the 

maintenance period with fleet turnover. 

Motorcycle Exhaust Standards 

In 2004, the U.S. EPA published a final rule to implement improved exhaust emission standards on new 

highway motorcycles. These exhaust emission standards apply to all 2006 model year and newer 

motorcycles, including scooters and mopeds. In addition, motorcycles with the largest engines are subject 

to more stringent NOx and hydrocarbon standards beginning with the 2010 model year. 

Large Non-road Diesel Engine Standards 

In May 2004, the U.S. EPA expanded on previous requirements by adopting a new rule establishing 

tighter emission limits for large non-road diesel engines, such as those used in construction, agricultural, 

and industrial equipment, to be phased in between 2008 and 2014. The non-road diesel rule also required 

reductions in the sulfur content of non-road diesel fuel from pre-rule levels of approximately 3,400 ppm 

to 500 ppm by 2006, with a further reduction to 15 ppm by 2010, a total reduction of over 99 percent. 

The combined engine and fuel rules reduced NOx and PM emissions from new large non-road diesel 

engines by over 90%, compared to previous generation non-road engines using higher sulfur content 

diesel. Given the timing of the new requirements, most of the reductions will occur during the 

maintenance period as the fleet of older non-road diesel engines is gradually replaced with the newer, 

lower emitting engines. Nonetheless, the required reduction in fuel sulfur content did yield an immediate 

reduction in sulfate particle emissions from all non-road diesel vehicles. 

NOx SIP Call

In October 1998, the U.S. EPA issued a NOx SIP Call requiring the District of Columbia and 22 states to 

reduce emissions of NOx. The program was primarily targeted at securing emission reductions from 

EGUs (power plants) in states that were determined to be significantly contributing to violations of the 1-

hour ozone NAAQS in other, downwind states. Affected states were required to comply with Phase I of 

the SIP Call beginning in 2003/2004 and Phase II beginning in 2007. 

CAIR / CSAPR

In order to assist states in addressing their obligations regarding regionally transported pollution, the U.S. 

EPA finalized the Clean Air Interstate Rule (CAIR) to reduce emissions NOx and SO2 from large EGUs. 

The WDNR has promulgated CAIR (Wis. Adm. Code NR 432). Chapter NR 432 applies to all major 

EGUs in Wisconsin and in upwind states. Nationwide, CAIR resulted in an estimated reduction of NOx

emissions by 53% by 2009. Sulfur dioxide emissions were reduced by 45% by 2010. 

On December 23, 2008, the D.C. Circuit Court decided to remand, rather than vacate, the CAIR rule, thus 

leaving CAIR in place while EPA revises the rule. In response, the U.S. EPA recently promulgated the 

Cross-State Air Pollution Rule (CSAPR). However, due to ongoing litigation involving CAIR and 

CSAPR, all potential emission reductions resulting from CAIR and CSAPR have been left out of the 

maintenance emission inventory projections in this redesignation request, unless they are already fully 

committed controls. 
21

6.2 State Control Measures 

Improvements in Wisconsin’s ambient PM2.5 air quality are partially due to state control programs that 

have reduced emissions in Wisconsin. Post-2002 NOx, SO2 and PM2.5 state control measures that have 

resulted in improvements in ambient PM2.5 levels are listed in Table 14. 

Table 14 – Post-2002 State Control Programs 

Control Measure PM NOx SO2

NOx RACT X 

VOC RACT 

Mercury Multi-pollutant Rule X X 

Best Available Retrofit Technology (BART) X X X 

NOx RACT

For purposes of reducing ambient ozone levels, the WDNR promulgated NOx RACT rules. These rules 

are located in Chapter NR 428 of the Wisconsin Administrative Code. An added benefit from 

implementing and enforcing these NOx RACT requirements is the resulting reduction in PM2.5. 

VOC RACT

For purposes of reducing ambient ozone levels, the WDNR promulgated VOC RACT rules. The 

Wisconsin VOC RACT rules are codified in several chapters of the NR 400 series of the Wisconsin 

Administrative Code. An added benefit from implementing and enforcing these VOC RACT 

requirements is the reduction in VOC emissions that are precursors to organic carbon PM2.5. 

Mercury Multi-Pollutant Rule

NR 446, Wis. Adm. Code, allows large or small coal-fired electrical generating units the option to reduce 

NOx, SO2, and mercury by 2015 to the emission limitations listed in NR 446.14, Wis. Adm. Code, instead 

of the mercury only limitations listed in NR 446.12 and 446.13, Wis. Adm. Code. 

Best Available Retrofit Technology (BART)

NR 433, Wis. Adm. Code, affects certain large sources of NOx, SO2, or direct particle pollution that began 

operation between 1962 and 1977. The main sources subject to emission reductions are boilers at electric 

generating power plants and pulp and paper facilities. 
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7.0 MAINTENANCE PLAN 

Section 175A of the CAA sets forth the elements of a maintenance plan for areas seeking redesignation 

from nonattainment to attainment. The plan must demonstrate continued attainment of the applicable 

NAAQS for at least 10 years after the U.S. EPA approves a redesignation to attainment. Eight years after 

the redesignation, the state must submit a revised maintenance plan, which demonstrates attainment for 

the 10 years following the initial 10-year period. 

7.1 Maintenance Inventory Methodology (2020 and 2025) 

This section contains the projected emission inventories for 2020 and 2025 for the Milwaukee, Racine, 

and Waukesha three-county PM2.5 nonattainment area. The WDNR performed emission projections using 

the following methodologies. 

Point Source Inventory

Electric Generating Unit (EGU) projected 2018 emissions for NOx, SO2, and VOC were based on IPM3.0 

and included “will do” adjustments identified by Wisconsin. These adjustments included NOx RACT. 

Non-EGU projected 2018 emissions were derived by applying growth and control factors – developed by 

Pechan – to the 2005 base year inventory. Growth factors were initially based on EGAS and were 

modified for select priority categories by examining emissions activity data. Projected emissions for 

2020 and 2025 were estimated using linear extrapolation from 2010 and 2018 emissions. The 2020 and 

2025 point source emissions calculations are located in Appendix 7. 

EGU projected 2018 emissions for PM2.5 were not available from LADCO. Therefore, the 2020 and 2025 

PM2.5 emission inventories for the EGU source category were created by projecting forward the 

Wisconsin 2008 base year emissions inventory submitted to the U.S. EPA in 2010 for the NEI. This same 

approach was used in the WDNR’s recent ozone redesignation request and proposed for approval by the 

U.S. EPA. The emission projections were based on growth factors from the EGAS model. The “Default 

REMI 6.0 SCC Configuration” for EGAS was used. 

The EGAS growth factors are based on the 2004 Annual Energy Outlook (AEO) from the U.S. 

Department of Energy. The 2020 and 2025 growth factors were modified slightly to reflect more recent 

AEO reports (2008 – 2012) [EIA, 2012]. In 2020, energy consumption projections have decreased from 

13.34 – 21.10% and in 2025, they have decreased from 16.08 – 24.58% compared to the 2004 AEO 

report. In order to reflect these reduced energy consumption projections, the 2020 and 2025 growth 

factors were conservatively reduced by 13% and 16%, respectively. A table of the EGAS growth factors 

is located in Appendix 7. 

Area Source Inventory

The 2020 and 2025 area source emission inventories were created by projecting forward the 

Wisconsin 2008 base year emissions inventory submitted to the U.S. EPA in 2010 for the NEI. This same 

approach was used in the WDNR’s recent ozone redesignation request and proposed for approval by the 

U.S. EPA. The emission projections were primarily based on growth factors from the EGAS model. The 

“Default REMI 6.0 SCC Configuration” for EGAS was used. If growth factors were not available for a 

certain SCC, population based growth factors were derived based on the Wisconsin Department of 

Administration’s Demographic Services Center population reports. 

The EGAS growth factors are based on the 2004 AEO from the U.S. Department of Energy. The 2020 

and 2025 growth factors were modified slightly to reflect more recent AEO reports (2008 – 2012) [EIA, 
23

2012]. In 2020, energy consumption projections have decreased from 13.34 – 21.10% and in 2025, they 

have decreased from 16.08 – 24.58% compared to the 2004 AEO report. To reflect these reduced energy 

consumption projections, the 2020 and 2025 growth factors were conservatively reduced by 13% and 

16%, respectively. A table of the EGAS growth factors and the 2020 and 2025 area source emissions by 

county and SCC is located in Appendix 5. 

Nonroad Inventory

The 2020 and 2025 nonroad mobile emission estimates were created by using the U.S. EPA 

NMIM model (2009/05/04 Version). In addition, marine and rail emissions were grown to 2018 

from 2005 Pechan statewide growth factors, while EGAS growth factors were used to grow the 

aircraft inventory to 2018 [LADCO, 2011]. Marine, aircraft, and rail projected emissions for 2020 and 

2025 were estimated using linear inter/extrapolation from 2008 and 2018 emissions. This same approach 

was used in the WDNR’s recent ozone redesignation request and proposed for approval by the U.S. EPA. 

Onroad Inventory

Emission projections were created using the U.S. EPA MOVES model. All estimates were made in 

accordance with the Users Guide to MOVES (U.S. EPA, Office of Transportation and Air Quality, 

Assessment and Standards Division, August 2010, EPA 420-B-10-036) and Technical Guidance on the 

Use of MOVES2010 for Emission Inventory Preparation in State Implementation Plans and 

Transportation Conformity (U.S. EPA, Office of Transportation and Air Quality, Transportation and 

Regional Programs Div., April 2010, EPA-420-B-10-023). 

Emissions Summary

The following tables summarize the 2020 and 2025 NOx, PM2.5 direct, SO2 and VOC emissions. 

Table 15 - Total NOx Emissions for 2020 and 2025 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

2020 

Milwaukee County 21.23 10.86 18.60 4.10 54.79 

Racine County 1.16 2.07 3.91 1.13 8.27 

Waukesha County 1.55 5.27 10.11 2.34 19.27 

Three-County 

Nonattainment Area 23.94 18.20 32.62 7.57 82.33 

2025 

Milwaukee County 17.08 10.59 16.32 3.00 46.99 

Racine County 1.15 2.04 3.45 0.81 7.45 

Waukesha County 1.74 5.24 8.92 1.84 17.74 

Three-County 

Nonattainment Area 19.97 17.87 28.69 5.65 72.18 

Note: Point emissions include combined EGU and non-EGU emissions.
24

Table 16 - Total PM2.5 Direct Emissions for 2020 and 2025 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

2020 

Milwaukee County 0.23 8.87 1.32 0.34 10.76 

Racine County 0.05 3.41 0.28 0.07 3.81 

Waukesha County 0.04 5.11 0.73 0.23 6.11 

Three-County 

Nonattainment Area 0.32 17.39 2.33 0.64 20.68 

2025 

Milwaukee County 0.30 8.62 1.22 0.24 10.38 

Racine County 0.08 3.40 0.26 0.05 3.79 

Waukesha County 0.06 5.18 0.68 0.21 6.13 

Three-County 

Nonattainment Area 0.44 17.20 2.16 0.50 20.30 

Note: Point emissions include combined EGU and non-EGU emissions.

Table 17 - Total SO2 Emissions for 2020 and 2025 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

2020 

Milwaukee County 27.00 2.18 0.22 0.23 29.63 

Racine County 0.68 0.46 0.05 0.08 1.27 

Waukesha County 0.16 1.24 0.12 0.08 1.60 

Three-County 

Nonattainment Area 27.84 3.88 0.39 0.39 32.50 

2025 

Milwaukee County 9.52 2.05 0.21 0.20 11.98 

Racine County 0.78 0.44 0.05 0.05 1.32 

Waukesha County 0.15 1.19 0.12 0.12 1.58 

Three-County 

Nonattainment Area 10.45 3.68 0.38 0.37 14.88 

Note: Point emissions include combined EGU and non-EGU emissions.
25

Table 18 - Total VOC Emissions for 2020 and 2025 (Tons per Winter Day) 

Location Point Area Onroad Nonroad Total 

2020 

Milwaukee County 5.79 41.08 8.72 3.98 59.57 

Racine County 1.30 10.76 2.01 0.75 14.82 

Waukesha County 3.22 19.86 5.16 3.18 31.42 

Three-County 

Nonattainment Area 10.31 71.70 15.89 7.91 105.81

2025 

Milwaukee County 6.57 42.88 6.63 4.17 60.25 

Racine County 1.34 11.29 1.52 0.77 14.92 

Waukesha County 3.49 20.88 3.83 3.33 31.53 

Three-County 

Nonattainment Area 11.40 75.05 11.98 8.27 106.70

Note: Point emissions include combined EGU and non-EGU emissions.

7.2 Demonstration of Maintenance (Comparison of Emissions) 

The maintenance emission inventory estimates are presented in the tables below and demonstrate that 

emissions of direct PM2.5, NOx, SO2, and VOC will decrease in future years. The results of this analysis 

show that the nonattainment area is expected to maintain the air quality standard for at least ten years into 

the future. 

Table 19 – NOx Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 

Sector 2010 2020 Net Change 

from 2010 2025 Net Change from 2010 

Point 29.98 23.94 -6.04 19.97 -10.01 

Area 20.40 18.20 -2.20 17.87 -2.53 

Onroad 65.71 32.62 -33.09 28.69 -37.02 

Nonroad 18.02 7.57 -10.45 5.65 -12.37 

Total 134.11 82.33 -51.79 72.18 -61.93 

Table 20 – PM2.5 Direct Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 

Sector 2010 2020 Net Change 

from 2010 2025 Net Change from 2010 

Point 0.02 0.32 0.30 0.44 0.42 

Area 18.89 17.39 -1.50 17.20 -1.69 

Onroad 3.45 2.33 -1.12 2.16 -1.29 

Nonroad 1.23 0.64 -0.59 0.50 -0.73 

Total 23.59 20.68 -2.91 20.30 -3.29 
26

Table 21 – SO2 Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 

Sector 2010 2020 Net Change 

from 2010 2025 Net Change from 2010 

Point 61.82 27.84 -33.98 10.45 -51.37 

Area 4.53 3.88 -0.65 3.68 -0.85 

Onroad 0.47 0.39 -0.08 0.38 -0.09 

Nonroad 0.50 0.39 -0.11 0.37 -0.13 

Total 67.32 32.50 -34.82 14.88 -52.44 

Table 22 – VOC Emissions in the Three-County Nonattainment Area (Tons per Winter Day) 

Sector 2010 2020 Net Change 

from 2010 2025 Net Change from 2010 

Point 8.12 10.31 2.19 11.40 3.28 

Area 72.27 71.70 -0.57 75.05 2.78 

Onroad 37.24 15.89 -21.35 11.98 -25.26 

Nonroad 9.77 7.91 -1.86 8.27 -1.50 

Total 127.40 105.81 -21.59 106.70 -20.70 

7.3 Verification of Continued Attainment 

Continued verification of attainment of the 2006 24-hour PM2.5 NAAQS in the counties of Milwaukee, 

Racine, and Waukesha depends on Wisconsin’s effort toward tracking indicators of continued attainment 

during the maintenance period. The tracking plan for these areas primarily consists of continued PM2.5

monitoring in accordance with the requirements of 40 CFR Part 58. 

7.4 Contingency Plan 

Despite the best efforts to demonstrate continued compliance with the NAAQS, the ambient PM2.5

concentrations may exceed or violate the NAAQS. Therefore, as required by section 175A of the CAA, 

Wisconsin has provided contingency measures to promptly correct a future PM2.5 air quality problem. 

These contingency measures would be implemented if a future 24-hour PM2.5 design value for any of the 

current monitors is above the PM2.5 24-hour NAAQS (35 μg/m3

). 

Contingency Measures Approach: 

1. Evaluation of Adequacy of Existing Control Measures – If a violation occurs, the first and most 

important step Wisconsin will take will be to evaluate the adequacy of already-adopted control 

measures to rectify the violation. Control measures that have already been promulgated, but not 

fully implemented at the time of the violation may very likely be sufficient to return the area to 

attainment. 

If a measure or control is already promulgated and scheduled to be implemented at the federal or 

state level, the state will assess whether that measure or control in combination with other 

existing controls will be sufficient. Wisconsin will consider existing control measures that have 

been adopted in Wisconsin, as well as existing measures that have already been adopted in other 

states or by the federal government. If existing control measures are determined to be sufficient 

to address the upward trend in PM2.5 concentrations, additional local control measures will not be 

necessary. In that case, Wisconsin will submit to U.S. EPA an analysis to demonstrate that the 
27

existing measures that have not been fully implemented are adequate to return the area to 

attainment. 

2. Evaluation of Additional Control Measures – If it is demonstrated through modeling that existing 

and on-the-way measures are inadequate to return the area to attainment, the WDNR will identify 

candidate additional control measures as necessary to return the area to attainment within 18 

months. The selection of candidate measures will be based upon cost-effectiveness, emission 

reduction potential, economic and social considerations and other appropriate factors. Before 

proposing any specific candidate control measures, WDNR will solicit input from all interested 

and affected parties. 

It is important to note that adoption of any additional control measures is subject to the necessary 

administrative and legal process as well as required legislative oversight. This process will include 

publication of notices, an opportunity for public hearing, and other measures required by Wisconsin law 

for rule making. 

7.5 List of Potential Additional Control Measures 

Since it is not possible at this time to determine what control measure (if any) will be appropriate at an 

unspecified time in the future, the list of potential candidate contingency measures outlined below is not 

comprehensive nor is the list in priority order. 

1. Broaden the application of the NOx RACT program: 

 to include a larger geographic area, and/or 

 to include sources with potential emissions of 50 tons/year, and/or 

 to increase the cost-effectiveness thresholds utilized as a basis for Wisconsin’s NOx RACT 

Program 

2. Consideration of PM2.5 and SO2 RACT 

3. Diesel reduction emission strategies (e.g., further grant programs) 

4. Ammonia (NH3) emission reduction strategies 

 With U.S. EPA guidance, identify how strategies can be developed to control the emissions of 

NH3, which is a gaseous precursor to nitrate (NO3) PM2.5. This proposed action is based upon a 

conceptual model developed by Stanier, et.al (2010) to explain winter time PM2.5 episodes in 

Wisconsin. Namely, from Stanier’s model, it is suggested that "Controls of ammonia or nitrate 

[and, by extension, NOx] are likely to decrease [wintertime PM2.5] episode concentrations." 

No contingency measure shall be implemented without providing the opportunity for full public 

participation during which the relative costs and benefits of individual measures can be fully evaluated. 

7.6 Commitment to Revise Maintenance Plan 

Wisconsin hereby commits to review its Maintenance Plan eight (8) years after redesignation, as required 

by Section 175(A) of the CAA. This revised SIP will provide for maintenance for an additional 10 years. 
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8.0 PUBLIC PARTICIPATION 

The WDNR will publish in the State’s official newspaper of record (The Wisconsin State Journal) a 

notice that it will hold a public hearing on this PM2.5 redesignation request. This public hearing will take 

place at WDNR Southeast Regional Headquarters (2300 N. Dr. Martin Luther King Dr., Milwaukee) on 

Monday, May 7, 2012. Furthermore, all documentation will be posted on the WDNR website 

(http://dnr.wi.gov/topic/AirQuality). There will be at least a 30-day public comment period on this 

redesignation request. The WDNR will review and respond to all received public comments and include 

those responses as part of the final submittal to the U.S. EPA. 
29

9.0 CONCLUSION 

The counties of Milwaukee, Racine, and Waukesha have attained the 2006 24-hour PM2.5 NAAQS. In 

addition, all applicable provisions of the CAA and PM2.5 implementation rule regarding redesignation to 

attainment have been met, as described within this document. Therefore, the WDNR, on behalf of the 

State of Wisconsin, hereby requests that the U.S. EPA redesignate these three counties to attainment 

status for the 24-hour PM2.5 NAAQS. 
30

10.0 REFERENCES 

Damberg, R., 2007: Policies for Addressing PM2.5 Precursor Emissions. U.S. EPA Office of Air Quality 

Planning and Standards, June 20. 

EIA, 2012: U.S. Energy Information Administration, Analysis and Projections Web site. 

http://www.eia.gov/forecasts/aeo/er/ (accessed February 24, 2012). 

LADCO, 2011: Current Inventory – LADCO’s BaseC Version 8 2007/2008 Inventory. LADCO Website. 

http://www.ladco.org/tech/emis/current/index.php (accessed October 15, 2011). 

LADCO, 2012: Current Inventory – LADCO’s BaseC Version 8 2007/2008 Inventory. LADCO Website. 

http://www.ladco.org/tech/emis/current/index.php (accessed February 15, 2012). 

MOVES Users Guide. U.S. EPA, Office of Transportation and Air Quality, Assessment and Standards 

Division, August 2010, EPA 420-B-10-036. 

NACO, 2011: Nat’l Assoc. of Counties. www.naco.org/Counties/Pages/FindACounty.aspx

Technical Guidance on the Use of MOVES2010 for Emission Inventory Preparation in State 

Implementation Plans and Transportation Conformity. U.S. EPA, Office of Transportation and Air 

Quality, Transportation and Regional Programs Division, April 2010, EPA-420-B-10-023. 

U.S. Census Bureau, 2011: http://quickfacts.census.gov/qfd/states/55000.html

Wisconsin DNR, 2011: An Analysis of Characteristics and Precursors to Ambient PM2.5 Levels 

Southeastern Wisconsin for Purposes of Designing Emission Inventories for Inclusion in a Request for 

Redesignation to Attainment PM2.5 Nonattainment Counties of Milwaukee, Racine, and Waukesha. 

Bureau of Air Management Report, 26 pp, August. Full report contained in Appendix 3.