State of Wisconsin

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

Jun e 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 -2 621
Toll Free 1-888-936-7463
TTY Access via re la y

- 711

Subject: Redesignation Request for F ine Patticulate Matter (PM 2 5 )

Dear Ms. Hedman:

The Wisconsin Depattment of Natural Resources (WDNR) her eby submits a redesignation r equest for the cou nties of

Milwaukee

, Racine and Waukesha for the 2006 PM 2

. 5 National Ambient Air Quality Standard (NAAQS). The Depattment is happy to report that all countie s in Wisconsin mea su red attainment of the PM 2

. 5 NAAQS from 2008 through 20 10 and continue to measure attainment.

The WDNR h as the legal aut hority under Wisconsin law to adopt and implem ent the se requested SIP revisions.
Section 285.11 (6), Wis. Stats., authorizes the WDNR to develop a nd revi se the SIP for prevention, abatement, and
control of air pollution. The WDNR conducted a pub lic hearing on May 7, 2012

. A copy of the public hearing notice
is included as an attac hm ent.

In accordance with the April 6, 2011 McCabe Memo

, one paper copy of the SIP revision document s is enclosed. In addition, an e l ectronic copy of these document s i s provided as well on an enclosed CD

. If yo u h ave any questions regarding this submittal, please feel free to ca ll Joseph Hoch at 608-267-7543 or Ralph Patter so n at 608-267-7546.

S incer ely, 

# c-2-;:-::

Air Management

# BUI~au Director

Wisconsin Department of Natural Resources

cc: Patrick Stevens

- AD/8 Joseph Hoch- AM/7

Ra lph 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- 1 8J), 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 Nw ia- U.S. EPA Region V (AT- 18J)

, 77 West Jackson Boulevard

, C hi cago , IL 60604

dnr

. wi.gov wisconsin .go v 

### Naturally 

## WISCONSIN PR I NTED ON R E CYCLED PAPERPage 2.

Summary of Attachments: Hard Copy aud Electronic

• EPA Region V SIP Submittal Checklist

• Public Hearing Notice

• Public Comments and Response to Comments

• PM 2

. 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 in corporated 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

No2

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., Admini strative 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 heari ngs 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 pub lic 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 (NO

x ) Sulfur dioxide (SO 2 ) Fine Particulate Matter (PM 2.5 ) Ammonia (NH 3 ) 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 impl emented? 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? Pr ovide additional explan ation (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 requirement s 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: WISCONSIN5



## 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) inventor ies are included for 2020 and 2025, demonstrating decreasing NO

x , PM 2.5 , SO 2 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 2012i 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 PM 2.5 Air Quality 1 1.4 Redesignation Requirements 2 2.0 FEDERAL CAA REQUIREMENTS 3 2.1 Satisfying CAA Secti on 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 PM 2.5 MONITORING DATA 5 3.1 Deriving PM 2.5 Attainment / Nonattainment 5
3.2 Nonattainment Area FRM PM 2.5 Monitoring Network 5 3.3 Quality Assurance 6 3.4 Data Completeness 6
3.5 24-Hour PM 2.5 98th Percentile and Design Value Concentrations 7
3.6 Nonattainment Area FRM PM 2.5 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 Main tenance (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 30ii List of Appendices

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

Appendix 2 – Fine Particulate Matter (PM 2.5 ) Clean Data Finding

Appendix 3 – An Analysis of Characteristics and Precursors to Ambient PM 2.5 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 PM 2.5 Monitoring Data 1

1 Note: Non-certified, quality-assured 2011 PM 2.5 monitoring data became available after this draft was completed. However, this data is included as an appendix to show the continued decrease in PM 2.5 concentrations.iii List of Tables

Table 1 – FRM PM 2.5 Monitors – Milwaukee, Racine, and Waukesha Counties

Table 2 – Percentage Completeness

Table 3 – Annual 98th Percentile FRM PM 2.5 Concentrations and 24-Hour PM 2.5 Design Values

Table 4 – Total NO

x Emissions for Nonattainment Year 2006 ( Tons per Winter Day )

Table 5 – Total PM 2.5 Direct Emissions for Nonattainment Year 2006 ( Tons per Winter Day )

Table 6 – Total SO 2 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 NO

x Emissions for Attainment Year 2010 ( Tons per Winter Day )

Table 9 – Total PM 2.5 Direct Emissions for Attainment Year 2010 ( Tons per Winter Day )

Table 10 – Total SO 2 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 NO

x Emissions for 2020 and 2025 ( Tons per Winter Day )

Table 16 – Total PM 2.5 Direct Emissions for 2020 and 2025 ( Tons per Winter Day )

Table 17 – Total SO 2 Emissions for 2020 and 2025 ( Tons per Winter Day )

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

Table 19 – NO

x Emissions in the Three-County Nonattainment Area ( Tons per Winter Day )

Table 20 – PM 2.5 Direct Emissions in the Three-County Nonattainment Area ( Tons per Winter Day )

Table 21 – SO 2 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 PM 2.5 Monitors – Milwaukee, Racine, and Waukesha Counties

Figure 2 – Design Value Trends

Figure 3 – Average Month-of-Year Speciated 24-Hour PM 2.5 Concentrations

Figure 4 – Average Month-of-Year Speciated 24-Hour PM 2.5 Concentrations as Percentage

Figure 5 – Month-of-Year Average 24-Hour PM 2.5 Concentrations in Milwaukee

Figure 6 – Month-of-Year Average 24-Hour PM 2.5 Concentrations in Waukesha1 1.0 INTRODUCTION

1.1 Background

The federal Clean Air Act (CAA) requires area s failing to attain a National Ambient Air Quality Standard (NAAQS) for a speci fied 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. Wh en attainment of a NAAQS in a nonattainment area has been achieved, Section 107(d)(3)(E) of the CAA allo ws 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 (PM 2.5 ) NAAQS, based upon available health studies ( 71 FR 61144 ). The updated (i.e.,"2006") 24-hour PM 2.5 NAAQS was made more restrictive - 35 μg/m 3 , reduced from the 1997 standard of 65 μg/m 3 . In this action the U.S. Environmental Protection Agency (EPA) retained the original annual PM 2.5 standard at15.0 μg/m 3

.

On November 13, 2009 the U.S. EPA published final rulemaking that established initial air quality designations for the 2006 PM 2.5 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 PM 2.5 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 PM 2.5 NAAQS.

Based on supporting information provided in this do cument, 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 PM 2.5 NAAQS.

1.2 Geographical Description

The counties of Milwaukee, Racine, and Waukesha ar e located in southeastern Wisconsin (Figure 1). Milwaukee and Racine Counties border along the wester n 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 adj acent to the heavily-urban ized Milwaukee County. Consequently, these counties also have fairly subs tantial 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, rela tive 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 PM 2.5 Air Quality

For Milwaukee, Racine, and Waukesha Counties, th e fully-validated federal reference method (FRM)-
derived PM 2.5 monitoring data for the most recent three years, 2008 - 2010, demonstrate that air quality levels have attained the NAAQS for 24-hour PM 2.5 . 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 estim ated emission totals of those air pollutants that
contribute to PM 2.5 levels, help justify a redesignation to a ttainment for these counties based on Section 107(d)(3)(D) of the CAA.

1.4 Redesignation Requirements

Once attainment has been achieved for a PM 2.5 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 th at 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 improve ment 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 provid ing technical support to the WDNR’s request that the counties of Milwaukee, Racine, and Waukesha be redesignated from nonattainme nt to attainment of
the 2006 24-hour PM 2.5 NAAQS. Additional information to support continued compliance (i.e., maintenance) with respect to the 2006 24-hour PM 2.5 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 requi rements 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 require ments 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 ot her control measures, means or techniques necessary to meet the requirements of the CAA;

 Provide for establishment and operation of approp riate devices, methods, systems, and procedures necessary to monitor ambient air quality;

 Provide for implementation of a source perm it program to regulate the modification and construction of any stationary source w ithin the areas covered by the plan;

 Include provisions for the implementation of pa rt C, Prevention of Significant Deterioration (PSD), and part D, New Source Review (NSR) permit programs;

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

 Include provisions for air quality modeling; and pr ovide for public and local agency participation in planning and emission control rule development.

Wisconsin submitted an “infrastruct ure SIP” for the 2006 24-hour PM 2.5 NAAQS to the U.S. EPA on January 24, 2011, with a supplemental submittal on Ma rch 28, 2011, demonstrating compliance with the CAA Section 110 requirements. This prio r submittal is included in Appendix 1.

2.2 Satisfying CAA Part D Requirements

CAA Title I, Part D, Subpart 1 sets forth the b asic nonattainment requirements applicable to all
nonattainment areas. For the 2006 PM 2.5 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 Sect ion 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

PM 2.5 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 quantif ication 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 m eets 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 applicab le provisions of CAA Section 110(a)(2). As noted in the previous section, Wisconsin submitted an affirm ation 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 establis h criteria and procedures to ensure that federally supported or funded activities, including highway proj ects, conform to the air quality planning goals in the applicable SIPs. The requirement to determine co nformity 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 requi rements 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 st ate rules have not been approved. Section 5.0 of this document includes transportation conformity budge ts 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 elemen t that must be addressed for the 24-hour PM 2.5 NAAQS is the CAA Section 172(c)(3) requirement for an inventor y of actual emissions for the area. An emissions inventory is presented in Section 4.0 of this red esignation request. When the U.S. EPA approves this inventory, Wisconsin will m eet 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 Se ction 110(k) for all requirements applicable for purposes of redesignation.5 3.0 WISCONSIN PM 2.5 MONITORING DATA

3.1 Deriving PM 2.5 Attainment / Nonattainment

The U.S. EPA's requirements for PM 2.5 air monitoring data are contained in Appendix N to 40 CFR Part 50 (“Interpretation of the National Ambient Air Quality Standards for PM 2.5 ”). An FRM PM 2.5 monitoring site that meets the data completeness requi rements for the most recent three calendar years is
considered to have attained the 24-hour PM 2.5 NAAQS when the site’s most current 24-hour PM2.5 design value (DV) concentration is less than or equal to 35 μg/m 3

.

The ambient PM 2.5 concentrations used to determine attainmen t/nonattainment status are daily, integrated 24-hour (calendar day) measurements of PM 2.5 mass collected on Teflon filters. The PM 2.5 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 PM 2.5 monitoring network to ensure that the

PM 2.5 NAAQS is maintained in all of Wisconsin.

3.2 Nonattainment Area FRM PM 2.5 Monitoring Network

There were a total of five FRM PM 2.5 monitoring sites operated by the WDNR in the PM 2.5 nonattainment counties during the 2008 - 2010 period (T able 1, Figure 1). Each of these sites, individually or combined, met the completeness requirements detailed in A ppendix N to 40 CFR Part 50 during this period.

Table 1 - FRM PM 2.5 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 monito ring. The College Ave site began collecting PM 2.5 data on the first scheduled sampling date after the FAA site took its final PM 2.5 measurement. The College Ave site is located approximately 2 miles dire ctly south of the now-discontinued FAA site. Both locations are situated east of and within a couple hun dred 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 PM 2.5 data from the MilwaukeeFAA and Milwaukee-College Ave sites for purposes of deriving a combined-site 24-hour PM 2.5 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 downt own area 1.5 miles west of Lake Michigan. The
Waukesha-Cleveland St. site is located in a mixe d industrial and residential setting approximately 15 miles west of Lake Michigan and 14 miles west of downtown Milwaukee.6 Figure 1 - FRM PM 2.5 Monitors – Milwaukee, Racine, and Waukesha Counties

3.3 Quality Assurance

WDNR follows the fully-approved Wisconsin PM 2.5 Quality Assurance Plan in accordance with 40 CFR 58.10, to assure that the quality of the FRM PM 2.5 monitoring data submitted to the U.S. EPA’s Air Quality System (AQS) met federal criteria. All validated FRM PM 2.5 measurement data collected during
2008 - 2010 for the nonattainment sites listed in Tabl e 1 have been archived in U.S. EPA’s AQS. In addition, these full data sets have been cer tified and are available to the public.

3.4 Data Completeness

Table 2 shows that the annual percentage of FRM PM 2.5 sampling success for each site-year in
Wisconsin’s PM 2.5 nonattainment area during 2008 - 2010. The data completeness at these FRM PM 2.5 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 PM 2.5 sample schedule Every 3rd day Every 3rd day Every 6th day Every 3rd day

2008 # of valid samples 119 119 60 117

2008 % FRM PM 2.5 Data Completeness 98% 98% 98% 96%

2009 # of valid samples 115 120 61 115

2009 % FRM PM 2.5 Data Completeness 94% 98% 100% 94%

2010 # of valid samples 112 171 57 121

2010 % FRM PM 2.5 Data Completeness 92% 100% 93% 99%7 3.5 24-Hour PM 2.5 98th Percentile and Design Value Concentrations

Table 3 displays the final-validated 24-hour PM 2.5 98th percentile and subsequent design value
concentrations for the FRM PM 2.5 sites in the nonattainment area during 2008 - 2010. All of the sites
have 24-hour PM 2.5 design values that are 2-3 μg/m 3 below the 24-hour PM 2.5 NAAQS of 35 μg/m 3 during this period.

Table 3 - Annual 98th Percentile FRM PM 2.5 Concentrations and 24-Hour PM 2.5 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 PM 2.5 Trends (1999 – 2010)

For the FRM PM 2.5 sites that operated in the nonattainment ar ea 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 PM 2.5 design values beginning with the 3-year period 2006 - 2008.

Figure 2 – Design Value Trends8 4.0 EMISSIONS INVENTORY

4.1 Overview

The CAA requires the submittal of a comprehensive i nventory of actual emissions that contribute to
levels of PM 2.5 . The WDNR must demonstrate that the improvement in PM 2.5 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 b ase year (nonattainment year) emissions be used to construct the following other require d 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 ex act year for which each of the emission inventories
can be constructed. After some discussion with th e 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) PM 2.5 and three gaseous precursors to secondary PM 2.5 formation, as follows:

1. Oxides of nitrogen (NO

x ), which is a precursor to nitrate (NO 3 ) PM 2.5 ; 2. Sulfur dioxide (SO 2 ), which is a precursor to sulfate (SO 4 ) PM 2.5 ;and
3. Volatile organic compounds (VOCs) which ar e a precursor to organic carbon (OC) PM 2.5

.

The emissions inventory for direct PM 2.5 and SO 2 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 NO

x and/or VOCs make a significant contribution to PM 2.5 concentrations in the nonattainment area. The assessment of the impact on PM 2.5 levels from these precursors is required under 40 CFR 51.1004(c). Figures 3 and 4, which are from the above-cite d study, demonstrate that much of the PM 2.5 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 (NO 3 – derived largely from NO

x precursors) and organic carbon (OC – largely derived from heavier VOCs cal led aromatics [Damberg, 2007]) are substantial components to the overall PM 2.5 profile in southeastern Wisconsin. Consequently, this redesignation request will also address emissions of both NO

x and VOCs. Additionally, Figures 3 and 4 show that sulfates (SO 4 – derived mostly from sulfur dioxide [SO 2 ]) also comprises a sizable portion of PM 2.5 levels
in southeastern Wisconsin.

The U.S. EPA regulation 40 CFR 1002 (c)(4) notes that “The State is not required to address ammonia [NH 3 ] as a PM 2.5 attainment plan precursor and evaluate sources of ammonia emissions from sources in the State for control measures, unless: (i) The State pr ovides an appropriate technical demonstration for a specific area showing that ammonia emissions from sources in the State significantly contribute to PM 2.59 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 NH 3 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 NH 3 levels on

PM 2.5 levels in southeastern Wisconsin – as it did for NOx, VOCs and SO 2 (Appendix 3).

However, the Illinois State Water Supply (ISWS) collected daily 24 hour-averaged NH 3 measurements during January – March 2009 at the WDNR mon itoring sites in Mayville (ID # 550270070) and Milwaukee SERHQ (ID# 550790026). The ISWS conducted this NH 3 sampling as part of a LADCOsponsored study to evaluate the science of nitrate PM 2.5 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 PM 2.5 concentrations, including OC, are unadjusted from final validated values. Figure
from WDNR PM 2.5 study (2011) - see Appendix 3.

Figure 4

(a) All speciated PM 2.5 concentrations, including OC, are unadjusted from final validated values. Figure
from WDNR PM 2.5 study (2011) - see Appendix 3.11 4.3 Temporally-Resolved Emission Estimates

The nonattainment violations occurre d 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

PM 2.5 concentrations. The WDNR PM 2.5 study (2011 – see Appendix 3) also evaluated the collective month-of-year profiles of average 24-hour FRM PM 2.5 levels during 1999-20 10. This assessment identified the meteorological winter months of December, January, and February as having both the highest monthly average PM 2.5 concentrations and the highest mont hly percentage of site-days with 24-
hour PM 2.5 concentrations greater than 30 μ g/m 3 (Figures 5 and 6). Accordingly, the WDNR designed
and constructed emission inventories for this PM 2.5 redesignation request to focus on pollution-related activity levels during the winter months (more sp ecifically - for an average January weekday).

Figure 5

(a) The WDNR operated seven FRM PM 2.5 monitoring sites in Milwaukee County during Jan 1999 - Dec 2010 -- collecting a total of 9065 validated FRM 24-Hr PM 2.5 samples. Figure from WDNR PM 2.5 study (2011) - see Appendix 3.12 Figure 6

(a) The WDNR operated two FRM PM 2.5 monitoring sites in Waukesha County during Jan 1999 - Dec 2010 -- collecting a total of 6445 validated FRM 24-Hr PM 2.5 samples. Figure from WDNR PM 2.5 study (2011) - see Appendix 3.

4.4 Base Year Inventory (Non attainment Year Inventory)

The WDNR has prepared a comprehensive inve ntory of actual emissions for Wisconsin’s PM 2.5 nonattainment area (counties of Milwaukee, Racine , and Waukesha) for the base year 2006. The emission rates are set for activity levels during an av erage January weekday for reasons that are explained in Section 4.3. This base year inventory includ es area, mobile, non-road, and point sources for direct

PM 2.5 , NO

x , SO 2 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 estim ated 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 calculati ons. Emissions were estimated by collecting processlevel information from each facility that qualifies for in clusion 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 grow th factors from the Economic Growth and Analysis13 System (EGAS) model. The “Default REMI 6.0 SCC Configuration” for EGAS was used. If growth factors were not available for a certain SCC, populat ion based growth factors were derived based on the Wisconsin Department of Administration’s Demographi c Services Center population reports. A table of the EGAS growth factors and the 2006 area source em issions by county and SCC is located in Appendix

5.

Onroad Inventory

The 2006 onroad mobile emission estimates were crea ted 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, Assess ment 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 independ ent contractor, which, through contracts with LADCO, has developed state specific emission inventory data, including growth factors, for the entire LADCO region. Aircraft emissions were calcula ted using the Federal Aviation Administration’s Emissions and Dispersion Modeling System (EDMS).

Emissions Summary

The following tables summarize the 2006 NO

x , PM 2.5 direct, SO 2 and VOC emissions.

Table 4 - Total NO

x 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 PM 2.5 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 SO 2 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 estim ated 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 calculati ons. Emissions were estimated by collecting processlevel information from each facility that qualifies for in clusion 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 mo del. The “Default REMI 6.0 SCC Configuration” for EGAS was used. If growth factors were not av ailable for a certain SCC, population based growth factors were derived based on the Wisconsin Depa rtment of Administration’s Demographic Services Center population reports. A table of the EGAS grow th 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 accordan ce with the Users Guide to MOVES (U.S. EPA, Office of Transportation and Air Quality, Assess ment 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, Transportati on 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 a nd rail emissions were es timated using linear extrapolation from the 2005 and 2008 emissions invent ories. Pechan, an independent contractor, provided marine and rail emission estimates via th e LADCO for Wisconsin [LADCO, 2012]. Aircraft emissions were calculated using the Fe deral Aviation Administration’s EDMS.

Emissions Summary

The following tables summarize the 2010 NO

x , PM 2.5 direct, SO 2 and VOC emissions.

Table 8 - Total NO

x 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 PM 2.5 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 SO 2 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 tre nds are an important gauge for continued compliance
with the PM 2.5 NAAQS.

4.7 Permanent and Enforceable Emission Reductions

Permanent and enforceable reductions of NO

x , VOC and SO 2 have contributed to attaining the 24-hour

PM 2.5 NAAQS in the nonattainment counties of Milwa ukee, Racine, and Waukesha. Some of these emission reductions were due to the implementation of the NO

x SIP Call, VOC Reasonably Available Control Technology (RACT) limitations, NO

x 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 PM 2.5 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 PM 2.5 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 PM 2.5 and NO

x are established as part of a PM 2.5 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 PM 2.5 , and precursors NO

x , SO 2 , 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 de rived 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 nonattainme nt 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 th e 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 re quirement for reasonable further progress, attainment, or maintenance. For the purposes of these emission budge ts, 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 NO

x PM 2.5 SO 2 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 11.9819 6.0 CONTROL MEASURES AND REGULATIONS

CAA Section 107(d)(3)(E)(iv) specifies that a nonattain ment area cannot be redesignated to attainment unless the U.S. EPA determines that the improveme nts in air quality are due to permanent and
enforceable emission reductions. This secti on documents that reductions in direct PM 2.5 and PM 2.5 precursor emissions (e.g., SO 2 and NO

x ) have occurred in Wisconsin as a result of permanent and enforceable federal and state control measures, acc ounting for the significant improvements realized in
measured PM 2.5 air quality. Descriptions of the federal and state measures follow.

6.1 Federal Control Measures

Improvements in Wisconsin’s ambient PM 2.5 air quality are partially due to federal control programs that
have reduced emissions in Wiscons in and other states. Post-2002 NO

x , SO 2 and PM 2.5 federal control measures that have resulted in improvements in ambient PM 2.5 levels are listed in Table 13.

Table 13 – Post-2002 Federal Control Programs

Control Measure PM NO

x SO 2 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

NO

x 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 NO

x , PM and sulfur compounds from new cars and light duty trucks, including large sport utility and passenger vans. The final Tier 2 standards
limit NO

x 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 pe r million (ppm) by 2006, about an order of magnitude
lower than 2002 levels. Sulfur in gasoline interferes with the operati on of catalytic converters on vehicles resulting in higher NO

x emissions. In addition to facilitating lo wer 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 t hose 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 NO

x 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 NO

x emission limits for heavy- duty diesel and gasoline highway engines and also required highway diesel fuel sulfur content to be re duced 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 NO

x emissions from new engines using low sulfur diesel, compared to previous genera tion engines using higher sulfur content diesel. The20 reduction in fuel sulfur content also provided a dditional immediate reductions in sulfate particle
emissions from all on-road diesel vehicles. Fu rther 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 st andards apply to all 2006 model year and newer motorcycles, including scooters and mopeds. In additi on, motorcycles with the largest engines are subject to more stringent NO

x 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 NO

x 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 re placed with the newer, lower emitting engines. Nonetheless, the required reducti on in fuel sulfur content did yield an immediate reduction in sulfate particle emissions from all non-road diesel vehicles.

NO

x SIP Call

In October 1998, the U.S. EPA issued a NO

x SIP Call requiring the District of Columbia and 22 states to
reduce emissions of NO

x . 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 obligatio ns regarding regionally tran sported pollution, the U.S.
EPA finalized the Clean Air Interstate Rule (CAIR) to reduce emissions NO

x and SO 2 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. Nationwid e, CAIR resulted in an estimated reduction of NO

x 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). Howe ver, due to ongoing litigation involving CAIR and CSAPR, all potential emission reductions resulting fro m 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 PM 2.5 air quality are partially due to state control programs that
have reduced emissions in Wisconsin. Post-2002 NO

x , SO 2 and PM 2.5 state control measures that have resulted in improvements in ambient PM 2.5 levels are listed in Table 14.

Table 14 – Post-2002 State Control Programs

Control Measure PM NO

x SO 2 NOx RACT X

VOC RACT Mercury Multi-pollutant Rule X X Best Available Retrofit Technology (BART) X X X

NO

x RACT

For purposes of reducing ambient ozone levels, the WDNR promulgated NO

x RACT rules. These rules are located in Chapter NR 428 of the Wisconsin Administrative Code. An added benefit from implementing and enforcing these NO

x RACT requirements is the resulting reduction in PM 2.5

.

VOC RACT

For purposes of reducing ambient ozone levels, th e 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 PM 2.5

.

Mercury Multi-Pollutant Rule

NR 446, Wis. Adm. Code, allows large or small coal -fired electrical generating units the option to reduce
NO

x , SO 2 , 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 NO

x , SO 2 , 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 a nd pulp and paper facilities.22 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 de monstrate continued attainment of the applicable NAAQS for at least 10 years after the U.S. EPA approv es a redesignation to attainment. Eight years after the redesignation, the state must submit a revised ma intenance 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 invent ories for 2020 and 2025 for the Milwaukee, Racine, and Waukesha three-county PM 2.5 nonattainment area. The WDNR pe rformed emission projections using the following methodologies.

Point Source Inventory

Electric Generating Unit (EGU) projected 2018 emissions for NO

x , SO 2 , and VOC were based on IPM3.0 and included “will do” adjustments identified by Wisconsin. These adjustments included NO

x RACT. Non-EGU projected 2018 emissions were derived by appl ying 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 extra polation from 2010 and 2018 emissions. The 2020 and 2025 point source emissions calculations are located in Appendix 7.

EGU projected 2018 emissions for PM 2.5 were not available from LADCO. Therefore, the 2020 and 2025

PM 2.5 emission inventories for the EGU source category were created by projecting forward the Wisconsin 2008 base year emissions in ventory submitted to the U.S. EPA in 2010 for the NEI. This same approach was used in the WDNR’s recent ozone re designation 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 factor s were modified slightly to reflect more recent AEO reports (2008 – 2012) [EIA, 2012]. In 2020, energy consumpti on 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 in ventory submitted to the U.S. EPA in 2010 for the NEI. This same approach was used in the WDNR’s recent ozone re designation 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 c onservatively 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 estim ates were created by using the U.S. EPA NMIM model (2009/05/04 Version). In addition, marine and rail emissi ons 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 inte r/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 Tr ansportation 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 Prep aration in State Implementation Plans and Transportation Conformity (U.S. EPA, Office of Tr ansportation 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 NO

x , PM 2.5 direct, SO 2 and VOC emissions.

Table 15 - Total NO

x 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 PM 2.5 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 SO 2 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 pr esented in the tables below and demonstrate that
emissions of direct PM 2.5 , NO

x , SO 2 , and VOC will decrease in future year s. 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 – NO

x 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 – PM 2.5 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 -3.2926 Table 21 – SO 2 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 atta inment of the 2006 24-hour PM 2.5 NAAQS in the counties of Milwaukee, Racine, and Waukesha depends on Wisc onsin’s effort toward tracking in dicators of continued attainment during the maintenance period. The tracking plan for these areas primarily consists of continued PM 2.5 monitoring in accordance with the requirements of 40 CFR Part 58.

7.4 Contingency Plan

Despite the best efforts to demonstrate con tinued compliance with the NAAQS, the ambient PM 2.5 concentrations may exceed or violate the NAAQS. Th erefore, as required by section 175A of the CAA, Wisconsin has provided contingency measures to promptly correct a future PM 2.5 air quality problem. These contingency measures would be implemented if a future 24-hour PM 2.5 design value for any of the
current monitors is above the PM 2.5 24-hour NAAQS (35 μ g/m 3 ).

Contingency Measures Approach:

1. Evaluation of Adequacy of Existing Control Measu res – If a violation occurs, the first and most important step Wisconsin will take will be to ev aluate the adequacy of already-adopted control measures to rectify the violation. Control measur es 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 m easure 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 measu res 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 PM 2.5 concentrations, additional local control measures will not be necessary. In that case, Wisconsin will submit to U.S. EPA an analysis to demonstrate that the27 existing measures that have not been fully impl emented 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 so cial 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 a dditional 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 hear ing, 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 NO

x RACT program:

 to include a larger geographic area, and/or

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

 to increase the cost-effectiv eness thresholds utilized as a basis for Wisconsin’s NO

x RACT Program

2. Consideration of PM 2.5 and SO 2 RACT

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

4. Ammonia (NH 3 ) emission reduction strategies

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

NH 3 , which is a gaseous precursor to nitrate (NO 3 ) PM 2.5 . This proposed action is based upon a conceptual model developed by Stanier, et.al (2010) to explain winter time PM 2.5 episodes in Wisconsin. Namely, from Stanier’s model, it is s uggested that "Controls of ammonia or nitrate [and, by extension, NO

x ] are likely to decrease [wintertime PM 2.5 ] episode concentrations."

No contingency measure shall be implemented w ithout providing the opportunity for full public participation during which the relative costs and benef its 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.28 8.0 PUBLIC PARTICIPATION

The WDNR will publish in the State’s official newspa per of record (The Wisconsin State Journal) a notice that it will hold a public hearing on this PM 2.5 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 doc umentation 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 PM 2.5 NAAQS. In addition, all applicable provisions of the CAA and PM 2.5 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 PM 2.5 NAAQS.30 10.0 REFERENCES

Damberg, R., 2007: Policies for Addressing PM 2.5 Precursor Emissions. U.S. EPA Office of Air Quality Planning and Standards, June 20.

EIA, 2012: U.S. Energy Information Administ ration, 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 Trans portation 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 Transpor tation Conformity. U.S. EPA, Office of Transportation and Air Quality, Transportation and Regional Program s 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 PM 2.5 Levels Southeastern Wisconsin for Purposes of Designing Emi ssion Inventories for Inclusion in a Request for Redesignation to Attainment PM 2.5 Nonattainment Counties of Milwaukee, Racine, and Waukesha. Bureau of Air Management Report, 26 pp, Augus t. Full report contained in Appendix 3.