Appendix A 

Annual and Daily PM2.5 Monitoring Data
 Data Completeness and Quarterly Averages of Fine Particulate Material in Mich

Guideline on Data Handling Conventions for the PM NAAQS, p 4 "If you're doing an intermediate calculation, such as quarterly 

average PM10 value from the 24-hour values, keep all digits on your calculator."

updated 3/4/11

shaded cell indicates sampling frequency changed to 1:6 red'n in samplling frequency from 1shaded cell indicates sampling frequency changed to 1:3 from 1:1 sampling frequeny increased to dai

First Quarter Second Quarter Third Quarter Fourth Quarte

AIRSID Site POC Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Q

260990009 New Haven 1 1999 30 24 80 11.66 30 22 73 13.55 31 31 100 13.95 5 27 540 1260990009 New Haven 1 2000 31 29 94 16.26 30 29 97 12.76 31 30 97 12.43 30 25 83 1260990009 New Haven 1 2001 30 28 93 14.75 31 28 90 14.68 30 29 97 13.18 31 30 97 1260990009 New Haven 1 2002 30 28 93 11.86 30 28 93 13.37 31 30 97 15.19 31 31 100 1260990009 New Haven 1 2003 30 29 97 14.47 30 26 87 12.92 31 31 100 13.08 30 28 93 1260990009 New Haven 1 2004 31 31 100 11.82 30 30 100 11.49 31 30 97 14.23 30 30 100 1260990009 New Haven 1 2005 30 30 100 15.21 31 31 100 14.21 30 29 97 16.14 31 30 97 1260990009 New Haven 1 2006 30 30 100 13.68 15 15 100 9.65 15 12 80 9.50 16 15 94 1260990009 New Haven 1 2007 30 29 97 12.37 30 29 97 9.58 31 27 87 13.33 30 29 97 1260990009 New Haven 1 2008 31 30 97 13.24 30 27 90 9.10 31 30 97 10.91 30 30 100 260990009 New Haven 1 2009 30 28 93 13.71 31 31 100 6.30 30 30 100 8.09 31 27 87 260990009 New Haven 1 2010 30 30 100 9.35 30 30 100 7.27 31 31 100 10.28 31 31 100 261150005 Luna Pier 1 1999 --- --- --- --- --- --- --- --- --- --- --- --- 5 5 100 1261150005 Luna Pier 1 2000 31 30 97 16.92 30 29 97 14.54 31 29 94 14.33 30 29 97 1261150005 Luna Pier 1 2001 30 27 90 16.24 31 25 81 16.58 30 29 97 15.68 31 30 97 1261150005 Luna Pier 1 2002 30 30 100 14.99 30 27 90 17.77 31 28 90 15.96 31 25 81 1261150005 Luna Pier 1 2003 30 28 93 15.93 30 27 90 12.84 31 31 100 14.36 30 30 100 1261150005 Luna Pier 1 2004 31 26 84 13.02 30 30 100 12.61 31 31 100 14.83 30 29 90 1261150005 Luna Pier 1 2005 30 28 93 16.50 31 27 87 13.40 30 27 90 19.78 31 30 97 1261150005 Luna Pier 1 2006 30 27 90 14.55 30 29 97 10.91 31 30 97 12.98 31 30 97 1261150005 Luna Pier 1 2007 30 29 97 12.26 30 26 87 11.41 31 29 94 14.87 30 30 100 1261150005 Luna Pier 1 2008 31 31 100 13.25 30 30 100 9.76 31 29 94 12.28 30 27 90 1261150005 Luna Pier 1 2009 30 30 100 13.84 31 30 97 8.19 30 28 93 9.75 31 27 87 261150005 Luna Pier 1 2010 30 30 100 10.07 30 29 97 7.76 31 31 100 10.73 31 29 94 
First Quarter Second Quarter Third Quarter Fourth Quarte

AIRSID Site POC Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Q

261250001 Oak Park 1 1999 30 25 83 13.83 30 18 60 14.84 31 25 81 14.64 30 26 87 1261250001 Oak Park 1 2000 31 24 77 18.57 30 28 93 14.79 31 18 58 11.88 30 20 67 1261250001 Oak Park 1 2001 30 28 93 15.58 31 26 84 17.30 30 26 87 14.81 31 16 52 1261250001 Oak Park 1 2002 30 15 50 12.73 30 21 70 17.29 31 27 87 16.07 31 27 87 1261250001 Oak Park 1 2003 30 28 93 18.39 30 27 90 13.79 31 30 97 13.66 30 30 100 1261250001 Oak Park 1 2004 31 30 97 13.73 30 30 100 11.26 31 30 97 14.78 30 27 90 1261250001 Oak Park 1 2005 30 27 90 17.49 31 31 100 13.77 30 30 100 17.61 31 30 97 1261250001 Oak Park 1 2006 30 27 90 13.51 15 15 100 10.40 15 14 93 10.76 16 16 100 1261250001 Oak Park 1 2007 30 30 100 12.48 30 28 93 12.27 31 30 97 14.68 30 30 100 1261250001 Oak Park 1 2008 31 30 97 13.59 30 28 93 8.75 31 30 97 11.31 30 30 100 261250001 Oak Park 1 2009 30 30 100 14.24 31 30 97 7.26 30 27 90 9.14 31 31 100 261250001 Oak Park 1 2010 30 29 97 9.91 30 30 100 7.36 31 30 97 10.74 31 29 94 261470005 Port Huron 1 1999 16 23 144 12.13 30 25 83 13.46 31 28 90 15.12 30 27 90 1261470005 Port Huron 1 2000 31 21 68 17.04 30 26 87 14.65 31 29 94 12.83 30 26 87 1261470005 Port Huron 1 2001 30 28 93 13.65 31 30 97 16.26 30 27 90 14.12 31 27 87 1261470005 Port Huron 1 2002 30 29 97 12.13 30 26 87 14.03 31 29 94 16.28 31 29 94 1261470005 Port Huron 1 2003 30 24 80 18.73 30 30 100 13.11 31 29 94 13.05 30 27 90 1261470005 Port Huron 1 2004 31 28 90 11.44 30 28 93 12.81 31 27 87 13.18 30 29 97 1261470005 Port Huron 1 2005 30 30 100 16.76 31 28 90 14.73 30 24 80 16.47 31 29 94 1261470005 Port Huron 1 2006 30 30 100 15.52 15 15 100 10.71 15 15 100 9.09 16 16 100 1261470005 Port Huron 1 2007 30 29 97 12.64 30 28 93 9.97 31 30 97 14.49 30 29 97 1261470005 Port Huron 1 2008 31 30 97 13.66 30 29 97 9.78 31 30 97 11.56 30 29 97 261470005 Port Huron 1 2009 30 27 90 13.99 31 31 100 6.92 30 29 97 8.86 31 30 97 261470005 Port Huron 1 2010 30 28 93 8.53 30 30 100 8.06 31 30 97 10.32 31 31 100 261610008 Ypsilanti 1 1999 --- --- --- --- --- --- --- --- 20 18 90 14.72 30 28 93 1261610008 Ypsilanti 1 2000 31 13 42 16.82 30 28 93 12.85 31 31 100 13.21 30 30 100 1261610008 Ypsilanti 1 2001 30 28 93 15.92 31 30 97 15.46 30 29 97 14.15 31 30 97 1261610008 Ypsilanti 1 2002 30 29 97 14.71 30 30 100 14.57 31 26 84 16.43 31 29 94 1261610008 Ypsilanti 1 2003 30 25 83 16.70 30 28 93 15.05 31 30 97 14.39 30 29 97 1261610008 Ypsilanti 1 2004 31 30 97 13.74 30 28 93 11.76 31 31 100 14.17 30 29 97 1261610008 Ypsilanti 1 2005 30 29 97 17.49 31 27 87 14.27 30 29 97 17.69 31 29 94 1261610008 Ypsilanti 1 2006 30 24 80 14.80 30 29 97 10.67 31 29 94 13.12 31 23 74 1261610008 Ypsilanti 1 2007 30 27 90 12.95 30 27 90 11.68 31 30 97 13.78 30 30 100 1261610008 Ypsilanti 1 2008 31 28 90 13.23 30 30 100 9.07 31 31 100 11.21 30 29 97 1261610008 Ypsilanti 1 2009 30 29 97 13.50 31 30 97 7.76 30 28 93 9.27 31 31 100 261610008 Ypsilanti 1 2010 30 29 97 9.97 30 28 93 7.32 31 31 100 10.29 31 30 97 
First Quarter Second Quarter Third Quarter Fourth Quarte

AIRSID Site POC Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Q

261610008 Ypsilanti 2 2001 15 14 93 16.19 16 16 100 13.99 15 12 80 12.18 15 14 93 1261610008 Ypsilanti 2 2002 15 13 87 12.35 15 11 73 13.34 15 11 73 13.17 15 14 93 1261610008 Ypsilanti 2 2003 15 14 93 16.80 15 14 93 13.59 16 16 100 17.41 15 14 93 1261610008 Ypsilanti 2 2004 15 14 93 10.29 15 14 93 9.83 16 16 100 13.21 15 15 100 1261610008 Ypsilanti 2 2005 15 15 100 18.79 15 15 100 15.01 15 13 87 21.35 16 16 100 1261610008 Ypsilanti 2 2006 15 12 80 17.93 16 13 81 10.52 16 14 88 11.64 16 16 100 1261610008 Ypsilanti 2 2007 7 6 86 17.67 8 6 75 9.47 7 7 100 14.90 8 6 75 1261610008 Ypsilanti 2 2008 8 13 163 15.17 7 7 100 9.70 8 7 88 18.16 7 7 100 261610008 Ypsilanti 2 2009 15 14 93 12.97 16 16 100 9.04 15 14 93 8.02 15 14 93 261610008 Ypsilanti 2 2010 15 13 87 8.32 15 15 100 8.11 16 16 100 10.25 15 15 100 1261630001 Allen Park 1 1999 --- --- --- --- 17 48 282 18.99 92 78 85 16.63 92 83 90 1261630001 Allen Park 1 2000 91 81 89 16.99 91 86 95 13.69 92 87 95 14.46 92 85 92 1261630001 Allen Park 1 2001 90 76 84 20.05 91 80 88 16.68 92 86 93 17.46 92 55 60 1261630001 Allen Park 1 2002 90 78 87 15.32 91 72 79 16.15 92 66 72 17.33 92 87 95 1261630001 Allen Park 1 2003 90 79 88 17.37 91 86 95 15.25 92 80 87 15.11 90 80 89 1261630001 Allen Park 1 2004 91 74 81 15.41 91 85 93 12.22 92 89 97 16.18 92 83 90 1261630001 Allen Park 1 2005 90 88 98 18.45 91 86 95 13.77 92 89 97 17.15 92 86 93 1261630001 Allen Park 1 2006 90 81 90 13.70 91 83 91 11.59 92 87 95 13.76 92 90 98 1261630001 Allen Park 1 2007 90 86 96 12.92 91 88 97 10.28 92 86 93 13.74 92 92 100 1261630001 Allen Park 1 2008 91 88 97 13.86 91 90 99 10.18 92 86 93 12.98 92 87 95 1261630001 Allen Park 1 2009 90 84 93 13.87 91 89 98 8.94 92 79 86 11.32 92 86 93 1261630001 Allen Park 1 2010 90 80 89 11.19 91 87 96 8.83 92 84 91 11.83 92 83 90 261630001 Allen Park 2 1999 --- --- --- --- 9 6 67 26.08 15 13 87 18.22 15 12 80 1261630001 Allen Park 2 2000 16 13 81 16.82 15 12 80 13.32 15 14 93 15.29 15 15 100 1261630001 Allen Park 2 2001 15 14 93 18.62 16 15 94 15.82 15 15 100 16.22 15 13 87 1261630001 Allen Park 2 2002 15 6 40 13.10 15 9 60 11.80 15 7 47 16.19 15 15 100 1261630001 Allen Park 2 2003 15 10 67 21.21 15 15 100 16.63 16 15 94 18.77 15 15 100 1261630001 Allen Park 2 2004 15 15 100 12.03 15 14 93 10.63 16 15 94 13.68 15 14 93 1261630001 Allen Park 2 2005 15 14 93 19.61 15 15 100 16.22 15 15 100 22.47 16 15 94 1261630001 Allen Park 2 2006 15 13 87 17.32 15 13 87 11.35 15 13 87 12.00 16 15 94 1261630001 Allen Park 2 2007 7 5 71 18.04 8 6 75 8.62 7 6 86 17.47 8 6 75 1261630001 Allen Park 2 2008 8 8 100 14.28 7 7 100 11.31 8 5 63 21.02 7 7 100 261630001 Allen Park 2 2009 15 15 100 14.55 16 15 94 10.11 15 15 100 9.43 15 11 73 1261630001 Allen Park 2 2010 monitor moved to Dearborn
First Quarter Second Quarter Third Quarter Fourth Quarte

AIRSID Site POC Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Q

261630015 SW HS 1 1999 12 8 67 18.69 30 27 90 16.54 31 25 81 18.54 30 25 83 1261630015 SW HS 1 2000 31 30 97 20.34 30 28 93 17.04 31 31 100 16.29 30 30 100 1261630015 SW HS 1 2001 30 29 97 19.33 31 28 90 20.05 30 30 100 17.67 31 27 87 1261630015 SW HS 1 2002 30 27 90 16.80 30 27 90 17.42 31 25 81 18.27 31 29 94 1261630015 SW HS 1 2003 30 26 87 17.41 30 27 90 15.39 31 30 97 16.68 30 27 90 1261630015 SW HS 1 2004 31 31 100 14.95 30 27 90 15.01 31 29 94 17.69 30 28 93 1261630015 SW HS 1 2005 30 27 90 20.20 31 27 87 14.73 30 30 100 18.73 31 30 97 1261630015 SW HS 1 2006 30 29 97 16.98 30 26 87 12.26 31 28 90 14.93 31 31 100 1261630015 SW HS 1 2007 30 28 93 15.15 30 30 100 13.06 31 27 87 15.12 30 29 97 1261630015 SW HS 1 2008 31 31 100 16.07 30 30 100 11.00 31 32 103 12.03 30 29 97 1261630015 SW HS 1 2009 30 30 100 15.40 31 28 90 8.18 30 29 97 10.35 31 29 94 1261630015 SW HS 1 2010 30 30 100 11.35 30 30 100 8.98 31 30 97 11.85 31 30 97 1261630016 Linw ood 1 1999 --- --- --- --- 17 28 165 19.30 92 79 86 15.76 92 82 89 1261630016 Linw ood 1 2000 91 83 91 17.67 91 74 81 13.82 92 78 85 13.52 92 90 98 1261630016 Linw ood 1 2001 90 81 90 17.19 91 84 92 15.66 92 83 90 16.57 92 79 86 1261630016 Linw ood 1 2002 90 73 81 15.04 91 82 90 15.61 92 75 82 16.78 92 88 96 1261630016 Linw ood 1 2003 90 84 93 18.36 91 85 93 15.33 92 86 93 14.94 92 71 77 1261630016 Linw ood 1 2004 91 76 84 14.87 91 80 88 12.10 92 82 89 14.78 92 86 93 1261630016 Linw ood 1 2005 90 87 97 18.92 91 79 87 14.78 92 84 91 16.62 92 88 96 1261630016 Linw ood 1 2006 90 79 88 13.04 15 14 93 11.58 15 13 87 12.58 16 17 106 1261630016 Linw ood 1 2007 30 26 87 13.98 30 26 87 12.12 31 30 97 14.74 30 29 97 1261630016 Linw ood 1 2008 31 29 94 14.59 30 30 100 9.58 31 29 94 12.61 30 30 100 1261630016 Linw ood 1 2009 30 27 90 14.27 31 27 87 8.22 30 26 87 9.23 31 31 100 261630016 Linw ood 1 2010 30 26 87 10.42 30 28 93 8.55 31 31 100 11.34 31 30 97 261630019 E 7 Mile 1 2000 --- --- --- --- 21 17 81 13.93 31 24 77 13.74 30 29 97 1261630019 E 7 Mile 1 2001 30 26 87 14.58 31 29 94 14.88 30 30 100 14.76 31 30 97 1261630019 E 7 Mile 1 2002 30 26 87 14.39 30 28 93 15.83 31 28 90 17.86 31 30 97 1261630019 E 7 Mile 1 2003 30 26 87 17.05 30 30 100 14.80 31 30 97 13.98 30 29 97 1261630019 E 7 Mile 1 2004 31 31 100 13.23 30 29 97 12.47 31 30 97 15.44 30 29 97 1261630019 E 7 Mile 1 2005 30 28 93 19.82 31 31 100 14.48 30 29 97 17.43 31 29 94 1261630019 E 7 Mile 1 2006 30 30 100 15.20 15 15 100 10.39 15 14 93 11.78 16 16 100 1261630019 E 7 Mile 1 2007 30 30 100 13.20 30 28 93 11.16 31 31 100 14.36 30 27 90 1261630019 E 7 Mile 1 2008 31 30 97 13.60 30 30 100 9.51 31 26 84 11.42 30 30 100 1261630019 E 7 Mile 1 2009 30 30 100 14.73 31 31 100 7.61 30 26 87 9.88 31 28 90 261630019 E 7 Mile 1 2010 30 30 100 10.27 30 23 77 8.68 31 26 84 11.18 31 29 94 
First Quarter Second Quarter Third Quarter Fourth Quarte

AIRSID Site POC Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Q

261630025 Livonia 1 1999 --- --- --- --- --- --- --- --- 15 15 100 15.21 30 19 63 1261630025 Livonia 1 2000 31 30 97 16.53 30 28 93 14.08 31 30 97 13.28 30 25 83 1261630025 Livonia 1 2001 30 27 90 15.39 31 30 97 15.67 30 29 97 15.14 31 29 94 1261630025 Livonia 1 2002 30 18 60 13.33 30 28 93 14.26 31 29 94 16.47 31 28 90 1261630025 Livonia 1 2003 30 26 87 15.96 30 28 100 15.36 31 31 100 13.89 30 27 90 1261630025 Livonia 1 2004 31 29 94 12.72 30 25 83 11.98 31 28 90 14.13 30 30 100 1261630025 Livonia 1 2005 30 26 87 17.86 31 28 90 11.74 30 30 100 17.45 31 30 97 1261630025 Livonia 1 2006 30 27 90 13.49 15 14 93 11.23 15 15 100 10.01 16 17 106 1261630025 Livonia 1 2007 30 26 87 12.23 30 30 100 10.59 31 31 100 13.76 30 27 90 1261630025 Livonia 1 2008 31 27 87 13.56 30 29 97 9.50 31 31 100 11.21 30 30 100 261630025 Livonia 1 2009 30 29 97 13.93 31 31 100 7.40 30 28 93 9.19 31 28 90 261630025 Livonia 1 2010 30 28 93 9.37 30 29 97 6.65 31 27 87 10.98 31 30 97 261630033 Dearborn 1 1999 19 8 42 13.98 30 26 87 16.75 31 28 90 18.31 30 29 97 1261630033 Dearborn 1 2000 31 29 94 22.76 30 23 77 20.13 31 27 87 17.56 30 29 97 2261630033 Dearborn 1 2001 30 29 97 20.95 31 29 94 18.58 30 28 93 18.27 31 29 94 2261630033 Dearborn 1 2002 30 29 97 20.99 30 28 93 18.15 31 29 94 20.22 31 30 97 2261630033 Dearborn 1 2003 30 28 93 22.59 30 27 90 19.03 31 27 87 17.83 30 28 93 1261630033 Dearborn 1 2004 31 29 94 17.71 30 25 83 16.10 31 25 81 17.46 30 28 93 1261630033 Dearborn 1 2005 30 28 93 21.50 31 31 100 16.57 30 28 93 18.22 31 28 90 1261630033 Dearborn 1 2006 30 28 93 18.79 30 29 97 12.85 31 27 87 15.56 31 31 100 1261630033 Dearborn 1 2007 30 29 97 18.84 30 29 97 15.20 31 29 94 16.02 30 27 90 1261630033 Dearborn 1 2008 31 31 100 16.59 30 28 93 11.18 31 30 97 13.51 30 30 100 1261630033 Dearborn 1 2009 30 29 97 17.29 31 31 100 8.42 30 27 90 10.42 31 31 100 1261630033 Dearborn 1 2010 30 27 90 11.70 30 30 100 9.39 31 30 97 12.32 31 31 100 1261630033 Dearborn 2 2010 15 14 93 13.18 15 15 100 10.05 16 15 94 12.30 15 15 100 1261630036 Wyandotte 1 1999 14 7 50 17.06 30 17 57 14.55 31 26 84 18.85 30 21 70 1261630036 Wyandotte 1 2000 31 16 52 19.30 30 28 93 16.52 31 29 94 15.64 30 30 100 1261630036 Wyandotte 1 2001 30 30 100 21.49 31 30 97 17.53 30 29 97 18.53 31 24 77 1261630036 Wyandotte 1 2002 30 24 80 15.40 30 28 93 15.98 31 28 90 16.51 31 25 81 1261630036 Wyandotte 1 2003 30 24 80 15.07 30 24 80 20.37 31 28 90 16.37 30 29 97 261630036 Wyandotte 1 2004 31 27 87 14.48 30 29 97 12.74 31 29 94 15.91 30 28 93 261630036 Wyandotte 1 2005 30 29 97 16.96 31 28 90 14.93 30 29 97 18.58 31 27 87 1261630036 Wyandotte 1 2006 30 29 97 15.10 30 26 87 10.95 31 29 94 13.69 31 29 94 1261630036 Wyandotte 1 2007 30 29 97 13.75 30 28 93 11.96 31 30 97 14.60 30 29 97 1261630036 Wyandotte 1 2008 31 31 100 12.55 30 29 97 9.47 31 30 97 11.95 30 30 100 261630036 Wyandotte 1 2009 30 28 93 14.21 31 30 97 7.86 30 28 93 9.89 31 25 81 261630036 Wyandotte 1 2010 30 23 77 9.44 30 29 97 7.84 31 29 94 11.30 31 31 100 
First Quarter Second Quarter Third Quarter Fourth Quarte

AIRSID Site POC Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Quart. Sch # Obs. # % Q

261630038 New berry 1 2004 --- --- --- --- --- --- --- --- --- --- --- --- 2 2 100 2261630038 New berry 1 2005 30 28 93 16.98 31 25 81 14.60 30 22 73 17.66 261630038 New berry 1 2006 30 29 97 11.09 31 27 87 14.34 31 28 90 261630038 New berry 1 2007 30 27 90 13.63 30 27 90 12.85 31 28 90 15.35 30 30 100 261630038 New berry 1 2008 31 29 94 13.95 30 30 100 10.15 31 28 90 12.16 30 28 93 261630038 New berry 1 2009 30 25 83 13.24 31 29 94 7.89 30 27 90 9.43 31 29 94 1261630038 New berry 1 2010 30 27 90 9.39 30 30 100 8.73 31 31 100 11.92 31 30 97 1261630039 FIA\Lafayette St 1 2005 --- 7 --- 18.20 31 28 90 1261630039 FIA\Lafayette St 1 2006 30 29 97 14.78 30 30 100 11.71 31 31 100 14.20 31 30 97 

261630039 FIA\Lafayette St 1 2007 30 29 97 13.83 30 30 100 12.98 31 30 97 14.65 30 28 93 261630039 FIA\Lafayette St 1 2008 31 30 97 14.26 30 28 93 10.70 31 29 94 12.80 30 29 97 

261630039 FIA\Lafayette St 1 2009 30 29 97 14.67 31 31 100 7.89 30 30 100 9.44 92 84 91 1261630039 FIA\Lafayette St 1 2010 90 83 92 10.69 91 89 98 8.65 92 76 83 11.22 92 84 91 

A 3-year annual average of 15.1 ug/m3 would violate the NAAQS according to the data handling conventions in 40 CFR part 50

vandalism

vandalism
Current

Sampling 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 99-01 00-02 01-03 02-04 03-05 04-0

AIRS ID Site POC Freq

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile

98th 

% ile Avg Avg Avg Avg Avg Av

260990009 New Haven 1 1 in 3 31.9 33.2 42.0 35.6 31.8 31.9 41.5 34.4 29.0 28.9 26.2 25.5 36 37 36 33 35 36 

261150005 Luna Pier 1 1 in 3 18.1 37.2 39.2 42.7 34.7 35.0 49.3 32.6 32.2 28.6 23.6 26.3 32 40 39 37 40 39 261250001 Oak Park 1 1 in 3 42.8 40.7 39.4 38.4 36.6 32.5 52.2 33.0 35.3 30.4 30.1 27.1 41 40 38 36 40 39 

261470005 Port Huron 1 1 in 3 44.5 33.1 40.5 35.3 37.2 32.2 47.6 37.9 36.3 31.0 29.9 25.8 39 36 38 35 39 39 261470005 Port Huron 2 --- --- --- 35.9 37.7 38.0 --- --- --- --- 36 37 37 --- --- --- 261610008 Ypsilanti 1 1 in 3 40.6 30.3 39.7 30.9 38.8 31.5 52.1 31.3 34.5 28.2 28.2 23.3 37 34 36 34 41 38 

261610008 Ypsilanti 2 1 in 6 --- --- 39.0 32.6 32.5 31.2 54.6 33.0 30.6 31.3 29.4 22.4 39 36 35 32 39 40 

261630001 Allen Park 1 1 in 1 43.7 38.6 44.2 39.6 40.5 36.9 43.0 32.8 31.0 30.3 29.2 27.8 42 41 41 39 40 38 261630001 Allen Park 2 1 in 6 44.1 34.6 40.1 30.9 39.2 33.8 58.0 34.2 36.2 32.3 32.4 --- 40 35 37 35 44 42 

261630015 SW High Sch. 1 1 in 3 50.2 44.5 42.9 38.2 33.6 36.0 49.7 36.2 34.0 34.3 30.9 26.6 46 42 38 36 40 41 

261630016 Linw ood 1 1 in 6 44.5 40.3 40.9 42.7 46.2 38.3 51.8 36.9 34.3 30.0 31.0 27.9 42 41 43 42 45 42 

261630019 E 7 Mile 1 1 in 6 --- 42.0 42.0 34.4 37.1 35.0 52.3 36.2 31.9 31.9 29.2 28.6 42 39 38 36 41 41 

261630025 Livonia 1 1 in 6 38.4 35.9 44.7 32.7 38.1 32.2 40.2 30.4 32.8 28.3 29.3 25.3 40 38 39 34 37 34 

261630033 Dearborn 1 1 in 3 45.1 45.1 43.2 45.7 42.8 39.4 50.2 43.1 36.6 31.7 35.7 28.6 44 45 44 43 44 44 261630033 Dearborn 2 1 in 6 --- --- --- --- --- --- 31.5 --- 261630036 Wyandotte 1 1 in 3 45.0 42.7 46.6 34.1 34.8 32.3 46.7 33.2 28.6 26.3 26.9 24.4 45 41 39 34 38 37 

261630038 New berry 1 1 in 3 --- --- --- --- --- 36.8 57.5 28.6 33.4 31.5 25.9 30.4 --- --- --- --- --- 41 261630039 FIA/Lafayette 1 1 in 3 --- --- --- --- --- --- 43.9 32.4 34.8 31.7 31.7 27.7 --- --- --- --- --- 38 

A 3-year 24-hour average of 36 ug/m3 would violate the NAAQS according to the data handling conventions in 40 CFR part 50

 98th Percentile PM2.5 Values Averaged over 3 Years

updated 3/1/11
 

Appendix B 

EMISSIONS INVENTORY 

METHODOLOGY 

SUPPORT DOCUMENTATION 

FOR THE 

PM2.5 REQUEST TO REDESIGNATE TO 

ATTAINMENT − SOUTHEAST MICHIGAN 

March 2011 
 

Table of Contents 

Page No.

1. Introduction .......................................................................................................1 

2. EGU Point Sources...........................................................................................1 

3. Non-EGU Point Sources ...................................................................................3 

4. Stationary Area (Non-point) Sources ................................................................7 

5. Non-road Mobile Sources ................................................................................47 

6. On-road Mobile Sources..................................................................................49 
 Page 1 

1. Introduction 

2005 and 2008 Emissions Inventory 

Emissions inventory documentation support for the PM2.5 Request to Redesignate to 

Attainment is provided in this appendix. An inventory was prepared for the following 

Michigan counties: Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and 

Wayne. Mobile estimates for the nonattainment counties were prepared by the 

Southeast Michigan Council of Governments (SEMCOG). The remaining emission 

source categories were developed by the Michigan Department of Environmental 

Quality (MDEQ) and the Lake Michigan Air Director’s Consortium (LADCO). LADCO is 

the Midwest Regional Planning Organization (MRPO) which MDEQ and other Midwest 

states access for a multitude of technical air quality planning activities. The focus of the 

inventory effort was to produce emission inventories for the nonattainment year (2005) 

and the attainment base year (2008). The future year projections (2018 and 2022) take 

into account existing control measures and measures that are promulgated and known 

to be on the way. Many of the future year emission estimates for this inventory product 

were taken from the LADCO Base B Inventory. Where data was not available in the 

Base B inventory, data from the previous inventory cycle - Base M run was utilized, if 

appropriate. Procedures used to prepare the Base M inventory product can be found in 

the Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Technical 

Support Document, prepared by LADCO. LADCO has produced numerous summary 

reports with state and county total emissions, and posted them on their Internet site at: 

 http://www.ladco.org/tech/emis/ 

In a related effort, the 2005 and 2008 Michigan statewide inventories were submitted to 

the U.S. Environmental Protection Agency (EPA) by the MDEQ pursuant to 40 CFR 

Part 51, Subpart A – Emissions Inventory Reporting Requirements. Many of the more 

significant methodologies are described in this appendix. 

2018 and 2022 Growth and Control Factors 

To assess progress for attaining air quality goals, LADCO uses emission activity growth 

and control data to forecast emissions from a 2005 nonattainment year and 2008 

attainment year inventories to two future years of interest. These future years include 

2018 and 2022 (e.g., 2018 is the first milestone for regional haze reasonable progress 

demonstrations). As a contractor to LADCO, Pechan prepared emission control factors 

to support forecasting for 2018 and 2022. Because the incremental level of effort 

required to develop emission activity growth factors for each year over the 2003-2018 

period was nominal, Pechan prepared non-electric generating unit (non-EGU) point, 

area and non-road source growth factors for each year over this entire period. 

For the non-EGU point source, stationary area source and Marine, Air and Railroad 

(MAR) source sectors, the future year emissions for the LADCO states were derived by 

applying growth and control factors to the base year inventory. Growth factors were 

based initially on Economical Growth Analysis System (EGAS version 5.0), and were 
 Page 2

subsequently modified (for select priority categories) by examining emissions activity 

data. 

The report, Development of 2005 Base Year Growth and Control Factors for Lake 

Michigan Air Directors Consortium (LADCO), describes Pechan’s efforts to develop 

emission growth and control data to support future year air quality modeling by LADCO. 

The report is organized into a background chapter and: 

Chapter II, which describes the development of the emission activity growth data; 

Chapter III, which discusses how the emission control data were compiled; 

Chapter IV, which describes the preparation of the growth and control factor files; 

Chapter V, which identifies projection issues for future consideration; and 

Chapter VI, which presents the references consulted in preparing this report. 

The Pechan Growth and Control Factor report is too lengthy to be included in this 

document, but it can be provided upon request or downloaded at: 

http://www.ladco.org/reports/technical_support_document/references/ladco_2005_base

_yr_growth_and_controls_report_final.pdf 

Additional information on the procedures used to project emissions can be found in the 

Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Technical Support 

Document, prepared by LADCO. 

2. EGU Point Sources 

2005 EGU Point Source Methodology 

The 2005 electrical generation unit (EGU) point source data originated with annual 

emissions data provided to MDEQ via the Michigan Air Emissions Reporting System 

(MAERS). Temporal allocation was performed by emission unit, month, day of week, 

and hour using the procedures described in Temporally Allocating Emissions with CEM 

Data for Chemical Transport and SIP Modeling, available at: 

http://www.epa.gov/ttn/chief/conference/ei15/session4/edick.pdf

In addition to the heat input-based temporal profiles described in the paper, separate 

temporal profiles were developed based on Continuous Emissions Monitoring (CEM) 

reported emissions of nitrogen oxides (NOx) and sulfur dioxide (SO2) and these profiles 

were used instead of heat input to temporalize annual emissions of the respective 

pollutants into winter weekday. The CEM data used as the basis of the profiles was for 

2004 through 2006, obtained from the EPA Clean Air Markets Division (CAMD) website: 

http://cfpub.epa.gov/gdm/index.cfm?fuseaction=iss.progressresults

2008 EGU Point Source Methodology 
 Page 3

Year 2008 EGU annual emissions were obtained from MAERS, and temporally adjusted 

to represent winter weekday as determined from LADCO base B inventory data. 

2018 Future Year EGU Point Source Methodology 

In developing emission projections for year 2018, consideration was given to both 

British Thermal Units (BTU) heat input of EGUs within the 7-county area, as well as 

scheduled facility improvements such as selective catalytic reduction (SCR) of NOx and 

flue gas desulfurization (FGD) for reduction of SO2. Because of several utility and 

industrial EGUs that experience load-shifting among various units, peaker plant use, 

and occasional shutdowns, total combined BTU heat input data was obtained for the 7-

county region for each year of years 2002 – 2008. Correlation and bivariate regression 

analysis of each year’s BTU heat input was then performed to forecast the 7-county 

future year boiler BTU heat input requirements. The results of this analysis were then 

used to predict year 2018 BTU heat input and for comparison with other known 

Integrated Planning Model (IPM) studies by the EPA in their development of the air 

transport rule. The EPA relied on the IPM model when developing their base case 

v.4.10 emission projections for years 2012-2050. The EPA’s base case v.4.10 IPM 

model results consider the national Title IV SO2 cap-and-trade program, NOx SIP Call 

regional ozone season cap-and-trade program, and all current settlements and state 

rules. The EPA base case simulation represents conditions without the proposed 

transport rule and without the rule it replaces, the Clean Air Interstate Rule (CAIR). The 

predicted BTU heat input obtained from regression forecasts was then compared to the 

heat input results obtained by the EPA’s base case v.4.10 IPM model results and also 

with LADCO/Visibility Improvement State and Tribal Association of the Southeast 

(VISTAS) BTU heat input to determine the reasonableness of the prediction. 

Deductions were made for selective catalytic reduction and flue gas desulfurization at 

the Detroit Edison Monroe Power Plant that occurred after year 2008. These additional 

control measures would explain the further reduction in emissions in the future year 

2018 emission forecast. 

2022 Future Year EGU Point Source Methodology 

Bivariate regression analysis was used to forecast future year 2022 energy demand as 

BTU heat input of EGUs for the 7-county planning area, as was done in the earlier 2018 

forecast. Because emission reductions occurred in earlier years between 2008 and 

2018, the later 2022 forecast is reflective of expected energy demand growth after 

control measures were implemented at the Detroit Edison Monroe Power Plant. 
 Page 4

3. Non-EGU Point Sources 

2005 Non-EGU Point Source Methodologies 

The original source of the 2005 point source data is the 2005 Michigan point source 

emission inventory. This section of the document describes the compilation and 

processing of point source emission data submitted to comply with the Consolidated 

Emission Reporting Rule (CERR) for the EPA National Emissions Inventory (NEI) 2005 

inventory. 

The data originates with the entry of data by the reporting facilities into MAERS. The 

electronic data received from the reporting facilities is reviewed and compiled by the 

MDEQ and exported to the fixed-width text version of the National Inventory Format 

(NIF). After the exported data is loaded into a PostgreSQL database patterned after the 

Microsoft (MS) Access version of the NIF, the following processing steps and checks 

are performed. 

Both emissions estimated by default calculations in MAERS and any emissions reported 

by facility operators are maintained in MAERS. For evaluation and quality assurance 

purposes, both types of records are included in the exports. To avoid double-counting, 

where a specific process/pollutant has emission records both reported directly by the 

facility operator and estimated via MAERS calculations, the latter are excluded. 

Portable facilities such as asphalt plants report total throughput and emissions, plus 

operating percentages for each county in which the portable facility was located during 

the year. From this information, records are generated for each county of operation, 

and throughput and emissions are apportioned based on the operating percentages 

reported by county and process. As geographic coordinates for all operating sites are 

not reported, coordinates corresponding to the centers of the counties of operation are 

assigned. 

As attention has shifted from total particulate to PM10 and PM2.5, total particulate records 

are excluded from the reporting requirements. 

Over 99.8% of total criteria pollutant emissions are accounted for by emissions reported 

by the operator. Therefore, exported criteria emissions estimated via MAERS 

calculations are excluded. 

In the site table, where strFacilityCategory is not set in the export, it is set to “01.” 

Mandatory geo-coordinate fields were added to the NIF specifications released in 

December 2003, well after it would have been possible to collect this information from 

the reporting facilities for 2002 operations. The following values were deemed most 

often representative and the exported data are updated accordingly for 2002 data: 

“strHorizontalCollectionMethodCode” is set to '027' 

“strHorizontalAccuracyMeasure” is set to '2000' 
 Page 5

“strHorizontalReferenceDatumCode” is set to '001' 

“strReferencePointCode” is set to '106' 

For 2005, these geographic data elements were requested of the facilities. The defaults 

above were applied only where data was not provided by the facility. 

 

MAERS tracks emissions of some pollutants that are of interest to the Great Lakes 

Commission (GLC), but which do not have corresponding pollutant codes in the most 

recent NIF pollutant code table. Emission records for the following pollutant codes are 

excluded: 

7440508; 8052413; DICDD,TOT; DICDF,TOT; HYDFLUORO; PERFLUORO; 

TRICDD,TO; TRICDF,TO; CH4; CO2; N20; 117840; 7783064. 

Emission records for ammonia are exported with the Chemical Abstract Service number 

7664417, rather than the pollutant code NH3. These pollutant codes are updated to 

NH3. Likewise, records exported with pollutant codes PAH and POM are updated to 

pollutant codes 234 and 246, respectively. 

 

All criteria and Hazardous Air Pollutant (HAP) emissions are reported at the process 

level, and the export routines reflect that in the strEmissionDataLevel field of the 

emission table. This field is set to null for criteria pollutant emission records per EPA 

guidance. 

All emissions are exported as pounds of annual emissions. The EPA guidance 

suggests that criteria pollutant emission be reported in tons. The field 

strEmissionUnitNumerator is changed to TON and the filed dblEmissionNumericValue is 

divided by 2000 for criteria pollutant emission records. 

Null values in the quarterly throughput fields of process records are set to zero. 

Where quarterly throughput fields of process records sum to zero, throughput 

percentages are set to 25% for each quarter. 

MAERS recognizes a control device code of '909' for a “Roll Media Fiberglass Tack 

Filter (Tacky 1 side),” which is not recognized in the NIF code tables. Where this control 

device code is exported, the “strPrimaryDeviceTypeCode” field of the control equipment 

table is updated to a value of 058. 

Because of the exclusion of emission records as described above, referential integrity of 

the exported data can be compromised. At this point, it is re-established by deleting 

records stepwise, in the following order. 

CE records without corresponding EM records 

PE records without corresponding EM records 

EP records without corresponding EM records 

ER records without corresponding EP records 

EU records without corresponding EP records 
 Page 6

SI records without corresponding EU records 

The data are then checked again for referential integrity and mandatory fields and then 

loaded into the MS Access shell version of the NIF via append queries that connect to 

the PostgreSQL data tables via ODBC. The Basic Content and Format Checker is run 

and its output is reviewed. Where corrections are needed, to assure consistency 

among data sources, the corrections are made in the MAERS and a full iteration of the 

export and post-processing steps are performed. 

The 2005 point source inventory was incorporated into the LADCO Base M inventory 

and serve as the basis for Michigan’s 2005 CERR submittal. 

2008 Stationary Non-EGU Point Source Methodologies 

The 2008 point source data have as their original sources the 2008 Michigan point 

source emission inventory. This section of the document describes the compilation and 

processing of point source emission data submitted to comply with CERR for the EPA 

NEI 2005 inventory. 

The data originates with the entry of data by the reporting facilities into the MAERS. 

The electronic data received from the reporting facilities is reviewed and compiled by 

the MDEQ, and exported to the Consolidated Emissions Reporting Schema (CERS) 

extendible markup language (XML) text version of the EPA Emissions Inventory System 

(EIS). After the exported data is loaded into a PostgreSQL database patterned after the 

MS Access version of the CERS Staging Tables, the following processing steps and 

checks are performed. 

Both emissions estimated by default calculations in MAERS and any emissions reported 

by facility operators are maintained in MAERS. For evaluation and quality assurance 

purposes, both types of records are included in the exports. To avoid double-counting, 

where a specific process/pollutant has emission records both reported directly by the 

facility operator and estimated via MAERS calculations, the latter are excluded. 

Portable facilities such as asphalt plants report total throughput and emissions, plus 

operating percentages for each county in which the portable facility was located during 

the year. From this information, records are generated for each county of operation, 

and throughput and emissions are apportioned based on the operating percentages 

reported by county and process. As geographic coordinates for all operating sites are 

not reported, coordinates corresponding to the centers of the counties of operation are 

assigned. 

As attention has shifted from total particulate to PM10 and PM2.5, total particulate records 

are excluded from the reporting requirements. 

Over 99.8% of total criteria emissions are accounted for by emissions reported by the 

operator, therefore exported criteria emissions estimated via MAERS calculations are 

excluded. 
 Page 7

All criteria and HAP emissions are reported at the process level. 

All emissions are exported as pounds of annual emissions. The EPA guidance 

suggests that criteria pollutant emissions be reported in tons. The CERS emissions 

field is converted to TONs and the emissions unit field is changed to TON. 

Null values in the quarterly throughput fields of process records are set to zero. 

Where quarterly throughput fields of process records sum to zero, throughput 

percentages are set to 25% for each quarter. 

The 2008 point source inventory was incorporated into the LADCO Base B inventory 

and serve as the basis for Michigan’s 2008 CERR submittal. 

2018 and 2022 Future Year Stationary Non-EGU Point Source Methodologies 

A Correlation/Regression analysis of energy demand as expressed as BTU heat input 

for actual year fuel consumption of years 2002-2008 obtained from MAERS was used to 

derive future year growth factors. The results of this analysis did not indicate any trend 

with time within the 7-county planning region. Future year 2018 and 2022 emission 

projections take into consideration a 7-year average of the BTU heat input from nonEGU sources. Additional analysis was performed at the statewide level using Energy 

Information Administration fuel BTU heat input data for years 2002-2008. Unlike the 

Southeast Michigan 7-county area, which didn’t show any trend with time, the statewide 

correlation/regression analysis showed a declining trend with time in BTU heat input. It 

was found that the 7-year average BTU heat input resulted in growth factors for the 7-

county area that were greater than those obtained from the statewide 

correlation/regression analysis. 

4. Stationary Area (Non-point) Sources 

2005 and 2008 Stationary Area Source Emission Inventory 

The following is a description of the various area source categories that were 

inventoried as part of the years 2005 and 2008 emissions inventories as required by the 

EPA under CERR. It also provides documentation as part of the development of a 

broader emissions inventory (which encompasses point, area, non-road mobile, on-road 

mobile, and biogenic sources) that is being developed to support State Implementation 

Plan (SIP) requirements for attainment demonstrations. 
 

Summary of Area Sources and Respective Air Pollutants Inventoried for 2005 Inv

Seq # Area Source Description SCCs SIC CO NH3 NOx

PM10-

PRI 

1 Residential coal 2104001000 8811

√

√

√

√

2 Residential distillate oil 2104004000 8811

√

√

√

√

3 Residential kerosene 2104011000 8811

√

√

√

√

4 Residential natural gas 2104006000 8811

√

√

√

√

5 Residential propane 2199007000 8811

√

√

√

6 Commercial coal 2103002000 9999

√

√

√

√

7 Commercial distillate oil 2103004000 9999

√

√

√

√

8 Commercial kerosene 2103011005 9999

√

√

√

√

9 Commercial natural gas 2103006000 9999

√

√

√

√

10 Commercial residual oil 2103005000 9999

√

√

√

√

11 Industrial coal 2102002000 3999

√

√

√

√

12 Industrial distillate oil 2102004000 3999

√

√

√

√

13 Industrial kerosene 2102011000 3999

√

√

√

√

14 Industrial natural gas 2102006000 3999

√

√

√

√

15 Industrial residual oil 2102005000 3999

√

√

√

√

16 Remedial action 2660000000 9511

√

√

√

17 Municipal landfills 2620030000 4953

√

√

√
 Page 9

Stationary Source Fossil Fuel Combustion 

The combustion of natural gas, propane-liquefied petroleum gas (LPG), distillate fuel oil, 

kerosene, and residual fuel oil in small boilers, furnaces, heaters, and stoves are also a 

source of VOC, NOx, particulates, SO2, and ammonia emissions. Because these 

sources are so numerous to be identified in point source inventories, this area source 

category attempts to provide a collective estimate of emissions from these smaller 

energy consumption sources by subtracting all fuel used by point sources from total fuel 

consumption. Procedures for the estimation of these smaller sources are presented in 

the EPA’s documents entitled: 

1. Volume II, Chapter 2 of the Emission Inventory Improvement Program January 

2001 Preferred and Alternate Methods for Estimating Air Emissions from Boilers. 

2. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract- Fuel Oil and Kerosene Combustion. 

3. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Natural Gas and LPG Combustion. 

4. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Coal Combustion. 

5. Documentation for the Draft 1999 National Emissions Inventory (Version 3.0) for 

Criteria Air Pollutants and Ammonia. 

6. Hanke, B.H, manuscript prepared for U.S Environmental Protection Agency 

entitled: A National Methodology and Emission Inventory for Residential Fuel 

Combustion.

This documentation involves determination of total fuel consumption over an area with 

subsequent fuel deductions made for point source fuel consumption, and then applying 

emissions factors to estimate fuel emissions. 

Total fuel consumption information was based on data supplied from U.S. Department 

of Energy, Energy Information Administration (EIA) documents. The unaccounted fuel 

consumption was then apportioned to individual counties using U.S. Census Bureau 

information for the individual end use sector fuel types based on LADCO states 

methodology. Area source fuel emissions were reported for the following residential, 

commercial/institutional, and industrial end use sectors. Since utility boilers are 

accounted as point sources, area source emissions are not reported for this end use 

sector. 

Residential Boilers & Furnaces 
 Page 10

County emission estimates for the residential end use sector were based on the 

consumption of natural gas, propane-LPG, distillate fuel oil, kerosene, and coal. This 

energy consumption information was obtained from U.S. Department of Energy, EIA 

data. Since the EIA merely provides statewide fuel consumption totals, county fuel 

consumption estimates were obtained by apportioning the fuel consumption based on 

the number of year 2000 occupied household census counts using the given fuel. 

Emission estimates were calculated using the following mathematical equation: 

 Cf = Ch/Sh x Sf 

Where: 

Cf = Estimated county residential sector consumption of a given fuel type for year 2005 

Ch = Number of year 2000 census occupied households in a given county that utilize a 

given fuel type 

Sh = Total number of year 2000 census occupied households statewide that utilize a 

given fuel type 

Sf = Total statewide residential sector consumption of a given fuel type 

Michigan Residential Fuel Consumption Information Sources 

Residential Fuel 

Type 

U.S. Dept of Energy, EIA Data Sources 

Natural gas Natural Gas Annual 2005, Michigan Table 48 

Propane LPG Petroleum Marketing Annual, 2005, Table 49: Prime 

Supplier Sales Volumes of Aviation Fuels, Propane and 

Residual Fuel Oil by PAD District and State 

Distillate fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 19: 

Adjusted Sales for Residential Use: Distillate Fuel Oil and 

Kerosene, 2005 

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: 

Adjusted Sales of Kerosene by Energy Use 

Coal EIA Annual Coal Report 2005, Table 26 U.S. Coal 

Consumption by End Use Sector, by Census Division and 

State 2005, 2004 (Thousand Short Tons) 

Upon obtaining county residential fuel consumption estimates for the various fuel types 

in all Michigan counties Cf, emission estimates were obtained by applying an emission 

factor that is specific to that fuel type. These emission factors were obtained from 

various EPA publications. 
 Page 11

Michigan Residential Fuel Emission Factors 

Residential 

Fuel Type 

Units CO NH3 NOx PM10-

PRI 

PM25-

PRI 

SO2 VOC

Natural gas Lbs/million 

cubic feet 

40 0.49 94 7.6 7.6 0.6 5.5 

Propane 

LPG 

Lbs/1,000 

gal 

3.2 13 0.68 0.68 0.1 0.5 

Distillate 

fuel oil 

Lbs/1,000 

gal 

5.0 0.8 18 2.38 2.13 42.60 0.7 

Kerosene Lbs/1,000 

gal 

4.8 0.8 17.4 2.38 2.13 41.1 0.7 

Coal Lbs/ton 275 0.000565 3.0 18.63 4.86 37.83 10 

Sources of Emission Factors: 

1. U.S. Environmental Protection Agency Documentation for the Draft 1999 

National Emissions Inventory (Version 3.0) for Criteria Air Pollutants and 

Ammonia. 

2. Hanke, B.H, manuscript prepared for U.S Environmental Protection Agency 

entitled: A National Methodology and Emission Inventory for Residential Fuel 

Combustion.

3. U.S. Environmental Protection Agency. Final Report on Development and 

Selection of Ammonia Emission Factors. 

The resulting emission estimates were reported by individual fuel type using the 

following SCC codes: 

Michigan Residential Combustion Emission SCC Codes 

Residential Fuel 

Type 

SCC 

Natural gas 2104006000 

Propane LPG 2199007000 

Distillate fuel oil 2104004000 

Kerosene 2104011000 

Coal 2104001000 
 Page 12

Commercial/Institutional Boilers and Furnaces 

Estimation of fuel combustion by the commercial/institutional sector was performed 

using an adaptation of a methodology presented in the following EPA publications: 

1. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract- Fuel Oil and Kerosene Combustion 

2. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Natural Gas and LPG Combustion 

3. Emission Inventory Improvement Program –April 6, 1999, Area Source Category 

Abstract-Coal Combustion 

County emission estimates for the commercial/institutional end use sector were based 

on the consumption of natural gas, residual fuel oil, distillate fuel oil, kerosene, and coal. 

This energy consumption information was obtained from U.S. Department of Energy, 

EIA data. Fuels were subtracted for point sources, and the net area fuel contribution 

was apportioned or allocated using procedures instructed by LADCO. This procedure 

involved statewide commercial/institutional fuel apportionment to a county level using 

the commercial/institutional employment data as obtained from U.S. Department of 

Commerce, Bureau of Census publication entitled County Business Patterns, Michigan: 

2003 (CBP/03-24 issued September, 2005). County fuel estimates of individual fuel 

types were estimated using the following equation: 

 Cf = Ce/Se x Sf 

Cf = Estimated county commercial/institutional sector consumption of a given fuel 

type 

Ce = Total county employment in the commercial/institutional sector 

Se = Statewide employment in commercial/institutional sector 

Sf = Statewide commercial/institutional sector consumption of a given fuel type 

Because the Energy Information data includes diesel fuel totals within the distillate fuel 

oil total, these motor vehicle fuels were deducted to provide only an estimate of #1, #2, 

and #4 fuel oils. 
 Page 13

Michigan Commercial/Institutional Fuel Consumption Information Sources 

Fuel Type U.S. Dept of Energy, EIA Data Sources 

Natural gas Natural Gas Annual 2005, Michigan Table 48 

Residual fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 17: 

Adjusted Sales of Residual Oil by Energy Use, 2004 and 

2005 

Distillate fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 20: 

Adjusted Sales for Commercial Use: Distillate Fuel Oil, 

Residual Fuel Oil and Kerosene 2005 

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: 

Adjusted Sales of Kerosene by Energy Use 

Coal EIA Annual Coal Report 2005, Table 26 U.S. Coal 

Consumption by End Use Sector, by Census Division and 

State 2005, 2004 (Thousand Short Tons) 

Upon obtaining county commercial/institutional fuel consumption estimates for the 

various fuel types in all Michigan counties Cf, emission estimates were obtained by 

applying an emission factor that is specific to that fuel type. These emission factors 

were obtained from various EPA publications. 

Michigan Commercial/Institutional Fuel Emission Factors 

Commercial/Institutional 

Fuel Type 

Units CO NH3 Nox PM10-

PRI 

PM25-

PRI 

SO2 VOC 

Natural gas Lbs/million 

cubic feet 

84 0.49 100 7.6 7.6 0.6 5.5 

Residual fuel oil Lbs/1,000 

gal 

5 0.80 55 9.07 3.37 194.05 1.13 

Distillate fuel oil Lbs/1,000 

gal 

5 0.80 20 2.38 2.13 53.96 0.34 

Kerosene Lbs/1,000 

gal 

5 0.80 18 2.38 2.13 41.1 0.713

Coal Lbs/ton 6 0.000565 7.5 6.0 2.2 36.86 0.05 

Sources of Emission Factors: 

1. LADCO state uniform adopted emission factors for commercial/institutional 

natural gas combustion. 
 Page 14

2. U.S. Environmental Protection Agency. FIRES database. 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant Emission 

Factors, Volume 1: Stationary Point and Area Sources, 5th Edition and 

Supplements (AP-42). 

4. U.S. Environmental Protection Agency. Final Report on Development and 

Selection of Ammonia Emission Factors. 

The resulting emission estimates were reported by individual fuel type using the 

following SCC codes: 

Michigan Commercial/Institutional Combustion Emission SCC Codes 

Fuel Type SCC 

Natural gas 2103006000 

Residual fuel oil 2103005000 

Distillate fuel oil 2103004000 

Kerosene 2103011005 

Coal 2103002000 

Industrial Boilers and Furnaces 

Estimation of fuel combustion emissions of industrial boilers and furnaces was 

performed in similar manner as the commercial/institutional sector. Statewide industrial 

fuel consumption information was obtained from the U.S. Department of Energy, EIA 

publications. Point source deductions were made for each fuel type to obtain the area 

contribution that was then apportioned to the county level using LADCO prescribed 

procedures. 

 

County fuel consumption estimates of natural gas, residual fuel oil, distillate fuel oil, 

kerosene, and coal were based upon the following mathematical equation: 

 Cf = Ce/Se x Sf 

Cf = Estimated county industrial sector consumption of a given fuel type 

Ce = Total county employment in the industrial sector 

Se = Statewide employment in industrial sector 

Sf = Statewide industrial sector consumption of a given fuel type 
 Page 15

Michigan Industrial Fuel Consumption Information Sources 

Industrial Fuel 

Type 

U.S. Dept of Energy, EIA Data Sources 

Natural gas Natural Gas Annual 2005, Michigan Table 48 

Residual fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 17: 

Adjusted Sales of Residual Oil by Energy Use, 2004 and 

2005 

Distillate fuel oil Fuel Oil and Kerosene Sales 2005 Report, Table 21: 

Adjusted Sales for Industrial Use: Distillate Fuel Oil, 

Residual Fuel Oil, and Kerosene (#1, #2, and #4 fuel oils 

– excludes diesel oil) 

Kerosene Fuel Oil and Kerosene Sales 2005 Report, Table 18: 

Adjusted Sales of Kerosene by Energy Use 

Coal EIA Annual Coal Report 2005, Table 26: U.S. Coal 

Consumption by End Use Sector, by Census Division and 

State 2005, 2004 (Thousand Short Tons) 

County employment data was obtained from the U.S. Department of Commerce, 

Bureau of Census publication entitled County Business Patterns, Michigan: 2003 

(CBP/03-24 issued September, 2005). Upon obtaining county industrial fuel 

consumption estimates for the various fuel types in all Michigan counties Cf, emission 

estimates were obtained by applying an emission factor that is specific to that fuel type. 

These emission factors were generally based on the LADCO adopted emissions 

factors. 

Michigan Industrial Fuel Emission Factors 

Industrial 

Fuel Type 

Units CO NH3 NOx PM10-

PRI 

PM25-

PRI 

SO2 VOC 

Natural 

gas 

Lbs/million 

cubic feet 

84 3.2 100 7.6 7.6 0.6 5.5 

Residual 

fuel oil 

Lbs/1,000 

gal 

5.0 0.8 55 7.17 4.67 157 0.28 

Distillate 

fuel oil 

Lbs/1,000 

gal 

5.0 0.8 20 2.3 1.55 53.96 0.2 

Kerosene Lbs/1,000 

gal 

5.0 0.8 18 2.38 2.13 41.1 0.713

Coal Lbs/ton 6 0.00057 7.5 6.0 2.2 38 0.05 
 Page 16

Sources of Emission Factors: 

1. LADCO state uniform adopted emission factors for industrial natural gas, 

residual fuel oil, distillate fuel oil, and coal combustion. 

2. U.S. Environmental Protection Agency. FIRES database. 

3. U.S. Environmental Protection Agency. Compilation of Air Pollutant 

Emission Factors, Volume 1: Stationary Point and Area Sources, 5th 

Edition and Supplements (AP-42). 

4. U.S. Environmental Protection Agency. Final Report on Development and 

Selection of Ammonia Emission Factors. 

Emission estimates were reported using the following SCC codes: 

Michigan Industrial Combustion Emission SCC Codes 

Industrial Fuel 

Type 

SCC 

Natural gas 2102006000 

Residual fuel oil 2102005000 

Distillate fuel oil 2102004000 

Kerosene 2102011000 

Coal 2102002000 

Remedial Action, Site Clean Up & Leaking Storage Tanks 

Evaporative VOC emissions occur during remediation and cleanup at sites of 

environmental contamination. Such remediation activities may include air stripping or 

sparging of a VOC from contaminated groundwater or incineration of a spoil material 

removed from a contaminated site. In some instances carbon adsorption may be 

required to reduce VOC emitted during air stripping or spraying operations. 

Estimation of VOC loss from remedial action activities was determined by summing the 

allowable emissions from permits to those parties that were engaged in such activities 

as provided by the MDEQ, Air Quality Division (AQD), Permit Section. Although site 

remediation activities are subject to NESHAPs, these requirements did not apply at the 

time of the year 2005 emissions inventory. Emissions were reported using an SCC of 

2660000000. 

Municipal Waste Landfills 

A municipal solid waste landfill is defined as any facility that is regulated under 

Subtitle D of the Resource Conservation and Recovery Act (RCRA) that receives 

primarily household and/or commercial wastes. 
 Page 17

VOCs are produced from municipal solid waste by: the volatilization of the waste 

material itself, the microbiological (anaerobic) putrefaction of organic waste materials 

that result in the formation of organic acids and alcohols that are vaporized, and the 

chemical reaction of one or more waste materials or chemical decomposition 

intermediate. The rate at which VOCs are emitted from a landfill is dependent upon the 

structural design of cells, the waste composition (physical/chemical properties), the 

moisture content of the waste, the amount of waste disposed, temperature, age of the 

landfill, the chemical reactivity of the waste, the microbiological toxicity of the waste, and 

the effectiveness of landfill gas collection systems. Where landfill gas is collected for 

use in boilers, internal combustion engines (reciprocating and turbines) or flared at the 

landfill site, there are additional air pollutants such as NOx, particulates (PM2.5 and 

PM10), and carbon monoxide produced from incomplete combustion. 

Estimation of VOC emissions from municipal landfills were based on the revised 

technical procedures presented in the EPA publication entitled: Volume III, Chapter 15 

of the Emission Inventory Improvement Program January 2001 Revised Final Guidance 

for Landfills. In this publication, the preferred method for the estimation of area source 

emissions is to use the LandGem model or the equations from the Compilation of Air 

Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, 5th Edition 

and Supplements (AP-42) section on landfills. LandGem is a computer-based model 

that uses the same equations as that of AP-42. The emissions calculation for the 

estimation of landfill gas requires site specific information including: landfill design 

capacity, accumulated waste totals from operation of the landfill, and existing control 

requirements from landfill gas collection systems. Landfills may be subject to either 

new source performance standards (40 Code of Federal Regulations Part 60 Subpart 

WWW) or emission guidelines (40 Code of Federal Regulations, Part 60, Subpart Cc). 

Landfills are now also subject to NESHAPs that became effective on January 16, 2003. 

For those landfills that were not being reported in the point source inventory, area 

emission estimates were reported on the basis on LandGem model simulations using 

the SCC of 2620030000. These simulations reflected total waste receipts under the 

prior year 1999 inventory with addition made for waste receipts for years 2000-2005 as 

obtained from annual reports by the MDEQ, Waste and Hazardous Division Report of 

Solid Waste Landfilled in Michigan. For those landfills that operated landfill gas 

collection/combustion systems, emission estimates considered Tables 2.4-3 and 2.4-5 

of AP-42 with adjustments considered for a landfill gas methane collection efficiency of 

75% of LandGem model predicted methane generation at a given landfill site. 

Non-Methane Organic Compound Control Efficiencies for Landfill Gas 

Combustion from AP-42 

Combustion Control 

Device 

Typical Control 

Efficiency (%) 

Boilers 98 

Flares 99.2 

Gas Turbines 94.4 

IC Engine 97.2 
 Page 18

Emission Rates for Secondary Compounds from Landfill Gas Combustion 

(Based upon lbs/ Million Cubic Feet of Landfill Gas Combusted) 

Combustion Control 

Device 

NOx PM2.5-

PRI 

PM10-

PRI 

CO 

Flare 40 17 17 750 

IC Engine 250 48 48 470 

Boiler 33 8.2 8.2 5.7 

Gas Turbines 87 22 22 230 

Open Burning: Municipal Solid Waste 

For the category of open burning of municipal solid waste (MSW), EPA’s methodology 

from Appendix A of Documentation for the Final 2002 Nonpoint Sector (Feb 06 Version) 

National Emission Inventory for Criteria and Hazardous Air Pollutants was followed. 

The ratio of urban to rural population was obtained from 2000 U.S. Census data, per the 

EPA’s method, then multiplied by a 2005 U.S. Census Bureau estimate of the county 

population in Michigan to obtain an estimate of rural population in 2005. Per capita 

emission factors were used, after first excluding those counties where the population 

was greater than 80% urban under EPA’s presumption that open burning of MSW would 

not occur there. 

Outdoor Wood Boilers 

The Wisconsin methodology distributed by Bart Sponseller was followed. Per that 

methodology, the MARAMA emission factor of 13.82 g/kg wood burned was used. 

An estimate of 11.68 cords/yr/unit in Michigan was obtained from Brian Brady, AQD. 

Brian serves as the AQD’s outdoor wood boiler expert. 

Michigan estimated an average weighted density of 1.65 tons/cord of wood, based on 

information contained within Table 8 of the USDA survey report Residential Fuelwood 

Consumption and Production in Michigan, 1992. 

Per the Wisconsin methodology, it was assumed that 90% of outdoor wood boilers are 

used in rural areas and 10% are used in urban areas. To determine which counties 

were urban and which were rural, staff reviewed the list of counties, which are part of 

Michigan’s Consolidated Statistical Areas (metropolitan areas) and determined that the 

22 affected counties should be considered as urban. Ten percent of the 29,568 

Michigan outdoor wood boilers were apportioned to the urban counties by population. 

The remaining 90% of the outdoor wood boilers were apportioned to the 61 rural 

counties by population. 

 2005 Residential Wood Burning
 Page 19

Michigan utilized the EIIP methodology’s alternative method for estimating emissions 

from residential wood burning, by apportioning data from the U.S. Census Bureau and 

the EIA. 

Two options were available to estimate wood burning households per county. 

• Housing Units with Wood Heat by County was determined by using 1990 U.S. 

Census Data, Database C90STF3C1, Summary Level State, for House Heating 

Fuel for Occupied Housing Units (http://venus.census.gov/cdrom/lookup). 

Although this data is for the 1990 year, it did provide a value for each county. 

• Housing Units with Wood Heat by County was determined by using the U.S. 

Census Bureau’s DP-4, Profile of Selected Housing Characteristics: 2000, Data 

Set: Census 2000 Summary File 3 (SF 3) for Michigan. This file provided a total

value of households using wood heating. However, no breakdown was given by 

county. 

The AQD staff used the 2000 number of total wood burning households in Michigan, 

and used the 1990 county proportions of the 1990 total to apportion the 2000 value to 

the county level. 

Then based on county value for number of wood burning households, the value for state 

wood use in cords was apportioned to each county. The 2003 state wood use in cords 

data came from the US MAP States Page, Table 8, Residential Energy Consumption 

Estimates, Selected Years 1960-2003, Michigan, from the U.S. Department of Energy, 

EIA: 

http://www.eia.doe.gov/emeu/states/sep_use/res/use_res_mi.html

Data for 2005 was not available at the time the 2005 inventory was developed. 

Once county wood use in cords was produced, the next step was to determine the wood 

weight in tons for each county. Wood weight was determined by estimating a weighted 

average wood weight of 1.65 tons per cord, from species and consumption data from 

Table 8 of the USDA report, “Residential Fuelwood Consumption and Production in 

Michigan, 1992.” 

Michigan did not have data available on the number of catalytic and non-catalytic 

woodstoves in Michigan, but did utilize 1993 survey data which showed the proportions 

of fireplaces to woodstoves by county in Michigan. This was used to apportion wood 

weight per county between wood stoves and fireplaces. SCCs and emission factors 

were selected for fireplaces – cordwood (2104008001), and woodstoves – general 

(2104008010). 

No ozone season activity was estimated, as staff felt it was unlikely that residents would 

utilize their fireplaces or wood stoves between June 1 and August 31 of each year. 
 Page 20

FIRE 6.23 and Source Summary Database (SSD) list the following Area Mobile Source 

Codes (AMS): 

 A2104008000: Total wood stoves and fireplaces 

 A2104008001: (lb/ton dry wood burned): Fireplaces - general 

 A2104008010: (mg/Mg dry wood burned): Wood stoves - general 

 A2104008030: (lb/ton dry wood burned): Catalytic wood stoves - general 

 A2104008050: (lb/ton dry wood burned): Non-catalytic wood stoves - general 

 A2104008051: (lb/ton dry wood burned): Non-catalytic wood stoves - 

conventional 

 A2104008052: (lb/ton dry wood burned): Non-catalytic wood stoves - low emitting 

 A2104008053: (lb/ton dry wood burned): Non-catalytic wood stoves - pellet fired 

Michigan selected AMS codes A2104008001 and A2104008010. These were the most 

appropriate codes, as data exists for the proportion of woodstoves to fireplaces per 

county in Michigan, but data was not available on numbers of catalytic or non-catalytic 

wood stoves. Emission factors for A2104008010 were converted from mg/Mg to lb/ton 

by multiplying by the conversion factor of 2.00E-06. 

References: 

1. EPA, Factor Information Retrieval System Version 6.23, U.S. Environmental 

Protection Agency, 2000. 

2. EPA, STAPPA, ALAPCO, Emission Inventory Improvement Program (EIIP), Volume 

III, July 1997, Chapter 2. 

2008 Residential Wood Combustion 

Michigan utilized the EPA’s Residential Wood Combustion tool (RWC_2008_Toolv4.1) 

to estimate emissions from Residential Wood Combustion for the 2008 emissions 

inventory. The residential wood combustion tool was modified to address a few 

deficiencies with Michigan Counties. Double-counting of emissions for SCCs 

2104008400, 21048510, and 2104008610 was resolved, and the allocation of 

appliances for SCC 2104008610 Hydronic heater: outdoor was revised using an inverse 

population density methodology. 

Structure Fires 

The EIIP guidance from EIIP Volume III, Chapter 18: Structure Fires, was followed. The 

preferred method for estimating emissions was used, due to the availability of county 

level structure fire data for 2002. More recent data was not available; the fire statistics 

data, which was originally kept by the Michigan State Police Fire Marshall Division, is 

now kept by the Michigan Department of Labor and Economic Growth. DLEG staff 

were unable to locate more recent county level data on structure fires. The 2002 data 
 Page 21

was re-used from the 2002 area source submittal. However, it did not provide any detail 

on the extent of each structure fire, or indicate if the structure was residential or 

commercial. 

The default fuel loading factor provided in the EIIP guidance (1.15 tons of fuel per 

structure fire) was used. Emission factors for VOC, CO, and NOx were obtained from 

Table 18.4-1. 

Year 2018 and 2022 Stationary Area Source Emission Inventory Projections: 

Area sources represent those emission sources that do not report to MAERS. Future 

year projections take into consideration the corresponding BTU heat input from 

residential, commercial/institutional, and unaccounted industrial sources. Residential 

projections considered SEMCOG forecast of expected number of households within the 

7-county area. Similarly, regional economic employment forecast from SEMCOG 

projections was used to derive the non-manufacturing sector employment growth for the 

7-county area. For unaccounted industrial sources, growth rates were assumed to be 

similar as Non-EGU source projections. 
 Page 22

5. Non-Road Mobile Sources 

Non-Road Emissions Estimation Exclusive of Locomotive, Shipping, and Aircraft 

Emissions 

Non-road equipment population and emission estimates for 2005, 2008, 2018, and 2022 

were obtained from the EPA NONROAD2008a model to simulate winter weekday and 

annual PM2.5, SO2, and NOx emissions. The updated model and technical support 

documentation can be obtained from: 

http://www.epa.gov/otaq/nonrdmdl.htm . Fuel property information utilized in LADCO 

regional emission simulations were from Grant Hetherington of the State of Wisconsin 

and from EPA NONROAD2008 model documentation. 

2005 and 2008 Aircraft Emissions Estimation 

To estimate aircraft emissions, aircraft activity was obtained for Michigan airports. 

Historically this information was obtained from MDOT. However, MDOT was unable to 

provide updated information for year 2005. In the absence of updated MDOT 2005 

aircraft activity data, commercial aircraft and commercial air freight departure 

information by aircraft model type was obtained from Federal Aviation Administration 

(FAA) airport records. For determining airport LTO cycles, the Air Traffic Activity Data 

System (ATADS) air traffic count database of larger towered airports, Terminal Area 

Forecast (TAF) air traffic operations database of towered and non-towered airports, and 

G.C.R. & Associates airport activity data were used. Since ATADS provides aircraft 

operations for a limited number of the states’ airports, TAF aircraft operations estimates 

were considered where ATADS information was unavailable. G.C.R. & Associates, Inc. 

consultant data was used for the smaller airports of which FAA aircraft operations 

information was unavailable. The following information from the respective sources was 

considered in the development of emission estimates: 

 1. Commercial scheduled and non-scheduled aircraft air carrier activity and 

commercial air freight activity by aircraft model types; 

 2. General aviation and air taxi annual local and itinerant operations for year 

2005; 

 3. Military annual local and itinerant operations for year 2005. Due to need 

to have aircraft operations information expressed as LTO cycles, the 

following assumptions were made: 

a. For commercial aircraft and commercial air freight activity, the 

number of annual aircraft annual LTO cycles was assumed to be 

equal to the number of departures. The daily LTO cycle frequency 

was then obtained by dividing the yearly LTO cycles by 365. 
 Page 23

b. For general aircraft annual local and itinerant airport operations, 

each respective operations total was divided by two to obtain the 

corresponding year local and itinerant LTO cycles. The expected 

daily local and itinerant LTO cycles then were obtained by dividing 

these annual totals by 365. 

c. For military annual local and itinerant operations, each respective 

operations total was divided by two to obtain the corresponding 

year local and itinerant LTO cycles. The expected military daily 

local and itinerant LTO cycles then were obtained by dividing these 

annual totals by 365. 

Airport LTO cycles were further categorized into commercial aircraft by plane and 

engine type, general aviation itinerant aircraft of unknown aircraft type, general aviation 

local aircraft of unknown aircraft type, and military aircraft. This was necessary to utilize 

the U.S. Department of Transportation, FAA Emissions and Dispersion Modeling 

System 4.5 (EDMS). A description of this model can be found in the FAA publication 

entitled, Emissions and Dispersion Modeling System (EDMS) User Manual (September 

2004). Commercial and air freight aircraft emission factors per LTO cycle were 

determined using EDMS 4.5 for each commercial aircraft type models where possible 

were used at each towered airport. Default commercial aircraft engine type, and EPA 

default time in mode values for takeoff, approach, and landing roll times were used in 

the EDMS 4.5 model simulations. 

For those aircraft types that could not be determined using the EDMS 4.5 emissions 

model, aircraft emission factors based on EPA alternative fleet average procedures 

were then used to estimate their emissions. These included general aviation and air 

taxi itinerant aircraft of unknown aircraft type, general aviation local aircraft of unknown 

aircraft type, and military aircraft. Conversion from total hydrocarbons to VOC was 

performed and based on the EPA guidance. 

Aircraft emissions were then obtained by adding emissions contributions from 

commercial, itinerant general, and local general aircraft, and were reported using the 

following SCC codes: 

Michigan Aircraft Emission SCC Codes 

Aircraft Type SCC 

Military 2275001000 

Commercial 2275020000 

General Aviation 2275050000 
 Page 24

2005 Locomotive and Shipping Emissions Estimation 

The 2005 non-road shipping and locomotive emissions were prepared using the same 

techniques used for the 2002 emissions. These estimates are based on work and a 

follow-up report (Environ Report for LADCO, 2002 Shipping Emissions Sources, April 

2004) completed by Environ to support LADCO’s efforts to prepare a 2002 Air 

Emissions Inventory. The report describes Environ efforts to develop a shipping 2002 

air emissions estimates to support air quality modeling. The Environ report is too long 

to be included in this document, but it can be provided upon request or downloaded at: 

http://ladco.org/reports/rpo/MWRPOprojects/Emissions/Environ_Final_Report_nonroad.pdf 

The estimate of 2005 locomotive and shipping emissions was made by LADCO in the 

same manner as the 2002 inventory described above. The 2005 estimates are part of 

LADCO’s Base M inventory. 

2008 Locomotive, Shipping, and Aircraft Emissions Estimation 

The 2008 emissions are based on work and a follow-up report (E.H. Pechan & 

Associates, Inc., Development of Growth and Control Factors for Lake Michigan Air 

Directors Consortium, Final Report, December 14, 2004) done by E.H. Pechan & 

Associates, Inc. (Pechan). This work supports LADCO’s efforts to forecast anthropogenic emissions for the purpose of assessing progress for air quality goals, including 

goals related to regional haze and attainment of the ozone NAAQS. The Pechan 

growth factors were used to estimate the LADCO Base M future year emissions posted 

by LADCO in 2007. The future year emissions represent both emission controls that 

already exist and those that are known to be on the way. 

Non-road Mobile Source Emission Inventory Projections to 2018 and 2022

The non-road source categories exclusive of locomotive, shipping, and aircraft were 

grown in the EPA Mobile source model NMIM. The locomotive, shipping, and aircraft 

non-NMIM source categories were grown using growth factors provided in the report, 

Development of Growth and Control Factors for Lake Michigan Air Directors 

Consortium, Final Report, December 14, 2004, prepared by Pechan for LADCO and 

available upon request. 

See Growing Stationary Non-EGU Point, Stationary Area, Locomotive, Shipping, 

and Aircraft Categories for the Years 2018 and 2022 in the Non-EGU Point Sources

section for references and methodology for projecting the Locomotive, Shipping and 

Aircraft emissions inventory. 
 Page 25

6. On-road Mobile Sources

Please refer to the On-road Mobile Source Emissions Inventory for Southeast 

Michigan – PM2.5 Redesignation Request, January 27, 2011, prepared by SEMCOG, 

and contained in Appendix C. 
Appendix C 

On-Road Mobile Source Emissions Inventory 

for Southeast Michigan 

PM2.5 Redesignation Request 
On‐Road Mobile Source Emissions Inventory for

Southeast Michigan

PM2.5 Redesignation Request

January 27, 2011

Prepared by the

Southeast Michigan Council of Governments (SEMCOG)

535 Griswold, Suite 300

Detroit, MI  48226

(313) 961‐4266
ii

Table of Contents 

I. Emissions Inventory Summary............................................................................1

II. On-Road Mobile Emissions Inventory Development.........................................1

A. Local Travel Data Inputs............................................................................2

 1. Demographic Data .................................................................................... 

 2. SEMCOG’s Travel Demand Forecasting Model (TDFM) .......................... 

 3. Mapping of TDFM Functional Classes and Area Types............................ 

 To MOVES Road Types ........................................................................... 

 4. Vehicle Miles of Travel (VMT)................................................................... 

 5. Hourly VMT Fractions ............................................................................... 

 6. Road Type Distribution ............................................................................. 

 7. Average Speed Distributions..................................................................... 

 8. Ramp Fractions......................................................................................... 

 9. Vehicle Population .................................................................................... 

 10. Vehicle Age Distribution............................................................................ 

B. Other Local Data Inputs...............................................................................

List of Tables

Table 1 Annual and 24-Hour PM2.5 On-Road Emissions Inventory 

 for Southeast Michigan ................................................................................1 

Table 2 Mapping of TDFM Functional Class and Area Type to 

 MOVES Road Type......................................................................................4 

Table 3 VMT Distribution Factors by HPMS Vehicle Types ......................................5 

Table 4 Road Type Distribution Used in MOVES......................................................6 

Table 5 Urban and Rural Ramp Fractions.................................................................7 

Table 6 Mapping between MOVES Vehicle Types and Michigan 

 DOS Body Style ...........................................................................................8 

Table 7 Mapping between HPMS Vehicle Types and Michigan 

 DOS Body Style ...........................................................................................9 

Table 8 Monthly Average Min/Max Temperatures for PM2.5..................................10 

Table 9 Barometric Pressure Data used in MOVES................................................10 

Table 10 Revised RVP and Ethanol Market Shares Used in MOVES.......................11 
1 

On-Road Mobile Source Emissions Inventory 

for Southeast Michigan PM2.5 Redesignation Request 

I. Emissions Inventory Summary

Below are the annual and daily on-road mobile source emission inventories for fine particulate 

(PM2.5), nitrogen oxide (NOx) and sulfur dioxide (SO2). The daily inventory reflects average 

winter weekday conditions because the highest PM2.5 concentrations generally occur during the 

winter season. 

Table 1: Annual and 24-Hour PM2.5 On-Road Emissions Inventories for Southeast Michigan 

Annual Inventory Average Winter Weekday Inventory 

Year Vehicle 

Population 

Vehicle 

Miles of 

Travel 

(millions) 

PM2.5 

(tons) 

NOx 

(tons) 

SO2 

(tons)

Vehicle 

Miles of 

Travel 

(millions) 

PM2.5 

(tons) 

NOx 

(tons) 

SO2 

(tons) 

2005 3,660,074 44,187 5,323 154,294 3,809 126.1 19.2 460.8 8.6

2008 3,647,666 44,156 4,360 119,194 1,066 125.6 15.7 365.3 3.1

2018 3,667,667 44,279 1,633 37,847 310 126.3 6.6 117.8 0.9

2022 3,687,940 44,523 1,311 28,044 294 127.0 5.6 88.1 0.8

2035 3,795,289 45,819 1,123 21,791 283 130.7 4.9 69.2 0.8

II. On-Road Mobile Emissions Inventory Development 

The PM2.5 on-road emissions inventories were developed using the U.S. EPA’s new Motor 

Vehicle Emission Simulator (MOVES) model. The analysis used version MOVES2010a, which 

was released in August 2010. MOVES is EPA’s successor to the Mobile6 model. However, in 

addition to generating mobile emission rates, MOVES also has the capability to calculate onroad mobile emissions inventories, thus eliminating the need for most of the post-processing that 

was necessary with Mobile6. 

To prepare a regional emissions inventory, the user has the choice of modeling each county 

separately or combining counties to form a custom domain. SEMCOG has chosen the latter 

option for two reasons. First and foremost, staff believe that traffic count and vehicle population 

data used in the emissions modeling process are more robust at the regional level and more 

accurately reflect the travel patterns in the region, which are not confined within county 

boundaries. For example, the age distribution of vehicles registered within a specific county may 

not reflect the age distribution of vehicles traveling on that county’s roads because of the high 

amount of inter-county travel in the region. The second reason for choosing the custom domain 

option is that it saves a significant amount of time. A single MOVES run, whether by county or 

custom domain, takes approximately one hour. Thus, a typical conformity analysis which 
2 

requires two separate runs for each of four required analysis years, would take 56 hours if run at 

the county level but only 8 hours using the custom domain. 

MOVES includes default data for many of its necessary data inputs. However, wherever possible 

SEMCOG has incorporated local data in order to develop the most accurate emissions inventory 

for Southeast Michigan. These local data inputs are described below. To ease the transition from 

Mobile6 to MOVES, EPA has provided a number of “conversion tools” that allow users to 

convert local data inputs used in Mobile6 to the MOVES input format. SEMCOG has taken 

advantage of several of these tools. Their use is noted under the appropriate sections below. 

A. Local Travel Data Inputs 

1. Demographic Data 

Travel forecasts used to develop the on-road mobile source emissions inventory were 

based on demographic data from SEMCOG’s 2035 Regional Development Forecast 

(RDF), which was adopted in early 2008. A three-step process was used to develop this 

forecast. 

1) Regional forecast totals of population, households and jobs were generated from 

the REMI (Regional Economic Models, Inc.) model which forecasts Southeast 

Michigan’s ability to attract and retain population and jobs relative to all other 

parts of the United States. Regional totals are developed in five-year intervals 

from the 2005 base year to 2035; 

2) The regional totals were then used to develop a small-area forecast that 

disaggregates regional population, households and jobs into five-acre grid cells 

using the UrbanSim model. UrbanSim is a computer simulation model for 

planning and analysis of urban development. It incorporates the interaction 

between land use, transportation, and public policy. In doing so, it puts future 

population and jobs into the most desirable grid cells and models residential and 

nonresidential developments as demand arises. 

3) Grid cells from the small-area forecast were aggregated to traffic analysis zones 

(TAZs) for use in SEMCOG’s travel forecasting model. 

As noted above, SEMCOG’s RDF provides forecasts in five-year increments from 2005 

to 2035. The 2008, 2018 and 2022 demographic forecasts used to develop the PM2.5 

emissions inventories were interpolated using the two closest five-year forecasts for each 

of these years (i.e. 2008 was interpolated using the 2005 and 2010 RDF forecasts). 
3 

It should also be noted that the 2035 RDF was developed prior to the severe economic 

downturn in late 2008. The 2040 RDF, which is currently under development and will be 

completed in March 2012, will likely forecast significantly lower population and 

employment for the region. 

2. SEMCOG’s Travel Demand Forecasting Model (TDFM) 

Vehicle miles of travel (VMT) forecasts for the on-road emissions inventory were 

developed using version E5 of SEMCOG’s Travel Demand Forecasting Model (TDFM), 

which was implemented in 2009. The TDFM runs on the TransCAD software platform 

and utilizes the standard four-step travel modeling process: trip generation, trip 

distribution, mode choice, and traffic assignment. Detailed documentation on the model 

is contained in a separate SEMCOG document that is available upon request. 

3. Mapping of Travel Demand Model (TDFM) Functional Classes and Area Types to 

MOVES Road Types 

In order to use TDFM travel data in MOVES, the road types used in SEMCOG’s model 

must be reconciled with those used in MOVES. The MOVES model uses four basic road 

types for on-road activities: Urban Restricted, Urban Unrestricted, Rural Restricted and 

Rural Unrestricted. The term restricted refers to restricted or limited access roadways. In 

the SEMCOG region, this includes all freeway facilities. All other roadways in the 

SEMCOG region are considered unrestricted facilities. The TDFM also includes several 

special functional classes that are not part of the regular roadway network (e.g. walk 

only, external zone connectors, transit-only links). These are not included in SEMCOG’s 

emissions modeling. 

As TDFM functional classes do not distinguish between urban and rural facilities, 

another TDFM variable, Area Type, was used as a surrogate. The TDFM defines four 

area types (urban business, urban, suburban and rural) and assigns one to each roadway 

link based on the density of households, population and employment in the traffic 

analysis zone in which the link resides. 

Table 2 shows how each area type and functional class in SEMCOG’s TDFM is mapped 

to the four road types used in MOVES. 
4 

Table 2: Mapping of TDFM Functional Class and Area Type to MOVES Road Type 

SEMCOG TDFM Area Type SEMCOG TDFM 

Functional Class Urban 

Business Urban Suburban Rural 

 1 - Interstate Freeway 

 2 - Other Freeway 

 8 - Ramp 

11 - Freeway Connector 

4 – MOVES Urban Restricted 

Road Type 

2 – MOVES Rural 

Restricted Road Type 

 4 - Principal Arterial 

 5 - Minor Arterial 

 6 - Collector 

 7 - Local 

12 - Gravel Road 

99 - Centroid connector 

 (local road surrogate) 

5 – MOVES Urban Unrestricted 

Road Type 

3 – MOVES Rural 

Unrestricted Road Type 

81-94 Transit Use Only

90 - External

96 - Walk Only 

Non-road or outside region. Not used in MOVES 

 

4. Vehicle Miles of Travel (VMT) 

MOVES requires the user to input annual VMT by the six FHWA Highway Performance 

Monitoring System (HPMS) vehicle types: 

1) Motorcycle 

2) Passenger car 

3) Other 4-tire, 2-axle vehicles 

4) Bus 

5) Single unit truck 

6) Combination truck 

However, local VMT data used in the MOVES model is derived from SEMCOG’s Travel 

Demand Forecast Model, which generates average weekday VMT forecasts and does not 

currently have the capability to allocate this VMT to different vehicle types. Thus, some 

adjustments were required to convert the TDFM data into the format required for 

MOVES. These adjustments are described below. 
5 

a. HPMS Normalization 

In accordance with EPA and FHWA guidance, SEMCOG TDFM VMT was 

normalized to HPMS VMT by county and road type. Normalization factors were 

developed by dividing 2009 HPMS VMT by 2009 TDFM VMT. The resulting factors 

were then applied to TDFM VMT in all analysis years. 

b. Distribution of VMT Among HPMS Vehicle Types 

A two-step process was used to develop this distribution. First, SEMCOG’s 2006 

screen line traffic count database was used to develop VMT distribution factors 

among the six HPMS vehicle classes. This database includes 779 traffic classification 

counts collected throughout the seven-county SEMCOG region. When collected, the 

counts were classified by FHWA’s standard 13 traffic bins. These bins were then 

aggregated to the six HPMS classifications. 

The second step in the process involved adjusting for a recognized bias in the traffic 

count data toward undercounting the proportion of light trucks, SUVs, and vans. This 

bias was first recognized in 2004 when local count data was compared to both vehicle 

registration records and Mobile6 national default data. The bias is likely due to the 

inability of traffic counting equipment to correctly distinguishing these vehicles from 

cars, causing them to be classified under the HPMS system as “passenger cars” rather 

than “other 4-tire, 2-axle vehicles”. To correct for this bias, the count data from these 

two classifications were combined and then redistributed based on the MOVES 

default distribution. Both the original and adjusted factors are shown in Table 3. 

Table 3: VMT Distribution Factors by HPMS Vehicle Types 

HPMS Vehicle Type Before Step 2 

Adjustment 

After Step 2 

Adjustment* 

1 Motorcycle 0.011567 0.011567 

2 Passenger Car 0.713678 0.534530 

3 Other 4-tire, 2-axle vehicles 0.186204 0.365352 

4 Bus 0.008705 0.008705 

5 Single-Unit Truck 0.039116 0.039116 

6 Combination Truck 0.040730 0.040730 

* MOVES default split between vehicle types 2 & 3: 59.4% vs. 40.6% 

c. Conversion of Average Weekday VMT to Annual VMT 

Monthly and weekend day adjustment factors were developed using 2004-2006 data 

from the 150+ permanent traffic recording (PTR) stations in Southeast Michigan. 

These adjustment factors, along with the HPMS-normalized weekday VMT by 

vehicle type were then entered into EPA’s aadvmtcalculator_hpms.xls converter tool 

to compute the annual VMT and monthly and daily VMT fractions needed for 

MOVES. 
6 

5. Hourly VMT Fractions 

Two different data sources were used to develop hourly VMT fractions for MOVES: 

1) 2006 screen line traffic counts collected by SEMCOG - All screen line counts 

include classification data but were only collected on weekdays. 

2) 2005 PTR counts for locations within the SEMCOG region - This data includes 

both weekdays and weekends but all of the count stations are on freeways and 

only a limited number of these stations collect classification data. 

Using this data, SEMCOG was able to develop weekday hourly VMT fractions for each 

of the four MOVES road types and six HPMS vehicle types. However, for weekends, the 

count data was not robust enough to develop separate factors by road type or vehicle type 

so only a single set of hourly VMT factors was developed for all the road types and 

vehicle types. 

6. Road Type Distribution 

SEMCOG 2006 screen line counts were used to develop the Road Type Distribution for 

each HPMS vehicle type. Because these counts were not evenly distributed among the 

four MOVES road types, the count data was first expanded to reflect the system-wide 

VMT distribution by road type from the TDFM. Table 4 shows the final distribution 

factors used in MOVES runs for PM2.5 re-designation request. The same distributions 

were used for all analysis years. 

Table 4: Road Type Distribution Used in MOVES 

MOVES Road Type 

HPMS Vehicle Type Rural 

Restricted 

Rural 

Unrestricted 

Urban 

Restricted 

Urban 

Unrestricted 

Motorcycle 0.082102 0.080699 0.348661 0.488538

Passenger Car 0.051566 0.092906 0.290307 0.565221

Other 4-tire, 2-axle vehicles 0.054670 0.154881 0.258523 0.531927

Bus 0.115776 0.082206 0.365080 0.436938

Single-Unit Truck 0.080163 0.127845 0.355673 0.436318

Combination Truck 0.171595 0.066330 0.447998 0.314077

7. Average Speed Distributions 

MOVES uses the distribution of vehicle hours traveled (VHT) by average speed to 

determine an appropriate operating mode distribution. To develop the local average speed 

distribution for Southeast Michigan, SEMCOG used congested speed and VHT output 
7 

from the TDFM to compute the VHT fraction in each MOVES speed bin. MOVES 

requires the user to input hourly speed distributions by road type and vehicle class. While 

SEMCOG’s travel model does not provide hourly speed data, it does calculate speeds by 

four different time periods: 

1) AM peak, simulating the hours of 7:00 - 9:00 a.m.; 

2) PM peak, simulating the hours of 3:00 - 6:00 p.m.; 

3) Mid-day, simulating the hours of 9:00 a.m. - 3:00 p.m.; 

4) Off-peak, simulating the hours of 6:00 p.m. - 7:00 a.m. 

For MOVES, a separate speed distributions was developed for each of these time periods 

and applied to all hours within that period. This was done as follows: 

• For each time period, the directional congested speed of each roadway link was 

assigned to one of MOVES 13 speed bins; 

• The associated directional VHT on the links was then aggregated by speed bin 

and MOVES road type; 

• Then, for each road type, the VHT fraction in each speed bin was computed. 

As no local data is currently available on speed differentiation between vehicle classes, 

the same distributions were applied to all vehicle types. 

Note: Ramp data was not included in the development of the above speed distributions as 

it was assumed that MOVES makes an internal adjustment for ramps using the usersupplied ramp fractions. 

8. Ramp Fractions 

Ramp fractions used in MOVES were derived from SEMCOG’s Travel Demand Forecast 

Model. Table 4 shows the TDFM ramp fractions for each of the years modeled in 

SEMCOG’s long-range transportation plan. While the fractions show little variation over 

time, there is a significant difference between urban and rural areas. Thus, SEMCOG 

decided to use separate ramp fractions for urban and rural areas in MOVES. Rather than 

select the fraction associated with any one TDFM forecast year, the average of all six 

years was chosen. The specific fractions used in MOVES are shown in the far right 

column of Table 5. 

Table 5: Urban and Rural Ramp Fractions 

TDFM Forecast Year Area Type 2005 2010 2015 2020 2025 2030 2035 MOVES 

2-Rural Ramp 0.0412 0.0408 0.0397 0.0398 0.0398 0.0395 0.0393 0.04 

4-Urban Ramp 0.0795 0.0807 0.0814 0.0812 0.0809 0.0837 0.0843 0.08 
8 

9. Vehicle Population 

Year 2010 vehicle registration data from the Michigan Department of State (DOS) was 

used to develop the base year vehicle population inputs for MOVES. This data was 

supplemented with vehicle title data to capture information on public sector fleet vehicles 

(e.g. those owned and operated by cities, counties, universities, etc.) that do not appear in 

the registration database. The body style and plate type fields in the DOS database were 

used to determine the MOVES source type of each vehicle. Table 6 shows how each 

DOS body style and plate type was mapped to the MOVES source types. Where DOS 

data did not provide sufficient detail, the data was supplemented with information from 

other sources including local transit agencies, the National Transit Database, and 

MOVES default distributions for Southeast Michigan counties. 

Table 6. Mapping between MOVES Vehicle Types and Michigan DOS Body Style 

MOVES Vehicle Type Michigan DOS Body Style 

11 – Motorcycle Motorcycle 

21 – Passenger Car 2-door; 4-door; Convertible 

31 – Passenger Truck Station Wagon; Non-Commercial Pick-up/Van 

32 – Light Commercial Truck Ambulance; Hearse; Panel; Commercial Pick-up/Van 

41 – Intercity Bus 

42 – Transit Bus 

43 – School Bus 

Bus 

(Apportioned this data between MOVES M41 and M43 vehicle types 

using split factors from MOVES 2010 default run; data for M42-

transit buses was added using local fleet data from local transit 

providers) 

51 – Refuse Truck 

52 – Single-unit Short-haul 

Truck 

53 – Single–unit Long-haul 

Truck 

Dump Truck; Mixer; utility; Wrecker; Stake; Tank 

(Apportioned this data MOVES M51, M52 and M53 vehicle types 

using split factors from MOVES 2010 default run.)

54 – Motor Home Motor Home 

61 – Combination Short-haul 

Truck 

62 – Combination Long-haul 

Truck 

Tractor 

(Apportioned this data between MOVES M61 and M62 vehicle types 

using split factors from MOVES 2010 default run) 

To generate future year vehicle population data, it was assumed that this population 

would grow at the same rate as forecasted vehicle miles of travel from the TDFM. The 

rate of growth between 2010 and each future analysis year was calculated. This rate was 

then uniformly applied to all 2010 vehicle population source types to generate the future 

year population. 

Detailed documentation on the development of SEMCOG’s vehicle population data is 

contained in a separate SEMCOG mobile emissions model development memo.
9 

10. Vehicle Age Distribution 

Year 2010 DOS vehicle registration and title data were also used to develop the 

vehicle/source type age distribution used in MOVES. The DOS body style field was used 

to assign each vehicle to one of six HPMS vehicle types (see Table 7 below). Once 

HPMS vehicle types had been assigned, the data was aggregated by model year and 

assigned to the appropriate age category. Model years 2010 and 2011 were considered 

age 0, 2009 was considered age 1 and so on. Model years 1980 and older were grouped 

into the age 30+ category. The age distribution for each HPMS vehicle type was then 

computed. The same distributions are used for all analysis years. 

Table 7: Mapping between HPMS Vehicle Types and Michigan DOS Body Styles 

HPMS Vehicle Type Michigan DOS Body Style 

Motorcycle Motorcycle 

Passenger Car 2-door; 4-door; Convertible 

Other 4-tire, 2-axle vehicles Station Wagon; Non-Commercial Pick-up/Van; 

Ambulance; Hearse; Panel; 

Bus Bus 

Single-unit Short Truck Dump Truck; Mixer; Utility; Wrecker; Stake; Tank , 

Motor Home 

Combination Truck Tractor 

B. Other Local Data Inputs 

1. Temperature and Humidity Data 

Temperature and humidity data are required inputs for MOVES. For the PM2.5 on-road 

mobile emissions inventories, local temperature profiles were developed for each month 

of the year. To generate these profiles, the average minimum and maximum daily 

temperatures for each month in Southeast Michigan were computed using 2007-2009 

National Weather Service (NWS) local climatological data reports. This data was 

provided by the Michigan Department of Environmental Quality (MDEQ). EPA’s 

MeteorologicalDataConverter_Mobile6.xls tool was then used to convert the average 

minimum and maximum temperatures to the required hourly temperature inputs for 

MOVES. Table 8 shows the average min/max temperatures that were used to develop 

each month’s hourly profile. 
10 

Table 8: Monthly Average Min/Max Temperatures for PM2.5 

 Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

Min 18.4 17.2 28.6 39.5 48.7 60.0 61.4 62.9 56.6 44.1 34.3 22.7 

Max 32.2 31.5 46.2 60.0 70.2 79.8 81.2 81.8 76.1 62.4 48.6 34.8 

SEMCOG’s emissions analysis used MOVES default humidity data for Southeast 

Michigan as no other local data was available. 

2. Barometric Pressure 

The barometric pressure used for Southeast Michigan was the average of the MOVES 

default values for SEMCOG’s seven counties. Table 9 below shows each county’s 

default value and the resulting average used for the emissions inventory. 

Table 9: Barometric Pressure Data used in MOVES 

SEMCOG County 

MOVES Default 

Barometric Pressure 

(inches of Mercury, inHg) 

26093 - Livingston 29.113 

26099 - Macomb 29.144 

26115 - Monroe 29.173 

26125 - Oakland 29.146 

26147 - St. Clair 29.172 

26161 - Washtenaw 29.095 

26163 - Wayne 29.069 

Average 29.130 

 

3. Fuel Supply/Fuel Formulation 

In transitioning its mobile emissions modeling from Mobile6 to MOVES, SEMCOG 

reviewed both the Fuel Supply and Fuel Formulation default values contained in MOVES 

for counties in Southeast Michigan (Lenawee, Livingston, Macomb, Monroe, Oakland, 

St. Clair, Washtenaw and Wayne counties). Only 2005 and later years were reviewed. 

Earlier years will be reviewed in future if there is a need to model them. 

Several adjustments were made to accurately reflect observed ethanol market share data 

from the Michigan Department of Agriculture as well as State regulation on permitted 

oxygenates and maximum allowable summertime Reid vapor pressure (RVP) in 

Southeast Michigan. These adjustments are documented below. 

• Corrected the 2012 summertime gasoline RVP for all SEMCOG Counties to 

reflect the State’s legal limit for Southeast Michigan (7.0 psi). 
11 

• Zeroed out any market share for gasoline with MTBE or TAME since neither has 

been used in Michigan since 2003. 

• Adjusted the ethanol market share for all SEMCOG counties to match observed 

data from the Michigan Department of Agriculture’s Consumer Protection 

Section Annual Reports for years 2005-2009. 

• Set the ethanol market share for all SEMCOG counties to 100% in years 2010 and 

later. This was the observed share in 2009 and is expected to continue in future 

due to federal requirements for increased use of biofuels. 

The resulting RVP and ethanol market share values used in MOVES after the above 

corrections are shown in Table 10 below. 

Table 10: Revised RVP and Ethanol Market Shares used in MOVES 

Year Summer RVP 

(months 5-9)

Ethanol 

Market Share 

(all months) 

2005 7.8 psi 39.5%

2006 7.8 psi 58.4%

2007 7.0 psi 80.3%

2008 7.0 psi 98.9%

2009 7.0 psi 100.0%

2010 and later 7.0 psi 100.0%

. 
Appendix D 

Stationary Source Facility Detail 
2

Purpose of this Appendix

The information in this appendix was collected for the purpose of supplementing 

inventory data found in Section 5 of the main document. The data in this appendix was 

collected from company permits, Air Quality Division (AQD) field reports, special studies, 

and discussions with companies that are in the general vicinity of the Dearborn air 

monitor, which has the highest PM2.5 values in Southeast Michigan. Figure 1 shows the 

location of emission sources around the Dearborn monitor. These sources will be 

discussed below. These sources include both large and smaller facilities. Most are still 

operating but some are closed. 

Figure 1. Map of Emission Sources Near the Dearborn Monitor

Dearborn Monitor 
3

List of Sources 

SRN Source SRN Source 

A6902 Darling International Inc B3533 Edw C Levy Co Plant 1 

A7809 US Steel Great Lakes Works B3567 St Mary's Cement 

A8196 M-Lok Riley Plating – OOB* B4752 Great Lakes Petroleum Terminal – OOB* 

A8640 Severstal North America B5162 Xcel Steel Pickling (formerly Castle Steel) 

A8648 Ford Motor Co. - Rouge Complex B5558 Honeywell – OOB* 

A9196 Fabricon Products Inc B7071 Automotive Components Holding 

A9831 Marathon-Ashland Oil Refinery B9080 Envirosolids, LLC 

B2103 Detroit Water and Sewerage Department K1636 City of Dearborn 

B2169 Carmeuse Lime, Inc. (River Rouge Facility) M3066 Spartan Industrial – OOB* 

B2247 Buckeye Terminals LLC (Detroit Terminal) M4685 Detroit Salt 

B2798 Detroit Edison Co. - Delray M4798 Ferrous Environmental – OOB* 

B2810 Detroit Edison Co. - River Rouge M4848 Ford Motor Allen Park Clay Mine – OOB* 

B2926 Sunoco Partners M & T, L.P. (River Rouge 

Terminal) 

N0226 Hinkle MFG LLC 

B2956 Ford Motor New Model Program N1014 Magni Industries Inc 

B3195 Cadillac Asphalt Products N6631 Dearborn Industrial Generation 

B3518 United States Gypsum Company N7723 DTE Energy / Ford World Headquarters 

* OOB means “Out of Business.”

The purpose of this source-by-source review is to better understand the types of facilities 

that may be impacting the PM2.5 levels in the vicinity of the Dearborn monitor and 

activities at the facilities that may have contributed to emission changes over a period of 

years. Various parameters were acquired, including emissions information, operating 

schedules, distance and direction from the Dearborn monitor, stack heights, and product 

throughput. 

An example of additional information that can be helpful in understanding emissions 

impacting the Dearborn area can be seen by comparing emissions inventories for 2005 

to 2008 (see Tables 5 and 6 in the main document), NOX and SO2 emissions from 

electric generating unit (EGU) and non-EGU point sources in the 7-county nonattainment 

area increase between 2005 and 2008 for the annual inventory. However, this may not 

reflect the changes that are occurring at sources that are in the more immediate vicinity 

of the Dearborn monitor. Some of these facilities may have reduced their emissions 

which may have a positive impact on PM2.5 levels in the area, which is not obvious by 

the 7-county emissions data. In general, since local sources have a bigger impact on 

the nearby Dearborn monitor than more distant sources, they deserve to be analyzed in 

greater detail. 

It should be noted that attempts were made to obtain detailed information for other 

sources as well. Sources throughout the 7-county nonattainment area were screened to 

determine permanent and enforceable reductions made between 2005 and 2008. 

However, emissions inventories and permits to install (PTI) do not give clear indications 

of what controls are installed or when controls are installed. Therefore, it made the most 

sense to focus limited resources on analyzing sources near the Dearborn monitor. 
4

Other Consideration - Emission Inventory Challenges of PM2.5

Using emission inventories for PM2.5 and precursors is the primary metric required to 

demonstrate the reason for an area moving from nonattainment to attainment. This is 

detailed in Section 5 of the main document. The use of inventories brings some inherent 

issues described here and is the reason for considering other metrics of information in 

making a robust demonstration, as has been done in Section 6 of the main document 

and in this appendix. The Michigan Air Emissions Reporting System (MAERS) 

emissions inventory from 1998-2008 was evaluated. Emissions inventory trends are 

very difficult to interpret since the data is always changing. Companies may report 

emission units (reporting group or individual units), source classification codes (SCCs), 

etc. differently from year to year. In addition, emission factors that are used to calculate 

the emissions are frequently changed by the Environmental Protection Agency (EPA) as 

better data becomes available. If no emission factor is available, the company does not 

have to report emissions for that pollutant. The company may also use different 

methods for calculating emissions from year to year, including federal emission factory 

stack testing and continuous emission monitoring (CEM). 

In the case of particulate matter (PM), major changes have occurred over the last ten 

years. In 1998, only PM-primary and PM10-primary were reported. In 1999, a few 

companies voluntarily started reporting PM2.5-primary. In 2002 PM-primary was no 

longer reported, only PM10-primary and PM2.5-primary. In 2004, PM10-filterable and 

PM2.5-filterable started to be reported, thus, PM10-primary, PM10-filterable, PM2.5-primary 

and PM2.5-filterable are reported for each SCC. Each emissions unit may have more 

than one SCC and may report emissions for PM10 and/or PM2.5 that are either filterable 

or primary. 

Other Metrics Used

Emissions of primary PM2.5 are obviously important when assessing a nearby facility’s 

potential impacts on the monitor. Emissions of PM2.5 precursors, SO2 and NOX, are also 

important to understand. Depending on the facility distance to the monitor, these 

precursors may have time to react to form PM2.5 in the form of sulfates and nitrates. 

Stack heights are important because they affect dispersion of the pollutants. Tall stacks 

produce pollutant plumes that may not impact a nearby ground level monitor, but can 

influence a monitor at some distance away. Short stacks tend to have the opposite 

effect, impacting nearby sources. 

Process throughput (or production) usually is a more consistent measure of what is 

happening at an industrial process than reported emissions when looking at trends. The 

emissions are often calculated based on throughput, but emission factors may change 

over time as described previously. However, throughput will not indicate decreases in 

emissions if control equipment is added. 

The location of a facility relative to the Dearborn monitor is important. Wind, in the area 

are predominantly from the south and southwest, so sources located in this upwind 

direction from the monitor will have a much larger impact than sources in other 

directions. The proximity of a source to the monitor also can determine the level of 

impact the source may have. A facility’s operating schedule can be informative, 

particularly if the facility has seasonal changes. For the daily PM2.5 standard, high PM2.5

levels occur more often in winter months, so a company’s operating schedule could 
5

suggest higher or lower impacts to the Dearborn monitor during the more critical winter 

months. 

Determining emission trends from a nearby facility is important in judging how the facility 

may have impacted PM2.5 levels in the area over the 2005 – 2008 time period, which 

represents the change from not meeting the PM2.5 standard to meeting the standard at 

the Dearborn monitor. However, throughput may provide an even clearer picture of a 

facility’s impact in cases where emission data may be less reliable as described in the 

previous paragraphs. Reporting of throughput by a facility is usually a much more stable 

metric than emissions, and companies generally keep good records of throughput. 

Throughput trends therefore are also used to help understand changes in potential 

emission impacts from facilities near the Dearborn monitor. It should be noted that 

throughput does not account for controls that may be added to a process at a facility, 

resulting in lower emissions from the year the controls were added into the future. Aside 

from this, increases and decreases in throughput can be expected to result in increases 

and decreases in emissions. 

In the following facility studies, emission trends are compared to throughput trends to 

help show reliability of emissions information. Also, years when the two metrics diverge 

can show that additional controls may have been added. 

Ultimately, these evaluations of facilities may provide insight into whether emissions 

reductions can be expected to be permanent or are fluctuations in throughput. One 

requirement of the redesignation state implementation plan (SIP) is to show that 

emission reductions that led to the area meeting the standard are permanent and 

enforceable, as described in Section 5 of the main document. These facility studies may 

provide some clues as to the source of reductions when this information is not readily 

available and whether reductions are permanent. The trends themselves also can 

provide insight on expectations for future emissions and impacts on the ambient air in 

the vicinity of the Dearborn monitor. 

FACILITY DETAILS 

Severstal

Severstal North America, Inc. operates an integrated steel mill at the Rouge Industrial 

Complex in Dearborn, Michigan. The Rouge Industrial Complex is located at 3001 Miller 

Road in Dearborn, Michigan (Wayne County). The complex is bounded by Rotunda 

Drive on the north, Miller Road on the east, Dix Avenue and Rouge River on the south, 

and Schaefer Road on the west. The area is mainly industrial, and the nearest 

residence is approximately 1500 ft east of Miller Road. This mill is less than one mile 

southeast of the Dearborn air monitoring station (Dearborn monitor). 

Severstal operations cover approximately 500 acres, occupying the southern half of the 

Rouge complex. Operations include three blast furnaces (BFA, BFB, BFC) with only 

BFB currently operational, a waste oxides reclamation facility, a basic oxygen furnace 

(BOF) shop, two continuous casters, a hot strip mill, and cold mill operations. The plant 

produces sheet steel that is used in a variety of manufacturing applications. Ford Motor 

Company operates the remainder of the complex. Severstal North America, Inc. is 

independent of the Ford Motor Company and is an autonomous producer of steel. 
6

The steel mill runs year around, 24 hours per day, seven days per week. The stack 

emission heights are generally over 150 ft for the major emissions units. The annealing 

furnaces have shorter stacks at 64 feet. A few minor emission sources have baghouse 

stacks ranging from 27 to 51 feet. Severstal may also have some areas of fugitive 

emissions that are not as well documented. 

A review of the company’s emission inventory data from 1998 through 2008 indicates 

that the facility’s operations have decreased since approximately 2005. The BOF and 

the blast furnaces with their stoves are the major sources of emissions and throughput at 

Severstal. 

 

Comparing emissions trends to throughput trends indicates that they generally match, 

but there is an occasional year that diverges (see Figure 2 through 4). Emission factors 

used to calculate emissions for a process can be determined by the company, and they 

are occasionally revised. For example, Severstal used AP-42 factors for their blast 

furnace cast house operations in 1998, but in 1999-2007, they used stack test data from 

another steel mill. In 2008, they ran their own stack tests and are now using those 

values. Severstal has done additional on-site stack tests and will be using those results 

for future emissions reports. Thus throughput may more accurately represent emissions 

to ambient air over several years, unless controls are added. 

Figure 2. BOF Emissions to Throughput Comparison at Severstal 

BOF-NOx 

0

50

100

150

200

250

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

 Thruput (tons)

Nox Thruput (tons)

BOF- SO2

-

0.05

0.10

0.15

0.20

0.25

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

thruput (tons)

SO2 Thruput (tons)

BOF-PM

0

50

100

150

200

250

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

thruput (tons)

PM2.5 (tons) PM10 (tons) Thruput (tons)
7

Figure 3. Blast Furnace Emissions to Throughput Comparisons at Severstal 

Blast Furnaces - NOx

-

5.00

10.00

15.00

20.00

25.00

30.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007* 2008*

emissions (tons)

0

200000

400000

600000

800000

1000000

1200000

1400000

1600000

1800000

thruput (tons)

NOX-BFC NOX-BFB Thruput-BFB Thruput-BFC

Blast Furnaces - SO2

0

5

10

15

20

25

30

35

40

45

50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007* 2008*

emissions (tons)

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

thruput (tons)

SO2-BFB SO2-BFC Thruput-BFB Thruput-BFC

438 

2,409

1,344

Blast Furnace B - PM

0

5

10

15

20

25

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

thruput (tons)

pm10 PM2.5 Thruput-BFB

Blast Furnace C - PM

0

5

10

15

20

25

30

35

40

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007* 2008*

emissions (tons)

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

thruput (tons)

PM2.5 PM10 Thruput-BFC

Figure 4. Blast Furnace Stove Emissions to Throughput Comparisons at Severstal 

BF Stoves - NOx

0

50

100

150

200

250

300

350

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

5000

10000

15000

20000

25000

30000

thruput (e6ft3)

Nox-BFB NOX-BFC BFB Stove Gas BFC Stove Gas 

BF Stoves - SO2

-

20.00

40.00

60.00

80.00

100.00

120.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

5000

10000

15000

20000

25000

30000

thruput (E6ft3)

SO2-BFB SO2-BFC BFB Stove Gas BFC Stove Gas 

Stove BFB - PM

0

10

20

30

40

50

60

70

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

2000

4000

6000

8000

10000

12000

14000

16000

18000

thruput (E6ft3)

PM10-pri (tons) PM2.5 pri (tons) BFB Stove Gas

Stove BFC - PM

0

20

40

60

80

100

120

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

emissions (tons)

0

5000

10000

15000

20000

25000

30000

thruput (E6ft3)

PM2.5-pri PM10-pri BFC Stove Gas 
8

A different comparison can be made with throughput compared to ambient PM2.5. For 

Severstal, this comparison does show some correlation. In 2007, baghouse controls for 

the BOF and blast furnace C were added. In January 2008, blast furnace B was 

severely damaged; requiring shut down and has not been repaired. The company 

indicated that when the blast furnace B does start up again, it will be controlled by a 

baghouse. In 2008 throughput began to increase for the BOF and Blast Furnace C, but 

ambient PM2.5 decreased. This decrease in ambient PM2.5 may be due to the blast 

furnace B shut down, as well as the impact of the new controls (see Figure 57). 

Figure 5. BOF Throughput to Ambient PM2.5 Concentrations at the 

Dearborn Monitor 

BOF 

0

500,000

1,000,000

1,500,000

2,000,000

2,500,000

3,000,000

3,500,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Thruput (tons)

0

5

10

15

20

25

concentration (ug/m3)

BOF material thruput (tons) PM2.5 (ug/m3)
9

Figure 6. Blast Furnace Throughput to Ambient PM2.5 Concentrations at 

the Dearborn Monitor 

Blast Furnace Thruput

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

1,800,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

thruput (tons)

0

5

10

15

20

25

concentration (ug/m3)

B Blast Furnace Cast House (tons) C Blast Furnace Cast House (tons) PM2.5 (ug/m3)

Figure 7. Blast Furnace Stoves Throughput to Ambient PM2.5 

Concentrations at the Dearborn Monitor 

BF Stoves Gas Thruput

0

5,000

10,000

15,000

20,000

25,000

30,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Thruput (E6ft3)

0

5

10

15

20

25

Concentration (ug/m3)

Stoves BFB Gas (E6ft3) Stoves BFC Gas (E6ft3) PM2.5 (ug/m3)

Severstal, being a major emissions source located very near and directly upwind of the 

Dearborn monitor, is considered to directly impact PM2.5 levels at the monitor. With the 

recent (2007) installation of additional PM controls to the steel mill, ambient PM2.5

showed attainment for PM2.5 NAAQS for the first time at the Dearborn monitor. A major 

reason can be explained by additional Severstal controls, and this source is a likely 

candidate for contingency measures if additional controls are needed in the Dearborn 

area. 
10

US Steel

United States Steel, Great Lakes Works operates an integrated steel mill that has been 

in operation since August 1930. It is located just south of the city of Detroit. The site 

consists of approximately 1100 acres that span along the Detroit River through the cities 

of Ecorse and River Rouge. The facility includes the Main Plant Area, the 80-inch Hot 

Strip Mill, and the iron making and coke-making operations on Zug Island. The plant 

produces flat-rolled steel products for the automotive, appliance, container, service 

center, and piping and tubing industries. It should be noted that the coke-making 

operations have been sold to another company. 

The primary iron producing facility is located on Zug Island, in the city of River Rouge. 

Zug Island is bordered by the Rouge River on the north, south, and west sides and the 

Detroit River on the east side. The Zug Island facility includes three operating blast 

furnaces, one coke oven, coke by-product recovery plant, and three boiler houses. The 

facility site is zoned heavy industrial. The nearest residential area is approximately 0.6 

miles from the facility. This portion of the facility is located 2.5 miles southeast of the 

Dearborn monitor. 

The 80-inch Hot Strip Mill facility is located in the city of River Rouge between the Zug 

Island and Main Plant facility location. The 80-inch Hot Strip Mill facility includes the hot 

strip finishing and shipping building, scale pit, coil storage and shipping building, slab 

yard, and 80-inch hot strip mill. The facility site is zoned heavy industrial. The nearest 

residential area is approximately 1.5 miles from the facility. 

The Main Plant Area is located on a 682-acre site located in the city of Ecorse. It is 

bordered by the Detroit River on the east, by the 80-inch Hot Mill Strip facility on the 

north, by the E.W. Levy Plant No. 5 on the south and Jefferson Avenue to the west. The 

following steel-making operations are located at the Main Plant: No. 2 Basic Oxygen 

Process (#2 BOP), Vacuum Degasser, Ladle Metallurgical Facility (LMF), Pickle Line, 

Electrogalvanizing Line, No. 4 tandem cold mill, Annealing Furnace, and Boiler House. 

The plant site is zoned heavy industrial. The nearest residential area is approximately 

0.5 mile from the facility. 

US Steel has several large emitting sources, and in some cases, the emissions do not 

follow throughput (see Figures 8 through 14). In particular, some units’ emissions in 

2004 and 2005 do not follow throughput (see Figure 8 through 12). Information is not 

available to explain these changes. Also, emission factors used are not reported for 

several years in the AQD MAERS program, so the reason for changes are difficult to 

track. 
11

Figure 8. 80” Strip mill emissions to throughput comparison at US Steel. 

80" Mill - Nox & SO2

0

500

1000

1500

2000

2500

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Emissions (tons)

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

Thruput (Million FT3)

Nox SO2 Thruput 

80" Mill - PM

0

5

10

15

20

25

30

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Emissions (tons)

0

2000

4000

6000

8000

10000

Thruput (Million FT3)

PM10 Thruput 

 

Figure 9. Blast furnaces B and D emissions to throughput comparison at US Steel.

Blast Furance B

0

50

100

150

200

250

300

350

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

0

5000

10000

15000

20000

25000

30000

Nox SO2 PM10 Thruput 

Blast Furnace D

0

50

100

150

200

250

300

350

400

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Emissions (tons)

0

5000

10000

15000

20000

25000

30000

35000

40000

Thruput (E6FT3)

Nox SO2 PM10 Thruput 

 

Figure 10. Coke oven emissions to throughput comparison at US Steel. 

Coke Oven - SO2 & NOx

0

500

1000

1500

2000

2500

1998 1999 2000 20012002 20032004 20052006 20072008

1050000

1100000

1150000

1200000

1250000

1300000

1350000

1400000

Thruput (tons)

Nox SO2 Thruput 

Coke Oven - PM

0

50

100

150

200

250

300

350

400

450

500

1998 1999 2000 20012002 2003 2004 20052006 20072008

1050000

1100000

1150000

1200000

1250000

1300000

1350000

1400000

PM 10 PM 25 Thruput 
12

Figure 11. Coke oven gas flare emissions to throughput comparison at US Steel. 

Coke Oven Gas Flares - SO2

0.00

200.00

400.00

600.00

800.00

1,000.00

1,200.00

1,400.00

1,600.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

0

500

1000

1500

2000

2500

3000

3500

4000

4500

SO2 Thruput 

Coke Oven Gas Flares - Nox & PM

0

20

40

60

80

100

120

140

160

180

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

0

500

1000

1500

2000

2500

3000

3500

4000

4500

Nox PM10 Thruput 

Figure 12. BOF emissions to throughput comparison at US Steel. 

BOF - Nox, PM, &SO2

0

100

200

300

400

500

600

700

800

900

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

0

500000

1000000

1500000

2000000

2500000

3000000

3500000

4000000

Nox SO2 PM10 PM2.5 Thruput 

Figure 13. Zug Island boiler house #1 emissions to throughput comparison at US Steel. 

Zug Island Boiler House #1 -Nox & SO2

0

200

400

600

800

1000

1200

1400

1998 1999 2000 2001 2002 2003 2004 20052006 20072008

0

5000

10000

15000

20000

25000

30000

35000

Nox SO2 Thruput 

Zug Island Boiler House #1 - PM

0

5

10

15

20

25

30

35

40

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

0

5000

10000

15000

20000

25000

30000

35000

PM10 PM2.5 Thruput 
13

Figure 14. Zug Island boiler house #2 emissions to throughput comparison at US Steel.

Zug Island Boiler House #2 - SO2 & NOx

0

200

400

600

800

1000

1200

1400

1600

1998 1999 2000 2001 2002 2003 2004 20052006 20072008

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

Nox SO2 Thruput 

Zug Island Boiler House #2 - PM

0

10

20

30

40

50

60

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

PM 10 PM 2.5 Thruput 

Since throughput does not follow emissions very well, another comparison was made. 

Throughput was compared to ambient PM2.5 at the Dearborn monitor and at the 

Southwest High School (SWHS) monitor, since US Steel is much closer and upwind of 

the SWHS monitor. This comparison shows some correlation for some emission units, 

but not for others (see Figure 15). 

It should be noted that while US Steel is a large emissions source, it may have less 

impact on the Dearborn monitor than other large sources in the area, since it is 

downwind of the monitor. 

Figure 15. Throughput to Ambient PM2.5 Concentrations at the Dearborn and SWHS 

Monitors.

Thruput to Ambient PM2.5

0

5000

10000

15000

20000

25000

30000

35000

40000

45000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Thruput (million Ft3)

0

5

10

15

20

25

Ambient PM2.5 (ug/m3)

 BFB BFD Zug Boiler #1

Zug Boiler #2 Dearborn PM2.5 SWHS PM2.5

Thruput to Ambient PM2.5

0

1000

2000

3000

4000

5000

6000

7000

8000

9000

10000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Thruput (Milion FT3)

0

5

10

15

20

25

Ambient PM2.5 (ug/m3)

80"Mill Coke Oven Flares Dearborn PM2.5 SWHS PM2.5

Thruput to Ambient PM2.5

0

500000

1000000

1500000

2000000

2500000

3000000

3500000

4000000

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Thruput (tons)

0

5

10

15

20

25

Ambient PM2.5 (ug/m3)

Coke oven BOF Dearborn PM2.5 SWHS PM2.5
14

Marathon-Ashland Petroleum LLC

Marathon Ashland Petroleum LLC. – Detroit Refinery and Detroit Light Products 

Terminal are located at 1300 Fort Street and 12700 Toronto Street in the southwest part 

of the city of Detroit. The facilities are sited between Interstate Highway I-75, Fort 

Street, Oakwood Avenue and Dix Avenue and the Rouge River. The nearest residential 

area is approximately 100 feet west of Stocker Avenue near the Rouge River Terminal. 

Marathon is located two miles south of the Dearborn monitor. The refinery operates 24 

hours per day, seven days per week and 52 weeks per year. 

Marathon Ashland Petroleum LLC refinery processes approximately 72,000 barrels per 

day of crude oil, which is refined into a product mix of liquefied petroleum gases, 

gasoline, fuel oil, asphalt, and other products. The makeup of this production will vary 

depending on the type of crude used as charge stocks. The finished products leave the 

facility via truck, lake tanker, railroad car, or pipeline. 

The refinery is organized into five complexes for operations and maintenance purposes. 

Complex I has the Crude and Vacuum Units. Complex II consists of the Unifiner, 

Alkylation, and Sulfur Recovery units. Complex III includes the Fluid Catalytic Cracking 

Unit (FCCU) and other Light Ends Units. Complex IV includes the Catalytic Reformers, 

Hydrotreaters, and Boilers; and Complex V contains the Storage and Blending Facilities, 

as well as the Marine Loading Facilities. The refinery operations are controlled by a 

Distributed Control Computer System. 

Crude oil is the raw material the refinery utilizes to create finished products such as fuels 

and asphalt. The refinery is staged such that processing alters the physical and 

chemical state of the crude oil, which in turn, produces marketable products. Both sweet 

and sour crude oils are processed at the Detroit refinery. Sour crude contains a higher 

content of sulfur components than sweet crude. All crude oil is pipelined into the 

refinery. Other raw material may be brought into the refinery by pipeline or is 

transported in trucks including iso-butane, n-butane, toluene, xylene, ethanol, gas oil and 

catalysts. 

Reviewing the company’s emission inventory and throughput data from 1998 through 

2008 indicated that the facility’s operations had actually increased for the years 2006 

through 2008; i.e., the same time period as the decreased emissions shown on the 

Dearborn monitor. Marathon reported source emissions using the emissions factors 

within MAERs. The material and fossil fuel throughput amounts for the largest units at 

this location, the FCCU, Zurn Boiler and B&W Boiler were used to determine whether 

significant changes in operations had occurred. See Figure 16 through Figure 19. The 

graphs begin in the year 2003 and go through 2008. Prior to 2003 the operations at the 

facility were intermittent. Emissions for PM2.5 were not reported, and back calculations 

of the emissions using the most current emission factor did not show anything 

significant. 

The Detroit Heavy Oil Upgrade project (DHOUP) air permit (most recent permitting 

activity) has specific emission limits for the FCCU, Zurn Boiler and B&W Boiler, which 

are federally enforceable. In addition, the refinery purchased 80 tons of PM10 emission 

credits for offsetting purposes during the permitting for the DHOUP project. Per the 

facility and district staff contact, the credits were never used and were retired from use. 
15

The offsets were purchased from Central Wayne Recovery and Carmeuse Lime. 

Central Wayne Recovery was located in Inkster MI, near Dearborn. The facility ceased 

all operations in the fall of 2003. Therefore the reductions are permanent. 

Carmeuse Lime (formerly known as Detroit Lime) was located on Dix Road in Detroit 

near Dearborn. The facility ceased all operations in Fall 2002. Therefore the reductions 

are permanent. 

Zurn Boiler

The Zurn Boiler’s normal operations are year-round 24 hours a day. The exhaust stack 

for this unit is 150 feet high with an inside diameter of 72 inches. This unit is centrally 

located within the facility boundaries. The facility originally proposed removal of the Zurn 

boiler (at 210 mmbtu/hr) and replacing it with a new boiler (rated at 300 mmbtu/hr). 

However, the facility determined that the extra steam generating capacity was not 

necessary and kept the Zurn boiler in operation. The Zurn boiler has the capacity to 

burn refinery fuel gas, but only uses natural gas at this time. The Zurn boiler has 

federally enforceable permitted emission limits for NOx, CO, VOC, PM and PM10. The 

Zurn boiler also has a material throughput limit of 210,000 cubic feet per hour of fuel 

burned. The Zurn Boiler has a federally enforceable permit limit requiring installation 

and maintenance of multi-staged low-NOx burners. Figure 16 shows a comparison of 

emissions to ambient PM2.5 at the Dearborn monitor. 

Figure 16. Zurn Boiler Emissions to Ambient PM2.5 at Dearborn Monitor 

Emissions to ambient PM2.5 for Zurn Boiler

0.0

1,000.0

2,000.0

3,000.0

4,000.0

5,000.0

6,000.0

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Emissions (lbs)

0

5

10

15

20

25

PM2.5 (ug/m3)

so2 pm2.5 * ambient PM2.5

*PM2.5 emissions calculated based on throughput. 

FCCU

The FCCU’s normal operations are year-round, 24 hours a day. The exhaust stack for 

this unit is 195 feet high with an inside diameter of 72 inches. This unit is centrally 

located within the facility boundaries. Per the company contact, the FCCU has had 

major control projects installed to help reduce PM from the unit. In December 2004, the 

refinery installed Electrostatic Precipitators on the exhaust portion of this stream to 

reduce PM below the federal limits. After they began using higher sulfur crude (tar 

sands?) they experienced an increase of PM rates in 2008. In late 2008, the facility 
16

installed an ammonia injection system to condition the gas plume on the unit to keep PM 

at conservative levels below the company’s allowable limits. Overall the facility 

estimates that the ammonia injection system installation reduced NOx emission by 20 

percent. Per the facility, they have reduced criteria pollutant emissions by 75 percent 

through the installation of state of the art technologies (see Figure 17 and Figure 18). 

Figure 17. Emissions to Throughput Comparison for the FCCU at Marathon 

FCCU

0.0

100,000.0

200,000.0

300,000.0

400,000.0

500,000.0

600,000.0

700,000.0

800,000.0

900,000.0

1,000,000.0

19981999200020012002200320042005200620072008

LBS

0.0

2,000.0

4,000.0

6,000.0

8,000.0

10,000.0

12,000.0

bbls

nox

thruput

FCCU

0.0

200,000.0

400,000.0

600,000.0

800,000.0

1,000,000.0

1,200,000.0

1,400,000.0

19981999200020012002200320042005200620072008

LBS

0.0

2,000.0

4,000.0

6,000.0

8,000.0

10,000.0

12,000.0

bbls

so2 

thruput

Figure 18. FCC Emissions to Ambient PM2.5 at Dearborn Monitor 

Emissions to ambient PM2.5 for FCCU

0.0

200,000.0

400,000.0

600,000.0

800,000.0

1,000,000.0

1,200,000.0

1,400,000.0

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Emissions (lbs)

0

5

10

15

20

25

PM2.5 (ug/m3)

nox so2 ambient PM2.5

B&W Boiler

The B&W Boiler’s normal operations are year-round, 24 hours a day. The exhaust stack 

for this unit is 150 feet high with an inside diameter of 80 inches. However, this unit is 

centrally located within the facility boundaries. The B&W boiler has federally 

enforceable permitted emission limits for NOx, CO, VOC, PM and PM10. In addition, the 

unit has a SO2 federally enforceable permit limit. The B&W boiler also has a federally 

enforceable material throughput limit of 300,000 cubic feet per hour of fuel burned. The 

boiler has a low NOx burner and flue gas recirculation control system. The B&W boiler 

burns natural and process gases (see Figure 19). 
17

Figure 19. B&W Boiler Emissions for Marathon to Ambient PM2.5 at Dearborn Monitor 

Emissions to Ambient PM2.5 for B&W Boiler

0

1,000

2,000

3,000

4,000

5,000

6,000

7,000

8,000

9,000

2003 2004 2005 2006 2007 2008

Emissions (lbs)

0.00

5.00

10.00

15.00

20.00

25.00

PM2.5 (ug/m3)

so2 pm2.5 * ambient PM2.5

*PM2.5 emissions calculated based on throughput. 

Ford Motor Company - Rouge Complex

The Ford Motor Company Dearborn Assembly Plant is located on Miller Road in the city 

of Dearborn, part of the Rouge Industrial Complex. The facility is bounded by Rotunda 

Drive to the north, by Interstate 94 on the northwest, Schaefer Avenue to the west, the 

Rouge River to the south and Miller Road to the east. It is located less than one mile 

west of the Dearborn monitor. 

The Ford Dearborn Rouge Complex consists of four individual manufacturing plants that 

produce automobile and automobile components, as follows: an assembly plant that 

produces and paints vehicles, an engine and fuel tank manufacturing plant that produces 

automobile engines and metal fuel tanks, a stamping plant that stamps vehicle body 

panels and similar body parts for other vehicles, and a diversified manufacturing plant 

that electrocoats and manufactures vehicle frames. 

Ford operations at the Rouge complex have not experienced the economic downslide as 

have other Ford facilities. Series F-150 trucks are built in the complex and production 

levels have been relatively stable. See Figure 20 for production information for the four 

plants. Ford ceased foundry operations around 1981 in the closing of the Specialty 

Foundry. The steel-making operations located in the complex are currently owned by 

Severstal. 
18

Figure 20: Productions for the Ford Rouge Complex. 
19

Several emissions were combined under the RG-Paint reporting group, which has 

natural gas usage reported. RG-Paint reports the total natural gas combustion for the 

Dearborn Truck Plant paint shop building. The natural gas usage includes the paint 

shop space heating, booth air supply houses, hot water boilers, coating curing ovens 

and air emission abatement equipment (thermal oxidizers and carbon adsorption 

systems). In addition, the EU-NATGASSPACE emission unit includes all the natural gas 

used for space heating at the Dearborn Truck Plant outside of the paint shop (i.e., body 

and final assembly buildings). Several other EUs report natural gas usage as well. EUHEATERSFRAME includes the natural gas used for space heating the Dearborn 

Diversified Manufacturing Plant (DDMP, formally known as the Dearborn Frame Plant). 

EU-ECOATFRAME includes the natural gas used in the DDMP Ecoat curing oven. EUHEATERSENGINE includes the natural gas used for space heating the Dearborn 

Engine and Fuel Tank Plant. 

The old Dearborn Assembly Plant ceased operations in May 2004. A portion of the 

building was demolished in 2004/2005. The remaining building was decommissioned 

and put into a cold idle status (natural gas line was blanked) after the heating season in 

2005. Although there may have been other efficiency improvements, it appears the 

shutdown of the old Dearborn Assembly Plant was a significant portion of the decrease 

in natural gas usage (see Figure 21). 
20

Figure 21: Ford Rouge Complex natural gas usage. 

NOx emissions are generated from the combustion of natural gas (space heaters, air 

houses, ovens, thermal oxidizers) located at the Dearborn Truck Plant (paint and 

assembly), from natural gas combustion (space heaters and ovens) at the other 

manufacturing facilities and also from the gasoline combustion associated with engine 

dynamometer testing (EU-DYNOTEST) located at the Engine Plant. Generally any SOX

and PM2.5 emissions result from natural gas combustion and the gasoline combustion in 

the engine dynameters. In addition, there are PM2.5 emissions generated from the 

painting, body scuffing and machining operations located at Ford manufacturing facilities 

at the Rouge Complex. In addition to the natural gas, diesel fuel is used for emergency 

generators and fire pumps, gasoline is used in the engine testing dynamometers and 

propane is used for the mobile hi-los. 

There are three natural gas billing meters to account for all of the natural gas used by 

Severstal and Ford in the Rouge Complex. The facility indicates that the total natural 

gas usage allocated to the Ford facilities is a reasonable value. Building-specific usage 

rates are considered less reliable and provided to the company by Severstal for 

budgetary purposes. Similarly, the PM2.5 due to natural gas combustion will be less 

reliable on a building by building basis. 

Dearborn Industrial Generation (DIG) began providing steam to the facilities at the 

complex around August 2001. At that time, the temporary 250-MMBTU boilers, in use 

since the summer of 1999 as interim replacement for the Rouge Powerhouse, were idled 

in advance of being shutdown and removed. 

The facility fugitive dust plan indicates several areas are swept, flushed or treated to 

keep dust to a minimum. There are two road vacuum/sweepers. These two road 

sweepers are cleaned daily and sent to the mechanic shop for routine maintenance 

(grease, inspection, etc.) on a weekly basis. A consent order mentions bulk materials to 

address road salt stored in a dome and used to melt snow during the winter season and 

to address the occasional construction-related debris when temporarily stored on site 

while awaiting proper waste characterization just prior to being hauled offsite. At this 

time, the road salt is stored in a dome. There is no need for other enclosures as there 

are no other permanent material stockpiles. The newest Ford facilities in the Rouge 

Complex are those buildings associated with the Dearborn Truck Plant. The Paint shop 
21

became operational in late 2001. Operations in the new final assembly and body shop 

buildings began during 2004, replacing the former Dearborn Assembly Plant operations. 

Ford’s Installation of the green roof on the Dearborn Truck Plant Final Assembly building 

was completed in June 2003. There are no reports estimating any air emission 

reductions associated with the green roof. There have been some storm water benefits 

from the green roof. The MDEQ believes that the installation of a green roof (while not 

documented) impacts the reduction of NOx and possibly PM2.5 within the immediate 

area. 

Ford is upwind of the Dearborn monitor; however, its throughput does not correspond 

well with the ambient PM2.5 trends. The major emissions from Ford are VOCs (430 tons 

per year), which the MDEQ is not analyzing for controls in this SIP. Other pollutants 

such as NOx (>50 tons per year) and PM (>10 tons per year) are not as large as other 

facilities in the area, and therefore may have less affect on ambient PM2.5 in the 

Dearborn area. 

 

Dearborn Industrial Generation 

Dearborn Industrial Generation (DIG) is located directly east of Severstal Steel, less than 

one-quarter mile from the Dearborn monitor. DIG is a cogeneration unit that uses blast 

furnace gas from Severstal to produce electricity and also provides steam back to 

Severstal for their processes. The facility consists of three natural gas fired combustion 

turbines (one installed 1999, other two in 2001), three natural gas (NG) and blast 

furnace gas (BFG) fired boilers (all installed 2001), and two diesel fuel oil fired 

emergency generators (installed 2003). Two existing flares (previously owned and 

operated by Rouge/Severstal Steel Company and now owned by DIG, one installed 

1936 other in 1999) burn blast furnace gas if it cannot be utilized in the boilers. All three 

of the boilers are designed to fire a mixture of up to 95 percent BFG and five percent NG 

(by heat input) or 100 percent NG. The BFG is received from Severstal Steel as a 

byproduct of their iron and steel-making operations. 

The plant runs year around and use for each unit varies by quarter and year. There is 

no regular pattern of usage. The flares, boilers and all but one combustion turbine have 

stacks over 150 feet high. The one combustion turbine has a shorter stack at 60 feet. 

Emissions appear to mirror throughput in most cases (see 
22

Figure 22 through Figure 24). Emissions are determined by parametric emission 

monitors (PEMs), CEMs, stack tests or other. MAERS factors are rarely used to 

determine emissions. Boiler #2 for PM10 has lower emissions compared to throughput 

than the other boilers (see 
23

Figure 22). These numbers are based on stack test emissions. The NOx emissions for 

the boilers do not follow the throughput. These emissions are combined for natural gas 

and process gas usage. NOx emissions appear to decrease as process gas throughput 

increases. Therefore emissions to throughput will not correlate as well as other 

pollutants. These NOx emissions are based on CEMs or PEMs. 

Turbine #3 has lower emissions for PM10 compared to throughput than the other 

turbines (see Figure 23). All three turbines are equipped with low NOx burners. The 

emissions are based on stack test emissions. 
24

Figure 22. SO2, PM10 and NOx for Boilers at DIG 

SO2 Thruput to Emissions

0.00

20.00

40.00

60.00

80.00

100.00

120.00

140.00

160.00

180.00

200.00

2000 2001 2002 2003 2004 2005 2006 2007 2008

E m ission (tons)

0

10000

20000

30000

40000

50000

60000

Thruput (Million Ft3)

PM10 Thruput to Emissions

0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

40.00

45.00

20002001 20022003 20042005200620072008

Emissions (tons)

0

10000

20000

30000

40000

50000

60000

Thruput (Million Ft3)

NOx Thruput to Emissions 

0.00

5.00

10.00

15.00

20.00

25.00

30.00

35.00

40.00

45.00

2000 2001 2002 2003 2004 2005 2006 2007 2008

Em ission (tons)

0

10000

20000

30000

40000

50000

60000

Thruput (Million Ft3)

Boiler #1 Boiler #2 Boiler #3 Boiler #1 thruput Boiler #2 thruput Boiler #3 thruput

Figure 23. PM10 and NOx for Turbines at DIG 

PM10 Thruput to Emissions

0.00

5.00

10.00

15.00

20.00

25.00

2000 20012002 20032004200520062007 2008

Emission (tons)

0

1000

2000

3000

4000

5000

6000

7000

8000

Thruput (Million Ft3)

Turbine #1

Turbine #2

Turbine #3

Turbine #1

thruput

Turbine #2

thruput

Turbine #3

thruput

NOx Thruput to Emissions

0.00

20.00

40.00

60.00

80.00

100.00

120.00

140.00

200020012002200320042005200620072008

Emission (tons)

0

1000

2000

3000

4000

5000

6000

7000

8000

Thruput (Million Ft3)
25

Figure 24. SO2 and NOX for Flares at DIG 

SO2 Thruput to Emissions

0.00

50.00

100.00

150.00

200.00

250.00

300.00

350.00

400.00

450.00

2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

10000

20000

30000

40000

50000

60000

70000

80000

Thruput (Million Ft3)

Flare #1

Flare #2

Flare #1

thruput

Flare #2

thruput

NOx Thruput to Emissions

0.00

50.00

100.00

150.00

200.00

250.00

2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

10000

20000

30000

40000

50000

60000

70000

80000

Thruput (M illion Ft3)

Throughput for the boilers and flares at DIG was compared to throughput at the blast 

furnaces at Severstal (see Figure 25). For the initial year (2001-2004) the throughput 

does not align; however, for 2005-2008, throughput correlates for DIG and Severstal. 

The boilers and one flare were built in 2001. Since they were just starting up, they likely 

were not in full use until around 2005 where they start to correlate with Severstal’s 

emissions. 

Figure 25. Throughput Comparing DIG to Severstal 

Thruput for DIG and Severstal

0

10000

20000

30000

40000

50000

60000

70000

80000

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

thruput (million ft3)

0

500000

1000000

1500000

2000000

2500000

3000000

thruput (tons)

Boiler #1 process

gas (E6FT3)

Boiler #2 process

gas (E6FT3)

Boiler #3 process

gas (E6FT3)

Flare #1 (E6FT3)

Flare #2 (E6FT3)

B and C Blast

Furnace Cast

House (tons)
26

Ambient PM2.5 at Dearborn is decreasing similar to emissions at DIG after 2005, but 

earlier years do not correspond to PM2.5 ambient concentrations (see Figure 26). 

Figure 26. Throughput to ambient PM2.5 for DIG 

Thruput to Ambient PM2.5 at Dearborn

0

10000

20000

30000

40000

50000

60000

70000

80000

2000 2001 2002 2003 2004 2005 2006 2007 2008

Thruput (Millions Ft3)

0.00

5.00

10.00

15.00

20.00

25.00

Concentration (ug/m3)

Boiler #1 process gas

(E6FT3)

Boiler #2 process gas

(E6FT3)

Boiler #3 process gas

(E6FT3)

Flare #1 (E6FT3)

Flare #2 (E6FT3)

PM2.5 (ug/m3)

Cadillac Asphalt Products Corporation

The Cadillac Asphalt Products Corporation Plant 5A hot mix asphalt facility is located at 

670 S. Dix Avenue, Detroit, Michigan. The location is about one half mile south of the 

Ford Rouge Complex and 1.5 miles south-southwest of the Dearborn monitor. 

The facility operates a 525 tons-per-hour parallel flow hot mix asphalt (HMA) process. 

During a permit modification in 1999, the plant was limited to the use of natural gas and 

No. 2 fuel oil (where previously it had been allowed to use recycled oils). The maximum 

allowed production at the facility, based on a 12-month rolling period, is 940,000 tons per 

year, with a maximum hourly capacity of 525 tons per hour of HMA. The HMA 

production season in Michigan usually occurs early April through November, depending 

on weather conditions. 

Figure 27 and 28 indicate an increase in the natural gas throughput for 2003 and a 

significant decrease for asphalt throughputs for 2006 (which can be attributed to the 

beginning of the economic decline in Michigan). Other than 2006, the asphalt operations 

were fairly steady. This could imply that emissions from the facility are not reflected in 

the decreasing PM2.5 levels at the Dearborn monitor. 
27

Figure 27. Throughput of Natural Gas in Asphalt Heater 

Asphalt Heater Natural Gas Thruput

0.00

20.00

40.00

60.00

80.00

100.00

120.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Calendar Year

EFT3

Figure 28. Throughput of Hot Mix Asphalt Through Rotary Drum 

Hot Mix Asphalt through Rotary Drum 

0

100,000

200,000

300,000

400,000

500,000

2000

2001

2002

2003

2004

2006

2007

2008

Calendar Year

Tons

US Gypsum

The US Gypsum plant is located 2.5 miles southeast of the Dearborn monitor in River 

Rouge. This plant emits 50 tons or less of NOX and 100 tons or less of PM. 

Ninety percent of the plant’s production is gypsum wallboard. US Gypsum Company's 

exclusive registered trade name for its gypsum wallboard is Sheetrock. The plant also 

manufactures cement board, which is used as backing for tiled walls, such as 

bathrooms. 

The primary raw material used is gypsum, or calcium sulfate, which forms airborne 

particulate air pollution during the manufacturing process. The plant has a large number 

of baghouse type dust collectors to control these emissions.
28

US Gypsum has one stack for its mill rock dryer that is 122 feet tall. A second baghouse 

stack that is discharged inside a building is only 25 feet tall. US Gypsum operates year 

around, generally 4 to 6 days per week. 

Emissions reported in MAERS are based on MAERS emission factors or other factors. 

The NOx emissions and some PM emissions appear to closely follow the throughput 

values (see Figure 29 and Figure 30). The emissions do not correlate well with the 

ambient PM2.5 (see Figure 31). US Gypsum does mostly grinding of materials and does 

not incinerate, therefore, most of it emissions are likely in the PM10 fraction rather than 

the PM2.5 fraction. 

Figure 29. NOX Emissions to Throughput Comparison for 

US Gypsum 

Emissions to Thruput for NOx

0.00

10.00

20.00

30.00

40.00

50.00

60.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0.00

100.00

200.00

300.00

400.00

500.00

600.00

Thruput (million ft3)

NOX

Nox

Thruput

EU0085

Figure 30. PM10 Emissions to Throughput 

Comparison for US Gypsum 

Emissions to Thruput for PM10

0.00

20.00

40.00

60.00

80.00

100.00

120.00

19981999200020012002200320042005200620072008

Emissions (tons)

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

Thruput (tons)

PM10-PRI

PM10-FIL

PM-PRI

PM10 thruput

EU0051
29

Figure 31. Emissions to Ambient PM2.5 Concentrations 

for US Gypsum 

Emissions to Ambient PM2.5

0.00

20.00

40.00

60.00

80.00

100.00

120.00

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

5

10

15

20

25

PM2.5 (ug/m3)

NOX

PM10-FIL

PM10-PRI

PM-PRI

SO2

Ambient

PM2.5 

Carmeuse Lime/River Rouge

Carmeuse Lime in River Rouge is approximately 2.5 miles southeast from the Dearborn 

monitor. Another lime plant, Carmeuse/Detroit Lime was less than a mile from the 

Dearborn monitor; however, that plant closed down in 2003. 

Carmeuse Lime/River Rouge produces lime by the calcination of limestone. Limestone 

is calcinated in two horizontal rotary kilns. Limestone from the storage pile is transferred 

to the kilns through transfer stations and conveyors. The facility has two rotary kilns that 

may be operated simultaneously. The kilns are fired using pulverized coal and natural 

gas. The gases from the kilns are exhausted through two baghouses. 

Three baghouses collect emissions generated by the handling of lime (loadout and 

rescreen). Flue dust from the kilns is pneumatically conveyed to the flue dust tank 

where it is stored and loaded into trucks. The flue dust tank and loadout spout are 

controlled by a dust collector. 

Carmeuse Lime/River Rouge is a major emitter of NOx, SO2 and PM. Carmeuse has 

two baghouse stacks about 70 feet tall. This plant operates year around and uses 

mostly MAERS emission factors. The emissions generally follow the throughput of lime 

(see Figure 32). The emissions do not correlate well to the ambient data at Dearborn. 

This may be partially explained by the facility distance and direction from the Dearborn 

monitor (see Figure 33). 
30

Figure 32. Emissions to Throughput Comparison for 

Carmeuse Lime/River Rouge 

Thruput to Emissions

0

100

200

300

400

500

600

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

100000

200000

300000

400000

500000

600000

700000

Thruput (tons)

SO2

PM10

Nox

Lime

Thruput

Bit Coal

Thruput

Limestone

Thruput

Figure 33. Emissions to Ambient PM2.5 Concentrations 

for Carmeuse Lime/River Rouge 

Emissions to Ambient PM2.5

0

100

200

300

400

500

600

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

5

10

15

20

25

SO2

PM10

Nox

PM2.5 (ug/m3)

Detroit Wastewater Treatment Plant

The Detroit Wastewater Treatment Plant is located two miles southeast of the Dearborn 

monitor. The wastewater treatment plant collects and treats domestic and industrial 

wastewater from the Metro Detroit area. The treatment capacity of the plant is about two 

billion gallons per day. The treated wastewater is discharged to the Detroit River. The 

treatment involves removal of large solids using bar racks and grit chambers, primary 

and secondary biological treatment for the removal of suspended and dissolved solids, 

clarification, chlorination of water from secondary clarifiers, sludge dewatering, sludge 

incineration and ash disposal to a sanitary landfill. The treatment processes are 

significant sources of volatile organic compound emissions; however, the incineration of 

sludge from filtration is the major source of NOX, SO2, and PM. 

The facility has 14 sludge incinerators controlled by venturi and impingement tray 

scrubbers. The complex I incinerators (incinerators 1 through 6) were constructed in 

1940. The Installation permit (No. C-6657) covers Tall Stack #1 (254 ft tall) for Complex 

I Sewage Sludge Incinerator System serving Incinerators 1 through 6. The Complex II 
31

incinerators were constructed in 1970 and are covered by installation permits C-6649 

through C-6656 for incinerators 7 through 14 respectively. Installation permit (No. C6658) covers Tall Stack #II (254 ft tall) for Complex II sewage sludge incinerator system 

serving incinerators 7 through 10. Installation permit (No. C-6659) covers Tall Stack III 

(254 ft tall) for Complex II sludge incinerator system serving incinerators 11 through 14. 

Each incinerator has a flue (stack). These flues are enclosed within three tall stacks. 

The six flues for the incinerators Number 1-6 are enclosed in Tall Stack #1, flues for 

incinerators 7-10 are enclosed in the Tall Stack II and flues for incinerators 11-14 are 

enclosed in Tall Stack #III. For an observer, only three stacks are visible. 

Installation permits (No. C-6628 and C-6629) cover Sludge Mixer #1(East) and Sludge 

Mixer #1 (West) respectively. The sludge/lime mixing area is also covered by the 

installation permit (No. C-6629). Because sludge mixers are situated inside the lime pad 

area, EGLIMEPAD and the sludge mixers (EGSLUDGEMIXER1 and EGSLUDGE 

MIXER2) are combined into one emission unit. Installation permits (No. C-6630 through 

C-6635) cover Lime Storage Silos 1 through 6, which are controlled by a fabric filter 

baghouse. The sludge mixing facility is controlled by a fabric filter baghouse. Complex I 

and Complex II ash handling systems are controlled by fabric filters. 

The plant runs year around. Emissions are calculated using MAERS emission factors 

(see Figure 34) according to the MAERS inventory. While the SO2 and NOx correlate 

with the throughput, the PM does not. In 2005, MAERS emissions factors were reported 

to be used, but control efficiencies were added. 

Figure 34. Emissions to Throughput Comparison for DWTP 

Emission to Thruput

0

50

100

150

200

250

300

350

400

450

500

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

20000

40000

60000

80000

100000

120000

140000

160000

180000

200000

Thruput (tons)

NOX thruput (tons)

Emission to Thruput

0

20

40

60

80

100

120

140

160

180

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

20000

40000

60000

80000

100000

120000

140000

160000

180000

200000

Thruput (tons)

PM10-PRI PM10MITOT PM25-PRI PM-PRI SO2 thruput (tons)

Emissions to ambient data do not correlate well except for the later 3 to 4 years (see 
32

Figure 35). In general, this source’s location and controls may partially explain this. The 

plant has multiple controls for their incinerators, such as demisters, impingement plate 

scrubbers and venturi scrubbers that control 90-99 percent of PM emissions. 
33

Figure 35. Emissions to Ambient PM2.5 Concentrations for DWTP 

Emissions to Ambient PM2.5

0

5

10

15

20

25

30

35

40

45

50

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

5

10

15

20

25

PM2.5 (ug/m3)

PM10-PRI PM10MITOT PM25-PRI PM2.5 

Emissions to Ambient PM2.5

0

50

100

150

200

250

300

350

400

450

500

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

5

10

15

20

25

PM2.5 (ug/m3)

NOX SO2 PM2.5 

St. Mary’s Cement

St. Mary’s is a cement processing plant about 1.5 miles southeast of the Dearborn 

monitor. The plant has less than 10 tons per year emissions of NOX and SO2, and 

around 25-35 tons of PM10 per year. PM emissions are mainly from their grinding mills 

that have bag house control with 99.9 percent control efficiency of PM10. There are no 

emissions stacks indicated in MAERS and the majority of their activity occurs in the 

warmer months. The emissions do not match the throughput (see Figure 36) probably 

because the emission factors for PM have changed. Also, MAERS indicates the method 

used as “other,” but no other indication of how the emission factor is calculated is shown 

in MAERS. The emissions do not match the ambient PM2.5 (see Figure 37) although 

there is a slight trend downward for the last four years for both emissions and ambient 

data. The emissions from this source are not from combustion, but rather grinding, 

therefore, the size fraction will likely be greater than PM2.5, more in the PM10 size range. 

This source is not likely to affect the ambient PM2.5 in the Dearborn area for this reason. 

Figure 36. Emissions to Throughput Comparison 

for St. Mary’s 

Emissions to Thruput

0

5

10

15

20

25

30

35

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

Thruput (tons)

NOX 

PM10-FIL

PM10-PRI

PM-PRI

SO2

thruput
34

Figure 37. Emissions to Ambient PM2.5 Concentrations 

for St. Mary’s 

Emissions to Ambient PM2.5

0

5

10

15

20

25

30

35

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Emissions (tons)

0

5

10

15

20

25

PM2.5 (ug/m3)

NOX 

PM10-FIL

PM10-PRI

PM-PRI

SO2

PM2.5 

Edward C. Levy Co Plant 1

This company crushes and screens slag. It is located approximately one mile northeast 

of the Dearborn monitor. Most of their emissions are from hauling on paved and 

unpaved roads in the form of PM10. Since the operation is crushing, most of the PM is 

likely in the PM10 fraction, not PM2.5. This source likely has little effect of the ambient 

PM2.5 is the area. 

Darling International, Inc.

The facility is a rendering operation located at 3350 Greenfield Road, Melvindale, Wayne 

County, Michigan. It is approximately two miles southwest of the Dearborn monitor. 

This facility has two permits, one for the three boilers in operation at the site and the 

other permit covers processing operations. As of 2004, to address numerous odor 

complaints, the facility does not “render” animal carcasses at this location. All carcasses 

are packaged and sent to another location (Coldwater, Michigan) for processing. 

Rendering is a process that converts waste animal tissue into stable, value-added 

materials. Rendering can refer to any processing of animal byproducts into more useful 

materials, or more narrowly to the rendering of whole animal fatty tissue into purified fats 

like lard or tallow. The majority of tissue processed comes from slaughterhouses, but 

also includes restaurant grease and butcher shop trimmings. This material can include 

the fatty tissue, bones, and offal, as well as entire carcasses of animals condemned at 

slaughterhouses, and those that have died on farms. 

However, the facility continues to process grease and oils taken in from local 

restaurants. This includes cooking off the water and filtering any solids remaining in the 

grease. 

Power Plants

Detroit Edison has two power plants in the area. One plant has very tall stacks (>350 ft) 

and likely doesn’t significantly affect the Dearborn monitor. The other plant has natural 

gas fired combustion turbines that operate only during peak demand. This source has 

low emissions and may not be impacting the Dearborn monitor significantly. 
35

Small Sources

Several sources have minimal emissions (less than 5 tons) and were not evaluated. 

These sources include Xcel Steel Pickling, Ford Motor New Model Program, Automotive 

Components Holding; Envirosolids LLC, City of Dearborn, Detroit Salt, Hinkle MFG LLC, 

and DTE Energy/Ford World Headquarters. 

VOC Sources

Several sources emit primarily VOCs, such as Fabricon Products, Inc.; Buckeye 

Terminals LLC; Sunoco Partners M&T; LP (River Rouge Terminal); and Magni 

Industries, Inc. Since the EPA and DEQ did not find that VOCs should be evaluated for 

possible controls, these sources were not further evaluated. 

Sources Out of Business Near the Dearborn Monitor

Several sources that were located near the Dearborn Monitor have ceased operations. 

These include, M-Lok (aka Riley Plating), Spartan Industrial, Great Lakes Petroleum 

Terminal (Owens Corning), Ferrous Environmental, Ford Motor Clay Mine and 

Honeywell Industries (aka Allied Signal and Detroit Tar). Of the four sources indicated 

above, only Honeywell had significant particulate (PM2.5), oxides of nitrogen (NOX) and 

oxides of sulfur (SOX) emissions. The Ford Motor Clay Mine had high particulate 

emissions due to truck traffic. The remaining two sources emitted VOCs through coating 

operations. 

Honeywell

Honeywell (SRN B5558) is located 2.5 miles southeast of the Dearborn monitor, just 

north of Zug Island (US Steel). Honeywell ceased operations in 2005, with some minor 

emissions for volatile organic compounds as the storage tanks were emptied completely. 

The source permits were voided in calendar year 2005. The facility had boiler and 

process heater material throughputs of more than 24,801,449 million gallons in 1998 

reducing to approximately 533 thousand gallons in 2004. AQD staff believes the data 

submitted in 1998 was reported erroneously, (i.e., may have been in gallons only) so 

data is not included in the review. Therefore the material throughput value for the boiler 

and process heaters in 1999 were approximately 2,200 million gallons of fuel oil. Please 

note the facility did have a coal fired boiler; however, this boiler was not in operation 

during the time frame under discussion. 

The NOX emissions decreased from 57 tons per year in 1999 to 1.3 tons in 2004 with 

zero emissions reported in 2005. The SOX emissions decreased from 105 tons per year 

in 1999 to 25.2 tons in 2004 and again no emissions reported for 2005. The PM2.5

emissions were reported from 2003 and 2004 and calculated using an emissions factor 

based on those year’s submittals of 2.5 pounds PM2.5 per material throughput. The 

PM2.5 emissions were calculated for 1999 as 2.8 tons and reported at 1.4 tons in 2004 

(see Figure 38 and Figure 39). 
36

Figure 38. Honeywell Emissions 

Honeywell Emissions

0

10

20

30

40

50

60

70

80

90

100

1999 2000 2001 2002 2003 2004 2005

Calendar years

Tons

Nox Emissions Sox Emissions PM 2.5 Emissions

Figure 39. Material Throughput for Honeywell 

Material Thruput Thousand Gallons

0

500

1,000

1,500

2,000

2,500

1999 2000 2001 2002 2003 2004 2005

Great Lakes Petroleum (Owens Corning)

This company was located about 1.5 miles south-southeast of the Dearborn monitor. It 

produced asphalt, was a small source of NOX (< 30 tons per year), PM (< 20 tons per 

year) and emitted 30-70 tons of SO2 (see Figure 40). Owens Corning shut down their 

Detroit Plant on January 1, 2008. The company has had their ROP voided and will have 

their PTIs voided, as well. 
37

Figure 40. Emissions from Owens Corning 

Owens Corning Emissions

0

10

20

30

40

50

60

70

80

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007

Emissions (tons)

NOX

PM10-PRI

PM25-PRI

SO2
Appendix E 

Impact of Southeast Michigan’s New Economic 

Reality on Regional Pollutant Emissions 

Provided by SEMCOG 
2

The Impact of Southeast Michigan’s New Economic Reality 

on Regional Pollutant Emissions 

While substantial emission reductions have been achieved through implementation of local and 

national controls included in the PM2.5 State Implementation Plan for Southeast Michigan, 

significant additional reductions have occurred as a result of the economic transformation that has 

taken place in the region. 

Since 2000, Southeast Michigan has lost over 116,000 people and 400,000 jobs. The recent loss of 

jobs is almost entirely due to the permanent downsizing of the American auto industry and the 

overall decline of the manufacturing sector. Since the early 1900s, manufacturing had been the 

predominant source of jobs in Michigan. However, this has changed significantly over the past 

decade. Between 2002 and 2007, the state lost nearly 404,000 auto-related jobs, while gaining just 

over 200,000 jobs in non-manufacturing sectors (Figure 1). 

 

Figure 1 

Growing and declining industries in Michigan, 2002-2007 

Source: U.S. Bureau of Labor Statistics, Don Grimes 

There is national recognition that the American auto industry and the manufacturing sector as a 

whole, will never return to its prerecession size and that future jobs in the region will need to come 

from other sectors. Indeed, this transition is already taking place. By the end of 2007, the number of 

health care jobs in Southeast Michigan had actually surpassed the number in manufacturing 

(Figure 2). 
3

Figure 2 

Employment is shifting to less polluting sectors 

Manufacturing vs. health care jobs, Southeast Michigan, 2000-2009

Source: SEMCOG analysis of Michigan Labor Market Information data 

The transition away from manufacturing to a more service and retail based economy has resulted in 

lower utility consumption. Figures 3, 4 and 5 show the decline in natural gas, electricity and water 

use over the past decade. Lower utility use means lower pollutant emissions from these sources. 

Figure 3 Figure 4 

The region is consuming less natural gas The region is also consuming less electricity 

Consumers Energy gas deliveries DTE electricity deliveries

Source: Consumers Energy Source: DTE Energy 
4

Figure 5 

Water use is also declining 

Average daily water use, Detroit Water and Sewerage Department 

Source: The Foster Group 

In addition to the reduction in manufacturing activity and the resulting decline in stationary source 

pollution, Southeast Michigan has also experienced a significant decrease in vehicle miles of travel 

(VMT). Since 2002, VMT has declined 13 percent. As would be expected, this decrease has closely 

mirrored the decline in regional employment (Figure 6). 

Figure 6 

As jobs have declined, so has travel 

Changes in Southeast Michigan employment and travel, 2002-2009 

Source: SEMCOG and U.S. Bureau of Economic Analysis 
5

It is important to understand that these economic changes are not a temporary artifact of the current 

nation-wide recession. As noted earlier, the changes in Southeast Michigan began long before 2008. 

Employment has been dropping since 2000 and population, which had shown little growth over the 

last 40 years, began to decline in 2006. 

Furthermore, the latest demographic forecasts for the region do not predict much change in this 

trend for the foreseeable future The latest forecast from the Southeast Michigan Council of 

Governments (SEMCOG) shows that by 2035 the region will still have 196,000 fewer people and 

213,000 fewer jobs than it had in 2000 (Figures 7 and 8). 

Figure 7 

Southeast Michigan will have 196,000 fewer people in 35 years 

Actual and projected population, 2001-2035

Source: SEMCOG 

Figure 8 

Southeast Michigan will have 213,000 fewer jobs in 35 years 

Actual and projected employment, 2000-2035

Source: SEMCOG 
6

As previously shown, the amount of travel in the region is closely tied to the amount of 

employment. Thus, fewer jobs in the future will also mean less vehicle miles of travel. This 

reduction, on top of the already expected pollutant decrease from fleet turnover, means on-road 

mobile source emissions will continue to decline significantly in the future. 

The above weight of evidence, coupled with the dramatic decrease in monitored PM2.5 

concentrations in the region, clearly indicates that significant and permanent emission reductions 

have occurred in Southeast Michigan and will remain for the foreseeable future. 
Appendix F 

Public Hearing and Comments 
2

Calendar Notice of Public Comment Period and Public Hearing
3
4
5

Response to Comments

Comment: Several commenters stated the local targeted reductions as well as regional and 

federal programs including sulfur in fuel limits, acid rain provisions, NOX SIP call, Clean Air 

Interstate Rule and its replacement rule and fleet turnovers, helped reduce PM2.5 in the 

nonattainment area. 

Response: MDEQ agrees with these comments. Thank you for your support.

Comment: Several commenters recognized the research effort and analysis to develop the 

state implementation plan (SIP) and correctly identify the sources contributing to the PM2.5

problem. 

Response: MDEQ agrees with these comments. Thank you for your support.

Comment: Several commenters encourage the MDEQ to recognize the progress in improving 

air quality and it should be recognized by an attainment designation.

Response: MDEQ agrees with these comments. Thank you for your support.

Comment: Several commenters indicated that EPA is looking to tighten the PM2.5 standard, 

thus MDEQ should not attempt to redesignate the area to attainment.

Response: Unless EPA revokes the current standards, Michigan still must show that all areas 

are attaining the current standards, regardless of whether EPA changes the standard in the 

future. Furthermore, MDEQ was recently told by senior EPA program staff that there is no 

current estimate when new PM2.5 standards will be proposed. This uncertainty is another 

reason to move forward with redesignation to attainment. 

Comment: Several commenters indicated the economic downturn in Michigan as the reason 

the 7-county area reached attainment. For this reason, the cause of the lower monitored PM2.5

is not permanent or enforceable. When the economy improves, emissions will increase and the 

area may fall back into nonattainment.

Response: MDEQ acknowledges that there has been an economic downturn, but believes that 

permanent and enforceable emissions reductions have occurred beyond the downturn to bring 

the area into attainment. Reductions from federal control programs for the on-road mobile 

sector, acid rain program, NOX SIP call, local stationary source controls, and permanent closure 

of facilities (permit withdrawn) are permanent and enforceable. These emission reductions are 

significant, and the reduction in PM2.5 levels can reasonably be attributed to these emission 

reductions. 

Also, the maintenance plan which is part of this redesignation proposal clearly demonstrates 

that future year emissions will remain below those of the 2008 attainment year. The 

demonstration uses a variety of estimates to project future emissions based on growth 

estimates for the various categories of sources that make up the emissions inventory. The 

maintenance plan also includes a list of contingency measures. Contingency measures are a 

menu of additional controls from which to choose further emissions reductions in the event an 

area violates the National Ambient Air Quality Standards (NAAQS). 

Furthermore, economic projections from the Southeast Michigan Council of Governments 

(SEMCOG) (see Appendix E) indicates that many of the manufacturing jobs in southeast 

Michigan are gone permanently, and MDEQ cannot assume that emission levels will return to 

pre-recession levels. An excerpt from the SEMCOG projections follows: 
6

“The recent loss of jobs is almost entirely due to the permanent downsizing of the 

American auto industry and the overall decline of the manufacturing sector. . . 

Between 2002 and 2007, the state lost nearly 404,000 auto-related jobs, while 

gaining just over 200,000 jobs in non-manufacturing sectors. . . There is national 

recognition that the American auto industry and the manufacturing sector as a whole, 

will never return to its prerecession size and that future jobs in the region will need to 

come from other sectors. . . The transition away from manufacturing to a more 

service and retail based economy has resulted in lower utility consumption . . .[and] 

decline in stationary source pollution.” 

Comment: Consumers Energy and BASF commented that continued success in attaining air 

quality standards is essential to the health and economic revitalization and competiveness of 

our state. 

Response: MDEQ agrees with these comments and continues to implement programs to attain 

and maintain the NAAQS. 

Comment: Several commenters stated that PM2.5 has many health effects including 

cardiovascular disease in post-menopausal women, premature mortality, heart attacks, strokes, 

cardiovascular hospital admissions, respiratory hospital admissions, asthma emergency room 

visits, asthma exacerbations and chronic bronchitis. Added to that is a lack of health insurance 

and medical facilities. These all add to a greater concern of the issue of PM2.5 emissions and 

the health implication of redesignating. Such a move will prove to be a detriment to vulnerable 

groups. 

Response: MDEQ acknowledges that serious health issues can be attributed to PM2.5 at levels 

above the NAAQS and has made attainment of the NAAQS a priority. In setting the 1997 

annual PM2.5 NAAQS and the 2006 daily NAAQS, EPA believed, based on all available data, 

that the standards were protective of human health. Now that the air quality in the 7-county 

area is meeting these levels, the area should be designated attainment as provided for in the 

Clean Air Act (CAA). Part of the CAA requirements for an area to qualify for redesignation is the 

development of a maintenance plan that projects that the area will remain in attainment of the 

standard for at least 10 years. MDEQ makes this demonstration in this redesignation proposal. 

MDEQ also will continue monitoring PM2.5 levels in the area and will continue requiring permits 

for new or modified sources in the area to demonstrate that any emissions of PM2.5 from these 

sources are to be within legal levels.

Comment: The Michigan Environmental Council (MEC) commented that their primary concern 

with the redesignation is that it does not account for the downturn in the economy, and they use 

electric generation data to make their point. They point out that the MDEQ data shows an 

increase in electric generation unit (EGU) emissions for the years 2005 to 2008 but that the 

department uses data from 2007 to 2010 to demonstrate attainment of the standard. MEC also 

stated that electric energy usage was lower in 2007-2009, but then increased in 2010 by 6.1 

percent and is expected to increase by another 2.3 percent in 2011 according to the Public 

Service Commission. Since MDEQ used 2007-2010 to demonstrate attainment, it did not take 

into account the current increases in electrical demand.

Response: MDEQ did take into account EGU activity and emissions for the years described in 

the MEC comments through 2010 in developing the redesignation request. The fact that actual 

emissions from EGUs in southeast Michigan increased during the years leading to attainment of 

the standard simply shows that other sources are responsible for the drop in emissions in the 

area of the Dearborn monitor, traditionally the monitor with the highest PM2.5 levels. If the 

energy usage increased by 6.1 percent statewide in 2010, it is not reflected in the monitored 

values for 2010, which were the lowest recorded for all monitors in southeast Michigan. 
7

Further, the maintenance plan in this redesignation plan accounts for all emissions in the area 

and demonstrates that total emissions will continue to decrease into the future years, through 

2022. The maintenance plan emission projections are based on the best estimates available of 

growth in the area. It also should be noted that DTE Energy stated they began reducing 

emissions at the Monroe power plant, the largest EGU source in the state, starting in 2010 (see 

statement from Michael Lebeis below). Other EGUs will likely install additional controls to 

address EPA’s proposed Transport Rule in the next several years. These additional EGU 

controls were not taken into account in the 2008 and future emissions inventories of this 

designation request. 

Comment: Several groups requested an extension of the comment period.

Response: The notice of the public comment period along with an opportunity to request a 

public hearing were posted in the MDEQ calendar on April 25, 2011 for a 30-day comment 

period, which ended on May 25, 2011. A public hearing was requested on May 20 and was 

held on May 26, 2011. MDEQ believes that there was adequate time during the 30-day 

comment period for interested parties to provide comments and does not believe that an 

extension of the comment period is warranted. 

Comment: Clean Water Action commented that it is likely when there is an upswing in the 

economy; monitors such as Allen Park that is currently at 14.6 micrograms per cubic meter 

(ug/m3

) could be expected to exceed the current standard again and therefore should not be 

designated as in attainment. 

Response: The current monitored design value for Allen Park for 2008-2010 is 11.0 ug/m3

, well 

below the standard. This monitor has been showing attainment since 2006. MDEQ believes 

that the maintenance plan in this redesignation plan does adequately address any upswing in 

the economy through 2022 and predicts that the entire redesignation area will remain in 

attainment. 

Comment: Clean Water Action commented that in Dearborn, which is nearest to 

nonattainment, it looks like daily values are below the NAAQS, only in the most recent previous 

three years, which shifted in one year. This is evidence that the changes in air quality are not 

permanent. 

Response: MDEQ believes these changes are due to permanent and enforceable permitted 

controls that were installed near the Dearborn monitor. Controls were installed and began 

operation in the late summer of 2007 at the steel mill near that monitor. The annual average at 

the Dearborn monitor dropped from 16.89 in 2007 to 13.34 ug/m3

 in 2008. The monitored 

values at Dearborn have continued to be as low or lower for 2009 and 2010 since the controls 

were added at the steel mill. Further, as stated in previous responses, the maintenance plan 

demonstrates continued emission reductions through 2022.

Comment: Clean Water Action commented that the state has not yet performed a diesel 

hotspot analysis, and they are not entirely confident that these monitors have been correctly 

located to best represent the potential danger zones from fine particulate emissions.

Response: MDEQ is uncertain what a diesel hotspot analysis is. However, two of the monitors 

in Wayne County, Newberry and FIA-Lafayette Street were installed using a community air 

toxics grant from EPA to specifically address diesel issues. Newberry was installed to monitor 

near the proposed Detroit Intermodal Freight Terminal and FIA-Lafayette was installed to 

monitor the Ambassador Bridge Traffic. Both Newberry and FIA-Lafayette Street monitors are 

below the annual standard at 10.7 and 11.0 ug/m3

, respectively and below the daily standard at 

29 and 30 ug/m3

, respectively.
8

Comment: Clean Water Action commented that no safe threshold for PM2.5 exposure has been 

determined. So since PM from diesel emissions is particularly deadly and spikes in exposure 

are not represented by the averaging of monitoring data, this needs to be considered as the 

state seeks redesignation status.

Response: The current NAAQS standards for PM2.5 are intended to be protective of public 

health. When air monitors show that a nonattainment area is meeting these standards, the CAA 

provides for the mechanism of redesignation to reflect that the air meets the standards. MDEQ 

is following this path and believes it is the appropriate action. MDEQ agrees that diesel 

emissions are a source of concern and encourages further study of emissions and impacts on 

public health. 

Comment: Clean Water Action commented that EPA is expected to soon tighten the standards 

for PM2.5. The PM2.5 standards are expected to be 13 ug/m3

 averaged over three years or 

lower. If the monitoring data reflected in the 2008-2010 average remains the same, then the 

Allen Park and Dearborn monitors show levels that would be back in nonattainment. However, 

there is the possible standard of 12 and that would put Ypsilanti, Allen Park, SWHS, Dearborn, 

and FIA-Lafayette Street out of compliance. 

Response: Based on the 2008-2010 3-year averages, the highest monitor, Dearborn, is 

showing 12.2 ug/m3

. The remaining monitors are showing 11.5 ug/m3 or less. Furthermore, 

unless EPA revokes the current standard, Michigan still must show that they are attaining the 

current standards, regardless of whether EPA changes the standard in the future. Recent 

information presented by EPA officials suggests that new PM2.5 standards will not be proposed 

in the near future. 

Comment: Two commenters from the Sierra Club commented that “diesel emissions may be a 

significant risk driver in the context of the total cancer risks estimated in this [DATI] report for the 

other Detroit area air toxics.” (MDEQ DATI Report, 2010). They go on to say that it raises a 

number of concerns about whether these levels would actually be adequate to protect public 

health. It is important that the MDEQ consider the existing international trucking traffic in this 

area and the projected truck traffic from the proposed bridge, which was not considered here. 

Diesel pollution should be considered because of traffic going to and from the Ambassador 

Bridge, and any new bridge to come. 

Response: MDEQ has accounted for truck traffic in the area. Emissions from Ambassador 

Bridge traffic, both now and in the future, are included in the on-road emissions inventory 

SEMCOG prepared for the PM2.5 redesignation request. Current and expected future travel 

across the bridge is included in SEMCOG’s travel demand model, which produces the vehicle 

miles of travel that are input to the MOVES emissions model to calculate on-road emissions. 

Regarding levels of PM2.5, as pointed out in a previous response in this document, the monitor 

near the Ambassador Bridge, FIA-Lafayette Street, is showing attainment for the annual PM2.5

standard at 11.0 ug/m3

 for 2008-2010, well below the NAAQS. 

Comment: DTE Energy commented that the 2005, 2008 and future year inventories used in 

this redesignation request does not accurately portray emissions at the Monroe Power Plant. 

The selective catalytic reduction (SCR) controls were not used year-round until 2009. In 2010, 

SO2 emissions dropped by over 50,000 tons due to operation of flue gas desulfurization (FGDs) 

controls, and the projected inventory between 2008 and 2018 only predicted a total drop of 

28,000 tons. In addition, DTE intends to add FGDs on the remaining two units and an SCR on 

the remaining unit by 2014. Since DTE went through the process of permitting, these 

reductions are enforceable and permanent. 

Response: These additional reductions, beyond what is calculated in the emissions inventory, 

will help to ensure that the area remains in attainment of the standard.
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Public Hearing Record

A public hearing was held on May 26, 2011 as requested. Attending the meeting were G. 

Vinson Hellwig, representing MDEQ Director Dan Wyant, who is the decision-maker; Craig 

Fitzner, the hearing officer; and Teresa Cooper, Robert Irvine, Cindy Hodges, Mary Maupin, 

Amy Robinson and Robert Rusch from the MDEQ. Public statements were made by James 

Clift from the Michigan Environmental Council, Susan Harley from Clean Water Action, Anne 

Woiwode representing Sierra Club, and Michael Lebeis from DTE Energy. Also attending were 

Scott Sinkwitts and Kate Ross from CMS Energy, Kurt Kissling from Pepper-Hamilton Law Firm, 

and Kristin Jabin from the Michigan Clean Cities. The following are statements from the public 

hearing. 

Hearing Officer’s Statement 

Department of Environmental Quality 

Opening Statement 

By: Craig Fitzner, Hearings Officer 

May 26, 2011 

Introduction 

Good afternoon. My name is Craig Fitzner, and I am the supervisor of air monitoring unit in the 

Air Quality Division of the Michigan Department of Environmental Quality. I will be serving as 

the Hearing Officer for this public hearing on the request for redesignation of southeast 

Michigan, to attainment status for both the annual and 24-hour PM2.5 NAAQS. 

With me today are other MDEQ staff who will be assisting with this hearing. Seated with me are 

Cindy Hodges of the Strategy Development Unit, and Vince Hellwig, Chief of the Air Quality 

Division, who is the decision-maker for this redesignation request. 

 

Hearing Agenda 

To describe how this is going to work today, I will begin with some background information as to 

why we are here today. I will then describe the purpose of this formal hearing and how your 

comments will be used. Following that, I will outline the procedures under which we will take 

your comments and then describe what will happen after today’s hearing. It will then be your 

time to provide comments, and we will spend the majority of time today listening to those 

comments. At the end of the hearing, I will provide a short summary and closing. 

Background Information 

By way of background information, the Air Quality Division is responsible for protecting 

Michigan’s air resources. The law governing those responsibilities is Part 5502 of the 1994 

Natural Resources and Environmental Protection Act, Public Act 451, as amended. We are 

here today for a public hearing on the MDEQ’s request to EPA to redesignate seven counties in 

southeast Michigan to attainment status for the annual and 24-hour fine particulate matter 

standards. 

I will now ask Cindy Hodges to summarize the redesignation request. 
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Purpose of Public Hearing 

To fulfill EPA requirements in the redesignation process, the MDEQ must provide a 30-day 

comment period and the opportunity to request a public hearing in accordance with Section 110 

(a) (2) of the Clean Air Act. 

The purpose of today’s hearing is to give anyone interested in the redesignation request an 

opportunity to provide input. The MDEQ will consider any comments received in completing the 

redesignation request. 

Procedures 

Notice of this hearing was published in the MDEQ calendar and on other MDEQ web pages. 

As you came in this afternoon, you were given an opportunity to fill out a public comment card. 

We request that everybody fill out a card and indicate if you wish to make comments. We will 

use these cards to maintain a record of people interested in the redesignation request and to 

call upon those who want to make a statement today. To ensure that the hearing is conducted 

in a fair manner, we will follow these steps: 

1. I will call on those who have indicated on the cards that they would like to speak in the 

general order in which the cards were turned in. When all the cards have been 

completed, I will ask if anyone else would like to make a statement. 

2. When your name is called, please come to the front of the room, face me, and make your 

statement. If you have written comments or materials you would like to present, please 

hand them to me as you come to the microphone. As you begin your comments, please 

state your name and any group or association you may represent. 

How the Information Will be Used 

This hearing is being recorded and your comments will be a part of the information the MDEQ 

will considered in making its decision on this redesignation request. The public comment period 

for the redesignation request ended May 25, 2011, but comments from this hearing will be 

accepted as well. Additional information can be submitted until then and will also be considered 

when the MDEQ completes the redesignation request. 

Following the public hearing, the MDEQ staff will review all comments and include them in the 

redesignation request document including the response to those comments. A copy of the 

redesignation request including comments will be available on the MDEQ website. These 

comments will be sent to EPA as part of our redesignation request. Once EPA has determined 

that the redesignation request is complete, EPA has up to 18 months to propose approval or 

disapproval of the redesignation request. EPA’s proposal and final determination will be 

published in the federal register. 

Thank you for your attention. I will now begin calling the names of those who have indicated 

they would like to make a statement.

Closing Statement 

Thank you for your comments and cooperation today. We appreciate your interest in the 

redesignation request and that you took the time to be here today. 

The hearing is now closed. Thank you again. 

Closing time – 4 pm 
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Staff Background Information Statement 

Michigan Department of Environmental Quality 

Air Quality Division 

Request to Redesignate to Attainment Status 

For Both the Annual and 24-Hour PM2.5 NAAQS 

May 26, 2011 

By Cindy Hodges 

The State of Michigan, through the Michigan Department of Environmental Quality, is asking the 

U.S. Environmental Protection Agency to make a determination that southeast Michigan is in 

attainment with the annual and daily Fine Particulate Matter (PM2.5) National Ambient Air Quality 

Standards (NAAQS) and to approve the maintenance plan as a revision to the Michigan State 

Implementation Plan. The seven counties in the southeast Michigan PM2.5 nonattainment area 

are Livingston, Macomb, Monroe, Oakland, St. Clair, Washtenaw, and Wayne. 

The EPA established the annual and daily NAAQS for fine particulate matter in 1997 and 

revised them in 2006. EPA determined that the seven counties should be designated as 

nonattainment for the annual standard in 2005 and for the daily standard in 2009. The 

designations were based on design values derived from air quality monitoring data. Annual 

averages over 15 micrograms per cubic meter (μg/m3

) and daily averages over 35 μg/m3 were 

considered to be violating the standard. The EPA designated seven counties in Michigan as 

nonattainment for the annual standard, because monitored design values exceeded these limits. 

The MDEQ submitted a State Implementation Plan to EPA in June 2008 demonstrating that 

both local and regional control programs would bring about reductions in PM2.5 levels in the 7-

county nonattainment area such that the area would be expected to attain the NAAQS by 2010. 

 

Air quality monitoring data collected in the 2007-2010 period has confirmed that the 7-county 

southeast Michigan area is attaining the PM2.5 annual and daily standards. The most recent 3-

year average of the ambient annual concentration is 12.2 ug/m3

, which is below the annual 

standard of 15.0 ug/m3

. The most recent 3-year average of the daily ambient concentration is 

32 ug/m3

, which is below the daily standard of 35 ug/m3. 

The components of the redesignation package include: 

• A determination that the area has attained the standard; based on monitoring data, 

emissions inventory reductions and additional supporting evidence; 

• An approved State Implementation Plan for the area; 

• A determination that the improvement in air quality is due to permanent and enforceable 

reductions in emissions; 

• A fully approved maintenance plan that includes contingency measures; and 

• A determination that all Section 110 and Part D requirements, including monitoring, 

reporting, and permitting under the Clean Air Act have been met. 

The redesignation document summarizes compliance with each required component of the 

attainment redesignation providing a demonstration to EPA that the 7-county area should be 

redesignated to attainment of the annual and daily PM2.5 NAAQS. 
12

Transcription of Citizens’ Statements 

TRANSCRIPT OF COMMENTS FROM ATTENDEES 

AT A PUBLIC HEARING ON MDEQ’s 

PM2.5 REDESIGNATION REQUEST TO EPA 

AIR QUALITY DIVISION, MDEQ 

MAY 26, 2011 

James Clift, Michigan Environmental Council

My name is James Clift, I’m the policy director for the Michigan Environmental Council, we are 

an umbrella group of environmental, public health, conservation groups located across the 

state. 

We think the redesignation of the seven counties in the southeast Michigan area is premature 

and not in the best interest of the residents of Michigan. The main reason we think so is that we 

think that the data we’re seeing today is not permanent and enforceable, we think it is a 

reflection of the economic downturn that Michigan has experienced, and we are concerned that 

when our economy recovers, the data will not keep us below the current standards. 

We noted that in the data that the decision is based on, we did have an increase from our 

electric generating units in the period of 2005 to 2008, but we show the data, when you’re 

looking at the data from the 2007 to 2010 framework, shows a significant decrease in the 

utilization of these facilities by our utilities; DTE the largest utility in southeast Michigan, 

dropping down to basically 1998 levels of electricity demand. Since that time, we’ve got our 

public service commission talking about a 2.3% increase in demand in 2011, which followed a 

6.1% increase in use in 2010. We also have presented documentation from CMS Energy that 

talks about a 6% decline in the period of 2007 to 2009, but that they expect a 4% increase in the 

2010 to 2011 period. 

We couple that with the fact that we think there are significant health impacts that we are 

experiencing under our current particulate matter pollution standards. Those involve premature 

immortality, cardiovascular hospital admissions, respiratory hospital admissions, and asthma 

emergency visits. We think that Michigan has avoidable health impacts in this area of over one 

billion dollars per year if we continue to focus on this area of particulate matter pollution and try 

to reduce it. 

Therefore we think that it’s in the best interest of Michigan actually to keep vigilant in reducing 

this particulate matter pollution in Michigan, reduce those health care costs, and we don’t see 

the redesignation as being helpful in continuing that focus. I appreciate this opportunity to 

comment. Thank you. 

(Mr. Clift’s letter was submitted in support of his comment). 
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Susan Harley, Clean Water Action

Thank you so much for holding this hearing and allowing us the opportunity to comment on the 

MDEQ’s request for redesignation by the EPA of our current 7-county nonattainment status for 

fine particulates. My name is Susan Harley, I’m the Michigan Policy Director for Clean Water 

Action. We have over 250,000 members in the state. 

First off, I’d like to say that because of the extremely short timeline given regarding the 

announcement of this public hearing, we would request an extension of the public comment 

period so that a more thorough analysis can be done of the data presented by the State. 

Clean Water Action coordinates the Michigan Diesel Cleanup Campaign and also participates in 

the Clean Energy Now Coalition that is working to reduce coal plant pollution in the state and 

transition Michigan to a clean energy economy. 

Fine particulate pose a grave danger to human health, including causing premature death, heart 

attacks and strokes, as well as exasperating existing cardiovascular and respiratory issues such 

as asthma. I would like to submit to you this study outlining the particular danger from PM2.5

that is due to diesel emissions. Whereas it does appear that air monitors are at the moment in 

compliance with current annual and 24-hour standards for PM2.5, we do not believe that the 

state has proven under the weigh of evidence that these changes are permanent and due to 

sustainable reductions in air pollutants. 

It is likely when there is an upswing in the economy; monitors such as Allen Park that is 

currently at 14.6 micrograms per cubic meter could be expected to exceed the current standard 

again and therefore should not be designated as in attainment. Also in Dearborn, which is 

nearest to nonattainment, it looks like daily values are below the NAAQS, only in the most 

recent previous three years, which shifted in one year. This is evidence that the changes in air 

quality are not permanent. Moreover, since the state has not yet done a diesel hotspot analysis, 

we are not entirely confident that these monitors have been correctly located to best represent 

the potential danger zones from fine particulate emissions. In addition, no safe threshold for 

PM2.5 exposure has been determined. So since PM from diesel emissions is particularly deadly 

and spikes in exposure are not represented by the averaging of monitoring data, this needs to 

be considered as the state seeks redesignation status. 

Lastly, the EPA is expected to soon tighten - again - the standards for PM2.5. The PM standards 

coming down the pike are expected to be 13 micrograms per cubic meter averaged over three 

years. Or lower, if the monitoring data reflected in the 2008-2010 average remains the same, 

then the following monitors show levels that would be back in nonattainment. If the standard 

coming from the EPA is 13, Allen Park and Dearborn would be out of attainment status. 

However, there is the possible standard of 12 and that would put Ypsilanti, Allen Park, SWHS, 

Dearborn, and FIA-Lafayette Street out of compliance. 

For these and for other reasons, we believe it is not in the best interest of the state’s residents 

to move forward at this time with a request for redesignation. Thank you. 

(Ms. Harley’s comments were submitted in support of her comments as well as the document 

Clean Air Task Force, 2004, Diesel Emissions: Particulate Matter-Related Health Damages, 

prepared by Abt Associates, Inc. Due to the length, this document was not included in this 

redesignation request but is available upon request). 
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Ann Woiwode

Thank you for holding the hearing and I want to reiterate the comments from Susan Harley 

regarding the notice of the hearing itself, the comment period was noticed in two calendars but 

the actual confirmation that there would be a hearing was only made two days ago and there 

are a number of people who we are aware of who were unable to come to the hearing, make 

arrangements to get here with just a two-day notice that the hearing would be held. It would be 

helpful in future calendars if it’s clear that if someone requests a hearing, it will automatically be 

held, I believe that wasn’t clear people were awaiting confirmation that a hearing would be held 

and when they didn’t hear anything until two days before, we literally had people scrambling 

who were unable to make the hearing. 

I am speaking on behalf of the Sierra Club and I want to offer a few comments on the proposed 

new set of redesignations. As has been said by some others, the monitoring data alone is not 

sufficient because of these changes in the levels of emissions are not permanent and are not 

enforceable and that raises a lot of concerns. We want the economy to recover. We want to 

simultaneously assure that we are protecting the health of people when that happens, and that 

simply is setting ourselves up for additional health and environmental issues as a result of a 

recovery that we hope is underway. 

There are a couple of other specific observations. From the Detroit Air Toxics Report issued by 

the MDEQ in Dec. 2010, page ES-3, I want to note that it says that: 

“Elevated cancer risk from diesel particulate matter was found in both the DATI-1 and 

DATI-2 studies. However, these risks were not included in the above estimates and 

comparisons due to the greater uncertainty associated with determining diesel 

particulate matter, ambient concentrations, estimating risks and the limited number of 

sites with surrogate monitoring data. Although these estimated values are relatively 

uncertain, they serve to provide a general sense of the contribution DPM may add to the 

cancer risk for air toxics in the Detroit area. The DATI-2 concentration range resulted in 

an estimated increased cancer risk of approximately 200 x 10-6 associated with the 

estimated level at Allen Park, the only site with available surrogate data for comparison. 

In contrast, the DATI-1 risk estimate was over 300 x 10-6. These estimated ranges of 

cancer risk are considered to have significant uncertainty. However, they suggest that 

diesel emissions may be a significant risk driver in the context of the total cancer risks 

estimated in this report for the other Detroit area air toxics.” 

That raises a number of concern for us about whether these levels would actually be adequate 

to protect public health. It is important that the MDEQ consider the existing international 

trucking traffic in this area and the projected truck traffic from the proposed bridge, which was 

not considered here. 

The last observation is that given the proposed PM2.5 rules being developed by the EPA, it is 

premature to submit a redesignation based on the 2006 standard 15 when EPA is considering 

lowering those standards to 11 to 13 for a 24-hour standard. Many of the area sites monitored 

would not meet the new standards in this process should consider those proposed standards. 

The hearing notice also said that it would be between 1 and 4 PM and I just want to make sure 

since the late notice that there will be someone to take comments up until 4 PM so there is no 

one who is left out if they couldn’t get here at 1 PM. Thank you. 
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Mike Lebeis

Yesterday I actually submitted hard copy comments that already went into the record; I just 

have a few other things to add to that. This is kind of at the request of Joan Weidner. It actually 

deals with the enforceability of emission reductions that are being implemented in southeast 

Michigan. The primary location I am commenting on is the Monroe power plant. It turns out that 

the past actual data were really from 2005 and 2008. The important part about that is that those 

are years before the flue gas desulfurization was installed on units 3 and 4 and also that was at 

the time that selective catalytic reduction was installed on units 1, 3 and 4 and was only 

operated in 2008 during the ozone season because the annual NOx cap did not kick in until 

2009 so beginning in 2009, we actually started to winterize our SCR devices so they could 

operate in a non-ozone season as well as the ozone season. So actually beginning in 2009 and 

going into the future, those emission reductions that have been acquired by basically putting in 

the control devices are actually operational now and we have a year or two under our belts to 

find out what the emissions actually are after putting the devices in. 

One thing I want to point out is that 2008 data showed about on the order for units 3 and 4 

showed about 58,000 tons of SO2 and actually 2010 was the first year that the FGDs were 

running the full year. Actually during that year they dropped to on the order of about just slightly 

over 1,000 tons. So there is over a 50,000 ton drop in SO2 emissions, you know, from before 

the FGDs were installed versus after. The numbers that are projected to go into the future, it 

shows like between 2008 and 2018 I believe, about a 28,000 ton drop but what we’re saying is 

that actually from the two units that the FGDs are already installed on, we’ve had almost double 

that number from just two of the units. And actually we’re in the process of installing FGDs on 

units 1 and 2 and also adding an SCR to unit 2 that is the only unit at the plant that doesn’t have 

one at this time. And those are projected to be installed by on the order of 2014. 

The other thing that comes into play is that these emission reductions are going to be 

enforceable because we actually went through the process of actually getting the permit for 

them and we went through a back review for both SO2 and for NOx to actually solidify the 

numbers to make sure they’re enforceable so we think that those are permanent reductions that 

are going to be taking place in the air shed in southeast Michigan. So we just wanted to get that 

on record that we believe they are permanent and there’s a legitimate reason to use even lower 

numbers than have been projected at the current estimates at this time. So those are the main 

things that I wanted to say. Thank you. 
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Written Comments
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Ms. Lorraine Hickman 

Michigan Department of 

Environmental Quality, 

Air Quality Division 

P.O. Box 30260 

Lansing, MI 48909 

Regarding the State of Michigan's move to redesignate seven counties in Southeast MI as 

attainment. In matters of 2.5 particulate matter and the impact on Environmental Justice 

communities in Southwest Detroit and in particular in the zip code of 48217, I believe it 

will cause greater harm to the health and quality of life of the residents in these 

communities and other communities throughout MI. According to a article in the New 

England Journal of Medicine, particular matter 2.5 has a direct connection to 

cardiovascular disease in post-menopausal women. Add to that lack of health insurance, 

and medical facilities most likely there be will be greater concerns of these issues. The 

health implication of such a move will prove to be a detriment to vulnerable groups 

Heavy truck traffic in SW Detroit is another concern. Diesel pollution should be 

considered because of traffic going to and from the Ambassador Bridge, and any new 

bridge to come. Thanking you for your consideration. 

Peace 

Rhonda Anderson 

Field Organizer 

National Environmental Justice & Community Partnership Program 

Sierra Club/Detroit 

2727 Second Ave. suite 320 

Detroit, Mi 48201 

313 965 0052 office 
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