8-HOUR OZONE REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR THE 

MILWAUKEE-RACINE 6-COUNTY 

SUBPART-2 MODERATE NONATTAINMENT AREA 

SHEBOYGAN COUNTY 

SUBPART-2 MODERATE NONATTAINMENT AREA 

DOOR COUNTY 

SUBPART-1 BASIC NONATTAINMENT AREA 

MANITOWOC COUNTY 

SUBPART-1 BASIC NONATTAINMENT AREA 

WISCONSIN 

Developed By: 

The Wisconsin Department of Natural Resources 

September 2009 

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V. IMPROVEMENT IN AIR QUALITY IS DUE TO PERMANENT 

AND ENFORCEABLE MEASURES 

Wisconsin must be able to reasonably attribute the improvement in air quality to emission 

reductions that are permanent and enforceable. To satisfy this requirement, Wisconsin 

submits the following data indicating a decrease in emissions between 2002, when the 

Milwaukee-Racine 6-County Area and the counties of Door, Manitowoc, and Sheboygan 

were monitored as nonattainment for the 8-hour ozone NAAQS, and 2007, when these 

nine counties were monitored as being in attainment based on ozone design values 

determined from 2006 through 2008 data. In addition, Wisconsin has documented 

specific permanent and enforceable programs responsible for emission reductions over 

this time period. 

A. Nonattainment Year (2002) Inventory

As part of a larger inventory development project, the WDNR prepared a comprehensive 

inventory for the State of Wisconsin. This inventory included point, mobile, and area 

sources for precursors of ozone (VOC and NOx) for the nonattainment year 2002. 

Biogenic emission estimates were not included. A basic description of the utilized 

methodologies follows. 

• Point Source Inventory - The methodology used to develop the comprehensive 2002 

non-Electric Generating Unit (non-EGU) point source inventory is contained in 

Appendix 4. Contained in Appendix 5 is the EGU emission estimation methodology 

created by a WDNR Air Management engineer and EGU specialist. The EGU 

emissions inventory incorporates U.S. EPA’s Clean Air Markets Division data. 

• Area Source Inventory – The 2002 area source emissions inventory was derived by 

backcasting the Wisconsin 2005 Base Year emissions inventory submittal to U.S. 

EPA in June of 2007. This was done since different methodologies were used to 

develop the original Wisconsin 2002 Base Year emissions inventory compared to the 

2005 inventory. WDNR received verbal confirmation from U.S. EPA Region 5 staff 

that this is an acceptable approach during a phone call on May 18th, 2009. These 

emission estimates were made based on various activity data compiled by, but not 

limited to, the U.S. Census Bureau, the U.S. Energy Information Administration, U.S. 

Bureau of Economic Analysis, the Lake Michigan Air Director’s Consortium 

(LADCO), as well as several Wisconsin State agencies. A description of the 

methodologies followed to develop the original and backcasted 2002 inventory is 

included in Appendix 4. Appendix 7 contains area source emissions by county and 

SCC, including the backcasted growth factors. 

• Nonroad Inventory – The nonroad emission estimates were prepared by using the 

U.S. EPA National Mobile Inventory (NMIM) model. Pechan, an independent 

contractor, provided marine and rail emission estimates via LADCO for Wisconsin in 

2002. Aircraft emissions were calculated using the Federal Aviation 

Administration’s Emissions and Dispersion Modeling System (EDMS). 

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• Onroad Inventory - 2002 mobile source emissions were calculated using 

MOBILE6.2. All emission estimates were made in accordance with the Users Guide 

to MOBILE 6.1 and MOBILE 6.2, U.S. EPA, Office of Transportation and Air 

Quality, Assessment and Standards Division, August 2003, EPA 420-R-03-010 and 

The Technical Guidance on the Use of MOBILE6 for Emission Inventory 

Preparation, U.S. EPA, Office of Air and Radiation, Office of Transportation and Air 

Quality, January 2002. 

 

Point, area, nonroad, and onroad emissions data are in Appendices 5 through 9. Tables 5 

and 6 below summarize total emissions in 2002, reported as tons per summer day (tpsd). 

As the tables indicate, major sources categories of NOx in 2002 are point and onroad. 

Milwaukee County has the greatest level of NOx emissions. Area and nonroad sources 

account for the greatest VOC emissions. Emissions of VOC are highest in Milwaukee 

County followed by Waukesha County. 

Table 5: Total NOx Emissions for Nonattainment Year 2002 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 67.64 0.80 8.08 4.42 80.94 

Milwaukee 37.80 6.10 44.44 18.50 106.84 

Ozaukee 6.49 0.60 6.66 5.83 19.58 

Racine 1.55 1.08 8.71 5.94 17.28 

Washington 0.36 0.86 9.71 4.31 15.24 

Waukesha 0.89 3.43 25.58 12.94 42.84 

MilwaukeeRacine 

6-Co. Area 

114.73 12.87 103.18 51.94 282.72 

Door 0.01 0.19 2.68 6.74 9.62 

Manitowoc 2.83 0.42 7.41 4.21 14.87 

Sheboygan 26.07 1.00 8.25 4.47 39.79 

* Point includes combined non-EGU and EGU emissions 

Table 6: Total VOC Emissions for Nonattainment Year 2002 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 0.63 6.22 3.61 4.99 15.45 

Milwaukee 7.54 45.90 20.92 18.38 92.74 

Ozaukee 0.51 6.77 2.54 3.07 12.89 

Racine 1.61 18.19 4.06 6.78 30.64 

Washington 0.62 11.41 3.61 6.34 21.98 

Waukesha 3.81 18.12 10.62 21.63 54.18 

MilwaukeeRacine 

6-Co. Area 

14.72 106.61 45.36 61.19 227.88 

Door 0.23 1.57 1.39 9.63 12.82 

Manitowoc 1.58 4.63 3.26 3.59 13.06 

Sheboygan 2.50 7.59 3.76 5.62 19.47 

* Point includes combined non-EGU and EGU emissions 

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B. Attainment Year (2007) Inventory

WDNR developed a 2007 attainment year inventory by growing the statewide 2005 base 

year emissions inventory of VOC and NOx emissions for the current nine nonattainment 

counties in Wisconsin. Point sector emissions estimates, both EGU and non-EGU, are 

actual 2007 reported emissions. Biogenic emission estimates were not included. WDNR 

received written confirmation from U.S. EPA Region V staff that this is an acceptable 

approach. The 2007 inventory emissions were determined using the following 

approaches. 

• Point Source Inventory Projections- Actual 2007 reported emissions, both EGU and 

non-EGU, are presented in Appendices 4 and 5. 

• Area Source Inventory Projections - Projections were performed by applying growth 

factors and applicable emission controls to the 2005 base year inventory. These 

growth factors were carefully selected based on a prioritization schema. Foremost 

priority was given to county-specific employment based growth factors. Next, if 

available, a state-specific employment based growth factor was used. These 

employment based growth factors were determined from U.S. Census Bureau County 

Business Patterns data1

. Next county-specific growth factors developed by Pechan2

contained in the document entitled Development of Updated Growth and Control 

Factors for the Lake Michigan Air Directors Consortium (LADCO)- Draft Report

(December 29, 2005) were used. Next, if a county-specific growth factor was 

unavailable, a Wisconsin state-specific growth factor developed by Pechan was 

applied. Finally, an EGAS 6.0-generated growth factor was employed if no other 

growth factors were available. Appendix 7 contains area source growth factors, 

emission controls, and grown emissions by county and SCC. 

• Nonroad Inventory Projections - 2007 nonroad mobile emission estimates were 

prepared by using the U.S. EPA National Mobile Inventory (NMIM) model. Marine 

and rail emissions were grown from 2005 Pechan state-wide growth factors. EGAS 

6.0-generated growth factors were used to grow the aircraft inventory.

• Onroad Inventory Projections - Emission projections were created using the U.S. 

EPA MOBILE 6.2 model. All projections were made in accordance with the Users 

Guide to MOBILE 6.1 and MOBILE 6.2, U.S. EPA, Office of Transportation and Air 

Quality, Assessment and Standards Division, August 2003, EPA 420-R-03-010 and 

The Technical Guidance on the Use of MOBILE6.2 for Emission Inventory 

Preparation, U.S. EPA, Office of Air and Radiation, Office of Transportation and Air 

Quality, August 2004, EPA 420-R-04-013. 

 

1

 http://www.census.gov/econ/cbp/download/index.htm 

2

 Pechan is an independent contractor, which, through contracts with LADCO, has developed state specific 

emission inventory data, including growth factors, for the entire LADCO region. 

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Point, area, nonroad, and onroad emissions data are in Appendices 5, through 9. Tables 7 

and 8 below summarize the total emissions. Table 9 compares the total emissions for the 

nonattainment and the attainment inventories for the Milwaukee-Racine 6-County Area 

and the counties of Door, Manitowoc, and Sheboygan. 

Table 7: Total NOx Emissions for Attainment Year 2007 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 10.62 0.83 6.05 3.95 21.45 

Milwaukee 26.88 6.29 29.81 16.83 79.81 

Ozaukee 1.11 0.62 4.70 4.84 11.27 

Racine 0.93 1.12 6.21 5.17 13.43 

Washington 0.74 0.90 7.20 3.61 12.45 

Waukesha 1.41 3.54 19.24 11.26 35.45 

MilwaukeeRacine 

6-Co. Area 

41.69 13.30 73.21 45.66 173.86 

Door 0.002 0.20 1.97 5.28 7.452 

Manitowoc 3.13 0.43 5.38 3.61 12.55 

Sheboygan 12.99 1.04 5.81 3.73 23.57 

* Point includes combined non-EGU and EGU emissions 

Table 8: Total VOC Emissions for Attainment Year 2007 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 1.61 5.72 2.63 4.13 14.09 

Milwaukee 5.16 41.40 13.75 14.46 74.77 

Ozaukee 0.46 6.41 1.75 2.23 10.85 

Racine 1.25 17.17 2.82 5.59 26.83 

Washington 0.59 11.03 2.63 5.07 19.32 

Waukesha 3.13 16.82 7.81 16.97 44.73 

MilwaukeeRacine 

6-Co. Area 

12.20 98.55 31.39 48.45 190.59 

Door 0.30 1.51 0.93 8.85 11.59 

Manitowoc 1.43 4.39 2.24 3.15 11.21 

Sheboygan 2.26 7.08 2.50 5.02 16.86 

* Point includes combined non-EGU and EGU emissions 

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Table 9: Comparison of 9-County Area Total NOx and VOC emissions 

for 2002 and 2007

(Tons per summer day) 

Milwaukee-Racine 6-County Area 

NOx VOC 

Sector 2002 2007 Net Change 

(2007 – 2002) 2002 2007 Net Change(2007 – 2002) 

Point 114.73 41.69 -73.04 14.72 12.20 -2.52 

Area 12.87 13.30 0.43 106.61 98.55 -8.06 

Onroad 103.18 73.21 -29.97 45.36 31.39 -13.97 

Nonroad 51.94 45.66 -6.28 61.19 48.45 -12.74 

Total 282.72 173.86 -108.86 227.88 190.59 -37.29 

Door County 

NOx VOC 

Sector 2002 2007 Net Change 

(2007 – 2002) 2002 2007 Net Change(2007 – 2002)

Point 0.01 0.002 -0.01 0.23 0.30 0.07 

Area 0.19 0.20 0.01 1.57 1.51 -0.06 

Onroad 2.68 1.97 -0.71 1.39 0.93 -0.46 

Nonroad 6.74 5.28 -1.46 9.63 8.85 -0.78 

Total 9.62 7.452 -2.17 12.82 11.59 -1.23 

Manitowoc County 

NOx VOC 

Sector 2002 2007 Net Change 

(2007 – 2002) 2002 2007 Net Change(2007 – 2002) 

Point 2.83 3.13 0.30 1.58 1.43 -0.15 

Area 0.42 0.43 0.01 4.63 4.39 -0.24 

Onroad 7.41 5.38 -2.03 3.26 2.24 -1.02 

Nonroad 4.21 3.61 -0.60 3.59 3.15 -0.44 

Total 14.87 12.55 -2.32 13.06 11.21 -1.85 

Sheboygan County 

NOx VOC 

Sector 2002 2007 Net Change 

(2007 – 2002) 2002 2007 Net Change(2007 – 2002)

Point 26.07 12.99 -13.08 2.50 2.26 -0.24 

Area 1.00 1.04 0.04 7.59 7.08 -0.51 

Onroad 8.25 5.81 -2.44 3.76 2.50 -1.26 

Nonroad 4.47 3.73 -0.74 5.62 5.02 -0.60 

Total 39.79 23.57 -16.22 19.47 16.86 -2.61 

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Table 9 shows a substantial decrease in NOx (37 %) and moderate decrease in VOC 

(16 %) between 2002 and 2007 throughout the nine nonattainment counties. Large NOx 

reductions in the point category are due to controls on electric generating units in the 

area. Vehicle fleet turnover also contributed to NOx and VOC reductions for both the 

onroad and nonroad emission sectors. Emissions have also decreased for the nonroad 

sector due to various control programs, such as the clean air nonroad diesel rule. 

C. Permanent and Enforceable Control Measures

The improvement in air quality can be attributable to a number of regulatory control 

measures that Wisconsin has implemented in recent years. Air quality in the MilwaukeeRacine 6-County Area and the counties of Door, Manitowoc, and Sheboygan is 

significantly affected by the transport of ozone from upwind counties. Therefore, in 

addition to controls implemented in the area, region-wide controls implemented in 

upwind counties are also relevant to the improvement in the air quality in these nine 

counties. 

1. Rate of Progress Plan 

Areas designated as nonattainment for the 1-hour ozone standard are required to reduce 

VOC emissions 3% per year from “adjusted” 1990 levels until the areas attain the ozone 

standard and get reclassified. For severe ozone areas, Rate of Progress (ROP) plans are 

required to meet milestone years in 1996 (15%), 1999 (24%), 2002 (33%), 2005 (42%) 

and 2007 (48%). For each milestone plan, an additional 3% reduction must be identified 

as a contingency measure. A contingency measure is a control option that could be 

instituted in addition to existing air quality control measures.

Wisconsin inventoried actual emissions of VOCs from all stationary, mobile, and area 

sources and first submitted it as part of its 1992 SIP requirements. In late 1993, 

Wisconsin submitted a 1996 ROP SIP revision to the U.S. EPA describing actions the 

state planned to implement to achieve the 3% annual VOC reductions beginning in 1996, 

known as the “15% VOC reduction plan.” On March 22, 1996, Wisconsin became the 

first state to receive U.S. EPA approval of its 15% VOC reduction plan (61 FR 11735). 

The 1990 level of emissions in the state was 341 tons per day, so the state was required to 

reduce VOC emissions by 51.2 tons per day, beginning in 1996. The 1996 plan allocated 

the reduction as follows: a) 51% (26.3 tons per day) from mobile sources; b) 36% (18.4 

tons per day) from area sources; and c) 13% (6.5 tons per day) from industrial sources. 

Federal programs to reduce VOC emissions included reformulated gasoline, clean fuel 

fleets, and revised motor vehicle emission standards. Wisconsin program elements 

included rules defining VOC Reasonably Available Control Technology (RACT) for 

major sources, enhancement to the vehicle inspection and maintenance (I/M) programs, 

stage 2 gasoline fuel vapor recovery, solvent limits for various coatings applications, and 

some voluntary industrial solvent regulation enhancements. 

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In 1997, after an analysis of VOC emissions in the nine county nonattainment area (Door, 

Kenosha, Manitowoc, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and 

Waukesha), Wisconsin sent a letter to U.S. EPA indicating that the state had achieved the 

required milestone of reducing VOCs by 15% from the 1990 base level of emissions. 

In 1997, Wisconsin submitted a 1999 ROP SIP revision to U.S. EPA describing actions 

the state planned to begin implementing in 1999 to achieve the required additional 3% 

annual reduction in VOCs in the state’s six severe nonattainment counties. In the 1999 

plan, Wisconsin projected that VOC emission control measures in the 1996 plan, along 

with additional emission reductions from adopted federal programs, would be sufficient 

to reach the 1999 rate-of-progress. In 2000, Wisconsin completed an analysis of 

emissions that demonstrated that the state met the emissions milestone for 1999 of 

reducing VOC emissions by 9% from 1996 to 1999. 

In late 2000, Wisconsin included the 2002, 2005 and 2007 ROP SIP revisions with the 1-

hour attainment demonstration plan. On October 10, 2001, the U.S. EPA approved the 

ROP SIP revisions (66 FR 51572). 

2. VOC Reasonably Available Control Technology 

Section 182(b)(2) of the 1990 CAA requires states with moderate nonattainment areas to 

implement RACT under section 172(c)(1) with respect to each of the following: 

a) each category of VOC sources in the area covered by a CTG document issued 

by the Administrator between the date of the enactment of the 1990 CAA and 

the date of attainment 

b) all VOC sources in the area covered by any CTG issued before the enactment 

date of the 1990 CAA 

c) all other major stationary sources of VOCs that are located in the area 

Wisconsin has adopted and implemented, as a part of its SIP, rules requiring all existing 

major stationary sources of VOCs at the 25 ton level in the Milwaukee-Racine 6-County 

Area and Sheboygan County to meet RACT. These RACT requirements are contained 

within chs. NR 419 to 424, Wis. Adm. Code, and apply to sources in categories covered 

by all applicable CTG and other non-CTG source categories of VOCs. Even though 

Manitowoc and Door Counties were not designated as moderate nonattainment areas and 

are not subject to these requirements, the changes are significant because of the large 

contribution of VOCs from the Milwaukee-Racine 6-County Area and Sheboygan 

County. 

There are certain source categories for which CTG documents exist but for which 

Wisconsin has no stationary sources. For such categories, Wisconsin submitted negative 

declarations to U.S. EPA certifying that sources do not exist in Wisconsin for such 

categories and therefore rules need not be adopted for those categories. 

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As noted in subsection 4 below (and Appendix 10), Wisconsin has adopted Maximum 

Achievable Control Technology (MACT) rules further controlling VOC emissions 

throughout the state. The Occupational Safety and Health Administration (OSHA) 

enacted rules have also limited VOC emissions in Wisconsin. The cumulative effect of 

these rules is very effective emissions control of all high-emitting stationary sources of 

VOC in the area. Thus, Wisconsin has re-examined its VOC RACT rules and determined 

that it meets the Subpart 2 VOC RACT requirement. 

VOC RACT rules have been very successful in reducing emissions over the past decades 

as indicated in Table 10. Note that VOCs and reactive organic gases (ROGs) are nearly 

identical in definition and photochemical function. ROG excludes CFCs and HCFCs. 

Table 10: Emissions of Reactive Organic Gases 

in 9-County Area 1985 & 2005 

County 1985 ROG 

(tons) 

2005 ROG 

(tons) 

Percent 

Decrease 

(%) 

Door 214.23 105.65 50.7 

Kenosha 840.19 534.97 36.3 

Manitowoc 470.24 559.20 -18.9 

Milwaukee 10,728.51 2,143.25 80.0 

Ozaukee 283.69 156.24 44.9 

Racine 1,235.84 448.89 63.7 

Sheboygan 1,244.94 908.28 27.0 

Washington 619.00 222.00 64.1 

Waukesha 1,647.31 1,147.63 30.3 

Totals 17,283.95 6,226.11 64.0 

Source: http://dnr.wi.gov/air/emission/historical_emissions/historical_emissions_rog.htm 

ROG emissions in the Milwaukee-Racine 6-County Area and the counties of Door, 

Manitowoc, and Sheboygan have declined by 64% in total between 1985 and 2007. 

3. NOx Reasonably Available Control Technology 

Wisconsin established specific NOx controls as part of the necessary progress plans 

setting formal maximum NOx budgets within Wisconsin's SIP. These specific controls 

were implemented in November 2001 in Wis. Admin. Code NR 428. 

In 2006, Wisconsin started rule making proceedings to implement NOx RACT 

requirements on major sources in the Milwaukee-Racine 6-County Area. The emission 

requirements apply to individual stationary combustion units at major sources with a 

compliance date of May 1, 2009. The proposed RACT rule is estimated to achieve 

reductions of over 29,000 tons per year of NOx emissions from 2002 emission levels. 

WDNR has updated NR 428 to comply with NOx RACT requirements. WDNR plans to 

submit this rule prior to, or concurrently with, submittal of this redesignation request. 

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4. Measures in addition to Clean Air Act Requirements 

In anticipation of the need for additional reductions beyond CAA requirements, 

Wisconsin worked with the community to identify and implement additional control 

measures. Thus, in addition to emission reductions that will occur as a result of various 

federal measures, further reductions in ozone precursor emissions have occurred, or are 

anticipated to occur, as a result of local and federal control programs. These additional 

non-voluntary control measures include: 

• NOx SIP Call: To address the ozone transport problem, U.S. EPA finalized 

rulemaking in September 1998 requiring 22 states to reduce NOx emissions 

within each state to a level consistent with a NOx emissions budget identified 

in the final rule (63 FR 57356). The 22 states were required to submit a 

revision to their SIP addressing the regional transport of ozone, consisting of 

rules to reduce NOx emissions from electric utility boilers, cement kilns, large 

industrial boilers, and stationary internal combustion engines. Implementation 

of the NOx SIP call in states upwind from Wisconsin began in May 2004. 

This rule results in a significant reduction of NOx emissions that contribute to 

ozone concentrations in the Milwaukee-Racine 6-County Area and the 

counties of Door, Manitowoc, and Sheboygan. Note: Wisconsin was removed 

from the requirement to implement the NOx SIP as a result of the litigation 

after the NOx SIP call was finalized. 

• Best Available Retrofit Technology (BART): s. NR 433 affects certain 

large sources of NOx, SO2, or direct particle pollution that began operation 

between 1962 and 1977. The main sources subject to emission reductions are 

boilers at electric generating power plants and pulp and paper facilities. 

• Mercury Multipollutant Reduction Alternative: s. NR 446 allows large or 

small coal-fired electrical generating units the option to reduce NOx, SO2, 

and mercury by 2015 to the emission limitations listed in s. NR 446.14 instead 

of the mercury only limitations listed in s. NR 446.12 and 446.13. 

• Tier 2 Emission Standards for Vehicles and Gasoline Sulfur Standards: 

On February 10, 2000, U.S. EPA finalized a federal rule to significantly 

reduce emissions from cars and light trucks, including sport utility vehicles 

(SUVs). Under this rule, automakers are required to sell lower-emitting cars, 

and refineries are required to make cleaner, lower sulfur gasoline. This rule 

applies nationwide. The federal rules are being phased in between 2004 and 

2009. U.S. EPA has estimated that NOx emission reductions will be 

approximately 77% for passenger cars, 86% for smaller SUVs, light trucks, 

and minivans, and 65-95% reductions for larger SUVs, vans, and heavier 

trucks. VOC emission reductions will be approximately 12% for passenger 

cars, 18% for smaller SUVs, light trucks, and minivans, and 15% for larger 

SUVs, vans, and heavier trucks. 

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• Ultra-low Sulfur Diesel Requirements for Highway Vehicles: Beginning 

June 1, 2006, refiners started producing diesel fuel for use in highway vehicles 

with a sulfur content of no more than 15 ppm. At the terminal level, highway 

diesel fuel sold as low sulfur fuel was required to meet the 15 ppm sulfur 

standard as of July 15, 2006. For retail stations and fleets, highway diesel fuel 

sold as low sulfur fuel met the 15 ppm sulfur standard by October 15, 2006. 

• Clean Air Nonroad Diesel Rule: In June 2004, U.S. EPA finalized the Clean 

Air Nonroad Diesel Rule which requires stringent pollution controls on diesel 

engines used in industries such as construction, agriculture, and mining that 

will result in a reduction in NOx emissions. In addition, beginning in 2007, 

sulfur levels in nonroad diesel fuels were reduced by 99 percent from current 

levels (from approximately 3,000 ppm now to 15 ppm in 2010). In the case of 

locomotive and marine diesel fuel, the second step will occur in 2012. The 

rule also requires engine manufacturers to use advanced clean technologies, 

similar to catalytic technologies used in passenger cars. New engine standards 

took effect, based on engine horsepower, in 2008. This rule applies 

nationwide. 

• Mobile Sources Air Toxics Rule: In February 2007, U.S. EPA issued a final 

rule to reduce hazardous air pollutants from mobile sources. Among these 

requirements in the rule are new standards to reduce non-methane 

hydrocarbon exhaust emissions from new gasoline-fueled passenger vehicles, 

more stringent evaporative emissions standards for new passenger vehicles 

and establishing standards that will limit hydrocarbon emissions that 

evaporate from and permeate through portable fuel containers such as gas 

cans. These standards have a co-benefit of reducing VOC emissions. 

• Maximum Achievable Control Technology Standards: Using a technology 

based approach, the U.S. EPA develops standards for controlling emissions of 

air toxics from each major type of facility within an industry group. These 

standards are based on emission levels that are already being achieved by 

lower emitting sources in an industry. For a list of MACT standards 

implemented in the Milwaukee-Racine 6-County Area and the counties of 

Door, Manitowoc, and Sheboygan see Appendix 10. 

• Stationary Source NOx Control Program (Wis. Adm. Code NR 428): NR 

428 addresses stationary source NOx emissions and is structured to meet ROP 

emission reduction requirements through 2007, the 1-hour ozone standard 

attainment deadline for the Lake Michigan region. The program encompasses 

the seven southeast counties of Kenosha, Milwaukee, Ozaukee, Racine, 

Sheboygan, Washington, and Waukesha, which are upwind of Manitowoc and 

Door. It controls NOx for larger existing sources and establishes emissions 

standards for new sources. The existing source control program reduces 

emissions at electric utility facilities and on larger industrial combustion 

sources from projected baseline levels in 2002. The performance standards 

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for new sources address emission rates from new uncontrolled facilities in the 

seven counties and for those undergoing major modification. 

The existing source performance standards affect 48 individual units at 21 

facilities. This program was targeted to achieve reductions of 30 tons of NOx 

per day at an average cost of approximately $1,000 per ton by the 2003 ozone 

season. The program was expected to achieve a 55 ton per day reduction by 

2007 at an average cost of approximately $1,600 per ton. 

The program consists of two basic elements: 1) ozone season emission limits 

for electric utility systems comprised of boilers equal to or greater than 500 

mmbtu/hr; and 2) Unit-specific requirements of either emission rate limits or 

combustion optimization for other large emission sources. 

WDNR has updated NR 428 to comply with NOx RACT requirements. 

WDNR plans to submit the rule prior to, or concurrently with, submittal of 

this redesignation request. 

• Clean Air Interstate Rule (CAIR) (Wis. Adm. Code NR 432): NR 432 

applies to all major electric generating units in Wisconsin and in upwind 

states. Nationwide, CAIR results in a reduction of NOx emissions by 53% by 

2009 and 63% by 2015. Sulfur dioxide emissions will be reduced by 45% by 

2010 and by 57% by 2015. A rule implementing CAIR in Wisconsin was 

adopted by the Natural Resources Board. On December 23, 2008, the D.C. 

Circuit Court decided to remand, rather than vacate, the CAIR rule, thus 

leaving CAIR in place while U.S. EPA revises the rule. Due to the ongoing 

litigation involving CAIR, all potential emission reductions resulting from 

CAIR have been left out of the emission projections in Section VI. 

• Side Benefits of Control of Hazardous Pollutants (Wis. Adm. Code NR 

445): NR 445 applies to all stationary air contaminant sources, which may 

emit hazardous contaminants. Some sources may be exempt from these 

requirements based on a risk-based threshold. These controls are expected to 

result in the reduction of NOx emissions from the nonroad stationary 

reciprocating diesel engines. The reduction is the result of NR 445 requiring 

affected engines to fire low sulfur on-road fuel beginning in July 2006. NR 

445 also includes an incentive to replace old engines with engines that meet 

Tier 2 or later nonroad standards. This will result in reductions of NOx in the 

Milwaukee-Racine 6-County Area as well as in the counties of Door, 

Manitowoc, and Sheboygan. 

• Local Controls of Traffic Congestion: The Milwaukee-Racine 6-County 

Area has implemented local controls to decrease the traffic congestion in the 

city. These voluntary local controls will reduce idling times of motor vehicles 

and thus reduce NOx emissions. The state does not commit to continuing 

these voluntary programs. Implemented measures include:

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• Commuter Value Pass (CVP) & UPASS programs: The CVP transit 

agency program offers discounted transit passes through large employers, 

providing a shared cost program between employer and employee. The 

UPASS program involves giving students/staff at area universities 'free' 

transit passes paid through student fees. 

• Rideshare: A Wisconsin Department of Transportation interactive webbased ride matching service. 

• Advanced Traveler Information Systems: Real-time data from traffic 

condition cameras is used to provide traveler information to the media and 

motorists. In addition, the live updates are communicated to motorists 

using electronic messaging signs. 

• Education/Marketing Promotion: Wisconsin Partners for Clean Air 

voluntary coalition promoting emission reductions along with an Air 

Quality Watch & Advisory Program alerting the public to air quality 

conditions and promoting transportation alternatives. 

• Traffic Incident Management: A freeway operational detection and control 

system with limited use of service patrol vehicles to assist road clearance 

and motorists. (limited to Kenosha and Racine counties) 

• Ramp Metering and High-Occupancy Vehicle Priority: Located on 

freeway entrance ramps to control the rate of entry and encourage 

ridesharing and transit use. 

• Guaranteed Ride Home (State and Milwaukee County Transit System 

(MCTS)): Provides transit and vanpool participants a taxi ride in the case 

of an employee or family member's illness or medical emergency. 

WisDot also offers reimbursement to employers who offer a guaranteed 

ride when an unforeseen event occurs. 

• Van Pool (State and MCTS): The State Vanpool provides alternative 

transportation for commuting to Madison from the Milwaukee area. 

• Park & Rides: A system of park and ride facilities throughout the area 

designed for meeting transit and carpools. 

5. Controls to Remain in Effect 

Wisconsin intends to maintain the non-voluntary control measures listed above after 

redesignation. Wisconsin hereby commits that any changes to its rules or emission limits 

applicable to VOC and/or NOx sources, as required for maintenance of the ozone 

standard in the Milwaukee-Racine 6-County Area or the counties of Door, Manitowoc, or 

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
 25 

Sheboygan, will be submitted to U.S. EPA for approval as a SIP revision. Wisconsin, 

through its Bureau of Air Management, has the necessary resources to actively enforce 

any violations of its rules or permit provisions. After redesignation, it intends to continue 

enforcing all rules that relate to the emission of ozone precursors in these nine counties. 

6. New Source Review Provisions 

Wisconsin has a fully approved New Source Review (NSR) procedure. This is addressed 

in Wis. Adm. Code NR 405. The rule includes provisions for the Prevention of 

Significant Deterioration (PSD) in Wis. Adm. Code NR 405.01. U.S. EPA has approved 

this program as a part of Wisconsin’s SIP and it is applicable to attainment areas in 

Wisconsin. The review process will be identical to that used for new sources. Any new 

source or major modification causing significant emissions under Wis. Adm. Code NR 

405 will be required to receive an air pollution control permit and apply Best Available 

Control Technology (BACT). Significant, as defined in Table A of the chapter, is 

defined as a net emissions increase or potential to emit of any air contaminant above the 

applicable threshold, including 40 tons/year NOx and 40 tons/year VOC. Any major 

source that is not listed in the 2005 emission inventory or for which attainment 

demonstration credit was taken upon closure of the facility will not be allowed to 

construct, reopen, modify, or reconstruct without meeting any applicable permit rule 

requirement. 

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

QUICKLOOK CRITERIA PARAMETERS

Report Request ID: 1283755 Report Code: AMP450 Jan. 7, 2015

Selection Criteria Page 1

User ID: GHG

State County Site Parameter POC City AQCR UAR CBSA CSA

EPA

Region

55 117 0006

GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS

Parameter

Classification Parameter Method Duration

QUICK LOOK

SELECTED OPTIONS

WORKFILE DELIMITER

MERGE PDF FILES

EVENTS PROCESSING

AGENCY ROLE

Option Type Option Value

,

YES

EXCLUDE REGIONALLY CONCURRED EVENTS

PQAO

SORT ORDER

1

2

3

4

5

6

7

Order Column

PARAMETER_CODE

STATE_CODE

COUNTY_CODE

SITE_ID

POC

DATES

EDT_ID

DATE CRITERIA

2014

Start Date End Date

2014

Tribal

Code

APPLICABLE STANDARDS

Standard Description

CO 1-hour 1971

CO 8-hour 1971

Lead 3-Month 2009

Lead 3-Month PM10 Surrogate 2009

NO2 1-hour

NO2 Annual 1971

Ozone 1-hour Daily 2005

Ozone 8-Hour 2008

PM10 24-hour 2006

PM25 24-hour 2013

PM25 Annual 2013

SO2 1-hour 2010

SO2 24-hour 1971

SO2 3-hour 1971

SO2 Annual 1971

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 1 of 3

EXCEPTIONAL DATA TYPES

EDT DESCRIPTION

0

1

2

5

NO EVENTS

EVENTS EXCLUDED

EVENTS INCLUDED

EVENTS WITH CONCURRENCE EXCLUDED

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 2 of 3

Ozone (44201) Wisconsin Parts per million (007)

SITE ID

P

O

C PQAO CITY COUNTY ADDRESS YEAR METH

VALID

DAYS

MEAS

1ST

MAX

1-HR

CERT 

and 

EVAL EDT

55-117-0006 1 1175 Not in a city Sheboygan KOHLER ANDRE 

PARK, 1520 

Beach Park Rd.

2014 087 182 .089 .084 0

2ND

MAX

1-HR

1-HOUR 

NUM

DAYS

REQ

184 .082

3RD

MAX

1-HR

.081

4TH

MAX

1-HR

DAY

MAX>

STD

0

EST

DAYS>

STD

 0.0

MISS

DAYS<

STD

2

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Page 3 of 3

Ozone (44201) Wisconsin Parts per million (007)

SITE ID

P

O

C PQAO CITY COUNTY ADDRESS YEAR METH

VALID

DAYS

MEAS

4TH

MAX

8-HR

CERT 

and 

EVAL EDT

55-117-0006 1 1175 Not in a city Sheboygan KOHLER ANDRE 

PARK, 1520 

Beach Park Rd.

2014 087 .079 .076 0

8-HOUR 

NUM

DAYS

REQ

184 .073 .072

DAY

MAX>

STD

180 2

%OBS

98

1ST

MAX

8-HR

2ND

MAX

8-HR

3RD

MAX

8-HR

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

Note: These reported values do not reflect the combination of 14129 and 85129 and validation substitution tests utilized for Design Value Calculations

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450)

Lead (TSP) LC

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450 END)

44201 087 INSTRUMENTAL ULTRA VIOLET ABSORPTION

PARAMETER

METHOD

CODE COLLECTION METHOD ANALYSIS METHOD

METHODS USED IN THIS REPORT

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450 END)

PQAOS USED IN THIS REPORT

PQAO AGENCY DESCRIPTION

1175 Wisconsin Dept Of Natural Resources, Air Monitoring Section

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

Note: The * indicates that the mean does

not satisfy summary criteria.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

QUICK LOOK REPORT (AMP450 END)

M

N

S

U

X

Y

The monitoring organization has revised data from this monitor since the


most recent certification letter received from the state.

The certifying agency has submitted the certification letter and required


summary reports, but the certifying agency and/or EPA has determined


that issues regarding the quality of the ambient concentration data cannot


be resolved due to data completeness, the lack of performed quality


assurance checks or the results of uncertainty statistics shown in the


AMP255 report or the certification and quality assurance report.

The certifying agency has submitted the certification letter and required


summary reports. A value of "S" conveys no Regional assessment regarding


data quality per se. This flag will remain until the Region provides an "N" or


"Y" concurrence flag.

Uncertified. The certifying agency did not submit a required certification


letter and summary reports for this monitor even though the due date has


passed, or the state's certification letter specifically did not apply the


certification to this monitor.

Certification is not required by 40 CFR 58.15 and no conditions apply to be


the basis for assigning another flag value

The certifying agency has submitted a certification letter, and EPA has no


unresolved reservations about data quality (after reviewing the letter, the


attached summary reports, the amount of quality assurance data


submitted to AQS, the quality statistics, and the highest reported


concentrations).

MEANING

CERTIFICATION EVALUATION AND CONCURRENCE FLAG MEANINGS

FLAG

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

DATA COMPLETENESS REPORT

Report Request ID: 1283758 Report Code: AMP430 Jan. 7, 2015

Selection Criteria Page 1

User ID: GHG

State County Site Parameter POC City AQCR UAR CBSA CSA

EPA

Region

55 117 0006

GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS

Parameter

Classification Parameter Method Duration

ALL

SELECTED OPTIONS

OZONE EVALUATION

MERGE PDF FILES

AGENCY ROLE

Option Type Option Value

SEASONAL-HOURLY

YES

REPORTING

SORT ORDER

1

2

3

4

5

6

7

Order Column

EPA_REGION

STATE_CODE

MONITOR_TYPE

COUNTY_CODE

SITE_ID

PARAMETER_CODE

POC

DATE CRITERIA

2014

Start Date End Date

01 2014 12

Tribal

Code

APPLICABLE STANDARDS

Standard Description

CO 1-hour 1971

Lead 3-Month 2009

Lead 3-Month PM10 Surrogate 2009

Lead Quarterly 1978

NO2 Annual 1971

Ozone 1-hour Daily 2005

PM10 24-hour 2006

PM25 Annual 2013

SO2 1-hour 2010

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

DATA COMPLETENESS REPORT

Page 1 of 3

MONITORS NOT REPORTING 

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

DATA COMPLETENESS REPORT

Page 2 of 3

DATE RANGE: 

REGION: (05) CHICAGO

Wisconsin MONITOR TYPE: 

Wisconsin Dept Of Natural Resources, Air Monitoring Section

SLAMS

JAN. 01, 2014 THRU DEC. 31, 2014

SITE ID

CITY

ADDRESS

PARAMETER POC DURATION

METHOD

------------------------------- OBSERVATIONS -------------------------------

NUMBER / PERCENT

55-117-0006

55-117-0006

55-117-0006

55-117-0006

55-117-0006

55-117-0006

44201

61101

61102

61103

61104

62101

Ozone

Wind Speed - Scalar

Wind Direction - Scalar

Wind Speed - Resultant

Wind Direction - Resultant

Outdoor Temperature

1

1

1

1

1

1

1

1

1

1

1

1

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

KOHLER ANDRE PARK, 1520 Beach Park Rd.

087

050

050

020

020

040

383

529

529

529

 100%

 73%

 73%

 73%

740

742

742

742

 99%

 100%

 100%

 100%

718

720

720

720

 100%

 100%

 100%

 100%

739

743

743

743

 99%

 100%

 100%

 100%

704

711

711

711

 95%

 96%

 96%

 96%

712

418

418

275

275

694

 99%

 92%

 92%

 95%

 95%

 96%

358

508

508

508

 99%

 68%

 68%

 68%

4354

3863

3863

783

783

4647

 99%

 61%

 61%

 31%

 31%

 53%

MONITORS REPORTING 

JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC YEAR

STATE:

REP ORG:

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

AIR QUALITY SYSTEM

DATA COMPLETENESS REPORT

Page 3 of 3

DATE RANGE: 

REGION: (05) CHICAGO

Wisconsin

MONITOR TYPE: 

Wisconsin Dept Of Natural Resources, Air Monitoring Section

SLAMS

JAN. 01, 2014 THRU DEC. 31, 2014

PARAMETER ACTIVE MONITORS # NOT REPORTING # MONITORS > 75% MONITORS AVG COMPLETENESS

44201

61101

61102

61103

61104

62101

Ozone

Wind Speed - Scalar

Wind Direction - Scalar

Wind Speed - Resultant

Wind Direction - Resultant

Outdoor Temperature

1

1

1

1

1

1

0

0

0

0

0

0

1

0

0

0

0

0

 99.0%

 61.0%

 61.0%

 31.0%

 31.0%

 53.0%

6 0 1 56.0%

6 0 1 56.0%

6 0 1 56.0%

6 0 1 56.0%

6 0 1 56.0%

Wisconsin Dept Of Natural Resources, Air Monit

Wisconsin

REGION SUMMARY: (05) CHICAGO

REPORT SUMMARY: 

MT SUMMARY: SLAMS

REPORT SUMMARY

STATE:

STATE SUMMARY: 

REP ORG:

RO SUMMARY:

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

CERTIFICATION EVALUATION AND CONCURRENCE

Report Request ID: 1283749 Report Code: AMP600 Jan. 7, 2015

Selection Criteria Page 1

User ID: GHG

State County Site Parameter POC City AQCR UAR CBSA CSA

EPA

Region

55 117 0006

GEOGRAPHIC SELECTIONS

PROTOCOL SELECTIONS

Parameter

Classification Parameter Method Duration

CRITERIA

SELECTED OPTIONS

MERGE PDF FILES

AGENCY ROLE

Option Type Option Value

YES

CERTIFYING

DATE CRITERIA

2014

Start Date End Date

2014

Tribal

Code

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Jan. 7, 2015 Data Evaluation and Concurrence Report Summary

Page 1 of 1

Certification Year: 2014

Certifying Agency (CA): Wisconsin Dept Of Natural Resources, Air Monitoring Section (1175)

Pollutants in Report:

PQAO

Parameter

Code

Ozone 44201

Parameter Name Code

1

Wisconsin Dept Of Natural Resources, Air Monitoring Section 1175

PQAO Code

AQS Site-ID POC

AQS

Recommended

Flag

Cert. Agency

Recommended

Flag Reason for AQS Recommendation

Signature of Monitoring Organization Representative: ________________________________________________________

PQAO Name

Summary of 'N' flags for all pollutants:

1 0

PQAOs in Report:

04/26/12

TSA Date

Monitors 

Evaluated

Monitors Recommended for

Concurrence by AQS

Monitors NOT Recommended 

for Concurrence by AQS

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Data Evaluation and Concurrence Report for Gaseous Pollutants

Certifying Year 2014

Certifying Agency Code Wisconsin Dept Of Natural Resources, Air Monitoring Section (1175)

Ozone (44201) (ppm)

PQAO Name Wisconsin Dept Of Natural Resources, Air Monitoring Section (1175)

QAPP Approval Date 10/01/2009

55-117-0006 SLAMS 1 0.049

Mean

 0.018

Min

 0.089

Max

0

Exceed.

Count

0

Outlier

Count

99

Perc.

Comp.

 0.68

Precision

+/-0.53

Bias

 100

Complete

100

Complete

- 1.15

Bias

Y

PQAO Level

Criteria

Y

Aqs Rec 

Flag

CA Rec

Flag

Epa 

Concur

Parameter

8 Y

NPAP Audit Summary: Number of Valid Audits NPAP Bias Criteria Met

1.18056

 1.84

Routine Data One Point Quality Check Annual PE NPAP Concur. Flag

AQS 

Site ID

POC Monitor

Type

Bias QAPP

Appr.

Y

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Data Evaluation and Concurrence Report for Particulate Matter

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments
Data Concurrence and Evaluation Report for Lead

WDNR Request for an extension of the 2008 ozone standard attainment date for the Sheboygan nonattainment area - Attachments