Michigan Department of Environmental Quality 

Recommended Attainment/Nonattainment 

Designations and Boundaries in Michigan 

for the 

Ozone National Ambient Air Quality Standard

March 12, 2009
Recommended Attainment/Nonattainment Designations and Boundaries 

In Michigan for the 0.075 ppm 

Ozone National Ambient Air Quality Standard 

In March 2008, the U.S. Environmental Protection Agency (EPA) revised the National 

Ambient Air Quality Standard (NAAQS) for ozone from 0.08 parts per million (ppm) to 

0.075 ppm. The federal Clean Air Act requires the EPA to seek recommendations from the 

states’ governors for initial designations of the attainment status for all areas of the states 

when a new or revised standard is promulgated. The states are also asked to provide 

recommendations for the appropriate boundaries of all nonattainment areas. The EPA will 

either affirm the states’ recommendations or make modifications as determined to be 

necessary. Final promulgation of designations is to occur by March 12, 2010, in accordance 

with the federal Clean Air Act. 

Recommendation

The designation recommendations of the Michigan Department of Environmental Quality 

(MDEQ) for the State of Michigan are based on the design value of ambient monitored data 

for the period 2006-2008 (Table 1). The MDEQ recommends that 16 Michigan counties be 

designated nonattainment and all others be designated attainment. The 16 counties are 

Wayne, Washtenaw, St. Clair, Oakland, Monroe, Macomb, Livingston, Lapeer, Livingston, 

Benzie, Manistee, Muskegon, Ottawa, Kent, Allegan, and Berrien. The recommendations on 

appropriate boundaries (Figure 1) are based, for the most part, on nonattainment boundaries 

for the 0.08 ppm ozone standard as previously established in 2004 (Figure 5). At this time, 

only one ozone monitor in the state, in Holland, is recording ozone levels above the 

0.08 ppm NAAQS. 

The MDEQ recommends that the EPA designate the seven-county Southeast Michigan area 

as a nonattainment area, and Lenawee County as an attainment area (Figure 2). This 

designation recommendation deviates from the boundaries established in 2004 that included 

Lenawee County in Southeast Michigan. Analysis supporting this recommendation follows. 

In all other areas with design values over the 0.075 ppm standard the MDEQ recommends 

retaining the boundaries that were established in 2004. The MDEQ recommends that 

Genesee and Lapeer Counties be designated separately as the Flint nonattainment area. 

The recommendation of separate nonattainment areas for the West Michigan areas of 

Allegan County, Muskegon County, and the Grand Rapids area of Kent and Ottawa Counties 

is especially important in light of the environmental and regulatory burden thrust upon the 

ozone transport receptor areas in counties that border Lake Michigan. Several metropolitan 

areas and non-urban counties that were established as nonattainment areas in 2004 under 

the 0.08 ppm ozone standard now have design values that attain the revised ozone NAAQS, 

including Lansing, Kalamazoo, and Cass, Huron, and Mason Counties. One county, 

Manistee, was designated attainment in 2004 but now is being recommended for a 

nonattainment designation. 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 2 

Table 1 

Recommended Attainment/Nonattainment 

Designations and Boundaries in Michigan for the 

Ozone National Ambient Air Quality Standard 

 2006-2008 Design Value 

Designation Area Designation Parts per million (ppm)

Southeast Michigan .082 

 Wayne County Nonattainment 

 Oakland County Nonattainment 

 Macomb County Nonattainment 

 St. Clair County Nonattainment 

 Livingston County Nonattainment 

 Washtenaw County Nonattainment 

 Monroe County Nonattainment 

Flint Metropolitan Area .076 

 Genesee County Nonattainment 

 Lapeer County Nonattainment 

Lenawee .075 

 Lenawee County Attainment 

Berrien .078 

 Berrien County Nonattainment 

Muskegon .082 

 Muskegon County Nonattainment 

Allegan .086

 Allegan County Nonattainment 

 

Grand Rapids .079 

Kent County Nonattainment 

 Ottawa County Nonattainment 

Benzie .076 

 Benzie County Nonattainment 

Manistee .077 

 Manistee County Nonattainment 

Cass .075 

Cass County Attainment 

Mason .075 

 Mason County Attainment 

All other counties Attainment 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 3 

 

Note: Michigan Map with County Names on Page 12 (Figure 6). 

Figure 1 

Recommended Ozone Designations (2006/2007/2008) 

Nonattainment - 

Wayne, Oakland, Macomb, St. Clair, 

Livingston, Washtenaw, Monroe, 

Genesee, Lapeer, Berrien, Allegan, 

Ottawa, Kent, Muskegon, Manistee, 

Benzie 

Attainment - 

All other counties 

monitoring site ≤0.075 ppm 

monitoring site >0.075 ppm 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 4 

Background

The ozone designations are to be based on design values (the average of the fourth highest 

values from each three consecutive years of data at each monitor) calculated from 

observations during the most recent three-year period of record. The ozone design value for 

an entire region is derived by the measurements of whichever monitor in the region has the 

highest ozone values. State recommendations are based on the period 2006-2008, whereas 

the EPA will make designations based on a different data set, 2007-2009. 

Design values in violation of the 0.075 ppm ozone NAAQS have been recorded in the 

counties of Wayne, Macomb, Oakland, St. Clair, Genesee, Kent, Ottawa, Allegan, 

Muskegon, Berrien, Manistee, and Benzie. 

The non-binding EPA guidance on boundary determination suggests using the Combined 

Statistical Area (CSA) or Core Based Statistical Area (CBSA), as defined by the U.S. Office 

of Management and Budget, Census Bureau, as the starting point or the presumptive 

boundary in the evaluation of appropriate nonattainment areas. A CBSA consists of a county 

or counties containing at least one urban core plus adjacent counties that have a high degree 

of social and economic integration with the urban core as measured by commuting ties. A 

CSA includes two or more adjacent CBSAs. States are asked to provide an analysis of local 

factors, such as location relative to the urban core, amount of emissions, population, and 

prevailing meteorology, in those recommendations that deviate from the CSA or CBSA 

presumptive boundaries. The federal Clean Air Act requires that nonattainment area 

designations for the 0.075 ppm ozone standard incorporate not only the areas of measured 

violations, but also the contributing nearby emission source areas. Recommendations that 

vary from the presumption should be supported with an analysis considering the following 

nine factors: 

• Air quality data. 

• Emissions data (location of sources and contribution to ozone concentrations). 

• Population density and degree of urbanization (including commercial 

development). 

• Traffic and commuting patterns. 

• Growth rates and patterns. 

• Meteorology (weather/transport patterns). 

• Geography-topography (mountain ranges or other air basin boundaries). 

• Jurisdictional boundaries (e.g., counties, air districts, existing nonattainment 

areas, Reservations, metropolitan planning organizations, etc.). 

• Level of control of emission sources.

Analysis of Southeast Michigan and Lenawee County follows, as separating the two areas is 

the only deviation from 2004 boundaries that is being recommended for those areas with 

design values above 0.075 ppm.

Southeast Michigan and Lenawee County

A nonattainment designation for Southeast Michigan area is warranted. The MDEQ 

recommends that the nonattainment area boundaries for the for the 0.075 ppm ozone 

standard include the seven counties of Wayne, Oakland, Macomb, St. Clair, Livingston, 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 5 

Washtenaw, and Monroe that comprised the 1-hour ozone attainment area and the current 

PM2.5 nonattainment area. These counties also coincide with the jurisdictional boundaries 

of the Southeast Michigan Council of Governments (SEMCOG) Metropolitan Planning 

Organization (MPO) that has responsibilities for air quality and transportation planning 

(Figure 3). 

When nonattainment designations were made for the 0.08 ppm standard in 2004, the monitor 

in Lenawee County was not meeting the standard and, at that time, the county was part of 

the Southeast Michigan Consolidated Metropolitan Statistical Area (CMSA). Hence, it was 

designated nonattainment and included in the Southeast Michigan nonattainment boundary. 

However, neither of these conditions is true today. The 2006-2008 data show the monitor in 

Lenawee is meeting the revised ozone standard with a design value of 0.075 ppm (Table 2). 

In addition, the latest U.S. Census boundaries, adopted in June 2003, removed Lenawee 

County from the Southeast Michigan CSA, and instead designated it as the Adrian 

Micropolitan Statistical Area (Figure 3). 

Lenawee County, located upwind of the Detroit area, is predominantly rural in character with 

few emissions of ozone precursors. More than half of the population resides in rural areas 

(Table 7). Forest and farmland account for 81% of the land use according to the Natural 

Resource Conservation Service. The 2000 population density of Lenawee County is low at 

131.8 persons per square mile (Table 6). The most populace area in the county is the city of 

Adrian with 21,574 people according to the 2000 U.S. Census, with an estimated 2007 

population loss of 4.2 percent. 

There are only two major stationary sources of criteria pollutant emissions (both volatile 

organic compounds (VOC) emissions sources) in Lenawee County. Local emissions of 

nitrogen oxides (NOx) and VOC generated in Lenawee County comprise only 1.4% and 

3.1% of the total emissions, respectively, when included in the Southeast Michigan area 

(Tables 3 and 4). 

According to the county-to-county worker flow data from the 2000 U.S. Census, 21.9% of 

Lenawee County’s workers commute to the seven-county SEMCOG region, which is only 

0.5% of the work force in the seven-county SEMCOG region (Table 10). Little growth is 

expected in future years, both in terms of population and employment. From 2000-2007, the 

rate of population growth was 0.3 % per year (Table 5). The most recent demographic 

forecast for Lenawee County predicted population would increase 6.9% from 2000 to 2020, a 

rate of growth of 0.33% per year (Table 11). Employment was expected to increase only 

7.2% from 2005 to 2025, a rate of 0.36% per year (Table 12). It should be noted that these 

forecasts were made over five years ago and thus do not include the impact of the recent 

economic downturn in Michigan. It is highly likely that the new forecasts would estimate an 

even smaller rate of growth over the next 20 years. 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 6 

Figure 2 

Recommended Ozone Designations for Southeast Michigan, 

Lenawee County and Genesee/Lapeer Counties 

Figure 3 

Combined Statistical Area as revised June 2003 

Wayne

Monroe 

Washtenaw

Oakland

Livingsto

Macom

Genesee St. Clair Lapeer SEMCOG Region 

East Seven Mile 

Flint 

Warren 

Otisville 

New Haven 

Oak Park 

Ypsilanti 

Tecumseh 

Port Huron 

Allen Park 

St. 

Clair

Lapeer 

Genesee 

Oakland 

Macom

b

Livingston

Washtenaw Wayne

Lenawee

Monroe

Monitor ≤ 0.075 ppm 

Monitor > 0.075 ppm 

Attainment 

SE MI 

Nonattainment 

Flint 

Nonattainment 

Note: Based on monitoring data for 2006, 2007 and 2008.
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 7 

Table 2 

2006-2008 8-Hour Ozone Monitoring Data for Southeast Michigan and Lenawee 

Monitoring Site Purpose 

2006 4th

High (ppm)

2007 4th

High (ppm)

2008 4th

High (ppm) 

Design Value 

(ppm) 

Allen Park Pop exp. 0.068 0.079 0.067 0.071 

Detroit E. 7 Mile Max. conc. 0.078 0.092 0.076 0.082 

New Haven Max. conc. 0.078 0.093 0.073 0.081 

Oak Park Pop. exp. 0.072 0.086 0.074 0.077 

Port Huron Pop. exp. 0.078 0.089 0.067 0.078 

Warren Max. conc. 0.078 0.091 0.072 0.080 

Ypsilanti Pop. exp. 0.076 0.077 0.069 0.074 

Tecumseh (Lenawee) Backgrd. 0.074 0.081 0.072 0.075 

 Note: The monitoring sites in bold type are violating the 0.075 ppm standard. 

Table 3 

NOx Emissions in Southeast Michigan and Lenawee (Tons/Yr) 

County Point Area Non-road On-road Total % of Total 

Livingston 660.10 647.95 1,372.07 5,417.90 8,098.02 3.1%

Macomb 855.33 2,498.84 5,643.24 14,121.20 23,118.61 9.0%

Monroe 42,258.23 606.83 2,362.92 5,454.40 50,682.38 19.6%

Oakland 1,168.88 4,535.97 7,975.70 31,088.00 44,768.55 17.3%

St. Clair 21,668.47 563.69 2,076.48 3,812.60 28,121.24 10.9%

Washtenaw 1,051.71 1,056.74 3,203.29 9,962.20 15,273.94 5.9%

Wayne 20,778.21 6,039.67 13,576.69 43,981.40 84,375.97 32.7%

Lenawee 133.35 454.13 1,124.41 2,118.44 3,830.32 1.5%

Total 89,630.34 18,212.94 41,019.99 130,165.33 279,028.59 100.0% 

Table 4 

VOC Emissions in Southeast Michigan, and Lenawee (Tons/Yr) 

County Point Area Non-road On-road Total % of Total 

Livingston 177.14 4,338.29 1,950.70 1,696.90 8,163.03 4.8%

Macomb 2,310.72 11,807.62 5,025.52 5,784.70 24,928.56 14.7%

Monroe 3,856.65 3,663.62 1,955.24 1,742.60 11,218.11 6.6%

Oakland 2,495.69 17,387.40 9,955.41 11,918.00 41,756.50 24.7%

St. Clair 1,664.49 2,671.18 2,209.44 1,550.90 8,096.01 4.8%

Washtenaw 388.83 5,406.23 2,652.13 3,349.70 11,796.89 7.0%

Wayne 6,494.98 24,887.81 8,856.99 16,931.10 57,170.88 33.8%

Lenawee 272.10 3,205.00 1,031.49 1,471.74 5,980.34 3.5%

Total 19,368.09 83,942.61 37,598.19 54,411.41 195,320.29 100.0%

 Source for Tables 2 and 3: Michigan’s 2005 base year inventory, on-road emissions for the SEMCOG 

area generated by SEMCOG. 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 8 

Table 5 

Population of Southeast Michigan and Lenawee, 2000-2007 

County 

2000 

Population 

2007 

Population Population Change 

Growth 

Rate (%/yr) 

Percent of 2007 

Total Pop. 

Livingston 156,951 183,194 26,243 2.2 3.3 

Macomb 788,149 831,077 42,928 0.7 15.1 

Monroe 145,945 153,608 7,663 0.7 2.8 

Oakland 1,194,156 1,206,089 11,933 0.1 21.9 

St. Clair 164,235 170,119 5,884 0.5 3.1 

Washtenaw 322,895 350,003 27,108 1.1 6.4 

Wayne 2,061,162 1,985,101 -76,061 -0.5 36.0 

Lenawee 98,890 101,243 2,353 0.3 1.8 

Total 5,456,428 5,507,161 50,733 0.1 100 

 Source: U.S. Census 

Table 6 

Population Density 

County 2000 Pop./sq. mi.

Livingston 276.1 

Macomb 1,640.5 

Monroe 264.8 

Oakland 1,368.6 

St. Clair 226.7 

Washtenaw 454.8 

Wayne 3,356.1 

Lenawee 131.8 

 Source: U.S. Census 

Table 7 

Lenawee County-2000 Urban/Rural Split 

 # of persons in urban area 45,355 45.9% 

 # of persons in rural area 53,535 54.1% 

TOTAL 98,890 100.0% 

 Source: U.S. Census 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 9 

Table 8 

Southeast Michigan County-to-County Commuting Data 

Work In County 

Lenawee Livingston Macomb Monroe Oakland St. Clair Washtenaw Wayne Total 

Lenawee 31,063 113 54 1,074 504 14 7,008 1,208 41,038 

Livingston 98 33,845 1,002 82 17,064 26 11,033 10,549 73,699 

Macomb 85 458 224,720 235 94,376 2,941 952 56,211 379,978 

Monroe 817 1,332 369 35,202 1,256 44 4,587 12,161 55,768 

Oakland 145 4,484 41,935 565 429,030 583 6,723 106,405 589,870 

St. Clair 52 52 17,967 57 4,038 48,324 122 3,522 74,134 

Washtenaw 872 2,250 715 1,085 6,864 93 129,808 23,269 164,956 

Wayne 423 2,469 44,064 4,111 124,137 759 25,015 618,405 819,383 

Live In 

Total 33,555 45,003 330,826 42,411 677,269 52,784 185,248 831,730 2,198,826 

Source: U.S. Census Bureau, 2000 Journey-to-Work (CTPP) data 

Table 9 

Summer Daily Vehicle Miles Traveled 

Year Lenawee SEMCOG area 

2000 2,362,255 

2005 2,506,136 147,312,316

2010 2,684,798 151,834,658

2015 2,800,613 156,638,125

2020 2,901,403 160,221,828

2025 3,036,161 163,374,474

2030 166,909,207

Source: SEMCOG 2030 Regional Transportation Plan and Lenawee County provided 

by Michigan Department of Transportation. 

Table 10 

Journey to Work Data from the 2000 U.S. Census 

County # of workers in 

county 

# of workers who drive 

to SEMCOG area 

% workers who drive 

to SEMCOG area 

% of workers in 

SEMCOG area from 

county* 

Lenawee 45,822 9,975 21.8 0.5 

*The total number of workers in the 7-county SEMCOG area is 2,208,906
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS March 12, 2009 

Page 10 

Table 11 

Population Projections for Southeast Michigan and Lenawee 

County 

2000 

Census 2005 2010 2015 2020 2025 2030 

Livingston 156,951 181,501 193,740 197,228 200,639 205,602 210,346 Macomb 788,149 829,765 854,626 867,339 877,357 890,013 906,895 Monroe 145,945 153,785 156,264 156,652 159,461 163,709 167,588 Oakland 1,194,156 1,214,481 1,226,169 1,235,849 1,249,154 1,272,065 1,303,678 St. Clair 164,235 171,471 173,122 176,030 180,294 185,038 189,280 Washtenaw 322,895 341,810 349,673 353,327 356,560 361,715 369,463 Wayne 2,061,162 1,998,226 1,905,706 1,837,542 1,812,593 1,811,244 1,824,113 Detroit 951,270 890,963 821,798 769,423 741,934 725,914 715,601 Balance Wayne 1,109,892 1,107,263 1,083,908 1,068,119 1,070,659 1,085,330 1,108,512 Lenawee 99,039 100,568 101,347 103,077 105,849 

Source: 2035 Forecast for Southeast Michigan, SEMCOG, April 2008 Lenawee Source: April 2003 REMI Model (Regional Economic Models, Inc.) results provided by the University of Michiga

Department of Transportation. 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 11 

Table 12 

Projection of Total Employment for Southeast Michigan and Lenawee County 

Year 

% 

Change 

County 2005 2010 2015 2020 2025 2030 2035   

Livingston 65,603 69,259 74,365 78,720 81,853 84,620 87,323 33.1 

Macomb 380,964 374,561 379,326 385,602 389,312 393,282 397,847 4.4 

Monroe 52,850 83,479 55,635 56,937 57,600 58,162 58,975 11.6 

Oakland 867,687 871,043 897,957 921,811 936,053 947,778 964,418 11.2 

St. Clair 62,384 65,188 68,123 70,113 71,661 73,165 74,890 20.1 

Washtenaw 231,722 243,605 254,985 263,814 271,611 277,521 285,914 23.4 

Wayne 932,480 909,527 908,457 913,495 909,268 905,452 907,973 -2.6 

Detroit 342,241 326,615 322,879 320,536 315,078 309,926 307,014 -10.3 

Balance 

Wayne 590,239 532,912 585,578 592,959 594,190 595,526 600,959 1.8 

Lenawee 50,880 53,405 54,325 54,428 54,568    7.2 

Source: SEMCOG 2035 Regional Development Forecast, April 2008, and Lenawee County’s numbers 

are from the 2003 REMI model results provided by the University of Michigan and Michigan 

Department of Transportation. 

Figure 4 

Southeast Michigan Urbanized Area 
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 12 

Figure 5 

0.08 ppm NAAQS Ozone Designations

June 15, 2004

 

Attainment 

Nonattainment 

Monitor Site Met 8-hr 

Monitor Site Violated 8-hr
Michigan’s Recommended Designations 

 for the 0.075 ppm Ozone NAAQS 

March 12, 2009 

 Page 13 

Figure 6 

M 

VAN

BUREN

BERRIEN CASS

ST. 

JOSEPH

KALAMAZOO

CALHOUN

BARRY EATON INGHAM LIVINGSTON OAKLAND

MACOMB

MONROE

WASHTENAW

BRANCH HILLSDALE LENAWEE

ALLEGAN

JACKSON

WAYNE

MANISTEE

MASON LAKE OSCEOLA

WEXFORD

OCEANA

NEWAYGO

MECOSTA

CLARE GLADWIN

MIDLAND BAY

EMMET

CHEBOYGAN

PRESQUE ISLE

ANTRIM OTSEGO

MONTMORENCY

ALPENA

KALKASKA OSCODA ALCONA

CRAWFORD

BENZIE

MISSAUKEE

ROSCOMMON

OGEMAW

IOSCO

HURON

TUSCOLA SANILAC

ST. CLAIR

ISABELLA

LEELANAU

BARAGA

DELTA

IRON

ALGER

SCHOOLCRAFT

LUCE CHIPPEWA

MACKINAW

GOGEBIC

ONTONAGON

HOUGHTON

KEWEENAW

MENOMINEE

MARQUETTE

CHARLEVOIX

KENT

OTTAWA

MUSKEGON

IONIA SHIAWASSEE

GENESEE LAPEER

CLINTON

MONTCALM SAGINAW

ARENAC

7-03 

GRATIOT

GRAND

TRAVERSE

DICKINSON

MICHIGAN