(217) 785

- 4140

(217) 782

- 9143 (TDD)

March 9, 2009

Mr. Bharat Mathur, Acting Regional Administrator Office of the Regional Administrator USEPA Region 5, R19J 77 West Jackson Boulevard Chicago, I llinois 60604

- 3507

Dear Mr. Mathur:

On behalf of Govern or Quinn, and p ursuant to the U.S. Environmental Protection Agency’s revision to the National Ambient Air Quality Standards (NAAQS) for ozone dated March 12, 2008, I am submitting our recommendations for attainment and nonattainment designations for the St ate of Illinois. I ncluded with Illinois’ recommendations is a supporting document prepared by the Illinois Environmental Protection Agency (I llinois EPA). The I llinois EPA will also provide this document to your staff in electronic format to facilitate y our timely review.

Specifically, the following designations are recommended for Illinois:

Cook Nonattainment Chicago
DuPage Nonattainment Chicago

Kane Nonattainment Chicago

Lake Nonattainment Chicago

Will Nonattainment Chicago

McHenry Nonattainment Chicago

Kendall: Oswego Township All Other Townships Nonattainment Attainment Chicago

Grundy: Aux Sable Township Goose Lake Township All Other Townships Nonattainment Nonattainment Attainment Chicago

Chicago

Madison Nonatta inment Metro

- East

Monroe Nonattainment Metro

- East

St. Clair Nonattainment Metro

- East

All Other Counties AttainmentWe are recommending that portions of the Chicago and Metro

- East metropolitan areas be designated as

nonattainment for the revised 8

- ho ur ozone NAAQS. As violations of the revised ozone standard have been measured in these areas during 2006

- 2008, designating them as nonattainment is appropriate. The remainder of Illinois is attaining the revised ozone standard and should, therefore, be designated as attainment.

The recommended nonattainment boundaries are the same as the boundaries established pursuant to the 1997 revisions of the ozone NAAQS, with the exception of Jersey County. We are recommending that Jersey County, which is locat ed in the Metro

- East area in southwestern Illinois, be designated as attainment for the revised ozone standard even though it is currently designated nonattainment for the 1997 version of the standard. Jersey County is rural, with virtually no emission so urces, and does not contribute to nearby nonattainment areas. Jersey County was included in the nonattainment area established in 2004 because violations of that standard were measured in 2001

- 2003 at I llinois EPA’s monitoring station located in Jerseyvil le. Based on 2006

- 2008 data, the monitoring station located in Jerseyville is attaining not just the level of the standard established in 1997, but it is attaining the level of the revised standard as well.

If there ar e any questions, please feel free to contact me or Laurel L. Kroack, Chief of the Bureau of Air at I llinois EPA.

Very truly yours

,

Douglas P. Scott Director

cc: Cheryl Newton, Acting Chief Air and Radiation Division U.S. Environmental Protection Agency, Region 5

Attachment

## Technical Support Document f or Recommended Nonattainment Boundaries in Illinois

f or t he 8

- hour Ozone National Ambient Air Quality Standard

AQPSTR 0 9

- 0 1

March 9 , 2009

Illinois Environmental Protection Agency Division of Air Pollution Control 1021 North Grand Avenue East P.O. Box 19276 Springfield, IL 62794

- 92762 

### Table of Contents

Tables................................................................................................ 4
Figures...........................................................................

.................... 5

Introduction

......................................................................................... 6

Federal Guidance

................................................................................... 7
Nine Factor Analysi s.............................................................................. 9
Air Quality Data

.................................... ........ ......... .... ........................ ... 9

Emissions Data

.................................... ... .. ............ ...... ..................... . ... . 12
Population Density and Urbanization..........

.............................. ....... .. ....... .... 14

Growth Rates and Patterns...............................................................

...... .. . 17
Traffic and Commuting Patterns

............................................................ ... . . 18
Topograph y..................

...... ............................................................ ..... . 20

Jurisdictional Boundaries...................................................................

.. ... . . 21
Meteorology

................................................................................. ... ..... 21

Level of Control of Emission Sources

............................................. ... ...... ... .. 22

Recommendation s........................................................................

... ....... 2 4
Chicago Metropolitan Area

...... ...... ...................... ............ . ................. . ...... . ... .. 24
Cook County

........................................................................ ... ..... 24

Lake Count y........................................................................

... ..... 25

DuPage and Will Counties

......................................................... ...... 25
McHenry and Kane Counties

...................................................... ...... 25

DeKalb and Kankakee Counties

................................................... ..... 26
Grundy and Kendal l Counties......................................................

.... 26

St. Louis Metropolitan Area.........

............................. ......... ..... ................... ... 26
Madison County

..................................................................... ...... 26

St. Clair Count y.......................................

.............................. ...... 27

Monroe County

........................................................................ .... 27

Jersey County

........................................................................ ...... 27

Clinton Count y........................................................................

..... 283

Randolph County

..................................................................... .... 28
Macoupin , Bond and Calhoun Counties

.......................................... .... 28

Montgomery Count y............

...................................................... .... 29
Washington County

.................................................................. .... 29

Remainder of Illinoi s

........................................................................ ...... 304 

### Tables

Table 1 Counties Included in the Chicago CSA and St. Louis MSA.................... 8

Table 2 2006

– 2008 8

- Hour Ozone Design Values in Illinois (ppb).................. 11

Table 3 Population and Population Density Estimates by County

Chica go CSA (Illinois Counties Only) St. Louis MSA and Adjacent Counties (Illinois Counties Only)...

... ... 15

Table 4 Average Daily Vehi cles Miles Traveled for Selected Counties

from Illinois Travel Statistics 2007..........................................

. 18

Table 5 Recommended Attainment/Nonattainment Designations in Illinois

f or the 8

- Hour Ozone National Ambient Air Quality Standard.........

.. 31

Table 6: 8

- Hour Ozone Boundary Recommendations Nine Factor Documentation... 325 

### Figures

Figure 1 Proposed Illinois 8

- Hour Ozone Nonattainment Areas within CSA/MSA Figure 2 Illinois 8

- hour Ozone Design Values 2006

- 2008 Figure 3 2006

- 2008 Lake Michigan 8

- Hour Ozone Design Values Figure 4 2006

- 2008 St. Louis, MO 8

- Hour Ozone Design Values Figure 5 a 2005 NOx Emissions by County for the Chicago CSA (Tons/Day) Figure 5b 2005 VOC Emissions by County for the Chicago CSA (Tons/Day) Figure 6a 2005 NOx Emissions by County for St. Louis MSA (Tons/Day) Figure 6b 2005 VOC Emissions by County for St. Louis MSA (Tons/Day) Figure 7a Major NOx Point Sources

– 2005 Emissions for Chicago CSA Figure 7b Major VOC Point Sources

- 2005 Emissions for Chicago CSA Figure 8a Major NOx Point Sources

– 2005 Emissions for St. Louis MSA Figure 8b Major VOC Point Sources

– 2005 Emissions for St. Louis MSA Figure 9 Population Density (2007) by Census Tract in the Chicago CSA Figure 10 Population Density (2007) by Census Tract in the St. Louis MSA Figure 11 Urban Areas within Chicago

- Naperville

- Michigan City, IL

- IN

- WI Combined

Statistical Area (C SA ) Figure 12 Urban Areas with in St. Louis MO

- IL MSA and Adjacent Counties Figure 13 Land Cover in the Chicago

- Naperville

- Michigan City IL

- IN

- WI CSA (I llinois

Part) Figure 14 Land Cover in the St. Louis MO

- IL MSA and Adjacent Counties (Illinois Part) Figure 15 2000

- 2007 Population Change by County Chicago CSA (Illinois Part ) Figure 16 200 0

- 2007 Population Change by County St. Louis MSA (Illinois Part)
F igure 1 7 Population Projections Total Populatio n by County Change from 2000

- 203 0 Figure 18 Occupational Employment Projections by County

- Change from 2004

- 2014 Figure 19 200 7 Average Daily Vehicle Miles Traveled (ADVMT) in the Chicago Area Figure 20 2007 Average Daily Vehicle Miles Traveled (ADVMT) in the St. Louis Area Figure 21 Average Daily VMT in the Chicago NAA, 1990

– 2007 Figure 22 Average Daily VMT in the Metro

- East NAA, 1990

– 2007 Figure 23 Where People Reside and Counties Where they Journey to Work Chicago CSA

Counties Figure 24 Where People Reside and Counties Where they Journey to Work St. Louis MSA

and Adjacent Counties Figure 25 Topography Figure 26 Chicago Area Pollution Rose 2006

– 2008 (All Sites) Figure 27 Metro

- East Pollution Rose 2 006

– 2008 (All Sites) Figure 28 Proposed 8

- Hour Ozone Nonattainment Areas6

Introduction

On March 12, 2008, U.S. Environmental Protection Agency (U.S. EPA) revised the ozone National Ambient Air Quality Standard (NAAQS) in response to numerous studies which link
the health effects associated with ozone exposure to increases in mortality, as well as

cardiovascular and respiratory health effects. The primary ozone standard was strengthened

from 0 .08 parts per million (ppm)

, set in 1997 to a level of 0.07 5 ppm (73 FR16436; March 27,
2008)

. U.S. EPA also strengthened the secondary ozone standard to provide increased
protection against adverse public welfare effects including im pacts on vegetation. This standard
is identical to the primary standard (0.075 ppm). Following the promulgation of a new or revised
air quality standard, the Clean Air Act (CAA) requires the Governor to recommend initial
designations of the attainment sta tus for all areas of the State. Areas can be classified as

nonattainment (does not meet, or contributes to a nearby area that does not meet the NAAQS),

attainment (meets the NAAQS), or unclassifiable (cannot be classified based on available data).

Illino is is, therefore, required to provide recommendations for attainment/nonattainment area

boundaries for the new 8

- hour ozone standard. The U.S. EPA will act on the St ate’s
recommendations by either affirming and promulgating the recommended designation

bou ndaries, or by promulgating new designations.

This report provides the basis for recommendations by the Illinois Environmental Protection
Agency ( IEPA ) for attainment/nonattainment designation boundaries for all areas in the State of

Illinois for the 8

- ho ur ozone standard

. Based on the most recent three years of ambient
monitoring data (200 6

- 200 8 ), only two counties in Illinois are currently violating the 8

- hour

o zone NAAQS, Cook and Madison c ounties. Based on an analysis of the factors contained in
federal guidance

, the IEPA is recommending that portions of the Chicago and Metro

- East
metropolitan areas be designated as nonattainment for the 8

- hour ozone standard. The
recommended boundaries also reflect U.S. EPA guidance “to show that: 1) violations are not
occurring in the excluded portions of the recommended area and 2) the excluded portions do not

contain emission sources that contribute to the observed violations.” The remaining areas of

Illinois should be classified as attainment areas for the o z one standard (Figure 1)

.7

Federal Guidance

IEPA initially relied on guidance memorandum s issued by U.S. EPA on March 28, 2000 and
April 1, 2003 for developing this recommendation for establishing the geographic boundaries of

nonattainment areas (NAA) for the 8

- hour ozone standard. In these guidance document s , U.S.

EPA recommend ed that areas with air quality data showing violations of the 8

- hour NAAQS,
and nearby areas that cause or contribute to NAAQS violations, be designated nonattainment.

Due to the pervasive nature of ground level ozone

, and transport of ozone and its precursors over
large geographic areas, U.S. EPA also recommends that Metropolitan Statistical Areas (MSAs)

, as well as Core Based Statistical Areas (CBSAs) or Combined Statistical Areas (CSAs)

, as defined by the Office of Management and Budget (OMB)

, associated with the violating
monitor(s) serve as the starting point or “presumptive” boundary of 8

- hour ozone NAAQS. U.S.

EPA published updated guidance on December 4, 2008. This gui dance follows the same
conceptual approach as the March 2000 and April 2003 guidance in that it recommends

pres umptive boundaries based on CSA and CBSA defined statistical areas.

The proposed ozone nonattainment area boundaries are shown in Figure 2 and a re included
within the boundaries of the Chicago

- Naperville

- Michigan City, IL

- IN

- WI Combined Statistical
Area (Chicago CSA) and St. Louis MO

- IL Metropolitan S tatistical Area (St. Louis MSA) . For
the purpose of this analysis, the St. Louis MSA counties in Illinois are consistent with the CSA

boundaries included in the St. Louis, St. Charles

- Farmington, MO

- IL CSA. A listing of the
counties comprising the Ch icago CSA a nd the St. Louis, St. Charles

- Farmington, MO

- IL CSA

are included in Table 1. Of these stat istical areas, only those counties in Illinois are represented
as part of this analysis.8 TABLE 1 COUNTIES INCLUDED IN THE CHICAGO CSA AND ST. LOUIS MSA *

Chicago

- Naperville

- Michigan City (IL

- IN

- WI)

Combined Statistical Area St. Louis, St. Charles

- Farmington, MO

- I L CSA

Cook County, IL Bond County, IL DuPage County, IL Calhoun County, IL Lake County, IL Clinton County, IL Kane County, IL Jersey County, IL Will County, IL Macoupin County, IL DeKalb County, IL Madison County, IL McHenry County, IL Monroe County, IL Kankakee County, IL St. Clair County, IL Kendall County, IL Grundy County, IL Crawford County (Sullivan City), MO Lake County, IN Jefferson County, MO Porter County, IN Lincoln County, MO Jasper County, IN St. Charles County, MO Newton County, IN St. Louis County, MO LaPorte County, IN Warren County, MO

Kenos h a County, WI Washington County, MO St. Louis City, MO
Franklin County, MO
St. Francois County , MO

* Bold Face County Names represent Counties in St. Louis, MO

- IL MSA

Metropolitan areas defined by U.S. Office of Mana gement and Budget, November 20, 2007 Website: http://www.census.gov/population/www/metroareas/metrodef.html

S tates may request non attainment area boundaries that are smal ler than the existing CSA or
CBSA (MSA) boundaries where counties, or portions of counties are rural and do not contribute

to non attainment based on nine factors. The nine factors are liste d below. States may also
request nonattainment area boundaries that are larger than the current CSA/CBSA or MSA to
include adjacent counties when those counties contain emission sources, population, growth,
commuting patterns and other factors that may con tribute to the non attainment problem. The
IEPA’s analysis of each of the nine factors is provided in the following sections of this report.9

Nine Factor Analysis

U.S. EPA recommends that States and Tribes consider the following nine factors in assessing
whether to include an area in the designated nonattainment area boundary:

Air quality data

Emission data

Population density and degree of urbanization

Growth rates and patterns

Traffic and commuting patterns

Geography/topography

Jurisdictional Boundaries

Meteorology (weather/transport patterns)

Level of control of emission sources

Air Quality Data

The 8

- hour ozone design values (i.e., the average of the fourth highest values from each of three
consecutive years of data at a given ambient monito r) derived from ozone measurements
collected from IEPA’s ambient air monitoring network from the most recent 3

- year period of
record (2006

- 2008) are summarized in Table 2 and Figure 2. As shown in Table 2 and Figure 2,
IEPA’s monitoring data indicate that violations of the 8

- hour ozone standard have been
measured in both the Chicago an d Metro

- East metropolitan areas . The rest of Illinois currently

meets the 8

- hour standard, although occasional exceedances have been recorded at almost all
monitoring sites statewide due to the pervasiveness of ozone transport. Violations of the 8

- hour
standard within the Chicago and Metro

- East areas have been measured at only a few locations.
In the Chicago area, measured design values from the 2006

- 2008 period exceed the NAAQS at
only one monitoring station located in Cook County. In the Metro

- East area, design values
exceeding the NAAQS have been measured in Madison County during this 3

- year period.
Ozone air quality data collected in Illinois, therefore, indicate that it is appropriate to designate at
least portions of the Chicago and Metro

- East metropolitan areas as nonattainment areas for the10

8

- hour ozone standard. The remaining portions of Illinois should be designated attainment for

the 8

- hour ozone standard.

F igures 3 and 4 depict ozone design values for 2006

- 2008 in the Lake Michigan and St. Louis
areas, respectively. In both areas, ozone design values of greater magnitude and broader spatial
extent occur in neighboring states than are observed in Illinois.11 

### Table 2 2006

- 2008 8

- Hour Ozone Design Values in Illinois (ppb)

4th High 2006

- 2008 8

- Hour Values 8

- hr AQCR County Site Address 2006 2007 2008 Average Chicago Metropolitan Area
67 Cook Alsip 4500 W 123 rd St 78 85 66 76 67 Cook Chicago

- ComEd 7801 Lawndale 75 80 66 73 67 Cook Chicago

- Jardine 1000 E. Ohio 65 75 63 67 67 Cook Chicago

- SWFP 3300 E. Cheltenham 75 82 67 74 67 Cook Chicago

- Taft 6545 W. Hurlburt 77 79 64 73 67 Cook Chicago

- University 5720 S. Ellis 70 79 63 70 67 Cook Cicero 1830 S. 51st Ave 60 68 60 62 67 Cook Des Plaines 9511 W. Harrison St. 65 78 57 66 67 Cook Evanston 531 Lincoln 72 80 58 70 67 Cook Lemont 729 Houston 70 85 71 75 67 Cook Northbrook 750 Dundee Rd 68 76 65 69 67 DuPage Lisle Morton Arboretum 62 72 57 63 67 Kane Elgin 665 Dundee 62 75 61 66 67 Lake Waukegan Golf & Jackson 71 81 63 71 67 Lake Zion Camp Logan 68 80 69 72 67 McHenry Cary 1st St. & Three Oaks 57 74 65 65 67 Will Braidwood 36400 S. Essex Rd 68 71 60 66
Metro

- East
70 Madison Alton 409 Main St. 79 81 68 76 70 Madison Maryville 200 W. Division 77 87 70 78 70 Madison Wood River 54 N. Walcott 77 86 67 76 70 Randolph Houston Hickory Grove & Fallview 72 79 65 72 70 St. Clair East St. Louis 13 th & Tudor 77 77 64 72 75 Jersey Jerseyville Liberty St. 75 75 69 73
Rest of Illinois
65 Peoria Peoria Hurlburt & Mac Arthur 67 74 60 67 65 Peoria Peoria Hts 508 E. Glen 70 81 67 72 66 McLean Normal Main & Gregory 72 75 67 71 66 Champaign Champaign 606 E. Grove 64 71 60 65 69 Rock Island Rock Island 32 Rodman Ave. 70 71 58 66 73 Winnebago Loves Park 1405 Maple 63 73 60 65 74 Effingham Effingham Route 45 South 67 78 63 69 74 Hamilton Knight Prairie State Route 14 66 76 66 69 75 Adams Quincy 732 Hampshire 71 75 65 70 75 Macon Decatur 2200 N 22nd St. 71 77 85 71 75 Macoupin Nilwood Heaton & DuBois 70 75 65 70 75 Sangamon Springfield 2875 N. Dirksen 66 72 59 65 Note: The Quincy ozone monitor was moved in 2007. Data for 2006 is from the old AIRS site 170010006; data for 2007 and 2008 was collected at the new AIRS site 170010007.12

Emission s Data

U.S. EPA recommends that proposed nonattainment designations for the new 8

- hour NAAQS
reflect not only the areas of measured violations, but also the nearby areas that contribute to

measured violations. Ozone is a secondary pollutant formed by chemical reaction s from

emissions of oxides of nitrogen (NOx) and v ola tile o rganic c ompounds (VOCs) that occur in the
atmosphere in the presence of sunligh t. These pollutants are referred to as precursors of o zone

. IEPA e missions data for NOx and VOC for 2005 are s ummarized in de sc ending order by county
for point, area, non

- road and on

- road (mobile) source categories in Figures 5 and 6

.

A point source is defined as a source whose emissions are generally discharged through stacks

, Area sources are defined as emissions that are spread over wide areas with no distinct discharge

p oints (e.g. forest fires) , or ones that are comprised of a large number of small point sources that

are dif ficult to describe separately (e.g. residential fuel combustion ) . On

- road mobile sources are

classified as emissions from cars, trucks, buses, and m otorcycles that are used for transportation
of goods and passengers on streets and roads. Mobile non

- road sources are characterized by
emissions from other modes of powered transportation, such as airplanes, trains, ships, and off

highway motor vehicles.

Figures 5 a and 5 b , a long with the accompanying tables, summarize IEPA’s 2005 estimated
emissions from point, area , non

- road and on

- road/ mobile sources in the Chicago CSA for NO
x and VOC s

. Figures 6 a through 6 b provide similar information for the St. Louis MSA , including
the adjacent counties of Randolph , Montgomery, Washington

. Note that the Randolph County

emissions for VOC, and NO x reflect 200 5 reported emissions from the Baldwin power plant , as it
is the only major contributing source in Baldwin T ownship of Randolph County.

For the Chicago CSA Counties (Figures 5 a

- 5 b ):

NO x emissions are highest in Cook County with the greatest emissions from on

- road

sources

. Cook County contributes about 47 % of total NO
x emissions in the Chicago CSA

counties. NO x emissions in Will, DuPage, and Lake Counties are also relatively high

.13

Kendall, Grundy and DeKalb counties have relatively low emissions , which combined
amount to approximately 5% of total NO
x emissions

. VOC emissions are highest in Cook County , with the greatest emissions coming from

area sources

. VOC e missions from Cook County are approximately 5 3 % of the total

VOC emissions in the area. DuPage

, Lake and Will c ounties also have relatively high

VOC emissions. VOC emissions are lowest in DeK alb

, Kendall and Grundy counties ;

these counties combined contribute approximately 5 % of total VOC emissions in the

area

.

For the St. Louis MSA and Adjacent Counties (Figures 6 a

- 6 b ):

NO x emissions are highe st in Madison

, Montgomery, St. Clair, and Randolph c ounties.

Combined NO
x emissions from Madi son, Montgomery, St. Clair and Randolph c ounties

contribute about 77 % of total NO
x emissions within the area. The greatest source

contributors to the total NO x emissions for Mad ison, Montgomery, and Randolph

c ounties are point sources, whereas the greatest source contributions in St. Clair C ounty

comes from on

- road sources. Washington , Bond, Jersey, and Calhoun c ounties have
relatively low emissions ; combined th ey contribute to nearly 10% of total NO
x emissions

. VOC emissions are hi ghest in Madison and St. Clair c ounties

, and account for nearly

5 2 % of total VOC emissions. In contrast, Clinton, Macoupin, Randolph, Montgomery,

and Monroe VOC emissions contribute to 3 3 % of total VOC emissions for the area. Area
sources are the major contributor towards total VOC emissions f or 2005. VOC emissions

are lowest in Calhoun and Bond c ounties

, with combined emissions contributing
approximately 7% of total VOC emissions

.

Figures 7 a through 7 b depict both the locations and emission rates of major point sources in the
current Chicago CSA for NO x and VOCs. . Emission totals are based on IEPA reported

emissions for 2005 . The orange solid shaded areas in the figures represent the areas being

recommended as nonattainment for the new 8

- hour ozone and counties bordered in blue14

represent counties included in the CSA/MSA where emission sources are e valuated as
contributing to non attainment

. Figures 8 a and 8b provide similar information for St. Louis MSA.
Additional counties adjacent to the St. Louis MSA which are included in this analysis are
Montgomery, Washington

, and Randolph counties.

For th e Chicago CSA (Figures 7 a

- 7 b), t he largest point sources for NO
x are located in Will
County. Cook and Lake c ounties also contain major point sources contributing NO x emission s

. In comparison, Kankakee, Kendall, DeKalb, and Grundy c ounties have relatively few point
sources emitting NO
x with contributions only representing approximately 8% of total NO x
emissions. Both the largest size and greatest number of VOC point sources occur in Cook

, Will

, and Grundy c ounties

. In comparison, DeKalb, Kankakee and Kend all c ounties have relatively
few VOC point sources.

For the St. Louis MSA (Figures 8 a

- 8 b), t he largest point sources for NO
x are l ocated in Madison

, Montgomery and Randolph c ounties . Madison and St. Clair c ounties have the largest number of

NO x emitting point sources , most emitting less than 100 tons per year

. Adjacent counties have
relatively few point sources emitting NO
x . The largest emitting and greatest number of point
sources emitting VOC’s are lo cated in Madison and St. Clair c ounties. Adjacent counties have
relatively few point sources emitting VOC’s.

Population Density and Urbanization

Table 3 lists the population of each of the counties contained in the Chicago CSA and

St. Louis MSA, as well as land areas, and population densiti es based on U.S. Census Bureau

estimates for 200 7

. Figures 9 and 10 graphically depict population densities in the Chicago CSA

and the St. Louis MSA, respectively. For the Chicago area, Cook, DuPage, Lake, and Will

c ounties have the highest population and high population densities, while DeKalb and Grundy
County have the lowest. Madison and St. Clair counties contain the majority of the Metro

- East
population, w hile Bond, Washington and Calhoun counties are considerably less populated

.15 

### TABLE 3

POPULATI ON and POPULATION DENSITY

ESTIMATES BY COUNTY

Chicago CSA (Illinois Counties Only)

County Population 2007 Land Area (Square Mile) Population Density

(Persons per Sq. Mile) Cook 5,285,107 945.68 5,589 DuPage 929,192 333.61 2,785 Lake 710,241 447.56 1,587
Kane 501,021 520.44 963 Will 673,586 836.94 805 McHenry 315,943 603.51 524 Kendall 96,818 320.58 302 Kankakee 110,705 676.75 164 DeKalb 103,729 634.16 164 Grundy 47,144 419.9 112



### St. Louis MSA and Adjacent Counties

(Illinois Counties Only)

*Counties not included in St. Louis MO

- IL MSA Source: U.S. Census Bureau estimate as of July 1, 200 7

, at http://factfinder.census.gov/ Source: U.S. Census Bureau’s State and County Quick Facts County Population 2007 Land Area (Square Mile) Population Density

(Persons per Sq. Mile) St. Clair 261,316 663.81 394 Madison 267,347 725.02 369 Clinton 36,450 472.23 77
Monroe 32,372 388.29 83 Jersey 22,455 369.16 61 Randolph * 32,760 578.42 57 Macoupin 48,235 863.57 56 Bond 18,103 380.2 48 Montgomery * 29,810 703.8 42 Washington * 14,769 562.61 26 Calhoun 5,167 263.62 2016

Figure 11 illustrates the extent of the urbanized area within the Chicago CSA. According to the

U.S. Census Bureau, MSA an d CSA boundaries are dependent on a central urbanized area or
contiguous area of relatively high population density. Outlying counties are included in MSAs if
they exhibit strong social and economic ties to this core area, often measured by commuting and
economic patterns. Therefore, it is logical to conclude that the urbanized area in Boone C ounty
is not directly influencing emissions in the Chicago CSA. A pattern of fragmented urban
development and commuting is also apparent in DeKalb, Kankakee and par ts of Grundy

count ies

. County urban extents are not contiguous with the Chicago CSA

.

In the St. Louis MSA and adjacent county area, urbanization is not as pronounced as seen in the
Chicago CSA (See Figure 12). Madison and St. Clair counties are the most urbanized of the

counties in the Metro

- East portion of the S t. Louis MSA. Adjacent counties such as Washington,

Montgomery and Randolph are not included in the St. Louis MSA and exhibit a fragmented
population with the Metro

- East urban core. Based on th e non

- contiguous pattern of
urbanization, it is logical to conclude that Washington

, Montgomery

, and Randolph counties are
not influencing emissions related to social, economic and population growth in the Metro

- East.

Figures 13 and 1 4 depict current land cover for both the Chicago CSA and St. Louis MSA areas based on data compiled by the Illinois Department of Agriculture . According to the “Land

Cover of Illinois 1999

- 2000 On

- Line Statistical Summary”

, the Chicago CSA has the most

urb anized counties in the state. A high degree of urbanization is apparent in both Cook (79.9%)
and DuPage (77.5%) c ounties

. Lake C ounty is also highly urban , with 48.3% of the county

classified as urban or built

- up land. In each of the Chica g o area counti es of Kane, Will and
McHenry the land cover is dominated by a griculture ranging from 63 to 67% and the amount of

urban and built

- up land is less than 25% of the total land cover. The p rimarily rural counties of
Kendall, DeKalb, Grundy and Kankakee have le ss than 6% urban land; however each county’s
land cover is greater than 80% agriculture

.17

Unlike the Chicago CSA , all nonattain ment counties in the Metro East/St. Louis MSA area have
high per centage of agriculture land (greater than 49 %). Madison and St. Clair c ounties have the
greatest urban land cover in the Metro

- E ast area. ( See Figure 14)

. The counties of Calhoun,
Jersey, Macoupin, Monroe, Bond and Clinton have less than 4% urban built

- up land. The
dominance of agricultural land use, coupled with the low population densities in these counties,
confirm that they are primarily rural in nature.

Growth Rates and Patterns

Short term population growth is an important indicator of potential emission increases in an area.
Figures 15 and 16 outline percent change in population between 2000 and 200 7 by county for
both the Chicago CSA and St. Louis MSA. This data was provided by the U.S. Census Bureau

and is based on estim ates dated March 22, 200 7

. According to the data, t he Chicago CSA count y

of Kendall has experienced the greatest perce nt increase in population at 75.4 % ; however its

total popul ation is relatively small compared to other counties in the CSA. C ook C ounty has
experienced an estimated 2.7 % decrease in population; however its total population for 2007
represents approximately 60 % of the population base in the Chicago CSA area. According to the

U.S Census Bureau , the Metro

- East county of Monroe has experienced the greatest percen t
increase in population at 16.6 %. Jersey Count y has experienced a m oderate population change at

3.7 %

, while Randolph County experienced a loss in total population (

- 3

. 4 %)

.

Population and economic trends are developed for long range planning activities by both State
and local governmental agencies. Data compiled by the Illinois Department of Commerce and
Economic Opportunity (DCEO) were referenced for this analysis and are shown in Figure 1 7

. In
the Chicago CSA, the highest total population growth between 2000 and 2030 is projected to

occur in Cook and Will counties. The lowest growth in terms of net population change is
projected for DeKalb, Grundy, Kendall, and Kankakee counties. In the Metro

- East area, long
term population growth is projected to be highest in Madison, Monroe and Macoupin countie s, and lowest in Randolph, Jersey, Bond, Clinton and Calhoun counties. According to this study,
St. Clair County is expected have a decrease in population in future years.18

Occupational e mployment growth projections between 2004 and 2014 were provided by D CEO

and compiled from projections developed by the Illinois Department of Employment Security,

and are shown in Figure 1 8

. In the Chicago area, the highest rate of occupational employment
growth is expected to occur in Cook and DuPage c ountie s , mod erate increases in employment
are expected to occur for Lake

, Kane and Will c ounties, while the lowest rates of employment
growth are expected in Kankakee, DeKalb, Kendall , and Grundy c ounties. In the Metro

- East
area, moderate employment growth is f orecast for Madison County while r elatively low
employment growth is expected to occur in St. Clair, Monroe, Clinton, Jersey, Bond

, Washington and Macoupin c ounties. Based on this study

, Randolph C ounty is expect ed to
experience job losses in the future.

Traffic and Commuting Patterns

The Illinois Department of Transportation’s (IDOT) Office of Planning and Programming
publishes an annual report entitled Illinois Travel Statistics . This report provides much useful

information on Illinois traffic, including Vehicle Miles Traveled (VMT) data by county, derived
from IDOT’s Traffic Count Program. Tab le 4 and F igures 19 and 20 summarize IDOT’s
estimates of Average Daily Vehicle Miles Traveled (ADVMT) in 2007, as calculated by IDOT’ s Highway Information System.



### Table 4

Average Daily Vehicle Miles Traveled for Selected Counties from Illinois Travel Statistics 2007

Chicago Consolidated Statistical Area (CSA) County Average Daily Vehicle Miles Traveled (ADVMT) Cook 89,983,183 DuPage 23,653,693 Lake 15,747,091 Will 15,583,052
Kane 9,995,846 McHenry 6,071,07119 Kankakee 2,638,934 DeKalb 2,389,212 Kendall Oswego NAA Township 2,150,002 737,471 Grundy Aux Sable NAA Township Goose Lake NAA Township 1,904,904 394,274 47,695

St. Louis Metropolitan Statistical Area (MSA) County Average Daily Vehicle Miles Traveled (ADVMT) Madison 7,943,331 St. Clair 7,507,369 Montgomery* 1,402,503 Macoupin 1,170,604 Clinton 1,098,142 Washington* 1,088,059
Monroe 1,010,593 Bond 803,052 Randolph* 729,219 Jersey 539,760 Calhoun 111,684 * Montgomery, Randolph and Washington Counties are not part of the MSA

County ADVMT is calculated by dividing County Annual VMT by 365, the number of days in a
year (366 in a leap year). The ADVMT on a segment of road is calculated by multiplying the
Average Daily Traffic on the segment by the length of the segment in miles.

In the Chicago area, Cook, DuPage, Lake, and Will counties have the highest ADVMT. In fact,
the ADVMT in these four counties account for approximately 85% of the total for the Illinois
portion of the CSA. Collectively, Kankakee, DeKalb, Kendall, and Grundy counties account for

about 5% of the total ADVMT in the CSA. In the 11 counties listed above, Madison, St. Clair,
and Montgomery Counties have the highest ADVMT, and account for 7 2 % of the VMT in the

11

- county area. Randolph, Jersey, and Cal houn Counties have the lowest VMT, with about 6 %
of the 11 county total VMT

. In addition, VMT has decreased in most of the State in the last few20

years (see Figure 21 and 22 ), and was nearly the same in the existing 8

- hour ozone
nonattainment areas (NAAs) in 2007 as it was in 2002 and 2003.

The U. S. Census Bureau has compiled statistics from the 200 0 census that quantify commuting
patterns in the Chicago and St. Louis metropolitan areas

. Figures 23 and 2 4 illustrate where
people reside and the counties wh ere they journey to work. Each county is color

- coded on the
histograms. For example, Cook County is shown in Figure 23 as a blue bar in each county’s
histogram. The data show that 2.07 million people reside in Cook County and commute within
Cook County to reach their place of employment, but only 826 people reside in Cook County
and commute to DeKalb County for employment. In some counties, a significant percentage of
commuters travel to places of employment in other counties. For example, 1 46,135 resi dents of
DuPage County commute to Cook County for employment. Similarly, a large percentage of
commuters residing in Kendall County travel to Will and Kane c ounties for employment,
although the number of commuters residing in Kendall County is small rel ative to the number of

commuters in the Chicago CSA. From Figure 23

, it is evident that more commuters in the
Chicago CSA travel to places of employment in the county where they reside than travel to other

counties. Commuting patterns in the St. Louis MS A (see Figure 2 4 ) are similar in that more

commuters stay in their residence county for work than commute to surrounding counties.

Topography

Illinois is typified by f

lat to gently rolling terrain

, with the exception of the Driftless A rea in the

northwest corner of the state and the Ozark Plateau in southern portion of the state (see Figure

2 5 ). Illinois occupies a land mass of approximately 55,584 square miles

. The average elevation

of the state is approximately 600 f ee t (183 m) above sea level

. Charle s Mound

, located in Jo
Davies County

, is the highest point in the state with an elevation of 1,235 feet (376 m) above sea

level

. The lowest point in the state is 279 feet (85 m) above sea level along the Mississippi River

in Alexander County

. Total topographic relief across the state is less than 1000 feet

, demonstrating the general flatness of the terrain. Topography is generally not a factor in
determining pollutant transport in Illinois , and is not considered a significant issue in defini ng21

the boundaries of the 8

- hour ozone nonattainment areas.

Jurisdictional Boundaries

Jurisdictional boundaries considered in this analysis are consistent with recommended
geographic boundaries or “presumptive boundary” definitions outlined in the ozone gu idance

documentation. Boundar ies in this study reflect July 2003

, OMB CSA and CBSA boundary

definitions

. Counties within the St. Louis, St. Charles

- Farmington, MO

- IL CSA within the state

of Illinois are consistent with those counties included with the St. Louis MO

- IL MSA.
Additional counties are only included within Missouri under this St. Louis CSA definition.
Proposed boundaries for nonattainment are consistent with existing 8

- hour ozone nonattainment
boundaries (1997 ozone NAAQS) as well as the pr evious 1

- hour ozone NAA boundaries

. Proposed ozone NAA areas in the Chicago CSA are the same as the current PM2.5 NAA

boundaries and the proposed ozone St. Louis NAA include s three of the fo ur counties in the

PM2.5 NAA

. Based on these geographic similar ities it is expected that the coordination of
planning activities required to address nonattainment designations can be carried out in a

cohesive manner

.

Meteorology

Illinois has a temperate climate, with cold winters and hot humid summers

. The seasons are
sharply differentiated between the northern and southern portions of the state , due to its
elongated north

- south orientation. Average winter temperatures are 22°F (

– 6°C) in the north and
37°F (3°C) in the south . Average summer temperatur es are 70°F (21°C) in the north and 77°F
(25°C) in the south. Illinois averages 36 in ches (91 cm) of precipitation a year. A nnual snowfall

of 37 in ches (94 cm) is normal for northern Illinois, decreasing to 1 4 in ches ( 36 cm ) or less in the

southern portions of the state

. The predominant wind direction across the state is from the
south/southwest, with an average wind speed of approximately 11 miles per hour.22

Monitors in the Chicago area that exceed the new o zone design value (200 6

- 200 8 ) show strong
evidence of regional influence s based on previous data analyses and modeling

. Figure 2 6

, contains a pollution rose based on the three year period from 200 6

– 200 8 which supports this
contention. This pollution rose incorporates Alsip wind data for days with monitored

exceedances. Exceedances may occur at one or more monitoring site(s) on a given day. The
length of each blue or red line represents th e percentage of time that the wind blew from a
particular direction on days when o zone concentra tions were > 75 ppb. Based on this

information

, the predominant wind direction ranged from south to southwest on high
concentration days instead of from the urban core to the north.

In the Metro

- East Area, regional influences have been shown through pre vious modeling studies

to be a significant factor contributing to monitored violations of the o zone standard. The
pollution rose for the Metro

- East area representing Edwardsville winds and Illinois Metro

- East

monitor ing sites show s predominant wind directions ranging from south to south

- southeast (see
Figure 2 7 ) on days with elevated levels of o zone

. These wind directions indicate that a
substantial portion of the regional background is coming from sources in the Ohio River Valley

and the southeast ern U.S.

. Meteo r o logy for all Metro

- East sites on high days > 75ppb identifies
the same general wind conditions (see F igure 2 7 ).

Level of Control of Emission Sources

Emission control measures which have been promulgated at the federal and state levels, in

combination with court

- approved consent decrees, have impacted emission levels from a wide
spectrum of emission sectors in the Metro

- East St. Louis area. These have led to significant air
quality improvements. Further emission reductions through planned or pending rulemakings are
expected to enhance these air quality gains. Principal among existing and pending emission
reduction measures include the following:23

E lectricity

- Generating Power Plants Clean Air Act Title IV (Phases I and II)

NOx SIP Call

Illinois Multi

- Pollutant Strategy (MPS/CPS) Clean Air Interstate Rule (CAIR) Dynegy Midwest Generation Consent Decree

Other Stationary Point Sources
NSPS and NESHAPS/M ACT ConocoPhillips Consent Decree NOx RACT Rulemaking (not yet adopted by IPCB)

Area Sources Aerosol Coatings, AIM Coatings, Household and Institutional Consumer Solvents

Portable Fuel Containers

On

- Highway Mobile Sources
Tier 2 Motor Vehicle Standards / Gasoline Sulfur Requirements Heavy

- Duty Engine Standards / Highway Diesel Sulfur Requirements

Reformulated Gasoline Vehicle Inspection & Maintenance Program Evaporative Large Spark Ignition and Recreational Vehicle Standards

Off

- Highway Mobile Sources
Tier 4 Nonroad Diesel Engines / Diesel Sulfur Requirements Marine Compression

- Ignition Standards Locomotive Engine Standards

Permitting activities result in issuance of new construction permits which add to ambient ozone
precursor emission levels. Typically, state

- of

- the

- art emission controls are required on these new
emission sources before they can operate, and thus greatly limit additional ozone precursor
loadings due to new construction. The Prairie State Generating Company, LLC mine

- mouth

coal

- fired pow er plant that is currently under construction in Washington County, Illinois,
underwent a rigorous regulatory review prior to receiving a Prevention of Significant
Deterioration permit. Boiler operations and virtually all other emission sources at this fac ility are
subject to stringent emission control levels. Similarly stringent emission limitations have been24

placed on other new construction and operating permits for industrial facilities in counties
adjoining or within the Metro

- East area.

RECOMMENDATI ONS

The CAA does not specify the geographic boundaries, size, or the extent to which source
contributions would require that an area be designated as nonattainment for the 8

- hour ozone

standard

, nor has U.S. EPA promulgated rules prescribing such. IEPA’s recommendations are

consistent with a guidance memorandum provided by U.S. EPA ( December 4, 2008 ), and are
based on an evaluation of present and projected air quality, the distribution of precursor
emissions, and other factors. The IEPA recognizes that ea ch of the factors considered in this
evaluation are not necessarily conclusive when evaluated individually. Rather, IEPA’s
recommendations are based on consideration of all of the data and projections taken together.

Documentation of data sources utilized in this analysis is shown in Table 6.

IEPA’s recommendations for attainment/nonattainment designations in Illinois for the 8

- hour

o zone ambient air quality standards are contained in Table 7

. Current air quality data collected
by the IEPA indicate that the only areas of Illinois where the 8

- hour ozone air quality standard is
not being met are in portions of the Chicago and Metro

- East metropolitan areas. Nonattainment
designations for at leas t portions of these metropolitan areas are, therefore, warranted. The

IEPA’s recommendation for inclusion of counties within the boundaries of the nonattainment
areas are discussed in the following section and geographically depicted in Fi gure 28

.

Chicag o Metropolitan Area

Cook County : Cook County is the only county in northeastern Illinois where current air quality
data (2006

- 2008) does not meet the 8

- hour ozone standard (Alsip monitor) . Cook County is
currently designated nonattainment for the existing 8

- hour ozone standard as well as the previous

1

- hour ozone standard. In terms of precursor emissions, Cook County has the highest levels of
both VOC and NOx emissions of any of the ten counties in the CSA. Demographically, Cook
County has the hi ghest population, the highest population density, and the largest acreage of25

urban land cover of all the counties in the CSA. The IEPA, therefore, recommends Cook County
be included in the Chicago nonattainment area for the 8

- hour ozone standard.

Lake Co unty : Lake County is currently designated nonattainment for the existing 8

- hour ozone

standard as well as the previous 1

- hour ozone standard. Lake County has high levels of
precursor emissions, relatively high total population and population density, a h igh percentage of
urban land cover, and high levels of vehicular traffic. The IEPA, therefore, recommends that
Lake County be included in the Chicago nonattainment area for the 8

- hour ozone standard.

DuPage and Will Counties : Both DuPage and Will Counties are currently designated

nonattainment for the current 8

- hour standard as well as the previous 1

- hour ozone standard.

DuPa ge and Will Counties have some of the highest levels of precursor emi ssions in the Chicago

CSA

. DuPa ge County is second only to Cook County in total population, population density,
vehicular traffic, and total urban land cover. Similarly, Will County has a relatively high
population, population density, population growth, traffic level, and urban land c overage. The
IEPA, therefore, recommends that DuPage and Will Counties be included in the Chicago

nonattainment area for the 8

- hour ozone standard.

McHenry and Kane Counties : McHenry and Kane Counties are on the western fringe of the
metropolitan area w ith the eastern portions of these counties having an urban/suburban character,
while the western portions are basically rural. These counties have moderate levels of precursor
emissions relative to Cook, Lake, DuPage, and Will Counties, and the total popu lation,
population density, and total urban land cover in these counties are also relatively moderate.
McHenry and Kane Counties are experiencing moderate population and employment growth.
Both McHenry and Kane Counties are currently de signated nonattain ment for the existing 8

- hour
ozone standard as well as the previous 1

- hour standard. The IEPA, therefore, recommends that
McHenry and Kane Counties be included in the Chicago nonattainment area for the 8

- hour ozone

standard.26

DeKalb and Kankakee Counties : DeKalb and Kankakee Counties were added to the list of CSA
counties by the U.S. Census Bureau in 1998 and were not included in the Chicago nonattainment
area for the previous 1

- hour ozone standard. They were also classified as attainment for the

1997 8

- hour ozone standard. These counties are primarily rural, as shown by their low 2007
population totals and population densities, and the small amount of urban land cover in each
county is not contiguous with the Chicago urbanized area. Current precursor emission levels in
these counties are also low, compared to the other counties in the CSA. For these reasons, the

IEPA recommends that DeKalb and Kankakee Counties not be included in the nonattainment
area and that they be designated as attainment for the 8

- hour NAAQS for ozone.

Grundy and Kendall Counties : Oswego Township in Kendall County and Goose Lake and Aux
Sable Townships in Grundy County are included in the existing 8

- hour ozone NAA. Due to their
primarily rural character, most of Grundy and Ken dall Counties were not included in the
previous Chicago 1

- hour nonattainment area, the boundaries of which were established
subsequent to the 1990 Amendments to the CAA. Certain townships in Grundy and Kendall

Counties were included in the previous 1

- hour nonattainment area due to the significance of
certain stationary, or point, sources as indicated by the IEPA’s 1990 emissions inventory.
Precursor emission levels in the remaining portions of these counties are low , as is the total
population, population density, traffic volumes, and total urban land cover. For these reasons,
the IEPA recommends that Oswego Township in Kendall County and Goose Lake and Aux
Sable Townships in Grundy County be included in the Chicago nonattainment area for the 8

- hour NAAQS for ozone, but that the remainder of these two counties should retain their current

classification of attainment.

St. Louis Metropolitan Area

Madison County : Madison County is the only county in the St. Louis MSA where current air
quality data (2006

- 2008) does not meet the 8

- hour ozone standard (3 monitors)

. Madison C ounty
is currently designated nonattainment for the existing 8

- hour standard and a maintenance area for

the previous 1

- hour ozone standard. In terms of precursor emissions, Madison County has the27

highest levels of both VOC and NOx emissions of any of the counties in the Metro

- East.
Demographically, Madison County has the highest population, the second high est population
density, the largest acreage of urban land cover and highest v olume of traffic of all the counties

in the Metro

- East. Madison County should be included in the St. Louis Metro

- East

nonattainment area for the 8

- hour standard.

St. Clair County : Air quality data from the most recent 3

- year period (2006

- 2008) indi cate that
St. Clair County currently meet s the new 8

- hour ozone standard. However, it is currently
designated nonattainment for the 1997 8

- hour standard and a maintenance area for the previous

1

- hour ozone standard. St. Clair County has relatively high levels of both VOC and NOx

emissions, re latively high total population and population density, and a large percentage of
urban land cover. St. Clair County is expected to experience negative population growth and
moderate employment growth in future years. The IEPA, therefore, recommends that St. Clair
County be included in the St. Louis Metro

- East nonattainment area for the 8

- hour standard.

Monroe Count

y : Monroe County is on the southern fringe of the Metro

- East area with the
northern portions of the county having an urban/suburban character, while the southern and
eastern portions of the county are basically rural. It is currently designated as nonattainment for

the 1997 8

- hour standard as well as a maintenance area for the previous 1

- hour ozone standard.

T his county has relatively low levels of precursor emissions relative to Madison and St. Clair
Counties, and the total population, population density, and total urban land cover is also

relativ ely low. Because of its existing status as an ozone NAA for the 1997 NAAQS and its
previous designation as a 1

- hour ozone maintenance area, the IEPA recommends that Monroe
County be included in the St. Louis Metro

- East nonattainment area for the 8

- hour ozone

standard.

Jersey Count

y: Jersey County is a rural county located to the north of St. Louis, and is currently
attaining the 8

- hour ozone standard. This county has low levels of precursor emissions, low
population and population den sity, low urban land cover, low population and employment
growth rates as well as low volumes of traffic . The character of Jersey County is distinctly28

different from the St. Louis metropolitan area and a ir quality dat a from the most recent 3

- year period (2006

- 2008) indicate s that Jersey County is meeting the 8

- hour ozone standard

. Jersey
County is downwind from the violating monitor and therefore, does not contribute to violations
in the proposed NAA. F or this reason, the IEPA recommends that Jersey County be designated

as attainment for the 8

- hour NAAQS for ozone.

Clinto n Count

y : As mentioned previously, the current (1998) MSA boundaries establ ished by
the Office of Management and Budget, for St. Louis include Clinton County, Illinois. Clinton

County was no t contained within the previous 1

- hour ozone nonattainment area. This c ounty i s primarily rural, with low 2007 population totals and population densities, and small amounts of
urban land cover, compared to other counties in the MSA. Current precursor emission levels in
Clinton County are low, as are expected rates of populat ion and employment growth. For these
reasons, the IEPA recommends that Clinton County be designated as attainment for the 8

- hour

NAAQS for ozone.

Randolph County : Randolph Count y is not part of the St. Louis MSA as d efined by the Office
of Management an d Budget . It is not included as part of the existing 8

- hour ozone NAA and was
not contained within the previous 1

- hour ozone nonattainment area. This rural county has low
population and population density, low urban land cover, and low population and empl oyment
growth rates. Randolph County has high le vels of precursor emission s of NOx , virtually all of
which are emitted from an existing, stationary emission sour ce, the Baldwin Power Station

. The

Baldwin Power Station is subject to Illinois multi

- polluta nt strategy controls as well as a federal
consent order which will significantly reduce NO x emissions in future years

. For these reasons,
the IEPA recommends that Randolph County be designated as attainment for the 8

- hour NAAQS

for ozone.

Macoupin, Bond and Calhoun Counties : Bond, Calhoun and Macoupin counties were added to

the St. Louis MO

- IL MSA as defined by the U.S. Census Bureau, in 2003. All three counties are

no t included in the existing 8

- hour ozone nonattainment area. These counties ar e primar ily rural,

with low 2007 population totals and population densities, and have small amounts of urban land29

cover, compared to other counties in the St. Louis MSA. Current precursor emission levels in
Macoupin, Bond and Calhoun counties are low, as are expe cted rates of population, employment
growth and VMT . For these reasons, the IEPA recommends that Macoupin, Bond and Calhoun
counties be designated as attainment for the NAAQS for 8

- hour ozone

.

Montgomery County : Montgomery County is not included in the existing 8

- hour ozone

nonattainment area, nor i s it part of the St. Louis MSA. The county is not contiguous with the

Metro

- East urbanized area a nd does not influence population and ec onomic growth in the MSA

. Based on 2005 emissions data high precursor emission totals are the results of a large electric
utility so urce which is more than 4 0 miles away from the violating monitor and is downwind

from the Metro

- East area. Further, this source is subject to Illinois multi

- pollutant requirements

which will greatly reduce NO
x emissions in future years. For these reasons, the IEPA
recommends that Montgomery County not be included in the nonattainment area and that it be
designated as attainment for the NAAQS for 8

- hour ozone

.

Washington County : Washington C ounty is not included in the existing 8

- hour ozone

nonattainment area, nor i s it part of the St. Louis MSA. Washington County is considered
adjacent to St. Clair County; however the county is not contiguous with the Metro

- East

urbanized area and exhibits low population, VMT and economic influence. Current precursor
emission levels in these counties are very low, compared to the other counties evaluated for this
analysis

, although a new electric generating unit is being constructed that will increase emiss ions
in the near future. This source has been permitted under the Prevention of Significant
Deterioration program which requires the installation of Best Available Control Technology.
For these reasons, the IEPA recommends that Washington County not be i ncluded in the
nonattainment area and that it be designated as attainment for the NAAQS for 8

- hour ozone

.30

Remainder of Illinois

Areas of the state that are not part of these two metropolitan areas are in attainment with the

8

- hour ozone NAAQS, and it is recommended that all remaining counties be designated as

attainment.31 

### Table 5 Recommended Attainment/Nonattainment Designations in Illinois
For the 8

- hour Ozone National Ambient Air Quality Standard

County Designation Name of Area

Cook Nonattainment Chicago

DuPage Nonattainment Chicago

Kane Nonattainment Chicago

Lake Nonattainment Chicago

Will Nonattainment Chicago

McHenry Nonattainment Chicago

Kendall:
Oswego Township
All Other Townships Nonattainment

Attainment Chicago

Grundy:
Aux Sable Township
Goose Lake Township
All Other Townships Nonattainment

Nonattainment

Attainment Chicago

Chicago

Madison

Aux Sable Township

Goose Lake Township

All Other Townships Nonattainment Metro

- East

Monroe Nonattainment Metro

- East

St. Clair Nonattainment Metro

- East

All Other Counties Attainment32

Factor Data Analysis Data Source Date of Study

1. Air Quality Data

- Monitoring Ozone 200 6

- 200 8 Design Values at individual monitors (statewide) IEPA BOA Database, Air Monitoring Section 200 6

- 200 8

2. Emissions Data Emission inventory information for pollutants: NO
x , and VOC within the Chicago CSA and St. Louis MSA /CSA and adjacent counties. Emission totals (tons/year) are summarized by county for point, area, on

road/mobile, and off

- road sectors IEPA 2005 Reported

Inventory 2005

Source locations in non

attainment areas and adjacent counties IEPA BOA database 2005

3. Population Density and Degree of Urbanization Annual Estimates of the Population in Illinois. Total population and population density estimates*

Urbanized area boundaries Table1:Annual Estimates of the Population for Counties of Illinois: July 1 , 2000 to July, 200 7 (CO

- EST200 7

- 0 3

- 22 ) Population Division, U.S. Census Bureau;

ESRI Maps and Data Release date:

200 7

4 . Expected Growth Rates and
Patterns Total population change based on Long

- Term population projection **

Total occupational employment change based on Long Term study** Illinois Department of Commerce and Economic Opportunity: Illinois Population Trends 2000

- 2030

Illinois Department of Employment Security 2000

- 2030 Population Projection Table

- 2005 edition

2004

- 2014 Occupational Employment Projections by County

– 2005 edition

5 . Traffic and Commuting
Patterns Average Daily Traffic tables for
2007

County to County Commuting Workflow files table Illinois Department of Transportation, Travel Statistics 2007; U.S. Census Bureau 2007

2000 

### Table 6 8

- hour Ozone NAA Boundary Recommendation

Nine Factor Documentation March 9, 200933

* http://www.census.gov



### ** http://www.commerce.state.il.us/dceo/Bureaus/Facts _Figur es 6 . Topography

relatively flat Google Earth; U.S. Geological Survey 2007 (data is about one to three years old and updated on a regular basis

– no set year is given)
7 . Jurisdictional Boundaries MSA/CBSA/CSA boundary information; Office of Management and Budget; ( in conjunction with U.S. Census Bureau) 2003;

April 2005
8 . Meteorology Weather patterns

– Pollution/Wind Rose, Regionally Influenced High days Chris Price (Air Monitoring Section); Illinois State Water Survey 2006

- 2008

9. Level of Control of Emission Sources Existing and expected controls IEPA

– BOA Programs 2008

# Figure 1

# Figure 2

# Figure 3

2006

- 2008 Lake Michigan 8

- Hour Ozone Design Values

# Figure 4

2006

- 2008 St. Louis, MO 8

- Hour Ozone Design Values

# Figure 5a

200 5 NOx Emissions by County for the Chicago C SA

(Tons/ Day)

NO x



### COUNTY POINT AREA NONROAD ONROAD Total Tons/Day



### Cook 68.42 19.98 161.61 186.16 436.17



### Will 110.06 1.16 33.08 31.25 175.55 

### DuPage 5.72 5.03 33.33 47.02 91.10



### Lake 27.47 3.61 18.64 30.47 80.19



### Kane 2.67 1.89 19.63 20.47 44.66



### Kankakee 17.2 0.28 7.51 6.75 31.74 

### McHenry 2.32 1.44 12.08 11.91 27.75 

### Grundy 3.51 0.11 5.72 6.65 15.99



### Kendall 7.11 0.30 4.55 3.59 15.55



### DeKalb 0.65 0.32 5.6 6.07 12.64

# Figure 5b

2005 VOC Emissions by County for the Chicago CSA

(Tons/ Day)

VOC

COUNTY POINT AREA NONROAD ONROAD Total Tons/Day



### Cook 40.80 166.99 77.44 77.91 363.14 

### DuPage 5.58 31.05 24.52 19.68 80.83



### Lake 3.63 23.49 24.20 13.43 64.75



### Will 10.04 22.76 13.49 12.56 58.85



### Kane 4.91 16.64 12.47 8.51 42.53 

### McHenry 2.29 11.45 7.88 5.34 26.96



### Kankakee 3.90 7.69 2.36 3.58 17.53



### DeKalb 1.02 7.44 1.78 3.29 13.53 

### Grundy 2.48 3.87 2.51 2.19 11.05



### Kendall 1.41 4.47 2.82 2.31 11.01

# Figure 6a

NO x



### COUNTY POINT AREA NONROAD ONROAD Total Tons/Day


### Madison 39.10 0.59 17.31 20.88 77.88


### Montgomery* 38.41 0.12 6.19 5.14 49.86


### St. Clair 2.17 0.56 7.75 18.54 29.02 

### Randolph* 16.78 0.19 9.57 1.56 28.10


### Monroe 0.75 0.08 8.16 2.34 11.33


### Clinton 3.57 0.11 4.76 2.75 11.19 

### Macoupin 0.06 0.14 4.74 3.42 8.36 

### Washington* 0.04 0.08 4.21 3.98 8.31


### Bond 0.06 0.05 3.00 3.08 6.19 

### Jersey 0.00 0.05 4.69 1.16 5.90


### Calhoun 0.00 0.01 4.10 0.22 4.33 * C ounty is not in MSA

# Figure 6b

VOC

COUNTY POINT AREA NONROAD ONROAD Total Tons/Day



### Madison 8.78 13.02 6.67 8.14 36.61



### St. Clair 3.46 11.47 4.73 7.73 27.39



### Clinton 0.31 3.29 4.33 1.43 9.36 

### Macoupin 0.11 5.38 1.63 1.64 8.76 

### Montgomery* 0.40 4.59 1.78 1.86 8.63 

### Randolph* 1.12 3.03 3.16 1.03 8.34 

### Washington* 0.25 3.01 1.01 1.31 5.58



### Monroe 0.13 2.30 1.77 1.16 5.36 

### Jersey 0.08 2.23 1.56 0.78 4.65



### Calhoun 0.00 0.88 3.47 0.15 4.50



### Bond 0.11 2.23 0.96 1.06 4.36 * County is not in MSA

# Figure 7a Figure 7b

# Figure 8a Figure 8b

# Figure 9

# Figure 10

# Figure 11

# Figure 12

# Figure 13

# F igure 14

# Figure 15

- 10.0 0.0 10.0 20.0 30.0 40.0 50.0 60.0 70.0 80.0

Cook DuPage Kankakee Lake DeKalb McHenry Kane Grundy Will Kendall 

### - 1.7 2.5 6.6 9.6 16.1 20.6 22.9 25.1 32.6 75.4 Population Change (%)



## County 2000

Population 2007

Population

Kendall 55,207 96,818

Will 508,067 673,586

Grundy 37,674 47,144

Kane 407,584 501,021

McHenry 261,887 315,943

DeKalb 89,331 103,729

Lake 648,241 710,241

Kankakee 103,881 110,705

DuPage 906,760 929,192

Cook 5,377,927 5,285,107

# Figure 16

# Figure 17

# Figure 18

# Figure 19

0 10 20 30 40 50 60 70 80 90 100

Cook DuPage Lake Will Kane McHenry Kankakee DeKalb Kendall Grundy

90.0

23.7

15.7 15.6

10.0 6.1 2.6 2.4 2.2 1.9 Millions of ADVMT

County 

## 2007 Average Daily Vehicle Miles Traveled (ADVMT)

in the Chicago Area (millions)

# Figure 20

0 1 2 3 4 5 6 7 8 9 10

7.9 7.5

1.4 1.2 1.1 1.1 1.0 0.8 0.7 0.5 0.1 Millions of ADVMT

County * denotes counties not part of St. Louis MSA 

### 2007 Average Daily Vehicle Miles Traveled (ADVMT)

in the St Louis Area (millions)

# Figure 21

A verage Daily VMT in the Chicago NAA, 1990

- 2007

IDOT Travel Statistics Figures Show ADVMT to the nearest million Chicago NAA + 3 Nonattainment Townships in Grundy & Kendall Counties

# Figure 22

A verage Daily VMT in the Metro

- East NAA, 1990

- 2007

IDOT Travel Statistics Figures Show ADVMT to the nearest million Metro

- East NAA ( Madison, Monroe & St. Clair Counties)

# Figure 23

0 50,000 100,000 150,000 200,000 250,000 300,000

*Cook DeKalb DuPage Grundy Kane Kankakee Kendall Lake McHenry Will
Cook 2,077,798 2,221 152,433 1,123 34,361 4,559 2,459 83,502 31,337 76,574

DeKalb 826 28,811 560 7 1,311 0 725 60 202 149

DuPage 146,135 2,857 277,934 765 34,318 471 7,051 6,967 4,650 43,498
Grundy 533 19 260 8,884 51 202 299 24 47 2,702

Kane 18,345 6,468 16,539 296 107,807 30 6,630 1,383 8,877 3,432

Kankakee 977 0 95 98 36 36,936 8 8 0 1,352

Kendall 837 1,263 949 180 2,866 12 8,798 64 73 1,097

Lake 64,253 249 5,377 68 3,012 63 108 212,450 16,731 1,128

McHenry 5,182 448 884 23 5,056 4 20 5,866 68,108 158

Will 24,432 349 9,197 5,869 1,840 3,564 1,737 389 343 107,456

*2,077,798 Number of Workers Commuting 

## Where People Reside and Counties Where they Journey to Work Chicago CSA Counties

Resident County

# Figure 24

0 10,000 20,000 30,000 40,000 50,000 60,000 70,000 80,000

Bond Calhoun Clinton Jersey Macoupin Madison Monroe Montgomer

y Randolph St. Clair Washington

Monroe 18 0 20 0 0 421 5,367 0 623 1,730 8

Jersey 7 38 0 4,473 204 3,480 0 7 6 111 0

Calhoun 0 1,099 0 208 12 362 0 5 2 13 0

Clinton 256 0 8,567 0 22 1,598 20 16 41 2,586 309

Macoupin 14 2 0 238 11,335 3,897 7 1,516 14 315 0

Bond 4,168 0 248 0 42 1,471 4 292 13 201 10
Washington 5 0 340 0 23 94 0 0 228 786 4,408

Madison 289 39 460 506 650 75,494 70 239 322 9,317 21

St. Clair 29 0 479 30 61 7,044 916 57 871 70,379 179

Montgomery 153 8 12 7 542 288 0 8,843 23 75 0
Randolph 6 0 30 0 0 181 485 4 9,545 1,162 144 Number of Workers Commuting

Resident County 

## Where People Reside and Counties Where they Journey to Work

ST. Louis MSA and Adjacent Counties

# Figure 25


# Topography

# Figure 26

Chicago Area Pollution Rose 2006

– 2008 All sites Days > 75ppb

Meteor ology based on Alsip 2006

- 2008

# Figure 27

Metro

- East Pollution Rose ( 2006

– 2008 )

All sites Days > 75ppb

Meteor ology based on Edwardsville 2006

- 2008

# Figure 28