## Attainment Demonstration

The Wisconsin Counties

of
Kenosha, Racine, Milwaukee, Waukesha, Ozaukee, Washington, Shebo ygan, Manitowoc and Door

From Nonattainment to Attainment Of the 1997 Eight-Hour Ozone NAAQS

------------- ------------- 

### Revision to Wisconsin’s Ozone Air Quality Management State Implementation Plan

------------- -------------



### Wisconsin Department of Natural Resources Bureau of Air Management

P.O. Box 7921
Madison, WI 53707

Publ AM-395 2009

September 2009Natural Resources Board

Christine L. Thomas, Chair, Stevens Point
Jonathan P. Ela, Vice Chair, Madison John W. Welter, Secretary, Eau Claire Dave Clausen, Amery
Preston D. Cole, Milwaukee Gary E. Rohde, River Falls Jane Wiley, Wausau

Wisconsin Department of Natural Resources

Matthew J. Frank, Secretary Pat Henderson, Deputy Secretary Mary Ellen Vollbrecht, Executive Assistant

WDNR Division of Air & Waste

Al Shea, Administrator Suzanne Bangert, Deputy Administrator

WDNR Bureau of Air Management

John H. Melby, Jr., Director Larry H. Bruss, Chief, Regional Pollutants and Mobile Source Section

Principal Author

Bill Adamski

Acknowledgments

A note of appreciation to the people who helped make this study possible: The WDNR Air Monitoring staff for effectively operating the state’s ozone a nd ozone precursor monitoring network. The WDNR emissions inventory specialists for compiling the deta iled emissions inventories used in this study. The Lake Michigan Air Director’s Consortium (LADCo ) for conducting the ozone modeling, whose results were used in performing the modeled attainment test. Donna Kenski (LADCo) for doing her CART
analyses, which were used in this analysis. The WDNR Air Management staff whose review and

comments of draft versions helped improve this study.i 

## Attainment Demonstration

The Wisconsin Counties

of
Kenosha, Racine, Milwaukee, Waukesha, Ozaukee, Washington, Shebo ygan, Manitowoc and Door

From Nonattainment to Attainment Of the 1997 Eight-Hour Ozone NAAQS

------------- ------------- 

### Revision to Wisconsin’s Ozone Air Quality Management State Implementation Plan

------------- -------------



### Wisconsin Department of Natural Resources Bureau of Air Management

P.O. Box 7921
Madison, WI 53707

Publ AM-395 2009

September 2009ii Table of Contents
Page

Table of Contents ii

List of Figures iv

List of Tables v

List of Appendices v

Chapter Description Page

1 Introduction 1

1.1 Attainment Demonstration: Pu rpose and Regulatory Background 1

1.2 Historical Overview: Wisconsin 8-ho ur ozone nonattainment areas 1 1.3. Report Outline 3

2 Conceptual Description: Ozone Dynami cs in L. Mich. and E. Wis areas 4

2.1 Introduction 4 2.2 Synoptic-Scale Meteorological Influences to High Ozone in the L. Mich. area 4 2.3 Mesoscale Meteorological Influences to High Ozone in Eastern Wisconsin 8

3 Trends in Ozone Air Quality Measurements 13

3.1 Introduction: Pollutant Trends St udy as Supplemental Analyses 13
3.2 Ozone Trends at Nonattainment Sites 13 3.3 Ozone Exceedance Days & Hot Temperature Days 20

4 Trends in Ozone Precursor Air Quality Data 22

4.1 Introduction 22 4.2 Diurnal Profiles of Hourly NOx 23 4.3 Diurnal Profiles of Hourly VOCs 25 4.4 Morning (6-9A CST) VOC and NOx Measurements 27 4.5 Morning (6-9A CST) VOC / NOx Ratios in Milwaukee 29

5 Emission Inventories and Impl emented Control Measures 31

5.1 Introduction 31iii Chapter Description Page

5.2 Wisconsin Control Strategies for Ozone Precursor Emissions 31 5.2.1 VOC Reasonably Available Control Technology 32

5.2.2 NOx RACT 33

5.2.3 Non-Motor Vehicle Ozone Cont rol Measures in Addition to CAA 34

5.2.4 Traffic Reduction Measures 35

5.2.5 Controls to Remain in Effect 36 5.3 RFP Emissions Inventories (EIs): Base 2002 and Projected 2008 36 5.3.1 2002 Base Year Emissions Inventory for RFP 37 5.3.2 Adjusted Base Year 2002 Emi ssions Inventory (EI) for RFP 40 5.3.3 2008 Projected Emissions Inventory (EI) for RFP 40

5.4 Base and Future Year Inventories fo r the Modeled Attainment Test 42

6 Ozone Attainment Demonstration Modeling 43

6.1 Introduction 43

6.2 Modeled Years and Emission Scenarios 43 6.3 Modeling System 43 6.4 Modeling Performance Evaluation 44 6.5 Modeling Future Years and Modele d Attainment Test Results 44

7 Additional Data Analyses: 48 7.1 CART Ozone analyses 48

7.2 NOx and VOC Concentrations vs. Wind Direction 51

8 Summary and Conclusions. 53

References 55iv List of Figures

# Description Page 1 Wisconsin Counties Designated Nonattainment of the 1997 8-Hr O3 NAAQS 2 2 Counties in Lake Michigan Basin – Current or Previously Designated Non
Attainment of the 1997 8-Hr O3 NAAQS 5 3a Surface Synoptic Weather Map: 6AM CST 22 June 02 7 3b Site Peak-Daily 1-Hr Ozone: S. Lake Mich Basin 22 June 02 7 4 Time-Space Series 3-Min Averaged Ozone (Aloft vs Surface) Coastal

Southern Wis 2:21-2:36 PM CDT 17 June 87 10 5 Time Series Hrly Surface Air Temperature Racine, WI and S. L. Mich 11 6 Lake Breeze Diagram 12 7 Annual Sum Totals Site-Day Exceedances of the 1997 8-hr NAAQS Six Sites Near L. Michigan 1994-2008 15 8 8-Hr Ozone Design Values, Annual Numb er of 8-hr O3 Exceedance Days -
Chiwaukee, WI 1988-2008 17 9 8-Hr Ozone Design Values, Annual Numb er of 8-hr O3 Exceedance Days - Milwaukee-Bayside, WI 1988-2008 17 10 8-Hr Ozone Design Values, Annual Numb er of 8-hr O3 Exceedance Days - Harrington Beach, WI 1994-2008 18 11 8-Hr Ozone Design Values, Annual Numb er of 8-hr O3 Exceedance Days - Sheboygan, WI 1997-2008 18 12 8-Hr Ozone Design Values, Annual Numb er of 8-hr O3 Exceedance Days -
Manitowoc, WI 1994-2008 19 13 8-Hr Ozone Design Values, Annual Numb er of 8-hr O3 Exceedance Days - Newport, WI 1989-2008 19 14 Peak Daily 8-Hr O3 > 84 ppb at any Eastern Wis O3 Site, Milwaukee Airport NWS Daily Max Temps > 90F 1988-2008 21 15 Numerator: Peak Daily 8-Hr O3 > 84 ppb at any Eastern Wis O3 Site, Denominator: Milw Airport NWS Daily Max Temps > 90F 1988-2008 21

16 Annual Diurnal Profiles: Median Ho urly NOx Milw-UWMN 15 May - 15 Sept 1994-2000 24

17 Annual Diurnal Profiles: Median Ho urly NOx Milw-SER 15 May - 15 Sept 1999-2008 24

18 Annual Diurnal Profiles: Median Ho urly TNMOCs Milw-SER June- July-Aug 1999 - 2007 26 19 Median Site-Monthly NOx, TNMOCs Daily 6-9AM CST Averages Milw-UWMN June-Aug 1994-1999, Milw-DNR SERHQ June-Aug 1999-07 28v List of Figures (continued)

# Description Page 20 Median Site-Monthly Median Va lues Daily TNMOC / NOx, Ratios 6-9 AM: UWMN June-Aug 1994-1999, DNR SERHQ June-Aug 1999-07 30

21 Concentration Trends in CART Node s – 5 Wisconsin Shoreline Sites 49

22 Concentration Trends in CART No des – 3 Milwaukee Monitors 50 23 June-Aug Hrly NOx vs Hrly Wind Dir, Milwaukee 1999, 2007 52 24 June-Aug Hrly VOCx vs Hrly Wind Dir, Milwaukee 1999, 2007 52

List of Tables

# Description Page 1 Ozone Monitoring Sites, 2006-08 8-Hr Ozone Design Values

Wis Ozone Nonattainment Counties 14 2 Emissions of Reactive Organic Gases in 9-County Area 1985 & 2005 33 3 Summary: NOx and VOC Emi ssions Inventories 38
4 Base (2002 Actual) and Future (200 8) NOx Emission Inventories 39
5 Base (2002 Actual) and Future (200 8) VOC Emission Inventories 39 6 Summary NOx and VOC Emission Calcs For RFP 41

7 Predicted Future Year 8-Hr Ozone Design Values (Modeled
Attainment Test Results) 7 Wis Ozone Nonattainment Sites 47

List of Appendices

A LADCo, 2008: Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Final Technical Support Document . 126 pp + appendices, April 25.

B LADCo, 2006: Base K [2002] Strategy Modeling: Emissions . 15 pp, May 16.

C LADCo, 2008: Base M [2005] Strategy Modeling: Emissions (Revised) . 24 pp,

D LADCo, 2008: Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Final Technical Support Document (Supplement), 56 pp, September 12

E Overview: VOC / NOx Ratios and Ozone Production

F Listing: Promulgated W DNR Ozone Control Rules

G Overview: CART Analysis Modelvi <Blank Page>1 1 Introduction

1.1 Attainment Demonstration: Pur pose and Regulatory Background

This document details an assessment of measured and modeled air quality data to demonstrate how full implementation of Wiscon sin’s ozone air quality State Implementation Plan (SIP) and other factors have combined to help attain th e 1997 eight-hour ozone nati onal ambient air quality standard (NAAQS, 0.08 parts per million [ppm]) as of the end of 2008 for all areas of Wisconsin currently classified as nonattain ment for this NAAQS (Figure 1).

This attainment demonstration (AD) also doc uments how permanent and enforceable control measures of ozone precursors in Wisconsin’s ozone nonattainment area have resulted in
substantial emission reductions for these counties to date. Furthermore, these control measures are projected to yield emissi on reductions that meet reas onable further progress (RFP) requirements. Chemical transport modeling for fu ture years shows attainment and maintenance of the 1997 8-hour ozone NAAQS in Wisconsin thr ough at least 2018. Supplemental analyses of
measurement data are included to corroborate that ambient levels of ozone and ozone precursors has substantially diminished in eastern Wi sconsin over the past 10-15 years.

This AD satisfies one of the regulatory requireme nts established in Section 110 and Part D of the Clean Air Act for states requesting that nonattainm ent areas be considered for redesignation to
attainment.

1.2 Historical Overview: Wisconsin 8-Hour Ozone Nonattainment Areas

Portions of eastern Wisconsin have had a long hi story of excessively high ozone levels. In 1979 the US EPA designated counties in southeastern Wisconsin as nonattainment for the 1-hour ozone NAAQS (0.12 ppm).

On July 18, 1997, the US EPA published a final ru le (US EPA, 1997) that established a new ambient ozone NAAQS – a rolling 8-hour averag e not to exceed 0.08 ppm (equivalent to 84 parts per billion [ppb]). On April 30, 2004, the US EPA published a final rule (US EPA, 2004b) that set forth designations and classifications for the 8-hour ozone NAAQS. These designations became effective on June 15, 2004.

The US EPA’s April 30, 2004 action designated te n (10) Wisconsin counties (Figure 1) as nonattainment of the 8-hour ozone NAAQS. The counties of Manitowoc, Kewaunee and Door were designated as nonattainme nt - Subpart 1. The 6-county Raci ne-Milwaukee area (counties of Kenosha, Racine, Milwaukee, Waukesha, O zaukee and Washington) and Sheboygan County were all designated nonattainme nt - moderate/Subpart 2.

On March 27, 2008 the US EPA published a fina l rule (US EPA, 2008a) that established a23 new 8-hr ozone NAAQS of 0.075 ppm (75 ppb). The original 8-hour ozone NAAQS is now referred to by the year it was promulgated (1997 ). This Attainment De monstration addresses only the 1997 8-hour ozone NAAQS.

On May 21, 2008 the US EPA published a final rule (US EPA, 2008b) that redesignated Kewaunee County to attainment of the 1997 8-hour ozone NAAQS. The other 9 Wisconsin counties previously identified rema in nonattainment for this NAAQS.

1.3 Report Outline

The structure to this AD follows the recomme nded guidance contained in the US EPA (2007) document entitled “Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of Air Quality Goals for Ozone , PM2.5, and Regional Haze” (EPA-454/B-07-002). Specifically, the report answers questions raised in Part I of this guidance (“How Do I Use Results Of Models And Other Analyses To Help Demonstrate Attainment?“).

Subsequently, the remaining chapters of this AD are outlined as follows:

Chapter 2: A conceptual description that char acterizes ozone dynamics in the larger Lake Michigan basin, then in the focused eastern Wisconsin area.

Chapter 3: Ozone trends in Wisconsin ozone no nattainment areas during the past 20 years.

Chapter 4: Trends in ozone precursor air qua lity measurements (VOCs and NOx) data in
Wisconsin’s ozone nonattainment ar eas during the past 15 years.

Chapter 5: An overview of the development of each of the emissions inventories used in this demonstration, as well as a brief discussion of the implemented reasonably available control measures to reduce precursor emissions in order to lower ozone levels.

Chapter 6: An overview of the ozone modeling program and results designed to predict both base and future year ambient 8-hour ozone levels in Wisconsin’s ozone nonattainment areas. This discussion includes applying th e US EPA’s modeling attainment test to the predicted results
to assess whether attainment of the 1997 8- hour ozone NAAQS is achieved by the regulatory
deadline date.

Chapter 7: Supplemental analyses of ambient da ta are presented to help provide additional
assessments on whether the 1997 ozone standard has been attained.

Chapter 8: Summary and conclusions.

Several appendices are included to supplement th e information provided in this report. Some these appendices are included by internet links.4 2. Conceptual Description: Ozone Dynamics in Lake Michigan and Eastern Wisconsin

2.1 Introduction

This attainment demonstration assessment pertains to Wisconsin’s nine ozone nonattainment counties (Figure 1). However, excessively hi gh ozone is prevalent th roughout most of the
shoreline areas in the Lake Mi chigan basin. Almost every co unty along the Lake Michigan’s shoreline, as well as some sec ond and third tier inland counties, ha ve measured violations of the
1997 8-hour standard at one time or another and 10 of these coun ties were officially designated as nonattainment in 2004 (US EPA 2004b) (Figure 2).

In order to mitigate excessive ozone in the Lake Michigan area - many control measures have been promulgated over the years to substantially reduce those emissions that contribute to ozone formation. While these actions have yielded mu ch progress over the last three decades, groundlevel ozone remains a regional problem in th is airshed, with exceedances of the 1997 8-hour ozone NAAQS still occasionally occurring and much of the region still in nonattainment of this air quality standard.

A conceptual overview of the ozone problem is pr esented from the perspective of both the larger Lake Michigan region (Section 2.2) and the fo cused eastern Wisconsin nonattainment area (Section 2.3).

2.2 Synoptic-Scale Meteorological Influences to High Ozone in the Lake Michigan Area

The entire coastal tri-state urban area that extends from northern I ndiana clockwise through Chicago and Milwaukee to Sheboygan, Wis (Figure 2) has more than 10 million inhabitants and is heavily industrialized. Consequently, regardle ss of the meteorology of the region, this massive complex of contiguous metropolitan areas genera tes a substantial amount of ozone precursor emissions with which to produce ex cessive ozone levels locally.

Ozone has been a persistent air quality health problem throughout the Lake Michigan basin
since the 1970s. In addition to the ozone nonattai nment areas in Wisconsin (Figure 1), the eightcounty Chicago IL-Gary IN region and shoreline c ounties in Michigan have also been out of attainment with respect to eith er the 1-hour or 8-hour ozone NAAQS (or both) for much of the past 30 years (Figure 2). Southeastern Wi sconsin was originally designated as being nonattainment of the ozone NAAQS (1-hour averaging time) in 1979.

The four states (Wisconsin, Illinois, Indiana and Michigan) that borde r Lake Michigan along with the US EPA recognized in the late 1980s that a coordinated interstate approach was needed to bring the region into attainme nt of the ozone NAAQS. In 1989, the Lake Michigan states and the US EPA signed a Memorandum of Agreement (MOA) that created the Lake Michigan Air Directors Consortium (LADCO) fo r purposes of coordinating efforts among the states towards attaining the ozone NAAQS throughout the basin.5 

## Fi g ure 26 This MOA also established that LADCo shall co ordinate a comprehensive assessment of ozone dynamics in the Lake Michigan airshed in order to develop a more refined, targeted approach towards reducing the area’s ozone. This pr oject, called the Lake Michigan Ozone Study (LMOS), included a massive field study during the summer of 1991.

However, even before LMOS, other rese archers (e.g,. Lyons, 1975, Lyons and Cole,1976) presented research that highlighted the unique ozone-conducive meteorology of the region at the synoptic weather scale (i.e., weather features of 24-48 hours duration) and mesoscale meteorology (i.e., weather features less than 24 hours duration).

On the synoptic scale, the rese archers demonstrated that high pressure systems can generate meteorological conditions that are very favorable to excessive ozone as the weather migrates through the region from west to east during late May - early Se ptember. These systems are typified by hazy, sunny skies with generally we ak, clockwise-rotating winds and relatively shallow mixing (poor dilution). These weather conditions greatly assist in the buildup and photo-reactivity of considerable amounts of ozone precursors.

The position of the surface high pressure system’s center is important with respect to ozone transport into the region. Haney, et al., (1989) estimated that 50% of Wisconsin's ozone exceedance days during 1980-1988 [1-hr ozone NAA QS] occurred when the center of a high pressure system was situated to the area's southe ast (i.e., Ohio and east thereof) (Figures 3a and 3b). Samson and Ragland (1977) showed throug h trajectory and synoptic -scale analysis of a 1975 Lake Michigan ozone episode that "..adve rse [air quality] conditions occurred when stagnant air originating in the Ohio River valley was transporte d northward on the western half of a high pressure system...into northern Illinois and southeastern Wisconsin".

The WDNR (1988a, 1988b) conducted studies of Lake Michigan’s ozone meteorology along its
western shoreline with Wisconsi n. WDNR (1988a) included ozone measurements collected aloft via airplane. Both studies noted that the oz one transformation and tran sport processes in the vicinity of the Lake were extremely complex and warranted further analysis. However, both studies did identify interrelated ozone and weat her features that suppor ted the Lake Michigan ozone meteorology research of Lyons, 1975, Lyons and Cole,1976

The LMOS contributed to a bett er understanding of synoptic-scal e weather influences on ozone in the Lake Michigan area. Reports by Robert s, et. al. (1994), Hanna and Chang (1995), Dye, et al. (1994) and Korc, et al. , (1993) Hanna and Chang (1995) ge nerally conclude that ozone episodes are associated with high pressure systems over the eastern United States and transported pollutants and precursors from the south and eas t result in increased the region-wide ozone
concentrations.7 ozone8 Ozone measurements collected aloft via aircraft present a reasonably good "snap shot" of the magnitude of ozone that can be transported into an area at any given time. Aircraft flights above Lake Michigan (Westberg et al. 1981, WDNR 1988, Hillery 1993, Korc et al. 1993, WDNR, 2003) have monitored ozone that often exceed ed both the ozone NAAQS and concentrations
monitored at the surface in the Lake Michigan airshed (Figure 4). Since only a portion of the ozone formed near the surface is mixed vertically aloft, much of the additional ozone that is measured aloft must be coming from non-local sources.

Both Korc, et al. (1993) and WDNR (2003) noted that ai rcraft-measured ozone concentrations aloft in the Lake Michigan ar ea can often be quite substantia l (Korc: 70 - 100 ppb) on high ozone days, even up to 100 - 150 km south of Lake Mich igan. This is much higher than the generallyaccepted local rural background level of 30-40 ppb (Trainer, et al. , 1993) and can occasionally exceed the ozone NAAQS. Korc, et al. (1993) estimated that upwind boundary ozone
contributes 40-60% to the maximu m ozone concentrations in the Lake Michigan airshed. The geographical domain of excessive oz one appears to be notably great er aloft than at the surface on episode days (WDNR 2003, Korc et al . 1993).

In summary, all of these studies demonstrat e that on warm, sunny, humid days in the Lake Michigan area with weak southerly flow emana ting on the trailing edge of an atmospheric high pressure situated in the eastern U.S. – there can be a widespread incidence of high ozone where long-range transport is prevalent into the Lake Michigan area.

Hanna and Chang (1995) further point out that “..the local pollutant sources in the GaryChicago-Milwaukee then add their [considerab le emissions] contribution to the incoming pollutant mass” embedded in the southerly flow on warm sunny, hazy days (e.g., Figure 4).

2.3 Mesoscale Meteorological (Lake Breeze) Infl uences to High Ozone in Eastern Wisconsin

Wisconsin’s ozone nonattainment region is positioned along approximately 220 miles of Wisconsin eastern coastline with Lake Michigan (Figure 1). Lake Michigan with a surface area of approximately 22,400 square miles constitu tes a huge heat sink dur ing the warm months. Figure 5 highlights the considerab le difference between the land ai r temperature (Racine, Wis) and the buoy-derived air temperature above the s outhern Lake Michigan surface during a 5 day ozone episode in June 2002.

As described in section 2.2, synoptic weather cond itions in the Lake Michigan basin that are favorable to the formation of high ozone levels include being on the we stern edge of a high pressure system during warm weather (Figure 3a). This synoptic scenario, in combination with the unique Lake-induced meteorol ogical features produces a mesoscale environment in which the capability to produce ozone is greatly intensified.

At the mesoscale meteorological scale, there is a strong temperature cont rast between the warm land and cold lake (Figure 5). This scenario can lead to the formation of a daytime thermallydriven circulation cell called the lake breeze, wh ich runs approximately perpendicular to the Lake Michigan shoreline (Figure 6). In a classi cal lake breeze circulation cell, the following series of inter-related processes take place:9 • A shallow but intensely stable conduction i nversion exists just above the relatively cold Lake (Figure 6). During the early daylight hours the prevailing (synopticscale) surface winds transport ozone and fresh (morning rush hour) ozone precursor emissions towards the Lake (i.e., offshore flow). This emissions transport is confined to the shallow, stable condu ction inversion (Robe rts, et. al, 1994).

• The newly-injected precursors’ in a sta gnant, cloudless cond uction inversion are subject to considerable s unlight and heat along with sufficient amounts of water vapor. This translates into the over-la ke environment becoming an incredibly
efficient ozone reaction cham ber (Roberts, et. al, 1994).

• By mid-morning a sharp horizontal temp erature is formed along the shoreline between cold lake and increasingly wa rmer land (Figure 5). This gradient effectively “cuts off” additional flow, including pollutants into the conduction layer (Roberts, et. al, 1994). The lakeward winds are subsequently forced to flow up and
over the conduction inve rsion (Figure 6).

• Over the Lake - the aloft, la nd-originated flow is now s ubject to subsidence in the cooler Lake’s mesohigh and begins to sink. When the cooling air approaches the Lake’s surface – it spreads out, moving in all directions, including towards shoreline (Figure 6).

• When this shallow, cool air flow (now filled with high amounts of ozone formed in the conduction inversion) reaches the shor eline, the onset of the onshore lake
breeze is realized.

• The lake breeze flow gradually dissipates within the first 2-15 miles onshore – largely restricting its major ozone impact to this narrow region. Th is translates into
the ozone nonattainment c ounties being mostly confin ed to shoreline counties (Figures 1, 2).1011 

## Figure 5: Time Series Hourly Surface Air Temperature Racine, WI and S. Lake Mich. Buoy
20 - 25 June 02

0 5 10 15 20 25 30 35159131721159131721159131721159131721159131721159131721

Hour of Day (CST)Hrly Ambient Temp. (C



### Racine Ambient Temp. (C) L. Mich. Buoy Air Temp. (C)

Source: WDNR 200312 

### Figure 6: An idealized depiction of a typical lake breeze circulation cell.

Dashed line represents outer boundary of the inflow layer

Conduction

inversion

layer
0 - 200 m

Source: WDNR 200313 3 Trends in Ozone Air Quality Measurements

3.1 Introduction: Pollutant Trends Study as Supplemental Analyses

The US EPA (2007) states that an attainment demonstration uses “..m odeling [and inventory] analyses to assess whether various emission reducti on measures will bring an individual area into attainment for the NAAQS...” However, the US EPA also recommends that supplemental analyses should accompany all model attainment demonstrations.

For this attainment demonstrati on of areas in eastern Wisconsin the following study of trends in ozone levels, as well a review of trends in ozone precursors (Chapter 4) constitutes one supplemental analysis for this project.

3.2 Ozone Trends at Nonattainment Sites

Table 1 identifies all ozone monitoring sites that the Wisconsin DNR operated during 2006-2008 in the counties currently desi gnated as nonattainment of the 1997 eight-hour ozone NAAQS. For the current 2006-08 data period all of these sites have 8-hour ozone design values (DVs) that are below the 8-hour ozone NAAQS (0 .08 ppm [84 ppb]). This is the first time that every operational ozone monitoring site in Wisconsin’s ozone nonattainment areas attained the 8-hour ozone standard since they were officially designated as nonattainment (US EPA 2004b).

The top part of Table 1 identifies six ozone m onitoring sites (Chiwaukee, Milwaukee-Bayside, Harrington Beach, Sheboygan, Manitowoc and Newport) that are targeted for principal ozone analysis in this attainment demonstration tec hnical support document (TSD). These sites were chosen for extra analysis for the following reasons:

• They had the highest 8-hour ozone DVs in Wisconsin during both the 2005-07 and 2006- 08 periods (Chiwaukee, Sheboygan, Manito woc and Newport all exceeded the 1997 8- hour NAAQS during 2005-07). Because these sites have recently had the highest 8-hr O3
DVs - the attainment demonstr ation analysis of these si tes would show the biggest improvements in ozone air quality levels.

• Geographically, the sites repr esent a good spread along Wisconsin’s eastern coastline:
One site in each of the coastal nonattainme nt counties (save for Racine) (Figure 1).

Ozone data from other ozone sites listed in Ta ble 1 are also subject to assessment in this
document.14 Table 1 Ozone Monitoring Sites (a)
2006 – 2008 8-Hr Ozone Design Values

Wis Ozone Nonattainment Counties

Site Name Site Location County 2006-08 8-hr
O3 DV (ppb)(b) Primary Sites for
Attain. Demo. Analysis
Chiwaukee Pleasant Prairie /
Chiwaukee Kenosha 78

Milw-Bayside Milw-B ayside Milwaukee 75 Harrington Beach Harrington Beach State
Park Ozaukee 74

Sheboygan Sheboygan-Kohler Andre
Park Sheboygan 82

Manitowoc Manitowoc-Woodland

Dunes Manitowoc 75

Newport Newport State Park Door 80 Additional Analysis
Sites
Milw-16 th St. Health

Ctr Milw-16 th St. Health Ctr Milwaukee 75

Milw-SER HQ Milw-SER HQ Milwaukee 68

Milw-UWMN Milw-UWMN Milwaukee 72

Grafton Grafton Ozaukee 72

Racine Racine Racine 71 Slinger Slinger Washington 65

Waukesha Waukesha-Cleveland St. Waukesha 66 (a) See Figure 1 for site locations (b) 8-hour ozone NAAQS: 0.08 ppm (84 ppb)

Figure 7 displays the trend in the collective annual number of site-day exceedances of the 1997 8-hour ozone NAAQS for these six primary ozone sites in the 15 years (1994-2008) that they were all operational. This gra phs shows that there has been a wide range in the number of exceedance days over this period. However, th e sites have witnessed considerably fewer exceedances during 2006-08 (37) than during an y other 3 year period since 1994. Equally important is that all the site s – for the first time - recorded no ozone exceedances in 2008.1516 For each of the six primary anal ysis sites - the history of 8-hour ozone DVs and annual number of exceedance days for varying durations are gra phed in Figures 8-13. Each site has its own unique profile. Nevertheless, there are general commonalities in the graphs as follows:

• For those sites whose ozone monitoring extends back to the late 1980s – there has been a substantial improvement in the ozone air qu ality from extremely high peaks (8-hr ozone DVs above 100 ppb) in the late 1980s to DVs in the range of high 80s to mid-90s by
1994.

• There was a general plateau in the 8-hour ozone DVs (ra nge: 90 to 100 ppb) during the mid-to-late 1990s. However, there was still co nsiderable variation in the year-to-year totals of site-day exceedan ces for each monitor.

• Since approximately year 2000 all sites ha ve witnessed a broad, albeit occasionally uneven, shift towards lower DVs (range: 80 to 90 ppb) and decreasing occurrences of exceedance days per year. The DV trend culmin ated with all six analyzed sites achieving attainment for the 2006-08 period. Four of th ese sites (Chiwaukee [Figure 8], Sheboygan [Figure 11], Manitowoc [Figure 12] and New port [Figure 13]) were nonattainment during 2005-07). The substantial decline in ozone exceedance days among all six sites is collectively borne out in Figure 7.17181920 3.3 Ozone Exceedance Days and Hot Temperature Days

A major ingredient in the recipe for high ozone is the presence of relatively warm temperatures (i.e., above 80 F). Many of the photochemical reactions that produce ozone are expedited by ambient temperatures above 80 F (NRC, 1991). Ho lding emissions and air quality levels for ozone precursors approximately constant over a gi ven time period, the incidence of high ozone days might reasonably be correlated with the occurrence of excessively warm days. LADCo’s (2008) definition of a “hot” warm day in th e upper Midwest (i.e., days with maximum temperatures 90 F or greater) for ozon e assessments was employed in this study.

Milwaukee’s Mitchell Field Airport is located 3 m iles west of Lake Michigan’s shoreline and is
witness to much of the same weather that the six primary s horeline ozone sites experience. Additionally, its temperature reco rd is more complete and bett er validated than any of the temperature archives from the WDNR sites. Cons equently, the hourly temperature data from the National Weather Service (NWS) station at Mitchell Field (“MKE”) were used for this analysis.

Figure 14 compares the annual number of calendar da ys with at least one ozone monitoring site exceeding the 1997 8-hour ozone NAAQS in eastern Wi sconsin to the number of 90 F days at MKE during the period 1988 – 2008. The graph shows that the number of hot days at MKE has generally been most frequent during the curren t decade (save for the relatively cool years 2004 and 2008 and the excessively hot year,1998.

Nevertheless, the increasing numbe r of MKE 90 F days has not resulted in more ozone 8-hr exceedance days since 2002. In fact, many more ozone exceedance days occurred during the 1988 – 1999 period when there were fewer hot days (the anomalously warm 1988 excepted).

The annual ratio of high ozone days to hot days in eastern Wisconsin (Figure 15) clearly displays the relatively poor correlation between the form er and latter parameters. The ozone exceedance day / hot day ratio has greatly diminished from the high levels in earl ier years (peak: 11.0 in 1992) to ratios below 2 since 2002. Essentially a 90 F day at MKE is be coming an increasingly less reliable indicator that high ozone will occur somewhere in eastern Wisconsin on that day.

In conclusion, this sizable improvement in the ozone air quality of easte rn Wisconsin is even more remarkable considering that some of the region’s meteorol ogical features (stagnating high pressure systems, lake breeze) greatly enhance th e formation and transport of ozone in the Lake Michigan
airshed.2122 4 Trends in Ozone Precursor Measurement Data

4.1 Introduction

Ambient ozone levels have a non-linear relationshi p to the presence of its precursors (NOx and VOCs). This Chapter assesses the trends in the area’s ambient VOC and NOx air quality

measurements.

As noted in Section 3.2, certain meteorological conditions are favor able to transport of sizable amounts of ozone into the Lake Michigan area. This meteorology is also conducive to advecting VOCs and NOx into the region. Consequently, th e VOC and NOx measurements in Wisconsin can potentially include significant precursors that are emitted from outside of the State.

Monitoring VOCs and NOx is relatively compli cated and labor-intensive. Consequently, measuring these pollutants in Wisconsin’s nonatt ainment areas has been very limited, both in space (a few sites) and calendar (i.e., the ozone season). The only WDNR monitoring sites for ozone precursors that have data histories sufficiently long to ade quately assess th eir trends over the years are located in Milwaukee (Figure 1):

• University of Wisconsin-Milwaukee nor th campus (UWMN [AIRS # 550790041], 2116 E. Kenwood Blvd).

• DNR Southeast Regional Headquarters (DNR SERHQ, [AIRS # 550790026], 2300 N. Dr. Martin Luther King Dr.)

During the 1990s the Milw-UWMN site was WD NR’s principle location for monitoring NOx
and VOCs. The NOx measurements were hour ly-averaged from a continuous sampler. The
VOC concentrations were derived from the lab analysis of integrated ambient air samples collected in canisters - mostly for 3 h our averaging times during 6-9 AM CST.

During 1999-2000 VOC and NOx monitoring shifte d from Milw-UWMN to Milw-SER, which is located approximately 2 air miles southwest of UWMN. The NOx monitoring instrumentation
at SER has been similar to what it was at UWMN.

The VOC data collected at the SER site derived fr om analyzing a continuous flow of ambient air through an automated gas chromatograph (“autoGC ”). The autoGC is operated only during the heart of Wisconsin’s ozone season (June-July-August).

4.2 Diurnal Profiles of Hourly NOx

Figure 16 displays the diurnal profile of median hourly NOx at Milw-UWMN during the most active portion of Wisconsin’s ozone season ( 15 May – 15 Sept) for each year between 1994 and 2000, which was the final year of NOx sampling at UWMN.23 All of Milwaukee-UWMN’s daily urban NOx cycl es shown in Figure 16 have much in common. The sharp increase in concentra tions during the early daylight hours is principally due to the injection of fresh NOx emissions from Milwa ukee’s morning rush hour traffic. Around 8AM there is a steep reduction in NOx. This is due to a combination of incr easing atmospheric mixing / pollution dilution at the surface (L yons, 1975) and the hydroxyl radical ( - OH, mostly formed via photolysis from oxygenated compounds) beginni ng to efficiently remove most of the NOx (Seinfeld and Pandis, 1998).

For purposes of studying overall trends in Mi lw-UWMN’s seven annual NOx profiles in Figure 16, the first year’s data (1994) and the last year’s data (2000 ) are highlighted. The 1994 NOx levels were predominantly the highest of a ll the profiled years. Correspondingly, the 2000 median NOx profile was the lowest fo r many hours during the diurnal period.

Figure 17 is similar to Figure 16, but pertains to the hourly NO x measurements collected at Milw-DNR SERHQ during 15 May – 15 Sept for each year 1999 – 2008. Similar to UWMN, SER’s most recent ozone season (2008) had the lo west NOx measurement series in the graph.

In summary, Figures 16 and 17 appear to indicate that both Milw-UWMN (1994-2000) and Milw-SER (1999-2008) witnessed su bstantial declines in the average diurnal median hourly
NOx concentrations between initial and concludi ng ozone seasons in the sites’ NOx archives.

Of note is that the SER site measures fairly higher NOx concentrations (peak median value: approximately 28 ppb [Figure 17]) than at UW MN (Figure 16, peak median hourly NOx: 23 ppb). That is probably due, at least partially to the difference in si te exposures. The UWMN monitor is located on a moderately -traveled arterial street and is adjacent to a residential neighborhood. On the other hand, the SER site is exposed to much more motor vehicle traffic (and subsequently much more NOx) due to its cl ose proximity to major street arterials and interstate highway.2425 4.3 Diurnal Profiles of Hourly VOCs (TNMOCs)

Figure 18 shows the diurnal prof ile of median hourly TNMOCs at Milw-SER during the JuneAugust period for each year between 1999 and 2007. [As of this writing (mid-June 2009), the TNMOC data for 2008 are still being validated and are currently not availa ble for analysis.]

Each of the median diurnal hourly TNMOC profiles shows basic features that are similar to those for NOx (Figures 16, 17): Maxima occurri ng approximately during 7-9 AM and 9-11 PM. However, the TMNOC fluctuations have less ma gnitude than for NOx, as well as being less coherent among the individual summers.

Nevertheless, the TNMOC graph exhi bits another behavior that is quite similar to those for both NOx displays. Namely, the annual median diurnal profile for TNMOCs duri ng the initial year of operations (1999) is the highest of all nine years’ data displayed – by far. Correspondingly, the most recent year of TNMOC data (2007) is ap proximately average among the remaining summer profiles. The TNMOC curve for 2006 appears to be lowest among all these profiles.2627 4.4 Morning (6-9A CST) VOC and NOx Concentrations

The diurnal profiles of median hourly NOx (Fi gures 16 and 17) and TNMOCs (Figure 18) all
reveal one attribute that is crucial to the form ation of ozone. Namely, during the 6-9 AM period the precursor levels witness a st eep rise to daily peak values, followed by a rapid descent.

The 6 to 9 AM time span is a critical period for assessing precursor levels which often leads to of peak ozone production later in the day (NES CAUM, 1995). Due to morning rush traffic, emissions from motor vehicles are high, while photochemical activity is still minimal during 6- 9AM (NESCAUM, 1995).

Figure 19 presents a time series of monthly me dian values of daily 6-9 AM CST average concentrations of both NOx and hydrocarbons (UWMN: VOCs, SER: TNMOCs) during June, July and August at Milw-UWMN (1994- 99) and Milw-DNR SERHQ (1999-2007).

Each site’s separate trends in median 6-9 AM precursor levels have similar characteristics to those visible in the median diurnal (24-hour) profiles (Figures 16-18) . Namely, both sites witnessed substantial, albeit irregular pollution decreases between initia l and concluding ozone seasons in Figure 19, as follows:

• UWMN NOx 1994: 28.9 ppb 1999: 12.8 ppb (55.7% decrease from 1994)

• UWMN VOC 1994: 151.7 ppbC 1999: 68.5 ppbC (54.8% decrease from 1994)

• SER NOx 1999: 24.8 ppb 2007: 15.3 ppb (38.3% decrease from 1999)

• SER TNMOC 1999: 105 ppbC 2007: 80.2 ppbC (23.6% decrease from 1999)2829 4.5 Morning (6-9A CST) VOC / NOx Ratios in Milwaukee

The relation between ozone, NOx and VOC is driven by complex nonlinear photochemistry. As
noted in Section 4.1 of the Attainment Demonstra tion - the availability of VOCs and NOx in the morning along with their differing rates of reaction with the - OH radical can greatly influence how much ozone is formed for a given site-day (Seinfeld and Pandis, 1998).

The reader is referred to Appendix E (“Overvi ew: VOC / NOx Ratios and Ozone Production“) to get some background on the basics of the ozone sc ience of VOC / NOx ratios that is part of the
discussion in this section.

The morning (6-9 AM CST) VOC and NOx le vels for Milw-UWMN (1994-99) and Milw-SER (1999-2007) that were used to construct Figure 19 have also been employed to derive the median monthly ratios of these 2 metrics (Figure 20). As expected for both of these very urbanized monitoring sites, the VOC / NOx ratios are almost consistently quite low (i.e., less than 6.4, save for the 1998 UWMN exception [7.7]).

This indicates that both sites ar e exposed to relatively sizable NOx levels and subsequently are within air masses defined as VOC-sensitive (App endix E). Consequently, the areas around both sites would be expected to achieve lower ozone levels more efficiently through VOC emission controls (Appendix E).

As is demonstrated in Chapter 5 regardi ng ozone reduction strategies – the WDNR has emphasized VOC controls in the urban areas of the ozone nonattainment counties. Conversely,
in Wisconsin’s more rural ozone nonattainment counties (e.g., Sheboygan, Manitowoc) that haverelatively higher amounts of VOCs, lower NOx and higher VOC / NOx ratios – these “NOxsensitive” counties are being targeted for more NOx controls to effectively reduce ozone concentrations (Appendix E).3031 5 Emission Inventories and Implemented Control Measures

5.1 Introduction

Chapter 3 details the trends that show there ha ve been substantial reduc tions in ambient ozone levels throughout eastern Wiscons in’s ozone nonattainment areas over the past 15-20 years. This
achievement culminated in 2008 with all of Wisc onsin’s ozone sites having 8-hour ozone design values for the 2006-08 period that are below the 1997 8-hour ozone NAAQS. Year 2008 is the first year for which there are no Wisconsin ozone monitoring sites with design values exceeding an ozone NAAQS since the 1970s. Chapter 4 shows the considerable decr ease in ambient ozone precursor concentrations (VOCs, NOx) duri ng the past 10-15 years in Milwaukee.

A major element of this ozone attainment demo nstration is to substantiate that the abovedescribed improvements in ozone air quality ar e due to sizable reductions in VOC and NOx emissions that result from implementing perman ent and enforceable emission control measures (WDNR, 2009). In order to meet this objec tive the WDNR needs to detail these emission changes during critical time periods. The US EPA (2005c) states that it is necessary to develop
several inventories in order to demonstrate compliance with the 8-hour ozone NAAQS, These inventories are for the base year, and meas uring reasonable further progress in emission reductions and for modeling ozone levels.

The remaining sections in this chapter provide an overview of 1) control strategies implemented in Wisconsin to reduce ozone precursor emissions, and 2) how the various emissions inventories of ozone precursors used in th is attainment demonstration were developed for the 9 Wisconsin
ozone nonattainment counties.

5.2 Wisconsin Control Strategies for Ozone Precursor Emissions

As stated in the Redesignation Guidance, in orde r for a state to have an approvable ozone SIP, it must meet all requirements esta blished in Section 110 and Part D of the federal Clean Air Act that were applicable prior to submittal of a complete redesignation request. Wisconsin has met these requirements, excluding the following:

1. 1997 8-Hour Ozone NAAQS A ttainment Demonstration

2. 1997 8-Hour Ozone NAAQS Reasonably Fu rther Progress (RFP) Demonstration

3. A U.S. EPA approved NOx RACT Rule

4. All outstanding CTGs, as part of VOC RACT requirements, prior to 2008.

On March 17, 2008, U.S. EPA issued findings th at the Milwaukee-Racine 6-County Area and Sheboygan County missed CAA deadlines for su bmitting these elements of the state’s 1997 Ozone NAAQS SIP (73 FR 15416). WDNR plans to submit the required documents for the four SIP elements listed above prior to, or concurrently with, submittal of this redesignation request.32 Excluding these 1997 Ozone NAAQS SIP elements, Wisconsin’s Ozone Control SIP is fully approved and contains all federally required emission control programs related to ozone.

The following subsections form a bulleted version of the emissions regulatory analysis portion of the WDNR (2009) document that requests rede signating Wisconsin’s nine counties from
nonattainment to attainment for the 1997 oz one NAAQS. A chronological listing of the administrative rules adopted by the WDNR that are designed to help lo wer ozone levels is contained in Appendix F.

5.2.1 VOC Reasonably Availabl e Control Technology (RACT)

Section 182(b)(2) of the 1990 CAA requires states with moderate nonattainment areas to implement RACT under section 172(c)(1) w ith respect to each of the following:

• Each category of VOC sources in the ozone nonattainment area covered by a US EPA control technique guideline (C TG) document issued between the date of the enactment of
the 1990 CAA and the date of attainment.

• All VOC sources in the area covered by any CTG issued before the enactment date of the
1990 Clean Air Act

• All other major stationary VOC sources that are located in ozone nonattainment areas.

• As a part of its SIP The WDNR has adopt ed and implemented administrative rules requiring all existing major stationary sources of VOCs at the 25 ton-per-year level in the Milwaukee-Racine 6-County ozone nonattainme nt area and Sheboygan County to meet
VOC RACT. Excluded here are those VOC RACT rules for which there are no identified
sources in Wisconsin ozone nonattainment areas.

• Maximum Achievable Control Technology (MACT). Wisconsin has adopted MACT rules further controlling air toxics, whic h include many VOCs, from major sources throughout the state.

All of the above-listed Wiscons in administrative rules and federal regulations collectively comprise a comprehensive VOC emissions control program covering all high-emitting stationary
sources of VOC in the ozone nonattainment areas. Consequently, the WDNR has determined that all of these VOC RACT requireme nts combine to meet the VOC RA CT mandate of Subpart 2 of
the federal Clean Air Act.

VOC RACT rules have been very successful in reducing emissi ons over the past decades as
indicated in Table 2. Note that VOCs and reactiv e organic gases (ROGs) ar e nearly identical in definition and photochemical function. ROG excludes chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs).33 Table 2: Emissions of Reactive Organic Gases in 9-County Area 1985 & 2005

County 1985 ROG (tons) 2005 ROG (tons) 1985-2005

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

Table 2 shows that ROG emissions in the Milw aukee-Racine 6-County Ar ea and the counties of Door, Manitowoc, and Sheboygan have decl ined by 64% in total between 1985 and 2005.

5.2.2 NOx RACT

Beginning in 2001the WDNR estab lished specific NOx controls (Wis. Admin. Code chapter NR 428) as part of the progress plans setting formal maximum NOx budgets within Wisconsin's SIP. In 2006, the WDNR started rule making proceedi ngs to implement NOx RACT requirements on major sources in the Milwaukee-Racine 6-C ounty ozone nonattainment 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.

The WDNR is currently updating ch apter NR 428 to comply with NOx RACT requirements. It is anticipated that the rule will be adopted by spring 2009 and submitted to the U.S. EPA for approval in the summer of 2009.

Of important note is that Wisconsin was removed from US EPA’s original list of 22 states which are required to comply with the Agency’s NOx SIP Call. This NOx SIP call requires statewide reductions in NOx emissions from electric utility boilers, cement kilns, large industrial boilers, and stationary intern al combustion.34 5.2.3 Non-Motor Vehicle Ozone Control Measures in Addition to Clean Air Act Requirements

In anticipation of the need for additional redu ctions beyond the Clean Air Act requirements, The WDNR has worked with many groups, both governmental and non- governmental, to identify and implement additional control measures that can help reduce emissions of ozone precursors. 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).

• Tier 2 Emission Standards for Vehicles and Gasoline Sulfur Standards: A U.S. EPA regulation to significantl y reduce emissions from cars, light trucks, including sport utility vehicles (SUVs) nationally.

• Ultra-low Sulfur Diesel Requirements for Hi ghway Vehicles: Oil refiners must produce diesel fuel for use in highway vehicles w ith a sulfur content of no more than 15 ppm.

• Clean Air Non-road Diesel Rule: This US EPA nationwide regulation requires stringent pollution controls on diesel engines used in i ndustries such as cons truction, agriculture, and mining that will result in a reduction in NOx emissions. In addition, beginning in 2007, sulfur levels in non-road diesel fuels were reduced by 99 percent from current levels (from approximately 3,000 ppm now to 15 ppm in 2010.

• Mobile Sources Air Toxics Rule: This U. S. EPA regulation re duces hazardous air pollutants from mobile sources. These new st andards will have a co-benefit of reducing
VOC emissions.

• Maximum Achievable Control Technology (M ACT) Standards: Using a technology based approach, the U.S. EPA has developed standards for controlling emissions of air toxics, which includes VOCs, from each major type of facility within an industry group.

• Stationary Source NOx Control Program (W is. Adm. Code NR 428): NR 428 addresses stationary source NOx emissions and is struct ured to meet Rate of progress (ROP) NOx emission reduction requirements for larger existing sources and es tablishes emissions standards for new sources through 2007. The program encompasses the seven southeast counties of Kenosha, Milwaukee, Oza ukee, Racine, Sheboygan, Washington, and
Waukesha.

• The Stationary Source NOx control program consists of two basic elements: 1) ozone season emission limits for electric utility system s comprised of boilers equal to or greater than 500 mmbtu/hr; and 2) Unit-specific require ments of either emission rate limits or combustion optimization for other large emission sources.

• 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 in35 a reduction of NOx emissions by 53% by 2009 and 63% by 2015. On December 23, 2008, the D.C. Circuit Court decided to remand, rather than vacate, the CAIR rule, thus leaving CAIR in place while EPA revises the rule. Due to the ongoing litigation involving CAIR, all potential emission reductions resulting from CAIR have been left out of the emission projections.

• Wisconsin’s mercury control regulation with the multi-pollutant compliance option is expected to significantly reduce NOx emissi ons in Wisconsin from electric generating
units.

• Side Benefits of Control of Hazardous Po llutants (Wis. Adm. Code NR 445): NR 445 applies to all stationary air contam inant sources, which may emit hazardous contaminants, which also includes VOCs.

• Clean Diesel Grant Programs: There have b een various programs in Wisconsin to fund diesel emission reduction programs. F unding has been provided by CMAQ, DERA, ARRA, various other EPA grants, the Wiscons in Legislature and i ndividual donations.
Substantial emission reductions ha ve been achieved in the diesel fleet as a result of these
efforts.

5.2.4 Traffic Reduction Measures

The WDNR has partnered with other governmental units and pr ivate organizations on programs to help reduce motor vehicle tra ffic, particularly in the heavil y populated southeastern portion of the State. These voluntary local controls will reduce idling times of motor vehicles and thus
reduce NOx emissions. The state does not comm it to continuing these voluntary programs. These programs, which will include the benefit of helping to lower VOC and NOx emissions are
as follows:

• Local Controls of Traffic Congestion: The Milwaukee-Racine 6-County Area has implemented local controls to decrease the traffic congestion in the city.

• Commuter Value Pass (CVP) & UPASS program s: The CVP transit agency program offers discounted transit passes through large employers, providing a shared cost program between employer and employee.

• Rideshare: A Wisconsin Depa rtment of Transportation in teractive web-based ride matching service.

• Advanced Traveler Information Systems: R eal-time data from traffic condition cameras is used to provide traveler information to the media and motorists.

• Ramp Metering and High-Occupancy Vehicle Priority: Located on freeway entrance ramps to control the rate of entry and encourage rideshari ng and transit use.36 • Park & Rides: A system of park and ri de facilities throughout the area designed for meeting transit and carpools.

• Van Pool (State and MCTS): The State Va npool provides alternativ e transportation for commuting to Madison from the Milwaukee area.

• 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 quali ty conditions and promoting transportation alternatives.

5.2.5 Controls to Remain in Effect

Wisconsin intends to maintain the non-volunt ary control measures listed in 5.22 and 5.2.3. Wisconsin also expects that voluntary programs such as those listed above will continue to provide emission reductions into the future, but there is no commitment to continue those specific programs.

5.3 RFP Emissions Inventories (EIs ): Base 2002 and Projected 2008

Section 182 of the federal Clean Air Act requi res states with ozone nonattainment areas classified as moderate or highe r must submit plans that show reasonable further progress (RFP) towards attaining the NAAQS. The Phase 2 Ozone Implementation Rule (US EPA 2005b) defines RFP towards attaining the 1997 8-hr ozone NAAQS for moderate nonattainment areas (e.g, the 9 ozone nonattainment counties in Wisconsin ) as demonstrating that there has been at
least a 15% emission reduction be tween the base year (2002) and the attainment year (2008). The 15% reduction requirement can be satisfied with any combination of VOC and NO reductions. Additional reductions are also required to achieve attainment beyond 2008.37 5.3.1 2002 Base Year Emissions Inventory for RFP

The base year (2002) portion of the RFP requi rement is a compilation of all anthropogenic sources of VOC and NOx for an average su mmer weekday in 2002, including all control programs in place at that time. The US EPA (2005b, 2005c) has ruled that the 2002 baseline RFP
EI is identical to th e 2002 base year EI.

The WDNR followed EPA’s requirements and guidance and prepared a comprehensive statewide EI of VOC and NOx emissions for year 2002 (WDNR 2009). The 2002 area source
emissions were back-calculated from the 2005 em issions that were estimated with current methodologies. The 2002 inventory includes poin t, mobile, and area sources. A succinct description of the methods and data bases used to develop this EI appears below:

• Point Source EI - The method used to de velop the comprehensive 2002 non-Electric Generating Unit (non-EGU) point source EI is contained in Appendix 4 of WDNR’s (2009) Request for Redesignation to Ozone Atta inment. The method used to develop the 2002 EGU point source EI that incorporates US EPA’s Clean Air Ma rkets Division data is described in Appendix 5 of WDNR’s (2009) Request for Redesignation to Ozone
Attainment.

• Area Source EI - The 2002 area source EI was derived from the Wisconsin 2005 Base Year EI submitted to U.S. EPA in June 2007. The back calculation was performed to maintain consistency between the 8-Hr Ozone Redesigination Request and Maintenance Plan EIs and the RFP EIs. The Redesigna tion EIs used a base year of 2005. 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 and several Wisconsin Stat e agencies. A description of the methods followed to develop the 2002 area source EI is included in Appendix 4 of the WDNR (2009) Request for Redesignation to Ozone A ttainment. Appendix 7 in the redesignation request contains area source emissions by county and SCC.

• Non-road EI – The non-road emission estimat es were prepared by using the U.S. EPA (2005) National Mobile Invent ory (NMIM) model. The co ntractor Pechan, provided
marine and rail emission estimates via LADCo for Wisconsin in 2002. Aircraft emissions were calculated using the Fede ral Aviation Administration’s Emissions and Dispersion Modeling System (EDMS).

• On-road EI - 2002 mobile source emissions we re calculated using the mobile sources
emissions model called MOBILE 6.2. All em ission estimates were made in accordance with MOBILE 6.2’s user’s guide (US EP A 2003) and technical guidance (US EPA 2004).

• Biogenic emissions were not included.

Following these methods, the WDNR constructed a statewide base year 2002 EI for NOx and VOCs. From this EI, the emissions for Wisc onsin’s nine ozone nonattainment counties were38 identified and separated for inclusion here. Tables 3 includes a su mmary for each of the 9 counties – its base year “actual” 2002 county-wi de emissions (units: average summer day) for both for NOx and VOCs. Tables 4 (NOx) and 5 (VOCs) provide more detail by separating the
emissions totals into five EI sour ce sectors: on-road, non-road, commercial marine/aircraft/railroad (MAR ), point and area/nonpoint.

As the year 2002 NOx portion of Table 4 indicat es, the largest base year NOx emission source categories are point and on-road. As expect ed, Milwaukee County had the highest NOx
emissions totals in 2002.

Area and non-road sources account for the largest to tals of the base year VOC emissions (Table 5). Emissions of VOCs are highest in Milwaukee County followed by Waukesha County.3940 5.3.2 Adjusted Base Year 2002 Em issions Inventory (EI) for RFP

In order to demonstrate RFP, a nonattainment area must show that its projected attainment year (2008) EIs of NOx and VOCs will be less than or equal to the required or targeted emission levels set for the end of the RFP period, (i.e ., for moderate ozone nona ttainment areas - the attainment year 2008). The US EPA (2005b) requi res that for moderate ozone nonattainment areas – the target is a 15% re duction in combined VOC and NO x emissions between the base year 2002 and the projected attainment year (2008).

The US EPA also requires that – prior to dete rmining if RFP is achie ved – the base year 2002 emissions (Section 5.3.1) must be adjusted to exclude emission reductions from two noncreditable programs: 1) the Federal Motor Ve hicle Control Program (FMVCP) tailpipe and evaporative standards ap plicable as of January 1, 1990; and 2) Federal regulations limiting the Reid Vapor Pressure (RVP) of gasoline in oz one nonattainment areas applicable June 15, 1990.

Following US EPA supplemental guidance, the Department can assume the gasoline to have an RVP of 9.0 pounds per square inch (psi). The post-1990 RACT "fix-up" requirements are met previously and surpassed with the implement ation of RACT statew ide as required by CAA Section 184(b)(1)(B). Therefore, the ad justment for this in 2002 was zero.

These modifications to the base year 2002 inve ntory are reflected in the VOC and NOx data columns of Table 3 labeled “2002 RFP Adjusted” for each of Wisconsin’s ozone nonattainment counties(units: average summer day).

5.3.3 2008 Projected Emissions Inventory (EI) for RFP

The next step in evaluating RFP is to comp ile a projected 2008 RFP inventory from the 2002 base year inventory (Section 5.3.1) by applying appropriate growth factors and the impact of post-2002 control strategies (Section 5.2) to each source category. Of not e is that the 2008 EGU point emissions are actual rather than projec ted emissions. A summar y of what calculations went into deriving the 2008 RFP emissions inventory is contained in Table 6.

The US EPA’s RFP method specifies that the required 15% RFP reduction can come from any
combination of VOC and NOx reductions o ccurring between 2002 and 2008. Reductions of 35.0% in NOx emissions and 14.7% in VOC accrued between 2002 and 2008 collectively for the 9 ozone nonattainment counties (Table 3). This indicates that the promulgation, implementation and enforcement of the control strategies di scussed in Section 5.2 have been successful.4142 5.4 Base and Future Year Inventories for the Modeled Attainment Test

The US EPA (2007) requires the use of a modeled at tainment test (MAT) to help determine if a region has attained the 1997 8-hour NAAQS. The MAT, which is discussed in more detail in Chapter 6, is a method to estimate future (attain ment) year 2008 eight-hour ozone design values (DVs) by applying proportionality ratios based on modeled ozone predictions (i.e., future year / base year values) to averages of the measured 8-hour ozone DVs centered on the base year (US EPA 2007). If the MAT-derived future estimates of ozone concentrations are less than 85 ppb,
then this element of the attainment test is satisfied.

LADCO (2008, [Appendix A]) conducted the photochem ical grid modeling that formed the basis
for the MAT for ozone nonattainment areas in the upper Midwest including Wisconsin and Illinois (IEPA 2009). LADCO employed the base year emissions inventories for both 2002 and 2005 in the ozone modeling (Appendix A). The US EPA (2007) modeling guidance recommends using 2002 as the baselin e inventory year, but also allo ws for use of an alternative baseline inventory year, esp ecially a more recent year.

The regional ozone concentrations in bot h 2002 and 2005 were above normal (LADCO 2008, [Appendix A]) with 2002 having higher values comp ared to 2005. Examination of multiple base years provides for a more complete technical asse ssment. Both sets of model runs are discussed in Appendix A.

Since the base-year 2005 represented more recent air quality data, there were several inventory improvements to the 2005 base-year and 2005 was after implementation of the NOx SIP call, the WDNR decided to use Base Case M 2005 (L ADCO TSD [Appendix A] as the base year for ozone predictions).

Tabular data and graphical information of base year emissions are pr ovided in Section 3.6 (“Model Inputs: Emissions”) of Appendix A. Add itional detail on the invent ories can be found in the Appendix B (“Base K/Round 4 [2002] St rategy Modeling Emissi ons” [LADCO, May 16, 2006]), and Appendix C (“Base M [2005] Strategy Modeling: Emissions (Revised)” [LADCO, February 27, 2008]).

The methods used to build the emissions invent ory for base year 2005 were similar to those employed in constructing the base year 2002 in ventory for RFP (Section 5.3.1). The inventories were compiled for point, area, on-road mobile , and non-road, emission categories for NOx, and VOCs. Inventories were prepared directly fr om the statewide databa se or generated from approved emissions models (i.e. EGUs, on-road, non-road, etc..).

The methods used to project the emissions i nventory for future year 2008 for ozone modeling from the base year 2005 EI were similar to t hose employed in constructing the future year 2008 inventory for RFP (Section 5.3.3)

Throughout the inventory development process, LADCO and member states implemented quality assurance procedures and quality control checks to assure inventories of the highest quality. Procedures outlined in U.S. EPA guidan ce pertaining to inventory quality assurance were followed, yielding complete, accurate inventories.43 6 Ozone Attainment Demonstration Modeling

6.1 Introduction

States seeking to demonstrate attainment with the ozone NAAQS need to assess whether the emission control measures are truly sufficient to confirm attainment of the ozone NAAQS, as well as maintain this attainment. The US EPA (2 007) requires that this assessment be completed by conducting a modeled attainment demonstration of the nonattainment ar ea(s) in question. The
US EPA further states that a modeled attain ment demonstration can consist of analyses [including computer simulations] which estimate whether selected emissions reductions will result in ambient concentrations that meet the NAAQS.

As noted in Chapter 5 LADCo (Appendix A) conducted a comprehensive ozone modeling program for the upper Midwest, including Wisconsi n. This modeling exercise serves to provide predicted ozone concentrations (base year and fu ture year) to evaluate whether the emissions reductions have resulted in attainment by the required attain ment year of 2008.

Chapter 6 provides a succinct overview of th e various components to this ozone modeling project along with its predicted oz one results that pertinent to Wi sconsin. The information in the following sections is derived largely from that portion of the LADCo (2008) modeling documentation that focuses exclusively on photoc hemical modeling. The modeling project was run in accordance with guidelines established by the US EPA (2007).

6.2 Modeled Years and Emission Scenarios

LADCo conducted photochemical grid modeling fo r several base and future year emissions scenarios. As noted in Chapter 5, the WDNR is using the predicted results in its modeling demonstration which are derived, in part fr om photochemical modeling scenarios (i.e., emissions, ambient air quality, meteorology) for base year 2005 (referred to a Base M in Appendices A and C).

Modeling for attainment year 2008 included an inventory that was appropriately adjusted to 2008 from the base year 2005. The details on how both the base and projected attainment year inventories were compiled are contained in A ppendices A and C. LADCo (Appendix A) also constructed EIs for several projected a ttainment and mainte nance years (2012, 2018).

6.3 Modeling System

LADCO (2008 [Appendix A]) indicates that “the air quality anal yses were conducted with the CAMx model, with emissions and meteorol ogy generated using EMS (and CONCEPT) and MM5, respectively. The selection of CAMx as th e primary model was based on several factors: Performance, operator consider ations (e.g., ease of applicati on and resource requirements), technical support and documentation, model exte nsions (e.g., 2-way nested grids, process analysis, source apportionment, and plume-in-grid, and model science).”44 The Wis DNR and the air quality agencies from the states of Indiana, Michigan, Ohio, and Illinois worked cooperatively with LADCO to refine the CAMx photochemical model to simulate the formation and transport of ozone in the Midwest. The modeling system was used to
evaluate emissions reduction strate gies for inclusion in the states’ attainment plans. A complete description of the modeling methodologies and re sults are contained in the LADCo documents included as Appendices A and D.

The modeling study included emissions, meteorologi cal, and ozone simulations using a nested 36/12/4 km grid covering the central U.S. a nd centered on the Lake Michigan region. The air quality analyses were conducted using the CA Mx model, with emissions and meteorology generated using EMS (and CO NCEPT) and MM5, respectively.

6.4 Modeling Performance Evaluation

As described in Section 3.7 of the LADCO T echnical Support Docume nt (Appendix A), model performance was assessed by comparing modeled a nd monitored concentrati ons with statistical measures recommended by U.S. EPA to assess th e reasonableness of the results. The model performance evaluation focused on the magnitude, spatial pattern, and temporal variations of
modeled and measured concentrations.

The 2002 and 2005 baseline CAMx and CMAQ mode ling databases were evaluated against monitored ozone data from the lower Lake Michig an and Detroit-Clevela nd area in order to
evaluate the fitness of the databases for use in the modeled attainment test. In summary, model performance for ozone is generally accepta ble and can be characterized as follows:

• Good agreement between modeled and monitored concentrations for higher concentration levels (> 60 ppb) – i.e., bias within 30%;

• Regional modeled concentrations appear to be underestimated in the 2002 base year, but show better agreement (with monitored data ) in the 2005 base year due to model and inventory improvements;

• Day-to-day and hour-to-hour variation in and sp atial patterns of modeled concentrations were consistent with monitored data;

• The model accurately simulated the change in monitored ozone concentrations due to reductions in precursor emissions.

6.5 Modeled Attainment Test Results

After detailed performance testing of the 2002 and 2005 base case simulations, the CAMx modeling system was exercised with “On-the- Books” (OTB) emissions control scenarios for both 2008 and 2009 (Appendix A). These scenarios aime d at assessing the effects of future year emission control strategies on ozone in the Midwest.45 As described in Section 4.0 of Appendix A, air quality modeling and other supplemental analyses performed to estimate future year ozone concentrations indicated that:

• Existing (OTB) controls are expected to c ontinue producing signifi cant improvement in ozone air quality.

• Attainment by the applicable attainment da te is dependent on actual future year meteorology (e.g., if weather conditions are si milar to [or less severe than] 2005, then attainment is likely).

The US EPA (2007) requires the use of a modeled at tainment test (MAT) which is described as a procedure in which an air quality model (e.g., CA Mx) is used to simulate current and future ozone air quality. If future ozone predictions, as derived from the MAT, are below the 1997 8-hr ozone NAAQS (84 ppb) then this element of the attainment test is satisfied.

In a MAT, model estimates are used in a “relative” rather than “absolute” sense. These ratios are called “relative reduction factors” (RRF). Futu re 8-hr ozone design value concentrations are estimated at existing monitoring sites by multip lying modeled RRF at locations “near” each monitor by the observation-based monitor-spec ific baseline (2005) ozone design value:

RRF = ratio: modeling cell specific future / base line (i.e.,“Base M”, 2005) modeling results. According to LADCo (2008, Appendix A) the predic ted ozone results were provided for those grid cells with ozone monitors. The RRF calcula tion considers all nearby grid cells (i.e., 3x3 for 12 km modeling) and a threshold of 85 ppb. If th ere were less than 10 days above this value,
then the threshold was lowered unt il either there were 10 days or the threshold reached 70 ppb.

RRF represents predicted percent change in a si te’s ozone between the base year (2005) and future year (attainment year 2008, maintenance years 2009, 2012, 2018).

The next step is to calculate the site-specific base year design values (DVBaseline, units: ppb). For ozone DVBaselines were derived by averaging th e site’s three 3-year periods centered on the emissions base year (i.e: for 2005 base year: 2003-2005, 2004-2006 and 2005-2007).

Next - calculate future year design values: Fo r each grid cell (with a monitor), the RRFs are multiplied by the base year design values to project the future year values.

DVFuture (ppb) = DVBaseline X RRF

Finally, in order to assess whet her or not the site is predic ted to achieve attainment, the DVFuture values are compared to the 8-hour O3 NAAQS (84 ppb).

Table 7 displays the baseline ( 2002-centered) 8-hr ozone design values and the subsequentlyderived RRFs and modeled attainment test (MAT ) results for 7 ozone monitoring sites that are
located in Wisconsin’s ozone nonattainment areas (Figure 1). For the year 2008 attainment scenario, the modeled attainment test show s attainment of the 1997 eight-hour ozone NAAQS
for all seven sites.46 Of note is that the MAT-pred icted 2008 DVs for Newport (8 4.8 ppb) and Sheboygan (84.4 ppb) are quite close to being nonattainment (85 ppb). However, Table 7 also shows that successive MAT results for future maintenance years (2009, 2012, 2018) indicate progressively lower future years’ 8-hr ozone DVs for thes e sites. Furthermore, the MAT predict that ozone NAAQS
attainment will be achieved in 2008 and 2009 with no additional emission control regulations. Namely that the current “On th e Books” control strategies only were included in constructing the 2008 and 2009 emissions data bases for modeling (LADCo, 2008 [appendix A to this Attainment Demonstration]).4748 7 Additional Data Analyses

As noted in section 3.1 the US EPA (2007) re commends that supplemental analyses should accompany all model attainment demonstrations . Included in this assessment are two supplementary analyses that help evaluate progress on improving ozone air quality in
southeastern Wisconsin dur ing the past 10-15 years.

7.1 CART analyses

The first study was LADCo applying a bina ry recursive partitioning method called the

C lassification A nd R egression T ree (CART) analysis to ozone a nd meteorology data for selected ozone monitors in the upper Mi dwest (Kenski, 2009). These s ites have 8-hour ozone design values which have historically been close to or exceeded the NAA QS. The reader is referred to Appendix G for a brief technical overview of the CART model.

The purpose of this CART analysis was to as sess ozone trends, using the CART bins as meteorologically adjusted results (Kenski, 2009).

The focus of the CART analyses presented here are on the collective ozone monitors (total: 5) along the Wisconsin’s coastline with Lake Michig an and Milwaukee’s 3 ozone monitors. Only
monitors with continuous records for the 1995-20 07 period were included in this analysis. Foreach individual monitor, regression trees were developed that classify each summer day (MaySeptember) by its meteorological conditions (Kensk i, 2009). Similar days are assigned to nodes, which are equivalent to branches of the regression tree.

The results of these CART analyses are disp layed in Figures 21 (5 “Wisconsin Shoreline Monitors”) and 22 (3 “Milwaukee” ozone sites). Both displays clearly show that CART’s objective analysis of th e pertinent factors to ozone form ation for the years 1995 to 2007 yield trend lines that show a steady decline in oz one concentrations through this period – and extrapolated into 2009.

The results from this alternative analysis met hod (CART) helps corroborate that the trends in measured ozone (Chapter 3) have been moving noticeably downward over the past 10-20 years, culminating in all Wisconsin sites having 8- hour ozone design values below the 1997 ozone NAAQS for the current 2006-08 period.49 

### Figure 2150 

### Figure 2251 7.2 NOx and VOC Concentrations vs Wind Direction

The second supplemental analysis involves data pairs of hourly-averaged 1) NOx and VOC
concentrations collected at the Milwaukee SER site and 2) wind di rection data collected at the Milwaukee Mitchell Field Airport NWS (MKE) s ite during June-Aug of the year when ozone precursor monitoring commenced at Milw-SER (1999) and the most recent year for which both VOC and NOx data are available (2007). This analysis would offer an understanding how summertime wind-dependent NOx and VOC levels varied between 1999 and 2007. The hourly NOx and VOC data were averaged ac ross 36 separate bins of wind direction - 10 compass degrees - for 1999 and 2007. The NOx vs wind and VOC vs. wind direction are displayed in Figures 23 and 24 respectively.

These graphs both show a similar profile. Namely that the highest concentrations are strongly
associated with winds that have a sizable south-southeasterly to southwesterly orientation (i.e., 160 – 270 degrees, compass direction). This is consistent with the general wind-high ozone characteristics discussed in Chapter 2.

The graphs also show that for both NOx (Figur e 23) and VOCs (Figure 24) - there has been a sizable decline in pollutant le vels across much of wind dire ction spectrum between 1999 and 2007 at Milw-SER. More signif icantly, the largest decreases have been across those wind sectors described above as being associated with the highest pollu tant levels. Figures 23 and 24 help corroborate the findings identified in the NOx and VOC median diurnal profiles (Figures 17, 18) that there has been a sizable reduction in the ambient levels of both pollutants between
1999 and 2007 at Milwaukee-SER.5253 8 Summary and Conclusions.

The nine counties in eastern Wisc onsin that are currently classifi ed as nonattainment of the 1997 eight-hour ozone NAAQS (Figure 1) have had a long history of being witness to excessively high ozone. Southeastern Wisconsin was first classified nonattainment for the 1-hour ozone NAAQS in 1979.

As noted in Chapter 2 these count ies are part of the Lake Mich igan basin, which is a heavily industrialized and populated region. The region ’s considerable amount of ozone precursor
emissions have often combined with the uni que ozone-conducive meteorology of the region (Chapter 2) to yield widespr ead high ozone throughout the basi n with most of the coastal counties having been nonattainment for ozone NAAQS at one time or another for many years (Figure 2).

Nevertheless, Wisconsin has had an aggressive pl an to enact permanent, enforceable rules and regulations during the past three decades in order to help significantly reduce the emissions of VOC and NOx that contribute to the producti on of ozone in these nonattainment counties (Chapter 5). These efforts have resulted in a s ubstantial decline in ambi ent levels of both ozone (Chapter 3) and ozone precurs ors (Chapter 4, Section 7.2) over the past 10-20 years.

The decrease in Wisconsin’s ozone levels achiev ed a milestone in 2008, when all of the State’s
ozone sites derived 8-hour desi gn values that are below the 1 997 8-hr ozone NAAQS. Indeed, there were no exceedances of the 1997 eight-hou r ozone NAAQS anywhere in Wisconsin during 2008 (Figure 7). This achievement has not been r ealized in Wisconsin in at least 30 years.

As part of this attainment demonstration analysis The WDNR submitted to two US EPArequired tests to help evaluate whether the re gulatory actions implemented and enforced have yielded attainment of the 1997 8-hour ozone NAAQS in the nine Wisconsin nonattainment
counties.

The first test is to determine if the implementa tion and enforcement of th e control strategy rules in the 9 counties has yielded a reduction in over all VOC and NOx emissions between base year (2002) and attainment year (2008) that constitute s reasonable further progress (“RFP”: at least a 15% reduction combined for both pollutant s between the 2 years) (US EPA 2007).

Section 5.2 details this emissions accounting wh ich demonstrates that Wisconsin’s emission control strategies are estimated to reduce NOx and VOC emissions between 2002 and 2008 in the 9 nonattainment counties by 35% and 14.7%, respec tively (Table 3). These estimates easily exceed the required 15% RFP requirement.

The second attainment demonstration measure is employing the modeling attainment test (MAT) (US EPA 2007). The MAT pertai ns to using predicted ozone concentrations to derive a proportional change (i.e., relative reduction factor [RRF]) in futu re (i.e., 2008) eight-hour ozone design values, relative to the measured 8- hour ozone design values (centered on 2002).54 Chapter 6 details the WDNR use of the MAT with predicted ozone concentrations calculated for the base year (2005) and attainment year (2008 ) modeling scenarios. The MAT results, which are summarized in Table 7, indicate that the seven ozone sites with the highest ozone design
values in Wisconsin’s ozone nonattainment counties are predicted to attain the ozone standard by the attainment year (2008). Fu rthermore, applying the MAT to predicted ozone concentrations from modeling runs for modeling scenarios 2009, 2012 and 2018 show that these sites are predicted to maintain attainment for these future years (Table 7).

LADCo’s application of the Classification A nd R egression T ree (CART) objective analysis model to ozone and meteorology data for sele cted ozone monitors in Wisconsin during 1995- 2007 clearly yield trend line s that show a steady decline in oz one concentrations at these through this period – and extrapolated into 2009 (Figures 21, 22).

Graphical displays of both NOx and VOCs air quality measurements vs. wind direction at Milwaukee-SER for 1999 and 2007 (Figures 23 and 24 respectively) show that that there has been a sizable decline in both pollutants levels between these 2 years wh en winds transport the highest levels of precursors to th is site (i.e., south-southeasterl y to southwesterly flow). These displays help corroborate the findings identified in the NOx and VOC median diurnal profiles (Figures 17, 18) – that there has been a sizable reducti on in ambient levels of ozone precursors
between 1999 and 2007 at Milwaukee-SER.

All in all, this attainment demonstration st udy presents a considerable body of persuasive evidence that shows that the development, en actment, promulgation and enforcement of the elements in Wisconsin ozone air quality management state implementation plan (SIP) has successfully achieved the goal of attaining the 8-hour ozone NAAQS throughout the state, including the nine counties currently classified as nonatta inment of this NAAQS.55 References

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Nonattainment Areas. Bureau of Air Mgmt, June, 52 pp.58 DOUGLAS BAYFIELD

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