BEFORE THE 

DEPARTMENT OF NATURAL RESOURCES 

Notice of Public Hearing 

Proposed Redesignation to Attainment for the 2006 24-Hour Fine Particulate (PMz.s) National 

Ambient Air Quality Standard (NAAQS) for the Counties of Milwaukee,.Racine, and Waukesha 

NOTICE IS HEREBY GIVEN that pursuant toss. 285.11(5) and (6) and 285.23(2) and (4), Wis. 

Stats., and ch. NR 401, Wis. Adm. Code, the Department of Natural Resources will hold a public hearing 

on its proposal to redesignate the counties of Milwaukee, Racine, and Waukesha from nonattainment to 

attainment for the 2006 24-hour PM25 NAAQS. 

Background 

Under the federal Clean Air Act (CAA), the U.S. Environmental Protection Agency (EPA) is required to 

identify areas that do not meet the NAAQS for PM2.s. The counties of Milwaukee, Racine, and 

Waukesha were designated nonattainment on November 13, 2009 by the U.S. EPA (74 FR 58688). The 

Department has drafted a request to the U.S. EPA that they redesignate these counties from nonattainment 

to attainment based on monitoring data .collected during 2008- 2010. 

NOTICE IS HEREBY FURTHER GIVEN that the public hearing will be held on: 

Monday, May 7, 2012 at 1:00 p.m. 

WI DNR Southeast Region Headquarters, Room 140- 141 

2300 N. Dr. Martin Luther King Jr. Drive 

Milwaukee, WI 

NOTICE IS HEREBY FURTHER GIVEN that pursuant to the Americans with Disabilities Act, 

reasonable accommodations, including the provision of informational material in an alternative format, 

will be provided for qualified individuals with disabilities upon request. Please call Mr. Joseph Hoch at 

(608) 267-7543 with specific information on your request at least 10 days before the date of the scheduled 

hearing. 

Written Comments and Copies of Documents 

Written comments on the draft PM2.

5 redesignation request may be submitted to Mr. Joseph Hoch, Bureau 

of Air Management AM/7, P.O. Box 7921, Madison, WI 53707 no later than May 11,2012. Comments 

may also be submitted electronicall y to joseph.hoc h@wisconsin.gov. Written comments will have the 

same weight and effect as oral statements presented at the hearing. 

The draft PM2.

5 redesignation request may be downloaded from http://dnr.wi.gov/topic/AirOuality or a 

hard copy may be obtained by contacting seph Hoch at (608) 267-7543. 

Dated at Madison, Wisconsin & / ,<::P / ~ 
May 9, 2012

Submitted Electronically

Mr. Joe Hoch

DNR Bureau of Air Management

Wisconsin Department of Natural Resources

P.O. Box 7921

Madison, WI 53707

RE: Comments on DNR’s Proposed Redesignation Request and Maintenance Plan for the 24-

hour Fine Particulate Matter National Ambient Air Quality Standard

Dear Mr. Hoch:

Wisconsin Electric Power Company, doing business as We Energies, submits these comments in

response to the Wisconsin Department of Natural Resources (“WDNR” or the “Department”)

Proposed Redesignation Request and Maintenance Plan for the 24-hour Fine Particulate Matter

National Ambient Air Quality Standard (“Redesignation Request”). WDNR’s Redesignation

Request proposes to redesignate Milwaukee, Racine, and Waukesha counties as attainment areas

meeting the 24-hour Fine Particulate Matter National Ambient Air Quality Standard (PM2.5

NAAQS).

We Energies is an investor-owned electric and gas utility that serves more than 1.1 million electric

customers in Wisconsin and Michigan’s Upper Peninsula and more than 1 million natural gas

customers in Wisconsin. We Energies owns and operates coal-fueled power plants that are located

in the counties that are proposed for redesignation. These include the Milwaukee County Power

Plant, the Valley Power Plant, and all generation units at the Oak Creek Site, including the South

Oak Creek and Oak Creek Expansion units. Future construction permitting activities at any of these

facilities will be impacted by a change in designation status related to the PM2.5 NAAQS.

We are aware of the benefits that may be available to our affected generation units, our customers,

and new business development and growth in southeast Wisconsin if the 3-county area is

redesignated as an attainment area. We understand that a successful designation effort will replace

the need for WDNR to prepare and submit a State Implementation Plan (SIP) revision, which would

necessarily contain an attainment demonstration, additional emissions control measures, and other

requirements. In addition, the requirement to obtain emission offsets and to employ Lowest
We Energies Comments on WDNR Proposed Redesignation Request Related to PM2.5 NAAQS

May 9, 2012

Page 2

Available Emission Rate technologies as part of major source construction permitting would no

longer apply.

While these are all tangible benefits associated with redesignation, there is also a need to resolve

potential associated permitting complexities. Specifically, there is a need to address key technical

issues having to do with regional air pollutants like PM2.5, including the background PM2.5

concentrations that must be used during construction permitting and permit modeling. An advance

effort to manage these related permitting implications will allow southeast Wisconsin to benefit

fully from the proposed redesignation.

Despite the uncertain impacts on construction permitting, WDNR’s proposal to the United States

Environmental Protection Agency (U.S.EPA) to redesignate the three counties in southeast

Wisconsin is generally a positive action because it reflects real improvements in air quality.

Separately, U.S.EPA has published a notice that they are proposing to determine that the

Milwaukee-Racine area has attained the 2006 PM2.5 NAAQS requirements based on certified

monitoring data from the 2008-2010 period. These actions are indicative that air quality is

improving.

Air Quality Improvements

We Energies investment in emission controls and other clean air initiatives has been a contributing

factor to improved air quality in southeast Wisconsin. When construction of the latest air quality

control project is completed at the end of this year, the company will have reduced emissions of

sulfur dioxides (SO2) and nitrogen oxides (NOx) by approximately 90% and 75%, respectively,

from our electric generating facilities in southeast Wisconsin since 2000. See figure 1, below.

Figure 1:
We Energies Comments on WDNR Proposed Redesignation Request Related to PM2.5 NAAQS

May 9, 2012

Page 3

Comments on DNR’s Proposed Redesignation Request and Maintenance Plan

We have reviewed the proposed Redesignation Request prepared by WDNR, and the supporting

analysis in Appendix 3 - An Analysis of Characteristics and Precursors to Ambient PM2.5 Levels in

Southeastern Wisconsin for Purposes of Designing Emission Inventories for Inclusion in a Request

for Redesignation to Attainment for PM2.5Nonattainment Counties of Milwaukee, Waukesha and

Racine, Appendix 4: 2006 and 2010 Point Source Emission Calculations, and Appendix 7: 2020

and 2025 Point Source Emission Calculations. We have two areas of comment to provide on these

draft documents.

The first comment is related to the relevance of a recently published study done jointly by the Lake

Michigan Air Directors Consortium (LADCO), the Electric Power Research Institute (EPRI), and

other contributors1. This study includes an analysis of wintertime episodes of PM2.5 concentrations,

and subsequent scenario analyses of reductions in precursor emissions that contribute to monitored

levels of PM2.5. Our second comment pertains to the point source emission inventories and

projected calculations for We Energies facilities that DNR has used in its Redesignation Request.

I. References to the Lake Michigan Air Directors Consortium and Electric Power

Research Institute Winter Nitrate Study

As stated in its introduction, the purpose of Appendix 3 to WDNR’s proposed Redesignation

Request is to provide a technical demonstration to identify certain long-term characteristics,

distribution and profiles in measured fine particulates and some of their precursors in southeast

Wisconsin. We request that this Appendix be modified to reference a recently completed study that

adds to the technical knowledge of the attributes of PM2.5 and PM2.5 episodes in southeast

Wisconsin.

A collaborative study involving LADCO, EPRI, and other contributors was initiated in 2008 to

collect ambient PM data in Wisconsin and investigate the source of high PM2.5 episodes in the

upper Midwest during winter. Historically, these episodes contributed to nonattainment of the

PM2.5 NAAQS. While these exceedences featured high levels of ammonium and nitrate

particulates, the processes that explain when and how these episodes occur, and the relative role of

nitric acid and ammonia was not well understood. The study sought to develop an improved

conceptual model to describe the nitrate component with respect to, among other things, the

influence of meteorological conditions and contributions from different emissions sources, as well

as insights into potential refinements to reactive nitrogen chemistry represented in air quality

models. The study was conducted using monitoring data at two sites in Wisconsin, an urban site in

Milwaukee and an upwind rural site in Mayville.

A midpoint report on the study (the data analysis phase) was issued in October 2010, and can be

found on LADCO’s website, http://www.ladco.org/. The manuscript for this phase of the study was

submitted on April 4, 2012 to Atmospheric Chemistry and Physics Discussions Journal for peer

1 Other contributors to the “LADCO Winter Nitrate Study” include Atmospheric Research and Analysis (ARA), the

Illinois State Water Survey, the University of Illinois, the University of Iowa, and the Wisconsin Department of Natural

Resources.
We Energies Comments on WDNR Proposed Redesignation Request Related to PM2.5 NAAQS

May 9, 2012

Page 4

review, http://www.atmos-chem-phys-discuss.net/papers_in_open_discussion.html and should

appear on this site shortly. A report on the second phase of the study (the modeling phase) has

recently been completed and should be available on LADCO’s website in the near future. The

manuscript for this phase of the study will also be submitted for peer review.

There are a number of policy-relevant findings contained in this comprehensive study. Of particular

interest to the Redesignation Request is the study’s finding that reductions in ammonia emissions

result in lower modeled PM2.5 levels, and that ammonia emissions reductions have a greater impact

on PM2.5 concentrations than NOx emissions reductions. The study leads to an increased technical

understanding of the chemistry of PM2.5 in the upper Midwest, and was able to demonstrate

generally good agreement between modeled and measured PM2.5 concentrations and characteristics.

Overall the study is important to support air quality management activities related to managing

PM2.5 levels.

Given the importance of the study’s findings, we suggest that a description of the study and the

study findings be added to Appendix C, Section 6 – Evaluating characteristics of PM2.5 in

Milwaukee and Waukesha Counties.

In addition, it is relevant to include ammonia reduction emission strategies in the Maintenance Plan

in Section 7.0 of the Redesignation Request, specifically as a line item in Section 7.5 List of

Potential Additional Control Measures.

II. Comments on Emission Inventory Data Related to We Energies Facilities

We attempted to review the emissions data for the We Energies facilities that were included in

DNR’s underlying analysis. This includes point source data for direct PM2.5, NOx, SO2 and VOCs

for We Energies facilities in the counties of Milwaukee, Racine, and Waukesha.

These data were summarized in Section 4.4 Base Year Inventory (Nonattainment Year Inventory) of

the Redesignation Request, and by facility id (FID) number in Appendix 4. We also reviewed

Section 7.1 Maintenance Inventory Methodology (2020 and 2025) of the Redesignation Request,

which contains the projected emission inventories for 2020 and 2025, and the Electric Generating

Unit (EGU) 2020 and 2025 point source emissions calculations in Appendix 7. Overall, a quick

review of the data related to We Energies facilities looks realistic.

Future Permitting Challenges

As noted in our opening paragraphs, we generally view redesignation to attainment as a positive

action and appreciate DNR’s initiative to proceed with the Redesignation Request. We recognize

that the next steps in the process will involve the state working with U.S.EPA as they evaluate and

act on the redesignation submittal. We would also like to identify some additional activities that we

believe will be valuable as part of transitioning from the construction permitting requirements
We Energies Comments on WDNR Proposed Redesignation Request Related to PM2.5 NAAQS

May 9, 2012

Page 5

currently applicable in nonattainment areas, to different requirements that will apply in attainment

areas.

The Clean Air Act includes a permitting framework for prevention of significant deterioration of air

quality (“PSD”) in areas designated as in attainment with a NAAQS. WDNR implements this

portion of the CAA and carries out the preconstruction permitting of all new or modified major

emitting facilities. As part of this process, those wishing to build or modify major emitting facilities

must undertake an air quality impact analysis to demonstrate that emissions from the proposed

source will not cause or contribute to an exceedence of the PM2.5 NAAQS. In addition, the PSD

regulations call for each permit applicant to conduct a broader source impact analysis to

demonstrate that allowable emission increases from the proposed source or modification, combined

with emissions from other nearby sources and representative background levels of PM2.5, would not

cause or contribute to violations of any NAAQS.

Our primary interest going forward is related to the technical details of this required cumulative

impact analysis. These details pertain to the geographic location, extent of existing sources, higher

emission inventory, and increased population density in the three-county area. While the

Department already has experience with construction permitting in attainment areas in other parts of

the state, we expect that there will be some additional modeling and permitting complications in the

urban area being proposed for redesignation.

The company has been involved in modeling PM2.5 for past permitting actions. Based on this

experience, additional investigation into the applicable PM2.5 background levels to be used in the

counties being proposed for redesignation is needed. In particular, it is unclear how a PSD permit

could be issued for new or modified sources in attainment areas where area monitors are showing

levels of PM2.5 that are very close to the PM2.5 NAAQS. Therefore, the monitoring data used to

develop applicable PM2.5 background levels will be a critical part of future PSD permitting in the

redesignated counties.

Other technical issues that appear to need more review and potential refinement are related to the

regional nature of PM2.5. Secondary formation of PM2.5 from emissions of ammonia, NOx, SO2,

and other compounds from across the region often contribute significantly to total ambient levels of

PM2.5, and therefore must also be accounted for in cumulative modeling exercises. The use of

dispersion models as related to the relatively new PM2.5 NAAQS is continuing to be evaluated and

refined. The modeling challenges related to PM2.5 are well known to the states, regulated sources,

and U.S.EPA.

Consequently, implementation of the PM2.5 NAAQS is still being developed and revised by

U.S.EPA. The agency has recently indicated that they are planning to issue draft PM2.5 Modeling

Guidance in the near future for review and comment. This action has been anticipated for some

time, but has been delayed. U.S.EPA first sought collaborative input from states and other parties

in developing draft PM2.5 Modeling Guidance, and now plans to publish this draft for additional

public comment. We encourage the Department to participate in the upcoming review of EPA’s

draft PM2.5 Modeling Guidance, and provide comment on provisions that would or could affect

future PSD permitting actions in the urban areas proposed for redesignation.
We Energies Comments on WDNR Proposed Redesignation Request Related to PM2.5 NAAQS

May 9, 2012

Page 6

In conclusion, a successful redesignation effort will recognize the underlying improvements in air

quality in southeastern Wisconsin, but unless there is a well-defined PSD permitting process in

place that allows for preconstruction permitting of new or modified sources in these redesignated

areas, then, ironically, there could be impediments to the desired economic growth in this part of the

state that should be anticipated as a result of redesignation.

Once again, We Energies appreciates the effort that the Department has put into developing

this Redesignation Request and the opportunity to comment on it. If you should have any

questions or require further information regarding these comments, please contact Kathleen

Standen, Manager Environmental Regulatory, by telephone at 608-283-3009, or by e-mail at

kathleen.standen@we-energies.com.

Sincerely,

Bruce W. Ramme

Vice President Environmental

Copy: Pat Stevens, Administrator – Air & Waste Division, WDNR

Bart Sponseller, Director – Bureau if Air Management, WDNR
Hoch, Joseph A - DNR

From: Hiebert, Christopher T. [CHIEBERT@SEWRPC.org]

Sent: Wednesday, May 30, 2012 7:43 AM

To: Hoch, Joseph A - DNR

Cc: Yunker, Kenneth R.; Hoel, Ryan W.; Trainer, Patricia - DOT; Glaze, John - DOT; Dwight 

McComb (dwight.mccomb@fhwa.dot.gov); Friedlander, Michael - DNR

Subject: SEWRPC comments regarding the sufficiency of the emission budgets included in the 

PM2.5 redesignation request

Follow Up Flag: Follow up

Flag Status: Blue

Page 1 of 2

06/05/2012

Dear Mr. Hoch,

  

The Southeastern Wisconsin Regional Planning Commission has completed its review of the Wisconsin

Department of Natural Resources’ (WDNR) April 2012 draft document Proposed Redesignation Request and

Maintenance Plan for the 24‐Hour Fine Particulate Matter National Ambient Air Quality Standard for the

Milwaukee‐Racine 3‐County Nonattainment Area. This update included new nitrogen oxide (NOx), fine

particulate (PM2.5), sulfur dioxide (SO2), and volatile organic compound (VOC) emission budgets for the years

2020 and 2025 based on the new emission model (MOVES) promulgated by the U.S. Environmental Protection

Agency (U.S. EPA) on March 2, 2010. At the time the update to the emission inventory and emission budgets was

initiated, U.S. EPA required that this update be conducted using MOVES, as the two‐year grace period to use the

MOVES model was nearing its end (March 2, 2012). The grace period to implement MOVES has subsequently

been extended an additional year.  

  

This is the second time in Wisconsin that the MOVES model has been applied by the WDNR to develop mobile

source emission budgets, and the first time mobile source emission budgets have been developed to for the 24‐

hour fine particulate matter national ambient air quality standard (NAAQS). The emission budgets proposed by

WDNR were estimated based on data from previous emission analyses, including data interpolated from years

other than 2020 and 2025. The proposed emission budgets include a 7.5 percent safety margin necessary to

account for future uncertainties based on changing economic conditions and potential new U.S. EPA required

emission models.  

  

To make a determination as to the sufficiency of the safety margin included in the proposed mobile source

emission budgets, the Commission developed a set of high economic growth emission estimates for the years

2020 and 2025, using both the Commission’s travel demand model and the MOVES emission model, and

compared those estimates to the proposed emission budgets included in the redesignation request.  

Commission staff worked closely with WDNR staff in this effort. The results of this analysis indicated that the

proposed mobile source emission budgets (32.62 tons per winter day in the year 2020 and 28.69 tons per winter

day in the year 2025 for NOx, 2.33 tons per winter day in the year 2020 and 2.16 tons per winter day in the year

2025 for PM2.5, 0.39 tons per winter day in the year 2020 and 0.38 tons per winter day in the year 2025 for SO2,

and 15.89 tons per winter day in the year 2020 and 11.98 tons per winter day in the year 2025 for VOC’s)

included in the draft April 2012 Proposed Redesignation Request and Maintenance Plan for the 24‐Hour Fine

Particulate Matter National Ambient Air Quality Standard for the Milwaukee‐Racine 3‐County Nonattainment

Area do provide a 7.5 percent safety margin as indicated in the draft document.

  

We appreciate the expertise and effort that the WDNR has exercised in conducting the analyses and

documentation necessary to demonstrate attainment of, and to make a redesignation request to the U.S. EPA

from nonattainment to attainment of, 24‐hour fine particulate matter national ambient air quality standard for
the 3‐county Southeastern Wisconsin 24‐hour fine particulate matter nonattainment area.

  

Sincerely,

  

Christopher T. Hiebert, P.E.

Chief Transportation Engineer

Southeastern Wisconsin Regional Planning Commission

W239 N1812 Rockwood Drive

P.O. Box 1607

Waukesha, WI 53187‐1607

Phone: (262)547‐6722 x 227

Fax: (262)547‐1103

chiebert@sewrpc.org

  

Page 2 of 2

06/05/2012
Fine Particulate Matter (PM2.5) Redesignation Request 

Response to Comments 

Comment # Commenter Date of Comment Comment 

1 We Energies May 9, 2012 

Despite the uncertain impacts on construction permitting, WDNR’s proposal to the United States Environmental Protection Agency (U.S.EPA) to redesignate the three counties in southeast Wisconsin is generally a positive action because it reflects real improvements in air quality. 

No response nece

2 We Energies May 9, 2012 

Of particular interest to the Redesignation Request is the study’s finding (LADCO Winter Nitrate Study) that reductions in ammonia emissions result in lower modeled PM2.5 levels, 

and that ammonia emissions reductions have a greater impact on PM2.5 concentrations than NOx

emissions reductions. Given the importance of the study’s findings, we suggest that a description of the study and the study findings be added to Appendix C, Section 6 – Evaluating characteristics of PM2.5 in 

Milwaukee and Waukesha Counties. In addition, it is relevant to include ammonia reduction emission strategies in the Maintenance Plan in Section 7.0 of the Redesignation Request, specifically as a line item in Section 7.5 List of Potential Additional Control Measures. 

Appendix 3 has bdiscussion of the 

a PM2.5 precursor

NH3 emission red

list of potential ad(Section 7.5) of thdocument. 

3 We Energies May 9, 2012 

Overall, a quick review of the data (emissions inventory) related to We Energies facilities looks realistic 

No response nece
Comment # Commenter Date of Comment Comment 

4 We Energies May 9, 2012 

The company has been involved in modeling PM2.5 for past permitting actions. Based on this 

experience, additional investigation into the applicable PM2.5 background levels to be used in 

the counties being proposed for redesignation is needed. In particular, it is unclear how a PSD permit could be issued for new or modified sources in attainment areas where area monitors are showing levels of PM2.5 that are very close to 

the PM2.5 NAAQS. 

The WDNR curreapproach for PM2

data from 2001 – “close” current leWDNR’s approacconcentrations. 

5 SEWRPC May 30, 2012 

The proposed motor vehicle emissions budgets (MVEBs) do in fact provide a 7.5 percent safety margin as indicated. 

No response nece

Commenters

We Energies – Wisconsin Electric Power Company (i.e., We Energies) SEWRPC – Southeastern Wisconsin Regional Planning Commission