8-HOUR OZONE REDESIGNATION REQUEST AND 

MAINTENANCE PLAN FOR THE 

MILWAUKEE-RACINE 6-COUNTY 

SUBPART-2 MODERATE NONATTAINMENT AREA 

SHEBOYGAN COUNTY 

SUBPART-2 MODERATE NONATTAINMENT AREA 

DOOR COUNTY 

SUBPART-1 BASIC NONATTAINMENT AREA 

MANITOWOC COUNTY 

SUBPART-1 BASIC NONATTAINMENT AREA 

WISCONSIN 

Developed By: 

The Wisconsin Department of Natural Resources 

September 2009 
i

Table of Contents 

Table of Contents 

List of Tables 

List of Figures 

List of Appendices 

Introduction 01 

A. Background 01 

B. Geographical Description 03 

I. 

C. Status of Air Quality 03 

II. Requirements for Redesignation 04 

Attainment of the 1997 8-hour Ozone NAAQS 05 

A. Ozone Monitoring Network 05 

B. Ambient Ozone Monitoring Data 08 

C. Quality Assurance 08 

D. Data Completeness and Expected Exceedances 08 

III. 

E. Commitment to Continued Monitoring 11 

IV. All Relevant Requirements Under Section 110 

and Part D of the Act Have Been Met and State 

has Fully Approved SIP Under Section 110(K) 

of the Clean Air Act 

12 

Improvement in Air Quality is due to 

Permanent and Enforceable Measures 13 

A. Nonattainment Year (2002) Inventory 13 

B. Attainment Year (2007) Inventory 15 

C. Permanent and Enforceable Control Measures 18 

1. Rate of Progress Plan 18 

2. Volatile Organic Compound Reasonably 

 Available Control Technology (RACT) 19 

3. Nitrogen Oxides Reasonably Available 

 Control Technology (RACT) 20 

4. Measures in addition to Clean Air Act Requirements 21 

5. Controls to Remain in Effect 24 

V. 

6. New Source Review Provisions 25 

Maintenance Plan Under Section 175(A) of the 

Clean Air Act for the Milwaukee-Racine 6-County Area and 

the counties of Door, Manitowoc, and Sheboygan

26 

A. Attainment Inventory 26 

B. Demonstration of Maintenance 26 

1. Maintenance Inventory Methodology 26 

2. Maintenance Inventory for 2012 and 2020 27 

3. Demonstration of Maintenance 31 

4. Transportation Conformity 31 

5. Provisions for Future Updates 34 

C. Monitoring Network 34 

VI. 

D. Verification of Continued Attainment 34 
ii

E. Contingency Plan 35 

F. Commitment to Revise Maintenance Plan 36 

VII. Attainment of the Revoked 1-Hour Ozone Standard 

for the Milwaukee-Racine 6-County Area 37 

VIII. Public Participation 43 

IX. Conclusions 45 
iii

List of Tables 

Table 1: Ozone Monitors Meeting Data Completeness Requirements 2006 through 2008 

Table 2: Top Four Peak-Daily 8-hr Average Ozone Concentrations and Design Values for 

the Current Wisconsin 1997 Ozone Nonattainment Areas 

Table 3: Average Ozone Season Data Completeness at the Current Wisconsin 1997 Ozone 

Nonattainment Areas 

Table 4: August 15 - 30, 2006 Ozone Monitoring Data in Milwaukee County 

Table 5: Total NOx Emissions for Nonattainment Year 2002 

Table 6: Total VOC Emissions for Nonattainment Year 2002 

Table 7: Total NOx Emissions for Attainment Year 2007 

Table 8: Total VOC Emissions for Attainment Year 2007 

Table 9: Comparison of 9-County Area Total NOx and VOC emissions for 2002 and 2007 

Table 10: Emissions of Reactive Organic Gases in 9-County Area 1985 & 2005 

Table 11: Total NOx Emissions in 2012 

Table 12: Total VOC Emissions in 2012 

Table 13: Total NOx Emissions in 2020 

Table 14: Total VOC Emissions in 2020 

Table 15: Comparison of Total NOx and VOC Emissions 

Table 16: Mobile Sector Budget for the New Maintenance Plan for the Redesignation of the 

Milwaukee-Racine 6-County Area and Door, Manitowoc, and Sheboygan 

Counties

Table 17: 1-Hour Ozone Violation Assessment 2003 – 2008
iv

List of Figures 

Figure 1: Ozone Monitoring Locations in the Current Wisconsin 1997 Ozone 

Nonattainment Areas 

Figure 2: Bayside (550790085) – Milwaukee County 

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 

(April 15 – October 15) 

Figure 3: Grafton (550890008) – Ozaukee County 

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 

(April 15 – October 15) 

Figure 4: Harrington Beach (550890009) – Ozaukee County 

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 

(April 15 – October 15) 

Figure 5: Pleasant Prairie (550590019) – Kenosha County 

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 

(April 15 – October 15) 
v

List of Technical Appendices 

Appendix 1: Redesignation Guidance from U.S. EPA 

Appendix 2: Ozone Data Summaries for 2006 through 2008 

Appendix 3: Components of Wisconsin Ozone SIP 

Appendix 4: 2002 and 2005/2007 Wisconsin Redesignation Emission Inventories 

Documentation 

Appendix 5: EGU Inventory Methodology and Emissions for 2002, 2007, 2012 and 2020 

Appendix 6: Point Non-EGU Emissions for 2002, 2007, 2012 and 2020 

Appendix 7: Area Source Emissions for 2002, 2007, 2012 and 2020 

Appendix 8: Nonroad Emissions for 2002, 2007, 2012 and 2020 

Appendix 9: Onroad Emissions for 2002, 2007, 2012 and 2020 

Appendix 10: Wisconsin MACT Standards 

Appendix 11: State 1-Hour Ozone Redesignation Documents for the Milwaukee-Racine 6-

County Area 

Appendix 12: WDNR's Response to Public Comments
 1 

I. INTRODUCTION 

This document supports Wisconsin’s request that the Milwaukee-Racine 6-County Area, 

and the counties of Door, Manitowoc, and Sheboygan be redesignated from 

nonattainment to attainment of the 1997 8-hour ozone standard. The Milwaukee-Racine 

6-County Area includes the counties of Kenosha, Milwaukee, Ozaukee, Racine, 

Washington, and Waukesha. All of these nonattainment areas are classified as Subpart II 

moderate ozone nonattainment areas, except the counties of Manitowoc and Door, which 

are classified as Subpart I basic ozone nonattainment areas. The ozone monitoring 

stations in all of these nonattainment areas recorded three years of complete, qualityassured ambient air quality monitoring data from 2006 through 2008, demonstrating 

attainment of the 1997 8-hour ozone standard. 

Section 107 of the Clean Air Act (CAA) establishes the following criteria to be met in 

order for an area to be considered for redesignation of a National Ambient Air Quality 

Standard (NAAQS): 

(a) A determination by the U.S. Environmental Protection Agency (EPA) that the 

area has attained the NAAQS (e.g., 1997 ozone standard); 

(b) A fully approved State Implementation Plan (SIP) for the area under Section 

110(k) of the CAA; 

(c) A determination by the U.S. EPA that the improvement in air quality is due to 

permanent and enforceable reductions in emissions; 

(d) A determination that all applicable requirements for the area under Section 110 

and Part D of the CAA have been met; 

(e) A fully approved maintenance plan, including a contingency plan, for the area 

under Section 175(A) of the CAA. 

This document addresses each of these criteria. It also provides additional information to 

support continued compliance with the 1997 8-hour ozone standard. 

A. Background

The CAA requires areas failing to meet the NAAQS for ozone to develop SIPs to 

expeditiously attain and maintain the standard. Historically, exceedances of the ozone 

standard have been monitored in the counties along the western lakeshore of Lake 

Michigan, including the counties of Door, Manitowoc, Sheboygan, and the MilwaukeeRacine 6-County Area. 

In 1991, U.S. EPA identified all areas violating the 1-hour ozone standard as 

nonattainment areas (56 FR 56850). The Milwaukee-Racine 6-County Area was 

designated as severe nonattainment; Sheboygan County as serious nonattainment; 

Manitowoc County as moderate nonattainment; and Door County as rural transport 

(marginal) nonattainment. In 1992, U.S. EPA reclassified Sheboygan County to 

moderate nonattainment. The nonattainment designations were based on monitored 

violations of the NAAQS for ozone. As a result of this classification, the State of 
 2 

Wisconsin was subject to new requirements, including development of a plan to reduce 

volatile organic compound (VOC) emissions and a plan demonstrating that the area 

would meet the federal primary 1-hour standard for ozone by November 15, 1996. 

By the 1993 through 1995 time period, Sheboygan County was monitoring attainment of 

the 1-hour NAAQS. U.S. EPA published a final rule in the Federal Register on August 

26, 1996, redesignating Sheboygan County as attainment for the 1-hour ozone standard 

(61 FR 43675). By the 2001 through 2003 time period, the counties of Manitowoc and 

Door were monitoring attainment of the 1-hour NAAQS. U.S. EPA published a final rule 

in the Federal Register on April 17, 2003, redesignating Manitowoc and Door Counties 

as attainment for the 1-hour ozone standard (68 FR 18884). By the 2003 through 2005 

time period, the Milwaukee-Racine 6-County Area nonattainment area was monitoring 

attainment of the 1-hour NAAQS. The Wisconsin Department of Natural Resources 

(WDNR) reclassified this nonattainment area as an attainment area under s. 285.23, Wis. 

Stats., and ch. NR 401, Wis. Adm. Code on February 10, 2009. Appendix 11 includes 

the documents related to this state redesignation. 

As part of this 8-hour ozone redesignation request, WDNR also requests that U.S. EPA 

redesignate the Milwaukee-Racine 6-County Area to attainment for the revoked 1-hour 

ozone NAAQS. U.S. EPA has already made a formal finding of attainment for the area, 

which was published in the Federal Register on April 24, 2009 (74 FR 18641). The 

ozone monitoring data demonstrating attainment of the revoked 1-hour NAAQS are 

presented in Section VII of this redesignation request. 

On April 30, 2004, U.S. EPA published a final rule in the Federal Register setting forth 

designations and classifications for the 8-hour ozone standard. These designations 

became effective on June 15, 2004. At this time, Door and Manitowoc Counties were 

designated as Subpart 1 basic nonattainment areas for the 8-hour ozone standard. 

Sheboygan County and the Milwaukee-Racine 6-County Area were designated as 

Subpart 2 moderate nonattainment areas for the 8-hour ozone standard. Based on 2006 

through 2008 ozone data, all nine counties are now monitoring attainment of the 8-hour 

ozone standard. 

Based on 2004 through 2006 ozone monitoring data, WDNR submitted a redesignation 

request to U.S. EPA for the Milwaukee-Racine 6-County Area and the counties of 

Manitowoc and Kewaunee for the 8-hour ozone standard on June 14, 2007. U.S. EPA 

published a final rule in the Federal Register on May 21, 2008, redesignating Kewaunee 

County as attainment for the 8-hour ozone standard (73 FR 29346). The other seven 

counties remained as nonattainment because based on 2005 through 2007 ozone 

monitoring data, subsequent exceedances of the 8-hour ozone NAAQS were observed. 

This redesignation request supersedes the previous redesignation request for the 

Milwaukee-Racine 6-County Area and Manitowoc County. 

The attainment level air quality for these nine counties comes as a result of more than 

twenty years of control efforts across the Lake Michigan Region from all sectors to limit 
 3 

and reduce the emissions of VOCs and nitrogen oxides (NOx), precursor pollutants of 

ambient ozone. 

Since 1990, in compliance with the CAA, Wisconsin developed and implemented several 

new programs and new or amended rules designed to control emissions of VOCs and 

NOx. The status of these rules with respect to their approval by the U.S. EPA as SIPs is 

detailed in Section IV. 

B. Geographical Description

The counties of Door and Manitowoc are located in eastern Wisconsin along the western 

shoreline of Lake Michigan. With an estimated 2008 population of 30,303 in Door 

County and 84,830 in Manitowoc County, and predominately agriculturally based 

economies, the populations are approximately 70% and 40% rural, respectively. The 

City of Sturgeon Bay, with an estimate 2008 population of 9,778, is Door County’s 

largest city. The City of Manitowoc, with an estimated 2008 population of 34,670, is 

Manitowoc County’s largest city. 

The following Wisconsin counties in nonattainment of the ozone standard that are 

upwind of Door and Manitowoc Counties, and significantly affect the air quality in the 

counties are: Kenosha, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and 

Waukesha. All of these counties have attained the 8-hour ozone NAAQS and are 

included in this redesignation request. 

Sheboygan County and the Milwaukee-Racine 6-County Area are located in eastern 

Wisconsin along the western shoreline of Lake Michigan. With an estimated 2008 

population of 117,472 in Sheboygan County and 1,897,103 in the Milwaukee-Racine 6-

County Area, and a largely industrial and service-based economy, these seven counties 

comprise approximately 35% of Wisconsin’s entire population. The City of Sheboygan, 

with an estimated 2008 population of 50,580, is Sheboygan County’s largest city. The 

City of Milwaukee, the largest city in Wisconsin with an estimated 2008 population of 

590,870, is the Milwaukee-Racine 6-County Area’s largest city. The densely populated 

Chicago-Gary-Lake County nonattainment area consisting of eight counties is upwind of 

these seven counties and affects the resulting air quality. 

C. Status of Air Quality

Ozone monitoring data for the most recent three years, 2006 through 2008, demonstrate 

that air quality has met the NAAQS for ozone in the Milwaukee-Racine 6-County Area 

and in the counties of Door, Manitowoc, and Sheboygan. This fact, accompanied by the 

decrease in estimated emission levels discussed in Section V, justifies a redesignation to 

attainment for these areas based on Section 107(d)(3)(D) of the CAA. 
 4 

II. REQUIREMENTS FOR REDESIGNATION 

Section 110 and Part D of the CAA list a number of criteria that must be met by 

nonattainment areas prior to consideration for redesignation to attainment. In addition, 

the U.S. EPA has published detailed guidance in a document entitled “Procedures for 

Processing Requests to Redesignate Areas to Attainment,” issued September 4, 1992, to 

U.S. EPA Regional Air Directors. This document is hereafter referred to as 

“Redesignation Guidance.” The Redesignation Guidance is for redesignation requests for 

those areas designated nonattainment under the 1-hour ozone standard. Wisconsin 

received written confirmation from U.S. EPA Region V to use this guidance for 

redesignation requests for the 1997 8-hour ozone nonattainment areas. See Email from 

K. Dagostino, U.S. EPA Region V, dated February 18, 2009 in Appendix 1. This 

Request for Redesignation and Maintenance Plan is based on this Redesignation 

Guidance, supplemented with additional guidance received from staff of U.S. EPA 

Region V. This guidance is included in Appendix 1. 

The following sections below refer in greater detail to the requirements listed in Section I 

of this document. The pertinent sections of the CAA are referenced where appropriate. 
 5 

III. ATTAINMENT OF THE 1997 8-HOUR OZONE NAAQS 

The 1997 8-hour primary and secondary ozone ambient air quality standards are met at an 

ambient air quality monitoring site when the 3-year average of the annual fourth-highest 

daily maximum 8-hour average ozone concentration is less than or equal to 0.08 ppm 

(0.084 ppm rounds down). 

The requirements for ozone monitoring are set out in 42 U.S.C. sec. 107(d)(3)(E)(i) and 

include: 

1) A demonstration that the NAAQS for 8-hour ozone standard, as published in 

40 CFR 50.10, have been attained. Ozone monitoring data must show that 

violations of the ambient standard are no longer occurring. 

2) Ambient monitoring data quality assured in accordance with 40 CFR 58.10, 

recorded in the Air Quality System (AQS) database, previously known as the 

Aerometric Information and Retrieval System (AIRS) database, and available for 

public view. 

3) A commitment that, once redesignated, the state will continue to operate an 

appropriate monitoring network to verify the maintenance of the attainment 

status. 

A. Ozone Monitoring Network

Thirteen ozone monitors operated by the WDNR Air Management Bureau measured 

ozone concentrations in the Milwaukee-Racine 6-County Area and the counties of Door, 

Manitowoc, and Sheboygan during the 3-year period (2006 through 2008) (Table 1). 

Table 1: Ozone Monitors Meeting Data 

Completeness Requirements 2006 through 2008 

County AQS # Site Name Date Monitoring 

Commenced 

Door 550290004 Newport State Park 15-Apr-1989 

Kenosha 550590019 Pleasant Prairie 15-Apr-1988 

Manitowoc 550710007 Woodland Dunes 15-Apr-1994 

Milwaukee 550790010 Mil-16th Street Health Ctr 24-Jun-2003 

Milwaukee 550790026 Mil-SER HQ 01-Jun-1999 

Milwaukee 550790041 Mil-UWMN 01-Jul-1973 

Milwaukee 550790085 Mil-Bayside 01-May-1984 

Ozaukee 550890008 Grafton 05-Jun-1991 

Ozaukee 550890009 Harrington Beach 08-Jun-1994 

Racine 551010017 Racine 26-Aug-1977 

Sheboygan 551170006 Kohler Andre Park 26-Jun-1997 

Washington 551310009 Slinger 06-Jun-1991 

Waukesha 551330027 Waukesha- Cleveland St. 27-Apr-2004 
 6 

• The Door Newport State Park ozone monitor has been in operation for 20 

years. It is located near the tip of the Door County peninsula in Newport State 

Park. Currently, this is the only ozone monitor located in Door County. 

• Situated on Nature Conservancy property, the Pleasant Prairie ozone monitor 

in Kenosha County is located in the far southeastern corner of Wisconsin 

close to the Lake Michigan. It is approximately 600 feet from Lake Michigan. 

The current ozone monitor has yielded 19 years of valid, quality-assured 

ozone data. 

• The Manitowoc Woodland Dunes Monitor is located on the 1,200 acre 

Woodland Dunes Nature Center between Two Rivers and Manitowoc, 

Wisconsin. The current ozone monitor has yielded 14 years of valid, quality 

assured ozone data. Currently, this is the only ozone monitor located in 

Manitowoc County. 

• The Milwaukee 16th Street Health Center ozone monitoring site is a more 

recent addition to the Wisconsin ozone monitoring network. The monitor has 

been in operation since June 2003 and is approximately 2 miles from the Lake 

Michigan shoreline. 

• The ozone monitor located at the WDNR’s Southeast Region (SER) 

Headquarters has operated for 7.5 ozone seasons. SER is situated in an urban 

neighborhood approximately 1.5 miles west of Lake Michigan. 

• The University of Wisconsin Milwaukee (UWM)-North ozone monitor has 

been in operation for nearly 34 years. It is located in an urban setting on the 

UWM-North campus. 

• The Milwaukee Bayside ozone monitor has been a part of the monitoring 

network for 23 years. It is located in northern Milwaukee County 

approximately 0.75 miles west of Lake Michigan. 

• The Grafton ozone monitor is sited in the Village of Grafton in Ozaukee 

County north of Milwaukee. Grafton is located approximately 2 miles west of 

the Lake Michigan shoreline. The ozone monitor has been in operation since 

1991. 

• The Harrington Beach ozone monitor is located in Ozaukee County directly 

on Lake Michigan in a state park about 35 miles north of Milwaukee and 21 

miles south of Sheboygan, Wisconsin. The WDNR has monitored ozone 

concentrations at this rural location for 13 years. 

• The Racine ozone monitor is located in an urban setting in the City of Racine 

approximately 0.8 miles from the Lake Michigan coast. It has provided valid, 

quality-assured ozone data for 29 years. 
 7 

• The Sheboygan Kohler Andre Park ozone monitor has been in operation for 

nearly 12 years. Currently, this is the only ozone monitor located in 

Sheboygan County. Ozone data from other, since discontinued, monitoring 

sites in Sheboygan County are available since 1978. 

• The Slinger ozone monitor has operated in the small village of Slinger at its 

current location for nearly 16 years. It is about 12 miles west of Lake 

Michigan in Washington County. 

• The ozone monitor located on Cleveland Street in Waukesha has been 

operating at this location since April 2004. The site is located in a mixed 

industrial and residential setting approximately 15 miles west of the Lake 

Michigan shoreline and the City of Milwaukee. 

The location of the thirteen monitoring sites in the Milwaukee-Racine 6-County Area and 

the counties of Door, Manitowoc, and Sheboygan are shown in Figure 1. 

Figure 1: Ozone Monitoring Locations in the Current Wisconsin 

1997 Ozone Nonattainment Areas 
 8 

B. Ambient Ozone Monitoring Data

The 1997 8-hour ozone NAAQS are 0.08 parts per million (ppm) averaged over eight 

hours. The ozone NAAQS, both primary and secondary, are attained when the 3-year 

average of the fourth highest 8-hour daily maximum value is less than or equal to 0.08 

ppm (0.084 ppm rounds down). Table 2 contains the top four peak-daily 8-hour ozone 

concentrations measured at the thirteen ozone monitoring sites in the Milwaukee-Racine 

6-County Area and the counties of Door, Manitowoc, and Sheboygan for the period 2006 

through 2008. 

An ozone design value is defined as the 3-year average of the fourth highest 8-hour daily 

maximum ozone concentration. Design values are typically used to classify 

nonattainment areas, assess progress towards meeting the NAAQS, and develop control 

strategies. If the ozone design value is less than or equal to 0.08 ppm (0.084 ppm rounds 

down), then the 1997 8-hour ozone standard is met. Table 2 contains 2006 through 2008 

ozone design values for the thirteen monitoring locations, demonstrating that the NAAQS 

for ozone have been attained at all locations. 

Appendix 2 provides several ozone monitoring data summaries including (1) Quick Look 

Summary Reports, which contain the number of valid ozone monitoring days, the four 

highest 8-hour values by site and date, and the number of exceedance days at each site by 

year, (2) Violation Day Count Reports, which show the number of violation days by year, 

site, and date (3) Data Completeness Reports for 2006 through 2008 detailing the 

monthly and annual ozone monitoring data completeness percentages by year and site 

and (4) the Maximum Values Report, which contains the ten highest 8-hour ozone 

concentrations measured at each site for the period 2006 through 2008. 

C. Quality Assurance

WDNR follows the fully approved Wisconsin Ozone Quality Assurance Plan, in 

accordance with 40 CFR 58.10, to assure the quality of the monitoring data it submits to 

the Air Quality System. All available 2006 through 2008 data for the thirteen ozone 

monitoring sites listed in Table 1 have been recorded and are available in their entirety to 

the public. 

D. Data Completeness and Expected Exceedances

The data completeness reports in Appendix 2 demonstrate that data completeness at the 

ozone monitoring sites meets U.S. EPA requirements for the three year period for all 

monitoring sites. The overall average data completeness for all sites is 98.5%. All sites 

averaged at least 96% completeness for the 3-year period (Table 3). 
 9 

Table 2: Top Four Peak-Daily 8-hr Average Ozone Concentrations and Design 

Values for the Current Wisconsin 1997 Ozone Nonattainment Areas 

8-Hour Average Ozone 

Concentrations (ppm) 

Rank (high to low) County AQS # / 

Site Name Year 

1st 2nd 3rd 4th 

2006-2008 

Ozone Design 

Value (ppm) 1

2006 0.103 0.097 0.079 0.079 

Door 2007 0.095 0.093 0.092 0.092 

550290004 

Newport 

State Park 2008 0.080 0.070 0.069 0.069 

0.080 

2006 0.091 0.085 0.079 0.079 

Kenosha 2007 0.095 0.090 0.090 0.085 

550590019 

Pleasant 

Prairie 2008 0.078 0.075 0.072 0.072 

0.078 

2006 0.104 0.094 0.079 0.078 

Manitowoc 2007 0.092 0.089 0.088 0.085 

550710007 

Woodland 

Dunes 2008 0.074 0.065 0.065 0.064 

0.075 

2006 0.075 0.070 0.066 0.064 

2007 0.075 0.072 0.068 0.067 550790010 

16th St. HC 2008 0.061 0.060 0.060 0.059 

0.063 

2006 0.069 0.069 0.068 0.068 

2007 0.079 0.078 0.078 0.075 

550790026 

WDNR - 

SERHQ 2008 0.068 0.067 0.066 0.063 

0.068 

2006 0.085 0.077 0.074 0.073 

2007 0.086 0.085 0.082 0.078 

550790041 

UWMNorth 2008 0.068 0.066 0.065 0.065 

0.072 

2006 0.085 0.083 0.078 0.073 

2007 0.092 0.091 0.089 0.083 

Milwaukee 

550790085 

Bayside 2008 0.071 0.070 0.069 0.069 

0.075 

2006 0.084 0.080 0.076 0.071 

2007 0.091 0.088 0.086 0.082 550890008 

Grafton 2008 0.068 0.067 0.065 0.064 

0.072 

2006 0.093 0.089 0.075 0.072 

2007 0.088 0.084 0.084 0.084 

Ozaukee 

550890009 

Harr. Beach 

2008 0.070 0.070 0.067 0.067 

0.074 

2006 0.080 0.078 0.072 0.071 

Racine 2007 0.085 0.080 0.079 0.077 551010017 

Racine 

2008 0.070 0.068 0.066 0.065 

0.071 

2006 0.109 0.097 0.090 0.083 

Sheboygan 2007 0.092 0.090 0.088 0.088 

551170006 

Kohler 

Andre Park 2008 0.079 0.076 0.075 0.075 

0.082 

2006 0.069 0.069 0.068 0.066 

Washington 2007 0.073 0.071 0.071 0.071 551310009 

Slinger 2008 0.061 0.060 0.060 0.060 

0.065 

2006 0.075 0.068 0.068 0.067 

Waukesha 2007 0.075 0.075 0.073 0.072 551330027 

Waukesha 

2008 0.067 0.064 0.062 0.060 

0.066 

Data Source: http://www.epa.gov/oar/data/

 

1

 Design values ≤ 0.084 show attainment of the 1997 ozone standard. 
 10 

Table 3: Average Ozone Season Data Completeness at the Current 

Wisconsin 1997 Ozone Nonattainment Areas 

County AQS # Site Name 2006 

(%) 

2007 

(%) 

2008 

(%) 

Door 550290004 Newport State Park 100 98 99 

Kenosha 550590019 Pleasant Prairie 97 100 100 

Manitowoc 550710007 Woodland Dunes 100 99 92 

Milwaukee 550790010 16th St. HC 99 100 99 

Milwaukee 550790026 WDNR - SERHQ 91 98 99 

Milwaukee 550790041 UWM-North 98 99 100 

Milwaukee 550790085 Bayside 99 98 98 

Ozaukee 550890008 Grafton 100 100 100 

Ozaukee 550890009 Harr. Beach 100 100 98 

Racine 551010017 Racine 99 93 97 

Sheboygan 551170006 Kohler Andre Park 99 99 95 

Washington 551310009 Slinger 99 100 99 

Waukesha 551330027 Waukesha 100 99 100 

Data Source: http://www.epa.gov/oar/data/ 

In 2006, Milwaukee WDNR Southeast Regional Headquarters (SERHQ) achieved 91% 

data completeness. Despite lower data capture in 2006, the 3-year data completeness 

average at SERHQ is 96.0%. Between August 15, 2006 and August 30, the Southeast 

Region Headquarters building underwent roof resurfacing using chemicals. For the 

approximately 16 day period, monitoring staff covered the sampling line to protect the 

inlet and prevent the collection of potentially spurious ozone levels. 

The maximum daily 8-hour average ozone concentrations from the 3 closest ozone 

monitoring sites in Milwaukee County are shown in Table 4 below. 

As Table 4 indicates, ozone concentrations measured at nearest ozone monitoring sites 

during this 16-day period did not approach 0.085 ppm. The maximum 8-hour ozone 

concentration (0.068 ppm) measured at UWM-North is equal to the 4th high measured 

concentration at Southeast Region Headquarters in 2006. Assuming that the maximum 

daily 8-hour ozone concentrations at the other three ozone sites in Milwaukee County are 

representative of ozone measured at SERHQ, it is clear that the lack of data at WDNR - 

SERHQ during this timeframe would not alter the site’s calculated design value for the 3-

year period (2006 through 2008). Additionally, the 4th highest value in 2006 would need 

to equal 0.117 ppm to create a 3-year design value of 0.085 ppm. The lack of ozone data 

during the 16-day period has little bearing on the design value at the WDNR – SERHQ 

monitoring site. 
 11 

Table 4: August 15 - 30, 2006 Ozone Monitoring Data in Milwaukee County 

Date 

16th St. HC 

8-hr Peak Daily O3 

Conc. (ppm) 

UWM-North 

8-hr Peak Daily O3 

Conc. (ppm) 

Bayside 

8-hr Peak Daily O3 

Conc. (ppm) 

8/15/2006 0.042 0.043 0.040 

8/16/2006 0.060 0.059 0.050 

8/17/2006 0.054 0.057 0.050 

8/18/2006 0.065 0.068 0.061 

8/19/2006 0.050 0.053 0.048 

8/20/2006 0.029 0.029 0.023 

8/21/2006 0.053 0.052 0.049 

8/22/2006 0.048 0.046 0.036 

8/23/2006 0.043 0.044 0.040 

8/24/2006 0.047 0.047 0.040 

8/25/2006 0.036 0.033 0.025 

8/26/2006 0.036 0.036 0.032 

8/27/2006 0.040 0.039 0.027 

8/28/2006 0.034 0.033 0.025 

8/29/2006 0.038 0.036 0.023 

8/30/2006 0.028 0.028 0.021 

E. Commitment to Continued Monitoring

The WDNR commits to continue monitoring ozone levels in the Milwaukee-Racine 6-

County Area and the counties of Door, Manitowoc, and Sheboygan indefinitely. WDNR 

will discuss changes in siting that may become necessary with U.S. EPA Region V staff. 

WDNR will continue to quality assure the monitoring data to meet the requirements of 40 

CFR 58. Connection to a central station and updates to the WDNR website1 will provide 

real-time availability of the data and knowledge of any exceedances to the public. 

WDNR will enter all data into AQS on a timely basis in accordance with federal 

guidelines. 

 

1

 http://maps.dnr.state.wi.us/imf/dnrimf.jsp?site=wisards 
 12 

IV. ALL RELEVANT REQUIREMENTS UNDER SECTION 110 AND 

PART D OF THE ACT HAVE BEEN MET AND STATE HAS 

FULLY APPROVED SIP UNDER SECTION 110(K) OF THE 

CLEAN AIR ACT 

As stated in the Redesignation Guidance, a state must meet all CAA requirements of 

Section 110 and Part D 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 Attainment Demonstration 

2. 1997 8-Hour Ozone NAAQS Reasonably Further 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 that the Milwaukee-Racine 6-County Area 

and Sheboygan County missed CAA deadlines for submitting 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. 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. 

Wisconsin’s Ozone Control SIP for Subpart 1 areas, including the counties of Manitowoc 

and Door, is fully approved and contains all federally required emission control programs 

related to ozone. Appendix 3 lists the major state and federal control program 

components of Wisconsin’s Approved Ozone Attainment SIP, providing information on 

year of submittal and approval and most recent status. 

CAA Sections 172(c)(3) and 182(a)(1) require the submittal of U.S. EPA approved base 

year inventories for an area to be redesignated from nonattainment to attainment. The 

inventories developed as part of this redesignation request, and presented in the following 

section, are intended to meet this requirement. 
 13 

V. IMPROVEMENT IN AIR QUALITY IS DUE TO PERMANENT 

AND ENFORCEABLE MEASURES 

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

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

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

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

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

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

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

specific permanent and enforceable programs responsible for emission reductions over 

this time period. 

A. Nonattainment Year (2002) Inventory

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

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

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

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

methodologies follows. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

methodologies followed to develop the original and backcasted 2002 inventory is 

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

SCC, including the backcasted growth factors. 

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

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

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

2002. Aircraft emissions were calculated using the Federal Aviation 

Administration’s Emissions and Dispersion Modeling System (EDMS). 
 14 

• Onroad Inventory - 2002 mobile source emissions were calculated using 

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

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

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

The Technical Guidance on the Use of MOBILE6 for Emission Inventory 

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

Quality, January 2002. 

 

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

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

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

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

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

County followed by Waukesha County. 

Table 5: Total NOx Emissions for Nonattainment Year 2002 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 67.64 0.80 8.08 4.42 80.94 

Milwaukee 37.80 6.10 44.44 18.50 106.84 

Ozaukee 6.49 0.60 6.66 5.83 19.58 

Racine 1.55 1.08 8.71 5.94 17.28 

Washington 0.36 0.86 9.71 4.31 15.24 

Waukesha 0.89 3.43 25.58 12.94 42.84 

MilwaukeeRacine 

6-Co. Area 

114.73 12.87 103.18 51.94 282.72 

Door 0.01 0.19 2.68 6.74 9.62 

Manitowoc 2.83 0.42 7.41 4.21 14.87 

Sheboygan 26.07 1.00 8.25 4.47 39.79 

* Point includes combined non-EGU and EGU emissions 

Table 6: Total VOC Emissions for Nonattainment Year 2002 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 0.63 6.22 3.61 4.99 15.45 

Milwaukee 7.54 45.90 20.92 18.38 92.74 

Ozaukee 0.51 6.77 2.54 3.07 12.89 

Racine 1.61 18.19 4.06 6.78 30.64 

Washington 0.62 11.41 3.61 6.34 21.98 

Waukesha 3.81 18.12 10.62 21.63 54.18 

MilwaukeeRacine 

6-Co. Area 

14.72 106.61 45.36 61.19 227.88 

Door 0.23 1.57 1.39 9.63 12.82 

Manitowoc 1.58 4.63 3.26 3.59 13.06 

Sheboygan 2.50 7.59 3.76 5.62 19.47 

* Point includes combined non-EGU and EGU emissions 
 15 

B. Attainment Year (2007) Inventory

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

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

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

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

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

approach. The 2007 inventory emissions were determined using the following 

approaches. 

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

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

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

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

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

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

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

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

Business Patterns data1

. Next county-specific growth factors developed by Pechan2

contained in the document entitled Development of Updated Growth and Control 

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

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

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

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

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

emission controls, and grown emissions by county and SCC. 

• Nonroad Inventory Projections - 2007 nonroad mobile emission estimates were 

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

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

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

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

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

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

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

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

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

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

 

1

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

2

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

emission inventory data, including growth factors, for the entire LADCO region. 
 16 

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

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

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

and the counties of Door, Manitowoc, and Sheboygan. 

Table 7: Total NOx Emissions for Attainment Year 2007 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 10.62 0.83 6.05 3.95 21.45 

Milwaukee 26.88 6.29 29.81 16.83 79.81 

Ozaukee 1.11 0.62 4.70 4.84 11.27 

Racine 0.93 1.12 6.21 5.17 13.43 

Washington 0.74 0.90 7.20 3.61 12.45 

Waukesha 1.41 3.54 19.24 11.26 35.45 

MilwaukeeRacine 

6-Co. Area 

41.69 13.30 73.21 45.66 173.86 

Door 0.002 0.20 1.97 5.28 7.452 

Manitowoc 3.13 0.43 5.38 3.61 12.55 

Sheboygan 12.99 1.04 5.81 3.73 23.57 

* Point includes combined non-EGU and EGU emissions 

Table 8: Total VOC Emissions for Attainment Year 2007 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 1.61 5.72 2.63 4.13 14.09 

Milwaukee 5.16 41.40 13.75 14.46 74.77 

Ozaukee 0.46 6.41 1.75 2.23 10.85 

Racine 1.25 17.17 2.82 5.59 26.83 

Washington 0.59 11.03 2.63 5.07 19.32 

Waukesha 3.13 16.82 7.81 16.97 44.73 

MilwaukeeRacine 

6-Co. Area 

12.20 98.55 31.39 48.45 190.59 

Door 0.30 1.51 0.93 8.85 11.59 

Manitowoc 1.43 4.39 2.24 3.15 11.21 

Sheboygan 2.26 7.08 2.50 5.02 16.86 

* Point includes combined non-EGU and EGU emissions 
 17 

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

for 2002 and 2007

(Tons per summer day) 

Milwaukee-Racine 6-County Area 

NOx VOC 

Sector 2002 2007 Net Change 

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

Point 114.73 41.69 -73.04 14.72 12.20 -2.52 

Area 12.87 13.30 0.43 106.61 98.55 -8.06 

Onroad 103.18 73.21 -29.97 45.36 31.39 -13.97 

Nonroad 51.94 45.66 -6.28 61.19 48.45 -12.74 

Total 282.72 173.86 -108.86 227.88 190.59 -37.29 

Door County 

NOx VOC 

Sector 2002 2007 Net Change 

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

Point 0.01 0.002 -0.01 0.23 0.30 0.07 

Area 0.19 0.20 0.01 1.57 1.51 -0.06 

Onroad 2.68 1.97 -0.71 1.39 0.93 -0.46 

Nonroad 6.74 5.28 -1.46 9.63 8.85 -0.78 

Total 9.62 7.452 -2.17 12.82 11.59 -1.23 

Manitowoc County 

NOx VOC 

Sector 2002 2007 Net Change 

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

Point 2.83 3.13 0.30 1.58 1.43 -0.15 

Area 0.42 0.43 0.01 4.63 4.39 -0.24 

Onroad 7.41 5.38 -2.03 3.26 2.24 -1.02 

Nonroad 4.21 3.61 -0.60 3.59 3.15 -0.44 

Total 14.87 12.55 -2.32 13.06 11.21 -1.85 

Sheboygan County 

NOx VOC 

Sector 2002 2007 Net Change 

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

Point 26.07 12.99 -13.08 2.50 2.26 -0.24 

Area 1.00 1.04 0.04 7.59 7.08 -0.51 

Onroad 8.25 5.81 -2.44 3.76 2.50 -1.26 

Nonroad 4.47 3.73 -0.74 5.62 5.02 -0.60 

Total 39.79 23.57 -16.22 19.47 16.86 -2.61 
 18 

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

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

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

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

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

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

C. Permanent and Enforceable Control Measures

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

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

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

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

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

counties. 

1. Rate of Progress Plan 

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

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

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

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

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

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

instituted in addition to existing air quality control measures.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

some voluntary industrial solvent regulation enhancements. 
 19 

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

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

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

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

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

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

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

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

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

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

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

reducing VOC emissions by 9% from 1996 to 1999. 

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

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

ROP SIP revisions (66 FR 51572). 

2. VOC Reasonably Available Control Technology 

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

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

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

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

the date of attainment 

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

date of the 1990 CAA 

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

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

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

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

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

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

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

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

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

County. 

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

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

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

categories and therefore rules need not be adopted for those categories. 
 20 

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

Achievable Control Technology (MACT) rules further controlling VOC emissions 

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

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

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

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

that it meets the Subpart 2 VOC RACT requirement. 

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

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

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

Table 10: Emissions of Reactive Organic Gases 

in 9-County Area 1985 & 2005 

County 1985 ROG 

(tons) 

2005 ROG 

(tons) 

Percent 

Decrease 

(%) 

Door 214.23 105.65 50.7 

Kenosha 840.19 534.97 36.3 

Manitowoc 470.24 559.20 -18.9 

Milwaukee 10,728.51 2,143.25 80.0 

Ozaukee 283.69 156.24 44.9 

Racine 1,235.84 448.89 63.7 

Sheboygan 1,244.94 908.28 27.0 

Washington 619.00 222.00 64.1 

Waukesha 1,647.31 1,147.63 30.3 

Totals 17,283.95 6,226.11 64.0 

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

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

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

3. NOx Reasonably Available Control Technology 

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

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

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

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

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

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

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

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

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

submit this rule prior to, or concurrently with, submittal of this redesignation request. 
 21 

4. Measures in addition to Clean Air Act Requirements 

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

Wisconsin worked with the community to identify and implement additional control 

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

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

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

non-voluntary control measures include: 

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

rulemaking in September 1998 requiring 22 states to reduce NOx emissions 

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

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

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

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

industrial boilers, and stationary internal combustion engines. Implementation 

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

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

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

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

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

after the NOx SIP call was finalized. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

SUVs, vans, and heavier trucks. 
 22 

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

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

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

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

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

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

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

Air Nonroad Diesel Rule which requires stringent pollution controls on diesel 

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

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

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

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

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

rule also requires engine manufacturers to use advanced clean technologies, 

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

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

nationwide. 

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

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

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

hydrocarbon exhaust emissions from new gasoline-fueled passenger vehicles, 

more stringent evaporative emissions standards for new passenger vehicles 

and establishing standards that will limit hydrocarbon emissions that 

evaporate from and permeate through portable fuel containers such as gas 

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

• Maximum Achievable Control Technology Standards: Using a technology 

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

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

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

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

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

Door, Manitowoc, and Sheboygan see Appendix 10. 

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

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

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

attainment deadline for the Lake Michigan region. The program encompasses 

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

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

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

standards for new sources. The existing source control program reduces 

emissions at electric utility facilities and on larger industrial combustion 

sources from projected baseline levels in 2002. The performance standards 
 23 

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

seven counties and for those undergoing major modification. 

The existing source performance standards affect 48 individual units at 21 

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

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

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

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

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

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

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

combustion optimization for other large emission sources. 

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

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

this redesignation request. 

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

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

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

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

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

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

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

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

litigation involving CAIR, all potential emission reductions resulting from 

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

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

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

emit hazardous contaminants. Some sources may be exempt from these 

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

result in the reduction of NOx emissions from the nonroad stationary 

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

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

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

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

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

Manitowoc, and Sheboygan. 

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

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

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

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

these voluntary programs. Implemented measures include:
 24 

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

agency program offers discounted transit passes through large employers, 

providing a shared cost program between employer and employee. The 

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

transit passes paid through student fees. 

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

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

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

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

using electronic messaging signs. 

• Education/Marketing Promotion: Wisconsin Partners for Clean Air 

voluntary coalition promoting emission reductions along with an Air 

Quality Watch & Advisory Program alerting the public to air quality 

conditions and promoting transportation alternatives. 

• Traffic Incident Management: A freeway operational detection and control 

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

and motorists. (limited to Kenosha and Racine counties) 

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

freeway entrance ramps to control the rate of entry and encourage 

ridesharing and transit use. 

• Guaranteed Ride Home (State and Milwaukee County Transit System 

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

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

WisDot also offers reimbursement to employers who offer a guaranteed 

ride when an unforeseen event occurs. 

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

transportation for commuting to Madison from the Milwaukee area. 

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

designed for meeting transit and carpools. 

5. Controls to Remain in Effect 

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

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

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

standard in the Milwaukee-Racine 6-County Area or the counties of Door, Manitowoc, or 
 25 

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

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

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

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

6. New Source Review Provisions 

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

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

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

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

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

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

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

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

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

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

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

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

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

requirement. 
 26 

VI. MAINTENANCE PLAN UNDER SECTION 175(A) OF THE 

CLEAN AIR ACT FOR THE MILWAUKEE-RACINE 6-COUNTY 

AREA AND THE COUNTIES OF DOOR, MANITOWOC, AND 

SHEBOYGAN 

Section 175A of the CAA sets forth the elements of a maintenance plan for areas seeking 

redesignation from nonattainment to attainment. The plan must demonstrate continued 

attainment of the applicable NAAQS for at least 10 years after the U.S. EPA approves a 

redesignation to attainment. Eight years after the redesignation, the state must submit a 

revised maintenance plan, which demonstrates attainment for the 10 years following the 

initial 10-year period. To address potential future NAAQS violations, the maintenance 

plan must contain contingency measures, with a schedule for implementation adequate to 

assure prompt correction of any air quality problems. 

Section 175A(d) requires that the contingency provisions include a requirement that the 

state will implement all control measures that were in the SIP prior to redesignation as an 

attainment area. 

An ozone maintenance plan should address the following five elements: attainment 

inventory, demonstration of maintenance, monitoring network, verification of continued 

attainment and a contingency plan. 

A. Attainment Inventory

Wisconsin used the year 2007 to demonstrate attainment as discussed above in Section V. 

B. Demonstration of Maintenance

In order to demonstrate continued attainment for ten years after U.S. EPA approves the 

redesignation, the state is required to develop projected inventories. After discussion 

with U.S. EPA Region V staff and receiving their written confirmation (Appendix 1), 

WDNR is using 2012 as the interim projection year. The Redesignation Guidance 

requires the maintenance year be at least 10 years after the redesignation request is 

approved by U.S. EPA. The year 2020 meets this requirement and is used as the 

maintenance year. 

1. Maintenance Inventory Methodology 

This section contains projected emissions for 2012 and 2020 inventories for the 

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

WDNR performed emission projections using the following approaches. 

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

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

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

priority was given to county-specific employment based growth factors. Next, if 
 27 

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

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

Business Patterns data1

. Next county-specific growth factors developed by Pechan2

contained in the document entitled Development of Updated Growth and Control 

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

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

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

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

growth factors were available. Growth factors were only available for emission 

projections to 2018. Emissions for 2020 were estimated using linear interpolation 

from 2018. WDNR received written confirmation that this is an acceptable approach 

(see Appendix 1). EGU emissions projections were grown from information 

provided by an Air Management engineer and EGU specialist. Again, this detailed 

EGU methodology is contained in Appendix 5. 

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

factors and applicable emission controls to the 2005 attainment year inventory. For 

area source emission projections, the same prioritization schema was applied as with 

point sources. Emissions for 2020 were estimated using linear interpolation from 

2018. WDNR received written confirmation that this is an acceptable approach (see 

Appendix 1). Appendix 7 contains area source growth factors, emission controls, and 

grown emissions by county and SCC. 

• Nonroad Inventory Projections – 2012 and 2020 nonroad mobile emission estimates 

were prepared by using the U.S. EPA NMIM model. Marine and rail emissions were 

grown from 2005 Pechan state-wide growth factors. EGAS 6.0-generated growth 

factors were used to grow the aircraft inventory. Marine, air, and rail emissions for 

2020 were estimated using linear interpolation from 2018. WDNR received written 

confirmation that this is an acceptable approach (see Appendix 1).

• Onroad Inventory Projections - Emission projections were created using the US EPA 

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

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

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

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

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

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

2. Maintenance Inventory for 2012 and 2020 

The maintenance emission inventory estimates are presented in the tables below and 

demonstrate that NOx and VOC emissions will decrease in future years. The results of 

this analysis show that the Milwaukee-Racine 6-County Area and the counties of Door, 

 

1

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

2

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

emission inventory data, including growth factors, for the entire LADCO region. 
 28 

Manitowoc, and Sheboygan are expected to maintain the air quality standard for at least 

ten years into the future. 

Table 11: Total NOx Emissions in 2012 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 16.27 0.84 3.79 3.41 24.31 

Milwaukee 37.76 6.37 19.10 14.04 77.27 

Ozaukee 1.17 0.64 3.02 3.65 8.48 

Racine 0.61 1.14 3.87 4.36 9.98 

Washington 0.58 0.92 4.89 2.81 9.20 

Waukesha 1.09 3.61 12.59 8.89 26.18 

MilwaukeeRacine 

6-Co. Area 

57.48 13.52 47.27 37.16 155.43 

Door 0.002 0.20 1.55 5.49 7.242 

Manitowoc 3.69 0.44 3.76 3.16 11.05 

Sheboygan 15.07 1.07 4.15 2.92 23.21 

* Point includes combined non-EGU and EGU emissions 

* Onroad includes uncertainty factor (7.5% for Milwaukee-Racine Counties, 

15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth 

factor is less because a high growth assumption was used for VMT 

projections.

Table 12: Total VOC Emissions in 2012 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 1.13 5.70 1.85 3.47 12.15 

Milwaukee 8.68 40.44 9.87 12.34 71.33 

Ozaukee 0.56 6.29 1.26 1.81 9.92 

Racine 1.32 17.14 1.97 4.67 25.10 

Washington 0.54 11.07 2.00 4.23 17.84 

Waukesha 4.11 17.36 5.72 14.08 41.27 

MilwaukeeRacine 

6-Co. Area 

16.34 98.00 22.66 40.60 177.60 

Door 0.16 1.52 0.78 7.53 9.99 

Manitowoc 1.64 4.41 1.76 2.59 10.40 

Sheboygan 2.88 7.02 2.01 4.12 16.03 

* Point includes combined non-EGU and EGU emissions 

* Onroad includes uncertainty factor (7.5% for Milwaukee-Racine Counties, 

15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth 

factor is less because a high growth assumption was used for VMT 

projections.
 29 

Table 13: Total NOx Emissions in 2020 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 16.65 0.87 1.64 2.94 22.10 

Milwaukee 30.47 6.50 7.91 12.20 57.08 

Ozaukee 1.38 0.66 1.29 2.17 5.50 

Racine 0.61 1.18 1.62 3.70 7.11 

Washington 0.68 0.95 2.26 2.12 6.01 

Waukesha 1.19 3.73 5.69 6.93 17.54 

MilwaukeeRacine 

6-Co. Area 

50.98 13.89 20.41 30.06 115.34 

Door 0.002 0.20 0.74 5.24 6.182 

Manitowoc 3.74 0.46 1.86 2.61 8.67 

Sheboygan 10.52 1.12 1.79 2.03 15.46 

* Point includes combined non-EGU and EGU emissions 

* Onroad includes uncertainty factor (7.5% for Milwaukee-Racine Counties, 

15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth 

factor is less because a high growth assumption was used for VMT 

projections.

Table 14: Total VOC Emissions in 2020 

(Tons per Summer Day) 

County Point Area Onroad Nonroad Total 

Kenosha 1.50 5.85 1.23 3.16 11.74 

Milwaukee 10.96 40.33 6.25 12.62 70.16 

Ozaukee 0.65 6.46 0.83 1.76 9.70 

Racine 1.53 17.78 1.26 4.26 24.83 

Washington 0.62 12.19 1.41 3.94 18.16 

Waukesha 4.94 18.80 3.95 13.25 40.94 

MilwaukeeRacine 

6-Co. Area 

20.20 101.41 14.91 38.99 175.51 

Door 0.15 1.59 0.53 6.36 8.63 

Manitowoc 2.08 4.62 1.25 2.27 10.22 

Sheboygan 3.71 7.20 1.32 3.51 15.74 

* Point includes combined non-EGU and EGU emissions 

* Onroad includes uncertainty factor (7.5% for Milwaukee-Racine Counties, 

15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth 

factor is less because a high growth assumption was used for VMT 

projections.

Emission trends are an important gauge for continued compliance of the ozone standard. 

Therefore, WDNR performed comparisons of 2007 emissions and the maintenance year 

emissions, which are summarized below in Table 15. A comparison of net emission 

changes between the 2007 inventory and projected 2012 and 2020 inventories is also 

included. 
 30 

Table 15: Comparison of Total NOx and VOC Emissions (tpsd)

Milwaukee-Racine 6-County Area 

Sector 2007 NOx 

2012 NOx 

(Net Change 

from 2007) 

2020 NOx 

(Net Change 

from 2007) 

2007 VOC 

2012 VOC 

(Net Change 

from 2007) 

2020 VOC 

(Net Change 

from 2007) 

Point 41.69 57.48 50.98 12.20 16.34 20.20 

Area 13.30 13.52 13.89 98.55 98.00 101.41 

Onroad 73.21 47.27 20.41 31.39 22.66 14.91 

Nonroad 45.66 37.16 30.06 48.45 40.60 38.99 

Total 173.86 155.43 

(- 18.43) 

115.34 

(- 58.52) 190.59 177.60 (- 12.99) 

175.51 

(- 15.08) 

Door County 

Sector 2007 NOx 

2012 NOx 

(Net Change 

from 2007) 

2020 NOx 

(Net Change 

from 2007) 

2007 VOC 

2012 VOC 

(Net Change 

from 2007) 

2020 VOC 

(Net Change 

from 2007) 

Point 0.002 0.002 0.002 0.30 0.16 0.15 

Area 0.20 0.20 0.20 1.51 1.52 1.59 

Onroad 1.97 1.55 0.74 0.93 0.78 0.53 

Nonroad 5.28 5.49 5.24 8.85 7.53 6.36 

Total 7.452 7.242 

(- 0.21) 

6.182 

(- 1.27) 11.59 9.99 (- 1.60) 

8.63 

(- 2.96) 

Manitowoc County 

Sector 2007 NOx 

2012 NOx 

(Net Change 

from 2007) 

2020 NOx 

(Net Change 

from 2007) 

2007 VOC 

2012 VOC 

(Net Change 

from 2007) 

2020 VOC 

(Net Change 

from 2007) 

Point 3.13 3.69 3.74 1.43 1.64 2.08 

Area 0.43 0.44 0.46 4.39 4.41 4.62 

Onroad 5.38 3.76 1.86 2.24 1.76 1.25 

Nonroad 3.61 3.16 2.61 3.15 2.59 2.27 

Total 12.55 11.05 

(- 1.50) 

8.67 

(- 3.88) 11.21 10.40 (- 0.81) 

10.22 

(- 0.99) 

Sheboygan County 

Sector 2007 NOx 

2012 NOx 

(Net Change 

from 2007) 

2020 NOx 

(Net Change 

from 2007) 

2007 VOC 

2012 VOC 

(Net Change 

from 2007) 

2020 VOC 

(Net Change 

from 2007) 

Point 12.99 15.07 10.52 2.26 2.88 3.71 

Area 1.04 1.07 1.12 7.08 7.02 7.20 

Onroad 5.81 4.15 1.79 2.50 2.01 1.32 

Nonroad 3.73 2.92 2.03 5.02 4.12 3.51 

Total 23.57 23.21 

(- 0.36) 

15.46 

(- 8.11) 16.86 16.03 

(- 0.83) 

15.74 

(- 1.12) 
 31 

As Table 15 above indicates, substantial reductions in NOx emissions occur in the 

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

from 2007 to 2020. The largest reductions are from the mobile sectors, nonroad and 

onroad. Projected total NOx emissions throughout the nine counties will be reduced by 

approximately 33% (or 71.8 tpsd) during the 13-year period. 

By 2020, VOC emissions are projected to decrease by approximately 9% (or 20.2 tpsd) 

during the 13-year period. Emissions do not decrease as much as the NOx because 

projected point emissions reduce the impact of the onroad and nonroad VOC reductions. 

However, the federal Mobile Source Air Toxics rule will lead to additional VOC 

reductions as a result of portable fuel container emission limits in that rule. 

3. Demonstration of Maintenance 

Ambient air quality data from the thirteen ozone monitoring sites within the current 

Wisconsin 1997 ozone nonattainment areas indicate that air quality met the NAAQS for 

ozone during the period 2006 through 2008. The Redesignation Guidance states, “A state 

may generally demonstrate maintenance of the NAAQS by either showing that future 

emissions of a pollutant or its precursors will not exceed the level of the attainment 

inventory, or by modeling to show that the future mix of sources and emission rates will 

not cause a violation of the NAAQS.” The emission projections demonstrate that the total 

emissions are not expected to exceed the level of the 2007 attainment year inventory 

during the 13-year period. NOx emissions will be substantially reduced in the 

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

(34%, 17%, 31%, and 34%, respectively), while VOC emissions will decrease by 8%, 

26%, 9%, and 7%, respectively. 

In Wisconsin, point sources in all counties emitting greater than 5 tons carbon monoxide, 

sulfur dioxide, particulate matter or 6 tons of VOC per year are required to submit air 

emissions information annually in accordance with the Air Contaminant Emission 

Inventory Reporting Requirements Rule, Chapter NR 438. WDNR prepares a new 

periodic inventory for all ozone precursor emission sectors every three (3) years. These 

ozone precursor inventories will be prepared for 2008, 2011, and 2014 as necessary, to 

comply with the inventory reporting requirements established in the CAA. Emissions 

information will be compared to the 2005 year inventory, 2007 attainment year inventory, 

and the 2020 projected maintenance year inventories to assess emission trends, as 

necessary, to assure continued compliance with the ozone standard. 

4. Transportation Conformity 

Attainment demonstrations and maintenance plans must include estimates of motor 

vehicle emissions. These estimates act as a ceiling or a “budget” for emissions from 

motor vehicles, and are used to determine whether transportation plans and projects 

conform to the attainment SIP. The conformity requirements are described in CAA 

section 176(c)(2)(A) and 23 U.S.C. 109(j), with respect to the conformity of 

transportation plans, programs, and projects which are developed, funded, or approved by 
 32 

the U.S. Department of Transportation (DOT), and by Metropolitan Planning 

Organizations (MPOs) or other recipients of funds under title 23U.S.C. or the Federal 

Transit Laws (49 U.S.C. Chapter 53). In order for transportation plans and projects to 

conform, estimated emissions from transportation plans and projects must not exceed the 

emission budgets contained in the attainment demonstration. The criteria that determine 

whether a SIP's motor vehicle emission budgets are adequate for transportation 

conformity purposes are outlined in 40 CFR 93.118(e)(4). 

A motor vehicle emissions budget (MVEB) is that portion of the total allowable 

emissions defined in the submitted or approved control strategy implementation plan 

revision or maintenance plan for a certain date for the purpose of meeting reasonable 

further progress milestones or demonstrating attainment or maintenance of the NAAQS, 

for any criteria pollutant or its precursors, allocated to highway and transit vehicle use 

and emissions. MVEB must reflect appropriate and up-to-date projections of motor 

vehicle emissions for the attainment year. For example, assumptions about vehicle miles 

traveled (VMT), socio-economic variables, and other planning assumptions must be 

appropriate and up-to-date. Also, the inputs to the MOBILE6 model and vehicle fleet 

characteristics must be appropriate and up-to-date as required by U.S. EPA's guidance on 

SIP inventories and the MOBILE users' guide. The nonattainment and maintenance area 

MVEB and VMT inventories that are used to establish the budgets must include the 

effects of all motor vehicle controls that will be in place by the attainment year. These 

controls include federal measures, (e.g., National Low Emission Vehicle – NLEV 

program) and the mobile source control measures assumed in the 1-hour Ozone 

Attainment Demonstration SIP, submitted in 2000, and the 8-hour Ozone Attainment 

Demonstration SIP, to be submitted prior to, or concurrently with, submittal of this 

redesignation request. 

The MVEB for the Milwaukee-Racine 6-County Area was based on Southeastern 

Wisconsin Regional Planning Commission (SEWRPC) high growth projections that 

VMT will increase from 48,515,332 miles per summer weekday (mpsw) in 2007 to 

52,471,624 mpsw in 2012 and 57,662,148 mpsw in 2020. The MVEB for the counties of 

Door, Manitowoc, and Sheboygan was based on Wisconsin Department of Transportation 

(WDOT) projections that VMT will increase from 1,211,030; 2,720,436; and 3,368,913 

mpsw in 2007, respectively, to 1,350,987; 2,837,152; and 3,745,396 mpsw in 2012, 

respectively, and 1,352,908; 3,040,105; and 4,104,560 mpsw in 2020, respectively. 

Isolated rural nonattainment and maintenance areas, such as Door and Manitowoc 

Counties, are areas that do not contain or are not part of any metropolitan planning area 

as designated under the transportation planning regulations. Isolated rural areas do not 

have federally required metropolitan transportation plans or transportation improvement 

plans (TIPs) and do not have projects that are part of the emissions analysis of any 

MPO’s metropolitan transportation plan or TIPs. Projects in such areas are instead 

included in statewide transportation improvement programs. Sheboygan County is part 

of the Bay-Lake Regional Planning Commission (RPC). 
 33 

Conformity budgets must address both VOC and NOx emissions for all ozone 

nonattainment and maintenance areas designated under the CAA. These budgets need to 

reflect reasonably consistent planning assumptions between the air quality and 

transportation planning processes and reflect the impact of emission forecasts and 

emission control programs incorporated into the attainment demonstration. The 2012 and 

2020 MVEB for the Milwaukee-Racine 6-County Area and the counties of Door, 

Manitowoc, and Sheboygan is shown below in Table 16: 

Table 16: Mobile Sector Budget for the New Maintenance Plan for the Redesignation of 

the Milwaukee-Racine 6-County Area and Door, Manitowoc, and Sheboygan Counties 1

2012 2020 

NOx 

(tpsd) 

VOC 

(tpsd) 

NOx 

(tpsd) 

VOC 

(tpsd) 

Milwaukee-Racine 

6 Co. Area 47.27 22.66 20.41 14.91 

Door Co. 1.55 0.78 0.74 0.53 

Manitowoc Co. 3.76 1.76 1.86 1.25 

Sheboygan Co. 4.15 2.01 1.79 1.32 

Conformity of emissions from the entire transportation system for Door or Manitowoc 

County must be re-determined when a regionally significant project from either of these 

isolated rural maintenance areas are added to the Statewide TIP. 

Conformity of the emissions from the entire transportation system for the MilwaukeeRacine 6-County Area and Sheboygan County, including all regionally significant 

projects contained in the plan and all other regionally significant highway and transit 

projects must be re-determined within 18 months of the following: 

1) The effective date of U.S. EPA’s finding that MVEBs from an initially 

submitted control strategy implementation plan or maintenance plan are 

adequate pursuant to §93.118(e) and can be used for transportation 

conformity purposes; 

2) The effective date of U.S. EPA approval of a control strategy 

implementation plan revision or maintenance plan which establishes or 

revises a MVEB if that budget has not yet been used in a conformity 

determination prior to approval; 

3) The effective date of U.S. EPA promulgation of an implementation plan 

which establishes or revises a MVEB; and 

 

1

 Emission estimates include an uncertainty factor (7.5% for Milwaukee-Racine Counties, 15% for Door, 

Manitowoc, and Sheboygan). The Milwaukee-Racine growth factor is less because a high growth 

assumption was used for VMT projections. 
 34 

4) The effective date of U.S. EPA’s finding that a MVEB in a submitted 

control strategy implementation plan revision or maintenance plan for the 

8-hour ozone NAAQS is adequate for transportation conformity purposes. 

If the re-determination does not happen, the existing conformity determination will lapse, 

and no new project-level conformity determinations may be made until conformity of the 

regionally significant transportation projects has been determined by the SEWRPC or the 

Bay-Lake RPC. 

After the maintenance plan has been submitted, transportation conformity must be 

demonstrated by ensuring that emissions are less than or equal to the MVEB(s) 

established for the last year of the maintenance plan, and for any other years for which 

the maintenance plan establishes MVEBs. For years after the last year of the 

maintenance plan, emissions must be less than or equal to the maintenance plan’s 

MVEB(s) for the last year of the maintenance plan. 

If an approved and/or submitted control strategy implementation plan has established 

MVEBs for years in the time frame of the transportation plan, emissions in these years 

must be less than or equal to the control strategy implementation plan’s MVEB(s) for 

these years; and for any analysis years before the last year of the maintenance plan, 

emissions must be less than or equal to the MVEB(s) established for the most recent prior 

year. 

5. Provisions for Future Updates 

As required by Section 175A(b) of the CAA, Wisconsin commits to submit to the 

Administrator, eight (8) years after redesignation, an additional revision of this SIP. The 

revision will contain Wisconsin’s plan for maintaining the NAAQS for ten (10) years 

beyond the first 10-year period after redesignation. 

C. Monitoring Network

Wisconsin currently operates thirteen ozone monitors throughout the Milwaukee-Racine 

6-County Area and the counties of Door, Manitowoc, and Sheboygan. For a detailed 

discussion of these monitors refer to Section III. Wisconsin has committed to the 

continued operation and maintenance of an approved ozone monitor network in these 

areas through the maintenance period and beyond. 

D. Verification of Continued Attainment

Continued attainment of the 8-hour ozone NAAQS in the Milwaukee-Racine 6-County 

Area and the counties of Door, Manitowoc, and Sheboygan depends, in part, on the 

Wisconsin’s effort toward tracking indicators of continued attainment during the 

maintenance period. The tracking plan for these areas primarily consists of continued 

ambient ozone monitoring in accordance with the requirements of 40 CFR Part 58. 

Wisconsin maintains a comprehensive ambient air quality monitoring network and air 
 35 

quality reporting program, including ozone monitoring sites throughout the state and a 

fully enhanced network in the area around Lake Michigan. These commitments are 

structured in state statute to continue through and past the maintenance period. The state 

will also evaluate future VOC and NOx emissions inventories for increases over 2007 

emission inventory levels. 

E. Contingency Plan

Despite the best efforts to demonstrate continued compliance with the NAAQS, the 

ambient ozone concentrations may exceed or violate the NAAQS. Therefore, as required 

by section 175A of the CAA, Wisconsin has provided contingency measures to promptly 

correct a future ozone air quality problem. These contingency measures would be 

implemented if a future ozone design value for any of the current nine nonattainment 

counties is 0.085 ppm or higher. 

Contingency Measures Approach: 

1. Evaluation of Adequacy of Existing Control Measures – If a violation occurs, the first, 

and most important step Wisconsin will take will be to evaluate the adequacy of already 

adopted control measures to rectify the violation. Control measures that have already 

been promulgated, but not fully implemented at the time of the violation may very likely 

be sufficient to return the area to attainment. 

If a measure or control is already promulgated and scheduled to be implemented at the 

federal or state level, the state will assess whether that measure or control in combination 

with other existing controls will be sufficient. Wisconsin will consider existing control 

measures that have been adopted in Wisconsin, as well as existing measures that have 

already been adopted in other states or by the federal government. If existing control 

measures are determined to be sufficient to address the upward trend in ozone 

concentrations, additional local control measures will not be necessary. In that case, 

Wisconsin will submit to U.S. EPA an analysis to demonstrate that the existing measures 

that have not been fully implemented are adequate to return the area to attainment. 

2. Evaluation of Additional Control Measures - If it is demonstrated through modeling 

that existing and on-the-way measures are inadequate to return the area to attainment, the 

WDNR will identify candidate additional control measures as necessary to return the area 

to attainment within 18 months. The selection of candidate measures will be based upon 

cost-effectiveness, emission reduction potential, economic and social considerations and 

other appropriate factors. Before proposing any specific candidate control measures, 

WDNR will solicit input from all interested and affected parties. 

It is important to note that adoption of any additional control measures is subject to the 

necessary administrative and legal process as well as required legislative oversight. This 

process will include publication of notices, an opportunity for public hearing, and other 

measures required by Wisconsin law for rule making. 
 36 

List of Potential Additional Control Measures: 

Since it is not possible at this time to determine what control measure (if any) will be 

appropriate at an unspecified time in the future, the list of potential candidate contingency 

measures outlined below is not comprehensive nor is the list in priority order. 

• Broaden the application of the NOx RACT program to include: 

o a larger geographic area, and/or 

o sources with potential emissions of 50 tons/year, and/or 

o to increase the cost-effectiveness thresholds utilized as a basis for 

Wisconsin’s NOx RACT Program, and/or 

• Develop an anti-idling control program for mobile sources targeting diesel 

vehicles, and/or 

• Reduced VOC content in architectural, industrial and maintenance coatings, 

and/or 

• Reduced VOC content in commercial and consumer products 

F. Commitment to Revise Maintenance Plan

Wisconsin hereby commits to review its Maintenance Plan eight (8) years after 

redesignation, as required by Section 175(A) of the CAA. This revised SIP will provide 

for maintenance for an additional 10 years. 
 37 

VII. ATTAINMENT OF THE REVOKED 1-HOUR OZONE STANDARD 

FOR THE MILWAUKEE-RACINE 6-COUNTY AREA 

The revoked primary and secondary ambient air quality standards for 1-hour ozone are 

0.12 ppm measured as the maximum hourly average concentration. A monitoring site 

attains the standard if the fourth highest 1-hour ozone concentration value is equal to, or 

less than, 0.12 ppm, during a 3-year period. Based on fully quality-assured ambient air 

quality monitoring data from 2003 through 2008, the Milwaukee-Racine 6-County Area 

has attained, and continues to attain, the 1-hour ozone standard. 

Table 17 indicates the number of daily maximum 1-hour ozone values that are greater 

than or equal to 0.125 ppm for a given 3-year period. None of the monitoring sites in the 

6-county area measured more than two exceedances. In the most recent 3-year period 

(2006 - 2008), no sites in the Milwaukee-Racine 6-County Area measured a daily 

maximum 1-hour ozone value greater than or equal to 0.125 ppm. In addition, daily 

maximum 1-hour ozone concentrations have been trending downward since 2003. 

Figures 2 through 5 show the daily maximum 1-hour ozone concentrations for each 

ozone season (April 15 – October 15) from 2003 through 2008 at the Bayside, Grafton, 

Harrington Beach, and Pleasant Prairie monitors. Each monitoring site exhibits a 

downward linear trend in daily maximum 1-hour ozone concentration during this period. 

The rate of decrease for these monitoring locations varies from 0.40 parts per billion 

(ppb) per ozone season to 1.31 ppb per ozone season. Daily maximum 1-hour ozone 

concentrations have been maintained well below 0.12 ppm, or 125 ppb. Since 2006, the 

highest 1-hour ozone concentration measured at these four sites was 112 ppb at the 

Pleasant Prairie monitor on June 16, 2007. 

WDNR reclassified this nonattainment area as an attainment area under s. 285.23, Wis. 

Stats., and ch. NR 401, Wis. Adm. Code on February 10, 2009. Appendix 11 includes 

the documents related to this state redesignation. As part of this 8-hour ozone 

redesignation request, WDNR requests that U.S. EPA redesignate the Milwaukee-Racine 

6-County Area to attainment for the revoked 1-hour ozone NAAQS. 
Table 17: 1-Hour Ozone Violation Assessment 2003 – 2008 

# days 

≥ 0.125 ppm SITE ID COUNTY SITE NAME 

2003-2005 2004-2006 2005-2007 2006-2008 

550590019 Kenosha Pleasant Prairie 0 0 0 0 550790010 Milwaukee 16th St Health Center 0 a 0 0 0 550790026 Milwaukee SER-HQ 1 1 1 0 550790041 Milwaukee UWM North 2 2 2 0 550790044 Milwaukee Appleton Avenue 0 --- b --- b --- b 550790085 Milwaukee Bayside 2 2 2 0 550890008 Ozaukee Grafton 1 1 1 0 550890009 Ozaukee Harrington Beach 2 1 1 0 551010017 Racine Racine 0 0 0 0 551310009 Washington Slinger 0 0 0 0 551330017 Waukesha Carroll College 0 --- c --- c --- c 551330027 Waukesha Cleveland Avenue --- d 0 0 0 Notes:(a) Data completeness at 550790010 in 2003 was 62%. This does not meet US EPA’s 75% completeness criterion. Hence, the 3rd high o

determine the design value for 2003-2005. That value is 0.097 ppm. (b) The ozone monitor at Appleton Avenue in Milwaukee (550790044) was removed from service after the 2005 monitoring season. Thdetermination can be made only for the period 2003-2005. (c.) The Carroll College site (551330017) was shut down after the 2005 ozone monitoring season because the building where the monit

(d) Ozone monitoring at the Cleveland Avenue site (551330027) began in 2004. A violation assessment cannot be completed for 2003-data. 
Figure 2: Bayside (550790085) – Milwaukee County

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15) 

0

102030405060708090

100110120130140

2003 2004 2005 2006 2007 2008

Date

1-Hour Ozone Concentration (ppb)

1-HR 

Dashed Line: Linear Trend LineSlope of the Trend Line: - 0.72 p
Figure 3: Grafton (550890008) – Ozaukee County

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15) 

0

102030405060708090

100110120130140

2003 2004 2005 2006 2007 2008

Date

1-Hour Ozone Concentration (ppb)

1-HR 

Dashed Line: Linear Trend LineSlope of the Trend Line: - 1.21 pp
Figure 4: Harrington Beach (550890009) – Ozaukee County

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15) 

0

102030405060708090

100110120130140

2003 2004 2005 2006 2007 2008

Date

1-Hour Ozone Concentration (ppb)

1-HR 

Dashed Line: Linear Trend LineSlope of the Trend Line: - 1.31 p
Figure 5: Pleasant Prairie (550590019) – Kenosha County

Daily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15) 

0

102030405060708090

100110120130140

2003 2004 2005 2006 2007 2008

Date

1-Hour Ozone Concentration (ppb)

1-HR 

Dashed Line: Linear Trend LineSlope of the Trend Line: - 0.40 pp
 43 

VIII. PUBLIC PARTICIPATION 

This section describes the outreach and public participation activities that WDNR 

initiated for the redesignation request, highlights related to ongoing air quality outreach, 

and summarizes the public participation plans for any contingency measures, if needed. 

Redesignation Outreach & Public Participation

In accordance with Section 100(a) (2) of the CAA, public participation in the SIP process 

for redesignation included a notice of availability of the ozone redesignation documents. 

The date, time and location of the public hearing were published in the Wisconsin State 

Journal on July 16, 2009. 

 

The public hearing to receive comments on the redesignation request was held at 

1:00 pm on Tuesday, August 18, 2009 at WDNR Southeast Regional Headquarters. A 

summary of the comments received and WDNR’s responses is included in Appendix 12. 

Ongoing Air Quality Information and Outreach

In addition to the targeted outreach conducted for the ozone redesignation process, the 

WDNR has ongoing public information programs for stakeholders and the general public 

to provide information on air quality. Both the national Air Quality Index (AQI) and 

WDNR’s air quality hotline (1-866-DAILY AIR) are actively promoted. WDNR is also 

in the fourth year of a program in partnership with the National Weather Service in 

Wisconsin to announce Air Quality Watches and Air Quality Advisories when conditions 

and/or monitoring indicates elevated levels of air pollutants. An Air Quality Watch is 

issued when pollutant levels are forecast to rise to a level on the AQI that would impact 

the health of certain sensitive groups in the community. Air Quality Advisories may 

follow an Air Quality Watch if air pollutant levels actually reach or exceed the level. 

WDNR’s website includes access to the monitoring data for Wisconsin and is linked to 

the U.S. EPA’s AIRNow ozone mapping program. This effort makes use of a website to 

provide regularly updated maps showing the AQI readings in color for the participating 

states. The maps are intended to provide real-time air quality information and provide a 

snapshot forecast map. 

Public Outreach Regarding The Contingency Measures

The contingency plan provides for different levels of response and action based on the 

monitored ambient levels of ozone. A public involvement process is a critical part of the 

contingency response and any determination of need or the selection of the contingent 

control measures. 

If a triggering event occurs, WDNR will assess the exceedance and conduct a thorough 

analysis, as necessary. Before any contingency measure is selected, WDNR will develop 

a public involvement plan to inform key stakeholders and the general public, and develop 
 44 

a more focused process for soliciting input on the potential contingency measures. Key 

stakeholder groups include the Clean Air Act Task Force, the Transportation Conformity 

Workgroup and the Wisconsin Partners for Clean Air. 

No contingency measure will be implemented without providing the opportunity for full 

public participation. At a minimum, that process will include: 1) the publication of 

notices; and 2) a hearing and an opportunity for public, governmental and legislative 

input on the relative costs and benefits of individual measures at the time they are under 

consideration. 
 45 

IX. CONCLUSIONS 

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

Sheboygan have attained the NAAQS for 8-hour ozone and complied with the applicable 

provisions of the 1990 Amendments to the Clean Air Act regarding redesignation of 

Subpart 1 Basic and Subpart 2 Moderate ozone nonattainment areas. Documentation to 

that effect is contained herein. WDNR has prepared a State Implementation and 

Maintenance Plan that meets the requirement of Section 110(a)(1) of the 1990 CAA. 

WDNR has performed an analysis and believes the air quality improvements are due to 

permanent and enforceable measures. In addition, WDNR believes that significant 

regional NOx reductions will ensure continued compliance (maintenance) with the 

standard and that all CAA requirements necessary for redesignation have been met. 

WDNR believes that these areas meet the requirements for redesignation under the CAA 

and U.S. EPA guidance. Furthermore, because this area is subject to significant transport 

of pollutants, significant regional NOx reductions will ensure continued compliance 

(maintenance) with the NAAQS and provide an increasing margin of safety. 

The State of Wisconsin hereby requests that the Milwaukee-Racine 6-County Area and 

the counties of Door, Manitowoc, and Sheboygan be redesignated to attainment 

simultaneously with U.S. EPA approval of Wisconsin’s State Implementation and 

Maintenance Plan provisions contained herein.