## 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 2009i 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 34ii 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 45iii List of Tables

Table 1 : Ozone Monitors Meeting Data Co mpleteness 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 NO x 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 – 2008iv 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 Em issions 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 Comments1 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 Ke nosha, Milwaukee, Ozaukee, Racine, Washington, and Waukesha. All of these nonatt ainment 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 nona ttainment areas recorded thre e 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) establ ishes the following criteria to be met in
order for an area to be considered for rede signation of a National Ambient Air Quality Standard (NAAQS):

(a) A determination by the U.S. Environmen tal Protection Agency (EPA) that the area has attained the NAAQS (e.g., 1997 ozone standard); (b) A fully approved State Implementation Pl an (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 fo r the area under Section 110 and Part D of the CAA have been met; (e) A fully approved maintenance plan, incl uding 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 standa rd. Historically, ex ceedances of the ozone
standard have been monitored in the coun ties along the western lakeshore of Lake Michigan, including the coun ties of Door, Manitowoc, Sheboygan, and the MilwaukeeRacine 6-County Area.

In 1991, U.S. EPA identified all areas vi olating the 1-hour ozone standard as nonattainment areas (56 FR 56850). The Milwaukee-Racine 6-County Area was designated as severe nonattainment; Sh eboygan County as serious nonattainment; Manitowoc County as moderate nonattainme nt; and Door County as rural transport (marginal) nonattainment. In 1992, U.S. EPA reclassified Sheboygan County to
moderate nonattainment. The nonattainmen t designations were based on monitored violations of the NAAQS for ozone. As a re sult of this classi fication, the State of2 Wisconsin was subject to new requirements, including development of a plan to reduce volatile organic compound (VOC) emissions a nd a plan demonstrat ing that the area would meet the federal primary 1-hour standard for ozone by November 15, 1996.

By the 1993 through 1995 time period, Sheboyga n County was monitoring attainment of the 1-hour NAAQS. U.S. EPA published a fina l rule in the Federal Register on August 26, 1996, redesignating Sheboygan County as atta inment 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-R acine 6-County Area nonattainment area was monitoring attainment of the 1-hour NAAQS. The Wisc onsin 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-R acine 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 Regi ster on April 24, 2009 (74 FR 18641). The ozone monitoring data demonstrating atta inment 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 nonattainmen t areas for the 8-hour ozone standard. Sheboygan County and the Milwaukee-Racine 6-County Area were designated as Subpart 2 moderate nonattainment areas fo r the 8-hour ozone st andard. 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 oz one standard on June 14, 2007. U.S. EPA published a final rule in the Federal Re gister 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 oz one NAAQS were observed. This redesignation request supersedes th e previous redesignation request for the Milwaukee-Racine 6-County Area and Manitowoc County.

The attainment level air quality for these ni ne counties comes as a result of more than twenty years of control efforts across the Lake Michigan Region from all sectors to limit3 and reduce the emissions of VOCs and nitrog en oxides (NOx), precursor pollutants of
ambient ozone.

Since 1990, in compliance with the CAA, Wisconsin develope d and implemented several new programs and new or amended rules desi gned to control emissions of VOCs and
NOx. The status of these rule s with respect to their approva l by the U.S. EPA as SIPs is
detailed in Section IV.

B. Geographical Description

The counties of Door and Man itowoc 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 approximatel y 70% and 40% rural, respectively. The City of Sturgeon Bay, with an estimat e 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 nonattain ment of the ozone standard that are upwind of Door and Manitowoc Counties, and significantly affect th e air quality in the counties are: Kenosha, Milwaukee, Oza ukee, 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 a nd 1,897,103 in the Milwaukee-Racine 6- County Area, and a largely i ndustrial and service-based ec onomy, these seven counties comprise approximately 35% of Wisconsin’s entire population. Th e City of Sheboygan, with an estimated 2008 population of 50,580, is Sheboygan County’s largest city. The City of Milwaukee, the larg est city in Wiscons in with an estima ted 2008 population of 590,870, is the Milwaukee-Racine 6-County Area’ s largest city. The densely populated Chicago-Gary-Lake County nonattainment area c onsisting of eight counties is upwind of
these seven counties and affect s 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-R acine 6-County Area and in the counties of Door, Manitowoc, and Sheboygan. This fact, accompanied by the
decrease in estimated emission levels discusse d 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 c onsideration for redesignation to attainment. In addition, the U.S. EPA has published detailed guidan ce in a document entitled “Procedures for Processing Requests to Redesi gnate Areas to Attainment,” issued September 4, 1992, to U.S. EPA Regional Air Directors. This document is hereafter referred to as “Redesignation Guidance.” The Redesignati on Guidance is for redesignation requests for those areas designated nona ttainment 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 guida nce received from staff of U.S. EPA Region V. This guidance is included in Appendix 1.

The following sections below refer in greater de tail 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 ambi ent 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 concentr ation 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 st andard are no longer occurring.

2) Ambient monitoring data quality a ssured 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-Raci ne 6-County Area and the counties of Door, Manitowoc, and Sheboygan during the 3-ye ar 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-16 th 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 Harringt on 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-20046 • 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 ozon e monitor located in Door County.

• Situated on Nature Conservancy proper ty, the Pleasant Prairie ozone monitor in Kenosha County is located in the fa r southeastern corner of Wisconsin close to the Lake Michigan. It is approximately 600 fe et from Lake Michigan. The current ozone monitor has yielde d 19 years of valid, quality-assured
ozone data.

• The Manitowoc Woodland Dunes Mon itor is located on the 1,200 acre
Woodland Dunes Nature Center betw een 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 16 th Street Health Center ozon e 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 seas ons. SER is situated in an urban neighborhood approximately 1.5 mile s west of Lake Michigan.

• The University of Wisconsin Milwa ukee (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 lo cated 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 oz one 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 ab out 35 miles north of Milwaukee and 21 miles south of Sheboygan, Wisconsin. The WDNR has monitored ozone
concentrations at this ru ral location for 13 years.

• The Racine ozone monitor is located in an urban setti ng 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 ot her, since discontinued, monitoring sites in Sheboygan County are availabl e 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 Clevel and Street in Waukesha has been operating at this location since April 2004. The site is located in a mixed industrial and residential setting appr oximately 15 miles west of the Lake Michigan shoreline and the City of Milwaukee.

The location of the thirteen monitoring site s in the Milwaukee-R acine 6-County Area and the counties of Door, Manitowoc, and Sheboygan are shown in Figure 1.

Figure 1: Ozone Monitoring Loca tions in the Current Wisconsin
1997 Ozone Nonattainment Areas8 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 s econdary, are attained when the 3-year average of the fourth highest 8-hour daily ma ximum 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 oz one monitoring sites in the Milwaukee-Racine 6-County Area and the counties of Door, Ma nitowoc, 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 valu es are typically used to classify nonattainment areas, assess progress toward s 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 mon itoring 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 monito ring 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 vi olation days by year, site, and date (3) Data Completeness Reports for 2006 through 2008 detailing the monthly and annual ozone monitoring data co mpleteness percentage s by year and site and (4) the Maximum Values Report, whic h 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 Wiscons in Ozone Quality Assurance Plan, in accordance with 40 CFR 58.10, to assure the qualit y 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 av ailable 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 requi rements for the three year period for all monitoring sites. The overall average data co mpleteness 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 Av erage 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

2007 0.095 0.093 0.092 0.092 Door 550290004 Newport
State Park 2008 0.080 0.070 0.069 0.069 0.080

2006 0.091 0.085 0.079 0.079

2007 0.095 0.090 0.090 0.085 Kenosha 550590019
Pleasant
Prairie 2008 0.078 0.075 0.072 0.072 0.078

2006 0.104 0.094 0.079 0.078

2007 0.092 0.089 0.088 0.085 Manitowoc 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

16 th 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

2007 0.085 0.080 0.079 0.077 Racine 551010017
Racine 2008 0.070 0.068 0.066 0.065 0.071

2006 0.109 0.097 0.090 0.083

2007 0.092 0.090 0.088 0.088 Sheboygan 551170006
Kohler
Andre Park 2008 0.079 0.076 0.075 0.075 0.082

2006 0.069 0.069 0.068 0.066

2007 0.073 0.071 0.071 0.071 Washington 551310009 Slinger 2008 0.061 0.060 0.060 0.060 0.065

2006 0.075 0.068 0.068 0.067

2007 0.075 0.075 0.073 0.072 Waukesha 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 16 th 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 Regi onal Headquarters (S ERHQ) achieved 91% data completeness. Despite lower data cap ture 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 c oncentrations from the 3 closest ozone monitoring sites in Mi lwaukee 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 appro ach 0.085 ppm. The maximum 8-hour ozone concentration (0.068 ppm) measured at UWM-North is equal to the 4 th high measured concentration at Southeast Region Headqua rters in 2006. Assuming that the maximum daily 8-hour ozone concentrations at the othe r 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 th e site’s calculated design value for the 3- year period (2006 through 2008). Additionally, the 4 th highest value in 2006 would need to equal 0.117 ppm to create a 3-year design va lue 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 16 th 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, Manito woc, 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 mon itoring data to meet the requirements of 40
CFR 58. Connection to a central station and updat es to the WDNR website 1 will provide real-time availability of the data and know ledge 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=wisards12 IV. ALL RELEVANT REQUIREMEN TS 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 appli cable prior to submittal of a complete redesignation request. Wisconsin has met th ese requirements, excluding the following:

1. 1997 8-Hour Ozone NAAQS Atta inment Demonstration

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

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

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

On March 17, 2008, U.S. EPA issued findings that the Milwaukee-R acine 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 a bove prior to, or concurrently with, submittal of this redesignation request. Exclud ing these 1997 Ozone NAAQS SIP elements, Wisconsin’s Ozone Control SIP is fully a pproved and contains a ll 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 a ll federally required emission control programs related to ozone. Appendix 3 lists the major state a nd 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 redesigna ted 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 attri bute 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 c ounties 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 Y ear (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 include d. A basic descripti on of the utilized methodologies follows.

• Point Source Inventory - The methodology used to develop the comprehensive 2002 non-Electric Generating Unit (non-EGU) poi nt source inventory is contained in Appendix 4. Contained in Appendix 5 is the EGU emission estimation methodology created by a WDNR Air Management engi neer and EGU specialist. The EGU emissions inventory incorporates U.S. EPA’s Clean Air Markets Division data.

• Area Source Inventory – The 2002 area source emissi ons inventory was derived by backcasting the Wisconsin 2005 Base Year emissions inventory submittal to U.S.
EPA in June of 2007. This was done sin ce different methodologies were used to develop the original Wisconsin 2002 Base Y ear emissions inventory compared to the 2005 inventory. WDNR received verbal conf irmation from U.S. EPA Region 5 staff that this is an acceptable approach during a phone call on May 18 th , 2009. These
emission estimates were made based on va rious 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 St ate agencies. A description of the methodologies followed to develop the or iginal and backcasted 2002 inventory is included in Appendix 4. Appendix 7 contai ns 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 (NMI M) model. Pechan, an independent contractor, provided marine and rail emissi on estimates via LADCO for Wisconsin in
2002. Aircraft emissions were calc ulated using the Federal Aviation
Administration’s Emissions and Di spersion Modeling System (EDMS).14 • Onroad Inventory - 2002 mobile source emissi ons were calculated using
MOBILE6.2. All emission estimates were ma de 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 Radiat ion, 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 categ ories 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. Em issions of VOC are hi ghest 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 emissions15 B. Attainment Year (2007) Inventory

WDNR developed a 2007 attainment year in ventory by growing the statewide 2005 base year emissions inventory of VOC and NOx emissions for the current nine nonattainment
counties in Wisconsin. Point sector emi ssions estimates, both EGU and non-EGU, are actual 2007 reported emissions. Biogenic emi ssion 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 em issions, both EGU and non-EGU, are presented in Appendices 4 and 5.

• Area Source Inventory Projections - Projections were perf ormed by applying growth factors and applicable emission controls to the 2005 base year inventory. These growth factors were carefully selected ba sed on a prioritization schema. Foremost priority was given to county-specific empl oyment based growth factors. Next, if available, a state-specific employment based growth factor was used. These employment based growth factors were dete rmined from U.S. Census Bureau County
Business Patterns data 1 . Next county-specific growth factors developed by Pechan 2

contained in the document entitled Deve lopment of Updated Growth and Control Factors for the Lake Michigan Air Di rectors 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 em ission estimates were prepared by using the U.S. EPA National M obile Inventory (NMIM) model. Marine and rail emissions were grown from 2005 Pech an 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 Radiat ion, 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. Ta ble 9 compares the total emissions for the
nonattainment and the attainment inventorie s 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 emissions17 Table 9: Comparison of 9-County A rea 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 -2.6118 Table 9 shows a substantial decrease in NOx ( 37 %) and moderate decrease in VOC (16 %) between 2002 and 2007 throughout the ni ne nonattainment counties. Large NOx reductions in the point categor y are due to controls on elect ric generating units in the
area. Vehicle fleet turnover also contri buted to NOx and VOC reductions for both the
onroad and nonroad emission sectors. Emissi ons have also decreased for the nonroad sector due to various control programs, su ch as the clean air nonroad diesel rule.

C. Permanent and Enforceable Control Measures

The improvement in air quality can be attr ibutable 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 oz one from upwind counties. Therefore, in addition to controls implemented in the ar ea, region-wide controls implemented in upwind counties are also relevant to the impr ovement in the air quality in these nine
counties.

1. Rate of Progress Plan

Areas designated as nonattainment for the 1- hour ozone standard ar e required to reduce VOC emissions 3% per year from “adjusted” 199 0 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 existi ng air quality control measures.

Wisconsin inventoried actual emissions of VO Cs 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 th e 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, be ginning 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 in cluded reformulated gasoline, clean fuel fleets, and revised motor vehicle emission standards. Wisconsin program elements included rules defining VOC Reasonably Av ailable 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 coatin gs applications, and some voluntary industrial solven t 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% fr om 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 a dopted federal programs, would be sufficient to reach the 1999 rate-of-progress. In 2000, Wisconsin completed an analysis of
emissions that demonstrated that the st ate 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 Availabl e Control Technology

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

a) each category of VOC sources in the ar ea 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 pa rt of its SIP, rule s requiring all existing major stationary sources of VOCs at the 25 ton level in the Milwa ukee-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 design ated as moderate nonattainment areas and are not subject to these requirements, the ch anges are significant because of the large
contribution of VOCs from the Milwa ukee-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 no t be adopted for those categories.20 As noted in subsection 4 below (and Appe ndix 10), Wisconsin has adopted Maximum Achievable Control Technology (MACT) ru les further controlling VOC emissions throughout the state. The Occupational Sa fety 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 ve ry successful in reducing em issions over the past decades
as indicated in Table 10. Note that VOCs and reactive organic gases (ROGs) are nearly identical in definition and phot ochemical 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 th e counties of Door, Manitowoc, and Sheboygan have declin ed 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 Milwa ukee-Racine 6-County Area. The emission requirements apply to individua l 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 additi onal reductions beyond CAA requirements, Wisconsin worked with the community to identify and implement additional control measures. Thus, in addition to emission reduc tions 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 le vel 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 addre ssing the regional transport of ozone, consisting of
rules to reduce NOx emissions from electr ic utility boilers, cement kilns, large industrial boilers, and stati onary internal combustion engines. Implementation of the NOx SIP call in states upwi nd from Wisconsin began in May 2004. This rule results in a significant reducti on of NOx emissions th at contribute to
ozone concentrations in the Milw aukee-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 pa rticle pollution th at began operation between 1962 and 1977. The main sources subject to emission reductions are boilers at electric generating power pl ants 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 tr ucks, including sport utility vehicles (SUVs). Under this rule, automakers are required to sell lower-emitting cars, and refineries are required to make clean er, 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 fo r larger SUVs, vans, and heavier trucks. VOC emission reductions will be approximately 12% for passenger cars, 18% for smaller SUVs, light truc ks, and minivans, and 15% for larger SUVs, vans, and heavier trucks.22 • Ultra-low Sulfur Diesel Requi rements for Highway Vehicles : Beginning June 1, 2006, refiners started producing dies el 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 st ations and fleets, highway diesel fuel sold as low sulfur fuel met the 15 pp m 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 c onstruction, 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 adva nced clean technologies, similar to catalytic technologies used in passenger cars. New engine standards took effect, based on engine horsepowe r, 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 wi ll limit hydrocarbon emissions that evaporate from and permeate through porta ble fuel containers such as gas
cans. These standards have a co -benefit of reduci ng 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 f acility within an industry group. These
standards are based on emission levels that are already being achieved by lower emitting sources in an industr y. 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 emissi ons and is structured to meet ROP emission reduction requirements th rough 2007, the 1-hour ozone standard attainment deadline for the Lake Michig an region. The program encompasses
the seven southeast counties of Kenos ha, Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha, which are upwind of Manitowoc and Door. It controls NOx for larger ex isting sources and establishes emissions
standards for new sources. The ex isting source control program reduces
emissions at electric ut ility facilities and on la rger industrial combustion sources from projected ba seline levels in 2002. The performance standards23 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 aff ect 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 appr oximately $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 elem ents: 1) ozone season emission limits for electric utility systems comprised of boilers equal to or greater than 500 mmbtu/hr; and 2) Unit-specific requirement s 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 generati ng 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 re ductions resulting from
CAIR have been left out of the em ission projections in Section VI.

• Side Benefits of Control of Hazard ous 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 thres hold. These controls are expected to
result in the reduction of NOx emi ssions from the nonroad stationary reciprocating diesel engines. The re duction 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 reductio ns 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 w ill 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 tr ansit passes through large employers, providing a shared cost program betw een employer and employee. The UPASS program involves giving students /staff at area universities 'free' transit passes paid th rough 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 tr aveler information to the media and motorists. In addition, the live upd ates are communicated to motorists using electronic messaging signs.

• Education/Marketing Promotion : Wisconsin Partners for Clean Air voluntary coalition promoting emi ssion 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 a nd Milwaukee County Transit System (MCTS)) : Provides transit and vanpool partic ipants 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 Ma dison 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-volunt ary 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 Ar ea or the counties of Door, Manitowoc, or25 Sheboygan, will be submitted to U.S. EPA for approval as a SIP revision. Wisconsin, through its Bureau of Air Management, has th e necessary resources to actively enforce any violations of its rules or permit provision s. After redesignation, it intends to continue enforcing all rules that relate to the emissi on of ozone precursors in these nine counties

.

6. New Source Review Provisions

Wisconsin has a fully approved New Source Revi ew (NSR) procedure. This is addressed
in Wis. Adm. Code NR 405. The rule includes provisions for the Prevention of Significant Deterioration (PSD) in Wis. Ad m. Code NR 405.01. U.S. EPA has approved this program as a part of Wisconsin’s SIP a nd 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 signifi cant emissions under Wis. Adm. Code NR 405 will be required to receive an air polluti on 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 potenti al 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 emi ssion inventory or for which attainment demonstration credit was taken upon closure of the facility will not be allowed to construct, reopen, modify, or reconstruct wi thout meeting any applicable permit rule requirement.26 VI. MAINTENANCE PLAN UN DER SECTION 175(A) OF THE
CLEAN AIR ACT FOR THE MI LWAUKEE-RACINE 6-COUNTY AREA AND THE COUNTIES OF DOOR, MANITOWOC, AND
SHEBOYGAN

Section 175A of the CAA sets forth the elemen ts 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 redesi gnation, the state must submit a revised maintenance plan, which demonstrates attainment for the 10 years following the initial 10-year period. To address potentia l 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 incl ude 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, m onitoring network, verification of continued attainment and a contingency plan.

A. Attainment Inventory

Wisconsin used the year 2007 to demonstrate a ttainment 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 re quired to develop projected i nventories. After discussion with U.S. EPA Region V staff and receivi ng their written confirmation (Appendix 1), WDNR is using 2012 as the interim projec tion year. The Redesignation Guidance requires the maintenance year be at least 10 years after the rede signation request is approved by U.S. EPA. The year 2020 meet s this requirement and is used as the maintenance year.

1. Maintenance Inventory Methodology

This section contains projected emi ssions for 2012 and 2020 inventories for the Milwaukee-Racine 6-County Area and the count ies of Door, Manitowoc, and Sheboygan. WDNR performed emission projections using the following approaches.

• Point Source Inventory Projections - Projections were perf ormed by applying growth factors and applicable emission controls to the 2005 base year inventory. These growth factors were carefully selected ba sed on a prioritization schema. Foremost priority was given to county-specific empl oyment based growth factors. Next, if27 available, a state-specific employment based growth factor was used. These employment based growth factors were dete rmined from U.S. Census Bureau County
Business Patterns data 1 . Next county-specific growth factors developed by Pechan 2

contained in the document entitled Deve lopment of Updated Growth and Control Factors for the Lake Michigan Air Di rectors 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 we re estimated using linear interpolation
from 2018. WDNR received written confirmati on that this is an acceptable approach (see Appendix 1). EGU emissions proj ections were grown from information provided by an Air Management engineer a nd EGU specialist. Again, this detailed EGU methodology is contained in Appendix 5.

• Area Source Inventory Projections - Projections were perf ormed by applying growth factors and applicable emission controls to the 2005 attainment year inventory. For area source emission projections, the same pr ioritization schema was applied as with point sources. Emissions for 2020 were es timated 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 inve ntory. Marine, air, a nd rail emissions for 2020 were estimated using linear interpol ation from 2018. WDNR received written confirmation that this is an accep table 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 Radiat ion, 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 d ecrease in future year s. The results of this analysis show that th e Milwaukee-Racine 6-County Ar ea 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 main tain 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 uncerta inty factor (7.5% for M ilwaukee-Racine Counties, 15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth factor is less because a high gr owth 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 uncerta inty factor (7.5% for M ilwaukee-Racine Counties, 15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth factor is less because a high gr owth 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 uncerta inty factor (7.5% for M ilwaukee-Racine Counties, 15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth factor is less because a high gr owth 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 uncerta inty factor (7.5% for M ilwaukee-Racine Counties, 15% for Door, Manitowoc, and Sheboygan). The Milwaukee-Racine growth factor is less because a high gr owth 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 pr ojected 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 c ounties of Door, Manitowoc, and Sheboygan from 2007 to 2020. The largest reductions ar e from the mobile sectors, nonroad and onroad. Projected total NOx emissions through out the nine counties will be reduced by approximately 33% (or 71.8 tp sd) during the 13-year period.

By 2020, VOC emissions are projected to de crease 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 re duce the impact of the onroa d and nonroad VOC reductions. However, the federal Mobile Source Air T oxics 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 indi cate 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 wi ll not exceed the level of the attainment inventory, or by modeling to show that the fu ture mix of sources and emission rates will not cause a violation of the NAAQS.” The emi ssion projections demons trate 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 c ounties 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 accord ance with the Air Contaminant Emission Inventory Reporting Requirements Rule, Ch apter NR 438. WDNR prepares a new periodic inventory for all ozone precursor em ission sectors every three (3) years. These ozone precursor inventories will be prep ared for 2008, 2011, and 2014 as necessary, to comply with the inventory reporting requireme nts established in the CAA. Emissions information will be compared to the 2005 year inventory, 2007 attainment year inventory, and the 2020 projected maintenance year in ventories to assess emission trends, as necessary, to assure continued co mpliance 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 conf ormity 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 by32 the U.S. Department of Transportati on (DOT), and by Metropolitan Planning Organizations (MPOs) or othe r recipients of funds under ti tle 23U.S.C. or the Federal Transit Laws (49 U.S.C. Chapter 53). In or der for transportation pl ans and projects to conform, estimated emissions from transporta tion plans and projects must not exceed the emission budgets contained in the attainment de monstration. 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 demonstrati ng 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 appropr iate 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 MOBI LE6 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 wi ll 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 t o, 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 (S EWRPC) 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 w ill 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 maintenan ce 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 planni ng regulations. Isolat ed rural areas do not have federally required metropolitan transpor tation plans or transportation improvement plans (TIPs) and do not have projects that ar e part of the emissions analysis of any MPO’s metropolitan transportation plan or TI Ps. Projects in su ch areas are instead included in statewide transportation improve ment 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 designate d under the CAA. These budgets need to reflect reasonably consiste nt planning assumptions between the air quality and transportation planning processes and refl ect the impact of emission forecasts and emission control programs incorporated into the attainment demonstration. The 2012 and
2020 MVEB for the Milwaukee-Racine 6-C ounty Area and the counties of Door, Manitowoc, and Sheboygan is shown below in Table 16:

Table 16 : Mobile Sector Budget for the New Ma intenance 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 tr ansportation system for Door or Manitowoc County must be re-determined wh en a regionally si gnificant project from either of these
isolated rural maintenance areas are added to the Statewide TIP.

Conformity of the emissions from the enti re transportation system for the MilwaukeeRacine 6-County Area and Sheboygan Count y, including all regionally significant projects contained in the plan and all other regionally si gnificant highway and transit projects must be re-determined w ithin 18 months of the following:

1) The effective date of U.S. EPA’s fi nding that MVEBs from an initially submitted control strategy implementation plan or maintenance plan are adequate pursuant to §93.118(e) an d can be used for transportation conformity purposes;

2) The effective date of U.S. EPA approval of a control strategy implementation plan revision or main tenance plan which establishes or revises a MVEB if that budget has no t 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 uncer tainty 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 re vision or maintenance plan for the 8-hour ozone NAAQS is adequate for transportation conformity purposes.

If the re-determination does not happen, the ex isting conformity determination will lapse, and no new project-level conformity determina tions may be made until conformity of the regionally significant transporta tion projects has been determ ined 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 mainte nance 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 th an 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 fr ame of the transportation pla n, emissions in these years must be less than or equal to the contro l strategy implementation plan’s MVEB(s) for these years; and for any analysis years befo re 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 C AA, Wisconsin commits to submit to the Administrator, eight (8) years af ter 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 pe riod after re designation.

C. Monitoring Network

Wisconsin currently operates thirteen ozone monitors throughout the Milwaukee-Racine 6-County Area and the counties of Door, Ma nitowoc, 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 indicat ors of continued attainment during the maintenance period. The tracking plan for th ese 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 air35 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 em issions inventories for increases over 2007 emission inventory levels.

E. Contingency Plan

Despite the best efforts to demonstrat e 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 viola tion occurs, the first, and most important step Wisconsin will take will be to evaluate the adequacy of already adopted control measures to rectify the viola tion. 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 al ready promulgated and scheduled to be implemented at the federal or state level, the st ate will assess whether that meas ure or control in combination with other existing controls will be sufficient. Wisconsin will consider existing control measures that have been adopted in Wiscons in, as well as existing measures that have already been adopted in other states or by the federal gover nment. If existing control
measures are determined to be sufficien t 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 ad equate to return the area to attainment.

2. Evaluation of Additional Control Measur es - If it is demonstrated through modeling that existing and on-the-way measures are inad equate 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 selec tion of candidate measures will be based upon cost-effectiveness, emission re duction potential, economic and social considerations and other appropriate factors. Before proposi ng any specific candidate control measures, WDNR will solicit input from all in terested and affected parties.

It is important to note that adoption of any additional contro l measures is subject to the necessary administrative a nd legal process as well as requir ed 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 dete rmine what control meas ure (if any) will be appropriate at an unspecified time in the futu re, 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 emissi ons of 50 tons/year, and/or

o to increase the cost-effectiveness th resholds 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-RACI NE 6-COUNTY AREA

The revoked primary and secondary ambient ai r quality standards for 1-hour ozone are 0.12 ppm measured as the maximum hourly av erage 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 atta in, the 1-hour ozone standard.

Table 17 indicates the number of daily maxi mum 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 exceed ances. 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 ha ve 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 monito rs. 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 we ll below 0.12 ppm, or 125 ppb. Since 2006, the highest 1-hour ozone concentration measur ed at these four sites was 112 ppb at the Pleasant Prairie monitor on June 16, 2007.

WDNR reclassified this nona ttainment area as an atta inment 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 redesi gnation. 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 ppmSITE ID COUNTY SITE NAME2003-2005 2004-2006 2005-2007 2006-2008In Violation?550590019 Kenosha Pleasant Prairie 0 0 0 0 No550790010 Milwaukee 16thSt Health Center 0a0 0 0 No550790026 Milwaukee SER-HQ 1 1 1 0 No550790041 Milwaukee UWM North 2 2 2 0 No550790044 Milwaukee Appleton Avenue 0 ---b---b---bNo550790085 Milwaukee Bayside 2 2 2 0 No550890008 Ozaukee Grafton 1 1 1 0 No550890009 Ozaukee Harrington Beach 2 1 1 0 No551010017 Racine Racine 0 0 0 0 No551310009 Washington Slinger 0 0 0 0 No551330017 Waukesha Carroll College 0 ---c---c---cNo551330027 Waukesha Cleveland Avenue ---d0 0 0 NoNotes:(a) Data completeness at 550790010 in 2003 was 62%. This doesnot meet US EPA’s 75% completeness criterion. Hence, the 3rdhigh ozone value was used todetermine 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. Therefore a violationdetermination can be made only for the period 2003-2005.(c.) The Carroll College site (551330017) was shut down after the 2005 ozone monitoring season becausethe building where the monitor was located was razed.(d) Ozone monitoring at the Cleveland Avenue site (551330027) began in 2004. A violation assessment cannot be completed for 2003-2005 due to the lack ofdata. 38Figure 2:Bayside (550790085) – Milwaukee CountyDaily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15)01020304050607080901001101201301402003 2004 2005 2006 2007 2008Date

1-Hour Ozone Concentration (ppb)1-HR NAAQS - 125 PPBDashed Line: Linear Trend LineSlope of the Trend Line: - 0.72 ppb / ozone season 39Figure 3:Grafton (550890008) – Ozaukee CountyDaily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15)01020304050607080901001101201301402003 2004 2005 2006 2007 2008Date

1-Hour Ozone Concentration (ppb)1-HR NAAQS - 125 PPBDashed Line: Linear Trend LineSlope of the Trend Line: - 1.21 ppb / ozone season 40Figure 4:Harrington Beach (550890009) – Ozaukee CountyDaily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15)01020304050607080901001101201301402003 2004 2005 2006 2007 2008Date

1-Hour Ozone Concentration (ppb)1-HR NAAQS - 125 PPBDashed Line: Linear Trend LineSlope of the Trend Line: - 1.31 ppb / ozone season 41Figure 5:Pleasant Prairie (550590019) – Kenosha CountyDaily Maximum 1-Hour Ozone Concentration from 2003 – 2008 (April 15 – October 15)01020304050607080901001101201301402003 2004 2005 2006 2007 2008Date

1-Hour Ozone Concentration (ppb)1-HR NAAQS - 125 PPBDashed Line: Linear Trend LineSlope of the Trend Line: - 0.40 ppb / ozone season 4243 VIII. PUBLIC PARTICIPATION

This section describes the outreach and public participa tion activities that WDNR initiated for the redesignation request, highl ights related to ongoi ng air quality outreach, and summarizes the public participation plan s for any contingency measures, if needed.

Redesignation Outreach & Public Participation

In accordance with Section 100(a) (2) of the C AA, public participation in the SIP process for redesignation included a not ice of availability of the ozone redesignation documents. The date, time and location of the public he aring 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 WD NR’s responses is included in Appendix 12.

Ongoing Air Quality Information and Outreach

In addition to the targeted outreach conducte d for the ozone redesi gnation process, the WDNR has ongoing public information programs for stakeholders a nd 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 partne rship with the National Weather Service in Wisconsin to announce Air Quality Watches an d 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 th e 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 monito ring 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 re al-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 in volvement 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 continge ncy measure is selected, WDNR will develop a public involvement plan to inform key stak eholders and the general public, and develop44 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 implemente d without providing the opportunity for full public participation. At a mi nimum, that process will in clude: 1) the publication of notices; and 2) a hearing and an opportunity for public, governmental and legislative input on the relative cost s and benefits of individual m easures 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 requireme nt of Section 110(a )(1) of the 1990 CAA.

WDNR has performed an analysis and believe s the air quality improvements are due to permanent and enforceable measures. In addition, WDNR belie ves that significant regional NOx reductions will ensure continued compliance (maintenance) with the standard and that all CAA requirements neces sary 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 th is area is subject to significant transport of pollutants, significant regional NOx re ductions will ensure continued compliance (maintenance) with the NAAQS and provi de 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 Sh eboygan be redesignated to attainment simultaneously with U.S. EPA approval of Wisconsin’s State Implementation and Maintenance Plan provisions contained herein.