JIM DOYLE

GOVERNOR

STATE OF WISCONSIN

P.O. BOX 7863, MADISON, WISCONSIN 53707-7863  (608) 266-1212  FAX: (608) 267-8983

WWW.WISGOV.STATE.WI.US

March 12, 2009 

Lisa Jackson 

Administrator 

US EPA Headquarters 

Ariel Rios Building 

1200 Pennsylvania Ave., N.W. 

Mail Code: 1101A 

Washington, D.C., 20460 

Subject: Designation of 8-Hour Ozone Nonattainment Areas in Wisconsin. 

Dear Acting Administrator Mathur: 

I am sending this letter in compliance with section 107(d)(1)(A) of the federal Clean Air 

Act, which requires the Governor of each state to submit a recommendation as to 

nonattainment designations within one year from the date of promulgation of new 

federal standards. 

Recommendation

Based on rationale provided below, I am recommending that all counties in Wisconsin 

be designated as attainment for the 8-hour ozone standard. 

Rationale

As you are aware, the State of Wisconsin is very concerned about air pollution and the 

resultant adverse impacts to public health and the environment. The State has 

historically been a national leader in improving air quality and has put in place many 

critical air pollution regulations. The result of these past state actions has born fruit 

with an improvement in air quality in Wisconsin in recent years. 

More specifically, the rationale for my recommendation that portions of the state be 

designated as nonattainment in Wisconsin is based on the following 4 considerations: 

1. Substantial Progress in Reducing Ozone Levels - Even though the federal 8-hour 

ozone standard was lowered to 75 ppb last year, for the three year period of 2006-08, 

Wisconsin had only 3 counties monitoring above the standard. This is a reduction of 

7 counties from the 10 that were designated as nonattainment for the older 8-hour 

standard of 85 ppb. 
P.O. BOX 7863, MADISON, WISCONSIN 53707-7863  (608) 266-1212  FAX: (608) 267-8983  

WWW.WISGOV.STATE.WI.US

2. Modeling Results – Modeling results conducted by the Lake Michigan Air Director’s 

Consortium for the upper Great Lakes region including the regional emission 

reductions from the federal Clean Air Interstate rule, and other on-the-books and onthe-way federal and state regulations, shows all of Wisconsin, save one monitor, will 

be attaining the new ozone standard by 2015. While including emission reductions 

from the federal CAIR rule, these positive results do not include additional reductions 

that will occur in Wisconsin from other recent state actions. 

3. State Actions to Reduce NOx – As you know, NOx and VOC emissions are key 

contributors to elevated ozone levels in Wisconsin. Wisconsin’s regulatory platform to 

reduce NOx and VOC emissions is a strong one. The state’s on-going mobile source 

emission control programs for reformulated gasoline and vehicle inspection 

maintenance have been very effective in reducing VOC emissions. Additionally, in the 

past three years, Wisconsin focused its efforts on reducing NOx emissions through the 

promulgation of four important air quality rules. In addition to the aforementioned 

CAIR rule, the following 3 rules are now in place: 

NOx Reasonable Available Retrofit Rule 

Best Available Retrofit Technology Rule 

Mercury Multi-pollutant Rule 

In total, these four rules are estimated to reduce NOx emissions in Wisconsin by more 

than 60% from 2005 levels and more than 70% from 1995 levels. The net result of 

these rules is to position the state to meet all applicable current federal air quality 

standards, and as a result, protect Wisconsin’s citizens from the deleterious impacts of 

ozone, as well as fine particulates and haze. 

4. Ineffectiveness of Non-attainment Designations – There is no firm evidence that 

designation of the 3 counties that have monitored as exceeding the standard will have 

any material additional benefit to reducing ozone levels in those counties. Door 

County has no heavy industry or large coal-fired power plants. As outlined in point # 

3 above, industries and utilities in Sheboygan and Kenosha Counties are already 

subject to state and federal rules targeted at making significant reductions in NOx and 

other air pollutants. A non-attainment designation will not change the positive impact 

of those regulations, nor require additional actions to be pursued. 

Under my administration, Wisconsin has taken swift and significant action to protect 

its citizens from the harmful affects of air pollution. We have jump-started the federal 

process, by acting now, not after lengthy planning processes. At this time of severe 

economic crisis for the nation’s economy, we should not place punitive nonattainment 

designations on counties that would only serve to hinder the vitality of Wisconsin’s 

businesses. 

Lastly, if EPA determines to act on nonattainment designations in Wisconsin, then I 

request you consider minimizing the geographic area covered by such designations by 

designating only townships or utilizing alternative designations, such as rural 

transport for Door County. 

Please contact John Melby, Director of the Bureau of Air Management in the 

Wisconsin DNR, if you have any questions related to this communication. Thank you 
P.O. BOX 7863, MADISON, WISCONSIN 53707-7863  (608) 266-1212  FAX: (608) 267-8983  

WWW.WISGOV.STATE.WI.US

for the opportunity to submit the State of Wisconsin’s recommendations on this 

important air quality matter. 

Sincerely, 

Jim Doyle 

Governor 

CC: Bharat Mathur, Acting Administrator, Region V, US EPA 

 Senator Mark Miller, Chair, Senate Environment Committee 

 Representative Spencer Black, Chair, Assembly Natural Resource Committee 

 Matt Frank, Secretary, Department of Natural Resources 

 Al Shea, Administrator, Air & Waste Division, Department of Natural Resources 

 John Melby, Director, Bureau of Air Management, Department of Natural 

 Resources 

 County Executives for Door, Sheboygan and Kenosha Counties 
2008 Daily Ozone Standard Nonattainment Designation Options 

Technical Support Document 

Wisconsin Department of Natural Resources 

February 27, 2009 
Table of Contents 

Table of Contents 

List of Tables 

List of Figures 

List of Appendices 

I. Executive Summary 1

II. Background on Revised 8-hour Ozone NAAQS 8

III. Air Quality Data – Wisconsin Ozone Data Summary 9

IV. Wisconsin Emissions Data 19

V. Population Density and Degree of Urbanization 25

VI. Traffic and Commuting Patterns 29

VII. Growth Rates and Patterns 30

VIII. Meteorology / Transport 34

IX. Geography / Topography 48

X. Jurisdictional Boundaries 50

XI. Level of Control of Emission Sources 51

XII. Analysis of Potential Nonattainment Areas 54

XIII. References Cited 70

2008 Ozone Standard Technical Support Document i
List of Tables 

Table 1.1: Options Summary for the Door County Area 

Table 1.2: Options Summary for the Sheboygan County Area 

Table 1.3: Options Summary for the Kenosha County Area 

Table 3.1: Fourth-Highest Daily Maximum 8-Hour Average Ozone Concentrations 

Table 4.1: Statewide Ranks for NOx Emission Indicators 

Table 4.2: 2005 Emissions Data for the Twenty Counties Considered for a 

Nonattainment Designation 

Table 4.3: Change in Summer Day Emissions for the Twenty Counties Considered 

for a Nonattainment Designation 

Table 5.1: Population Density Change (2000 to 2008) and 2008 Population Density 

Table 5.2: Counties with an Urban Population > 75 % 

Table 5.3: Large Urban Population Increases for Rural Counties 

Table 6.1: Summer Vehicle Miles Traveled 

Table 7.1: Population Growth (2000 to 2008) 

Table 7.2: Projected Population Growth (2000 to 2035) 

Table 8.1: Hysplit Back Trajectories for Days when the 1-Hour Ozone 

Concentrations ≥ 75 ppb 

Table 8.2: OSAT Source Regions 

Table 12.1: Analysis of Factors for the Door County Area 

Table 12.2: Options Summary for the Door County Area 

Table 12.3: Analysis of Factors for the Sheboygan County Area 

Table 12.4: Options Summary for the Sheboygan County Area 

Table 12.5: Analysis of Factors for the Kenosha County Area 

Table 12.6: Options Summary for the Kenosha County Area 

2008 Ozone Standard Technical Support Document ii
List of Figures 

Figure 1.1: 8-Hour Ozone Designation Analysis Area 

Figure 1.2: Counties Considered for an 8-Hour Ozone Nonattainment Designation 

(Option 1) 

Figure 1.3: Counties Considered for an 8-Hour Ozone Nonattainment Designation 

(Option 2) 

Figure 1.4: Counties Considered for an 8-Hour Ozone Nonattainment Designation 

(Option 3) 

Figure 3.1: 8-Hour Ozone Design Values (2006 to 2008) 

Figure 3.2: Number of 8-Hour Ozone Design Values Since 2003 that have Exceeded 

the 2008 Ozone Standard 

Figure 3.3: 8-Hour Ozone Design Values Since 1999 for the MKE-Racine 

Nonattainment Area 

Figure 3.4: 8-Hour Ozone Design Values Since 1999 for Sheboygan County 

Figure 3.5: 8-Hour Ozone Design Values Since 1999 for Manitowoc County 

Figure 3.6: 8-Hour Ozone Design Values Since 1999 for Kewaunee County 

Figure 3.7: 8-Hour Ozone Design Values Since 1999 for Door County 

Figure 4.1: 2005 NOx Emissions by County 

Figure 4.2: 2005 VOC Emissions by County 

Figure 4.3: NOx and VOC from Stationary Air Pollution Sources (1985-2007) 

for the Twenty Counties Considered for a Nonattainment Designation 

Figure 5.1: 2008 Population Density by County 

Figure 5.2: One-Year Percentage Change in Service Providing Jobs 

Figure 7.1: Population Growth by County (2000 to 2008) 

Figure 7.2: Projected Population Growth by County (2008 to 2035) 

Figure 8.1: Eastern Wisconsin Climate Divisions 

Figure 8.2: Average May – September Temperature and Average Fourth-Highest 8-

Hour Average Ozone Concentrations for the East Central and Southeast 

Climate Divisions 

Figure 8.3: Door County Wind Rose when the 1-Hour Ozone Concentration ≥ 75 ppb 

Figure 8.4: Sheboygan County Wind Rose when the 1-Hour Ozone Concentration ≥

75 ppb 

Figure 8.5: Kenosha County Wind Rose when the 1-Hour Ozone Concentration ≥ 75 

ppb 

Figure 8.6: OSAT Results for Door County 

Figure 8.7: OSAT Results for Sheboygan County 

Figure 8.8: OSAT Results for Kenosha County 

Figure 8.9: 2005 NOx Emissions for the Twenty Counties Considered for a 

Nonattainment Designation and the Chicago Nonattainment Counties 

Figure 8.10: 2005 VOC Emissions for the Twenty Counties Considered for a 

Nonattainment Designation and the Chicago Nonattainment Counties 

Figure 9.1: Topography of the Twenty Counties Considered for Nonattainment 

Figure 10.1: Wisconsin Ozone Nonattainment Areas 

2008 Ozone Standard Technical Support Document iii
List of Appendices 

Appendix 1 Guidance from U.S. EPA for Determining Nonattainment Designations 

Appendix 2 DNR’s Response to Public Comments 

Appendix 3 Summary of Public Comments – Preferred Options 

2008 Ozone Standard Technical Support Document iv
02/27/2009 

I. Executive Summary

On March 12, 2008, the U.S. Environmental Protection Agency (EPA) promulgated 

revisions to the 1997 primary and secondary national ambient air quality standards 

(NAAQS) for ozone. The revisions became effective on May 27, 2008 tightening the 8-

hour ozone standard, both primary and secondary, from 0.08 parts per million (ppm) to 

0.075 ppm. Monitoring sites with a design value greater than 0.075 ppm measure 

nonattainment of the 8-hour ozone standard. The purpose of this document is to provide 

technical information to support the determination of which Wisconsin counties should 

receive nonattainment designations for the revised 8-hour ozone standard. 

Section 107(d)(1)(A)(i) of the Clean Air Act (CAA) states that “any area that does not 

meet (or that contributes to ambient air quality in a nearby area that does not meet) the 

primary or secondary ambient air quality standard for the pollutant” should be designated 

as a nonattainment area. 

EPA provided guidance on determining ozone designation boundaries in a December 4, 

2008 memorandum from Robert J. Meyers, “Area Designations for the 2008 Revised 

Ozone National Ambient Air Quality Standards.” This document states that a Core 

Based Statistical Area (CBSA) or Combined Statistical Area (CSA) serve as the starting 

point or presumptive boundary for considering what should be the geographic boundary 

of an ozone nonattainment area. When an ozone monitor is located in a county not part 

of a CBSA or CSA, EPA recommends the county boundary serve as the presumptive 

nonattainment area. To support the determination of nonattainment boundaries, EPA 

recommends an evaluation of the following nine factors: 

1. Air quality data 

2. Emissions data (location of sources and contribution to ozone concentrations) 

3. Population density and degree of urbanization (including commercial 

development) 

4. Traffic and commuting patterns 

5. Growth rates and patterns 

6. Meteorology (weather/transport patterns) 

7. Geography/topography (mountain ranges or other air basin boundaries) 

8. Jurisdictional boundaries (e.g., counties, air districts, existing nonattainment area, 

Reservations, metropolitan planning organizations (MPOs)) 

9. Level of control of emission sources 

Based on ozone monitoring data from 2006 through 2008, the counties of Door, 

Sheboygan, and Kenosha exceeded the revised 8-hour ozone standard. The tables below 

summarize designation options for these three counties and other nearby counties that 

may have contributed to the measured nonattainment. Twenty counties are considered 

for a potential nonattainment designation (Figure 1.1). A detailed assessment of the nine 

factors recommended by the EPA for the twenty counties is presented in Section 12 of 

this document. This technical support document is developed to support nonattainment 

recommendation decisions by the Governor. 

2008 Ozone Standard Technical Support Document 1
02/27/2009 

Door County Area

Ozone monitoring data from 2006 through 2008 demonstrate a design value 

concentration above the 8-hour ozone standard in Door County (0.080 ppm). The 

following table (1.1) outlines three possible nonattainment designation options for the 

Door County area. These options are based on EPA’s nine factors to consider when 

determining nonattainment boundaries. The counties of Brown, Calumet, Kewaunee, 

Manitowoc, Marinette, Oconto, and Outagamie are evaluated for potentially contributing 

to the measured nonattainment in Door County. 

 

Table 1.1: Options Summary for the Door County Area 

Designation Option 1 Option 2 Option 3 

Nonattainment 

Counties 

Door 

Brown 

Kewaunee 

Manitowoc 

Door None

Door County is not part of a CBSA or CSA, thus the presumptive boundary for any 

ozone nonattainment area is the county boundary (Option 2). 

Sheboygan County Area

Ozone monitoring data from 2006 through 2008 demonstrate a design value 

concentration above the 8-hour ozone standard in Sheboygan County (0.082 ppm). The 

following table (1.2) outlines three possible nonattainment designation options for the 

Sheboygan County area. These options are based on EPA’s nine factors to consider 

when determining nonattainment boundaries. The counties of Calumet, Dodge, Fond Du 

Lac, Jefferson, Kenosha, Manitowoc, Milwaukee, Ozaukee, Racine, Walworth, 

Washington, Waukesha, and Winnebago are evaluated for potentially contributing to the 

measured nonattainment in Sheboygan County. 

Table 1.2: Options Summary for the Sheboygan County Area 

Designation Option 1 Option 2 Option 3 

Nonattainment 

Counties 

Sheboygan 

Milwaukee CSA 

Kenosha 

Sheboygan None 

Milwaukee CSA: Milwaukee, Ozaukee, Racine, Washington, and Waukesha Counties 

Sheboygan County makes up the Sheboygan, WI Core Based Statistical Area (CBSA 

Code 43100), which includes no other counties. Thus, the presumptive boundary for any 

ozone nonattainment area is the county boundary (Option 2). 

2008 Ozone Standard Technical Support Document 2
02/27/2009 

Kenosha County Area

Ozone monitoring data from 2006 through 2008 demonstrate a design value 

concentration above the 8-hour ozone standard in Kenosha County (0.078 ppm). The 

following table (1.3) outlines three possible nonattainment designation options for the 

Kenosha County area. These options are based on EPA’s nine factors to consider when 

determining nonattainment areas. The counties of Milwaukee, Ozaukee, Racine, 

Walworth, Washington, and Waukesha are evaluated for potentially contributing to the 

measured nonattainment in Kenosha County. 

Table 1.3: Options Summary for the Kenosha County Area 

Designation Options 1 & 2 Option 3 

Nonattainment 

Counties Kenosha None 

Kenosha County is part of the Chicago-Naperville-Michigan City CSA (CSA Code 176), 

which includes no other Wisconsin counties. Thus, the presumptive boundary for any 

ozone nonattainment area is the county boundary (Options 1 & 2). 

Other Counties in the State

Monitoring data in other counties of the state indicate attainment of the 8-hour ozone 

standard. Counties not specifically analyzed in the options summarized above should be 

designated as attaining the standard. 

2008 Ozone Standard Technical Support Document 3
02/27/2009 

Figure 1.1 8-Hour Ozone Designation Analysis Area 

Counties shaded in dark gray exceeded the 8-hour ozone standard (> 0.075 ppm) based on ozone monitor 

data from 2006 to 2008. 

2008 Ozone Standard Technical Support Document 4
02/27/2009 

Figure 1.2 Counties Considered for an 8-Hour Ozone Nonattainment Designation 

(Option 1) 

Nonattainment 

Attainment 

2008 Ozone Standard Technical Support Document 5
02/27/2009 

Figure 1.3 Counties Considered for an 8-Hour Ozone Nonattainment Designation 

(Option 2) 

Nonattainment 

Attainment 

2008 Ozone Standard Technical Support Document 6
02/27/2009 

Figure 1.4 Counties Considered for an 8-Hour Ozone Nonattainment Designation 

(Option 3) 

Nonattainment 

Attainment 

2008 Ozone Standard Technical Support Document 7
02/27/2009 

II. Background on Revised 8-Hour Ozone NAAQS 

On March 12, 2008, the EPA promulgated revisions to the 1997 primary and secondary 

NAAQS for ozone. The revisions became effective on May 27, 2008 tightening the 8-

hour ozone standard, both primary and secondary, from 0.08 ppm to 0.075 ppm. 

Monitoring sites with a design value greater than 0.075 ppm measure nonattainment of 

the 8-hour ozone standard. 

EPA concluded that ozone causes adverse health effects at the level of the 1997 standard 

and below. The 0.075 ppm level for the primary and secondary standard was selected 

based on “an extensive review of thousands of scientific studies on the impact of ground 

level ozone on public health and the environment” (U.S. EPA, 2008b). 

EPA demonstrated that the benefits of a lower ozone standard are likely greater than the 

expected costs. The value of the health benefits from the new standard was estimated to 

range from $2 billion to $19 billion per year in 2020. The cost of implementing the new 

standard was estimated to range from $7.6 billion to $8.5 billion per year in 2020 (U.S. 

EPA, 2008b). 

The 2008 ozone standard designation process is as follows: 

• Final Rule Promulgated: March 12, 2008 

• State Designation Recommendations to EPA: No later than March 12, 2009 

• Potential EPA Modifications: No later than November 12, 2009 

• 30-Day Public Comment Period Initiated: Mid-November 2009 

• State Response Regarding EPA Modifications: No later than January 12, 2010 

• Final Designations: No later than March 12, 2010 

The purpose of this document is to provide technical information enabling appropriate 

delineation of nonattainment area boundaries for the 2008 ozone standard. Section 

107(d)(1)(A)(i) of the Clean Air Act (CAA) states that “any area that does not meet (or 

that contributes to ambient air quality in a nearby area that does not meet) the primary or 

secondary ambient air quality standard for the pollutant” should be designated as a 

nonattainment area. EPA provided guidance on how to determine ozone attainment 

boundaries in a December 4, 2008 memorandum from Robert J. Meyers, “Area 

Designations for the 2008 Revised Ozone National Ambient Air Quality Standards.” 

Nonattainment recommendations are based upon the nine factors presented in this 

memorandum. 

2008 Ozone Standard Technical Support Document 8
02/27/2009 

III. Air Quality Data – Wisconsin Ozone Data Summary 

Title 40 of the Code of Federal Regulations (40 CFR) Part 50, Appendix I explains the 

data handling conventions and computations necessary for determining whether the 

national 8-hour primary and secondary ambient standards for ozone are met at an ambient 

ozone air quality monitoring site. Design values are determined by averaging the fourthhighest daily maximum 8-hour average ozone concentrations for three consecutive 

years1. A monitoring site is classified as “in attainment” if the design value is less than 

or equal to 0.075 ppm. During the three year period, daily maximum 8-hour average 

ozone concentrations are required to be available for at least 90%, on average, of the days 

during the designated ozone monitoring seasons (April 15th – October 15th), with a 

minimum data completeness in any one year of 75% of the designated sampling days. 

Ozone was monitored at 32 locations across the state from 2006 through 2008. The data 

was collected in accordance with the requirements of 40 CFR Part 50 and fully qualityassured in accordance with the requirements of 40 CFR Part 58, Appendix A. Table 3.1 

lists the fourth-highest daily maximum 8-hour average ozone concentrations for the 32 

monitoring locations and resulting design values. The only counties that exceeded the 

2008 ozone standard are Door, Sheboygan, and Kenosha (Table 3.1 and Figure 3.1). 

The fourth-highest daily maximum 8-hour average ozone concentrations ranged from 

0.059 to 0.092 ppm from 2006 through 2008. Across the state, higher than normal ozone 

concentrations were measured during 2007, while lower than normal ozone 

concentrations were measured during 2008. The average of the fourth-highest daily 

maximum 8-hour average ozone concentrations for all 32 monitors is 0.076 ppm for 2007 

and 0.064 ppm for 2008. From 2006 through 2008, 15.6 % (5 / 32), 46.9 % (15 / 32), and 

0 % (0 / 32) of the ozone monitors recorded fourth-highest daily maximum 8-hour 

average ozone concentrations that exceeded 0.075 ppm, respectively. It should be noted 

that Kewaunee and Manitowoc are the only two counties that measured fourth-highest 

daily maximum 8-hour average ozone concentrations that exceeded 0.075 ppm during 

two of the three years and still had design values below 0.075 ppm. 

Meteorological conditions are most likely the main reason for the variation in ozone 

concentrations from 2007 to 2008. The daily maximum temperature was 3.1 o F and 1.7 o 

F above normal during the 2007 ozone season at Madison and Milwaukee, respectively, 

compared to 0.5 o F above normal and -0.3 o F below normal during the 2008 ozone 

season (NWS, 2008a). Normal daily maximum temperatures are based on climatological 

data from 1971 through 2000 (NWS 2008b). The daily maximum temperature in 

Milwaukee was 90 o F or above seven times in 2007 and zero times in 2008 (NWS, 

2008a). 

Design values from 2006 through 2008 are compared against previous design values to 

determine the representativeness of the latest 3-year period. Figure 3.2 shows the number 

of ozone design values since 2003 that have exceeded the 2008 ozone standard on a 

county level. Design values for the counties of Door, Kenosha, and Sheboygan have 

 

1

 Note: Design values are truncated after three decimal points (i.e., 0.0759 ppm = 0.075 ppm). 

2008 Ozone Standard Technical Support Document 9
02/27/2009 

exceeded 0.075 ppm for every concurrent three year period since 2003 (2003-05, 2004-

06, 2005-07, and 2006-08). The counties of Kewaunee, Manitowoc, Milwaukee, 

Ozaukee, and Racine have exceeded 0.075 ppm for every concurrent three year period 

since 2003, except for the most recent three year period. 

Figures 3.3 through 3.7 show ozone design values from the 1999-01 period onward, 

including a linear trend for the Milwaukee-Racine nonattainment area (Ozaukee, 

Washington, Waukesha, Milwaukee, Racine, and Kenosha Counties) and the counties of 

Sheboygan, Manitowoc, Kewaunee, and Door. Based on extrapolation of the linear 

trends, all counties, except Door, should achieve the 8-hour ozone standard by the 2010-

12 period. Although the design values from the latest period are the lowest since the 

1999-01 period, they are consistent with the downward trends shown. 

2008 Ozone Standard Technical Support Document 10
02/27/2009 

Table 3.1: Fourth-Highest Daily Maximum 8-Hour Average Ozone Concentrations 

Locations with design values exceeding the 2008 ozone standard are highlighted 

AIRS ID SITE ADDRESS COUNTY 2006 2007 2008 DESIGN 

VALUE 

550030010 Bad River Tribal School - Odanah Ashland 0.061 0.066 0.060 0.062 

550090026 Uw-Green Bay, Hwys 54 & 57 Brown 0.066 0.082 0.063 0.070 

550210015 Wendt Rd, Columbus Columbia 0.066 0.077 0.064 0.069 

550250041 East High, 2302 Hoard St Dane 0.066 0.080 0.063 0.069 

550270007 Mayville, Near N6705 Madison Rd Dodge 0.068 0.074 0.064 0.068 

550290004 Newport State Park (Near Ellison Bay) Door 0.079 0.092 0.069 0.080 

550370001 Popple River, Nadp Fire Station #565 Florence 0.065 0.070 0.061 0.065 

550390006 Fond Du Lac, N3996 Kelly Rd, 

Twn Byron Fond du Lac 0.066 0.074 0.062 0.067 

550410007 Fire Tower Rd, Potawatomi Site Forest 0.066 0.073 0.066 0.068 

550550002 Jefferson H.S. Trailer, Willow Dr. Jefferson 0.069 0.076 0.066 0.070 

550590019 Chiwaukee Prairie, 11838 First Court Kenosha 0.079 0.085 0.072 0.078 

550610002 Kewaunee, Route 1, Hwy 42 Kewaunee 0.077 0.085 0.065 0.075 

550710007 Manitowoc/Woodlnd Dunes, 

2315 Goodwin Rd Manitowoc 0.078 0.085 0.064 0.075 

550730012 Lake Dubay, 1780 Bergen Rd, 

Bergen Tnshp Marathon 0.066 0.072 0.064 0.067 

550790085 601 E. Ellsworth Lane Milwaukee 0.073 0.083 0.069 0.075 

550790041 Uwm North Campus, 

2114 E Kenwood Blvd Milwaukee 0.073 0.078 0.065 0.072 

550790026 Dnr Ser Hdqrts, 

2300 N M. L. King Jr Dr Milwaukee 0.068 0.075 0.063 0.068 

550790010 Health Center, 1337 So 16th St Milwaukee 0.064 0.067 0.059 0.063 

550850004 Harshaw Farm, 4398 Grace Lane, 

Harshaw Oneida 0.064 0.071 0.063 0.066 

550870009 Aal, 4432 N Meade St Outagamie 0.069 0.075 0.062 0.068 

550890009 Harrington Beach State Park, 

531 Hwy D Ozaukee 0.072 0.084 0.067 0.074 

550890008 Grafton, Hwy32 And I43 Ozaukee 0.071 0.082 0.064 0.072 

551010017 1519 Washington Ave Racine 0.071 0.077 0.064 0.070 

551050024 Cunningham, 1948 Merrill St Rock 0.067 0.077 0.065 0.069 

551110007 Devils Lake State Park, 

E12886 Tower Rd Sauk 0.064 0.070 0.061 0.065 

551170006 Kohler Andre Park, 

1520 Old Park Road Sheboygan 0.083 0.088 0.075 0.082 

551091002 Hwy 64, Somerset Town Hall St. Croix 0.068 0.075 0.062 0.068 

551230008 Wildcat Mtn, Hwy 33, Ontario Vernon 0.066 0.071 0.065 0.067 

551250001 Trout Lake Nursery, County Hwy M Vilas 0.066 0.073 0.063 0.067 

551270005 Lake Geneva Nadp Site, 

Rr4 Elgin Club Rd Walworth 0.072 0.075 0.064 0.070 

551310009 Slinger, Hwy 60 & Scenic, Polk Twnshp Washington 0.066 0.071 0.060 0.065 

551330027 1310 Cleveland Ave Waukesha 0.067 0.072 0.060 0.066 

* Annual fourth-highest daily maximum 8-hour average ozone concentrations exceeding 0.075 ppm are listed in bold. 

Source: U.S. EPA AirData, Air Quality System (AQS): (http://www.epa.gov/air/data/index.html) 

2008 Ozone Standard Technical Support Document 11
02/27/2009 

Figure 3.1: 8-Hour Ozone Design Values (ppb) (2006 to 2008) 

2008 Ozone Standard Technical Support Document 12
02/27/2009 

2008 Ozone Standard Technical Support Document 13

Figure 3.2: Number of 8-Hour Ozone Design Values Since 2003 that have Exceeded 

the 2008 Ozone Standard 

(2003-05, 2004-06, 2005-07, and 2006-08) 

Source: U.S. Environmental Protection Agency Design Values 

(http://www.epa.gov/airtrends/values.html) 

Number of Design Values Since 2003 

that have Exceeded the 2008 Ozone 

Standard 
02/27/2009 

FIGURE 3.3: 8-Hour Ozone Design Values Since 1999 for the Milwaukee-Racine Nonattainm

0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.110

1999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-1

3-Year Period

Ozone Design Value (ppm)

Milwaukee-Rac

8-Hour Ozone Standard (0.075 ppm)

Linear Trend

Source: U.S. Environmental Protection Agency Design Values (http://www.epa.gov/airtrends/values.html) 

2008 Ozone Standard Technical Support Document 
02/27/2009 

FIGURE 3.4: 8-Hour Ozone Design Values Since 1999 for Sheboygan County 

0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.110

1999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-1

3-Year Period

Ozone Design Value (ppm)

Sheboy

8-Hour Ozone Standard (0.075 ppm)

Linear T

Source: U.S. Environmental Protection Agency Design Values (http://www.epa.gov/airtrends/values.html) 

2008 Ozone Standard Technical Support Document 
02/27/2009 

FIGURE 3.5: 8-Hour Ozone Design Values Since 1999 for Manitowoc County 

0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.110

1999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-1

3-Year Period

Ozone Design Value (ppm)

Manito

8-Hour Ozone Standard (0.075 ppm)

Linear Trend

Source: U.S. Environmental Protection Agency Design Values (http://www.epa.gov/airtrends/values.html) 

2008 Ozone Standard Technical Support Document 
02/27/2009 

FIGURE 3.6: 8-Hour Ozone Design Values Since 1999 for Kewaunee County 

0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.110

1999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-1

3-Year Period

Ozone Design Value (ppm)

Kewau

8-Hour Ozone Standard (0.075 ppm)

Linear Trend

Source: U.S. Environmental Protection Agency Design Values (http://www.epa.gov/airtrends/values.html) 

2008 Ozone Standard Technical Support Document 
08 Ozone Standard Technical Support Document 

FIGURE 3.7: 8-Hour Ozone Design Values Since 1999 for Door County 

0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.110

1999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-1

3-Year Period

Ozone Design Value (ppm)

Doo

8-Hour Ozone Standard (0.075 ppm)

Linear Trend

Source: U.S. Environmental Protection Agency Design Values (http://www.epa.gov/airtrends/values.html) 

02/27/2009 20
02/27/2009 

2008 Ozone Standard Technical Support Document 19

IV. Wisconsin Emissions Data 

Ground level ozone is created by a chemical reaction between nitrogen oxides (NOx) and 

volatile organic compounds (VOCs) in the presence of heat and sunlight. The highest 

daily ozone concentrations typically occur during the mid- to late-afternoon when daily 

temperatures reach their maximum. Vehicle and equipment exhaust, industrial 

emissions, gasoline vapors, and chemical solvents are some major sources of NOx and 

VOCs. These emissions contribute to ozone formation locally and regionally. Therefore, 

it is important to consider emissions in counties where nonattainment is measured, as 

well as counties that contribute to nonattainment via atmospheric transport of NOx and 

VOCs. Emissions summarized below are from the Wisconsin 2005 base year inventory 

submitted to EPA in June 2007. 

Table 4.2 details 2005 summer day emissions for the twenty counties considered for a 

nonattainment designation. Emissions are summarized by source sector and the 

pollutants that contribute to ozone production. Automobiles and electric generating units 

(EGUs) are the major NOx sources in the state due to high temperature fuel combustion 

associated with these sources. VOC emissions are derived from a number of sources, 

including onroad and nonroad mobiles sources (e.g., cars, trucks, lawn mowers, and 

outboard engines), industrial solvents and coatings, as well as smaller point sources, such 

as gasoline stations, portable fuel containers, and usage of solvents, coatings and cleaning 

agents in the home. 

Significant NOx emissions occur in the counties of Milwaukee, Brown, Kenosha, 

Waukesha, Sheboygan, and Outagamie (Table 4.2 and Figure 4.1). The counties with 

EGUs, the greatest vehicle miles traveled (VMT), and the largest populations have the 

highest NOx emissions. The following table (4.1) shows the statewide ranks for these 

three factors. 

Table 4.1: Statewide Ranks for NOx Emission Indicators 

COUNTY NOx 

(tpsd) 

2008 

POPULATION 

2003-2007 

AVERAGE VMT 

2005 NOx 

from EGUs 

Milwaukee 91.3 1 1 3 

Brown 72.9 4 4 2 

Kenosha 47.7 8 10 1 

Waukesha 29.7 3 3 24 

Sheboygan 29.6 12 18 7 

Outagamie 25.3 6 8 22 

Note: Wisconsin has 72 counties. 

Figure 4.2 demonstrates that VOC emissions occur in the more populous and industrial 

areas of the state. In Milwaukee County nearly 96 tons of VOC are emitted on a summer 

day, while 54 tons and 36 tons are emitted daily in Waukesha and Brown Counties, 

respectively. Substantial VOC emissions also occur in the Fox River Valley (Brown, 

Outagamie, and Winnebago Counties) and in counties such as Sheboygan, Washington, 

and Racine Counties. The counties noted either directly border a nonattainment area or 

are upwind of an area that measures nonattainment.
08 Ozone Standard Technical Support Document 

Table 4.2: 2005 Emissions Data for the Twenty Counties Considered for a Nonattainment Des

POINT AREA OFFROAD ONROAD 

COUNTY FIPS Code 

NOX VOC NOX VOC NOX VOC NOX VOC NOX 

BROWN 55009 48.88 6.75 2.20 13.20 6.40 8.06 15.46 8.11 72.94 15CALUMET 55015 0.23 1.04 0.19 2.25 1.90 1.89 2.44 1.29 4.76 1DODGE 55027 0.52 1.77 0.40 7.82 3.75 4.01 6.17 2.94 10.83 2DOOR 55029 0.00 0.25 0.26 1.91 5.35 9.21 2.45 1.05 8.06 1FOND DU LAC 55039 1.84 2.69 0.68 6.56 3.44 4.33 6.87 3.51 12.82 2JEFFERSON 55055 3.25 1.73 0.65 7.85 2.89 4.97 8.49 2.97 15.28 3KENOSHA 55059 35.40 0.93 0.99 7.42 4.13 4.46 7.13 3.02 47.65 10KEWAUNEE 55061 0.07 0.31 0.09 1.65 1.73 1.61 1.22 0.59 3.11 0MANITOWOC 55071 5.07 1.80 0.53 5.83 3.81 3.33 7.36 2.57 16.77 3MARINETTE 55075 6.67 3.03 0.21 3.98 1.74 4.77 3.07 1.48 11.69 2MILWAUKEE 55079 30.95 9.01 7.25 54.57 17.80 16.02 35.33 15.86 91.34 19OCONTO 55083 0.16 0.89 0.22 2.50 1.23 5.01 3.47 1.51 5.07 1OUTAGAMIE 55087 9.53 4.65 1.54 7.36 4.63 4.64 9.62 5.39 25.33 5OZAUKEE 55089 1.04 0.65 0.77 8.81 5.28 2.55 5.57 2.02 12.66 2RACINE 55101 0.83 1.66 1.32 23.10 5.44 6.06 7.33 3.24 14.92 3SHEBOYGAN 55117 16.43 2.98 1.22 9.50 4.08 5.36 7.84 2.86 29.58 6WALWORTH 55127 0.44 1.33 0.82 6.26 3.36 6.88 7.59 3.65 12.21 2WASHINGTON 55131 0.53 0.66 1.06 15.09 3.89 5.65 8.36 2.97 13.84 3WAUKESHA 55133 1.00 4.60 4.12 21.59 12.11 18.87 22.49 8.88 39.72 8WINNABEGO 55139 2.78 7.25 1.34 9.39 5.57 11.44 10.81 5.62 20.49 4TOTAL --- 165.62 53.97 25.86 216.62 98.53 129.12 179.07 79.53 % OF POLLUTANT --- 35.3 % 11.3 % 5.5 % 45.2 % 21.0 % 26.9 % 38.2 % 16.6 % 

469.08 

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02/27/2009 

NOx and VOC from stationary air pollution sources have been trending downward in 

Wisconsin since 1985. Figure 4.3 shows the annual amount of NOx and VOC emitted 

from stationary air pollution sources from 1985 through 2007 for the twenty counties 

considered for a nonattainment designation. The actual tonnage of reported NOx ranged 

from approximately 84,544 tons in 1985 to approximately 42,386 tons in 2007. The 

actual tonnage of reported VOC ranged from approximately 36,460 tons in 1985 to 

approximately 14,237 tons in 2007. 

The following table (4.3) shows the change in summer day emissions for the point, area, 

on-road, and off-road source sectors from the 2002 to 2005 Wisconsin emissions 

inventories for the twenty counties considered for a nonattainment designation. The total 

NOx and VOC emissions decreased from 2002 to 2005 across the twenty county region. 

Table 4.3: Change in Summer Day Emissions for the Twenty Counties Considered 

for a Nonattainment Designation 

NOx (tons per summer day) VOC (tons per summer day) 

Sector 2002 2005 Sector 2002 2005 

Point 202.8 165.6 Point 44.6 54.0 

Area 20.1 25.9 Area 236.3 216.6 

On-road 218.5 179.1 On-road 102.3 79.5 

Off-road 107.4 98.5 Off-road 144.6 129.1 

548.8 469.1 527.8 479.2 Total 14.5 % Decrease Total 9.2 % Decrease 

2008 Ozone Standard Technical Support Document 21
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Figure 4.1: 2005 NOx Emissions by County (Tons per Summer Day) 

NOx (tpsd)

2008 Ozone Standard Technical Support Document 22
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2008 Ozone Standard Technical Support Document 23

Figure 4.2: 2005 VOC Emissions by County (Tons per Summer Day) 

VOC (tpsd)
08 Ozone Standard Technical Support Document 

Figure 4.3: NOx and VOC from Stationary Air Pollution Sources (1985-2007) 

for the Twenty Counties Considered for a Nonattainment Designation 

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

02/27/2009 20
02/27/2009 

V. Population Density and Degree of Urbanization 

Population density and the degree of urbanization are well correlated with the amount 

and concentration of air pollutant emissions. Identifying areas with a dense population 

and those experiencing rapid urbanization is critical for determining areas that contribute 

to ozone formation. 

a. Population Density 

Since 2000, population density has increased in all twenty counties considered for a 

nonattainment designation, except Milwaukee. The counties experiencing the largest 

total increase in population density include Kenosha, Waukesha, Brown, Washington, 

and Racine (Table 5.1). This is important because emissions typically increase with 

population density increases. 

Table 5.1: Population Density Change (2000 to 2008) and 2008 Population Density 

Counties with pop. density change > 25 persons/mi2 or pop. density > 500 persons/mi2

COUNTY Population Density Change 

2000 to 2008 (persons/mile2

) 

2008 Population Density 

(persons/mile2) 

Kenosha 45.88 594.12 

Waukesha 39.47 688.82 

Brown 35.01 463.74 

Washington 30.14 302.89 

Racine 22.49 589.38 

Source: Derived from Data Created by Wisconsin Department of Administration – Demographic Services 

(http://www.doa.state.wi.us/docview.asp?locid=9&docid=7263) 

Figure 5.1 shows the 2008 population density estimates for the twenty counties 

considered for a nonattainment designation. The counties of southeast Wisconsin and the 

Fox River Valley are the two most densely populated areas. 

b. Degree of Urbanization 

The degree of urbanization is also an important influence on pollutant emissions. In 

2000, 68.3% of Wisconsin’s population lived in urban areas, as defined by the U.S. 

Census Bureau (More recent estimates are not available). That is 2.6% greater than in 

1990 (65.7%). 

Approximately 33% of Wisconsin’s entire population lives in the twenty counties 

considered for a nonattainment designation. In 1990, 2.854 million people lived in these 

counties and 78.7% was classified as urban. During the next 10 years, the population in 

this area grew to 3.048 million and 81.1% was classified as urban. The twenty counties 

considered for a nonattainment designation, as a whole, are becoming more urban. 

Seven of the twenty counties considered for a nonattainment designation had an urban 

population of 75% or greater in 1990 or 2000 (Table 5.2). Of these seven largely 

urbanized counties, all, except Milwaukee and Ozaukee, experienced an increasing 

degree of urbanization between 1990 and 2000. 

2008 Ozone Standard Technical Support Document 25
02/27/2009 

Table 5.2: Counties with an Urban Population > 75% 

COUNTY % Urban Population 

in 2000 

% Urban Population 

in 1990 

 % Difference 

2000 – 1990 

Milwaukee 99.7 % 100.0 % - 0.3 % 

Brown 83.9 % 83.2 % + 0.7 % 

Winnebago 84.2 % 81.7 % + 2.5 % 

Racine 87.0 % 79.4 % + 7.6 % 

Kenosha 88.6 % 78.8 % + 9.8 % 

Waukesha 87.8 % 78.1 % + 9.7 % 

Ozaukee 74.6 % 75.7 % - 1.0 % 

Source: U.S. Census Bureau – Summary File 1 – SF 1 – 100% Data 

(http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=DEC&_submenuId=&_lang=en&_ts=)

Rural counties in the twenty counties considered for a nonattainment designation are also 

rapidly becoming more urban. Counties such as Walworth and Washington witnessed 

urbanization rates exceeding 10% between the 1990 and 2000 (Table 5.3). 

Table 5.3: Large Urban Population Increases for Rural Counties 

(2000 – 1990) > 10% 

COUNTY % Urban Population 

in 2000 

% Urban Population 

in 1990 

% Difference 

2000 – 1990 

Walworth 64.0 % 40.3 % + 23.7 % 

Washington 65.2 % 50.8 % + 14.4 % 

Source: U.S. Census Bureau – Summary File 1 – SF 1 – 100% Data 

(http://factfinder.census.gov/servlet/DatasetMainPageServlet?_program=DEC&_submenuId=&_lang=en&_ts=)

The nonattainment boundary guidance provided by EPA recommends considering the 

degree of commercial development. Based on data from the Wisconsin Department of 

Workforce Development, the one year change in “service providing” jobs from October, 

2007 to October, 2008 was analyzed for the twenty counties considered for a 

nonattainment designation (WI DWD, 2008a). Service providing jobs include, 

construction, mining, and natural resources; manufacturing; trade; transportation, 

warehousing, and utilities; financial activities; education and health services; leisure and 

hospitality; information, professional and business; and other services, excluding public 

service (i.e., government). Figure 5.2 shows the one year percentage change in service 

providing jobs. Some of the statistics were only provided on a metropolitan, or multiple 

county, level. Milwaukee and the surrounding counties saw a decrease in the amount of 

service providing jobs. Only two counties, Dodge and Kenosha, saw an increase in the 

amount of service providing jobs by more than five percent. 

2008 Ozone Standard Technical Support Document 26
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Figure 5.1: 2008 Population Density by County 

# Persons/Mile2

2008 Ozone Standard Technical Support Document 27
02/27/2009 

Figure 5.2: One-Year Percentage Change in Service Providing Jobs 

October, 2008 – October, 2007 

Percent Change

2008 Ozone Standard Technical Support Document 28
02/27/2009 

VI. Traffic & Commuting Patterns 

Motor vehicles are the single largest source category of ozone precursor NOx emissions 

and the second largest source category of ozone precursor VOC emissions across the 

twenty counties considered for a nonattainment designation. One indicator of vehicle use 

is the total miles traveled on roads and highways by motor vehicles in the state, or VMT. 

The greatest total gasoline VMT occurs in counties with major interstate stretches of 

highway, as well as areas of greater population (Table 6.1). The counties with the 

greatest summer average VMT are Milwaukee (1.914 Billion), Waukesha (1.050 Billion), 

and Brown (0.610 Billion) of the twenty counties considered for a nonattainment 

designation 

Table 6.1: Summer Vehicle Miles Traveled (Billions of Miles)

COUNTY 2003 2004 2005 2006 2007 Average 

 BROWN 0.606 0.614 0.619 0.605 0.605 0.610 

 CALUMET 0.096 0.098 0.100 0.099 0.097 0.098 

 DODGE 0.233 0.245 0.242 0.239 0.238 0.239 

 DOOR 0.097 0.098 0.093 0.090 0.090 0.094 

 FOND DU LAC 0.267 0.270 0.278 0.283 0.278 0.275 

 JEFFERSON 0.249 0.255 0.250 0.244 0.243 0.248 

 KENOSHA 0.371 0.376 0.384 0.384 0.381 0.379 

 KEWAUNEE 0.047 0.048 0.047 0.046 0.048 0.047 

 MANITOWOC 0.215 0.218 0.219 0.215 0.214 0.216 

 MARINETTE 0.122 0.124 0.120 0.120 0.120 0.121 

 MILWAUKEE 2.002 2.009 1.847 1.853 1.859 1.914 

 OCONTO 0.131 0.128 0.130 0.129 0.130 0.130 

 OUTAGAMIE 0.391 0.399 0.412 0.418 0.413 0.407 

 OZAUKEE 0.224 0.230 0.254 0.250 0.297 0.251 

 RACINE 0.419 0.423 0.412 0.402 0.396 0.411 

 SHEBOYGAN 0.256 0.259 0.264 0.260 0.261 0.260 

 WALWORTH 0.285 0.284 0.288 0.287 0.294 0.288 

 WASHINGTON 0.328 0.336 0.338 0.353 0.342 0.339 

 WAUKESHA 1.035 1.049 1.048 1.064 1.055 1.050 

 WINNEBAGO 0.453 0.446 0.441 0.438 0.439 0.444 

TOTAL 7.83 7.91 7.79 7.78 7.80 7.82 

Source: Wisconsin Department of Transportation 

(http://www.dot.state.wi.us/travel/counts/vmt.htm) 

Commuting data provides a measure of how far an individual travels between work and 

home. Based on 2000 U.S. Census data from the Wisconsin Department of Workforce 

Development, commuting patterns were analyzed for the three counties that measured 

nonattainment of the 2008 ozone standard (Door, Sheboygan, and Kenosha) (WI DWD 

2008b). Of those that live in Door County, 88.6 % work in Door County; and of those 

that work in Door County, 92.2 % live in Door County. Of those that live in Sheboygan 

County, 87.9 % work in Sheboygan County; and of those that work in Sheboygan 

2008 Ozone Standard Technical Support Document 29
02/27/2009 

County, 86.7 % live in Sheboygan County. Of those that live in Kenosha County, 56.2 % 

work in Kenosha County, 9.1% work in Racine County, and 28.5 % work in Illinois; and 

of those that work in Kenosha County, 76.5 % live in Kenosha County, 11.0% live in 

Racine County, and 6.1 % live in Illinois. Most individuals in these three counties work 

and live in the same county, with a decreased majority in the Illinois border county of 

Kenosha. 

VII. Growth Rates and Patterns 

Wisconsin’s population has grown by 5.8 % from 5.36 million to 5.68 million over the 

past eight years. Several counties experienced strong population growth during this 

period, while Milwaukee County’s population decreased by 0.2 %, or 1,674 inhabitants 

(Table 7.1 and Figure 7.1). Milwaukee County remains Wisconsin’s most populous 

county with approximately 938,500 inhabitants in 2008. 

Many counties witnessed notable population growth. The counties experiencing the 

largest total increase in population include Waukesha, Brown, Outagamie, Washington, 

and Kenosha (Table 7.1). The counties experiencing the largest percentage increase in 

population include Calumet, Washington, Oconto, and Walworth (Table 7.1). 

Table 7.1: Population Growth (2000 to 2008) 

Counties with growth > 10,000 persons or > 10% increase 

COUNTY 

Population Growth 

2000 to 2008 

(persons) 

% Increase 

2000 to 2008 

January 1, 2008 

Population Estimate 

(persons) 

Waukesha 21,930 6.1 % 382,697 

Brown 18,510 8.2 % 245,168 

Outagamie 13,687 8.5 % 174,778 

Washington 12,997 11.1 % 130,493 

Kenosha 12,517 8.4 % 162,094 

Walworth 9,302 10.1 % 101,315 

Calumet 5,661 13.9 % 46,292 

Oconto 3,609 10.1 % 39,261 

Source: Wisconsin Department of Administration – Demographic Services 

(http://www.doa.state.wi.us/docs_view2.asp?docid=2066) 

The Wisconsin Department of Administration – Demographic Services projects 

population growth from 2000 through 2035. Positive growth is forecasted throughout the 

twenty counties considered for a nonattainment designation, except for Milwaukee 

County (Figure 7.2). The counties projected to have the largest total increase in 

population include Waukesha, Brown, Outagamie, Kenosha, and Washington (Table 7.2). 

The counties projected to have the largest percentage increase in population include 

Calumet, Walworth, Washington, Oconto, Kenosha, and Outagamie (Table 7.2). 

2008 Ozone Standard Technical Support Document 30
02/27/2009 

Table 7.2: Projected Population Growth (2000 to 2035) 

Counties with growth > 50,000 persons or > 40% increase 

COUNTY Population 

Growth (persons)

Population 

Growth (%) 

Population in 2035 

(persons)

Waukesha 93,700 26.0 % 454,467 

Brown 90,387 39.9 % 317,045 

Outagamie 67,307 41.8 % 228,398 

Kenosha 63,500 42.5 % 213,077 

Washington 51,663 44.0 % 169,159 

Walworth 40,928 44.5 % 132,941 

Calumet 30,596 75.3 % 71,227 

Oconto 15,385 43.2 % 51,037 

Source: Wisconsin Department of Administration – Demographic Services 

(http://www.doa.state.wi.us/docs_view2.asp?docid=2066) 

Strong population growth will lead to increasing mobile and area source emissions 

throughout the region. 

2008 Ozone Standard Technical Support Document 31
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Figure 7.1: Population Growth by County (2000 to 2008) 

# Persons

2008 Ozone Standard Technical Support Document 32
02/27/2009 

Figure 7.2: Projected Population Growth by County (2008 to 2035) 

# Persons

2008 Ozone Standard Technical Support Document 33
02/27/2009 

VIII. Meteorology / Transport 

Wisconsin is located in the upper Midwest. It experiences primarily a continental climate 

with synoptic scale weather features that are often moderated by the passage of either 

dry, cooler air masses from Canada or warm, humid air that originates from the Gulf 

coast area. 

The topography of Wisconsin is predominantly flat. Consequently, topography has 

relatively little influence on Wisconsin’s weather, especially as it pertains to air pollution 

transport. However, both Lake Michigan and Lake Superior are large bodies of water on 

the eastern and northern borders of Wisconsin whose surface temperatures relative to 

land temperature (spring/summer: cold, fall/winter: warm) often can greatly modify both 

thermal and wind patterns along the shoreline areas of the state. In particular, the 

summer and spring time Lake Michigan lake breeze is a mesoscale meteorological 

feature that is often associated with high levels of tropospheric ozone along the eastern 

Wisconsin coastline. 

On a larger synoptic meteorological scale, when Wisconsin is positioned on the western 

side of high pressure system, this often brings warm, sunny, humid air with limited 

atmospheric mixing. This feature is especially, but not exclusively, evident during the 

warmer months. These meteorological conditions are often very conducive to the 

transport of high levels of air pollution into the state from upwind regions, such as the 

Chicago-Gary area and the Ohio River Valley. 

a) Eastern Wisconsin Temperatures 

Wisconsin has nine climate divisions. Climate divisions are regions with similar 

temperature and precipitation characteristics. The eastern portion of the state makes up 

the East Central and Southeast Climate Divisions (Figure 8.1). Ozone monitors are 

located in all of the counties in these two climate divisions, except Calumet and 

Winnebago. 

The average temperature from May through September, based on data from 1971 through 

2000, for these two climate divisions is 64 o F. Over the past five years, the average May 

through September temperature has ranged from 62 o F to 66 o F (Figure 8.2). Above 

normal temperatures can lead to higher than normal ozone concentrations. The average 

fourth-highest daily maximum 8-hour average ozone concentrations for the ozone 

monitors located in the East Central and Southeast Climate Divisions are also shown in 

Figure 8.2 (EPA, 2008c). The average May through September temperatures are well 

correlated with the average 8-hour ozone concentrations. For example, the average May 

through September temperature during 2005 was 2.0 o F above normal and the average 

fourth-highest daily maximum 8-hour average ozone concentration reached a five year 

high. Temperature data was obtained from the Western Regional Climate Center 

(WRCC, 2008). 

2008 Ozone Standard Technical Support Document 34
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b) Transport Patterns 

Atmospheric back trajectories can be used to identify upwind regions contributing to high 

air pollution concentrations. A brief analysis of transport patterns of both gaseous 

precursors to ozone and ozone was conducted using derived back trajectories. Wind 

roses were also developed for the counties that exceeded the 2008 ozone standard from 

onsite wind measurements. 

The HYSPLIT (HYbrid Single-Particle Lagrangian Integrated Trajectory) trajectory 

model (Draxler and Hess, 1998) was applied to gridded hourly meteorological data on 

those days from 2006 through 2008 when an ozone monitor in Kenosha, Sheboygan, or 

Door County measured a 1-hour ozone concentration greater than or equal to 75 parts per 

billion (ppb). Near surface (10 meters above ground level [agl]) 6-hour back trajectories 

were determined from the three monitoring locations in Door, Kenosha, and Sheboygan 

Counties. The ending time for the trajectories was the hour when the highest 1-hour 

ozone concentration was measured. 

The following table (8.1) shows the percentage of times a back trajectory passed through 

a particular county. Only Sheboygan County has more than 20 % of trajectories that pass 

through any other Wisconsin counties. 

Table 8.1: Hysplit Back Trajectories for Days when 1-Hour Ozone Conc. ≥ 75 ppb 

Door County Sheboygan County Kenosha County 

Number of Days the 1-Hour 

Ozone Concentration ≥ 75 ppb 

from 2006 – 2008 = 26 Days 

Number of Days the 1-Hour 

Ozone Concentration ≥ 75 ppb 

from 2006 – 2008 = 29 Days 

Number of Days the 1-Hour 

Ozone Concentration ≥ 75 ppb 

from 2006 – 2008 = 19 Days 

Percentage of Times a 6-Hour 

Back Trajectory Passed 

Through a Particular County 

Percentage of Times a 6-Hour 

Back Trajectory Passed 

Through a Particular County

Percentage of Times a 6-Hour 

Back Trajectory Passed 

Through a Particular County

Brown 11.5 % Ozaukee 41.4 % Walworth 15.8 % 

Kewaunee 7.7 % Waukesha 31.0 % Racine 5.3 % 

Manitowoc 7.7 % Milwaukee 31.0 % Rock 5.3 % 

Racine 31.0 % 

Chicago N.A. 69.2% Washington 24.1 % Chicago N.A. 57.9% 

Kenosha 20.7 % 

Dodge 17.2 % 

Fond Du Lac 13.8 % 

Walworth 6.9 % 

Calumet 6.9 % 

Winnebago 6.9 % 

Jefferson 6.9 % 

Wind roses for ozone monitor locations in Kenosha, Sheboygan, and Door County were 

derived for those hours from 2006 through 2008 when the 1-hour ozone concentration 

was greater than or equal to 75 ppb (Figures 8.4 – 8.6). Wind roses show the percentage 

of time the wind was blowing from a particular direction. The primary wind direction for 

the Door County monitor was from the south-southwest towards Kewaunee, Brown, and 

Manitowoc Counties. The primary wind direction for the Sheboygan County monitor 

was from the south-southwest towards Ozaukee, Washington, Waukesha, Milwaukee, 

2008 Ozone Standard Technical Support Document 35
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Racine, and Walworth Counties. The primary wind direction for the Kenosha County 

monitor was from the south-southeast towards Chicago. 

c) Ozone Source Apportionment 

Air quality models can be useful tools for determining which areas contribute to high 

ozone concentrations. One such model is the Comprehensive Air Quality Model with 

Extensions (CAMx). CAMx is a multi-scale, three dimensional, state of the science 

photochemical model that contains a variety tools, including the ozone source 

apportionment tool (OSAT). OSAT identifies the contribution to modeled ozone 

concentration at a particular location from regional locations and various emissions 

sectors. 

The Lake Michigan Air Directors Consortium (LADCO) provided ozone source 

apportionment results for Door, Sheboygan, and Kenosha Counties. The modeled ozone 

concentrations were determined assuming 2009 air pollution controls. The 1-hour 

average ozone concentrations were calculated as 86 ppb, 88 ppb, and 88 ppb for Door, 

Sheboygan, and Kenosha Counties, respectively, for days when the 1-hour ozone 

concentration was at least 75 ppb. 

Contribution to the 1-hour average ozone concentrations are determined from seventeen 

geographic regions and six emission sector categories. The geographic regions are listed 

in Table 8.2. The emission sector categories include electrical generating units and nonelectrical generating units, which are combined for a point sector estimate, on-road, offroad, area, and biogenic. A portion of the 1-hour average ozone concentration can not be 

attributed to any geographic region or emission sector category, rather it is attributed to 

the boundary contribution from the model. The boundary contribution represents ozone 

entering the model through the lateral and top boundaries, which may represent a 

hemispheric or global background contribution. Contributions to the 1-hour average 

ozone concentrations are based on the “attributable” portion of the average, which 

excludes the background contribution. Figures 8.7 through 8.9 provide a summary of the 

OSAT results. 

The Chicago nonattainment area contributes the largest portion of the average 1-hour 

ozone concentration to Door County, 28.9 %. The Milwaukee nonattainment area 

contributes 8.9 % of the average 1-hour ozone concentration to Door County. The onroad emission source sector is the largest contributor to the average 1-hour ozone 

concentration to Door County, 27.7 %. 

The Chicago nonattainment area contributes the largest portion of the average 1-hour 

ozone concentration to Sheboygan County, 32.0 %. The Milwaukee nonattainment area 

contributes 13.5 % of the average 1-hour ozone concentration to Sheboygan County. The 

on-road emission source sector is the largest contributor to the average 1-hour ozone 

concentration to Sheboygan County, 29.0 %. 

2008 Ozone Standard Technical Support Document 36
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The Chicago nonattainment area contributes the largest portion of the average 1-hour 

ozone concentration to Kenosha County, 39.6 %. The Milwaukee nonattainment area 

contributes 4.1 % of the average 1-hour ozone concentration to Kenosha County. The 

off-road emission source sector is the largest contributor to the average 1-hour ozone 

concentration to Kenosha County, 29.0 %. 

Table 8.2: OSAT Source Regions 

Chicago Nonattainment Counties MANE-VU States 2

Canada Michigan (Excluding Detroit Nonattainment Counties)

CENRAP and WRAP States 2

(Excluding Iowa, Minnesota, and Missouri) Milwaukee Nonattainment Counties 

Cleveland Nonattainment Counties Missouri 

Detroit Nonattainment Counties Ohio (Excluding Cleveland Nonattainment Counties)

Illinois (Excluding Chicago Nonattainment Counties) VISTAS States (Excluding Kentucky and West Virginia) 2

Indiana (Excluding Chicago Nonattainment Counties) West Virginia 

Iowa and Minnesota Wisconsin (Excluding Milwaukee Nonattainment Counties)

Kentucky 

d) Chicago Nonattainment Area NOx and VOC Emissions 

As shown in the OSAT results, the Chicago nonattainment counties contribute a 

significant portion of the attributable ozone concentrations to Door, Sheboygan, and 

Kenosha Counties. Figures 8.10 and 8.11 show the NOx and VOC emissions from the 

Chicago nonattainment counties compared to the twenty counties in Wisconsin 

considered for a nonattainment designation. Based on 2005 emissions data estimates 

provided by LADCO, the Chicago nonattainment counties contribute at least 65% of the 

regional NOx and VOC emissions considering the point, area, on-road, and non-road 

emission source sectors (2008). 

 

2 CENRAP (Central Regional Air Planning Association): Arkansas, Iowa, Kansas, Louisiana, Minnesota, Missouri, 

Nebraska, Oklahoma, and Texas.

WRAP (Western Regional Air Partnership): Alaska, Arizona, California, Colorado, Hawaii, Idaho, Montana, Nevada, 

New Mexico, North Dakota, Oregon, South Dakota, Utah, Washington, and Wyoming.

MANE-VU (Mid-Atlantic / Northeast Visibility Union): Delaware, Maine, Maryland, Massachusetts, New Hampshire, 

New Jersey, New York, Pennsylvania, Rhode Island, and Vermont.

VISTAS (Visibility Improvement – State and Tribal Association of the Southeast): Alabama, Florida, Georgia, 

Kentucky, Mississippi, North Carolina, South Carolina, Tennessee, Virginia, and West Virginia.

2008 Ozone Standard Technical Support Document 37
02/27/2009 

2008 Ozone Standard Technical Support Document 38

Figure 8.1: Eastern Wisconsin Climate Divisions 

Counties shaded in blue represent counties with ozone monitors. 

Climate Division #6 

East Central 

Climate Division #9 

Southeast 
08 Ozone Standard Technical Support Document 

Figure 8.2: Average May – September Temperature and Average Fourth- Highest 8-Hour Average Ozo

 for the East Central and Southeast Climate Divisions. 

02/27/2009 20

60.561.061.562.062.563.063.564.064.565.065.566.066.5

2004 2005 2006 2007 2008

Year

Average Temperature (May-Sept) (Deg F)

Average Temperature 64.0 oF

Bar Graph: Temperatures, Line Graph: Ozone Concentrations 
02/27/2009 

Figure 8.3: Door County Wind Rose when the 1-Hour Ozone Concentration ≥ 75 ppb 

2008 Ozone Standard Technical Support Document 40
02/27/2009 

Figure 8.4: Sheboygan County Wind Rose when the 1-Hour Ozone Concentration ≥ 75 ppb 

2008 Ozone Standard Technical Support Document 41
02/27/2009 

2008 Ozone Standard Technical Support Document 42

Figure 8.5: Kenosha County Wind Rose when the 1-Hour Ozone Concentration ≥ 75 ppb 
02/27/2009 

Figure 8.6: OSAT Results for Door County (Site 5502900041) 

Regional Contributions for Attributable Ozone (Days when 1-Hour Ozone Concentration ≥ 75 p

The average 1-hour ozone concentration on days when the 1-hour ozone concentration exceeds 75 ppb is 86 ppb, assuming 2009 

68 ppb of the 86 ppb ozone concentration is attributable to regional sources and 18 ppb is from the modeled boundary 

2008 Ozone Standard Technical Support Document 
02/27/2009 

Figure 8.7: OSAT Results for Sheboygan County (Site 5511700061) 

Regional Contributions for Attributable Ozone (Days when 1-Hour Ozone Concentration ≥ 75 p

The average 1-hour ozone concentration on days when the 1-hour ozone concentration exceeds 75 ppb is 88 ppb, assuming 2009 

69 ppb of the 88 ppb ozone concentration is attributable to regional sources and 19 ppb is from the modeled boundary 

2008 Ozone Standard Technical Support Document 
02/27/2009 

Figure 8.8: OSAT Results for Kenosha County (Site 5505900021 / 5505900191) 

Regional Contributions for Attributable Ozone (Days when 1-Hour Ozone Concentration ≥ 75 p

The average 1-hour ozone concentration on days when the 1-hour ozone concentration exceeds 75 ppb is 88 ppb, assuming 2009 

68 ppb of the 88 ppb ozone concentration is attributable to regional sources and 20 ppb is from the modeled boundary 

2008 Ozone Standard Technical Support Document 
02/27/2009 

Figure 8.9: 2005 NOx Emissions for the Twenty Counties Considered for a Nonattainment Designation 

Nonattainment Counties 

Source: LADCO – Round 5 Emission Inventory Summaries 

(http://www.ladco.org/tech/emis/current/index.php)

2008 Ozone Standard Technical Support Document 
08 Ozone Standard Technical Support Document 

Figure 8.10: 2005 VOC Emissions for the Twenty Counties Considered for a Nonattainment Designatio

Nonattainment Counties

Source: LADCO – Round 5 Emission Inventory Summaries 

(http://www.ladco.org/tech/emis/current/index.php)

02/27/2009 20
02/27/2009 

IX. Geography/ Topography 

As shown in Figure 9.1, the topography of eastern Wisconsin is predominately flat. 

There is no evidence to suggest that the variations in topography influence measured 

ozone concentrations or has an effect on ozone transport in the region. 

Transport patterns, and subsequently ozone concentrations, can be significantly 

influenced by Lake Michigan. Often during the day the land surface is relatively warmer 

than the water surface and a pressure gradient is created causing winds to blow from the 

water towards the land. Often during the night the opposite pattern exists; the land 

surface is relatively cooler than the water surface causing winds to blow from the land 

towards the water. This mesoscale meteorological phenomenon is referred to as a lake 

breeze circulation. 

Dr. G. Jay Lennartson and Dr. Mark Schwartz studied the relationship between high 

ozone concentrations and the lake breeze circulation in eastern Wisconsin. Their results 

are summarized in a paper published in the International Journal of Climatology titled, 

“The lake breeze-ground-level ozone connection in eastern Wisconsin: a climatological 

perspective” (Lennartson, 2002). Their results showed the following: 

(1) a decrease in both magnitude and frequency of exceedances of the 1-hour 

ozone standard in eastern Wisconsin with increasing distance from the lakeshore; 

(2) a positive correlation between average onset time of the initial exceedancehour and a site's distance from Lake Michigan; 

(3) a very high percentage of initial exceedance-hours occurring in association 

with southeasterly surface air flow; and 

(4) ozone concentration exceedances occurring in association with lake breezes 

82.1% of the time at near-shore sites. 

Although the lake breeze circulation can play an important role during high ozone events, 

the purpose of this document is to determine which counties are in nonattainment, or 

contributing to the nonattainment, of the 2008 ozone standard. No counties are 

implicated for nonattainment based on the effects of the lake breeze circulation. 

2008 Ozone Standard Technical Support Document 48
02/27/2009 

Figure 9.1: Topography of the Twenty Counties Considered for Nonattainment 

Elevation

(feet) 

Source: University of Wisconsin – Green Bay 

(http://www.uwgb.edu/dutchs/GEOLWISC/TopoWiscLgCty.htm) 

2008 Ozone Standard Technical Support Document 49
02/27/2009 

X. Jurisdictional Boundaries 

The ozone boundary guidance from the EPA recommends that the CBSA or CSA serve 

as the starting point or presumptive boundary for considering what should be the 

geographic boundaries of an ozone nonattainment area. When an ozone monitor is 

located in a county not part of a CBSA or CSA, EPA recommends the county boundary 

serve as the presumptive nonattainment area. None of the three counties that exceeded 

the 2008 ozone standard, Door, Sheboygan, or Kenosha, are part of a multiple Wisconsin 

county CSA. Kenosha County is part of the Chicago-Naperville-Michigan City CSA; 

however, it is also part of the Southeastern Wisconsin Metropolitan Planning Area. This 

planning area includes the counties of Kenosha, Milwaukee, Ozaukee, Racine, Walworth, 

Washington, and Waukesha Counties. It is important to note that during previous 

nonattainment designation determinations, the WDNR and the EPA have included 

Kenosha County with the Milwaukee CSA (i.e., the Milwaukee-Racine 8-hour Ozone 

Nonattainment Area). 

The following figure (10.1) shows the Wisconsin counties that are currently classified as 

nonattainment for the 1997 ozone standard (80 ppb). 

Figure 10.1: Wisconsin Ozone Nonattainment Areas 

Note: 1997 ozone nonattainment counties are shaded in grey. 

2008 Ozone Standard Technical Support Document 50
02/27/2009 

XI. Level of Control of Emission Sources 

The Wisconsin Department of Natural Resources (WDNR) has adopted a number of 

regulations to permanently control VOC emissions in eastern Wisconsin. Limited 

regulations were adopted by WDNR prior to 2007 to control NOx emissions. 

Throughout the twenty counties considered for a nonattainment designation, some of the 

regulations are specific to the Milwaukee-Racine ozone nonattainment area, which 

includes Kenosha, Racine, Milwaukee, Waukesha, Washington, and Ozaukee Counties. 

Other regulations include Sheboygan, Manitowoc, and Kewaunee Counties. 

Wisconsin has adopted and implemented, as part of its State Implementation Plan (SIP), 

rules requiring all existing stationary sources of VOCs at the 25 ton level in the 

Milwaukee-Racine Area to meet reasonably available control technology (RACT) 

requirements. These RACT requirements are contained within chs. NR 419 to 424, Wis. 

Adm. Code, and apply to sources in categories covered by all applicable control 

technology guidelines (CTG) and other non-CTG source categories of VOCs. 

Under the 1-hour federal ozone standard, Kenosha County, along with other counties 

classified as part the Milwaukee-Racine Area, was a severe nonattainment area; 

Sheboygan County was a moderate nonattainment area; and Door County was a rural 

transport (marginal) nonattainment area. Inspection and maintenance, and VOC RACT 

were implemented in Kenosha and Sheboygan County, but not in Door County. 

The following is a list of NOx controls implemented by the State of Wisconsin: 

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

address control of stationary source NOx emissions and is structured to meet Rate 

of Progress (ROP) emission reduction requirements through 2007, the 1-hour 

ozone standard attainment deadline for the Lake Michigan region. The 

requirements and performance standards for new or modified sources are 

presented in NR 428.04. The requirements are applicable in the counties of 

Kenosha, Milwaukee, Ozaukee, Racine, Washington, and Waukesha. The 

requirements and performance standards for existing sources are presented in NR 

428.05. The requirements are applicable in the counties of Kenosha, Manitowoc, 

Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha. 

RACT requirements for NOx emissions are specified in NR 428, Subchapter IV. 

The purpose of the RACT requirements is to limit NOx emissions from major 

sources. The requirements are applicable for the counties of Kenosha, 

Milwaukee, Ozaukee, Racine, Sheboygan, Washington, and Waukesha. These 

requirements are estimated to reduce NOx emissions in the region by 

approximately 15,000 tons/year (WDNR, 2007). 

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

February 10, 2000, US EPA finalized a federal rule to significantly reduce 

emissions from cars and light trucks, including sport utility vehicles (SUVs). 

2008 Ozone Standard Technical Support Document 51
02/27/2009 

Under this rule, automakers are required to sell lower-emitting cars, and refineries 

are required to make cleaner, lower sulfur gasoline. This rule applies nationwide. 

The federal rules are being phased in between 2004 and 2009. Though not fully 

implemented, Wisconsin began benefiting from the reductions in 2004. 

• Side Benefits of Control of Hazardous Pollutants (Wis. Adm. Code NR 445): 

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

hazardous contaminants. Some sources may be exempt from these requirements 

based on a risk-based threshold. These controls are expected to result in the 

reduction of NOx emissions from the nonroad stationary reciprocating diesel 

engines. The reduction is the result of NR 445 requiring affected engines to fire 

low sulfur on-road fuel beginning in July 2006. NR 445 also includes an 

incentive to replace old engines with engines that meet Tier 2 or later nonroad 

standards. This will result in reductions of NOx in the Milwaukee-Racine Area. 

These measures began benefiting the Area only during the latter half of 2006. 

• Wisconsin’s Mercury Rule Multi-Pollutant Option (Wis. Adm. Code NR 446): 

Large coal-fired power plants (≥ 150 Megawatts) have the option of choosing a 

multi-pollutant approach for Wisconsin’s mercury rule. This option requires 

those affected power plants to achieve NOx and sulfur dioxide (SO2) reductions 

beyond those currently required by federal and state regulations. 

• EPA’s Clean Air Interstate Rule (CAIR): 

This rule will permanently cap emissions of sulfur dioxide (SO2) and NOx in the 

eastern United States, including Wisconsin. CAIR is implemented in two phases. 

The Phase I NOx cap begins in 2009 and the Phase II NOx cap begins in 2015. 

By 2015, EPA estimates that CAIR will help Wisconsin sources reduce emissions 

of NOx by 50,000 tons, or 61%. 

The Milwaukee-Racine Area, including Kenosha County, has implemented local controls 

to decrease the traffic congestion in the city. These local controls will reduce idling times 

of motor vehicles and thus reduce NOx emissions. Implemented measures include:

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

program offers discounted transit passes through large employers, providing a 

shared cost program between employer and employee. The UPASS program 

involves giving students/staff at area universities 'free' transit passes paid through 

student fees. 

• Rideshare: A Wisconsin Department of Transportation interactive web-based ride 

matching service. 

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

cameras is used to provide traveler information to the media and motorists. In 

addition, the live updates are communicated to motorists using electronic 

messaging signs. 

2008 Ozone Standard Technical Support Document 52
02/27/2009 

• Education/Marketing Promotion: Wisconsin Partners for Clean Air voluntary 

coalition promoting emission reductions along with an Air Quality Watch & 

Advisory Program alerting the public to air quality conditions and promoting 

transportation alternatives. 

• Traffic Incident Management: A freeway operational detection and control system 

with limited use of service patrol vehicles to assist road clearance and motorists. 

(limited to Kenosha and Racine Counties) 

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

entrance ramps to control the rate of entry and encourage ridesharing and transit 

use. 

• Guaranteed Ride Home (State and Milwaukee County Transit System (MCTS)): 

Provides transit and vanpool participants a taxi ride in the case of an employee or 

family member's illness or medical emergency. WisDot also offers 

reimbursement to employers who offer a guaranteed ride when an unforeseen 

event occurs. 

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

transportation for commuting to Madison from the Milwaukee area. 

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

for meeting transit and carpools. 

Areas without Ozone Precursor Controls 

All counties outside of the ozone nonattainment area throughout the twenty counties 

considered for a nonattainment designation have no major point source control program 

for ozone precursor pollutants, which also contribute to fine particle levels in measured 

nonattainment counties. These areas also do not have inspection and maintenance, 

reformulated gasoline or stage 2 vapor recovery. 

2008 Ozone Standard Technical Support Document 53
02/27/2009 

XII. Analysis of Potential Nonattainment Areas 

EPA provided guidance on determining ozone designation boundaries in a December 4, 

2008 memorandum from Robert J. Meyers, “Area Designations for the 2008 Revised 

Ozone National Ambient Air Quality Standards.” This document provided the following 

nine factors to consider when making nonattainment area boundary recommendations: 

1. Air quality data 

2. Emissions data (location of sources and contribution to ozone concentrations) 

3. Population density and degree of urbanization (including commercial 

development) 

4. Traffic and commuting patterns 

5. Growth rates and patterns 

6. Meteorology (weather/transport patterns) 

7. Geography/topography (mountain ranges or other air basin boundaries) 

8. Jurisdictional boundaries (e.g., counties, air districts, existing nonattainment area, 

Reservations, metropolitan planning organizations (MPOs)) 

9. Level of control of emission sources 

Tables 12.1, 12.3, and 12.5 summarize the implicating factors for each of the three 

counties that had ozone design values that exceeded the 2008 ozone standard. 

Nonattainment options are summarized in Tables 12.2, 12.4, and 12.6 and in Figures 1.2, 

1.3, and 1.4. Ozone monitoring in the remainder of the state indicates that all other 

counties should be designated as attaining the 2008 ozone standard. 

2008 Ozone Standard Technical Support Document 54
02/27/2009 

Door County Area

Table 12.1: Analysis of Factors for the Door County Area 

(The Counties of Brown, Calumet, Door, Kewaunee, Manitowoc, Marinette, Oconto, and Outagamie) 

Factor Door County Area Implications for Nonattainment 

Air Quality In 

Adjacent Areas

Nonattainment measured in Door 

(DV – 80 ppb)

Attainment measured in other 

nearby counties, including: 

• Brown 

 (DV – 70 ppb) 

• Kewaunee 

 (DV – 75 ppb) 

• Manitowoc 

 (DV – 75 ppb) 

• Outagamie 

 (DV – 68 ppb) 

No ozone monitors currently in 

Calumet, Marinette, or Oconto. 

Door County is implicated 

because nonattainment levels are 

measured in this county. 

Kewaunee and Manitowoc 

Counties are implicated because 

near nonattainment levels are 

measured in these counties.

Emissions In Adjacent Areas 

(Based on 2005 WI Emissions 

Inventory) 

VOC (tpsd) 

• Brown (36.1) 

• Outagamie (22.0)

• Manitowoc (13.5)

• Marinette (13.3)

• Door (12.4)

• Oconto (9.9)

• Calumet (6.5)

• Kewaunee (4.2)

NOX (tpsd) 

• Brown (72.9)

• Outagamie (25.3)

• Manitowoc (16.8)

• Marinette (11.7)

• Door (8.1)

• Oconto (5.1)

• Calumet (4.8)

• Kewaunee (3.1)

Brown and Outagamie Counties 

are substantial source regions for 

precursor pollutants. However, 

Outagamie County is located 

southwest of Door County where 

ozone or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.4, & 8.7). 

Population Density and 

Degree of Urbanization 

2008 Population Density 

(persons/mi2

) / Percent Urban 

Brown 463.74 / 83.9% 

 Outagamie 272.95 / 74.1%

 Calumet 144.73 / 60.3% 

 Manitowoc 143.41 / 60.9% 

 Door 62.78 / 31.5% 

Population density and degree of 

urbanization implicate Brown 

County. 

2008 Ozone Standard Technical Support Document 55
02/27/2009 

Population Density and Degree 

of Urbanization Continued 

 Kewaunee 62.33 / 17.6%

 Oconto 39.34 / 19.9% 

 Marinette 31.98 / 40.2% 

No counties in the Door County 

area saw an increase in service 

providing jobs from October, 

2007 to October, 2008 of more 

than 5.0 %. 

Traffic Patterns 

Summer Total Vehicle Miles 

Traveled (2007) 

Brown (605 Million) 

 Outagamie (413 Million)

 Manitowoc (214 Million) 

 Oconto (130 Million) 

 Marinette (120 Million)

 Calumet (97 Million)

 Door (90 Million) 

 Kewaunee (48 Million)

Summer vehicle miles traveled 

implicate Brown County. 

Commuting Patterns 

Percentage of people who live 

in Door County and work in: 

 Door 88.6%

 Brown 5.3% 

 Kewaunee 3.2% 

 All Other Wisconsin 

 Counties < 0.5% 

Percentage of people who work 

in Door County and live in: 

 Door 92.2%

 Kewaunee 4.2% 

 Brown 2.2%

 All Other Wisconsin 

 Counties < 0.5%

Commuting patterns implicate 

only Door County. 

Population Growth Rates 

and Patterns 

Total population changes from 

2000 U.S. Census to 2008 WI 

DSC final estimate 

 Brown (18,510, +8.2%) 

 Outagamie (13,687, +8.5%)

 Calumet (5,661, +13.9%) 

 Oconto (3,609, +10.1%) 

 Door (2,342, +8.4%) 

 Manitowoc (1,937, +2.3%)

 Marinette (1,439, +3.3%) 

 Kewaunee (1,171, +5.8%)

The greatest population growth 

and projected population growth 

implicate Calumet, Oconto, 

Brown and Outagamie Counties. 

However, Oconto County is 

located west-southwest and 

Outagamie is located southwest 

of Door County where ozone or 

its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.4, & 8.7). 

2008 Ozone Standard Technical Support Document 56
02/27/2009 

Population Growth Rates 

and Patterns Continued 

Projected population changes 

from 2000 U.S. Census to 2035 

 Brown (90,387, +39.9%) 

 Outagamie (67,307, +41.8%)

 Calumet (30,596, +75.3%)

 Oconto (15,385, +43.2%)

 Manitowoc (9,412, +11.4%) 

 Kewaunee (5,446, +27.0%) 

 Marinette (3,725, +8.6%) 

 Door (3,558, +12.7%) 

Meteorology (weather & 

transport patterns) 

On days when the measured 1-

hour ozone concentration 

exceeded 75 ppb, the winds were 

predominately from the southsouthwest direction (62.9% of the 

total hours). The next most 

predominate wind direction was 

from the west (14.9% of the total 

hours), followed by winds from 

the south (7.4% of the total 

hours) and west-northwest (5.1% 

of the total hours). 

The NOAA Hysplit trajectory 

model reveals that on days when 

the 1-hour ozone concentration 

exceeded 75ppb, the polluted air 

masses did not pass through any 

of the surrounding counties more 

than 11.5% of the time (Brown 

County) six hours before the 

daily maximum ozone 

concentration was measured. 

69.2% of the air masses were 

transported from the southward 

direction (i.e., towards the 

Chicago nonattainment area). 

The OSAT results for days with a 

modeled 1-hour ozone 

concentration of at least 75 ppb in 

Door County, which are based on 

2009 air pollution controls, show 

that the Milwaukee 

nonattainment area contributes 

8.9% of the average ozone 

concentration. The Chicago 

nonattainment area contributes 

28.9% of the average ozone 

concentration. Wisconsin areas, 

excluding the Milwaukee 

nonattainment area, only 

contribute 5.5% of the average 

ozone concentration. 

The measured wind direction 

patterns implicate Brown, 

Calumet, Kewaunee, and 

Manitowoc Counties. 

The NOAA Hysplit model does 

not implicate any Wisconsin 

counties. 

The OSAT results don’t seriously 

implicate any Wisconsin 

Counties.

2008 Ozone Standard Technical Support Document 57
02/27/2009 

Geography / Topography 

Topography is predominantly flat 

and has little influence on 

weather, especially related to 

transport. 

Lake breezes are typically 

associated with high ozone 

concentrations. 

No implications for 

nonattainment. 

Jurisdictional Boundaries Door County is not part of a CSA 

or Micropolitan Statistical Area. 

No implications for 

nonattainment. 

Level of Control of Emission 

Sources 

Some VOC RACT rules have 

been implemented in Kewaunee 

and Manitowoc Counties due to 

ground level ozone 

nonattainment. 

Federal Tier 2 Vehicle Emission 

Controls, Nonroad engine 

standards, NR 445 side benefits 

and some local controls apply in 

all counties. 

Most of the stationary source 

control programs do not apply to 

counties surrounding Door 

County. 

All counties are implicated due to 

limited emission controls, except 

for Kewaunee and Manitowoc 

which are affected by groundlevel ozone regulations. 

However, Marinette, Outagamie, 

and Oconto Counties are located 

west and west-southwest of Door 

County where ozone or its 

precursors are rarely transported 

from during high ozone 

concentration days (See Figures 

8.3, 8.4, & 8.7). 

Air quality, emissions, population, traffic, growth, and meteorological data indicate that 

counties bordering or near to Door County contribute to nonattainment there. Based on 

the data summary above, the following table (12.2) outlines three possible nonattainment 

designation options for the Door County area. 

Table 12.2: Options Summary for the Door County Area 

Designation Option 1 Option 2 Option 3 

Nonattainment 

Counties 

Door 

Brown 

Kewaunee 

Manitowoc 

Door None 

Option 1 includes all counties that are implicated by at least three of the nine factors 

analyzed, except Calumet, Kewaunee, and Manitowoc Counties. The primary factors 

that implicate the four counties are air quality measurements, air pollution emissions, and 

meteorology-related transport patterns. Kewaunee and Manitowoc Counties, although 

only implicated by two factors, are included because ozone monitoring data shows the 

fourth-highest 8-hour average daily ozone concentration exceeded 75 ppb for two of the 

three years. Calumet County, although implicated by three factors, is not included 

2008 Ozone Standard Technical Support Document 58
02/27/2009 

because one implicating factor was transport patterns, not emissions, and another 

implicating factor was the lack of control on emission sources. There is not much 

emission control in Calumet County because of a smaller contribution to regional 

emissions. 

Option 2 includes only Door County because it is the only county that measured 

nonattainment of the 2008 ozone standard. Guidance provided by the EPA states that 

that a CBSA or CSA should serve as the starting point or presumptive boundary for 

considering what should be the geographic boundaries of an ozone nonattainment area. 

Door County is not part of a multi-county CBSA or CSA. 

Option 3 classifies all areas as in attainment of the 2008 ozone standard due to the 

downward trend in monitored ozone design values since 1999, regional decreases in 

VOC and NOx emissions, and continued enforcement of state and federal air pollution 

rules. 

2008 Ozone Standard Technical Support Document 59
02/27/2009 

Sheboygan County Area

Table 12.3: Analysis of Factors for the Sheboygan County Area 

(The Counties of Calumet, Dodge, Fond Du Lac, Jefferson, Kenosha, Manitowoc, Milwaukee, Ozaukee, 

Racine, Sheboygan, Walworth, Washington, Waukesha, and Winnebago)

Factor Sheboygan County Area Implications for Nonattainment 

Air Quality In 

Adjacent Areas

Nonattainment measured in 

Sheboygan (DV – 82 ppb) and 

Kenosha (DV – 78 ppb) Counties 

Attainment measured in other 

nearby counties, including: 

• Dodge 

 (DV – 68 ppb) 

• Fond Du Lac 

 (DV – 67 ppb) 

• Jefferson 

 (DV – 70 ppb) 

• Milwaukee 

 (DV – 63, 68, 72, 75 ppb) 

• Manitowoc 

 (DV – 75 ppb) 

• Ozaukee 

 (DV – 72 & 74 ppb) 

• Racine 

 (DV – 71 ppb) 

• Walworth 

 (DV – 70 ppb) 

• Washington 

 (DV – 65 ppb) 

• Waukesha 

 (DV – 66 ppb) 

No ozone monitors currently in 

Calumet or Winnebago County. 

Sheboygan and Kenosha 

Counties are implicated because 

nonattainment levels are 

measured in these counties. 

Milwaukee, Manitowoc, and 

Ozaukee Counties are implicated 

because near nonattainment 

levels are measured in these 

counties. However, Manitowoc 

County is located north of 

Sheboygan County where ozone 

or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.5, & 8.8). 

Emissions In Adjacent Areas 

(Based on 2005 WI Emissions 

Inventory) 

VOC (tpsd)

• Milwaukee (95.5) 

• Waukesha (53.9) 

• Racine (34.1) 

• Winnebago (33.7) 

• Washington (24.4) 

• Sheboygan (20.7) 

• Walworth (18.1)

• Jefferson (17.5) 

• Fond Du Lac (17.1) 

• Dodge (16.5) 

• Kenosha (15.8) 

• Ozaukee (14.0) 

• Manitowoc (13.5) 

• Calumet (6.5)

Milwaukee, Kenosha, 

Sheboygan, Racine, Winnebago, 

and Waukesha Counties are 

substantial source regions for 

precursor pollutants. However, 

Winnebago County is located 

west-northwest of Sheboygan 

County where ozone or its 

precursors are rarely transported 

from during high ozone 

concentration days (See Figures 

8.3, 8.5, & 8.8). 

2008 Ozone Standard Technical Support Document 60
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Emissions In Adjacent Areas 

Continued (Based on 2005 WI 

Emissions Inventory) 

NOX (tpsd) 

• Milwaukee (91.3)

• Kenosha (47.7) 

• Waukesha (39.7)

• Sheboygan (29.6)

• Winnebago (20.5) 

• Manitowoc (16.8) 

• Jefferson (15.3)

• Racine (14.9)

• Washington (13.8)

• Fond Du Lac (12.8)

• Ozaukee (12.7)

• Walworth (12.2)

• Dodge (10.8)

• Calumet (4.8)

Population Density and 

Degree of Urbanization 

2008 Population Density 

(persons/mi2

) / Percent Urban 

 Milwaukee 3,885.12 / 99.7%

 Waukesha 688.82 / 87.8%

 Kenosha 594.12 / 88.6%

 Racine 589.38 / 87.0%

 Winnebago 377.03 / 84.2%

 Ozaukee 375.12 / 74.6%

 Washington 302.89 / 65.2%

 Sheboygan 228.71 / 70.8%

 Walworth 182.45 / 64.0%

 Jefferson 145.46 / 57.8%

 Calumet 144.73 / 60.3% 

 Manitowoc 143.41 / 60.9%

 Fond Du Lac 140.74 / 62.1%

 Dodge 101.79 / 47.8% 

Dodge and Kenosha Counties are 

the only counties in the 

Sheboygan County area that saw 

an increase in service providing 

jobs from October, 2007 to 

October, 2008 of more than 5.0% 

(7.2 % and 10.2 %, respectively). 

Population density and degree of 

urbanization implicate 

Milwaukee, Waukesha, Kenosha, 

Racine, Winnebago, and Dodge 

Counties. However, Winnebago 

County is located west-northwest 

of Sheboygan County and Dodge 

County is located west-southwest 

of Sheboygan County where 

ozone or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.5, & 8.8). 

Traffic Patterns 

Summer Total Vehicle Miles 

Traveled (2007) 

 Milwaukee (1.86 Billion) 

 Waukesha (1.06 Billion)

 Winnebago (439 Million) 

 Kenosha (381 Million)

 Racine (396 Million) 

 Washington (342 Million)

 Ozaukee (297 Million)

Summer vehicle miles traveled 

clearly implicate Milwaukee and 

Waukesha Counties. 

2008 Ozone Standard Technical Support Document 61
02/27/2009 

Traffic Patterns Continued 

 Walworth (294 Million)

 Fond Du Lac (278 Million)

 Sheboygan (261 Million)

 Jefferson (243 Million) 

 Dodge (238 Million)

 Manitowoc (214 Million) 

 Calumet (97 Million)

Commuting Patterns 

Percentage of people who live 

in Sheboygan County and work 

in: 

 Sheboygan 87.9%

 Ozaukee 3.3%

 Manitowoc 2.0%

 Milwaukee 2.0%

 All Other Wisconsin 

 Counties < 2.0%

Percentage of people who work 

in Sheboygan County and live 

in: 

 Sheboygan 86.7%

 Manitowoc 6.2%

 All Other Wisconsin 

 Counties < 2.0% 

Commuting patterns implicate 

only Sheboygan County. 

Population Growth Rates 

and Patterns 

Total population changes from 

2000 U.S. Census to 2008 WI 

DSC final estimate 

 Waukesha (21,930, +6.1%)

 Washington (12,997, +11.1%)

 Kenosha (12,517, +8.4%)

 Walworth (9,302, +10.1%) 

 Winnebago (8,595, +5.5%)

 Racine (7,490, +4.0%)

 Calumet (5,661, +13.9%)

 Jefferson (5,255, +6.9%) 

 Sheboygan (4,816, +4.3%) 

 Ozaukee (4,691, +5.7%) 

 Fond Du Lac (4,444, +4.6%) 

 Dodge (3,913, +4.6%)

 Manitowoc (1,937, +2.3%) 

 Milwaukee (-1,674, -0.2%)

Projected population changes 

from 2000 U.S. Census to 2035 

 Waukesha (93,700, +26.0%)

 Kenosha (63,500, +42.5%)

 Washington (51,663, +44.0%)

 Winnebago (46,495, +29.7%)

The greatest population growth 

and projected population growth 

implicate Waukesha, 

Washington, Kenosha, Walworth, 

and Calumet. However, Calumet 

County is located northwest of 

Sheboygan County where ozone 

or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.5, & 8.8). 

2008 Ozone Standard Technical Support Document 62
02/27/2009 

Population Growth Rates 

and Patterns Continued 

 Walworth (40,928, +44.5%)

 Calumet (30,596, +75.3%)

 Jefferson (24,567, +32.4%) 

 Racine (26,866, +14.2%)

 Sheboygan (23,826, +21.1%)

 Ozaukee (21,115, +25.7%) 

 Fond Du Lac (19,004, +19.5%)

 Dodge (17,177, +20.0%)

 Manitowoc (9,412, +11.4%)

 Milwaukee (-76,956, -8.2%) 

Meteorology (weather & 

transport patterns) 

On days when the measured 1-

hour ozone concentration 

exceeded 75 ppb, the winds were 

predominately from the southsouthwest direction (76.4% of the 

total hours). The next most 

predominate wind direction was 

from the south (9.8% of the total 

hours), followed by winds from 

the southwest (5.7% of the total 

hours) and south-southeast (4.6% 

of the total hours). 

The NOAA Hysplit trajectory 

model reveals that on days when 

the 1- hour ozone concentration 

exceeded 75ppb, the polluted air 

masses passed through Ozaukee 

County 41.4%, Waukesha, 

Milwaukee, and Racine Counties 

31.0%, Washington County 

24.1%, Kenosha County 20.7%, 

and all other counties less than 

20% of the time six hours before 

the daily maximum ozone 

concentration was measured. 

The OSAT results for days with a 

modeled 1-hour ozone 

concentration of at least 75 ppb in 

Sheboygan County, which are 

based on 2009 air pollution 

controls, show that the 

Milwaukee nonattainment area 

contributes 13.5% of the average 

ozone concentration. The 

Chicago nonattainment area 

contributes 32.0% of the average 

ozone concentration. Wisconsin 

areas, excluding the Milwaukee 

nonattainment area, only 

contribute 3.5% of the average 

ozone concentration. 

The measured wind direction 

patterns implicate Ozaukee, 

Washington, Waukesha, 

Milwaukee, Racine, and 

Walworth Counties. 

The NOAA Hysplit model results 

implicate Ozaukee, Waukesha, 

Milwaukee, Racine, Washington, 

and Kenosha Counties. 

The OSAT results implicate the 

Milwaukee nonattainment area to 

the south of Sheboygan County. 

(Washington, Ozaukee, 

Waukesha, Milwaukee, Racine, 

and Kenosha) 

2008 Ozone Standard Technical Support Document 63
02/27/2009 

Geography / Topography 

Topography is predominantly flat 

and has little influence on 

weather, especially related to 

transport. 

Lake breezes are typically 

associated with high ozone 

concentrations. 

No implications for 

nonattainment. 

Jurisdictional Boundaries 

Sheboygan is part of the 

Sheboygan, WI Core Based 

Statistical Area (CBSA). 

Jurisdictional boundaries 

implicate Sheboygan County (i.e., 

Sheboygan CBSA). 

Level of Control of Emission 

Sources 

A number of ground level ozone 

related emission control programs 

have been implemented in 

Kenosha, Racine, Milwaukee, 

Waukesha, Ozaukee, 

Washington, and Sheboygan 

Counties, and to a lesser extent 

Manitowoc County. 

Programs include VOC RACT, 

NR 428, Federal Tier 2 Vehicle 

Standards, Enhance Inspection 

and Maintenance, Reformulated 

Gasoline, Nonroad engine 

standards, NR 445 side benefits 

and some local controls. 

Most of the stationary source 

control and certain area source 

and mobile source programs do 

not apply to the counties of 

Calumet, Fond Du Lac, Dodge, 

Jefferson, Walworth, or 

Winnebago. 

Calumet, Fond Du Lac, Dodge, 

Jefferson, Walworth, and 

Winnebago Counties are 

implicated due to the lack of 

stationary, mobile and area 

source controls. However, all of 

these counties, except Walworth 

County, are located in areas 

where ozone or its precursors are 

rarely transported from during 

high ozone concentration days for 

Sheboygan County (See Figures 

8.3, 8.5, & 8.8). 

Air quality, emissions, population, traffic, growth, and meteorological data indicate that 

counties bordering or near to Sheboygan County contribute to nonattainment there. 

Based on the data summary above, the following table (12.4) outlines three possible 

nonattainment designation options for the Sheboygan County area. 

Table 12.4: Options Summary for the Sheboygan County Area 

Designation Option 1 Option 2 Option 3 

Nonattainment 

Counties 

Sheboygan 

Milwaukee CSA 

Kenosha 

Sheboygan None 

Milwaukee CSA: Milwaukee, Ozaukee, Racine, Washington, and Waukesha Counties 

2008 Ozone Standard Technical Support Document 64
02/27/2009 

Option 1 includes all counties that are implicated by at least three of the nine factors 

analyzed, except Ozaukee, Washington, and Walworth Counties. The primary factors 

that implicate the seven counties are air quality measurements, air pollution emissions, 

population density and urbanization, population growth, and meteorology-related 

transport patterns. Washington and Ozaukee Counties, although only implicated by two 

factors, are included because they are part of the Milwaukee-Racine-Waukesha 

Combined Statistical Area (CSA). Walworth County, although implicated by three 

factors, is not included because one implicating factor was transport patterns, not 

emissions, and another implicating factor was the lack of control on emission sources. 

There is not much emission control in Walworth County because of a smaller 

contribution to regional emissions. 

Option 2 includes only Sheboygan County because it is the only county that measured 

nonattainment of the 2008 ozone standard. Guidance provided by the EPA states that 

that a CBSA or CSA should serve as the starting point or presumptive boundary for 

considering what should be the geographic boundaries of an ozone nonattainment area. 

Sheboygan County is not part of a multi-county CBSA or CSA. 

Option 3 classifies all areas as in attainment of the 2008 ozone standard due to the 

downward trend in monitored ozone design values since 1999, regional decreases in 

VOC and NOx emissions, and continued enforcement of state and federal air pollution 

rules. 

2008 Ozone Standard Technical Support Document 65
02/27/2009 

Kenosha County Area

Table 12.5: Analysis of Factors for the Kenosha County Area 

(The Counties of Kenosha, Milwaukee, Ozaukee, Racine, Walworth, Washington, and Waukesha) 

Factor Kenosha County Area Implications for Nonattainment 

Air Quality In 

Adjacent Areas

Nonattainment measured in 

Kenosha (DV – 78 ppb) County 

Attainment measured in other 

nearby counties, including: 

• Milwaukee 

 (DV – 63, 68, 72, 75 ppb) 

• Ozaukee 

 (DV – 72 & 74 ppb) 

• Racine 

 (DV – 71 ppb) 

• Walworth 

 (DV – 70 ppb) 

• Waukesha 

 (DV – 66 ppb) 

• Washington 

 (DV – 65 ppb) 

Kenosha County is implicated 

because nonattainment levels are 

measured in this County. 

Milwaukee and Ozaukee 

Counties are implicated because 

near nonattainment levels are 

measured in these counties. 

However, these counties are 

located north of Kenosha County 

where ozone or its precursors are 

rarely transported from during 

high ozone concentration days 

(See Figures 8.3, 8.6, & 8.9).

Emissions In Adjacent Areas 

(Based on 2005 WI Emissions 

Inventory) 

VOC (tpsd) 

• Milwaukee (95.5)

• Waukesha (53.9)

• Racine (34.1)

• Washington (24.4)

• Walworth (18.1)

• Kenosha (15.8)

• Ozaukee (14.0)

NOX (tpsd) 

• Milwaukee (91.3)

• Kenosha (47.7)

• Waukesha (39.7)

• Racine (14.9)

• Washington (13.8) 

• Ozaukee (12.7)

• Walworth (12.2)

Milwaukee, Kenosha, Racine, 

and Waukesha Counties are 

substantial source regions for 

precursor pollutants. However, 

these counties are located north 

of Kenosha County where ozone 

or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.6, & 8.9). 

Population Density and 

Degree of Urbanization 

2008 Population Density 

(persons/mi2

) / Percent Urban 

 Milwaukee 3,885.12 / 99.7%

 Kenosha 594.12 / 88.6%

 Waukesha 688.82 / 87.8% 

 Racine 589.38 / 87.0%

 Ozaukee 375.12 / 74.6% 

 Washington 302.89 / 65.2%

 Walworth 182.45 / 64.0% 

Population density and degree of 

urbanization implicate 

Milwaukee, Kenosha, Waukesha, 

and Racine Counties. However, 

these counties are located north 

of Kenosha County where ozone 

or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.6, & 8.9). 

2008 Ozone Standard Technical Support Document 66
02/27/2009 

Population Density and 

Degree of Urbanization 

Continued 

Kenosha County is the only 

county in the Kenosha County 

area that saw an increase in 

service providing jobs from 

October, 2007 to October, 2008 

of more than 5.0% (10.2 %). 

Traffic Patterns 

Summer Total Vehicle Miles 

Traveled (2007) 

 Milwaukee (1.86 Billion) 

 Waukesha (1.06 Billion)

 Racine (396 Million) 

 Kenosha (381 Million)

 Washington (342 Million) 

 Ozaukee (297 Million)

 Walworth (294 Million) 

Summer vehicle miles traveled 

clearly implicate Milwaukee and 

Waukesha Counties. However, 

these counties are located north 

of Kenosha County where ozone 

or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.6, & 8.9). 

Commuting Patterns 

Percentage of people who live 

in Kenosha County and work 

in: 

 Kenosha 56.2% 

 Racine 9.1%

 All Other Wisconsin 

 Counties < 4.0% 

Percentage of people who work 

in Kenosha County and live in: 

 Kenosha 76.5%

 Racine 11.0%

 All Other Wisconsin 

 Counties < 4.0%

Commuting patterns implicate 

only Kenosha County. 

Population Growth Rates 

and Patterns 

Total population changes from 

2000 U.S. Census to 2008 WI 

DSC final estimate 

 Waukesha (21,930, +6.1%) 

 Washington (12,997, + 11.1%)

 Kenosha (12,517, +8.4%)

 Walworth (9,302, +10.1%)

 Racine (7,490, +4.0%) 

 Ozaukee (4,691, +5.7%)

 Milwaukee (-1,674, -0.2%)

Projected population changes 

from 2000 U.S. Census to 2035 

 Waukesha (93,700, +26.0%)

 Kenosha (63,500, +42.5%)

 Washington (51,663, +44.0%)

 Walworth (40,928, +44.5%)

 Racine (26,866, +14.2%)

 Ozaukee (21,115, +25.7%)

 Milwaukee (-76,956, -8.2%) 

The greatest population growth 

and projected population growth 

implicate Waukesha, Kenosha, 

Walworth, and Washington 

Counties. However, these 

counties are located north or west 

of Kenosha County where ozone 

or its precursors are rarely 

transported from during high 

ozone concentration days (See 

Figures 8.3, 8.6, & 8.9). 

2008 Ozone Standard Technical Support Document 67
02/27/2009 

Meteorology (weather & 

transport patterns) 

On days when the measured 1-

hour ozone concentration 

exceeded 75 ppb, the winds were 

predominately from the southsoutheast direction (41.3% of the 

total hours). The next most 

predominate wind direction was 

from the south (18.7% of the total 

hours), followed by winds from 

the southwest (17.3% of the total 

hours) and southeast (8.0% of the 

total hours). 

The NOAA Hysplit trajectory 

model reveals that on days when 

the 1-hour ozone concentration 

exceeded 75ppb, the polluted air 

masses did not pass through any 

of the surrounding counties more 

than 15.8% of the time 

(Walworth County) six hours 

before the daily maximum ozone 

concentration was measured. 

The OSAT results for days with a 

modeled 1-hour ozone 

concentration of at least 75 ppb in 

Kenosha County, which are based 

on 2009 air pollution controls, 

show that the Milwaukee 

nonattainment area contributes 

only 4.1% of the average ozone 

concentration. The Chicago 

nonattainment area contributes 

39.6% of the average ozone 

concentration. Wisconsin areas, 

excluding the Milwaukee 

nonattainment area, contribute 

1.6% of the average ozone 

concentration. 

The measured wind direction 

patterns do not implicate any 

Wisconsin counties, but rather the 

Chicago nonattainment area. 

The NOAA Hysplit model results 

don’t implicate any Wisconsin 

counties. 

The OSAT results don’t implicate 

any Wisconsin counties. 

Geography / Topography 

Topography is predominantly flat 

and has little influence on 

weather, especially related to 

transport. 

Lake breezes are typically 

associated with high ozone 

concentrations. 

No implications for 

nonattainment. 

Jurisdictional Boundaries Kenosha is part of the ChicagoNaperville-Michigan City CSA. 

Jurisdictional boundaries 

implicate the Chicago 

nonattainment area. 

2008 Ozone Standard Technical Support Document 68
02/27/2009 

Level of Control of Emission 

Sources 

A number of ground level ozone 

related emission control programs 

have been implemented in 

Kenosha, Racine, Milwaukee, 

Waukesha, Ozaukee, and 

Washington Counties. 

Programs include VOC RACT, 

NR 428, Federal Tier 2 Vehicle 

Standards, Enhanced Inspection 

and Maintenance, Reformulated 

Gasoline, Nonroad engine 

standards, NR 445 side benefits 

and some local controls. 

Most of the stationary source 

control and certain area source 

and mobile source programs do 

not apply to Walworth County. 

Walworth County is implicated 

due to its lack of stationary, 

mobile and area source controls. 

However, Walworth County is 

located west of Kenosha County 

where ozone or its precursors are 

rarely transported from during 

high ozone concentration days 

(See Figures 8.3, 8.6, & 8.9). 

Air quality, emissions, population, traffic, and growth indicate that counties bordering or 

near to Kenosha County could potentially contribute to nonattainment there. However, 

all six counties considered are located north or west of Kenosha County where ozone or 

its precursors are rarely transported from during high ozone concentration days (See 

Figures 8.3, 8.6, & 8.9). Based on the data summary above, the following table (12.6) 

outlines three possible nonattainment designation options for the Kenosha County area. 

Table 12.6: Options Summary for the Kenosha County Area 

Designation Options 1 & 2 Option 3 

Nonattainment 

Counties Kenosha None 

Options 1 and 2 only include Kenosha County because it is the only county that measured 

nonattainment of the 2008 ozone standard and air pollution transport patterns do not 

implicate any other Wisconsin counties. Guidance provided by the EPA states that that a 

CBSA or CSA should serve as the starting point or presumptive boundary for considering 

what should be the geographic boundaries of an ozone nonattainment area. Kenosha 

County, although part of the Chicago-Naperville-Michigan City CSA, is not part of a 

multiple Wisconsin county CBSA or CSA. 

Option 3 classifies all areas as in attainment of the 2008 ozone standard due to the 

downward trend in monitored ozone design values since 1999, regional decreases in 

VOC and NOx emissions, and continued enforcement of state and federal air pollution 

rules.

2008 Ozone Standard Technical Support Document 69
02/27/2009 

XIII. References Cited 

Code of Federal Regulations: Title 40, Part 50, Appendix I: Interpretation of the 8-Hour 

Primary and Secondary National Ambient Air Quality Standards for Ozone. 

Code of Federal Regulations: Title 40, Part 58, Appendix A: Quality Assurance 

Requirements for SLAMS, SPMs and PSD Air Monitoring. 

Draxler, R.R. and G.D. Hess, 1998: An overview of the HYSPLIT_4 modeling system 

for trajectories, dispersion, and deposition, Aust. Met. Mag., 47: 295-308. 

Dutch, Steven, Natural and Applied Sciences, University of Wisconsin – Green Bay, 

2008. Topography of Wisconsin with County Overlay. Website: 

http://www.uwgb.edu/dutchs/GEOLWISC/TopoWiscLgCty.htm 

Lake Michigan Air Director’s Consortium (LADCO), 2008. Round 5 Emission 

Inventory Summaries. Website: http://www.ladco.org/tech/emis/current/index.php 

Lennartson, G. J. and M. D. Schwartz, 2002: The lake breeze-ground-level ozone 

connection in eastern Wisconsin: a climatological perspective. Intern. Jour. of 

Climatology, Vol. 22 Issue 11, Pages 1347-1364. 

National Weather Service (NWS), 2008a. Preliminary Monthly Climate Data (CF6). 

Website: http://www.weather.gov/climate/index.php?wfo=mkx 

National Weather Service (NWS), 2008b. Daily Station Normals (CLIM84). Website: 

http://cdo.ncdc.noaa.gov/cgi-bin/climatenormals/climatenormals.pl?directive= 

prod_select2&prodtype=CLIM84&subrnum= 

U.S. Census Bureau, 2008. Census 2000 Summary File 1 (SF1). Website: 

http://factfinder.census.gov/ servlet/DatasetMainPageServlet?_program= 

DEC&_submenuId=&_lang=en&_ts= 

U.S. Environmental Protection Agency, 2008a. Memorandum from Robert J. Meyers, 

Principal Deputy Assistant Administrator. Subject: Area Designations for the 2008 

Revised Ozone National Ambient Air Quality Standards. December 4, 2008. 

U.S. Environmental Protection Agency, 2008b: Fact Sheet, Final Revisions to the 

National Ambient Air Quality Standards for Ozone. 

U.S. Environmental Protection Agency, 2008c. AirData, Air Quality System (AQS). 

Website: http://www.epa.gov/air/data/index.html 

U.S. Environmental Protection Agency, 2008d. Ozone Design Values. 

Website: http://www.epa.gov/airtrends/values.html 

2008 Ozone Standard Technical Support Document 70
02/27/2009 

Western Regional Climate Center (WRCC), 2008. Plot time history of single/multimonth precipitation/temperature. Website: http://www.wrcc.dri.edu/cgibin/divplot1_form.pl?4709 

Wisconsin Department of Natural Resources (WI DNR), 2007. Memorandum from Scott 

Hassett, Secretary. Subject: Reasonably Available Control Technology (RACT) 

program for major sources of nitrogen oxides (NOx) in the moderate ozone nonattainment 

area and miscellaneous non-substantive corrections to current ch. NR 428 requirements. 

April 9, 2007. 

Wisconsin Department of Natural Resources (WI DNR), 2008. NOx and VOC Emission 

Summaries (1985-2007) Website: 

http://dnr.wi.gov/air/emission/historical_emissions/historical_emissions_nox.htm 

Wisconsin Department of Transportation (WI DOT), 2008. Vehicle Miles of Travel. 

Website: http://www.dot.state.wi.us/travel/counts/vmt.htm 

Wisconsin Demographic Services Center (WI DSC), 2008a. January 1, 2008 Final 

Population Estimates for Wisconsin Counties. Website: 

http://www.doa.state.wi.us/docview.asp?locid=9&docid=7263 

Wisconsin Demographic Services Center (WI DSC), 2008b. County Population 

Projections, Components of Change, 2000 – 2035. Website: 

http://www.doa.state.wi.us/docs_view2.asp?docid=2066 

Wisconsin Department of Workforce Development (WI DWD), 2008a. Local Area 

Unemployment Statistics. Website: 

http://dwd.wisconsin.gov/oea/employment_by_industry/employment_by_industry.htm 

Wisconsin Department of Workforce Development (WI DWD), 2008b. County-toCounty Worker Flow in Wisconsin. Website: 

http://dwd.wisconsin.gov/oea/pdf/Commuting2000.pdf 

2008 Ozone Standard Technical Support Document 71
Page 1 

Appendix

Door County – Rural Transport Classification 

Section 107(d)(1)(A)(i) of the Clean Air Act states that any area that does not meet the ozone 

standards, primary or secondary, should be designated as a nonattainment area. Thus to meet the 

requirements of the Act, Door County should be designated as a nonattainment area. However, it 

is requested that the Environmental Protection Agency (EPA) designate Door County as a “rural 

transport” nonattainment area for the following reasons: 

• EPA has previously stated that Door County meets the rural transport area eligibility 

requirements of the Clean Air Act, Section 182(h). [Docket ID No. EPA-HQ-OAR2007-0956]. There are two requirements to be eligible for this classification. First, an 

area must not be part of or adjacent to any part of a Metropolitan Statistical Area (MSA) 

or, where one exists, a Consolidated Metropolitan Statistical Area (CMSA). Second, 

sources of VOC and NOx emissions in the area must not make a significant contribution 

to the ozone concentrations measured in other areas. 

• Door County is not in or adjacent to a Metropolitan Statistical Area (MSA) or Combined 

Metropolitan Statistical Area (CMSA). 

• Based on 2005 emissions data from the Lake Michigan Air Director’s Consortium 

(LADCO), Door County only contributes 1.1% of VOC emissions and 0.6% of NOx 

emissions compared to the current Wisconsin ozone nonattainment counties and the 

current Chicago area ozone nonattainment counties. 

Kenosha County Monitor 

Section 107(d)(1)(A)(i) of the Clean Air Act states that any area that does not meet the ozone 

standards, primary or secondary, should be designated as a nonattainment area. Thus to meet the 

requirements of the Act, Kenosha County, or some portion thereof, should be designated as a 

nonattainment area. The smallest portion of Kenosha County (i.e., Pleasant Prairie Municipality) 

should be designated as a nonattainment for the following reasons: 

• The Chiwaukee ozone monitor in Kenosha County is located less than 1 mile from the 

Illinois border in Pleasant Prairie Municipality. 

• All major VOC point sources (> 100 tons/year) in Kenosha County were located in 

Pleasant Prairie Municipality based on 2007 emissions data (see figure). 

• The largest NOx point source in Kenosha County was located in Pleasant Prairie 

Municipality based on 2007 emissions data (see figure). This source, We Energies – 

Pleasant Prairie Station, accounted for approximately 83% of the total NOx emissions 

from major sources in Kenosha County. 

• The exceedance of the ozone standard at the Chiwaukee ozone monitor in Kenosha 

County is most likely due to transport from areas outside the state of Wisconsin. On 

days when the 1-hour ozone concentration exceeded 75 parts per billion (ppb), the 

observed wind speed at the Chiwaukee ozone monitor had a southerly component 

89.3% of the time from 2006 through 2008. Also, air quality modeling data from the 

Lake Michigan Air Director’s Consortium (LADCO) shows that the Milwaukee 

nonattainment counties (Kenosha, Milwaukee, Ozaukee, Racine, Waukesha, and 
Page 2

Washington) and the remainder of Wisconsin only contribute 4.1% and 1.6%, 

respectively, of the attributable ozone concentration at the Chiwaukee ozone monitor 

when the 1-hour ozone concentration exceeds 75 ppb. The Chicago nonattainment 

counties contribute 39.6% of the attributable ozone concentration. 

• Based on 2005 emissions data from the Lake Michigan Air Director’s Consortium 

(LADCO), the Chicago nonattainment counties contribute approximately 75 to 80% of 

the total NOx and VOC emissions compared to Wisconsin’s current ozone 

nonattainment counties. 

Major Sources (> 100 tons/year) of NOx and/or VOC in Kenosha County 

. 






02/27/2009 DNR’s Response to Public Comments 

The following are public comments received on the Department’s nonattainment options 

draft technical support document. The majority of the comments resulted in no change 

to the document; rather, they quoted statistics from the document or expressed a 

preference for a particular nonattainment designation. Any changes to the document 

resulting from a particular comment or response to a comment are noted in red. 

Comments were received from the following groups: 

1. Door County – Office of Corporation Counsel 

2. Manitowoc County – County Executive 

3. We Energies 

4. Wisconsin Public Service Corporation (WPSC) 

5. Wisconsin Power and Light Co. (WPL) 

6. Sierra Club 

7. Wisconsin Manufacturers and Commerce (WMC) 

Commenter: Door County 

Office of Corporation Counsel 

• Door County remains in nonattainment status. It is understood and accepted that 

this status will likely persist for the foreseeable future. 

• Door County is affected by overwhelming transport from one or more upwind 

areas. 

• Door County's primary goal is to be granted a "rural-transport nonattainment 

designation.” The DNR is asked to support Door County in its endeavor to 

qualify for and gain the protections of this nonattainment classification. 

Rural Transport Classification: Section 182(h) of the Clean Air Act states 

that in order for an area to receive the “rural-transport nonattainment 

designation” it must not include any other nonattainment areas (i.e., Option 2 

for the Door County area). 

• Door County also wishes to stress the importance of the DNR and EPA 

continuing and strengthening efforts to reduce upwind NOx and VOC emissions. 

Otherwise down wind areas affected by transport [e.g., Door County] will be 

hampered in their efforts to meet federally mandated NAAQS and deadlines. 

1
02/27/2009 DNR’s Response to Public Comments 

Commenter: Manitowoc County 

Office of the County Executive 

• Manitowoc County believes that it should not be designated as a nonattainment 

county for the Door County area for the following reasons: 

1) Manitowoc County met the revised ozone standard of 0.075 ppm for the 

2006-08 monitoring period. 

2) Current performance standards for existing sources have been working. 

Manitowoc County's ozone design value has shown steady downward progress 

from 0.092 ppm in 1999-01 to 0.075 ppm in 2006-08. 

3) Manitowoc County is only implicated by two of the nine U.S. EPA factors 

considered for making nonattainment recommendations. Those two factors are 

air quality in adjacent areas and weather/transport patterns. 

4) Regional contributions for attributable ozone from Wisconsin counties, 

excluding Milwaukee Nonattainment Counties, only account for 5.5% of the total. 

• Adding more restrictions on ozone emissions will not have a beneficial effect on 

business or the well being of the citizens of Manitowoc County. 

Regulatory Burden: The Federal Clean Air Act does not provide a 

nonattainment designation exception based on the resulting designation’s 

potential effect on businesses. 

2
02/27/2009 DNR’s Response to Public Comments 

Commenter: We Energies 

• Nonattainment designations will impact We Energies’ system of electric 

generation units and our electricity customers in Wisconsin. The proposed 8-

hour ozone nonattainment designations will make it more difficult to add new 

businesses and expand existing businesses in the affected counties. 

See the “Regulatory Burden” response above. 

• The data in the technical support document (TSD) demonstrate very clearly that 

the overwhelming contribution to monitored ozone exceedances in Wisconsin 

comes from regional emissions that are outside the state’s boundaries. This 

conclusion, however, seems somewhat lost by the focus on providing Wisconsin 

County-specific data to satisfy the letter of the EPA protocol as well as on the 

nonattainment designation “options” that the Department took out to public 

information meetings and public hearing. The TSD should be revised to 

emphasize the supporting data and conclusion that the overwhelming 

contribution to monitored ozone exceedances in Wisconsin comes from regional 

emissions that are outside the state’s boundaries. We recommend that some 

additional data and analysis be included in the TSD. Specifically, we request that 

the TSD include more data that illustrate the regional nature of the ozone 

problem affecting Wisconsin, and include more analysis and conclusion that 

Wisconsin point, area, and mobile sources of VOCs and NOx, contribute 

insignificantly to the ozone levels monitored in the subject counties. 

Regional Transport: The Ozone Source Apportionment (OSAT) results 

presented in the Department’s nonattainment options document already 

highlight the regional contribution to monitored ozone exceedances in 

Wisconsin. However, to further illustrate this point, the percentage of 

NOx and VOC emissions for non-road, point, area, and on-road emission 

sectors will be compared from the Illinois Chicago nonattainment 

counties, the Indiana Chicago nonattainment counties, the Wisconsin 

nonattainment counties, and the other Wisconsin counties considered for 

a nonattainment designation in Section 8 of the Department’s document. 

• U.S. EPA’s guidance for presumptive nonattainment boundaries is the county 

boundary itself, unless that county is part of a Core Based Statistical Area 

(CBSA) or Combined Statistical Area (CSA). None of these three counties 

(Door, Kenosha, or Sheboygan) with monitored data above the ozone standard 

falls within a Wisconsin CBSA or CSA, making the applicable presumptive 

boundaries the actual county boundaries. Notably, Kenosha County is included 

in the Chicago-Naperville-Michigan City CSA. The more appropriate use of this 

monitor is as a compliance monitor for the upwind Chicago-Gary region. In light 

of the modeling data presented in the Draft TSD showing that nearly all of the 

monitored ozone levels at the Kenosha monitor are attributable to sources 

located outside of Wisconsin, this appears to be a critical time to reevaluate this 

situation. Inappropriate use of the Kenosha County monitor may result in the 

burden of preparing an unachievable attainment plan. 

Presumptive Boundaries: The presumptive boundaries are the county 

borders; however, based on the nine factors considered in the 

3
02/27/2009 DNR’s Response to Public Comments 

Department’s document, as recommended by the EPA guidance, 

additional counties may be designated as nonattainment counties. 

Chiwaukee Monitor: Section 107(d)(1)(A)(i) of the Clean Air Act (the 

Act) states that any area that does not meet the ozone standards, primary 

or secondary, should be designated as a nonattainment area. Although 

the monitor is close to the border of Illinois, it is located in Kenosha 

County. 

In a 26 February 2009 call, EPA Region 5 Staff indicated that the Clean 

Air Act does not provide Kenosha County any relief from a nonattainment 

designation. The Chiwaukee Prairie monitor is located in Kenosha 

County and recorded a violation of the ozone standard; therefore, EPA 

will designate Kenosha County as a nonattainment county. 

• If all Wisconsin contributions are eliminated from the OSAT results presented in 

the TSD and the 18 ppb due to inflow from areas beyond the modeled domain 

are added back in, the resulting ozone concentration is still above the standard 

for all three counties (Door 76 ppb, Sheboygan 76 ppb, and Kenosha 84 ppb). 

This information clearly suggests that option 2 – recommending the minimum 

number of nonattainment counties, and potential excluding a nonattainment 

recommendation for Kenosha County, is the option that makes sense for 

Wisconsin’s citizens. This is not only consistent with U.S. EPA’s guidance, but it 

also anticipates the next step in the process, developing a compliant SIP. If the 

data show that the majority of the ozone problem comes from out-of-state 

sources, then why would the state want to obligate itself to solving an ozone 

problem that it is largely not culpable for creating? 

• The TSD needs to include data that illustrates the regional nature of the ozone 

problem affecting Wisconsin. At a minimum, adding emission data and 

information on traffic and commuting patterns in upwind states would strengthen 

the TSD (Examples for potential TSD additions provided in the letter). 

See the “Regional Transport” response above. The added regional 

emission comparison includes the on-road sector, which accounts for 

traffic and commuting patterns. 

• It may also be instructive for the Department to ask LADCO to zero-out 

Wisconsin emissions of NOx, and VOCs for the 20 Wisconsin counties included 

in the TSD, then re-run CAMx for an entire ozone season to test the hypothesis 

suggested by the OSAT data; namely, that Wisconsin point, area, and mobile 

sources of VOCs and NOx, contribute insignificantly to the ozone levels 

monitored in the subject counties. 

The suggested zero-out modeling would not provide any additional useful 

information in selecting ozone nonattainment areas in Wisconsin. 

• We oppose Option 1; conditionally support Option 2, conditioned on further 

evaluation of the appropriate use of the Kenosha County monitor; and question 

whether Option 3 is consistent with the provisions of the Clean Air Act. 

4
02/27/2009 DNR’s Response to Public Comments 

Commenter: Wisconsin Public Service Corporation (WPSC) 

• WPSC supports Option 2 for Door and Sheboygan counties and Option 3 for 

Kenosha County. 

• The nonattainment designations of Door, Sheboygan and Kenosha counties 

have potential to impact not only our own operations, but also the operations of 

many industries in the State of Wisconsin. The proposed designations could 

inhibit the siting of new businesses or the expansion of existing businesses in 

these areas, which is of significant concern during this period of economic 

uncertainty. 

See the “Regulatory Burden” response above. 

• U.S. EPA’s evaluation criteria for determining nonattainment boundaries do not 

account for regional transport of ozone. The modeling data shown in the TSD 

clearly indicate that regional contributions to monitored ozone exceedances are 

significant, and most of the regional contribution comes from areas beyond the 

borders of Wisconsin. Unfortunately, the conclusions in the TSD do not discuss 

any options for dealing with ozone transport from areas outside of Wisconsin. 

WPSC believes that this issue is of critical importance for determining 

nonattainment boundaries. 

See the “Regional Transport” response above. 

• Modeling data in the TSD indicate that even if all sources of ozone in Wisconsin 

are eliminated, regional ozone transport may still cause monitors in these 

counties to exceed the 8-hour standard. 

• Option 1 is overly conservative because surrounding counties to Door, 

Sheboygan, and Kenosha met the standard and is contrary to Wis. Stats. 

285.01(30) and 285.23(1). None of the three counties are part of a multiple 

Wisconsin county CSA or CBSA. 

Wisconsin Statutes: The referenced State Statutes are as follows: 

285.01(30), “’Nonattainment area’ means an area identified by the 

department in a document prepared under s. 285.23 (2) where the 

concentration in the atmosphere of an air contaminant exceeds an 

ambient air quality standard.” 

285.23(1), “The department may not identify a county as part of a 

nonattainment area under the federal clean air act if the concentration of 

an air contaminant in the atmosphere in that county does not exceed an 

ambient air quality standard, unless under the federal clean air act the 

county is required to be designated as part of a nonattainment area.” 

Option 1 is not contrary to these State Statutes because 285.23(1) states 

that an area can also be designated as nonattainment under the Federal 

Clean Air Act (the Act). Section 107(d)(1)(A)(i) of the Act states that any 

5
02/27/2009 DNR’s Response to Public Comments 

area that does not meet (or that contributes to ambient air quality in a 

nearby area that does not meet) the primary or secondary ambient air 

quality standard for the pollutant should be designated as a 

nonattainment area. Thus, counties that did not measure an exceedance 

of the ozone standard can still be designated as nonattainment if they 

contributed to another county’s violation of an ambient air quality 

standard. 

• The monitor located in Kenosha County was located in Chiwaukee, which is very 

close to the border with Illinois, and was designed to monitor ozone 

concentrations coming from the Chicago area. The location of this monitor does 

not allow for the measurement of ozone generated within the State of Wisconsin. 

Modeling results from the TSD support this assertion. 

See the “Chiwaukee Monitor” response above. 

• Option 2 closely follows Wis. Stats. 285.01(30) and 285.23(1) in the case of Door 

and Sheboygan Counties, but may not apply to Kenosha County due to the 

location of the Chiwaukee monitor. 

See the “Wisconsin Statutes” response above. 

• There is significant evidence that the main cause of nonattainment in Door, 

Sheboygan, and Kenosha Counties is the result of regional transport of ozone 

from areas outside of Wisconsin. However, Option 3 is contrary to Wis. Stats 

285.01(30) and 285.23(1) for Door and Sheboygan counties, as the data from 

monitors in those counties clearly indicate that they are above the 75 ppb limit 

and modeling data indicate that a significant amount of ozone comes from within 

Wisconsin. Although the Kenosha County monitor indicates that the ozone 

concentration is above the limit, the location of the monitor does not capture 

contributions from Kenosha or any other county in Wisconsin. Since there are no 

data to support that Kenosha County is nonattainment for ozone, a 

nonattainment designation should not be made. 

See the “Regional Transport” response above. 

See the “Chiwaukee Monitor” response above. 

6
02/27/2009 DNR’s Response to Public Comments 

Commenter: Wisconsin Power and Light Co. (WPL) 

• WPL asks that WDNR better reinforce the significant NOx emissions reductions 

that have occurred and will continue to occur in Sheboygan County, as a result of 

voluntary early emission reductions and continued efforts to comply with 

Wisconsin Administrative Code rule requirements in Chapter 428. This includes 

recent revisions adding Subchapter IV to NR428, which now requires stringent 

NOx emissions compliance requirements that are beyond EPA’s required levels 

for Reasonably Available Control Technology (RACT). WPL requests that the 

WDNR reinforce the significant NOx emissions reductions under Chapter NR428 

rule on pages 50 and 62 of the TSD and in the final recommendations provided 

to the Governor. 

Section 11 of the nonattainment options document will be updated to 

indicate that based on the NR428 RACT rule limitations for the counties 

of Kenosha, Racine, Milwaukee, Waukesha, Washington, Ozaukee, and 

Sheboygan the estimated NOx emissions reduction is nearly 15,000 

tons/year.

• Statistics and commentary presented on the ongoing and planned measures to 

reduce NOx at the Sheboygan Falls Energy Facility and Edgewater Generating 

Station. 

• WPL points out that the NR428 Subchapter IV RACT requirements will also 

reduce NOx in the additional counties of Kenosha, Milwaukee, Ozaukee, Racine, 

Washington and Waukesha. As presented by the WDNR to the Wisconsin 

Natural Resources Board when requesting final rule approval, the NR428 RACT 

rule limitations are estimated to reduce NOx emissions by almost 15,000 

tons/year. 

• WPL believes that whatever the final outcome of designation status is for 

Sheboygan County under the revised 8-hour ozone NAAQS, the area is wellpositioned to attain the standard as a result of the NR428 rule, Wisconsin RACT 

rules limiting volatile organic compounds (VOC) emissions, as well as, additional 

adopted federal rules that will reduce transport of ozone precursor emissions, 

such as the Clean Air Interstate Rule (CAIR) that has NOx reductions 

commencing this year. 

• Potential issues with maintaining the standard would result if emissions are not 

controlled from areas outside of Wisconsin. Final recommendations should 

reinforce the relevance of these out-of-state sources in achieving future 

compliance. 

7
02/27/2009 DNR’s Response to Public Comments 

Commenter: Sierra Club 

• The Draft Technical Support Document (TSD) proposes three general options. 

Only the first option is scientifically and legally defensible and, therefore, we urge 

the Governor to propose designation of the counties in Option 1. 

• Ozone pollution is a significant health threat at levels below the 2008 standard. 

The Bush Administration’s decision to adopt a 0.075 ppm ozone standard 

conflicted with evidence that a lower standard was necessary to protect public 

health (statistics and further commentary presented in the letter). It is now well 

known that the 0.075 ppm standard was the result of improper political influence 

by the Bush Administration in a process that is supposed to be controlled by 

science (statistics and further commentary presented in the letter). Because the 

0.075 ppm standard is not protective of health and was adopted for political 

reasons, rather than health reasons, it will be updated. It is almost certain that 

the U.S. EPA will revise the 2008 standard to no higher than 0.070 ppm and 

probably as low as 0.060 ppm based on the science we already know. Most or 

all of the counties in Option 1 will be in violation of these lower values. Also, 

ozone trends presented in the TSD do not show ozone levels at the 0.060 to 

0.070 ppm level for many years (if ever). 

• Even if Option 1 were not the only technically and legally defensible option for 

designating nonattainment areas for the 2008 0.075 standard, the Governor 

should still propose designation of the counties in Option 1 because it puts 

Wisconsin on a path to compliance with the coming, lower ozone standard and 

with ozone levels that impartial scientists tell us is necessary to protect public 

health. Option 1 is also supported by the total emissions from Wisconsin sources 

that contribute to ozone formation (statistics from the TSD quoted in the letter). 

• We also note that each of the factors to be considered in whether to designate 

up-wind counties favors including more counties than merely Door, Sheboygan 

and Kenosha. The point of designating nonattainment areas is to trigger 

pollution controls to bring down pollution levels. Therefore, because these 

pollution controls will be most effective if applied to the counties causing the 

ozone pollution, rather than the counties suffering the pollution, Option 1 is the 

only option that makes technical and scientific sense. 

• Option 3 is not a viable or legally defensible option. It relies on the same flawed 

legal interpretation that was used to designate nonattainment areas for the 2006 

PM2.5 standard. In a December 18, 2007 letter, the Governor recommended 

designations based on projections of 2015 levels. However, in December, 2008, 

the EPA correctly rejected that proposal and designated counties based on 

actual monitored pollution levels because that is what the Clean Air Act requires. 

Wisconsin should avoid making the same mistake here. 

8
02/27/2009 DNR’s Response to Public Comments 

Commenter: Wisconsin Manufacturers & Commerce (WMC) 

• Nonattainment designations carry with them substantial regulatory and related 

economic burdens. Given the costly regulatory implications and negative 

business climate perceptions associated with a nonattainment designation, we 

urge the Governor to limit his nonattainment designation recommendations to 

only those counties that are actually violating the standard. 

See the “Regulatory Burden” response above. 

• Any evaluation of these nonattainment options must start with the statutory 

directive (Wis. Stats. 285.23(1)) that nonattainment designations may only be 

attached to those counties “where the concentration in the atmosphere of an air 

contaminant exceeds an ambient air quality standard.” That is, there must be a 

“violating monitor.” An obvious, but related tenet is the legal and policy 

imperative that the monitor used to determine compliance in a particular county 

must be measuring that county’s air quality. Based on this litmus test, we 

oppose Option 1 as it includes numerous counties with no violating monitors. 

Conversely, we question the validity of Option 3 as it is inconsistent with the Act 

and an invitation to EPA to make unilateral nonattainment designations not in the 

best interest of Wisconsin. While we generally support Option 2, we note below 

the fact Kenosha County does not have a compliance monitor violating the new 

ozone standard, and should therefore not be designated as nonattainment. 

See the “Wisconsin Statutes” response above. 

See the “Chiwaukee Monitor” response above. 

• We strongly oppose the nonattainment designation of any counties that are 

meeting the standard. 

• For Door County, ozone contributions from non-Wisconsin counties amount to 

over 85 percent for the offending monitor (TSD, pp. 44). Similarly, for 

Sheboygan County, about 83 percent of the relevant ozone contributions are 

from out of state (TSD, pp. 45). It is important to note that even the relevancy of 

these insignificant amounts from Wisconsin is overstated in the TSD. That is, 

EPA created the CBSA/CSA boundary presumption to address the Act’s 

requirement to include contributing “nearby areas.” The presumption can be 

rebutted if a state identities other contributing sources in areas that are 

considered nearby. 

See the “Presumptive Boundaries” response above. 

• EPA’s nonattainment boundary guidance rests on the presumption that 

boundaries are defined by Core Based Statistical Area (CBSA) or Combined 

Statistical Area (CSA). Door County is not part of a CBSA or CSA, thus the 

presumptive boundary for any ozone nonattainment area is the county boundary 

(Option 2). Sheboygan County makes up the Sheboygan, WI Core Based 

Statistical Area (CBSA Code 43100), which includes no other counties. Thus, 

the presumptive boundary for any ozone nonattainment area is the county 

boundary (Option 2). Thus, there is a strong presumption, consistent with 

9
02/27/2009 DNR’s Response to Public Comments 

Wisconsin law, that only Door and Sheboygan counties be considered 

nonattainment. To rebut that presumption, upwind counties must have sources 

that significantly contribute to the violations in those counties. The Department’s 

TSD generally supports the conclusion that emissions from the upwind counties 

targeted under this option are insignificant. 

See the “Presumptive Boundaries” response above

The Department’s document does not “generally support the conclusion 

that emissions from the upwind counties targeted under this option are 

insignificant.” Rather, as summarized in Table 12.1, 12.3, and 12.5 the 

following upwind counties are considered “substantial source regions” for 

either NOx and/or VOC: Brown, Milwaukee, Kenosha, Sheboygan, 

Racine, and Waukesha. 

• For example, for Sheboygan County, this option targets Milwaukee, Ozaukee, 

Washington, Waukesha, Racine, and Kenosha counties for their contribution to 

the Sheboygan County violation. The Department’s TSD analysis merely 

aggregates all sources in the entire six-county region, and then, only finds a 13.5 

percent contribution. There is no attempt to identify specific sources 

meaningfully affecting the Sheboygan County monitor, or whether such sources 

are considered “nearby” under the Act. It would difficult, for example, to conclude 

any given source in any of these counties are making meaningful contribution, 

and that these emissions are not already controlled. 

The OSAT results provided by LADCO were only available on this larger 

scale. The remaining portions of the document, such as NOx and VOC 

emissions, population growth, vehicle miles, etc., focus more specifically 

on the individual counties. 

• Finally, we urge the Department to provide additional analysis in the TSD that the 

Wisconsin counties noted under Option 1, including sources in Door and 

Sheboygan counties, are insignificant and the violations in Door and Sheboygan 

counties are driven by regional pollution. 

The department followed the guidance provided by the EPA. 

See the “Regional Transport” response above

• We urge the Department to evaluate and advocate that Door and Sheboygan 

obtain regulatory relief under overwhelming or rural transport concepts or other 

avenues that recognize these counties should not be burdened with additional 

regulations for pollution not emanating from within their borders. This approach, 

we believe, is more consistent with the Act and better addresses the violations in 

those counties than Option 3, which will default to an EPA determination these 

counties should be considered nonattainment, possibly without any protections 

otherwise afforded under the Act. 

See the “Rural Transport Classification” response above. 

10
02/27/2009 DNR’s Response to Public Comments 

Sheboygan County would not be eligible for this classification since it 

borders the Milwaukee Combined Statistical Area (CSA) and it is also a 

single county metropolitan area. 

• We could support Option 2 except for the fact Kenosha County does not have a 

compliance monitor violating the new ozone standard. That is, the Chiwaukee 

monitor in Kenosha County that the Department properly notes exceeds the 

standard does not measure Wisconsin air quality, nor was it ever intended to be 

a Wisconsin compliance monitor. The Department’s data relating to 

meteorology/transport patterns and ozone source apportionment provide 

compelling evidence that the Chiwaukee monitor is not affected by Wisconsin 

sources. The Chiwaukee monitor is located within the Chiwaukee Prairie Nature 

Preserve, less than a quarter mile from Lake Michigan, less than a mile north of 

the Illinois border, and miles south of the city of Kenosha. Based on DNR wind 

direction data during relevant time periods, zero percent of the pollution affecting 

the Chiwaukee monitor is coming from the North, the North-Northwest or the 

Northwest. DNR’s ozone source apportionment data shows that at over 94 

percent of the contributions to the Chiwaukee monitor during relevant times are 

from out of state sources. EPA requires a compliance monitor be downwind of 

population areas. Being upwind of the City of Kenosha or other relevant areas of 

Kenosha County, the Chiwaukee monitor fails that test. Consistent with these 

policies, EPA acknowledges, as did the Department in the past, that being 

downwind of the Chicago-Gary region makes the Chiwaukee monitor the 

compliance monitor for that region. Thus, treating Chiwaukee monitor as a 

compliance monitor for any Wisconsin county, including Kenosha, conflicts with 

the Act and EPA policies and positions, and defies logic. Because Kenosha 

County does not have a violating monitor, the Governor should recommend an 

attainment designation. 

See the “Chiwaukee Monitor” response above. 

• As it stands today, every county in Wisconsin is meeting the current 84 ppb 

ozone standard. Unfortunately, as with the prior request, the Department is 

failing to timely submit a redesignation request. One again, we fear these areas 

are being shortchanged. We urge the Department to submit a redesignation 

request without delay for all Wisconsin counties now designated nonattainment, 

including Sheboygan, Manitowoc, Door, Ozone Designation Comments Page 5 

Milwaukee, Ozaukee, Washington, Waukesha, Racine, and Kenosha counties. 

These counties have suffered for too long due to unjustified delays. 

The Department is currently working on a redesignation request for all of 

Wisconsin’s nonattainment counties based on 2006 through 2008 ozone 

data. 

• In summary, we respectively request that the Department and the Doyle 

Administration recommend all Wisconsin counties meeting the new ozone 

standard, including Kenosha County, be designated attainment and that all 

Wisconsin counties be swiftly redesignated attainment for the old standard. 

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02/27/2009 DNR’s Response to Public Comments 

• Additional comments provided on DNR’s air quality monitoring network proposal, 

including the following topics: 

o Using the Chiwaukee monitor to determine the compliance status for the 

downwind Milwaukee-Racine CMSA is inconsistent with the Clean Air Act 

and EPA policies. 

o DNR and EPA have misconstrued Governor Thompson’s and Governor 

Doyle’s requests to EPA for Kenosha County “Ozone Planning” authority. 

o The Chiwaukee monitor is not considered a compliance monitor for any 

Wisconsin county, even Kenosha. 

12
02/27/2009 Public Comments Summary - Preferred Options 

DOOR COUNTY AREA

Option 1 

Nonattainment Counties: 

Door, Brown, Kewaunee and 

Manitowoc 

Option 2 

Nonattainment Counties: 

Door

Option 3 

Nonattainment Counties: 

None

Sierra Club Door County 

Office of Corporation Counsel 

Manitowoc County 1

Office of the County 

Executive 

Wisconsin Public Service 

Corporation (WPSC) 

We Energies 

Wisconsin Manufacturers & 

Commerce (WMC)

SHEBOYGAN COUNTY AREA

Option 1 

Nonattainment Counties: 

Sheboygan, Kenosha, 

Milwaukee, Ozaukee, Racine, 

Washington, and Waukesha 

Option 2 

Nonattainment Counties: 

Sheboygan 

Option 3 

Nonattainment Counties: 

None

Sierra Club Wisconsin Public Service 

Corporation (WPSC) 

We Energies 

Wisconsin Manufacturers & 

Commerce (WMC)

Note: Wisconsin Power and Light Co. (WPL) did not endorse any option; rather, they requested 

the technical support document include a revised discussion regarding the level of control of 

emission sources in Sheboygan County. 

KENOSHA COUNTY AREA

Option 1 

Nonattainment Counties: 

Kenosha 

Option 2 

Nonattainment Counties: 

Kenosha 

Option 3 

Nonattainment Counties: 

None

Sierra Club Wisconsin Public Service 

Corporation (WPSC) 

We Energies 

Wisconsin Manufacturers & 

Commerce (WMC)

 

1

 Manitowoc County did not specifically endorse Option 2; rather, they commented that they should not be 

designated as a nonattainment county as presented in Option 1 for the Door County area.