# J IM 

# D OYLE

G OVERNOR


## S TATE OF 

## W ISCONSIN

P.O. B OX 7863, M ADISON

, W ISCONSIN 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 s ubmit 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 recommendin g that all counties in Wisconsin be designated as attainment for the 8-hour ozone st andard.

Rationale

As you are aware, the State of Wisconsin is very co ncerned about air pollution and the resultant adverse impacts to public health and the environment. The State has historically been a national leader in improving ai r 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 recommendat ion that portions of the state be designated as nonattainment in Wisconsin is based o n 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 nona ttainment for the older 8-hour standard of 85 ppb.P.O. B OX 7863, M ADISON

, W ISCONSIN 53707-7863  (608) 266-1212  FAX: (608) 267-8983 

WWW

. WISGOV

. STATE

. WI

. US 2. Modeling Results – Modeling results conducted b y the Lake Michigan Air Director’s Consortium for the upper Great Lakes region includi ng the regional emission

reductions from the federal Clean Air Interstate ru le, 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 stat e actions.

3. State Actions to Reduce NOx – As you know, NO

x 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 VO C emissions. Additionally, in the past three years, Wisconsin focused its efforts on reducing NO

x 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 19 95 levels. The net result of these rules is to position the state to meet all ap plicable current federal air quality standards, and as a result, protect Wisconsin’s cit izens 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 a s exceeding the standard will have any material additional benefit to reducing ozone l evels in those counties. Door County has no heavy industry or large coal-fired po wer 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 maki ng significant reductions in NOx and other air pollutants. A non-attainment designation will not change the positive impact of those regulations, nor require additional action s to be pursued.

Under my administration, Wisconsin has taken swift and significant action to protect its citizens from the harmful affects of air pollut ion. 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 h inder the vitality of Wisconsin’s

businesses.

Lastly, if EPA determines to act on nonattainment d esignations 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 o f Air Management in the Wisconsin DNR, if you have any questions related to this communication. Thank youP.O. B OX 7863, M ADISON

, W ISCONSIN 53707-7863  (608) 266-1212  FAX: (608) 267-8983 

WWW

. WISGOV

. STATE

. WI

. US for the opportunity to submit the State of Wisconsi n’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 Com mittee Representative Spencer Black, Chair, Assembly Natu ral Resource Committee Matt Frank, Secretary, Department of Natural Resou rces Al Shea, Administrator, Air & Waste Division, Depa rtment of Natural Resources John Melby, Director, Bureau of Air Management, De partment 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 th e Twenty Counties Considered for a Nonattainment Designation Table 4.3: Change in Summer Day Emi ssions 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 Popula tion Increases for Rural Counties

Table 6.1: Summer Ve hicle Miles Traveled Table 7.1: Populati on Growth (2000 to 2008) Table 7.2: Projected Popul ation Growth (2000 to 2035) Table 8.1: Hysplit Back Trajectories for Days wh en the 1-Hour Ozone

Concentrations ≥ 75 ppb Table 8.2: OSAT Source Regions Table 12.1: Analysis of F actors for the Door County Area Table 12.2: Options Summary for the Door County Area Table 12.3: Analysis of Fact ors for the Sheboygan County Area Table 12.4: Options Summary for the Sheboygan County Area Table 12.5: Analysis of Fact ors 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 Va lues 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 Va lues 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 Stati onary Air Pollution Sources (1985-2007) for the Twenty Counties Considered for a Nonattainment Designation Figure 5.1: 2008 Popula tion Density by County Figure 5.2: One-Year Percentage Change in Service Providing Jobs Figure 7.1: Population Gr owth by County (2000 to 2008) Figure 7.2: Projected Populati on Growth by County (2008 to 2035) Figure 8.1: Eastern Wisconsin Climate Divisions Figure 8.2: Average May – September Te mperature and Average Fourth-Highest 8- Hour Average Ozone Concentrations for the East Central and Southeast

Climate Divisions Figure 8.3: Door County Wind Rose wh en the 1-Hour Ozone Concentration ≥ 75 ppb Figure 8.4: Sheboygan County Wind Rose wh en the 1-Hour Ozone Concentration ≥ 75 ppb Figure 8.5: Kenosha County Wind Rose wh en the 1-Hour Ozone Concentration ≥ 75 ppb Figure 8.6: OSAT Re sults 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 th e 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 De termining Nonattainment Designations Appendix 2 DNR’s Response to Public Comments Appendix 3 Summary of Public Co mments – Preferred Options

2008 Ozone Standard Technical Support Document iv

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I. Executive Summary

On March 12, 2008, the U.S. Environmenta l Protection Agency (EPA) promulgated revisions to the 1997 primary and secondary national ambient ai r quality standards (NAAQS) for ozone. The revisions becam e 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 desi gn value greater th an 0.075 ppm measure

nonattainment of the 8-hour ozone standard. The purpose of this document is to provide technical information to support the determin ation 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 standa rd 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 Standard s.” This document states that a Core Based Statistical Area (CBSA) or Combined Statistical Area (CSA) serve as the starting point or presumptive boundary for consider ing what should be the geographic boundary

of an ozone nonattainment area. When an oz one 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 dete rmination 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 ne arby counties that may have contributed to the measured nonatta inment. 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 presente d in Section 12 of this document. This technical support doc ument is developed to support nonattainment recommendation decisions by the Governor.

2008 Ozone Standard Technical Support Document 1

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Door County Area

Ozone monitoring data from 2006 th rough 2008 demonstrate a design value

concentration above the 8-hour ozone sta ndard 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 th rough 2008 demonstrate a design value

concentration above the 8-hour ozone sta ndard 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 ba sed on EPA’s nine f actors to consider when determining nonattainment boundaries. The counties of Calumet, Dodge, Fond Du Lac, Jefferson, Kenosha, Manitowoc, Milw aukee, Ozaukee, Racine, Walworth, Washington, Waukesha, and Winnebago are eval uated 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).

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Kenosha County Area

Ozone monitoring data from 2006 th rough 2008 demonstrate a design value

concentration above the 8-hour ozone standa rd 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 c ounties of Milwaukee, Ozaukee, Racine, Walworth, Washington, and Waukesha are eval uated 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-Nape rville-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 st ate indicate attainment of the 8-hour ozone standard. Counties not specifically analyzed in the options summarized above should be designated as attain ing the standard.

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Figure 1.1 8-Hour Ozone Designation Analysis Area

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

data from 2006 to 2008.

2008 Ozone Standard Technical Support Document 4

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Figure 1.2 Counties Considered for an 8- Hour Ozone Nonattainment Designation (Option 1)

Nonattainment

Attainment

2008 Ozone Standard Technical Support Document 5

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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

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II. Background on Revi sed 8-Hour Ozone NAAQS

On March 12, 2008, the EPA promulgated revi sions 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 great er than 0.075 ppm meas ure 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 prim ary 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 th e environment” (U.S. EPA, 2008b).

EPA demonstrated that the benefits of a lowe r ozone standard are li kely greater than the expected costs. The value of the health bene fits 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 designa tion 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 In itiated: Mid-November 2009

• State Response Regarding EPA Modificat ions: 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 memorandu m from Robert J. Meyers, “Area Designations for the 2008 Revised Ozone Na tional Ambient Air Quality Standards.” Nonattainment recommendations are based upo n the nine factors presented in this

memorandum.

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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 valu es are determined by averaging the fourthhighest daily maximum 8-hour average ozone concentratio ns for three consecutive

years 1 

### . A monitoring site is classi fied 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 15 th 

### – October 15 th 

### ), 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 require ments 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 concen trations for the 32 monitoring locations and resulting design valu es. The only counties that exceeded the 2008 ozone standard are Door, Sheboygan, a nd Kenosha (Table 3.1 and Figure 3.1).

The fourth-highest daily maximum 8-hour av erage ozone concentrations ranged from 0.059 to 0.092 ppm from 2006 through 2008. Across the state, higher than normal ozone

concentrations were measured durin g 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 20 08, 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 tw o counties that measur ed fourth-highest daily maximum 8-hour average ozone concen trations 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 comp ared against previous design values to determine the representativeness of the late st 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

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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 Milwa ukee-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 th e lowest since the 1999-01 period, they are consistent w ith the downward trends shown.

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Table 3.1: Fourth-Highest Daily Maximu m 8-Hour Average Ozone Concentrations
Locations with design values exceeding th e 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. Tr ailer, 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 oz one 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

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

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20 08 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

Standard02/27/2009FIGURE 3.3: 8-Hour Ozone Design Values Since1999 for the Milwaukee-Racine Nonattainment Area0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.1101999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-11 2010-123-Year Period

Ozone Design Value (ppm)Milwaukee-Racine NA8-Hour Ozone Standard (0.075 ppm)Linear TrendSource: U.S. Environmental Protection Agency DesignValues (http://www.epa.gov/airtrends/values.html)2008 Ozone Standard Technical Support Document1402/27/2009FIGURE 3.4: 8-Hour Ozone DesignValues Since 1999 for Sheboygan County0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.1101999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-11 2010-123-Year Period

Ozone Design Value (ppm)Sheboygan Co8-Hour Ozone Standard (0.075 ppm)Linear TrendSource: U.S. Environmental Protection Agency DesignValues (http://www.epa.gov/airtrends/values.html)2008 Ozone Standard Technical Support Document1502/27/2009FIGURE 3.5: 8-Hour Ozone DesignValues Since 1999 for Manitowoc County0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.1101999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-11 2010-123-Year Period

Ozone Design Value (ppm)Manitowoc Co8-Hour Ozone Standard (0.075 ppm)Linear TrendSource: U.S. Environmental Protection Agency DesignValues (http://www.epa.gov/airtrends/values.html)2008 Ozone Standard Technical Support Document1602/27/2009FIGURE 3.6: 8-Hour Ozone DesignValues Since 1999 for Kewaunee County0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.1101999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-11 2010-123-Year Period

Ozone Design Value (ppm)Kewaunee Co8-Hour Ozone Standard (0.075 ppm)Linear TrendSource: U.S. Environmental Protection Agency DesignValues (http://www.epa.gov/airtrends/values.html)2008 Ozone Standard Technical Support Document1708 Ozone Standard Technical Support Document18FIGURE 3.7: 8-Hour Ozone DesignValues Since 1999 for Door County0.0600.0650.0700.0750.0800.0850.0900.0950.1000.1050.1101999-01 2000-02 2001-03 2002-04 2003-05 2004-06 2005-07 2006-08 2007-09 2008-10 2009-11 2010-123-Year Period

Ozone Design Value (ppm)Door Co8-Hour Ozone Standard (0.075 ppm)Linear TrendSource: U.S. Environmental Protection Agency DesignValues (http://www.epa.gov/airtrends/values.html)02/27/200920

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20 08 Ozone Standard Technical Support Document 19 

### IV. Wisconsin Emissions Data

Ground level ozone is created by a chemical r eaction between nitrogen oxides (NOx) and volatile organic compounds (VOCs) in the pr esence of heat and s unlight. The highest daily ozone concentrations t ypically occur during the mid- to late-afternoon when daily temperatures reach their maximum. Vehi cle and equipment exhaust, industrial emissions, gasoline vapors, and chemical solv ents are some major sources of NOx and

VOCs. These emissions contribute to ozone fo rmation locally and regionally. Therefore, it is important to consider emissions in counties where nonattainme nt is measured, as

well as counties that contribute to nonattain ment 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 fo r the twenty counties considered for a nonattainment designation. Emissions ar e summarized by source sector and the pollutants that contribu te to ozone production. Automobile s and electric generating units (EGUs) are the major NOx sources in the stat e due to high temperature fuel combustion

associated with these sources. VOC emissi ons are derived from a number of sources, including onroad and nonroad mobiles sour ces (e.g., cars, trucks, lawn mowers, and outboard engines), industrial solv ents 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 (V MT), and the largest populations have the highest NOx emissions. The following table (4.1) shows the statew ide ranks for these

three factors.

Table 4.1: Statewide Ranks fo r 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 n early 96 tons of VOC are emitted on a summer day, while 54 tons and 36 tons are emitte d daily in Waukesha and Brown Counties, respectively. Substantial VOC emissions al so occur in the Fox River Valley (Brown, Outagamie, and Winnebago Counties) and incounties such as Sheboygan, Washington,

and Racine Counties. The counties noted eith er directly border a nonattainment area or are upwind of an area that measures nonattainment.08 Ozone Standard Technical Support Document20Table 4.2: 2005 Emissions Data for the Twenty Counties Considered for a Nonattainment DesignationPOINTAREAOFFROADONROADTOTALCOUNTYFIPSCodeNOXVOCNOXVOCNOXVOCNOXVOCNOXVOCBROWN5500948.886.752.2013.206.408.0615.468.1172.9415.5%36.117.5%CALUMET550150.231.040.192.251.901.892.441.294.761.0%6.461.3%DODGE550270.521.770.407.823.754.016.172.9410.832.3%16.543.5%DOOR550290.000.250.261.915.359.212.451.058.061.7%12.412.6%FOND DU LAC550391.842.690.686.563.444.336.873.5112.822.7%17.093.6%JEFFERSON550553.251.730.657.852.894.978.492.9715.283.3%17.523.7%KENOSHA5505935.400.930.997.424.134.467.133.0247.6510.2%15.833.3%KEWAUNEE550610.070.310.091.651.731.611.220.593.110.7%4.160.9%MANITOWOC550715.071.800.535.833.813.337.362.5716.773.6%13.532.8%MARINETTE550756.673.030.213.981.744.773.071.4811.692.5%13.262.8%MILWAUKEE5507930.959.017.2554.5717.8016.0235.3315.8691.3419.5%95.4619.9%OCONTO550830.160.890.222.501.235.013.471.515.071.1%9.902.1%OUTAGAMIE550879.534.651.547.364.634.649.625.3925.335.4%22.044.6%OZAUKEE550891.040.650.778.815.282.555.572.0212.662.7%14.042.9%RACINE551010.831.661.3223.105.446.067.333.2414.923.2%34.077.1%SHEBOYGAN5511716.432.981.229.504.085.367.842.8629.586.3%20.694.3%WALWORTH551270.441.330.826.263.366.887.593.6512.212.6%18.123.8%WASHINGTON551310.530.661.0615.093.895.658.362.9713.843.0%24.365.1%WAUKESHA551331.004.604.1221.5912.1118.8722.498.8839.728.5%53.9411.3%WINNABEGO551392.787.251.349.395.5711.4410.815.6220.494.4%33.707.0%TOTAL---165.6253.9725.86216.6298.53129.12179.0779.53% OF POLLUTANT---35.3 %11.3 %5.5 %45.2 %21.0 %26.9%38.2 %16.6 %469.08479.2402/27/200920

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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 fr om 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 fr om 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 consider ed for a nonattainment designation. The total

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

Table 4.3: Change in Summer Day Emission s 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

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Figure 4.1: 2005 NOx Emissions by County (Tons per Summer Day)

NOx (tpsd)

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20 08 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 Document24Figure 4.3: NOx and VOC from Stationary Air Pollution Sources (1985-2007)for the Twenty Counties Considered for a Nonattainment DesignationData Source:http://dnr.wi.gov/air/emission/historical_emissions/historical_emissions_nox.htm02/27/200920

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V. Population Density and Degree of Urbanization

Population density and the degr ee of urbanization are well correlated with the amount and concentration of air pollutant emissions . Identifying areas w ith a dense population and those experiencing rapid urba nization is critical for dete rmining areas that contribute

to ozone formation.

a. Population Density

Since 2000, population density has increased in all twenty counties considered for a nonattainment designation, excep t Milwaukee. The countie s 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/mi 2 or pop. density > 500 persons/mi 2

COUNTY Population Density Change 2000 to 2008 (persons/mile 2 ) 2008 Population Density (persons/mile 2 )

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 Depart ment of Administration – Demographic Services (http://www.doa.state.wi.us/doc view.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 south east Wisconsin and the Fox River Valley are the two most densely populated areas.

b. Degree of Urbanization

The degree of urbanization is also an impor tant 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 cl assified as urban. The twenty counties considered for a nonattainment designati on, as a whole, are becoming more urban.

Seven of the twenty counties considered fo r a nonattainment desi gnation had an urban population of 75% or greate r 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.

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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/DatasetMainPa geServlet?_program=DEC&_s ubmenuId=&_lang=en&_ts=)



### Rural counties in the twenty counties consider ed for a nonattainment designation are also rapidly becoming more urban. Counties such as Walworth and Washington witnessed urbanization rates exceeding 10% betw een 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/DatasetMainPa geServlet?_program=DEC&_s ubmenuId=&_lang=en&_ts=)



### The nonattainment boundary guidance provide d 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 th e twenty counties considered for a nonattainment designation (WI DWD, 2008a). Service providing jobs include, construction, mining, and na tural resources; manufacturin g; trade; transportation, warehousing, and utilities; financial activities ; education and health services; leisure and hospitality; information, professional and bus iness; 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 we re 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.

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Figure 5.1: 2008 Population Density by County

# Persons/Mile 2

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Figure 5.2: One-Year Percentage Ch ange in Service Providing Jobs
October, 2008 – October, 2007



### Percent Change

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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 fo r a nonattainment designation. On e indicator of vehicle use

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

The greatest total gasoline VMT occurs in coun ties with major interstate stretches of highway, as well as areas of greater popul ation (Table 6.1). The counties with the greatest summer average VMT are Milwauk ee (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 fa r an individual trav els between work and

home. Based on 2000 U.S. Census data from the Wisconsin Department of Workforce Development, commuting patterns were analy zed 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

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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 Illi nois 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 p opulation include Waukesha, Br own, Outagamie, Washington, and Kenosha (Table 7.1). The counties expe riencing the largest pe rcentage increase in population include Calumet, Washingt on, 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 Admi nistration – Demographic Services (http://www.doa.state.wi.us/ docs_view2.asp?docid=2066)



### The Wisconsin Department of Administra tion – Demographic Services projects population growth from 2000 through 2035. Pos itive 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, Outagami e, Kenosha, and Washington (Table 7.2). The counties projected to have the largest percentage in crease in population include Calumet, Walworth, Washington, Oconto, Kenosha, and Outagamie (Table 7.2).

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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 Admi nistration – Demographic Services (http://www.doa.state.wi.us/ docs_view2.asp?docid=2066)



### Strong population growth will lead to incr easing mobile and area source emissions throughout the region.

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Figure 7.1: Population Grow th by County (2000 to 2008)

# Persons

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

# Persons

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VIII. Meteorology / Transport

Wisconsin is located in the upper Midwest. It experiences primarily a continental climate with synoptic scale weather features that ar e often moderated by th e 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 predominan tly flat. Consequently, topography has relatively little influence on Wi sconsin’s weather, especially as it pertains to air pollution transport. However, both Lake Michigan and Lake Superior are larg e bodies of water on

the eastern and northern borders of Wiscons in whose surface temperatures relative to land temperature (spring/summer: cold, fall/winter: warm) often can greatly modify both thermal and wind patterns along th e shoreline areas of the st ate. 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 especi ally, but not exclusively, evident during the warmer months. These meteorological c onditions 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. C limate divisions are regions with similar temperature and precipitation characteristics. The eastern portion of the state makes up

the East Central and Southeast Climate Di visions (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 y ears, 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 aver age ozone concentrations for the ozone

monitors located in the East Central and S outheast Climate Divisions are also shown in Figure 8.2 (EPA, 2008c). The average May th rough September temperatures are well correlated with the average 8-hour ozone con centrations. 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).

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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 anal ysis 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-Pa rticle Lagrangian Integrated Trajectory) trajectory model (Draxler and Hess, 1998) was applied to gridded hourly mete orological data on those days from 2006 through 2008 when an ozone monitor in Kenosha, Sheboygan, or Door County measured a 1-hour ozone concentra tion 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 monitori ng locations in Door, Kenosha, and Sheboygan Counties. The ending time for the trajecto ries was the hour when the highest 1-hour

ozone concentration was measured.

The following table (8.1) shows the percentage of times a ba ck trajectory passed through a particular county. Only Sheboygan County ha s 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 % Milwauk ee 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 Oza ukee, Washington, Wa ukesha, Milwaukee,

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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 us eful tools for determining wh ich 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 vari ety tools, including the ozone source apportionment tool (OSAT). OSAT iden tifies the contribution to modeled ozone concentration at a particular location from regional loca tions and various emissions

sectors.

The Lake Michigan Air Directors C onsortium (LADCO) provided ozone source apportionment results for Door, Sheboygan, a nd Kenosha Counties. The modeled ozone

concentrations were determined assumi ng 2009 air pollution controls. The 1-hour average ozone concentrations were calc ulated as 86 ppb, 88 ppb, and 88 ppb for Door, Sheboygan, and Kenosha Counties, respectiv ely, for days when the 1-hour ozone concentration was at least 75 ppb.

Contribution to the 1-hour average ozone con centrations are determined from seventeen geographic regions and six emi ssion 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 combinedfor 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 regi on 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 “attr ibutable” 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 por tion 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 larges t contributor to the average 1-hour ozone concentration to Door County, 27.7 %.

The Chicago nonattainment area contributes the largest por tion 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 larg est contributor to th e average 1-hour ozone concentration to Sheboygan County, 29.0 %.

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The Chicago nonattainment area contributes the largest por tion of the average 1-hour ozone concentration to Kenosha County, 39.6 %. The Milwaukee nonattainment area contributes 4.1 % of the average 1-hour oz one concentration to Kenosha County. The off-road emission source sector is the larg est contributor to th e 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 A rea NOx and VOC Emissions

As shown in the OSAT results, the Ch icago nonattainment counties contribute a significant portion of the at tributable 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 consideri ng 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 Caro lina, Tennessee, Virginia, and West Virginia.

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### Figure 8.1: Eastern Wisc onsin Climate Divisions

Counties shaded in blue represent counties with ozone monitors. Climate Division #6

East Central

Climate Division #9

Southeast08 Ozone Standard Technical Support Document39Figure 8.2: Average May – September Temperature and AverageFourth- Highest 8-Hour Average Ozone Concentrationsfor the East Central and Southeast Climate Divisions.02/27/20092060.561.061.562.062.563.063.564.064.565.065.566.066.520042005200620072008Year

Average Temperature (May-Sept) (Deg F)0.0600.0630.0650.0680.0700.0730.0750.0780.0800.0830.0850.0880.090 Average 4th Highest 8-Hour Ozone Concentration (ppm)AverageTemperature 64.0 oFBar Graph: Temperatures,Line Graph: Ozone Concentrations

### 02/27/2009

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

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

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20 08 Ozone Standard Technical Support Document 42

Figure 8.5: Kenosha County Wind Rose when the 1-Hour Ozone Concentration ≥ 75 ppb02/27/2009Figure 8.6: OSAT Results for Door County (Site 5502900041)Regional Contributions for Attributable Ozone (Days when 1-Hour Ozone Concentration≥75 ppb)The average 1-hour ozone concentration on days when the 1-hour ozone concentration exceeds 75 ppb is 86 ppb, assuming 2009 airpollution controls.68 ppb of the 86 ppb ozone concentration is attributable to regional sources and 18 ppb is from the modeled boundary contribution.2008 Ozone Standard Technical Support Document4302/27/2009Figure 8.7: OSAT Results for Sheboygan County (Site 5511700061)Regional Contributions for Attributable Ozone (Days when 1-Hour Ozone Concentration≥75 ppb)The average 1-hour ozone concentration on days when the 1-hour ozone concentration exceeds 75 ppb is 88 ppb, assuming 2009 airpollution controls.69 ppb of the 88 ppb ozone concentration is attributable to regional sources and 19 ppb is from the modeled boundary contribution.2008 Ozone Standard Technical Support Document4402/27/2009Figure 8.8: OSAT Results forKenosha County (Site 5505900021 / 5505900191)Regional Contributions for Attributable Ozone (Days when 1-Hour Ozone Concentration≥75 ppb)The average 1-hour ozone concentration on days when the 1-hour ozone concentration exceeds 75 ppb is 88 ppb, assuming 2009 airpollution controls.68 ppb of the 88 ppb ozone concentration is attributable to regional sources and 20 ppb is from the modeled boundary contribution.2008 Ozone Standard Technical Support Document4502/27/2009Figure 8.9: 2005 NOx Emissions for theTwenty Counties Considered for a Nonattainment Designation and the ChicagoNonattainment CountiesSource: LADCO – Round 5 Emission Inventory Summaries(http://www.ladco.org/tech/emis/current/index.php)2008 Ozone Standard Technical Support Document4608 Ozone Standard Technical Support Document47Figure 8.10: 2005 VOC Emissions for the Twenty Counties Considered for a Nonattainment Designation and the ChicagoNonattainment CountiesSource: LADCO – Round 5 Emission Inventory Summaries(http://www.ladco.org/tech/emis/current/index.php)02/27/200920

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IX. Geography/ Topography

As shown in Figure 9.1, the t opography of eastern Wisconsin is predominately flat. There is no evidence to suggest that the va riations in topography influence measured

ozone concentrations or has an eff ect 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 patte rn exists; the land surface is relatively cooler than the water su rface causing winds to blow from the land

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

breeze circulation.

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

ozone concentrations and the lake breeze circul ation in eastern Wisconsin. Their results are summarized in a paper published in the International Journal of Climatology titled, “The lake breeze-ground-level ozone connecti on in eastern Wisconsin: a climatological perspective” (Lennartson, 2002). Their results showed the following:

(1) a decrease in both magnitude and fr equency 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 occurr ing 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 determin e which counties are in nonattainment, or contributing to the nonattainment, of th e 2008 ozone standard. No counties are implicated for nonattainment based on the e ffects of the lake breeze circulation.

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Figure 9.1: Topography of the Twenty Counties Considered for Nonattainment

Elevation
(feet)

Source : University of Wisconsin – Green Bay (http://www.uwgb.edu/dutchs/G EOLWISC/TopoWiscLgCty.htm)

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X. Jurisdictional Boundaries

The ozone boundary guidance from the EPA recommends that the CBSA or CSA serve as the starting point or presumptive bounda ry for considering what should be the geographic boundaries of an ozone nonattainme nt 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 Ke nosha, are part of a multiple Wisconsin county CSA. Kenosha County is part of th e Chicago-Naperville-Michigan City CSA; however, it is also part of th e Southeastern Wisconsin Metro politan Planning Area. This planning area includes the counties of Kenos ha, 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 curr ently 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



### .

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XI. Level of Control of Emission Sources

The Wisconsin Department of Natural Res ources (WDNR) has a dopted a number of regulations to permanently control VOC em issions in eastern Wisconsin. Limited regulations were adopted by WDNR prio r to 2007 to control NOx emissions. Throughout the twenty counties considered fo r a nonattainment design ation, some of the regulations are specific to the Milwaukee-Racine ozone nonattainment area, which includes Kenosha, Racine, Milwaukee, Wauke sha, 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 st ationary sources of VOCs at the 25 ton level in the

Milwaukee-Racine Area to meet reasona bly 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 nonattainme nt area; and Door County was a rural transport (marginal) nonattainment area. Inspection and maintena nce, and VOC RACT were implemented in Kenosha and Sh eboygan 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 em issions 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 standard s 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 fo r existing sources are presented in NR 428.05. The requirements are applicable in the counties of Kenosha, Manitowoc, Milwaukee, Ozaukee, Racine, Sheb oygan, 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 appli cable for the counties of Kenosha, Milwaukee, Ozaukee, Racine, Shebo ygan, Washington, and Waukesha. These requirements are estimated to redu ce 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 fe deral rule to significantly reduce emissions from cars and light trucks, in cluding sport utility vehicles (SUVs).

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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 benef iting from the reductions in 2004.

• Side Benefits of Control of Hazard ous Pollutants (Wis. Adm. Code NR 445) : NR 445 applies to all stationary ai r contaminant sources, which may emit hazardous contaminants. Some sources may be exempt from these requirements

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

reduction of NOx emissions from the nonr oad 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 engi nes 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 Ar ea 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 th e 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 fe deral 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 Kenos ha 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 employ ers, 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 Trans portation 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 communicat ed to motorists using electronic messaging signs.

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• 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 en try and encourage ridesharing and transit

use.

• Guaranteed Ride Home (State and M ilwaukee 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 Ma dison from the Milwaukee area.

• Park & Rides : A system of park and ride f acilities throughout the area designed for meeting transit and carpools.

Areas without Ozone Precursor Controls

All counties outside of the ozone nonattainment area thr oughout the twenty counties considered for a nonattainment designation have no major point s ource control program for ozone precursor pollutants, which also cont ribute to fine particle levels in measured

nonattainment counties. These areas also do not have inspection and maintenance, reformulated gasoline or stage 2 vapor recovery.

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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 indica tes that all other counties should be designated as attaining the 2008 ozone standard.

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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 Im plications 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/mi 2 ) / 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.

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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).

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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 werepredominately 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 th e 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.

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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 Manitowocwhich 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 meteorol ogical data indicate that counties bordering or near to Door County c ontribute to nonattainment there. Based on the data summary above, the following tabl e (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 implicat ed by at least three of the nine factors analyzed, except Calumet, Kewaunee, and Ma nitowoc Counties. The primary factors that implicate the four countie s are air quality measurements , air pollution emissions, and meteorology-related transport patterns. Kewaunee and Ma nitowoc Counties, although only implicated by two factors, are include d because ozone monitoring data shows the fourth-highest 8-hour average daily ozone concentration exc eeded 75 ppb for two of the three years. Calumet County, although imp licated by three factor s, is not included

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because one implicating factor was transport patterns, not emissions, and another implicating factor was the lack of contro l 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 st arting 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 enforc ement of state and federal air pollution

rules.

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Sheboygan County Area

Table 12.3: Analysis of Factors for the Sheboygan County Area
(The Counties of Calumet, Dodge, Fond Du Lac, Je fferson, Kenosha, Manitowo c, Milwaukee, Ozaukee, Racine, Sheboygan, Walworth, Washington, Waukesha, and Winnebago)

Factor Sheboygan County Area Im plications 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).

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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/mi 2 ) / 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.

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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).

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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 werepredominately 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)

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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 Sheboyga n 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 meteorol ogical data indicate that counties bordering or near to Sheboygan C ounty contribute to nonattainment there. Based on the data summary above, the follo wing 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

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Option 1 includes all counties that are implicat ed by at least three of the nine factors analyzed, except Ozaukee, Wa shington, and Walworth Counties. The primary factors that implicate the seven coun ties are air quality measurements, air pollution emissions, population density and urba nization, population growth, and meteorology-related transport patterns. Washington and Ozauk ee 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 impli cating factor was transport patterns, not emissions, and another implicating factor was the lack of control on emission sources.

There is not much emissi on control in Walworth C ounty 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 st arting 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 enforc ement of state and federal air pollution

rules.

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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 Im plications 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/mi 2 ) / 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).

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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).

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Meteorology (weather & transport patterns) On days when the measured 1-

hour ozone concentration exceeded 75 ppb, the winds werepredominately 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 south east (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.

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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 cont ribute 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 su mmary 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 be cause 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. Guidan ce provided by the EPA states that that a CBSA or CSA should serve as the starting poi nt 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 enforc ement of state and federal air pollution

rules.

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XIII. References Cited

Code of Federal Regulations: Title 40, Part 50, Appendix I: Interpretation of the 8-Hour Primary and Secondary National Ambien t 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/GE OLWISC/TopoWiscLgCty.htm

Lake Michigan Air Director’s Cons ortium (LADCO), 2008. Round 5 Emission Inventory Summaries. Website: ht tp://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 climatol ogical perspective. Intern. Jour. of Climatology, Vol. 22 Issue 11, Pages 1347-1364.

National Weather Service (NWS), 2008a. Pr eliminary 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/climate normals/climatenormals.pl?directive= prod_select2&prodtype=CLIM84&subrnum=

U.S. Census Bureau, 2008. Census 2000 Su mmary 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 Agen cy, 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 Cent er (WRCC), 2008. Plot ti me history of single/multimonth precipitation/temperature. We bsite: http://www.wrcc.dri.edu/cgibin/divplot1_form.pl?4709

Wisconsin Department of Natural Resour ces (WI DNR), 2007. Memorandum from Scott Hassett, Secretary. Subject: Reasonab ly Available Contro l Technology (RACT) program for major sources of nitrogen oxides (NO

x 

### ) in the moderate ozone nonattainment

area and miscellaneous non-substantive correct ions to current ch. NR 428 requirements. April 9, 2007.

Wisconsin Department of Natural Resour ces (WI DNR), 2008. NOx and VOC Emission Summaries (1985-2007) Website: http://dnr.wi.gov/air/emission/histori cal_emissions/historical_emissions_nox.htm

Wisconsin Department of Transportation (W I 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/doc view.asp?locid =9&docid=7263

Wisconsin Demographic Services Cent er (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 De velopment (WI DWD), 2008a. Local Area Unemployment Statistics. Website: http://dwd.wisconsin.gov/oea/employme nt_by_industry/employment_by_industry.htm

Wisconsin Department of Workforce Development (WI DWD), 2008b. County-toCounty Worker Flow in Wisconsin. Website: http://dwd.wisconsi n.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 stat es that any area that does not meet the ozone standards, primary or secondary, should be designat ed 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 Environmen tal Protection Agency (EPA) desi gnate Door County as a “rural transport” nonattainment area for the following reasons:

• 

### EPA has previously stated that Door County meets the rural trans port area eligibility requirements of the Clean Air Act, Sec tion 182(h). [Docket ID No. EPA-HQ-OAR2007-0956]. There are two requirements to be elig ible 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 Metr opolitan Statis tical Area (CMSA). Second,

sources of VOC and NOx emissions in the ar ea must not make a si gnificant contribution

to the ozone concentrations measured in other areas.

• 

### Door County is not in or adjacent to a Metr opolitan 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 Wiscons in 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 stat es that any area that does not meet the ozone standards, primary or secondary, should be designat ed as a nonattainment area. Thus to meet the requirements of the Act, Kenosha County, or so me portion thereof, should be designated as a nonattainment area. The smallest portion of Kenos ha County (i.e., Pleasant Prairie Municipality) should be designated as a nonattainment for the following reasons:

• 

### The Chiwaukee ozone monitor in Kenosha Count y is located less than 1 mile from the

Illinois border in Pleasan t Prairie Municipality.

• 

### All major VOC point sources (> 100 tons/y ear) 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 (s ee figure). This sour ce, We Energies – Pleasant Prairie Station, accounted for appr oximately 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 concentrati on exceeded 75 parts per billion (ppb), the observed wind speed at the Chiwaukee oz one monitor had a southerly component 89.3% of the time from 2006 through 2008. Al so, air quality modeling data from the Lake Michigan Air Director’s Consor tium (LADCO) shows that the Milwaukee nonattainment counties (Kenosha, Milwauk ee, Ozaukee, Racine, Waukesha, andPage 

### 2 Washington) and the remainder of Wisc onsin only contribute 4.1% and 1.6%, respectively, of the attributable ozone c oncentration at the Chiwaukee ozone monitor when the 1-hour ozone concentration exceeds 75 ppb. The Chicago nonattainment

counties contribute 39.6% of the at tributable ozone concentration.

• 

### Based on 2005 emissions data from the Lake Michigan Air Director’s Consortium (LADCO), the Chicago nonattainment counties contribute approxima tely 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 moni tored 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.



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### 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



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### 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.



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### 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 forSheboygan 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.



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### 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.



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### 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



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### 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 we re 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 Cla ssification” response above.



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### 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.



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### 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 revise d 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 presen ted in Option 1 for the Door County area.