Respect 

ath Stepp, Sec tary 

isconsin Department of atural Resources 

cc: Scott Walker, Governor, State of Wisconsin 

State of Wisconsin 

DEPARTMENT OF NATURAL RESOURCES 

101 S. Webster Street 

Box 7921 

Madison WI 53707-7921 

Scott Walker, Governor 

Cathy Stepp, Secretary 

Telephone 608-266-2621 

Toll Free 1-888-936-7463 

TTY Access via relay - 711 

February 29, 2012 

Susan Hedman 

U.S. Environmental Protection Agency (EPA) - Region 5 

77 West Jackson Boulevard 

Mail Code: R-19J 

Chicago IL 60604 

Subject: Re: Wisconsin's 120-Day Letter for Ozone Designations 

Dear Regional Administrator Hedman: 

Thank you for the opportunity to provide comments on the U.S. EPA's recently proposed air quality designations 

for the 2008 ozone National Ambient Air Quality Standards (NAAQS). These comments are in response to your 

letter dated December 9, 2011 to Governor Scott Walker. We anticipate providing additional comments in regard 

to Kenosha County in response to your letter dated January 31, 2012 within the required 120-day time period. 

First, we agree with the "unclassifiable / attainment" designation for seventy of Wisconsin's seventy-two 

counties. Significant progress has been made in reducing ozone concentrations throughout Wisconsin and this 

designation acknowledges that achievement. Average statewide ozone design values have decreased from 77 

parts per billion (ppb) to 66 ppb just over the last five years. Recognizing our improving air quality is important 

given the associated public health benefits and economic burdens associated with nonattainment designations. 

Second, in regards to Sheboygan County, we recognize that the U.S. EPA proposed a "nonattainment" 

designation given their recorded design value of 78 ppb from 2008 — 2010. We appreciate that the U.S. EPA 

recognized in their technical support document that Sheboygan County and the adjacent counties all have 

"relatively low emissions" and furthermore, that "the low emission levels in the area indicate that longer range 

transport is the significant contributor to violations in the Sheboygan, WI area." Given the acknowledged low 

emissions in the area, imposing nonattainment status, along with its corresponding negative impacts on business 

and economic development, highlights a fundamental flaw in the regulatory structure contained in the Clean Air 

Act. 

Finally, we ask the U.S. EPA to finalize all necessary ozone implementation guidance as soon as practicable. In 

addition, in accordance with the proposed implementation guidance, we request Sheboygan County be designated 

as a marginal nonattainment area since it only exceeded the standard by 3 ppb. 

Thank you for consideration of these comments. If you have any questions please feel free to contact Bart 

Sponseller, Air Management Bureau Director, at (608) 264 — 8537 or Bart.Sponseller@wisconsin.gov . 

d nr.wi.gov 

wisconsin.gov Naturally WISCONSIN PRINTED 

ON RECYCLED 

PAPER 
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 Matt Moroney, Deputy Secretary, WDNR – AD / 8 

Patrick Stevens, Air and Waste Division Administrator, WDNR – AD / 8 

 Bart Sponseller, Air Management Bureau Director, WDNR – AM / 7 

Joseph Hoch, Regional Pollutant and Mobile Source Section Chief – AM / 7