WISCONSIN 

DEPT OF NATURAL RESOURCES 

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 

January 18, 2012 

Ms. Susan Hedman 

Regional Administrator 

U.S. Environmental Protection Agency 

77 West Jackson Boulevard, R-19J 

Chicago IL 60604-3507 

Subject: Wisconsin's Regional Haze State Implementation Plan (SIP), Excluding Best Available 

Retrofit Technology (BART) Implementation 

Dear Ms. Hedman: 

The Wisconsin Department of Natural Resources (WDNR) hereby submits its Regional Haze SIP, excluding BART 

implementation, for compliance with the federal Regional Haze Rule issued in 1999 and modified in 2005 (64 FR 

35714 and 70 FR 39104). Implementation of BART for protection of visibility was submitted under a separate SIP 

submittal dated January 18, 2012. The primary purpose of this SIP is to address 2018 reasonable further progress 

(RFP) goals for visibility protection in federal Class I Areas. 

The WDNR has the legal authority under Wisconsin law to adopt and implement these requested SIP revisions. 

Section 285.11 (6), Wis. Stats., authorizes the WDNR to develop and revise the SIP for prevention, abatement, and 

control of air pollution. The WDNR conducted a public hearing on the Regional Haze SIP on September 13, 2011. 

In accordance with the April 6, 2011 McCabe Memo, one paper copy of the SIP revision documents are enclosed. In 

addition, an electronic copy of these documents is provided as well on an enclosed CD. If you have any questions 

regarding this submittal, please feel free to call either Joseph Hoch at 608-267-7543 or Ralph Patterson at 608-267- 

7546. 

Sincerely, 

William B. Baumann, Acting Director 

Bureau of Air Management 

cc: Patrick Stevens — AD/8 

Joseph Hoch — AM/7 

Ralph Patterson — AM/7 

Cheryl Newton — U.S. EPA Region V (A-18J), 77 West Jackson Boulevard, Chicago, IL 60604 

Douglas Aburrano — U.S. EPA Region V (AR-18J), 77 West Jackson Boulevard, Chicago, IL 60604 

Jacqueline Nwia — U.S. EPA Region V (AT-18J), 77 West Jackson Boulevard, Chicago, IL 60604 

dnr.wi.gov 

wisconsin.gov Naturally WISCONSIN n

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ON RECYCLED 

PAPER 
Page 2 

Summary of Attachments: Hard Copy and Electronic 

Attachment 1 — U.S. EPA SIP checklist 

Attachment 2 — Regional Haze SIP Submittal 

Attachment 3 — Regional Air Quality Analyses for Ozone, PM 2.5 , and Regional Haze, April 25, 2008 

Attachment 4 — Proof of Public Hearing on September 13, 2011 and Summary / Response to Public Comments 
ATTACHMENT 1
EPA Region V 

Wisconsin SIP Submittal 

Completeness Review

Submittal Letter 

1. Signed by Governor’s Designee (Bill Baumann)? Yes X No 

2. Date of Submittal: January 18, 2012 

3. WDNR Person in charge of SIP submittal. 

Name: Ralph Patterson 

Telephone Number: (608) 267-7546 

 Fax Number: (608) 267-0560 

E-mail Address: Ralph.Patterson@wisconsin.gov 

4. WDNR Technical Person in charge of answering questions on SIP Submittal 

Name: Joseph Hoch 

Telephone: (608) 267-7543 

 Fax Number: (608) 267-0560 

E-mail Address: Joseph.Hoch@wisconsin.gov 

Incorporation Into Wisconsin Administrative Code

5. Is evidence that the State incorporated the revision into the Wisconsin Administrative Code 

supplied in this SIP package? 

 

Yes 

No (if No, explain) 

Not applicable X (if Not applicable, explain answer) 

 This SIP submittal is a non-rule submittal. 

6. The effective date of the regulation is or was: 

 

 Not applicable 

7. Are test methods/rules incorporated by reference correctly? (Has approval been obtained from the 

state Attorney General 

Yes 

No (if No, explain) 

Not applicable X (if Not applicable, explain answer) 

 This SIP submittal is a non-rule submittal. 

8. Has WDNR provided evidence that it has necessary legal authority under State law to adopt and 

implement the revision? Provide additional explanation (if necessary). 
2

 Yes X 

 No 

9. Did the State include a copy of the actual regulation or document for USEPA review? Provide 

additional explanation (if necessary). 

 Yes X 

 No 

10. Did the State provide evidence that it followed all of the requirements of its Administrative 

Procedures Act (ch. 227, Wis. Stats., Administrative Procedure and Review) in conducting and 

completing adoption/issuance of the revision? Provide additional explanation (if necessary). 

Yes 

No (if No, explain) 

Not applicable X (if Not applicable, explain answer) 

 This SIP submittal is a non-rule submittal. 

11. Did the State include evidence that Public Notice was given of the revision, including date of 

publication? Provide additional explanation (if necessary). 

 Yes X 

 No 

12. Did the State provide a copy of the certification that public hearings were held in accordance with 

the information provided in the public notice (copy of notarized Class I paper proof). Provide 

additional explanation (if necessary). 

 Yes X 

 No 

13. Does the submittal contain a compilation of public comments and the State’s response? Provide 

additional explanation (if necessary). 

 Yes X 

 No 

Technical Issues 

14. Name all the regulated pollutants affected by the revision. 

 Oxides of nitrogen (NOx) 

 Particulate Matter (PM) 

 Sulfur Dioxide (SO2) 

15. Does the submittal identify the designation, status of the attainment plan and attainment date for 

the area(s)? Provide additional explanation (if necessary). 
3

 Yes 

 No X 

 Not applicable. 

16. Does the submittal identify the location and types of affected sources? Provide additional 

explanation (if necessary). 

 Yes X 

 No 

 

17. Does the submittal quantify the changes in SIP-allowable emissions and estimate or quantify the 

changes in actual emissions from affected sources? Provide additional explanation (if necessary). 

 Yes X 

 No 

18. Has the State demonstrated that the NAAQS/PSD Increment/RFP demonstration/visibility will be 

protected if the revision is approved and implemented? Provide additional explanation (if 

necessary). 

 Yes X 

 No 

19. Has the State provided modeling information to support the revision. 

 Yes X 

 No 

20. Has the State provided evidence that emission limitations are based on continuous emission 

reduction technology? Provide additional explanation (if necessary). 

 Yes X 

 No 

21. Has the State provided evidence that the revision contains emission limitations, work practice 

standards and record keeping/reporting requirements where necessary, to ensure emission levels? 

Provide additional explanation (if necessary). 

 Yes X 

 No 

22. Does the submittal contain enforcement/compliance strategies including how compliance will be 

determined in practice, and at what frequency? Provide additional explanation (if necessary). 

 Yes X 

 No 

STATE APPROVABILITY CHECKLISTENFORCEABILITY 
4

USEPA USE ONLY 

SIP Package Number ___________ 

Date Received by USEPA ________________ 

Date Due_____________________________ 

State: WISCONSIN 
5

WDNR Information 

Subject Matter: Implementation of Protection of Visibility by Application of Best 

Available Retrofit Technology (BART) 

Applicability 

USEPA Question USEPA Requirement State Response 

What sources are being 

regulated? Clear discussion Any sources subject to Reasonable Further Progress (RFP) requirements. 

What are criteria for 

exemption? Clear discussion Little / no impact on visibility 

Is calculation procedure 

for exemption clearly 

specified? 

Supply example calculation or 

clear explanation of how to 

determine exemption (line by 

line, etc.) 

Yes. 

Is emission inventory 

listed in the background 

document of the 

attainment demonstration? 

Inventory including allowable 

and actual emissions in source 

category should be included, for 

enforcement purposes and 

independent of any Clean Air 

Act requirements, in the 

attainment demonstration if 

such data is necessary for 

determining baselines in 

regulations. 

Not applicable. 

Is the averaging time(s) 

used in the rule different 

from that of the ambient 

standard? 

The averaging time in the rule 

must be consistent with 

protecting the ambient standard 

in question. Normally, it should 

be equal to or shorter than the 

time associated with the 

standard. Longer term 

averaging is available only in 

limited instances provided that 

the ambient standard is not 

compromised. 

Not applicable (no ambient standard). 

What are the units of 

compliance (lbs VOC per 

gallon of solids applied 

less water, grains per 

standard cubic foot?) 

Clearly stated in the rule. Not applicable. 
6

USEPA Question USEPA Requirement State Response 

Is bubbling or averaging 

of any type allowed? If 

yes, state criteria. Could a 

USEPA inspector 

independently determine 

if the criteria were met?? 

Does USEPA have to 

approve each case? 

Explicit description of how 

averaging, bubbling, or 

equivalency is to be determined. 

VOC equivalency must be on a 

“solids applied” basis. Any 

method must be independently 

reproducible. Provision must 

be explicit as to whether 

USEPA case-by-case approval 

is required. If provision 

intended to be “generic” then 

USEPA bubble policy must be 

met. 

Not applicable. 

If there is a redesignation, 

will this change the 

emission limitations? If 

yes, which ones and how? 

Regulation may not 

automatically allow for self 

nullification upon redesignation 

of area to attainment. New 

maintenance demonstration 

required to order to drop 

regulation. 

Not applicable. 

Compliance Dates 

USEPA Question USEPA Requirement State Response 

What is the compliance 

date? 

The compliance date must not 

be later than the approved or 

about to be approved date of 

attainment unless emission 

reductions are not necessary for 

attainment. In some cases, it 

will be necessary for the 

regulation to specify dates in 

compliance schedules that are 

required to be submitted by 

source to state. 

RFP relies on current controls that are already 

in place. 

What is the attainment 

date? Clearly defined. Not applicable. 
7

Specificity of Conduct 

USEPA Question USEPA Requirement State Response 

What test method is 

required? 

Test method must be explicitly 

stated. Not applicable. 

What is the averaging time 

in the compliance test 

method? 

Averaging time and application 

of limit must be explicit. Not applicable. 

Is a compliance 

calculation or evaluation 

required? (i.e., daily 

weighted average for 

VOC). 

Clearly defined. No. 

If a compliance calculation 

is necessary, list the 

formula, period of 

compliance, and/or 

evaluation method. 

Formula must be explicit. Not applicable. 

Incorporation by Reference

USEPA Question USEPA Requirement State Response 

What is the state authority 

for rulemaking. Clearly stated. Not applicable (non-rule). 

Are methods/rules 

incorporated by reference 

in the right manner? 

Clearly stated. Not applicable (non-rule). 

Recordkeeping

USEPA Question USEPA Requirement State Response 

What records are required 

to determine compliance? Clearly stated. Records associated with current “on-the books” controls. 

In what form or units 

(lbs/gal, gr/dscf, etc.) must 

the records be kept? On 

what time basis 

(instantaneously, hourly 

daily)? 

Records to be kept must be 

consistent with units of 

compliance in the performance 

requirements, including the 

applicable time period . 

The records vary depending on what current 

control is being discussed. 

Does the rule affirmatively 

require the records be 

kept? 

There must be clearly defined 

and distinguishable from what 

constitutes a violation. 

Not applicable (non-rule). 
8

Exemptions

USEPA Question USEPA Requirement State Response 

List any exemptions 

allowed. 

Must be clearly defined and 

distinguishable from what 

constitutes a violation. 

Not applicable. 

Are the criteria for 

application clear? Clearly stated. Yes. 

Malfunction Provisions

USEPA Question USEPA Requirement State Response 

Are there any malfunction 

provisions in the rule? 

Rule must specify what 

exceedances may be excused, 

how the standard is to be 

applied, and who makes the 

determination. 

Not applicable. 
ATTACHMENT 2
1

REGIONAL HAZE STATE IMPLEMENTATION PLAN 

FOR WISCONSIN 

January 18, 2011 

Wisconsin Department of Natural Resources 
2

TABLE OF CONTENTS 

Part I. Executive Summary 3

Part II. Introduction 4

 Regulatory Background 4

 Regional Haze Rule and Applicable Wisconsin Requirements 5

Part III. Wisconsin Contribution to Visibility Impairment 7

Part IV. Wisconsin Implementation Plan Elements 9

 1. Regional Planning – MRPO and Regional Consultation 9

 2. Defined Baseline and Natural Visibility Conditions 11

 3. Emissions Inventory 13

 4. Best Available Retrofit Technology 20

 BART for EGU Sources 22

 BART for Non-EGU Point Sources 23

 5. Reasonable Progress Goals 26

 6. Long-term Strategy 36

 Emission Reductions Due to Ongoing Air Pollution Control Programs 36

 Additional Emission Limitations and Schedules of Compliance 37

 Potential Future Projects and Impacts 37

 Other Factors Considered 38

 Anticipated Net Effect on Visibility 38

 7. Periodic Implementation Planning and Adequacy 39

 8. Monitoring Strategy 40

Part V. List of Appendices 42
3

Part I. Executive Summary 

The Wisconsin Department of Natural Resources (WDNR, or Department) submits this State 

Implementation Plan (SIP) to address requirements of the federal Regional Haze Rule (referred 

to hereafter as the “Haze Rule”) for reducing visibility impacts to federal Class I areas caused by 

man-made sources. The Haze Rule requires consultation between the states, tribes, and Federal 

Land Managers (FLMs) who are responsible for managing the Class I areas. Technical analyses 

show that sources in Wisconsin impact visibility at the Isle Royale National Park and Seney 

Wilderness Area in northern Michigan, and the Boundary Waters Canoe Wilderness Area and 

Voyageurs National Park in northern Minnesota. 

The requirements for Wisconsin fulfilled by this Haze SIP submittal include: (1) Demonstrating 

fulfillment for regional planning and consultation in cooperation with other affected states; (2) 

providing the baseline and natural visibility conditions for Class I areas affected by Wisconsin; 

(3) meeting near-term reasonable progress goals (RPG) for reducing haze precursor pollutants; 

(4) providing a long-term strategy for visibility improvement; (5) implementing Best Available 

Retrofit Technology (BART) requirements for the subset of major emission sources shown 

subject to BART; and (6) addressing direct haze monitoring for Class I areas and indirect 

monitoring used for technical support and analysis of progress in reducing haze. 

For purposes of fulfilling regional haze and other fine particulate matter (PM2.5) requirements, 

several Midwest states exhibiting contribution, including Wisconsin, Illinois, Indiana, Michigan 

and Ohio, participated in the Midwest Regional Planning Organization (MRPO) and pursued 

consultation with Minnesota. The MRPO performed air quality modeling to help the states 

identify their relative levels of contribution to haze and the scope of emission reductions 

necessary to meet the reasonable progress goals. The assessments addressed known and 

potential control strategies established during 2005 to 2007. 

This document describes Wisconsin’s strategy for meeting the reasonable progress goals by 2018 

for Class I areas which relies primarily on existing control programs and implementation of 

BART for affected major sources. In this SIP, Wisconsin commits to evaluate reasonable 

progress for every 10 year period beginning with the period after 2018. In addition, Wisconsin 

commits to re-evaluating RPG for meeting the first period RPG goals as part of the 2013 

required review. These periodic regional progress evaluations are to meet the eventual goal of 

achieving pristine visibility conditions in these protected areas by 2064 as required under the 

Haze Rule. 

Wisconsin is meeting the requirement for a "long-term strategy" under this SIP through the 

enforceable control programs committed in meeting the RPG requirement and noting that 

additional emission reductions are anticipated from certain future air regulatory programs and 

revised air quality standards. Together, these two elements are fully anticipated to result in a 

"uniform rate of visibility improvement" consistent with the goal of reaching pristine conditions 

before 2064. Additionally, Wisconsin will continue its efforts to maintain monitoring networks 

and emissions inventories, participate in regional planning and consultation, and will provide the 

required progress reports and future SIP revisions for the Regional Haze Rule.
4

Part II. Introduction

The following describes Wisconsin’s fulfillment of State Implementation Plan (SIP) 

requirements established by the federal Regional Haze Rule for purposes of remedying and 

protecting visibility in designated federal Class I areas. The Regional Haze Rule was adopted on 

July 1, 1999 (64 FR 35714) and incorporated under 40 CFR part 51.308 as part of Subpart P – 

Protection of Visibility. States subject to the Haze Rule were required to submit their SIPs no 

later than December 17, 2007. 

Regulatory Background 

The Clean Air Act (CAA) under section 169A(b)(2) requires each state in which a Class I area 

resides – and any state from which emissions are reasonably anticipated to cause or contribute to 

impairment of visibility of such a Class I area – to make reasonable progress towards remedying 

the impairment due to man-made air pollution. Two discreet components of reasonable progress 

requirements are the implementation of Best Available Retrofit Technology (BART) as 

expeditiously as practicable for certain major emission sources, and establishing a long-term (10 

to 15 year) strategy for making continued visibility improvements. The U.S. Environmental 

Protection Agency (EPA) has designated 156 protected national and state parks and wilderness 

areas as applicable Class I areas based on importance of visibility in those areas. 

In conjunction with these state requirements, section 169B of the CAA directs EPA to study the 

chemistry of visibility impairment and identify sources or regions contributing to the impairment 

of the Class I areas. Based on this information, EPA is then required to establish Visibility 

Transport Regions and Commissions consisting of states which together are found to contribute 

to a Class I area visibility degradation. In 1999, EPA concluded that certain groups of states do 

act together in impacting visibility, and therefore formed regional planning organizations (RPOs) 

in order to fulfill visibility requirements on a coordinated basis. Specifically, EPA mandated 

Wisconsin as part of the Midwest RPO, which includes the states of Illinois, Indiana, Ohio, 

Michigan, and Wisconsin. The CAA requires such RPOs to perform technical assessments and 

to cooperatively meet visibility requirements for the affected Class I areas. Analysis performed 

by the Midwest RPO confirmed that Wisconsin emission sources do contribute to visibility 

impairment of MRPO Class I areas in Michigan and Minnesota.1

 Participating in an RPO does 

not alleviate any state's obligation towards other affected Class I areas. 

To implement the CAA requirements for the CAA Visibility program, EPA established 40 CFR 

Subpart P "Protection of Visibility." EPA structured this regulation to address two principal 

forms of identified visibility impairment: 

1) "Reasonably Attributable Visibility Impairment" – impairment attributable to a single 

source or small group of sources. This portion of the visibility program specifically 

applies to states with Class I areas, and outlines requirements for reasonable progress in 

 

1

 Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Technical Support Document. LADCO. 

Online. http://www.ladco.org/reports/technical_support_document/tsd/tsd_version_iv_april_25_2008_final.pdf . 

September 15, 2010. 
5

reducing haze and adopting long-term strategies - both of which include BART and new 

source review requirements. 

2) "Regional Haze" – widespread haze from a multitude of sources which impairs visibility 

in every direction over a large area. This portion of the Visibility program implements 

requirements similar to Reasonably Attributable requirements, but provides mechanisms 

for extending requirements to contributing states and implementing controls as necessary 

across broad source categories, including area and mobile source sectors. The Regional 

Haze program also adopts a schedule of remedying man-made visibility impacts in the 

Class I areas by 2064. 

Wisconsin, being identified as a contributing state, is specifically subject to requirements under 

the Regional Haze program, 40 CFR Part 51.308. 

Regional Haze Rule and Applicable Wisconsin Requirements 

The Regional Haze Rule, 40 CFR Part 51.308, requires all states with Class I areas – and states 

contributing to those areas – to submit SIPs by December 17, 2007. On January 15, 2009, EPA 

made a finding that 37 states (including Wisconsin), the District of Columbia, and the Virgin 

Islands failed to submit all or a portion of their Regional Haze SIP. The notice established a 

deadline of January 15, 2011 by which states must fulfill SIP submittal requirements or EPA 

would issue a Federal Implementation Plan (FIP). Wisconsin, along with the other MRPO states, 

are submitting delayed Regional Haze SIPs beyond the 2007 deadline. Delays allowed states to 

take advantage of federal and state emission reduction requirements including the federal CAIR 

program, perform applicable BART determinations, and complete the analysis of emission 

reductions and resulting improvements to regional visibility. 

The Regional Haze Rule requires reasonable progress towards improving visibility, with the goal 

of achieving natural visibility conditions in the protected Class I areas by 2064. Contributing 

states are required to participate in a regional planning and consultation process as identified by 

EPA. Each affected state must submit an initial plan to achieve reasonable progress goals, which 

are part of a long-term strategy, by 2018. These goals are submitted to EPA for approval, but are 

not directly enforceable. Rather, the primary requirement is ensuring that each state is 

addressing its share of emission reductions in a reasonable manner as established through the 

regional planning and consultation process. 

EPA can implement FIP elements if they find a state is deficient in meeting rate of progress or 

that additional reasonable control options are available. Rather than taking that approach, EPA 

has committed to establishing federal control programs – such as the Clean Air Interstate Rule 

(CAIR) and its intended replacement, the Cross-State Air Pollution Rule (CSAPR) – to reduce 

regional pollutants. The state must re-assess and revise an incremental progress plan every 10 

years, with 5 year intermediate controls progress assessments thereafter to meet continued 

reasonable progress goals for natural conditions by 2064. The review of control programs and 

meeting RPG goals for the first 10 year period is due in 2013. 
6

The Regional Haze Rule provides several general provisions that states must address in the SIPs. 

Pursuant to 40 CFR 51.308, these requirements include: (1) Participating in a regional planning 

and consultation process; (2) setting reasonable progress goals; (3) calculating baseline and 

natural visibility conditions; (4) providing a long-term strategy for regional haze; (5) 

implementing Best Available Retrofit Technology (BART) for specific emission sources; and (6) 

providing a monitoring strategy and other implementation plan requirements. For contributing 

states like Wisconsin, meeting certain plan elements, such as RPG, is based on meeting the 

state's share of emission reductions as determined through the RPO and consultation process (see 

40 CFR 51.308(d)(3)(ii)). This Haze SIP submittal is Wisconsin’s first 10-year plan for meeting 

reasonable progress goals. 
7

Part III. Wisconsin Contribution to Visibility Impairment 

The Midwest RPO process confirmed that participating states, including Wisconsin, contribute to 

visibility impacts of Class I areas in Michigan and Minnesota. To assess the contribution, the 

MRPO first performed back trajectory analysis of historic air flow and meteorological conditions 

for 2000 through 2005. To build on this analysis and assess relative impacts, the MRPO then 

conducted photochemical modeling using the Comprehensive Air quality Model with extensions 

(CAMx) for visibility impacts in 2018 based on several versions of emission inventories 

projected to represent base conditions and known emission controls (refer to Part IV, Section 3 

below). Examination of multiple base years provides for a more complete technical assessment. 

Details of this analysis and apportionment of contribution are documented in Appendix 1 of the 

MRPO document, “Regional Haze in the Midwest: Summary of Technical Information”.2 A 

summary of results and a list of all Class I areas potentially impacted by the MRPO states is 

included in Appendix B. 

In identifying contribution, the MRPO states considered 2% or more of light extinction as 

significant and impacting visibility. For purposes of MRPO and the regional haze analysis, light 

extinction is measured in deciviews (dv). The results of the back trajectory analysis and 

photochemical modeling, summarized in Table 1, show Wisconsin contributes more than 5% 

light extinction to all four Class I areas within Michigan and Minnesota. For these areas 

Wisconsin's average annual impact to visibility is estimated to range from 6 to 18%, depending 

on the methodology and year(s) of concern. The Class I areas identified as impacted by 

Wisconsin emissions are the Isle Royale National Park, Seney Wilderness Area, Boundary 

Waters Canoe Area, and Voyageurs National Park (refer to Appendix A for locations). Based on 

this analysis of visibility impact, Wisconsin is subject to the Regional Haze Rule and must fulfill 

implementation plan requirements relative to these four Class I areas. 

Appendix B of the MRPO analysis also shows Wisconsin potentially contributing more than 2% 

visibility impact to Class I areas in Arkansas and Missouri. However, according to the criteria 

established by the Arkansas-Missouri RPO for that area only Illinois, Indiana, and Ohio are 

identified as significant contributors. It should be noted that emission reduction measures which 

aid Wisconsin in meeting its MRPO Regional Haze requirements will also aid to decrease 

visibility impacts at any other Class I areas, including those addressed by the Arkansas-Missouri 

RPO. 

 

2

 Regional Haze in the Midwest: Summary of Technical Information. LADCO. Online. 

http://www.ladco.org/reports/rpo/consultation/products/regional_haze_in_the_upper_midwest_summary_of_technic

al_information_v2.2_feb_22_2008.pdf. September 15, 2010. 
8

Table 1 – Wisconsin Culpability to Visibility Impairment in Northern Class I Areas

State 

Back-trajectory 

Analysis (2000-2005 

data) 

CAMx Modeling 

2018 Emissions 

(Round 4)1

CAMx Modeling 

2018 Emissions 

(Round 5) 2

Boundary Waters 

Illinois 2.7% 5.2% 5.1% 

Indiana 1.2% 2.9% 3.9% 

Michigan 0.7% 3.4% 4.8% 

Minnesota 37.6% 30.5% 23.5% 

Wisconsin 10.6% 10.4% 10.9% 

Isle Royale 

Illinois 7.0% 8.7% 

Indiana 5.6% 5.2% 

Michigan 12.7% 13.4% 

Minnesota 14.1% 9.5% 

Wisconsin 

N/A 

12.6% 10.9% 

Seney 

Illinois 9.7% 6.3% 7.9% 

Indiana 2.2% 9.6% 11.6% 

Michigan 14.7% 13.8% 18.1% 

Minnesota 3.8% 4.8% 1.6% 

Wisconsin 8.4% 13.8% 18.1% 

Voyageurs 

Illinois 1.2% 3.0% 7.1% 

Indiana N/A 1.6% 4.6% 

Michigan 1.6% 2.0% 4.9% 

Minnesota 36.9% 35.0% 31.0% 

Wisconsin 9.7% 6.3% 7.9% 

Reference: “Regional Haze in the Midwest: Summary of Technical Information”, MRPO 2008 

1

 Round 4 modeling uses 2002 base year data for conducting modeling 

2

 Round 5 modeling uses 2005 base year data for conducting modeling 
9

Part IV. Wisconsin Implementation Plan Elements 

As described for the Regional Haze requirements, Wisconsin must demonstrate implementation 

or fulfilling of specific Regional Haze plan elements as identified by 40 CFR 51.308(d) and (e). 

This section is intended to make this demonstration and presents the following plan elements: 

1. Regional Planning - MRPO and Regional Consultation 

2. Defining Baseline and Natural Visibility Conditions for Affected Class I Areas 

3. Visibility Related Emissions Inventory 

4. Best Available Retrofit Technology (BART) 

5. Reasonable Progress through 2018 

6. Long-Term Strategy though 2018 

7. Periodic Implementation Planning and Adequacy 

8. Monitoring Strategy 

1. Regional Planning - MRPO and Regional Consultation 

Under the Regional Haze Rule, states contributing to visibility impairment of a Class I area are 

required to consult with the affected states in meeting obligations for their share of emissions. 

The consultation process is required to occur between the states responsible for the Class I areas, 

the Federal Land Managers (FLMs), U.S. EPA, and other affected parties. Wisconsin fulfilled 

these requirements by participating in the Midwest RPO process, as described below, and by 

meeting the current requirements for Reasonable Progress and Long Term Strategy as described 

in sections 5 and 6. 

In 1999, EPA formed the RPOs to address Regional Haze requirements and designated 

Wisconsin as part of the Midwest RPO which is targeted to address Class I areas in Minnesota 

and Michigan. The MRPO includes the states of Illinois, Indiana, Michigan, Ohio, and 

Wisconsin, and directly consulted with Minnesota. The MRPO is organized as follows: 

 Policy Steering Committee consisted of the Environmental Directors of the member states, 

tribal leaders, FLMs, and the Regional Administrator of U.S. EPA - Region 5. The Policy 

Steering Committee provided the overall policy direction for the MRPO, and met, as needed, to 

oversee the progress of the effort. 

 Technical Steering Committee consisted of the Directors of the Air Quality offices of the 

member states, plus tribal representatives, FLMs, and the Director of the Air and Radiation 

Division of U.S. EPA - Region 5. The Technical Steering Committee was responsible for the 

management of the regional planning effort, and met on a regular basis to carry out these 

duties. 

 Project Team consisted of representatives of the member states, participating tribes, FLMs, 

and U.S. EPA to implement the directions of the Technical Steering Committee and to guide 

the technical aspects of the planning effort. The Project Team met on a regular basis. 
10

Through the MRPO, Wisconsin has participated in consultations convened by Minnesota to 

address the Boundary Waters and Voyageurs Class I areas and consultations convened by 

Michigan through the Lake Michigan Air Directors Consortium (LADCO) and the Midwest RPO 

for the Isle Royale and Seney Class I areas. These consultations also included the Central 

Regional Air Planning Association (CENRAP), and the Western Regional Air Partnership 

(WRAP) along with FLMs and U.S. EPA representatives involved with these Northern Class I 

areas. This group engaged in analysis of visibility conditions and control strategies needed to 

improve visibility at these four Class I areas.

The MRPO process additionally addressed Wisconsin's obligations for planning and consultation 

relative to all other non-MRPO Class I areas. For these other Class I areas, the MRPO 

conducted technical analysis of contribution and consulted with the other regional RPOs on these 

findings. Specifically, Wisconsin worked with states from the Mid-Atlantic, Northeast Visibility 

Union (MANE-VU) region, to address regional haze issues affecting Acadia National Park and 

Moosehorn Wilderness Area in Maine, Great Gulf Wilderness Area in New Hampshire, 

Brigantine Wilderness Area in New Jersey, and Lye Brook Wilderness in Vermont. Wisconsin 

and the MRPO also participated in the consultation process established by CENRAP to develop 

coordinated strategies for Class I areas in the Central states, including Mingo and HerculesGlades in Missouri, and Upper Buffalo and Caney Creek in Arkansas. Through these 

consultations, Wisconsin was determined not to be a significant contributor to any other Class I 

area at this time. 

In meeting the Haze Rule requirements for the individual MRPO states and for regional planning 

and consultation, the MRPO process addressed the following major tasks: 

 Developed regional emissions inventories (historic and future); 

 Determined background and natural visibility conditions for MRPO Class I areas; 

 Technical analysis of each states contribution to visibility impairment for all Class I areas; 

 Determined which pollutants are major contributors and visibility precursors; 

 Performed trajectory and photochemical air quality modeling; 

 Prepared technical support documents for BART control options; 

 Evaluated regional control options for reducing visibility impairing pollutants; 

 Performed technical analysis and modeling for purposes of regional visibility impacts and 

reasonable progress obligations through 2018 for the MRPO Class I area. 

Full documentation of the MRPO process, including meeting minutes, technical reports, 

modeling results, can be found at http://www.ladco.org. Major work products include: 

 Regional Haze Technical Support Document; 

 List of Class I Areas Impacted; 

 Regional Haze in the Upper Midwest: Summary of Technical Information (February 2008); 

 BART Control Strategy Evaluations; 

 Reasonable Progress for Class I Areas in the Northern Midwest – Factor Analysis (July 

2007); 

 SIP Modeling Emissions Inventories; 
11

 Identification and Evaluation of Control Measures for EGUs and Non-EGUs, Mobile 

Sources; 

 Integrated Planning Model (IPM) Summaries 

2. Defined Baseline and Natural Visibility Conditions 

The Regional Haze Rule requires that baseline and natural visibility conditions be established for 

the affected Class I area (40 CFR 51.308(d)(2)). The baseline represents the current level of 

visibility impact and is defined as the visibility seen for the 20% best and worst days for each 

Class I area. Natural conditions were estimated from the distributions of pollutants measured 

during the baseline scaled to estimates of annual average natural conditions made by Trijonis3. 

Under the rule, reducing visibility impacts to natural conditions by 2064 at all times represents 

the objective to meet the Clean Air Act’s goal of eliminating visibility impairment.

The MRPO aided Michigan and Minnesota in determining both Baseline and Natural Visibility 

conditions, provided in Table 2, for their respective Class I areas. As required by the Haze Rule, 

the MRPO analyzed monitored data for 2000 through 2004. The baseline visibility condition 

values were derived using the average for the 20% worst and 20% best days for each year. 

These values were calculated using the reconstructed light extinction equation revised by the 

IMPROVE Steering Committee in 2005. Additional details on pollutant contributions at the 

Class I areas may be found in the MRPO technical support document (TSD). In particular, the 

MRPO states affecting the Northern Class I areas agreed that the priority emissions and sources 

are SO2 from point sources (EGUs and non-EGUs); NOX from point sources (EGUs and nonEGUs) and mobile sources; and NH3 from agricultural operations (see Reasonable Progress 

Goals at Section 5). 

The U.S. EPA guidance for the Regional Haze Rule directs states to determine a “uniform rate of 

visibility improvement” (URI) that would be maintained during each decade-long 

implementation period in order to attain natural visibility conditions by 2064. The URI can be 

viewed as a “glide path” from the baseline to natural visibility conditions (Figure 1). Under the 

Haze Rule, moving from the baseline to natural conditions is used as a primary measure in states 

for meeting reasonable progress and long-term strategy (see Sections 5 and 6). 

 

3 Copeland, S. A., Pitchford, M. L., and Ames, R. B. 2008. Regional haze rule natural level estimates using the 

revised IMPROVE aerosol reconstructed light extinction algorithm. Presented at the Air & Waste Management 

Association Visibility Specialty Conference, Moab, April 2008.
12

Table 2 – Baseline and Natural Visibility Conditions for Northern Class I Areas 

 20% Worst Days Average 

2000 2001 2002 2003 2004 

Baseline 

Value (2000-

2004 average) 

Natural 

Conditions 

Isle Royale 20.53 23.07 21.97 22.35 20.02 21.59 12.36 

Seney 22.94 25.91 25.38 24.48 23.15 24.37 12.65 

Boundary Waters 20.20 20.04 20.76 20.13 18.18 19.86 11.61 

Voyageurs 19.55 18.57 20.14 20.25 18.87 19.48 12.05 

20% Best Days Average 

2000 2001 2002 2003 2004 

Baseline 

Value (2000-

2004 average) 

Natural 

Conditions 

Isle Royale 6.49 7.16 7.07 6.99 6.12 6.77 3.72 

Seney 6.50 6.78 7.82 8.01 6.58 7.14 3.73 

Boundary Waters 6.00 6.92 7.00 6.45 5.77 6.43 3.42 

Voyageurs 7.01 7.12 7.53 7.68 6.37 7.14 4.26 

Reference: MRPO TSD, 2008 

Figure 1 – Visibility “Glide Paths” for Northern Class I Areas 
13

3. Emissions Inventory 

Modeled Emissions 

Under 40 CFR 51.308(d)(4)(v), a state is required to prepare a statewide emission inventory of 

pollutants which are reasonably anticipated to cause or contribute to visibility impairment in any 

mandatory Class I area. These pollutants are sulfur dioxide (SO2), nitrogen oxides (NOX), 

particulate matter (PM10 and PM2.5), ammonia (NH3), and reactive organic gases (ROG). The 

MRPO facilitated a process to compile inventories for 2005 actual emissions and several cases of 

future emissions projected through 2018 for the region. This inventory was then used to model 

air quality and visibility impacts for the affected Class 1 areas. 

A summary of 2005 statewide visibility related emissions by source category is provided in 

Table 3A. The largest source of SO2 and NOX emissions in 2005 is the electric generating sector 

(EGUs), followed next in quantity by non-EGU (industrial stationary sources) for SO2 and nonEGU and mobile sources for NOX. This 2005 inventory provided the basis for growth and 

control scenarios projected out to 2018 as further described below. 

The procedures followed in compiling the 2005 emissions are briefly described here, with 

detailed information provided in Section 3 of the MRPO TSD. EGU and non-EGU point 

stationary source emissions are as reported by the sources to the 2005 Wisconsin Air Emissions 

Inventory (AEI) database. EGU emissions are corroborated by the EPA Clean Air Markets 

Division (CAMD) EGU database. On-road mobile source emissions were prepared using the 

CONCEPT model and using transportation data supplied by Wisconsin Department of 

Transportation.4 Off-road mobile source emissions were estimated using EPA’s National Mobile 

Inventory Model (NMIM2005). Railroad and marine source emissions were estimated using 

local data for 2005.5 Emissions for air sources were estimated by WDNR using the Federal 

Aviation Administration’s Emission Dispersion and Modeling System. Area source emissions 

were estimated using EPA’s Emission Inventory Improvement Program. 

 

4

 LADCO On-Road Emissions Inventory Development Using Concept MV. Online. 

http://www.ladco.org/reports/rpo/emissions/NREL_LADCO_FinalReport09.pdf. December 15, 2010. 5

 LADCO Nonroad Emission Inventory Project for Locomotive, Commercial Marine and Recreational Marine 

Emission Sources. Online. 

http://www.ladco.org/reports/rpo/emissions/nonroad_locomotive_commercial_marine_recreational_marine_final_re

port_environ.pdf. December 15, 2010. 
14

Table 3A – Wisconsin Statewide Emissions for 2005 

Category NH3 NOX PM10 PM2.5

1 SO2 ROG 

EGU 510 71,416 3,970 3,348 181,430 1,667 

Non-EGU 332 36,030 7,590 48 59,778 27,186 

Area 2,242 21,906 41,596 41,339 8,909 113,965 

On-road

(tons/day)2 6,501 150,975 1,155 2,574 3,036 57,783 

Off-road 52 48,962 5,409 5,145 4,955 97,237 

Animal 113,611 0 0 0 0 0 

MAR 12 20,047 774 689 2,448 1,392 

Total 123,260 349,336 60,494 53,143 260,556 299,230 

MAR = Commercial marine, aircraft and railroad sectors 

1 WDNR staff used the EGU PM2.5/PM10 ratio in Table 3B to estimate the EGU PM2.5 emissions. 

The original modeling assumed a value of “0” for EGU PM2.5 emissions. 

2 WDNR staff used the tons/day estimate from the MRPO and a multiplier of 330 (based on 

multipliers developed using the MOBILE6.2 model for the year 2002) to estimate annual on-road 

emissions. 

The 2005 emissions inventory is projected to 2018 for purposes of evaluating reasonable 

progress goals. This projection of emissions accounted for all known on-the-books requirements 

and control equipment installations as of 2007 (see Appendix C for the full list of on-the-books 

controls). The activity level of all source categories, except on-road mobile and EGUs, are 

projected using the Economic Growth and Analysis System (EGAS) and/or Energy Information 

Administration (EIA) energy system projections. On-road mobile sources are projected using 

MOBILE6, while EGU emissions are estimated using fuel consumption and operation projected 

by the Integrated Planning Model (IPM), version 3.0. The total projected emissions for 

Wisconsin are summarized by sector in Table 3B. 

This base on-the-books projection of 2018 emissions includes the IPM results for EGUs meeting 

the CAIR rule. Therefore this on-the-books inventory also addresses Best Available Retrofit 

Technology (BART) requirements for Wisconsin EGUs (see s. NR 433.05(1)(e), Wis. Adm. 

Code). Projected SO2 and NOX emissions for non-EGUs in Wisconsin are based on BART 

controls at several sources (including Georgia Pacific paper mill in Green Bay) and EIA 2005 

projections for industrial coal use through 2020. 
15

Table 3B – Projected Wisconsin Statewide Emissions for 2018 (On-the-Books) 

Category NH3 NOX PM10 PM2.5 SO2 ROG 

EGU 683 56,158 8,827 7,445 127,073 1,179 

Non-EGU 419 30,116 9,109 47 32,831 34,204 

Area 2,856 22,804 50,047 49,744 7,998 109,427 

On-road (tons/day)1 7,326 45,705 1,221 1,287 660 22,572 

Off-road 58 25,611 2,712 2,555 70 60,720 

Animal 103,388 0 0 0 0 0 

MAR 8 9,346 315 275 1,157 704 

Total 114,738 189,741 72,231 61,353 169,790 228,806 

MAR = Commercial marine, aircraft and railroad sectors 

1 WDNR staff used the tons/day estimate from the MRPO and a multiplier of 330 (based on 

multipliers developed using the MOBILE6.2 model for the year 2002) to estimate annual on-road 

emissions. 

Overall, significant decreases from 2005 emissions are projected for SO2 and NOX based on the 

2018 on-the-books controls. SO2 emissions are projected to decrease by 35% and NOX

emissions decrease by 46%. Large decreases in SO2 emissions are projected from 

implementation of a combination of fuel switching and emission controls in the EGU sector 

(30%) as well as a multi-faceted reduction in SO2 emissions from the non-EGU sector (55%). 

Decreases are also projected for NOX in these two sectors: 21% at EGUs and 16% at non-EGUs. 

Mobile source (on-road and off-road sources) controls are projected to result in significant NOX

emissions reductions of 64%. For the other pollutant emissions: PM10 and PM2.5 emissions are 

projected to increase, and ROG and NH3 emissions are projected to decrease. The emissions 

increase in PM10 and PM2.5 is deemed by WDNR to be insignificant relative to the visibility 

improvements projected from reduction of SO2 and NOX emissions. 

Adjusted Emissions 

Since the EGU sector is the largest source of emissions, additional EGU emission cases are 

evaluated in order to determine the robustness of meeting the RPG goals for the first 10 year 

period. For direct comparison and identification of EGU cases addressed by the modeled 

visibility impact runs, refer to Table 4. Of particular note is the decrease seen in actual 

emissions between 2005 and 2010. This decrease is a result of both added pollutant control 

systems and decreased energy consumption related to the economy. In particular 2009 was the 

first year for CAIR NOX requirements and reflects a recent historic low in annual electricity 

usage. 

 

Additional cases were developed for the EGU sector by MRPO and WDNR staff to compare 

emission reductions (see Table 4). Case A includes the on-the-books controls from EGU’s – 

these emission reductions are reflected in Table 3B above. In Case B, WDNR staff performed a 

“simple emissions growth” for EGU emissions from 2010 to 2018. For this projection, WDNR 

staff first assumed a 1% per year growth in peak demand for Wisconsin electricity consumption 
16

from 2010 to 2018. Then the projection was adjusted to reflect committed SO2 controls as of 

May 2011 (see also Figure 2).6

 The adjustments reflect an assumed 90% SO2 control efficiency 

for controls installed or committed at the following units: Alliant Energy – Columbia Units 1 and 

2; Dairyland Power – Genoa Unit 1 and John P. Madgett Unit 1; WE Energies – South Oak 

Creek Units 5, 6, 7 and 8. It should be noted that the emission reductions in the 2018 “simple 

emissions growth” estimate are based on a combination of controls and reduced electricity 

consumption related to both economic downturn and demand reduction effort. The specific 

effect on long-term emissions due to either factor – current economic conditions or demand 

reduction – cannot be specifically identified but the overall affect should not be discounted in 

this analysis. 

Note, the WDNR recently became aware that SO2 control is not committed at this unit. To 

reflect the non-committed control at JPM, adjustments will be made to two cases of projected 

2018 emissions in Table 4 (p. 17): Case B (Simple Emissions Growth) is increased from 70,528 

to 75,007 annual tons SO2; Case D (Committed Controls – updated will do) is increased from 

105,228 to 106,804 annual tons SO2. WDNR maintains that even with the increased emissions 

from JPM, Wisconsin meets RPG due to the lower emissions allocations under the CSAPR 

compared to CAIR and the proposed CATR.

An additional 2018 emissions projection, referred to as Case C, is similar to Case A in reflecting 

on the books control requirements as well as additional controls committed to by EGUs that 

Wisconsin was aware of as of 2007, such as switching from coal to gas or the We Energies 

consent decree. However, Case C does not include the controls projected by IPM in meeting the 

CAIR rule beyond those already committed for operation. This approach reflects the open 

trading market structure of the CAIR program with no strict requirement for meeting reductions 

locally. That is why Case C, although lower than 2005 emissions, results in higher emissions 

(SO2 only) than the Case A on-the-books emissions estimate. Case D is presented to reflect the 

Case C control scenario but updated to reflect controls committed to by EGUs as of May 2011 in 

response to CAIR/CSAPR and EGU MACT. Both Case C and D are based on IPM 3.0 fuel 

projections. 

As noted in the discussion of BART below (Section 4), the Cross-State Air Pollution Rule 

(CSAPR) is intended to replace CAIR requirements. Under the finalized CSAPR rule (76 FR 

48208, August 8, 2011) the 2014 emissions budgets for Wisconsin are 28,572 tons for NOx and 

38,117 tons for SO2. Under a current proposal (76 FR 63860, October 14, 2011), the 2014 

emission budgets for Wisconsin may be increased to 31,045 tons for NOx and 45,874 tons for 

SO2. 

Similar or greater emission reductions are anticipated in Wisconsin under the CSAPR restricted 

trading programs as compared to the open market trading under CAIR. Case E represents 

Wisconsin emission allocations from the emission budgets that were initially proposed for the 

CSAPR (i.e., the Clean Air Transport Rule (CATR) proposal). It should be noted that these 

CATR emission budgets have a trading limitation of 10% (i.e. even under possible trading 

scenarios, SO2 emissions would remain below 79,000 tons and NOx below 39,000 tons). Note 

that the 2014 CATR projections were very close to the simple emissions growth 2018 projection 

 

6

 Draft Strategic Energy Assessment. Wisconsin Public Service Commission. October 2010. 
17

in case B (70,528 tons SO2 and 36,047 tons NOx). To ensure continued fulfillment of Regional 

Haze requirements Wisconsin will re-evaluate projected emissions when CSAPR emission 

budgets and implementation requirements are finalized,. 

Cases A, C, D and E use the IPM CAIR/CATR modeling, which has the benefit of showing 

emissions under control programs without depressed electricity demand, and therefore are 

anticipated to reflect a conservatively high estimate of EGU sector emissions. Conversely, Case 

B of simple emissions growth and control illustrate that EGU sector emissions may be 

considerably lower than the IPM-based emission cases A, C and D, and on target with the IPMbased emission Case E. Including these various 2018 emissions estimates gives a range of 

emission reductions from EGUs to be considered for meeting reasonable progress goals for 

visibility improvement (see Section 5). None of the cases in Table 4 represents total legally 

enforceable controls that will be installed by 2018. Wisconsin believes that a combination of 

committed controls and legally enforceable controls are appropriate in meeting reasonable 

progress goals under the Regional Haze Rule. 

Table 4 – Annual Emissions of SO2 and NOX in 2005 – 2010 and 2018 (Projected) for EGU 

Sources in Wisconsin 

Annual Emissions 

Year/Scenario (Tons) 

SO2 NOX 

Modeled by MRPO for 

Visibility Impacts? 

Actual Emissions 1

2005 181,430 71,416 Yes 

2006 166,665 64,883 No 

2007 133,629 51,710 No 

2008 129,695 47,347 No 

2009 104,314 33,264 No 

2010 109,472 33,289 No 

Projected 2018 Emissions 

Case A – On-the-books 2 127,073 56,158 Yes 

Case B – Simple emissions growth 3 75,007 36,047 No 

Case C – Will do 4 150,340 55,019 Yes 

Case D – Committed controls (updated 

will do) 5

106,804 48,410 No 

Case E – CATR 6 71,514 35,391 No 

1 Emissions based on actual emissions from CAMD EGU database. 

2 MRPO projections based on 2005 actual emissions and on-the-books control requirements 

(CAIR and Consent Decrees).

3 WDNR staff estimate, grown from 2010 actual emissions from CAMD EGU database and 

adjusted to reflect committed controls as of May 2011. 

4 MRPO projections based on 2005 actual emissions and committed controls as of 2007. 
18

5 Projections based on Case C and adjusted to reflect committed controls as of May 2011 in 

response to CAIR/CATR/CSAPR and EGU MACT. 

6 IPM 4.01 projections reflecting 2014 emission allocations for Wisconsin (Note: emission 

trading limited to 10%). 

Figure 2 – Actual and Projected (2018) SO2 and NOX Emissions for 

EGUs in Wisconsin 1

Case A *

Base *

Base * Case B

Case A *

Case B

0

20

40

60

80

100

120

140

160

180

200

2000 2005 2010 2015 2020

Year

Annual Emissions (1000 tons)

SO2

NOx

* Modeled for visibility impact by MRPO. 

1

 Actual emissions are shown for 2005 – 2010. 

The 2018 “on the books” emissions inventory initially developed and modeled for visibility RPG 

included estimated BART controls (applied to 2005 actual emissions) for several non-EGU 

sources in Wisconsin: 

 Georgia-Pacific Consumer Products LP in Green Bay 

 New Page - Wisconsin Rapids Pulp in Wisconsin Rapids 

 Packaging Corporation of America in Tomahawk 

 Procter & Gamble Paper Products Company in Green Bay 

 Thilmany, LLC in Kaukauna 

Georgia Pacific in Green Bay is the only industrial source determined to be subject to BART in 

Wisconsin. The BART controls at Georgia Pacific will reduce emissions by an estimated 10,240 

tons/year SO2 and 2,533 tons/year NOx. A reasonable adjustment can be made to the projected 

2018 non-EGU emissions by first adding the initially assumed BART emission reductions back 

on to these projected emissions, and then subtracting the estimated BART emission reductions at 

Georgia Pacific. This adjustment results in an estimated 48,147 tons/year SO2 and 33,363 

tons/year NOx for the non-EGU sector in 2018. 
19

Summary 

The non-EGU adjusted emissions essentially add 15,316 tons SO2 and 3,257 tons NOx to the 

2018 on-the-books non-EGU emission projections used in the MRPO visibility modeling. 

However, much lower EGU emissions than the 2018 on-the-books EGU emissions are also 

projected. For example, Case B emission projections are lower than the on-the-books EGU 

projections by 56,545 tons SO2 and 20,111 tons NOx. The actual and projected emissions for 

point sources (EGUs and non-EGUs) are shown for select years and cases in Figure 3. 

Accounting for the lower EGU emissions projected in Case B (Table 4) – along with the higher 

projected non-EGU emissions – is expected to produce more beneficial visibility results than onthe-books controls alone modeled in Case A (Table 4). These adjusted emissions should be 

reflected in the interim review of meeting RPG for the first 10 year period. Wisconsin’s 

Reasonable Progress Goals (Section 5) and Long Term Strategy (Section 6) expand on these 

emission reductions as they relate to visibility improvement at the Northern Class I areas.
20

 

Figure 3 – Actual and Projected (2018) SO2 and NOX Emissions for Point 

Sources (EGUs and Non-EGUs) in Wisconsin 1,2

Case A *

Base *

Case B

Case B

Base *

Case A *

0

50

100

150

200

250

300

2000 2005 2010 2015 2020

Year

Annual Emissions (1000 tons)

SO2

NOx

* Modeled for visibility impact by MRPO. 

1

 Actual emissions shown for 2005 and 2010. Non-EGU 2009 actual emissions 

used in place of 2010 non-EGU emissions (data not yet available). 

2

 Case B 2018 projection based on 2005 non-EGU emissions less GP BART reductions 

of 10,240 tons SO2 and 2,533 tons NOX. 

4. Best Available Retrofit Technology 

BART Background 

A core federal requirement for addressing visibility impairment in the federal Class I areas is the 

implementation of a control program known as Best Available Retrofit Technology (BART) for 

certain older major sources directly impairing visibility. This BART control requirement 

addresses sources constructed in the decade before New Source Performance Standards (NSPS) 

first came into effect, and as a result have minimal or less than adequate emission controls. The 

federal requirements for identifying sources subject to BART, and the methods for determining 

appropriate emission control requirements, are set forth by the US EPA under 40 CFR Part 51, 

Appendix Y, Guidelines for BART Determinations Under the Regional Haze Rule.

7

 

7

 Title 40: Protection of Environment, Part 51 – Requirements for Preparation, Adoption, and Submittal of 

Implementation Plans, Appendix Y to Part 51 – Guidelines for BART Determinations Under the Regional Haze 

Rule. Online. http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&sid=12c576278c3887c8025da9c8f39c0b17&rgn=div9&view=text&node=40:2.0.1.1.2.22.11.14.39&idn

o=40. November 15, 2008. 
21

In order to meet the federal requirements, Wisconsin implemented rules for BART as provided 

under NR Ch. 433, Wis. Adm. Code, that address emissions of PM, SO2, and NOX. The 

Wisconsin rules establish that electricity generating units (EGUs) meet BART requirements for 

SO2 and NOX by meeting the Federal Clean Air Interstate Rule (CAIR) requirements. For all 

other cases, the Wisconsin rules establish a process for determining those sources subject to 

BART and applicable BART emission reduction requirements on a case-by-case basis. As part 

of this process the source must submit an analysis of potential pollution control technologies and 

their installation cost and related issues. Sources must implement BART requirements by 

December 31, 2015.8 Note, the U.S. EPA recently proposed that the CSAPR will be sufficient 

for EGUs to comply with their BART requirements (December 23, 2011). 

BART Modeling 

Under the state rule the CALPUFF air quality model is used to determine a source's visibility 

impairment on a Class I area for those sources found to be an appropriate age to be eligible under 

the BART program. If the modeled results show a significant reduction in visibility, the source 

is subject to BART or "BART-affected". The default protocol for the CALPUFF modeling and 

threshold for determining if a source is subject to BART controls is a follows: 

A source is BART-affected if the modeled reduction in visibility at any individual Class I 

area is greater than 0.5 deciviews (dv) for more than 2% of the year (7 days) as compared 

to the natural background visibility. The CALPUFF/CALMET modeling domain 

represents a coarse meteorological grid. This approach to applying the CALPUFF model is 

discussed in more detail within a protocol developed by the states in the Lake Michigan 

Air Directors Consortium (LADCO).9 

The CALPUFF analyses, as allowed under the state rule, for several sources utilized more 

specific data not universally available. This alternate analysis correspond to the VISTAS 

protocol developed by a large group of stakeholders, including the U.S. EPA, the VISTAS member 

state agencies and tribes, the Federal Land Managers (FLMs), industry representatives, and 

consulting experts. 10 One specific difference involved applying the CALPUFF model to see 

changes in visibility over smaller geographic areas (referred to as higher resolution / fine grid 

modeling). Another modification under this alternate approach is that the natural background 

threshold of visibility in the CALPUFF modeling was the annual average of natural background 

visibility for the Class I area. This average natural background value typically produces higher 

background impairment levels which results in smaller changes in visibility associated with 

changes in emission levels. 

 

8

 August 14, 2010 - Delayed installation date from 2013 as a rule change. See final rulemaking at 

https://health.wisconsin.gov/admrules/public/Rmo?nRmoId=5086. 

9 “Single Source Modeling to Support Regional Haze BART Modeling Protocol.” March 21, 2006. Lake Michigan 

Air Directors Consortium, Des Plaines, IL. 

10 Protocol for the Application of the CALPUFF Model for Analyses of Best Available Retrofit Technology 

(BART). Online. http://www.vistas-sesarm.org/BART/VISTASBARTModelingProtocol_Dec222005.pdf. 

November 15, 2008. 
22

BART for EGU Sources 

All of the EGUs found subject to BART, listed in Table 5, are also subject to CAIR under 40 

CFR part 97, and therefore meet sulfur dioxide (SO2) and nitrogen oxide (NOX) BART under 

Wisconsin state rules. However, the CAIR rule is in effect only until the CSAPR 

implementation begins. The EGU NOX and SO2 budgets under the CSAPR are expected to 

ensure reductions by 2018 at least equivalent to those anticipated with full implementation of the 

CAIR program. Therefore, the CSAPR should be sufficient to meet an updated EPA "better than 

BART" assessment. 

As discussed in the Emission Inventory section above (Section 3), projected EGU emissions in 

2018 under CSAPR (38,117 tons SO2 and 28,72 tons NOx) are much lower than projected 2018 

EGU emissions under CAIR (127,073 tons SO2 and 56,158 tons NOx). Note, the U.S. EPA 

recently proposed that the CSAPR will be sufficient for EGUs to comply with their BART 

requirements (December 23, 2011). Wisconsin will evaluate the impact of the final CSAPR 

emission budgets and respond to EPA findings relative to CSAPR and BART equivalency as 

needed. The next Regional Haze SIP revision will include emission reductions based on the final 

CSAPR emission budgets. The BART technical support document (TSD) for EGUs was 

submitted to the U.S. EPA as a separate SIP submittal for BART implementation. 

The EGU sources were required to conduct a BART analysis for PM, as this pollutant is not 

covered under CAIR or the replacement CSAPR. Based on the submitted PM BART analyses 

from the EGUs, and consideration by WDNR of available controls, costs, and visibility 

impairment in keeping with the Regional Haze Rule Guidelines for BART, WDNR is proposing 

a BART determination for BART-subject boilers at these sources. This determination found the 

existing PM control equipment (electrostatic precipitator or baghouse) and permit limitations 

satisfactory for BART. The revised BART TSD for EGUs is provided in the document, “BART 

TSD for EGUs – Revised July 2011.” WDNR received comments on this portion of the July 

2011 Draft Haze SIP during the public comment period. In responding to comments, WDNR 

maintains that the existing PM control equipment (electrostatic precipitator or baghouse) and 

permit limitations are satisfactory for BART. The BART Response to Comments and Final 

BART Determination are found in the BART SIP submittal. 

 
23

Table 5 – PM BART Determination for Wisconsin EGU Sources 

Source Name Emission Units 

(B = Boiler) 

PM Permit Emission 

Limit 

(Lbs/mmBtu) 

County 

Electrostatic Precipitator Control 

Alliant Energy – Columbia 1 B-21, B-22 0.60 (B-21) 

0.10 (B-22) Columbia 

Alliant Energy – Edgewater B-24 0.13 Sheboygan

Alliant Energy – Nelson Dewey B-22 0.10 Grant 

Wisconsin Energy – Oak Creek B-27,28 0.03 Milwaukee

Wisconsin Energy – Pleasant Prairie B-21, B-22 0.10 Kenosha 

Wisconsin Public Service Corporation 

– JP Pulliam Plant B-27 0.30 Brown 

Baghouse Control 

Dairyland Power Coop – Alma B-25,26 0.10 Buffalo 

Dairyland Power Coop – Genoa B-20 0.034 Vernon 

Wisconsin Energy – Valley B-21, B-22, B-23, 

B-24 0.15 Milwaukee

1

 In February 2011, Alliant Energy – Columbia received approval from the PSCW to install 

scrubbers and baghouses at boilers B21 and B22, which are expected to be placed into service in 

2014. Alliant submitted the associated construction permit application to WDNR in July 2011. 

The Department will update the Haze SIP for the next implementation period when the proposed 

particulate matter (PM) limitations at Columbia are available. 

BART for Non-EGU Point Sources 

The status of non-EGU sources as BART-subject is summarized in Table 6. The pollutants of 

concern emitted by boilers at these facilities are SO2, NOX, and PM. The WDNR determined 

that four facilities have sources that are potentially subject to BART based on source category 

and age criteria. Based on visibility modeling the WDNR determined that the Green Bay 

Georgia Pacific (GP) facility is the only source subject to BART. The BART determination for 
24

Georgia Pacific is described below. The BART TSD for non-EGUs is located in Wisconsin’s 

BART SIP. 

Based on visibility modeling results the three other BART eligible industrial facilities listed in 

Table 6 – Thilmany (a.k.a. International Paper Kaukauna facility), Packing Corporation of 

America-Tomahawk, and Mosinee Paper Corporation – do not exceed the threshold of 7-day 

visibility impact in any base year to any single Class I area. Therefore the WDNR determined 

these sources are not subject to BART control requirements. The modeling evaluation for these 

facilities relied on the VISTAS protocol for utilizing more specific model inputs and smaller grid 

analysis for visibility impacts compared to the default approach. The details for these visibility 

modeling analyses are located in Wisconsin’s BART SIP. 

Table 6 – Status of Wisconsin Non-EGU Sources Potentially Subject to BART 

Source Name 

Eligible Emission 

Units 

(B = Boiler) 

BART-subject 

Status County 

Georgia Pacific – Green Bay B-26, B-27 Subject Brown 

International Paper Kaukauna facility 

(a.k.a. Thilmany) B-11 Not subject * Outagamie

Packing Corporation of America – 

Tomahawk B-24 Not subject * Lincoln 

Mosinee Paper Corporation B-20, B-21, B-24 Not subject * Marathon 

* Determination based on CALPUFF modeling using VISTAS modeling protocol. 

BART Determination for Georgia Pacific 

The pollutants of concern emitted from the BART-subject boilers at GP (B-26 and B-27) are 

SO2, NOx and PM. As required under the Wisconsin's BART rule, Georgia Pacific submitted an 

engineering analysis of control options for the affected boilers. WDNR prepared a technical 

support document and proposed BART controls and associated permit requirements. The 

WDNR BART determination was subject to comment by the Federal Land Managers and public 

comment as required under the Haze rule. 

The documentation of the amended BART determination including response to received 

comment – as well as the associated Title V operating permit for GP updated with emission 

limitations and language reflecting BART – is provided in the document “BART Determination 

– Amended July 2011, Georgia Pacific Broadway Mill, Green Bay WI” (Attachment 3 of 

Wisconsin’s BART SIP). WDNR received comments on this portion of the July 2011 Draft 

Haze SIP during the public comment period. Responses to these comments are provided in the 

BART SIP submittal. The finalized PM BART requirements for BART boilers B26 and B27 are 

the existing emission limitation of 0.30 Lb/mmBtu. The final BART determination for SO2
25

reflects fuel switching of petroleum coke from BART boilers B26 and B27, followed by 

circulating bed dry scrubbing technology at 93% control. The BART SO2 control will reduce 

SO2 emissions by an estimated 10,240 tons/year. The BART determination for NOx on B26, a 

stoker boiler, reflects combustion modifications followed by selective non-catalytic reduction 

technology (SNCR) to achieve an overall 68% long-term reduction. For B27, a cyclone boiler, 

the BART determination for NOx reflects overfire air combustion modifications followed by 

Regenerative Selective Catalytic Reduction (RSCR) to yield an 85% long-term NOx control 

requirement. The BART NOx controls will reduce NOx emissions by an estimated 2,533 

tons/year. 

The 30-day and 12-month rolling BART mass caps for each boiler are calculated by applying the 

BART control efficiencies to the 30-day and annual emission baselines, respectively. A 10% 

additional reduction is then applied to the BART boiler controlled emissions to address the 

environmental benefit. This is consistent with EPA’s economic incentive program (EIP) policy 

guidance in reducing emissions 10% below that which would occur through the BART 

requirement on the individual boilers. The mass cap over all boilers creates an additional 

environmental benefit (as outlined in the EIP) by limiting the amount of overall emissions, 

addressing any switch of capacity from one boiler to another, and precluding any future growth 

in emissions from the non-BART boilers. The resulting emissions for each boiler are summed to 

yield the 30-day and 12-month rolling emission caps for stack S10. The Georgia Pacific BART 

controls and emission limitations for the BART affected boilers are provided in Tables 7A and 

7B. 

Table 7A – BART Determination for Boilers B26 and B27 at Georgia Pacific 

BART Technology and Control Level 

Emission Unit 

SO2

1

 NOx PM10

B26 Dry FGD – 93% OFA/FGR/SNCR – 68% Existing Baghouse > 99% 

B27 Dry FGD – 93% OFA/RSCR – 85% Existing Baghouse > 99%

1

 Overall SO2 control efficiency, based on combination of fuel switching and dry scrubber 

control at 93%, is 95.8% for B26 and 93.8% for B27. 

Dry FGD = Dry Flue Gas Desulphurization 

FGR = Flue Gas Recirculation 

OFA = Over-fire Air 

RSCR = Regenerative Selective Catalytic Reduction 
26

Table 7B – Summary of SO2 and NOx BART Compliance Requirements 

Pollutant Tons Emitted in any 30 Day Period 

at Stack S10 

Tons Emitted in any 12 Month Period 

at Stack S10 

SO2 268 2,340 

NOx 110 977 

PM 0.30 lbs/mmBtu 

5. Reasonable Progress Goals 

Wisconsin is required under 40 CFR 51.308(d)(1) to establish Reasonable Progress Goals 

(RPGs) regarding visibility improvement and attaining a natural level visibility. Wisconsin 

participated in the MRPO process to perform analysis for RPGs for Class I areas located in other 

MRPO states. The detailed RPG analysis is presented in Section 5 of the MRPO TSD. As 

described below, Wisconsin meets its RPG obligation for the first 10 year period through 2018. 

Class I Area RPG Demonstration 

Boundary Waters 

Voyageurs 

 Meets URI Line 

Isle Royale 

Seney 

 Meets 4 factor requirement 

 Meets requests for action by 

other states 

 Meets Wisconsin portion of 

contribution 

Background 

As discussed in Section 2, the primary test for meeting RPG is looking at projected emissions in 

2018 relative to the URI line. The URI is the uniform rate of visibility improvement which 

reflects the line drawn from baseline visibility (current emission levels) to the natural visibility 

conditions, for each Northern Class I area. If future emissions are expected to be above this URI 

glide path, there are 4 factors, listed below, that are considered in determining whether the RPG 

requirements are being met. 

 The costs of compliance. 

 The time necessary for compliance 

 The energy and non-air environmental impacts. 

 The remaining useful life of the source. 
27

Under 40 CFR 51.308(g), meeting RPG also requires a mid-decade progress report to determine 

how well the progress objectives are being met. Wisconsin will submit results of the first 

progress review to EPA by 2013. 

RPG and MRPO Modeling 

The URI line is the "Glide-path" line for each northern class I area as presented in Figure 2, 

section 2 of this document. To test whether RPG is met the MRPO performed visibility 

modeling of the "on the books" 2018 emissions inventory (Case A, Table 4). The results of this 

analysis and the URI goals for 2018 are compared in Table 8 and Figure 4. From Figure 4 the 

visibility impact to the Boundary Waters and Voyageurs is at or below the URI line. In addition 

actual emissions for 2018 (Case B, Table 4) are projected to be less than the emission levels for 

which visibility results are shown in Figure 4. Therefore the WDNR has determined that RPG is 

met for the Boundary Waters and Voyageurs northern class I areas. 

The visibility modeling results in Figure 4 do not demonstrate that Isle Royale and Seney are 

reaching visibility levels consistent with the URI goals. Therefore meeting RPG for these areas 

is evaluated further under the four factors. 

Table 8 – Measured Baseline and Modeled Future Year Deciview Values for Northern 

Class I Areas, Performed by MRPO (2005 Base Year for 2018 Projection) 

Site Baseline 

(2000-2004) 

2009 

OTB 

2012 

OTB 

2018 

OTB 

2018 

URP 

2018 OTB + 

Will Do 1

Isle Royale National 

Park 21.59 20.52 20.43 20.09 19.43 20.13 

Seney Wilderness Area 24.38 23.10 23.04 22.59 21.64 22.42 

Boundary Waters 

Canoe Wilderness Area 19.86 18.45 18.33 17.94 17.94 17.92 

Voyageurs National 

Park 19.48 18.20 18.07 17.63 17.75 17.66 

URP = Uniform Rate of Progress for visibility improvement 

OTB = On-the-Books control measures 

1

 “Will Do” scenario for EGUs represents Case C, discussed above in Section 3, 

“Emissions Inventory” 
28

Figure 4 – Visibility “Glide Paths” and 2018 Modeled Deciview Values for Northern Class I 

Areas 1

1

 Visibility estimates for 2018 reflect on-the-books controls. 

Demonstrating RPG for Isle Royale and Seney 

The WDNR has determined that RPG for Isle Royal and Seney is met through consideration of 

the following: 

1. Lower projected emissions vs. modeled emissions 

2. Four factors – compliance timeframe 

3. Meeting identified contribution and reduction obligations 

4. Meeting "asks" by other states 

1. Lower Projected Emissions vs. Modeled Emissions 

The MRPO states agreed that the priority emission sources affecting visibility of the Northern 

Class I areas are: SO2 from point sources (EGUs and non-EGUs), NOX from point sources 

(EGUs and non-EGUs), NOx from mobile sources, and NH3 from agricultural operations. In this 

context this section presents two findings: 1) that overall Wisconsin emissions are being reduced 

below the modeled inventories for the important source sectors and; 2) Emissions are being 
29

reduced below modeled inventories for individual sources (northern sources) with the greatest 

impact to Seney and Isle Royale. The WDNR concludes that any shortfall in meeting the URI 

line is reduced versus the modeled results for Seney and Isle Royale. Further, any shortfall 

cannot be identified and an appropriate response formulated without an updated modeling effort. 

In ensuring emission reductions and evaluating RPG, the WDNR will continue to evaluate if any 

additional emission reductions are necessary to meet the state’s RPG as part of the evaluation 

due to EPA by 2013. 

Overall Emissions

The Emission Inventory section above shows cases of projected emissions for the EGU sector 

that are significantly lower (Cases B, D and E) than on-the-books (Case A) and will do (Case C). 

For the non-EGU or industrial sector, the adjusted emission projections are higher than the onthe-books modeled emissions. This low projection for the non-EGU sector results from the 

assumption of on-the-books BART controls for industrial sources other than Georgia Pacific. 

Overall the EGU and non-EGU stationary source emissions, shown in Table 3, are projected to 

be lower than the modeled emissions demonstrating visibility impact above the URI line. 

Source Specific Emissions

The MRPO effort produced a list of the top 30 sources affecting visibility in each of the Northern 

Class I areas. Wisconsin sources on this list for Seney Wildlife Refuge and Boundary Waters 

Canoe Area are shown in Tables 8A and 8B, respectively (see also Figure 5). For each source a 

relationship of emissions and distance is determined - Emissions per year (Q) / Distance to class 

I area (D). This ratio is a simple metric for assessing the potential importance of a source to the 

visibility impact of a specific class I area. The sources with the largest values are expected to 

have the largest visibility impact. The sources in the table are listed first by largest expect 

impact. 

In compiling the Q/D information the MRPO used the "on the books" 2018 inventory. This Q/D 

then does not include significant controls installed and committed since that effort. For 

comparison the table provides the additional committed control levels and the source's actual 

emissions in 2009 before these controls. This comparison simply shows that for both Seney and 

Isle Royale the emissions from the top-tier of sources will be significantly reduced. These 

emission reductions are expected to be significantly more beneficial than equivalent emission 

reductions from the overall source sector. However this assessment cannot be made until a new 

modeling effort is completed. Further, the extent of any additional controls must be identified 

through that same modeling effort. Therefore, the Department concludes that source specific 

reductions will occur which will reduce the visibility impact for both Seney and Isle Royale. 

As noted above in Section 4 for BART at Georgia-Pacific, the mass cap over all of the boilers 

(BART and non-BART) at the common stack S10 creates an additional environmental benefit 

(as outlined in the EIP) by limiting the amount of overall emissions, addressing any switch of 

capacity from one boiler to another, and precluding any future growth in emissions from the nonBART boilers. This mass cap further contributes to RPG for this implementation period.
30

Table 8A – Wisconsin Sources Contributing to Visibility Impairment at Seney 

Actual 2009 

Emissions (tons) 1

 Controls not 

Facility ID Name Modeled 

(Q/d)NOx + 

(Q/d)SO2

(Lbs/min/km) SO2 NOx SO2 NOx

460033090 Alliant Energy - Edgewater 0.263 13,448 2,962 90%-

unit 5 

111003090 Alliant Energy - Columbia 0.254 26,865 5,265 > 90% 

606034110 Dairyland Power Coop – Alma 0.195 14,849 4,736 > 90% 

405032870 Georgia Pacific 0.178 13,105 3,143 55% - 

S10 

70% - 

S10 

737009020 WPSC – Weston 0.166 8,994 3,821 

241007800 We Energies – Valley 0.131 5,376 1,817 

405031990 WPSC – JP Pulliam 0.129 4,385 3,389 

445031180 Thilmany LLC 0.095 7,629 2,293 

663020930 Dairyland Power Coop – Genoa 0.086 6,479 1,574 > 90%

735008010 PCA – Tomahawk 0.074 4,787 1,589 

241007690 We Energies – Oak Creek 0.073 14,823 5,530 >95% 90% 

772009480 Stora Enso – Biron Mill 0.054 5,249 2,413 

438039360 NewPage Wisconsin Systems, 

Inc. 0.041 0 0 

772010690 Domtar A. W. LLC – Nekoosa 0.037 4,905 1,338 

744008100 Rhinelander Paper 0.036 2,796 1,661 

405032210 Procter & Gamble Paper 0.03 862 857 

772010140 Wisconsin Rapids 0.023 1,825 2,218 

445030960 Kimberly Mill 0.021 0 5 

737009570 Wausau Paper Mills, LLC 0.017 1,432 682 

1 Reported to the WDNR Air Emissions Inventory
31

Table 8B – Wisconsin Sources Contributing to Visibility Impairment at Isle Royale 

Actual 2009 

Emissions (tons)1

Controls not 

Facility ID Name Modeled 

(Q/d)NOx + 

(Q/d)SO2

(Lbs/min/km) SO2 NOx SO2 NOx

111003090 Alliant Energy - Columbia 0.234 26,865 5,265 90% 

606034110 Dairyland Power Coop - Alma 0.220 14,849 4,736 90% 

460033090 Alliant Energy - Edgewater 0.205 13,448 2,962 90% -

Unit 5 

737009020 WPSC - Weston 0.175 8,994 3,821 

405032870 Georgia Pacific 0.138 13,105 3,143 55%-

S10 

70%-

S10 

241007800 We Energies - Valley 0.105 5,376 1,817 

405031990 WPSC – JP Pulliam 0.100 4,385 3,389 

802033320 Xcel Energy Bay Front 

Generating Station 

0.094 738 915 

735008010 PCA – Tomahawk 0.091 4,787 1,589 

663020930 Dairyland Power Coop - Genoa 0.087 6,479 1,574 90% 

445031180 Thilmany LLC 0.077 7,629 2,293 

772009480 Stora Enso – Biron Mill 0.054 5,249 2,413 

744008100 Rhinelander Paper 0.044 2,796 1,661 

772010690 Domtar A. W. LLC - Nekoosa 0.037 4,905 1,338 

438039360 NewPage Wisconsin Systems, 

Inc. 0.037 0 0 

772010140 Wisconsin Rapids Fiber and 

Energy Mill 0.024 1,825 2,218 

405032210 Procter & Gamble Paper 

Products Company 0.023 862 857 

816009590 Murphy Oil 0.021 537 459 

445030960 Kimberly Mill 0.018 0 5 

737009570 Wausau Paper Mills, LLC (aka 

Mosinee Paper Corp.) 0.017 1,432 682 

1 Reported to the WDNR Air Emissions Inventory
32

Figure 5 – Map of WI Facilities Contributing to Visibility Impairment at Northern 

Class I Areas 
33

2. Four Factors - Compliance Timeframe 

In considering the factor of "time necessary for compliance" the EGU control programs and 

BART requirements included are implementing emission reductions in an expeditious and 

reasonable time-frame. U.S. EPA's own assessment of requirements describes that the CAIR and 

CSAPR are capturing emission reductions on a schedule that is as soon as can be practically 

implemented for the sector. The CSAPR FIP (replacing CAIR) indicates that EGU NOX and 

SO2 budgets will likely ensure reductions by 2018 at least equivalent to those caused by 

implementation of the CAIR program in Wisconsin. On this basis, the CSAPR is likely to 

achieve the BART EGU reductions achieved through CAIR. 

As part of the RPG evaluation work the MRPO contracted EC/R to perform an analysis of 

control options for each sector and implementation timeframes. One conclusion of the MRPO 

EC/R analysis is that CAIR is being implemented as fast as possible. Another portion of the 

EC/R analysis showed that additional progress in visibility for Seney and Isle Royale is limited 

by the time necessary for compliance rather than potential control levels and cost. 

For non-EGU stationary sources other regulatory requirements are addressing potential emission 

reductions on a practical schedule. Several regulatory requirements are expected to significantly 

affect emissions from the industrial boilers as well as the EGU boilers identified in Tables 8A 

and 8B, the northern boilers. These programs include PM2.5 reasonably available control 

technology (RACT), attainment with the 1-hour SO2 National Ambient Air Quality Standards 

(NAAQS) and NO2 NAAQS, and acid gas requirements under the ICI and EGU Boiler 

Maximum Achievable Control Technology (MACT) rules. All of these programs have 

compliance time-frames consistent with the 2018 RPG date. It should also be noted that EPA 

has committed to evaluating ICI boiler control measures for the Phase 2 of the CSAPR. EPA 

addressed in the proposed Phase 1 of the CSAPR that industrial sector controls are not included 

in that phase, as further evaluation of available control measures and compliance timeframes is 

required before implementing a program for this sector. EPA's conclusion that further evaluation 

is needed before proposing controls to the ICI boiler sector supports the WDNR conclusion that 

controls cannot be implemented any faster for this sector. 

Therefore, based on EPA's own assessment for implementing controls and the EC/R analysis, the 

states will not be able to implement deeper emission reductions more rapidly than current 

regulatory program efforts. Since the time for compliance is a limiting step the consideration of 

the other RPG factors is not evaluated for this RPG determination. 

In ensuring emission reductions and evaluating RPG, the WDNR commits to evaluating the 

implementation results of the discussed regulatory programs. 

3. Meeting identified contribution and reduction obligations 

The rate of emission reduction projected for Wisconsin sources compared to Michigan and 

Minnesota shows that Wisconsin is meeting its share of visibility improvement. Figures 6 and 7 

show the total SO2 and NOx emitted by sources in Michigan, Minnesota and Wisconsin. Of the 
34

three MRPO states, both Michigan and Minnesota have similar or higher visibility impairment 

contribution to Isle Royale compared to Wisconsin, and only Michigan has higher visibility 

impairment contribution to Seney compared to Wisconsin. Figures 6 and 7 show that Wisconsin 

emissions, using the "on the books" inventory, decrease at a similar or greater rate than Michigan 

and Minnesota emissions. Further, as previously identified, Wisconsin emissions (particularly 

EGUs) are anticipated to be significantly lower than those shown in Figures 6 and 7. This is 

supported by the NOx and SO2 budgets under the CSAPR, which are similar to or less than the 

Michigan and Minnesota budgets. Also, the finalized SO2 and NOx BART control levels for 

Georgia-Pacific in Wisconsin are higher than the SO2 and NOx BART control levels for 

industrial sources in both Michigan and Minnesota. Since Wisconsin sources are achieving 

emission reductions as rapidly as Michigan and Minnesota, WDNR has determined that 

Wisconsin is meeting its emission reductions obligations for its portion of contribution to RPG 

for the first 10 year period. 

Figure 6 – SO2 Emissions in 2005 and 2018 (projected based on on-the books 

controls) for MI, MN, and WI 1,2

MI -26% 

reduction

MN - 30% 

reduction

WI - 27% 

reduction

0

50

100

150

200

250

300

350

400

450

2000 2005 2010 2015 2020

Year

Annual SO2 Emission

s

(1000 tons)

1

 WI on-the-book non-EGU projections corrected to only include BART emission 

reductions at Georgia Pacific. 

2

 Total 6-state (IL, IN, MI, MN, OH, WI) estimated SO2 emissions % reduction from 

2005 to 2018 is 46% (3,509,106 tpy to 1,884,040 tpy). 
35

Figure 7 – NOx emissions in 2005 and 2018 (projected based on on-the books 

controls) for MI, MN, and WI 1,2

MI - 42% 

MN - 41% reduction

reduction

WI - 44% 

reduction

0

100

200

300

400

500

600

2000 2005 2010 2015 2020

Year

Annual NOx Emission

s

(1000 tons)

1

 WI on-the-book non-EGU projections corrected to include only BART emission 

reductions at Georgia Pacific. 

2

 Total 6-state (IL, IN, MI, MN, OH, WI) estimated NOX emissions % reduction from 

2005 to 2018 is 49% (3,000,565 tpy to 1,524,763 tpy). 

4. Meeting "asks" by other states 

On September 19, 2007, the State of Minnesota sent Wisconsin a letter asking for specific 

emission reductions: 

“In particular, Minnesota asks Iowa, Missouri, North Dakota, and Wisconsin to evaluate 

further reductions of SO2 from electric generating units (EGU) in order to reduce SO2 

emissions by 2018 to a rate that is more comparable to the rate projected in 2018 for 

Minnesota, approximately 0.25 lbs/MMBtu. Minnesota believes that Illinois is already in 

the process of meeting this goal. Emission reductions in Wisconsin are particularly 

important, as Wisconsin is the highest contributor outside Minnesota to visibility 

impairment in Minnesota’s Class I areas.” 

In 2009, EGU SO2 emission rates in Wisconsin were 0.47 lbs/mmBtu. The proposed adjusted 

final CSAPR budget (47,883 tons SO2) and heat input (441 billion Btu’s) from October 2011 

result in an SO2 emission rate of 0.19 lbs/mmBtu. Therefore, the overall goal of reducing the 

EGU emission rate in response to the Minnesota ask is met. 
36

6. Long-term Strategy 

Wisconsin is required under 40 CFR 51.308(d)(3) to submit a long-term strategy addressing 

regional haze for each mandatory Class I area which may be affected by emissions from within 

the state, in order to “achieve the reasonable progress goals established by States having 

mandatory Class I areas.” The long-term strategy must include enforceable emission limitations, 

compliance schedules and other measures necessary to achieve the RPGs. The long-term 

strategy must be set every 10 years, and part of the requirement is to show the RPG for the next 

10 years. Section 5 above discusses how Wisconsin is meeting the first RPG (through 2018) – 

this RPG includes the required enforceable limits and schedules. Most of the long-term strategy 

discussion here addresses future anticipated rules and actions in Wisconsin. 

Emission Reductions Due to Ongoing Air Pollution Control Programs 

Under 40 CFR 51.308(d)(3)(v)(F), WDNR is required to ensure that emission limitations and 

control measures used to meet the RPG are enforceable. The CAIR requirements have been 

adopted as state regulations and the CSAPR requirements will need to be adopted as state 

regulations as well, unless Wisconsin depends on EPA’s FIP program structure. The BART 

control evaluations are required by a state rule (NR 433), and the limits and provisions of each 

source’s BART determination are enforceable through permits / administrative order. 

WDNR considered several ongoing or expected control programs in participating in the MRPO 

development of RPGs for Class I areas where the state contributed to visibility impairment. 

These controls are discussed in Section 3 above (also see Appendix C). Several EGUs in 

Wisconsin and throughout the MRPO region have begun to install controls for CAIR. EPA has 

committed to address interstate transport and contribution for NOX associated with ozone, and 

NOX and SO2 associated with PM2.5, via Phase 1 and Phase 2 of the CSAPR FIPs. Additional 

emission reductions in the EGU sector are expected under Wisconsin’s Case D scenario (see 

Section 3), which is based on IPM 3.0 fuel projections, and considers the CAIR control/emission 

levels known as of 2011 that will be in place by 2018. Large reductions in NOX emissions are 

also taking place under rate-of-progress for ozone. One non-EGU source in Wisconsin (Georgia 

Pacific paper mill in northeast Wisconsin) is subject to BART – the final determination of 

required SO2 and NOX reductions is proposed in this SIP. Three additional non-EGU sources 

have been determined to not be subject to BART, based on revised air quality modeling. 

Additional details on BART are found in Section 4. Significant emissions reductions for the 

mobile sector – included in the modeling of predicted 2018 emissions – are also expected to 

result from several federal rules that are undergoing implementation through 2018: 

 Tier II for on-highway mobile sources 

 Heavy-duty diesel (2007) engine standards 

 Low sulfur fuel standards 

 Federal control programs for nonroad mobile sources 
37

Additional Emission Limitations and Schedules of Compliance 

Wisconsin is required under 40 CFR 51.308(d)(3) to identify additional measures to meet 

visibility goals when ongoing programs alone are not sufficient. Sufficient controls for setting 

the visibility goal are those that are shown to meet the URI visibility glide path, or to be 

reasonable based on the four factors as well as visibility impacts (see Reasonable Progress Goals 

section above). WDNR believes that reasonable controls include U.S. EPA’s CSAPR Phase 1 

and Phase 2 FIP commitments, on-the-books controls affecting Wisconsin mobile sources, and 

BART controls. 

As mentioned in the Reasonable Progress Goals section above, the study by EC/R evaluated the 

primary source categories that may impact Class I areas in the region. The category of sources 

having the largest impact on Class I areas is EGUs. All major EGUs are subject to Phase 1 

CAIR and will also be subject to Phase 1 CSAPR. It should be noted that Phase 2 CSAPR is 

focused on the upcoming ozone and PM2.5 ambient standard revisions. WDNR is making the 

presumption that U.S. EPA is already making efforts to examine cost-effective control strategies 

in the shortest timeframe possible as part of CSAPR, and that EGUs in the state will continue to 

meet those intentions. ICI boilers were also reviewed by EC/R, and showed potentially 

reasonable additional controls on a cost basis. WDNR may use results from the EC/R study for 

reasonable controls for ICI boilers – should Wisconsin’s long-term strategy be determined to be 

insufficient – with a focus on the significant emission sources in Tables 8A and 8B in the 

Reasonable Progress Goals section. The other categories of sources analyzed by EC/R have less 

impact on the Class I areas than EGUs and boilers and are not being pursued for control beyond 

what is already on the books. It should also be noted that the MRPO, in general, has ongoing 

studies for meeting visibility improvement goals. These studies will continue to be used by 

WDNR staff. 

WDNR plans to include updated emission predictions of agricultural ammonia in the Five Year 

SIP Assessment, and is studying potential mechanisms for targeted reductions from the sector as 

part of the next RPG for the period 2019-2028. Such reductions are expected to help meet the 

emission reduction goals associated with the future visibility goals for the Northern Class I areas. 

WDNR will continue to evaluate if any additional emission reductions are necessary, including 

those from ICI boilers, RICE and turbines, and mobile sources, as needed to meet the state’s 

RPG. WDNR will continue to share information with other states on NOX and SO2 controls in 

the state, for those states to include in RPGs for their Class I areas. 

Potential Future Projects and Impacts 

Other actions are likely to take place over the next 10 years that will improve visibility in the 

Class I areas in 2018. These potential actions have not been included in this RPG. EGU MACT 

and ICI MACT regulations – which control hazardous air pollutants (HAPs) from boilers – may 

also lead to lower future emissions reductions from EGUs and industrial boilers that impact 

visibility. Industrial Boiler MACT and EGU MACT were finalized in late 2011. WDNR has not 

adjusted its 2018 emission reduction estimates to account for these regulations. Tighter National 

Ambient Air Quality Standard (NAAQS) for ozone and PM2.5, as well as NO2 and SO2, may 
38

cause parts of Wisconsin and other surrounding states to become nonattainment for these 

pollutants, requiring reductions in the primary or precursor pollutants. These additional 

reductions in precursor emissions will likely further reduce regional haze by 2018. Finally, it 

should be noted that ICI boiler emissions are expected to be regulated under the second phase of 

the CSAPR if the Boiler MACT proves inadequate to ensure reductions in SO2 and NOx 

sufficient to meet modeled ozone and PM NAAQS attainment for the key dates – likely to be on 

or before 2018. 

Other Factors Considered 

In consideration of construction activities and their effect on regional haze, construction 

activities in Wisconsin are subject to federal non-road standards for construction equipment and 

vehicles. The impact of these activities will continue to be mitigated through the federal general 

conformity and transportation conformity rules. For the construction of new major sources, the 

visibility impacts of such sources will continue to be managed in conformance with existing 

requirements pertaining to New Source Review (NSR) and Prevention of Significant 

Deterioration (PSD). This involves analysis of visibility impacts and consultation with FLMs in 

determining if a new major source or major modification is installing Best Available Control 

Technology (BACT), and if it may have an adverse impact on visibility in Class I areas. WDNR 

commits to ensuring that permitting of new and modified sources through Wisconsin’s NSR 

program is consistent with making reasonable progress toward the visibility goals of the Haze 

SIP. Source retirement and replacement schedules, which must be considered under 40 CFR 

51.308 (d)(3)(v)(D) in developing reasonable progress goals, will be managed in conformance 

with existing requirements under the PSD program. WDNR has worked with land managers in 

the state to prepare a plan to address controllable fire activities that can impact visibility locally: 

“Wisconsin Smoke Management Best Management Practices for Prescribed Burning” (October 

25, 2010). This plan being reviewed by EPA for certification is located in Appendix D. 

Anticipated Net Effect on Visibility 

Under 40 CFR 51.308(d)(3)(v)(G), WDNR is required to address the net effect on visibility 

resulting from changes projected in point, area, and mobile source emissions by 2018. The 

emission inventory used for this SIP addresses changes to point, area, and mobile source 

inventories by the end of the first implementation period. Factors taken into consideration for 

the emissions projections include population growth; industrial, energy and natural resources 

development; land management; and air pollution control. These changes, and their net effect on 

visibility, are described in the Reasonable Progress Goals section above. The MRPO TSD shows 

that the reasonable progress goals for the Northern Class I areas in northern Minnesota 

(Boundary Waters and Voyageurs) will be achieved by 2018 from implementation of “on the 

books” and “will do” control measures in the states contributing to visibility impairment, 

however those in northern Michigan (Isle Royale and Seney) may not be achieved; however, 

WDNR expects that Wisconsin’s existing and planned controls will ensure it has included all 

measures needed to achieve its apportionment of emission reduction obligations. Control 
39

requirements will be evaluated for the 2013 implementation assessment report associated with 

the 2018 RPG review process, and periodically as required in the Regional Haze Rule. 

Additional emission reductions will be achieved in Wisconsin that were not included as “on the 

books” and “will do” controls in the MRPO analysis. Additional emission reductions in the 

EGU sector are expected under Wisconsin’s Case D scenario (Table 4) – which is based on IPM 

3.0 fuel projections, and considers the CAIR control/emission levels known as of 2011 that will 

be in place by 2018 – as well as Case E (Table 4) which represents Wisconsin emission 

allocations under the CATR proposal (emissions greater than the CSAPR). Consideration of 

these additional EGU emission reductions in future Haze SIP submittals is expected to satisfy 

Wisconsin’s required participation in keeping visibility improvement at the Northern Class I 

areas close to or below the glide path. 

7. Periodic Implementation Planning and Adequacy 

Under 40 CFR 51.308(f), certain states are required to revise their regional haze implementation 

plan and submit a plan revision to the EPA by July 31, 2018 and every ten years thereafter. In 

addition, 40 CFR 51.308(g) requires periodic reports evaluating progress towards the reasonable 

progress goals established for each mandatory Class I area, with potential follow-up actions 

listed in 40 CFR 51.308(h). The specific states to which these requirements apply are listed in 

40 CFR 51.300. Although Wisconsin is not one of the states listed under 40 CFR 51.300, 

WDNR will participate in the MRPO efforts to address these requirements. 

Wisconsin’s long-term strategy contains enforceable emission reduction measures that are 

expected to achieve the reasonable progress goals in 2018. WDNR will participate in 

reassessment and revision of the goals in 2018 and every 10 years thereafter. WDNR will also 

continue in its efforts to maintain monitoring networks and emissions inventories, and will 

continue to provide separately the required progress reports every five years, as well as future 

SIP revisions for the Regional Haze Rule. The reasonable progress report will evaluate the 

progress made towards the reasonable progress goal for each mandatory Class I area where 

Wisconsin sources are determined to impact visibility. WDNR will continue to have periodic 

calls as needed with the Northern Class I consultation group including states, tribes, FLMs, and 

EPA. The MRPO states and Minnesota will continue to do technical evaluations that will be 

necessary to determine if the Class I areas are reaching their RPGs. In the five-year report, 

WDNR will undertake an emission review to determine if the emission reductions projected to 

occur through the application of BART, CAIR/CSAPR, and the other components of WDNR’s 

long-term strategy have occurred. The review will also look at what new emission sources have 

begun operation. Depending on the findings of the five-year progress report, WDNR will 

evaluate what actions, if any, are appropriate and necessary. In particular, WDNR will reevaluate the significant emission sources in Tables 8A and 8B in the Reasonable Progress Goals 

section for emission reductions should Wisconsin be above its projected emissions inventory for 

the 2013 progress assessment point. 
40

8. Monitoring Strategy 

Wisconsin currently maintains a monitoring network to measure and report levels of various 

pollutants, including those that contribute to impairment of visibility in Class I areas. Wisconsin 

is not required to perform direct Haze monitoring, and therefore does not commit our monitoring 

network under the Haze SIP. Wisconsin's ongoing monitoring efforts and resulting data will be 

used to certify and Q/A modeling efforts used in evaluating visibility impacts and contribution – 

with a focus on the Class I areas in Michigan and Minnesota – via the MRPO process. WDNR 

believes this approach fulfills 40 CFR 51.308(d)(4)(iii) of the Haze Rule. 

Wisconsin’s monitoring program relies upon Wisconsin’s network of State and Local Air 

Monitoring Sites (SLAMS), which include the following types of monitors: PM2.5 speciation, 

photochemical assessment monitoring (PAM), and special purpose monitors (SPM). Since there 

are no Class I areas located in the state, Wisconsin does not operate any monitoring sites under 

the federal Interagency Monitoring of Protected Visual Environments (IMPROVE) program; 

however, Wisconsin does operate Speciation Trends Network (STN) sites. Figure 8 illustrates 

Wisconsin’s ambient monitoring network. Specific site information, including the pollutants 

measured, site locations (address and latitude/longitude), and the sampling schedule, is found in 

the WDNR Air Monitoring document, “Network Plan 2011” (June 2010).11

 

11 Network Plan 2011. Wisconsin Department of Natural Resources – Air Monitoring Section (June 2010). Online. 

http://dnr.wi.gov/air/pdf/2011_Network_Plan_FINAL.pdf. November 3, 2010. 
Figure 8 – Wisconsin Monitoring Locations 
42

Part V. List of Appendices 

Appendix A. Primary Federal Class I Areas Affected by Wisconsin Stationary 

Source Emissions 

Appendix B. Draft List of Class I Areas Located Within (or Impacted by) 

Midwest RPO States 

Appendix C. List of On-the-Books Controls Assumed by MRPO 

Appendix D. WI Smoke Management Plan 
Appendix A. Northern Federal Class I Areas Impacted by Wisconsin Emission 

Sources 

Note: Rainbow Lake is not one of the listed 156 Class I areas under the Regional Haze 

Rule. 
June 26, 2007 

Draft List of Class I Areas Located Within 

(or Impacted by) Midwest RPO States 

The purpose of this paper is to provide a draft list of Class I areas located within or impacted by 

a Midwest Regional Planning Organization (MRPO) State. A variety of technical analyses were 

considered in developing the draft list, including base year (2002) and future year (2018) 

modeling, back trajectories, and other data analyses. This information shows that every MRPO 

State impacts multiple Class I areas in the eastern U.S. 

Regulatory Requirements 

EPA’s regional haze rule requires a state to “address regional haze I each mandatory Class I 

Federal area located within the State and in each mandatory Class I Federal area located 

outside the State which may be affected by emissions from within the State.” (40 CFR Part 

51.308(d)) EPA has interpreted this provision as requiring a table identifying each mandatory 

Class I Federal area located within the State and each mandatory Class I Federal area located 

outside the State affected by emissions from within the State (see Draft EPA Checklist for 

Regional Haze SIPs Submitted Under 40 CFR 51.308 - 7/13/06 Staff Draft ).

Discussion 

Technical analyses conducted by the RPOs were consulted to obtain information on areas of 

influence and culpability for Class I areas in the eastern U.S.1 A summary of this information is 

provided below and in Table 1. 

For the MRPO analyses, a state was assumed to affect visibility impairment in a Class I area if it 

contributes 2% (or more) to total light extinction. This criterion was selected based on a review 

of the back trajectory and modeling results which showed that states contributing 2% (or more) 

make-up about 90-95% of total light extinction, whereas states contributing 5% (or more) makeup only about 75-80% of total light extinction. For the other RPO analyses, deference was 

given to the criteria established by each group to identify contributing states. 

(1) MRPO Back Trajectory Analyses

An initial trajectory analysis was conducted using data for 1997-2001 (all sampling days), a start 

height of 200 m, and a 72-hour (3-day) trajectory period (Cite: “Quantifying Transboundary 

Transport of PM2.5: A GIS Analysis”, May 2003, LADCO). By combining trajectory frequencies 

with concentration information, the average contribution to PM2.5 mass and individual PM2.5

species was estimated (which, in turn, was used to estimate the average contribution to light 

extinction). The results for 17 Class I areas in eastern U.S. were examined to identify those 

Class I areas where an MRPO state had at least a 2% contribution to total light extinction 

(based on all days). 

 

1 Back trajectories and modeling conducted by the WRAP indicate that the Midwest RPO States are not 

important contributors to visibility impairment due to sulfates and nitrates in western Class I areas (Cite: 

“Attribution of Haze Phase I Report, Geographic Attribution for the Implementation of the Regional Haze 

Rule”, March 14, 2005). The analyses show only five groups of western Class I areas with at least 5% 

contribution from states outside the WRAP. The outside-WRAP contribution is generally small (on the 

order of 0-15%), and is likely due mostly to nearby CENRAP states. 
June 26, 2007 

A second trajectory analysis was conducted using data for 2000-2003 (20% highest and lowest 

days), a start height of 200m, and a 120-hour (5-day) trajectory period (Cite: “Sensitivity 

Analysis of Various Trajectory Parameters”, June 2005, LADCO). Back trajectory plots were 

prepared for each of the four northern Class I areas in Michigan and Minnesota for the high 

extinction days (see Figure 1 – note: areas in orange are mostly likely upwind and the areas in 

green are least likely upwind on poor visibility days). Although somewhat qualitative, these 

results provide additional information in identifying states impacting the northern Class I areas. 

 Voyageurs Boundary Waters 

S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA

 

S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA

 Isle Royale Seney

S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA

 

S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA

Figure 1. Contoured trajectory plots for poor visibility days for Class I areas in northern 

Minnesota and Michigan 

(2) MRPO PSAT Modeling 

A photochemical grid model (CAMx) was applied to provide source contribution information for 

2018 conditions. Specifically, the model estimated the impact of 18 geographic source regions 

and 6 source sectors (EGU point, non-EGU point, on-road, off-road, area, and ammonia 

sources) at Class I areas in the eastern U.S. Example results for four Class I areas (Seney, 

Mammoth Cave, Mingo, and Shenandoah) are presented in Figure 2. The results for 13 Class I 

areas in eastern U.S. were examined to identify those Class I areas where an MRPO state had 

at least a 2% contribution to total light extinction. 
June 26, 2007 

Figure 2. Source region contributions to light extinction based on MRPO PSAT modeling for 

select Class I areas: Seney, Mammoth Cave, Mingo, and Shenandoah 

(3) MANE-VU Contribution Assessment 

A weight-of-evidence report was prepared by NESCAUM (on behalf of MANE-VU) to 

understand the causes of sulfate-driven visibility impairment at Class I areas in the northeastern 

and mid-Atlantic portions of the U.S. (cite: “Contributions to Regional Haze in the Northeast and 

Mid-Atlantic United States”, August 2006) The report provides information on the relative 

contribution of various emissions sources and geographic source regions. The analytical and 

assessment tools considered include Eulerian and Lagangian air quality models, and data 

analysis techniques, such as source apportionment analyses, back trajectories, and 

examination of emissions and monitoring data. Sulfate impacts were quantified using five 

analytical techniques based on 2002 conditions: REMSAD, Q/d, CALPUFF (w/ NWS data), 

CALPUFF (w/ MM5 data), and percent time upwind (based on trajectory analyses). Figure 3 

summarizes the five sets of results for three MANE-VU Class I areas. Although no specific 

criteria were identified in the report to determine a significant contribution, the States of 

Vermont, New Hampshire, Maine, and New Jersey assumed a 2% sulfate impact in recent 

letters to other states inviting them to consult on reasonable progress goals. The MRPO States 

identified as contributing to a MANE-VU Class I area were Illinois, Indiana, Michigan, and Ohio 
June 26, 2007 

Figure 3. Percent contribution results using different techniques for ranking state contributions 

to sulfate levels at MANE-VU Class areas (cite: “Contributions to Regional Haze in the 

Northeastern and Mid-Atlantic Portions of the U.S.”, August 2006)
June 26, 2007 

(4) Missouri-Arkansas Contribution Assessment 

The draft Consultation Plan for the two Missouri and two Arkansas Class I areas provides 

information on source regions affecting these Class I areas (i.e., areas of influence) using a 

variety of data and analyses. (cite: “Central Class I Areas Consultation Plan”, States of Missouri 

and Arkansas, February 2007) A decision on whether a given state is a contributor to visibility 

impairment in these Class I areas was based on the combined results of three approaches: 

areas of influence (see Figure 4), PSAT modeling (based on 2018 conditions), and monitoring 

data analyses (PMF and back trajectories). According to the draft plan, if a state was a major 

contributor for at least two of the three approaches (for either sulfate or nitrate), then it was 

determined to be a significant contributor. The MRPO States identified as contributing to a 

central CENRAP Class I area were Illinois, Indiana, and Ohio. 

Figure 4. Areas of Influence for Central CENRAP Class I Areas (cite: “Central Class I Areas 

Consultation Plan”, States of Missouri and Arkansas, February 2007)

(5) VISTAS Area of Influence Analysis 

Areas of influence (AOI) were identified for Class I areas in the southeastern U.S. using 

residence time plots based on wind trajectory direction and frequency, and weighted by visibility 

impact (light extinction by ammonium sulfate, ammonium nitrate, or elemental carbon). 

(Cite: “VISTAS Areas of Influence Analysis”, Draft, February 28, 2007). These extinctionweighted residence time analyses were overlayed on gridded emissions (for both 2002 and 

2018) to define emission sources in the areas of greatest influence for each Class I area. 

Figure 5 shows the plots for two VISTAS Class I areas. AOIs were defined on the basis of 

residence times greater than 10%. The MRPO States identified as contributing to a VISTAS 

Class I area were Illinois, Indiana, and Ohio. 
June 26, 2007 

Figure 5. Areas of Influence for Shenandoah (left) and Mammoth Cave (right) for 2018 conditions 

(cite: “VISTAS Area of Influence Analyses” PowerPoint presentation, November 28, 2006) 

Note: green circles indicate 100- and 200-km radii from Class I area, red line perimeter indicate 

AOI with residence time > 10%, and orange line perimeter indicate AOI with residence time > 5%
June 26, 2007 

Table 1. Draft List of Class I Areas Impacted by MRPO States - References

AREA NAME IL IN MI OH WI

81.401 Alabama.

Sipsey Wilderness Area (1) (1)

81.404 Arkansas.

Caney Creek Wilderness Area (2), (4) (2), (4) (2), (4)

Upper Buffalo Wilderness Area (1),(2),(4),(5) (2), (4) (2), (4) (2)

81.408 Georgia.

Cohotta Wilderness Area

Okefenokee Wilderness Area

Wolf Island Wilderness Area

81.411 Kentucky.

Mammoth Cave NP (1), (2), (5) (1), (2), (5) (1), (2) (1), (2), (5)

81.412 Louisiana.

Breton Wilderness Area

81.413 Maine.

Acadia National Park (3) (3) (3) (3)

Moosehorn Wilderness Area. (3) (3) (3) (3)

81.414 Michigan.

Isle Royale NP. (1), (2) (1), (2) (1), (2) (1), (2)

Seney Wilderness Area (1), (2) (1), (2) (1), (2) (1), (2) (1), (2)

81.415 Minnesota.

Boundary Waters Canoe Area Wilderness (2) (2) (2) (1), (2)

Voyageurs NP (2) (2) (1), (2)

81.416 Missouri.

Hercules-Glades Wilderness Area (2), (4), (5) (2), (4), (5) (2), (4) (2)

Mingo Wilderness Area (2), (4), (5) (2), (4), (5) (2) (2), (4) (2)

81.419 New Hampshire.

Great Gulf Wilderness Area (3) (3) (3) (1), (3)

Pres. Range-Dry River Wilderness Area.

81.42 New Jersey.

Brigantine Wilderness Area (3) (3) (1), (3) (1), (3)
June 26, 2007 

81.422 North Carolina.

Great Smoky Mountains NP{1} (1) (1) (1)

Joyce Kilmer-Slickrock Wilderness Area{2}

Linville Gorge Wilderness Area.

Shining Rock Wilderness Area.

Swanquarter Wilderness Area

81.426 South Carolina.

Cape Romain Wilderness

81.428 Tennessee.

Great Smoky Mountains NP{1}. (1) (1) (1)

Joyce Kilmer-Slickrock Wilderness{2}

81.431 Vermont.

Lye Brook Wilderness (2), (3) (2), (3) (2), (3) (1), (2), (3)

81.433 Virginia.

James River Face Wilderness. (2) (2) (2) (2), (5)

Shenandoah NP (2), (3) (1), (2), (3) (2), (3) (1),(2),(3),(5)

81.435 West Virginia.

Dolly Sods/Otter Creek Wilderness. (2), (3) (1), (2), (3) (1), (2), (3) (1),(2),(3),(5)

Key 

(1) MRPO Back Trajectory Analyses

(2) MRPO PSAT Modeling 

(3) MANE-VU Contribution Assessment 

(4) Missouri-Arkansas Contribution Assessment 

(5) VISTAS Areas of Influence 
On-the-Books Control Measures Used in MRPO Analysis 1

• Power Plants 

o Title IV (Phases I and II) 

o NOX SIP Call 

o Clean Air Interstate Rule 

• On-road Mobile Source Programs 

o Federal Motor Vehicle Emission Control Program 

o Inspection – maintenance programs 

o Reformulated gasoline 

• Non-road Mobile Source Programs 

o Federal control programs 

o Large Spark Ignition and Recreational Vehicle standards 

o Heavy-duty diesel (2007) engine standard / Low sulfur fuel 

o Federal railroad/locomotive standards 

o Federal commercial marine vessel engine standards 

• Area Sources 

o Consumer solvents 

o Architectural and industrial maintenance coatings 

o Aerosol coatings 

o Portable fuel containers 

• Other Point Sources 

o VOC 2-, 4-, 7-, and 10-year MACT standards 

o Combustion Turbine MACT 

o Consent decrees (refineries, ethanol plants, and ALCOA) 

o NOX Reasonably Available Control Technology (RACT) in Illinois, Ohio 

and Wisconsin 

 

1

 Regional Air Quality Analyses for Ozone, PM2.5, and Regional Haze: Technical Support Document. 

LADCO. Online. 

http://www.ladco.org/reports/technical_support_document/tsd/tsd_version_iv_april_25_2008_final.pdf . 

September 15, 2010. 
1

Wisconsin 

Smoke Management 

Best Management 

Practices for 

Prescribed Burns 
2

Wisconsin Smoke Management Best Management Practices 

Table of Contents 

 

 Page

Introduction 3 

 

Smoke Management Best Management Guidelines 5 

 

Glossary 13 

Literature Cited 17 

Appendices: 

 A – Federal and State Laws Related to Smoke Management 19 

 B – Managing Prescribed Fire in Wisconsin 23 

 

 C -- Smoke Production and Dispersion 25 

 D – Guideline for Use of the Ventilation Index 28 
3

INTRODUCTION

Prescribed fire is an important tool in Wisconsin for restoring and maintaining fire dependent 

ecosystems, providing wildlife habitat, reducing hazardous fuel buildups, meeting silvicultural and 

other needs. However, wildland fire (wildfire and prescribed fire) can be a large, intermittent source 

of particulates that have the potential to cause significant short-term impacts on human health, 

welfare, safety, and visibility. This Smoke Management Best Management Practices (SMBMP) 

document has been developed to minimize those potential air quality impacts while optimizing the 

opportunity to use fire as a land management tool. 

In 2005, several public and private land management agencies and organizations agreed to develop 

and implement SMBMP to mitigate potential air quality impacts from prescribed fire. In general, 

agencies and organizations in Wisconsin that conduct prescribed burns prepare site specific 

individual burn plans. State law and/or local ordinances may require burn permits for “open 

burning.” Currently most prescribed fire plans include provisions that address the effects of smoke. 

These SMBMP will begin a formal effort to minimize impact of smoke produced from managed 

wildland fires in Wisconsin. 

The signatories to this SMBMP document agree to abide by its provisions for prescribed fires they 

ignite for resource benefit. These SMBMP have been developed based on the principles identified in 

Section VI, “Smoke Management Programs” of the U.S. Environmental Protection Agency’s (EPA) 

April 23, 1998 “Interim Air Quality Policy on Wildland and Prescribed Fires” 

(http://fire.r9.,fws.gov/ifcc/smoke/EPA_Policy.htm ) 

The Lands and Forestry Divisions and the Bureau of Air Management (Air and Waste Division) of 

the Wisconsin Department of Natural Resources (WDNR) serve as the central authority for the 

State’s SMBMP. The SMBMP guidelines will become effective when the Department WDNR certifies 

in writing to Environmental Protection Administration (EPA) that a SMP has been adopted and 

implemented. The SMBMP document should be reviewed annually and amended as necessary to 

achieve the purpose of the SMBMP and incorporate changes in regulations, policies and advances 

in technology. 

Organizations that May Wish to Sign-on to the SMBMP 

In Wisconsin, The Nature Conservancy (TNC), WDNR, National Park Service (NPS), U.S. Fish & 

Wildlife Service (USFWS), U. S. Forest Service (USFS), Department of Defense (DOD), the Bureau 

of Indian Affairs (BIA), Menominee Indian Tribe of Wisconsin (MITW), Pheasants Forever, and 

several non-profit conservation groups all use fire to accomplish goals and objectives ranging from 

ecosystem management to fuels reduction. USDA conservation programs (i.e. Conservation 

Reserve Program, Wildlife Habitat Incentives Program) offered through the Farm Service Agency 

and Natural Resources Conservation Service (NRCS), place an emphasis on prescribed fire, making 

the increased use of prescribed fire in the private sector a general trend. 

Signing organizations agree to follow the SMBMP guidelines in the next section as part of their burn 

plan. 

Use of Fire as an Ecosystem Management Tool in Wisconsin 

The use of prescribed fire presents the need to weigh the trade-offs associated with the ecological 

benefit of this practice vs. the impact of increased emissions from current and accelerated burning 

programs. Part of this trade-off involves the careful consideration of and application of smoke 

management techniques to minimize the impact of emissions, while still meeting ecological needs. 

An example of this trade-off to be considered is the increased fuel consumption from a wild fire 
4

burning under severe meteorological conditions versus the reduced fuel consumption of a 

prescribed fire ignited that might burn under moderate weather conditions. 

Many of the vegetative cover types within the state evolved with fire as the natural process for 

restoration and maintenance (Curtis). Prescribed fire, therefore, is the preferred management tool 

when safety and environmental conditions permit. Vegetative types ranging from grasslands and 

prairie plantings, to wetlands, savannas, conifer and hardwood forests, brush lands and agricultural 

fields are all treated with fire. Broadcast burning is the preferred method for landscape scale land 

treatments. Piled slash is burned throughout the year for cover type conversion, site preparation, 

and to mitigate insect and disease related problems, such as oak wilt. 

Use of prescribed fire has been intermittent since the post-logging era wildland fires. The various 

ecosystem types that have a fire dependent element reflect the impacts of this intermittent pattern. 

Savannas, pine barrens, grasslands, and many other plant communities require fire for health and 

maintenance. The differing degree of fire occurrence over the past 100 years has contributed to the 

loss of acreage of these ecosystems. 

In summary, the main reasons to use prescribed fire include: 

 Wildlife habitat improvement and maintenance 

 Site preparation and seed production 

 Ecosystem management and restoration 

 Maintenance of biological diversity 

 Restoration of fire as a natural process 

 Control of insect and disease 

 Fuel reduction, including hazardous fuels 

 Minimizing the potential for significant air quality impacts from wildfire 

 The training of fire personnel resources 

 Testing of fire suppression equipment and suppression techniques. 
5

SMOKE MANAGEMENT BEST MANAGEMENT PRACTICES GUIDELINES

Purpose 

These Smoke Management Best Management Practices (SMBMP) are a set of guidelines and 

procedures that are followed by signatory organizations to reduce the adverse effects of smoke from 

prescribed fires. The goal of the Wisconsin SMBMP is to prevent violations of the federal fine 

particles standard (PM2.5) and minimize adverse effects including: 

 Health effects from smoke inhalation 

o Premature death 

o Decreased lung function 

o Increased asthma attacks and chronic bronchitis 

o Acute respiratory symptoms 

o Respiratory and cardiopulmonary related hospital admissions 

o Increased work and school absences 

 Visibility related travel hazards 

o Aircraft 

o Highways 

o Rail 

 Electric utility hazards 

 Violations of an ambient air quality standard 

 Decreased visibility in scenic vistas 

Authorization to Burn 

The WDNR Division of Forestry is responsible for issuing permits for open burning in organized 

protection areas, outside of incorporated cities or villages, of Wisconsin (Figure 1), for forest fire 

protection purposes. In cooperative protection areas, town chairpersons are responsible for issuing 

permits for open burning for forest fire protection purposes. This authority is stated in Wisconsin 

State Statute Chapter 26 and associated administrative rules. 

The WDNR issues written permits for open burning of vegetative materials. A permit is not required 

when the ground is covered with snow. Permitting of open burning is also administered locally when 

municipalities or townships have local ordinances more restrictive than the state rules. 

Wisconsin Administrative Code, NR 429.04(1), prohibits open burning with certain exceptions. One 

of those exceptions is backfires to control forest fires or fires set for forest or wildlife habitat 

management with the approval of the department where no reasonable alternative is available. 

Factors in considering the reasonableness of alternatives may include: 1) costs of other alternatives, 

2) availability of other alternatives; or 3) effectiveness of each of the other alternatives in comparison 

to a prescribed burn in achieving the land management objectives. In addition, NR 429.04(2) 

specifies that all allowed open burning shall be conducted in a safe pollution-free manner, when 

wind and weather conditions will minimize adverse effects and in conformance with local and state 

fire protection regulations. 

Prescribed burning on public lands in Wisconsin is done under the on-site supervision of an agency 

certified burn boss. 
6

Figure 1 

Historically the Federal agencies in Wisconsin have complied with state burning regulations. 

Procedures for coordinating open burning restrictions between state and federal agencies have 

been handled by the Wisconsin Interagency Fire Council. These SMBMP are a formal agreement 

among signatory agencies for state burning regulation compliance for the purposes of future smoke 

related emission and impact reduction. 

In the event that an air quality watch or advisory is declared by WDNR, signatories to this SMBMP 

agree to cancel all open burning related to prescribed fire use for the applicable county or counties 

affected by the burn while the advisory remains in effect. The WDNR has a website at 

http://dnr.wi.gov/air/aq/health/status.asp for air quality watches and advisories. 

Burn Plans 

All signatories to this SMBMP agree to have burn plans that incorporate the elements listed below. 

They should be on file at agency or organization offices and are available upon request. These 

prescribed burn plans will include the following elements at a minimum: 

 Location and legal description (Town, Range, Section and quarter-quarter section) of the 

area to be treated, including ownership. 

 Personnel and/or certified prescribed burn boss responsible for managing the fire. 

 Type of vegetation or fuel model (utilizing the National Fire Behavior Prediction System) to 

be burned. 

 Area in acres to be burned. 

 Amount of fuel to be consumed* 

 Fire prescription including smoke management components and ventilation index limits. 

 Criteria the fire manager will use for making go-no-go burn decisions. 
7

 Safety and contingency plans. 

*As an example, if burning in a fuel model 6 (brush fuel type), and the objective is to top kill 75% of 

the woody vegetation ,this can be calculated by multiplying average fuel present (6 tons/acre) by 

75%. This results in amount of fuel to be consumed equaling 4-1/2 tons/acre. 

Smoke Management Best Management Practices for Burn Plans 

Actions to Minimize Fire Emissions – The burn plan should document the steps to be taken prior to, 

during, and after the burn to reduce air emissions. This could include, but may not be limited to, any 

of the following measures (NWCG Smoke Management Guide for Prescribed and Wildland Fires, 

2001): 

 Minimize the area burned; reduce the acreage burned per burning period, or use non-fire 

treatments. 

 Reduce the fuel loading in the area to be burned by mechanical means, or by using frequent, 

low intensity burns to gradually reduce fuels. 

 Reduce the amount of fuel consumed by the fire by burning when large non-target fuel 

moistures and duff moistures are higher. 

 Minimize emissions per ton of fuel consumed, by using mass ignition techniques, using 

backing fires, increasing combustion efficiency and performing rapid and complete mop-up. 

 Pre-treat heavy fuels or use firing techniques that exclude them from the burn.

 Minimize potential smoke impacts on sensitive receptors

Evaluate Smoke Dispersion and Sensitive Receptor Sites

Prescribed burn plans should identify and evaluate potential smoke impacts on sensitive receptors. 

Fires should be timed to minimize exposure of sensitive populations (those that smoke may present 

particular health risks). 

There are 5 steps to address sensitive receptor sites and smoke dispersion: 

1. Identify and list sensitive receptor sites 

2. Specify the requirements for smoke dispersal at sensitive receptor sites 

3. Check for Air Quality Watches or Advisories 

4. Notify affected populations and authorities 

5. Identify monitoring plans for sensitive receptor sites 

These steps are further described below. 

1. Identify and list sensitive receptor sites 

Sensitive receptor sites are usually defined as locations where human populations tend to 

concentrate and where smoke could impact the health of those populations or significantly impact 

visibility that may be detrimental to health or the enjoyment of scenic qualities of the landscape. 

These may be residential concentrations in the form of towns or cities, or locations where people 

tend to gather in groups such as parks and schools. Travel routes such as highways may be 

labeled as sensitive receptor sites where smoke can be a factor in potential motor vehicle accidents. 

Particular areas along highways or other locations may be more prone to being declared sensitive 

receptor sites because of topographic and microclimate features. 

2. Specify the requirements for smoke dispersal at sensitive receptor sites 

The plan should identify the distance and direction from the burn site to local sensitive receptor 

areas where appropriate. Fire prescriptions will specify minimum requirements for the atmospheric 

capacity for smoke dispersal such as minimum surface and upper level wind speeds, desired wind 

direction, minimum mixing height, and dispersion index. Utilize the Ventilation Index explained in 

Appendix D for minimum requirements. 
8

Another source of information for burn day decisions in counties with an air quality monitor is the Air 

Quality Index (AQI). Check the AQI for the area of the burn and downwind impact zone on the 

WDNR internet website, at http://dnrmaps.wi.gov/wisards . Values at or above the AQI orange 

(unhealthy for sensitive groups) or red (unhealthy) categories for the burn and the downwind impact 

zone should be considered in the decision making process. 

3. Check for Air Quality Watches or Advisories 

The burn boss or prescribed fire manager responsible for a proposed prescribed burn has the 

responsibility to assure that there is no air quality advisory or watch in effect for the county or 

counties affected by smoke dispersal on the day that the prescribed burn occurs. Check the WDNR 

website at http://dnr.wi.gov/air/aq/health/status.asp or the National Weather Service website at 

http://www.crh.noaa.gov/mkx/ which posts air quality watches and advisories. 

4. Notify affected populations and authorities 

The burn plan should identify actions that will be taken to notify populations and authorities at 

sensitive receptors, including those in adjacent jurisdictions, prior to the fire. The plan should also 

identify contingency recommendations that should be taken during a fire to reduce the exposure of 

people at sensitive receptors if smoke intrusions occur. These recommendations are from the 

National Wildfire Coordinating Group’s Smoke Management Techniques Course (Rx-410) and 

include the following: 

 Notify sensitive receptors and DNR Air Management as soon as possible when 

conditions change. 

 Place field observers at sensitive receptors to monitor smoke conditions. 

 Work with local health agencies and DNR Air Management (issues air quality health 

advisories). 

 Relocate smoke-sensitive people. 

 Terminate project. 

 Accelerate completion of project. 

5. Identify monitoring plans for sensitive receptor sites 

The plan should identify how the effects of the fire on air quality at sensitive receptors areas should 

be monitored. The extent of the monitoring plan should match the size of the fire, fuel loading and 

consider the proximity to smoke sensitive areas. For small, or short duration fires (such as those in 

grass or leaf litter), visual monitoring of the directions of the smoke plume and monitoring nuisance 

complaints by the public may be sufficient. Other monitoring techniques include posting personnel 

at sensitive receptors to look for smoke intrusions and continued tracking of meteorological 

conditions during the fire. For fires in fuels with longer duration burning (such as timber litter or 

slash), and which are expected to last more than one day, locating real-time PM monitors at 

sensitive receptors may be warranted to facilitate timely response to smoke impacts. 

Smoke Management Best Management Practices Related to Road Impacts

The Wisconsin Department of Transportation (WDOT) is responsible for maintaining the state and 

federal highways within Wisconsin. WDOT has 8 Region offices to serve the transportation needs of 

Wisconsin motorists, location and right-of-way contacts are available on the following web site 

www.dot.wisconsin.gov/business/rules/docs/contact-row.pdf. 

Planning for smoke management adjacent to state and federal highways begins with contacting the 

local WDOT Regional Office to determine if a DOT permit is required. If a prescribed burn is being 

planned within WDOT right-of-way (ROW) by another state or federal land management agency, 

organization or private landowner, and a DOT permit is required, the following documents will be 

submitted to the WDOT Regional Right of Way permit contact: 
9

1. Application/Permit To Work on Highway Right-Of-Way (WDOT Form DT 1812) 

2. The Burn Plan 

*WDOT forms are available from the local Regional office and online 

www.dot.wisconsin.gov/forms/docs/dt1812.doc. 

Processing time for permit approval is up to 30 days and is intended for non-emergency activities. 

The approval of an annual permit rather than an individual permit may be desirable to accommodate 

flexibility in the time range to complete multiple burns adjacent to highways planned by state and 

federal land managers. 

The thresholds for pre-planning the distance of a burn from travel routes should be determined on a 

site-by-site basis. Property ownership, rural vs. urban environment, average daily traffic (ADT) and 

the justification for burning within the vegetated ROW should be evaluated and addressed within the 

burn plan. 

Participation in the WDOT ROW permit process as described above should assure that the Burn 

Boss/Fire Manager should receive specific information on the required signage and its proper 

placement within the ROW. The WDOT brochure Work Zone Safety: Guidelines for Construction, 

Maintenance, & Utility Operations is an excellent reference and is available on line at 

www.dot.wisconsin.gov/business/rules/docs/wzsb.pdf . The use of electronically programmable 

signs for smoke warning and speed reduction is an option. The responsibility for providing standard 

signs or renting the programmable signs lies with the agency or organization conducting the 

prescribed burn. Traffic control devices placed and maintained by the State, County, City or other 

local officials are required by Wisconsin Law to conform to the Wisconsin Manual on Uniform Traffic 

Control Devices. The manual can be downloaded from www.dot.wisconsin.gov/business/engrserv/ . 

For emergency situations fire officials should immediately call 911 or local law enforcement or 

contact the local Region WDOT Emergency Coordinator for the fastest response. The use of 

signage, the decision to temporarily close a state or federal highway and to reroute traffic must be 

coordinated with WDOT in cooperation with fire officials and law enforcement. 

Responsibility for county, city, or town roads is under the jurisdiction of the local unit of government. 

Fire managers/burn bosses need to contact local highway officials for the permitting process. 

Please refer to the following website for contact information for each County Highway Commissioner 

in Wisconsin www.wcha.net/CO/Co_Map_Page.htm . 

Authority to control traffic must be coordinated with state, county, or local units of government having 

jurisdiction over the road. The best practice would be not to burn when it is apparent that

smoke would be placed over a roadway. 

For detailed information about all roads within the state of Wisconsin including State and Federal 

Routes, County roads, Town roads or others, please visit the following website: 

www.dot.wisconsin.gov/travel/maps . 

Smoke Management Best Management Practices Related to Railway Impacts 

Contact the emergency management representative for the specific railroad effected. These 

representatives should have firsthand knowledge of their internal processes for emergency response 

to smoke and the timing of rail activity along the rail line. 
10

The Official Rail Map and directory of railroads is available from the WDOT public website: 

www.dot.wisconsin.gov/travel/rail . The Wisconsin Rail Map, Emergency Railroad Phone Numbers

and Required Clearances near Railroad Tracks are just a few of the documents available to assist in 

planning for smoke management along railroad corridors. 

 Smoke Management Best Management Practices Related to Air Traffic Impacts 

The coordinating agency should contact any private and/or public airport within 10 miles of the 

closest burn perimeter so that air traffic control is aware of the situation. Prescribed burning within 5 

miles of an airport perimeter should be closely coordinated with the airport manager/owner so that 

the burn does not conflict with airport usage (e.g. new pilot training). Airport locations can be 

obtained using www.dot.wisconsin.gov/travel/air . This link can provide detailed information on 

locations and contact information. 

Smoke Management Best Management Practices Related to Utility Impacts 

The safety of fire line personnel in relation to fire use near overhead transmission lines, where 

smoke, ash and incidental mist from fire line operations may contaminate the insulators on 

transmission structures is a consideration. Standard utility recommendations are to maintain a 

minimum radial distance of 35 feet between firefighters, vehicles and transmission structures to 

protect fire fighting personnel from this electrical hazard. Further recommendations would be to 

place containment lines no closer than 100 feet of and parallel to the edge of the outer most 

conductor. 

Planning to address the direction and dispersion of smoke in these situations is critical as a heavy 

smoke plume on power lines may cause a conductor to ground short. Consider including any utility 

owner or operator that maybe impacted in the planning process. Qualified company representatives 

are responsible for safely adhering to all other rules pertaining to this subject matter. 

Smoke Management Best Management Practices and Dispersion 

The National Weather Service (NWS) forecast offices in Green Bay, Sullivan, LaCrosse, Duluth, MN, 

and Minneapolis, MN provide twice daily fire weather forecasts every day during the fire season 

(generally April 1 to November 1). The fire weather forecasts issued by the respective NWS offices, 

at 0700 and again by 1500, include projected smoke management information. The Fire Weather 

Annual Operating Plan (FWAOP) available at the forecast offices or most agency dispatch or 

coordination centers provides extensive forecast information. State and Federal Agency Prescribed 

fire managers who plan ignitions at other than the forecast time may request dispersion/ventilation 

criteria as part of a spot weather forecast from the NWS. At this time a spot weather forecast from 

the NWS is not available to the private sector. 

To ensure optimum dispersal of smoke emissions during prescribed burns, the mixing height should 

be deep enough and have sufficient transport wind speed to ensure the dilution and dispersal of 

emission concentrations. The ventilation index multiplies mixing height (measured in feet) and 

transport wind speed (measured in knots per hour) to produce an index that expresses the ability of 

the atmosphere to disperse emissions. This dispersion information is included as part of the daily 

fire weather forecast. It describes the mixing height, transport wind speed and ventilation index for 

the peak or low conditions during the forecast period. For more information on the ventilation index 

refer to Appendix D. 

Public Education and Awareness 

Agencies and organizations should work to establish and maintain programs to stress the use and 

importance of fire for ecosystem and related land management goals. Public health and safety are 

critical to this effort. The Wisconsin Prescribed Fire Council has been working towards this goal 

since 2002. 
11

Surveillance and Enforcement: 

Failing to follow the burn plan prescription, agency and TNC certified burn bosses would be subject 

to that organization’s specific review protocols and possible disciplinary action. Formal after-action 

reports generated by any agency review should be forwarded to that agency’s representative to the 

Wisconsin Interagency Fire Council (WIFC). The agency representative will then forward the review 

on to the remaining members of WIFC, to promote lessons learned. Agencies are encouraged to 

include private sector members from the Wisconsin Prescribed Fire Council Board of Directors in 

any after-action review. Agency-certified prescribed burn bosses follow a pre-burn go-no-go 

procedure to ensure that the burn day parameters meet the burn plan prescription including 

SMBMP. 

Private sector agencies, who are signatories on this SMBMP, who do not follow the burn plan 

prescription would be subject to the following peer review protocol. Smoke intrusions and/or 

escaped prescribed burn are two examples that could trigger a review. A three person review team 

will be organized consisting of: 1) representative chosen by the private burn boss, 2) WDNR 

representative, and 3) representative from the WIFC agreed to by both WDNR and the private burn 

manager/boss. The group would review the burn proposal, weather conditions, go-no-go decision 

process, and other factors regarding the prescribed burn. The review team would make 

recommendations to the WDNR and WIFC as to appropriate corrective actions. These actions could 

include (but are not limited to): no action (plan was good and followed), removal as a signatory to the 

SMBMP document, prescribed burn plans requiring a peer review before being implemented, or 

denied future approval under NR429. WDNR, as the central authority, in consultation with WIFC 

would make the finial determination on recommended actions. Should legal action be taken for a 

prescribed burn that may trigger a review, the review may be delayed or pre-empted by necessary 

legal considerations. 

Private sector burn managers/burn bosses are encouraged to summit one burn plan per year to the 

WDNR Fire Operations Specialist (1500 N. Johns Street, Dodgeville, WI 53533) for a peer review. 

Private sector burn bosses are encouraged to utilize Wisconsin Prescribed Fire Council’s go-no-go 

checklist to ensure that the burn day parameters meet the burn plan prescription, including smoke 

management concerns. 

Optional Air Quality Protection 

Agencies should consider opportunities to establish specific, stringent protection for those special 

areas requiring additional regulation in the interest of public health and safety. Recognition of these 

areas should be documented in site-specific burn unit plans, along with the steps to minimize 

impacts. 

Program Evaluation 

To evaluate the effectiveness of the SMBMP, an interagency prescribed fire stakeholder group 

should annually review information on acres burned by fuel type with prescribed fire. Reports of 

nuisance complaints or smoke intrusions should be noted and the interagency prescribed fire 

stakeholder group should use this information to measure the effectiveness of this plan. The WDNR 

recommends that SMBMP member agencies maintain records necessary to demonstrate an 

Exceptional Event, per Environmental Protection Agency 40 CFR Parts 50 and 51, Treatment of 

Data Influenced by Exceptional Events; Final Rule, for the necessary time that the WDNR is 

required to report data to the EPA. In 2009, the duration was 4 years. 

In addition, the WDNR should review data from the existing PM2.5, and ozone monitors in Wisconsin. 

Correlations of air quality (NAAQS) with prescribed fire should be assessed for the interagency 

prescribed fire stakeholder group. In the event an exceedance (PM10, PM2.5, or ozone) is recorded, 

WDNR will notify the principal contacts listed in the Memorandum of Agreement between the 
12

signatories of these SMBMP to ensure the documentation necessary to demonstrate an Exceptional 

Event is collated and available. 

The interagency prescribed fire stakeholder group should also review annually: 

 The acres of prescribed burns by fuel type and any associated air quality issues, 

 The need for changes in the SMBMP. 

This SMBMP document is an evolving and will undergo ongoing evaluation using stakeholder input. 

Upon implementation of this plan, signatories should annually submit electronically on WDNR forms 

by January 31 of each year to the Forest Protection Section – Operations Specialist the following: 

 Acres prescribed burned by fuel type for the previous calendar year. 

 Date of burns. 

 Duration of burns. 

 Moisture content (if available) 

 Location and legal description of burns conducted. 

 Nuisance complaints or smoke intrusions. 

WDNR will estimate emissions based upon stakeholder inputs for inclusion in the annual emissions 

report for the previous calendar year to EPA. 
13

GLOSSARY

Air Quality -- The characteristics of the ambient air (all locations accessible to the general 

public) as indicated by concentrations of the six air pollutants for which national standards 

have been established [i.e., particulate matter (PM), sulfur dioxide (SO2), nitrogen dioxide 

(NO2), ozone (O3), carbon monoxide (CO) and lead], and by measurement of visibility in 

mandatory Federal Class I areas. 

Air Quality Advisory -- An air quality advisory is issued when the ambient air quality in an 

area is unhealthy for sensitive individuals or when the air quality is expected to degrade to 

that level within a few hours. 

Air Quality Watch – An air quality watch is called for an area when the air quality forecasts 

for the next day, or the next few days, indicates that there is a potential for air quality to 

become unhealthy for sensitive individuals. 

Ambient Air -- That portion of the atmosphere, external to buildings, to which the general 

public has access. 

Attainment area -- A geographic area in which levels of a criteria air pollutant meet the 

national ambient air quality standard, or NAAQS for the pollutant. An area may have on 

acceptable level for one criteria air pollutant, but may have unacceptable levels for others. 

Thus, an area could be both attainment and non-attainment at the same time. Attainment 

areas are defined using federal pollutant limits set by EPA. 

Burn Boss -- Person responsible for supervising a prescribed burn from ignition through 

mop-up. 

Class I Area -- An area set aside under the Clean Air Act (CAA) to receive the most 

stringent protection from air quality degradation. Mandatory Class I Federal areas are (1) 

international parks, (2) national wilderness areas which exceed 5,000 acres in size, (3) 

national memorial parks which exceed 5,000 acres in size, and (4) national parks which 

exceed 6,000 acres and were in existence prior to the 1977 CAA Amendments. The 

extent of a mandatory Class I Federal area includes subsequent changes in boundaries, 

such as park expansions. 

Combustion -- Burning. Many important pollutants, such as sulfur dioxide, nitrogen oxides, 

and particulates (PM10) are combustion products, often products of the burning of fuels such 

as coal, oil, gas and wood 

Criteria air pollutants -- A group of very common air pollutants regulated by EPA on the 

basis of criteria (information on health and/or environmental effects of pollution) and for 

which NAAQS have been established. In general, criteria air pollutants are widely distributed 

all over the country. They are: particulate matter (PM), carbon monoxide (CO), sulfur dioxide 

(SO2), ozone (03), Nitrogen Oxide (NOx) and lead (Pb). 
14

Emission -- Release of pollutants into the air from a mobile source (e.g. vehicle), stationary 

source (e.g. industry), or area sources (e.g. gas stations, chimneys, vegetative burning). We 

say sources emit pollutants 

Fuel -- Includes combustible vegetative matter such as grass, trees, shrubs, limbs, 

branches, duff, and stumps.

Haze -- Particles in the air that scatter light and degrade visibility. 

Monitoring (monitor) -- Measurement of air pollution is referred to as monitoring. EPA, state 

and local agencies measure the types and amounts of pollutants in the ambient in 

community air. 

National Ambient Air Quality Standards (NAAQS) -- National standards for maximum 

acceptable concentrations of “criteria” pollutants in the ambient air. Designed to protect 

public health with an adequate margin of safety (primary standard), and to protect public 

welfare from any known or anticipated adverse effects of such pollutants (e.g., visibility 

impairment, soiling, materials damage, etc.) in the ambient air (secondary standard). 

Non-attainment area -- A geographic area in which the level of a criteria air pollutant is 

higher than the level allowed by the federal standards. A single geographic area may have 

levels that are acceptable of one criteria air pollutant but unacceptable levels of one or more 

other criteria air pollutants; thus, an area can be both attainment and non-attainment at the 

same time. 

Nuisance Smoke -- Amounts of smoke in the ambient air, that interfere with a right or 

privilege common to members of the public, including the use or enjoyment of public or 

private resources. 

Ozone -- A highly reactive gas consisting of three oxygen atoms. 

Particulate Matter (PM) --Any airborne finely divided material mixture of very small particles 

that are suspended in the atmosphere, except uncombined water, which exists as a solid or 

liquid at standard conditions (e.g., dust, smoke, mist, fumes, or smog). 

PM10 -- Particles with an aerodynamic diameter less than or equal to a nominal 10 

micrometers (including PM2.5). Concentrations in the air are measured as micrograms per 

cubic meter of air (μg/m3). 

PM2.5 -- Particles with an aerodynamic diameter less than or equal to a nominal 2.5 

micrometers. Concentrations in the air are measured as micrograms per cubic meter of air 

(μg/m3

). 

Prescription -- Measurable criteria that guide selection of appropriate management 

response and actions. Prescription criteria may include the meteorological conditions 

affecting the area under prescription, as well as factors related to the state of the area to be 

burned such as the fuel moisture condition and other physical parameters. Other criteria 
15

which may be considered include safety, economic, public health, environmental, 

geographic, administrative, social or legal considerations, and ecological and land use 

objectives. 

Prevention of Significant Deterioration (PSD) -- A requirement in the Clean Air Act, which 

establishes the maximum allowable increases in ambient air concentrations of selected air 

pollutants above baseline concentrations in areas designated as Class I, Class II, or Class 

III. 

Prescribed Fire -- Any fire ignited by management actions to meet specific objectives. For 

federal agencies a written, approved prescribed fire plan must exist, and NEPA 

requirements (where applicable) must be met, prior to ignition.

Sensitive populations -- Those populations to which smoke emissions may present 

particular health risks.

Sensitive Receptors -- Locations where human population tend to concentrate and where 

smoke could impact the health of those population or significantly impact visibility that may 

be detrimental to either health or the enjoyment of scenic qualities of the landscape. These 

may be residential concentrations in the form of towns or cities, or locations where people 

tend gather in groups such as parks. Travel routes such as highways may be labeled as 

sensitive receptor sites where smoke can be a factor in potential motor vehicle accidents. 

Particular areas along highways or other locations may be more prone to being declared 

sensitive receptor sites because of topographic and microclimate features. (i.e.--Population 

centers such as towns and villages, camp grounds and trails, hospitals, nursing homes, 

schools, roads, airports, mandatory Class I Federal areas, etc. where smoke and air 

pollutants can adversely affect public health, safety and welfare.) 

Smoke Management Best Management Practices (SMBMP) -- Establishes a basic 

framework of procedures and requirements for managing smoke from fires that are 

managed for resource benefits. The purposes of SMBMPs are to mitigate the health, 

nuisance and public safety hazards (e.g., on roadways and at airports) posed by smoke 

intrusions into populated areas; to prevent deterioration of air quality and NAAQS violations; 

and to address visibility impacts in mandatory Class I Federal areas in accordance with the 

regional haze rules. 

Source -- any place or object from which pollutants are released, such as power plants, 

factories, dry cleaners, gas stations, farms, motor and consumer products. 

State Implementation Plan (SIP) -- State implementation plans are collections of the 

regulations and emission reduction measures used by a state to reduce air pollution in order 

to attain and maintain NAAQS or to meet other requirements of the Act. The Clean Air Act 

requires that EPA approve each state implementation plan. 

Violation of the PM NAAQS -- As revised in 2006, the daily PM10 standard is violated when 

the 99th percentile of the distribution of 24-hour concentrations for a period of 1 year 

(averaged over 3 calendar years) exceeds 150 μg/m3 at any monitor within an area. PM2.5

are set at a daily concentration less than or equal to 35 μg/m3

, and an annual mean 
16

concentration of less than or equal to 15 μg/m3. For PM2.5 the daily standard is violated 

when the 98th percentile of the distribution of the 

24-hour concentrations for a period of 1 year (averaged over 3 calendar years) exceed 35 

μg/m3 at any monitor within an area. The annual standard is violated when the annual 

arithmetic mean of the 24-hour concentrations from a network of one or more populationoriented monitors (averaged over 3 calendar years) exceeds 15 μg/m3

. 

Wildfire -- An unplanned and unwanted wildland fire including unauthorized human-caused 

fire, escaped prescribed fire projects, and all other wildland fires where the objective is to 

put the fire out. 

Wildland Fire -- Any non-structural fire that occurs in the wildland. Two distinct types of 

wildland fire have been defined in Wisconsin and include wildfire and prescribed fire. 

Wisconsin Interagency Fire Council – The Wisconsin Interagency Fire Council consists of 

representatives of the Wisconsin Department of Natural Resources, US Fish & Wildlife 

Service, US Forest Service, Menominee Tribal Enterprises, Bureau of Indian Affairs and 

National Park Service. For the purposes of the Smoke Management Best Management 

Practices, WIFC would also include representatives of the other signatories to the SMBMP 

including, but not limited to, The Nature Conservancy and the Wisconsin Prescribed Fire 

Council.
17

LITERATURE CITED 

Anderson, G.K., Sandberg, D.V., Norheim, R. 2004. Fire Emissions Production Simulator (FEPS) 

User’s Guide ver. 1. USDA Pacific Northwest Research Station, Fire and Environmental Research 

Applications team. Seattle, WA 

Anderson, H.E. 1982. Aids in Determining Fuel Models for Estimating Fire Behavior. Gen. Tech. 

Rep. INT-122. Fort Collins, CO. 

Curtis, J.T. 1959. The Vegetation of Wisconsin: An Ordination of Plant Communities. Univ. of 

Wisconsin Printing. Madison, WI 

Dorney, J. R. 1981. The Impact of Native Americans on Pre-settlement Vegetation in Southeastern 

Wisconsin. Wisconsin Academy of Sciences, Vol. 69: 26-36. 

Dorney, C.H., Dorney, J.R. 1989. An Unusual Oak Savanna in Northeastern Wisconsin: The Effect 

of Indian-Caused Fire. American Midland Naturalist, Vol. 122, #1: 103-113. 

EPA. 1992. Prescribed burning background document and technical information document for 

prescribed burning best available control measures. Office of Air Quality Planning and Standards, 

Research Triangle Park, NC 27711. EPA-45012-92-003. 

EPA. 1998. Interim air quality policy on wildland and prescribed fires. Office of Air Quality Planning 

and Standards, Research Triangle Park, NC 27711. 

Michigan DNR. 2006. Michigan Smoke Management Program. 

MN ICS. 2007. Minnesota Smoke Management Plan. 

National Wildfire Coordination Group. 2001. Smoke Management Guide for Prescribed and Wildland 

Fire. PMS 420-2. Boise, ID. 

National Wildfire Coordination Group. 2003. Smoke Management Techniques Instructor Guide, 

Course RX-410. NFES 2475, Boise, ID 

Ottmar, R. D., and R. E. Vihnanek. 1999. Stereo photo series for quantifying natural fuels. Volume 

V: Midwest Red and White Pine, Northern Tallgrass Prairie, and Mixed Oak Types in the Central and 

Lake States. PMS 834. Boise, ID. 

Peterson, J., and B. Leenhouts. 1997. What wildland fire conditions minimize emissions and 

hazardous air pollutants and can land management goals still be met? (Unpublished support 

document to the EPA Interim Air Quality Policy on Wildland and Prescribed Fires. August 15, 1997.) 

Sandberg, D.V., Ottmar, R.D., Peterson, J.L., and Core, J. 2002. Wildland fire on ecosystems: 

effects of fire on air. Gen. Tech. Rep. RMRS-GTR-42-vol. 5. Ogen, UT. 

Scott, J.H., Burgan, R.E. 2005. Standard fire behavior fuel models: a comprehensive set for use with 

Rothermel’s surface spread model. Gen. Tech. Rep. RMRS-GTR-153. Fort Collins, CO. 

Williams, G.W. 2000. Introduction to Aboriginal Fire Use in North America. Fire Mgmt Today 

60(Summer): 8-12. 
18

Table 1 

Interagency Prescribed Burns Completed 

Agency 2002 2003 2004 2005 2006 2007 2008 2009 Total 

Acres 

2002-

2009 

USF&WS 5677 6928 5996 9345 7681 9601 7982 7359 60569 

WDNR 18750 19750 19500 20000 19000 27000 21550 21330 166880 

USFS 586 2108 1259 1045 3211 1201 3450 775 13635 

TNC 818 636 609 418 895 596 375 550 4897 

Pheasants 

Forever 

100 150 295 200 850 870 500 775 13635 

NRCS 40 30 350 830 1015 3826 7010 13101 

DoD Fort 

McCoy 

5121 5583 5627 5270 5731 4856 3130 550 4897 

BIA 400 630 720 100 350 1258 3458 

WDOT 160 280 80 120 80 20 30 770 

Mississippi 

Valley 

Consevancy 

 129 56 22 60 267 

MITW 140 11 371 280 521 514 850 2936 

Total Acres 31052 35335 33727 37629 39198 45760 41677 48157 319087 

NOTE: The prescribed burn acres in Table 1 are the best data available; some burn acreage may 

have been missed or double reported.
19

APPENDICES

Appendix A 

Federal and State Laws Related to Smoke Management Best Management Practices 

Legal Requirements and Environmental Regulations for Wisconsin Smoke Management Best 

Management Practices 

The Clean Air Act (Public Law 95-95) as amended in 1977 and 1990 identifies standards and legal 

requirements that must be met by the EPA, other Federal agencies, the states, and industry. Prior 

to 1990, the Federal Clean Air Act did not directly address prescribed burning. However, the latest 

amendments contain a number of sections which may result in both direct and indirect regulatory 

controls. 

Section 109 of the Clean Air Act (CAA) requires EPA to develop primary ambient air quality 

standards to protect human health and secondary standards to protect welfare. In July of 1987, the 

EPA promulgated ambient air quality standards for those particulates less than 10 microns in 

diameter (PM10). The PM10 standards were designed to protect that portion of the population 

which is most susceptible to the effects of airborne respirable particles with an adequate margin of 

safety. However, more recent research indicated that the PM10 standard did not protect those 

people who already had existing respiratory problems. As a result EPA issued their initial fine 

particulate standards in July, 1997 to regulate those particulates less than 2.5 microns in diameter 

(PM2.5). These standards are of interest to the fire community because approximately 70% of the 

particulate emitted from biomass burning are in this size range. More current epidemiological 

studies indicate a much stronger relationship between increases in PM2.5 concentrations and 

mortality and morbidity. As a result, EPA revised these standards in September, 2006 reducing the 

24 hr standard from 65 to 35 micrograms per cubic meter (μg/m3). The annual standard stayed the 

same at 15 (μg/m3

). (Table B1, PM Ambient Air Quality Standards) 

Table A1 (From MI SMP 2007)

EPA’s PM Standards: Old and New

150 μg/m3

1 expected 

exceedance

150 μg/m3 Revoked

1 expected 

exceedance

50 μg/m3

Annual average

PM10

(Coarse 

Particles)

35 μg/m3

98th percentile

15 μg/m3

Annual average

65 μg/m3

98th percentile

15 μg/m3

Annual average

PM2.5

(Fine 

Particles)

Annual 24-hour Annual 24-hour

2006 Standards

September 21, 2006

1997 Standards

July 17, 1997

 
20

Wisconsin has several monitoring sites, Green Bay, Milwaukee and Madison, that have 

measured violations of the new 24-hour PM2.5 standard base on 2005 through 2007 monitoring 

data. Based on this information and additional monitoring data EPA has designated three 

nonattainment counties in Wisconsin: Milwaukee, Racine and Waukesha Counties. Wisconsin is 

currently working on a comprehensive plan with Illinois, Indiana, Michigan and Ohio to address 

ozone, PM2.5 and haze problems. DNR’s analysis indicates that the problem is regional in nature 

and the most effective way to deal with the problem is to limit emissions of SO2 and NOx on a 

regional basis. NOx comes from combustion in cars, trucks, off-road equipment, power plants and 

industrial sources. SO2 comes primarily from coal combustion in power plants and industrial 

boilers. 

Up-to-date monitoring data and monitor address information is available from the DNR web site at 

http://dnrmaps.wi.gov/wisards under the “Reports” and “Find Location” tabs. 

Section 110 CAA requires the state to develop State Implementation Plans (SIPs) which identify how 

the state will attain and maintain national ambient air quality standards (NAAQS) and meet other 

Federal air quality regulations. 

Section 112 identifies 188 hazardous air pollutants; the EPA has focused their attention on 33 of the 

188 pollutants at this time. Five of these are emitted from biomass burning: Acetaldehyde, Acrolein, 

1,3 Butadiene, Formaldehyde, and Polycyclic organic matter. While this section focuses control 

requirements on major and minor stationary air pollution sources, the State and EPA are trying to 

determine the risk to the public from all air toxic emission sources including biomass burning. 

Sections 160-169 provide for the prevention of significant deterioration of air quality in those areas of 

the county which currently have air quality concentrations which are better than the standards set 

under Section109. 

Section 169A provides visibility protection for the mandatory Federal Class I areas There are no 

Class I areas in Wisconsin where visibility is an air quality related value. However, Wisconsin must 

submit a plan to limit the effects of our sources on visibility on any Class I area. The closest Class I 

areas are in Michigan and Minnesota; i.e.. Seney National Wildlife Refuge and Isle Royale National 

Park in Michigan, and Voyageurs National Park and Boundary Waters Canoe Area Wilderness in 

Minnesota. 

Section 176 (c) prohibits Federal Agencies from permitting, approving, providing financial 

assistance, or supporting in any way an activity which does not conform to an EPA approved State 

Implementation Plan. This section of the Act only applies to federal agencies. However, a federal 

agency’s prescribed burn emissions are presumed to conform to these plans provided the burn is 

conducted under certified Smoke Management Best Management Practices (SMBMP), and thus no 

determination is required. 

Section 319 directs EPA to promulgate regulations governing the review and handling of air quality 

monitoring data influenced by an exceptional event. These regulations were designed to codify a 

number of existing EPA policies into a rule. That rule was published on March 22, 2007. The Rule 

provides that if exceptional events cause violations of the NAAQS, EPA would use its discretion not 

to re-designate an area as non-attainment. 

 

One of those policies included in the Rule was the 1998 EPA Interim Air Quality Policy on Wildland 

and Prescribed Fire. The policy integrated two public policy goals: (1) to allow fire to function as 
21

nearly as possible in its natural role in maintaining healthy wildland ecosystems, and (2) to protect 

public health and welfare by mitigating the impacts of air pollution emissions on air quality and 

visibility. The document identified significant procedural and legal benefits for the States and the 

users of wildland fire if they develop smoke management programs that are State certified. A State 

Smoke Management Program would establish a standard framework of those related procedures 

and requirements for managing smoke from prescribed fires. As a result of the new Exceptional 

Events Rule, EPA has committed to revise the Interim Policy, which will be forthcoming. 

The Rule defines an exceptional event as an event that: 

Affects air quality 

Is not reasonably controllable or preventable 

Is an event caused by human activity that is unlikely to reoccur at a particular location 

Is a natural event 

Examples of Exceptional Events are: 

Chemical Spills and Industrial Accidents 

Structural Fires 

Exceedances due to Transported Pollution 

Exceedances due to a Terrorist Attack 

Natural Events: 

Volcanic & Seismic Activities 

Natural Disasters & Associated Clean-up Activities 

High Wind Events 

Wildfires 

Stratospheric Ozone Intrusions 

The rule states that wildfires will be treated as natural events. 

Prescribed fires managed for resources benefits may qualify for exceptional events if they meet 

certain criteria: 

“Unlikely to recur at the same location” and “not reasonably controllable or preventable” 

Where State certifies that a smoke management program or basic smoke management 

practices, were in place 

EPA’s handling of data from all other fires will continue to be addressed under the Interim Air Quality 

Policy for Wildland and Prescribed Fires. 

Agency Authority 

The Wisconsin Department of Natural Resources (WDNR) has the authority to implement and 

enforce Federal regulations related to air quality standards. 

The WDNR maintains the air monitor system throughout the state. If an air monitor in the state 

records a violation of the NAAQS, then the area in violation of the standard is designated as “nonattainment” area. As required by Section 110 of the CAA, the state must submit a SIP to the EPA 

identifying what measures the state will take to reduce emissions affecting the area in order to meet 

and maintain compliance with the standard. Each plan shall include “enforceable emission limitation 

and other control measures” as required by Section 110. This would apply to facilities and sources 

that contribute to the violation of the standard. Construction and modification of stationary sources 

within non-attainment areas would be subject to emission offset regulations which require any new 

emissions to obtain emission offsets from existing air pollution sources. This requirement is 

designed to result in a net emission decrease to help bring the area back into attainment. 

By implementing the requirements of a SIP that has EPA approval, the WDNR enforces compliance 

with air quality standards within the State of Wisconsin. Regulatory instruments that may be 
22

included in a SIP in order to return an area to compliance with an air quality standard, include 

statutes, rules, orders, or permit conditions. If any of these become part of a federally approved WI 

SIP, the measure would become both State and Federal enforceable 

Wisconsin is currently working to develop a Regional Haze SIP and PM2.5 SIP as a member of the 

Midwest Regional Planning Organization (RPO) which includes Michigan, Ohio, Indiana, and Illinois. 

The projects underway by the Midwest RPO include visibility monitoring, data analysis, 

photochemical modeling, and engineering analysis of selected large PM2.5 emitters in the region. 
23

Appendix B 

Managing Prescribed Fire in Wisconsin 

Basis for Developing Smoke Management Best Management Practices (SMBMP) 

The purposes of the SMBMP are directly related to the mitigation of any public health, nuisance and 

safety hazards posed by smoke intrusions into populated areas and roadways. The goals are to 

prevent deterioration of air quality and National Ambient Air Quality Standards (NAAQS) violations, 

and address visibility impacts on mandatory Class 1 Federal areas. The NAAQS referred to here 

are for particulate matter (PM) less than 2.5 microns (PM2.5) and PM less than 10 microns (PM10) 

in diameter.

The reasons SMBMP are being developed for Wisconsin are: 

1. There has been an increase in the use of prescribed fire in Wisconsin. 

Table A1 identifies a trend of increased use of prescribed fire in Wisconsin. This follows a 

nationwide trend identified by federal and state land managers. This increase of prescribed fire has 

strong ecosystem and landscape management implications to increase biodiversity and productivity. 

2. To utilize a voluntary program to prevent PM NAAQS violations related to emissions from 

prescribed fire managed for resource benefits. 

Implementation of SMBMP by land management agencies, organizations and the private sector 

should reduce potential emissions and smoke impacts from prescribed fires so that emissions do not 

result in “non-attainment” status with NAAQS and state air quality standards. The EPA Interim 

Guidance document explains that states which implement a certified SMP and do violate the PM10

or PM2.5 standards will not have areas designed as “non-attainment”, if the State demonstrates that 

prescribed and/or wildland fire significantly contributed to the concentration of pollutants that 

exceeded the standards. This incentive by the EPA for implementation of a Smoke Management 

Plan is important if an area of the state were to violate the air quality standards due to smoke 

produced by prescribed burning. 

The EPA Exceptional Events Rule published on March 22, 2007 states that all wildfires will be 

considered as natural events and will not be counted in determining an areas attainment or nonattainment status. The impact of prescribed fires may be discounted if the burn was conducted 

under a certified Smoke Management Plan or the burner was using basic smoke management 

practices (as defined by the applicable air quality regulatory agency). 

3. The EPA Regional Haze Rule to protect and improve visibility in mandatory Class I areas the 

Lake States. 

Section 169A of the Clean Air Act Amendments (CAAA) of 1977 sets forth “the national goal of 

preventing any future, and remedying any existing, impairment of visibility in mandatory Class I 

Federal areas which impairment results from man-made air pollution.” The EPA rules issued in 

1980 included language directed at those sources “reasonably attributable” to visibility impairment. 

With the addition of section 169B of the CAAA of 1990, congress addressed “regional haze” visibility 

impairment in the nation’s national parks and wilderness areas. The EPA determined that all 156 

listed mandatory Class I areas across the nation demonstrate impaired visibility based on monitoring 

data from the Interagency Monitoring of Protected Visual Environments (IMPROVE). This includes 

the Class 1 areas of Seney National Wildlife Refuge and Isle Royale National Park in Michigan, and 

Voyageurs National Park and Boundary Waters Canoe Area Wilderness in Minnesota. For the Class 
24

I areas, in Minnesota and Michigan, smoke from Wisconsin prescribed fires have not been shown to 

be a significant contributor to visibility impairment. 

EPA published their final Regional Haze Rule on July 1, 1999 (64FR35714). This rule is directed at 

man-made air pollution sources that have the potential to cause or contribute to visibility impairment 

including: 1) stationary sources (industry), 2) mobile sources (vehicles), 3) area sources (gas 

stations, dry cleaners, etc.), and 4) the use of managed fire. Of the pollutants most responsible for 

haze (nitrates, sulfates, soil material, organic carbon, and elemental carbon), nitrates, organic 

carbon and elemental carbon are produced by vegetative burning. The regional haze program goal 

is to show continued improvement in monitored visibility in Class 1 areas and restore natural 

background conditions by 2064. 

Other factors that do not apply to Wisconsin at this time but are “strong indications” that a smoke 

management plan is necessary are listed in the EPA “Interim Air Quality Policy on Wildland and 

Prescribed Fires” issued April 1998. These include any of the following if they result from fire use: 

1. Citizens increasingly complain of smoke intrusions. 

 

2. The trend of monitored air quality values is increasing (approaching the daily or annual NAAQS 

for PM2.5 or PM10) because of significant contributions from fires managed for resource benefits. 

3. Fires cause or significantly contribute to monitored air quality that is already greater than 85 

percent of the daily or annual NAAQS for PM2.5 or PM10. 

4. Fires in the area significantly contribute to visibility impairment in mandatory Class I Federal 

areas. 
25

Appendix C 

Smoke Production and Dispersion 

Overview and Definition of Smoke Dispersion 

Information pertaining to smoke dispersion is an important element of these SMBMP. Smoke 

dispersion is directly related to ventilation, which is the process within the atmosphere that mixes 

and transports smoke away from its source. Ventilation is a function of atmospheric stability, mixing 

height and transport winds. Mixing height is defined as the upper limit of an unstable mixed layer, in 

which upward and downward exchange of air occurs. In theory, the mixing height represents the 

level that smoke will rise to before spreading out horizontally. Transport wind is defined as the 

arithmetic average of the wind speed and direction within the mixed layer. Transport wind should 

provide a basic estimate of the movement of the smoke column as it advects out of the source 

region. 

Just as various indices are used to estimate fire behavior, a ventilation index has been developed to 

estimate the lower atmosphere’s ability to diffuse and disperse smoke. The Ventilation Index (also 

known as the Dispersion Index) is calculated by multiplying the mixing height (feet) by the transport 

wind (knots). A high Ventilation Index usually means that smoke will disperse in an efficient manner. 

A low Ventilation Index usually means that the dispersion of smoke in the lower atmosphere will be 

hindered. Caution should be used when interpreting the Ventilation Index, as the values can 

sometimes be misleading. For instance, a high Ventilation Index can be produced with either a high 

transport wind and low mixing height or a low transport wind and high mixing height. In both of 

these situations, smoke dispersion may still be hindered. 

Table C1 

Ventilation Index Dispersion Category 

0 – 12,999 Poor 

13,000-29,999 Fair 

30,000 – 60,000 Good 

60,000 or greater Excellent 

Smoke dispersion information is available on the Fire Weather Planning Forecast (FWF), which is 

issued twice daily during the fire season at 7 am and 3 pm. Average mixing height and transport 

wind for the noon to 6 pm period are provided for the daytime periods (through day 2) in the Fire 

Weather Planning Forecast. The Ventilation Index, which is labeled as smoke dispersal in the FWF, 

is also averaged between noon and 6 pm, and is provided for the daytime periods of the forecast 

through day 2. Average values are used in order to provide a more representative estimate for 

prescribed burn projects, which may be started at varying times of the day (depending on the 

agency, type and size of the project). Fire Weather Planning Forecasts are posted on all local 

National Weather Service (NWS) websites. Smoke dispersion forecasts are also available as part of 

a spot forecast request. 

Climate Factors that Influence Smoke Dispersion in Wisconsin 

Wisconsin resides in the humid continental climate region, due to its interior location in the midlatitudes of North America. The state lies in the boundary zone between many different air masses, 

including those of polar and tropical origin. As a result, Wisconsin experiences highly variable 

weather conditions and large seasonal changes in temperature. Weather conditions are most 

variable during the spring and fall months, when the jet stream migrates across the Great Lakes, 

resulting in strong storm systems tracking through the region. Lake Superior and Lake Michigan 

strongly influence local weather conditions near their respective shorelines in northwest and eastern 

Wisconsin. 
26

Here are some more detailed explanations of the various factors that influence smoke dispersion 

potential in Wisconsin: 

Air Masses and Frontal Systems are the main factors that influence day-to-day variations in 

smoke dispersion. There are five different types of air masses that affect the United States, 

including continental polar, continental arctic, continental tropical, maritime polar and maritime 

tropical. Wisconsin can be affected by all of these air masses during the course of a fire season, but 

is most commonly affected by continental polar, maritime polar and maritime tropical air masses. 

Continental polar air masses, which arrive from northern Canada, are usually cool, dry and stable, 

and sometimes result in low mixing heights and poor smoke dispersion due to the presence of a 

subsidence inversion. Maritime polar air masses form over the northern Pacific Ocean region, 

where they take on their typical cool, moist and unstable characteristics. However, these air masses 

usually lose most of their moisture as they ascend the west slopes of the Rocky Mountains, and 

warm as they descend the east slopes. By the time they arrive in Wisconsin, they are usually dry, 

mild and unstable. As a result, mixing heights are typically quite high in air masses of Pacific origin. 

Maritime tropical air masses, which originate from the Gulf of Mexico, are usually warm, moist and 

unstable. 

Frontal systems can also have a significant effect on smoke dispersion. Cold fronts are usually 

accompanied by windy and unstable conditions, which provide for excellent smoke dispersion. 

Conditions are quite variable with warm fronts, with stable conditions and poor smoke dispersion 

expected north of the front, and unstable and windy conditions to the south. 

Latitude, which controls the sun angle and length of the day, is responsible for seasonal 

temperature contrasts. Mid-latitude locations such as Wisconsin experience sharp changes in 

seasonal temperatures due to widely varying sun angle and day length. These temperature 

changes can significantly impact smoke dispersion. For example, mixing heights are typically lowest 

during the winter months, since daytime heating is limited due to low sun angle, short day length and 

snow covered ground. During the spring and summer, increased solar heating due to a high sun 

angle and longer day length is usually sufficient to mix out low level inversions, resulting in higher 

mixing heights and more effective smoke dispersion. 

Lake Superior and Lake Michigan have a significant impact on smoke dispersion, especially 

during the spring and summer months. Lake breezes, which frequently develop in northwest and 

eastern Wisconsin from April through August, often result in poor smoke dispersion near the 

lakeshore. Lake breezes typically form during the late morning or early afternoon, become strongest 

during the mid to late afternoon, then weaken by early evening. On most days, the lake breeze front 

will only push inland 5 to 10 miles, but in extreme cases, may move inland 50 miles or more. Stable 

conditions develop as the cooler marine air penetrates inland, forcing warmer air aloft. In addition to 

smoke dispersion concerns, shifting winds associated with a lake breeze front can occasionally 

cause fire control problems. 

Upper Level Disturbances, also known as upper level troughs of low pressure, often result in 

improved smoke dispersion as they pass through the western Great Lakes region. These 

disturbances, which are usually accompanied by pockets of cold air aloft, often produce windy and 

unstable conditions, and help to generate large scale rising motion in the atmosphere. 

Weather Patterns that Affect Smoke Dispersion in Wisconsin 

Wisconsin usually receives good ventilation throughout most of the fire season. During the months 

of April through October, solar radiation is usually strong enough to either mix out or lift inversions 
27

that are near the surface. However, there are some typical seasonal weather patterns that cause 

smoke dispersion problems. 

 During the early spring and late fall, strong Canadian high pressure systems often sag into 

the northern Great Lakes region and persist for several days. These Canadian highs 

typically have strong subsidence inversions, which gradually lower toward the surface, 

leading to poor smoke dispersal. Ventilation is especially poor when widespread low clouds 

(stratus) are present. The low clouds typically form in two ways; either due to low level east 

winds advecting marine moisture off of Lake Michigan, or due to the presence of a warm 

front over Iowa and northern Illinois, which lifts warm, moist air from the Gulf of Mexico over 

the top of the cooler Canadian air mass. The poor smoke dispersal is the net result of low 

mixing heights (generally 1,000-2,000 feet) and light winds. 

 Persistent (lasting up to a week or more) summertime high pressure systems accompanied 

by a large blocking ridge of high pressure aloft can produce significant smoke dispersion 

problems. Although daytime mixing heights are often sufficiently high, transport winds are 

typically too light to support efficient smoke dispersion. The stagnant conditions eventually 

lead to reduced visibility and poor air quality, especially during the nighttime and early 

morning hours, when smoke particles aloft fall back to the surface. 

 Radiation inversions (also known as nocturnal inversions), which develop as the earth’s 

surface cools at night, can trap smoke near the ground during the nighttime and morning 

hours. Radiation inversions can occur throughout the year, and typically form on nights 

when skies are clear and winds are light. Summertime radiation inversions tend to be 

shallower, and usually mix out earlier in the morning, than those that develop during the 

spring and fall. 

 Inland intrusions of cool, stable marine air associated with lake breeze fronts (or persistent 

onshore winds) can significantly hinder smoke dispersion during the spring and summer 

months. Lake breeze fronts are most common on days when winds at the surface and aloft 

are light. Lake breezes that develop near Lake Superior in northwest Wisconsin typically 

have a northerly component to their wind direction, while those that develop near Lake 

Michigan (and the bay of Green Bay) have an easterly component. Although a lake breeze 

front will typically remain within 5 to 10 miles of the lake during the early to mid afternoon, 

they can occasionally penetrate well inland (50 miles or more) before weakening during the 

late afternoon or early evening hours. 
28

Appendix D 

Guidance for Use of the Ventilation Index and Dispersion Tables 

The Ventilation Index (also known as the Dispersion Index) is calculated by multiplying the mixing 

height (feet) by the transport wind (knots). A high Ventilation Index usually means that smoke will 

disperse in an efficient manner. A low Ventilation Index usually means that the dispersion of smoke 

in the lower atmosphere will be hindered. 

Table D1 

Ventilation Index Dispersion Category 

0 – 12,999 Poor 

13,000-29,999 Fair 

30,000 – 60,000 Good 

60,000 or greater Excellent 

Note: In using the ventilation index, exercise caution with high transport wind speed and low mixing 

height or low transport wind and high mixing height. Either combination may result in a false 

representation of an acceptable category, which can result in smoke dispersion problems and 

potential control problems. 

When utilizing the ventilation index it is important to consider the total fuel load being burned, both in 

terms of the fuel loading (tons of fuel per acre) and the total area to be treated. The proximity of 

downwind smoke sensitive areas to the burn unit should also be considered, so that in general the 

lower the expected total fuel consumption and the farther away from smoke sensitive receptors, the 

lower the ventilation index can be. Additionally, practices that reduce the total fuel load available for 

consumption can lower the acceptable dispersion category either by reduction of fuel, or acres to be 

treated. 

Two methods that can be utilized for mitigation of smoke impacts during the burn planning process 

are as follows: 

Method A: This method may be used as a general guide to use the Ventilation Index in combination 

with a smoke screening map to screen for sensitive downwind receptors. It is recommended for 

those burn units with low to moderate potential for smoke impacts. 

1. From the Daily Burn Unit Size chart (Table D2) select the size of the planned burn 

 unit* in acres. 

2. Determine the general fuel category which best represents the majority of the burn 

 unit. 

3. On a map of the area locate the sensitive downwind receptors that could be impacted 

 by smoke produced by the burn unit. 

4. Use the Dispersion Category charts (Table D3) and determine the minimum 

 distance which a burn should take place upwind of a sensitive receptor on a certain 

 Dispersion Category day. 

 Note: These are voluntary guidelines which may vary based on the local unit’s definition 

of smoke sensitive receptor and the ability to mitigate potential smoke problems by 

instituting traffic controls when smoke could impact major roads or by burning under fuel 

moisture conditions which limit consumption of heavier fuels. 

Note: Use of these charts assumes no more than one burn unit within a 5 mile radius. 

 
29

DAILY BURN UNIT SIZES – Table D2 

Small <50 acres 

Medium 50 – 150 acres 

Large 150-500 acres 

Landscape 500 + acres 

Distances to Smoke Sensitive Areas (from MN SMP)– Table D3

General Fuel 

Category 

Daily Fire 

size 

(acres)* 

Dispersion Index 

Category 

Minimum dist. to 

downwind smoke 

sensitive areas 

(miles) 

Single large pile or NA POOR 0.25 

Scattered small piled 

fuels NA FAIR or BETTER No limitation 

< 50 POOR 0.25 

< 50 FAIR or BETTER No limitation 

50 - 150 POOR No burning 

50 - 150 FAIR or BETTER No limitation 

150 - 500 POOR No burning 

150 - 500 FAIR 0.25 

150 - 500 GOOD or BETTER No limitation 

500+ POOR No burning 

500+ FAIR 0.75 

500+ GOOD 0.50 

Grass or Leaf litter 

500+ EXCELLENT 0.25 

< 50 POOR 

No burning (See 

above exception for 

pile(s)) 

< 50 FAIR 0.50 

< 50 GOOD or BETTER No limitation 

50 -150 POOR No burning 

50 - 150 FAIR 0.50 

50 - 150 GOOD or BETTER No limitation 

150 - 500 POOR No burning 

150 - 500 FAIR 0.75 

150 - 500 GOOD 0.50 

150 - 500 EXCELLENT 0.25 

500+ POOR No burning 

500+ FAIR 1.0 

500+ GOOD 0.75 

Timber, slash, or 

piled fuels 

500+ EXCELLENT 0.50 
30

Note: On Poor Category days no burning is suggested within 1⁄4 mile of any 

downwind smoke sensitive area and is not recommended in general. 

As an example, for a 500 acre burn in grass fuels, a minimum distance that a burn should 

occur upwind of a sensitive receptor would be: greater than 0.25 miles with Excellent 

Dispersion, greater than 0.5 mile with Good Dispersion, greater than 0.75 miles with Fair 

Dispersion and there should be no burn under Poor Dispersion.

Method B: Recommended for Complex Prescribed Burns where there is a high potential for 

smoke impacts. 

1. Estimate the fuel loading for the area to be burned. This may be done formally, utilizing sitespecific survey data if available or by consulting the fuel model information found in: Aids in 

Determining Fuel Models for Estimating Fire Behavior, or Standard Fire Behavior: A 

Comprehensive Set for Use with Rothermel’s Surface Spread Model or the digital photo series at 

http://depts.washington.edu/nwfire/dps/. 

2. Determine the acreage to be burned in one day. 

3. Estimate the expected fuel consumption using hand calculations or computer models such as 

FOFEM or CONSUME. Selection of higher fuel moistures (such as higher 100 and 1,000 hour 

fuel moisture), which should reduce the fuel available for consumption, should be factored into 

the calculations. 

4. Determine the total PM10 and PM2.5 emissions per day based on outputs from #3. 

5. Locate downwind sensitive receptors that could be impacted from your smoke. 

6. Utilize a dispersion computer program to screen for the potential to exceed ambient air quality 

standards. 

Mapping guidance to identify the closet smoke sensitive target and distance from the 

prescribed fire.

1. Locate on a map the prescribed fire and all potential smoke sensitive targets, plus 

areas known to already have air pollution problems. 

2. Determine the wind direction that should have the least impact on smoke sensitive 

targets. 

3. Draw a line representing the centerline of the path of the smoke plume using the wind 

direction chosen in the previous step. 

4. Determine the distance from the edge of the prescribed fire to the nearest smokesensitive target. 

5. To allow for horizontal dispersion of the smoke, as well as shifts in wind direction, 

draw two other lines from the burn at an angle of 30 degrees from the centerline. 
31

Figure D1 Smoke Plotter (NWCG RX 410) 
ATTACHMENT 3
Regional Air Quality Analyses for

Ozone, PM2.5, and Regional Haze: 

Final Technical Support Document

April 25, 2008

States of Illinois, Indiana, Michigan, Ohio, and Wisconsin
ATTACHMENT 4
BEFORE THE 

DEPARTMENT OF NATURAL RESOURCES 

Notice of Public Hearing 

State Implementation Plan (SIP) to Address Requirements of the Federal Regional Haze Rule 

NOTICE IS HEREBY GIVEN that pursuant to s. 285.13(1), Wis. Stats., the Department of Natural 

Resources will hold a public hearing on the proposed Regional Haze SIP for the State of Wisconsin. 

Background 

The Regional Haze Rule was adopted on July 1, 1999 (64 FR 35714) and incorporated under 40 

CFR part 51.308 as part of Subpart P — Protection of Visibility. The Clean Air Act (CAA) under 

section 169A(b)(2) requires each state with a residing listed Class I area — and any state from 

which emissions are reasonably anticipated to cause or contribute to any impairment of visibility 

of such a Class I area — to make reasonable progress towards remedying impairment from manmade air pollution. Wisconsin, being identified as a contributing state, is specifically subject to 

requirements under the regional haze program, 40 CFR Part 51.308. 

In accordance with 40 CFR Part 51.308, the Department has developed a draft Regional Haze SIP 

based on the requirements of the Regional Haze Rule. This document describes Wisconsin's 

fulfillment of SIP requirements established by the rule for purposes of remedying and protecting 

visibility in designated federal Class I areas. The document includes Wisconsin's strategy for 

meeting reasonable progress goals by 2018 for Class I areas — which relies primarily on existing 

control programs across different source categories — and implementation of Best Available 

Retrofit Technology (BART) for affected major sources. 

NOTICE IS HEREBY FURTHER GIVEN that the public hearing will be held on: 

Tuesday, September 13, 2011 at 10:00 a.m. 

Wisconsin Department of Natural Resources, Room 713 

101 S. Webster Street 

Madison, WI 53707-7921 

NOTICE IS HEREBY FURTHER GIVEN that pursuant to the Americans with Disabilities Act, 

reasonable accommodations, including the provision of informational material in an alternative format, 

will be provided for qualified individuals with disabilities upon request. Please call Jonathan Loftus at 

(608) 264 - 8868 with specific information on your request at least 10 days before the date of the 

scheduled hearing. 

Written Comments and Copies of Documents 

Written comments on the proposed Regional Haze SIP may be submitted to Mr. Jonathan Loftus, 

Bureau of Air Management AM/7, P.O. Box 7921, Madison, WI 53707 no later than September 16, 

2011. Comments may be submitted electronically to jonathan.loflus@wisconsin.gov . Written comments 

will have the same weight and effect as oral statements presented at the hearing. 
A copy of the documents for the proposed Regional Haze SIP may be downloaded from 

http://dnr.wi.gov/air/aq/particles/vishaze.htm or a hard copy may be obtained from: 

Jonathan Loftus AM/7 

Bureau of Air Management 

P.O. Box 7921 

Madison, WI 53707 

.Jonathan.Loftus(a)wisconsin.gov 

Phone: (608) 264-8868 

FAX: (608) 267-0560 

Dated at Madison, Wisconsin 

STATE OF WISCONSIN 

DEPARTMENJ' OF NA RESOURCES 

in Cathy St - p, Secretary 
STATE OF WISCONSIN Notice/Permit Number: 

DEPARTMENT OF NATURAL RESOURCES Hearing Notice 

Proposed Ozone Redesignation Request and Maintenance Plan Supplement for the Milwaukee-Racine 

Nonattainment Area and the Sheboygan County Nonattainment Area 

State Implementation Plan (SIP) to Address Requirements of the Federal Regional Haze Rule 

Linda Lund, being first duly sworn on oath deposes and says that said person is employed as a Office 

Operations Associate, by the State of Wisconsin Department of Natural Resources; that on the 8th day of 

August, 2011, said person deposited in the United States mail at Madison, Dane County, Wisconsin, copies 

of the notice for public hearing to the above entitled action, securely enclosed in envelopes, the postage duly 

prepaid and one copy addressed to each of the following at his/her respective last known address; and emailed the same to the interested parties who have requested to receive the public notices via e-mail: 

Susan Kraj (e-mailed) 

US EPA - Region 5 

Kraj.Susan@epamail.epa.gov 

Janice Kelb 

PO Box 146 

Brokaw, WI 54417 

Michael Huenick 

Env. Tech. & Engineering Corp. 

13020 Bluemound Rd. 

Elm Grove, WI 53122 

Lee Kottke (e-mailed) 

Anguil Environmental Consultants 

lkottke118 @aol.com 

Gregory Denny (e-mailed) 

Environmental Monitoring & Tech. Inc. 

dkrueger@emt.com 

Dennis Greil (e-mailed) 

Bay Environmental Strategies 

dcgreil@bayenvironmental.com 

Clean Wisconsin 

122 State Street 

Ste. 200 

Madison, WI 53703-2500 

Environmental Law Society, UW Law School 

975 Bascom Mall 

Madison, WI 53706 

Mike Mayan 

RMC Env. 

PO Box 216 

Rosendale, WI 54974 

Jennifer Feyerherm (e-mailed) 

Sierra Club 

Jennifer.Feyerherm@sierraclub.org 

Mark Larson (e-mailed) 

mlarson@prefinishing.com 

David C. Bender (e-mailed) 

McGillivray Westerberg & Bender LLC 

Bender@mwbattomeys.com 

Danny Marcus (e-mailed) 

US EPA - Region 5 

Marcus.Danny@epamail.epa.gov 

Rosemary Thorne (e-mailed) 

Badger Laboratories & Engineering, Inc. 

rthome@badgerlabs.com 

Marney Hoefer - LS/8 
<NYV1/411`0 

Notary Public, State of Wisconsin 

My commission expires: 

AReARA * 

Publication to appear in:, 

The DNR will publish in: 

Wisconsin State Journal 

PO Box 8056 

Madison, WI, 53708-8056 

On Thursday, August 11, 2011 

Public Hearing Contact: 

Jonathan Loftus —AM/7 

Bureau of Air Management 

Phone: (608) 264-8868 

Location and date of hearing: 

Tuesday, September 13, 2011 at 1:00 p.m. 

Wisconsin Department of Natural Resources. 

Room 713 

101 S. Webster Street 

Madison, WI 53707-7921 

inda Lund, Office Operations Associate 

Bureau of Air Management 

608-264-9206 

Subscribed and sworn to before me 

this CiA./:■_, day of axiivo, ap 
ONSIN 

SS. 

} ;ounty 

i\6 1. 6 20 

My Commission expires April 15th, 2015 

(Signed) 

(Title) Principal Clerk 

Subscribed and sworn to before me on 

3- la.‘ ■ ( 

Notary Public, Dane County, Wisconsin 

Capital Newspapers Proof of Publication Affidavit 

Ad #: 1802836 Price: $93.37 Ad ID: AMLL-863 

Retain this portion for your records. 

Please do not remit payment until you receive your advertising invoice. 

Mail to: 

DEPT OF NATURAL RESOURCES 

Sharon Reeve 

P.O. Box 7921 

MADISON, WI 53707 

BEFORi THE 

OF NATURAL 

Notice of Public 

State ImplementationPIsn 'SIP) to A.4 

dress Requirements of. AN Federal Regional Haze Rule NOTICE is wow *at Pursuant 

to s. 285.13(1), WI. , the Department of Natural' Resoi0ea will hold a 

public heating on the prOposedRegional 

e SIP tor the State of Wisconsin. 

The &COO& Heize.Rule waip adopted on 

July 1, 1999 (64 FR 35714) and Incorp6- 

rated 1.ft 40 'CFR part-11,908 as part 

of Subpart P ProtectioA of Visibility. 

' ttnder section 

With a restate 

anto any irna Class I area 

ess towards 

man-Made 

identified 

citify subregional 

air poll 

?loco 

to 

The Clean Air •Act 

169A(b)(2)* * 

siding listed 

from 

ticipat 

pas 

- to 

SHARON SCALLON 

being duly sworn, doth depose and say that 

he (she) is an authorized representative of 

Capital Newspapers, publishers of 

In ac 6.308, 

the a draft 

Regional Haze SIP based on the requirements of the Regional Haze Rule. Thia 

document WiscOnsin's 'fulfillment of SIP requirements established by 

the rule for of remedying and 

Mass 

protecting ,federal 

I areas. includes 

able 

Wisconsin's strategy rrsoni 

progress goals 

areas which relies existing 

source 

ectitiology 

. GIVEN 

that the public hearing will be held on: 

Tuesday, September 13, 2011 at 10:00 

Nisaltisin DepArtment of. Natural RelourCes, Room 713 

101 S. Webster Street 

vtadiiion, WI 53707-7921 

FURTHER 

a

GiVEN 

American with 

noble SICC01117 

the provision of 

I in an alteThative 

for qualified inupon request. 

Loftus at (608) 264 

on your 

before the date 

loNring. 

Ond Copses of Documeat on the proposed Rebe submitted to Mr. 

u of Air Manage921, Madison; WI 

tember 16, 2011. 

itted eleCtronfa@wisconsin.gov. 

will have the same 

*oral statements pre- 

) 

nts for the proSIP may be down- 

' 

/eq/partIcles/viscopy may be ob- 

, 

Bilreau of Air 

x 7921. Madison, 

nathan.Loftua@wisconsin.gov 

one: (608) 264-8868 

X:' (608) 207-0660 

ted at Madison, Wisconsin : 8/1/11 

ATE OF WISCONSIN 

:PARTMENT QF 

;WAAL RESOURCES 

: 

• Matt Moroney • for 

thy StOpp, Secretary . 

PUB. WSJ: August 11, 2011 

#1802836 WNAXLP 

Var 

Best Available 

:Nn for a isaffaln; 

PWSJ Wisconsin State Journal 

a newspaper, at Madison, the seat of government of said State, 

and that an advertisement of which the annexed is a true 

copy, taken from said paper, was published therein on 

August 11th, 2011 

0• 
Response to Comments for Wisconsin Regional Haze SIP

Wisconsin is required to submit a Haze State Implementation Plan (SIP) for meeting 

federal Haze requirements including a Best Available Retrofit Control program and 

Reasonable Progress Goals for eventual elimination of anthropogenic visibility impact to 

federal Class I areas. The Department proposed Haze SIP requirements in July of 2010 

for public comment. The Department received comment from Georgia Pacific, U.S. 

Forest Service, National Parks Service, U. S EPA, and joint comment from Sierra Club 

and the Midwest Environment Defense Center. This document comprises the 

Department's response to specific and identified areas of comment of the general Haze 

SIP. Comments to the proposed BART component of the SIP are addressed under 

separate document. 

Herein the U.S. Forest Service and National Parks Service when addressed in common 

are referred to as the Federal Land Managers (FLMs). The Wisconsin Department of 

Natural Resources is referred to as the Department. 

Comment: U.S. Forest Service (FS) and National Park Service (NPS) commented that 

Wisconsin needs to include the required reasonable progress four factor analysis to 

evaluate what additional emission reductions are feasible and reasonable, and that this 

analysis is required independent of the projected visibility improvement by 2018. 

Response: Wisconsin Department of Natural Resources (the Department) disagrees with 

this interpretation of the Regional Haze rule. In the Regional Haze SIP, Wisconsin 

shows that emissions are decreasing through 2018 versus the 2005 base year. Also, that 

several of the largest sources close to Class I areas are implementing controls. 

Therefore, the Department maintains that it is premature to regulate industrial (other 

than Georgia-Pacific under BART) and specific EGU sources without additional 

visibility modeling. Wisconsin is restricted in implementing control programs that are 

not required by the CAA. Wisconsin has committed to performing the modeling and 

evaluation as part of the periodic review for 2013. 

Furthermore, even though results from MRPO modeling of 2005 emissions show that 

Seney and Isle Royale are above the URI line, Wisconsin evaluated emissions trends 

since 2005 to show it is gaining ground. The Department maintains that the rate of 

emission reduction projected for Wisconsin sources compared to Michigan and 

Minnesota shows that Wisconsin is meeting its share of visibility improvement. This is 

supported by the NOx and SO2 budgets under the CSAPR, which are similar to or less 

than the Michigan and Minnesota budgets. Also, the finalized SO2 and NOx BART 

control levels for Georgia-Pacific in Wisconsin are higher than the SO2 and NOx BART 

control levels for industrial sources in both Michigan and Minnesota. Since Wisconsin 

sources are achieving emission reductions as rapidly as Michigan and Minnesota, 

WDNR has determined that Wisconsin is meeting its emission reductions obligations 

for its portion of contribution to RPG for the first 10 year period. 
Comment: FS commented that the northern Class I areas have shown degradation since 

2005 through 2009, so that the amount of work to achieve the RPGs has increased. 

Response: Wisconsin is not addressing the issue of 2005-2009 degradation in this SIP, 

primarily because updated modeling to address this issue is not available. The issue 

should be addressed as part of the next round of MRPO modeling. 

Comment: FS commented that Minnesota set the RPGs for its Class I areas above the 

URI due to the uncertainties with the different modeling runs. In a related comment, NPS 

claims that WDNR’s finding that Boundary and Voyageurs meet URI is contrary to 

Minnesota's SIP. 

Response: WDNR believes it is allowed discretion of which base year to use for 

modeling, per the Regional Haze Rule. Four assessments were performed by MRPO. 

Year 2005 modeling shows Boundary and Voyageurs meeting the URI line, and was 

used by WDNR because it reflects more accurate reductions among all the states as well 

as meteorology.