JENNIFER M. GRANHOLM 

GOVERNOn 

SWTE OF MICIIK;AN 

DEPARTMENT OF ENVIRONMENTAL QUALITY 

LANSING 

STEVEN E. CHESTER DIRECTOR 

December 6,2007 

Ms. Mary A. Gade, Regional Administrator 

United States Environmental Protection Agency 

Region 5 

77 West Jackson Boulevard (R-19J) 

Chicago, Illinois 60604-3507 

Dear Administrator Gade: 

SUBJECT: Michigan Infrastructure of State Implementation Plans 

Through this letter, the Michigan Department of Environmental Quality (MDEQ) is confirming 

that the State of Michigan continues to retain the authorities necessary to implement and 

satisfactorily complete the Clean Air Act, Section 11 0 infrastructure requirements listed below. 

The requirements are met for the current and any prospective future National Ambient Air 

Quality Standards (NAAQS), including standards for ozone and various sizes of particulate 

matter. 

The State Implementation Plan (SIP) elements listed below are required under 

Section 1 10(a)(2). Section 11 0(a) provides the procedural and timing requirements for SIPS. 

Section 110(a)(2) lists the basic or "infrastructure" elements that all SIPS must contain. 

Emission limits and other control measures: Section 1 IO(a)(Z)(A) requires SIPS to include 

enforceable emissions limits and other control measures, means or techniques, schedules for 

compliance and other related matters. The United States Environmental Protection Agency 

(EPA) notes that the specific nonattainment plan requirements of Section I I O(a)(2) are subject 

to the timing requirement of Section 172, not the timing requirement of Section 110(a), and also 

that SIPS to meet this section are not covered by the Consent Decree. 

The MDEQ continues to staff and implement needed revisions to the Michgan SIP. The 

Michigan Natural Resources and Environmental Protecfion Act, 1994 PA 451, as amended 

(Act 451), MCL 324.5503 and 324.5512, provides the MDEQ Director the authow to regulate 

the discharge of air poilutants, to promulgate rules to establish standards for emissions for 

ambient air quality and for emissions. 

Ambient air quality monitoring data system: Section 1 IO(a)(Z)(B) requires SIPS to include 

provisions to provide for the establishment and operation of ambient air quality monitors, to 

collect and analyze ambient air quality data, and make these data available to EPA upon 

request. 

In accordance with the Michigan SIP, the MDEQ maintains a comprehensive network of air 

quality monitors throughout Michigan with fhe primary objective being to determine compliance 

with the NAAQS. The MDEQ submits network reviews to the EPA annually to ensure that its air 

monitoring operations comply with all applicable federal requirements. 

CONSTkTUTlON HALL 525 WEST AUEGAN STF3EET* P.O. BOX 30473 LANSING, MICHIGAN 48909-7973 

www.rnichipan.w (800) 862-9278 
Ms. Mary A. Gade -2- December 6,2007 

Program for enforcement of control measures: Section 110(2)(C) requires states to include 

a program providing for enforcement of all SIP measures and tfw regulation of construction of 

new or modified stationary sources to meet Prevention of Significant Deterioration (PSD) and 

nonattainment New Source Review (NSR) requirements. 

The MDEQ continues to staff and impiement a vigorous enforcement program to assure 

compliance with all requirements under State law. The PSD program responsibility was 

delegated to Michigan on September 10, 1979 and amended on November 7, 1983 and 

September 26, 1988. Michigan also administers an NSR permitting program. 

Interstate transport: Section 11 0(a)(2)(D) requires SIPS to include provisions prohibiting any 

source or other type of emission activity in one state from contributing significantly to 

nonattainment, or interfering with maintenance of the NAAQS in another state, or from 

interfering with measures required to prevent significant deterioration of air quality or to protect 

visibility in another state. The EPA has ateady issued the Clean Air Interstate Rule (CAIR) to 

assist states in developing SIPS to meet this requirement for purposes of the 8-hour ozone and 

PM 2.5 NAAQS, and has issued separate guidance to all states on how to comply with each 

prong of this statutory provision. 

The MDEQ has adopted and implemented various major programs related to the interstate 

transport of pollution, such as the Nitrogen Oxides - Budget Trading Program 

(R 336.1802- 181 8), and the CAIR Program (R 336.1821- 7826 and R 336.1830-1 836). 

Adequate resources: Section 11 O(a)(Z)(E) requires states to provide for adequate personnel, 

funding, and legal authority under state law to cavy out its SIP, and related issues. 

The MDEQ Air Quality Program is funded through Title V fees, Section 105 and 103 grants, and 

matching funds, Act 451 provides the legal authority under state law to cany out the Michigan 

SIP. 

Stationary source monitoring system: Section (I 1 O(aX2)(F) requires states to establish a 

system to monitor emissions from stationary sources and to submit periodic emissions reports. 

The Michigan Administrative Code R 336.2001-2004 provides requirements for performance 

testing and sampling. R 336.2 10 1-2 199 provides requirements for continuous emission 

monitoring, and R 336.201-202 requires annual reporting of emissions. 

Emergency power: Section I 1 O(a)(Z)(G) requires states to provide for authority to address 

activities causing imminent and substantial endangerment to public health, including 

contingency plans to implement the emergency episode provisions in their SIPS. 

MCL R 324.5518 of Act 451 provides authority for the MDEQ to require the immediate 

discontinuation of air contaminant discharges that constituie an imminent and substantial 

endangerment to the public health, safety, or welfare, or to the environment. R 324.5530 

provides for civil action by the Michigan Attorney General for a violation as described in 

R 324.5518. The MDEQ wili revise administrative rules to implement emergency action plans 

when the €PA establishes the revised significant harm levels for PM2.5, if needed. The MDEQ 

is a pariner in the EnviroFlash alert system, provides current air quality status on the MDEQ 

web pages, participates in the EPA AirNow program, and is a partner in the Biowatch 

emergency preparedness system. 
Ms. Mary A. Gade -3- December 6,2007 

Future SIP revisions: Section 1 lO(a)(Z)(H) requires states to have the authority to revise their 

SIPS in response to changes in the NAAQS, availability of improved methods for attaining the 

NAAQS, or in response to an EPA finding that the SIP is substantially inadequate, 

Act 451 provides the MDEQ with authority to promulgate rules to establish standards for 

ambient air quality and emissions; to issue, deny, revoke, or reissue permits; to make findings of 

fact and determinations; to make, modify, or cancel orders that require the control of air 

pollution, and permits rules and regulations necessary to meet NAAQS; and to prepare and 

develop a general comprehensive plan for the control or abatement of existing air pollution and 

for control or prevention of any new air pollution. 

Consultation with government officials: Section 110(a)(2)(J) requires states to provide a 

process for consultation with local governments and federal Land Managers canying out 

NAAQS implementation requirements pursuant to Section 121 relating to consultation. 

The MDEQ actively participates in planning efforts that include stakeholders from local 

governments, the business community, and communiiy activist groups. Federal Land Managers 

and tribal groups have been involved in Michigan SIP development through the Midwest 

Regional Planning Organization. 

Public notifications: Section 110(a)(2)(J) further requires states to notify the public if NAAQS 

are exceeded in an area and to enhance public awareness of measures that can be taken to 

prevent exceedances. 

Ozone Action! Progmms, AirNow and EnviroFIash program participation, and posting of current 

air qualify concentrations on MDEQ web pages a# serve to notify the public and to enhance 

awareness. The MDEQ also prepares an annual Air Quality Report. 

PSD and visibility protection: Section 1 10(a)(2)(J) also requires states to meet applicable 

requirements of Part C related to prevention of significant detei~ration and visibility protection. 

The MDEQ is addressing both the long-term requirements to meet natural visibility levels by 

2064 and the ongoing review of new major sources under the PSD program. The MDEQ will be 

submitting the regional haze/BART SIP and is consulting with the federal Land Managers 

regarding the SIP. 

Air quality modeling data: Section 1 1 O(a)(2)(K) requires that SIPS provide for performing air 

quality modeling for predicting effects on air quality of emissions from any NAAQS pollutant and 

submission of such data to the EPA upon request. 

73e MDEQ reviews the potential impad of mejor and some minor new sources, consistent with 

the Code of Federal Regulations, Parts 51 and 52, Appendix W, Guideline on Air Quality 

Models. Modeling data are available upon request by the EPA or other interested parties. 

Permitting fees: Section I1 O(a)(Z)(L) requires SIPS to require each major stationary source to 

pay permitting fees to cover the cost of reviewing, approving, implementing, and enforcing a 

permit. 

The MDEQ continues to implement the approved Titfe V program, including requiring major 

sources to pay permit fees under provisions of MCL R 324.5522 of Act 451. 
Ms. Mary A. Gade -4- December 6,2007 

Consultationlparticipation by affected local entities: Section 1 10(a)(2)(M) requires states to 

provide for consultation and participation in SIP development by local political subdivisions 

affected by the SIP. 

Memorandums of Understanding regarding mnsultation/participation in SIP development have 

been established between the MDEQ and local political subdivisions. The MDEQ provides 

opportunity for stakeholder workgroup participation in mle development processes. 

Michigan has the necessary infrastructure provisions to satisfy the requirements of the Clean Air 

Act. Please contact Mr. G. Vinson Hetlwig, Chief, Air Quality Division, at 517-373-7069 if you 

have any questions. 

Sincerely /M& 

~tev/en%. Chester 

Director 

5 1 7-373-79 1 7 

cc: Ms. Cheryl Newton, EPA 

Mr. Jim Sygo, Deputy Director, MDEQ 

Mr. G. Vinson Hellwig, MDEQ