To: palma.elizabeth@epa.gov, 

Cc:

Bcc:

Subject: Additional Information Supporting Kenosha County Partial Nonattainment for the 2008 Ozone 

NAAQS

From: "Sponseller, Bart A - DNR" <Bart.Sponseller@Wisconsin.gov>

To: George Czerniak/R5/USEPA/US@EPA

Cc: John Mooney/R5/USEPA/US@EPA, Douglas Aburano/R5/USEPA/US@EPA, "Stevens, Patrick K - 

DNR" <Patrick.Stevens@wisconsin.gov>, "Hoch, Joseph A - DNR" <Joseph.Hoch@wisconsin.gov>

Date: 05/14/2012 08:15 AM

Subject: Additional Information Supporting Kenosha County Partial Nonattainment for the 2008 Ozone 

NAAQS

Dear Mr. Czerniak,

We have reviewed comments submitted to the U.S. EPA on April 13, 2012 by the Indiana

Department of Environmental Management (IDEM) and wanted to express some concerns.

Foremost, we question the ozone contribution results presented on page 13 of Enclosure 1.

These results indicate that Kenosha County contributes approximately 3 parts per billion (ppb),

the Milwaukee area contributes approximately 5.5 ppb, and the remainder of Wisconsin

contributes 8 ppb to the ozone concentrations recorded at the Zion, Illinois ozone monitor. This

results in a total Wisconsin contribution of 16.5 ppb or 21.7% of the total design value of 76

ppb. In stark contrast, the U.S. EPA’s own analysis conducted during the development of the

Cross‐State Air Pollution Rule (CSAPR) indicated that Wisconsin only contributed 2.1 ppb or

2.9% of the 2012 base case ozone maximum design value of 74.1 ppb (

http://www.epa.gov/airtransport/pdfs/CSAPR_Ozone%20and%20PM2.5_Contributions.xls).

This percent contribution for the entire state from the U.S. EPA is less than that suggested in

IDEM’s comments for Kenosha County alone (3.9%). Suggesting that Wisconsin contributes

more than one‐fifth of the ozone to a monitor south of our border is counter to years of

forecasting and modeling experience, which confirms that high ozone concentration days occur

under southerly wind direction regimes i.e., the precursor pollution comes from Illinois, Indiana

and other areas south.

I would also like to point out that significant emission reductions have occurred in Kenosha

County over the last decade. Stationary source nitrogen oxide (NOx) emissions have dropped

from a maximum of 18,758.77 tons in 2001 to 3,012.35 in 2010, an 84% decrease. IDEM’s

contribution modeling relied on a 2007 emissions inventory. Stationary source volatile organic

compound (VOC) emissions have dropped from 534.97 tons in 2007 to 218.09 tons in 2010, a

59% decrease. In addition, stationary source NOx emissions have dropped from 3,127.60 tons

in 2007 to 3,012.35 tons in 2010, a 3.7% decrease in Kenosha County.

Again, we ask that Kenosha County be designated attainment, or if not attainment, then the

smallest feasible area of Kenosha County should be designated nonattainment (i.e., east of

Sheridan Road). Please feel free to contact me if you have any questions at (608) 264‐8537.

Thank you for this opportunity to provide additional information for the record.

Bart Sponseller

Director, Bureau of Air Management
Wisconsin Department of Natural Resources

() phone: (608) 264-8537

() cell: (608) 219-6430

() fax: (608) 267-0560