ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRANO AVENUE EAST, P.O. Box 19506, SPRINGFIELD, ILLINOIS 62794··9506 (217) 782-2113

PAT QUINN, COVCRNOR

217/785-4140

217/782-9143 (TDD)

September 16, 2011

Ms. Cheryl A. Newton, Director

Office of the Air and Radiation Division

U.S. Environmental Protection Agency, Region V (RI8J)

77 West Jackson Boulevard Chicago, Illinois 60604-3507

Re: Control Techniques Guidelines SIP Submittal and Redesignation Requests for 8-Hour

Ozone and P 25

Dear Ms.**Ne~11;1**

The Illinois Environmental Protection Agency (Illinois EPA), on behalf of the State of Illinois, is making three requests regarding State Implementation Plan (SIP) requirements related to the

1997 8-hour ozone and fine particle (PM25) National Ambient Air Quality Standards (NAAQS).

First, the Illinois EPA hereby requests that the Illinois portion of the Chicago ozone nonattainment area be redesignated to attainment of the 8-hour ozone standard promulgated in

1997. The Chicago ozone nonattainment area consists of Cook, Lake, DuPage, McHemy, Kane, Will, and portions of Grundy and Kendall counties in Illinois, as well as Lalce and POlier

counties in northwest Indiana. The Illinois EPA understands that the State of Indiana has already

submitted a similar redesignation request Ambient air monitoring data collected by the Illinois

EPA in the Chicago nonattainment area, as well as data collected in northwest Indiana and

southeast .Wisconsin, demonstrates that the area is currently meeting the 1997 8-hour ozone NAAQS, and has been meeting tlle NAAQS since the 2006-2008 period. Note that U.S. EPA published a Clean Data Determination for the Chicago ozone nonattainrnent area on April 12,

2010.

Second, the Illinois EPA requests that the Illinois portion of the S1. Louis ozone nonattainn1ent

area, known as the Metro-East area, be redesignated to attainment of the 8-hour ozone standard promulgated in 1997. The Metro-East portion of the ozone nonattainment area consists of Madison, Momoe, St Clair, and Jersey counties in Illinois. The Illinois EPA understands that

the State of Missouri is making a similar redesignation request. Ambient air monitoring data

collected by the Illinois EPA in the Metro-East area, as well as data collected in Missouri,

demonstrates that the entire St. Louis nonattainment area is currently meeting the 1997 8-hour

ozone NAAQS, and has been meeting the NAAQS since the 2007-2009 period. Note that U.S.

EPA published a Clean Data Determination for the St Louis ozone nonattainment area on July 11,2011.

PRINTED ON RECYCLED PAPERThird, the Illinois EPA hereby requests that the Illinois portion of the Chicago PM 25 nonattainment area be redesignated to attainment of the fme particle standard promulgated in

1997. The Chicago PM 25 nonattainrnent area consists of Cook, Lake, DuPage, McHenry, Kane, Will, and portions of Grundy and Kendall counties in Illinois, as well as Lake and Porter

counties in northwest Indiana. The Illinois EPA understands that the State ofIndiana has already

submitted a similar redesignation request. Ambient air monitoring data collected by the Illinois

EPA in the Chicago nonattainrnent area, as well as data collected in northwest Indiana,

demonstrates that the area is currently meeting the 1997 PM 25 NAAQS, and has been meeting

the NAAQS since the 2007-2009 period. Note that U.S. EPA published a Clean Data

Determination for the Chicago PM 25 nonattainrnent area on November 27,2009.

In support of these redesignation requests, the Illinois EPA submits the follovving amendments to
lllinois' SIP for ozone and PM 25 :

• Reasonably Available Control Technology (RACT) for Volatile Organic Material (VOM) Emissions from Group II and Group IV Consumer and Commercial Products; Proposed Amendments to 35 lll. Adm. Code 211, 218, and 219;

• Final Maintenance Plan for the Illinois Portion of the Chicago Ozone

Nonattainrnent Area for the 1997 8-Hour Ozone National Ambient Air Quality Standard;

• Final Maintenance Plan for the Metro-East Ozone Nonattainment Area for the

1997 8-Hour Ozone National Ambient Air Quality Standard;

• Final Maintenance Plan for the Chicago Nonattainment Area for the 1997 PM25

National Ambient Air Quality Standards.

The YOM RACT submittal is intended to meet the obligation of the State of Illinois under the

Clean Air Act (CAA) to submit a revision to the SIP to address requirements under Sections 172

and 182 for sources ofVOM emissions in areas designated as nonattainment with respect to the

ozone NAAQS. This submittal addresses deficiencies identified by your staff in Illinois EPA's previous submittal dated July 29, 2010. We have worked closely with your staff in this regard

and we believe this submittal is fully approvable. As you know, U.S. EPA did not identify

deficiencies in Illinois EPA's July 29, 2010 submittal with regards to the Group III Consumer

and Commercial Product Categories, so these rules have not been amended and are not included

in this submittal.

The Illinois EPA is also submitting Maintenance Plans for the Chicago and Metro-East 8-hour

ozone nonattainrnent areas, and the Chicago PM2.5 nonattainment area pursuant to Sections 107(d)(3)(E), 110(a)(2), and l75A of the CAA. InclUded with these plans are revised year 2025

motor vehicle emissions budgets developed using the MOVES model. The Maintenance Plans, including the motor vehicle emissions budgets, are required as part of the Illinois EPA's redesignation request. The Maintenance Plans provide the supporting information for this
request, consistent vvith the criteria for redesignation set forth in Section 175A of the CAA.

2The Maintenance Plans constitute revisions of Illinois' SIP for ozone and PM2.5. Accordingly,

the Illinois EPA held a public comment period and offered an opportunity for a public hearing.

The Public Notice was published in local newspapers on July 8, 2011, and also posted on the

Illinois EPA's web site. Due to receiving no requests for a hearing a hearing was not held.
However, the Illinois EPA did receive comments during the 30 day comment period. The

enclosed Responsiveness Summary summarizes the comments received and the Illinois EPA's

revisions to the Final Maintenance Plan to address these comments.

In order to assist with your review of these SIP submittals, two paper copies and an electronic

disk of all documents are enclosed. A list of the enclosed documents is also attached.

The Illinois EPA believes that these submittals, in conjunction with other submittals made previoLlsly to the U.S. EPA, will allow the U.S. EPA to expeditiously take the necessary actions

to redesignate both the Chicago and Metro-East areas to attairunent for the 1997 8-hour ozone
standard and to redesignate the Chicago area to attairunent for the 1997 PM25 standards.

If further information is required or should you have any questions, please feel free to contact

Rob Kaleel, Air Quality Planning Section, at (217) 524-4387.

Sincerely,

# i<U~~

Laurel L. Kroack
Chief, Bureau of Air

Attachments

3Illinois State Implementation Plan

List of Enclosed Documents

RACT for VOM Emissions from Group II and Group IV Consumer and Commercial Products; Proposed Amendments to 35 III. Adm. Code 211, 218, and 219

1. Illinois EPA regulatory proposal, March 7, 2011 (certain docnments omitted)

2. Letter from Acting Chairman Girard to Director Ribley of the Department of Commerce

and Economic Opportunity ("DCEO") regarding request for economic impact study,

March 17,2011

3. Order of the Board by A.S. Moore, accepting the Illinois EPA's regulatory proposal for hearing, granting the Illinois EPA's request for waiver of copy requirements, and ordering the clerk to tile the proposal for first notice publication in the Illinois Register,

March 17,2011 (full text of rule omitted)

4. Hearing Officer Order, Notice of Hearings, March 17,2011

5. Illinois Register Notice of Proposed Amendments, 35 Ill. Reg. 4887, April 1, 2011 (full

text of rule omitted)

6. Prefiled Testimony of David Bloomberg and Prefiled Testimony ofYoginder Mahajan of

Illinois EPA, April 14, 2011

7. Comments of Specialty Graphic Imaging Association, April 15, 2011

8. lllinois EPA's Motion to Amend Rulemaldng Proposal, April 25, 2011

9. Record of Hearing, April 27, 2011 (full transcript omitted)

10. Prefiled Testimony of James Sell, American Coatings Association, May 6, 2011

11. Post-Hearing Comments of the Illinois EPA, May 16,2011

12. Comments of The Boeing Company, filed May 17,2011

13. Record of Hearing, May 18, 20 11 (full transcript omitted)

14. lllinois EPA's Request to Cancel [Third] Hearing and Motion to Correct Transcript, May 19,2011

15. Hearing Officer Order cancelling third hearing, May 20, 2011

416. Post-Hearing Comments of the Illinois EPA, June], 2011

17. Order of the Board by A.S. Moore, adopting the rule for second notice review by JCAR,

June 16,2011 (full text of rule omitted)

18. Letter from JCAR to Acting Chairman Girard and Certification of No Objection to Rulemaking Proposal, July 12, 2011

19. Final Order of the Board by A. S. Moore, adopting the rule and ordering the clerk to file

final rule for publication in Illinois Register, July 21,2011 (full text of rule omitted)

20. Illinois Register Notice of Adopted Amendments, 35 Ill. Reg. 13451, August 12,2011

Maintenance Plans for the Chicago and Metro-East Ozone Nonattainment Areas for the

1997 8-Hour Ozone NAAQS, and the Chicago PM 

### z

. 5 Nonattainment Area for the 1997

PM z .5 NAA QS

1. Final Maintenance Plan for the Illinois Portion of the Chicago Ozone Nonattainrnent

Area for the 1997 8- Hour Ozone National Ambient Air Quality Standard (Revised), AQPSTR I**]~06,** Illinois EPA, September 15,2011.

2. Final Maintenance Plan for the Metro-East Ozone Nonattainment Area for the 1997 8-

Hour Ozone National Ambient Air Quality Standard (Revised), AQPSTR 11-05, Illinois
EPA, August 18, 20 II.

3. Final Maintenance Plan for the Chicago Nonattainrnent Area for the 1997 PM2.5 National

Ambient Air Quality Standards (Revised), AQPSTR 11-07, Illinois EPA, August 17, 20]1.

4. Notice of Public Hearing and Comment Period, July 8, 2011.

5. Notice of Cancellation of Public Hearing. August 12,2011.

6. Comments of the Sierra Club, filed August 8, 2011.

7. Responsiveness Summary, Illinois EPA, September 13, 2011.

5

# Maintenance Plan for the

Illinois Portion of the Chicago Ozone Nonattainment Area

f or the 1997 8

- Hour Ozone Standard

(Revised)

AQPSTR 11

- 0 6

September 15, 2011

Illinois Environmental Protection Agency

1021 North Grand Avenue East Springfield, Illinois 62794

- 9276i TABLE OF CONTENTS

Page

LIST OF TABLES

. . . . . . . . . iii

LIST OF FIGURES

. . . . . . . . . iv

EXECUTIVE SUMMARY

. . . . . . . . 5

1.0 INTRODUCTION

. . . . . . . . 6
1.1 Regulatory Background

. . . . . . 6
1.2 Status of Air Quality

. . . . . . . 8

2.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS 9

3.0 OZONE MONITORING

. . . . . . . 11

3.1 Monitored Design Values

. . . . . . 11

3.2 Qua lity Assurance

. . . . . . . 1 2

3.3 Continu ed Monitoring

. . . . . . 13

4.0 EMISSION INVENTORY

. . . . . . . 14

4.1 Attainment Year Inventory

– 200 8

. . . . . 14

4.2 Air Quality Improvements and Emission Controls

. . . 15

4.3 Emissi on Projections

. . . . . . . 16

4.4 Demonstration of Ma intenance

. . . . . 17

4.5 Provisions for Future Updates

. . . . . 18

5.0 CONTROL MEASURES AND REGULATIONS

. . . 19

5.1 Attainment Demonstration Control Measures

. . . 19

5. 2 Reasonable Further Progress (RFP)

. . . . 20

5. 3 Reasonably Available Control Technology (RACT)

. . . 2 0

5. 4 Controls to Remain in Effect

. . . . . . 2 2

5. 5 Provisions for Permitting New or Modified Emission Sources

. 22

5. 6 Transport ation Conformity

. . . . . . 22

6.0 CONTINGENCY MEASURES

. . . . . . 24

6.1 Contingency Measure s

. . . . . . 24

6.2 Commitmen t to Revise Plan

. . . . . . 26

6.3 Public Participation

. . . . . . . 2 6
6.4 Legal Authority to Implement and Enforce

. . . . 27

7 .0 CONCLUSIONS

. . . . . . . . 28ii TABLE OF CONTENTS (Continued)

APPENDIX A Summary of Ambient Air Monitoring Data ( 2006

- 2008 ) .......................... 29

APPENDIX B Transportation Conformity .............................................................. 32ii i LIST OF TABLES

Page

Table 4.1 200 8 Chicago Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 14

Table 4. 2 20 02 Chicago Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 15

Table 4.3 201 5 Chicago Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 16

Table 4.4 2020 Chicago Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 1 7

Table 4. 5 202 5 Chicago Ozone Nonattainment Area

VOM and NOx Emissions

. . . . . . 1 7

Table 4. 6 Comparison of 200 8

, 2015 , 20 20 , and 2025 Emission Estimates

Chicago Nonattainment Area

. . . . . . 1 8

Table 5.1 Proposed Chicago Maintenance Year Plan 20 08 and 2025 Motor

Vehicle Emissions Budgets for the 1997 8

- Hour Ozone NAAQS

. . 23

Table 6.1 Contingency Plan for the Chicago 8

- Hour Ozone

Nonattainment Area

. . . . . . . 2 5iv LIST OF FIGURES Page

Figure 1.1 Map of the Lake Michigan Ozone Nonattainment Areas

. . 7

Figure 3.1 Ozone Monitors in the Lake Michigan Area

. . . . 11

Figure 3. 2 Comparison of 8

- Hour Ozone Design Values for the

Lake Michigan Region Between 2001

- 2003 and 2006

- 2008

. . 125

EXECUTIVE SUMMARY

This document describes Illinois’ Mai ntenance Plan for the Illinois portion of the Chicago ozone nonattainment area. A Maintenance Plan is required before the area can be redesignated from nonattainment to attainment of the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) promulgat ed in 1997

. This document also provides technical information required to support a redesignation request. Illinois intends to submit such a request to the U. S. Environmental Pro tection Agency (U.S. EPA)

. This revision incorporates motor vehicle emissions estimates developed using the U.S. EPA’s

MOVES model. The Illinois Environmental Protection Agency ( Illinois EPA) has prepared this plan in c o nsultation with the Indiana Department of Environmental Manage ment (IDEM), the Wisconsin Department of Natural Resources (WDNR), and the Michigan Department of Environmental Quality (MDEQ), the Lake Michigan Air Directors Consortium (LADCO), and the U.S. EPA. The IDEM has submitted a similar plan for the Indiana por tion of the Chicago nonattainment area.

Ozone air quality has dramatically improved in the Lake Michigan region as a result of implementation of State and Federal control measures since the designation of the Chicago area as nonattainment in 2004. With t he exception of Holland, Michigan, t he entire Lake Michigan region, including the Chicago nonattainment a rea, has at least three years of complete, quality assured ambient air quality monitoring data for 2006

- 2008 that demonstrates compliance with the 1997 8

- hour ozone NAAQS . These air quality improvements are due to permanent and enforceable emission control measures.

This Maintenance Plan provides for continued attainment of the 1997 8

- hour ozone air quality standard for the Chicago nonattainment area f or a period of ten years after U.S. EPA has formally redesignated the area to attainment. The Plan also provides assurances that, even if there is a subsequent violation of the air quality standard, measures listed in the Plan will prevent any future occu rrences through contingency measures that would be triggered upon such an occurrence. Finally, the Plan includes on

- road motor vehicle emissions budgets for use in transportation conformity determinations to assure that any

increases in emissions from thi s sector do not jeopardize continued attainment of the 8

- hour ozone standard during the ten

- year maintenance period.6

1.0 INTRODUCTION

This document describes Illinois’ Maintenance Plan for the Illinois portion of the Chicago ozone nonattainment area. A maintenance plan is required before the area can be redesignated from nonattainment to attainment of the 8

- hour ozone National Ambient

A ir Quality Standard (NAAQS) promulgated by the U. S. Environmental Protection Agency (U.S. EPA) in 1997

. Illinois intends to submit such a request to the U.S. EPA in conjunction with this Maintenance Plan. The Illinois E PA has prepared this plan in

co nsu lta tion with the Indiana Department of Environmental Management (IDEM), the Wisconsin Department of Natural Resources (WDNR), and the Michigan Department of Environmental Quality (MDEQ), the Lake Michigan Air Directors Consortium (LADCO), and U.S. EPA. Th e IDEM has submitted a similar plan for the Indiana portion of the Chicago nonattainment area . With the exception of Holland, Michigan, t he entire Lake Michigan region, including the Chicago area, has at least three years of complete, quality assured ambi ent air quality monitoring data for 2006

- 2008

, demonstrating attainment with the 1997 8

- hour ozone NAAQS.

This document also provides the technical information needed to support a request to redesignate the Chicago area to attainment of the 8

- hour ozone N AAQS. Section 107 of the Clean Air Act (CAA) establishes specific requirements to be met in order for a nonattainment area to be considered for redesignation. Before an area can be reclassified to attainment, U.S. EPA must make a determination that the a rea has attained the 8

- hour ozone NAAQS based on at least three complete years of ambient monitoring data. U.S. EPA must have approved a State Implementation Plan (SIP) for the area under Section

110 and Part D of the CAA. The state must demonstrate that the improvement in air quality is due to permanent and enforceable reductions in emissions resulting from implementation of the SIP and other federal requirements. Finally, the state must submit, and U.S. EPA must approve, a maintenance plan under Sectio n 175(A) of the CAA, including provisions for contingency measures that will be implemented if future

violations of the 8

- hour ozone NAAQS are measured.

This Maintenance Plan provides for the continued attainment of the 8

- hour ozone NAAQS for the Chicago nonattainment area (NAA) for a period of at least ten years after U.S. EPA has formally redesignated the area to attainment. The Plan also provides assurances that even if a subsequent violation of the ozone NAAQS occurs, provisions in the Plan will preve nt any future occurrences through contingency measures that would be triggered upon such occurrence.

This document addresses the maintenance plan requirements established by the CAA and U.S. EPA, and includes additional information to support continued co mpliance with the

8

- hour ozone NAAQS.

1.1 Regulatory Background

The CAA, as amended in 1990, requires areas that fail to meet the NAAQS for ozone to develop SIPs to expeditiously attain and maintain the NAAQS. Historically, exceedances of the ozone NAAQ S have been monitored in Cook and Lake Counties in Illinois, and in7

portions of Wisconsin, Indiana, and Michigan immediately downwind of the Chicago, Gary, and Milwaukee metropolitan areas.

The Chicago NAA, which includes Lake and Porter Counties in north west Indiana, was originally designated as n onattainment in 2004 pursuant to the 199 7 revisions to the

ozone N AAQS. Several counties in eastern Wisconsin , and one county in western Michigan adjacent to Lake Michigan were also designated as nonattainment of the 8

- hour ozone NAAQS , although these areas are separate from the Chicago NAA. Figure 1.1 depicts the current NAA s in the Lake Michigan region.

Figure 1.1 Map of the Lake Michigan Ozone Nonattainment Areas

The following is a list of the counties, and portions thereof, contained in the Chicago 8

- hour ozone severe nonattainment area:

Cook County, IL Lake County, IL DuPage County, IL McHenry County, IL8 Kane County, IL Will County, IL Grundy County, IL (Aux Sab le and Goose Lake Townships) Kendall County, IL (Oswego Township) Lake County, IN Porter County, IN

As a result of the designation as nonattainment and the accompanying classification as

moderate , these areas were subject to new requirements, including development of a plan demonstrating that the area would meet the federal 8

- hour NAAQS for ozone by June 15,

20 10

.

Recognizing the need for a regional solution, the States of Illinois, Indiana, Mich igan, Ohio, and Wisconsin worked cooperatively, under the auspices of the Lake Michigan Air Directors Consortium (LADCO)

, to jointly develop a nd evaluat e an effective regional attainment strategy to enable the Lake Michigan region to attain the 8

- hour ozone NAAQS. The attainment strategy recognize s the importance of both locally generated ozone precursor emissions and the need for significant reductions of incoming (transported) ozone and ozone precursor emissions (including oxides of nitrogen, or

NOx ) to allow the States to attain the NAAQS. The emission reductions needed to attain

the 8

- hour ozone NAAQS include both State and Federal measures that have reduced ozone precursor emissions both locally and regionally. These measures have allowed the

Ch icago nonattainment area to attain the 8

- hour ozone standard by the attainment deadline established by the U.S. EPA.

1.2 Status of Air Quality

Ozone monitoring data for the most recent three

- year period, 2006 through 200 8

, demonstrates that air quality h as met the 1997 8

- hour ozone NAAQS in the entire Lake Michigan region, including the Chicago nonattainment area , with the exception of Holland, Michigan

. Modeling performed by LADCO shows that Holland, MI will attain

the 1997 ozone NAAQS by 2012.9

2.0 REDESIGNATION AND MAINTENANCE PLAN REQUIREMENTS

Sections 107 and 110 of the CAA list a number of requirements that must be met by nonattainment areas prior to consideration for redesignation to attainment. One of those requirements is the maintenance pla n, which describes a state’s plan for maintaining the NAAQS for a ten

- year period after redesignation to attainment. U.S. EPA has published guidance for the preparation of maintenance plans and redesignation requests. This guidance is contained in a docu ment entitled ―Procedures for Processing Requests to Redesignate Areas to Attainment‖ (September 4, 1992).

Before a redesignation to attainment can be promulgated, U.S. EPA must:

Determine that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show that violations of the ambient NAAQS are no longer occurring. This showing must rely on three consecutive years of data. The ambient air monitoring data must be quality assured in accordance with 40 CFR 58.10, recorded in U.S. EPA’s Air Quality System (A Q S) data base, and is available to the public.

Approve the state’s plan for demonstrating attainment. The attainment plan,

which is based on air quality modeling, must contain enforceable control measures and must be submitted as a revision to the state’s SIP after a public hearing.

Determine that the improvement in air quality between the year violations occurred and the year that attainm ent was achieved is based on permanent and

enforceable emission reductions

.

Approve the state’s maintenance plan. The requirements for the maintenance plan

are discussed below.

Determine that all other requirements applicable to nonattainment areas have been

met.

A maintenance plan provides for the continued attainment of the 8

- hour ozone NAAQS for a nonattainment area for a period of ten years after U.S. EPA has formally redesignated the area to attainment. The plan also provides assurances that even if a subsequent violation of the NAAQS occurs, provisions in the plan will prevent any future occurrences through contingency measures that would be triggered upon such

occurrence. To be approvable, the state is required to have a public comment period an d provide the opportunity for a public hearing on the Maintenance Plan prior to adoption. The maintenance plan must contain the following elements:

A comprehensive emission inventory of the precursors of ozone completed for the ―attainment year‖ ;10 A projection of the emission inventory forward to a year at least ten years after redesignation and a demonstration that the projected level of emissions is sufficient to maintain the ozone NAAQS ;

A commitment that, once redesignated, the state will continu e to operate an appropriate monitoring network to verify maintenance of the attainment status ;

A demonstration of legal authority to implement and enforce all control measures
contained in the SIP ;

Provisions for future updates of the inventory to enable tracking of emission levels, including an annual emission statement from major sources ;

Motor vehicle emissions budgets for transportation conformity for the ten

- year maintenance period ;

A commitment to submit a revised maintenance plan eight years afte r redesignation ;

A commitment to enact and implement additional contingency control measures expeditiously in the event that future violations of the NAAQS occur ;

A list of potential contingency measures that would be implemented in such an

event.

Illinois’ Maintenance Plan has been prepared in accordance with the requirements specified in U.S. EPA’s guidance document and additional guidance received from U.S.

EPA staff.

The following sections of this document describe how U.S. EPA’s requirements h ave been met.11

3.0 OZONE MONITORING

U.S. EPA’s published guidance document, ―Procedures for Processing Requests to Redesignate Areas to Attainment‖ (September 4, 1992), details specific requirements regarding the collection and use of ambient air monitor ing data needed to support a redesignation request. Before the Chicago NAA can be redesignated, Illinois must demonstrate that the NAAQS for ozone, as published in 40 CFR 50.4, has been attained. Ozone monitoring data must show that violations of the NAA QS are no longer occurring

within the nonattainment area . This showing must rely on three complete, consecutive calendar years of quality assured data. Further, the air monitoring data must be quality assured in accordance with 40 CFR 58.10, recorded in U.S. EPA’s AQS data base, and made available to the public. Finally, Illinois must commit to continue to operate an appropriate monitoring network to verify the maintenance of the attainment status, once the area has been redesignated.

The following subsections describe how each of these requirements has been addressed.

3.1 Monitored Design Values

Currently there are 55 ozone monitors located in the nonattainment counties in the Lake Michigan region; 9 are located in northwestern Indiana, 17 in northeastern Illinois, 13 in western Michigan, and 16 in eastern Wisconsin.

Figure 3.1 Ozone Monitors in the Lake Michigan Area

To determine whether the NAAQS is being exceeded, the design value must be12

calculated. The current U.S. EPA method for calculating the ozone design value is to

average the 4 th highest daily maximum 8

- hour value for each year over the 3

- year period.

The calculated 8

- hour ozone design values for the monitors in the Lake Michigan r egion

for 2006

- 2008 are included as Appendix A of this report. Figure 3. 2 compares the design

values for the 2001

- 2003 period for monitoring stations in the Lake Michigan region to the corresponding design values from 2006

- 2008 . The data demonstrate that ozone air quality has improved dramatically throughout the Lake Michigan region and that the NAAQS for ozone has been attained for the 2006

- 2008 period at all locations except Holland, Michigan

.

Figure 3. 2 Comparison of 8

- Hour Ozone Design Values for the Lake Michigan Region

Between 2001

- 2003 and 2006

- 2008

2001

- 2003 2006

- 2008

3.2 Quality Assurance

Illinois EPA has quality assured all data shown in Appendix A for all sites located in

Illinois in accordance with 40 CFR 58.10 and the Illinois EPA ’s Quality Assurance Plan,13

which describes Illinois EPA ’s standard operating procedures for operating the ambient

monito ring network and validating the data. The other states in the Lake Michigan region have similar quality assurance plans. Illinois EPA has recorded the data in the
U.S. EPA’s A QS database, as have the other Lake Michigan states. U.S. EPA’s AQS

database is available to the public.

3. 3 Continued Monitoring

Illinois commits to continue monitoring ozone levels according to a U.S. EPA approved monitoring plan, as required to ensure maintenance of the ozone NAAQS. Should changes in the location of an ozone monitor become necessary, Illinois EPA will work with U.S. EPA to ensure the adequacy of the monitoring network. Illinois EPA will continue to quality assure the monitoring data to meet the requirements of 40 CFR 58.

Illinois EPA will continue to enter a ll data into A QS on a timely basis in accordance with federal guidelines.14

4.0 EMISSIONS INVENTORY

A redesignation request must contain a demonstration that the improvement in air quality between the year that violations occurred and the year that attai nment was achieved is based on permanent and enforceable emission reductions . As described previously in Section 3.0, a three

- year monitoring period is used to evaluate whether attainment has been achieved. In this Section, the ―attainment year‖ refers t o the last year ( 200 8 ) of the

three

- year period ( 2006

- 2008 ) used to demonstrate attainment. The request should also include a projection of the emission inventory to a year at least 10 years following redesignation, a demonstration that the projected leve l of emissions is sufficient to maintain the ozone NAAQS, and a commitment to provide future updates of the inventory to enable tracking of emission levels during the 10

- year maintenance period.

4.1 Attainment Year Inventory, 200 8

Illinois EPA has prepar ed a comprehensive emissions inventory for the Illinois portion of

the Chicago ozone nonattainment area, including point, area, and on

- road and off

- road mobile sources for precursors of ozone ( VOM and NOx) for the attainment year, 200 8

. Point source information was compiled from 200 8 annual emission reports submitted to

the Illinois EPA by emission sources and the U.S. EPA’s Clean Air Markets Division

database for electric utilities

. Area source emissions were ―grown‖ from 2002 acti vity levels appropriate for each source category. Biogenic emissions are not included in these

summaries. On

- road mobile source emissions were calculated using U.S. EPA’s

MO VES emissions model with vehicle miles traveled (VMT) data provided by the

Illino is Department of Transportation (IDOT)

. Off

- road mobile source emissions were calculated using U.S. EPA’s NONROAD emissions model.

Table 4.1 summarizes the 200 8 e missions estimates for the Chicago ozone nonattainment

area. This summary has been revised to incorporate emissions estimates for on

- road mobile sources using U.S. EPA’s MOVES model.

Table 4.1
200 8 Chicago Ozone Nonattainment Area
VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)

Source C ategory VOM NOx

Point Sources 53.27 1 54.50

Area Sources 351.51 3 8.56

On

- Road Mobile Sources 1 17.23 373.52
Off

- Road Mobile Sources 265.44 330.18

Total 787.45 896.7615

4.2 Air Quality Improvement s and Emission Controls

The Chicago area was designated nonattainment in 2004, based on ozone air quality monitoring data collected between 2001 and 2003 . Since that time, permanent and

enforceable reductions of ozone precursor emissions have contributed to improvements in

ozone air quality and to the attainment of the ozone NAAQS. Some of these emission reductions were due to the application of tighter federal emission standards on motor
vehicles and fuels, and some due to the requirements of the federal NOx SIP Call.

Section 5.0 of this report describes these reductions in more detail, along with an explanation of their regulatory status. In this subsection, the emission levels from 200 8 are compared to emission levels estimated in 2002 when the Chicago area was first

propose d for a nonattainment designation for the 1997 8

- hour ozone standard.

U.S. EPA’s 8

- hour ozone Implementation Rule required that states with ozone nonattainment areas prepare and submit a 2002 base year anthropogenic inventory of sources of ozone precursor emissions. The base year inventory included emissions from point, area, on

- road mobile and off

- road mobile emissions. Illinois EPA prepared and submitted this inventory i n June 2006. Table 4.2 summarizes 2002 emissions by major source category and by p ollutant for the Illinois portion of the Chicago nonattainment

area. This summary has been revised to incorporate emissions estimates for on

- road mobile sources using U.S. EPA’s MOVES model.

Table 4.2
2002 Chicago Ozone Nonattainment Area
VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)
Source Category VOM NOx

Point Sources 76.62 307.73

Area Sources 520.21 42.93

On

- Road Mobile Sources 168.06 540.13
Off

- Road Mobile Sources 233.77 326.65

Total 998.66 1,217.44

Comparing the 2002 inventory to that for 200 8 indicates that total VOM emissions in the Chicago area decreased by about 210 tpd , while NOx emissions in the Chicago NAA

decreased by about 3 2 0 tpd during the same time period

. These sizeable emission reductions in ozone precursor emissions , plus reductions in upwind areas in Illinois and other nearby states, resulted in a substantial improvement in ozone air quality in the Chicago area, ultimately resulting in attainment of the 1997 8

- hour oz one NAAQS.16

4.3 Emission Projections

A maintenance plan must contain a demonstration that the level of emissions projected

for the ten

- year period following redesignation are sufficient to maintain the ozone NAAQS. Accordingly, Illinois EPA has projected VOM and NOx emissions for the Illinois portion of the Chicago nonattainment area for 20 2 5

. Illinois EPA has also projected emissions to 20 1 5 and 2020 , to represent two midpoint s during the maintenance period. Emissions for these t hree project ion years are compared to emission

levels in 200 8 to determine if emissions are sufficient to maintain the NAAQS during this period.

Chicago area point source emissions for 20 1 5, 2020, and 20 2 5 were estimated using the 2002 base year inventory and growth factors appropriate for each source category . Area source emissions were projected by applying category

- specific growth factors to

estimates contained in the 2002 base year inventory. County population projections for

20 1 5, 2020, and 20 2 5 were used to es timate emissions for categories which rely on a per capita emissions factors. Off

- road emissions projections were also developed using the 2002 inventory and growth factors contained in U.S. EPA’s NONROAD model. On

- road motor vehicle emissions were estimated using U.S. EPA ’s MO VES motor vehicle

emissions model. The figures assume the continued use of reformulated gasoline , the continued phase

- in of the Tier 2 motor vehicle emissions standards, and operat ion of an enhanced vehicle inspection and maintenance program. Total vehicle miles of travel (VMT) for 20 1 5, 2020, and 20 2 5 w ere assume d to increase at a rate of 1. 5 percent per year from 2002.

Tables 4.3 , 4.4, and 4. 5 include the VOM and NOx emissions estimates for the years

20 1 5, 2020, and 20 2 5 , respectively, for the Illinois portion of the Chicago nonattainment

area.

Table 4.3

20 1 5 Chicago Ozone Nonattainment Area
VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)

Source Category VOM NOx

Point Sources 62.02 15 0 .0 6
Area Sources 363.86 3 9.85

On

- Road Mobile Sources 50.33 197.14
Off

- Road Mobile Sources 90.83 106.36

Total 567.04 493.4117 Table 4.4
20 20 Chicago Ozone Nonattainment Area
VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)
Source Category VOM NOx

Point Sources 67.63 1 71.13

Area Sources 385.73 40.57

On

- Road Mobile Sources 37.98 116.69
Off

- Road Mobile Sources 84.16 84.34

Total 575.50 412.73

Table 4.5 2025 Chicago Ozone Nonattainment Area
VOM and NOx Emissions (Emissions stated in tons per ozone season weekday)
Source Category VOM NOx

Point Sources 72.79 180.13

Area Sources 406.96 41.35

On

- Road Mobile Sources 41.85 108.93
Off

- Road Mobile Sources 90.25 96.70

Total 611.85 427.11

4.4 Demonstration of Maintenance

Table 4. 6 demonstrates that the level of emissions projected for the ten

- year period following redesignation is sufficient to maintain the ozone NAAQS. As shown in the table, both VOM and NOx emissions within the nonattainment area are expected to

dec rease significantly between 200 8 and 202 5

. P rojected VOM and NOx emissions for

the mid

- point year s , 20 1 5 and 2020 , are also less than the emission levels in 200 8

. Based

on these emission trends it is expected that air quality will continue to meet the 8

- hour ozone NAAQS throughout the maintenance period.

In addition to the overall emission reductions projected to occur within the nonattainment area, significant reductions of statewide NO x emissions resulting from implementation of
Illinois’ multi

- pollutant standards affecting electric utilities by 20 12 , will also help to

ensure continued attainment of the 8

- hour ozone NAAQS.18 TABLE 4. 6 Comparison of 200 8 , 201 5, 2020, and 20 2 5 Emission Estimates

Chicago Nonattainment Area (Emissions stated in tons per ozone season weekday)

2008 2015 Difference

(2008

– 2015) 2020 Difference

(2008

– 2020) 2025 Difference

(2008

- 2025)

VOM 787.45 567.04 220.41 575.50 211.95 611.85 175.60

NOx 896.76 493.41 403.35 412.73 484.03 427.11 469.65

4.5 Provisions for Future Updates

As required by Section 175A(b) of the CAA, Illinois commits to submit to U.S. EPA, eight years after redesignation, a revised version of this Maintenance Plan. The revision will contain Illinois’ plan for maintaining the 8

- hour ozone NAAQS for ten years b eyond

the first 10

- year period after redesignation

.19

5.0 CONTROL MEASURES AND REGULATIONS

This section provides specific information on the control measures implemented in the Chicago nonattainment area, including the measures that were part of Illinois’ Attainment Demonstration, R easonable Further Progress (R F P) demonstration , CAA requirements,

and other state and federal measures. The control measures required in past ozone SIP revisions have been fully implemented, and other, more recent control progr ams will continue to provide emission reductions in future years. Illinois EPA commits to keep these measures in effect after redesignation, or to provide equivalent emissions levels using alternate measures. Illinois’ SIP contains acceptable provisions to provide for preconstruction review of new emission sources. After redesignation to attainment

, Prevention of Significant Deterioration (PSD) requirements will apply to the construction of new major sources and to significant modifications of existing s ources. Illinois has accepted delegation from U.S. EPA of this program. Illinois further commits to continue to require that all future transportation plans in the Chicago area conform with the SIP.

5.1 Attainment Demonstration Control Measures

Illinoi s’ attainment demonstration for the Chicago nonattainment area identifies control

measures that have been promulgated at either the state or federal level that are sufficient

to allow the Lake Michigan region, with the exception of Holland, MI, to meet the 1997

8

- hour ozone NAAQS by the required attainment date. The attainment demonstration

, which was submitted to U.S. EPA after a public hearing and public comment period, is
described in the Illinois EPA’s document: ―Attainment Demonstration for the 1997 8

- Hour Ozone National Ambient Air Quality for the Chicago Nonattainment Area‖ (Report

Number AQPSTR 09

- 03

, March 18, 2009 ). The primary emission reduction measures for demonstrating attainment of the ozone standard are as follows:

NOx SIP Call

New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPS)/Maximum Achievable Control Technology (MACT) Standards

VO M Solvent Categories: Aerosol Coatings, Architectural and Industrial Maintenance (AIM) Coatings, Consumer Solvents

Enhanced Vehicle Inspection & Maintenance Program

Reformulated Gasoline

Tier 2 Motor Vehicle Emissions Standards and Gasol ine Sulfur Control Requirements20 On

- Highway Heavy

- Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements

Federal Control Programs Incorporated into NONROAD Model (e.g., Nonroad Diesel Rule), plus Evaporative Large Spark Ignition and R ecreational Vehicle

Standards

Tier 4 Nonroad Diesel Engine Standards and Diesel Fuel Sulfur Content
Restrictions

Marine Compression

- Ignition Engine Standards and Locomotive Engine

Standards

Consent Decrees

--- Dynegy Midwest Generation, ConocoPhillips , CITGO

, Exxon

- Mobil, Marathon Ashland , Archer Daniels Midland

5.2 Reasonable Further Progress (RFP)

Since the Chicago region is classified as a moderate nonattainment area for the 8

- hour ozone standard, a 15 percent net reduction in VOM emissions from 2002 levels was required by 2008 in order to meet the RFP requirement. The Illinois EPA did not rel y on NOx substitution to meet its 15 percent RFP reduction, relying solely on VOM emission

reductions.

Reductions in VOM emissions are primarily achieved through implementation of the

contro l measures listed in Section 5.1.

The RFP demonstration is contained in Illinois EPA’s document: ―Chicago

Nonattainment Area 8

- Hour Ozone Reasonable Further Progress Demonstration‖

, (Report Number AQPSTR 09

- 05

, March 18, 2009 )

. The control measures identified in

the RFP document , including those listed above, will result in a 15.7 percent reduction in

VOM emissions from 2002 emissions levels by the year 2008. In addition, continuing reductions in 2009 and 2010 are estimated to result in year 2010 VOM emissions at 21.0 percent below 2002 levels. These emissio n reductions achieve the 15% RFP target for the Chicago nonattainment area.

5.3 Reasonably Available Control Technology (RACT)

Pursuant to Sections 172, 182(b) and (f) of the CAA, RACT is required for all existing major sources of the applicable criteria pollutant and its precursors (VOM and NOx)

located in NAAs. U.S. EPA defines RACT as the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technolog ical feasibility and economic reasonableness (70 FR 71612; November 29, 2005). The major source threshold for moderate NAAs is defined as 100 tpy. A source generally consists of several units that emit pollutants. The21

sum of emissions from all units at the source determines if a unit is major and thus subject to RACT requirements.

RACT is not a new requirement under the CAA. Illinois previously addressed RACT requirements in the Chicago area in developing attainment plans for the 1

- hour ozone standard. ( See 35 Ill. Adm. Code Part 21 8 ) T he Illinois EPA has evaluated the previously adopted regulations to determine if the RACT requirement is still being met

for 8

- hour ozone. The RACT r equirement for NOx was waived for the 1997 8

- hour ozone standard, based on U.S. EPA’s finding that additional NOx reductions were not

needed for the area to attain the standard.

Sections 172, 182(b)(2)

, and 182(f) of the C AA require implement ation of R ACT for sources that are subject to Control Techniques Guidelines (CTGs) that are promulgated by U

. S

. EPA. The U.S. EPA has issued CTGs defining RACT for those categories of sources that emit the greatest amounts of VOM emissions

. Illinois EPA has propos ed regulations to implement the revised CTGs issued by the U.S. EPA in 2006, 2007, and

2008. The 2006 CTG’s addressed industrial cleaning solvents, offset lithographic printing and letterpress printing, flexible package printing, and flat wood paneling

co atings. The 2007 CTG’s address paper, film, and foil coatings, large appliance coatings, and metal furniture coatings. The 2008 CTG’s address miscellaneous metal and plastic parts coatings, fiberglass boat manufacturing materials, miscellaneous industrial adhesives, and automobile and light

- duty truck assembly coatings. Other than the above

mentioned CTGs, Illinois has adopted applicable rules addressing all CTG s published by U.S. EPA for which there are existing sources in the Chicago NAA.

Non

- CTG sour ces are defined as major VOM sources which are not subject to CTGs, but for which RACT is required. All major sources of ozone precursors located in the ozone NAA that are not subject to individual RACT rules are subject to a generic RACT rule.

These rul es apply to non

- CTG sources that have the potential to emit 100 tons or more per year of VOM. Thus, Illinois has met the obligation to implement RACT on non

- CTG
VOM sources in the NAA.

It should be noted that other regulatory requirements also affect VOM emission sources within the Chicago ozone NAA. These include Maximum Achievable Control Technology (MACT), federal New Source Performance Standards (NSPS), and National Emission Standards for Hazardous Air Pollutants (NESHAPS) . T hese programs satisfy the RACT requirements for specific source categories because these rules are more stringent than RACT. It is concluded from this review that Illinois ’ existing VOM RACT

rules f ulfill U.S. EPA’s RACT requirements for VOM sources in the NAA.

As mentione d previously, the RACT requirement for NOx was waived under the 1997 8

- hour ozone NAAQS. Although the Illinois EPA has adopted NOx RACT rules

, the attainment demonstration for the Chicago NAA for the 1997 ozone NAAQS d id not rely

on emission reductions fr om the Illinois EPA’s NOx RACT rules . The reductions resulting from this program, when implemented, will help the area to maintain the NAAQS in future years.22

5.4 Controls to Remain in Effect

Illinois will maintain all of the control measures listed in t his Section to ensure

maintenance of the 8

- hour ozone NAAQS. Any revisions to the control measures included as part of the Maintenance Plan will be submitted as a SIP revision to U.S. EPA for approval, and will be accompanied by a showing that such change s will not interfere with maintenance of the NAAQS.

Illinois EPA has the necessary resources to enforce any violations of its rules or permit provisions. After redesignation, it intends to continue enforcing all rules that relate to the

emission of ozone precursors in the Chicago nonattainment area.

5. 5 Provisions for Permitting New or Modified Emission Sources

Illinois has longstanding and fully implemented programs for the review of new major sources and significant modifications of existing sources. The Prevention of Significant Deterioration (PSD) program

, which include s requirements for Best Available Control Technology (BACT) on major new sources or significant modifications of existing sources, will be applicable in the Chicago area once the area has been redesignated to
attainment . Illinois has been delegated full authority to implement the PSD program by

U.S. EPA.

5. 6 Transportation Conformity

The purpose of this section is to describe and establish the Chicago nonattainment area motor vehicle emissions budgets associated with the 8

- hour ozone Maintenance Plan S IP.

A verage summer weekday motor vehicle emissions budgets are being proposed for the attainment year, 2008, an d the final year of the Maintenance Plan, 20 2 5

, for the precursor pollutants VOM and NOx

. Although the Maintenance Plan includes motor vehicle emissions estimates for the milestone years 2015 and 2020, these years are not being proposed as motor vehicle e missions budgets. The 2008 and 20 2 5 budgets were developed consistent with the motor vehicle activity assumptions and emissions control strategies incorporated into the 8

- hour ozone attainment demonstration analysis. The budgets reflect an emissions leve l determined using motor vehicle VMT and fleet mix provided by the Chicago Metropolitan Agency for Planning (CMAP) and are consistent

with the emission levels used in the attainment demonstration

.

A motor vehicle emissions budget is that portion of the total allowable emissions allocated to highway and transit vehicle use that are defined in the SIP for a certain year. The rules governing transportation conformity require certain transportation activities to

be consistent with motor vehicle emissions bu dgets contained in control strategy implementation plans (40 CFR § 93.118). Section 93.101 of the rule defines a ―control strategy [State] implementation plan revision‖ as a ―plan which contains specific strategies for controlling the emissions and reduci ng ambient levels of pollutants in order to satisfy CAA requirements of reasonable further progress and attainment.‖ In order to23

demonstrate conformity to the motor vehicle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program must be less than or equal to the budget level (40 CFR § 93.118(a)).

The motor vehicle emissions budgets established and described herein were developed consistent with the methodology and control strategy assumptions us ed in the 8

- hour

ozone a ttainment d emonstration. The effects of motor vehicle control measures are incorporated into the emissions factors produced by the U

. S

. EPA’s MO VES model. These control measures include motor vehicle emissions standards, the opera tion of a vehicle inspection and maintenance (I/M) program, and the required use of reformulated gasoline and low sulfur gasoline and diesel fuel.

The Maintenance Plan emissions analysis summarized in Table 4.6 estimates that VOM

and NOx emissions will be 1 75.60 and 469.65 tons per day, respectively, less in 2025 than the 2008 attainment year emissions levels. The transportation conformity regulations (40 CFR § 93.118(a)) allow the addition of a portion of this ―safety margin‖

to the motor vehicle emissi ons estimates

. As year 2025 emissions levels are projected to be substantially less than the attainment year 2008 emissions, a 15% safety margin is being proposed to be added to the 2025 estimated motor vehicle emissions to make up the

motor vehicle emiss ions budget. The 15% increase would equate to an increase of 6.28 tpd of VOM and 16.34 tpd of NOx.

The motor vehicle emissions budgets, which reflect the VMT, control program assumptions and safety margin are listed in Table 5.1.

Table 5 .1

Proposed Chicago 8

- hour Ozone Maintenance Plan

2008 and 202 5 Motor Vehicle Emissions Budgets (tons per ozone season weekday)

Estimated Emissions Safety Margin Motor Vehicle Emissions Budgets

Year VOM NOx VOM NOx VOM NOx

2008 1 17

. 23 373.52

- - - - 1 17

. 23 373.52

202 5 41.85 108.93 6.28 16.34 48.13 125.27

Complete detail s on the derivation of the motor vehicle emissions budgets, including

discussion of the MO VES model inputs and assumptions are included in Appendix B of this report

.24

6.0 CONTINGENCY MEASURES

6.1 Contingency Measures

Section 175(A) of the CAA specifies the requirements for maintenance plans, including provisions for contingency measures that will be implemented if violations of the 8

- hour ozone NAAQS are measured after redesignation to a ttainment. A list of potential contingency measures that would be implemented in such an event should also be included in the Maintenance Plan. Finally, the plan should provide a commitment to submit a revised maintenance plan eight years after redesigna tion to ensure continued

maintenance for the next ten

- year maintenance period.

Contingency measures are intended to provide further emission reductions in the event

that violations of the 8

- hour ozone NAAQS occur after redesignation to attainment.

While these measures do not need to be fully adopted by the I PCB prior to the occurrence of NAAQS violations, the contingency plan should ensure that the contingency measures are adopted expeditiously once they are triggered. The Maintenance Plan must identify the triggers that determine when contingency measures will be adopted

, and the measures that the state will consider.

Illinois EPA ’s contingency plan for the Chicago NAA is described in Table 6.1

. Consistent with this plan, Illinois agrees to adopt and implement, as expeditiously as is practicable, the necessary corrective actions in the event that violations of the 8

- hour ozone NAAQS occur within the Chicago maintenance area after redesignation to
attainment. Further, Illinois commit s to continue to implement the control measures

identified in the attainment demonstration and R FP demonstration . As described in Section 5.0 of this report, Illinois has adopted and is continuing to implement a ran ge of control measures that will greatly reduce precursor emissions, both locally and statewide. The contingency plan anticipates that these emission reductions will be sufficient to mitigate exceedances or violations of the NAAQS that may occur in the co ming years without further regulatory action.

The contingency plan provides for different levels of corrective responses should ambient

8

- hour ozone levels exceed the NAAQS in any year , if emissions in the NAA increase significantly above current attainment levels, or if the NAAQS is violated. A Level I response would occur in the event that: 1) the fourth highest 8

- hour ozone concentration at any monitoring site in the Chicago NAA exceeds 84 ppb in any year, or 2) if VOM or

NOx emissions increase more than 5% above the levels contained in the attainment year (2006) emissions inventory. It should be noted that U.S. EPA does not require a state to implement contingency measures when occasional exceedances are recorded. I llinois EPA’s voluntary com mitment to initiate a Level I response is intended to prevent future violations of the NAAQS from ever occurring.

Illinois commits to compiling VOM and NOx emissions inventories every three years for

the duration of the Maintenance Plan to facilitate the emissions trends analysis included25 Table 6.1

Contingency Plan for the Chicago 8

- Hour Ozone Nonattainment Area

Contingency Measure Trigger Action to be Taken List of Potential Contingency Measures

Level I Trigger

Fourth highest

m onitored 8

- hour

average ozone concentration exceeding 84 ppb in
any year at any monitoring station in the Chicago

maintenance area.

The Chicago
maintenance area’s

NOx or VOM

emissions inventories

increase more than
5% above the levels

included in the 2006

emissions inv entories. IL will evaluate air quality , or determine if adverse emissions trends are likely to continue. If so, IL will

determine what and where controls may be required, as well as level of emissions reductions needed, to avoid a violation of the NAAQ S. The study shall be completed within 9 months. If necessary, control measures shall be adopted within 18 months of determination and implemented as expeditiously as practicable, taking into

consideration the ease of implementation and the technical and economic feasibility of the selected

measures. Point Source Measures

IL Multi

- Pollutant Program for electric generating units

NOx RACT Clean Air Transport Rule, after promulgation by USEPA

Best Available Retrofit Technology (BART) Broader geographic applicability of existing measures

Mobile Source Measures

Tier 2 Vehicle Standards and Low

Sulfur Fuel Heavy Duty Diesel Standards and

Low Sulfur Diesel Fuel High

- enhanced I/M (OBDII)

Federal railroad/locomotive

standards

Federal commercial marine vessel engine standards

Portable fuel containers

Area Source Measures

Architectural/Industrial Maintenance (AIM) Coatings

Commercial and Consumer

Products Aerosol coatings Level II Trigger

A violation of the NAAQS at any monitoring station in

the Chicago

maintenance area. IL will conduct a thorough analysis to determine appropriate measures to
address the cause of the violation. Analysis shall be completed within 6

months. Selected measures shall be implemented within 18 months of a

violation.

in the contingency plan under Level I. Illinois will coordinate with LADCO and other Lake Michigan states to evaluate the causes of high ozone levels or the emissions trends and to determine appropriate control measures needed to assure continued attainment of

8

- hour ozone NAAQS. Under Level I, measures that could be implemented in a short time would be selected so as to be in place quickly after the Illinois EPA is aware that corrective measures have been triggered. Control measures selected under Level I will be adopted in most cases within 18 months after a determination is made, and implemented, generally, within 24 months of adoption by the IPCB.

A Level II response would be implemented in the event that a violation of the 8

- hour ozone NAAQS were to be measured at a monitoring site within the Chicago maintenance

area

. In order to select appropriate corrective measures, Illinois will work with LADCO and other Lake Michigan States to conduct a comprehensive study to determine the26

causes of the violatio n and the control measures necessary to mitigate the problem. The analysis will examine the following factors:

the number, location, and severity of the ambient ozone concentrations; the weather patterns contributing to ozone levels; potential, contribut ing emissions sources; the geographic applicability of possible contingency measures; emissions trends, including timeliness of implementation of scheduled control

measures; current and recently identified control technologies;

air quality contributions from outside the maintenance area.

Contingency measures will be selected from those listed in Table 6.1 or from any other measure deemed appropriate and effective at the time the selection is made. This list of contingency measures is comprehensive, and it is expected that only a few of these measures would be required. The selection between measures will be based upon cost

effectiveness, emission reduction potential, economic and social considerations, ease and timing of implement ation, or other appropriate factors. Implementation of necessary controls in response to a Level II trigger will take place as expeditiously as possible, but in no event later than 18 months after Illinois makes a determination, based on quality

assured a mbient data, that a violation of the NAAQS has occurred.

Adoption of additional control measures is subject to necessary administrative and legal

processes. I llinois EPA will solicit input from all interested and affected persons in the area prior to sel ecting appropriate control measures. No contingency measure will be implemented without providing the opportunity for full public participation. This process will include publication of notices, an opportunity for public hearing, and other measures requi red by Illinois law.

6.2 Commitment to Revise Plan

As noted in Section 4.5 above, Illinois commits to review its Maintenance Plan eight years after redesignation, as required by Section 175(A) of the CAA

. The Maintenance

Plan revision is intended to ens ure continued attainment of the 8

- hour ozone NAAQS for

an additional ten

- year period.

6.3 Public Participation

In accordance with Section 110(a)(2) of the CAA, Illinois is required to have a public comment period and provide the opportunity for a public hearing on the Maintenance Plan prior to adoption. Public participation in the SIP process is provided for as follows:

Notice of availability of the Maintenance Plan docume nt and the time and date of the public hearing was published in the Chicago Sun Times on July 8, 2011

.27 If requested, the public hearing to receive comments on the Chicago Maintenance Plan was scheduled for August 18, 2011, at 1:00 p.m. in the Sangamo Room at the Illinois EPA’s Headquarters at 1021 N. Grand Ave. East, Springfield, Illinois.

A 30

- day public comment period was also available to receive comments on the
Maintenance Plan. A summary of the comments received and Illinois EPA’s responses thereto is included as part of the submittal to U.S. EPA.

6.4 Legal Authority to Implement and Enforce

The Maintenance Plan must contain a demonstration that the State of Illinois has the necessary legal authority to implement and enforce the measures relied upo n to attain and maintain the NAAQS. Illinois has the legal authority to implement and enforce the requirements of this SIP submittal pursuant to the Illinois Environmental Protection Act.28

7 .0 CONCLUSIONS

The Chicago nonattainment area has attained the 8

- hour ozone NAAQS established in

1997 and has complied with the applicable provisions of the Clean Air Act required of

moderate ozone nonattainment areas. Illinois has submitted an attainment demonstration that was based on air quality modeling and conta ins enforceable control measures. Illinois has performed an analysis that demonstrates that the Chicago NAA has attained

the 1997 8

- hour ozone NAAQS and believes the air quality improvements are due to permanent and enforceable control measures. Supporti ng documentation is contained

herein.

Illinois has prepared a Maintenance Plan that meets the requirement of the Clean Air Act. This Maintenance Plan provides for the continued attainment of the 1997 8

- hour ozone NAAQS for a period of ten years after U.S . EPA has formally redesignated the area to attainment. This Maintenance Plan provides adequate contingency measures for potential, additional emission reductions in the event that future violations of the 8

- hour ozone NAAQS are observed in the area.

I llinois has prepared a comprehensive emission inventory of the precursors of ozone completed for the ―attainment‖ year 200 8 , and has prepared a projection of the emission inventory to a year at least 10 years following redesignation. These projections ind icate

that emissions levels in the Chicago nonattainment area will continue to remain much lower than emissions from the attainment year 2008 levels, thereby maintaining the ozone NAAQS in future years. Illinois commits to continue to operate an appropriate monitoring network to verify the maintenance of the attainment status once the area has been redesignated. Illinois EPA has the legal authority to implement and enforce all

control measures.

Finally, the Maintenance Pl an includes on

- road motor vehicle emissions budgets for use in transportation conformity determinations to assure that any increases in emissions from this sector do not jeopardize continued attainment of the 8

- hour ozone standard during the ten

- year maint enance period. This Maintenance Plan has been prepared in accordance with the requirements specified in U.S. EPA’s guidance document, and additional guidance received from U.S. EPA staff.29 

## APPENDIX A

Summary of Ambient Air Monitoring Data

( 2006

- 2008 )30 

### Table A.1
2006

- 2008 8

- hour Ozone Design Values for Monitors in the Lake Michigan Region

State of Illinois County AQS Code Site Name Design Value 4th High 2006 4th High 2007 4th High 2008
Cook 170310001 Alsip 76 78 85 66 Cook 170310032 Chicago (SWFP) 74 75 82 67 Cook 170310064 Chicago (U. of Chicago) 70 70 79 63
Cook 170310072 Chicago (Jardine) 67 65 75 63 Cook 170310076 Chicago (ComED) 73 75 80 66 Cook 170311003 Chicago (Taft) 73 77 79 64 Cook 170311601 Lemont 75 70 85 71
Cook 170314002 Cicero 62 60 68 60 Cook 170314007 Des Plaines 66 65 78 57 Cook 170314201 Northbrook 69 68 76 65 Cook 170317002 Evanston 70 72 80 58 DuPage 170436001 Lisle 63 62 72 57
Kane 170890005 Elgin 66 62 75 61
Lake 170971002 Waukegan 71 71 81 63
Lake 170971007 Zion 72 68 80 69 McHenry 171110001 Cary 65 57 74 65
Will 171971011 Braidwood 66 68 71 60

State of Indiana County AQS Code Site Name Design Value 4th High 2006 4th High 2007 4th High 2008
Elkhart 180390007 Bristol 72 67 82 68
Lake 180890022 Gary 73 73 85 62
Lake 180890030 Whiting 77 81 88 62
Lake 180892008 Hammond 73 75 77 68
La Porte 180910005 Michigan City 69 75 73 59
La Porte 180910010 La Porte 70 69 78 65
Porter 181270026 Valparaiso 70 71 80 61 St. Joseph 181410010 Potato Creek St Park 69 69 75 63 St. Joseph 18141001 5 South Bend 6 1 58 67 58 St. Joseph 181411007 Granger 73 70 82 6931

State of Michigan County AQS Code Site Name Design Value 4th High 2006 4th High 2007 4th High 2008 Allegan 260050003 Holland 86 91 94 73
Benzie 260190003 Frankfort/Benzonia 76 80 82 66
Berrien 260210014 Coloma 78 76 86 73 Cass 260270003 Cassopolis 75 73 83 71
Kalamazoo 260770008 Kalamazoo 73 68 81 70
Kent 260810020 Grand Rapids 77 82 84 66
Kent 260810022 Evans/Oakfield 78 81 85 69
Leelanau 260890001 Peshawbestown 71 73 79 62
Ma nistee 2610 1 0 922 Manistee 77 83 83 6 5
Mason 261050007 Scottville 75 76 83 68
Missaukee 261130001 Houghton Lake 71 73 76 66 Muskegon 261210039 Muskegon 82 90 86 72 Ottawa 261390005 Jenison 79 83 88 67 Schoolcraft 261530001 Seney 75 76 85 64

State of Wisconsin County AQS Code Site Name Design Value 4th High 2006 4th High 2007 4th High 2008
Brown 550090026 Green Bay 70 66 82 63
Door 550290004 Newport Beach 80 79 92 69
Kenosha 550590019 Chiwaukee 78 79 85 72
Kewaunee 550610002 Kewaunee 75 77 85 65
Manitowoc 550710007 Manitowoc (Two Rivers) 7 5 78 85 6 4
Milwaukee 550790010 Milwaukee (16th St.) 63 64 67 60
Milwaukee 550790026 DNR SE Region 68 68 75 63
Milwaukee 550790041 Milwaukee (UWM

- North) 72 73 78 65
Milwaukee 550790085 Milwaukee (Bayside) 75 73 83 69 Ozaukee 550890008 Grafton 72 71 82 64 Ozaukee 550890009 Harrington Beach 74 72 84 67
Racine 551010017 Racine 71 71 77 65 Sheboygan 551170006 Sheboygan 82 83 88 75
Walworth 551270005 Lake Geneva 70 72 75 64 Washington 551310009 Slinger 65 66 71 60
Waukesha 551330027 Waukesha 66 67 72 6032 

## APPENDIX B

Chicago 8

- Hour Ozone Maintenance Plan Transportation Conformity Motor Vehicle Emissions Budget Documentation33 TRANSPORTATION CONFORMITY

This section describes the development of the Chicago nonattainment area motor vehicle emissions budgets associated with the revised Maintenance Plan for the 1997 8

- hour NAAQS. Average summer weekday motor vehicle emissions budget s are being proposed for the attainment year

, 2008

, and for the Maintenance Plan end year 202 5 for

the ozone precursor pollutants volatile organic material ( VOM ) and oxides of nitrogen ( NOx ) . These budgets were developed consistent with the motor ve hicle activity assumptions and emissions control strategies incorporated into the Chicago 8

- hour ozone

A ttainment D emonstration analysis. The enclosed budgets were developed using the inventory method of the United States Environmental Protection Agency ’s (U.S.EPA) MOVES2010 (MOVES) model. The MOVES model incorporates local inputs such as annual vehicle miles of travel, vehicle fleet characteristics, meteorological conditions and vehicle and fuel emission control programs.

Background

Section 176(c)(4) o f the Clean Air Act Amendments of 1990 requires that transportation plans, programs, and projects which are funded or approved under Title 23 of the United States Code (USC) must be determined to conform with State or Federal air implementation plans. A m otor vehicle emissions budget is that portion of the total allowable emissions allocated to highway and transit vehicle use that are defined in the implementation plan for a certain year. Section 93.101 of the rule defines a ―control strategy [State] impl ementation plan revision‖ as a ―plan which contains specific strategies for controlling the emissions and reducing ambient levels of pollutants in order to satisfy Clean Air Act (CAA) requirements of reasonable further progress and
attainment.‖ In order t o demonstrate conformity to the motor vehicle emissions budget, emissions from the implementation of a transportation plan or a transportation improvement program (TIP) must be less than or equal to the budget level (40 CFR § 93.118(a)).

Transportation co nformity will be determined based on these proposed on

- road motor vehicle emissions budgets after the U.S. Environmental Protection Agency (U.S. EPA) determines that the budgets meet the adequacy criteria of the transportation conformity rule under §93.118 (e). The motor vehicle emissions budgets in this submittal are adequate as each of the six criteria under §93.118(e) is satisfied. These six criteria

include:

1. The submitted control strategy implementation plan revision or M aintenance P lan

was endorsed by the Governor (or his or her designee) and was subject to a State public hearing.

2. Before the control strategy implementation plan or M aintenance P lan was submitted to U.S. EPA, consultation among federal, State, and local agencies occurred; full impleme ntation plan documentation was provided to U.S. EPA; and U.S. EPA’s stated concerns, if any, were addressed;34

3. The motor vehicle emissions budgets(s) is clearly identified and precisely quantified;

4. The motor vehicle emissions budget(s), when considered together with all other

emissions sources, is consistent with all applicable requirements for reasonable further progress, attainment, or maintenance (whichever is relevant to the given implementation plan submission);

5. The motor vehicle emissions budget(s ) is consistent with and clearly related to the emissions inventory and the control measures in the submitted control strategy implementation plan revision or M aintenance P lan, and

6. Revisions to previously submitted control strategy implementation plans ex plain and document any changes to previously submitted budgets and control measures, impacts on point and area source emissions; any changes to established safety margins; and reasons for the changes (including the basis for any changes related to

emission s factors or estimates of vehicle miles traveled).

This State Implementation Plan (SIP) and the associated motor vehicle emissions budgets have been developed by the Illinois Environmental Protection Agency (Illinois EPA), the designated air quality agenc y for the State of Illinois. The required public hearing to accept public comment on the proposed Maintenance Plan and associated motor vehicle emissions inventory was held on December 16, 2008 in Room 9

- 031 of the James R. Thompson Center in downtown Chi cago. Notification of this hearing was printed in the Chicago Sun Times on November 15, 2008 . Comments on the proposed attainment demonstration and motor vehicle emissions budgets were accepted for 30 days after the public hearing. A ―Responsiveness Su mmary‖ which addresses the written comments

received was prepared and is included in the final submission

.

Regarding this revision to the Chicago 8

- Hour Ozone Maintenance Plan, notice of a

comment 30

- day comment period was posted on the Illinois EPA’s w ebsite and printed in the Chicago Sun Times on July 8, 2011. A public hearing to discuss the revised Maintenance Plan and associated motor vehicle emissions budgets was to be held on August 18, 2011, if it was requested. Comments were required to be post marked by August 8, 2011, unless a public hearing was requested. No request for a public hearing was received. All comments were addressed in the attached Responsiveness Summary. None of the comments affected the proposed motor vehicle emissions budgets

.

In compliance with criterion #2 above

, a Tier 2 Conformity Consultation Team meeting was held on January 30, 2009 to discuss the proposed Maintenance Plan and associated motor vehicle emissions budgets. The Consultation Team includes representatives from the Federal Highway Administration, Fe deral Transit Authority, U.S. EPA, Chicago Metropolitan Agency for Planning (CMAP) , Illinois Department of Transportation (IDOT), Regional Transportation Authority, and the Illinois EPA. In addition, the development of the Maintenance Plan was discussed at length by the LADCO Project Team, which includes a representative from the U.S. EPA Region V office. The draft35

Maintenance Plan was also forwarded to the Region V representative for his review and

comment. A follow

- up meeting of the Tier 2 Conformity Consultation Team to discuss

the revised MOVES

- based motor vehicle emissions budgets w as held at the CMAP on June 28, 2011.

The motor vehicle emissions budgets propose d and described herein were , in compliance with adequacy criterion #5, developed consist ent with the methodology and control strategy assumptions used in the Chicago 1997 8

- hour O zone A ttainment D emonstration

a nd associated Reasonable Further Progress ( RFP ) plan. The effects of these controls are incorporated into the emissions estimates produced by the MO VES model. In response to adequacy criteria #4 and #6, the narrative of the Chicago 8

- hour Ozone Maintenance Plan discusses the emissions estimates from other sectors and any changes in regulations. Following , in response to adequacy c riteria #3, is a discussion of the inputs and assumptions incorporated into the development of the proposed Maintenance Plan motor vehicle emissions budgets.

Vehicle Miles Travelle d : The attainment year 2008 motor vehicle emissions estimates

contained C hicago 8

- hour ozone Maintenance Plan incorporate county

- and township

level 2008 annual vehicle miles traveled (VMT) levels from the Illinois Department of Transportation (IDOT). The 2008 annual VMT total for the 6

- county

- 3

- township Chicago NAA was approxi mately 58.8 billion miles. For future year emission estimates, VMT was grown to the target year at a compound growth rate of 1.5% per year. Applying this growth factor to the 2008 VMT level yields future year annual VMT projections of 65.2 billion for 20 15, 70.3 billion for 2020, and 75.7 billion for 2025.

Meteorological Data: U.S. EPA guidance for the use of the MOVES model requires the use of representative local temperature and absolute humidity data. Average 2008 maximum and minimum monthly temperatures for the region were obtained from the National Weather Service local climatological data (LCD) for O’Hare International Airport. Absolute humidities correspond ing to the average temperatures were calculated

from LCD information as well. These 2008 temperatures and absolute humidity values, shown below, were used in the year 2025 emissions modeling.

Motor Vehicle Emissions Controls: Beyond the U.S. EPA’s f ederal motor vehicle36

control program emissions standards, the primary local motor vehicle emissions control programs that were in place in the Chicago NAA in 2008, and are projected to still be required in 2025 are a vehicle inspection and maintenance (I/M ) program and the required use of reformulated gasoline (RFG).

Inspection and Maintenance (I/M): The Illinois I/M program in effect since 2007 requires biennial On

- Board Diagnostics II (OBD) testing on all model year (MY) 1996 and newer (MY96+) light

- du ty gasoline vehicles (cars and light

- duty trucks)
, and biennial exhaust idle and gas cap testing on MY96+ heavy duty gasoline vehicles including gasoline

- powered buses, registered in the I/M testable area. Motorcycles and diesel vehicles are not subject t o I/M. The program includes a 4

- year grace period for new vehicles. This post

- 2007 I/M program was established when the Illinois legislature amended the Illinois Vehicle Inspection law in 2005 to (a) end dynamometer testing of vehicles, (b) require an OB D

- based program beginning in February 2007, and (c) remove the requirement for testing compliant pre

- MY96 vehicles.

The Chicago I/M program vehicle testing domain includes the urbanized areas in the Chicago NAA. An ―I/M Coverage‖ percentage was devel oped based on the amount of VMT from vehicles subject to the inspection program compared to total area VMT. The I/M Coverage percentage for the Chicago 8

- hour ozone NAA is 91.5%.

Fuels: The use of federal RFG has been required in the Chicago NAA sin ce 1995. The 8

- hour ozone Attainment Demonstration and original Maintenance Plan assumed the use of northern grade RFG in 2008 and beyond. RFG was and is assumed to
contain 10% ethanol. The MO VES model can account for other fuels, such as E85, natural g as, methanol, etc, but for all practical purposes the gallons of such alternative fuels and hence the number of vehicles using them is very small compared to the number of gasoline and diesel vehicles, therefore, the use of such fuels was not considered.

Gasoline Sulfur: The federal Tier 2 regulations require gasoline sulfur levels to average no greater than 30 parts per million (ppm) with a maximum of 80 ppm beginning in 2007. There are no Illinois gasoline sulfur requirements, therefore,

the MOVES defa ult gasoline sulfur levels were used in the emissions modeling.

Diesel Sulfur: The federal Tier 2 regulations limit the level of sulfur in diesel fuel requiring on

- highway diesel fuel to 15 ppm beginning in 2006. There are no Illinois diesel sulfur requirements, therefore, the MOVES default diesel sulfur

levels were used in the e missions modeling.

Fuel Volatility: The volatility of summer RFG, measured as Reid vapor pressure (RVP), is not specifically regulated. However, a fuels’ RVP is one of the primary characteristics controlled by refiners in order to meet the RFG perform ance standards. The MOVES model contains default RVP levels for different seasons of the year based on fuel compliance testing. Therefore, the MOVES default RVP levels were used in the emissions modeling.37

Vehicle Registration Distribution: A Chicag o area

- specific vehicle registration distribution (RD) profile based upon 2008 information data was developed by Illinois EPA’s Division of Mobile Source Programs from vehicle age data for 2008 provided by the Illinois Secretary of State’s Department of Motor Vehicles. The RD is the fraction of vehicles of a given vehicle type and age in the fleet of vehicles of that type as a whole. Different vehicle types have different RDs Chicago

- area RDs general ly show fewer older vehicles than the nationwide average or default, because vehicles in the Chicago area tend to wear out faster than they do in the rest of the country due to rust from road salt and heavy city driving.

Source Type Population represent s the number of vehicles of each MOVES vehicle type

in the fleet as a whole within the area under consideration. Accurate local source

- type populations we re not available; therefore the MOVES default fractions modified by VMTs by vehicle type were used.

VMT Temporal Fractions are the VMT fractions of annual VMT by month of the year, of weekly VMT by day of the week, and daily VMT by hour of the day. The Illinois EPA uses temporal fractions derived from data collected from continuous count stations and pr esented by IDOT. Temporal fractions vary by road type.

Speed distributions are the fractions of VMT on a given road type by given vehicle types in various speed ranges (bins). Thus, on a typical Urban Arterial, a small fraction

of the vehicles are trave ling at less than 10 mph (plus or minus 5 mph), more at 20 mph, more at 30mph, most at 40 mph, less at 50 mph, and so on. These fractions differ by hour of the day

— in more congested conditions during rush hours, the maximum fraction might be in the 30 mph range rather than the 40 mph range. MOVES uses speed distributions when aggregating emissions (or emission rates) for vehicles at different speeds. The Illinois EPA used the speed distributions derived from the CMAP transportation demand model.

Ramp fr action is the fraction of total VMT on limited

- access highways such as

Interstates that is from on

- and off

- ramps to or from those highways. Driving on limited

access highways is more or less at uniform speed, but driving on ramps involves

considerable ac celeration and deceleration; and these speed changes affect emissions. The default MOVES Ramp Fractions are 15% on Rural Interstates, 10% on Urban Interstates, and 2% on Other Freeways and Expressways. Illinois does not have actual or observed Ramp Frac tion data; therefore the MOVES default values were used.

Road Type Distribution is the (fraction of) VMT on different road categories within an

area under consideration. The Illinois EPA uses VMT data by HPMS functional class (FC) published by IDOT as th e basis of its emission calculations. The Road Type Distribution for Rural Interstates in a county is the county’s Rural Interstate VMT divided by the county’s total all

- road

- type VMT. Similar calculations can be made for MOVES road types and vehicle typ es.38

Safety Margin The U.S. EPA’s transportation conformity regulations allow for the use of a safety margin in the development of motor vehicle emissions budgets for Maintenance Plans. A Safety Margin is defined as ―the amount by which the total projected emissions from al l sources of a given pollutant are less than the total emissions that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance.‖

According to table 4.6, VOM and NOx emissions for the end of the maintenance pla n year 2025 are 175.60 and 469.65 tons per day, respectively, less than the year 2008 attainment year levels. As year 2025 emissions levels are projected to be substantially less than the attainment year 2008 emissions, a 15% safety margin is being propos ed to be added to the 2025 estimated motor vehicle emissions to make up the motor vehicle emissions budget. The 15% increase would equate to an increase of 6.28 tpd of VOM and 16.34 tpd of NOx.

Motor Vehicle Emissions Budgets Using the emissions generated by the MOVES model inventory methodology and incorporating the additional emissions from the Maintenance Plan safety margin, following are the proposed attainment y ear 2008 and Maintenance Plan end y ear 202 5 Chicago 8

- hour ozone motor v ehicle emissions budgets for use in determining transportation conformity.

Proposed Chicago 8

- hour Ozone Maintenance Plan

2008 and 202 5 Motor Vehicle Emissions Budgets (tons per ozone season weekday)

Estimated Emissions Safety Margin Motor Vehicle Emissions Budgets

Year VOM NOx VOM NOx VOM NOx

2008 1 17

. 23 373.52

- - - - 1 17

. 23 373.52

202 5 41.85 108.93 6.28 16.34 48.13 125.27

### Law Office of Robert Ukeiley

435R Chestnut Street, Suite 1

0 Berea, Kentucky 40403

0 teI.859-986-5402

0 fax.866-618-1017

Robert Ukeiley rukeiley@igc.org

Darin Schroeder darin@airadvocafes.net



### VIA NEXT DAY MAIL

- RETURN RECEIPT REQUESTED

August 8, 2011

Dean Studer, Hearing Officer
Illinois EPA
1021 North Grand Avenue, East P,O. Box 19276 Springfield, Illinois 62794-9276 telephone number: 217/558-8280

RE: Comments on State Implementation Plan (SIP) Submittals for the Chicago and Metro-East Ozone Nonattainment Areas and the Chicago PM2.5 Nonattainment Area

Dear Hearing Officer Studer:

On behalf of my client, Sierra Club, and their thousands of members who are adversely impacted from air pollution from the Chicago and Metro-East
Nonattainment areas, I am writing to submit comments on Illinois EPA's draft
Maintenance Plans for the Chicago and Metro-East Nonattainment Areas for the
1997 ozone National Ambient Air Quality Standard (NAAQS) and the Chicago
Nonattainment Area for the 1997 particulate matter less than 2.5 microns (PM2.5) NAAQS. We appreciate the opportunity to comment on these Plans to make sure they are as strong as possible as ozone and PM2.5 have a variety of very serious
adverse impacts including triggering asthma attacks and causing premature mortality.

I. INTRODUCTION

The Illinois Environmental Protection Agency lIEPA) is holding a public

comment period on three maintenance plans: (1) The Metro-East Plan for the 1997

ozone NAAQS, (2) the Chicago Plan for the 1997 ozone NAAQS and; (3) the ChicagoHearing Officer Studer August 8, 2011 Page 2



### Plan for the 1997 PM2.5 NAAQS. These maintenance plans are a required part of
IEPA's attempt to have these nonattainment areas re-designated to attainment.
42 U.s.c. § 

### 7407(d)(3)(E)(iv).

There are several flaws in these maintenance plans which are described
below. The most serious is that the Chicago and Metro-East SIPs may not be currently adequate to maintain compliance with the ozone NAAQS.

IEPA should remedy these flaws in order to better protect the public from the harmful effects of PM2.5 and ozone. PM2.5 is "produced chiefly by
combustion processes and by atmospheric reactions of various gaseous pollutants," thus "[ s]ources of fine particles include

... motor vehicles, power generation, combustion sources at industrial facilities, and residential fuel burning." 71 Fed. Reg. 61,144, 61,146 (Oct. 17,2006). The effects of
PM2.5 on humans are profound. For example, short-term exposure to PM2.5
is associated with "premature mortality, hospital admissions or emergency department visits for respiratory disease, and effects on lung function and symptoms." 71 Fed. Reg. 2619,2627 Uan. 17,2006). Furthermore, PM2.5 adversely affects our natural surroundings. Regional haze is caused in part by particulates in the air scattering sunlight. EPA, Haze- How Air Pollution Affects the View (available at http://www.epa.gov/ttn/oarpg/tl/fr notices/haze.pdf).

Ozone, often referred to as smog, has numerous harmful effects on human respiratory systems which include inducing asthma attacks and aggravating chronic lung diseases like emphysema and bronchitis. EPA, Smog-Who Does it Hurt?, 2-3 (available at http://www.epa.gov/air/ozonepollution/pdfs/smog.pdf). Long-term exposure may result in the permanent scarring of lung tissue. EPA, Ozone and Your Health, U.S. Environmental Protection Agency (available at http://www.epa.gov/air/ozonepollution/pdfs/health.pdf). Ozone can be particularly harmful to adolescents, as exposure to ozone can also lead to "chronic, adverse effects on lung development in children from the age of 10

to 18 years

.... " See 

### Gauderman, W. James, et aI., The Effect of Air Pollution

on Lung Development from 10 to 

### 18 Years of Age, 

### N. Engl. J. Med. 351:11, at 1057 (Sept. 9, 2004). However, the greatest harm "may occur later in life,
since reduced lung function is a strong risk factor for complications and
death during adulthood." 

### lei. at 1063.

II. ANALYSIS

A. 

### CHICAGO OZONE MAINTENANCE PLAN

The most fundamental flaw with the Chicago ozone maintenance plan
is that it may not be adequate to maintain the NAAQS. According to the USHearing Officer Studer August 8, 2011 Page 3



### EPA, for the 2008-2010 period: "One or more sites in this area has violated
the NAAQS prior to 2008-2010 and does not have a valid 2008-2010 design
value." Ex. 1 at ftnt 4. Thus, IEPA cannot prove that its current SIP is maintaining the 1997 ozone NAAQS in the Chicago nonattainment area. Therefore, IEPA cannot say that the current SIP will maintain the NAAQS in
the future.

In addition, Clean Air Act Section 110(1) prohibits the US EPA for approving any SIP revision that may interfere with another NAAQS. 42 U.S.c.

§ 

### 7410(1). However, IEPA has presented no analysis at all to establish that re-designating Chicago from nonattainment to attainment and the implementing the maintenance plan will not interfere with the 2008 ozone NAAQS of 75 ppb or the 2010 I-hour nitrogen dioxide NAAQS. Without this analysis, US EPA will not be able to approve these proposed SIP changes. According to IEPA, several monitors in the Chicago nonattainment area monitored violations in 2006-2008 of the 2008 75 ppb NAAQS. 

### See Chicago
Maintenance Plan at 12. Thus, the Clean Air Act 110(1) analysis is even more critical.

IEPA claims that the 2006-2008 ozone design value was the result of permanent and enforceable emission limits. Maintenance Plan for the Illinois
Portion of the Chicago Ozone Nonattainment Area for the 1997 8-Hour Ozone Standard (Revised) ("Chicago Ozone Maintenance Plan") at 5. This

statement is not correct. Much of the emission reductions that influenced
the 2006-2008 design value were from the NOx SIP Call and later reductions

were from the Clean Air Interstate Rule (CAIR). 

### See Chicago Ozone
Maintenance Plan at 15, 19. Emissions reductions from the NOx SIP Call and CAIR are not permanent and enforceable because the NOx SIP Call and CAIR

are cap and trade programs which means sources can decrease and increase
their emissions on a yearly basis and because the NOx SIP Call is no longer in place and CAIR has been vacated by the US Court of Appeals for the U.S. Court of Appeals for the District of Columbia Circuit. IEPA presents no analysis of whether emission reductions from the Cross State Air Pollution
Rule will have the same effect on ambient ozone levels as the NOx SIP Call
and CAIR. In addition, the Cross State Air Pollution Rule also allows some trading so its emission reductions cannot be considered permanent.

Another flaw is that IEPA's future emission projections fails to consider US EPA's recent announcement that it is repealing the vapor capture requirements for gas stations. US EPA has been clear that this will increase
emissions because not all cars have on-board capture systems.

IEPA's projection of future emissions are based on an unsupported claim that
on-road NOx will decrease dramatically. This ignores the reality that vehicle
standards allow larger vehicles to emit more NOx in terms of mass emissions.Hearing Officer Studer August 8, 2011 Page 4



### Thus, IEPA's reliance on vehicle turnover is not supported by evidence which justifies the claimed reduction in mass NOx emissions. Furthermore, IEPA's
emission calculations from on-road mobile sources fail to consider US EPA's recent decision to allow 15% ethanol in all gas. See 

### Chicago Ozone Maintenance Plan at
36. This increased use of ethanol at levels for which many cars and light trucks,
and particularly their pollution control devices, were not designed to deal with will
increase NOx and VOC emissions. IEPA does not account for this increase.

IEPA acknowledges that ambient monitoring data must be available to the pUblic. US EPA no longer makes ambient monitoring data available to the public on its web page. IEPA claim to the contrary on page 13 is simply

no longer true. See http://www.epa.gov/air/data/monvals.html?st-IL-lilinois (no data after 2008).

The Chicago Ozone Maintenance Plan also fails to consider climate change. "A maintenance plan must take into account the sort of things, such

as population growth and changes to the industrial base, that might cause existing pollution-control measures to become inadequate in the future even if they served well in the past." Sierra Club v. EPA, 

### 375 F.3d 537 (7'h 

### cir. 2004). Climate change is just the sort of thing that might cause existing pollution-control measures to become inadequate in the future even if they
served well in the past.

US EPA has admitted that weather influences ozone formation. See 72 

### Fed. Reg. 44781; 72 Fed. Reg. 44778, 44779. Climate change, which we are indisputably experiencing, means that weather patterns in the future are going to be more conducive to ozone formation than weather patterns in the past. US EPA is well aware of this issue. US EPA has recently stated:

The report, "Assessment of the Impacts of Global Change on Regional
U.s. Air Quality: A Synthesis of Climate Change Impacts on GroundLevel Ozone," concludes that there is a potential for climate change to make ozone pollution worse in some regions and that future ozone management decisions may need to account for the possible impacts
of climate change.

EPA News Brief, April 17, 2009, Climate Change Impacts on Regional Air Quality Report Just Released by EPA. The Report is entitled: U.s. EPA.
Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A Synthesis of Climate Change Impacts on Ground-Level Ozone (An Interim Report of the U.S. EPA Global Change Research Program). U.s.
Environmental Protection Agency, Washington, DC, EPA/600/R-07/094F, 2009. This report is available at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=203459 and is incorporated herein by reference.Hearing Officer Studer August 8, 2011 Page 5



### US EPA's Report further found:

These climate-induced increases, averaged over the summer season,

were in the range of approximately 2-8 parts per billion (ppb) for Maximum Daily 8-hour Average 

### 03 concentration, a key metric for regulating U.S. air quality. The climate sensitivity of 

### 03 was greatest for the peak pollution episodes that tend to occur over a number of days each summer, resulting in substantially larger increases for these times than for the overall seasonal average.

Id. 

### at xix.

US EPA went on to find:

A subset of results also suggests that climate change effects 

### on 

### 03

grow continuously over time, with evidence for significant impacts (in
the same direction as described above) emerging as early as the
2020s. For example, the Columbia research group (which simulated only the eastern half of the United States) found significant
summertime 

### 03 increases across broad swathes of the Midwest and Mid-Atlantic by the 2020s, with greater increases by the 2050s and
2080s.

Id. 

### at xxiv (emphasis added).

Also, relevant, EPA stated:

Air quality managers may also need to plan to extend the season over which they monitor 

### 03 concentrations and be prepared to issue air quality alerts earlier in the spring and later into the fall.

Id. 

### at xxv. The proposed Chicago Ozone Maintenance Plan does not propose such an extension of the monitoring season.

Furthermore, an EPA-funded study by Knowlton and colleagues 1


### utilized the Goddard Institute for Space Studies (GISS) Global Climate Model,
in combination with the Penn State/National Center for Atmospheric
Research Mesoscale Model 5, and the Community Multiscale Air Quality (CMAQ) model to simulate climate-induced changes in ozone levels for the

1 Knowlton K. Rosenthal JE. Hogrefe C. Lynn B. Gaffin S. Goldberg R. Rosenzweig. Civerolo K.
Ku J-Y. Kinney PL. 2004. Assessing ozone-related health impacts under a changing climate.
Environ Health Perspect 112:1557-1563. doi:1O.1289/ehp.7163 available via http://dx.doLorg/Hearing Officer Studer August 8, 20 II Page 6



### purposes of conducting a health impact analysis. This study demonstrates
the feasibility of integrating global and regional climate models with
models that are typically used by air quality managers for the purposes of evaluating compliance with air quality standards. IEPA has not done this.

A study of the New York metropolitan region found a 4.5% increase in
summertime ozone-related premature deaths in 2050 relative to the 1990s. 2


### A second study projected increased ozone smog concentrations in suburban
counties downwind of New York City, demonstrating the potential of climate change to spread adverse health 

### effects well beyond the city limits. 3 

### A third study detailed climate change 

### effects on future ozone levels in 50 eastern US cities, projecting a 68% increase in the number of days exceeding the 8-hour


### 03 standard and increases in mortality and respiratory disease hospital
admissions.' The Jacobson 2008 report also directly links increases in carbon
dioxide to increased mortality, hospitalization, asthma and cancer rates. These studies are integral to a meaningful assessment of the impacts of
climate change on ozone. Yet with regard to the Chicago Ozone
Maintenance Plan, there has been no consideration of climate changes impacts on ozone, either as to formation or as to consequences. Failure to consider this important aspect of the problem would lead to an arbitrary result. Therefore, we request that IEPA re-evaluate the
Maintenance Plan in light of the increasing danger climate change will cause from ozone.

IEPA also provides for alternative measures which are not permissible under
the Clean Air Act. The Maintenance Plan states: "Illinois EPA commits to keep
these measures in 

### effect after redesignation, or to provide equivalent emissions
levels using alternate measures." Chicago Ozone Maintenance Plan at 18. However, the Clean Air Act does not allow for alternative measures.

Finally, IEPA states: "The control measures identified in the RFP document, including those listed above, will result in a 15.7 percent reduction in VOM
emissions from 2002 emissions levels by the year 2008." Chicago Ozone
Maintenance Plan at 20. Now that year 2008 has passed, IEPA must prove that
these reductions were actually achieved.

2 Knowlton K. et al (2004).

3 Kinney P, Rosenthal j, Rosenzweig C, Hogrefe C, Solecki W, Knowlton K, Small C, Lynn B,
Civerolo K, Ku j, Goldberg R, Oliveri C. 2006. Assessing potentiai public health impacts of changing climate and land uses: the New York Climate and Health Project. In: Regional Climate Change and Variability: Impacts and Responses (Ruth M, Donaghy K, Kirshen P, eds.). Cheltenham(UK):Edward Elgar, 161-189.

, jacobson (2008). jacobson, MZ. 2008. On the casual link between carbon dioxide and air pollution mortality. Geophysical Research Letters. 3S: L03809.Hearing Officer Studer August 8, 2011 Page 7



### B. METRO-EAST ST. LOUIS OZONE MAINTENANCE PLAN

Like the Chicago Ozone Maintenance Plan, the most fundamental flaw
with the Metro-East ozone maintenance plan is that it may not be adequate

to maintain the NMQS. According to the US EPA, for the 2008-2010 period, "[ olne or more sites in this area has violated the NMQS prior to 2008-2010
and does not have a valid 2008-2010 design value." Ex. 1 at ftnt 4. Thus,
IEPA cannot prove that its current SIP is maintaining the 1997 ozone NMQS
in the Metro-East nonattainment area. Therefore, IEPA cannot say that the

current SIP will maintain the NMQS in the future.

In addition, Clean Air Act Section 110(1) prohibits the US EPA for approving: any SIP revision that may interfere with another NMQS. 42 U.s.c.

§ 

### 7410(1). However, IEPA has presented no analysis at all to establish that re-designating Metro-East from nonattainment to attainment and the
maintenance plan will not interfere with the 2008 ozone NMQS of 75 ppb or the 2010 I-hour nitrogen dioxide NMQS. Without this analysis, US EPA will

not be able to approve these proposed SIP changes. According to IEPA,
several monitors in the Metro-East nonattainment area monitored violations
in 2007-2009 of the 2008 75 ppb NMQS. See 

### Metro-East Ozone
Maintenance Plan at 12. Thus, the Clean Air Act 110(1) analysis is even more critical.

IEPA claims that the 2006-2008 ozone design value was the result of permanent and enforceable emission limits. Metro-East Ozone Maintenance
Plan at 5. This statement is not correct. Much of the emission reductions
that influenced the 2006-2008 design value were from the NOx SIP Call and
later reductions were from the Clean Air Interstate Rule (CAIR). See 

### MetroEast Ozone Maintenance Plan at 19. Emissions reductions from the NOx SIP Call and CAIR are not permanent and enforceable because the NOx SIP Call
and CAIR are cap and trade programs which means sources can decrease
and increase their emissions on a yearly basis and because the NOx SIP Call
is no longer in place and CAIR has been vacated by the US Court of Appeals
for the DC Circuit. IEPA presents no analysis of whether emission reductions from the Cross State Air Pollution Rule will have the same effect. In addition,
this new rule also allows some trading so its emission reductions cannot be
considered permanent.

IEPA's emission projections appear to be inaccurate. There is no indication that the emission projections considered emissions from Prairie State Generating Station which should be in operation, and thus pOlluting, prior to 2015.

The Metro-East Ozone Maintenance Plan suffers from many of the
defects described above in Section II.A regarding the Chicago OzoneHearing Officer Studer August 8, 2011 Page 8



### Maintenance Plan. These include: (1) failing to consider increased emissions
from US EPA's repealing the vapor capture requirements for gas stations and allowing up to 15% ethanol in gasoline; (2) assuming that vehicle turn over will reduce mass on-road emissions even though purchasing larger new vehicles can offset this; (3) failing to make ambient monitoring data
available to the public; (4) failing to consider climate change impacts on future ambient ozone levels; (5) relying on unidentified alternate measures with no legal authority to do so. We will not repeat the detailed explanation of these flaws provided above but for the reasons provided above IEPA must fix these defects.

C. 

### CHICAGO PM2.5 MAINTENANCE PLAN

Similar to the ozone maintenance plans, IEPA claims that the Chicago
2007-2009 PM2.5 design value was the result of permanent and enforceable
emission limits. Maintenance Plan for the Chicago Nonattainment Area for
the 1997 PM2.5 National Ambient Air Quality Standard (Revised) ("Chicago
PM2.5 Maintenance Plan") at 5. This statement is not correct. Much of the
emission reductions that influenced the 2007-2009 design value were from
the NOx SIP Call and later reductions were from the Clean Air Interstate Rule (CAIR). See 

### Chicago PM2.5 Maintenance Plan at 15. Emissions reductions
from the NOx SIP Call and CAIR are not permanent and enforceable because
the NOx SIP Call and CAIR are cap and trade programs which means sources

can decrease and increase their emissions on a yearly basis and because the NOx SIP Call is no longer in place and CAIR has been vacated by the US Court
of Appeals for the DC Circuit. IEPA presents no analysis of whether emission
reductions from the Cross State Air Pollution Rule will have the same effect.
In addition, this new rule also allows some trading so its emission reductions

cannot be considered permanent.

The Chicago PM2.5 Maintenance Plan also suffers from many of the
defects described above in Section II.A regarding the Chicago Ozone
Maintenance Plan. These include: (1) failing to consider increased emissions
from US EPA's repealing the vapor capture requirements for gas stations and allowing up to 15% ethanol in gasoline; (2) assuming that vehicle turn over will reduce mass on-road emissions even though purchasing larger new vehicles can offset this; and (3) failing to make ambient monitoring data
available to the public. We will not repeat the detailed explanation of these flaws provided above but for the reasons provided above IEPA must fix these
defects.

III. CONCLUSION

It is imperative from a public health and welfare point of view that IEPA

correct the above flaws in its maintenance plans. If you have any questionsHearing Officer Studer August 8, 2011 Page 9



### about these comments, please do not hesitate to contact me. Otherwise, we look forward to IEPA improving its maintenance plans to ensure the health
and welfare of millions of Illinois inhabitants.

Sincerely,

Robert Ukeiley Counsel for Sierra Club, 

# .



# EXHIBIT 1Table1

Table 1. Design Values in Areas Previously Designated Nonattainment for the 1997 8-Hour Ozone NAAQS AQS Data Query: 6/27/2011 Last Updated: 7/12/2011

2008-2010 8·

Hour Ozone Clean Data EPA Designation Design Value Determination Redesignation Designated Area Region(s) Status' Classilication'**(ppm)'~** MetNAAQS? Date Date Albany.Schenectady-Troy, NY 02 Nonattainment Former Subpart 1 0.072 Ves 3/2512008 Allegan Co, MI OS Maintenance Former Subpart I 0.074 Ves 9/2512010 9/2412010 Allentown-Bethlehem-Easton, PA 03 Maintenance Fonner Subpart 1 0.076 Ves 3/4/2008 Altoona, PA 03 Maintenance Former Subpart 1 0.070 Ves 8/1/2007 Amador & Calaveras Cos (Central Mtn), CA 09 Nonattainment Former Subpart 1 0,083 Ves Atlanta, GA 04 Nonattainment Subpart 2IModerate 0.080 see footnote 4 Baltimore. MD 03 Nonanainment Subpart 2/Moderate 0.089 No Baton Rouge, LA 06 Nonattainment Subpart 2/Moderate 0.078 Ves 10112/2010 Beaumont-Port Arthur, TX 06 Maintenance Subpart 2/Moderate 0.074 Ves 10120/2010 Benton Harbor, MI 05 Maintenance Former Subpart I 0.071 Ves 511 6/2007 Benzie Co, MJ 05 Maintenance Former Subpart I 0.069 Ves 5/1612007 Berkeley & Jefferson Cos. WV 03 ' Attainment Fonner EAC 0.070 Ves Birmingham, AL 04 Maintenance Former Subpart 1 0.075 Ves 5/12/2006 Boston-Lawrence-Worcester (E. Mass), MA 01 Nonattainment Subpart 2/Moderate 0.075 Ves 4/18/2011 Boston-Manchester-Portsmouth (SE), NH 01 Nonattainment Subpart 2/Moderate 0.069 Ves Buffalo-Niagara Falls, NY 02 Nonanainment Former Subpart } 0.071 Ves 1/612010 Canton-Massillon, OH OS Maintenance Fonner Subpart I 0.073 see footnote 4 5/16/2007 CassCo, MI 05 Maintenance Subpart 2/Marginal 0.070 Ves 5/16/2007 Charleston, WV 03 Maintenance Fonner Subpart I 0.069 Ves 7/1112006 Charlone-Gastonia-Rock Hill, NC-SC 04 Nonattainment Subpart 2/Moderate 0.082 Ves Chattanooga, TN-GA 04 Attainment Former EAC 0.075 Ves Chicago-Gary-Lake County, IL-IN 05 Nonattainment Subpart 2/Moderate 0.074 see footnote 4 4/1212010 Chico,CA 09 Nonattainment Former Subpart 1 0.079 Ves Cincinnati-Hamilton, OH·K Y -IN 05,04 Maintenance Fonner Subpart I 0.079 Ves 5/11/2010 5/11/2010 Clarkesville-Hopkinsville, TN-KY 04 Maintenance Fonner Subpart 1 0.069 Ves 1125/2006 Clearfield & Indiana Cos, PA 03 Maintenance Former Subpart 1 0.074 Ves 3/1912009 Cleveland-Akron-Lorain, OH OS Maintenance Subpart 2/Moderate 0.077 Ves 9/15/2009 9/1512009 Columbia, SC 04 Attainment FonnerEAC 0.070 Ves Columbus, OH 05 Maintenance Former Subpart I 0.077 Ves 9/1512009 9/1512009 Dallas-Fort Worth, TX 06 Nonattainment Subpart 2/Serious 0.086 No Dayton-Springfield, OH 05 Maintenance Former Subpart 1 0.075 see footnote 4 8/1312007 Denver-Boulder-Greeley-Ft Collins-Loveland, CO 08 Nonattainment Former Subpart 1 0.077 Ves Detroit-Ann Arbor, Ml 05 Maintenance Subpart 2iMarginal 0.075 Ves 6/29/2009 6/29/2009 Door Co, WI OS Maintenance Fonner Subpart I 0.073 Ves 7/1212010 7/1212010 Erie, PA 03 Maintenance Former Subpart I 0.072 Ves 10/912007 Essex Co (Whiteface Mtn), NY 02 Nonattainment Former Subpart 1 0.072 see footnote 4 1/612010 Evansville, IN OS Maintenance Fonner Subpart 1 0.070 Ves 12129/2005 Fayetteville, NC 04 Attainment FormerEAC 0.071 Ves

Page 1Table1

Flint, Ml 05 Maintenance Fonner Subpart I 0.068 Yes 511612007 Fort Wayne, IN 05 Maintenance Former Subpart I 0.067 Yes 1/1112007 Franklin Co, PA 03 Maintenance Fonner Subpart I 0.067 Yes 712512007 Frederick Co, VA 03 Attainment Former EAC 0.068 Yes Fredericksburg, VA 03 Maintenance Subpart 2IModerate 0.070 Yes 1212312005 Grand Rapids, MI 05 Maintenance Fonner Subpart I 0.069 Yes 5/1612007 Greater Connecticut. CT 01 Nonattainment Subpart 2IModerate 0.078 see footnote 4 913012010 Greene Co, IN 05 Maintenance Former Subpart 1 0.071 Yes 11/14/2005 Greene Co, PA 03 Maintenance Former Subpart 1 0.072 Yes 311912009 Greensboro-Winston Salem-High Point, NC 04 Attainment Former EAC 0.076 Yes Greenville-Spartanburg-Anderson, SC 04 Attainment Fonner EAC 0.076 Yes Hancock, Knox, Lincoln & Waldo Cos, ME 01 Maintenance Former Subpart J 0.074 Yes 12/1112006 Harrisburg-Lebanon-earlisle, PA 03 Maintenance Former Subpart ) 0.073 Yes 7125/2007 Haywood and Swain Cos (Great Smoky NP), NC 04 Maintenance Former Subpart I 0,072 Yes 121712009 Hickory-Morganton-Lenoir, NC 04 Attainment Former EAC 0.070 Yes Houston-Galveston-Brazoria, TX 06 Nonattainment Subpart 2/Severe 15 0,084 see footnote 4 Huntington-Ashland, WV.K Y 03,04 Maintenance Former Subpart I 0.070 Yes 813/2007 Huron Co, MI 05 Maintenance Former Subpart I 0,067 Yes 5116/2007 Imperial Co, CA 09 Nonattainment Subpart 2IModerate 0.078 Yes 1/412010 Indianapolis, IN 05 Maintenance Fonner Subpart I 0.073 Yes 10/1912007 Jackson Co, IN 05 Maintenance Former Subpart I 0,067 Yes 1111412005 Jamestown, NY 02 Nonattainment Fonner Subpart I 0,077 Yes 1/612010 Jefferson Co, NY 02 Nonattainment Subpart 2IModerate 0,072 Yes 3/25/2008 Johnson City-Kingsport-Bristol, TN 04 Attainment Former EAC 0,071 Yes Johnstown, PA 03 Maintenance Former Subpart 1 0.067 Yes 8/112007 Kalamazoo-Battle Creek, Ml 05 Maintenance Former Subpart 1 0,069 Yes 5/16/2007 Kent & Queen Anne's Cos, MO 03 Maintenance Subpart 2/Marginal 0.075 Yes 12122/2006 Kern Co (Eastern Kern), CA 09 Nonattainment Former SubpaJ11 0.083 Yes Kewaunee Co, WI 05 Maintenance Former Subpart I 0,071 Yes 5121/2008 Knoxville, TN 04 Maintenance Former Subpart 1 0,077 see footnote 4 10/1212010 31812011 La Porte, IN 05 Maintenance Subpart 2/Marginal 0,065 Yes 7/19/2007 Lancaster, PA 03 Maintenance Subpart 2/Marginal 0,077 Yes 7/6/2007 Lansing·East Lansing, MI 05 Maintenance Former Subpart I 0.068 Yes 5/1612007 Las Vegas, NV 09 Nonattainment Fonner Subpart I 0,076 Yes 5/3112011 Lima,OH 05 Maintenance Former Subpart I 0,070 Yes 5/16/2007 Los Angeles South Coast Air Basin, CA 09 Nonattainment Subpart 2IExtreme 0,112 No Los Angeles·San Bernardino Cos (W. Mojave), CA 09 Nonattainment Subpart 21Severe 15 0,099 No Louisville, KY-IN 04,05 Maintenance FOrmer Subpart 1 0.075 Yes 7/19/2007 Macon,GA 04 Maintenance Fonner Subpart 1 0,073 Yes 9/1912007 Madison & Page Cos (Shenandoah NP), VA 03 Maintenance Former Subpart I 0,073 Yes 1/312006 Manitowoc Co, WI 05 Maintenance Former Subpart I 0,073 Yes 7/1212010 7/1212010 Mariposa & Tuolumne Cos (Southern Min), CA 09 Nonattainment Former Subpart I 0.083 Yes MasonCo,MJ 05 Maintenance Fonner Subpart I 0,068 Yes 5/1612007 Memphis, TN-AR 04,06 Maintenance Subpart 2IModerate 0,076 Yes 3/24/2010 Milwaukee·Racine, WI 05 Nonattainment Subpart 2IModerate 0,074 see footnote 4 3/3112011 Muncie, IN 05 Maintenance Fonner Subpart I 0.065 Yes 11/16/2005 Murray Co (Chattahoochee NFl, GA 04 Maintenance Former Subpart I 0,073 Yes 10/1612007

Page 2Table1

Muskegon, MI 05 Maintenance Subpart 2/Marginal 0.074 Ves 5/16/2007 Nashville, TN 04 Attainment FormerEAC 0.076 Ves Nevada Co (Western part), CA 09 Nonattainment Former Subpart I 0.084 Yes New York-No New Jersey-Long Island, NY -NJ-CT 02,01 Nonattainment Subpart 2/Moderate 0.084 see footnote 4 Norfolk-Virginia Beach-Newport News (HR). VA 03 Maintenance Subpart 2/Marginal 0.072 Yes 611/2007 Parkersburg-Marietta. WV-OH 03,05 Maintenance Fonner Subpart I 0.073 Yes 5/1612007 Philadelphia.Wilmington-Allantic CiIy, PA-NJ-MD-DE 03,02 Nonattainment Subpart 2/Moderate 0.083 see footnote 4 Phoenix-Mesa, AZ 09 Nonattainment Former Subpart I 0.077 Ves PittSburgh-Beaver Valley, PA 03 Nonattainment Former Subpart I 0.081 Ves Portland, ME 01 Maintenance Subpart 2/Marginal 0.072 Ves 12/11/2006 Poughkeepsie, NY 02 Nonattainment Subpart 2/Moderate 0.D75 Yes 116/2010 Providence (all ofRI), Rl 01 Nonattainment Subpart 2/Moderate 0.076 Ves 11122/2010 Raleigh-Durham-Chapel Hill, NC 04 Maintenance Fonner Subpart I 0.074 see footnote 4 12126/2007 Reading, PA 03 Maintenance Former Subpart I 0.079 Ves 8/24/2007 Richmond.Petersburg, VA 03 Maintenance Subpart 2/Marginal 0.076 Ves 6/112007 Riverside Co (Coachella Valley), CA 09 Nonattainment Subpart 2/Severe 15 0.095 No Roanoke, VA 03 Attainment Former EAC 0.069 Ves Rochester, NY 02 Nonattainment Former Subpart I 0.069 Ves 3/2512008 Rocky Mount, NC 04 Maintenance Fonner Subpart 1 0.071 Yes 11I6/2006 Sacramento Metro, CA 09 Nonattainment Subpart 2/Severe 15 0.102 No San Antonio, TX 06 Attainment Former EAC 0.D75 Ves San Diego, CA 09 Nonattainment Former Subpart 1 0.088 No San Francisco Bay Area, CA 09 Nonattainment Subpart 2/Marginal 0.080 Ves San Joaquin Valley, CA 09 Nonattainment Subpart 2/Extreme 0.104 No Scranton-Wilkes-Barre, PA 03 Maintenance Former Subpart 1 0.072 Yes 11/1912007 Sheboygan, WI 05 Nonattainment Subpart 2/Moderate 0.D78 see footnote 4 3/31/2011 South Bend-Elkhart, IN 05 Maintenance Fonner Subpart 1 0.064 Ves 7/19/2007 Springfield (W. Mass), MA 01 Nonattainment Subpart 2/Moderate 0.077 see footnote 4 SI. Louis, MO-IL 07,05 Nonattainment Subpart 2/Moderate 0.077 see footnote 4 7111/2011 State College, PA 03 Maintenance Fonner Subpart 1 0.070 Yes 11/1412007 Steubenville-Weirton,OH-WV 05,03 Maintenance Former Subpart 1 0.073 Yes 5/1612007 Sutter Co (Sutter Buttes), CA 09 Nonattainment Former Subpart 1 0.076 Ves Terre Haute. IN 05 Maintenance Former Subpart I 0.063 Yes 1/5/2006 Tioga Co, PA 03 Maintenance Former Subpart I 0.070 Ves 7/612007 Toledo,OH 05 Maintenance Former Subpart 1 0.072 Ves 8/9/2007 Ventura Co, CA 09 Nonattainment Subpart 2/Serious 0.086 No Washington Co (Hagerstown), MD 03 Attainment Former EAC 0.072 Ves Washington, DC·MD·VA 03 Nonattainment Subpart 2/Moderate 0.081 see footnote 4 Wheeling, WV -OH 03,05 Maintenance Former Subpart I 0.073 Ves 511612007 Vork, PA 03 Maintenance Former Subpart I 0.074 Yes 1/14/2008 Youngstown-Warren-Sharon, PA-QH 05,03 Maintenance Former Subpart I 0.074 Yes 10/19/2007

Notes:

1_ Area classification and designation status as of April 27. 2011

Page 3Table1

2. The level of the 1997 8Rhour ozone NAAQS Is 0.08 parts per million (ppm). The design value is the 3-year average of the annual fourth-highest dally

maximum 8 R hour ozone concentration.

3. The design values shown here are computed for the latest design value period using Federal Reference Method or equivalent data reported by State, Tribal, and Local monitoring agencies to EPA's Air Quality System (AQS) as of May 9, 2011. Concentrations flagged by State, Tribal, or Local monitoring agencies as having been affected by an exceptional event (e.g., wildfire, volcanic eruption) and concurred by the associated EPA Regional

Office are not included in these calculations.

4. One or more sites In this area has violated the NAAQS prior to 2008·2010 and does not have a valid 2008·2010 design val ue. Although a 2008·2010 design value Is shown, this design value may not represent the worst 2008-2010 air quality in the area. Consequently, we have not used it to Indicate

''Yes'' or "No" in the "Met NAAQS?" column.

Page 4Please**~cyc/~.** When used**mtematiOlJ\laJ~ a~**  otfStbl'!nS o:fedaraffons (PlS Form 2976/# or 2976A1

USPS**p~(;Raqlng** prodl.;/Gts hWfJ been
awarcied Cradle to**CradleGeftlfic:atlo~** fdrt{Jelt**eC()logica/ly~/fjtelllgent** design

For more lirformation go to mbdc.comlusps

CradJe to Cradle Cartiflad""1s a cartlflcallon marl< 01 M.l300

# [~ I

. SILVER I Addressee Copy

Label 11-B, March 2004

Post Office To Addressee

O WAIVER OF SIGNATURE (Dornestic.Maf/;Qljly)

. ..Additional merchandise insuranclills"old If
customer requests waiver of**signatu,r~** ....•.. l""ish delivery to be made without obtaining signature of addressee or addressee's agent (if delivery employee jUdge" that article can be left In secure location) aT"!d I authorize that delivery employee's signature constitutes
valid proof of delivery. 

# Ftat Rlate 

# Mailing Envelope

For Domestic and In/lemarional Use

Visit us 

### at usps

.. aQm

PHONE (

FOR INTERNATIONAL DESTINATIONS, WRITE COUNTRY NAME BELOW. u) lJ.J Q o u UNITED STIJTES POSTAL SERt/ICE

Place Mailing L.abel Here:



### 11111111111'1

# IIIIIIIIIIIIIII~ 111111111111111 '111111" 1IIIIIIj111

EG643637391US

o 2: S(:

lJ.J 0::: "'C

PHONE (

o a: «
I

UJ OJ W a: 0...USPS.com®

- Track & Confirm Page 1 of 1

C,ZSlomer $e",icI! USPS Mobile Registe. i Sign In



## 6IUSPS.COM"

Quick Tools



### Track & Confirm Ship a Psckage Manage Your Mail ShOp Sus,ness Solutions

OF.T EMi'JL llPn,l,TES

yeUR LA8EL !'lUI.13ER

EG64Jl;37391US PflJl./T OET AiLS**SER~1CE**

Express Mai" ST

.... 11.IS OF YOUR nEM

August 10, 2011, 8:01 am

Notice left (No August 10, 2011, 3:15 am

Authorized Recipient**Ava~abla)** Nolice lefl. (No August09,2011,10:54<VT1

Authorized Roclpien1

Available)

Arrival at Unit August 09, 2011, 10:52 am

Processed through Sort August 08, 2011, 8:59 pm Facility

Processed through Sort August 08, 2011, 5:22 pm Facility

Acceptance August 06. 2011, 3:36 pm SPRINGFIELD. IL 62794

SPRINGFIELD, IL 62794

SPRINGFIELD, IL 62794

SPRINGFIELD, IL 62703

LOUISVILLE, KY 40231

LEXINGTON, KY 40511

BEREA, KY 40403 Guaranteed By:
August 9, 2011. 12:00 PM

Retum Recaipt

PrtlOr of Delivery

Check on Another Rem

Wlat's your label (or receipt) number?

LEGAL

Pli'i3Cj Policy'

f"rms of Use,

FOiA·

No FEAR l'.ctE1:0 D-3tJ ON USPS.COM

Gover"mC''11 :&Irli;;es,
B"y Stil'TIpS;;; Shap

, PH'll,'; L<loc! ",.tit''! Pnsl.(;B€ >**Cu~:('o,er** Service

, Sit" Iri'kx ' Find

ON ABOUT.USPS.COM

About USPS Hom!'! • NiWsrOElm,

M.ail**Se;~;c!)** Updates,

Forms 1), Pub!icaticns

, OTHER USPS SITES

BlJsin"ss Custenler Gatev-my' Posla1lrlspeclors>**In~pector** G"r,.;,ral '

Postal**~.p;oref·**

https://tools.usps.oom/golTrackConfirmAction jnput?qtc _tLabelsl =EG64363 7391 US&qtc... 8/1 0/20 II1 ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

BUREAU OF AIR



### Responsiveness Summary for Public Questions and Comments on the State Implementation Plan Submittal s for the Chicago 8

- Hour Ozone Nonattainment Area
, the Chicago PM 2.5 

### Nonattainment Area , and the

Metro

- East 8

- Hour Ozone Nonattainment Area

September 1 6 , 201123

INTRODUCTION

The Illinois Environmental Protection Agency (Illinois EPA) has prepared Maintenance Plans for the Chicago and Metro

- East ozone nonattainment areas (NAA). The Maintenance Plans are required before the areas can be redesignated from nonattainment to attainment of the 8

- hour ozone National Ambient Air Quality Standard (NAAQS) pr omulgated by the U.S. Environmental Protection Agency (U.S. EPA) in 1997. Similarly, the Illinois EPA has prepared a Maintenance Plan for the Chicago NAA, as required before the areas can be redesignated from nonattainment to attainment of the annual NAAQ S for f i n e p a r t i c u l a t e s ( PM 2.5 ) promulgated by the U.S. EPA in 1997. The Illinois EPA intends to submit requests to the U.S. EPA to redesignate the Chicago NAA to attainment for both ozone and PM 2.5 , and to redesignate the

Metro

- East NAA to attainment for ozone in conjunction with the submittal of these Maintenance

Plans.

Th e Maintenance Plan s provide for the continued attainment of the 1997 ozone NAAQS for the Chicago and Metro

- East NAAs, and for the continued attainment of the annual PM 2.5 NAAQS
for the Chi cago NAA for a period of at least ten years after U.S. EPA has formally redesignated

the area s to attainment. The Plan s also provide assurances that even if a subsequent violation of
the NAAQS occurs, provisions in the Plan will prevent any future occurre nces through the enactment of contingency measures that would be triggered upon such occurrence.

PUBLIC HEARING AND COMMENT PERIOD

On July 8, 2011

, the Illinois EPA had the Notice of Public Comment Period for State Implementation Plan Submittals for the Chicago and Metro

- East o zone NAAs and the Chicago

PM 2.5 NAA published in the Chicago Sun Times and in the Illinois edition of the St. Louis Post Dispatch. Provision was also given in the notice for a public hearing to be held on August 18,

2011

, conditioned on the receipt of a timely request for Public Hearing. Since there were no requests for a public hearing

, the public hearing originally sched uled for August 18, 2011 w as cancelled. The Illinois EP A post ed a notice of Cancellation of the Public Hearing on its website on August 12, 201 1

. As indicated in the Notice of Public Comment, t he public comment period began on July 8, 2011 and closed on August 8, 2011.

COMMENTS AND RESPONSES BY THE ILLINOIS EPA

A commenter suggested that the Chicago ozone maintenance plan may not be adequate to maintain the NAAQS , noting that U

. S

. EPA ’s Air Quality System (AQS) contains the following

footnote for the 2008

- 2010 period for the Chicago NAA: “One or more sites in this area has violated the NAAQS prior to 2008

- 2010 and does not have a valid 2008

- 2010 design value.”

The footnote in the cited AQS report occurs when one or more monitors in the NAA do not

mee t the completeness criteria established by U.S. EPA. For the 2008

- 2010 period, design values are not shown in AQS for two monitoring stations in the Chicago area, prompting the footnote cited by the commenter. The two sites are located at Wacker and Adams4

Streets in downtown Chicago (site ID: 17

- 031

- 0042) and 750 Dundee Road in Northbrook (site ID: 17

- 031

- 4201). The monitor at Wacker and Adams is located on the 90 th floor of the Willis Tower (Sears Tower) and is operated as a special purpose monitor durin g the summer months (typically June, July, and August). As a special purpose monitor, the measurements are not used for the purpose of determining the areas attainment status. At Northbrook, the Illinois EPA has historically operated two instruments to m easur e ozone at the same location. The data from the two instruments are distinguished in AQS by POC (Parameter Occurrence Code) Codes 1 and 2. One of the instruments located at

Northbrook (POC 2) was an experimental open path analyzer that was difficult and expensive to maintain , and routinely reported lower ozone values than the co

- located instrument. The experimental analyzer was discontinued in 2009. The other instrument operated at this location is the Federal Reference Method (FRM) ozone monitor ( POC 1). It has operated normally during 2008

- 2010, meeting U.S. EPA’s completeness criteria, and for which a valid design value for 2008

- 2010 has been calculated. U.S. EPA confirmed the validity and completeness of ozone measurements , and that all monitoring sites in the Chicago nonattainment area have three years of data showing attainment of the 1997 ozone NAAQS by publishing the Clean Data Determination on April 12, 2011.

A commenter pointed out that: “ Clean Air Act (CAA) Section 110( l ) pr ohibit s the U

. S

. EPA from approving any SIP revision that may interfere with another NAAQS. 42 U.S.C. § 7410(I). However, I llinois EPA has presented no analysis at all to establish that re

- designating Chicago from nonattainment to attainment and that implementi ng the maintenance plan will not interfere

with the 2008 ozone NAAQS of 75 ppb or the 2010 1

- hour nitrogen dioxide NAAQS. ”

The Illinois EPA does not agree that a further analysis of the effects of redesignation on another NAAQS is required or that U.S. EP A cannot approve the SIP revision without such analysis. The Illinois EPA has prepared the Chicago ozone M aintenance P lan consistent with U.S. EPA’s published guidance. The document adequately demonstrate s that the 1997 NAAQS for ozone has been attained in the Chicago NAA based on three consecutive years of ambient air monitoring data . The plan contain s emission estimates of the precursors of ozone for the “attainment year” and multiple “projection years” that

demonstrate that the projected level of emissions is sufficient to maintain the NAAQS

. In fact, the emissions projections indicate that ozone precursor emissions will decrease substantially in future years, ensuring continued attainment and maintenance of the NAAQS. The Maintenance P lan provide s commitments to maintain and enforce the control measures that are already in place, to continue monitoring air quality in the NAAs, to prepare periodic updates of the emissions inventories, and to implement contingency

measures , if needed
, to correct future exceedances of the NAAQS. Based on these commitments, there is no basis to conclude that approval of the Maintenance Plan will cause backsliding of the air pollution control programs that have allowed the NAAs to
reach attainment with t he ozone NAAQS. As Illinois’ Maintenance Plan ha s been prepared in accordance with the requirements specified in U.S. EPA’s guidance document and additional guidance received from U.S. EPA staff , the plan is approvable as a SIP revision

.
Further, U.S. E PA has not implement ed the 2008 ozone NAAQS , and has decided not to tighten the standard before 2013

. Should U.S. EPA decide to implement the 2008 ozone5

standard, or to revise it in the future, Illinois is obligated to address the new ozone NAAQS, indepen dent of efforts to redesignate existing NAAs to attainment with the old standard.

With regard to the 2010 NO 2 NAAQS, all ambient monitors in Illinois, including the Chicago area , are meeting the standard and the Illinois EPA has recommended that all counties in Illinois be designated as attainment. U.S. EPA has not yet acted on Illinois’ recommendation. As shown in the Maintenance Plan, NOx emissions (a combination of compounds that includes NO 2 ) are expected to decrease significantly in future years, so
there is no basis to conclude that re
- designating the Chicago NAA from nonattainment to
attainment for the ozone NAAQS, and implementing the o z o n e maintenance plan will
interfere with a t t a i n m e n t o r m a i n t e n a n c e o f the 2010 1

- hour N O 2 NAAQS.

A commenter questioned whether air quality improvements were the result of permanent and

enforceable emission reductions since the NOx SIP Call and CAIR are cap and trade programs

, and because the NOx SIP Call is no longer in place and CAIR has been vacated by the U

. S

. Court of Appeals

.
Illinois EPA agrees that regional emission reductions provided by the NOx SIP Call and CAIR yielded significant air quality improvements, and that these progr ams combined with other emission reduction measures helped the Chicago area to meet the 8

- hour ozone NAAQS. The Illinois EPA does not agree, however, that these measures are not permanent
and enforceable. Illinois submitted
, and U.S. EPA approved
, SIP re visions addressing the requirements of the NOx SIP Call, and
, subsequently
, the CAIR program. Beginning in 2009, the CAIR program maintained the same emissions budgets as the NOx SIP Call program it replaced. In its decision to vacate the CAIR, the U.S C ourt of Appeals determined that the CAIR emissions budgets should remain in place, until U.S. EPA remedied the identified deficiencies. U.S. EPA recently promulgated the C r o s s
- S t a t e A i r P o l l u t i o n R u l e ( C S A P R ) to address the Court’s concerns. Sign i ficantly, the CSAPR

re quires that states meet emissions budgets that are more stringent than CAIR, and provides new requirements that ensure that emission reductions are achieved within each
affected state.

A commenter noted that I llinois EPA’s future emission projections did not consider U

. S

. EPA’s recent announcement that it is repealing the vapor capture requirements for gas stations.

Regarding the Stage II program, on July 15, 2011 the U.S. EPA issued a proposed rule determining that June 30, 2013 will be the date when the “widespread use” of onboard refueling vapor recovery (ORVR)

- equipped vehicles will occur. At this point the U.S. EPA expects “ORVR alone to achieve emissions reductions equal to Stage II alone” so no additional emissions would result from the cessation of the Stage II program. The widespread use determination would not obligate states to remove any existing Stage II vapor recovery requirements and the Chicago 8

- hour ozone Mai ntenance Plan does not propose to end the Stage II program. If at a later date, the Illinois EPA should wish to end the Stage II program in Chicago, a revision to the State Implementation Plan (SIP) would6

have to be adopted and approved by the U.S.EPA dem onstrating that no additional refueling e m i s s i o n s would result. As Stage II is not required in the Metro

- East St. Louis

area, U.S. EPA ’s widespread use determination would have no impact on either regional air quality or the Metro

- East St. Louis 8

- hour ozone Mainte nance Plan.

A commenter stated that I llinois EPA’s projection of future emissions decreases from on

- road

motor vehicles is unsupported , and that its emission s calculations from on

- road mobile sources

fail to consider U

. S

. EPA’s recent decision to allow 15% ethanol in all gas.

Illinois EPA used the U.S. EPA’s new MOVES2010 model to estimate motor vehicle emissions in both the Chicago and Metro

- East St. Louis areas. This model incorporates
emissions factors for all vehicl e category types. The model also incorporates local motor vehicle registration data and national fleet turnover rate statistics

. The reduction in estimated NOx emissions results from the introduction of new vehicles complying with the
Tier 2 motor vehicl e emissions standards and the retirement of older vehicles. The Tier 2 program, phased in beginning in 2004, established more stringent NOx emission s standard s

on cars , trucks
, and sport utility vehicles. Given the implementation of th ese significantly

m ore stringent emission standard s , the estimated reduction in motor vehicle NOx emissions
is reasonable

.
Regarding the comment regarding the U.S.EPA’s recent decision to allow the blending of up to 15% ethanol into conventional gasoline, the use of such fuel is limited to flexible

fueled vehicles and model year (MY) 2001 light

- duty cars and trucks, and medium

- duty passenger vehicles. In its “Notice of Decision Granting a Partial Waiver” (76 FR 4662), the U.S.EPA stated that Department of Energy (DOE) testing of MY 2001

- 2006 light duty motor vehicles “strongly supports a determination that E15 will not cause o r contribute to
MY2001

- 2006 light

- duty motor vehicles exceeding their applicable exhaust emission
standards.” The U.S.EPA further states that “MY 2001

- 2006 light duty motor vehicles should generally be able to meet evaporative emission standards when oper ated on E15 so long as the fuel does not exceed a RVP of 9.0 psi (pounds per square inch)in the summertime volatility control season.” The U.S.EPA goes on to state : “ ...i n fact, such vehicles should have somewhat lower evaporative emissions when operated on 9.0 psi E15 than when operated on currently available in

- use fuel.”

Regarding MY 2007 and newer vehicles, in its November 4, 2010 “Notice of Partial Waiver Decision” (75 FR 68094) the U.S. EPA states that DOE Catalyst Study and other
information befo re EPA adequately demonstrates that the impact of E15 on overall emissions, including both immediate and durability related emissions, will not cause or
contribute to violations of the emissions standards for these motor vehicle. Likewise, the
data and in formation adequately show that E15 will not lead to violations of the evaporative emissions standards, so long as the fuel does not exceed a Reid Vapor Pressure (RVP) of 9.0 psi in the summertime control season.”

The use of reformulated gasoline (RFG) is required in both the Chicago and Metro

- East St.
Louis areas. The summertime volatility of these fuels are in the range of 7.0 psi, well below the 9.0 psi level referenced by the U.S.EPA. Based on these statements from the U.S.EPA,7

the Illinois EPA believ es that the use of E15 gasoline blends will not result in any increase
in emissions in the ozone control season.

A commenter questioned whether ambient monitoring data is available to the public , since U

. S

. EPA and the Illinois EPA apparently do not have timely data available no their respective web

page s

.
The Illinois EPA submits all ambient monitoring data it collects to U.S. EPA’s Technology Transfer System (TTN) Air Quality System (AQS). The AQS Data Mart is a database containing all of the information from the AQS system and is available free of charge to the public

. The AQS Data Mart is available on the internet at :

http://www.epa.gov/ttn/airs/aqsdat amart

U.S. EPA also maintains the following web sites to disseminate air quality data to the public:

AirData @ http://www.epa.gov/air/data/index.html AirExplorer @ http://www.epa.gov/airexplorer/ AirNow @ http://www.airnow.gov/

A commenter pointed out that Chicago Ozone Maintenance Plan fail ed to consider climate change , noting that c limate change might cause existing pollution

- control measures to become inadequate in the future

.
The Illinois EPA understands that there is a clear relationship between meteorological conditions and ground level ozone levels, and that climate change may a ffect the frequency and severity of ozone

- conducive meteorological conditions in future years. Although climate change is not directly addressed in the Maintenance Plan, nor is it required to b e

a d d r e s s e d , the Maintenance Plan provides contingency measures that will b e triggered in the event of future NAAQS violations. The Illinois EPA has committed to maintain an adequate monitoring network in the Chicago area and to take corrective actions in the event of future NAAQS violations, whether caused by normal year

- to

- yea r meteorological variability, climate induced adverse conditions, or emissions changes that were not anticipated in the development of the Maintenance Plan. The Illinois EPA has also committed to revise the plan within the next ten years to ensure mainten ance of the NAAQS

.

A commenter stated that the Clean Air Act does not allow for alternative measures in the event that current control measures now in effect must be replaced with equivalent emission reduction

measures

.

I llinois EPA does not agree with the commenter’s statement. Section 110( l ) of the CAA provides for revisions of the SIP as long as the plan does not interfere with attainment or reasonable further progress, or other applicable requirements. To be clear, Illinois’8

Maintenance Plan does n ot rely on alternate measures. In fact, the plan clearly states Illinois’ commitment to keep existing control measures in place after the Chicago NAA has been redesignated to attainment. I n t h e e v e n t t h a t future revisions of Illinois’ SIP become necessary, the Main tenance Plan commits the state to provide equivalent emissions levels using alternate control measures

. Such revisions are subject to review and approval by
U.S. EPA.

A commenter noted that the summary of Illinois’ Reasonable Further Progress demonstration contained in the Chicago 8

- hour ozone Maintenance Plan states: “The control measures

identified in the RFP document

... will result in a 15.7 percent reduction in VOM emissions from 2002 emissions levels by the year 2008.” The commenter requested that I llinois EPA must prove that these reductions were actually achieved.

T he Illinois EPA does not agree that such a demonstration is require d for the Maintenance Plan, since there is no such requirement in any guidance published to date by U.S. EPA. Further, U.S. EPA has published a Clean Data Determination for the 1997 8

- hour ozone NAAQS for the Chicago NAA ( April 12, 2011), which waives CAA planning requirements, including RFP, as long as the nonattainment area continues to meet the NAAQS. However, based on this comment, the Illinois EPA has revised the 2002 VOM emission estimates contained in the Maintenance Plan (Table 4.2 on page 15). T he VOM emission estimates in the draft Maintenance Plan for 2002 did not properly account for changes in U.S. EPA’s emissions estimation guidance that occurred subsequent to preparation of the 2002 inventory. U.S. EPA’s guidance for computing emissions fr om certain area source categories, most significantly for graphic arts, consumer solvents, architectural coatings, and industrial coatings , changed between 2002 and 2008. Illinois EPA’s 2008 emissions estimates were performed using the revised methodology , but the 2002 estimates contained in the draft document were based on the earlier methodology. The final document has been revised to apply a consistent methodology for all years. Comparing VOM emissions in the Chicago NAA from 2002 to 2008 indicates th at VOM emissions decreased significantly during that period, about 210 tons per day. This amount equates to a reduction of about 21%, which exceeds the amount needed to demonstrate RFP.

Metro

- East St. Louis Ozone Maintenance Plan

A commenter suggested th at the Metro

- East ozone maintenance plan may not be adequate to maintain the NAAQS , noting that U

. S

. EPA ’s Air Quality System (AQS) contains the following

footnote for the 2008

- 2010 period for the St. Louis NAA: “One or more sites in this area has violated the NAAQS prior to 2008

- 2010 and does not have a valid 2008

- 2010 design value.”

The footnote in the cited AQS report occurs when one or more monitors in the NAA do not meet the completeness criteria establish ed by U.S. EPA. For the 2008

- 2010 period, design values are not shown in AQS for two monitoring stations (three samplers at two locations) in the St. Louis area, prompting the footnote cited by the commenter. The two sites are located at 4520 Margaretta i n St. Louis, MO (site ID: 29

- 510

- 0086) and 4580 South Lindbergh in Sunset Hills, MO (site ID: 29

- 189

- 004). The Missouri Department of Natural Resources (MDNR) discontinued these monitoring stations prior to the 2009 ozone season.9

These monitors were dete rmined by MDNR and U.S. EPA

– Region 7 to be redundant with other monitors in the metropolitan area, and did not measure the highest levels of ozone in the NAA during the years that they operated at those locations. U.S. EPA requires that changes in a sta te’s monitoring network be identified and approved in advance, and contained in the state’s monitoring network plan. MDNR’s 2009 network plan properly and timely identified and justified the need to discontinue these sites . By approving the changes to MD NR’s monitoring network plan, U.S. EPA determined that the revised network was still adequate to characterize ozone air quality in the St. Louis NAA.

A commenter pointed out that: “ Clean Air Act (CAA) Section 110( l ) prohibits the U

. S

. EPA from approving any SIP revision that may interfere with another NAAQS. 42 U.S.C. § 7410(I). However, Illinois EPA has presented no analysis at all to establish that re

- designating Metro

- East from nonattainment to attainment and that implementing the maintenance plan will not interfere with the 2008 ozone NAAQS of 75 ppb or the 2010 1

- hour nitrogen dioxide NAAQS. ”

The Illinois EPA does not agree that a further analysis of the effects of redesignation on another NAAQS is required or that U.S. EPA cannot approve the SIP revision without such analysis. The Illinois EPA has prepared the Metro

- East ozone M aintenance P lan consistent with U.S. EPA’s published guidance. The document adequately demonstrate s that the 1997 NAAQS for ozone has been attained in the St. Louis NAA based on three consecutive years of ambient air monitoring data. The plan contain s emission estimates of the precursors of ozone for the “attainment year” and multiple “projection years” that demonstrate that the projected level of emissions is sufficient to maintain the NAAQS. In fact, the emissions projections indicate that ozone precursor emissions will decrease substantially in future years, ensuring continued attainment and maintenance of the NAAQS. The Maintenance Plan provides commitments to maint ain and enforce the control measures that are already in place, to continue monitoring air quality in the NAAs, to prepare periodic updates of the emissions inventories, and to implement contingency measures, if needed, to correct future exceedances of the NAAQS. Based on these commitments, there is no basis to conclude that approval of the Maintenance Plan will cause backsliding of the air pollution control programs that have allowed the NAAs to
reach attainment with the ozone NAAQS. As Illinois’ Mainten ance Plan ha s been prepared in accordance with the requirements specified in U.S. EPA’s guidance document and additional guidance received from U.S. EPA staff , the plan is approvable as a SIP revision

.
Further, U.S. EPA has not implemented the 2008 ozone NAAQS, and has decided not to tighten the standard before 2013. Should U.S. EPA decide to implement the 2008 ozone standard, or to revise it in the future, Illinois is obligated to address the new ozone NAAQS, independent of efforts to redesignate existing NAAs to attainment with the old standard.

With regard to the 2010 NO 2 NAAQS, all ambient monitors in Illinois, including the

Metro

- East area , are meeting the standard and the Illinois EPA has recomme nded that all counties in Illinois be designated as attainment. U.S. EPA has not yet acted on Illinois’ recommendation. As shown in the Maintenance Plan, NOx emissions (a combination of compounds that includes NO 2 ) are expected to decrease significantly in future years, so
there is no basis to conclude that re
- designating the Metro

- East NAA from nonattainment10

to attainment of the ozone NAAQS
, and implementing the maintenance plan will interfere
with the 2010 1

- hour nitrogen dioxide NAAQS.

A commenter questioned whether air quality improvements in the Metro

- East area were the result of permanent and enforceable emission reductions since the NOx SIP Call and CAIR are cap and trade programs , and because the NOx SIP Call is no longer in place a nd CAIR has been vacated by the U

. S

. Court of Appeals

.

The Illinois EPA believes that these comm ents have been addressed in its previous responses for the Chicago ozone nonattainment area.

A commenter pointed out that I llinois EPA ’s emission projections do not account for emissions

from the Prairie State Generating Station which should be in operation, and thus polluting, prior

to 2015.

The Prairie State Generating Station is located in Washington County, Illinois and is expected to be in operation by 2012. As require d, Illinois EPA’s emissions projections include only those emissions occurring or projected to occur within the boundaries of the nonattainment area, which includes Madison, Monroe, St. Clair, and Jersey counties in
Illinois. The Illinois EPA acknowledges that the Prairie State Generating Station is located in close proximity to the Metro

- East ozone nonattainment area and emissions from it will cause air quality impacts within the NAA. Before issuing a PSD permit to Prairie State, the Illinois EPA require d the company to address its potential impact on the St. Louis ozone nonattainment area. Prairie State adequately demonstrated that future emissions from the facility will not interfere with the area’s ability to attain and maintain the NAAQS.

A commen ter identified the same “defects” in the Metro

- East Ozone Maintenance Plan identified previously in comments on the Chicago Ozone Maintenance Plan

, includ ing : (1) failing to

consider increased emissions from U

. S

. EPA’s repealing the vapor capture requirements for gas

stations and allowing up to 15% ethanol in gasoline; (2) assuming that vehicle turn over will

reduce mass on

- road emissions even though purchasing larger new vehicles can offset this; (3) failing to m ake ambient monitoring data available to the public; (4) failing to consider climate change impacts on future ambient ozone levels; (5) relying on unidentified alternate measures with no legal authority to do so.

The Illinois EPA believes that these comm ents have been addressed in its previous responses for the Chicago ozone nonattainment area.

A commenter questioned whether PM 2.5 air quality improvements in Chicago were the result of permanent and enforceable emission reductions since the NOx SIP Call an d CAIR are cap and trade programs , and because the NOx SIP Call is no longer in place and CAIR has been vacated by the U

. S

. Court of Appeals

.11

The Illinois EPA believes that th is comment ha s been addressed in its previous responses for the Chicago ozone n onattainment area.

A commenter identified the same “defects” in the Chicago PM 2.5 Maintenance Plan identified previously in comments on the Chicago Ozone Maintenance Plan

, includ ing : (1) failing to

consider increased emission from U

. S

. EPA’s repealing the vapor capture requirements for gas stations and allowing up to 15% ethanol in gasoline; (2) assuming that vehicle turn over will

reduce mass on

- road emissions even though purchasing larger new vehicles offset this; and (3) failing to m ake ambient monitoring data available to the public.

The Illinois EPA believes that these comments have been addressed in its previous responses for the Chicago ozone nonattainment area.