R­
19J
Honorable
Jennifer
M.
Granholm
Governor
of
Michigan
Lansing,
Michigan
Dear
Governor
Granholm:

Fine­
particle
pollution
represents
one
of
the
most
significant
barriers
to
clean
air
facing
our
nation
today.
These
tiny
particles
 
about
1/
30th
the
diameter
of
a
human
hair
 
have
been
scientifically
linked
to
serious
human
health
problems.
Their
ability
to
be
suspended
in
air
for
long
periods
of
time
makes
them
a
public
health
threat
far
beyond
the
source
of
emissions.
An
important
part
of
our
nation's
commitment
to
clean,
healthy
air
deals
with
reducing
levels
of
this
fine­
particle
(
PM2.5
)
pollution.

We
have
reviewed
the
February
13,
2004,
letter
from
Steven
E.
Chester,
Director,
Michigan
Department
of
Environmental
Quality,
submitting
Michigan's
recommendations
on
air
quality
designations
for
the
PM2.5
standard.
We
have
also
reviewed
the
technical
information
he
submitted
to
support
Michigan's
recommendations
for
areas
that
differed
from
the
presumptive
boundaries.
We
appreciate
the
effort
the
State
has
made
to
develop
this
supporting
information.
Consistent
with
the
Clean
Air
Act,
this
letter
is
to
inform
you
that
the
Environmental
Protection
Agency
(
EPA)
intends
to
make
modifications
to
Michigan's
recommended
designations
and
boundaries.

Your
Environmental
Director
will
receive
a
copy
of
this
letter
with
a
more
detailed
enclosure
containing
a
description
of
areas
where
EPA
intends
to
modify
your
state
recommendations,
and
the
basis
for
such
modification.
Should
you
have
additional
information
that
you
wish
to
be
considered
by
EPA
in
this
process,
we
request
that
you
provide
it
to
us
by
September
1.

You
will
hear
from
us
again
in
November
when
EPA
takes
the
final
step
in
the
PM2.5
designation
process
and
determines
those
areas
that
are
in
attainment
(
or
unclassifiable)
and
those
areas
that
are
nonattainment.
For
areas
in
attainment,
the
challenge
will
be
not
only
to
maintain,
but
also
to
continue
the
progress
you
2
have
made
toward
clean
air.
It
is
a
commitment
to
no
backsliding
in
your
State's
clean
air
status
for
fine
particles.
EPA
will
also
issue
a
proposed
fine
particle
implementation
rule
prior
to
final
designations,
which
will
allow
you
to
proceed
with
planning
to
achieve
clean
air.

The
Bush
Administration
is
addressing
fine
particle
pollution
with
a
comprehensive
national
clean
air
strategy.
This
strategy
includes
EPA's
recent
rule
to
reduce
pollution
from
nonroad
diesel
engines,
and
the
proposed
rule
to
reduce
pollution
from
power
plants
in
the
Eastern
United
States.
These
two
rules
are
important
components
of
EPA's
efforts
to
help
States
and
localities
meet
the
more
protective
national
fine­
particle
and
8­
hour
ozone
air
quality
standards.
Together
these
rules
will
help
all
areas
of
the
country
achieve
cleaner
air.

If
you
have
any
questions,
please
do
not
hesitate
to
contact
me.
We
look
forward
to
a
continued
dialogue
with
you
as
we
work
together
to
implement
the
PM2.5
standards.

Very
truly
yours,

Bharat
Mathur,
Acting
Regional
Administrator
Enclosure
3
cc:
Steven
E.
Chester,
Director
Michigan
Department
of
Environmental
Quality
Christopher
Jones,
Director
Ohio
Environmental
Protection
Agency
4
standard
bcc's:
official
file
copy
originator's
file
copy
originating
organization
reading
file
other
bcc's:
Kay
Hudson
ORA
reading
file
Rita
Cestaric
R.
Damberg,
OAQPS
(
electronic
copy)
L.
Wallace,
OAQPS
(
electronic
copy)
V.
Hellwig,
MDEQ
Naimah
Karim
Felicia
Williams
Shari
Holloway
Review
of
Designations
in
Michigan
For
the
Particulate
Matter
Air
Quality
Standard
The
following
table
identifies
the
individual
areas
and
counties
comprising
those
areas
in
Michigan
that
EPA
intends
to
designate
as
nonattainment
for
the
fine
particulate
matter
("
PM2.5")
air
quality
standard.
Following
the
table
is
a
description
of
areas
where
EPA
intends
to
modify
Michigan's
recommendation
and
the
basis
for
such
modifications.
EPA
intends
to
designate
as
attainment/
unclassifiable
all
counties
not
identified
in
the
table
below.

Area
Michigan
Counties
in
Metropolitan
Area
Michigan
Recommended
Nonattainment
Counties
EPA's
Intended
Nonattainment
Counties
Detroit­
Ann
Arbor­
Flint
Monroe
Wayne
Livingston
Macomb
Oakland
St
Clair
Washtenaw
Genesee
Lapeer
Lenawee
Monroe
Wayne
Monroe
Wayne
Livingston
Macomb
Oakland
St
Clair
Washtenaw
2
Nine­
Factor
Analysis
for
Detroit­
Ann
Arbor­
Flint
Discussion:

EPA
reviewed
the
nine
factors
for
the
counties
within
the
metropolitan
area
as
well
as
counties
adjacent
to
the
metropolitan
area
in
order
to
determine
the
appropriate
nonattainment
area.
There
are
violating
monitors
in
Monroe
and
Wayne
counties.
EPA
agrees
with
the
Michigan
DEQ
to
designate
Monroe
and
Wayne
counties
as
nonattainment.
However,
based
upon
our
nine­
factor
analysis,
EPA
believes
that
in
addition
to
Monroe
and
Wayne
counties,
the
Detroit
nonattainment
area
should
also
include
Livingston,
Macomb,
Oakland,
St.
Clair,
and
Washtenaw
counties
as
one
contiguous
area.
These
counties
have
significant
emissions
and
the
population,
population
density,
and
vehicle
miles
traveled
(
VMT)
are
at
sufficient
levels
to
be
part
of
the
designated
area.
This
is
consistent
with
the
national
approach
of
capturing
the
majority
of
emissions
and
population
in
a
metropolitan
area.
Genesee,
Lapeer,
and
Lenawee
counties
are
also
in
the
Metropolitan
area
but
were
excluded
upon
review
of
the
9
factors.
Except
for
Genesee
County,
which
is
discussed
below,
these
counties
have
lower
emissions,
population,
population
density,
and
VMT.

Michigan
supported
its
recommendation
of
attainment
for
most
counties
by
attributing
the
violations
in
Wayne
County
predominantly
to
high
emissions
in
Wayne
County,
and
attributing
the
violation
in
Monroe
County
to
emissions
in
Toledo,
Ohio.
Michigan
notes
the
monitored
attainment
in
Macomb
County,
and
observes
that
trajectories
for
high
and
low
concentration
days
in
Wayne
County
indicate
that
the
highest
concentrations
occur
when
winds
are
from
the
south
and
west.
Michigan
concludes
from
this
evidence
that
the
Wayne
County
violations
arise
from
a
combination
of
long
range
transport
and
very
localized
emissions,
and
that
counties
other
than
Wayne
County
do
not
contribute
to
violations
in
Wayne
County.

EPA
disagrees
with
Michigan's
analysis.
EPA's
guidance
includes
a
presumption
that
the
entire
metropolitan
area
contributes
to
the
nonattainment
problem,
reflecting
evidence
that
the
various
types
of
emissions
that
lead
to
PM2.5
concentrations
have
impacts
on
many
distance
scales
including
metropolitan
scale.
Michigan
has
not
provided
a
convincing
demonstration
that
EPA's
presumption
and
the
underlying
understanding
of
the
nature
of
PM2.5
is
invalid
or
inapplicable
to
the
Detroit
area.
The
design
value
in
Macomb
County
is
15.0
micrograms
per
cubic
meter,
just
barely
attaining
the
standard.
While
it
is
evident
that
Macomb
County
does
not
by
itself
cause
violations
in
Wayne
County,
the
3
wind
data
shown
for
factor
6
below
demonstrate
that
winds
often
blow
from
Macomb
County
into
Wayne
County.
While
the
wind
blows
from
the
southwest
quadrant
more
frequently
than
other
quandrants,
the
wind
blows
from
the
northwest
or
northeast
quadrants
about
40
percent
of
the
time.
Trajectory
information
can
often
be
misleading;
since
a
high
fraction
of
observed
PM2.5
concentrations
are
attributable
to
long
range
transport,
trajectories
for
high
concentration
days
tend
to
be
a
better
measure
of
whether
distant
contributions
to
transported
"
background"
concentrations
are
high
rather
than
indicating
high
local
contributions.
Michigan's
analysis
also
does
not
address
the
contributions
to
Wayne
County
concentrations
from
mobile
sources
that
originate
in
other
counties.
Although
different
components
of
PM2.5
have
different
geographic
scales
of
impact,
EPA
continues
to
believe
that
emissions
throughout
a
metropolitan
area
can
contribute
significantly
to
observed
violations.
Since
a
significant
fraction
of
the
Detroit
area's
emissions
occur
in
Livingston,
Macomb,
Oakland,
St.
Clair,
and
Washtenaw
Counties,
EPA
believes
that
these
contribute
to
nonattainment
in
Wayne
and
Monroe
Counties.

The
composite
emissions
score
for
Genesee
County
is
somewhat
higher
than
that
of
Washtenaw
County.
EPA
nevertheless
believes
that
Washtenaw
County
contributes
to
violations
in
Wayne
and
Monroe
Counties
and
Genesee
County
does
not.
Washtenaw
County
is
upwind
of
Wayne
and
Monroe
Counties
somewhat
more
frequently
than
Genesee
County.
More
importantly,
Washtenaw
County
is
closer
to
Wayne
and
Monroe
Counties
and
the
observed
violations,
which
means
that
the
emissions
are
likely
to
have
a
greater
impact
and
mobile
sources
are
more
likely
to
be
traveling
into
the
violating
counties.
Finally,
Washtenaw
County
is
part
of
the
Detroit
ozone
nonattainment
area
whereas
Genesee
County
is
part
of
a
separate
ozone
nonattainment
area,
and
the
Detroit
area
metropolitan
planning
organization
includes
Washtenaw
County
and
not
Genesee
County.
Therefore,
including
Washtenaw
County
in
the
PM2.5
nonattainment
area
will
facilitate
coordinated
ozone
and
PM2.5
planning.

Michigan
requested
that
Wayne
and
Monroe
Counties
each
be
treated
as
single
county
nonattainment
areas.
Michigan
has
not
justified
a
conclusion
that
either
of
these
counties
may
be
considered
single
county
nonattainment
areas.
While
Monroe
County
may
sometimes
be
considered
part
of
the
Toledo
area
(
along
with
Lucas
and
Wood
Counties,
Ohio),
particularly
when
winds
are
from
the
south,
on
such
occasions
Monroe
County
also
contributes
to
violations
in
Wayne
County.
The
Detroit
area
also
contributes
to
violations
in
Monroe
County.
Therefore,
EPA
intends
to
designate
a
single
Detroit
area
nonattainment
area
that
includes
Monroe
4
County.

There
are
seven
counties
adjacent
to
the
metropolitan
area
that
are
not
a
part
of
another
violating
metropolitan
area.
These
counties
have
relatively
low
emissions,
and
no
other
factors
warrant
including
these
counties
in
the
nonattainment
area.
Therefore,
no
data
are
provided
for
these
counties
under
factors
3
to
9
below.

Factor
1.
Emissions
in
areas
potentially
included
versus
excluded
from
the
nonattainment
area:

The
analysis
for
factor
1
looks
at
emissions
of
carbonaceous
particles
(
carbon),
inorganic
particles
(
crustal),
SO2,
and
NOx.
EPA
computed
a
composite
emission
score
for
each
county
by
multiplying
the
county's
emissions
as
a
fraction
of
the
metropolitan
area
emissions
for
each
of
these
pollutants
times
a
corresponding
air
quality
weighting
factor.
These
scores
for
the
metropolitan
area
counties
add
to
100.
The
air
quality
weighting
factors
for
each
area
are
given
below
and
reflect
the
percentages
of
the
total
estimated
"
urban
excess"
value
found
as
carbonaceous
particles,
miscellaneous
inorganic
particles
(
crustal
material),
ammonium
sulfate,
and
ammonium
nitrate.
Tables
presented
under
factor
1
provide
the
carbonaceous
particles,
inorganic
particles,
SO2,
and
NOx
emissions
and
the
composite
emission
scores
for
the
counties
in
the
corresponding
metropolitan
area
and
adjacent
counties.
Emissions
data
are
derived
from
the
National
Emissions
Inventory
and
are
for
2001,
given
in
tons
per
year.
Metropolitan
area
counties
are
in
bold.
Emissions
data
indicate
the
potential
for
a
county
to
contribute
to
observed
violations,
often
making
the
emissions
data
the
most
important
factor
in
assessing
boundaries
of
nonattainment
areas.

"
Urban
excess"
values
are
derived
by
comparing
urban
monitored
component
concentrations
against
rural
monitored
component
concentrations.
Concentrations
of
the
four
PM2.5
components
are
obtained
from
local
data
if
available
(
or,
if
necessary,
from
the
nearest
available
urban
site),
and
are
compared
to
available
rural
concentrations.
The
monitoring
sites
used
for
this
purpose
are
identified
below.
Although
this
information
is
air
quality
information,
it
is
presented
under
Factor
1
due
to
its
integration
into
the
analysis
of
emissions
information.

County
SOx
NOx
Carbon
Crustal
Composite
emissions
score
5
Genesee
3,010
20,648
1,377
1,914
7.5
Lapeer
895
5,202
389
1,109
2.1
Lenawee
642
4,496
554
1,488
2.5
Livingston
701
8,024
852
1,695
4.0
Macomb
4,602
33,482
1,413
1,282
9.5
Monroe
126,037
62,432
1,565
4,834
15.1
Oakland
8,277
44,171
2,264
1,829
13.6
St
Clair
72,450
40,659
1,248
2,687
10.4
Washtenaw
2,163
14,980
944
1,502
5.3
Wayne
59,884
107,604
4,435
2,823
29.9
Hillsdale
1,286
3,270
245
812
1.4
Ingham
13,381
17,912
648
1,126
4.9
Jackson
1,093
7,895
599
1,269
3.2
Saginaw
2,812
9,755
978
2,457
4.8
Sanilac
397
2,893
422
1,429
1.9
Shiawassee
768
3,749
318
1,024
1.7
Tuscola
531
3,162
417
1,404
1.9
Fulton,
OH
878
5,105
336
692
1.9
Lucas,
OH
31,000
36,975
1,370
1,702
10.0
Urban
increment:
Total
mass=
4.3
ug/
m3
0%
sulfates;
54%
nitrates;
42%
carbon;
4%
crustal.
Urban
site=
261630001;
Rural
site=
MKGO1
(
M.
K.
Goddard)

Factor
2.
Air
quality
in
potentially
included
versus
excluded
areas:

The
air
quality
analysis
looks
at
the
annual
averaged
design
value
for
each
area
based
on
data
for
2001
to
2003.
Counties
without
monitors
are
not
listed.

County
2001­
2003
Design
Value
Genesee
12.6
Macomb
13.3
Monroe
15.1
Oakland
14.8
St
Clair
13.9
Washtenaw
14.6
Wayne
19.5
6
Ingham
13.4
Saginaw
11.0
Lucas,
OH
15.2
Factor
3.
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas:

Tables
presented
under
factor
3
show
the
2003
population
for
each
metropolitan
area,
as
well
as
the
population
density
for
each
county
in
that
area.
Population
data
indicate
the
likelihood
of
population­
based
emissions
that
might
contribute
to
violations.

County
2003
Population
Population
Density
Genesee
441,423
690
Lapeer
90,776
139
Lenawee
100,145
133
Livingston
168,862
297
Macomb
808,529
1684
Monroe
149,253
271
Oakland
1,202,721
1378
St
Clair
167,712
231
Washtenaw
334,351
471
Wayne
2,045,540
3331
Factor
4.
Traffic
and
commuting
patterns:

The
traffic
and
commuting
analysis
looks
at
the
number
of
commuters
in
each
county
who
drive
to
another
county
within
the
metropolitan
area
("
Number"),
the
percent
of
total
commuters
in
each
county
who
commute
to
other
counties
within
the
metropolitan
area
("
percent"),
as
well
as
the
total
Vehicle
Miles
Traveled
(
VMT)
for
each
county
in
thousands
of
miles.
A
county
with
numerous
commuters
is
generally
an
integral
part
of
the
area,
and
would
be
an
appropriate
part
of
the
domain
of
some
mobile
source
strategies,
thus
warranting
inclusion
in
the
nonattainment
area.

Note
that
the
percent
of
commuters
traveling
to
counties
within
the
metropolitan
area
is
based
on
the
total
number
of
commuters
from
that
county.
This
total
includes
commuters
who
may
travel
outside
the
metropolitan
area
from
their
county
of
origin.
7
County
Number
Percent
County
VMT
(
Thousands)

Genesee
4,842
18
33,966
Lapeer
1,139
50
20,118
Lenawee
908
22
10,026
Livingston
1,804
54
42,858
Macomb
6,964
41
156,343
Monroe
1,679
28
19,372
Oakland
10,758
28
167,943
St
Clair
2,029
35
26,992
Washtenaw
3,521
21
35,525
Wayne
20,171
24
201,563
Factor
5.
Expected
growth:

The
expected
growth
analysis
looks
at
the
percent
growth
for
counties
in
each
metropolitan
area
from
1990
to
2000.

County
Percent
growth
1990­
2000
Genesee
1
Lapeer
18
Lenawee
8
Livingston
36
Macomb
10
Monroe
9
Oakland
10
St
Clair
13
Washtenaw
14
Wayne
­
2
Factor
6.
Meteorology:

The
meteorology
analysis
looks
at
wind
data
gathered
over
a
ten
year
period
by
the
National
Weather
Service.
Tables
presented
under
factor
6
list
the
year
round
average
prevailing
wind
directions
by
quadrant
for
each
county
in
the
corresponding
metropolitan
area.
These
data
show
that
annual
average
PM2.5
concentrations
are
influenced
by
emissions
in
any
direction
at
various
times,
but
these
data
may
also
suggest
that
emissions
in
some
directions
relative
to
the
violation
may
be
more
prone
to
contribute
than
emissions
in
other
directions.
8
Average
percent
of
wind
direction
by
quadrant
County
Northwest
Southwest
Southeast
Northeast
Genesee
24
42
18
16
Lapeer
25
40
18
17
Lenawee
25
40
16
19
Livingston
26
40
18
17
Macomb
26
39
18
18
Monroe
25
40
16
19
Oakland
25
39
18
18
St
Clair
25
39
18
18
Washtenaw
26
39
17
19
Wayne
26
38
17
19
Factor
7.
Geography/
topography:

The
geography/
topography
analysis
looks
at
physical
features
of
the
land
that
might
have
an
effect
on
the
airshed,
and
therefore,
the
distribution
of
particulate
matter
over
an
area.
The
State
of
Michigan
has
no
features
that
significantly
influenced
EPA's
recommended
nonattainment
areas.

There
are
no
geographical
features
(
mountain
ranges,
abrupt
changes
in
land
elevation,
etc.)
that
affect
this
area.
The
state
provided
no
information
about
geography/
topography
for
this
area.

Factor
8.
Jurisdictional
boundaries:

The
analysis
of
jurisdictional
boundaries
looks
at
the
planning
and
organizational
structure
of
an
area
to
determine
if
the
implementation
of
controls
in
a
potential
nonattainment
area
can
be
carried
out
in
a
cohesive
manner.

The
Southeast
Michigan
Council
of
Governments
(
SEMCOG
)
is
the
Metropolitan
Planning
Organization
(
MPO)
for
Livingston,
Macomb,
Monroe,
Oakland,
St.
Clair,
Washtenaw,
and
Wayne
counties.
­
source:
SEMCOG
webpage,
http://
www.
semcog.
org/

This
metropolitan
area
is
divided
into
two
ozone
nonattainment
areas.
The
Detroit
area
includes
the
following
counties:
Lenawee,
Livingston,
Macomb,
Monroe,
Oakland,
St
Clair,
Washtenaw,
and
Wayne.
The
Flint
area
includes
the
following
counties:
Genesee
and
Lapeer.
9
Factor
9.
Level
of
control
of
emission
sources:

The
level
of
control
analysis
looks
at
what
controls
are
currently
implemented
in
each
area.

The
state
provided
no
information
about
the
level
of
control
of
emission
sources
for
this
area.
