R­
19J
Honorable
Rod
R.
Blagojevich
Governor
of
Illinois
Springfield,
Illinois
Dear
Governor
Blagojevich:

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
March
5,
2004,
letter
from
Renee
Cipriano,
Director,
Illinois
Environmental
Protection
Agency,
submitting
Illinois'
recommendations
on
air
quality
designations
for
the
PM2.5
standard.
We
appreciate
the
effort
the
State
has
made
to
develop
these
recommendations.
Consistent
with
the
Clean
Air
Act,
this
letter
is
to
notify
you
that,
based
upon
the
information
contained
in
your
submission
and
other
available
information,
the
Environmental
Protection
Agency
(
EPA)
intends
to
make
modifications
to
Illinois'
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
the
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
have
made
toward
clean
air.
It
is
a
commitment
to
no
backsliding
2
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:
Renee
Cipriano,
Director
Illinois
Environmental
Protection
Agency
Lori
Kaplan,
Commissioner
Indiana
Department
of
Environmental
Management
Steven
Mahfood,
Director
Missouri
Department
of
Natural
Resources
P.
Scott
Hassett,
Secretary
Wisconsin
Department
of
Natural
Resources
4
standard
bcc's:
official
file
copy
originator's
file
copy
originating
organization
reading
file
other
bcc's:
Kay
Hudson
Rita
Cestaric
ORA
reading
file
Naimah
Karim
Felicia
Williams
Shari
Holloway
R.
Damberg,
OAQPS
(
electronic
copy)
L.
Wallace,
OAQPS
(
electronic
copy)
Dave
Kolaz,
IEPA
Review
of
Designations
in
Illinois
For
the
Particulate
Matter
Air
Quality
Standard
The
following
table
identifies
the
individual
areas
and
counties
comprising
those
areas
in
Illinois
that
EPA
intends
to
designate
as
nonattainment
for
the
fine
particulate
matter
("
PM2.5")
air
quality
standard.
Where
EPA
intends
to
include
only
part
of
a
county
in
a
nonattainment
area,
we
have
indicated
the
boundaries
of
the
portion
of
the
county
that
will
be
included.
Following
this
table
is
a
description
of
the
data
EPA
examined
and
a
discussion
of
each
area
and
the
basis
for
EPA's
intended
designations.
EPA
intends
to
designate
as
attainment/
unclassifiable
all
other
Illinois
counties
or
parts
thereof
not
identified
in
the
table
below.

Area
Illinois
Counties
in
Metropolitan
Area
Illinois
Recommended
Nonattainment
Counties
EPA's
Intended
Nonattainment
Counties
Chicago­
Gary­
Kenosha,
IL­
IN­
WI
Cook
Du
Page
Kane
Lake
Mc
Henry
Will
Grundy
Kendall
De
Kalb
Kankakee
Cook
Du
Page
Kane
Lake
Mc
Henry
Will
Grundy:
Aux
Sable
Township
Goose
Lake
Township
Kendall:
Oswego
Township
Cook
Du
Page
Kane
Lake
Mc
Henry
Will
Grundy:
Aux
Sable
Township
Goose
Lake
Township
Kendall:
Oswego
Township
Saint
Louis,
MO­
IL
Madison
Monroe
St
Clair
Clinton
Jersey
Madison
Monroe
St
Clair
Madison
Monroe
St
Clair
Randolph
2
An
Explanation
of
EPA's
9­
Factor
Analysis
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.

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.

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
3
county
in
that
area.
Population
data
indicate
the
likelihood
of
population­
based
emissions
that
might
contribute
to
violations.

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.

Factor
5.
Expected
growth:
The
expected
growth
analysis
looks
at
the
percent
growth
for
counties
in
each
metropolitan
area
from
1990
to
2000.

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.

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
Illinois
has
no
features
that
significantly
influenced
EPA's
recommended
nonattainment
areas.

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.
4
Factor
9.
Level
of
control
of
emission
sources:
The
level
of
control
analysis
looks
at
what
controls
are
currently
implemented
in
each
area.
5
9­
Factor
Analyses
for
the
Illinois
Portion
of
the
Chicago­
Gary­
Kenosha,
IL­
IN­
WI
Metropolitan
Area
Discussion:
EPA
reviewed
the
nine
factors
for
the
thirteen
counties
within
the
metropolitan
area
(
including
ten
counties
in
Illinois)
as
well
as
all
counties
adjacent
to
the
metropolitan
area
in
order
to
determine
the
appropriate
nonattainment
area.
There
are
violating
monitors
in
Cook
County
and
in
Lake
County,
Indiana.
EPA
agrees
with
the
Illinois
EPA
to
include
Cook,
Du
Page,
Kane,
Lake,
Mc
Henry,
and
Will
counties,
Aux
Sable
and
Goose
Lake
Townships
in
Grundy
County,
and
Oswego
Township
in
Kendall
County
in
the
Chicago
nonattainment
area.
The
bulk
of
emissions
and
population
are
captured
without
including
DeKalb,
Grundy,
Kankakee
and
Kendall
Counties,
since
these
counties
have
limited
emissions
and
population.
Nevertheless,
we
support
the
recommendation
by
the
Illinois
EPA
to
include
the
three
townships
in
Grundy
and
Kendall
counties
in
the
nonattainment
area
to
maintain
consistency
with
the
ozone
designations
and
thereby
facilitate
planning.

There
are
eight
Illinois
counties
adjacent
to
the
metropolitan
area,
including
Boone,
Ford,
Iroquois,
LaSalle,
Lee,
Livingston,
Ogle,
and
Winnebago
Counties.
Emissions
are
relatively
low
for
these
counties,
and
no
other
factor
warranted
designating
these
counties
nonattainment.
Therefore,
the
following
data
summaries
for
factors
3
through
9
do
not
address
these
counties.

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

County
SOx
NOx
Carbon
Crustal
Composite
emissions
score
Cook
61,676
195,428
10,110
8,268
33.0
De
Kalb
445
4,885
384
1,875
1.0
Du
Page
2,990
29,479
1,731
1,229
4.9
Grundy
6,149
9,589
563
1,235
2.1
Kane
1,395
9,490
1,047
2,326
2.8
Kankakee
551
6,628
490
1,720
1.4
Kendall
292
2,941
265
961
0.7
Lake
14,223
24,488
2,092
1,777
6.7
Mc
Henry
637
5,834
564
1,992
1.6
Will
80,847
37,518
1,447
4,120
11.7
Lake,
IN
50,110
72,142
5,708
7,588
19.5
6
Porter,
IN
21,601
41,315
2,702
5,587
9.2
Kenosha,
WI
33,122
27,469
770
1,236
5.4
Boone
849
2,188
215
834
0.6
Ford
219
1,462
216
1,280
0.6
Iroquois
458
4,177
452
2,290
1.3
La
Salle
2,140
13,984
845
3,352
2.5
Lee
3,978
4,793
345
1,722
1.3
Livingston
503
4,686
485
2,413
1.3
Ogle
672
4,985
335
1,536
1.1
Winnebago
1,100
10,496
656
1,405
1.9
Benton,
IN
101
1,326
215
724
0.5
Berrien,
IN
1,390
10,269
740
1,340
0.6
Jasper,
IN
34,435
23,020
668
1,838
5.2
La
Porte,
IN
10,974
19,681
826
1,643
3.3
Newton,
IN
89
1,321
160
642
0.4
Pulaski,
IN
111
1,187
196
667
0.5
St
Joseph,
IN
2,850
13,690
1,482
1,825
4.0
Starke,
IN
100
2,852
188
551
0.5
White,
IN
188
2,495
292
1,185
0.8
Racine,
WI
2,309
7,252
662
890
1.9
Walworth,
WI
866
5,693
470
908
1.3
Urban
increment:
Total
mass=
3.6
µ
g/
m3
25%
sulfates;
8%
nitrates;
65%
carbon;
2%
crustal.
Urban
site=
170310076;
Rural
site=
BOND1
(
Bondville)

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

County
2001­
2003
Design
Value
Cook
17.3
µ
g/
m3
Du
Page
14.4
µ
g/
m3
Kane
14.2
µ
g/
m3
Lake
12.8
µ
g/
m3
Mc
Henry
12.7
µ
g/
m3
Will
12.8
µ
g/
m3
Lake,
IN
17.7
µ
g/
m3
Porter,
IN
13.8
µ
g/
m3
Kenosha,
WI
11.7
µ
g/
m3
La
Porte
13.6
µ
g/
m3
7
La
Salle
14.1
µ
g/
m3
Winnebago
13.6
µ
g/
m3
St
Joseph,
IN
14.3
µ
g/
m3
Berrien,
MI
12.7
µ
g/
m3
Factor
3.
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas:

County
2003
Population
Population
Density
Cook
5,377,507
5,684
De
Kalb
91,561
144
Du
Page
924,589
2,768
Grundy
38,839
92
Kane
443,041
850
Kankakee
104,657
154
Kendall
61,222
191
Lake
674,850
1,506
Mc
Henry
277,710
460
Will
559,861
669
Lake,
IN
487,016
980
Porter,
IN
150,403
360
Kenosha,
WI
154,433
566
Factor
4.
Traffic
and
commuting
patterns:

County
County
VMT
Percent
Number
Cook
44,107,000
12
274,167
De
Kalb
729,000
31
13,894
Du
Page
6,609,000
40
186,686
Grundy
530,000
46
8,431
Kane
841,000
43
82,968
Kankakee
889,000
19
9,122
Kendall
278,000
67
19,070
Lake
3,549,000
32
100,810
Mc
Henry
792,000
47
62,415
Will
2,136,000
55
131,834
Lake,
IN
5,012,000
25
52,922
Porter,
IN
1,680,000
36
25,819
Kenosha,
WI
1,228,000
28
20,506
Factor
5.
Expected
growth:
8
County
Percent
growth
1990­
2000
Cook
5
De
Kalb
14
Du
Page
16
Grundy
16
Kane
27
Kankakee
8
Kendall
38
Lake
25
Mc
Henry
42
Will
41
Lake,
IN
2
Porter,
IN
14
Kenosha,
WI
17
Factor
6.
Meteorology:

Average
percent
of
wind
direction
by
quadrant
County
Northwest
Southwest
Southeast
Northeast
Cook
26
37
16
21
De
Kalb
27
34
19
21
Du
Page
26
37
17
21
Grundy
26
36
17
21
Kane
26
35
18
21
Kankakee
25
38
17
19
Kendall
26
36
17
21
Lake
26
37
17
20
Mc
Henry
28
32
19
20
Will
26
37
17
21
Lake,
IN
25
38
17
19
Porter,
IN
25
38
18
19
Kenosha,
WI
28
35
18
20
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
Illinois
has
no
features
that
significantly
influenced
EPA's
intended
nonattainment
areas.
9
Factor
8.
Jurisdictional
boundaries:
The
Chicago
Area
Transportation
Study
(
CATS)
Policy
Committee
is
the
Metropolitan
Planning
Organization
(
MPO)
for
the
northeastern
Illinois
region.
­
source:
CATS
webpage,
http://
www.
catsmpo.
com/

The
Illinois
portion
of
the
Chicago
ozone
nonattainment
area
consists
of
the
following
counties:
Cook,
Du
Page,
Kane,
Lake,
Mc
Henry,
Will,
Aux
Sable
and
Goose
Lake
Townships
in
Grundy
County,
and
Oswego
Township
in
Kendall
County.

Factor
9.
Level
of
control
of
emission
sources:
The
state
provided
no
information
about
the
level
of
control
of
emission
sources
for
this
area.

9­
Factor
Analysis
for
the
Saint
Louis
Metropolitan
Area
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
Madison
and
St.
Clair
counties
as
well
as
in
the
City
of
Saint
Louis.
EPA
agrees
with
the
Illinois
EPA
to
include
Madison,
Monroe
and
St.
Clair
counties
in
the
Illinois
portion
of
the
St.
Louis
nonattainment
area.

Illinois
recommended
a
designation
of
unclassified
for
a
portion
of
Randolph
County,
specifically
the
township
that
contains
the
Baldwin
power
plant.
EPA
intends
to
designate
Randolph
County
nonattainment
as
part
of
the
Saint
Louis
nonattainment
area.
EPA
notes
that
the
Baldwin
plant
has
recently
reduced
its
emissions
significantly.
Illinois'
submittal
did
not
indicate
whether
these
emission
reductions
are
enforceable
or
how
much
potential
exists
for
further
emission
reductions
at
this
facility
(
e.
g.
through
annual
operation
of
NOx
emission
controls).
Randolph
County
adjoins
a
county
that
is
monitoring
a
violation
of
the
standard,
and
the
most
significant
emissions
are
located
in
the
portion
of
the
county
closest
to
the
violation.
These
emissions
are
located
where
winds
would
commonly
blow
the
emissions
toward
the
observed
violations.
Emissions
are
moderately
high
even
after
the
recent
reductions.
EPA
concludes
that
emissions
are
sufficient
to
contribute
to
violations
in
the
Saint
Louis
area.
Illinois
did
not
provide
adequate
information
to
justify
designating
less
than
the
full
Randolph
County
nonattainment,
but
Illinois
may
wish
to
provide
further
support
for
including
just
a
portion
of
Randolph
County
in
the
Saint
Louis
nonattainment
area.
10
There
are
11
other
Illinois
counties
adjacent
to
the
Metropolitan
area,
namely
Bond,
Calhoun,
Fayette,
Greene,
Macoupin,
Marion,
Montgomery,
Morgan,
Pike,
Sangamon,
and
Washington
Counties.
Emissions
for
these
counties
are
relatively
low
and
no
other
factor
warranted
designating
the
adjacent
counties
nonattainment.
Therefore,
the
following
data
summaries
for
factors
3
through
9
do
not
address
these
counties.

Besides
Randolph
County,
Illinois
also
recommended
a
designation
of
unclassifiable
for
Jersey
County,
and
recommended
attainment
for
all
other
counties
in
the
state
that
are
not
part
of
the
recommended
Saint
Louis
or
Chicago
nonattainment
areas.
EPA
intends
to
promulgate
a
designation
of
attainment/
unclassifiable
for
all
counties
that
are
not
part
of
its
intended
Saint
Louis
or
Chicago
nonattainment
areas.

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

County
SOx
NOx
Carbon
Crustal
Composite
emissions
score
Clinton
624
3,717
238
1,067
2.0
Jersey
246
1,755
165
544
1.2
Madison
69,938
37,593
1,563
4,425
16.8
Monroe
244
2,489
206
647
1.6
St
Clair
4,471
11,813
863
1,996
6.8
Franklin,
MO
45,216
15,482
918
2,864
9.1
Jefferson,
MO
52,671
13,612
1,160
3,291
10.4
Lincoln,
MO
221
2,935
273
1,358
2.1
St
Charles,
MO
40,596
25,793
896
2,415
10.2
St
Louis,
MO
30,400
53,358
3,456
2,897
27.4
Warren,
MO
324
1,803
205
674
1.5
St
Louis
(
City),
MO
14,647
27,193
1,214
958
11.0
Bond
177
1,883
137
628
1.1
Calhoun
192
1,162
88
170
0.7
Fayette
290
2,795
223
786
1.7
Greene
196
1,409
159
771
1.2
Macoupin
281
3,123
344
1,415
2.5
Marion
297
3,879
290
891
2.3
Montgomery
38,079
18,254
625
2,230
7.6
Morgan
24,066
6,713
500
1,725
4.7
11
Pike
6,252
4,850
259
901
2.4
Randolph
23,984
33,023
559
1,863
8.9
Sangamon
16,411
19,811
900
2,742
8.7
Washington
167
2,045
199
814
1.5
Crawford,
MO
110
2,199
183
396
1.4
Dent,
MO
100
521
121
431
0.8
Gasconade,
MO
248
1,727
132
393
1.0
Iron,
MO
34,225
1,851
140
291
2.1
Madison,
MO
47
727
86
143
0.6
Montgomery,
MO
364
1,740
145
719
1.2
Perry,
MO
349
2,776
218
531
1.7
Phelps,
MO
754
2,990
244
645
1.9
Pike,
MO
15,205
10,931
206
773
3.3
St
Francois,
MO
697
4,204
328
825
2.5
Ste
Genevieve,
MO
3,666
7,315
255
940
2.7
Washington,
MO
152
1,161
137
322
1.0
Urban
increment:
Total
mass=
6.2
µ
g/
m3
8%
sulfates;
29%
nitrates;
58%
carbon;
5%
crustal.
Urban
site=
295100085;
Rural
site=
MING1
(
Mingo)

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

County
2001­
2003
Design
Value
Madison
17.5
µ
g/
m3
St
Clair
16.2
µ
g/
m3
Jefferson,
MO
14.5
µ
g/
m3
St
Charles,
MO
14.3
µ
g/
m3
St
Louis,
MO
14.0
µ
g/
m3
St
Louis
(
City),
MO
15.2
µ
g/
m3
Randolph
12.4
µ
g/
m3
Sangamon
13.3
µ
g/
m3
Ste
Genevieve,
MO
13.6
µ
g/
m3
Factor
3.
Population
density
and
degree
of
urbanization
including
commercial
development
in
included
versus
excluded
areas:
County
2003
Population
Population
Density
Clinton
35,855
76
12
Jersey
21,858
59
Madison
261,409
361
Monroe
29,058
75
St
Clair
257,904
388
Franklin,
MO
95,890
104
Jefferson,
MO
203,993
310
Lincoln,
MO
42,280
67
St
Charles,
MO
303,030
540
St
Louis,
MO
1,018,102
2,004
Warren,
MO
26,193
61
St
Louis
(
City),
MO
338,353
5,457
Randolph
33,641
58
Factor
4.
Traffic
and
commuting
patterns:
County
County
VMT
Percent
Number
Clinton
375,000
35
5,915
Jersey
196,000
51
5,259
Madison
2,768,000
35
43,125
Monroe
264,000
57
8,172
St
Clair
2,857,000
36
40,389
Franklin,
MO
1,391,000
36
16,422
Jefferson,
MO
2,511,000
63
61,991
Lincoln,
MO
493,000
52
9,622
St
Charles,
MO
2,738,000
52
77,347
St
Louis,
MO
11,553,000
27
134,153
Warren,
MO
348,000
54
6,414
St
Louis
(
City),
MO
4,178,000
40
56,734
Randolph
278,000
20
2,798
Factor
5.
Expected
growth:

County
Percent
growth
1990­
2000
Clinton
5
Jersey
5
Madison
4
Monroe
23
St
Clair
­
3
13
Franklin,
MO
16
Jefferson,
MO
16
Lincoln,
MO
35
St
Charles,
MO
33
St
Louis,
MO
2
Warren,
MO
26
St
Louis
(
City),
MO
­
12
Randolph
­
2
Factor
6.
Meteorology:
Average
percent
of
wind
direction
by
quadrant
County
Northwest
Southwest
Southeast
Northeast
Clinton
28
29
29
15
Jersey
28
28
29
15
Madison
28
28
29
15
Monroe
28
28
29
15
St
Clair
28
28
29
15
Franklin,
MO
27
27
31
15
Jefferson,
MO
28
27
31
15
Lincoln,
MO
27
27
31
15
St
Charles,
MO
29
27
30
15
St
Louis,
MO
29
27
30
15
Warren,
MO
27
27
31
16
St
Louis
(
City),
MO
29
27
30
15
Randolph
28
28
29
15
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
Illinois
has
no
features
that
significantly
influenced
EPA's
intended
nonattainment
areas.

Factor
8.
Jurisdictional
boundaries:
The
East­
West
Gateway
Council
of
Governments
(
EWGCC)
is
the
Metropolitan
Planning
Organization
(
MPO)
for
the
bi­
state
St.
Louis
area.
­
source:
EWGCC
webpage,
http://
www.
ewgateway.
org/
14
The
Illinois
portion
of
the
Saint
Louis
ozone
nonattainment
area
consists
of
the
following
counties:
Jersey,
Madison,
Monroe,
and
St.
Clair.

Factor
9.
Level
of
control
of
emission
sources:
The
State
has
provided
no
information
about
the
level
of
control
of
emission
sources
for
this
area.
Although
EPA
is
aware
that
the
Baldwin
Generating
Station
is
purchasing
low
sulfur
coal
and
has
installed
NOx
emission
controls
on
some
of
its
units,
EPA
does
not
have
information
as
to
the
permanence
of
those
reductions
and
whether
the
NOx
emission
controls
are
operated
on
an
annual
basis.
