July
15,
2003
Mr.
Thomas
V.
Skinner,
Regional
Administrator
United
States
Environmental
Protection
Agency
Region
5
77
West
Jackson
Boulevard
(
R­
19J)
Chicago,
Illinois
60604­
3507
Dear
Mr.
Skinner:

In
response
to
the
United
States
Environmental
Protection
Agency's
(
EPA's)
request
for
new
designation
recommendations
for
the
8­
hour
ozone
national
ambient
air
quality
standard,
the
Michigan
Department
of
Environmental
Quality
(
MDEQ)
hereby
submits
a
list
of
each
area
of
the
state
of
Michigan
with
an
indication
of
appropriate
designation
of
attainment
or
nonattainment
and
boundaries.
These
recommendations
are
supported
with
an
analysis
of
relevant
information
in
the
enclosed
document.

Consistent
with
the
EPA
guidance
provided,
the
MDEQ
recommendations
are
based
on
air
quality
design
values
in
excess
of
0.085
parts
per
million
for
the
years
2000­
2002.

The
MDEQ
has
considered
factors
relevant
to
regional
planning
agencies
in
Michigan
in
the
analyses.
The
Southeast
Michigan
Council
of
Governments
(
SEMCOG)
has
provided
a
great
deal
of
input
and
data
for
the
analysis
of
their
region.
Consistent
with
our
ongoing
efforts
to
partner
with
agencies
representing
local
government,
the
MDEQ
has
given
careful
consideration
to
regional
planning
programs
(
and
other
applicable
federal
statutes,
such
as
the
Intermodal
Surface
Transportation
Efficiency
Act)
in
developing
these
recommendations
whenever
doing
so
would
not
have
negative
impacts
on
air
quality
improvement.
The
MDEQ
urges
the
EPA
to
also
give
consideration
to
the
concerns
of
regional
planners.
We
believe
that
separating
Combined
Statistical
Areas
into
two
or
more
nonattainment
areas
will
help
make
the
conformity
process
function
better
and
provide
more
flexibility
in
the
strategy
development
phase
of
air
pollution
planning
without
jeopardizing
reaching
attainment.

Our
evaluation
and
recommendation
has
been
complicated
by
the
following
factors:

1.
The
EPA
intends
to
use
a
different
air
quality
data
set
to
designate
areas
than
the
state
has
used
for
recommendations.

2.
Further
complicating
the
above,
the
legal
and
policy
implications
for
areas
designated
nonattainment
for
the
8­
hour
ozone
standard
are
unknown.
The
EPA
has
yet
to
clarify
implementation
and
classification
positions.
The
June
2,
2003,
proposed
implementation
rule
provides
many
possible
directional
options
but
lacks
specific
statutory
language
to
guide
decision
making
in
this
evaluation.

3.
The
criteria
for
definitions
for
Metropolitan
Statistical
Areas
(
MSAs)
are
different
than
the
criteria
the
states
are
required
to
use
in
rebutting
the
presumptive
boundaries.
Further,
the
U.
S.
Office
of
Management
and
Budget
revised
the
MSA
definitions
in
June
2003.
This
action
resulted
in
changed
boundaries
for
many
MSAs
in
Michigan.
Mr.
Thomas
V.
Skinner
2
July
15,
2003
4.
In
the
nitrogen
oxides
(
NOx)
State
Implementation
Plan
(
SIP)
Call
docket,
the
EPA
claimed
that
the
regional
NOx
reductions
would
result
in
dramatic
ozone
improvement
with
fewer
nonattainment
areas.
It
is
necessary
and
appropriate
for
EPA
to
account
for
the
benefits
associated
with
the
phase­
in
of
these
reductions
in
making
designations.
The
NOx
controls
will
all
be
operational
in
the
next
ozone
season
and
many
monitors
are
recording
ozone
levels
marginally
over
the
standard.
The
impact
of
the
NOx
reductions
is
not
reflected
in
the
data
used
for
the
recommendations.

5.
Overwhelming
(
not
regional)
ozone
transport
is
the
sole
reason
for
nonattainment
levels
of
ozone
at
many
monitors
in
Michigan.
Community
support
for
nonattainment
designations
and
positive
actions
within
some
of
these
areas
is
hindered
because
such
a
designation
results
in
regulatory
mandates
based
on
the
erroneous
premise
that
a
local
area
should
be
held
responsible
for
their
air
quality.
Some
of
the
"
ozone
receptor"
counties
in
West
Michigan
have
minimal
industry
and
are
very
sparsely
populated.
Local
emission
reductions
do
not
reduce
ozone
concentrations
at
shoreline
monitors
even
in
counties
with
urbanized
areas.

Michigan's
track
record
in
achieving
all
national
ambient
air
quality
standards,
including
ozone,
should
weigh
heavily
in
EPA's
decision
making.
The
state
has
a
proven
record
of
applying
controls
when
necessary
beyond
nonattainment
areas.
Ultimately,
the
need
for
the
degree
and
expense
of
controls
will
be
decided
upon
after
a
thorough
technical
analysis
undertaken
in
the
SIP
development
process.

We
look
forward
to
working
with
EPA
as
you
develop
the
final
designations.
If
you
have
questions
regarding
our
recommendations,
please
contact
Mr.
G.
Vinson
Hellwig,
Chief,
Air
Quality
Division
(
AQD),
at
517­
373­
7069;
Ms.
Mary
Maupin,
AQD,
at
517­
373­
7039;
or
you
may
contact
me.

Sincerely,

Steven
E.
Chester
Director
517­
373­
7917
Enclosure
cc/
enc:
Governor
Jennifer
M.
Granholm
Ms.
Cheryl
L.
Newton,
EPA
Mr.
Chuck
Hersey,
SEMCOG
Ms.
Dana
Debel,
Governor's
Office
Mr.
Jim
Sygo,
Deputy
Director,
MDEQ
Mr.
G.
Vinson
Hellwig,
MDEQ
Ms.
Mary
Maupin,
MDEQ
