INDIANA
DEPARTMENT
OF
ENVIRONMENTAL
MANAGEMENT
We
make
Indiana
a
cleaner,
healthier
place
to
live.

Joseph
E.
Kernan
100
North
Senate
Avenue
Governor
P.
O.
Box
6015
Indianapolis,
Indiana
46206­
6015
Lori
F.
Kaplan
(
317)
232­
8603
Commissioner
(
800)
451­
6027
www.
IN.
gov/
idem
Recycled
Paper
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Equal
Opportunity
Employer
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Recycle
July
15,
2004
Mr.
Bharat
Mathur
Acting
Regional
Administrator
U.
S.
EPA,
Region
5
77
W.
Jackson
Blvd.
Chicago,
IL
60604
Dear
Mr.
Mathur:

The
State
of
Indiana
respectfully
requests
that
you
exercise
the
authority
granted
to
you
under
Section
181
(
a)(
4)
of
the
Clean
Air
Act
to
reclassify
LaPorte
County,
Indiana
from
its
current
classification
of
"
moderate"
under
the
8­
Hour
Ozone
National
Air
Quality
Standard
to
"
marginal".
The
Indiana
Department
of
Environmental
Management
(
IDEM)
has
worked
closely
with
the
Lake
Michigan
Air
Directors
Consortium
(
LADCO)
and
a
variety
of
stakeholders
representing
the
communities
of
LaPorte
County
in
evaluating
the
status
of
air
quality
in
the
area
and
concludes
that
this
reclassification
is
warranted.

LaPorte
County's
current
design
value
is
within
5%
of
a
design
value
within
the
next
lowest
classification
(
marginal).
According
to
U.
S.
EPA
guidance,
for
an
area
classified
as
"
moderate",
the
design
value
must
be
96
parts
per
billion
or
less
in
order
to
qualify
for
a
reclassification
to
a
"
marginal"
classification.
LaPorte
County's
highest
current
design
value
is
93
parts
per
billion
and
thus
meets
this
criterion.

A
reclassification
to
"
marginal"
would
result
in
a
new
attainment
deadline
of
June
15,
2007.
As
illustrated
in
the
attached
Technical
Support
Document
(
TSD),
modeling
conducted
by
the
U.
S.
EPA
and
LADCO
indicates
that
LaPorte
County
is
on
track
to
attain
the
standard
by
this
new
deadline.
Progress
towards
compliance
is
already
being
made,
as
the
2003
fourth
high
8­
hour
ozone
values
for
the
Michigan
City
and
City
of
LaPorte
monitors
were
82
and
84
parts
per
billion
respectively,
both
below
the
National
Ambient
Air
Quality
Standard.
B.
Mathar
July
15,
2004
Page
2.

Modeling
that
was
conducted
by
the
U.
S.
EPA
to
support
the
NOx
SIP
Call
clearly
indicates
that
LaPorte
County
is
adversely
and
significantly
affected
by
transported
air
pollutants.
This
is
further
illustrated
by
model
runs
conducted
by
LADCO
for
the
Lake
Michigan
Area
that
are
summarized
in
the
attached
TSD.
In
order
to
verify
the
significance
of
transport
and
the
potential
impact
of
local
emission
reductions
in
LaPorte
County
on
ozone
concentrations
within
the
area,
IDEM
recently
conducted
its
own
modeling.
The
results
of
this
modeling
exercise
(
summarized
in
the
attached
TSD)
clearly
demonstrate
that
local
emission
reductions,
regardless
of
volume,
have
little
to
no
impact
on
ozone
concentrations
within
LaPorte
County
or
neighboring
downwind
areas.
Therefore,
LaPorte
County
is
reliant
on
regional
reductions
to
attain
the
standard.

IDEM
has
facilitated
several
meetings
over
the
past
two
months
in
the
LaPorte
County
area
to
acquire
input
from
community,
business,
and
environmental
leaders.
While
there
is
some
opposition
within
the
community
to
reclassify
LaPorte
County,
the
clear
majority
of
the
stakeholders
involved
in
this
consultation
process
determined
that
the
pursuit
of
this
reclassification
is
merited
and
is
in
the
best
interest
of
the
citizens
of
LaPorte
County.
Furthermore,
the
board
of
the
Northwestern
Indiana
Regional
Planning
Commission,
representing
fifty­
one
separate
governmental
jurisdictions
in
Lake,
Porter,
and
LaPorte
Counties,
formally
recommended
that
IDEM
request
that
the
U.
S.
EPA
reclassify
LaPorte
County.
This
recommendation,
along
with
other
input
received
from
the
community,
is
enclosed.

Local
governments
within
LaPorte
County
have
recently
adopted
and
implemented
strategies
to
improve
air
quality
in
the
area
voluntarily.
These
strategies
include
the
use
of
cleaner
burning
alternative
fuels,
implementation
of
non­
idling
policies
for
municipal
vehicles,
and
enhanced
public
education
and
awareness.
IDEM
will
continue
working
with
stakeholders
within
the
community
to
identify
and
implement
cost­
effective
local
and
regional
programs
to
improve
air
quality
in
LaPorte
County
and
ensure
that
compliance
with
the
standard
is
achieved
as
soon
as
possible.

Upon
your
review
of
the
attached
TSD,
I
am
hopeful
that
the
U.
S.
EPA
will
agree
with
our
analysis
and
proceed
in
reclassifying
LaPorte
County
to
"
marginal".
If
I
can
be
of
assistance
during
your
review,
please
feel
free
to
contact
me
at
(
317)
232­
8222
or
jmccabe@
dem.
state.
in.
us.

Sincerely,

Lori
F.
Kaplan
Commissioner
Cc:
Jay
Bortzer,
U.
S.
EPA
Region
5
Steve
Marqardt,
U.
S.
EPA
Region
5
John
Mooney,
U.
S.
EPA
Region
5
Patricia
Morris,
U.
S.
EPA
Region
5
Cheryl
Newton,
U.
S.
EPA
Region
5
The
Honorable
Leigh
Morris,
City
of
LaPorte
The
Honorable
Chuck
Oberlie,
City
of
Michigan
City
Marlow
Harmon,
LaPorte
County
Clay
Turner,
LaPorte
County
Bill
Hager,
LaPorte
County
Reggie
Korthals,
NIRPC
