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EPA Air Quality Letter
EPA Docket Center,
Environmental Protection Agency
Mail code 6102T,
1200 Pennsylvania Ave., NW,
Washington, DC 20460
RE: Docket ID No. EPA-HQ-OAR-2005 -0172
Under current Environmental Protection Agency (EPA) ground level ozone standards, west Michigan has been meeting attainment levels - albeit with little margin to spare. If the current 0.075 ppm over 8-hours for ambient air quality standard changes to a 0.060 - 0.070 ppm standard, this region and most of Michigan will be thrown into non-attainment.
A non-attainment status will cause severe economic challenges to this region, which is already experiencing difficult economic times. In addition to increased regulations and restrictions on the development of new industries, non-attainment will also likely restrict our ability to obtain federal highway funds for projects that are vital to this region.
It has been well documented by the EPA that air transported across Lake Michigan from the cities of Chicago, Ill., Gary, Ind., and Milwaukee, Wis., is the primary contributor to west Michigan's air quality issues. In fact, it is stated in the executive summary of the Western Michigan Ozone Study (released by the EPA as required by the 2005 Energy Policy Act) that the ozone levels in western Michigan are dominated by this air transport problem.
Furthermore, the study also states that at shoreline locations, the contribution of ozone-forming emissions from sources in Michigan is negligible.
Until the cities that have contributed to the vast majority of our air quality problems can meet the National Ambient Air Quality Standards, or an alternative remedy is presented, we strongly urge EPA to exempt west Michigan from these unnecessary and punitive restrictions on commerce and activity amongst our citizens.
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