 Craig Summerfield. He is Wisconsin Manufacturers and Commerce Director of Environmental and Energy Policy. Prior to joining WMC, Craig spent nearly 15 years working in the Wisconsin State Legislature, formerly for Senator Lemahue, who has joined us today also. Including time as a policy advisor in the Assembly Speaker's Office and a Chief of Staff in the State Senate. Craig serves as the WMC representative of the Wisconsin DNR's Air Management Study Group, Drinking Water and Groundwater Study Group, and Brownfield's Study Group. Please welcome Craig. Thank you. My name is Craig Summerfield, Director of Environmental Energy Policy. I already talked about my background. I serve as WMC's representative for the Air Management Study Group, Drinking Water and Groundwater Study Group, and the Brownfield Study Group. The first two do meet on a quarterly basis, and we actually had an interesting meeting in the Air Management Group, which I will talk about a little bit later. And also, again, served in the Legislature for about 15 years. Was happy to serve as Senator Lemahue's Chief of Staff for about five years, so I appreciate seeing him here today to correct me on anything that I might get wrong today. And one of the reasons I just want to talk about my background is in political science, and I also have a master's in business. But I'm not, just to be clear, I'm not an environmental compliance officer. I'm not going to be able to offer great suggestions on what kind of emissions, you know, what kind of retrofit needs to go in a smokestack for emissions testing. My background is in legislation and rules management. So that's going to be the focus of my remarks today. So I wanted to hit three items. First, I do want to talk a little bit about Highway 23, not obviously directly related to my to my environmental role, but a couple of things. One, had a chance to drive up 151 over to 23 today, and let me tell you, it was really enjoyable to be able, once we got to that Cheboyon County Line, to finally drive on a four lane, four lane highway there. And real I mean, just after I know, I believe folks in this room, some had waited for 4050 years for for that, for that expansion to finally be completed. And it looks like, you know, knock on wood, you're just approaching the finish line there. So that's, so that's pretty exciting. Other reason I have that on there is that there was the biennial report issued by the Department of Transportation. That's the Transportation Projects Commission report. And that will talk a little bit more about the costs that have been incurred so far and what's expected moving forward. And I thought it was a so I happened to pull that this week pretty positive report, and I'll just highlight a couple of items on that. So that's the first point. Main reason I wanted to chat with you today, and I again appreciate the invite from the Cheboyon Chamber is talk a little bit about ozone non attainment. Certainly a lot of challenges facing Cheboyon County on that. Most recently with an EPA decision made last summer to actually expand again the boundaries in relation to the 2015 ozone non attainment standard. So I'll talk a little bit about the history that then talk about what happened with that with that EPA decision and then what steps if any can be taken moving forward in relation to non attainment because there's something very important to the business community. And then last I do want to talk about PFAS. If you're not familiar with this, there is a lot going on in the state and federal level in relation to relation to regulation on PFAS. And if you think it doesn't affect you, particularly if you're a manufacturer, I urge you to consider that these regulations could have an impact on you. So I'll wrap up with that. And again, just looking to provide timely information on the topics I mentioned and help folks understand how these regulatory changes could impact local businesses and then understand where these various regulations are in the process. So again, so again, Highway 23, and I mentioned that there is a that there was a report issued on Monday by the Transportation Projects Commission at the Department of Transportation. And they do this, they do this on a twice yearly basis. And I just wanted to highlight a couple items. And if you can't see in the back, I'll highlight what I'm talking about here. If you look at, you know, the cost, the cost of date, you can see that most of the items have most of the expense has, or most of the costs have been expensed, as well as the other item I wanted to point out was right. If you can't see in the back is 173.4 million. That was the estimated cost in August of 2021. And it's estimated to stay at 173.4 million. And as of February this year. So that's that's encouraging, you know, that means it appears that it is staying, it is staying on estimate. And I also highlighted a couple of the project costs, design costs have gone up a little bit, but construction costs have have gone down. I find that kind of funny, you know, it, you wonder what the Department of Transportation is doing to tweak the numbers that it just so happens that in one section, the cost went slightly up. The other section costs went slightly down. And then you end up with with with something where the costs are actually are actually identical. I think that's kind of suspect. But at the end of the day, the takeaway is that cost costs on that issue have not have not changed at this time. And then this this next charge is kind of highlights cost complete. And I'll note they right up here, right up there, what's where it says encumbered encumbered or committed not yet expense to 26.1 and only 2.2 million remaining in fiscal year 2022. That still needs to be committed. And then 0.4 million in fiscal year 2023. So So what does that mean? That means the majority of the monies committed to to go out the door. And there's a very small amount remaining for the current fiscal year or currently in the 2022 fiscal year, and then a little bit in the in the following fiscal year. So nearly all of the project costs over 98% has been encumbered, encumbered or committed. Again, I think that's that's positive news coming out of the Department of Transportation. To me, it's it's another indication that knock on wood, there's not going to be any any additional delays with with getting this with getting this project done. I've asked I remember asking previously, you know, what would be that 0.4 million in 2023 and kind of given the understanding that would be, you know, landscaping stuff along stuff along those lines, not actually impacting the the traffic and the ability of four lanes to go to go back and forth between between Fond du Lac and shabuigan. So and again, I think many, if not all of you know, highway 23 scheduled to conclude with the resurfacing of their the final the final phase is the resurfacing of the existing lanes. And that's expected to to occur later this year. And the project is expected to be done at by call this year. So with that, I can pause I can pause quick. And again, this was more of a actually, and I I didn't want to cite. And this is one reason I want to bring this up back when I worked for Senator Lemahue. I remember shortly after the decision was issued by Judge Edelman that that blocked the the four line expansion was initially supposed to happen. Well, the last time supposed to happen back in back in 2015. Remember getting an email from someone and he from a gentleman, he just kind of raved about the block it about blocking the expansion and all the problems with it. And that is requested. And then his note was I'm going to ask my my grandkids to have my ashes spread along 23 some, you know, somewhere west of Plymouth with the hope that one day I will my body will be able to enjoy a four lane four lane highway between between Fond du Lac and and Plymouth. So so and again, I just want to say, you know, I keep knocking on wood, but you know, a real kudos to the to the local to the elected officials in this room to the Schwoig and chamber. I know SCEDC also advocated that advocated for this, that that this project is almost almost over the over the hump and and hopefully will, you know, you'll have a four lane highway between between both Fond du Lac and Plymouth. And that's obviously important for, you know, infrastructure, but also safety, reducing all those accidents that occurred along those highway along that highway. So again, just want to talk about that a little bit. Any any questions or or anyone want to jump in on that before? And again, I'm not a highway, I'm not a highway 23 expert anymore. I just wanted to, or I should say I wasn't a highway 23 expert. But I wanted to highlight this this report since it just came out this week. And I thought it was a nice snapshot of what's going on with the highway 23 expansion. So anything on that, if not, I can move on into the exciting world of ozone non attainment. Deidre, I like your excitement. So so moving on to ozone non attainment, lots going on in this in this realm over the past year plus past couple years frankly, and certainly certainly different decisions coming down from the EPA that are of importance and of impact to Sheboygan County. So just a little, just to take a step back, you know, little ozone non attainment 101. Under the Clean Air Act, EPA periodically reviews ozone standards, it can keep the existing standards or or propose new ones. And then the EPA using state data determines if an area is in attainment or non attainment of upset standards, you know, an area in non attainment will face stepped up enforcement actions from from the EPA, and also the Wisconsin DNR is required to implement or required to submit a state implementation plan to demonstrate to the to the federal EPA how the state will will meet these plans. And if again, and if the state is unable to demonstrate that, that's where that's those stepped up enforcement come into play. So, so these standards have been adjusted a number of times going back to the own going back all the way to 1971 79, you can see that they gradually go down. I'm not going to spend too much time today talking about the 79 or the 97 standards because they're largely moot. I believe both were actually revoked in the early in the early 2000s. And we don't and we don't have many concerns over the over the 71 standard as well. Folks here that have been following this issue are probably most familiar with the 2008 standard of 0.075 parts per million and 0.070 parts per million for the for the 2015 standard. And then again, as I noted, non attaining the concerns of primary focused on those last two, I mentioned at the at the top of the slide that the the EPA will periodically review ozone requirements. In 2020, the the Trump administration did do that. And they and they determined not to make any revision to the 0.070 standard for parts per million that you see before that. That is something now that the Biden administration has said they are reviewing that decision, not to review, not to change the the 0.070 standard. So they have said that they plan to issue a decision on that by the fall of, excuse me, by the end of 2023. So I bring that up because even if we dig ourselves out of the 2015 standard, there could be more problematic standards on the horizon. So just just certainly something to to keep in mind on that. Just wanted to go through and this is this is a recent history. You could definitely go go further on that. Again, you had the EPA proposing that 0.075 standard 2008. And then all of Sheboygan County was that was designated as non attainment in 2008. And then in 2013, you actually had that was the initial petition, as I understand it to excuse me, getting our petitions, the EPA to reduce the size of the of the ozone boundaries in Sheboygan County. Then obviously you had that second air quality monitor established at Sheboygan Haven. You've obviously got the the first monitor right along the lake shore at Kohler-Andre. And then you've got the the second monitor more inland at Sheboygan Haven. And the Sheboygan Haven monitor is a better reflection of the emissions that actually occur in Sheboygan County, as opposed to the Kohler-Andre monitor, which which is primarily out of state emissions. And I'll talk I'll talk more about that in a bit. And then this 2018 EPA goes ahead and designates part of Sheboygan County attainment part of non attainment in relation to 2015 standard. And then in 2019, the EPA formally split Sheboygan County into two distinct non attainment areas, inland and shoreline. And that they were actually responding formally to that 23rd all the way back to that 2013 petition from Wisconsin DNR. And that that's where you had the two, you know, you have inland Sheboygan and shoreline Sheboygan County for for ozone attainment. And then finally, and then many of you probably remember this, EPA formally redesignated both inland Sheboygan County and shoreline Sheboygan County as in attainment of the of the 2008 standard. That was a that was a big, you know, that I remember working as a legislative staffer for Central Avenue at the time. And that, you know, obviously that was a that was a big step forward for the area. And that was kind of a what what we thought or what I thought was a was a light at the end of the tunnel moment in relation to non attainments and and the regulations. But and then again, I just want to this was the this was the initial, quote unquote, final. I say final because that was that was the word that was used by the EPA in 2018. This was the original designation for for non attainment in Sheboygan County for the 2015 standard. And you can see how it follows along I 43 there, but does jut a little to the west for further south of that. So that was that was the initial final. But you had this you had this outstanding court case. And again, I mentioned in 2018, EPA designated attainment all but narrow areas of certain counties. And this included Sheboygan counties along Wisconsin's Lake Michigan shoreline. And this designation was challenged by by Clean Wisconsin, the state of Illinois, the city of Chicago, and, and other entities. So again, you had a situation where the where the EPA 2018, they issued this designation. The designation you saw right here, it was challenged in court. It was challenged by multiple parties. Those those court cases were all consolidated. And then in 2018, the DC Circuit Court remanded excuse me, that's 2020. The DC Circuit Court remanded the EPA numerous area designations for the 2015 ozone boundaries. The court determined that some of these designations were arbitrary and capricious. So so basically required the EPA, hey, you should you should be reexamined. You should be reexamining the the boundaries that you put in place. And again, I apologize. That's that's 2020, not 2018 on on that move. Now we come to 2021. EPA issued new greatly expanded non attainment boundaries for Wisconsin as well as several other states. And I will show a map in a moment here that kind of goes through the the new, the new revised vastly larger on non attainment boundaries for for Wisconsin along the along the lakeshore. And I also want to make clear, there was no opportunity for the DNR or the public to comment. These that these designations were final. So typically when when the EPA does this, you know, they'll propose the designation, and then regulate entities as well as the state as well as the public have an opportunity to comment and say, you know, hey, that's this is why we like that idea. This is why we this is why we don't like that idea. You know, hey, did you consider this? That's not what happened with with these new boundaries. The EPA just said, Nope, we're responding to a court to a court to a court case. We're going to do this. We're going to do it today. I believe it went into effect approximately two months, two months later, and we're going to expand the boundaries across across Wisconsin. And then there were expanded boundaries and in other states as well. And if you don't like that tough, these these are these are the boundaries now. And then I also do want to know it without getting into the rationale as to why they why they did this, I want to know that again, we're talking about 2015 ozone boundaries. So so the EPA went back and they interpreted data from 2014 to 2016. You know, for example, they're pointing at the Edgewater Generating Station as a as a key contributor to emissions, which as I understand it, I believe is scheduled to close it at at the end of this year. So I mean, again, setting the whole whether or not that's appropriate. I mean, certainly, I think it's very frustrating for the for the business community to see this, to see them interpreting data that's that's several years old, not not relying on the most current data. And then really not also offering businesses, the public, or or even the Wisconsin DNR to actually submit comment on that. It was just it was just this this is it. And you're going to have to deal with it. So what are the new boundaries? The new boundaries are much larger than the old boundaries under the under the 2015 standard. You can see the very narrow pink strip there, which which again is still is still a concern for Sheboyin County businesses and and many others across the state because there's a lot of people in that narrow strip land. But you can see the very narrow strip that was initially approved by the EPA for the 2015 boundaries in 2018. And then that green area is is you know, the vastly new 2015 ozone boundaries, Kenosha, Milwaukee, Ozaki, Racine, Waukesha, Washington, Sheboyin obviously, Manitowoc, Dora County, including some counties that were not included at all. Initially under the boundaries were now included in these in the expanded boundaries. And again, no no opportunity for public comment just just boom we're done. Can't hear boom I was looking for like a boom, you know, if I pointed the mic directly at the at the podium, maybe that that would be better for I could I could clap I suppose that maybe that would be that would be more more effective. But again, no opportunity for comment Manitowoc, Dora County, the new boundaries. So I'll just I'll just go through here. You know, we don't have to spend a lot of time on each one of these. But you know, Kenosha County moved west to to I 94. And then look at this one. This is the this is southeast Wisconsin. This is considered the Milwaukee area. So Racine, Milwaukee, Waukesha, Washington, Ozaki counties. So look at so you know, Ozaki County further west Washington that was not even included. Now now finds itself under a 2015 ozone standard. And then you've got Waukesha County there again was not included initially not included at all. Now nearly the entire county included in the 2015 standard. Milwaukee County, which is just just part of the northern part of the county now now all of it. And then also and we'll talk about this a little bit more soon. But know that Racine County was not initially included in the or was not included in the 2018 boundary, I should say. But then when the EPA revised it in 2021, again, now now it's included. And yes, that does that does matter. And I'll talk about that. Again, I'll talk about that in a second. Manitowoc County again, pushing, pushing, pushing the boundary westward and then Door County, which was just the narrow area around. What is that? Just around Newport. Thanks, Mike. Just around just around Newport and then instead, nearly all of all of Door County. I will I will say it as a as an aside here after these designations came out the what happened was is that for some of these counties, I believe in particular Manitowoc and Door, the latest data actually demonstrated that they were in compliance. So I believe. So subsequently, the DNR submitted requests for for to demonstrate that those counties are are in attainment. I believe the the door one may have may the door in Manitowoc are either pending or or or they might be in final review for a final rule, the final review, the final rule by the EPA. So that is it. I mean, that is encouraging. Sheboyin County is not it's not so lucky in terms of being able to submit or by request to the to the EPA. And then again, finally, finally, Sheboyin County moving the moving the line west of west of I of I 43. And again, I want I want to emphasize, you know, there's a lot of people in a lot of businesses. And so it looks it looks like a really small move. But I think everybody in this room knows there's a lot of there's a lot more people in the eastern half of the county than the western half of Sheboyin County. So so it's a significant impact. So so what happened after so again, the EPA did this no opportunity for comment done. It happened too bad. So sad for those that are that are stuck with the new non attainment areas. I do want to know that on August 13th of last year, the DNR filed a petition for reconsideration with the EPA on narrow grounds. And then they noted the following one. As I mentioned, there was no opportunity to public comment. The EPA just did this boom done. And then I'm going to I'm going to read this quote and then EPA's action does not address the primary causes of Wisconsin's ozone non attainment, which has repeatedly been demonstrated to be driven by out of state emission. And this is again, this is a claim being made by our current by our current DNR. This was signed by the former deputy secretary, Todd Ames, right. He he has since he has since retired, but was signed by by by the current DNR. And then again, expanding Wisconsin's non attainment areas will have little to no impact on air quality and only serves to create to create regulatory uncertainty. So that I think that's kind of something that's the that the petition got right. An area of concern with the petition is that it really focused too much of its concerns with door counties revised boundaries. It talked about how door county was in kind of an awkward spot. And where did you come up with the with the issues for door county? And I agree, they they got it wrong with door county, but they also got it wrong with the rest of the state to, including Shaboy County. So what have been nice when the when the DNR made this made this petition that they had actually said, well, you got it wrong in door county, you got it wrong in Racine County, you got it wrong in Shaboy County, and you got it wrong in in Southeast in the rest of Southeast Wisconsin as well. But this was filed. It was acknowledged by the. But when I say that EPA has not responded, they they have acknowledged receipt of the petition. They have not otherwise responded to it. And we we don't know if and when the DNR will get a better response. I will note yesterday, we had meeting of the air management study group that I that I mentioned earlier, and I asked the air program ahead. Hey, have you gotten a response to your petition yet? And the answer was no, not and not any additional follow up on on that at this time. So certainly certainly some some unfortunate developments. Where am I at here? Hey, what does it matter? So so again, EPA has dramatically expanded areas in eastern Wisconsin that are subject to burdensome ozone. And then again, since out of state emissions contribute so heavily to the non attainment designations, Wisconsin businesses and consumers are largely at the mercy of actions of out of state actors and lowering their emissions. And many of you know this already, but about already iterated. According to modeling analyzed by the DNR, only 12% of the emissions measured at the core on remodeler are actually from Wisconsin sources. So Sheboyin County businesses and consumers have very little ability to actually control their own their own emissions. We have there's a standard of up here in Sheboyin County and another parts parts of the state that have been imposed by the EPA that businesses and consumers are largely at the mercy of other states. And to some extent, even other countries in terms of how to get of how to get those those emissions reduced and get back into get back into attainment of those standards. And I just wanted I wanted to highlight this. This is something that was put this is directly sourced from Department of Natural Resources. Again, some of you may have may have seen this before. But this looks at using modeling, the contribution towards air emissions measured for ozone at the color on during monitor, you'll know the biggest contributor as of 2017 was it was Illinois. The ICBC, I believe, is just a it's just another term for out of state or out of country. It's certainly it's certainly not it's certainly not Wisconsin. You'll see Wisconsin's third, Indiana Central, I think is a consortium of different states. This looked at everything up to one percent of contribution of emissions at the measure of the color on during monitor. And you'll know that last one other again, it's just that's that's just different there. So that was that's what the their model looked at 2017 2023, much the same story. Looks like Wisconsin looks like Wisconsin jumps from 12 all the way to 13 percent, perhaps, still, you know, and again, that's Wisconsin, that's not just that's not just your William County. Again, Illinois being the biggest contributor going down to Indiana, you know, again, this monitor is measuring emissions from, you know, Chicago, Chicago, Illinois, Gary, Gary, Indiana. And it's really it's not an accurate reflection of the of what's being generated locally, nor is it an accurate reflection of the airman of the air quality in Sheboygan County. It is a projection. Yes. Yes. Yes. Sorry. Yes. That yes, this is modeling. Yeah, we don't know. We can't look or I don't know. You can't you can't. I don't think you can actually take take or maybe you can't scientists do crazy things. Take a particle of air and say, yeah, this one's from, you know, Indiana, this one's this one's from this one's from Chicago. But yes, you were 100 percent right. This is that that is a projection based on based based on modeling that was analyzed by the by the Department of Natural Resources. Oh, and I was asked to repeat the question was to confirm it was a projection. And yes, it is in fact a projection. So any other any other questions, points on Mike, go ahead. I do not. I will say the question was, does this inventory in 2023 that does the modeling exclude the edge the edge water generating station, which as I mentioned earlier, is is scheduled to be retired at at the end at the end of this year. And so does that does that modeling account for that? That I don't know this was pulled from the DNR's application to the to the EPA in 2020 in February of 2020 to redesignate Sheboygan County inland as being sorry, Sheboygan County shoreline is being in attainment of the 2008 standards. This is from this is from sorry. So long story short, it's from a 2020 document early 2020 document produced by by the the EPA. I don't. Yeah. The the shorter the shorter answer is I don't know, but I be happy to happy to follow up with you on that. But that's that's a really good question. And either. Yeah, go ahead. We're suing the EPA. We're suing Illinois. What's going on? Because this is all ridiculous. You can shut down Wisconsin or Sheboygan County business and we would still be not attainment. Why is Wisconsin? Maybe this is for the legislators. Why is Wisconsin not saying enough enough? The gloves are off. So the question is, given given how little or not at all Sheboygan County businesses can actually reduce reduce their own their own their own emissions, why hasn't the the state taken taken actual legal action against against Illinois or or or against against the EPA? You know, that's that I think that's that's a that's a valid question. I will note in conversations I've had, there's always a there is a reluctance. You know, there's there's something in the EPA called the good neighbor provision, which which which is basically like you can you can file a petition with with the EPA saying that your neighbor has in this case, Illinois or perhaps Indiana is not fulfilling their obligations under the Clean Air Act. Traditionally, it's my understanding that traditionally states have been reluctant to take that action because you accuse your neighbor of something, your neighbor starts accusing accusing you of something and it kind of it kind of goes it kind of goes down a rabbit. Yes. Yes, they were yes, they were party. So that that could be that would be a that could certainly be a counter argument. I don't believe they I'm not I'm not going to say for certain. But but yet to your point, yes. The question was didn't in Illinois suit. And yes, Illinois was was one of the folks that that sued along with the Queen Wisconsin and the city of Chicago. And again, those those lawsuits were were consolidated. I'm still I'm still thinking I'm just thinking a second on I mean, it is it is a valid question. You know, the I guess and you know, I will I will say this, I have asked I have asked the DNR Air Management folks, hey, is there any consideration over over legal action by by DOJ? And I was not I was given a not I was given a non answer. I was told it was, you know, was legal matter matter and they could not could not comment on that. But I mean, it's I think it's I think it's a fair question. And but I'm not I'm not an attorney. I'm not going to, you know, discuss the whether or not it's it's the perfect legal strategy. But I will I, you know, obviously there's consequences anytime anytime you anytime anytime you seek a you seek a lawsuit. So so what is WMC? Well, we're educating the public for. So the the the question is the the the question is what is what is what is WMC doing? We've certainly we've certainly had not been shy and I'm pushing the pushing the DNR in terms of in terms of air mission right regulations, not not just in relation to ozone, but but but other but other issues but but other issues as well. I mean, it's it again, I just say it's yeah, obviously it's a it's a very it's a very challenging issue. I guess I'd say be happy to chat to chat further further with you afterward or I can I can bring it up. I can bring it up to superiors in terms of your your question on addition. But but certainly we're but certainly we're continuing to push push the DNR we're continuing and continuing to provide comment when when we're permitted to and work to fight back on on these standards because yes, they they are incredibly problematic over here and then here and then there. I just find it very curious that you know all the manufacturers, which we've got a ton of wonderful manufacturers and Chihuahua County I know for a fact I've worked for one for decades. There are rules and regulations that every manufacturer needs to abide by whether it's dust emission, noise emission, you name it and to me if you've got all these other businesses that are producing product and they're all all under the guidelines whether it's EPA or the DNR that okay, life is good and then you and then we come up with these type of these you know these types of graphs and grids where we're not really measuring anything these are all kind of projections and modeling I guess it's just one in one doesn't equal two in my mind because if all the businesses that are producing product are under the regulations and the guidelines you know how can you get results that look like this? Can I weigh in on that because this is a deja vu situation sure and I think it might answer Scott's question we could shut down everything in Chihuahua County and it wouldn't make part of the argument that we've had for Dave and I and maybe a few others in the room go back to when your predecessor spoke to this group and that launched us into the project that got the Haven Monitor we were able to generate data that showed that this area was entertainment we could shut down everybody to the south and it wouldn't make a difference we'd still have ozone picked up and would still be in non-attainment the only way we're going to get out of the situations is if we build a bunch of fans going to here and blow everything back and then see how they look that doesn't make any sense but it makes as much sense as this whole situation alright Deidre I'm going to try to sum it up no that's okay okay alright alright good no I I first of all that comments very well to yes this is you know it's really unfortunate that Sheboygan County businesses are suffering due to due to emissions from other states and to your point it is very it is very frustrating when you've got businesses and manufacturers that are meeting a myriad of requirements and yet we're still being told by the EPA no you're not doing it right no you're not doing it enough no you've got to face these ozone non attainment regulations when again this is as again this shows this DNR modeling shows this is an issue that is that is generated by this is this is an issue created by forces that be by emissions from outside Wisconsin and I do have a couple slides on potential next steps so I think if you don't mind I know there's one other hand raised but I'll I'll keep going I'll try to finish out part of this section and then but and then we can talk a little bit more about potential next steps or next challenges but I know there's one other hand raised in the back go ahead oh I thought sorry I didn't see you hurt she wanted to go and then yeah yeah that'd be that'd be great that'd be great go ahead okay the the the first point was in regards to concern over over Sheboygan generated emissions and the question was does it impact does this impact all Sheboygan businesses or is it just a narrow a narrow subset the the businesses that be more most directly impacted would be those with an air permit so if you need if you need to so if the business needs to needs to expand then they they essentially have to find a you know emissions reduction credit from from elsewhere in order to in order to do that and obviously that's a significant regulatory hurdle for for businesses and I do want to talk about it so when I so when I talk about that I do want to mention an example and I've got that next and then I know you mentioned concerns about emissions measured in Sheboygan County and I do have a slide on that so I'll get I'll get to that in a moment if you don't mind so I'm going to continue on here if I if I may and then is it Chris yeah so I'll I'll let Chris I've been towards towards the end here and can can provide a federal update which which is certainly appreciated so so again talking about the where was it yeah talking about the monitor so again so why so why does it matter so so last month as many of you probably saw Intel announced plans to build a massive chip manufacturing complex near Columbus, Ohio Mount Pleasant, Wisconsin may have actually been Intel's second choice and this was according to an article by the Milwaukee by the Milwaukee business news and again according to that and that this again would have been a huge project looking at a $20 billion capital investment 3,000 jobs average annual salary $100,000 again according to the same to the obviously that's that's not nothing according to the same article the state and local incentives were were not the issue however and again I'll quote officials say Intel appeared satisfied with their incentive package one concern that they say that the company did raise was uncertainty over the ability to obtain air credits in the future for its anticipated expansion Racine County lies within the EPA air pollution non-attainment zone the Columbus Ohio area including the site chosen by Intel is considered to be in attainment so that's that's one and again do we know no we no we don't know I mean this this is based on interviews with Tim Sheehee with MMAC and as well as local economic development folks in Racine County so we don't know we don't know for sure but I will go back to this slide right here again Racine County under the 2018 final boundaries was not was in attainment of the 2015 standard they turn they turn around the 2021 boundaries you can see right you can see right there in the blue they are back they are back in non-attainment and that may have been they may have been a key factor in in Intel not not sighting in Wisconsin and this is something again that this did come up with the the Intel article did come up with the Air Management study group yesterday excuse me and this was something that the Air Program had said could have she didn't say did but she said could have played a factor in terms of getting emissions credits and the attainment status of Racine County so I think so that's obviously you know in terms of examples that's a big one but I mean that I think it gives an idea in terms of what the consequences to a attainment versus a non-attainment designation can be for a for a county I just looked at my watch and I'm behind so so I did want I did want to look at look at this so this is again this is straight from a DNR DNR document Ozone Design Valley is Sheboygan County and there are three lines there the red line is Sheboygan Colerandre measurements the blue line is Sheboygan Haven you can see it's much shorter because it's because it's it's more recently installed and then the the dotted line there is the Ozone you know is the relevant Ozone standards and the reason I wanted to highlight this to the question earlier you can see a gradual not a fast by any stretch of the imagination but you can see a gradual decline in the historically at least in the in the Ozone measured in Sheboygan County and this is consistent with with statewide you know the you can go online and take a look at the DNR's latest air quality report Wisconsin is cleaner air than we than we ever have before and that and that reports readily available if anyone wants wants a copy feel free happy I'm happy to send it and then looking ahead again an initial look at the so this is a look back looking ahead 2022 Ozone this is the cause for concern so if you see the if you see the bottom line there the the measure the measurements as of December 31 2021 2021 was not as good of a year for for Ozone Ozone measurements and then the estimated 2022 critical values you'll see where it says 2015 standard you'll see 64 so that means the critical that means the value measured the critical zone value measured next year would have to be 64 in order for Sheboygan County to be able to apply next year to get a you know to to be an attainment of the 2015 standard so that is that is absolutely a challenge that's it's an it's an ongoing challenge facing Sheboygan County there's there's no way around it and then my my last my yes my last slide here you know again based on current data Sheboygan County appears unlikely to to reach attainment of of 2015 standard this year and again and this is where Chris if you want to talk for a second but again we'll need to continue to monitor the reconsideration petition seek a re-designation request as soon as it falls before the necessary values and then again I want to point back we do have a trending down line so you know hope that that line continues to to trend to trend downward for for next step but I know yeah Chris if you want to talk a little about what's going on Hi everyone Hey Chris from Congressman Grossman's office Congressman's office is out of fondle act but obviously this is an issue that's been going on for more than 10 years but I think there's a lot of positive things that have been done to what WMC does they provide a tremendous outlook and into our business community about what numbers in real time are coming out but another thing to be noted is that you know when we had the change of administration here so when we saw the split of the designations from the shoreline to the inland that was a very positive thing for a lot of our area in the county because it was just that sliver and just that sliver that usually gets out of attainment and this isn't all just because as far as the lawsuit level the lawsuit level is kind of a last ditch effort you know that would be heavily on to the state of Wisconsin and probably burden the state quite a bit however you know if we could look at it from an administrative point of view when we look at the Haven monitor and the Kohler Andre monitor if you went back to that slide now when we took into Kohler Andre out into the shoreline of that that's where we're paying too high so and I believe when we look back at where those monitors and the placement of those monitors I believe that was Governor Doyle that place that monitor out into the lake so when we talk about trans it was before okay so EPA but then the state you know with EPA in so far as if we could read that Haven monitor however if we need to come into compliance we have to have solid readings for a handful of years in attainment before we can select to move the monitor so even with that if we could get that administrative change you saw the Shabuigan County problem now when we look up to it you know if we look from door brown all the way down that lake shore this is now spread to the point where I always point to Door County is like look this is you know Shabuigan County and a lot of that lake shore and paper mills everything we have a lot of manufacturing Door County doesn't have anything but you know Illinois traffic is up there that are saying they're out of attainment and too high now this becomes you know I think this in our aspect strengthens our case to show look this is transport pollution this is you know this is naturally occurring ozone you know the ozone that occurs you know with weather patterns on the lake you know so again we're it's known that shutting down you know when we had the change over administration too it is worth noting that this wasn't you know the split happening you know shoreline in England was not some Trump administration thing to shred the documents and say hey we're going to be in compliance because this is all good these are career EPA folks for Region 5 that know and are very well versed in the areas and what we need and what we and the specific situation we have I think the there was only one county in the country that even got close to the issues we have and that was down in Texas so this is very very unique to our to our region and to our like to the United States as a whole so again one of the reasons they don't want to necessarily change and just pass green light okay you're fine even though I think there are huge amount of career people at EPA that would love to do that for Sheboygan County is because it would then now with the new standards in the 2015 standards as more and more regions are going to have trouble with it they're they're not going to you know just rip it out for the books just for us even as much as they want to so I think there are a lot of administrative fixes that still can occur because I think again our business community you guys are in the right you guys are doing the right things you know as much as painstaking as it is to keep going through this but I think that there's a lot of positive things that have been made and that's two efforts like WMC you know federal state DNR all doing a tremendous job so I think like anything this is a big you know the federal government itself is you know that big barge and then you know to get that barge to turn is very difficult to do but this has been very like a long ongoing process but I think we're making a lot of positive steps and I should note if anybody you know specifically to your businesses or business communities I think that's the strength in the fact that he said that you know they didn't open common period for when they you know the Biden administration this summer did not open for open common period for when we wanted to adjust these boundaries so I think we still have that on our side as well while it doesn't help in the short term and everything I think you know the momentum of where this is going but issue quite a long time with the congressman and then his predecessor Mr. Peter as well so this has been going on a lot but I'd say during the last few years we've seen a lot move in this space that has benefitted the county and the region so I don't know if there's any questions or they threw out the numbers they did not say were they didn't dispute where we ended up on those numbers they disputed how we got there and they said you've got to take more time to show your work which they worked through and did a lot of the ozone that is generated for the coloreandry site is generated during the summertime when the sun is hitting what's over top of the lake so it would be for me it would be interesting to see what the perspective is I'm sure an EPA does but where we saw they got to take the aggregate so some days will be high some days will be low it's the same thing with the water testing where you see a beach closed one day for your coli and then the next day the beach is open and the coli is gone it's always another sky day there could be where the jet stream is coming from so when we're trying to then okay so we'd say maybe it would be a clear day cooler day for the summer so the ozone wouldn't be as bogged down however what if we got that south wind coming up and then we were getting ozone brought up from the transport pollution from Chicago so again I think the aggregate is a strength as far as naturally occurring but then once we couple it with the good neighbor clause of well someone can try to say well on that day though it was nice and it was a Friday so a lot of people were driving up on 43 to come through so we get into again if we're looking at the metadata it'd be great if we could say 30% of the ozone is naturally off our books so our average can come lower even with our transport pollution that were good and as we've seen we're almost there to where everything being down I think the border where that border on that southern part of the county is going to be drawn is a big question mark and I honestly don't know how much input they're looking for for EPA as far as open comment I think that again a lot of people have been gone to the same people over in the EPA office but I think it's great to again register those register the things because even that slight border adjustment would be good and beneficial for the county but yeah I think once we start breaking it down into smaller aspects we could start looking at a lot and I don't know that feds or state is willing to take that on for a wrap I had slides on PFAS but we didn't get there but I think we had a really great discussion on ozone and on attainment and I think next time I come up I'll have you guys all lecture me and we can figure out more about this very challenging but very important topic so with that I will stick around for a few minutes if folks want to talk but I really appreciate everyone taking the time and hang on get to the end there we go and Wisconsin Business front of the environment our annual awards coming spring 2022 so please don't be afraid to nominate business so thank you very much for your time appreciate it