STATE OF COLORADO 

Bill Ritter, Jr., Governor 

Martha E. Rudolph, Executive Director 

Dedicated to protecting and improving the health and environment of the people of Colorado 

4300 Cherry Creek Dr. S. Laboratory Services Division 

Denver, Colorado 80246-1530 81 00 Lowry Blvd. 

Phone (303) 692-2000 Denver, Colorado 80230-6928 

TOO Line (303) 691-7700 (303) 692-3090 

Located in Glendale, Colorado 

http://www.cdphe.state.co.us 

March 31 , 2010 

Carol Rushin 

Acting Regional Administrator 

US EPA Region VIII 

1595 Wynkoop St. 

Denver, CO 80202 

Dear Ms. Rushin: 

-·· 

Colorado Department 

of Public Health 

and Environment 

RECEIVED 

U.S. EPA Region 8 

RA's Oftlc:e 

APR 012010 

The following actions are submitted to EPA for final approval and incorporation into the Colorado State 

Implementation Plan pursuant to 40 CFR Part 51 , Appendix V, 2.l(a). Two copies of the materials 

needed for your review of each action are included with this letter. 

• Colorado Spdngs Carbon MOnoxide Maintenance Plan - The Colorado Air Quality Control 

Commission (Commission) adopted a second ten-year maintenance plan for the Colorado 

Springs area using the Limited Maintenance Plan option. There were no revisions to the control 

measures in the plan. 

• Greeley Carbon Monoxide Maintenance Plan- The Commission adopted a second ten-year 

maintenance plan for the Greeley area using the Limited Maintenance Plan option. There were 

no revisions to the control measures in the plan. 

• Pagosa Springs PM 10 Maintenance Plan - The Commission adopted a second ten-year 

maintenance plan for the Pagosa Springs area. There were no revisions to the control measures 

in the plan, however, the mobile source emissions budget was reduced. 

• Telluride PMl 0 Maintenance Plan- The Commission adopted a second ten-year maintenance 

plan for the Telluride area. There were no revisions to the control measures in the plan, 

however, the mobile source emissions budget was reduced. 

• Common Provisions - The Commission adopted a revision to the Common Provisions 

Regulation to revise the definitions of "negligibly reactive volatile organic compound" and 

"volatile organic compound" (VOC) in Section I.G. to be consistent with the federal definitions 

for these terms. 
Carol Rushin 

March 31 , 2010 

Page 2 

• Interstate Air Pollutant Transport State Implementation Plan - the Commission adopted a 

proposal to revise the interstate transport element of the State Implementation Plan to address 

outstanding issues that the US EPA had identified with plan previously adopted by the 

Commission. 

We look forward to your timely review and approval of this request. The office of the Colorado Air 

Quality Control Commission may submit any additional technical suppmi documentation or information 

that you may need for review directly to the EPA. Should there be any questions regarding these 

materials, please contact the Commission office at 303-692-3478. Thank you. 

Martha E. Rudolph 

Executive Director 

Colorado Department of Public 

Health and Environment 

cc. Paul Tourangeau 

Doug Lempke 

MarkKomp 
Colorado Springs Carbon Monoxide 

Maintenance Plan 

ADMINISTRATIVE MATERIALS 

Copies of the following administrative materials are included in this submittal of revisions to 

Colorado Springs Carbon Monoxide Maintenance Plan. Hearing held on December 1 7, 

2009. 

• Hearing Notice as Published on the Commission Website 40 CFR Part 51 Appendix 

v 2.1 (f) 

• Meeting Agenda where Public Hearing Occurred and Notice published in the Legal 

Ads of the Denver Post 40 CFR Part 51 Appendix V 2.1 (f) 

• Procedural Documents of the Commission (this includes the Agenda Item Control 

Sheet) 

• Parties Hearing Documents (this includes a list of the parties, the parties prehearing 

statements and rebuttal statements, and any orders by the Commission - - do not 

include all the attachments from the parties) 

• Proposed Language for State Implementation Plan Element 

• Technical Support Document 40 CFR Part 51 Appendix V 2.2 

• State Implementation Plan Element Adopted by the Commission 40 CFR Part 51 

Appendix V 2.1 (d) 

• Colorado Air Quality Control Commission Meeting Minutes 40 CFR Part 51 

Appendix V 2.1 (g) 
Hearing Notice as Published 

on the Commission Website 

40 CFR Part 51 Appendix V 2.1 (f) 
STATE OF COLORADO 

Bill Rttter, Jr. , Governor 

James B. Martm, Executive Dtrector 

Dedicated to protecting and tmprovmg the health and envtronment of the people of Colorado 

COLORADO AIR QUALITY CONTROL COMMISSION 

http://www.cdphe.stale.co.us 

EDO-AQCC-A5 

4300 Cherry Creek Drtve South 

Denver, Colorado 80246-1530 

Phone (303) 692-3100 

Fax (303) 691-7702 

TDD (303) 691-7700 

Colorado Department 

of Public Health 

and Environment 

NOTICE OF PUBLIC RULEMAKING HEARING 

BEFORE THE 

COLORADO AIR QUALITY CONTROL COMMISSION 

Regarding proposed revisions to: 

Colorado Springs Carbon Monoxide Maintenance Plan 

SUBJECT: 

The Air Quality Control Commission will hold a public rulemaking hearing to consider revisions 

to the Carbon Monoxide Maintenance Plan for Colorado Springs. This is the second of two 1 0-

year plans that are required by the Clean Air Act. 

FEDERAL REQUIREMENTS: 

The federal act requires the adoption of a second 1 0-year maintenance plan to demonstrate long 

term compliance with the national standard. 

HEARING SCHEDULE: 

DATE: December 17, 2009 

TIME: 9:00 AM 

PLACE: Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South, Sabin Conference Room 

Denver, Colorado 80246 

The hearmg may be contmued at such places and time as the Comm1sswn may announce. Interested 

parties may contact the Comm1sswn Office at 303-692-3476 to confirm meeting dates and t1mes. 

PUBLIC COMMENT: 

The Commission encourages all interested persons to provide their views either orally at the 

hearing or in writing prior to or at the hearing. The Commission especially solicits comments 

and analyses from persons who will incur directly some cost or benefit from the proposed 

revisions. Public testimony will be taken as close to the start of the hearing as possible and 

during the hearing as necessary. Written and/or electronic submissions prior to the hearing are 

requested to allow review prior to presentation at the hearing. Written and/or electronic 

submissions should be mailed to the Commission Office at least 14 days prior to the hearing. 

Page 1 of3 
PARTY STATUS: 

In order to obtain party status at the hearing, compliance with several requirements as defined in 

the Commissions Procedural Rules is necessary. A petition for party status must be filed by 

electronic mail with the Office of the Air Quality Control Commission no later than close of 

business on October 19, 2009. The petition must: 1) identify the applicant; 2) provide the name, 

address, telephone and facsimile numbers, and email address of the applicants representative, 

and 3) briefly summarize what, if any, policy, factual, and legal issues the applicant has with the 

proposal(s) as of the time of filing the application. Electronically mailed copies must also be 

received, by this same date, by the Division staff person and the Assistant Attorneys General 

representing the Division and the Commission identified below. Any person may petition the 

Commission to file documents in paper copy format if they are unable for any reason to not 

comply with the requirements of 1.3.8(2) of the Commissions Procedural Rules. An original and 

a specified number of paper copies must be filed in the Office of the Air Quality Control 

Commission, Colorado Department of Public Health and Environment, 4300 Cherry Creek Drive 

South, Denver, Colorado 80246. 

Individuals may also obtain party status through the submittal of an initial alternative rule to the 

proposed rule. The submittal of an alternative proposal must be accompanied by an electronic 

copy of the initial alternative proposed rule and all other associated documents as required by the 

Commission's procedural rules and must be filed by electronic mail with the Office of the 

Commission by the date specified for party status requests. Initial alternative rules must also be 

filed by electronic mail with the Division staff person and with each of the Assistant Attorneys 

General. 

Air Quality Control Commission 

Theresa L. Martin 

EDO-AQCC-A5 

4300 Cherry Creek Drive South 

Denver, CO 80246 

Theresa.Martin@state.co. us 

Jerry Goad 

Attorney for the Commission 

Attorney General's Office 

1525 Sherman St., 5th Floor 

Denver, CO 80203 

Jerry. Goad@state.co. us 

Air Pollution Control Division 

Chris Dann 

APCD-B1 

4300 Cherry Creek Drive South 

Denver, CO 80246 

Christopher.Dann@state.co.us 

Thomas Roan 

Attorney for the Division 

Attorney General's Office 

1525 Sherman St., 5th Floor 

Denver, CO 80203 

Tom.Roan@state.co.us 

Requests received beyond the above stated deadline shall only be considered upon a written 

motion for good cause shown. The Commission reserves the right to deny party status to anyone 

that does not comply with the Commission's procedural rules. 

STATUS CONFERENCE: 

A status conference will be held October 22, 2009 at 11:00 a.m., at the Department of Public 

Health and Environment to ascertain and discuss the issues involved, and to ensure that parties 

are making all necessary efforts to discuss and resolve such issues prior to the submission of 

prehearing statements. Attendance at this status conference is mandatory for anyone who has 

requested party status. 

Page 2 of3 
PREHEARING CONFERENCE/PREHEARING STATEMENTS: 

Attendance at the prehearing conference is mandatory for all parties to this hearing. A 

prehearing conference will be held November 13, 2009 at 11:00 a.m. in the Commission 

Offices at 4300 Cherry Creek Drive South, Denver. All parties must submit by electronic mail a 

preliminary prehearing statement to the Commission Office by close of business November 9, 

2009. In addition, electronically mailed copies of these documents must be delivered by that 

date to all persons who have requested party status. A copy of the prehearing statement must 

also be electronically mailed to the Division point of contact and each of the Assistant Attorney's 

General identified above by close of business November 9, 2009. Any revisions to the 

prehearing statement must be submitted to the Administrator of the Commission at the 

pre hearing conference and by electronic mail to the Commission Office on the day of the 

prehearing conference. Any exhibit included in the prehearing statements will be electronically 

mailed to individual Commissioners for review prior to the hearing, provided the party files 

electronic copies of such exhibit. Rebuttals to the prehearing statement may be submitted to the 

Commission Office and all other parties by close of business November 24,2009. 

EXCEPTIONS TO FILE DOCUMENTS BY ELECTRONIC MAIL: 

The Commission's Procedural Rules provide for an exception to file documents by electronic 

mail. If granted an exception to electronic filing pursuant to the provisions of 1.3. 8(3) of the 

Commissions Procedural Rules, the applicant for party status shall file an original and fifteen 

copies ofthe prehearing statement in the Office of the Air Quality Control Commission, and 

shall also deliver copies to each other party, applicant for party status, the Assistant Attorneys 

General representing the Commission and Division, and the Division staff person for the 

proceedings, by electronic mail or as otherwise provided by the exception granted under 

Subsection 1.3.8(3), by that same day. 

STATUTORY AUTHORITY FOR THE COMMISSION'S ACTIONS: 

The Commission proposes these regulatory changes pursuant to its authority under Sections 25-

7-106,25-7-107,25-7-109 and 25-7-302, C.R.S. The rulemaking hearing will be conducted in 

accordance with sections 24-4-103 and 25-7-1"10, C.R.S., as amended, the Procedural Rules of 

the Commission and as otherwise stated in this notice. This list of statutory authority is not 

intended as an exhaustive list of the Commission's statutory authority to act in this matter. 

Dated this 5th day of October 2009 at Denver, Colorado 

Colorado Air Quality Control Commission 

97-'~ Douglas A. Lempke, Administrator 

Page 3 of3 
Meeting Agenda where Public Hearing Occurred and 

Notice published in the Legal Ads of the Denver Post 

40 C·FR Part 51 Appendix V 2.1(f) 
STATE OF COLORADO 

Bill Ritter, Jr., Governor 

Ned Calonge, M.D., lntenm Executive Dtrector 

COLORADO AIR QUALITY CONTROL COMMISSION 

http://www.cdphe.state.co.us 

4300 Cherry Creek Dnve South 

OED-OLRA-A5 

Denver, Colorado 80246-1530 

Phone (303) 692-3100 

Fax (303) 691-7702 

TDD (303) 691-7700 

Colorado Department 

of Public Health 

and Environment 

Notice of Meeting and Agenda 

Air Quality Control Commission 

December 17,2009 

Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South, Sabin Room 

Call to Order: 

Approval of Minutes: 

Public Comment: 

Agenda Review: 

Denver, Colorado 

9:00a.m. 

Determination of a Quorum 

Review/Approval of the November 19, 2009 meeting minutes of 

the Air Quality Control Commission. 

The public is invited to comment on any air pollution issue not on 

the agenda. The Commission will not take action on issues 

discussed under this agenda item today; however, items may be 

scheduled for further discussion or action. 

The Commission Administrator will review the meeting agenda 

and discuss any proposed revisions to the agenda for the 

Commission's consideration. 

REQUEST FOR PUBLIC HEARINGS FEBRUARY 18, 2010 

1. Contingency Plan Provisions for the Rocky Mountain National Park Nitrogen 

Deposition Reduction Plan 

(10 minutes presentation, 10 minutes discussion) 

The Division will request that the Commission hold a public hearing in February to consider 

endorsing the contingency plan provisions for the Nitrogen Deposition Reduction Plan that 

have been developed by the Department of Public Health and Environment/ Air Pollution 

Control Division, US Environmental Protection Agency and the National Park Service. 
REQUEST FOR RULEMAKING HEARING MARCH 18, 2010 

2. Ambient Air Quality Standards Regulation 

(5 minutes presentation, 10 minutes discussion) 

The Division will request that the Commission hold a rulemaking hearing to consider 

revisions to the Ambient Air Quality Standards regulation to remove the ambient air quality 

standards table in Section II and replace it with a reference to the federal standards, to 

remove Section LB. regarding the S02 increment standards and to make typographical, 

grammatical, and formatting revisions as necessary. 

3. Regulation Number 8, Part C 

(5 minutes presentation, 5 minutes discussion) 

The Division will request the Commission set a rulemaking hearing to consider revisions to 

Regulation Number 8, Part C, to repeal the lead emission standard. 

4. Regulation Number 11, Vehicle Emission Inspection Program in the North Front 

Range - Program Area Review 

(5 minutes presentation, 20 minutes discussion) 

The Division will request the Commission set a rulemaking hearing to consider revisions to 

Regulation No. 11 regarding the implementation of the vehicle emissions inspection 

program in Larimer and Weld Counties. Specifically, the Division will propose that the 

program area be expanded in Larimer and Weld Counties consistent with the statutory 

boundaries established in 2009 Senate Bill 003 and that the implementation date of the 

program be revised to reflect the implementation date requirements of the 2009 SB 003. 

The Division is also proposing to establish interim tailpipe emission limitations for the area 

and to update technical specifications for testing equipment. 

WRITTEN COMMENT 0NL Y RULEMAKING HEARING 

5. Common Provisions Regulation 

(5 minutes presentation, 5 minutes discussion) 

The Division proposed revisions to the Common Provisions Regulation, Section I.G., 

specific to the definition of "negligibly reactive volatile organic compound" and "volatile 

organic compound" to be consistent with the federal definitions. 

COMMISSION ACTION 0NL Y 

6. Regulation Number 13: Oxygenated Fuels Program 

(5 minutes discussion) 

On August 20, 2009 the Commission acted to adopt a proposal to repeal the requirements of 

Regulation Number 13 in its entirety effective February 1, 2011. This action ofthe 

Commission was not timely filed with the Secretary of State and did not become effective. 

The Commission will consider an action to resubmit their August action to the Secretary of 

State for publication. 

PUBLIC HEARINGS 

7. Denver Regional Council of Governments (DRCOG) Conformity 

(20 minutes presentation, 50 minutes discussion) 

The DRCOG will present to the Commission its anticipated Transportation Conformity 

findings regarding the 2035 Regional Transportation Plan and the 2008/2013 TIP. 

2 
RULEMAKING HEARINGS 

8. Interstate Transport SIP 

(20 minutes presentation, 30 minutes discussion) 

The Division will present a proposal to revise previously adopted provisions to address the 

Clean Air Act Section 11 0; interstate air pollutant transport requirements. The Division 

received adverse comment on the previously adopted provision in May 2009 and has worked 

to revise the interstate transport plan consistent with the comments of EPA. 

9. Colorado Springs Carbon Monoxide Maintenance Plan Revision 

( 10 minutes presentation, 10 minutes discussion) 

The Division will present to the Commission revisions to the carbon monoxide maintenance 

plan for Colorado Springs. This is the second oftwo 10-years plans that are required by the 

Clean Air Act. 

10. Greeley Carbon Monoxide Maintenance Plan Revision 

( 10 minutes presentation, 10 minutes discussion) 

The Division will present to the Commission revisions to the carbon monoxide maintenance 

plan for Greeley. This is the second oftwo 10-years plans that are required by the Clean Air 

Act. 

BRIEFINGS, DISCUSSIONS AND REPORTS 

11. Commissioner Informational Items 

Commissioners will discuss among themselves activities that they have participated in over 

the past month that they believe other Commissioners and/or members of the public may be 

interested in hearing about. 

12. Division Director's Report- Paul Tourangeau 

Monthly activities report 

13. Attorney General's Report- Jerry Goad 

Update of any recent court actions on air quality issues 

14. Administrator's Report- Doug Lempke 

• February meeting agenda items review 

• Review of Action Items from Today's Commission Meeting 

• Status of Pending Action Items 

Adjourn 

3 
The Denver Newspaper Agency 

DENVER, CO 

PUBLISHER'S AFFIDAVIT 

City and County of Denver, 

STATE OF COLORADO, SSo 

• o •••••• Jean Birch ........ being of lawful 

age and being first duly swom upon oath, deposes and says: 

That hetsh• Is the Legal Advertising Reviewer 

of The Denver Newspaper Agency, publisher of the Denver Post, 

dally newspaper of general circulation published and printed In 

whole or In part In Denver, In the County of Denver and State of 

Colorado, and that said newspaper was prior to end during all 

the time hereinafter mentioned duly qualified for the publication 

of legal notices and advertisements within the Meaning of an Act 

of the General Assembly of the State of Colorado, approved 

April 71 1g21, •• amended and approved March 301 1123; and •• 

amended and approved March 5, 1135, entitled •An Act Concemlng 

Legal Notices, Advertisements and Publications and the fees of 

printers and publishers thereof, and to repeal all •eta and parts 

of acts In conflict with the provision of this Act• and amendments 

thereto: 

That the notice, of which the annexed Is • true copy, was published 

In the said n~•P:6oto ~b (elates of publication) 

.......... ~~!-2, ... ~.1. ............ 0 

................. y:.··· ···········rJ···r··········o······· 

.................. ~~a ............. . Signature • 

Subscribed and swom to before me this ••••• 12 ••••• clay 

ot 0 •• october c. ••• A.Dfooe. · 0 

......... ~ .... J.;-......................... . '· ... ' 'J' Notary Public. 

My commission expires., •• , September 14, 2013, •••• 
Procedural Documents of the Commission 

- Agenda Item Control Sheet 
COLORADO AIR QUALITY CONTROL COMMISSION 

AGENDA ITEM CONTROL SHEET 

Item Title Proposed Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 

Meeting date December 17. 2009 

TYPES OF ACTION 

NON-HEARING ACTIONS REQUEST FOR HEARING HEARING 

- Administrative _ Public Rulemaking X Public Rulemaking 

_Briefing - Informational - Informational 

_Policy 

_Area Designations 

RECOMMENDED ACTION 

_Adoption X Approval - Denial 

MOTION 

X Required - Attached _ Not applicable 

STATUTORY AUTHORITY 

General 25-7-1 05 Specific 25-7-1061 -1071 -109 -302 

EPA SUBMITTAL 

Is this issue considered a SIP revision? Yes X No 

Which SIP? Colorado Sgrings CO Date of EPA submission deadline: 8/25/07 

Agenda Item Control Sheet 12/2/09 Page 1 
ISSUE STATEMENT: 

The Division is requesting that the Commission approve a proposed revision for the 

Colorado Springs CO attainmenUmaintenance area. Approval of the document was 

obtained from the Pikes Peak Area Council of Governments (PPACG) -the lead 

planning agency for the area- in November 2009. The Air Pollution Control Division 

also recommends approval of the revision. 

The documentation confirms that the Colorado Springs area will continue to attain the 

National Ambient Air Quality Standards (NAAQS) for carbon monoxide through 2020, 

and has recorded no violations of the standard since the 1993 attainment year 

established in the original carbon monoxide maintenance plan adopted by the AQCC in 

January 1998. No additional control measures are required for the Colorado Springs 

area to comply with the standard. 

Since carbon monoxide levels in Colorado Springs are significantly below the NAAQS, 

the Air Pollution Control Division is using the limited maintenance plan option for areas 

that the EPA assumes cannot reasonably be expected to experience enough growth to 

violate the standards. The Colorado Springs area's carbon monoxide values are 26 

percent of the 8-hour NAAQS, which is below the 85 percent criteria for utilizing the 

limited maintenance plan option. 

This revision satisfies the federal requirement for confirming attainment for the second 

ten-year period after redesignation to attainmenUmaintenance. No additional revisions 

of the Colorado Springs attainmenUmaintenance plan are anticipated. If future changes 

in mobile source models or other unforeseen considerations raise potential issues with 

maintaining the carbon monoxide standard, the State will address the need to revise 

the attainmenUmaintenance plan at that time. 

Please note that this maintenance plan was to be submitted to EPA by August 25, 2007 

(which is 8 years after EPA's approval of the initial redesignation request and 

maintenance plan, as required by the CAA). The Colorado Springs area 

attainmenUmaintenance plan was amended in 2004 and maintenance of the CO 

NAAQS was demonstrated through 2015. Though the plan update is late, no adverse 

environmental or administrative impact has occurred. 

Agenda Item Control Sheet 12/2/09 Page2 
ATIACHMENTS: 

1. Proposed Colorado Springs Maintenance Plan revision 

2. Technical Support Document 

SIGNATURES: 

Preparer 

Division Director 

Agenda Item Control Sheet 12/2/09 

Date 

J~l~/o9 

,:£ly/ OJ 

Date 

Page 3 
Parties Hearing Documents 

(this includes a list of the parties, the parties prehearing statements 

and rebuttal statements, and any orders by the Commission) 
BEFORE THE AIR QUALITY CONTROL COMMISSION 

STATE OF COLORADO 

PREHEARING STATEMENT OF COLORADO DEPARTMENT OF PUBLIC HEALTH 

AND ENVIRONMENT, AIR POLLUTION CONTROL DIVISION 

REGARDING PROPOSED REVISIONS TO COLORADO SPRINGS CARBON MONOXIDE 

MAINTENANCE PLAN 

The Colorado Department of Public Health and Environment, Air Pollution Control 

Division (''DIVISIOn") confirms that it supports Its original proposal. Pikes Peak Area Council of 

Governments, the only party, suppmts this proposal. The Division is aware of no Issues. The 

economic impact analysis has not changed. 

DATED this 9th day ofNovember, 2009 

JOHN W. SUTHERS 

Attorney Q._~ 

,.//~~- ~ C-- ---- ~~tlfoMMfA:ioAN:30867* 

Assistant Attorney General 

Envuonmental Quality 

Natural Resources and Environment Section 

Attorneys for AIR POLLUTION CONTROL 

DIVISION 

1525 She1man Street. 5th Floor 

Denver, Colorado 80203 

Telephone: (303) 866-5280 

*Counsel of Record 

RECEIVED 

NOV 16 2009 

AIR (} ·Al.ITY 

CONTROL C OMr ' 'SSION 
CERTIFICATE OF SERVICE 

I cert1fy that I have duly served the foregomg Colorado Department of Public Health 

and Environment, Air Pollution Control Div1s10n's Prehearing Statement upon the followmg 

parttes by electronic mail on November 9th, 2009· 

Jerry Goad 

Attorney General's Office 

1525 Shennan St., 5tJ1 Floor 

Denver, CO 80203 

Jen}'.gq!}d((i1state.co.us 

Rtck Muzzy 

Pikes Peak Are Council of Governments 

15 S. 7th Street 

Colorado Springs, CO 80905 

rrn uzzv@.ppac g.org 

Theresa L. Martin 

Air Quality Control Commission 

4300 Cherry Creek Drive South 

Denver, CO 80246 

Theresa.martJn@state.co.us 

~ I 
AIR QUALITY CONTROL COMMISSION 

RECEIVED 

NOV 16 2009 

AIR QUALITY 

CONTMl <XJMSSION 

---------------------------------------------------- RESPONSIVE PREHEARING STATEMENT OF THE PIKES PEAK AREA COUNCIL 

OF GOVERNMENfS 

IN TilE MA'ITER OF THE PROPOSED REVISIONS TO THE COLORADO SPRINGS 

CARBON MONOXIDE MAINTENANCE PLAN 

PPACG supports the changes as proposed by the Air Pollution Control Division in the Notice 

of Public Rulemaking Hearing for the Colorado Springs Carbon Monoxide Maintenance 

Plan. The PPACG Board recommended approval of the Revised Colorado Springs Carbon 

Monoxide Maintenance Plan at their November 9 meeting. 

II. WITNESSES 

Respectfully submitted this 16th day of November, 2009 

By: 

Rich Muzzy 

Environmental Program Manager 

rikes Peak Area Council of Governments 

15 S. 7th Street 

Colorado Springs, Colorado 80905 

Phone: (719) 471-7080 xl09 

Fax: (719) 471-1226 
Pikes Peak Area 

council of Governments 

October 16,2009 

Mr. Douglas A. Lempke, Technical Secretary 

CDPHE-AQCC 

APCD-CC-B 1, 4300 Cherry Creek Drive South 

Denver, CO 80222-1530 

Re: Party Status for Colorado Springs Carbon Monoxide Maintenance Plan 

Dear Doug: 

RECEIVED 

OCT 15 2009 

AIR QUALITY 

CON1lO.. COIIMISSDI 

Pikes Peak Area Council of Governments (PPACG) would like to apply for party status 

for the Colorado Springs Carbon Monoxide Maintenance Plan. The contact information is 

provided below: 

Applicant: 

Representative: 

Address: 

Phone#: 

Fax#: 

Email address: 

Pikes Peak Area Council of Governments (PPACG) 

Rich Muzzy 

15 S. 7th Street 

Colorado Springs, CO 80905 

719-471-70890 x109 

719-471-1226 

rmuzzy@ppacg.org 

PP ACG is the lead air quality planning agency for the Colorado Springs Urbanized Area. 

Over the past several months, PP ACG has been working in conjunction with members of 

the Air Pollution Control Division on revisions to the Plan. These revisions are in the 

process of being reviewed by our committees and by our region's citizens during a 30-

day public review and comment period. 

Thank you for your consideration of this application for party status. 

Sincerely, 

~~ Rich Muzzy, Environmental Program Manager 

Pikes Peak Area Council of Governments 

Cc: 

Theresa Martin, Air Pollution Control Division 

Chris Dann, Air Pollution Control Division 

Jerry Goad and Thomas Roan, Attorney Generals Office 
Proposed Language and 

State Implementation Plan Elements 
Revised Carbon Monoxide Attainment/Maintenance Plan 

Colorado Springs Attainment/Maintenance Area 

1 0-vear Revision: 

• In draft, August 31, 2009 

'Z'd Revision to the Attainment/Maintenance Plan Adopted by: 

The U.S. Environmental Protection Agency, September 7, 2004 

The Colorado Air Quality Control Commission, December 18, 2003 

The Pikes Peak Area Council of Governments, September 10, 2003 

151 Revision to the Attainment/Maintenance Plan Approved by: 

The U.S. Environmental Protection Agency, December 22, 2000 

Original Redesignation Request and Attainment/Maintenance Plan approved by: 

The U.S. Environmental Protection Agency, August 25, 1999 

Colorado Department 

of Public Health 

and Environment 

Revisions prepared by: 

The Air Pollution Control Division 

Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South 

Denver, CO 80246-1530 

(303) 692-3100 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 1 
Background 

The Environmental Protection Agency (EPA) approved a carbon monoxide (CO) 

redesignation request and maintenance plan for the Colorado Springs area on August 25, 

1999 (64 FR 46279), which became effective on October 29, 1999. This action, which 

was adopted by the Colorado Air Quality Control Commission (AQCC) in January 1998, 

established a base (attainment) year of 1993 and an out (maintenance) year of2010, 

provided for the continuation of the State's basic inspection and maintenance (I/M) 

program and the oxygenated gasoline program in the Colorado Springs area (as the 

programs existed in January 1998), established a CO emission budget of212 tons per day 

(tpd) to be utilized in transportation conformity determinations, and established a 

contingency plan in the event a violation of the CO National Ambient Air Quality 

Standards (NAAQS) was measured. 

On December 22, 2000, the EPA approved a revised Colorado Springs area CO 

attainment/maintenance plan, which became effective on February 20, 2001 (65 FR 

80779). This action, which was adopted by the AQCC in February 2000, revised the 

attainment year from 1993 to 1990, provided for the continuation ofthe basic liM 

program, eliminated the oxygenated gasoline program in El Paso County, revised the 

maintenance demonstration, revised the contingency plan, and revised the CO emission 

budget from 212 tpd to 270 tpd for the period 2001 and beyond. 

On September 7, 2004, the EPA approved another revised Colorado Springs area CO 

attainment/maintenance plan, which became effective on November 8, 2004 (69 FR 

54024). This action, which was adopted by the AQCC in December 2003, updated the 

emission inventories using the latest EPA-approved tools (including the MOBILE6.2 onroad mobile sources emission model), eliminated the basic I/M program in El Paso 

County from the federal State Implementation Plan (SIP), extended the maintenance year 

to 2015, and revised the CO emission budget from 270 tpd to 531 tpd for the period 2010 

and beyond. 

This revision to the attainment/maintenance plan -- considered a "limited maintenance 

plan" - revises the attainment year from 1990 to 2007, updates the base year emission 

inventory using the latest EPA-approved tools (including the MOBILE 6.2 on-road 

mobile sources emission model), and extends the maintenance year through 2020. This 

attainment/maintenance plan confirms that the CO standard will be maintained for a 

second ten-year period after the original redesignation. 

Limited Maintenance Plan Option 

Colorado is using the Limited Maintenance Plan option in preparing this second ten-year 

revision. The option is explained in EPA guidance of October 6, 1995, from Joseph W. 

Paisie, Group Leader, Integrated Policy and Strategies Group, U.S. Environmental 

Protection Agency. 

The guidance allows for a less rigorous approach than was previously required in 

developing attainment/maintenance plans for CO nonattainment areas that have design 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 2 
values at or below 7.65 ppm (85% of the CO NAAQS). The Colorado Springs area's 

design value in this plan revision is 2.3 ppm (approximately 26% of the CO NAAQS). 

The Colorado Springs area's design value in the first ten-year plan was 5.5 ppm. The 

design values were determined by using the second-highest maximum eight-hour value of 

eight consecutive quarters, as required by EPA guidance. The Colorado Springs area has 

shown a continued reduction in CO values throughout the maintenance period. 

The limited maintenance plan approach requires development of an emission inventory 

but does not require the inventory to be projected for future years. The maintenance 

demonstration is considered to be satisfied if the monitoring data show that the area is 

meeting the air quality criteria for limited maintenance areas (at or below 7.65 ppm or 

85% of the CO NAAQS). 

Transportation conformity is demonstrated by showing that the transportation plans are 

consistent with the emission budget. The guidance for limited maintenance plans state 

that emissions budgets may be treated as essentially non-constraining for transportation 

conformity because it is unreasonable to expect that such an area will experience so much 

growth during the maintenance period that a violation of the CO NAAQS would result. 

Therefore, the "budget test" of the transportation conformity rule is met, according to the 

guidance. 

Continued Attainment of the Carbon Monoxide Standard 

Attainment of the national ambient air quality standards for CO is demonstrated when 

monitoring data for each site show no more than one exceedance per year of the 8-hour (9 

ppm) and 1-hour (35 ppm) standards. The 8-hour standard has not been exceeded in the 

Colorado Springs area since 1989. The 1-hour standard has not been exceeded since 

1979. 

Monitoring data for 1999-2008 demonstrates that the Colorado Springs area continues to 

attain/maintain the national standard for CO as required by 40 CFR 50.8. Data from 

1999 through 2008 are provided to demonstrate continual attainment/maintenance since 

the redesignation to attainment was promulgated in 1999. This demonstration is based on 

quality assured monitoring data representative of the location of expected maximum 

concentrations of CO in the Colorado Springs area. Data presented is the second highest 

maximum value recorded at the monitors. The second maximum value is used by EPA 

for determining compliance with the CO NAAQS. 

The monitoring data presented in Table 1 verifies that the Colorado Springs area 

continues to attain the 8-hour NAAQS for CO. Data recovery rates for the monitor 

exceeded the 75% completeness requirements for all years. All state and federal quality 

assurance procedures were complied with, further substantiating the validity of the 

measurements as indicators of ambient CO levels in the Colorado Springs area. 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 3 
Table 1 

1999-2008, 8-Hour Carbon Monoxide Summary for Colorado Springs 

Standard: 8-hour = 9 ppm* 

8-Hour 2"d Maximum (ppm) 

Site Name 1999 2000 2001 

Colo. Spgs., 690 W. Hwy. 24 5.2 4.2 4.4 

8-Hour 2"0 Maximum (ppm) 

2002 

5.1 

Site Name 2003 2004 2005 2006 2007 

Colo. Spgs., 690 W. Hwy. 24 3.9 3.1 2.7 2.4 2.1 

*Due to mathematical rounding, a value of9.5 ppm or greater is necessary to exceed the standard. 

2008 

2.3 

Colorado Springs Carbon Monoxide Attainment/Maintenance Area Boundaries 

Beginning near the Town of Palmer Lake, at the Northwest comer of the Study Area at a 

point on the El Paso/Douglas County line, also on the Pike National Forest boundary, 

then: east along the County line to Elbert Road; south on Elbert Road to Judge Orr Road; 

east on Judge Orr Road to Ellicott Highway; south on Ellicott Highway to Squirrel Creek 

Road; west on Squirrel Creek Road to Williams Creek; south along Williams Creek to the 

confluence of Williams and Fountain Creeks; south along Fountain Creek to the El 

Paso/Pueblo County line; west on the County line to 1-25; north on I-25 to Exit 132; west 

on Magrath to Weston Ave.; south on Weston Ave. to Barkeley Ave. and then straight on 

to Specker Ave.; northwest on Specker Ave. to Titus Blvd.; west on Titus Blvd. to SH115; south on SH-115 to Rock Creek; northwest along Rock Creek to the Pike National 

Forest boundary; north along the Forest boundary to Old Stage Road; southwest on Old 

Stage Road to Gold Camp Road; north on Gold Camp Road to High Drive; north on High 

Drive to Lower Gold Camp Road; north on Lower Gold Camp Road to the Pike National 

Forest boundary; west along southern boundary of Sections 16, 17, and 18 of Township 

14 South (T 14 S), Range 67 West (R 67 W); north along the western boundary of 

Sections 7 and 6 ofT 14S R67 W; and east along the northern boundary of Sections 5 and 

4 ofT14S, R67W to US-24; northwest on US-24 to the Pikes Peak Toll Road; west on 

the Toll Road to the El Paso/Teller County line; north along the County line to Crystola 

Creek; west on Crystola Creek to County Road 28, north on County Road 282 to US-24; 

northeast on US-24 to Trout Creek Road; northwest on Trout Creek Road to Trout Creek; 

north along Trout Creek to the confluence of Trout and Mule Creeks; north along Mule 

Creek to Long Gulch; east along Long Gulch to White Gulch; east along White Gulch to 

Rampart Range Road; southeast on Rampart Range Road to the Pike National Forest 

Boundary; north along the Forest boundary to the El Paso/Douglas County line, to the 

point of origin. 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 4 
Figure 1. Colorado Springs Carbon Monoxide Attainment/Maintenance Area 

0 2.5 5 

- -

Map Created by the APCD Tectnical Services Program 

Colaado Department of Public Health end Environment 

CJ 

D 

10 15 20 

Miles 

Legend 

Attainment/Maintenance Area 

County Boundary 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 

N 

A 

Page 5 
Emission Inventories 

The area shown in Figure 1 represents the area in which the Pikes Peak Area Council of 

Governments (PP ACG) serves as the "Lead Planning Agency" for air quality and the 

"Metropolitan Planning Organization" (MPO) for transportation. 

This attainment/maintenance plan revision utilizes 2007 as the attainment year for 

emission inventories, which is the same year from which the 2.3 ppm design value was 

derived. Emission inventories for a typical winter day are presented in Table 2 for the 

2007 attainment year. Each inventory accounts for the emission control programs 

effective during that period. 

The modeling domain consists of the Colorado Springs attainment/maintenance area, 

which encompasses the city of Colorado Springs and surrounding communities (see 

Figure 1). The emission inventories, included here and detailed in the Technical Support 

Document for this attainment/maintenance plan revision, were developed using U.S. 

Environmental Protection Agency (EPA) approved emissions modeling methods, 

including EPA's MOBILE6 model and local VMT data for on-road mobile source 

emissions, EPA's non-road model, local demographic information for area and off-road 

sources, and reported actual emissions for point sources. The inventory represents 

average daily winter emissions. The MOBILE6 and non-road model inputs represent 

these average daily winter conditions. Heating and wood burning emissions were 

apportioned from annual emission estimates by heating degree day data from the Western 

Regional Climate Center. Other source categories were apportioned from annual to daily 

by dividing by 365. 

Table 2. CARBON MONOXIDE Emission Inventory (tons per day) 

Inventory Summary Source Category 2007 

Aircraft 2.92 

Biogenic 0.00 

Commercial Cooking 0.19 

Fuel Combustion 1.62 

Highway Vehicles 319.16 

Non O&G Point Sources 227 

Non-Road 40.45 

Railroads 021 

Structure Fires 0.09 

Wood burning 140.49 

Grand TOTAL 507.39 . . Note: Results are reported wtth two dectmal place prectston to provtde representation of smaller source categones . 

This level of precision is not intended to suggest a level of accuracy. 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 6 
Enforceable Control Measures for the Maintenance Period 

• Federal Motor Vehicle Emission Control tailpipe standards and 

regulations, including those for small engines and non-road mobile 

sources. Credit is taken for these federal requirements, but they are part of 

a federally-administered program and not a state commitment ofthe 

Colorado SIP. 

• Air Quality Control Commission (AQCC) Regulation No.3, Air Pollution 

Emission Notices - Permits 

• AQCC Regulation No.4, Wood Stove Standards 

• AQCC Regulation Number 6, New Source Performance Standards 

• AQCC Common Provisions Rule 

The Common Provisions and Regulation No.6 delineate industrial source control 

programs. The Common Provisions, and Parts A and B of Regulation No.3, already are 

included in the approved Colorado SIP. Regulation No.6 and Part C of Regulation No.3 

implement the federal standards of performance for new stationary sources and the 

federal operating permit program. The revised Colorado Springs attainment/maintenance 

plan makes no changes to these regulations. 

Maintenance Demonstration 

This attainment/maintenance plan utilizes the EPA's Limited Maintenance Plan option, 

as explained above. The Limited Maintenance Plan approach can be utilized when an 

area has a design value at or below 7.65 ppm (85% of the CO NAAQS). The design 

value for the Colorado Springs attainment/maintenance area is 2.3 ppm (approximately 

26% of the CO NAAQS), which is the highest second maximum concentration for the 

2007-2008 monitoring period. 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 7 
Transportation Conformity Determination 

Under the Limited Maintenance Plan approach, transportation conformity is 

demonstrated by showing that transportation plans are consistent with any existing 

emission budgets. When any existing budgets expire, conformity is then presumed and 

regional analyses and emission budget tests for transportation conformity are no longer 

necessary. The guidance for limited maintenance plans states that emission budgets may 

be treated as essentially non-constraining for transportation conformity because it is 

unreasonable to expect that such an area will experience so much growth during the 

maintenance period that a violation of the CO NAAQS would result. Therefore, the 

"budget test" of the transportation conformity rule is met, according to the guidance. 

For the Colorado Springs Attainment/Maintenance Area, the EPA approved emission 

budgets are 536 tons per day (2010-2014), and 531 tons per day (2015 and beyond). 

According to the Limited Maintenance Plan guidance, these budgets are to remain in 

place, and conformity with these budgets is demonstrated, through the year 2015. 

Beginning in 2016, the budgets expire. 

While the Colorado Springs Attainment/Maintenance Area (under the Limited 

Maintenance Plan approach) is not subject to the budget test, the area remains subject to 

other transportation conformity requirements. 

Monitoring Network I Verification of Continued Attainment 

The Air Pollution Control Division (APCD) will continue to operate an 

appropriate air quality monitoring network in accordance with 40 CFR Part 58 to verify 

the continued attainment of the CO NAAQS. If measured mobile source parameters 

(e.g., vehicle miles traveled, congestion, fleet mix, etc.) change significantly over time, 

the APCD will perform the appropriate studies to determine whether additional and/or resited monitors are necessary. An annual review of the NAMS/SLAMS air quality 

surveillance system will be conducted in accordance with 40 CFR 58.10 to determine 

whether additional and/or re-sited monitors are necessary and to determine whether the 

system continues to meet the monitoring objectives presented in Appendix D of 40 CFR 

Part 58. 

Contingency Plan 

Section 175A(d) of the Clean Air Act requires that the attainment/maintenance 

plan contain contingency provisions to assure that the State will promptly correct any 

violation of the CO NAAQS which occurs in the Colorado Springs 

Attainment/Maintenance Area. 

The contingency plan must ensure that the contingen'Cy measures are adopted 

expeditiously once the need is triggered. The primary elements of the contingency plan 

involve the tracking and triggering mechanisms to determine when contingency measures 

are needed and a process for implementing appropriate control measures. 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 8 
Tracking 

The tracking plan for the Colorado Springs area consists of continuous CO monitoring 

and analysis of CO concentrations by the APCD. The APCD will notify the EPA, the 

AQCC, the PPACG and local governments of any exceedance ofthe CO standard within 

30 days of occurrence. The ongoing regional transportation planning process carried out 

by the PPACG in coordination with the Colorado Department ofTransportation (CDOT), 

the APCD, the AQCC, and the EPA, will serve as another means oftracking mobile 

source CO emissions into the future. Since revisions to the regions' transportation 

improvement programs are prepared every two years and must go through a 

transportation conformity determination, a process is in place to periodically review the 

VMT and mobile source emissions of CO presented in this attainment/maintenance plan. 

Triggering and Response 

Triggering of the contingency plan does not automatically require a revision of the SIP, 

nor is the area necessarily redesignated once again to nonattainment. Instead, the State 

will have an appropriate time-frame to correct a violation by implementing one or more 

adopted contingency measures. In the event that violations continue to occur after 

contingency measures have been implemented, additional contingency measures will be 

implemented until the violations are corrected. 

An exceedance of the CO NAAQS (any value 9.5 ppm or greater) may trigger a 

voluntary, local process by the PP ACG and the APCD to identify and evaluate potential 

contingency measures. However, the only federally enforceable trigger for mandatory 

implementation of contingency measures shall be a violation of the CO NAAQS. 

Specifically, this would be a second value of 9.5 ppm or greater at the same monitor 

during any calendar year. 

The State will move forward with mandatory implementation of contingency measures 

under the SIP if a violation of the CO NAAQS occurs. No more than 60 days after being 

notified by the APCD that a violation occurred, the PP ACG - in conjunction with the 

APCD, the AQCC and local governments- will initiate a process to begin evaluating 

potential contingency measures. The PP ACG will present recommendations within 120 

days of notification, and the recommended contingency measures will be presented to the 

AQCC within 180 days of notification. 

The AQCC then will hold a public hearing to consider the recommended contingency 

measures, along with any other contingency measures the AQCC believes may be 

appropriate to effectively address the violation. The necessary contingency measures will 

be adopted and implemented within one year after a violation occurs. 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 9 
List of Potential Contingency Measures 

The PP ACG and the APCD may choose one or more of the following measures to 

recommend to the AQCC for consideration. The measures will be designed to bring the 

area quickly back into compliance with the CO NAAQS. 

• An enhanced vehicle inspection and maintenance program as set forth in AQCC 

Regulation No. 11, with the addition of any on-board diagnostics components 

required by federal law. 

• The State may evaluate other potential strategies including, but not limited to, 

transportation control measures and mandatory wood burning restrictions in order 

to address any future violations in the most appropriate and effective manner 

possible. 

Subsequent Attainment/Maintenance Plan Revisions 

It is required that an attainment/maintenance plan revision be submitted to the EPA 

demonstrating that the CO standard will be maintained for a second ten-year period. The 

purpose of this fmal revision is to fulfill that requirement for an additional ten years 

(through 2020) following the first ten-year period. 

If future changes in mobile source models or other unforeseen considerations raise 

potential issues with the conformity process, the State will address the need to revise the 

attainment/maintenance plan at that time. 

Colorado Springs Carbon Monoxide Attainment/Maintenance Plan Revision 8/31/09 Page 10 
Technical Support Document 

40 CFR Part 51 Appendix V 2.2 
Colorado Department of Public Health and Environment I Air Pollution Control Division 

Carbon Monoxide Maintenance Plan 

Colorado Springs 

Technical Support Document 

Emission Inventory 

December 17, 2009 

Colorado Department of Public Health and Environment 

Air Pollution Control Division 

4300 Cherry Creek Drive South 

Denver, Colorado 80246 

Colorado Springs Technical Support Document 12/2/09 Page 1 
Colorado Department of Public· Health and Environment I Air Pollution Control Division 

Table of Contents 

1. EMISSION INVENTORY METHODOLOG¥ .................................................................................................. 3 

2. 2007 EMISSION INVENTORY SUMMARY .................................................................................................... 4 

3. REFERENCES ...................................................................................................................................................... 6 

Colorado Springs Technical Support Document 12/2/09 Page2 
Colorado Department of Public Health and Environment I Air Pollution Control Division 

1. Emission Inventory Methodology 

The Air Pollution Control Division (APCD) developed the 2007 emission inventory in the 

"Carbon Monoxide Maintenance Plan for Colorado Springs" using U.S. Environmental Protection 

Agency (EPA) approved emissions modeling methods, including EPA's MOBILE6 model and the 

latest transportation data from the Colorado Department of Transportation (CDOT) and 

demographic data from the State Demographers Office. 

Highway mobile source emissions are from the EPA model MOBILE6, an emission factor model 

for predicting gram per mile emissions of Hydrocarbons (HC), Carbon Monoxide (CO), Nitrogen 

Oxides (NOx), Carbon Dioxide (C02), Particulate Matter (PM), and toxics from cars, trucks, and 

motorcycles under various conditions. 

Non-road source emissions are from the EPA Non-Road Model. 

Area source emissions (including heating, construction, railroads, etc.) are from the 2002 EPA 

National Emissions Inventory (NEI), grown to 2007 by population growth from data from the 

State. For more documentation for these categories, refer to the NEI documentation (EPA, 2008). 

Under Air Quality Control Commission Regulation No.3, the APCD requires any source that 

emits two tons per year or greater to submit an Air Pollutant Emission Notice (APEN) (APCD, 

2008). This means that sources that emit less than two tons per year are not necessarily accounted 

for in an emissions inventory. The point source emissions for Colorado Springs were obtained 

from this tracking system. The emission estimates are made using a variety of methodologies. 

Data from source-specific emission tests, or continuous emission monitors are preferable, but not 

always available. The EPA has developed a variety of emission factors to estimate emissions as 

well. Emission factors are frequently the best or only method available for estimating emissions. 

Colorado Springs Technical Support Document 12/2/09 Page3 
Colorado Department of Public Health and Environment I Air Pollution Control Division 

2. 2007 Emission Inventory Summary 

This section presents the 2007 emission inventories for the maintenance plan. 

Table 1. 2007 CARBON MONOXIDE Emission Inventory (tons per year). 

Inventory Summary ~0 (TonsN ear 

Commerc1al Cookmg 68.6S 

Fuel Combustion 317.07 

Non-Road 3S,SS6.16 

' Structure Fires 34.13 

Woodburnmg 27,S09.28 

A1rcraft 1,064.31 

Highway Vehicles 89,068.77 

Biogenic 1,0S9.71 

Railroads 7S.S2 

Non O&G Pomt Sources 826.78 

Grand TOTAL 155,580.4 

Non O&G Point Sources 

site id facility n 

0003 COLORADO SPRINGS UTILITIES-BIRDSALL PLT 1S.9 

0004 COLORADO SPRINGS UTILITIES-DRAKE PL T 2S3.0 

0006 U.S. AIR FORCE ACADEMY 24.8 

0007 COLORADO SPRINGS UTILITIES LAS VEGAS WWT 4.0 

0010 TRANSIT MIX CONCRETE 1.8 

0014 FORT CARSON USARMY (DECAM) 78.7 

0016 PETERSON AFB 21CES CEV 18.3 

0017 LAFARGE WEST, INC. -FILLMORE 93.0 

0022 COLORADO SPRINGS MEMORIAL HOSPITAL 12.0 

0023 BROADMOOR HOTEL INC 2.8 

0036 W FORGE HOLDINGS, INC 19.1 

0037 AGILENT TECHNOLOGIES 7.8 

0041 . ATMEL CORP 20.8 

0042 TRANSIT MIX CONCRETE CO 0.0 

004S IR SECURITY AND SAFETY 0.2 

ooso OGLEBAY NORTON INDUSTRIAL SANDS 4.4 

OOS4 PIKES PEAK COMMUNITY COLLEGE 2.6 

pass PENROSE COMMUNITY HOSPITAL 2.1 

OOS6 PENROSE HOSP 8.8 

0063 CHEYENNE MTN ZOO 0.1 

K>067 ST FRANCIS PENROSE HOSP SYS 1.3 

0069 COLORADO COLLEGE 4.S 

007S EVERGREEN PARK MAUSOLEUM ASSOCIATION 0.0 

K>o8o INTEL CORP (WAS ROCKWELL & UNITED TECH) 2S.S 

0096 LAFARGE WEST- VOLLMER CONCRETE PLANT 0.0 

p121 SCHRIEVER AFB USAF 4.S 

K>178 VILLA SAN JOSE APT BLDG 0.0 

0192 PETE LIEN & SONS DBA TRANS-COLO CONCRETE 0.3 

Colorado Springs Techmcal Support Document 12/2/09 Page4 
Colorado Department of Public Health and Environment I Air Pollution Control Division 

0223 HEWLETT-PACKARD CORPORATION 0.6 

0301 MOBILE ENERGY PRODUCTS 27.5 

0307 TEGRANT DIVERSIFIED BRANDS, INC. 3.8 

0310 BURTS AUTO SUPPLY 0.0 

0316 RAMTRON INTL CORP 0.1 

0328 SCHMIDT CONSTRUCTION CO.-DELTA DRIVE FAG 28.0 

0331 FOUNTAIN LANDFILL 31 .0 

0411 AEROFLEX UTMC MICROELECTRONICS 0.2 

p522 SINTON DAIRY FOODS CO 1.9 

0535 SNO WHITE LINEN & UNIFORM RENTAL INC 0.5 

0548 NUSTAR LOGISTICS- COLO SPGS TERMINAL 6.5 

0783 CHEYENNE MOUNTAIN AIR FORCE STATION 3.3 

0812 COLORADO SPRINGS MORTUARY & CREMATIONS 0.1 

0831 VITESSE SEMICONDUCTOR CORP 3.0 

0850 CAPPADONA'S FAMILY SVCES 0.2 

0856 MCI TELECOMMUNICATIONS CORP 0.1 

0882 KLK INC. -IOWA AVE 1 1 

0888 ROCKY MOUNTAIN PREMIX 2.1 

1595 U.S. CORP OF ENGINEERS- TSA/ONRA 0.2 

1608 TRANSIT MIX CONCRETE CO - EAST PLANT 1.6 

1996 CAPPADONA FUNERAL HOME 0.2 

1997 EL PASO CNTY- CENTRAL HEATING & COOLING 11 4 

2000 ROCKY MOUNTAIN MATERIALS & ASPHALT INC 80.0 

2001 ROCKY MOUNTAIN MATERIALS & ASPHALT INC 17.1 

2004 DPIX, LLC 0.3 

TOTAL 826.8 

Colorado Springs Technical Support Document 12/2/09 PageS 
Colorado Department of Public Health and Environment I Air Pollution Control Division 

3. References 

APCD, 2008. Air Quality Control Commission Regulation Number 3. Stationary Source 

Permitting and Air Pollutant Emission Notice Requirements. 5 CCR 1001-5. 

<http:/ /www.cdphe.state.co. us/regulations/airregs/1 001 03stationarysourcepermitting.pdf > 

U.S. EPA, 2008. "2002 National Emissions Inventory Data & Documentation." 

< http://www.epa.gov/ttn/chief/net/2002inventory.html#documentation > 

Colorado Springs Technical Support Document 12/2/09 Page6 
State Implementation Plan Element 

Adopted by the Commission 

40 CFR Part 51 Appendix V 2.1 (d) 
Revised Carbon Monoxide Attainment/Maintenance Plan 

Colorado Springs Attainment/Maintenance Area 

10-year Revision to the Attamment/Mamtenance Plan Adopted by· 

The Colorado Air Quality Control Comm1ss1on, December 17, 2009 

'?d Rev1s1on to the Attamment/Maintenance Plan Adopted by· 

The U.S. Environmental Protection Agency, September 7, 2004 

The Colorado A1r Quality Control Comm1ss1on, December 18, 2003 

The Pikes Peak Area Council of Governments, September 10, 2003 

1st Revision to the Attainment/Maintenance Plan Approved by· 

The U.S. Environmental Protection Agency, December 22, 2000 

Origmal Redes1gnation Reguest and Attainment!Mamtenance Plan approved by· 

The U.S. Environmental Protection Agency, August 25, 1999 

Colorado Department 

of Public Health 

and Environment 

Revisions prepared by: 

The Air Pollution Control Division 

Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South 

Denver, CO 80246-1530 

(303) 692-31 00 

Colorado Spnngs Carbon Monoxide Attarnment/Marntenance Dian Rev1s1on 12/ 17/ 09 Page 1 
Background 

The Environmental Protection Agency (EPA) approved a carbon monoxide (CO) 

redesignation request and maintenance plan for the Colorado Springs area on August 25 , 

1999 (64 FR 46279), which became effective on October 29, 1999. This action, which 

was adopted by the Colorado Air Quality Control Commission (AQCC) in January 1998, 

established a base (attainment) year of 1993 and an out (maintenance) year of2010, 

provided for the continuation of the State's basic inspection and maintenance (VM) 

program and the oxygenated gasoline program in the Colorado Springs area (as the 

programs existed in January 1998), established a CO emission budget of 212 tons per day 

(tpd) to be utilized in transportation conformity determinations, and established a 

contingency plan in the event a violation of the CO National Ambient Air Quality 

Standards (NAAQS) was measured. 

On December 22, 2000, the EPA approved a revised Colorado Springs area CO 

attainment/maintenance plan, which became effective on February 20, 2001 (65 FR 

80779). This action, which was adopted by the AQCC in February 2000, revised the 

attainment year from 1993 to 1990, provided for the continuation of the basic UM 

program, eliminated the oxygenated gasoline program in El Paso County, revised the 

maintenance demonstration, revised the contingency plan, and revised the CO emission 

budget from 212 tpd to 270 tpd for the period 2001 and beyond. 

On September 7, 2004, the EPA approved another revised Colorado Springs area CO 

attainment/maintenance plan, which became effective on November 8, 2004 (69 FR 

54024). This action, which was adopted by the AQCC in December 2003, updated the 

emission inventories using the latest EPA-approved tools (including the MOBILE6.2 onroad mobile sources emission model), eliminated the basic 1/M program in El Paso 

County from the federal State Implementation Plan (SIP), extended the maintenance year 

to 2015, and revised the CO emission budget from 270 tpd to 531 tpd for the period 2010 

and beyond. 

This revision to the attainment/maintenance plan-- considered a " limited maintenance 

plan" - revises the attainment year from 1990 to 2007, updates the base year emission 

inventory using the latest EPA-approved tools (including the MOBILE 6.2 on-road 

mobile sources emission model), and extends the maintenance year through 2020. This 

attainment/maintenance plan confirms that the CO standard will be maintained for a 

second ten-year period after the original redesignation. 

Limited Maintenance Plan Option 

Colorado is using the Limited Maintenance Plan option in preparing this second ten-year 

revision. The option is explained in EPA guidance of October 6, 1995, from Joseph W. 

Paisie, Group Leader, Integrated Policy and Strategies Group, U.S. Environmental 

Protection Agency. 

The guidance allows for a less rigorous approach than was previously required in 

developing attainment/maintenance plans for CO nonattainment areas that have design 

Colorado Spnngs Carbon Monox1de Atta1nment1Mamtenance Plan Rev1s1on 12/17/09 Page 2 
values at or below 7.65 ppm (85% of the CO NAAQS). The Colorado Springs area's 

design value in this plan revision is 2.3 ppm (approximately 26% of the CO NAAQS). 

The Colorado Springs attainment/maintenance area's design value in the first ten-year 

plan was 5.5 ppm. The design values were determined by using the secqnd-highest 

maximum eight-hour value of eight consecutive quarters, as required by EPA guidance. 

The Colorado Springs attainment/maintenance area has shown a continued reduction in 

CO values throughout the maintenance period. 

The limited maintenance plan approach requires development of an emission inventory 

but does not require the inventory to be projected for future years. The maintenance 

demonstration is considered to be satisfied if the monitoring data show that the area is 

meeting the air quality criteria for limited maintenance areas (at or below 7.65 ppm or 

85% of the CO NAAQS). 

Transportation conformity is demonstrated by showing that the transportation plans are 

consistent with the emission budget. The guidance for limited maintenance plans state 

that emissions budgets may be treated as essentially non-constraining for transportation 

conformity because it is unreasonable to expect that such an area will experience so much 

growth during the maintenance period that a violation of the CO NAAQS would result. 

Therefore, the "budget test" of the transportation conformity rule is met, according to the 

guidance. 

Continued Attainment of the Carbon Monoxide Standard 

Attainment of the national ambient air quality standards for carbon monoxide is 

demonstrated when monitoring data for each site show no more than one exceedance per 

year ofthe 8-hour (9 ppm) and 1-hour (35 ppm) standards. The 8-hour standard has not 

been exceeded in the Colorado Springs area since 1989. The 1-hour standard has not been 

exceeded since 1979. 

Monitoring data for 1999-2008 demonstrates that the Colorado Springs 

attainment/maintenance area continues to attain/maintain the national standard for carbon 

monoxide as required by 40 CFR 50.8. Data from 1999 through 2008 are provided to 

demonstrate continual attainment/maintenance since the redesignation to attainment was 

promulgated in 1999. This demonstration is based on quality assured monitoring data 

representative of the location of expected maximum concentrations of carbon monoxide 

in the Colorado Springs attainment/maintenance area. Data presented is the second 

highest maximum value recorded at the monitors. The second maximum value is used by 

EPA for determining compliance with the CO NAAQS. 

The monitoring data presented in Table 1 verifies that the Colorado Springs 

attainment/maintenance area continues to attain the 8-hour NAAQS for carbon 

monoxide. Data recovery rates for the monitor exceeded the 75% completeness 

requirements for all years. All state and federal quality assurance procedures were 

complied with, further substantiating the validity of the measurements as indicators of 

ambient carbon monoxide levels in the Colorado Springs attainment/maintenance area. 

Table 1 

Colorado Spnngs Carbon Monoxide Attammeni:/Mamtenance Plan Rev1s1on 12/17/09 Page 3 
1999-2008, 8-Hour Carbon Monoxide Summary for Colorado Springs 

Standard: 8-hour = 9 ppm* 

8-Hour 2°0 Maximum (ppm) 

Site Name 1999 12000 12001 

Colo. Spgs., 690 W. Hwy. 24 5.2 1 4.2 1 4.4 

8-Hour 2nd Maximum {ppm} 

12002 

1 5.1 

Site Name 2003 2004 2005 2006 2007 

Colo. Spgs., 690 W. Hwy. 24 3.9 3.1 2.7 2.4 2.1 

*Due to mathematical rounding, a value of9.5 ppm or greater is necessary to exceed the standard. 

2008 

2.3 

Colorado Springs Carbon Monoxide Attainment/Maintenance Area Boundaries 

Beginning near the Town of Palmer Lake, at the Northwest comer of the Study Area at a 

point on the El Paso/Douglas County line, also on the Pike National Forest boundary, 

then: east along the County line to Elbert Road; south on Elbert Road to Judge Orr Road; 

east on Judge Orr Road to Ellicott Highway; south on Ellicott Highway to Squirrel Creek 

Road; west on Squirrel Creek Road to Williams Creek; south along Williams Creek to the 

confluence of Williams and Fountain Creeks; south along Foun:ain Creek to the El 

Paso/Pueblo County line; west on the County line to 1-25; north on 1-25 to Exit 132; west 

on Magrath to Weston Ave.; south on Weston Ave. to Barkeley Ave. and then straight on 

to Specker Ave.; northwest on Specker Ave. to Titus Blvd.; west on Titus Blvd. to SH115; south on SH-115 to Rock Creek; northwest along Rock Creek to the Pike National 

Forest boundary; north along the Forest boundary to Old Stage Road; southwest on Old 

Stage Road to Gold Camp Road; north on Gold Camp Road to High Drive; north on High 

Drive to Lower Gold Camp Road; north on Lower Gold Camp Road to the Pike National 

Forest boundary; west along southern boundary of Sections 16, 17, and 18 ofTownship 

14 South (T 14 S), Range 67 West (R 67 W); north along the western boundary of 

Sections 7 and 6 ofT 14S R67 W; and east along the northern boundary of Sections 5 and 

4 of Tl4S, R67W to US-24; northwest on US-24 to the Pikes Peak Toll Road; west on 

the Toll Road to the El Paso/Teller County line; north along the County line to Crystola 

Creek; west on Crystola Creek to County Road 28, north on County Road 282 to US-24; 

northeast on US-24 to Trout Creek Road; northwest on Trout Creek Road to Trout Creek; 

north along Trout Creek to the confluence of Trout and Mule Creeks; north along Mule 

Creek to Long Gulch; east along Long Gulch to White Gulch; east along White Gulch to 

Rampart Range Road; southeast on Rampart Range Road to the Pike National Forest 

Boundary; north along the Forest boundary to the El Paso/Douglas County line, to the 

point of origin. 

Colorado Spnngs Carbon Monox1de Attamment/Mamtenance Plan Rev1s1on 12/17/09 Page 4 
Figure 1. Colorado Springs Carbon Monoxide Attainment/Maintenance Area 

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Colorado Spnngs Carbon Monox1de AttammentjMa1ntenance Plan Rev1sion 12/17/09 

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Page 5 
Emission Inventories 

The area shown in Figure 1 represents the area in which the Pikes Peak Area Council of 

Governments (PPACG) serves as the "Lead Planning Agency" for air quality and the 

"Metropolitan Planning Organization" (MPO) for transportation. 

This attainment/maintenance plan revision utilizes 2007 as the attainment year for 

emission inventories, which is the same year from which the 2.3 ppm design value was 

derived. Emission inventories for a typical winter day are presented in Table 2 for the 

2007 attainment year. Each inventory accounts for the emission control programs 

effective during that period. 

The modeling domain consists of the Colorado Springs attainment/maintenance area, 

which encompasses the city of Colorado Springs and surrounding communities (see 

Figure 1). The emission inventories, included here and detailed in the Technical Support 

Document for this attainment/maintenance plan revision, were developed using U.S. 

Environmental Protection Agency (EPA) approved emissions modeling methods, 

including EPA's MOBILE6 model and local VMT data for on-road mobile source 

emissions, EPA's non-road model, local demographic information for area and off-road 

sources, and reported actual emissions for point sources. The inventory represents 

average daily winter emissions. The MOBILE6 and non-road model inputs represent 

these average daily winter conditions. Heating and wood burning emissions were 

apportioned from annual emission estimates by heating degree day data from the Western 

Regional Climate Center. Other source categories were apportioned from annual to daily 

by dividing by 365. 

Table 2. CARBON MONOXIDE Emission Inventory (tons per day) 

Inventory_ Summary Source Category 2007 

Aircraft 2.92 

Biogenic 0.00 

Commercial Cooking 0.19 

Fuel Combustion 1.62 

Highway Vehicles 319.16 

Non O&G Point Sources 2.27 

Non-Road 40.45 

Railroads 0.21 

Structure Fires 0.09 

Woodburning 140.49 

Grand TOTAL 507.39 

Note: Results are reported w1th two dec1mal place prec1s1on to prov1de representatiOn of smaller source categones. 

Th1s level of prec1s1on IS not mtended to suggest a level of accumcy. 

Colorado Spnngs Carbon Monoxide Attamment/Mamtenance Plan Revision 12/17/09 Page 6 
Enforceable Control Measures for the Maintenance Period 

• Federal Motor Vehicle Emission Control tailpipe standards and 

regulations, including those for small engines and non-road mobile 

sources. Credit is taken for these federal requirements, but they are part of 

a federally-administered program and not a state commitment of the 

Colorado SIP. 

• Air Quality Control Commission (AQCC) Regulation No. 3, Air Pollution 

Emission Notices - Permits 

• AQCC Regulation No.4, Wood Stove Standards 

• AQCC Regulation Number 6, New Source Performance Standards 

• AQCC Common Provisions Rule 

The Common Provisions and Regulation No. 6 delineate industrial source control 

programs. The Common Provisions, and Parts A and B of Regulation No.3, already are 

included in the approved Colorado SIP. Regulation No.6 and Part C of Regulation No.3 

implement the federal standards of performance for new stationary sources and the 

federal operating permit program. The revised Colorado Springs attainment/maintenance 

plan makes no changes to these regulations. 

Maintenance Demonstration 

This attainment/maintenance plan utilizes the EPA's Limited Maintenance Plan option, 

as explained above. The Limited Maintenance Plan approach can be utilized when an 

area has a design value at or below 7.65 ppm (85% of the CO NAAQS). The design 

value for the Colorado Springs attainment/maintenance area is 2.3 ppm (approximately 

26% of the CO NAAQS), which is the highest second maximum concentration for the 

2007-2008 monitoring period. 

Colorado Spnngs Carbon Monoxide Attamment/Maintenance Plan Rev1s1on 12/17/09 Page 7 
Transportation Conformity Determination 

Under the Limited Maintenance Plan approach, transportation conformity is 

demonstrated by showing that transportation plans are consistent with any existing 

emission budgets. When any existing budgets expire, conformity is then presumed and 

regional analyses and emission budget tests for transportation conformity are no longer 

necessary. The guidance for limited maintenance plans states that emission budgets may 

be treated as essentially non-constraining for transportation conformity because it is 

unreasonable to expect that such an area will experience so much growth during the 

maintenance period that a violation of the CO NAAQS would result. Therefore, the 

"budget test" of the transportation conformity rule is met, according to the guidance. 

For the Colorado Springs Attainment/Maintenance Area, the previous EPA-approved 

motor vehicle emission budget was531 tons of carbon monoxide per day for 2010 and 

beyond (69 FR 54019, September 7, 2004). According to the EPA's Limited 

Maintenance Plan guidance and SIP and conformity requirements, the motor vehicle 

emission budget budget is to remain in place, and conformity demonstrated to this motor 

vehicle emission budget, through 2010. Beginning in 2011, this motor vehicle emission 

budget is no longer applicable and a regional emissions analysis will not need to be 

performed for conformity dterminations for the respective long range transportation plan 

(LRTP) or transportation improvement program (TIP) because the 2010 motor vehicle 

emission budget would no longer be in the timeframe. of the transportation plan. 

However,, until such time as the Limited Maintenance Plan revision becomes Federallyeffective (i.e., until EPA's adequacy finding is effective), the PPACG will need to 

continue to perform the necessary regional emissions analyses for the current motor 

vehicle emission budget for the appropriate years in their respective LR TP and TIP 

conformity determinations. 

While the Colorado Springs Attainment/Maintenance Area (under the Limited 

Maintenance Plan approach) is not subject to the budget test, the area remains subject to 

other transportation conformity requirements. 

Monitoring Network I Verification of Continued Attainment 

The Air Pollution Control Division (APCD) will continue to operate an 

appropriate air quality monitoring network in accordance with 40 CFR Part 58 to verify 

the continued attainment of the CO NAAQS. If measured mobile source parameters 

(e.g., vehicle miles traveled, congestion, fleet mix, etc.) change significantly over time, 

the APCD will perform the appropriate studies to determine whether additional and/or resited monitors are necessary. An annual review of the NAMS/SLAMS air quality 

surveillance system will be conducted in accordance with 40 CFR 58.10 to determine, 

whether additional and/or re-sited monitors are necessary and to determine whether the 

system continues to meet the monitoring objectives presented in Appendix D of 40 CFR 

Part 58. 

Colorado Spnngs Carbon Monoxide Attamment/Mamtenance Plan Rev1s1on 12/17/09 Page 8 
Contingency Plan 

Section 175A(d) of the Clean Air Act requires that the attainment/maintenance 

plan contain contingency provisions to assure that the State will promptly correct any 

violation ofthe CO NAAQS which occurs in the Colorado Springs 

attainment/maintenance area. 

The contingency plan must ensure that the contingency measures are adopted 

expeditiously once the need is triggered. The primary elements of the contingency plan 

involve the tracking and triggering mechanisms to determine when contingency measures 

are needed and a process for implementing appropriate control measures. 

Tracking 

The tracking plan for the Colorado Springs attainment/maintenance area consists of 

continuous carbon monoxide monitoring and analysis of carbon monoxide 

concentrations by the APCD. The APCD will notify the EPA, the AQCC, the PPACG 

and local governments of any exceedance of the carbon monoxide standard within 30 

days of occurrence. The ongoing regional transportation planning process carried out by 

the PPACG in coordination with the Colorado Department of Transportation (CDOT), 

the APCD, the AQCC, and the EPA, will serve as another means of tracking mobile 

source carbon monoxide emissions into the future. Since revisions to the regions' 

transportation improvement programs are prepared every two years and must go through 

a transportation conformity determination, a process is in place to periodically review the 

VMT and mobile source emissions of carbon monoxide presented in this 

attainment/maintenance plan. 

Triggering and Response 

Triggering of the contingency plan does not automatically require a revision of the SIP, 

nor is the area necessarily redesignated once again to nonattainment. Instead, the State 

will have an appropriate time-frame to correct a violation by implementing one or more 

adopted contingency measures. In the event that violations continue to occur after 

contingency measures have been implemented, additional contingency measures will be 

implemented until the violations are corrected. 

An exceedance of the CO NAAQS (any value 9.5 ppm or greater) may trigger a 

voluntary, local process by the PPACG and the APCD to identify and evaluate potential 

contingency measures. However, the only federally enforceable trigger for mandatory 

implementation of contingency measures shall be a violation of the CO NAAQS. 

Specifically, this would be a second value of 9.5 ppm or greater at the same monitor 

during any calendar year. 

The State will move forward with mandatory implementation of contingency measures 

under the SIP if a violation of the CO NAAQS occurs. No more than 60 days after being 

notified by the APCD that a violation occurred, the PPACG - in conjunction with the 

APCD, the AQCC and local governments- will initiate a process to begin evaluating 

Colorado Spnngs Carbon Monox1de Atta1nment/Mamtenance Plan Rev1s1on 12/17/09 Page 9 
potential contingency measures. The PPACG will present recommendations within 120 

days of notification, and the recommended contingency measures will be presented to the 

AQCC within 180 days of notification. 

The AQCC then will hold a public hearing to consider the recommended contingency 

measures, along with any other contingency measures the AQCC believes may be 

appropriate to effectively address the violation. The necessary contingency measures will 

be adopted and implemented within one year after a violation occurs. 

List of Potential Contingency Measures 

The PPACG and the APCD may choose one or more ofthe following measures to 

recommend to the AQCC for consideration. The measures will be designed to bring the 

area quickly back into compliance with the CO NAAQS. 

• An basic vehicle inspection and maintenance program as set forth in AQCC 

Regulation No. 11 , prior to modifications made as of December 18, 2003, with 

the addition of any on-board diagnostics components required by federal law. 

• A 2.7% oxygenated gasoline progam as set forth in AQCC Regulation No. 13, 

prior to modifications made as of February 17, 2000. 

• In addition to these potential contingency measures, the State may evaluate other 

potential strategies, including but not limited to, nonattainment New Source 

Review permitting requirements, enhanced liM, transportation control measures 

and mandatory wood burning restrictions, in order to address any future violations 

in the most appropriate and effective manner possible. 

Subsequent Attainment/Maintenance Plan Revisions 

It is required that an attainment/maintenance plan revision be submitted to the EPA 

demonstrating that the carbon monoxide standard will be maintained for a second tenyear period. The purpose of this final revision is to fulfill that requirement for an 

additional ten years (through 2020) following the first ten-year period. 

If future changes in mobile source models or other unforeseen considerations raise 

potential issues with the conformity process, the State will address the need to revise the 

attainment/maintenance plan at that time. 

Colorado Spnngs Carbon Monox1de Attamment/Mamtenance Plan Rev1s1on 12/17/09 Page 10 
Colorado Air Quality Control Commission 

Meeting Minutes 

- Action of the Commission to SIP Element Revision 

40 CFR Part 51 Appendix V 2.1 (g) 
STATE OF COLORADO 

Bill Ritter, Jr. , Governor 

James B. Martm, Executive Director 

COLORADO AIR QUALITY CONTROL COMMISSION 

http://www.cdphe.state.co.us 

4300 Cherry Creek Dnve South 

OED-OLRA-A5 

Denver, Colorado 80246-1530 

Phone (303) 692-3 100 

Fax (303) 691-7702 

TDD (303) 691-7700 

Colorado Department 

of Public Health 

and Environment 

Colorado Air Quality Control Commission 

~unber17,2009 

MEETING MINUTES 

Location: Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South, Sabin Room 

Members Present: 

Denver, CO 80246 

Robert Amott 

Teresa Coons 

Barbara Roberts 

Members Absent: None 

Commission Staff: 

Division Staff: 

Doug Lempke 

Paul Tourangeau 

Dena Wojtach 

Attorney General's Office: Jerry Goad 

Radford Byerly 

John Loewy 

Jon Slutsky 

Theresa Martin 

Ray Mohr 

Lisa Silva 

CALL TO ORDER AND DETERMINATION OF A QUORUM 

Ashley Campsie 

Dawn Meyers (depart J·OO) 

Jim Wilson (depart J·OO) 

Lisa Clarke Bob True 

Chris Dann 

Chair Roberts called the meeting to order at 9:10 AM and determined that a quorum of 

Commissioners was now present with nine Commissioners. 

APPROVAL OF MEETING MINUTES FOR NOVEMBER 19, 2009 

Chair Roberts asked the Commission if there were any modifications to the minutes. 

There were minor revisions provided by Commissioner Wilson. 

Motion: 

Moved: 

Second: 

Discussion: 

Carried: 

To approve the November 19, 2009 Meeting Minutes 

Commissioner Coons 

Commissioner Meyers 

none 

9-0 
PUBLIC COMMENT 

Chair Roberts asked if there were any members of the public who wished to make a comment on 

any air pollution issue not on the agenda. David Wolfsey with Sonic Spark, LLC presented the 

Commission with documentation regarding his concerns regarding the HHO convertor. Wolfsey 

commented that he believed that the HHO produced major destructive ECO pollutants such as 

nitric acid, hydrogen cyanide and nitrogen oxides and wishes the Commission to look into this 

matter and his findings of this product. Wolfsey provided the Commission with a copy of the 

web pages advertising the HHO systems noting that there was no mention in the literature of the 

environmental effects. 

AGENDA REVIEW 

Chair Roberts asked Lempke to review the meeting agenda noting any items that may have 

changed, been added or deleted. Lempke commented that Item #8 Interstate Transport SIP had 

some issues that were raised by EPA and the Commission agreed to continue this item to January 

13,2010 in order to allow EPA to provide further recommendations how the Division can 

produce a document that would be acceptable by EPA. 

REQUEST FOR PUBLIC HEARING FEBRUARY 18, 201 0 

Contingency Provisions for the Rocky Mountain National Park Nitrogen Deposition 

Reduction Contingency Plan 

At 9:29AM Lisa Clarke of the Division provided the Commission with background surrounding 

the RMNP Nitrogen Deposition Reduction Plan and that a draft Contingency Plan was required 

by the end of 2009. Clarke reviewed the Contingency Plan time line and the measurement 

development process. Clarke requested that the Commission set a public hearing to consider and 

endorse the Contingency Plan. Roberts commented that the Commission typically does not take 

public comment however; there was a request by a citizen to be heard regarding the timeliness of 

this hearing. Evelyn King representing citizens that had submitted 140 plus letters to the 

NFRMPO and Lempke. King noted her opposition to the Contingency Plan because of the 

inclusion of and reliance on liM information. The Commission discussed this issue. Coons 

asked to conduct the hearing after the Regulation Number 11 hearing that occurs in March. 

Motion: 

Moved: 

Second: 

Discussion: 

Carried: 

To approve the motion for hearing on April15, 2010 

Commissioner Wilson 

Commissioner Amott 

none 

9-0 

REQUEST FOR RULEMAKING HEARINGS NOVEMBER 19, 2009 

Ambient Air Quality Standards Regulation 

At 9:44AM Dena Wojtach of the Division provided the Commission with an overview of the 

Ambient Air Quality Standards Regulation and the reasons surrounding the proposed revisions. 

Wojtach noted that the removal of the Ambient Air Standards Table in Section II was necessary, 

as it was a duplication of the standards set by EPA and nationally applied without any action by 

the State. 

2 
Wojtach also noted that the removal of S02 increments in Section I. B. was necessary as they 

were artifacts from the 1970's rulemaking, could not be applied per current rules, and were not 

applicable to any area of Colorado. Wojtach noted that while this proposal removes the stateonly S02 increment standards, it does not undermine existing protection for Colorado Federal 

Class I and II areas, or the national monuments and forest service primitive areas granted under 

Regulation Number 3. Wojtach requested that the Commission set a rulemaking hearing to 

consider the revisions to the regulation. Coons asked if a link to what could be added and 

Wojtach noted that there is a possibility that the link changes and then it becomes inaccurate 

information. Tourangeau commented that the Division would discuss ifthere were a way to 

include a link, but also noted where it could be found in case the link was changed or otherwise 

disconnected. 

Motion: 

Moved: 

Second: 

Discussion: 

Carried: 

To approve the motion for hearing on March 18, 2010 

Commissioner Wilson 

Commissioner Slutsky 

none 

9-0 

Regulation Number 8, Part C 

At 9:53AM Dena Wojtach of the Division provided the Commission with an overview of why 

the Division believes the lead emission standard and associated compliance demonstrations 

requirement should be removed from Regulation Number 8, Part C. Wojtach noted that the 

proposal to remove the existing lead emission standard and its associated compliance 

demonstration requirements was due to the recent promulgation of a new Lead National Ambient 

Air Quality Standard. Wojtach requested that the Commission set a rulemaking hearing to 

consider the revisions to the regulation. 

Motion: 

Moved: 

Second: 

Discussion: 

Carried: 

To approve the motion for hearing on March 18,2010 

Commissioner Byerly 

Commissioner Loewy 

none 

9-0 

Regulation Number 11 

At 9:57AM Garry Kaufman of the Division provided an overview of the revisions proposed 

which included: proposed program area boundaries in Larimer and Weld Counties, phase-in of 

the IM240 emissions pass/fail cutpoints, technical specifications for fleet-only emissions testing 

equipment, and the modification of the start-up date consistent with statutory directives. 

Kaufman commented that subsequent to the Commission's action in December 2008, the 

General Assembly passed Senate Bill 09-003 that revised the North Front Range program area 

boundaries to more accurately reflect the current ozone nonattainment area boundary and 

redefined the boundaries to incorporate a greater land area and affected population. Kaufman 

noted that the boundaries for the program would be set in accordance with the boundaries set 

forth in statute as a result of SB09-003. 

3 
Kaufman commented that in order to provide an ease of transition in the North Front Range a 

less stringent set of IM240 emissions pass/fail cutpoints was being proposed as well as limited 

flexibility to the state date of the enhanced inspection program. Kaufman also noted that the 

technical proposal included a set of detailed specifications for an exhaust Test Analyzer System 

that would be used by owners of gasoline vehicle fleets that choose to do their own inspections. 

Kaufman requested that the Commission set a rulemaking hearing to consider the proposed 

changes. Roberts commented that there were a number of public who wished to comment. State 

Representative Glenn Vaad of Weld County noted his support to delay the hearing. Senator 

Scott Renfroe urged the Commission to listen to the citizens of Weld and Larimer Counties and 

noted that he was bringing this issue to Legislation as an act to repeal SB09-003. Barbara 

Kirkmeyer Weld County Commissioner noted her opposition to program area boundaries. 

Kirkmeyer stated that local monitors continued to show falling levels of ozone and that the 

proposed program would be burdensome for the county clerk and citizens. Bruce Barker Weld 

County Attorney referenced Section 42 in SB09-003, doesn't need to implement requirement 

until end of 2011. Sean Conway Weld County Commissioner expressed his agreement with the 

others and presented NFRMPO Resolution 2009-7 and asked for postponement of this hearing. 

Carol Kirkstadt of Larimer County expressed her support of postponement. Evelyn King noted 

her support of the request to delay this hearing and noted that she believed that there was lack of 

compliance. King commented that if the Commission chose to go forward with the hearing in 

March, that they request that the hearing occur in the evening and at a location in the North Front 

Range to accommodate the citizens of Larimer and Weld counties. King also noted that several 

of the letters had been sent directly to the Division and asked that the Division turn those letters 

over to the Commission for the record. King also commented that the program would create 

more emissions as it would force citizens to drive long distances to test centers. Campsie and 

Wilson asked how this might impact the Ozone SIP adopted from December 2008 and what the 

fallout may be such as does the timing impact what has already been done. Silverstein 

responded that the expansion to the North Front Range is a state-only provision so it's not in the 

SIP that was submitted to EPA. Pierre De Milt Mayor of the Town of Severance expressed his 

support in postponement of the Regulation Number 11 hearing. 

Roberts noted that there was a statute before us that changes some of the decisions made to the 

Ozone Plan from December 2008. Roberts commented that the statute would indicate that a 

hearing must be conducted to hear the statutory authority as well as to hear from both sides on 

this. Roberts questioned if there was a delay could it still get up and running by July and 

Tourangeau responded that a postponement would delay everything. Kaufman noted that it 

could impact implementation of stations, hiring of contractors and other processes and believes 

that the sooner the hearing occurs the better. Roberts noted that one of the questions that the 

Commission will have to answer is the interpretation of the statute and determine whether it is 

self-implementing; does the statute say that the Commission has the authority of postponing the 

program and this must be discussed within a public hearing. Amott expressed concern if the 

changing standard would impact the boundaries and implementation. Slutsky commented that it 

sounds like the Division is planning to move forward with implementation of a full I/M program 

and if there is going to be a delay, that decision should be made sooner rather than later to avoid 

the Division doing all the work for nothing. Roberts noted to the Commission that there were 

two decisions to be made: 1) postponement ofthe hearing or not and 2) location ofthe hearing. 

4 
The Commission agreed that the hearing would be conducted in March, the venue would be in 

the North Front Range and the hearing would be held during the day. Barbara Kirkmeyer noted 

that they would be willing to work with Lempke to determine a location. 

Motion: 

Moved: 

To approve the motion for hearing on March 18, 2010 and 

Commissioner Loewy 

Second: Commissioner Slutsky 

Discussion: none 

Carried: 9-0 

WRITTEN COMMENT 0NL Y RULEMAKING HEARING 

Common Provisions Regulation 

At 11 :04 AM Lempke noted that there would not be an official presentation as this was a written 

comment only rulemaking hearing regarding proposed revisions to the Common Provisions 

Regulation, Section I. G., specific to the definition of "negligibly reactive volatile organic 

compound" and "volatile organic compound" to be consistent with the federal definitions. 

Lempke commented that the Commission had not received any comments. 

Motion: To adopt Common Provisions Regulation revisions as proposed by the 

Division 

Moved: Commissioner Slutsky 

Second: Commissioner Campsie 

Discussion: none 

Carried: 9-0 

COMMISSION ACTION ONLY 

Regulation Number 13: Oxygenated Fuels Program 

At 11 :07 AM Lempke noted that on August 20, 2009 the Commission acted to adopt a proposal 

to repeal the requirements of Regulation Number 13 in its entirety effective February 1, 2011. 

Lempke noted that this action of the Commission was not timely filed with the Secretary of State 

and did not become effective. The Commission considered an action to resubmit their August 

action to the Secretary of State for publication. 

Motion: To resubmit the August 20, 2009 adoption by the Commission repealing the 

requirements of Regulation Number 13 in its entirety effective February 1, 

2011 to the Secretary of State for publication in the CCR 

Moved: Commissioner Wilson 

Second: Commissioner Coons 

Discussion: none 

Carried: 9-0 

PUBLIC HEARINGS 

Denver Regional Council of Governments (DRCOG) Conformity 

At 11:10 AM Lisa Silva of the Division noted that the presentation would include information 

from the DRCOG regarding its anticipated Transportation Conformity findings regarding the 

2035 Regional Transportation Plan second cycle amendments and the 2008/2013 TIP. 

5 
Silva commented that the NFRMPO was also in concurrence. Silva noted that neither the 

NFRMPO nor the Upper Front Range Transportation Planning Region had amended their plans 

but because they were part of the 8-Hour Ozone Nonattainment area, transportation conformity 

must be assured for those areas as well as the Denver region until the emission budgets for the 

individual areas were approved. Emily Chen of the DRCOG reviewed the Cycle 2 Amendments 

to the 2035 Regional Transportation Plan and the 2008/2013 TIP. Chen noted that the 

amendments included a new toll facility to the regional system and three partial interchanges 

associated with the Jefferson Parkway, widening to the roadway system on Federal Blvd and also 

on 1441

h Avenue, and a RTD station location change in the North Metro corridor. Chen 

reviewed with the Commission the conformity tests conducted and what the results indicated. 

Chen commented that DRCOG believed they had made a positive conformity finding for its 

amended 2035 Regional Transportation Plan. Silva reviewed with the Commission the 

Division's transportation modeling inputs and noted that they had ran the air quality model, 

finding that future emissions were below allowable mobile source emission budgets for carbon 

monoxide, PM10, and NOx and VOC for the 1-Hour Ozone Maintenance Area. Silva also 

commented that future VOC and NOx emissions in the 8-Hour Ozone Nonattainment Area were 

lower than base case (year 2002), and lower than 1-Hour Ozone emission budgets i.e., the 

interim conformity tests passed and asked that the Commission concur with the positive 

conformity findings. Slutsky asked about the $204 million and if it is just from tolls and private 

entities and Chen responded that it was construction costs on the project. Slutsky questioned 

whether or not this was really considered fiscally constrained." 

Byerly expressed concern regarding the Commission's commitment to this Plan commenting that 

there is about a 2-mile gap between the roadways. Cook commented that the project was 

proposed by the Jefferson Parkway Authority and they had provided information in the proposal 

such as traffic, economic development in the area. Cook noted that DRCOG had run it through 

the conformity modeling and found that the region still was passing the required tests. Byerly 

commented that if the roads are connected up, there will be a lot more traffic. Arnott asked if 

there was an obligation to relook at the impact of the other segments that had been approved for 

adding a segment. Cook replied that there isn't a legal obligation and the DRCOG Board of 

Directors had not directed them to do a larger scale analysis, but the Public Highway Authority is 

required to conduct a smaller analysis for the southern corridor to Highway 93. Roberts asked if 

a project was proposed and the initial analysis indicated it would not conform would DRCOG 

then work with the Division to work out an offsetting program. Cook replied that the 

amendments would not be passed and DRCOG would have to change the amendment package or 

look at alternatives with the Division and the RAQC. Coons asked if recent projections that 

were implemented in the Plan were reflective of the recent economic downturn. Cook responded 

that those had not been incorporated; that DRCOG revises the assumptions every three to four 

years and isn't scheduled to do that for another couple of years, but have done modifications to 

the transportation model to reflect the downturn. Wilson asked when the segment is modeled; 

does it have an impact on the modeled factors of population growth? Cook replied that there was 

a cyclical process of land use in the transportation model; and that the more accessible an area 

was, the more development that the land use model would plug into that area and those zones. 

Cook noted that DRCOG didn't do a thorough analysis though. 

6 
Motion: To adopt revisions as proposed by DRCOG and the Division with a letter 

identifying the Commission's concerns regarding the processes, analyses, and 

funding 

Moved: Commissioner Coons 

Second: Commissioner Meyers 

Discussion: None 

Carried: 7-2 (Byerly and Arnott opposed) 

RULEMAKING HEARINGS 

Interstate Transport SIP 

THIS ITEM WAS CONTINUED TO JANUARY 13, 2010 

Colorado Springs Carbon Monoxide Maintenance Plan Revision 

At 1:04PM Chris Dann ofthe Division and Rich Muzzy ofPPACG presented to the 

Commission revisions to the CO maintenance plan for Colorado Springs. Dann noted that this 

was the second of two 10-year plans that were required by the Clean Air Act. Dann commented 

that the data confirms that the Colorado Springs area would continue to attain the carbon 

monoxide National Ambient Air Quality Standards (NAAQS) through 2020 and that the area had 

recorded no violations ofthe standard since the 1993 attainment year. Coons remarked about the 

spike in 2002 and if the Division knew what triggered this and Muzzy responded that it was 

possibly due to it being at a different location and possibly construction occurring at the time. 

Dann noted that particular location had been retired. 

Motion: To adopt Colorado Springs Carbon Monoxide Maintenance Plan revisions as 

proposed by the Division 

Moved: Commissioner Coons 

Second: Commissioner Campsie 

Discussion: none 

Carried: 7-0 

Greeley Carbon Monoxide Maintenance Plan Revision 

At 1:17 PM Bob True of the Division and Suzette Mallette ofNFRMPO presented to the 

Commission revisions to the CO maintenance plan for Greeley. True noted that this was the 

second oftwo 1 0-year plans that were required by the Clean Air Act. True commented that the 

data shows that Greeley would continue to attain the NAAQS through 2020 and that no 

additional control measures were required for Greeley to continue attaining the standard. True 

did note that if future changes in mobile source models or other unforeseen considerations raise 

potential issues with the maintenance of the standard that the State would address the need to 

revise the maintenance plan at that time. 

Motion: To adopt Greeley Carbon Monoxide Maintenance Plan revisions as proposed 

by the Division 

Moved: Commissioner Slutsky 

Second: Commissioner Coons 

Discussion: none 

Carried: 7-0 

7 
BRIEFINGS, DISCUSSIONS AND REPORTS 

Commissioner Informational Items 

Byerly noted that Silverstein had some information for the Commission about his discussions 

with the National Center for Atmospheric Research. Silverstein commented on a meeting that 

occurred a few months ago. Silverstein noted that Amott and Byerly were responsible for this 

meeting and it was with scientists and researchers to evaluate the science for ozone. Silverstein 

noted that there was excellent dialogue on photochemistry, the research on air shed modeling, 

and ozone balloons. Silverstein commented that he would provide a matrix to the Commission at 

the February meeting. Amott commented that the matrix was very helpful. Byerly commented 

that it was an excellent meeting and the scientists felt it was beneficial to develop a relationship 

with the Division. Amott thanked the Division staff for the ozone data that had been requested 

by himself and Wilson. Coons discussed the PM1 0 issues related to Mesa County. Slutsky 

asked about the HHO documentation provided by David Wolfsey and if a letter should be 

written. Lempke noted that it was something that needed to be addressed and that he would 

contact Wolfsey after investigation ofthe product. Slutsky commented that he and one of the 

Water Commissioner's visited the sugar plant in Fort Morgan. Slutsky noted that they did admit 

that things weren't working and that they were not sure how to make things work. Roberts noted 

that it would be beneficial to have a briefing regarding odor regulations. Tourangeau noted that 

Lind had been invited to tour the facility and had a discussion with the plant manager. 

Tourangeau commented that the Division would send Lind a letter. 

Division Director's Report 

Tourangeau discussed: 

• Greenhouse gas affects and the Clean Air Act Tailoring Rule. Tourangeau noted that the 

rule would bring C02 into the permitting world 

• EPA 8-hour ozone NAAQS proposal should be out before Christmas 

• Power plants (Lamar and Comanche 3)- EPA's rule under CAMR was vacated which 

triggered Section 112. Lamar and Comanche 3 fall under Section 112.g. and there is 

currently litigation occurring to ensure the plants were in compliance. 

Attorney General's Report 

Goad discussed: 

• V almont - Roy Young appeal to the Commission: Lempke provided an overview of what 

had occurred with the Valmont hearing and the letter received from Roy Young 

requesting an appeal. Goad provided input about the Commission's obligation regarding 

the appeal and what the Commission's options are in responding to the petition. Goad 

noted there were three options: 1) to do further or more detailed investigation into the 

allegations, 2) to deny the appeal on grounds of lack of substantial factual basis or 

pending an investigation, and 3) to provide an opportunity to gather more information 

· such as a request for submittals or to conduct a hearing. Roberts commented she felt that 

the Division should readdress Young's initial letter and provide a more complete 

response to Young. Will Allison provided information regarding the permit process 

relating to Young's letter. Coons noted that if a letter were done that it should be noted 

that even ifthere is an investigation that it doesn't mean there would be a different 

response. 

8 
Arnott asked what would occur if through an investigation Young was found to be 

correct. Allison responded that it could cause the plant to cease operation or operation 

with coal. Tourangeau agreed with Roberts that the Division could produce a letter 

however the letter cannot address the initial letter from Young as it had already gone to 

EPA, but should address his appeal or petition letter. Lempke noted that the Division 

should respond to the Commission on the petition and the Commission would then 

respond to Young. Goad asked that this discussion be put into a motion as it is part of a 

statutory requirement. 

Motion: Move to respond Mr. Young's petition ofDecember 2, 2009 and ask the 

Division provide the Commission with additional information. 

Moved: Commissioner Slutsky 

Second: Commissioner Coons 

Discussion: none 

Carried: 7-0 

Administrator's Report 

Lempke reviewed: 

• January meeting: will provide lunch and the meeting will be held in CIA, Commissioners 

will need to meet at the guard's desk in Bldg. A and would be escorted to Bldg. C. 

ACTION ITEMS 

• Wolfsey investigation and response 

• Determination of March meeting location 

• Send letter to DRCOG about conformity concerns 

• Provide matrix from APCD/NCAR meetings 

• Schedule briefing on odor regulation for informational exchange and invite the facility 

and the Lind's 

• Get response from Division regarding Young petition and then respond to Young 

Roberts commented that Commissioners should keep Interstate Transport documents for the 

January meeting so as not to duplicate materials. 

Adjourn at 2:35 PM 

9