Janet Napolitano 

Governor 

1 1 10 West Washington Street Phoenix, Arizona 85007 

(602) 771-2300 - www.adeq.state.az.us Stephen A. Owens 

Director 

December 22,2004 

Mr. Wayne Nastri, Regional Administrator 

U. S. Environmental Protection Agency, Region IX 

Mail Code: ORA-1 

75 Hawthorne Street 

San Francisco, CA 94.1 05 

Re: Withdrawal of the Finalstate Iilzplenzentatiorz Plan for the Douglas PMlo Nonattainnzeni 

Area, April 1993 

Dear Mr. Nastri: 

The purpose of this letter is to request that the Final State In7plementation Plan for the 

Douglas PMlo Nonattainment Area, April 1993, be withdrawn from coilsideration for any further 

action by the Enviroiunental Protection Agency (EPA). Based on new analyses and a clean air 

quality record, the Arizona Department of Enviromnental Quality (ADEQ) is cui-rently worlting 

to update the Arizona State Imple~nentatioil Plan (SIP) for the Douglas area. 

The consolidated Douglas/Paul Spur area was designated and classified as a inoderate 

PMlo nonattainment area by operation of law upon enactment of the 1990 Clean Air Act 

Amendments. As a result of the nonattai~unent designation, the State was required to submit a 

SIP for the area to provide for iinplementation and maintenance of the PMlo air quality 

standards. During the SIP developinent process, ADEQ determined that the priinary sources of 

ambient Phllo concentrations contributing to nonattaiiient in the Douglas and Paul Spur areas 

were unique, and different control strategies were required to address the PMlo concentrations in 

each area. For example, a lime plant was the primary source category in the Paul Spur area 

while road dust and pollutant transpol-t across the United StatesIMexico border were the priinary 

sources of PMlo in the Douglas area. As such, air quality pla~lning for each area was addressed 

under a separate process. 

I.p 1993, ADEQ submitted to EPA the PMlo SIP for the Douglas Area which included an 

assessinent of emissions and ambient impacts as well as implemented control strategies. The SIP 

for the Douglas area noted that because of inadequate control of einissions in Mexico, violations 

of the PMlo air quality standards were expected to continue. Since that time, however, ambient 

air quality monitoring data demonstrate that the Douglas area has attained both the a~ulual and 

24-hour PMlo standards with no recorded violations since at least 1994. Based on tlis 

Northern Regional Office Sout1iel.n Regional Office 

151 5 East Cedar Avenue * Suite F a Flagstaff, AZ 86004 400 West Congress Street Suite 433 Tucson, AZ 85701 

(928) 779-031 3 (520) 623-6733 

Printed on recycled papei 
Wayne Nastri 

December 22,2004 

Page 2 

information, ADEQ is currently working to develop an updated plan for the Douglas 

nonattainment area including additional illformation to support separate nonattainment 

boundaries for the Douglas and Paul Spur areas. 

As ADEQ moves forward to update the SIP, we are committed to ensuring that the air 

quality progress made through the years will be sustained with appropriate control strategies in 

place. We welcome and encourage EPA's participatioil as we work to develop a plan that will 

allow EPA to redesignate the Douglas area to attainment. If you have any questions regarding 

this request, please coiltact Nancy Wrona, Director, Air Quality Division, at (602) 771-2308. 

cc: Colleen McKaughan, EPA