# Revised Carbon Monoxide Maintenance Plan Fort Collins Attainment/MaintenanceArea

Attainment/Maintenance Plan Revision for Second 10-vearMaintenance Period: • Approved by the U.S. EPA
- Pending • Adopted by the Colorado Air Quality Control Commission
- December 16,2010 Original Redesignation Request andAttainment/Maintenance Plan: • Adoptedby The Colorado Air Quality Control Commission, July 18, 2002 • Approvedby The U. S. Environmental Protection Agency, July, 22, 2003

Revisions prepared by: The Air Pollution Control Division Colorado Department of Public Health & Environment 4300 Cherry Creek Drive South ColoradoDepartment Denver, CO 80246-1530 ofPublicHealth (303) 692-3100 andEnvironmentBackground The purpose ofthis revision to the Fort Collins carbon monoxide (CO) attainment/maintenance plan is to showcontinued attainment ofthe federal CO standard for a second ten-year term (from 2013 through 2023) as required by the federal CleanAir Act and the U.S. Environmental ProtectionAgency (EPA). The Fort Collins area was originally designated as nonattainment for CO in 1979 under provisions ofthe 1977 CleanAirAct (CAA). This designation was reaffirmed bythe 1990 CAA, and Fort Collinswas designated as a "moderate" CO nonattainment area with a design value of less than 12.7parts permillion, effectiveNovember 15, 1990 (56FR 56694, Nov. 6, 1991). The EPA approved a CO redesignation request and maintenance planfor the Fort Collins area on . July 22, 2003 (Federal RegisterNotice: 68 FR43316). That plan established an attainment year of 1992, and showed continued maintenance through 2015. The plan removed three control measures from the federally enforceable SIP effective January 1,2004: 1. Oxygenated Fuels Program 2. Basic motor vehicle inspection/maintenance (11M) program 3. Contingency measures included in the 1982 attainment SIP element. The oxygenated fuels program and the basic 

### 11M control measures were removed because they were no longer needed to showattainment ofthe CO national ambient air quality standards (NAAQS). Removal ofthe control programs complied with state requirements that maintenance plans be no more stringent than federal requirements. The contingency measures in the 1982 attainment SIP were removed because attainment areas are not required to have pre-selected contingency measures. History 1979: Fort Collins designated nonattainment for CO underprovisions ofthe Clean Air Act 1981: Motor vehicle inspection/maintenanceprogram begins. 1982: First State Implementation Plan element for Fort Collins adopted by the Colorado Air Quality Control Commissionto bring area into attainment by 1987. 1987-88: Attainment was not reached, and EPAnotified Colorado ofneed to correct SIP deficiencies. 1988: Oxyfuels program begins. 1991 : Fort Collins designated a "moderate"nonattainment areaunder the Clean AirAct revisions of 1990 and required to attain the CO NAAQS by December 31,1995. 1992: Fort Collins attained the CO NAAQS and has shown declining levels ofCO since that time. 1997-2000: Emission inventories updated and submitted to EPA as required by the 1990 CAAA. 2001: Clean Screenpilotprogram begins in 2001, with full testing implemented in 2002. The program is not a SIP control measure, butrather a local voluntary control effort to screen clean vehicles out ofthe mandatory emissions inspectionprogram. 

### 1 December 16,2010

- Fort Collins AttainmentlMaintenance Plan Revision2002: The AQCC approves a request to EPA to redesignate Fort Collins as an attainment area. The redesignation request and maintenanceplan is approved byEPAin 2003. The 11M and oxyfuelsprograms are removed as a federally-required SIP control measure effective 2004, but continue as local controlprograms after 2004. 2005: AQCC votes to discontinue 11M and oxyfuels effective January 1,2007, allowing a phase outperiod. 2008: While notpart ofa carbon monoxide strategy norpart ofthis CO SIP, an ozone action plan is adopted by the AQCC which includes an enhanced 11M program in parts ofLarimer and Weld Counties as a state-onlyrequirementto control ozone. The program is scheduled to begin byNovember 2010. 2010: AQCC considers revised CO attainment/maintenanceplanthat shows continued attainment ofthe CO standard through a second ten-year period through2023.

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 ofOctober 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 previouslyrequired in developing maintenance plans for CO nonattainment areas that have design values at orbelow7.65 ppm (85 percent ofthe CO NAAQS). Fort Collin's design value in this plan revision isjust 3.0 ppm (33 percent ofCONAAQS). Thedesign value was determined by using the highest second-highest maximum 8-hourvalue ofeight consecutive quarters. Thisvalue is referred to as "thehighest of the second highs" in a June 18, 1990 EPA memo from Willam G. Laxton that describes how to establish designvalues for both carbon monoxide and ozone. The limited maintenance plan approachrequires development ofan emissions inventory but does notrequire the inventory to be projected for future years. The maintenance demonstration is considered to be satisfied ifthe monitoring data showthat the area is meeting the air quality criteriafor limited maintenance areas (at orbelow 7.65 ppm or 85 percent ofthe CO NAAQS). Transportation conformity is demonstrated by showing that transportation plans are consistent with the emissions budget. The guidance for limited maintenance plans states 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 ofthe CO NAAQS would result. Therefore, the "budgettest" ofthe transportation conformityrule is met, according to the guidance.

2 December 16,2010

- Fort Collins AttainmentlMaintenance PlanRevisionContinued Attainment ofthe Carbon Monoxide Standard Attainment ofthe national ambient air quality standard for carbon monoxide is demonstrated when monitoring datafor each site show no more than one exceedance per year ofthe 8-hour (9 ppm) and I-hour (35 ppm) standards. Fort Collins has never exceeded the I-hour standard, so this maintenance plan only addresses the 8-hour standard. The 8-hour standard has notbeen exceeded in Fort Collins since 1991. Monitoring data for 2002-2009 demonstrates that Fort Collins continues to attain/maintainthe national standard for carbonmonoxide as required by 40 CFR50.8. Datafrom 2002 through 2009 are providedto demonstrate continual attainment/maintenance since the redesignation to attainmentwas promulgated in 2003. This demonstration is based on quality assured monitoring data representative ofthe location ofexpected maximum concentrations ofcarbon monoxide in the area (708 S. Mason St. in central Fort Collins). Datapresented is the secondhighest maximum value recorded atthe monitors. The second maximum value is used by EPA for detennining compliance with the CO NAAQS. The monitoring datapresented in Table 1verifies that Fort Collins continues to attain the national 8-hour standard for carbon monoxide. Datarecovery rates for the monitorexceeded the 75 percent completeness requirements for all years. All State and Federal quality assurance procedures were complied with, further substantiating the validity ofthe measurements as indicators ofambient carbon monoxide levels in Fort Collins.

3 December 16, 2010

- Fort Collins AttainmentIMaintenance Plan RevisionFigure 1. Fort Collins AttainmentlMaintenance Area

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.. Heliports Point Sources

• CO Point Sources Local Roads

-- RAIL_L1NES_100KftColl

-- HIGHWAYSftCollins

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- 1 Interstate-Rural

- 11 Interstate·Urban

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The Fort Collins attainment/maintenance area and the Fort Collins urban growth area are one and the same. The Fort Collins Urban Growth Area Boundary was adopted by the City ofFort Collins and the Larimer County Commissioners and has been in effect since July 30, 1991.

4 December 16,2010

- Fort Collins Attainment/Maintenance Plan RevisionEmission Inventories This attainment/maintenance plan revision utilizes 2008 as an attainment year for emission inventories, which is the same year from whichthe 3.0 ppm design value was derived. Emission inventories for a typical winter day are presented in Table 2 for the 2008 attainmentyear. Each inventory accounts for the emission control programs effective during that period. The APCD developed the 2008 emission inventory in 2010 using U.S. Environmental Protection Agency (EPA) approved emissions modeling methods, including EPA'sMOVES2010 model and local VMT data for on-road mobile source emissions, EPA's non-road model, local demographic infonnation for area and off-road sources, and reported actual emissions for point sources. The inventory represents average daily winter emissions. The MOVES2010 and nonroad 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 WesternRegional Climate Center. Other source categories were apportioned from annual to daily by dividing by 365. For more detailed infonnation about inventory development, please see the Technical Support Document included as an appendix to this maintenance plan.


### Table 2. Fort Collins 2008 AttainmentlMaintenanceArea Emissions Inventory (Tons PerDay)

Emission Inventory Summary CO (tons/day) HELIPORT 0.009 Commercial Cooking 0.041 Fuel Combustion 0.428 Non-Road 14.161 Structure Fires 0.026 Woodburning 7.642 Highway Vehicles 64.624 Biogenic 0.275 Railroads 0.006 Point Sources 0.503 

### TOTAL 87.715

.. Note: Results are reported WIth three deCimal place preCISIOn to prOVIde representation ofsmaller source categories. This level ofprecision is not intended to suggest a level ofaccuracy.



### 5 December 16,2010

- Fort Collins AttainmentlMaintenance Plan RevisionEnforceable Control Measures for the Maintenance Period

• Federal Motor Vehicle Emissions Control tailpipe standards and regulations, including those for smallengines and non-road mobile sources. Credit is taken for these federal requirements, butthey are part ofa federally administered program and not a state commitmentofthe Colorado SIP.

• Air Quality Control Commission (AQCC) RegulationNo.3, Air Pollution EmissionNotices

- Permits

• AQCC RegulationNo.4, Wood Stove Standards

• AQCC RegulationNumber 6, New Source Performance Standards

• AQCC CommonProvisions Rule The Common Provisions and RegulationNo.6 delineate industrial source control programs. The Common Provisions, and Parts A and B ofRegulation No.3, are already included in the approved Colorado SIP. RegulationNo.6 and PartC ofRegulationNo.3 implementthe federal standards ofperformance for new stationary sources andthe federal operatingpermitprogram. The revised Fort Collins attainment/maintenance plan makes no changes to these regulations. Maintenance Demonstration This maintenance plan utilizes EPA'sLimited Maintenance Plan option, as explained above. The maintenance demonstration is considered to be satisfied ifthe monitoring data showthatthe area is meeting the air quality criteriafor limited maintenance areas (at orbelow7.65 ppm or 85 percent ofthe CONAAQS). Thedesign value for the Fort Collins COattainment/maintenance area is 3.0 ppm (33 percent ofCONAAQS), which is the highest second maximum concentration for the 2008-2009 monitoring period. Therefore, the maintenance demonstration is satisfied. Transportation Conformity Under the limited maintenance plan approach, transportation conformity is demonstrated by showing thattransportationplans are consistentwith any existing emissions budgets. When any existingbudgets expire, conformity is then presumed and regional analyses and emissionbudget tests for transportation conformity are no longer necessary. The guidance for limited maintenance plans states that emissions budgets may be treated as essentially non-constraining for transportation conformitybecause it is unreasonable to expect that such an area will experience so much growth during the maintenance period that a violation ofthe CO NAAQS would result. Therefore, the "budgettest" ofthe transportation conformity rule is met, according to the guidance.

6 December 16,2010

- FortCollins AttainmentlMaintenance Plan RevisionForthe Fort Collins attainment/maintenance area, the EPA-approved emission budgets are 99 tons ofCO per day (2005-2009),98 tons perday (2010-2014), and 94 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 must be demonstrated, through the year 2015. Beginning in 2016, the budgets expire. Under EPA's Limited Maintenance Plan (LMP)policy, once EPA approves the revised Fort Collins attainment/maintenance LMP the area is no longer subject to the motorvehicle emissions budget (MVEB) test after 2015. However, the area will remain subject to othertransportation conformity requirements found in 40 CFR 93. Monitoring Network/ Verification ofContinued Attainment The AirPollution ControlDivision (APCD) will continue to operate an appropriate airquality monitoring network in accordance with 40 CFRPart 58 to verifythe continued attainment ofthe CO NAAQS. Ifmeasured mobile source parameters (e.g., vehicle miles traveled, congestion, fleet mix, etc.) change significantly overtime, the APCD will perform the appropriate studies to determine whether additional and/or re-sited monitors are necessary. An annual review ofthe NAMS/SLAMS air quality surveillance system will be conducted in accordance with 40 CFR 58.10to determine whether additional and/or re-sited monitors are necessary and to determine whetherthe system continues to meetthe monitoring objectives presented in Appendix D of40 CFRPart 58. Contingency Plan Section 175A(d) ofthe CAArequires that the maintenanceplancontain contingencyprovisions to assure that the State will promptly correct any violation ofthe CONAAQS which occurs in the Fort Collins attainment/maintenance area. The contingency plan must ensure that the contingency measures are adopted expeditiously once the need is triggered. The primary elements ofthe contingencyplan involve the tracking and triggering mechanisms to determine when contingency measures are needed and a process for implementing appropriate control measures. Tracking The trackingplan for the Fort Collins areaconsists ofcontinuous carbon monoxide monitoring and analysis ofCO concentrations bythe APCD. The APCD will notify the EPA, the

### AQCC, the NFRMPO and local governments ofany exceedance ofthe CO standard within 30 days of occurrence. The ongoing regional transportation planningprocess carried outby the NFRMPO in coordination with the 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 improvementprograms are prepared every four years, which must go thiough a transportation conformity determination, aprocess is in place to periodically reviewthe vehicle miles traveled (VMT) and mobile source emissions ofCO presented in this maintenance plan.

7 December 16, 2010

- Fort Collins AttainmentlMaintenance PlanRevision

### Triggering and Response Triggering ofthe contingency plan does not automatically require a revision ofthe 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 eventthat violations continue to occur after contingency measures have been implemented, additional contingency measures will be implemented until the violations are corrected. Anexceedance ofthe CO NAAQS (any value over 9.5 ppm) maytrigger a voluntary, local process by the NFRMPO and APCD to identify and evaluate potential contingency measures. However, the only federally enforceable trigger for mandatory implementation ofcontingency measures shall be a violation ofthe CO NAAQS. Specifically, this would be a second value of 9.5 ppm or higher atthe same monitor during any calendar year. The State will move forward with mandatory implementation ofcontingency measures underthe SIP ifa violation ofthe CO NAAQS occurs. No more than 60 days after being notified bythe APCD that a violation occurred, the NFRMPO, in conjunction withthe APCD, the AQCC and local governments, will initiate a subcommittee process to begin evaluating potential contingency measures. The subcommittee will present recommendations within 120 days of notification, and the recommended contingency measures will be presented to the AQCC within 180 days ofnotification. The AQCC will then hold a public hearing to considerthe 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 ofPotential ContingencyMeasures TheNFRMPO 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 withthe CO NAAQS.

• Anenhanced vehicle inspection and maintenance (lIM) program as set forth in AQCC Regulation No. 11, withthe addition ofanyon-board diagnostics components required by federal law. While an enhanced inspection and maintenance program is already required in Fort Collins throughthe Ozone Action Plan, the program is "state-only" and as such is not federally enforceable and could be eliminated in the future without regard to the Fort Collins CO attainment/maintenanceplan. Byplacing an enhanced lIM program in the Fort Collins CO attainment/maintenanceplan, and making any adjustments to achieve maximum carbon monoxide benefits, the program would become a federally enforceable contingency measure.

8 December 16,2010

- Fort Collins AttainmentIMaintenance Plan Revision• A 2.7% oxygenated gasoline program as set forth in AQCC RegulationNo. 13 as of September 2009.

• Re-establishing nonattainmentnew source reviewpermitting requirements for stationary sources.
• In additionto these potential contingency measures, the State may evaluate other potential strategies, including but not limited to, transportation control measures and mandatory wood burning restrictions, in orderto address any future violations in the most appropriate and effective manner possible. SubsequentMaintenance Plan Revisions The Clean Air Act requires that a maintenance plan revision be submitted to EPA demonstrating that the CO standard will be maintained for a secondten-yearperiod. The initial maintenance plan was approved by EPA in 2003 and showed attainmentthrough 2015. The purpose ofthis final revision is to demonstrate maintenance for a second 10-yearperiod after the first 1O-yearperiod since redesignation, (through 2023). This plan utilizes the Limited Maintenance Plan option to demonstrate continued maintenance through a second ten-year period by showing that CO levels are below 85% ofthe CO NAAQS. No additional revisions ofthis maintenance plan are anticipated at this time. Iffuture changes in mobile source models or other unforeseen considerations raise potential issues withthe conformity process, the State will address the need to revise the maintenance plan atthattime.

9 December 16,2010

- Fort Collins AttainmentlMaintenance Plan Revision