## MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

MAY 2012

## MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

Prepared by:

May 2012

Technical Assistance Provided By: Arizona Department of Environmental Quality Arizona Department of Transportation Maricopa County Air Quality Department

U.S. Environmental Protection Agency

### MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

TABLE OF CONTENTS

CHAPTER PAGE

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-1

ONE INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
HISTORICAL BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-2

OUTLINE OF THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-4

TWO DESCRIPTION OF THE NONATTAINMENT AREA . . . . . . . . . . . . 2-1
NONATTAINMENT AREA BOUNDARIES . . . . . . . . . . . . . . . . . . . . 2-1
GEOGRAPHY AND CLIMATIC CONDITIONS . . . . . . . . . . . . . . . . . 2-3
THREE ASSESSMENT OF AIR QUALITY CONDITIONS . . . . . . . . . . . . . . 3-1
FORMATION OF PM-10 PARTICULATE POLLUTION . . . . . . . . . . 3-1

PM-10 EMISSIONS INVENTORY . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
AIR QUALITY MONITORING DATA AND TREND ANALYSIS . . . . . 3-4

FOUR THE ADOPTED PLAN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
MARICOPA COUNTY RESOLUTION TO EVALUATE MEASURES IN THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4
ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY DUST ACTION GENERAL PERMIT . . . . . . . . . . . . . . . . . . . . . . . . . 4-5

iTABLE OF CONTENTS (Continued)

CHAPTER PAGE
ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY COMMITMENT TO REVISE THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA IF NECESSARY FOR THE EMERGING AND VOLUNTARY MEASURE . . . . . . . . . . . . . . . . . . . 4-6
CONTINGENCY REQUIREMENT . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7

ASSURANCES THAT THE STATE HAS THE AUTHORITY TO IMPLEMENT THE MEASURES IN THE PLAN . . . . . . . . . . . . . . 4-7

TRACKING IMPLEMENTATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8

FIVE DEMONSTRATION OF ANNUAL FIVE PERCENT REDUCTIONS IN PM-10 EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . 5-1
MEASURES QUANTIFIED TO MEET THE FIVE PERCENT REDUCTION REQUIREMENT . . . . . . . . . . . . . . . . . . . . 5-1
DEMONSTRATION FOR THE FIVE PERCENT REDUCTION REQUIREMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-4
SIX ATTAINMENT DEMONSTRATION . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

SALT RIVER AREA MODELING . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-1

PM-10 NONATTAINMENT AREA MODELING . . . . . . . . . . . . . . . . 6-15

REASONABLE FURTHER PROGRESS . . . . . . . . . . . . . . . . . . . . . 6-34
CONTINGENCY REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . 6-35

ONROAD MOBILE SOURCE EMISSIONS BUDGET FOR CONFORMITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-42

EXPEDITIOUS ATTAINMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-43

ATTAINMENT DATE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-44
REQUEST FOR EXTENSION OF THE ATTAINMENT DATE FROM JUNE 6, 2012 TO DECEMBER 31, 2012 . . . . . . . . . 6-45

ii

### MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

LIST OF TABLES

TABLE PAGE

Table ES-1 2007-2012 Base Case PM-10 Emissions in the PM-10 Nonattainment Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-6 Table ES-2 Arizona Statutes, Maricopa County Rules, Maricopa County Ordinance, and Appendices to be Approved into the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area . . . . . . . . . . . . . . . . . . . . . ES-8

Table ES-3 2008-2012 PM-10 Emissions with Increased Rule Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-11

Table ES-4 PM-10 Emission Reductions and Five Percent Reduction Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-13 Table ES-5 Miles of Roads/Alleys/Shoulders in PM-10 Reduction Projects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-13 Table ES-6 2008-2012 PM-10 Reductions to Meet Contingency Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-14

Table ES-7 2008-2012 PM-10 Emissions with Five Percent Plan Measures and Contingency Projects . . . . . . . . . . . . . . . . . . . . . . ES-15

Table 3-1 Annual Emissions for the PM-10 Nonattainment Area from all Source Categories Included in the 2008 Periodic Emissions Inventory for PM-10 (English Tons/Year) . . . . . . . . . . . . . 3-3 Table 3-2 PM-10 Monitoring Stations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6

Table 3-3 Exceedances of t he 24-Hour PM-10 Standard, 2005 to 2007 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-10

Table 3-4 Exceedances of t he 24-Hour PM-10 Standard, 2008 to 2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-11

iiiLIST OF TABLES (Continued)

TABLE PAGE Table 4-1 Arizona Statutes, Maricopa County Rules, Maricopa County Ordinance, and Appendices to be Approved into the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area . . . . . . . . . . . . . . . . . . . . . . . 4-2 Table 5-1 Impact of Increased Rule Effectiveness on 2008-2012 PM-10 Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-3
Table 5-2 2007-2012 Base Case PM-10 Emissions in the PM-10 Nonattainment Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-5

Table 5-3 2008-2012 PM-10 Emissions with Increased Rule Effectiveness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-7

Table 5-4 PM-10 Emission Reductions and Five Percent Reduction Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-8 Table 6-1 Maricopa County and PM-10 Nonattainment Area 24-Hour Average PM-10 Standard Exceedance Dates, Measured Concentrations and Associated Meteorological Conditions in 2007 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-3 Table 6-2 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for May 4, 2007 Design Day at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-11
Table 6-3 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Salt River Area Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-13 Table 6-4 2012 Attainment Demonstration High Wind Design Day (May 4, 2007) at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . 6-14 Table 6-5 24-Hour Average PM-10 Concentrations on the High Wind Design Day (June 6, 2007) . . . . . . . . . . . . . . . . . . . . . . . . . . 6-16 Table 6-6 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Central Phoenix Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-19

ivLIST OF TABLES (Continued)

TABLE PAGE Table 6-7 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Durango Complex Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-20 Table 6-8 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Greenwood Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-21 Table 6-9 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Higley Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-22 Table 6-10 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West Phoenix Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-23 Table 6-11 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-24
Table 6-12 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Central City Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-25
Table 6-13 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Higley Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-26 Table 6-14 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Central Phoenix Monitor . . . . . . . . . . . . . . . . 6-27 Table 6-15 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Durango Complex Monitor . . . . . . . . . . . . . . 6-28 Table 6-16 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Greenwood Monitor . . . . . . . . . . . . . . . . . . . . 6-29 Table 6-17 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Higley Monitor . . . . . . . . . . . . . . . . . . . . . . . . 6-30 Table 6-18 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the State Super Site Monitor . . . . . . . . . . . . . . . . 6-31

vLIST OF TABLES (Continued)

TABLE PAGE Table 6-19 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West Phoenix Monitor . . . . . . . . . . . . . . . . . . 6-32 Table 6-20 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . 6-33 Table 6-21 Miles of Roads/Alleys/Shoulders in PM-10 Reduction Projects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-38 Table 6-22 2008-2012 PM-10 Reductions to Meet Contingency Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-39

Table 6-23 2008-2012 PM-10 Emissions with Five Percent Plan Measures and Contingency Projects . . . . . . . . . . . . . . . . . . . . . . . . 6-40

vi

### MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

LIST OF FIGURES

FIGURE PAGE Figure ES-1 Number of 24-H our PM-10 Exceedance Days . . . . . . . . . . . . . . . ES-3 Figure ES-2 Exceedances of the 24-H our PM-10 Standard at Monitors in Maricopa County . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ES-4 Figure ES-3 2008 PM-10 Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . ES-5 Figure ES-4 2012 PM-10 Emissions Inventory with Five Percent Plan Measures and Contingency Projects . . . . . . . . . . . . . . . . . . ES-16 Figure 2-1 PM-10 Nonattainment Area and Municipal Planning Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-2 Figure 3-1 2008 PM-10 Emissions Inventory . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5 Figure 3-2 PM-10 Nonattainment Area and PM-10 Monitoring Sites . . . . . . . . . 3-7 Figure 3-3 Number of 24-H our PM-10 Exceedance Days . . . . . . . . . . . . . . . . . 3-9 Figure 6-1 Summary of the Monitoring Conditions at West 43 rd Avenue on the High Wind Design Day (May 4, 2007) . . . . . . . . . . . . 6-5 Figure 6-2 Summary of the Monitoring Conditions at West 43 rd Avenue on the High Wind Design Day (June 6, 2007) . . . . . . . . . . . 6-6 Figure 6-3 Summary of the Monitoring Conditions at Higley on the High Wind Design Day (June 6, 2007) . . . . . . . . . . . . . . . . . . . . 6-7 Figure 6-4 Salt River Area Low Wind Domains and May 4, 2007 Hourly High Wind Back Trajectories and Associated Domains as Originating from West 43 rd Avenue Monitor . . . . . . . . . . 6-8 Figure 6-5 PM-10 Nonattainment Area Low Wind Domains and June 6, 2007 Hourly High Wind Back Trajectories and Associated Domains . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6-17

viiLIST OF FIGURES (Continued)

FIGURE PAGE Figure 6-6 Demonstration of Reasonable Further Progress . . . . . . . . . . . . . . . 6-36 Figure 6-7 2012 PM-10 Emissions Inventory with Five Percent Plan Measures and Contingency Projects . . . . . . . . . . . . . . . . . . . . 6-41

viii

### MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

APPENDICES

APPENDIX A

Exhibit 1: 2008 PM-10 Periodic Emissions Inventory for the Maricopa County, Arizona, Nonattainment Area. Ma ricopa County Air Quality Department. Revised June 2011.

APPENDIX B Exhibit 1: Technical Document in Support of the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. Maricopa Association of Governments.

Exhibit 2: Calculation of B enefits from PM-10 Certifie d Street Sweepers Purchased with CMAQ Funds in 2001-2009.

APPENDIX C

Exhibit 1: Arizona Revised Statutes Listed in Table 4-1. Exhibit 2: Maricopa County Resolution to Evaluate Measures in the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. Exhibit 3: Arizona Department of Environmental Quality Dust Action General Permit. Exhibit 4: Arizona Department of Environment al Quality Commitment to Revise the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area if Necessary for the Emerging and Voluntary Measure.

APPENDIX D Exhibit 1: Agricultural Best Management Practices Program.

APPENDIX E Exhibit 1: Public Hearing Process Documentation. Exhibit 2: Certification of Adoption.

ix

## MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

EXECUTIVE SUMMARYMAG 2012 FIVE PERCENT PLAN FOR PM-10 EXECUTIVE SUMMARY

Within the Maricopa County nonattainment area, the National Ambient Air Quality Standard has not yet been attained for PM-10 particulate pollution. The area is classified as a Serious Area under the Clean Air Act. The Ma ricopa Association of Governments (MAG) was designated by the Governor of Ariz ona in 1978 and recertified by the Arizona Legislature in 1992 to serve as the Regional Air Quality Planning Agency to develop plans to address air pollution problems. The plans are prepared through a coordinated effort with the Arizona Department of Environmental Quality (A DEQ), Arizona Department of Transportation, and Maricopa County Air Quality Department (MCAQD). To meet the requirements of Section 189(d) of the Clean Air Act, the MAG 2007 Five Percent Plan for PM-10 was submitted to t he Environmental Protection Agency (EPA) by the federal deadline of Decem ber 31, 2007. Collectively, the Five Percent Plan included fifty-three control measures from the State, Maricopa County, and local governments. The plan demonstrated that the measures would reduce PM-10 emissions by at least five percent per year and demonstrat ed attainment of the PM-10 standard in 2010. The region needed three years of clean data at the monitors in 2008, 2009 and 2010 in order for the region to be in attainment of the PM-10 st andard in 2010. There have been no violations of the standard during stagnant conditions since the plan was submitted in 2007. On September 9, 2010, EPA had published a not ice of proposed partial approval and disapproval of the plan in the Federal Regist er. There were two major reasons for the proposed disapproval: the EPA nonconcurrence with four high wind exceptional events at the West 43 rd Avenue monitor in 2008 resulted in a vi olation, which negated the attainment demonstration, and that the 2005 baseline emissions inventory was inaccurate since it overestimated construction and other emissions. On January 25, 2011, the Arizona Department of Environmental Quality voluntarily withdrew the MAG 2007 Five Percent Plan fo r PM-10 to address technical approvability issues and include new information, such as the new EPA equation for paved road dust emissions. While the plan was withdrawn, t he measures continue to be implemented to reduce PM-10. Consequently, the MAG 2012 Five Percent Plan for PM-10 has been prepared to meet the requirements in Section 189(d) of the Clean Air Act and improv e air quality in the Maricopa County nonattainment area. The plan is requir ed to reduce PM-10 emissions by at least five percent per year until t he standard is attained as meas ured by the monitors. The Clean Air Act specifies that the plan must be based upon the most recent emissions inventory for the area and also include a mode ling demonstration of attainment. The 2012 Five Percent Plan is designed to be a repl acement for the 2007 pl an that was withdrawn. The formation of PM-10 particulate polluti on is dependent upon several factors. Among
ES - 1these factors are stagnant air masses, severe temperature inversions in the winter, high winds from thunderstorms and front al systems, and fine, silty soils characteristic of desert locations. In the nonattainment area, hi gh PM-10 concentrations generally occur in September through March, on days with stagnant or near-stagnant conditions. High PM-10 concentrations can also occur during t hunderstorm outflows and frontal systems which create high winds that entrain soil particles from bare surfaces.

The trend in PM-10 levels for the Maric opa County nonattainment area is presented in Figure ES-1. The 24-hour PM- 10 standard is 150 micrograms per cubic meter. In 2008, there were 11 exceedance days of the 24-hour standard. Most of these exceedances were exceptional events. However, EPA did not concur with four high wind exceptional event days at the West 43 rd Avenue monitor in 2008, resulting in a violation of the PM-10 standard. All of the seven exceedance da ys in 2009 have been flagged as exceptional events and EPA concurrence is pending. In 2010, only one exceedance day of the PM-10 standard occurred, which did not constitute a violation of the standard. Figure ES-2 indicates the monitors where exceedances have occurred. It is important to note that beginning in 2004, the Arizona Department of Environmental Quality began flagging exceptional events. These are uncontro llable natural events (e.g., high winds, wildfires) or human-caused events t hat are not expected to recur at a given location (e.g., fireworks). The data and a dem onstration of the exceptional event are submitted to EPA for concurrence. Based upon the Maricopa County Air Qua lity Department 2008 Periodic Emissions Inventory (PEI) for PM-10 for the Maric opa County Nonattainment Area, the primary sources of PM-10 are: Unpaved Road Fugitive Dust - 24 percent; Construction Activities (residential, commercial, road, and other earthmoving) - 17 percent; Paved Road Fugitive Dust - 14 percent; Windblown Dust - 10 perc ent; and Onroad Mobile Vehicle Exhaust, Tire Wear and Brake Wear - 7 percent. The remain ing categories in the inventory individually contribute 6 percent or less to the total annual emissions. The sources are depicted in Figure ES-3.
The 2007 and 2009-2012 base case emissions were derived from the 2008 PEI emissions, using annual population and employment grow th factors published in August 2011 by Marshall Vest of the Economic and Business Research Center at the University of Arizona. These projections are based on the 2010 U.S. Census and the latest economic forecasts for the Phoenix-Mesa metropolitan area. Si nce the economic outlook for Arizona remains extremely unstable, the act ual population and employment levels in 2011 and 2012 may differ somewhat from the projections. Howeve r, the University of Arizona growth factors represent the most reliabl e data currently available. The annual five percent reduction target was calculated by mu ltiplying the total 2007 PM-10 emissions in Table ES-1 (59,218 tons) by five percent, which results in 2,961 tons. To meet the 189(d) requirement, the 2008 emissi ons must be at least 2,961 tons less than

ES - 2Figure ES-1Number of 24-Hour PM-10 Exceedance DaysNotes: -The Arizona Department of EnvironmentalQuality began flagging exceptional events in 2004.-The chart includes exceedance days at the Buckeye monitor,which is located outside the PM-10 nonattainment area.-On July 19, 2007, the exceedance at the Buckeye monitor was notassociated with the exceptional event that also occurred on that day.Sources: 1988 - 1997 - Revised MAG 1999 Serious Area Particulate Planfor PM-10 for the Maricopa County Nonattainment Area, February 2000.1998 - 2010 - EPA Air Quality System.1711112719342678413111810020030ES - 3Figure ES-2Exceedances of the 24-Hour PM-10 Standard at Monitors in Maricopa CountyNotes:1. Exceedances are based on data from the EPA Air Quality System (AQS).2. All exceedances in 2008 except for one at the Durango Complexmonitor have been flagged as exceptional events. EPA did not concur withfour exceptional events at the West 43rdAvenue monitor and has not taken action on the remaining events.3. All exceedances in 2009 have been flagged as exceptional events. EPA concurrence is pending.4. The one exceedance in 2010 was not flagged as an exceptional event.5. The chart includes exceedances from the Buckeye monitor, which is outside the PM-10 nonattainment area.012345678 W . 43r d Ave B uc keye Durang o S. Phoenix Coyote Lakes Higley

W. C hand l er Be t hun e W . Ph oeni x Glen d ale D ysar t G reenw oo d

Number of Exceedances200820092010ES - 4Figure ES-3ES - 5Table ES-1 2007-2012 Base Case PM-10 Emissions in the PM-10 Nonattainment Area

Source Category 2007 2008 2009 2010 2011 2012 (tons/year ) POINT 159 150 133 127 128 135 AREA Fuel combustion 1,276 1,301 1,307 1,311 1,316 1,328 Commercial cooking 974 993 998 1,001 1,005 1,014 Construction (includes windblown dust) 16,672 13,811 9,692 8,359 8,102 8,223 Tilling, harvesting and cotton ginning 936 893 893 893 893 893 Travel on unpaved farm roads 769 731 731 731 731 731 Livestock 261 261 261 261 261 261 Travel on unpaved parking lots 2,376 2,422 2,434 2,441 2,451 2,473 Offroad recreational vehicles 2,139 2,180 2,191 2,198 2,206 2,226 Leaf blowers 878 895 899 902 906 914 Windblown agriculture 448 448 448 448 448 448 Other windblown sources 5,430 5,430 5,430 5,430 5,430 5,430 Fires 497 497 497 497 497 497 Mining/quarrying (includes windblown dust) 752 721 661 641 643 667 Travel on industrial paved/unpaved roads 771 728 645 618 621 654 Other industrial sources 1,033 976 865 828 832 877 NONROAD Aircraft 194 184 152 142 143 146 Airport ground support equipment 29 27 23 21 20 20 Locomotives 34 34 34 34 34 34 Other nonroad equipment 1,710 1,683 1,661 1,641 1,595 1,513 ONROAD Exhaust 2,943 2,836 2,647 2,371 1,843 1,407 Tire wear 246 256 257 257 258 261 Brake wear 728 758 767 771 773 787 Paved roads 7,749 8,155 8,214 8,289 8,323 8,422 Unpaved roads and alleys 10,218 10,312 10,284 10,284 10,284 10,312 Totals 59,218 56,681 52,123 50,497 49,743 49,673

ES - 6the 2007 base case emissions. Each yearafter 2008 imposes yet another 2,961 ton reduction requirement. Thus, the cumulative reduction requirements (relative to 2007 base case emissions) are at least 5,922 tons in 2009, 8,883 tons in 2010, 11,844 tons in 2011, and 14,805 tons in 2012.
The new MAG 2012 Five Percent Pl an for PM-10 contains a wide variety of existing control measures and projects that have been impl emented to reduce PM- 10 and a new measure designed to reduce PM-10 during high risk c onditions, including high winds. While the 2007 Five Percent Plan was withdrawn, a wide range of control measures in that plan continue to be implemented to reduce PM- 10 and are being resubmitted. Table ES-2 includes the Arizona Statutes, Maricopa County Rules, a Maricopa County Ordinance, and Appendices for the resubmitted measures and a new high risk measure to be approved into the MAG 2012 Five Percent Plan for PM-10 fo r the Maricopa County Nonattainment Area. The 2012 Five Percent Plan also includes c ontingency measures t hat were implemented early such as PM-10 certified street sweepi ng on freeways and arterials, as well as the projects completed in 2008-2011 that paved and stabilized unpaved roads, alleys and shoulders; reduced speed limits; and over laid highways with rubberized asphalt. As described in Table ES-2, the Arizona Stat utes, Maricopa County Rules, and Maricopa County Ordinance include requirements to r educe PM-10 emissions from a broad range of sources. The requirements apply to unpaved roads and shoulders, leaf blowers, unpaved parking lots, vacant lots, sweeping street s with certified sweepers, off-road vehicle use, open and recreational burni ng, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. To meet the annual five percent reduction requirement in Se ction 189(d) of the Clean Air Act, the MAG 2012 Five Percent Plan takes cred it for increases in rule effectiveness for Maricopa County Rules 310 (Fugitive Dust from Dust-Generating Operations), 310.01 (Fugitive Dust from Non-Tradi tional Sources of Fugitive Dust) and 316 (Nonmetallic Mineral Processing). The increases in rule effectiveness are attributable to strengthened enforcement and increased compliance with these rules. EPA has approved Rules 310 and 310.01 in 2010 and Rule 316 in 2009, as par t of the State Implementation Plan. Compliance with these rules has increased every year since 2007. These Maricopa County rules also reduce emi ssions from a wide variety of sources and apply to the Maricopa County area. Maricopa County Rule 310 (Fugitive Dust from DustGenerating Operations) regulates fugitive dust emissions from sources and activities such as: land clearing, earthmoving, weed abatement, excavating, construction, demolition, bulk material handling, storage and transporting operations, outdoor equipment, motorized machinery, staging areas, parking areas, mate rial storage areas, haul roads, disturbed surface areas, initial landscapes and trackout onto paved surfaces from these sources. Maricopa County Rule 310.01 (Fugitive Dust from Non-Traditional Sources of Fugitive Dust) regulates fugitive dust em issions from sources and activities such as: vehicle use in

ES - 7Table ES-2 Arizona Statutes, Maricopa County Ru les, Maricopa County Ordinance, and Appendices to be Approved into the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area

Arizona Revised Statutes (A.R.S.) Description Effective Dates A.R.S. § 9-500.04. Only A.3., A.5., A.6., A.7., A.8., A.9. and H. Air quality control; definitions [city and town requirements in Area A regarding targeting unpaved roads and shoulders; leaf blower restrictions; restrictions related to parking, maneuvering, ingress and egress areas and vacant lots; requirement for certified street sweepers] 9/19/07

A.R.S. § 9-500.27. Off-r oad vehicle ordinance; app licability; violation; classification 9/19/07 A.R.S. § 11-871. Only A., B. and D.4. Emissions control; no burn; exemptions; penalty [no burn restriction for any HPA day, increased civil penalty] 9/19/07 A.R.S. § 11-877. Air quality control measures [county leaf blower restrictions] 9/19/07 A.R.S. § 28-1098. Only A. and C.1. Vehicle loads; restrictions; civil penalties [for safety or air pollution prevention purpose] 9/19/07 A.R.S. § 49-424. Only 11. Duties of department [develop and disseminate air quality dust forecasts for the Maricopa County PM-10 nonattainment area] 7/20/11

A.R.S. § 49-457.01. Leaf blower use restrictions and training; leaf blower equipment sellers; informational material; outreach; applicability 9/19/07

A.R.S. § 49-457.03. Off-road vehicles; pollution advisory days; applicability; penalties 9/19/07 A.R.S. § 49-457.04. Off-highway vehicle and all-terrain vehicle dealers; informational material; outreach; applicability 9/19/07 A.R.S. § 49-457.05. Only A., B., C., D. and I. Dust action general permit; best management practices; applicability; definitions 7/20/11

A.R.S. § 49-474.01. Only A.4., A.5., A.6., A.7., A.8., A.11., B. and H. Additional board duties in vehicle emissions control areas; definitions [county requirements for stabilization of targeted unpaved roads, alleys and shoulders; restrictions related to parking, maneuvering, ingress and egress areas and vacant lots; requirement for certified street sweepers] 9/19/07

A.R.S. § 49-474.05. Dust control; training; site coordinators 9/19/07 A.R.S. § 49-474.06. Dust control; subcontractor registration; fee 9/19/07 A.R.S. § 49-501. Only A.2., B.1., C., F. and G. Unlawful open burning; exceptions; civil penalty; definitions [ban on outdoor fires from May 1 to September 30; deletion of recreational purpose exemption; no burn day restrictions; penalty provision] 9/19/07

A.R.S. § 49-541. Only 1. Definitions [Area A] 8/9/01

ES - 8Table ES-2 Continued Maricopa County Air Quality Department Rules Description Effective Dates 310 Fugitive Dust from Dust-Generating Operations Adopted 1/27/10 and submitted to EPA 4/12/10 [Notice of Final Rulemaking 75 FR 78167; 12/15/10] EPA approved effective 1/14/11 310.01 Fugitive Dust From Non-Traditional Sources of Fugitive Dust Adopted 1/27/10 and submitted to EPA 4/12/10 [Notice of Final Rulemaking 75 FR 78167; 12/15/10] EPA approved effective 1/14/11 314 Open Outdoor Fires and Indoor Fireplaces at Commercial and Institutional Establishments Adopted 3/12/08 and submitted to EPA 7/10/08 [Notice of Final Rulemaking 74 FR 57612; 11/9/09] EPA approved effective 1/8/10 316 Nonmetallic Mineral Processing Adopted 3/12/08 and submitted to EPA 7/10/08 [Notice of Final Rulemaking 74 FR 58553; 11/13/09] EPA approved effective 1/8/10 Appendix C Fugitive Dust Test Methods Adopted 3/26/08 and submitted to EPA 7/10/08 [Notice of Final Rulemaking 75 FR 78167; 12/15/10] EPA approved effective 1/14/11 Maricopa County Ordinance Description Effective Dates P-26 Residential Woodburning Restriction Adopted 3/26/08 and submitted to EPA 7/10/08; [Notice of Final Rulemaking 74 FR 57612; 11/9/09] EPA approved effective 1/8/10 Appendices Description Effective Dates Appendix C, Exhibit 1 Arizona Revised Statutes Listed in Table 4-1 Appendix C, Exhibit 2 Maricopa County Resolution to Evaluate Measures in the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area 11/16/11

Appendix C, Exhibit 3 Arizona Department of Environmental Quality Dust Action General Permit 12/30/11 Appendix C, Exhibit 4 Arizona Department of Environmental Quality Commitment to Revise the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area if Necessary for the Emerging and Voluntary Measure

ES - 9open areas and vacant lots, open areas, vacant lots, unpaved parking lots, unpaved roadways (including alleyways), easements, ri ghts-of-way, access roads and trackout onto paved surfaces from these activities. Maricopa County Rule 316 (Nonmetallic Mineral Processing) regulates fugitive dust and process dust emissions from sources and ac tivities such as: mining, excavating, separating, combining, crushing and grindi ng any nonmetallic mineral, asphaltic concrete plants, raw material storage and distributi on, concrete plants, bagging operations, open storage piles, material handling, haul roads, and trackout onto paved surfaces from these sources. Emissions reduction credit is also taken fo r one new measure, the Dust Action General Permit, which was passed by the Arizona Legisl ature in April 2011. In accordance with A.R.S. § 49-457.05, this Du st Action General Permit i dentifies a series of Best Management Practices (BMPs) for specific dust generating operations. When ADEQ’s Maricopa County Dust Control Forecast predi cts that a day is at high risk for dust generation, those dust generating operations that are not alr eady required to control dust through a permit issued by the Arizona Departm ent of Environmental Quality or the Maricopa County Air Quality Department are expected to choose and implement at least one BMP to reduce or prevent PM-10 emissions . Implementation of a BMP is expected to occur as soon as practicable before and duri ng the high risk event. Although the BMPs in the Dust Action General Permit only apply to those sources that do not already have a permit, even dust generating operations with an air quality permit are also expected to implement the dust controls in their permit at the same time. According to state statute, BM Ps identified in the Dust Ac tion General Permit are expected to be employed absent the requirement to obtain an air quality pe rmit. If the owner or operator of a dust-generating operation is found by ADEQ’s Director to have failed to choose and implement an applicabl e BMP as soon as practic able before and during a day that is forecast to be at high risk of dus t generation, then the ow ner or operator can be required to obtain an Authorization to O perate under the Dust Action General Permit. This new measure is expected to raise rule effectiveness for Rule 310.01 by one percent during high wind hours and was fully implement ed by January 1, 2012. Credit for this measure is allowed under the EPA guidance, Incorporating Emerging and Voluntary Measures in a State Implementation Plan . The measures used to demonstrate the annual five percent reductions are also necessary to model attainment of the PM-10 standard under high wind conditions at all monitors as ex peditiously as practicable, which is 2012. Table ES-3 shows the impact of the increases in rule effectiveness on PM-10 emissions in 2008 through 2012. This table also quantifies the annual five percent reductions for 2008 through 2012. The total reduction in P M-10 emissions between 2007 and 2012 with the increases in rule effectiveness is 16,089 t ons, which represents a 27.2 percent reduction in total 2007 base case emissions.

ES - 10Table ES-3 2008-2012 PM-10 Emissions with Increased Rule Effectiveness

Source Category 2008 2009 2010 2011 2012 (tons/year) POINT 150 133 127 128 135 AREA Fuel combustion 1,301 1,307 1,311 1,316 1,328 Commercial cooking 993 998 1,001 1,005 1,014 Construction (includes windblown dust) 8,355 5,333 4,139 4,014 4,073 Tilling, harvesting and cotton ginning 893 893 893 893 893 Travel on unpaved farm roads 731 731 731 731 731 Livestock 261 261 261 261 261 Travel on unpaved parking lots 2,422 2,434 2,441 2,451 2,473 Offroad recreational vehicles 2,180 2,191 2,198 2,206 2,226 Leaf blowers 895 899 902 906 914 Windblown agriculture 448 448 448 448 448 Other windblown sources 3,938 3,788 3,788 3,788 3,639 Fires 497 497 497 497 497 Mining/quarrying (includes windblown dust) 476 401 355 356 369 Travel on industrial paved/unpaved roads 472 382 331 333 351 Other industrial sources 976 865 828 832 877 NONROAD Aircraft 184 152 142 143 146 Airport ground support equipment 27 23 21 20 20 Locomotives 34 34 34 34 34 Other nonroad equipment 1,683 1,661 1,641 1,595 1,513 ONROAD Exhaust 2,836 2,647 2,371 1,843 1,407 Tire wear 256 257 257 258 261 Brake wear 758 767 771 773 787 Paved roads 8,155 8,214 8,289 8,323 8,422 Unpaved roads and alleys 10,312 10,284 10,284 10,284 10,312 Totals 49,231 45,600 44,062 43,438 43,130 5% Reduction Targets (tons/year) 2,961 5,922 8,883 11,844 14,805 Actual Plan Reductions (tons/year) 9,987 13,618 15,157 15,781 16,089

ES - 11Table ES-4 confirms that t he annual five percent reduction requirements are met in 2008- 2012 and there is a surplus margin of benefit in each year. The total surplus in 2012 is 1,284 tons. This surplus is needed to model a ttainment at all monitors in the PM-10 nonattainment area by December 31, 2012. In accordance with the Clean Air Act, the MAG 2012 Five Percent Plan for PM-10 also includes contingency measures. The conti ngency measures are required to achieve emissions reductions beyond those measures relied upon to model attainment of the standard and demonstrate progress toward attain ment (five percent reductions, reasonable further progress, and milestones). They ar e required to be undertaken without further action by the State or the EPA Administrator if the area fails to make reasonable further progress or meet the st andard by the attainment date. EPA encourages early implementation of contingency measures to reduce emissions as expeditiously as practicable. EPA guidance indicates that contingency meas ures should provide emissions reductions equivalent to one year of reas onable further progress. For the Five Percent Plan, one year of reasonable further progress is equivalent to a reduction in PM-10 emissions of 3,218 tons. The contingency requirement is met in the MAG 2012 Five Percent Plan by quantifying projects that were completed in 2008-2011. A summary of the miles of roads, alleys and shoulders impacted by the pav ing and stabilization, speed lim it reduction, and rubberized asphalt overlay projects that were quantifi ed to meet the contingency requirement is presented in Table ES-5. Thes e PM-10 reduction projects were implemented in the PM-10 nonattainment area by twenty-one cities and towns, Maricopa County, Pinal County, Arizona Department of Transportation and the G ila River Indian Community. All of the projects for which credit was taken were open to traffic by September 2011.
The emissions reductions for all measures quantified to meet the contingency requirement are summarized in Table ES-6. Table ES-6 includes the benef its of the PM-10 certified street sweeping on freeways and arterials, as well as the projects completed in 2008-2011 that paved and stabilized unpaved roads, alleys and shoulders; reduced speed limits; and overlaid highways with rubberized asphalt. T he total PM-10 emissions reduction in 2012 is 3,439 tons, which exceeds the conti ngency target of 3,218 tons by 221 tons. The total 2012 PM-10 emissions, with the ai r quality benefits from the wide variety of control measures and contingen cy projects applied, are 39,691 tons per year (see Table ES-7), which represents a reduction, relati ve to 2007 base case PM-10 emissions, of 19,527 tons or 33 percent. A pie chart of the 2012 nonattainment area PM-10 emissions with the five percent measures and contingency projects appli ed is shown in Figure ES-4. For conformity analyses, the onroad mobile s ource emissions budget includes reentrained dust from travel on paved roads; vehicular exhaust, tire wear, and brake wear; travel on unpaved roads; and road construction. In 2012, the PM-10 emissions from these four source categories total 54.9 metric tons per day for the PM-10 nona ttainment area. This represents the onroad mobile source emissions budget for conformity.
ES - 12Table ES-4 PM-10 Emission Reductions and Fi ve Percent Reduction Requirements

Year 5% Reduction Requirement Total PM-10 Emission Reductions due to Increases in Rule Effectiveness Excess Benefit = Total PM-10 Emission Reductions minus 5% Reduction Requirement (tons/year) (tons/year) (tons/year) (%) 2008 2,961 9,987 7,026 237%
2009 5,922 13,618 7,696 130% 2010 8,883 15,157 6,274 71% 2011 11,844 15,781 3,937 33% 2012 14,805 16,089 1,284 9%

Table ES-5 Miles of Roads/Alleys/Shoulders in PM-10 Reduction Projects

Miles Impacted by Project Type 2008 2009 2010 2011 Total 2008-2011 Miles of dirt roads paved 41 18 8 16 83 Miles of dirt roads stabilized 39 39 36 31 145 Miles of dirt alleys paved 66 4 0 63 134 Miles of dirt alleys stabilized 164 106 124 106 501 Total miles of roads/alleys paved & stabilized 310 168 168 216 862 Miles of dirt shoulders paved 70 107 49 6 233 Miles of curb and gutter paved 19 0 0 0 19 Miles of dirt shoulders stabilized 235 236 236 200 906 Total miles of shoulders paved & stabilized 324 343 285 207 1,158 Miles of roads/alleys with lower speed limits 7 11 3 0 20 Miles of highway overlaid w/rubberized asphalt 13 0 0 0 13

ES - 13Table ES-62008-2012 PM-10 Reductions to MeetContingency RequirementsCompleted Projects Implementing Entities2008 2009 2010 2011 2012(tons/year)Sweep streets with PM-10 certified sweepersContracted sweeping of freeways, ramps andfrontage roads - 100% compliant, effective 2/20/1025 PM-10 certified sweepers purchased with CMAQfunds: 1/1/07-12/31/09ADOT 0 0 294 342 344Cities, towns 59 116 153 154 155Total for Street Sweeping 59 116 447 495 499Pave or stabilize existing public dirt roads andalleysPaving/stabilization projects completed in 2008-2011Cities, towns, Maricopa and Pinal County,and Gila River Indian Community 461 1,352 2,124 2,662 2,625Total for Road/Alley Paving/Stabilization 461 1,352 2,124 2,662 2,625Lower speed limits on dirt roads and alleysSpeed limits lowered in 2008-2011 Cities, towns, Maricopa County 4 78 161 161 161Total for Lower Speed Limits 4 78 161 161 161Pave or stabilize unpaved shouldersPaving/stabilization projects completed in 2008-2011 Cities, towns, Maricopa County 173 242 265 293 150Total for Shoulder Paving/Stabilizing 173 242 265 293 150Repave or overlay paved roads with rubberizedasphaltRubberized asphalt overlays completed in 2008-2011ADOT 0 3 3 3 3Total for Overlays 0 3 3 3 3Total for Completed Projects 697 1,790 2,999 3,614 3,439ES - 14Table ES-7 2008-2012 PM-10 Emissions with Five Percent Plan Measures and Contingency Projects Source Category 2008 2009 2010 2011 2012 POINT 150 133 127 128 135 AREA Fuel combustion 1,301 1,307 1,311 1,316 1,328 Commercial cooking 993 998 1,001 1,005 1,014 Construction (includes windblown dust) 8,355 5,333 4,139 4,014 4,073 Tilling, harvesting and cotton ginning 893 893 893 893 893 Travel on unpaved farm roads 731 731 731 731 731 Livestock 261 261 261 261 261 Travel on unpaved parking lots 2,422 2,434 2,441 2,451 2,473 Offroad recreational vehicles 2,180 2,191 2,198 2,206 2,226 Leaf blowers 895 899 902 906 914 Windblown agriculture 448 448 448 448 448 Other windblown sources 3,938 3,788 3,788 3,788 3,639 Fires 497 497 497 497 497 Mining/quarrying (includes windblown dust) 476 401 355 356 369 Travel on industrial paved/unpaved roads 472 382 331 333 351 Other industrial sources 976 865 828 832 877 NONROAD Aircraft 184 152 142 143 146 Airport ground support equipment 27 23 21 20 20 Locomotives 34 34 34 34 34 Other nonroad equipment 1,683 1,661 1,641 1,595 1,513 ONROAD Exhaust 2,836 2,647 2,371 1,843 1,407 Tire wear 256 254 255 255 259 Brake wear 758 767 771 773 787 Paved roads 7,922 7,857 7,578 7,534 7,772 Unpaved roads and alleys 9,847 8,854 7,999 7,461 7,525 Totals 48,534 43,810 41,062 39,823 39,691 Total PM-10 Emissions Reduction 2007-2012: 19,527 tons, 33.0%

ES - 15Figure ES-4ES - 16CHAPTER ONE

INTRODUCTION

Within the Maricopa County nonattainment area, the National Ambient Air Quality Standard has not yet been attained for PM-10 particulate pollution. The area is classified as a Serious Area under the Clean Air Act. On F ebruary 7, 1978, the Governor of Arizona designated the Maricopa Association of Go vernments (MAG) as the lead planning organization for Maricopa County that, toget her with the State is responsible for determining which elements of the State Implementation Plan revision will be planned, implemented, and enforced by St ate and local governments in Arizona. This designation was made in accordance with the Clean Air Ac t Section 174(a). In 1992, the Arizona Legislature recertified MAG as the regi onal planning agency in accordance with Section 174 of the 1990 Clean Air Act Amendments (A.R.S. Section 49-406 A.). To meet the requirements of Section 189(d) of the Clean Air Act, the MAG 2007 Five Percent Plan for PM-10 was submitted to t he Environmental Prot ection Agency (EPA) by the federal deadline of December31, 2007. Collectively, t he Five Percent Plan included fifty-three control measures fr om the State, Maricopa County , and local governments. The plan demonstrated that the meas ures would reduce PM-10 emissions by at least five percent per year and demonstrat ed attainment of the PM-10 standard in 2010. The region needed three years of clean data at the moni tors in 2008, 2009 and 2010 in order for the region to be in attainment of the PM-10 st andard in 2010. There have been no violations of the standard during stagnant conditions since the plan was submitted in 2007. On September 9, 2010, EPA had published a not ice of proposed partial approval and disapproval of the plan in the Federal Regist er. There were two major reasons for the proposed disapproval: the EPA nonconcurrence with four high wind exceptional events at the West 43 rd Avenue monitor in 2008 resulted in a vi olation, which negated the attainment demonstration, and that the 2005 baseline emissions inventory was inaccurate since it overestimated construction and other emissions. On January 25, 2011, the Arizona Department of Environmental Quality (ADEQ) voluntarily withdrew the MAG 2007 Five Percent Plan for PM-10 to address technical approvability issues and include new information, such as the new EPA equation for paved road dust emissions. While the plan was withdrawn, t he measures continued to be implemented to reduce PM-10. Consequently, the MAG 2012 Five Percent Plan for PM-10 has been prepared to meet the requirements in Section 189(d) of the Clean Air Act and improv e air quality in the Maricopa County nonattainment area. The plan is required to reduce P M-10 emissions by at least five percent per year until t he standard is attained as measured by the monitors. The Clean Air Act specifies that the plan must be based upon the most recent emissions inventory for the area and also include a mode ling demonstration of attainment. The 2012

1 - 1Five Percent Plan is designed to be a replac ement for the 2007 plan that was withdrawn. The following narrative describes the histor ical background preceding the preparation of the MAG 2012 Five Percent Plan for PM-10.

HISTORICAL BACKGROUND Based upon the 1990 Clean Air Act Amendments, the Maricopa County nonattainment area was initially classified as Moderate for PM-10 particulate pollution. However, on May 10, 1996, the nonattainment area was reclassified to Serious due to failure to attain the particulate standard by December 31, 1994. The Serious Area reclassification was effective on June 10, 1996.
The Revised MAG 1999 Serious Area Particulat e Plan for PM-10 for the Maricopa County Nonattainment Area was submitted to the En vironmental Protection Agency in February 2000. On July 25, 2002, EPA publis hed a notice of final approval for the plan. Collectively, the plan contained approximately seventy-seven control measur es from the State and local governments. The plan demonstr ated attainment of the P M-10 standard by December 31, 2006.

In order to be in attainm ent, the region needed three years of clean data at the monitors for 2004, 2005, and 2006. However, there we re numerous exceedances of the standard in 2005 and 2006. On June 6, 2007, EPA published a final notice with its findings that the Maricopa County nonattainment area had failed to attain the PM-10 standard by the federal deadline of December 31, 2006. It then bec ame necessary for MAG to prepare a Five Percent Plan for PM-10. In accordance with Section 189(d) of the Clean Air Act, a Five Percent Plan for PM-10 was due to the Environmental Protection Agency by December 31, 2 007. The plan was required to reduce PM-10 emissions by at least five percent per year until the standard was attained as measured by the monitors. The Cl ean Air Act specified t hat the plan must be based upon the most recent emissions invent ory for the area and also include a modeling demonstration of attainment.
The MAG 2007 Five Percent Plan for PM-10 wa s submitted to EPA by the federal deadline of December 31, 2007. Collect ively, the Five Percent Plan for PM-10 included fifty-three control measures from the State, Maric opa County, and local governments. The plan demonstrated that the measures would reduce PM-10 emissions by at least five percent per year and demonstrated attainment of the PM-10 standard in 2010. The region needed three years of clean data at the monitors in 2008, 2009 and 2010 in order for the region to be in attainment of the PM-10 standard in 2010. There have been no violations of the standard during stagnant conditions since the plan was submitted in 2007. In 2008, there were a number of exceedances of the twenty-four hourPM-10 standard due to high winds in the Maricopa County nonatta inment area. In June 2009, the Arizona Department of Environmental Quality had submitted a pre liminary demonstration to EPA

1 - 2on the 2008 high wind events, since high wind ex ceptional events should not count against the region. In November 2009, the ADEQ submitted final demonstrations for the exceedances, including five at the West 43 rd Avenue monitor. On December 2, 2009, the Arizona Center for Law in the Public Interest filed a lawsuit against EPA for failure to take action on the plan by June 30, 2009 in accordance with the Clean Air Act. The Environmental Protec tion Agency reviewed the plan that had been submitted two years ago and issues began to emerge. The plan was based upon a 2005 emissions inventory that wa s outdated with the downt urn in the economy; the contribution of emissions from the sources had ch anged. EPA had c oncerns with the Arizona Department of Environmental Quality exceptional events doc umentation of four high wind exceedances in 2008 at the West 43 rd Avenue monitor. On May 21, 2010, the Environmental Prot ection Agency sent a letter to the ADEQ indicating that EPA did not c oncur with the ADEQ documentat ion for the four high wind exceptional events at the West 43 rd Avenue monitor. As a result, the four exceedances would constitute a violation at the monitor and the region would not have its first of three years of clean data needed to attain the standard by 2010. On September 3, 2010, the Environmental Protection A gency signed a notice to propose partial approval and disapprov al of the MAG 2007 Five Pe rcent Plan for PM-10 based on the timetable in the consent dec ree with the Arizona C enter for Law in the Public Interest. On September 9, 2010, the notice was published in the Federal Register. EPA proposed disapproval of the emissions inventories, attainment demons tration, five percent annual reductions in emissions, reasonable furt her progress and milestones, contingency measures, and the 2010 motor vehicle em issions budget. EPA proposed limited approval and disapproval for agricultural regulati ons. EPA proposed approval of the Arizona Revised Statutes that mandated twenty measures in the plan and the Agricultural Best Management Practices Guidance Booklet and Pocket Guide. Based upon the consent decree, EPA indicated that a notice of fi nal action would be signed by January 28, 2011. According to EPA, there were two major reasons for the proposed partial disapproval of the plan:

1. EPA contended that the mode ling attainment demonstration in the plan cannot be approved if actual monitor dat a show that the area cannot attain the standard by the attainment date of December 31, 2010. Th is was directly resultant from the EPA nonconcurrence with the four high wind exceptional events at the West 43 rd Avenue monitor in 2008. The four exceedances constituted a viol ation of the standard. EPA further indicated that it was not necessary to review the exceptional event claims for 2009 since the region did not have its firs t year of clean data in 2008 needed to attain the standard by 2010.

2. EPA contended that the 2005 base line emissions inventory was inaccurate since it overestimated construction emissions and other emissions. The 2005 emissions

1 - 3inventory prepared by the Maricopa Count y Air Quality Department was the foundation upon which the plan was developed. The emissions inventory was the basis for the air quality modeling prepared by MAG for the five percent reductions in emissions; impact of the plan measur es and contingency measures; reasonable further progress (annual incr emental emissions reductions to ensure attainment); milestone demonstrations every three y ears; and the attainment demonstration. On January 25, 2011, the Arizona Department of Environmental Quality withdrew the MAG 2007 Five Percent Plan for PM-10 to address t he technical approvability issues identified by EPA and include new information, such as the new EPA equation for paved road dust emissions. The new EPA equation was more a ccurate and would improve the emissions inventory. Although the plan was withdrawn, the measures continued to be implemented to reduce PM-10. On February 14, 2011, the Envi ronmental Protection Agency pub lished a final notice in the Federal Register to make a Finding of Failure to Submit as a result of the withdrawal of the 2007 Five Percent Plan for PM-10. The Finding of Failure to Submit was effective on February 14, 2011. If a new comp lete plan is not submitted within eighteen months of the finding, the Clean Air Act sanction of tighter controls on major industries (two to one offsets) would be imposed by August 14, 2012. If a comp lete plan is not submitted within twentyfour months of the finding, the federal highway sanction and a federal implementation plan would be imposed by February 14, 2013. The submittal of a new plan and a completeness determination by EPA will stop the sanctions cl ocks. A plan approval action by EPA will stop the imposition of a federal plan.
OUTLINE OF THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 The purpose of this document is to present the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. The plan contains a variety of existing control measures and projects that have been impl emented to reduce PM- 10 and a new measure designed to reduce PM-10 during high winds.
The MAG 2012 Five Percent Plan for PM-10 is composed of the following major sections: 1. Introduction (This Chapter) - Includes a general discussion of historical background and the outline of the MAG 2012 Five Pe rcent Plan for PM-10. 2. Description of the Nonattainment Area - Includes a description of the nonattainment area; geography and climatic conditions. 3. Assessment of Air Quality Conditions - Includes a discussion of the formation of particulate pollution; PM-10 emissi ons inventory; and air quality monitoring data and trend analysis. 4. The Adopted Plan - Includes a table of statutes, rules, ordinance, and

1 - 4appendices for the plan; Maricopa County Resolution to Evaluate Measures in the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area; Arizona Department of Environmental Quality Dust Action General Permit; Arizona Departm ent of Environmental Quality Commitment to Revise the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area if Necessary for the Emerging and Voluntary Measure; tracking plan impl ementation; and assurances that the State has the authority to implem ent the measures in the plan.

5. Demonstration of Annual Five Perc ent Reductions in PM-10 Emissions - Includes a discussion of the measures quantified to meet the annual five percent requirement and demonstration for the five percent reduction requirement.

6. Attainment Demonstration - Includes a discussion of the Salt River area modeling; PM-10 nonattainment area modeling; reasonable further progress, contingency requirements; onroad mob ile source emissions budget for conformity; expeditious attainment; and attainment date.

1 - 5CHAPTER TWO

DESCRIPTION OF THE NONATTAINMENT AREA

The Maricopa County nonattainment area for par ticulates was formally designated in April 1974. As defined in the 1977 Clean Air Act, the term nonattainment area re fers to locations which exceed any national ambient air qualit y standard for any pollutant based upon the data collected through air quality monitoring. A general description of the Maricopa County nonattainment area, including a discussion of the boundaries of the area and the geography and climatic conditions is provided below.
NONATTAINMENT AREA BOUNDARIES When the Environmental Protection Agency pr omulgated the PM-10 National Ambient Air Quality Standard on July 1, 1987, there was little PM-10 monitoring data available for EPA to use in determining the nonattainment ar ea boundaries. In the August 7, 1987 Federal Register, EPA promulgated its poli cy of categorizing areas of t he country into three groups based on the probability that an area’s existing State Implementation Plan (SIP) would need to be revised to protect or attain the new PM-10 standard. Group I areas were those areas which EPA identified as having a strong likelihood of violati ng the PM-10 standard and requiring substantial SIP revisions. In the August 7, 1987 Feder al Register, EPA identified the Group I area in Maricopa County, Arizona as the Phoenix Planning Area. In the October31, 1990 Federal Register, EPA published technical corrections modifying t he boundaries of certain areas of concern. The designation of the nonatta inment area boundary is documented in the EPA letter dated September 11, 1991.

In the October 1990 Federal Register the area was defi ned as “The rectangle determined by, and including, T6N, R3W; T6N, R7E; T2 S, R3W; T2S, R7E; T1N, R8E.” The nonattainment area is generally encompassed by 259 th Avenue on the west, Hunt Highway on the south, Meridian Road on the east and a boundary approximately six miles north of Carefree Highway on the north (see Figure 2-1) . This area contains portions of the municipal planning areas for twenty-two cities and towns in Maricopa County, the Fort McDowell, Gila River, and Salt River Pi ma-Maricopa Indian Communities, as well as unincorporated areas under the jurisdiction of Maricopa County. The PM-10 nonattainment area also contains a six by si x mile section in Pinal Count y that encompasses a portion of the Apache Junction Municipal Planning Area which includes unincorporated areas under the jurisdiction of Pinal County. When determining the new PM-10 nonattainm ent area in 1987, the Environmental Protection Agency included the Cit y of Apache Junction, a sma ll eastern portion of Apache Junction lies in Maricopa County and the western portion lies in Pinal County. Pinal County

2 - 12 - 2worked with the Arizona Department of Environmental Qualit y on a separate PM-10 plan for that portion of the nonattainment area.
GEOGRAPHY AND CLIMATIC CONDITIONS Due to its valley location, the nonattainment area has an elevation of 1,105 feet above mean sea level (MSL) and is almost complete ly surrounded by mountains. The Salt River Mountains are located on the southern borderof the nonattainment area and rise to an elevation of 2,507 feet above MSL. To the northwest, the Phoenix Mountains have an elevation of 2,310 feet above MSL. The Estre lla Mountains are loca ted to the southwest and have an elevation of 3,320 f eet above MSL. On the we stern boundary, the White Tank Mountains rise to an elevat ion of 4,026 feet above MSL and on the eastern boundary, the Superstition Mountains rise to an el evation of 4,620 feet above MSL.

There are five main rivers that run thr ough the nonattainment area: the Salt River, Agua Fria River, Gila River, New River, and Verde River. These river beds are generally dry, except during torrential rain fall, which happens infrequently.

The climate in the nonattainment area is arid continental, experiencing extreme ranges in daily temperatures. Temperatures range from a mean of 55.5 degrees Fahrenheit in December to a mean of 94.8 degrees Fahrenheit in July; the annual mean temperature is 74.2 degrees Fahrenheit. The sun shines approx imately 85 percent of the time and the annual average rainfall is 8.29 inc hes. Most of the rainfall o ccurs from December through March and during the months of July and August. (Source: National Oceanic & Atmospheric Administration National Data Centers.) In general, the morning direction for the preva iling winds in the nonattainment area is from east (southeast) to west (southwest). Howeve r, wind direction can change in the afternoon to a more westerly direction. The average annual wind speed is 6.2 miles per hour.

2 - 3CHAPTER THREE
ASSESSMENT OF AIR QUALITY CONDITIONS

Within the Maricopa County nonattainment area, PM-10 is a problem throughout the year. Particulate air pollution is composed of solid particles or liquid droplets which are small enough to remain suspended in the air. The sma ller the size, the more likely the particles are to reach the innermost portions of the lungs and cause damage. Major concerns for human health from exposure to particle pollu tion include: increased respiratory symptoms, such as irritation of the airways, coughing, or difficulty breathing; decreased lung function; aggravated asthma; development of chronic bronchitis; irregul ar heartbeat; nonfatal heart attacks; and premature death in people with heart or lung disease. The elderly, children, and people with heart and lung disease are especially sensitive to the effects of particulate matter. Particles that are 2.5 micrometers in diameter and smalle r (PM-2.5) can lodge deep in the lungs and are belie ved to be the largest health risk. The EPA designated Maricopa County as an attainment area for PM-2.5 in September 2005. In order to effectively reduce PM-10, it is im portant to assess air quality conditions in the PM-10 nonattainment area. This chapter pr esents a discussion of PM-10 formation, the Maricopa County Air Quality Department 2005 Pe riodic Emissions Inventory for PM-10 for the Maricopa County, Arizona, Nonattainm ent Area, and air quality monitoring data.
FORMATION OF PM-10 PARTICULATE POLLUTION The formation of PM-10 particulate pollu tion is dependent upon several factors. Among these factors are stagnant air masses, severe temperature inversions in the winter, high winds from thunderstorms and front al systems, and fine, silty soils characteristic of desert locations. In the nonattainment area, hi gh PM-10 concentrations generally occur in September through March, on days with stagnant or near-stagnant conditions. High PM-10 concentrations can also occur during thunderstorm outflows and frontal systems which create high winds that entrain soil particles from bare surfaces. The PM-10 in the arid Southwest largely cons ists of coarse particles (i.e., aerodynamic diameter greater than 2.5 microns but less than or equal to 10 microns) which are typically crustal in nature and derive mainly from windblown dust, resuspended road dust (from paved and unpaved roads), unpaved parking lots, dist urbed vacant land, mining operations, construction, and agricultural activities (e .g., tilling and harvesting, travel on unpaved farm roads). Other components of parti culate matter, such as sulfat es, nitrates, and organic and elemental carbons, are typically found in t he fine fraction of parti culate matter (i.e., aerodynamic diameter less than or equal to 2.5 microns), but c an also contribute to coarse particulate matter. Previous analyses of P M-2.5 data in the Phoenix area have shown that mobile source exhaust, burning, and industrial sources are important constituents of PM2.5. The co-located PM-10 and P M-2.5 monitors at the Durango Complex site indicate that PM-2.5 readings on days with high PM-10 concent rations range from 6 to 15 percent of the

3 - 1PM-10 on high wind days and 14 to 22 percent on low wind days. Therefore, the PM-10 problem in the nonattainment area is largely attributable to coarse particles, comprised primarily of geologic material (MAG, 2008).

PM-10 EMISSIONS INVENTORY The Clean Air Act requires a comprehensive, a ccurate, and current inventory of actual emissions from all sources. In June 2011, the Maricopa County Air Quality Department compiled a revised 2008 periodic emissions in ventory which includes primary emissions of PM-10 and PM-2.5 as well as three particula te matter precursors: ni trogen oxides (NOx), sulfur dioxides (SOx) and amm onia (NH3). The inventory provides emission estimates for Maricopa County and the PM-10 nonattainment area. Maricopa County encompasses approximately 9,223 square miles and the PM-10 nonattainment area is about 2,888 square miles.

Emission sources included in the 2008 Periodic Emissions Inventory for PM-10 are Point Sources, Area Sources, Nonr oad Mobile Sources, Onroad M obile Sources, and Biogenic Sources. The inventory provides the typi cal daily emissions and annual emissions for these categories. Table 3-1 includes a breakdown of annual emissions for the PM-10 nonattainment area. The point source category includes stationary sources which emit a significant amount of pollution into the air. Exampl es of point sources include powerplants, industrial processes, and large manufacturing facilities. Area source s are stationary source s which are too small or too numerous to be treated as point sour ces. Examples include residential wood burning, commercial cooking, waste incinerati on, and wildfires. Nonroad mobile sources include off-highway vehicles and engines that move or are moved in a 12-month period such as construction and mining equipment, la wn and garden equipment, and aircraft. The onroad mobile sources category includes ex haust, paved road fugitive dust, unpaved road fugitive dust, tire wear, and break wear. Biogenic sources (plant life) were estimated using the Model of Emissions of Gases and Aeroso ls from Nature (MEGAN) Biogenic Emissions Inventory System. Among the chemical species included in the MEGAN Model, only NOx is attributable to particulate matter fo rmation and therefore only NOx emissions are included in the 2008 inventory. Collectively, the source ca tegories are estimated to hav e contributed 48,148.00 (English) tons of PM-10; 13,512. 16 tons of PM-2.5; 109,662.87 tons of NOx; 1,808. 84 tons of SOx; and 12,458.87 tons of NH3 in calendar year 2008 within the PM-10 nonattainment area. A complete description of these sources and the corresponding methodology used to calculate the emissions for 2008 are included in the 2008 Periodic Emissions Inventory for PM-10 for the Maricopa County, Arizona, Nonattainment Area, Revised June 2011. This inventory is provided in Appendix A, Exhibit 1. Projected emission inventories for years 2007 through 2012 are based upon the 2008 periodic in ventory for PM-10 and are provided in Chapter Five.

3 - 2Table 3-1 Annual Emissions for the PM-10 Nonattain ment Area from All Source Categories Included in the 2008 Periodic Emissions Inventory for PM-10 (English Tons/Year) Source Category PM-10 PM-2.5 NOx SOx NH3 POINT TOTAL 149.84 132.94 1,317.85 28.76 132.18 AREA Fuel Combustion 1,300.65 1,268.35 12,248.07 895.83 51.11 Industrial Processes 10,655.39 2,771.19 360.48 129.58 1,724.27 Waste Treatment/Disposal 120.77 95.42 50.30 56.85 1,494.12 Miscellaneous Area Sources 12,444.36 2,143.52 115.94 29.74 7,693.04 AREA TOTAL 24,521.17 6,278.48 12,774.79 1,112.00 10,962.54 NONROAD MOBILE Agricultural 15.13 14.67 161.35 0.06 0.30 Airport Ground Support 26.99 26.48 578.95 26.22 --- Commercial 117.66 112.69 1,391.61 2.39 21.06 Construction and Mining 1,249.88 1,210.00 14,666.42 6.55 27.85 Industrial 101.42 98.71 2,586.39 3.21 56.09 Lawn and Garden 183.02 169.48 801.41 3.17 19.71 Pleasure Craft 7.02 6.48 59.03 0.64 1.32 Railway Maintenance 1.13 1.10 9.26 0.00 0.02 Recreational 7.68 7.08 10.76 0.07 0.35 Aircraft 183.80 177.61 2,620.31 316.00 --- Locomotives 34.16 31.88 907.76 9.11 2.16 NONROAD MOBILE TOTAL 1,927.89 1,856.18 23,793.26 367.42 128.87 ONROAD MOBILE Exhaust, Tire Wear and Brake Wear 3,144.17 2,300.80 71,444.20 300.66 1,235.28 Paved Road Fugitive Dust 6,694.22 1,774.76 --- --- --- Unpaved Road Fugitive Dust 11,710.70 1,169.00 --- --- --- ONROAD MOBILE TOTAL 21,549.09 5,244.56 71,444.20 300.66 1,235.28 BIOGENIC TOTAL

--- --- 332.77

--- --- TOTAL ALL SOURCES 48,148.00 13,512.16 109,662.87 1,808.84 12,458.87 Notes: Totals shown may not equal the sum of individual values due to independent rounding.

3 - 3A pie chart of the 2008 PM-10 annual emissions in the PM-10 nonattainment area is shown in Figure 3-1. The largest single source category is unpaved road fugitive dust at 24 percent. Construction activities contribute a combined 17 percent (residential, commercial, road, and other earthmoving), while paved r oad fugitive dust contributes 14 percent. Windblown dust accounts for 10 per cent of the annual inventory. Onroad mobile vehicle exhaust, tire wear and brake wear contribute seven percent. The remaining categories in the figure individually contribute six perc ent or less to the total annual emissions.
AIR QUALITY MONITORING DATA AND TREND ANALYSIS In addition to identifying sources of PM-10 emi ssions, it is important to examine the impact of these emissions on the ambi ent concentrations. This sect ion includes discussions of the National Ambient Air Quality Standards (N AAQS) for PM-10 and the air quality data recorded by the areawide monitoring network.

The 24-hour PM-10 standard is 150 mi crograms per cubic meter (ug/m 3 ). The standard is attained when the expected number of exceedances per year at eac h monitoring site is less than or equal to one. The number of expec ted exceedances at a site is determined by recording the number of exceedances in each calendar year and then averaging them over the past three years. At some sites, P M-10 sampling is scheduled less frequently than every day. To account for this, an adjustment must be made to the data collected at each site to estimate the number of exceedances in a calendar year. Due to possible seasonal imbalance, the adjustment is made quarterly. The estimate of the expected number of exceedances for the quarter is equal to the observed number of exceedances plus an increment associated with the missing data. The expected num ber of exceedances is then estimated by averaging the annual estimates ov er the three-year period. Due to the rounding criteria used by EPA, a recorded average PM-10 concentration must be under 155 ug/m 3 to not be considered an exceedance and the three-year expected exceedance rate for any site must be less than 1.05 for t he region to be in attainment of the 24-hour standard. The annual PM -10 standard of 50 ug/m 3 was revoked by EPA effective December 18, 2006.

In order to determine the extent of the regional PM-10 pollution problem, it is necessary to examine the air quality data colle cted by the areawide monitoring network. A total of 27 criteria pollutant monitoring stations are currently operat ed by the Maricopa County Air Quality Department (MCAQD), Pinal County Ai r Quality Control District (PCAQCD), and Arizona Department of Environm ental Quality (ADEQ) in t he PM-10 nonattainment area. Sixteen of these sites monitor PM-10. The Bu ckeye monitoring site is located just outside the western boundary of the nonatta inment area and also monito rs PM-10. Site-specific information regarding the PM-10 m onitoring stations is provi ded in Table 3-2, and the geographic location of each site is indicated in Figure 3-2. As mentioned previously, not all PM-10 samp les are collected every day. Most of the exceedances prior to 2004 were recorded by f ilter-based monitors that measured PM-10

3 - 4Figure 3-13 - 5Table 3-2 PM-10 Monitoring Stations

FIGURE 3-2 MAP INDEX SITE ADDRESS OPERATING AGENCY SAMPLING SCHEDULE

AJ Apache Junction Fire Station 3955 E. Superstition Blvd. PCAQCD Continuous BE* Buckeye 26449 W. 100 th Dr. MCAQD Continuous CP Central Phoenix 1645 E. Roosevelt MCAQD Continuous

DC Durango Complex 2702 RC Esterbrooks Blvd. MCAQD Continuous DY Dysart 16825 N. Dysart Rd. MCAQD/ADEQ Continuous GL Glendale 6001 W. Olive MCAQD Continuous GR Greenwood 1128 N. 27 th Ave. MCAQD Continuous HI Higley 15400 S. Higley Rd. MCAQD Continuous JLG JLG Supersite 4530 N. 17 th Ave. ADEQ Continuous ME Mesa 310 S. Brooks MCAQD 1 in 6 day NP North Phoenix 601 E. Butler Dr. MCAQD Continuous SP South Phoenix 33 W. Tamarisk MCAQD Continuous SS South Scottsdale 2857 N. Miller Rd. MCAQD 1 in 6 day WC West Chandler 275 S. Ellis MCAQD Continuous WF West 43 rd Avenue 3940 W. Broadway MCAQD Continuous WP West Phoenix 3847 W. Earll MCAQD Continuous ZH Zuni Hills 10851 W. Williams Rd. MCAQD Continuous

* The Buckeye monitor is located outside the western boundary of the PM-10 nonattainment area. Sources: Pinal County Air Quality Website; Arizona D epartment of Environmental Quality State of Arizona Air Monitoring Network Plan for the Year 2011; Maricopa County Air Quality Department 2010 Air Monitoring Network Review.

3 - 63 - 7concentrations every sixth day. Since 2004, t he filter-based monitors that have exceeded the PM-10 standard have been replaced with moni tors that measure PM-10 concentrations continuously. Currently, within the nonattainm ent area samples are collected every sixth day at two of the PM-10 moni toring stations while 14 sites now sample continuously. The sampling schedule for each site is provided in Table 3-2. One method of assessing the over all air quality of a region is to examine the concentrations measured at the monitoring stations. The trend in the number of 24-hour PM-10 exceedance days is presented in Figure 3-3. Tables 3-3 and 3-4 provide detailed information on exceedances of the 24-hour P M-10 standard for the past six years. It is important to note that beginning in 2004, the Arizona Departm ent of Environmental Quality (ADEQ) began flagging exc eptional events. This is an uncontrollable natural event (e.g., high winds, wildfires) or a human-caused ev ent that is not expected to recur at a given location (e.g., fireworks) . The data and a demonstration of the event are submitted to EPA for concurrence. Once approved, t he data is not used in determining compliance with the PM-10 standard. Tables 3-3 and 3- 4 note the exceptional events that have occurred since 2005. Figure 3-3, which presents the trend in number of exceedance days of the 24-hour standard from 1988 to 2010, shows a noticeabl e increase in the number of exceedance days since 1994. Between 1988 and 1993, there were zero to three exceedance days per year. The number of exceedance days increased from zero in 1993 to 10 in 1994. This increase in 1994 is attributable to the installati on of a new site (Salt River monitor). This site was located in the Salt River Area and sources nearby included sand and gravel, metal recycling, precast manufacturing, and paved and unpaved haul road. The Salt River site was shut down as of December31, 2002. Efforts were made to find a suitable replacement site with comparable PM-10 concentrations and industrial emissions. The West 43 rd Avenue site was identified and began operating in the Salt River Area in the second quarter of 2002.

There was also an increase in the number of exceedance days from November 2005 through March 2006. During this period, t he region experienced stagnant conditions and an unusually long period with no rain, which may have contributed to the exceedances. Exceedances have also occurred since 2006; however, the majority of these have been flagged as high wind exceptional events. Tables 3-3 and 3-4 list the date, day, readi ng, and location of each exceedance of the 24-hour PM-10 standard recorded from 2005 to 2010, including the data flagged as exceptional events. In 2005, there were 19 exceedance days in t he region. The number increased to 27 exceedance days in 2006 with six being exceptional events. The EPA concurred with four of the ex ceptional event days and took no action on the remaining two. In both 2007 and 2008 there were 11 days where the region ex ceeded the PM-10 standard. Most of these exceedances were except ional events where EPA has yet to take

3 - 8Figure 3-3Number of 24-Hour PM-10 Exceedance DaysNotes: -The Arizona Department of EnvironmentalQuality began flagging exceptional events in 2004.-The chart includes exceedance days at the Buckeye monitor,which is located outside the PM-10 nonattainment area.-On July 19, 2007, the exceedance at the Buckeye monitor was notassociated with the exceptional event that also occurred on that day.Sources: 1988 - 1997 - Revised MAG 1999 Serious Area Particulate Planfor PM-10 for the Maricopa County Nonattainment Area, February 2000.1998 - 2010 - EPA Air Quality System.271918131111111078763434122000 03 - 9Table 3-3 Exceedances of the 24-Hour PM-10 Standard, 2005 to 2007

2005 2006 2007

DATE DAY READING LOCATION DATE DAY READ ING LOCATION DATE DAY READING LOCATION 4/4/05 Mon 172 WF 1/10/06 Tue 155 DC 3/27/07 Tue 227+ WF 6/21/05 Tue 157 BE 1 1/10/06 Tue 190 WF 4/12/07 Thu 171+ SP 11/1/05 Tue 166 WF 1/11/06 Wed 168 DC 4/12/07 Thu 202+ WF 11/2/05 Wed 173 WF 1/11/06 Wed 165 WF 5/4/07 Fri 196+ WF 11/3/05 Thu 163 DC 1/12/06 Thu 169 DC 6/6/07 Wed 180+ HI 11/10/05 Thu 165 WF 1/12/06 Thu 169 WF 6/6/07 Wed 225+ WF 11/17/05 Thu 155 DC 1/13/06 Fri 156 WF 7/19/07 Thu 194 BE 1 11/18/05 Fri 169 BE 1 1/19/06 Thu 183 DC 7/19/07 Thu 267+ CP 11/22/05 Tue 189 DC 1/19/06 Thu 183 WF 7/19/07 Thu 272+ CL 2 11/22/05 Tue 173 WF 1/24/06 Tue 170 HI 7/19/07 Thu 199+ HI 11/23/05 Wed 164 DC 2/8/06 Wed 183 WF 7/19/07 Thu 521+ JLG 11/23/05 Wed 175 WF 2/9/06 Thu 171 DC 7/19/07 Thu 177+ WF 12/1/05 Thu 158 DC 2/9/06 Thu 204 WF 8/13/07 Mon 159+ SP 12/2/05 Fri 164 DC 2/13/06 Mon 159 BE 1 8/16/07 Thu 195+ HI 12/2/05 Fri 194 WF 2/14/06 Tue 272 BE 1 8/16/07 Thu 214+ WF 12/12/05 Mon 198 BN 2/15/06 Wed 157 DC 8/23/07 Thu 230+ HI 12/12/05 Mon 206 DC 2/15/06 Wed 201 WF 10/21/07 Sun 312+ CL 2 12/12/05 Mon 172 GR 2/17/06 Fri 191 BE 1 10/24/07 Wed 174+ HI 12/12/05 Mon 232 WF 3/10/06 Fri 240+ DC 11/15/07 Thu 165+ BE 1 12/12/05 Mon 155 WP 3/10/06 Fri 166+ GR 11/15/07 Thu 155+ DC 12/13/05 Tue 165 DC 3/10/06 Fri 260+ WF 12/13/05 Tue 167 WF 4/14/06 Fri 211++ BE 1 12/14/05 Wed 180 DC 4/14/06 Fri 189++ CP 12/14/05 Wed 176 WF 4/14/06 Fri 253++ DC 12/15/05 Thu 155 DC 4/14/06 Fri 212++ GR 12/21/05 Wed 200 DC 4/14/06 Fri 221++ HI 12/21/05 Wed 200 WF 4/14/06 Fri 312++ WF 12/22/05 Thu 178 DC 4/14/06 Fri 177++ WP 12/22/05 Thu 167 WF 4/15/06 Sat 187++ CP 12/23/05 Fri 157 DC 4/15/06 Sat 179++ DC 12/23/05 Fri 156 WF 4/15/06 Sat 170++ GR 4/15/06 Sat 274++ HI 4/15/06 Sat 191++ WF 5/22/06 Mon 174++ WF 6/2/06 Fri 159 WF 6/6/06 Tue 155++ HI 10/5/06 Fri 165+ HI 11/16/06 Thu 163 WF 11/17/06 Fri 174 WF 11/27/06 Mon 164 WF 12/5/06 Tue 173 WF 12/6/06 Wed 167 DC 12/6/06 Wed 159 WF 12/7/06 Thu 174 DC 12/7/06 Thu 159 WF 12/14/06 Thu 163 WF 12/15/06 Thu 177 WF

1 The Buckeye monitor is located outside the PM-10 nonattainment area. 2 The Coyote Lakes monitor was a special purpose monitoring site that was shut down in February 2009. + Exceptional events where EPA took no action. ++ Exceptional events with EPA concurrence. Source: EPA Air Quality System.
3 - 10Table 3-4 Exceedances of the 24-Hour PM-10 Standard, 2008 to 2010

2008 2009 2010

DATE DAY READING LOCATION DATE DAY READ ING LOCATION DATE DAY READING LOCATION 3/2/08 Sun 159+ BE 1 3/22/09 Sun 198** WF 10/15/10 Fri 158 GR 3/14/08 Fri 250* WF 3/26/09 Thu 209** WF 4/30/08 Wed 172* WF 4/3/09 Fri 213** WF 5/21/08 Wed 278* WF 7/17/09 Fri 400** BE 1 6/4/08 Wed 203+ BE 1 7/17/09 Fri 161** DC 6/4/08 Wed 186+ CL 2 7/17/09 Fri 275** HI 6/4/08 Wed 193* WF 7/17/09 Fri 169** SP 7/1/08 Tue 172+ BE 1 7/17/09 Fri 185** WF 7/4/08 Fri 223+ BE 1 7/18/09 Sat 213** BN 10/11/08 Sat 161+ SP 7/18/09 Sat 439** BE 1 10/22/08 Wed 167+ CL 2 7/18/09 Sat 277** DC 11/7/08 Fri 247 DC 7/18/09 Sat 227** DY 11/9/08 Sun 169+ DC 7/18/09 Sat 196** GL 11/9/08 Sun 230+ SP 7/18/09 Sat 229** GR 11/9/08 Sun 247+ WF 7/18/09 Sat 250** SP 7/18/09 Sat 185** WC 7/18/09 Sat 317** WF 7/18/09 Sat 210** WP 9/3/09 Thu 160** SP 9/3/09 Thu 174** WF 10/27/09 Tue 166** BE 1 10/27/09 Tue 157** DC 10/27/09 Tue 177** HI 10/27/09 Tue 220** WC 10/27/09 Tue 188** WF

1 The Buckeye monitor is located outside the PM-10 nonattainment area. 2 The Coyote Lakes monitor was a special purpose monitoring site that was shut down in February 2009. + Exceptional events where EPA took no action. * Exceptional events where EPA did not concur. ** Exceptional events where EPA concurrence is pending. Source: EPA Air Quality System.

3 - 11action. However, EPA has indica ted that it does not concur with four high wind exceptional events at the West 43 rd Avenue site in 2008, resulting in a violation of the PM-10 standard. All of the exceedances in 2009 have been flagged as exceptional events and EPA concurrence is pending. In 2010, only one exceedance of the 24-hour PM-10 standard occurred, which did not constitute a violation. In summary, the region has exper ienced a number of exceptional events in recent years. However, due to EPA nonconcurrence wit h four events at the West 43 rd Avenue monitor in 2008, the region was unable to attain the PM-10 standard in 2010. The exceedances in 2009 have been flagged as exceptional events and only one exceedance occurred in 2010. Therefore, approval of the 2009 exceptional events woul d give the region two years of clean data.

3 - 12REFERENCES MAG, 2008. PM-10 Source Attribution and Deposition Study. March, 2008.

3 - 13CHAPTER FOUR

THE ADOPTED PLAN AND IMPLEMENTATION SCHEDULE FOR THE MAG 2012 FIVE PERCENT PLAN FOR PM-10

The new MAG 2012 Five Percent Pl an for PM-10 contains a wide variety of existing control measures and projects that have been implemented to redu ce PM-10 and a new measure designed to reduce PM-10 during high risk condi tions, including high winds. While the 2007 Five Percent Plan was withdrawn, a wide range of control measures in that plan continue to be implemented to reduce PM-10 and are being resubmitted. Table 4-1 includes the Arizona Statutes, Maricopa County Rules, a Maricopa County Ordinance, and Appendices for the resubmitted measures and a new high risk measure to be approved into the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. The Arizona Revised Statutes listed in Tabl e 4-1 are included in Appendix C, Exhibit 1. The 2012 Five Percent Plan also includes c ontingency measures t hat were implemented early such as PM-10 certified street sweepi ng on freeways and arterials, as well as the projects completed in 2008-2011 that paved and stabilized unpaved roads, alleys and shoulders; reduced speed limits; and over laid highways with rubberized asphalt. As described in Table 4-1, the Arizona Stat utes, Maricopa County Rules, and Maricopa County Ordinance include requirements to r educe PM-10 emissions from a broad range of sources. The requirements apply to unpaved roads and shoulder s, leaf blowers, unpaved parking lots, vacant lots, sweeping street s with certified sweepers, off-road vehicle use, open and recreational burning, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. It is also important to note that the Environment al Protection Agency (EPA) has approved Maricopa County Rules 310 and 310.01 in 2010 and Ru le 316 in 2009, as part of the State Implementation Plan. Compli ance with these rules has incr eased every year since 2007. These Maricopa County rules reduce emissions from a wide variety of sources and apply to the Maricopa County area. Maricopa Count y Rule 310 (Fugitive Dust from DustGenerating Operations) regulates fugitive dust emissions from sources and activities such as: land clearing, earthmoving, weed abatement, excavating, construction, demolition, bulk material handling, storage and transporting operations, outdoor equipment, motorized machinery, staging areas, parking areas, mate rial storage areas, haul roads, disturbed surface areas, initial landscapes and trackout onto paved surfaces from these sources. Maricopa County Rule 310.01 (Fugitive Dust fr om Non-Traditional Sources of Fugitive Dust) regulates fugitive dust em issions from sources and activi ties such as: vehicle use in open areas and vacant lots, open areas, vacant lots, unpaved parking lots, unpaved roadways (including alleyways), easements, ri ghts-of-way, access roads and trackout onto paved surfaces from these activities.

4 - 1Table 4-1 Arizona Statutes, Maricopa County Ru les, Maricopa County Ordinance, and Appendices to be Approved into the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area

Arizona Revised Statutes (A.R.S.) Description Effective Dates A.R.S. § 9-500.04. Only A.3., A.5., A.6., A.7., A.8., A.9. and H. Air quality control; definitions [city and town requirements in Area A regarding targeting unpaved roads and shoulders; leaf blower restrictions; restrictions related to parking, maneuvering, ingress and egress areas and vacant lots; requirement for certified street sweepers] 9/19/07

A.R.S. § 9-500.27. Off-r oad vehicle ordinance; app licability; violation; classification 9/19/07 A.R.S. § 11-871. Only A., B. and D.4. Emissions control; no burn; exemptions; penalty [no burn restriction for any HPA day, increased civil penalty] 9/19/07 A.R.S. § 11-877. Air quality control measures [county leaf blower restrictions] 9/19/07 A.R.S. § 28-1098. Only A. and C.1. Vehicle loads; restrictions; civil penalties [for safety or air pollution prevention purpose] 9/19/07 A.R.S. § 49-424. Only 11. Duties of department [develop and disseminate air quality dust forecasts for the Maricopa County PM-10 nonattainment area] 7/20/11

A.R.S. § 49-457.01. Leaf blower use restrictions and training; leaf blower equipment sellers; informational material; outreach; applicability 9/19/07

A.R.S. § 49-457.03. Off-road vehicles; pollution advisory days; applicability; penalties 9/19/07 A.R.S. § 49-457.04. Off-highway vehicle and all-terrain vehicle dealers; informational material; outreach; applicability 9/19/07 A.R.S. § 49-457.05. Only A., B., C., D. and I. Dust action general permit; best management practices; applicability; definitions 7/20/11

A.R.S. § 49-474.01. Only A.4., A.5., A.6., A.7., A.8., A.11., B. and H. Additional board duties in vehicle emissions control areas; definitions [county requirements for stabilization of targeted unpaved roads, alleys and shoulders; restrictions related to parking, maneuvering, ingress and egress areas and vacant lots; requirement for certified street sweepers] 9/19/07

A.R.S. § 49-474.05. Dust control; training; site coordinators 9/19/07 A.R.S. § 49-474.06. Dust control; subcontractor registration; fee 9/19/07 A.R.S. § 49-501. Only A.2., B.1., C., F. and G. Unlawful open burning; exceptions; civil penalty; definitions [ban on outdoor fires from May 1 to September 30; deletion of recreational purpose exemption; no burn day restrictions; penalty provision] 9/19/07

A.R.S. § 49-541. Only 1. Definitions [Area A] 8/9/01

4 - 2Table 4-1 Continued Maricopa County Air Quality Department Rules Description Effective Dates 310 Fugitive Dust from Dust-Generating Operations Adopted 1/27/10 and submitted to EPA 4/12/10 [Notice of Final Rulemaking 75 FR 78167; 12/15/10] EPA approved effective 1/14/11 310.01 Fugitive Dust From Non-Traditional Sources of Fugitive Dust Adopted 1/27/10 and submitted to EPA 4/12/10 [Notice of Final Rulemaking 75 FR 78167; 12/15/10] EPA approved effective 1/14/11 314 Open Outdoor Fires and Indoor Fireplaces at Commercial and Institutional Establishments Adopted 3/12/08 and submitted to EPA 7/10/08 [Notice of Final Rulemaking 74 FR 57612; 11/9/09] EPA approved effective 1/8/10 316 Nonmetallic Mineral Processing Adopted 3/12/08 and submitted to EPA 7/10/08 [Notice of Final Rulemaking 74 FR 58553; 11/13/09] EPA approved effective 1/8/10 Appendix C Fugitive Dust Test Methods Adopted 3/26/08 and submitted to EPA 7/10/08 [Notice of Final Rulemaking 75 FR 78167; 12/15/10] EPA approved effective 1/14/11 Maricopa County Ordinance Description Effective Dates P-26 Residential Woodburning Restriction Adopted 3/26/08 and submitted to EPA 7/10/08; [Notice of Final Rulemaking 74 FR 57612; 11/9/09] EPA approved effective 1/8/10 Appendices Description Effective Dates Appendix C, Exhibit 1 Arizona Revised Statutes Listed in Table 4-1 Appendix C, Exhibit 2 Maricopa County Resolution to Evaluate Measures in the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area 11/16/11

Appendix C, Exhibit 3 Arizona Department of Environmental Quality Dust Action General Permit 12/30/11 Appendix C, Exhibit 4 Arizona Department of Environmental Quality Commitment to Revise the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area if Necessary for the Emerging and Voluntary Measure

4 - 3Maricopa County Rule 316 (Nonmetallic Mineral Processing) regulates fugitive dust and process dust emissions from sources and ac tivities such as: mining, excavating, separating, combining, crushing and grindi ng any nonmetallic mineral, asphaltic concrete plants, raw material storage and distributi on, concrete plants, bagging operations, open storage piles, material handling, haul roads, and trackout onto paved surfaces from these sources. MARICOPA COUNTY RESOLUTION TO EVALUATE MEASURES IN THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA Maricopa County indicates that the Maricopa Board of Supervisors adopted a resolution on November 16, 2011 that in cluded a commitment for the Ev aluation of New Innovative Control Measures and Existing Maricopa C ounty Control Measures. Maricopa County indicates that the Maricopa County Air Quality Departm ent will develop and assess the effectiveness of the innovative control pr ogram implemented thr ough the dust generation forecast and Dust Action General Permit on permitted and unpermitted sources of PM-10 in Maricopa County on forecast high risk days. Maricopa County will perform a rule effectiveness study on the implementat ion of existing dust control rules. The Maricopa County Board of Supervisors is authorized by A.R.S. § 49-479 to adopt rules for air pollution control and by A.R.S. § 49- 480 to establish, administer and enforce a program for air quality permits. The Board adopt ed rules establishing an air quality permit program and pursuant to A.R.S. § 49-473, designated the Air Q uality Department to issue permits and administer and enforce the permit pr ogram. In the Memorandum of Agreement developed in 1992 under A.R.S. § 49-406(F), Maricopa County is responsible for tracking emissions from point, ar ea and non-road mobile sources and for tracking the implementation of cont rol measures. By operation of A.R.S. § 49-471, the executive head of the department designated underA.R.S. § 49-473 serves as the Air Pollution Control Officer. The Air Pollution Control Officer is s pecifically authorized to take the enforcement actions set forth in A.R.S. §§ 49-502, 49- 511, 49-512 and 49-513. A. R.S. § 474.01(A)(11) requires adoption of rule provisions by Marc h 31, 2008, and enforcement of the provisions by October 1, 2008, regarding stabilization of disturbed surfaces of vacant lots. Implementation Schedule: The Air Quality Department in consultation with the U. S. En vironmental Protection Agency completed a rule effectiveness study analyzi ng the impact of Rule s 310, 310.01 and 316 for the 2008 PM-10 Periodic Emissions Inventor y contained in Appendix A, Exhibit 1 of the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. The department in consultation with EPA will use a similar approach and process with an appropriate temporal period to evaluate the new innovative cont rol measures such as the dust generation forecast and Dust Action Gener al Permit. The Air Quality Department will conduct the program evaluations as follows:

4 - 4Initial Evaluation: January 2013 Initiate evaluation process fo r new innovative control measures and existing rule effectiveness studies. March 2013 Complete draft program evaluation reports. April 2013 Complete final program evaluation reports. Periodic Evaluation: The department will reevaluat e the effectiveness of the new innovative control measures as part of the periodic em issions inventory required by EPA every three years. Program evaluations will be accommodated as part of the air quality compliance, enforcement and planning processes and will be c oordinated by the Maricopa County Air Quality Department’s existing Planning and Analysis Division. The Maricopa County Air Quality Department administers the air quality program in Maricopa County. Currently the department has 140.6 employees. The Maricopa County Air Quality Department's FY 2010-11 revenue was approximately $15.3 million. No change in funding is anticipated for these program evaluations. The Air Quality Department's enforcement options for regul atory programs include orders of abatement, civil actions for injunctive re lief or civil penaltie s, and filing a class 1 misdemeanor citation. Senate Bill 1552 authorizes the county to enter the lot to stabilize the disturbed surface, issue notic es of violation, and collect monetary penalties that include the cost of stabilization. As noted above, the Air Qua lity Department will assess and evaluate the effectiveness of the new innovative measures as well as the complete rule effectiveness studies for the existing Rules 310, 310.01 and 316 (see Appendix C, Exhibit 2).

ARIZONA DEPARTMENT OF ENVIRONMEN TAL QUALITY DUST ACTION GENERAL PERMIT The Arizona Department of Envir onmental Quality indicates that since the start of Calendar Year 2008, the majority of exceedances of the PM-10 National Ambient Air Quality Standard (NAAQS) in the Maricopa County Seri ous PM-10 Nonattainment Area have been related to high wind events. High wind events, along with a number of other meteorological conditions that can lead to the generation of dust can be predicted through meteorological forecasts.
In accordance with A.R.S. § 49-424(11), ADEQ is developing and disseminating an air quality dust forecast for the Maricopa County Serious PM-10 Nonattainment Area. Based upon knowledge of historical and recent met eorological conditions, and the prediction of

4 - 5such factors as wind speed and wind direction, forecasts identify the potential risk of dust entrainment as “Low”, “Moderat e” or “High” for the next fi ve consecutive days. ADEQ updates this five-day Maricopa County Dust C ontrol Forecast every Sunday through Friday, and posts it on its website at http://www.azdeq.gov/envir on/air/ozone/mcdust.pdf

. In accordance with A.R.S. § 49- 457.05, this Dust Action General Permit identifies a series of Best Management Practices (BMPs) for specific dust generating operations. When ADEQ’s Maricopa County Dust Control Forecast predicts that a day is at high risk for dust generation, those dust generating operations that are not alr eady required to control dust through a permit issued by the Arizona Departm ent of Environmental Quality (ADEQ) or the Maricopa County Air Quality Department (MCAQD) are expected to choose and implement at least one BMP to reduce or prevent PM-10 emi ssions. Implementation of a BMP is expected to occur as soon as prac ticable before and during the high risk event. Although the BMPs in the Dust Action General Permit only appl y to those sources that do not already have a permit, even dust generati ng operations with an air quality permit are also expected to implement the dust contro ls in their permit at the same time. According to state statute, BM Ps identified in the Dust Ac tion General Permit are expected to be employed absent the requirement to obtain an air quality permit. If the owner or operator of a dust-generating operation is found by ADEQ’s Director to have failed to choose and implement an applicabl e BMP as soon as practic able before and during a day that is forecast to be at high risk of dus t generation, then the ow ner or operator can be required to obtain an Authorizat ion to Operate under the Dust Action General Permit. The process by which ADEQ’s Director makes such a finding is identified within the Dust Action General Permit. Violations of the Dust Action General Permit are subject to the enforcement requirements of Arizona Revised Statutes Title 49, C hapter 3, Article 2, including civil penalties of up to ten thousand dollars per day, per violation, pursuant to Section 463. In accordance with A.R.S. § 49-457.05(E) this Dust Action General Permit was subject to a 30-day public comment period and shall be e ffective for a period of five-years (see Appendix C, Exhibit 3).

ARIZONA DEPARTMENT OF ENVIRONMEN TAL QUALITY COMMITMENT TO REVISE THE MAG 2012 FIVE PERCENT PLAN FO R PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA IF NECESSARY FOR THE EMERGING AND VOLUNTARY MEASURE The Arizona Department of Envi ronmental Quality indicates that A.R.S. § 49-404 requires ADEQ to maintain a State Implementation Plan that provides for the implementation, maintenance and enforcement of national am bient air quality standards. Should it be demonstrated through Maricopa County's April 2013 final program eval uation reports that the emerging and voluntary m easure contained within the Five Percent Plan did not achieve the necessary emissions reductions , the Arizona Department of Environmental Quality commits to submitting a SIP revision t hat contains replacement measures to reduce

4 - 6PM-10 emissions by an amount equal to or mo re than the total PM-10 emissions reductions that were not achieved by t hese measures. An implementat ion schedule for the submission of this revised plan is as follows: May 2013 ADEQ will consult with MAG to determine if additional emissions reductions are necessary.

June 2013 If additional controls are requir ed, ADEQ will work with MAG to identify potential repl acement measures. April 2014 If additional controls are requi red, ADEQ will submit a SIP revision that contains the necessaryreplacement measure(s). ADEQ does not anticipate the need for additional personnel or funding to comply with this commitment as any required SIP revisions will be accommodated as part of its normal air quality planning process (see Appendix C, Exhibit 4).
CONTINGENCY REQUIREMENT

The 2012 Five Percent Plan also includes c ontingency measures t hat were implemented early such as PM-10 certified street sweepi ng on freeways and arterial s, as well as the projects completed in 2008-2011 that paved and stabilized unpaved roads, alleys and shoulders; reduced speed limits; and overlaid highways with rubberized asphalt. These PM-10 reduction projects were implemented in the PM-10 nonattainment area by twentyone cities and towns, Maricopa County, Pinal County, Arizona Department of Transportation and the Gila River Indian Community . All of the projects for which credit was taken were open to traffic by Septem ber 2011. EPA encourages ear ly implementation of contingency measures to reduce emissions as expeditiously as practicable. The contingency measures and projects are described in Chapter 6.

ASSURANCES THAT THE STATE HAS THE AUTHORITY TO IMPLEMENT THE MEASURES IN THE PLAN In order to comply with Section 110(a)(2)(E) of the Clean Air Act, a State law was passed in 1992 which provides an approach for assur ances that State and local measures will be adequately implemented (A.R.S. § 49-406 I. and J.). If any person (includes State, County, local governments, regional agenc ies, and other entities) fails to implement a measure as described in the resolution adopted pursuant to A.R.S. § 49-406 G., t he County would file an action in Superior Court to have the Cour t order that the meas ure be implemented. Likewise, the Director of the Arizona Department of Environm ental Quality will backstop the County if it fails to implem ent a measure or if the Count y fails to backstop the local governments and regional agencies. Regarding measures, A.R.S. § 49-406 G. (passed by the Legislature in 1992) requires that each agency which commits to implement any control measure contained in the State

4 - 7Implementation Plan must describe the commitment in a resolution. The resolution must be adopted by the appropriate governing body of the agency. State law also requires the entity to specify the following information in the resolutions: (1 ) its authority for implementing the limitation or measure as provided in statut e, ordinance, or rule; (2) a program for the enforcement of the limitation or meas ure; and (3) the level of personnel and funding allocated to the impl ementation of the measure. As noted in the MAG regional air quality pl ans, the action taken by the MAG Regional Council to approve the Suggested Measures and Adopted Plan Measures does not commit each jurisdiction to implement those measures . As indicated in the resolutions and commitments, each jurisdiction determines wh ich measures are reasonably available for implementation by that jurisdiction.
TRACKING PLAN IMPLEMENTATION The Maricopa County Air Qualit y Department determines reas onable further progress and reviews the implementation stat us of the various measures contained in the air quality plans. The Maricopa County Air Quality Department will also continue to have the responsibility for conducting ambient air quality monitoring. Supplemental to these tracking efforts, the Ma ricopa Association of Governments publishes regional traffic flow maps and calculates regi onal vehicle miles of travel from these flow maps. MAG also conducts vehicle occupancy studies and performs special traffic volume and speed studies, as needed. Phoenix Public Transit continuously monitors transit ridership for each month. The Regional Pu blic Transportation Authority will also be collecting transit and carpooling ridership information. The Arizona Department of Environmental Quality continuously monitors the number of vehicles inspected in the Vehicle Emissions Inspection Maintenance Program , the number of vehicles failing the test, and the improvement in tail pipe emissions after failed vehicles are repaired. In addition, the MAG Air Quality Technical Advisory Committee will review the information pertaining to the implementat ion of measures. The committee will also review the air quality monitoring data to assist in tra cking air quality improvement over time.

4 - 8CHAPTER FIVE

DEMONSTRATION OF ANNUAL FIVE PERCENT REDUCTIONS IN PM-10 EMISSIONS

Chapter Five demonstrates that the MAG 2012 Five Percent Plan for PM-10 meets the Clean Air Act requirement that PM-10 emissions be reduced by five percent per year until attainment is demonstrated. Section 189(d) of the Clean Air Act requires that the Five Percent Plan provide for an annual reduction in PM-10 emissions of not less than five percent of the total emissions in the most recent inventory prepared for the area. This chapter describes the increases in ru le effectiveness that achieve annual reductions of at least five percent of the emissions inv entory for 2007, the base y ear for the plan. The 2007 emissions inventory is based on the revi sed 2008 PM-10 Periodic Emission Inventory for the Maricopa County, Arizona, Nonattainm ent Area (PEI), which is the most recent inventory prepared for the area (A ppendix A, Exhibit 1). Since the attainment date for this Plan is December 31, 2012, annual five percent reductions are r equired for five years, 2008 through 2012. As discussed in detail in Chapter Six, attainment can not be achieved prior to December 31, 2012, becaus e there have been several exc eedances of the 24-hour PM10 standard in 2009 and 2011 which may be due to exceptional events and the required documentation for these events has not ye t been submitted to EPA for concurrence. Additionally, modeled attainment cannot be ac hieved without the credit achieved through the new Dust Action General Permit meas ure (described below) which is not fully implemented until January 1, 2012.
MEASURES QUANTIFIED TO MEET THE FIVE PERCENT REDUCTION REQUIREMENT Fifty-three control measures we re submitted to EPA in Decem ber 2007 as part of the MAG 2007 Five Percent Plan for PM-10. T he 2007 Plan was withdrawn by the Arizona Department of Environmental Q uality in January 2011. Most of the measur es in the 2007 Plan were implemented during the three y ears before the Plan was withdrawn. The measures submitted in the MA G 2012 Five Percent Plan for appr oval into the Arizona State Implementation Plan are listed in Table 4-1. Many of the measures from the 2007 Plan have been included in Table 4-1. To meet the annual five percent reduction requirement in Se ction 189(d) of the Clean Air Act, the MAG 2012 Five Percent Plan takes credi t for increases in rule effectiveness for Maricopa County Rules 310 (Fugi tive Dust from Dust-Gener ating Operations), 310.01 (Fugitive Dust from Non-Traditional Sources of Fugitive Dust) and 316 (Nonmetallic Mineral Processing). The increases in rule e ffectiveness are attributable to strengthened enforcement and increased compliance with these rules. EPA has approved Rules 310 and 310.01 (EPA, 2010) and Rule 316 (EPA, 2009), as part of the State Implementation Plan. Compliance with these rules has increas ed every year since 2007, as shown in Table 5-1.
5 - 1These Maricopa County rules reduce emissions from a wide variety of sources and apply to the Maricopa County area. Maricopa C ounty Rule 310 (Fugitive Dust from DustGenerating Operations) regulates fugitive dust emissions from sources and activities such as: land clearing, earthmoving, weed abatement, excavating, construction, demolition, bulk material handling, storage and transporting oper ations, outdoor equipment, motorized machinery, staging areas, parking areas, mate rial storage areas, haul roads, disturbed surface areas, initial landscapes and trackout onto paved surfaces from these sources. Maricopa County Rule 310.01 (Fugitive Dust from Non-Traditional Sources of Fugitive Dust) regulates fugitive dust em issions from sources and activities such as: vehicle use in open areas and vacant lots, open areas, vacant lots, unpaved parking lots, unpaved roadways (including alleyways), easements, ri ghts-of-way, access roads and trackout onto paved surfaces from these activities. Maricopa County Rule 316 (Nonmetallic Mineral Processing) regulates fugitive dust and process dust emissions from sources and ac tivities such as: mining, excavating, separating, combining, crus hing and grinding any nonmetallic mineral, asphaltic concrete plants, raw material storage and distributi on, concrete plants, bagging operations, open storage piles, material handling, haul roads, and trackout onto paved surfaces from these sources.
Emission reduction credit is also taken for one new measure, the Dust Action General Permit, which will be fully implemented by Januar y 1, 2012, as discussed in Chapter Four. Credit for this measure is allowed under the EPA guidance, Incorporating Emerging and Voluntary Measures in a State Implementation Plan (EPA, 2004). The measures used to demonstrate the annual five percent reducti ons are also used in modeling for the attainment demonstration, as described in Chapter Six. In addition to demonstrating five percent r eductions and modeling attainment, this Plan must meet contingency requirem ents of the Clean Air Act. It is important to note that the contingency requirements must be satisfied by quantifying the benefit of different measures than those used to meet the five percent and attainment demonstration requirements. The contingency requirements met by this Pl an are also discussed in Chapter Six. Strengthened enforcement and in creased compliance with Maricopa County Rules 310, 310.01 and 316 have raised compliance rates significantly since 2007. The benefits of increased compliance with these rules hav e been quantified to show the annual five percent reductions in PM-10 emissions. The rule effectiveness (RE) rates have been calculated for 2007 through 2010, using ac tual inspection data and a methodology developed by the Maricopa County Air Quality Department (MCAQD), in consultation with EPA. Table 5-1 shows the rule effectiveness rates calculated for 2007 through 2010. The RE

5 - 2Table 5-1Impact of Increased Rule Effectiveness on 2008-2012 PM-10 EmissionsCategories Affected by Rule EffectivenessBase Case Emissions (tons/year) Rule Effectiveness Rates2007 2008 2009 2010 2011 2012 2007 2008 2009 2010 -2011 2012Residential Construction 3,423 2,815 1,939 1,656 1,602 1,627 76% 90% 92% 94% 94%Commercial Construction 8,205 6,748 4,649 3,971 3,839 3,901 76% 90% 92% 94% 94%Road Construction 4,150 3,412 2,351 2,008 1,942 1,973 76% 90% 92% 94% 94%All Other Earthmoving 328 270 186 159 154 156 76% 90% 92% 94% 94%Non-metallic mineral mining 306 290 257 246 247 260 40% 65% 69% 73% 73%Mining & Quarrying 256 242 214 205 206 217 40% 65% 69% 73% 73%Industrial paved/unpaved road travel 771 728 645 618 621 654 40% 65% 69% 73% 73%Windblown Agriculture 448 448 448 448 448 448 n/a n/a n/a n/a n/aWindblown Construction 566 566 566 566 566 566 76% 90% 92% 94% 94%Windblown Vacant, Open, Landfill, Test Tracks 5,430 5,430 5,430 5,430 5,430 5,430 85% 95% 96% 96%97%Windblown Sand & Gravel, Mining 190 190 190 190 190 190 40% 65% 69% 73% 73%TOTALS:24,073 21,139 16,876 15,497 15,244 15,422Categories Affected by Rule EffectivenssControlled Emissions (tons/year) Benefits from RE Increases (tons/year)2007 2008 2009 2010 2011 2012 2008 2009 2010 2011 2012Residential Construction 3,423 1,692 1,056 807 780 793 1,122 884 849 821 834Commercial Construction 8,205 4,057 2,531 1,935 1,871 1,901 2,691 2,119 2,036 1,968 2,000Road Construction 4,150 2,052 1,280 979 946 961 1,361 1,071 1,029 995 1,011All Other Earthmoving 328 162 101 77 75 76 108 85 81 79 80Non-metallic mineral mining 306 188 152 132 132 139 102 105 114 114 121Mining & Quarrying 256 157 127 110 110 116 85 87 95 96 101Industrial paved/unpaved road travel 771 472 382 331 333 351 256 263 287 288 304Windblown Agriculture 448 448 448 448 448 448 0 0 0 0 0Windblown Construction 566 391 366 341 341 341 175 200 225 225 225Windblown Vacant, Open, Landfill, Test Tracks 5,430 3,938 3,788 3,788 3,788 3,639 1,492 1,642 1,642 1,642 1,791Windblown Sand & Gravel, Mining 190 132 123 113 113 113 58 68 77 77 77TOTALS:24,073 13,689 10,353 9,062 8,939 8,879 7,450 6,523 6,435 6,305 6,543Note: The increase of 1% for the 2012 higlighted rule effectiveness rate for windblown vacant and open lands is the result of the new Dust ActionGeneral Permit Measure.5 - 3rates have been applied to the base case emissions for the source categories shown in Table 5-1 to quantify the PM-10 emissi on reductions attributable to strengthened enforcement and increased compliance with Rules 310, 310.01 and 316. The RE rate increases are held constant after 2010. As mentioned earlier, the five percent reductions also include the benefits of one new measure, the Dust Action G eneral Permit, which was passed by the Arizona Legislature in April 2011. This new measur e is expected to raise rule effectiveness for Rule 310.01 by one percent during high wind hours, resulting in the RE rate highlighted in Table 5-1 for windblown vacant land, open space, landfills and test tracks in 2012. Additional details regarding the calculation of the PM-10 emissions reduction associated with the increases in rule effectiveness are provided in the TSD (Chapter III of Appendix B, Exhibit 1).

EPA allows an emission reduction benefit to be taken for the new Dust Action General Permit, as an emerging measure (EPA, 2004) . According to EPA guidance, emerging measures do not have the same high level of certainty as traditional measures for quantification purposes in a State Implementation Plan (S IP). The PM-10 emission reduction increment necessary to demonstrate attainment in 2012 (i.e., total 2012 base case emissions (in Table 5-2) minus total 2012 em issions with increased rule effectiveness (in Table 5-3), is 6,543 tons. EPA allows emer ging and voluntary measures to account for up to six percent of this incr ement (in this case, a maximum of 393 tons). The one percent increase in RE during high wind hours will reduc e PM-10 emissions by 149 tons in 2012. Since this reduction is less than 393 tons, benefit for this new measure may be used in meeting the annual five percent reduction require ment and demonstrating attainment in this Plan. As required by EPA's emerging and volunt ary measure guidance, Maricopa County has made a commitment to retrospectively assess the performance of the Dust Action General Permit. MCAQD will evaluate the effectiveness of Rules 310, 310.01 and 316 to ensure that this measure achieves at least a 149 ton r eduction during calendar year 2012. The County's commitment and the method to be used in calc ulating rule effectiveness are described in Chapter Four and Appendix C, Exhibit 2.
DEMONSTRATION FOR THE FIVE PERCENT REDUCTION REQUIREMENT As discussed above, increases in Rule E ffectiveness (RE) for Rules 310, 310.01 and 316 have been quantified to meet the annual five perc ent reductions required in Section 189(d) of the Clean Air Act. Table 5-2 provides t he base case emissions used to calculate the annual five percent reductions. The 2008 emi ssions in this table are based on the most recent version of the 2008 PEI, published in June 2011 (Appendix A, Exhibit 1).

The 2007 and 2009-2012 base case emissions were derived from the 2008 PEI emissions, using annual population and employment grow th factors published in August 2011 by Marshall Vest of the Economic and Business Resear ch Center at the Un iversity of Arizona. These projections are based on the 2010 U.S. Census and the latest economic forecasts

5 - 4Table 5-2 2007-2012 Base Case PM-10 Emissions in the PM-10 Nonattainment Area

Source Category 2007 2008 2009 2010 2011 2012 (tons/year ) POINT 159 150 133 127 128 135 AREA Fuel combustion 1,276 1,301 1,307 1,311 1,316 1,328 Commercial cooking 974 993 998 1,001 1,005 1,014 Construction (includes windblown dust) 16,672 13,811 9,692 8,359 8,102 8,223 Tilling, harvesting and cotton ginning 936 893 893 893 893 893 Travel on unpaved farm roads 769 731 731 731 731 731 Livestock 261 261 261 261 261 261 Travel on unpaved parking lots 2,376 2,422 2,434 2,441 2,451 2,473 Offroad recreational vehicles 2,139 2,180 2,191 2,198 2,206 2,226 Leaf blowers 878 895 899 902 906 914 Windblown agriculture 448 448 448 448 448 448 Other windblown sources 5,430 5,430 5,430 5,430 5,430 5,430 Fires 497 497 497 497 497 497 Mining/quarrying (includes windblown dust) 752 721 661 641 643 667 Travel on industrial paved/unpaved roads 771 728 645 618 621 654 Other industrial sources 1,033 976 865 828 832 877 NONROAD Aircraft 194 184 152 142 143 146 Airport ground support equipment 29 27 23 21 20 20 Locomotives 34 34 34 34 34 34 Other nonroad equipment 1,710 1,683 1,661 1,641 1,595 1,513 ONROAD Exhaust 2,943 2,836 2,647 2,371 1,843 1,407 Tire wear 246 256 257 257 258 261 Brake wear 728 758 767 771 773 787 Paved roads 7,749 8,155 8,214 8,289 8,323 8,422 Unpaved roads and alleys 10,218 10,312 10,284 10,284 10,284 10,312 Totals 59,218 56,681 52,123 50,497 49,743 49,673

5 - 5for the Phoenix-Mesa metropolitan area. Sinc e the economic outlook for Arizona remains extremely unstable, the ac tual population and employment levels in 2011 and 2012 may differ somewhat from the projections. Howeve r, the University of Arizona growth factors represent the most reliable data currently ava ilable. Details regarding the population and employment projections and other technical assumptions used in generating the base case emissions are provided in the TSD (C hapter II of Appendix B, Exhibit 1). The annual five percent reduction target was ca lculated by multiplying the total 2007 PM-10 emissions in Table 5-2 (59,218 tons) by five per cent, which results in 2,961 tons. To meet the 189(d) requirement, the 2008 emissions wit h increased rule effectiveness must be at least 2,961 tons less than the 2007 base case emissions. Each year after 2008 imposes yet another 2,961 ton reduction requirement. T hus, the cumulative reduction requirements (relative to 2007 base case emissions) are at least 5,922 tons in 2009, 8,883 tons in 2010, 11,844 tons in 2011, and 14,805 tons in 2012. Table 5-3 shows the impact of the increases in rule effectiveness on PM-10 emissions in 2008 through 2012. This table also quantifies t he annual five percent reductions for 2008 through 2012. The total reduction in P M-10 emissions between 2007 and 2012 with the increases in rule effectiveness is 16,089 tons , which represents a 27.2 percent reduction in total 2007 base case emissions. Table 5-4 confirms that the annual five per cent reduction requirements are met in 2008- 2012 and there is a surplus margin of benefit in each year. The total surplus in 2012 is 1,284 tons. This surplus is needed to model a ttainment at all monitors in the PM-10 nonattainment area by December 31, 2012. The modeling attainment demonstration is discussed in Chapter Six.

5 - 6Table 5-3 2008-2012 PM-10 Emissions with Increased Rule Effectiveness

Source Category 2008 2009 2010 2011 2012 (tons/year) POINT 150 133 127 128 135 AREA Fuel combustion 1,301 1,307 1,311 1,316 1,328 Commercial cooking 993 998 1,001 1,005 1,014 Construction (includes windblown dust) 8,355 5,333 4,139 4,014 4,073 Tilling, harvesting and cotton ginning 893 893 893 893 893 Travel on unpaved farm roads 731 731 731 731 731 Livestock 261 261 261 261 261 Travel on unpaved parking lots 2,422 2,434 2,441 2,451 2,473 Offroad recreational vehicles 2,180 2,191 2,198 2,206 2,226 Leaf blowers 895 899 902 906 914 Windblown agriculture 448 448 448 448 448 Other windblown sources 3,938 3,788 3,788 3,788 3,639 Fires 497 497 497 497 497 Mining/quarrying (includes windblown dust) 476 401 355 356 369 Travel on industrial paved/unpaved roads 472 382 331 333 351 Other industrial sources 976 865 828 832 877 NONROAD Aircraft 184 152 142 143 146 Airport ground support equipment 27 23 21 20 20 Locomotives 34 34 34 34 34 Other nonroad equipment 1,683 1,661 1,641 1,595 1,513 ONROAD Exhaust 2,836 2,647 2,371 1,843 1,407 Tire wear 256 257 257 258 261 Brake wear 758 767 771 773 787 Paved roads 8,155 8,214 8,289 8,323 8,422 Unpaved roads and alleys 10,312 10,284 10,284 10,284 10,312 Totals 49,231 45,600 44,062 43,438 43,130 5% Reduction Targets (tons/year) 2,961 5,922 8,883 11,844 14,805 Actual Plan Reductions (tons/year) 9,987 13,618 15,157 15,781 16,089

5 - 7Table 5-4 PM-10 Emission Reductions and Fi ve Percent Reduction Requirements

Year 5% Reduction Requirement Total PM-10 Emission Reductions due to Increases in Rule Effectiveness Excess Benefit = Total PM-10 Emission Reductions minus 5% Reduction Requirement (tons/year) (tons/year) (tons/year) (%) 2008 2,961 9,987 7,026 237%
2009 5,922 13,618 7,696 130% 2010 8,883 15,157 6,274 71% 2011 11,844 15,781 3,937 33% 2012 14,805 16,089 1,284 9%

5 - 8REFERENCES EPA, 2004. Incorporating Emerging and Voluntary M easures in a State Implementation Plan . Prepared by the EPA Office of Ai r Quality Standards. September 2004. EPA, 2009. Revisions to the Arizona State PM-10 Implementatio n Plan, Maricopa County Air Quality Department. Final Rule . Federal Register, Volume 74, Number 218, Pages 58553-58554. November 13, 2009. EPA, 2010. Revisions to the State Implementation Pl an, Maricopa County, Arizona. Final Rule . Federal Register, Volume 75, Num ber 240, Pages 78167-78168. December 15, 2010.

5 - 9CHAPTER SIX

ATTAINMENT DEMONSTRATION Chapter Six describes the modeling that was performed to demonstrate that attainment of the 24-hour PM-10 standard will be achieved in 2012. The modeling was conducted to show attainment under high wind conditions si nce violations of t he standard under stagnant conditions have not occurred since 2006 (see C hapter 3 for monitoring data information). A modeling attainment demonstration was perfo rmed for a 36 square m ile area in the Salt River area, which includes the West 43 rd Avenue monitor that has recorded the most exceedances of the PM-10 standard under high wind conditions during 2005-2010. A regional attainment demonstration for the ent irety of the nonattainment area is also provided in this chapter. Both the modeling demonstration in the Sa lt River area and the entire nonattainment area are based upon a distance-weighted rollback approach. Windblown PM-10 emission estimates during high wind hours are calculated from back trajectories while low wind hour emission esti mates are derived from land use distribution within each modeling domain. The benefits of the control m easures described in Chapter Five provide the reductions necessary to model attainment. In addition to the modeling attainment demons trations, this chapter addresses other requirements of a nonattainment area plan, including reasonable further progress, contingency measures, and the onroad motor vehicle emissions budget for conformity. The chapter concludes with a discussion of the cont rol measures in the Five Percent Plan that will reduce PM-10 emissions su fficiently to achieve attainment as expeditiously as practicable and the need for an extension of t he attainment date deadline to December 31, 2012.

SALT RIVER AREA MODELING This section describes the modeling and result s for the attainment demonstration in the Salt River Area. A detailed discussion of the technical me thods and assumptions used to perform the modeling for the Salt River Area is provided in t he TSD (Chapter V of Appendix B, Exhibit 1). Design Day Selection PM-10 monitors in the Maricopa County nona ttainment area recorded 17 exceedances of the 24-hour average PM-10 nati onal ambient air quality standar d in 2007 (the last year before the control measures in this plan were implemented). Exceedances were recorded at six monitoring sites in the nonattainment area: Coyote Lakes, Central Phoenix, Durango, Higley, South Phoenix and West 43 rd Avenue. The Buckeye monitor also exceeded the standard on two days in 2007, but this m onitor is outside the nonattainment area and therefore was not modeled in this plan.

6 - 1Of the 17 exceedances recorded within the nona ttainment area in 2007, the West 43 rd Avenue monitor recorded the highest number of exceedances with six. The Higley monitor was next highest with five. T he remaining exceeding monitors in the nonattainment area recorded two or less exceedances in 2007. All but one of the exceedances in 2007 occurred under high wind conditions. For the pur poses of this attainment demonstration, high wind conditions are defined as days w hen five-minute or hourly average wind speeds are greater than 12 miles per hour. This value is identical to the threshold for windblown dust production as identified in the 2008 PM- 10 Periodic Emissions Inventory (Appendix A, Exhibit 1). Table 6-1 provides a tabulat ion by monitor of the exceedance days, 24-hour average concentrations and the general meteorological condi tions associated with the exceedances. The following primary criteria were appli ed in selecting the design days for PM-10 modeling: 1. Exceedance days with five-minute or hourly average wind speeds > 12 miles per hour; and 2. Exceedance days that are unlikely to be considered as a high wind exceptional event.

The West 43 rd Avenue monitor recorded six exceedanc es when hourly average winds were greater than 12 miles per hour in 2007. Four of the six ex ceedance days were associated with high winds from a frontal storm system, wh ile the remaining two days were associated with high winds from monsoon season t hunderstorm outflows. Days on which thunderstorm outflow activity occurs hav e been excluded as candidate days for modeling, as these days are almost always flagged as uncontrollable exceptional events.

Two of the four frontal system exceedances days re corded at the West 43 rd Avenue monitor were days in which only the West 43 rd Avenue monitor exceeded the standard (March 27 and May 4). These days suggest that the local sources around the West 43 rd Avenue monitor may have been important contributors to the exceedance value. Of these two dates, May 4, 2007 was chosen as the des ign day as wind speeds on March 27 th were significantly higher making it a candidate for an exceptional event demonstration. For a demonstration of regional attainmentacross the nonattainment area, the other exceedance days in 2007 were evaluated using the same criteria employed to select May 4, 2007 for the Salt River ar ea modeling. All high wind da ys associated with thunderstorm outflows were removed for consideration due to their designation as uncontrollable exceptional events. Of the remaining da ys with high wind days, two days (April 12 and June 6) recorded exceedances at multiple m onitors, indicating that the high winds had a more regional effect on PM-10 concentrations . Of the these two dates, June 6, 2007 was chosen as the design day as April 12, 20 07 presented very str ong state-wide high winds indicating this date was also a candidate for an exceptional event dem onstration. A more

6 - 2Table 6-1 Maricopa County and PM-10 Nonattainment Area 24-Hour Average PM-10 Standard Exceedance Dates, Measured Concentrations and Associated Meteorological Conditions in 2007

Monitor Date PM-10 Conc. ( μ g/m 3 ) Meteorological Conditions

Buckeye July 19 195.0 Low Winds November 15 166.2 Irregular Winds Coyote Lakes July 19 273.4 Thunderstorm Outflow October 21 312.9 Frontal System High Winds Central Phoenix July 19 267.8 Thunderstorm Outflow Durango Complex November 15 155.7 Irregular Winds Higley June 6 181.0 Frontal System High Winds July 19 199.5 Thunderstorm Outflow August 16 195.6 Thunderstorm Outflow August 23 230.4 Thunderstorm Outflow October 24 174.8 Frontal System High Winds South Phoenix April 12 171.1 Frontal System High Winds August 13 159.5 Thunderstorm Outflow West 43 rd Avenue March 27 227.9 Frontal System High Winds April 12 202.7 Frontal System High Winds May 4 197.3 Frontal System High Winds June 6 225.7 Frontal System High Winds July 19 178.0 Thunderstorm Outflow August 16 215.1 Thunderstorm OutflowNote: The selected design days are highlighted in bold italics. The Buckeye monitor is located outside the PM10 nonattainment area and is not part of the attainment demonstration. The Coyote Lakes monitor was a special purpose monitor that no longer operates and has since been replaced by the Zuni Hills monitor in late 2009. As such, the Coyote Lakes monitor is not a good candidate for producing a design day.

6 - 3detailed discussion on design day selection is presented in the TSD (Chapter V of Appendix B, Exhibit 1). Plots of hourly wind speed and PM-10 concentration for the high wind design days of May 4, 2007 and June 6, 2007 at the West 43 rd Avenue and Higley monitors are shown in Figure 6-1 through 6-3. Modeling Domain On a high wind design day, the areal extent impac ting monitors is largely a function of wind speed. As such it is necessary to divi de the selected design days into high and low wind hours. High wind hours ar e represented by sources locat ed along back trajectories and low wind hours are represented by sources within a modeling dom ain surrounding the selected monitoring site. The basis for distinguish ing between high and low wind hours is the 12 mph windblown dust aerodynamic entrainment th reshold established in the 2008 PM-10 Periodic Emissions Inventory (Appendix A, Exhibit 1). Five-minute average wind speed and direct ion as measured at the West 43 rd Avenue monitor is employed to construct the ba ck trajectories for each high wind hour. Past modeling of back trajectories indicate that t he lands significantly contributing to elevated PM-10 concentrations recorded at the monitor lie generally within a m ile of either side of the path of the upwind back tr ajectories (see Section entit led “Establishing the Boundaries of a High Wind Domain” in Chapter V of Appendix B, Exhibit 1). The modeling domain used during t he low wind hours for the West 43 rd Avenue monitor is similar to the area initially defined in the ADEQ TSD for the 2005 PM-10 attainment plan and is bounded by Van Buren Str eet to the north, Baseline Road to the south, 59 th Avenue to the west and 7 th Street to the east. Due to the diversity and number of PM-10 sources in the Salt River area, it is considered to be a worst-case representation of sources throughout the nonattainment area. Figure 6-4 shows the low wind domain and the high wind back tr ajectories on May 4, 2007 as originating from the West 43 rd Avenue monitor. The highlighted area surrounding the back trajectories represent the land use dom ain used for calculating windblown PM-10 emissions during the high wind hours. Inventory Development For the high wind hours, hourly windblown PM-10 emissions ar e calculated based upon the land uses that fall withi n the hourly back trajectory. Emi ssions from the land uses within each hourly back trajectory are calculated per the methodology de scribed in the 2008 PM10 Periodic Emissions Inventory. Initially, the land uses within each back trajectory are evaluated for their potential to emit windblown dust. Some land uses are assumed to have no windblown dust emissions (office/ret ail), some are partially emissive (commercial/industrial) and others are assum ed to be 100% emissive (vacant lands).

6 - 4Figure 6-1 Summary of the Monitoring Conditions at West 43 rd Avenue on the High Wind Design Day (May 4, 2007)

6 - 5Figure 6-2 Summary of the Monitoring Conditions at West 43rd Avenue on the High Wind Design Day (June 6, 2007)

6 - 6Figure 6-3 Summary of the Monitoring Conditions at Higley on the High Wind Design Day (June 6, 2007)

6 - 7Figure 6-4 Salt River Area Low Wind Domain and May 4, 2007 Hourly High Wind Back Trajectories and Associated Domains as Originating from West 43 rd Avenue Monitor

6 - 8Land uses that are conservatively assumed to have 100% of their acreage available for windblown dust production include: vacant and open lands, sand and gravel/mining lands, lands under development, landfills and unpaved automotive test tracks. Land uses where only portions of the acreage is available for windblown dust production include: agricultural lands, industrial lands, commercial lands and large public lands.

Windblown PM-10 emissions from these land uses are calculated by use of emission factors based upon wind speed and the distur bance level of each land use. The disturbance level of each land use is derived from rule effectiveness studies of the fugitive dust rules that regulate the various land uses. The effectiveness of the rule is assumed to be an approximate surrogate for t he average level of disturbance of each regulated land use. The details of the calculation of the windblown PM-10 emissions are provided in the TSD (Chapter V of Appendix B, Exhibit 1). Since there have been no stagnation violations of the 24-hour PM-10 standard since 2006, detailed low wind design-day specificemission inventories are not needed. However, emissions reductions achieved as a re sult of controls in this plan during the low wind hours of the high wind design da ys are quantifiable and a necessary part of the attainment demonstration. In order to account for these emissions reductions, annual low wind emission inventories for the PM-10 nonattainment area are allocated to the Salt River area domain based upon land use distribution. This allows for representation of the low wind emissions, and associated control measure benefits, in the Salt River area domain wit hout having to create a design day inventory. The details on how low wind emissions are allocated to the Salt River ar ea domain based upon land use is included in the TSD (Chapter V of Appendix B, Exhibit 1). Distance-Weighted Rollback Modeling The fundamental assumption underlying any rollback method is that pollutant concentrations are directly proportional to total emissions over the area of interest. A weighted rollback approach applies a distance r eduction factor to the emissions of each source in the modeling domain to help asse ss the impact of emissions as distance from the monitor increases. The reduction fa ctor is calculated based upon the distance between each source and the impacting monitor. An investigation of results from a limit ed-term (2010-mid 2011) saturation monitoring study conducted in the Salt River area and beyond under high wind conditions suggested the need to account for distanc e between emission sources and the impacted monitor. Further testing of diffe rent weighting factors through the analysis of dispersion model AERMOD confirmed that a 1/ d weighting factor proved to be the best form of weight to use in adjusting P M-10 emissions developed through the back trajectory domains (See secti on entitled “Source Weighting” in Chapter V of Appendix B, Exhibit 1 for more informati on). Thus, all high wind desi gn day emissions inventories were weighted to account for a 1/ d distance from the modeled monitor.

6 - 9Distance weighting was not applied to the low wind domain, as the low wind domain primarily serves to identif y the predominant land uses near the monitor and thus the predominant low wind emissions associated with the land uses. The overall reduction in low wind emissions gained through the implement ation of control measures was applied as the reduction factor to the low wind hour ly concentrations without the need to weight these reductions by distance. A detailed explanation of the saturation monitoring study and the AERMOD evaluation can be found in the TSD (Chapter V of Appendix B, Exhibit 1). Background Concentrations The temporary saturation monitoring st udy also provided insights into nonanthropogenic levels of PM-10 within the nona ttainment area. These background values were established by comparing monitor ed readings under high and low wind conditions at the temporary, rural Arlington School monitor and the existing Buckeye monitor located just outside the western edge of t he nonattainment area. The Arlington School monitor was located approximately 11 miles west of the Buckeye monitor, surrounded by mostly natural desert land. Under high wind conditions (> 12 mph), when the wind is coming primarily from the west, the Arlington monitor consistently re corded lower PM-10 concentrations than the Buckeye monitor, which is primarily impac ted by PM-10 emissions from agricultural activities. The median value under high wi nd conditions at the Arlington monitor was found to be 21.9 μ g/m 3 and is assumed to be the non-anthropogenic background PM-10 concentration for the PM-10 nonattainment area under high wind conditions. A similar comparison under low wind conditions yielded a median value of 14.9 μ g/m 3 and is assumed to be the non-anthropogenic backgr ound PM-10 concentration for the PM-10 nonattainment area under low wind conditions. A detailed explanation of the methods and data used to develop the background values can be found in the TSD (Chapter V of Appendix B, Exhibit 1). Control Measure Analysis

To assess the benefits of the control meas ures under high wind conditions, separate hourly windblown PM-10 inventories were developed along back trajectory domains using base case soil disturbance rates in 2007 and then compared against inventories developed using the predicted so il disturbance rates in 2012. The high wind inventories are then weighted by distance from the moni tor to more accurately represent the lessening impact of emission sour ces that are farther away from the modeled monitor. The reductions seen during the high wind hours is strictly due to the benefits of control measures in this plan, as land use is he ld constant between 2007 and 2012. Table 6-2 provides a summary of the hourly high wind inventories for 2007 and 2012.

6 - 10Table 6-2 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for May 4, 2007 Design Day at the West 43 rd Avenue Monitor
High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 12 3.05 2.09 2.872E-04 1.900E-04 33.8% 13 9.49 6.36 6.529E-04 4.245E-04 35.0% 14 9.94 6.67 6.866E-04 4.454E-04 35.1% 15 13.94 9.19 8.721E-04 5.581E-04 36.0% 16 13.36 8.81 8.921E-04 5.699E-04 36.1% 17 19.01 12.39 1.190E-03 7.505E-04 36.9% 18 11.84 7.86 7.837E-04 5.033E-04 35.8% 19 6.58 4.44 5.158E-04 3.364E-04 34.8% 21 4.02 2.72 3.236E-04 2.129E-04 34.2% 22 6.63 4.48 5.104E-04 3.330E-04 34.8% Total 97.86 65.02 6.714E-03 4.324E-03 35.6%

6 - 11Under low wind conditions, emissions invent ories for the Salt River area domain were developed based upon land use distribution withi n the Salt River area. Annual 2007 base case and 2012 controlled low wind emissions were each allocated to the land uses within the domain for comparison of the benefits of the control measures in this plan. The reductions seen during the low wind hours ar e a result of the control measures in this plan along with adjustments to s ource categories based upon observed and expected economic and social growth factors. Table 6-3 provides a summary of the low wind inventories by land use for 2007 and 2012. Detailed discussions of the creation of high and low wind inventories is provided in the TSD (Chapter V of Appendix B, Exhibit 1).

Demonstration of Attainment Assessing the impact of the control measures in this plan on concentrations within the Salt River area at the West 43 rd monitor in 2012 is accomplished through a distanceweighted rollback methodology. As per t he methodology, the percent PM-10 emission reductions recorded between the 2007 and 2012 high and low wind inventories provide the percent reductions to the hourly c oncentrations on the design day. Nonanthropogenic background concentrations under high and low wind conditions are held steady and are not reduced by the benefits s een in the contrast between the 2007 base and 2012 controlled inventories. The result ing hourly concentrations in 2012 must then be summed and averaged across the design day in order to compare the 24-Hour value against the 24-hour PM-10 standard. The 24-hour value must be less the 155 μ g/m 3 in order to demonstrate atta inment of the standard. Table 6-4 provides a summary of the re sults of the distance-weighted rollback attainment demonstration for West 43 rd Avenue monitor in the Salt River area. A 24- hour value of 133.2 μ g/m 3 attests that the control measur es in this plan are sufficient to demonstrate that the West 43 rd Avenue monitor will have concentrations below the 24- hour PM-10 standard in 2012. This indica tes that attainment has been demonstrated under high wind conditions at the West 43 rd Avenue monitor within the Salt River area domain.

6 - 12Table 6-3 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Salt River Area Low Wind Domain

Land Use 2007 Emissions (tons) 2012 Emissions (tons) % Reduction
Residential 61.19 62.05 (1.4%) Commercial 61.34 62.81 (2.4%) Agriculture 29.19 28.57 2.1% Vacant/Open 27.97 28.62 (2.3%) Transportation 167.28 155.42 7.1% Industrial 465.10 350.77 24.6% Construction 437.70 132.98 69.6% Total 1,249.76 821.23 34.3%

6 - 13Table 6-4 2012 Attainment Demonstration High Wind Design Day (May 4, 2007) at the West 43 rd Avenue Monitor

Hour Wind Speed (mph) May 4, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 2.5 25.9 14.9 22.1 1 1.4 19.8 14.9 18.1 2 0.4 27.0 14.9 22.8 3 5.5 31.5 14.9 25.8 4 6.7 50.7 14.9 38.4 5 8.5 82.7 14.9 59.4 6 7.2 117.3 14.9 82.2 7 4.9 71.9 14.9 52.3 8 4.5 73.5 14.9 53.4 9 9.2 73.0 14.9 53.1 10 9.4 144.2 14.9 99.9 11 10.6 147.0 14.9 101.7 12 13.4 196.6 21.9 137.5 13 17.6 521.0 21.9 346.4 14 17.4 451.6 21.9 300.6 15 18.7 449.9 21.9 295.8 16 17.7 311.2 21.9 206.7 17 19.4 570.0 21.9 367.7 18 17.6 357.2 21.9 237.2 19 15.5 204.0 21.9 140.7 20 9.8 174.7 14.9 119.9 21 13.6 148.8 21.9 105.4 22 15.6 281.1 21.9 191.0 23 11.6 205.6 14.9 140.2 24-Hour Avg. 197.3 134.1 Note: High wind hours are highlighted in bold italics.

6 - 14PM-10 NONATTAINMENT AREA MODELING Similar to the modeling done for the Salt River area, attainment modeling for the entire nonattainment area is performed through th e use of distance-weighted rollback modeling. The design day of June 6, 2007 was chosen for the regional attainment demonstration based upon the criteria discuss ed earlier in this chapter. A detailed discussion of the technical methods and assumptions used to perform the modeling for the nonattainment area is provided in the TSD (Chapter V of Appendix B, Exhibit 1). Modeling Domain On the high wind design day of June 6, 2007, both the West 43 rd Avenue and the Higley monitor exceeded the 24-hour PM-10 standard. Five other monitors in the nonattainment area recorded elevated PM-10 concentrations but did not exceed the standard; these include: Cent ral Phoenix, Durango Complex, Greenwood, State Super Site and West Phoenix monitors. Table 6- 5 lists the modeled monitors and their 24- hour average concentrations on June 6, 2007. T he other official active PM-10 monitors in the nonattainment area were all 1-in-6 filt er monitors that did not have June 6, 2007 scheduled as a run day and therefore di d not monitor 24-hour average PM-10 concentrations. All seven monitors that did record PM-10 concentrations have been modeled to assure attainment throughout the nonattainment area. As was performed for the Salt River ar ea modeling, a 1-mile buffer around each calculated back trajectory serve as the domain during high wind hours, as developed from each monitoring location in the nona ttainment area. The number of high wind hours (> 12 mph) varies at each moni toring site depending on the unique physical characteristics of each site. In fact, the State Super Site which is located in a dense single-family and multi-family residentia l area had no high wind hours on June 6, 2007. Five-minute wind speed and direction was available to develop back trajectories for the Durango Complex, Greenwood, West Phoenix and West 43 rd Avenue monitors. Hourly wind speed and direction was used to develop the back trajectories for the Central Phoenix and Higley monitors. The large size of the nonattainment area requires that separate low wind domains around the modeled monitors be developed to capture the unique mix of land uses surrounding the monitors. In addition to the Salt River Area domain which includes the West 43 rd Avenue and Durango Complex monitors , a new low wind domain was developed to represent the land uses around th e Higley monitor located in the eastern portion of the nonattainment area. A thir d domain, labeled as the Central City domain, was developed to include central Phoenix monitors of Central Phoenix, Greenwood, State Super Site and West Phoenix. All four of these monitors are located in areas with dense residential and mixed retail/commercial/industrial land uses (see Table V-34 through V-36 in Chapter V of Appendix B, Exhibit 1, for distribution of land uses in low wind domains). Figure 6-5 displays the J une 6, 2007 high wind back trajectory domains and the low wind domains used in t he regional attainment modeling.

6 - 15Table 6-5 24-Hour Average PM-10 Concentrat ions on the High Wind Design Day (June 6, 2007)
Monitor 24-Hour PM-10 Concentration ( μ g/m 3 ) Central Phoenix 107.0 Durango Complex 133.7 Greenwood 121.7 Higley 181.1 State Super Site 80.6 West Phoenix 108.8 West 43 rd Avenue 225.7

6 - 16Figure 6-5 PM-10 Nonattainment Area Low Wind Domains and June 6, 2007 Hourly High Wind Back Tr ajectories and Associated Domains

Note: Emissions from the portions of back trajectorydomains that are outside of the nonattainment area are not included as part of the attainment modeling.

6 - 17Demonstration of Attainment Both the hourly high wind back trajectory and low wind modeling domain inventories are developed using the same methodology employed in the development of the inventories for the Salt River area. Base case 2007 and controlled case 2012 inventories are thus compared to provide the high and low wind r eductions to concentrations seen on the design day. Tables 6-6 through 6-11 prov ide a summary of the hourly high wind emission inventories and associated reduction percentages. Tables 6-12 through 6-13 provide a summary of the low wind dom ain inventories and associated reduction percentages for the Central City and Higley dom ains (the Salt River area domain has already been presented in Table 6-3). The assumptions used to develop non-anthropogenic background values and analysis of control measure benefits in this plan carry over from the modeling demonstration for the Salt River area. Detailed discussion on all aspects of the regional nonattainment modeling can be found in the TSD (Chapt er V of Appendix B, Exhibit 1). Tables 6-14 through 6-20 provide a summary of the results of the distance-weighted rollback attainment demonstration for the seven monitors included in the regional nonattainment demonstration for the June 6, 2007 design day. All seven monitors have 24-hour average PM-10 values under 155 μ g/m 3 which indicates that attainment has been demonstrated under high wind conditions throughout the PM-10 nonattainment area.

6 - 18Table 6-6 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Central Phoenix Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 0 1.90 1.32 7.549E-05 5.230E-05 30.7% 1 0.99 0.74 5.184E-05 3.687E-05 28.9% 6 1.69 1.18 6.873E-05 4.797E-05 30.2% 7 0.99 0.74 5.254E-05 3.730E-05 29.0% 10 0.88 0.64 4.939E-05 3.485E-05 29.4% 11 2.01 1.41 7.319E-05 5.123E-05 30.0% 12 4.01 2.91 1.706E-04 1.166E-04 31.7% 13 7.52 5.04 2.448E-04 1.625E-04 33.6% 14 7.28 4.96 2.265E-04 1.520E-04 32.9% 15 4.33 3.04 1.657E-04 1.121E-04 32.3% 16 4.27 3.13 1.737E-04 1.192E-04 31.4% 17 2.29 1.60 8.494E-05 5.855E-05 31.1% 18 2.21 1.55 7.971E-05 5.545E-05 30.4% Total 40.39 28.25 1.517E-03 1.037E-03 31.7%

6 - 19Table 6-7 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Durango Complex Monitor
High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 11 1.99 1.37 1.340E-04 9.011E-05 32.8% 12 3.69 2.55 2.267E-04 1.543E-04 31.9% 13 3.12 2.15 1.876E-04 1.281E-04 31.7% 14 8.02 5.49 4.672E-04 3.093E-04 33.8% 15 9.84 7.07 4.992E-04 3.379E-04 32.3% 16 5.62 3.79 3.247E-04 2.160E-04 33.5% 17 2.47 1.72 1.619E-04 1.110E-04 31.4% Total 34.74 24.13 2.001E-03 1.347E-03 32.7%

6 - 20Table 6-8 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Greenwood Monitor
High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 12 1.05 0.77 5.872E-05 4.191E-05 28.6% 13 1.03 0.80 6.482E-05 4.701E-05 27.5% 14 3.03 2.16 1.618E-04 1.110E-04 31.4% 15 2.34 1.75 1.266E-04 8.868E-05 30.0% Total 7.45 5.49 4.119E-04 2.886E-04 29.9%

6 - 21Table 6-9 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Higley Monitor
High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 10 0.74 0.55 6.103E-05 4.481E-05 26.6% 11 3.00 2.05 1.944E-04 1.330E-04 31.6% 12 2.15 1.54 1.805E-04 1.270E-04 29.6% 13 2.41 1.69 1.824E-04 1.268E-04 30.4% 14 5.61 3.83 2.282E-04 1.553E-04 31.9% 15 5.70 3.98 2.113E-04 1.442E-04 31.8% 16 5.65 3.90 2.065E-04 1.403E-04 32.1% 17 1.50 1.11 6.687E-05 4.791E-05 28.4% Total 26.76 18.64 1.331E-03 9.195E-04 30.9%

6 - 22Table 6-10 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West Phoenix Monitor
High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 11 0.65 0.53 2.164E-05 1.680E-05 22.4% 12 1.78 1.33 5.329E-05 3.930E-05 26.2% 13 3.35 2.45 8.177E-05 5.933E-05 27.4% 14 4.27 3.08 1.123E-04 8.105E-05 27.8% 15 1.63 1.21 4.623E-05 3.396E-05 26.5% Total 11.67 8.60 3.152E-04 2.304E-04 26.9%

6 - 23Table 6-11 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West 43 rd Avenue Monitor
High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 0 2.29 1.59 2.064E-04 1.388E-04 32.8% 5 3.31 2.29 2.894E-04 1.924E-04 33.5% 6 5.05 3.43 4.359E-04 2.860E-04 34.4% 10 3.44 2.38 2.835E-04 1.898E-04 33.1% 11 6.67 4.51 4.937E-04 3.237E-04 34.4% 12 6.02 4.06 5.697E-04 3.704E-04 35.0% 13 5.66 3.82 4.721E-04 3.088E-04 34.6% 14 9.67 6.48 6.830E-04 4.425E-04 35.2% 15 13.99 9.12 9.717E-04 6.168E-04 36.5% 16 9.67 6.48 6.630E-04 4.304E-04 35.1% 17 5.10 3.45 4.285E-04 2.812E-04 34.4% 18 4.94 3.34 3.857E-04 2.526E-04 34.5% Total 75.81 50.97 5.883E-03 3.833E-03 34.8%

6 - 24Table 6-12 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Central City Low Wind Domain

Land Use 2007 Emissions (tons) 2012 Emissions (tons) % Reduction
Residential 118.19 119.87 (1.4%) Commercial 87.33 89.43 (2.4%) Agriculture 0.00 0.00 0.0% Vacant/Open 25.73 26.33 (2.3%) Transportation 102.23 93.67 7.1% Industrial 262.58 198.03 24.6% Construction 164.80 50.07 69.6% Total 760.86 577.41 24.0%

6 - 25Table 6-13 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Higley Low Wind Domain

Land Use 2007 Emissions (tons) 2012 Emissions (tons) % Reduction
Residential 40.97 41.55 (1.4%) Commercial 15.28 15.65 (2.4%) Agriculture 46.15 45.17 2.1% Vacant/Open 16.62 17.01 (2.3%) Transportation 162.98 149.34 7.1% Industrial 2.58 1.95 24.6% Construction 312.06 94.81 69.6% Total 596.65 365.49 38.5%

6 - 26Table 6-14 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Central Phoenix Monitor

Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 12.5 138.5 21.9 102.7 1 13.1 176.2 21.9 131.6 2 8.6 133.6 14.9 105.1 3 8.0 109.7 14.9 86.9 4 10.9 92.9 14.9 74.2 5 10.3 81.5 14.9 65.5 6 12.4 99.6 21.9 76.1 7 12.8 104.0 21.9 80.2 8 11.1 80.2 14.9 64.5 9 11.3 73.2 14.9 59.2 10 12.1 69.6 21.9 55.6 11 13.9 96.1 21.9 73.8 12 15.3 106.2 21.9 79.5 13 15.4 150.5 21.9 107.3 14 16.9 211.2 21.9 148.9 15 17.8 255.7 21.9 180.1 16 15.7 111.7 21.9 83.5 17 14.0 71.0 21.9 55.7 18 14.0 74.4 21.9 58.4 19 11.9 72.5 14.9 58.7 20 11.1 59.8 14.9 49.0 21 11.7 70.6 14.9 57.2 22 8.8 63.0 14.9 51.5 23 8.5 66.9 14.9 54.4 24-Hour Avg. 107.0 81.7 Note: High wind hours are highlighted in bold italics.

6 - 27Table 6-15 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Durango Complex Monitor

Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 8.9 132.6 14.9 92.2 1 6.3 166.4 14.9 114.4 2 5.0 133.6 14.9 92.9 3 1.0 112.7 14.9 79.2 4 2.6 124.4 14.9 86.8 5 7.3 101.4 14.9 71.7 6 9.1 164.5 14.9 113.2 7 8.7 113.4 14.9 79.6 8 10.5 93.6 14.9 66.6 9 11.2 86.3 14.9 61.8 10 11.9 83.3 14.9 59.8 11 12.5 130.3 21.9 94.8 12 13.9 168.1 21.9 121.4 13 13.5 202.7 21.9 145.4 14 15.7 405.5 21.9 275.9 15 17.9 398.1 21.9 276.5 16 14.5 119.9 21.9 87.1 17 12.9 70.0 21.9 54.9 18 10.3 53.9 14.9 40.5 19 8.9 57.0 14.9 42.6 20 6.4 61.1 14.9 45.3 21 7.5 83.0 14.9 59.6 22 6.3 67.8 14.9 49.7 23 5.2 79.6 14.9 57.4 24-Hour Avg. 133.7 94.6 Note: High wind hours highlighted in bold italics.

6 - 28Table 6-16 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Greenwood Monitor

Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 8.1 138.4 14.9 108.8 1 5.7 159.9 14.9 125.1 2 4.9 123.4 14.9 97.4 3 2.9 105.2 14.9 83.5 4 2.1 105.6 14.9 83.8 5 5.4 86.5 14.9 69.3 6 6.7 112.6 14.9 89.2 7 7.7 103.8 14.9 82.5 8 8.3 77.9 14.9 62.8 9 10.0 79.0 14.9 63.6 10 11.0 74.7 14.9 60.3 11 10.8 103.2 14.9 82.0 12 12.7 172.2 21.9 129.2 13 12.6 194.6 21.9 147.1 14 15.4 442.1 21.9 310.3 15 13.9 240.6 21.9 175.1 16 11.9 93.5 14.9 74.6 17 11.7 96.9 14.9 77.2 18 11.4 82.5 14.9 66.3 19 8.7 68.3 14.9 55.5 20 7.4 61.3 14.9 50.2 21 7.0 67.9 14.9 55.2 22 5.1 63.5 14.9 51.8 23 4.0 68.3 14.9 55.5 24-Hour Avg. 121.7 94.0 Note: High wind hours highlighted in bold italics.

6 - 29Table 6-17 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Higley Monitor

Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 7.4 39.6 14.9 30.1 1 5.8 72.9 14.9 50.6 2 8.8 135.2 14.9 88.9 3 9.0 130.9 14.9 86.2 4 9.1 104.9 14.9 70.3 5 7.4 96.4 14.9 65.0 6 9.4 113.4 14.9 75.5 7 9.4 90.9 14.9 61.6 8 10.8 187.2 14.9 120.9 9 11.6 195.1 14.9 125.7 10 14.6 580.2 21.9 431.9 11 15.2 379.0 21.9 266.3 12 17.6 568.8 21.9 406.7 13 15.3 408.1 21.9 290.5 14 15.8 387.9 21.9 271.1 15 15.6 268.9 21.9 190.5 16 15.3 167.5 21.9 120.8 17 13.5 96.4 21.9 75.3 18 10.1 45.2 14.9 33.5 19 6.9 50.7 14.9 36.9 20 6.6 43.1 14.9 32.2 21 7.1 60.5 14.9 42.9 22 2.9 55.7 14.9 40.0 23 3.2 66.9 14.9 46.9 24-Hour Avg. 181.1 127.5 Note: High wind hours highlighted in bold italics.

6 - 30Table 6-18 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the State Super Site Monitor

Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 7.6 99.3 14.9 79.0 1 6.3 149.6 14.9 117.3 2 5.4 112.2 14.9 88.8 3 5.4 95.8 14.9 76.4 4 6.7 92.4 14.9 73.8 5 7.2 80.6 14.9 64.8 6 7.2 80.2 14.9 64.5 7 6.5 82.7 14.9 66.4 8 7.2 63.5 14.9 51.8 9 6.7 60.8 14.9 49.8 10 6.9 53.6 14.9 44.3 11 9.4 65.5 14.9 53.4 12 8.9 77.8 14.9 62.7 13 9.8 107.8 14.9 85.5 14 10.5 142.1 14.9 111.6 15 11.4 109.4 14.9 86.7 16 10.1 62.3 14.9 50.9 17 9.2 54.4 14.9 44.9 18 11.2 57.5 14.9 47.3 19 9.6 53.9 14.9 44.5 20 7.8 60.9 14.9 49.9 21 6.3 62.5 14.9 51.1 22 3.8 55.1 14.9 45.5 23 3.6 54.8 14.9 45.2 24-Hour Avg. 80.6 64.8

6 - 31Table 6-19 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West Phoenix Monitor

Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 7.1 134.4 14.9 105.7 1 7.8 164.9 14.9 128.9 2 8.4 123.8 14.9 97.7 3 4.2 106.1 14.9 84.2 4 5.1 99.1 14.9 78.9 5 6.1 84.4 14.9 67.7 6 8.5 94.4 14.9 75.3 7 10.3 102.9 14.9 81.8 8 8.7 75.2 14.9 60.7 9 8.6 70.3 14.9 57.0 10 8.8 62.1 14.9 50.8 11 12.1 122.2 21.9 99.7 12 13.6 169.6 21.9 130.8 13 15.1 256.6 21.9 192.2 14 15.1 259.8 21.9 193.6 15 13.5 132.1 21.9 102.9 16 12.0 88.2 14.9 70.6 17 11.7 71.9 14.9 58.2 18 10.0 66.7 14.9 54.3 19 9.3 65.1 14.9 53.1 20 9.1 66.7 14.9 54.3 21 6.8 67.3 14.9 54.7 22 5.3 62.6 14.9 51.2 23 4.8 63.7 14.9 52.0 24-Hour Avg. 108.8 85.7 Note: High wind hours highlighted in bold italics.

6 - 32Table 6-20 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West 43 rd Avenue Monitor

Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 13.3 175.1 21.9 124.9 1 9.9 177.0 14.9 121.4 2 9.1 150.0 14.9 103.7 3 7.8 115.5 14.9 81.0 4 10.6 145.0 14.9 100.4 5 14.5 318.0 21.9 218.8 6 14.9 267.2 21.9 182.9 7 11.4 208.1 14.9 141.8 8 11.3 131.4 14.9 91.4 9 12.0 152.0 14.9 105.0 10 13.8 180.8 21.9 128.3 11 16.0 438.3 21.9 294.9 12 16.6 449.1 21.9 299.6 13 15.1 394.9 21.9 265.9 14 17.6 643.1 21.9 424.3 15 18.1 662.3 21.9 428.4 16 17.0 237.5 21.9 161.8 17 14.5 92.3 21.9 68.1 18 14.9 77.9 21.9 58.6 19 12.0 56.1 14.9 42.0 20 8.8 87.3 14.9 62.5 21 9.3 98.1 14.9 69.6 22 7.0 82.6 14.9 59.4 23 6.8 78.3 14.9 56.6 24-Hour Avg. 225.7 153.8 Note: High wind hours highlighted in bold italics.

6 - 33REASONABLE FURTHER PROGRESS Section 189(c) of the Clean Air Act estab lishes a requirement that the plan include quantitative milestones that are to be achi eved every three years until the area is redesignated to attainment and which demons trate reasonable further progress toward attainment by the applicable date. Sect ion 171(1) of the Clean Air Act defines reasonable further progress as annual increm ental reductions in emissions for the purpose of ensuring attainment by the applicable date. For the MAG 2012 Five Percent Plan, the app licable attainment date is December 31, 2012. The MAG 2007 Five Percent Plan incl uded fifty-three control measures, most of which were implemented during the thr ee years before the Plan was withdrawn in January 2011. The measures were firs t implemented in 2008 and continue to be implemented. The measures submitted in t he MAG 2012 Five Percent Plan for PM-10 for approval into the Arizona SIP are listed in T able 4-1. Many of t he measures from the 2007 Plan have been included in Table 4-1. Although the 2007 Plan was withdrawn, EPA has approved Rules 310 and 310.01 (EPA, 2010) and Rule 316 (EPA, 2009), into the State Implementation Plan as permanent and enforceable measures. Increases in rule effectiveness are attributable to strengthened enforcement and increased co mpliance with these rules. Increased rule effectiveness resulted in major reduc tions in PM-10 emissions throughout the nonattainment area in 2008 through 2010. Attainment can not be achieved prior to December 31, 2012, bec ause the Dust Action General Permit measure needed for attainm ent modeling was not fully implemented until January, 2012. Additionally, according to the form of the PM-10 standard, three years of clean data are needed in order to demonstrate attainment (e.g., 2009-2011). There were several exceedances of the 24-hour PM-10 standard in 2009 and 2011 which may be due to high wind exceptional events and the required documentation for these events has not yet been submitted to EPA for concurrence. It is unknown if three years of clean data will be available for a ttainment by December 31, 2011 until ADEQ submits and EPA acts upon the exceedances due to high wind exceptional events in 2009 and 2011. Because emission reductions from the Dust Action General Permit in 2012 are needed to model attainment and EPA concurrence on exceptional events in 2009 and 2011 is outstanding, the earliest attain ment date achievable by this Plan is December 31, 2012. According to the General Preamble, nonattain ment area plans must include quantitative milestones which are to be achieved every th ree years until the area is redesignated to attainment. The quantitative milestones allo w progress to be measured. Specifically, air quality plans should identify and submit quantitative milestones providing for the amount of emission reductions adequate to achieve the standard by the attainment date. The milestone date analyzed in this Pl an is 2012. The modeling for the Salt River Area and the PM-10 nonattainment area has s hown that the emissions reductions due

6 - 34to increased rule effectiveness for Maricopa County Rules 310, 310.01 and 316 and implementation of the Dust Action General Permit measure are adequate to achieve attainment by 2012. The requirement for a 2012 milestone has been addressed by quantifying the emission reductions resulting fr om the implementation of the Dust Action General Permit measure and increases in ru le effectiveness for Rules 310, 310.01 and 316. As shown in Table 5-3, the m ilestone PM-10 emissions reduction needed to achieve attainment in 2012 is 16,089 tons.

The annual incremental reductions that demons trate reasonable further progress (RFP) between 2007 and 2012 are graphed in Figure 6-6. After 2007, the RFP line represents total emissions in the PM-10 nonattainment area after credit is applied for the increases in rule effectiveness described in Chapter Five. The RFP requirement is met by showing incremental emission reductions suffi cient to maintain linear progress towards attainment. The annual emissions in Figur e 6-6 show a downward linear trend. The slope of the line becomes less steep after 2008, because most of the increases in the rule effectiveness for Rules 310, 310.01 and 316 were achieved in 2008. Figure 6-6 demonstrates that RFP will be achieved betw een 2007 and the attainment date of 2012.
CONTINGENCY REQUIREMENTS

Measures in the MAG 2007 Five Perc ent Plan that strengthen and increase enforcement of Rules 310, 310.01 and 316, as well as the Dust Action General Permit, have been quantified to meet the annual five percent requirement, model attainment, and demonstrate reasonable further progress (RFP). Additional emission reduction benefits beyond those quantified in Chapter Five are needed to meet the contingency requirements of the Clean Air Act. Section 172(c)(9) of the Clean Air Act r equires that nonattainment plans contain contingency measures. Such measures are to be undertaken without further action by the State or the EPA Administra tor if the area fails to make reasonable further progress or meet the standard by the attainment date. The contingency measures must achiev e emission reductions above and beyond those relied upon for progress (five percent reduc tions, milestones, and reasonable further progress) and the modeled attainment demonstr ation. The benefits of the contingency measures must not be required to show attainment and can not hasten attainment. Although there is no mandated emissions reduction level, EPA has recommended that contingency measures provide the emissi ons reduction equivalent of one year’s average increment of RFP. EPA encourages early implem entation of contingency measures to reduce emissions as expediti ously as practicable (EPA, 1993). The contingency requirement is met in the MA G 2012 Five Percent Plan by quantifying the benefits of PM-10 reduction projects that were completed in 2008-2011.

6 - 35Figure 6-6 Demonstration of Reasonable Further Progress

6 - 36A large number of PM-10 reduction proj ects have been implemented in the PM-10 nonattainment area since the MAG 2007 Five Percent Plan was submitted to EPA in December 2007. As required for conti ngency measures, the emission reductions attributable to these projects are above and beyond the credit taken for the measures in Chapter Five. In the Fall of 2011, MAG updated the inventory of PM-10 reduction projects in the nonattainment area that were completed in 2008-2011 by the cities, towns, Maricopa County, Pinal County, the Arizona Department of Transportation (ADOT) and the Indian communities. Thes e projects included paving and stabilizing unpaved roads, alleys and shoulders; reducing speed limits on unpaved roads and alleys; and overlaying state highways with rubberized asphalt. In addition, MAG quantified the benefit for the freeways being swept by an ADOT contractor with PM-10 certified street sweepers and the arterials being swept by local jurisdictions with 25 PM10 certified street sweepers purchased wit h Congestion Mitigation and Air Quality Improvement (CMAQ) funds in 2007 through 2009. Figure 6-6 indicates that the total PM- 10 emissions in 2007 are 59,218 tons; after reductions due to the increases in rule e ffectiveness discussed in Chapter Five, PM-10 emissions are reduced to 43,130 tons in 2012. Subtracting these two values and dividing by five years produces a cont ingency target of 3,218 tons. Therefore, completed projects that reduce total PM- 10 emissions by at least 3,218 tons in 2012 must be quantified to meet the contingency ta rget. A summary of the miles of roads, alleys and shoulders impacted by the paving and stabilization, speed limit reduction, and rubberized asphalt overlay projects that were quantified to meet the contingency requirement is presented in Table 6-21. These PM-10 reduction projects were implemented in the PM-10 nonattainment area by twenty-one cities and towns, Maricopa County, Pinal County, ADOT and the Gila River Indian Community. All of the projects for which credit was taken were open to traffic by September 2011.

The emission reductions for all measures quantified to meet the contingency requirement are summarized in Table 6-22. Table 6-22 includes t he benefits of the PM10 certified street sweeping on freeways and arteri als, as well as the projects completed in 2008-2011 that paved and stabilized unpaved roads, alleys and shoulders; reduced speed limits; and overlaid highways with rubber ized asphalt. A detailed discussion of the assumptions used in quantifying the PM-10 reductions needed to meet the contingency requirement is provided in Chapt er IV of the TSD (Appendix B, Exhibit 1). The total PM-10 emissions reduction in 2012 is 3,439 tons, which exceeds the contingency target of 3,218 tons by 221 tons.

Table 6-23 shows the PM-10 emissions for 2008-2012 by source category after increases in rule effectiveness and contingen cy reductions are applied. The total tons quantified to meet the five percent r eduction, attainment modeling, RFP and contingency requirements is 19,527 in 2012. This represents a 33 percent reduction, relative to 2007 emissions. A pie chart of the 2012 nonattainment area PM-10 emissions with the five percent measures and contingency projects is shown in Figure 6-7.

6 - 37Table 6-21 Miles of Roads/Alleys/Shoulders in PM-10 Reduction Projects

Miles Impacted by Project Type 2008 2009 2010 2011 Total 2008-2011 Miles of dirt roads paved 41 18 8 16 83 Miles of dirt roads stabilized 39 39 36 31 145 Miles of dirt alleys paved 66 4 0 63 134 Miles of dirt alleys stabilized 164 106 124 106 501 Total miles of roads/alleys paved & stabilized 310 168 168 216 862 Miles of dirt shoulders paved 70 107 49 6 233 Miles of curb and gutter paved 19 0 0 0 19 Miles of dirt shoulders stabilized 235 236 236 200 906 Total miles of shoulders paved & stabilized 324 343 285 207 1,158 Miles of roads/alleys with lower speed limits 7 11 3 0 20 Miles of highway overlaid w/rubberized asphalt 13 0 0 0 13

6 - 38Table 6-222008-2012 PM-10 Reductions to MeetContingency RequirementsCompleted Projects Implementing Entities2008 2009 2010 2011 2012(tons/year)Sweep streets with PM-10 certified sweepersContracted sweeping of freeways, ramps and frontageroads - 100% compliant, effective 2/20/1025 PM-10 certified sweepers purchased with CMAQfunds: 1/1/07-12/31/09ADOT 0 0 294 342 344Cities, towns 59 116 153 154 155Total for Street Sweeping 59 116 447 495 499Pave or stabilize existing public dirt roads andalleysPaving/stabilization projects completed in 2008-2011Cities, towns, Maricopa and Pinal County,and Gila River Indian Community 461 1,352 2,124 2,662 2,625Total for Road/AlleyPaving/Stabilization 461 1,352 2,124 2,662 2,625Lower speed limits on dirt roads and alleysSpeed limits lowered in 2008-2011 Cities, towns, Maricopa County 4 78 161 161 161Total for Lower Speed Limits 4 78 161 161 161Pave or stabilize unpaved shouldersPaving/stabilization projects completed in 2008-2011 Cities, towns, Maricopa County 173 242 265 293 150Total for Shoulder Paving/Stabilizing 173 242 265 293 150Repave or overlay paved roads with rubberizedasphaltRubberized asphalt overlays completed in 2008-2011ADOT 0 3 3 3 3Total for Overlays 0 3 3 3 3Total for Completed Projects 697 1,790 2,999 3,614 3,4396 - 39Table 6-23 2008-2012 PM-10 Emissions with Five Percent Plan Measures and Contingency Projects Source Category 2008 2009 2010 2011 2012 POINT 150 133 127 128 135 AREA Fuel combustion 1,301 1,307 1,311 1,316 1,328 Commercial cooking 993 998 1,001 1,005 1,014 Construction (includes windblown dust) 8,355 5,333 4,139 4,014 4,073 Tilling, harvesting and cotton ginning 893 893 893 893 893 Travel on unpaved farm roads 731 731 731 731 731 Livestock 261 261 261 261 261 Travel on unpaved parking lots 2,422 2,434 2,441 2,451 2,473 Offroad recreational vehicles 2,180 2,191 2,198 2,206 2,226 Leaf blowers 895 899 902 906 914 Windblown agriculture 448 448 448 448 448 Other windblown sources 3,938 3,788 3,788 3,788 3,639 Fires 497 497 497 497 497 Mining/quarrying (includes windblown dust) 476 401 355 356 369 Travel on industrial paved/unpaved roads 472 382 331 333 351 Other industrial sources 976 865 828 832 877 NONROAD Aircraft 184 152 142 143 146 Airport ground support equipment 27 23 21 20 20 Locomotives 34 34 34 34 34 Other nonroad equipment 1,683 1,661 1,641 1,595 1,513 ONROAD Exhaust 2,836 2,647 2,371 1,843 1,407 Tire wear 256 254 255 255 259 Brake wear 758 767 771 773 787 Paved roads 7,922 7,857 7,578 7,534 7,772 Unpaved roads and alleys 9,847 8,854 7,999 7,461 7,525 Totals 48,534 43,810 41,062 39,823 39,691 Total PM-10 Emissions Reduction 2007-2012: 19,527 tons, 33.0%

6 - 40Figure 6-76 - 41The emission reductions that have been quantified for contingency credit are not required to meet the five percent requi rement, model attainment, or demonstrate reasonable further progress. In addition, these reductions will not hasten attainment. As discussed previously in this chapter, the earliest attainment date that can be achieved is December 31, 2012, due to the need to take PM-10 reduction credit for the new Dust Action General Permit in order to demonstrate attainment via rollback modeling. This chapter demonstrates t hat PM-10 emissions will be reduced by 3,439 tons more than the reductions achieved by measures used to show progress and model attainment. The early implementation of cont ingency projects in 2008-2011 is assisting in producing the three years of clean data nec essary to attain the standard at all monitors by December 31, 2012.

ONROAD MOBILE SOURCE EMISS IONS BUDGET FOR CONFORMITY

In accordance with the 1990 Clean Air Act Am endments, conformity requirements are intended to ensure that transportation activiti es do not result in air quality degradation. Section 176 of the Amendments requires t hat transportation plans, programs, and projects conform to applicable air quality plans before the transportation action is approved by a Metropolitan Planning Organizati on (MPO). The designated MPO for the Maricopa area is MAG. Section 176(c) of CAAA provides the fram ework for ensuring that Federal actions conform to air quality plans under section 110. Conformity to an implementation plan means that proposed activities must not (1) cause or contribute to any new violation of any standard in any area, (2) increase the frequen cy or severity of any existing violation of any standard in any area, or (3) delay ti mely attainment of any standard or any required interim emission reductions or other milestones in any area. EPA transportation conformity regulations es tablish criteria involving comparison of projected transportation plan emissions with the motor vehicle emissions assumed in applicable air quality plans. The regulations define the term “motor vehicle emissions budget” as meaning “the portion of the total allo wable emissions defined in a revision of the applicable implementation plan (or in an implementation plan revision which was endorsed by the Governor or his or her de signee) for a certain date for the purpose of meeting reasonable further progress mile stones or attainment or maintenance demonstrations, for any criteria pollutant or its precursors, allocated by the applicable implementation plan to highway and transit vehicles.” On June 25, 2002, EPA approved the Revised MAG 1999 Serious Area Particulate Plan for PM-10 in the Maricopa County Nonattain ment Area, includi ng the transportation conformity budget for the attainment y ear of 2006. The 2006 onroad mobile source emissions budget established for PM-10 was 59.7 metric tons per day. The PM-10 emissions in the conformity budget included reentrained dust from paved roads, vehicle exhaust, travel on unpaved roads, and road construction.

6 - 42The MAG 2012 Five Percent Plan establishes a transportation conformity budget based on the measures implemented for the attain ment year of 2012. The PM-10 emissions with the measures that m eet the five percent requi rement, demonstrate modeled attainment, and show reasonable further progr ess in 2012 are summarized in the table below. 2012 PM-10 Emissions from Onroad Mobile Sources (tons/year) Construction (road) 961 Exhaust/tire wear/brake wear 2,456 Paved roads (including trackout) 8,422 Unpaved roads 10,312 Total Onroad Mobile Source 22,151 Converting the annual tons per year to me tric tons on an annual average day in 2012 produces PM-10 emissions of 54.9 metric tons per day for the PM-10 nonattainment area. This represents the onroad mobile source emissions budget for the attainment year of 2012. MAG will use this new budget for conformityanalyses that begin after the budget is found to be adequate or is approved by EPA as part of the MAG 2012 Five Percent Plan for PM-10. In conformity analyses t hat begin after the new budget is found to be adequate or is approved, onroad m obile source PM-10 emissions for 2012 or horizon years after 2012 can not exceed this budget. The methods and assumptions used to estimate onroad mobile source emissions in 2012 are documented in Chapter II of the TS D (Appendix B, Exhibit 1). In future conformity analyses, the estimation of PM- 10 emissions from onroad mobile sources may differ from the TSD estimates, because EPA requires use of the latest planning assumptions (e.g., new emissions models, v ehicle registration data, vehicle speeds, population and travel projections) in effect atthe time each conformity analysis begins.

EXPEDITIOUS ATTAINMENT The measures that have been quantified ar e being implemented throughout the PM-10 nonattainment area. As shown in Table 6- 23, the measures are already reducing PM10 emissions from a variety of sources, including earthmoving, vacant lots, sand and gravel operations, and unpaved roads, a lleys and shoulders. The attainment demonstration discussed earlier in this chapter indicates that the measures in the plan will achieve modeled attainment at all monitors in the nonattainment area in 2012. The current attainment date established by EPA’s final notice of failure to attain is June 6, 2012 (72 FR 31183). However, because of the calendar year form of the PM-10 standard, a mid-year attainment date of June 6, 2012 in effect requires attainment at all monitors by December 31, 2011.

6 - 43The attainment date can not be expedited (f rom June 6, 2012 to December 31, 2011), because the emissions reduction credit from the Dust Action General Permit needed to model attainment is not ava ilable in 2011, as this measur e was not fully implemented until January 1, 2012. Expediting measures in the plan is also not feasible, because all measures except the Dust Action General Permit were already fully implemented by 2010. In addition, the attainment modeling for t he nonattainment area demonstrates that the 24-hour PM-10 standard will be met by a relati vely narrow margin in 2012 (i.e., 153.8 ug/m 3 at the West 43 rd Avenue monitor). The benefits of the measures in 2011 (i.e., without full implementation of the Dust Ac tion General Permit) are not sufficient to model attainment in 2011. For the reasons discussed above, the measures in the Five Percent Plan demonstrate attainment as expeditiously as practicabl e. The measures t hat were implemented throughout the nonattainment area in 2008- 2011, along with the new Dust Action General Permit measure, (fu lly implemented on January 1, 2012) enables attainment of the 24-hour PM-10 standard at all m onitors by December 31, 2012.

ATTAINMENT DATE On July 25, 2002, EPA published a notice of final approval for the Revised MAG 1999 Serious Area Particulate Plan for PM-10 fo r the Maricopa County Nonattainment Area. In this notice EPA also approved a five-year extension of the attainment date from December 31, 2001 to December 31, 2006 (67 FR 48718). On June 6, 2007, EPA published a final notice finding that the Maricopa County nonattainment area had failed to attain the PM-10 standard by the applicable attainment date of December 31, 2006 (72 FR 31183) . The EPA finding was based upon air quality monitoring data for the years 2004 through 2006. There were numerous exceedances of the PM-10 standard during st agnant conditions in 2005 and 2006. As a result, plan provisions that reduce PM-10 em issions by five percent per year until the standard is met are required by Section 189( d) of the Clean Air Act. The MAG 2012 Five Percent Plan has been prepared to meet the five percent reduction requirements, discussed in Chapter Five, as well as t he attainment modeling, reasonable further progress, and contingency requirements addr essed earlier in this Chapter. EPA’s June 6, 2007 final notice of failure to attain establishes the attainment deadline for an area that misses the serious area attainment date, “In accordance with CAA section 179(d)(3 ), the attainment deadline applicable to an area that misses the serious area attain ment date is as soon as practicable, but no later than 5 years from the public ation date of the nonattainment finding notice. EPA may, however, extend the attainment deadline to the extent it deems appropriate for a period no greater than 10 years from the publication

6 - 44date, ‘considering the severity of nonatta inment and the availability and feasibility of pollution control measures.’” (72 FR 31184) The attainment deadline based upon EPA’s final notice is no later than June 6, 2012 unless EPA deems an extension is appropriate. Under stagnant conditions, the PM-10 standard has not been violated since 2006. T he attainment modeling in this Chapter demonstrates that the st andard will also be met under high wind conditions throughout the nonattainment area in 2012.

Attainment of the 24-hour PM-10 standard is measured in terms of the number of exceedances in a three-year period (no mo re than three exceedances at any monitor in the nonattainment area over a three-year period, e.g., 2010-2012). It is anticipated that attainment of the PM-10 st andard will be achieved at all monitors in the nonattainment area by December 31, 2012, after th ree consecutive years (2010-2012) without monitored violations. As described earlier in this chapter, the MAG 2012 Five Percent Plan can not demonstrate attainment via m odeling without taking credit for the Dust Action General Permit that will increase ru le effectiveness for Rule 310.01 by one percent on high wind days. This emerging measure, which was fully implemented on January 1, 2012, will reduce PM-10 emissi ons during high wind conditions in 2012, enabling the Plan to demonstrate modeled a ttainment in 2012. Since modeled attainment can not be demonstrated until 2012 and three calendar years of clean data are needed to demonstrate attainment at all PM-10 monitors in the nonattainment area, the attainment date addressed by this Plan is December 31, 2012. REQUEST FOR EXTENSION OF THE ATTAINMENT DATE FROM JUNE 6, 2012 TO DECEMBER 31, 2012 As discussed in the preceding sections, t he current attainment deadline based upon EPA’s final notice of failure to attain is June 6, 2012. In order to meet the current midyear attainment date of J une 6, 2012, the calendar year form of the 24-hour EPA PM-10 standard requires three years of clean data (2009-2011) at the monitors and modeled attainment by December 31, 2011. As demonstrated in the attainment modeling sections earlier in this chapter, modeled a ttainment can only be achieved in 2012, as the Dust Action General Permit measur e does not become fully implemented until January 1, 2012. Modeled attainment c annot be demonstrated at all the monitors without taking emission reduction credit for this new measure. Also, it is unknown if clean data for years 2009-2011 will be available for attainment by December 31, 2011 until ADEQ submits and EPA acts upon document ation packages for several high wind exceptional events exceedances. As such, an extension of the attainment deadline from June 6, 2012 to December 31, 2012 is needed. As stated in the June 6, 2007 final notice of failure to attain, authority to extend the attainment deadline beyond June 6, 2012 is available to EPA,

6 - 45“EPA may, however, extend the attainm ent deadline to the extent it deems appropriate for a period no greater than 10 years from the publication date, ‘considering the severity of nonattainment and the availability and feasibility of pollution control measures.’” (72 FR 31184) For this Plan, the justification for an extens ion of the attainment deadline from June 6, 2012 to December 31, 2012 is centered around t he availability of the new Dust Action General Permit measure, wh ich was not fully implemented until January 1, 2012. Modeled attainment at all the monitors in the nonattainment area cannot be achieved under high wind conditions without the emissi ons reductions associated with the Dust Action General permit. Development of the MAG 2012 Five Percent Plan was centered on addressing the technical approvability issues identified by EPA in their September 9, 2010 proposed partial disapproval of the MAG 2007 Five Percent Plan for PM-10 (75 FR 54806). These approvability issues es tablished the need for a new emissions inventory and high wind modeling attainment demonstration in the MAG 2012 Five Percent Plan. In February 2011, to begin addressing the te chnical approvability issues identified by EPA, a broad stakeholders group consisting of public and private entities was formed by ADEQ to discuss possible policy options for the MAG 2012 Five Percent Plan. Also meeting at the same time was a Five Percent Plan Technical Committee created to produce a new emissions in ventory, conduct a high wind modeling attainment demonstration and address other technical issues as needed. EPA representatives participated regularly in both of these groups. As of January 2012, the stakeholders gr oup has met 16 times and the technical committee 20 times. The stakeholders group wa s involved in crafting a new measure to reduce fugitive dust on high wind days, the Dust Action General Permit. The Arizona Legislature passed House Bill 2208 in April 2011, which authorized the creation of the Dust Action General Permit. The Dust Acti on General Permit went through public notice and hearing and was signed and issued on December 30, 2011. In order to model attainment during high winds at all the moni tors in the PM-10 nonattainment area, the Five Percent Plan Technical Committee in consultation with EPA settled on the rollback modeling methodology for the MAG 2012 Five Percent Plan in August 2011. However, the high wind da ys to be modeled to demonstrate attainment were not agreed upon by the Five Percent Plan Technical Committee until October, 2011. After applying the rollback methodology to the selected days, it was determined that attainment could not be demonstrated without emissions reduction credit for the Dust Action General Permit. Since the Dust Action General Permit was signed on December 30, 2011, full implem entation of this measure di d not occur until 2012. As such, modeled attainment under high wind conditions at all monitors can only be shown in 2012, necessitating the need for an ext ension of the attainment deadline to December 31, 2012.

6 - 46In summary, the process of addressing t he technical approvability issues suggested by EPA resulted in the development of a new 2008 emissions inventory and the rollback conceptual model and design days selected for attainment modeling. These new technical pieces also identified the need for additional control of high wind fugitive dust beyond existing measures. Once identified, the feasibility of fully implementing the new control measure in order to model atta inment under high wind conditions in 2011 was not possible given the effectiv e date of December 30, 2011 for the Dust Action General Permit. As such, an extension from J une 6, 2012 to December 31, 2012 is needed to allow for a full year of implementation of the new Dust Action General Permit required to demonstrate attainment at all monitors in 2012.

6 - 47REFERENCES EPA, 1993. Early Implementation of Contingency Measures for Ozone and Carbon Monoxide (CO) Nonattainment Areas. August 13, 1993. MAG, 2000. Revised MAG 1999 Serious Area Part iculate Plan for PM-10 for the Maricopa County Nonattainment Area. February 2000.

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