PAYSON MODERATE AREA PM10 MAINTENANCE

PLAN AND REQUEST FOR REDESIGNATION TO

ATTAINMENT

Air Quality Division

Arizona Department of Environmental Quality

March 2002
C:\TEMP\MXLibDir\Payson LMP.wpd
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment i

PAYSON MODERATE AREA PM10 MAINTENANCE PLAN AND 

REQUEST FOR REDESIGNATION TO ATTAINMENT

TABLE OF CONTENTS

I. EXECUTIVE SUMMARY ................................................... 1

II. INTRODUCTION ........................................................ 3

A. Description of Payson PM10 Nonattainment Area ..................... 3

B. Applicable CAA Requirements .................................... 6

C. Applicable EPA Guidance ........................................ 6

D. Requirements for Nonattainment Areas that Have Attained the NAAQS 7

E. Limited Maintenance Plan Option .................................. 8

III. AIR QUALITY .......................................................... 10

A. Monitoring Network and Quality Assurance Procedures ............. 10

B. Historical Air Quality Data for 24-hour and Annual Standards ......... 10

C. Air Quality Data for 24-hour and Annual Standards .................. 11

D. Improvements in Air Quality Not Due to Temporary Economic Downturn

or Unusually Favorable Meteorology .............................. 12

IV. EMISSIONS INVENTORY ................................................. 16

A. 1999 Base-Year Emissions ......................................... 16

V. CONTROL MEASURES .................................................. 22

A. Reasonably Available Control Measures (RACM) ................... 22

B. Permanent and Enforceable Control Measures ..................... 23

C. Contingency Measures .......................................... 23

VI. DEMONSTRATION OF MAINTENANCE OF THE STANDARDS ................... 24

A. Commitment to Calculate PM10 Design Values Annually ............. 24

B. Discussion of Permitting Program to Ensure that New Sources Will Not

Jeopardize Continued Maintenance .............................. 24

C. CAA Section 175(A) Maintenance Plans ........................... 25

VII. OTHER REQUIREMENTS FOR MODERATE AREA AND MAINTENANCE PLANS ..... 25

A. CAA Section 110(a)(2) ........................................... 25

B. CAA Section 172(c) .............................................. 27
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment ii

REFERENCES ................................................................ 28

APPENDIX 1 Applicable EPA Guidance Documents

APPENDIX 2 Applicable Arizona Administrative Code

APPENDIX 3 ADEQ Air Quality Division Organization Chart

APPENDIX 4 Public Hearing Documentation

PAYSON MODERATE AREA PM10 MAINTENANCE PLAN AND 

REQUEST FOR REDESIGNATION TO ATTAINMENT

LIST OF TABLES

Table II-1 Decennial Census Population of Payson and Gila County: 1970-2000 ... 5

Table II-2 Population Projections for Payson and Gila County: 2000-2015 ......... 5

Table II-3 Civilian Labor Force Data for Payson ............................... 6

Table III-1 24-Hour Exceedances of the PM10 NAAQS in Payson 1989 - 1994 ...... 13

Table III-2 Annual Average PM10 Concentrations in Payson For Years 1989-1994 . . 13

Table III-3 1996-2000 PM10 Summary Statistics for Payson Nonattainment Area .... 14

Table IV-1 Payson PM10 Nonattainment Area - 1999 Emissions Estimates .......... 16

Table IV-2 Industrial Sources - Payson ....................................... 20

Table IV-3 Payson Area Industrial Source Emission Estimates .................... 21

Table V-1 Payson Area Contingency Measures .............................. 24

LIST OF FIGURES

Figure II-1 Payson PM10 Nonattainment Area Map ............................. 4

Figure III-1 Maximum 24-hour PM10 Concentration Payson PM10 Nonattainment Area15

Figure III-2 Annual Average PM10 Concentration Payson PM10 Nonattainment Area15

Figure IV-1 Payson PM10 Nonattainment Area 1999 Emissions Estimates ........... 17

Figure IV-2 PM10 Emissions Inventory Payson PM10 Nonattainment Area 1990 & 199917
1PM10 is particulate matter that is 10 micrometers or less in diameter.

2

The method for calculating design values for PM10 is detailed in PM10 SIP Development Guideline,

EPA-450/2-86-001, June 1987. 

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 1

PAYSON MODERATE AREA PM10 PLAN

AND REQUEST FOR REDESIGNATION TO ATTAINMENT

I. EXECUTIVE SUMMARY

The Clean Air Act (CAA) states that an area can be redesignated to attainment

if specific conditions are met, such as attainment of federal air quality standards;

approval of a state implementation plan and a maintenance plan; and permanent and

enforceable improvements in air quality. This document demonstrates that all CAA

requirements for attainment have been met, summarizes the progress of the area in

attaining the PM10 standards, demonstrates that the Payson area qualifies for EPA’s Clean

Data Policy and Limited Maintenance Plan (LMP) option, and includes a maintenance

plan to assure continued attainment for ten years after the redesignation.1 This

document is a formal request to the U.S. Environmental Protection Agency (EPA) to

redesignate the Payson, Arizona PM10 nonattainment area to attainment of the healthbased 24-hour average and annual average PM10 National Ambient Air Quality

Standards (NAAQS). 

Analyses included in this document show that ambient air quality measurements

have remained below the NAAQS for PM10, and both the 24-hour average design value

and annual average PM10 design value are below EPA’s LMP allowable limits.2 This

document also demonstrates that the emission reduction control measures responsible

for the air quality improvement are both permanent and enforceable. The primary

control measures to achieve attainment include implementing reasonably available

control measures (RACM) to reduce fugitive dust emissions and to reduce residential

wood combustion emissions. 

Air quality monitors, located in the Payson, Arizona PM10 nonattainment area,

recorded exceedances of the 24-hour PM10 NAAQS on eleven days in 1989 and 1990

(Table III-1). On December 21, 1993 (58 FR 67334), EPA designated the central portion of

Gila County that includes the community of Payson as a moderate PM10 nonattainment

area, effective January 20, 1994. As a result of this action, the State was required to
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 2

submit to EPA a PM10 State Implementation Plan (SIP) which included an attainment

demonstration for the area.

In June 1995, the Arizona Department of Environmental Quality (ADEQ) submitted

to EPA the PM10 SIP for the Payson PM10 nonattainment area. The SIP contained air

quality modeling for the design year 1990 and projected attainment in the year 2001

based on emission reductions from certain PM10 sources (such as unpaved roads and

parking lots). The 1990 base year emissions inventory comprised mainly of PM10 emissions

from paved and unpaved roads, wood smoke, and industrial sources. The attainment

demonstration was based upon the impact of implemented RACM that reduced PM10

emissions generated from the identified source categories, the closure of two industrial

sources, and more stringent EPA standards for woodstoves. The demonstration also took

into account the increases or decreases in PM10 that would result from changing land

use patterns and the growth in population and vehicle traffic between 1990 and 2001

in the Payson area. 

Attainment of the 24-hour standard is determined when the expected number of

days per year with PM10 concentrations above 150 Fg/m3 (average over a three year

period) is less than or equal to one. Attainment of the annual PM10 standard is achieved

when the expected annual arithmetic mean PM10 concentration over a three year

period is equal to or less than 50 Fg/m3. 

PM10 concentrations reported at the Payson monitoring site between 1998 and

2000, showed no measured exceedance of the 24-hour PM10 NAAQS. Thus, the threeyear average was less than one exceedance per year, which indicates the Payson area

attained the 24-hour PM10 NAAQS. Review of the annual standard for calendar years

1998, 1999 and 2000 reveals that the 3-year annual average was 27 Fg/m3, thus the

Payson area also attained the annual PM10 NAAQS. As a result, on February 15, 2002, EPA

determined that the Payson PM10 nonattainment area did attain the 24-hour and annual

PM10 NAAQS by December 31, 2000 (67 FR 7082).

EPA’s LMP option applies to certain moderate PM10 nonattainment areas seeking

redesignation to attainment. If the area meets certain criteria, the State may submit a

maintenance plan at the time it is requesting redesignation that is more streamlined than

would ordinarily be permitted. To qualify for the LMP option an area should be attaining

the NAAQS and the average PM10 design value for the area, based upon the most

recent 5 years of air quality data at all monitors in the area, should be at or below 98
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 3

Fg/m3 for the 24-hour and 40 Fg/m3 for the annual PM10 NAAQS with no violations at any

monitor. 

Based on the most recent 5 years of air quality data, 1996-2000, the 24-hour

average design value for the Payson area is 88 Fg/m3 and the annual average PM10

design value is 26 Fg/m3. Both the annual average and the 24-hour average PM10

design values are within EPA’s LMP allowable limits. 

With this submittal, ADEQ requests that EPA approve this limited maintenance plan

for the Payson PM10 nonattainment area and redesignate the area to attainment for the

24-hour and annual PM10 NAAQS.
3According to Thornthwaite Climate Regions (Hecht, Melvin, N., and Richard W. Reeves, The

Arizona Atlas, Office of Arid Lands Studies, University of Arizona, Tucson, 1981, pp. 64).

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 4

II. INTRODUCTION

A. Description of Payson PM10 Nonattainment Area

1. Location

Payson is located in the north central part of Gila County, 93 miles north of the

Phoenix area (Figure II-1). Payson is a recreational and retirement area. It is a gateway

to the Mogollon Rim with lakes, streams, and forests. At 5,000 feet in elevation, the area

has a moderate climate, classified as semiarid mesothermal.3 As a result, visitors and

retirees are attracted to this area. Payson was incorporated in 1973.

The Payson nonattainment area contains four complete townships and is144

square miles in size (40 CFR 81.303). Payson is geographically located in about the center.

The Payson nonattainment area is defined by the following townships (see Figure II-1):

T10N, R9E, sections 1-3, 10-15, 22-27, and 34-36

T11N, R9E, sections 1-3, 10-15, 22-27, and 34-36

T10-11N, R10E

T10N, R11E, sections 4-9, 16-21, and 28-33

T11N, R11E, sections 4-9, 16-21, and 28-33

2. Population

In the 1970s, during which rural counties in the U.S. outpaced urban counties in

population growth, the population of Payson, located in northern Gila County, increased

nearly three-fold. The population boom in Payson resulted in a growth rate of more than

180 percent between 1970 and 1980. At the same time, Gila County grew at a moderate

rate of 26.7 percent. Payson continued to gain population during the 1980s and 1990s

at a rate exceeding 60 percent. In contrast, Gila County’s growth rate was 8.5 percent

during the 1980s and increasing to 27.7 percent during the 1990s. Globe, which is

located in southern Gila County, is the second largest city and county seat with a 2000

Census population of 7,486. Decennial census data for Payson and Gila County are

shown in Table II-1.
Tabl eII- 1Decen

n i

al CensusPop

u l

at ionof PaysonandG

i l aC

ounty: 1970-2000
4

The 2000 Census shows a population of 13,620 with 7,033 housing units of which 5,832 are

occupied (17.1 percent vacant). The number of occupied housing units equals the number of households

residing in Payson with 2.3 persons per household. Payson also has a group quarters population of 232. 

Persons not living in households are included in group quarters. Group quarters is classified into

institutionalized persons (patients or inmates) and noninstitutionalized persons (rooming houses, group

homes, dormitories, shelters, etc.).

5

The 2000 Census count was approximately 2,700 higher than the projected population for 2000. 

The Arizona Department of Economic Security’s population projections are expected to be revised in

2002. 

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 6

Year

April 1

1970

April 1

1980

April 1

1990

April 1 

2000

Payson 1,787 5,068 8,377 13,620 4

Payson’s decennial change 183.6% 65.3% 62.6%

Gila County 29,255 37,080 40,216 51,335

Gila County’s decennial change 26.7% 8.5% 27.7%

SOURCE: U.S. Bureau of the Census, decennial census counts.

Table II-2 portrays the projected growth of Payson and Gila County in five-year

increments from 2000 to 2015. According to Arizona Department of Economic Security’s

projections, Payson is expected to grow by slightly more than 40 percent between 2000

and 2015, while Gila county is expected to grow just over 18 percent during this time

period.

Table II-2

Population Projections for Payson and Gila County: 2000-2015 

Year

July 1 

2000

July 1

2005

July 1

2010

July 1

2015

Payson 13,660 15,565 17,427 19,320

Gila County 48,614 551,644 54,603 57,613

SOURCE: Arizona Department of Economic Security, August 1, 1997.

3. Economics
6According to Arizona Department of Revenue, taxable sales in Payson have increased from

$93,413,750 in 1990 to $221,735,950 in 1999, an increase of 137%.

7Attainment of the 24-hour standard is determined by calculating the expected number of days

in a year with PM10 concentrations greater than 150 Fg/m3. The 24-hour standard is attained when the

expected number of days with levels above 150 Fg/m3 (average over a three year period) is less than or

equal to one. Attainment of the annual PM10 standard is achieved when the expected annual arithmetic

mean PM10 concentration over a three year period is equal to or less than 50 Fg/m3 [40 CFR 50.6 (a) and

(b)].

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 7

Economic activity in Gila County can be described as divided between mining

activities in the south and tourism in the north where Payson is located. Since Payson is

a retirement community, retail trade and various service industries play an important role

in the local economy. Because of the popularity of this area, permanent residents and

tourists have increased demand for lodging, restaurants, and various businesses,

including retail.6

Table II-3 shows a selected time series of civilian labor force data. Even though

the labor force recently has been declining, the unemployment rate has fallen to a low

of 2.8% in 2000.

Table II-3

Civilian Labor Force Data for Payson

Year 1990 1994 1996 1998 2000

Civilian Labor Force 3,033 3,490 3,592 3,586 3,357

Number Unemployed 110 148 151 129 93

Unemployment Rate 3.6% 4.2% 4.2% 3.6% 2.8%

SOURCE: Arizona Department of Economic Security. Data represent annual averages. Numbers for

2000 are preliminary. 

B. Applicable CAA Requirements

Section 107(d)(3)(E) of the CAA, as amended, states that an area can be

redesignated to attainment if the following conditions are met:

1. The NAAQS has been attained7;
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 8

2. The applicable implementation plan has been fully approved under

Section 110(k);

3. The improvement in air quality is due to permanent and enforceable

reductions in emissions;

4. The State has met all applicable requirements for the area under Section

110 and Part D; and

5. A maintenance plan with contingency measures has been fully approved

under Section 175(A).

C. Applicable EPA Guidance

PM10 SIP Development Guideline, U.S. Environmental Protection Agency, Office

of Air Quality Planning and Standards, EPA-450/2-86-001, Research Triangle Park, NC, June

1987.

Procedures for Processing Requests to Redesignate Areas to Attainment, John

Calcagni, Director, Air Quality Management Division, U.S. Environmental Protection

Agency, memorandum dated September 4, 1992.

PM10 Emission Inventory Requirements, U.S. Environmental Protection Agency,

Office of Air Quality Planning and Standards, Research Triangle Park, NC, September

1994.

Reasonable Further Progress, Attainment Demonstration, and Related

Requirements for Ozone Nonattainment Areas Meeting the Ozone National Ambient

Air Quality Standard, John S. Seitz, Director, Office of Air Quality Planning and Standards

(MD-10), May 15, 1995.

Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas, Lydia

Wegman, Director, AQSSD (MD-15), U.S. Environmental Protection Agency memorandum

dated August 9, 2001.

D. Requirements for Nonattainment Areas that Have Attained the NAAQS

EPA’s clean data policy applies to ozone nonattainment areas that are meeting

the ozone NAAQS. Specifically, the policy allows certain requirements under CAA

Section 172(c), including developing attainment demonstrations, and reasonable further

progress (RFP) demonstrations, to be waived due to the fact that the areas which are
8 Reasonable Further Progress, Attainment Demonstration, and Related Requirements for Ozone

Nonattainment Areas Meeting the Ozone National Ambient Air Quality Standard, John S. Seitz, Director,

Air Quality Planning and Standards (MD-10), memorandum dated May 25, 1995.

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 9

eligible under this policy have already attained the PM10 NAAQS and have met RFP.8

Similarly, PM10 nonattainment areas with simple PM10 source problems, such as fugitive

dust problems and residential wood combustion, that meet the following requirements

are not required to develop an attainment demonstration and RFP. The requirements for

the policy and how the Payson area meets the requirements are described below:

1. The area must be attaining the PM10 NAAQS based on the three most

recent years of quality assured monitored air quality data.

PM10 concentrations reported at the Payson monitoring site between 1998 and

2000, showed no measured exceedance of the 24-hour PM10 NAAQS. Thus, the threeyear average was less than one exceedance per year, which indicates Payson attained

the 24-hour PM10 NAAQS. Review of the annual standard for calendar years 1998, 1999

and 2000 reveals that the 3-year annual average was 27 Fg/m3, thus the Payson area

also attained the annual PM10 NAAQS. 

2. The State must continue to operate an appropriate PM10 air quality

monitoring network, in accordance with 40 CFR part 58, in order to verify

the attainment status of the area.

The State intends to continue to operate the Payson monitoring network, in

accordance with 40 CFR Part 58, in order to verify the attainment status of the area. The

Payson monitoring network is described in Section III (A) of this plan. 

3. The control measures for the area, which were responsible for bringing the

area into attainment, must be approved by EPA as meeting reasonably

available control measures (RACM) and reasonably available control

technology (RACT) requirements. 

The control measures for the area, which were responsible for bringing the area

into attainment, are described in Section V of this plan. The State anticipates that EPA will

approve these measures as meeting RACM and RACT requirements. 

4. An emissions inventory must be completed for the area. 
9Refer to footnote # 7.

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 10

An emissions inventory has been completed for the Payson area and a detailed

description is contained in Section IV of this plan. 

5. EPA must make a finding that the area attained the 24-hour and annual

PM10 NAAQS.

On February 15 2002, EPA determined that the Payson PM10 nonattainment area

has attained the 24-hour and annual PM10 NAAQS by December 31, 2000 (67 FR 7082).

In addition to the above requirements, any requirements that are connected

solely to designation or classification, such as new source review (NSR), and

RACM/RACT, must remain in effect. However, certain requirements under CAA Section

172(c), including developing attainment demonstrations, and reasonable further

progress (RFP) demonstrations, are waived due to the fact that the areas which are

eligible under this approach have already attained the PM10 NAAQS and have met RFP.

Finally, general conformity requirements continue to apply. The use of the clean data

policy does not constitute a CAA Section 107(d) redesignation, but only serves to

approve nonattainment area SIPs required under Part D of the CAA.

E. Limited Maintenance Plan Option

The LMP option applies to certain moderate PM10 nonattainment areas seeking

redesignation to attainment. If the area meets certain criteria, the State may submit a

maintenance plan at the time it is requesting redesignation that is more streamlined than

would ordinarily be permitted. To qualify for the LMP option an area should meet the

following applicability criteria. The Payson area qualifies for the LMP option in the

following manner: 

1. The area should be attaining the NAAQS.9

As described previously, PM10 concentrations reported at the Payson monitoring

site between 1998 and 2000, showed no measured exceedance of the 24-hour PM10

NAAQS. Thus, the three-year average was less than one exceedance per year, which

indicates Payson attained the 24-hour PM10 NAAQS. Review of the annual standard for

calendar years 1998, 1999 and 2000 reveals that the 3-year annual average was 27

Fg/m3, thus the Payson area also attained the annual PM10 NAAQS 
10The design value is the mathematically derived pollutant concentration at a given site that is

used to determine the level of control needed to reduce pollutant concentrations enough to attain the

NAAQS. 

11The regional emission analysis test is used to determine whether increased emissions from onroad mobile sources could, in the next 10 years, increase concentrations in the area and threaten the

assumption of maintenance that underlies the LMP policy. 

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 11

2. The average PM10 design value for the area, based upon the most recent

5 years of air quality data at all monitors in the area, should be at or below

40 Fg/m3 for the annual and 98 Fg/m3 for the 24 hour PM10 NAAQS with no

violations at any monitor in the nonattainment area.10

Based on the most recent 5 years of air quality data, 1996-2000, the 24-hour

average design value for the Payson area is 88 Fg/m3 and the annual average PM10

design value is 26 Fg/m3. Both the 24-hour average and annual average PM10 design

values within EPA’s LMP allowable limits of 98 Fg/m3 for the 24-hour and 40 Fg/m3 for the

annual PM10 NAAQS.

3. The area should expect only limited growth in on-road motor vehicle PM10

emissions (including fugitive dust) and should have passed a motor vehicle

regional emissions analysis test.11

The motor vehicle regional analysis for the Payson area was performed using the

methods described in Attachment B of the LMP Option for Moderate PM10

Nonattainment Areas memorandum. The following equation was used:

DV + (VMTpi ( DVmv) < MOS

where:

DV = the area’s design value based on the most recent 5 years of quality

assured data in ug/m3

VMTpi = the projected percentage increase in VMT over the next ten years

DVmv = motor vehicle design value based on on-road mobile portion of the

attainment year inventory in ug/m3

MOS = margin of safety for the relevant PM10 standard for a given area: 40

ug/m3 for the annual standard or 98 ug/m3 for the 24-hour standard

Applying the test for the 24-hour average PM10 standard yields the following result:

DV = 88 ug/m3 (24-hour average)
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 12

VMTpi = 27.5 percent (in proportion to expected population increase in Table

II-2)

DVmv = 28 ug/m3 (estimated using the PM10 emissions in Table IV-1)

MOS = 98 ug/m3 for 24-hour average PM10 standard

88 + (0.275 (28) = 95.7 ug/m3

Because the number is less than 98, the area passes regional analysis criterion for

the 24-hour average PM10 standard.

Applying the test for the annual average PM10 standard yields the following result:

DV = 26 ug/m3

VMTpi = 27.5 percent

DVmv = 8.3 ug/m3 (estimated using the PM10 emissions in Table IV-1)

MOS = 40 ug/m3 for the annual average PM10 standard

26 + (.275 ( 8.3) = 28.3 ug/m3

Because the number is less than 40, the area passes the regional analysis criterion

for the annual average PM10 ambient standard.

III. AIR QUALITY

A. Monitoring Network and Quality Assurance Procedures

Ambient concentrations of both Total Suspended Particulates (TSP) and PM10 have

been measured in Payson since 1974. Ambient concentrations of TSP were measured

from 1974 to 1987. In July 1987, ADEQ began monitoring ambient concentrations of PM10.

Initially, the ambient particulate monitor was located in downtown Payson from 1974 to

1977. The particulate monitor was moved to the Tonto National Forest Ranger Station in

1977 and operated at that site until 1980. Recorded PM levels at the Tonto Ranger

Station were much lower than the recorded levels at the Payson downtown site,

probably because it was two miles north of downtown Payson and, thus, not subject to

the same urban particulate sources and influences as the downtown site. As a result,

in 1980, the Tonto Ranger Station monitor was relocated to the Gila County Sheriff’s office

at 108 West Main Street. The Sheriff’s office was a single story, flat roofed building with

sampler inlets installed 5 to 6 meters above ground level. In June 1991, a pitched roof

was added to the Sheriff’s office, thus, it was necessary to move the PM10 monitor to a
12In February 1999, the Payson PM10 monitoring site was moved approximately one mile southeast

to 204 W. Aero Drive. The previous monitoring site location was 300 West Main Street.

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 13

new location. In July 1991, the PM10 monitor was relocated approximately 0.25 miles

west to the roof of the single story US West building at 300 West Main Street. In January

1999, sampling at the US West building was concluded and the PM10 monitor was

relocated to 204 W. Aero Drive (the Payson water treatment plant), approximately one

mile southeast of the US West site. It is the intent of ADEQ to operate the Payson PM10

monitor for the long-term. The site is operated on a once every sixth-day sampling

period. The location, method, and parameters measured are detailed below.

Site Address

Began

Operatin

g

Latitud

e

Longitud

e

Type of

Device

Pollutants

Measured Classificatio

n

Scale Objective

Payson, 204 W.

Aero Drive

199912 34E 14' 111E 20' Partisol PM10 State and

Local Air

Monitoring

Station

neighborhoo

d

general

population

exposure

B. Historical Air Quality Data for 24-hour and Annual Standards

Air quality monitors, located in the Payson PM10 nonattainment area, recorded

exceedances of the 24-hour PM10 NAAQS on eleven days in 1989 and 1990 (Table III-1).

Two exceedances of the annual PM10 NAAQS were recorded in Payson in the years 1989

and 1990 (Table III-2). The majority of the PM10 NAAQS exceedances in Payson occurred

during the winter months. Examination of the data indicated that this is probably due to

strong inversions that are typical during winter and the increased use of fireplaces and

woodstoves for residential heating. During the spring and summer, and to a lesser extent

during the fall, the atmosphere in the Payson area is less stable than during the winter.

The atmospheric instability is 

accompanied by increased turbulence which leads to greater dispersion of PM10 during

the spring, summer, and fall.

On December 21, 1993 (58 FR 67334), EPA designated the central portion of Gila

County that includes the community of Payson as a moderate PM10 nonattainment area,

effective January 20, 1994. As a result of this action, the State was required to submit to

EPA a PM10 State Implementation Plan (SIP) which included an attainment demonstration

for the area.
13The Payson Intensive PM10 Monitoring Study, was conducted by ADEQ and measured particulate

concentrations and particulate chemical constituents at three sites in the Payson area during the

summer and winter of 1990. The purpose of the study was to collect sufficient ambient particulate data

and associated weather data to perform an air quality modeling analysis of PM10 levels in the Payson

Nonattainment Area. PM10 State Implementation Plan for the Payson Nonattainment Area, Arizona

Department of Environmental Quality, June 1995, Appendix A, Technical Support Documentation of Data

Review, pp. 9.

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 14

In June 1995, ADEQ submitted to EPA the PM10 SIP for the Payson PM10

nonattainment area. The SIP contained air quality modeling for the design year 1990 and

projected attainment in the year 2001 based on the reductions in certain PM10 sources

(such as emissions for unpaved roads and parking lots). December 7, 1990, which

experienced a 24-hour PM10 NAAQS exceedance of 182 Fg/m3, was selected as the

design day for the 1995 Payson PM10 SIP. This day was selected over other days which

recorded PM10 exceedances in Payson because more PM10 chemical analyses and

weather data were available for that day from the Payson Intensive PM10 Monitoring

Study.13 An analysis of the micro-meteorological conditions of Payson on the design day,

indicated a diurnal wind pattern of northeast winds from 7 p.m. to 9 a.m. and then

southwest wind from 10 a.m. to 6 p.m. With a high pressure cell influencing the region,

winds were calm to light which are often precursors to subsidence type inversions. The

daytime maximum temperature was 63 degrees F. With a overnight low of 18 degrees

F. The last measurable precipitation before December 7, 1990 was November 28th with

an accumulation of 0.38 inches. 

The 1990 base year emissions inventory comprised mainly of PM10 emissions from

paved and unpaved roads, wood smoke, and industrial sources. The attainment

demonstration was based upon the impact of implemented RACM that reduced PM10

emissions from the identified source categories, the closure of two industrial sources, and

more stringent EPA standards for woodstoves. The demonstration also took into account

the increases or decreases in PM10 that would result from changing land use patterns

and the growth in population and vehicle traffic between 1990 and 2001 in the Payson

area. 

Since 1991, the 24-hour and annual average PM10 levels have been in compliance

with the NAAQS. This is due in part to the implementation of measures to control fugitive

PM10 emissions generated from identified source categories, the closure of two industrial

sources in 1993, and more stringent EPA standards for woodstoves (Section V). 

C. Air Quality Data for 24-hour and Annual Standards
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 15

Table III-3 provides summary statistics from PM10 ambient air quality measurements

at the Payson monitoring site during 1996 through 2000. Figure III-1 and Figure III-2 show

comparisons of PM10 concentrations and the PM10 NAAQS and LMP criteria. The PM10

data for Payson has been collected and quality assurance procedures have been

conducted in accordance with 40 CFR part 58. 

PM10 concentrations reported at the Payson monitoring site between 1998 and

2000, showed no measured exceedance of the 24-hour PM10 NAAQS. Thus, the threeyear average number of exceedances was less than one exceedance per year, which

indicates the Payson area attained the 24-hour PM10 NAAQS. Review of the annual

standard for calendar years 1998, 1999 and 2000 indicates that the 3-year annual

average was 27 ug/m3, thus the Payson area also attained the annual PM10 NAAQS. 

Based on the most recent 5 years of air quality data, 1996-2000, the 24-hour

average design value for the Payson area is 88 Fg/m3 and the annual average PM10

design value is 26 Fg/m3. Both the 24-hour average and annual average PM10 design

values within EPA’s LMP allowable limits of 98 Fg/m3 for the 24-hour and 40 Fg/m3 for the

annual PM10 NAAQS.

D. Improvements in Air Quality Not Due to Temporary Economic Downturn or

Unusually Favorable Meteorology

Section II contains Payson and Gila County population and economic data. The

data shows high population growth in Payson between 1970 and 1990 (Table II-1). No

economic downturn has occurred in the area over the past 10 years. During the ten

year period, the area experienced the full range of meteorological conditions, both

favorable and unfavorable, yet attainment was still achieved.
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 16

Table III-1

24-Hour Exceedances of the PM10 NAAQS in Payson 1989 - 1994

Date PM10 Concentration (Fg/m3)

January 10, 1989 276

January 16, 1989 188

January 22, 1989 153

February 15, 1989 150

December 12, 1989 161

December 18, 1989 190

January 11, 1990 168

January 23, 1990 156

February 16, 1990 156

December 7, 1990 182

December 31, 1990 287

Note: 24-hour PM10 NAAQS Standard = 150 Fg/m3

Source: PM10 State Implementation Plan for the Payson Nonattainment Area, Arizona Department of

Environmental Quality, June 1995, pp. 16.

Table III-2 

Annual Average PM10 Concentrations in Payson For Years 1989-1994 

Year PM10 Concentration (Fg/m3)

1989 79

1990 67

1991 48

1992 40

1993 32
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1994 30

Note: Annual PM10 NAAQS Standard = 50 Fg/m3

Source: PM10 State Implementation Plan for the Payson Nonattainment Area, Arizona Department of

Environmental Quality, June 1995, pp. 16.
14 Four data points substituted under EPA’s Guideline on Exceptions to Data Requirements for Determining Attainment of

Particulate Matter Standards, EPA-450/4-87-005, April 1987.

Table III-3

1996-2000 PM10 Summary Statistics for Payson Nonattainment Area

PM10 Concentrations are for Standard Conditions and are in ug/m3

Year Quarter # of Observations Average Concentration

Max 24-hour

Concentration

2

nd Highest

Concentration # of Exceedances

1996 1 14 43.6 70 65 0

2 15 24.3 29 29 0

3 16 15.1 25 20 0

4 14 36.1 66 52 0

Annual 59 29.8 70 66 0

1997 1 15 31.2 64 51 0

2 15 16.9 28 25 0

3 14 16.0 28 27 0

4 15 34.1 81 67 0

Annual 59 19.6 81 64 0

1998 1 15 33.7 77 63 0

2 15 20.9 34 27 0

3 15 16.6 28 26 0

4 14 35.8 58 53 0

Annual 59 26.8 77 63 0

1999 1 1514 50.3 88 47 0

2 13 21.6 38 36 0

3 14 11.8 22 20 0

4 14 33.6 52 45 0

Annual 56 29.3 88 63 0

2000 1 15 32.0 88 59 0

2 14 18.6 41 31 0

3 15 17.1 28 27 0

4 14 30.4 54 54 0

Annual 58 24.6 88 59 0
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

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Payson Moderate Area PM10 Maintenance Plan March 15, 2002

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50 

100 

150 

200 

250 

300 

ug/m3

1988 1989 1990 1991 1992 1993 1994 1995* 1996 1997 1998 1999 2000

Year

Max 24 hour 24 hour standard LMP 24-hour criteria

Figure III-1 Maximum 24-hour PM10 Concentration

Pa

ys

on

PM

10

No

na

ttai

n

m

en

t

Ar

ea

*Source: 1995 data - Arizona Department of Environmental Quality, 1995 air quality monitoring lab final

data spreadsheet for Payson.

Figure III-2 Annual Average PM10 Concentration 

Payson PM10 Nonattainment Area
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and Request for Redesignation to Attainment 21

10 

20 

30 

40 

50 

60 

70 

80 

ug/m3

1988 1989 1990 1991 1992 1993 1994 1995* 1996 1997 1998 1999 2000

Year

annual average annual standard LMP annual criteria

*Source: 1995 data - Arizona Department of Environmental Quality, 1995 air quality monitoring lab final

data spreadsheet for Payson.
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 22

IV. EMISSIONS INVENTORY

A. 1999 Base-Year Emissions

Table IV-1 and Figure IV-1 show the 1999 base-year emission estimates for the

Payson area. Figure IV-2 shows a comparison between the 1999 emission estimates and

the 1990 emissions inventory contained in the June 1995, PM10 SIP for the Payson PM10

nonattainment area. There is no reason to expect that emission levels in the Payson area

have changed since 1999, so that year is an appropriate one to use in this analysis. 

For the highway vehicle categories, PM10 emissions are estimated using Payson

area vehicle miles traveled (VMT) estimates multiplied by PM10 emission factors for

Arizona in EPA’s 1999 National Emission Inventory (NEI). For other source categories, the

April 1, 2000, population estimates were used to apportion emissions from the county to

the nonattainment area level. Gila County emissions were obtained from the 1999 NEI

Version 1.0 and were scaled to the Payson area, using the ratio of the Payson area

population to the Gila County population in 1999. 

For VMT related activities:

1999 Payson Area VMT = 48.9 million miles per year (0.13 million miles per

day)

For population related activities:

1999/2000 Payson Area Population = 13,660

1999/2000 Gila County Population = 48,614

Therefore, a ratio of (13,660/48,614), or 0.281, was used to allocate Gila County

emissions to the Payson area.

Table IV-1 

Payson PM10 Nonattainment Area - 1999 Emissions Estimates

Source Category

PM10 Emissions

(tons per year)

PM10 Emissions

(tons per day)

PM10 Emissions

(percent)

Unpaved Roads/Parking

Areas-Fugitive Dust

15.4 0.04 5.30%

Paved Roads-Fugitive Dust 88.3 0.24 30.36%
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and Request for Redesignation to Attainment 23

paved roads-dust (30.36%)

unpaved roads/parking-dust (5.30%)

residential wood combustion (28.65%)

industrial (0.93%)

paved roads-exhaust (1.58%)

construction (33.18%)

Paved Roads-Exhaust, Tire,

and Brake Wear

4.6 0.01 1.58%

Construction 96.5 0.26 33.18%

Residential Wood

Combustion

83.3 0.23 28.65%

Industrial Sources 2.7 0.01 0.93%

Total 290.8 0.80 100%

Figure IV-1 Payson PM10 Nonattainment Area

1999 Emissions Estimates
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 24

0 

50 

100 

150 

200 

250 

Tons Per Year

vehicular wood smoke industrial construction

Source Categories

1990* 1999

Figure IV-2 PM10 Emissions Inventory

Payson PM10 Nonattainment Area 1990 & 1999

Source 1990

Emiss

ions

Inve

ntory:

Final

P M 1 0

State

Impl

eme

ntati

o n

Plan

for

the Payson Nonattainment Area, June 1995. Appendix A: Technical Supporting Documentation for Payson,

Arizona PM10 State Implementation Plan, Arizona Department of Environmental Quality, June 19, 1995, pp.

54. Note: the 1990 “miscellaneous” emissions contained in the 1990 emissions inventory were primarily

emissions from construction activities. In order to more accurately compare the 1990 and 1999 construction

emissions, the 1990 “miscellaneous” emissions are included under the “construction” source category.
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 25

Unless otherwise noted, EPA-accepted emission factors in this section were

derived using methodologies from the Procedures Document for National Emission

Inventory, Criteria Air Pollutants 1985-1999 (NEI Procedures) (EPA, 2001). Descriptions of

emission estimation methods by source category are provided below:

Unpaved Roads-fugitive dust: EPA’s emission factor equation for PM10 depends

upon the surface material silt content, the mean weight of vehicles traveling on the

unpaved roads, the surface material moisture content, and the number of days with

measurable precipitation. Emissions are calculated by month at the State/road type

level for the average vehicle fleet and then allocated to the county/road type level.

The activity factor for calculating reentrained road dust emissions on unpaved roads is

the VMT accumulated on these roads. Vehicle miles traveled on unpaved roads in the

Payson Nonattainment Area are estimated by ADEQ to be 75,000 miles per year.

The calculated emission factor is representative of a fleet average emission factor

rather than a vehicle-specific emission factor. A default value of 2.2 tons is used

nationally as the mean vehicle weight for travel on publicly accessible unpaved roads

(AP-42 section 13.2.2- pg. 4). A surface material moisture content value of one percent

(1 percent) is representative of State-wide conditions.

Using this methodology, emission factors were calculated for each month in 1999.

The worst-case emission factor of 212.0 grams per mile was calculated, based on

precipitation during the month of December, 1999. December of 1999 had no days with

precipitation greater than 0.01 inches. Precipitation data for unpaved roads are from

a site in Winslow, Arizona. The daily Payson area emissions of 0.05 tons/day are based on

the December emission factor. Annual emissions were calculated by summing the

emissions for all twelve months. The average annual emission factor was 185.3 grams per

mile.

Paved Roads-fugitive dust: The 1999 NEI estimates fugitive dust emissions for mobile

sources on paved roads. EPA’s PART5 model uses road surface silt loading, vehicle

weight, and precipitation to estimate the PM10 emission factor. Paved road silt loadings

are assigned to each of the twelve functional roadway classifications (six urban and six

rural) based on the average annual traffic volume of each functional system. A silt

loading of 0.20 g /m2 is assigned to road types that had an ADTV (average daily traffic

volume) of less than 5,000 vehicles per day. ADTV is calculated by dividing annual VMT
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 26

by State and functional class (from Highway Statistics, Table VM-2 20) by 365 days per

year, and then dividing by State-specific functional class roadway mileage (from

Highway Statistics, Table HM-20 20). ADEQ estimates paved road VMT for the Payson

area to be 48.9 million miles annually.

The PM10 emission factor equation for paved roads is representative of a fleet

average emission factor rather than a vehicle-specific emission factor. A value of 3.2

tons is the mean vehicle weight for paved roads. The emission factors obtained from

PART5 are modified to account for the number of days with a sufficient amount of

precipitation to prevent road dust resuspension. The PART5 emission factors are multiplied

by the fraction of days in a month with less than 0.01 inches of precipitation.

Precipitation data for paved roads are measured at a site in Phoenix, Arizona.

Paved road PM10 emission factors were calculated for each month in 1999. The

worst-case emission factor of 1.7 grams/mile was calculated based on a design day in

the month of December. December of 1999 had no days with precipitation greater than

0.01 inches. Annual emissions were calculated by summing the emissions for all twelve

months. The emission factor takes into account the portion of PM10 emissions caused by

exhaust, brake wear, and tire wear; those emissions are subtracted from the total

fugitive dust emissions for paved roads and are discussed below, under separate

heading.

Paved Roads-exhaust, brake, and tire wear: EPA calculates monthly, county-level,

Source Classification Code (SCC)-specific PM emissions from on-road vehicle exhaust

components by multiplying year specific monthly, county-level, SCC-specific VMT by

State-level, SCC-specific exhaust PM10 emission factors generated using PART5. Because

none of the inputs affecting the calculation of the PM exhaust emission factors varies by

month, EPA only calculates annual PM exhaust emission factors. The exhaust emission

factor is 0.063 grams/mile.

The PART5 model PM10 emission factor for brake wear is 0.013 grams per mile for

PM10. This value is used to estimate brake wear emissions for all vehicle types.

The emission factors for tire wear generated by the PART5 model are proportional

to the average number of wheels per vehicle. The emission factor is 0.002 grams per mile

per wheel for PM10. EPA calculates separate tire wear emission factors for each vehicle

type. Estimates of the average number of wheels per vehicle by vehicle class were

developed from the Truck Inventory and Use Survey; an average vehicle weight of 3.2
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

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tons was used for this calculation. Tire wear PM emissions were then estimated by

multiplying the VMT by the tire wear emission factor for the appropriate vehicle type.

Construction Activities: The 1999 NEI estimates Gila County construction emissions

to be 343.4 tons/year. Payson area emissions were calculated by multiplying the County

totals by the ratio of population in the area to the population in Gila County; that ratio

is 0.281 (13,660:48,614).

The NEI Procedures document explains that PM10 emissions for construction

activities are calculated from an emission factor, an estimate of the acres of land under

construction, and the average duration of construction activity. The acres of land under

construction are estimated from the dollars spent on construction. The PM10 emission

factor is calculated from the total suspended particulates (TSP) emission factor for

construction (equation 4.8-13) obtained from AP-42 and data on the PM10/TSP ratio for

various construction activities. The PM10 emission factor for construction activities is 1.2

tons/acre/month of activity.

Residential Wood Combustion: The 1999 NEI calculates Gila County residential

wood-burning emissions at 296.1 tons/year. Payson area emissions were calculated by

multiplying the County totals by a ratio of population in the area to population in Gila

County; that ratio is 0.281 (13,660:48,614). The design day emission factor was calculated

using a daily fraction of the annual total, based on a day in December when wood

burning is at its peak. Heating degree days for all twelve months were used to apportion

monthly percentages of overall wood burning activity (a heating degree day is a unit,

based upon temperature difference and time, used in estimating fuel consumption and

specifying nominal heating load of a building in winter. For any one day, when the mean

temperature is less than 65 degrees Fahrenheit, there exists as many degree days as

there are Fahrenheit degrees difference in temperature between the mean

temperature for the day and 65 degrees Fahrenheit). December 1999 had 389 heating

degree days, out of an annual total of 1,679. Using the percentage of heating degree

days in December (23.2 percent), a daily percentage of 0.75 percent of the annual total

emissions was calculated (23.2 percent divided by 31 days).

The NEI Procedures document’s method for estimating residential wood burning

relies on activity factors such as wood use and wood weight, which were derived as

follows: for wood use, the wood burned at the State level was apportioned to the

county level using U.S. Census data on households that use wood as a primary fuel. The

wood weight was based on empirical estimates of one cord of wood taking up 79 cubic
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feet of space and the specific gravity of wood being approximately 0.639. Once the

amount of burned wood was calculated, the emissions were based on EPA criteria

pollutant emission factors (AP-42 methodology) for residential wood combustion,

specifically 34.6 pounds (0.017 tons) of PM10 per ton of wood burned in woodstoves and

fireplaces.

Industrial Sources: Three industrial PM10 sources were identified as operating in the

Payson nonattainment area as of July 2001: Payson Concrete and Materials - (a)

portable concrete batch plant and (b) portable hot mix asphalt plant and (c) Gila

Concrete and Materials - portable concrete batch plant. Two industrial PM10 sources,

contained in the June 1995 Payson SIP and operating in the Payson area on the

December 7, 1990, design day remain closed: (a) Kaibab Industries previously located

at 113 West Main Street, closed and dismantled in June 1993 and (b) Lewis M. Pyle

Memorial Hospital, 807 South Ponderosa, medical waste incinerator was shutdown in

1993. Table IV-2 below compares the industrial sources that were identified as operating

in the Payson area on the December 7, 1990, design day and 2001 industrial sources:

Table IV-2

Industrial Sources - Payson

SIP Industrial Sources

 Moderate PM10 SIP June 1995 2001 Industrial Sources

Applicable

State

Regulations

Comments

Payson Concrete

and Materials,

404 West Aero

Drive

portable concrete

batch plant

n/a n/a April 30, 1993 moved

concrete batch

plant to 1900 East

Highway 260.
SIP Industrial Sources

 Moderate PM10 SIP June 1995 2001 Industrial Sources

Applicable

State

Regulations

Comments

15 R18-2-324 Portable Sources was submitted to EPA on August 15, 1994, as part of a SIP revision

package pertaining to the New Source Review and Prevention of Significant Deterioration Program;

approval is pending.

16R18-2-723 Standards of Performance for Existing Concrete Batch Plants was submitted to EPA

July 15, 1998, as part of the SIP Revision Pertaining to 1993 Rule-Making Comprised of Articles 6,7,&8;

approval is pending.

17R18-2-708 Standards of Performance for Existing Asphalt Concrete Plants was submitted to EPA

on July 15, 1998, as part of the SIP Revision Pertaining to 1993 Rule-Making Comprised of Articles 6, 7, & 8;

approval is pending.

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Payson Concrete

and Materials,

1900 East

Highway 260 

portable concrete

batch plant &

crushing and

screening plant

Payson Concrete

and Materials, 1900

East Highway 260,

Payson, (Moved from

404 W. Aero Drive

4/30/93). Permit #

1001090

portabl

e

concret

e batch

plant

R18-2-32415

R18-2-72316

Facility is still

operating in this

location as of July

2001

Payson Concrete

and Materials, 1900

East Highway 260. 

Permit # 1000796. 

portabl

e hot

mix

asphalt 

R18-2-324

R18-2-70817

Gila Concrete

and Materials,

201 West

Phoenix Street,

Payson, 85541. 

portable concrete

batch plant 

Gila Recycling, Inc. -

Concrete Division,

operating as Gila

Redi-Mix, Inc., 201 W. 

Phoenix St., Payson. 

Permit # 1000454.

portabl

e

concret

e batch

plant

R18-2-324

R18-2-723

Facility is still

operating in original

location as of July

2001

Kaibab

Industries, 113

West Main

Street (south

Payson area)

lumber/sawmill

operation

n/a n/a Original permit #

18007-95. Permit

was terminated per

letter dated

11/16/93. 

Operations halted

and facility

dismantled in June

1993 - location is

retail as of July 2001
SIP Industrial Sources

 Moderate PM10 SIP June 1995 2001 Industrial Sources

Applicable

State

Regulations

Comments

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

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Lewis M. Pyle

Memorial

Hospital, 807

South Ponderosa

medical waste

incinerator

n/a n/a Hospital in

operation. 

Incinerator shutdown

in 1993. Incinerator

removed and permit

terminated 12/3/96. 

Table IV-3 presents the current estimates of PM10 and other criteria air pollutant

emissions for Payson area industrial sources that are still operating.

Table IV-3

Payson Area Industrial Source Emission Estimates

Industrial Sources 1998 or 1999 Emissions Inventory

SIP Industrial Sources PM10 Source Year PM10 NOx VOC SO2

Payson Concrete and Materials portable

concrete batch

plant

1998 0.38

portable hot mix

asphalt 1999 2.19 2.45 2.26 1.83

Gila Recycling, Inc. - Concrete

Division operating as Gila Redi-Mix,

Inc.

portable

concrete batch

plant

1999 0.14
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V. CONTROL MEASURES

A. Reasonably Available Control Measures (RACM)

The Clean Air Act requires that moderate PM10 nonattainment area plans include

provisions to ensure that RACM is implemented no later than 4 years after designation.

The Act further requires that the plan provide for implementation of controls on PM10

sources, within the same time period, reflecting reasonably available control technology

(RACT). RACM and RACT are not required, however, for sources which do not

contribute significantly to violations of the 24-hour or annual PM10 NAAQS, or where

additional controls on the sources would not expedite attainment of the NAAQS. The

Clean Air Act Section 189(e) requires that the RACT provision apply to the gaseous

precursors of PM10 except where EPA determines that such sources do not contribute

significantly to PM10 levels which exceed the standard. 

As discussed above, the exceedances recorded in the Payson area were the

result of primary PM10 emissions associated with paved and unpaved roads, wood

smoke, and industrial sources. Attainment of the PM10 NAAQS was the result of

implemented RACM that reduced PM10 emissions generated from the identified source

categories, the closure of two industrial sources in 1993, and more stringent EPA

standards for woodstoves. Since existing industrial sources contribute less than one

percent to the total 1999 PM10 emission estimates (Table IV-1), the RACT requirement does

not apply to the Payson area either with respect to primary or secondary PM10 emissions.

PM10 emissions from existing industrial sources are regulated under ADEQ’s air permits

program. Air quality permits are in place for existing industrial sources that ensure

adequate control of PM10 emissions and contain PM10 controls such as production or

discharge limits; maintenance and installation of air pollution controls, such as

baghouses, water sprays, enclosures, shrouds, or scrubbers; and use of dust suppressants,

soil stabilizers or wetting agents on haul roads, storage piles, and parking areas.

In response to the PM10 exceedances and nonattainment designation, the

following measures were implemented to control fugitive PM10 emissions:

1. ADOT installed two miles of curbs and gutters on Highway 87 from the

intersection of Highway 87 & 260 to Roundup Road in 1992.
18R18-2-607 Storage Piles was submitted to EPA on January 4, 1979, and subsequently approved by

EPA on April 23, 1982 (47 FR 17485).

Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 32

2. ADOT installed five miles of paved shoulders on Highway 87 North and

Highway 260 East when these stretches were widened to four lanes in

1992.

3. The Town of Payson paved four miles of unpaved roads in the Town of

Payson since 1990.

4. Gila County paved nearly 18 miles of unpaved roads between 1989 and

2000. Specifically, 11.2 miles of Houston Mesa Road and Whispering Pines

were paved between 1989 and 1992; 1.8 miles of Moonlight and Rainbow

Roads were paved in 1994; 0.25 miles of Valley Road was paved in 1994;

2.6 miles of Round Valley Road was paved in 1996; 0.4 miles of East Verde

Park was paved in 1999; and 1.25 miles of Mountain View Road was paved

in 2000.

5. Arizona Administrative Code R18-2-607 that requires control of storage piles

to minimize fugitive emissions (Appendix 2).18

6. In 1988, EPA implemented New Source Performance Standards for

woodstoves. 

The effective implementation of ordinances by the Town of Payson ensures that

the benefits of EPA’s New Source Performance Standards for woodstoves would be

achieved in the area. 

In addition to these RACM controls, the following strategies were also carried out

in the Payson area: The Town of Payson implemented an ordinance requiring the paving

of commercial parking facilities, and requiring paving of unpaved roads as condition of

minor land divisions. In addition, Kaibab Industries’ lumber/sawmill operation closed and

the facility was dismantled in June 1993 and Lewis M. Pyle Memorial Hospital’s medical

waste incinerator was shutdown and removed in 1993. Smoke management plan

requirements were implemented by the Forest Service, Bureau of Land Management,

and Arizona Department of State Lands, in cooperation with ADEQ. These supplemental

strategies contributed still further fugitive dust emission reductions and public health
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

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protection. Continued implementation of the measures will help ensure that the Payson

area maintains the 24-hour and annual PM10 NAAQS. 

B. Permanent and Enforceable Control Measures

The CAA requires that each maintenance plan demonstrate that those measures

that were credited with bringing the area into attainment be federally enforceable and

be continued in the future. Measures 1-4 above meet this requirement because they

are fully constructed and are permanent by their very nature. Measure 5 has previously

been approved by EPA and remains a federally enforceable component of the SIP.

Therefore, the Payson plan meets the CAA requirement for permanent and enforceable

control measures.

C. Contingency Measures

Section 175A of the Act requires that a maintenance plan include contingency

provisions, as necessary to promptly correct any violation of the NAAQS which may

occur after redesignation of the area to attainment. EPA’s memo, Limited Maintenance

Plan Option for Moderate PM10 Nonattainment Areas (Lydia Wegman, August 9, 2001),

states that the contingency measures do not have to be fully adopted at the time of

redesignation, but should identify measures to be promptly adopted, if necessary. The

State commits to seek an expeditious remedy for any violation of the PM10 NAAQS which

may occur after redesignation of the area to attainment. Specifically, the State commits

to determine whether or not violations have been recorded within six months of the

close of the calendar year, and to review and determine appropriate contingency

measure(s) by the end of the same calendar year. The State commits to implement the

selected contingency measure(s) within one year of determining that a violation has

occurred. 

Under the LMP, the State is required to recalculate the average design value for

the area annually and determine if the criteria of 98 Fg/m3 for the 24-hour and 40 Fg/m3

for the annual PM10 NAAQS for the LMP will still be met. If after performing the annual

recalculation, the State determines that the area no longer qualifies for the LMP, the

State commits to take action to attempt to reduce PM10 concentrations enough to

requalify for the LMP.

Table V-1 includes measures that will be considered for implementation in the

event of a violation of either the 24-hour or annual PM10 NAAQS or in the event the

annual recalculation of the area’s average design value exceeds the LMP average
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 34

design value criteria. The cause of the violation or exceedance of the LMP average

design value will help determine the appropriate contingency measure(s) to be

implemented.

Table V-1

Payson Area Contingency Measures

Contingency Measures

Implementing

Entity

Revise Arizona Administrative Code R18-2-702 B opacity limits from 40% to

20%

ADEQ

If any PM10 industrial source operating within the maintenance area is found

to be contributing to monitored readings above the limited maintenance

plan allowable limits, ADEQ will review existing air quality permit(s) to

identify additional PM10 control measures which may be needed. If the PM10

source does not have a permit, the permitting authority will determine if an

air quality permit and PM10 controls are needed.

ADEQ

Review of the requirement for dust control measures for material storage

piles to determine if additional action is needed (Arizona Administrative

Code R-18-2-607).

ADEQ

If wood burning sources are found to be contributing to monitored readings

above the limited maintenance plan allowable limits, ADEQ will review

State regulations and programs to determine appropriate action. 

ADEQ

Pave or stabilize public unpaved roads, vacant lots, or unpaved parking lots

located in the PM10 maintenance area subject to limits of statutory

authority.

Town of Payson

and/or Gila County

Continuation of Smoke Management Plan - state and federal land

managers conducting prescribed burning must register with ADEQ for

proposed burning activities (Arizona Administrative Code R18-2-Article 15 -

Forest & Range Management Burns).

U.S. Forest Service,

U.S. Bureau of Land

Management,

Arizona State Land

Department, ADEQ.

VI. DEMONSTRATION OF MAINTENANCE OF THE STANDARDS

A. Commitment to Calculate PM10 Design Values Annually

The State commits to recalculate the area’s PM10 design values annually to keep

track of the area’s air quality levels. If the levels rise above the limits qualifying the area
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 35

for the LMP, the State will act to lower them. If the action fails, the state will be required

to submit a full maintenance plan.

B. Discussion of Permitting Program to Ensure that New Sources Will Not

 Jeopardize Continued Maintenance

Arizona Administrative Code (AAC) R18-2-403 (Permits for Sources Located in

Nonattainment Areas) applies to new major sources or major modifications to sources

located in nonattainment areas. Following redesignation, AAC R18-2-406 (Permit

Requirements for Sources Located in Attainment and Unclassifiable Areas) will apply for

any major source or major modification to a source located within the maintenance

area. 

C. CAA Section 175(A) Maintenance Plans

ADEQ commits to submit a maintenance plan for the second ten year period

(2011-2021) by 2009.

VII. OTHER REQUIREMENTS FOR MODERATE AREA AND MAINTENANCE PLANS

A. CAA Section 110(a)(2)

Section 110(a)(2)(A) of the CAA requires that States provide for enforceable

emission limitations and other control measures, means, or techniques, as well as

schedules for compliance. Section V includes a list of control measures that help the

Payson area reach and maintain attainment of the NAAQS. 

Section 110(a)(2)(B) of the CAA requires that States provide for establishment and

operation of appropriate devices, methods, systems, and procedures necessary to

monitor, compile, and analyze data on ambient air quality. Under ADEQ’s air quality

assessment program, ambient monitoring networks for air quality are established to

sample pollution in a variety of representative settings, to assess the health and welfare

impacts and to assist in determining air pollution sources. These networks cover both

urban and rural areas of the State. The monitoring sites are combined into networks,

operated by a number of government agencies and regulated companies. Each

network is comprised of one or more monitoring sites, whose data are compared to the

NAAQS, as well as being statistically analyzed in a variety of ways. The agency or
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 36

company operating a monitoring network also tracks data recovery, quality control, and

quality assurance parameters for the instruments operated at their various sites. The

agency or company often also measures meteorological variables at the monitoring site.

Section III includes monitoring network information and data for the Payson area.

The collected data are summarized into the appropriate quarterly or annual

averages. The samplers are certified as Federal Reference or Equivalent Methods.

Regular checks of the stability, reproducibility, precision, and accuracy of the samplers

and laboratory procedures are conducted by either the agency or company network

operators. The protocol for PM10 monitoring used by the State, local agencies, and

companies was established by EPA in the following sections of the Code of Federal

Regulations (CFR):

! 40 CFR Part 50, Appendix J, Reference Method for the Determination of

Particulate Matter as PM10 in the Atmosphere

! 40 CFR Part 50, Appendix K, Interpretation of the National Ambient Air

Quality Standards for Particulate Matter

! 40 CFR Part 58, Appendix A, Quality Assurance Requirements for SLAMS

– Section 2, Quality System Requirements

– Section 3.3 and 3.4.1, Data Quality Assessment Requirements

– Section 4.2, Annual Reports

– Section 5.3, Precision of Manual Methods Excluding PM2.5

– Section 5.4, Accuracy of Manual Methods Excluding PM2.5

– 40 CFR Part 58, Appendix D, Section 2.8, Particulate Matter Design

 Criteria for SLAMS

– 40 CFR Part 58, Appendix E, Probe and Monitoring Path Siting Criteria for

 Ambient Air Quality Monitoring, Section 8, Particulate Matter (PM10 and

 PM2.5)

Section 110 (a)(2)(C), Section 110 (a)(2)(E), Section 110 (a)(2)(F), and Section 110

(a)(2)(L) of the CAA require States to have permitting, compliance, and source reporting

authority, as well as adequate resources and funding. The following portions of Arizona

Revised Statutes (ARS) indicate compliance with the CAA requirements: ARS § 49-402,

§ 49-404, and § 49-406 establish ADEQ’s permitting and enforcement authority, as well as

ADEQ’s responsibility and authority for development of nonattainment and maintenance

area plans. As authorized under ARS § 49-402, ADEQ retains adequate funding and

employs adequate personnel to administer the air quality program. Appendix 3 includes

organization charts for ADEQ’s Air Quality Division.
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 37

Under ADEQ’s air permits program, sources (e.g., businesses, utilities, government

agencies, and universities) that emit significant amounts of regulated air pollutants are

required to obtain a permit before constructing, modifying, replacing, or operating any

equipment or process which may cause air pollution. Existing sources are also required

to obtain a revision or modification to their permit before transferring ownership,

relocating, or otherwise significantly changing the method of their operation.

Additionally, ADEQ is responsible for assessing fees based on the actual emissions

submitted in the emission inventory for major sources under ADEQ jurisdiction pursuant

to Arizona Administrative Code (AAC) R18-2-326.

State regulations (AAC R18-2-327) require that any source subject to a permit must

complete and submit to the director an annual emissions inventory questionnaire. A

current air pollutant emissions inventory of both permitted and non permitted sources

within the State is necessary to properly evaluate air quality program effectiveness.

ADEQ is responsible for the preparation and submittal of an emissions inventory report

to the EPA for major sources and emission points prescribed in 40 CFR 51.322 and for

sources that require a permit under ARS 49-426 for criteria pollutants. 

Under ADEQ’s air quality compliance program, major sources are inspected

annually, while minor sources are inspected every two to three years. However, minor

sources may be the subject of various initiatives during the year. If a particular sector

(e.g., dry cleaners, portable sources) has evidenced problems in the prior year (e.g.,

failure to submit move notices by portable sources), ADEQ’s Air Compliance Section

implements initiatives to address the problem (e.g., seminars and workshops for the

regulated community explaining the general permit requirements; individual inspections

of all portable sources within a geographical area, mailings, etc.). In addition,

compliance initiatives are developed to address upcoming or future requirements (e.g.,

new general permits) and include such actions as training for inspectors; development

of checklists and other inspection tools for inspectors; public education workshops;

targeted inspections; mailings, etc. ADEQ’s Air Compliance Section also has an internal

performance measure to respond to all complaints as soon as possible, but no later than

within five working days.

Section 110(a)(2)(G) of the CAA requires that States provide for authority to

establish emergency powers and authority and contingency measures to prevent

imminent endangerment. AAC R18-2-220 prescribes the procedures the Director of

ADEQ shall implement in order to prevent the occurrence of ambient air pollution

concentrations which would cause significant harm to the public health. As authorized
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 38

by ARS § 49-426.07, ADEQ may seek injunctive relief upon receipt of evidence that a

source or combination of sources is presenting an imminent and substantial

endangerment to public health or the environment. 

B. CAA Section 172(c)

Section 172(c) of the CAA requires that nonattainment plan provisions comply with

each of the following:

Section 172(c)(1) of the CAA requires that nonattainment plan provisions provide

for the implementation of all reasonably available control measures (RACM) as

expeditiously as practicable and attainment of the national primary ambient air quality

standards. Section V includes a description of RACM implemented in the Payson area

to control PM10 emissions.

Section 172(c)(3) and Section 172(c)(4) of the CAA requires a current inventories

of actual emissions from all sources of relevant pollutant or pollutants and projected

emission inventories. The 1999 base-year emission estimates are contained in Section IV.

By qualifying for the LMP option, the requirements for projecting emissions inventories is

waived.

Section 172(c)(5) of the CAA require permits for the construction and operation

of new or modified major stationary sources. All new sources and modifications to

existing sources in Arizona are subject to State requirements for preconstruction review

and permitting pursuant to AAC, Title 18, Chapter 2, Article 1, 3, 4, 5, 6, 7, and 9. All new

major sources and modifications to existing major sources in Arizona are subject to the

New Source Review (NSR) provisions of these rules, including Nonattainment Area

Analysis (NAA) and Prevention of Significant Deterioration (PSD). The State NSR program

was conditionally approved by EPA in 1982, and has been revised and is pending

approval from EPA. 
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 39

REFERENCES 

1987 Census of Transportation: Truck Inventory and Use Survey - United States, TC87-T-52,

U.S. Department of Commerce, Bureau of the Census, August 1990.

EPA, 1987: U.S. Environmental Protection Agency, Guideline on Exceptions to Data

Requirements for Determining Attainment of Particulate Matter Standards, EPA450/4-87-005, Office of Air Quality Planning and Standards, Research Triangle Park,

NC, April 1987.

EPA, 2001: U.S. Environmental Protection Agency, Procedures Document for National

Emission Inventory Criteria Air Pollutants, 1985-1999, EPA-454/R-01-006, Office of

Air Quality Planning and Standards, Research Triangle Park, NC, 2001.

1999 National Emissions Inventory data base,

ftp://ftp:epa.gov/pub/EmisInventory/net99//

U.S. Department of Transportation, Federal Highway Administration, Highway Statistics

1999, http://www.fhwa.dot.gov/ohim/ohimstat.htm

EPA, 1995: U.S. Environmental Protection Agency, Draft User’s Guide to PART5: A

Program for Calculating Particle Emissions from Motor Vehicles, EPA-AA-AQAB94-2, Ann Arbor, MI, February 1995.

EPA, 1999: U.S. Environmental Protection Agency, Office of Air Quality Planning

Standards,Estimating Particulate Matter Emissions from Construction Operations,

prepared by Midwest Research Institute, Research Triangle Park, NC, September

1999.

EPA, 2000a: U.S. Environmental Protection Agency, National Air Pollutant Emission

Trends, 1900-1998, EPA-454-R-00-002, Office of Air Quality Planning and Standards,

Research Triangle Park, NC, March 2000.

EPA, 2000b: U.S. Environmental Protection Agency, Draft NONROAD Model Release,

http://www.epa.gov/oms/nonrdmdl.htm, June 2000.
Payson Moderate Area PM10 Maintenance Plan March 15, 2002

and Request for Redesignation to Attainment 40

MRI, 1988: Midwest Research Institute, Control of Open Fugitive Dust Sources, Kansas

City, MO, prepared for U.S. Environmental Protection Agency, Research Triangle

Park, NC, September 1988.
APPENDIX 1

 Applicable EPA Guidance Documents

Procedures for Processing Requests to Redesignate Areas to Attainment, John

Calcagni, Director, Air Quality Management Division, memorandum dated September

4, 1992.

Limited Maintenance Plan Option for Moderate PM10 Nonattainment Areas, Lydia

Wegman, Director, AQSSD (MD-15), memorandum dated August 9, 2001.
APPENDIX 2

Applicable Arizona Administrative Code

R18-2-324 Portable Sources

R18-2-607 Storage Piles

R18-2-723 Standards of Performance for Existing Concrete Batch Plants

R18-2-708 Standards of Performance for Existing Asphalt Concrete Plants
APPENDIX 3

 ADEQ Air Quality Division 

Organization Chart
APPENDIX 4

 Public Hearing Documentation
Appendix 4.A.

Public Notice Proof of Publication
Appendix 4.B.

Public Hearing Agenda
Appendix 4.C.

Public Hearing Presiding Officer Certification
Appendix 4.D.

Public Hearing Transcripts
Appendix 4.E.

Responsiveness Summary
Jane Dee Hull

Governor

ARIZONA DEPARTMENT

OF

ENVIRONMENTAL QUALITY

3033 North Central Avenue • Phoenix, Arizona 85012-2809

 (602) 207-2300 • www.adeq.state.az.us

Jacqueline E. Schafer

Director

Northern Regional Office Southern Regional Office

1515 East Cedar Avenue • Suite F • Flagstaff, AZ 86004 400 West Congress Street • Suite 433 • Tucson, AZ 85701

(928) 779-0313 (520) 628-6733

Printed on recycled paper

March 28, 2002

RESPONSIVENESS SUMMARY

to

Testimony Taken at Public Hearing and Written Comments Received on 

The Payson Moderate Area PM10 Maintenance Plan and

Request for Redesignation to Attainment

The public hearing on the Payson Moderate Area PM10 Maintenance Plan and Request for Redesignation

to Attainment, was held at 4:00 p.m., Tuesday, February 19, 2002, Payson Town Hall Council Chambers,

303 North Beeline Highway, Payson, Arizona. No oral comments were received during the hearing. The

Arizona Department of Environmental Quality (ADEQ) received written comments from two individuals

during the public comment period, which ended February 20, 2002. The public comments and ADEQ’s

responses are described below.

Comment #1: 

One commenter suggested that paving the dirt portion of Easy Street between Zurich Drive and Malibu

Drive and the dirt portion of Evergreen Street east of Easy Street would improve the air quality in Payson.

Response:

It is a general fact that paving unpaved roads does result in reduced particulate matter. However, several

factors, including feasibility, economics, and legal issues, must be considered in such decisions.

Municipalities are responsible for public road maintenance and road improvement activities within their

statutory authority. According to Town of Payson staff, the road sections noted are utility easements

located on private property and are not public roads. Municipalities are not permitted to expend public

funds for improvements to private roads. These roads would be required to be improved, in accordance

with the Town of Payson zoning requirements, as the property is developed by the owner. Questions and

comments regarding road maintenance and road improvements in Payson should be directed to the Town

of Payson, Public Works, 303 N. Beeline Highway, Payson, AZ 85541 or by calling (928) 757-0910 ext.

283. 

Comment #2:
March 28, 2002

Page 2

the One commenter stated that the prevailing winds are from the southwest and the only monitor referred

to in the Plan is located on the west side of Highway 87 and therefore, air quality is being blown away from

the monitor and is not being accurately measured. The commenter further stated that readings from the

monitor location do not reflect factual pollution data for area and this gives a false impression of good air

quality and to claim that air quality for the whole town is being monitored with one monitor located where

the prevailing wind direction blows pollution away from the monitor is an insult to the public intelligence.

Response:

The current ADEQ PM10 monitoring site in Payson is located at 204 E. Aero Drive and was placed there

in accordance with EPA siting guidelines. The site is situated in the lower portion of a valley. Wind data

collected at the monitoring site show that generally winds flow from the southwest during daylight hours and

from the northeast during the nighttime hours. The area sometimes experiences wintertime temperature

inversions which can trap pollutants in the valley and lead to higher pollutant levels. Because of these

conditions, ADEQ considers the monitor to be the best overall site to gauge average to high PM10 levels

in the nonattainment area.

Comment #3: 

One commenter stated there are approximately 8.5 miles of unpaved roads in Payson generating in some

cases extremely severe fugitive dust in residential areas. The commenter also stated that ADEQ has a

requirement that these roads be, at least, chemically stabilized to alleviate the problem. But the Town of

Payson has declared the roads to be unadoptable orphans and with the blessings of ADEQ, has made it

appear that they don’t exist in the pollution picture. 

Response: 

Approximately 2 miles of unpaved public roads and 6.5 miles of unpaved private roads exist within the

Town of Payson. Although annual application of chemical dust palliatives (magnesium chloride) to public

unpaved roads was identified in the 1995 PM10 State Implementation Plan for the Payson

Nonattainment Area as a measure to improve air quality, it was not identified as a committed measure,

nor relied upon to reach attainment (See page 22 of this Plan for the attainment measures). Municipalities

are responsible for public road maintenance and road improvement activities within their statutory authority,

but may not expend public funds for improvements to private roads. The Town of Payson is considering

future periodic application of a less expensive dust suppressant to public unpaved roads. 

Comment #4:

One commenter stated that Payson has really done nothing to improve the air quality of the past 20 years

except pass a wood stove ordinance. They do claim to have paved 4 miles of dirt roads in 10 years. They

are being given credit for things that have nothing to do with the real problem. Their attention to the

prevention of more dirt roads has nothing to do with the long existing problem. 

Response:
March 28, 2002

Page 3

The exceedances recorded in the Payson area during 1989 and 1990 were determined to be the result of

PM10 emissions associated with paved and unpaved roads, wood smoke, and industrial sources.

Attainment of the PM10 national ambient air quality standards was the result of a number of different

controls implemented to reduce PM10 emissions from these source categories. The controls were

implemented by a number of different agencies including the Town of Payson, Gila County, Arizona

Department of Environmental Quality, Arizona Department of Transportation, and the U.S. Environmental

Protection Agency. Controls implemented are identified on page 22-23 of this Plan and include the

following:

• Installation of curbs and gutters on Highway 87. This reduces the amount of PM10 generated from

vehicles driving on unpaved areas adjacent to the road and prevents erosion from stormwater from

washing onto streets and then being resuspended into the air from passing vehicles.

• Paving shoulders on Highway 87 North and Highway 260 East. This reduces the amount of PM10

generated from vehicles driving on unpaved areas adjacent to the road.

• Requiring control of storage piles to minimize fugitive emissions. This requires that reasonable

precautions be taken to prevent excessive amounts of particulate matter from becoming airborne.

• Paving by the Town of Payson and Gila County of nearly 22 miles of unpaved roads within the

nonattainment area.

• Closure of two industrial sources: Kaibab Industries’ lumber/sawmill and Lewis M. Pyle Memorial

Hospital’s medical waste incinerator.

• Implementation of EPA’s new source performance standard for woodstoves. Nationally, EPA has

established PM10 emission limits for new woodstoves and fireplace inserts. All woodstoves

manufactured on or after July 1, 1990, or sold on or after July 1, 1992, must meet stringent Phase

II emission limits. 

• Implementation of ordinances prohibiting any installation of non-Phase II woodstoves or

woodstove inserts within the Town of Payson; requiring a permit and inspection for installation;

prohibiting the sale of used wood stoves (non-Phase II) for use within the Town of Payson; and

prohibiting the use of woodstoves as the sole source of heat in residences.

• Implementation of ordinances requiring paving of commercial parking facilities and paving of roads

as a condition of minor land divisions. 

• Implementation of a smoke management plan which requires state and federal land managers

conducting prescribed burning to register proposed burning activities with ADEQ.

Comment #5

One commenter stated that Phoenix is being forced to pave their dirt roads to improve air quality, but

Payson’s don’t count.

Response

The Clean Air Act requires States to develop and submit to EPA a state implementation plan (SIP)

providing for the attainment of the PM10 NAAQS for every area designated nonattainment for PM10.

Nonattainment areas are classified based on the severity of the air quality problem. For example, the
March 28, 2002

Page 4

Payson area is classified a “moderate” PM10 nonattainment area while the Phoenix area is classified as a

“serious” PM10 nonattainment area. SIPs need to contain control measures designed to reduce PM10

emissions from the specific source categories identified as contributing to PM10 in the area. The type and

level of control required for an area is determined by the different source categories identified for the area

and by the area’s nonattainment classification (moderate, serious, severe). Moderate areas are required

to implement reasonably available control measures (RACM). RACM are available control measures for

significant sources that are reasonable, considering their technological and economic feasibility in the area

to which the SIP applies. Serious areas are required to implement best available control measures

(BACM) for significant sources. BACM is defined to be, among other things, the maximum degree of

emission reduction achievable from a source or source category that is determine on a case by case basis

considering energy, economic and environmental impacts. As part of the SIP for the Maricopa County

PM10 nonattainment area, the City of Phoenix did commit to pave unpaved roads; however, their

commitment was limited to paving only unpaved public roads which totals approximately 80 miles. Because

the Payson and Phoenix areas vary by many factors, including the severity of the air quality, the

nonattainment classification, and the specific source categories identified as contributing to PM10 in the area,

the control strategies required for the area to reach attainment may be different. 

Edits to Final Plan:

ADEQ determined that some minor formatting and grammatical revisions were appropriate to the final Plan.

In addition, the following clarifications were made:

• Page 2, added “expected” to the following sentence to correct the definition of attainment:

Attainment of the annual PM10 standard is achieved when the expected annual arithmetic

mean PM10 concentration over a three year period is equal to or less than 50 Fg/m3.

• Page 2, revised the following sentence to address EPA’s February 15, 2002, determination that

the Payson area did attain the 24-hour and annual PM10 NAAQS: As a result, on July 25, 2001

February 15, 2002, EPA proposed to determined that the Payson PM10 nonattainment area

did attain the 24-hour and annual PM10 NAAQS by December 31, 2000 (66 FR 38605) (67

FR 7082).

• Page 3, added “(see Figure II-1)” to the following sentence: The Payson nonattainment

area is defined by the following townships (see Figure II-1):

• Page 8, revised the following sentence to address EPA’s February 15, 2002, determination that

the Payson area did attain the 24-hour and annual PM10 NAAQS: On July 25, 2001 February

15, 2002, EPA proposed to determined that the Payson PM10 nonattainment area has

attained the 24-hour and annual PM10 NAAQS by December 31, 2000 (66 FR 38605)(67 FR

7082).
March 28, 2002

Page 5

• Figure III-1, the maximum 24-hour PM10 concentration for Payson for 1995 was revised using

the1995 ADEQ air quality monitoring lab final data spreadsheet. An analysis of the 1995 annual

report data and the monitoring lab data spreadsheet indicated that the annual report data and the

monitoring lab final data spreadsheet differed. ADEQ felt that it was more accurate to use the

monitoring lab report data.

• Figure III-2, the annual average PM10 concentration for Payson for 1995 was revised using the

1995 ADEQ air quality monitoring lab final data spreadsheet. An analysis of the 1995 annual

report data and the monitoring lab data spreadsheet indicated that the annual report data and the

monitoring lab final data spreadsheet differed. ADEQ felt that it was more accurate to use the

monitoring lab report data.

• Figure IV-2, revised as follows: the 1990 “miscellaneous” emissions contained in the 1990

emissions inventory were primarily emissions from construction activities. In order to more

accurately compare the 1990 and 1999 construction emissions, the 1990 “miscellaneous”

emissions are included under the “construction” source category. 

• Table V-1, replaced “design value” with “allowable limit” in the following sentence: If any PM10

industrial source operating within the maintenance area is found to be

contributing to monitored readings above the limited maintenance plan

design value allowable limits, ADEQ will review existing air quality permit(s)

to identify additional PM10 control measures which may be needed. If the

PM10 source does not have a permit, the permitting authority will

determine if an air quality permit and PM10 controls are needed.

• Table V-1, replaced “design value” with “allowable limit” in the following sentence: If wood

burning sources are found to be contributing to monitored readings above the limited

maintenance plan design value allowable limits, ADEQ will review State regulations and

programs to determine appropriate action. 

• Page 20, revised footnote number 15, 16, and 17, to clarify the status of EPA’s approval of

Arizona Administrative Code (AAC) R18-2-324 Portable Sources, AAC R18-2-723 Standards

of Performance for Existing Concrete Batch Plants, and AAC R18-2-708 Standards of

Performance for Existing Asphalt Concrete Plants.

• Page 22, added footnote number 18 to clarify the status of EPA’s approval of AAC R18-2-607

Storage Piles.

• Page 22, added the following sentence to clarify why reasonably available control technology

(RACT) provisions are not required for existing industrial sources in the Payson area. Since
March 28, 2002

Page 6

6

existing industrial sources contribute less than one percent to the total 1999 PM10 emission

estimates (Table IV-1), the RACT requirement does not apply to the Payson area either with

respect to primary or secondary PM10 emissions.

• Page 22, revised control measure number 1 to clarify that the Arizona Department of

Transportation (ADOT), not the Town of Payson, had installed two miles of curbs and gutters on

Highway 87 North from the intersection of Highway 87 & 260 to Roundup Road in 1992.

• Page 23, deleted “unpaved” from the following sentence to clarify the ordinance: The Town of

Payson implemented an ordinance requiring the paving of unpaved commercial parking facilities....