17.001 

### Department of Environmental Conservation

OFFICE OF THE COMMISSIONER

Post Office Box 111800 410 Willoughby Avenue, Suite 303 Juneau, Alaska 99811-1800 Main: 907.465.5066

Fax: 907.465.5070 www.dec.alaska.gov

January 6, 2016

Mr. Dennis McLerran, U.S. EPA Region 10 Regional Administrator’s Office, Mail Code: RA-210 1200 Sixth Avenue, Suite 900 Seattle, WA 98101

Dear Mr. McLerran:

The Alaska Department of Environmental Conservation (DEC) in accordance with the Clean Air Act (CAA) 189(c)(2) and 40 CFR 51.1013 (b) is submitting the enclosed Qualitative Milestone Report for the Fairbanks North St ar Borough’s (FNSB) PM2.5 nonattainment area. The Moderate Area State Implementation Plan (SIP) for the FNSB PM2.5 nonattainment area identified specific milestones to be reached in 2017. The enclosed report verifies that the 2017 milestones have been met.

Denise Koch is available to respond to any questions your staff might have or provide any additional information they might need. She can be reached at (907) 4 65-5109. As always, I would be pleased to discuss any of this with you.

Sincerely,

Larry Hartig Commissioner

Enclosure

cc via email:

Tim Hamlin, EPA Region 10 (w/o enclosures) Debra Suzuki, EPA Region 10 (w/o enclosures) Claudia Vaupel, EPA Region 10 (w/o enclosures) Alice Edwards, Deputy Commissioner, DEC (w/o enclosures) Denise Koch, Director, Division of Air Quality (w/o enclosures) Cynthia Heil, Program Manager, AN PMS Program, DEC (w/o enclosures)

## ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

Fairbanks North Star Borough PM2.5 Moderate Area State Implementation Plan

Quantitative Milestone Report

January 6, 2017

Bill Walker, Governor

Larry Hartig, Commissioner-i

### Fairbanks 2017 Quantitative Milestone Report

Table of Contents Page

1. SUMMARY ................................................................................................................ 1 1.1 Introduction ........................................................................................................ 1 1.2 RFP Findings ...................................................................................................... 2 1.3 Organization of the Report ................................................................................. 6

2. SIP CONTROL STRATEGY CERTIFICATION ...................................................... 7

3. SUPPORTING CALCULATIONS ............................................................................ 8 3.1 Control Measure Benefit Calculations ............................................................... 8 3.2 Summary of Emission Reductions ................................................................... 15

4. ATTAINMENT FINDINGS ..................................................................................... 17-iiList of Figures

Figure Page

Figure 1-1 Quantitative Milestone Analysis for PM 2.5 ..................................................... 4

Figure 1-2 Quantitative Milestone Analysis for SO 2 ........................................................ 5

Figure 1-3 Quantitative Mile stone Analysis for NOx....................................................... 5

Figure 1-4 Quantitative Milestone Analysis for NH 3 ....................................................... 6-iiiList of Tables

Table Page

Table 1-1 SIP Control Measures ....................................................................................... 2

Table 1-2 Control Measures Analyzed in QM Report ...................................................... 3

Table 3-1 Curtailment Program Alert Condi tions and Frequencies of Occurrence ........ 13

Table 3-2 Alert Stage Curtailmen t Program Emission Reductions (20% Compliance) ................................................................................................................ 14

Table 3-3 Curtailment Program Aver age Daily Emission Reductions (20% Compliance) ................................................................................................................ 14

Table 3-4 Summary of 2015 & 2016 Cont rol Measure Emission Reductions ............... 15

Table 3-5 Summary of 2015 & 2016 Cont rol Measure Emission Reductions ............... 161 

### 1. SUMMARY

1.1 Introduction

A portion of the Fairbanks North Star Bor ough (FNSB) that includes the cities of Fairbanks and North Pole as well as su rrounding areas was designated as a National Ambient Air Quality Standard (NAAQS) fine particulate matter (PM 2.5 ) Moderate nonattainment area for violation of the 24-hour average standard enacted in 2006. In December 2014, the Alaska Department of Environmental Conservation (DEC) submitted a State Implementation Plan (SIP) for the Fairbanks Moderate PM 2.5 area.

The key finding of that Plan (subsequently re ferred to as the Moderate SIP) was that attainment of the PM 2.5 NAAQS by the December 31, 2015 target date was impracticable * in accordance with the Clean Air Act (CAA).

Section 172(c)(2) of the CAA requires that plans for non-attainment areas “shall require reasonable further progress” (RFP) and include a “current inventory of actual emissions from all sources of relevant pollutants in such area ... to assure that the requirements of this part are met.” The goal of RFP is to achieve generally linear progress toward attainment (as opposed to deferring implementation of some or all measures until projected attainment date). The Moderate SIP included a RFP demonstration that established quantitative milestones to be achieved no later than 7.5 years from the date of designation (December 2009). As required under 40 CFR § 51.1013 the first milestone date is calendar year 2017.

Moderate SIP RFP Demonstration – The Moderate SIP evaluated linear progress toward attainment beyond 2015 associated with implementation of Reasonably Available Control Measures (RACM) and Reasonably Available Control T echnologies (RACT). The analysis determined whether forecasted controls (and their be nefits) in 2017 would be sufficient to assess linear progress from 2015 to projected attainment in 2019.

To address this requirement, 2015 and 2019 SIP Control inventories were interpolated to 2017 to establish target emission levels repr esenting a linear trajectory between the Moderate Area attainment deadline (2015) and the forecasted attainment year (2019).

Chapter 5.7 of the Moderate SIP provided a detailed discussion of RACM measures for Fairbanks. (All RACT measures have been implemented in Fairbanks.) Many of the RACM measures identified in Chapter 5.7 are either voluntary or were implemented prior to 2015. Thus, the remaining measures examined for RFP were measures slated for

* CAA Part D, subpart 4, Section 189(a)(1)(B)2 implementation or phase-in after 2015 and corr espond to the list of measures for which quantitative emission benefits were calcul ated and incorporated into the Control inventories. The entire set of control m easures/programs is summarized below in Table 1-1, along with their re spective implementation dates (or ranges).

Table 1-1 SIP Control Measures

Control Measure Implementation Date(s) Voluntary Measures - Mobile Sources - Other Sources 2001-2015

Hydronic Heater Retrofits 2012 Woodstove Change Out Program 06/2010
State Wood Device Standards 2015 Dry Wood Measures - State Moisture Disclosure - State/Borough Dry Wood Programs 02/2015

Borough Mandatory Curtailment Program 03/2015 Energy Efficiency Measures 2008 Other, pre-2015 Requirements (18 AAC and Borough Code, Title 21): - Opacity Limit - Open Burning 2/2015

Other, post-2015 (setbacks, 2 nd conviction, no waivers for new buildings) 2015-2016
Motor Vehicle/Wood Device Turnover n/a n/a – not applicable

ln light of the emission benefits of new measures adopted since the submittal of the Moderate SIP, Alaska has determined that it is appropriate to submit a Quantitative Milestone (QM) report at this time whic h examines RFP progress in 2017 based on current conditions and control measure implem entation and compliance that has occurred since the December 2014 Moderate SIP submittal. As a result, this QM report reflects an updated analysis of implemented control m easure benefits as of the end of 2016 and demonstrates that the milestones, “to be achieved no later than 3 years after December 31, 2014” have been met.



### 1.2 RFP Findings

Measures and Pollutants Addressed - Tabl e 1-2 summarizes the individual control measures for which emission benefits we re estimated in this QM report.3 Table 1-2 Control Measures Analyzed in QM Report

Control Measure 2017 Benefits? Pollutants for Which Benefits Calculated Voluntary Measures - Mobile Sources - Other Sources No n/a

Hydronic Heater Retrofits No n/a Woodstove Change Out Program Yes PM 2.5 , SO 2 , NOx, NH 3 State Wood Device Standards Yes PM 2.5 , SO 2 , NOx, NH 3 Dry Wood Measures - State Moisture Disclosure - State/Borough Dry Wood Programs Yes PM 2.5 , SO 2 , NOx, NH 3

Borough Mandatory Curtailment Program Yes PM 2.5 , SO 2 Energy Efficiency Measures No n/a Other, pre-2015 Requirements (18 AAC and Borough Code, Title 21): - Opacity Limit - Open Burning No n/a

Other, post-2015 (setbacks, 2 nd conviction, no waivers for new buildings) No n/a

Motor Vehicle/Wood Device Turnover PB PB n/a – not applicable PB – Turnover benefits reflected in projected 2017 baseline inventory

Those measures marked “Yes” are those th at were adopted after the December 2014 Moderate SIP submittal or provide additiona l incremental reductions in 2015 or 2016. This RFP analysis examined episodic emissions of directly emitted PM 2.5 as well as precursor pollutants: sulfur dioxide (SO 2 ), nitrogen oxides (NOx) and ammonia (NH 3 ). As noted in the rightmost column of Table 1-2, individual benefits were calculated for each pollutant, except NOx and NH 3 benefits for the curtailm ent program. (As discussed later, although there are bene fits for these pollutants, they were not needed to demonstrate that milestone targets were met.)

Quantitative Milestone Analysis – In a similar format to that presented in the Moderate SIP (for ease in comparison), Figure 1-1 presen ts the quantitative m ilestone analysis for directly emitted PM 2.5 . The vertical bars labeled “2015 Ctl” and “2019 Ctl” represent the 2015 and 2019 Control inventories from the SI P. The 2015 Control inventory reflects benefits for control measures quantified in th e SIP that were implemented prior to 2015. The 2019 Control inventory represents that fo r which attainment wa s modeled in the SIP by calendar year 2019. (Emission contributions from each source sector are shown for each inventory bar.) The middle bar, “2017 R FP” represents the linearly-interpolated 2017 quantitative milestone target from th e 2015 and 2019 Control inventories. Projected 2017 emissions below this milest one target reflect a demonstration of4 reasonable further progress toward attainme nt. (Projected 2017 emissions above the target would indicate that R FP is not being met.) The “2017 Ctl” bar represents projected 2017 emissions that reflect additional emission reductions from adopted and implemented control measures beyond the required 2015 atta inment year for the Moderate SIP. As shown in Figure 1-1, total direct PM 2.5 emissions within the nonattainment area were estimated to be 3.96 tons per day, meeting the 2017 target. Thus, reasonable further progress is demonstrated for PM 2.5

. Figure 1-1 Quantitative Milestone Analysis for PM 2.5

0.03 0.02 0.02 0.02 0.46 0.43 0.43 0.41 0.06 0.07 0.07 0.07 1.41 1.41 1.41 1.41 2.44 2.02 2.02 1.61

0.0 0.5 1.0 1.5 2.0 2.5 3.0 3.5 4.0 4.5 5.0

2015 Ctl 2017 Ctl 2017 RFP 2019 CtlPM2.5Emissions(tons/day)

Inventory Area, Space Heat

Point (Actual)

Area, Other

On

‐ Road

Non

‐ Road 4.40
3.96 3.52 3.96

Figure 1-2 through Figure 1-4 present similar plots of reasonable further progress for precursor pollutant emissions of SO 2 , NOx and NH 3 , respectively. For each pollutant, 2017 Control emissions are expected to be belo w the applicable milestone targets as seen in Figure 1-2 through Figure 1-4. For SO 2 (Figure 1-2) and NH 3 (Figure 1-4), the RFP slope is positive, representing slight increases in emissions. These upward trends for the two precursor pollutants are the result of contro l strategies in the 2019 attainment demonstration that in part reflect switchi ng from wood to other heating fuels that are much lower in direct PM 2.5 emissions, but result in nomi nal increases emissions from these precursors. (In Figure 1- 2, the contribution for on-road SO 2 emissions is less than 0.02 tpd for all inventories and is too small to be displayed.)

(Section 3 of this report disc usses the calculation of the 2017 Control emissions in detail and includes detailed breakdow ns of the emission benefits for each of the measures analyzed in the report.)5 Figure 1-2 Quantitative Milestone Analysis for SO 2

0.08 0.09 0.09 0.09 8.17 8.17 8.17 8.17 4.32 4.32 4.76 5.19

0 2 4 6 8 10 12 14 16

2015 Ctl 2017 Ctl 2017 RFP 2019 CtlSO2Emissions(tons/day)

Inventory Area, Space Heat

Area, Other

Point (Actual)

On

‐ Road

Non

‐ Road 12.58 13.47 12.59 13.03

Note: 2015 Control inventory SO 2 emissions were incorrectly reported as 12.53 tons/day in Figure 5-6.28 of the SIP.

Figure 1-3 Quantitative Milestone Analysis for NOx

1.06 1.08 1.08 1.09 2.50 2.19 2.19 1.87 13.28 13.28 13.28 13.28 2.38 2.40 2.42 2.46

0 5 10 15 20 25

2015 Ctl 2017 Ctl 2017 RFP 2019 CtlNOxEmissions(tons/day)

Inventory Area, Space Heat

Area, Other

Point (Actual)

On

‐ Road

Non

‐ Road 19.23 18.71 18.96 18.976 Figure 1-4 Quantitative Milestone Analysis for NH 3

0.003 0.003 0.003 0.003 0.051 0.050 0.050 0.048 0.000 0.000 0.000 0.000 0.125 0.117 0.148 0.171

0.00 0.05 0.10 0.15 0.20 0.25

2015 Ctl 2017 Ctl 2017 RFP 2019 CtlNH3Emissions(tons/day)

Inventory Area, Space Heat

Area, Other

Point (Actual)

On

‐ Road

Non

‐ Road 0.179 0.222

0.169 0.200

Note: NH 3 emissions data was not available for point sources at the time of preparation of the Moderate SIP inventory. Thus, point source contributions for NH 3 appear as zero.



### 1.3 Organization of the Report

Following this summary section, the remainde r of the report is organized in a manner consistent with the quantitative milestone requirements listed in 40 CFR § 51.1013(4)(b).

Section 2 contains a certification by the Governor or Governor's designee that the SIP control strategy is being implemented consiste nt with the RFP plan. Section 3 describes supporting technical calculations sufficient to document and demonstrate that the quantitative milestones have been satisfie d. It also describes how the emissions reductions achieved to date compare to those re quired or scheduled to meet RFP. Section 4 provides a discussion of whether th e area will attain the applicable PM 2.5 NAAQS by the projected attainment date for the area.

###### 7 2. SIP CONTROL STRATEGY CERTIFICATION8 

### 3. SUPPORTING CALCULATIONS

This section of the QM report provides detailed discussions of the data, assumptions and methods used to calculate emission benefits attr ibuted to each analy zed control measure. In the context of the SIP and reasonable fu rther progress demonstration, control measures discussed in this section refe r to state and Borough control measures/programs that were either adopted and implemented since the SIP was submitted or are projected to accumulate additional emission reductions betw een 2015 (the attainment target date) and the beginning of 2017 (the RFP milestone year).

After a discussion of the emission benefit calcu lations for each control measure, detailed tabular results for all pollutants are presen ted and their impacts in achieving the 2017 milestone targets are explained.



### 3.1 Control Measure Benefit Calculations

Emission benefit calculations are described in this sub-sectio n for each individual control measure analyzed under this QM report. Thes e calculations were performed in a serial order to avoid double counting of emission be nefits where measure effects overlap. Since all the analyzed measures apply to th e residential space h eating source sector, it was necessary to account for measure overla p. Emission benefits for the first measure (Wood Stove Change Out or WSCO Program) were developed as increments to projected baseline emissions in 2017. Benefits for each subsequent measure were then developed as increments in space heating emissions from the previous measure.

It is noted that emission be nefits presented here differ from those provided in DEC’s Response to Clarification Request RACM anal ysis. Under the RACM analysis, benefit estimates were developed for a single year, 2015 . This QM analysis calculates benefits for two years (2015 and 2016) and accounts fo r accumulation of benefits over multiple years from the WSCO Program as well as estimated improvements in compliance rates from one year to the next.

In addition, to meet the submittal schedule for this QM report, emission benefit estimates for NOx and NH 3 were calculated based on scaling of benefits for directly emitted PM 2.5

. Benefit calculations for PM 2.5 and SO 2 were based on source classification code (SCC)- specific emission factors for those pollutants. Relative differences in emission factors for NOx and NH 3 are similar to those for PM 2.5 for the space heating source categories9 represented in this analysis. Thus, the NOx and NH 3 benefits are reasonable approximations of more rigorously calculated estimates.

Emission benefit methodologies are pres ented below by individual measure.

Wood Stove Change Out Program – As not ed earlier, emission benefits from the Borough’s on-going WSCO Program accumulate over each year of operation as older higher emitting devices are removed or re placed with those ce rtified to lower PM 2.5 emission levels. The WSCO Program encompasses hydronic heaters, fireplaces, and fireplace inserts in addition to wood stove s. The program offers reimbursement incentives for replacing, removing or repair ing solid fuel burning appliances (SFBAs) (i.e. wood or coal stoves; wood- or coal-f ired furnaces; wood- or coal-fired hydronic heaters; fireplace inserts) orupgrading fireplaces. Replacement devices must be loweremitting EPA-certified devices, generally with emission ratings at or below 2.0 grams/hour. Subsidies for device replacement range from up to $5,000 for a wood or coal stove or insert and up to $10,000 for a hydroni c heater. (Higher subsidies up to $14,000 are offered for removal and replacement with a home heating oil or natural gas-burning appliance.)

WSCO Program benefits for two years of change outs, 2015 and 2016, were estimated using the methods contained in the Moderate SIP and actual change out data collected by the Borough from continued operation of the program through November 2016. As described there, WSCO program transactions ar e projected to decrease over time as more and more uncertified or higher-emitting devi ces are replaced. Totals of 386 and 316 change outs (replacements and removals) were projected in the SIP for calendar years 2015 and 2016 respectively. From these projected change outs by device type (fireplaces, inserts, wood stoves, hydronic he aters) emission benefits upon replacement were calculated by replacing the SCC-level emission factor for the old, higher-emitting device with that for the new replacement devi ce. Differences in net heating efficiency between replaced and new devices were also accounted for. For removals, emission impacts were calculated assuming the heat ing energy from the removed device was supplanted by that from a central oil fu rnace (and accounting for heating efficiency differences).

Average episodic emission reductions from continuation of the WSCO program from 2015 to 2017 were calculated to be 0.145 tpd for direct PM 2.5 , <-0.001 tpd for SO 2 , - 0.055 tpd for NOx and 0.002 tpd for NH 3 . The negative value for SO 2 reflects the effects of device removal and assumed energy repla cement by central oil, which has higher SO 2 emission per unit heating energy than wood devices. The nominal increase in NOx emissions results from projected populati on growth between 2015 and 2017 (which is subsumed by other factors for the other pollutants).

State Standards in New Homes – Like the WSCO program, emission benefits for the state’s wood-fired devi ce emission standards * (18 AAC 50.077) were calculated as increments in 2015 and 2016 based on effective im plementation dates for these standards.

* http://burnwise.alaska.gov/standards.htm10 The implementation dates are February 28, 2015 for hydronic heaters below 350,000 BTU/hour and all wood-fired devices a bove 350,000 BTU/hour and August 31, 2015 for wood stoves and most pellet stoves. These standards essentially require newly sold devices to meet cert ified 2.5 gram/hour PM 2.5 emission levels. Emission benefits for these standards were calculated using methods consistent in the Moderate SIP. Benefits were determined based on projections of new home sales within the nonattainment area and developed from data compiled by the Borough in its Community Research Quarterly * publications. Incremental benefits were calculated based on the historical mix of wood device emission rates relative to rates that apply under these standards, coupled with the fraction of new homes in which wood-fired de vices would be installed. (The wood device fraction was based on the 2011 Home Heating survey).

The incremental emission benefits for the st ate’s wood device emi ssion standards in 2015 and 2016 were estimated to be 0.021 tpd for direct PM 2.5 , 0.000 tpd for SO 2 , 0.004 tpd for NOx and 0.001 tpd for NH 3 . (SO 2 emission benefits are neg ligible because there is no difference in SO 2 emission factors for all wood device types.)

Dry Wood Measure – A series of state regulations and lo cal ordinances have been adopted and implemented that work in con cert to maximize the use of dry wood in the nonattainment area. (Dry wood reduces the amount of wood burned to supply a given amount of heat and reduces direct PM 2.5 and secondary pollutant emissions). To assist in ensuring the use of dry wood, there are three elements:

1. Opacity – Local ordinance 21.28.030.C (est ablished with Or dinance No. 2015-11 on February 27, 2015) states that emissions from solid fuel burning appliances may not create opacity greater than 20%, this is a year round requirement. The state program in 18 AAC 50.075 limits op acity to 20% during advisories and alerts.

2. State Wood Seller Moisture Disclosure Program – Under 18 AAC 51.076(d) the state has established a program whereby w ood sellers must disclose in writing the moisture content of commercially sold wood in the nonattainment area.

3. Dry Wood Requirement – Year-round borough require ment and seasonal state requirement. The state and local prog ram have adopted and implemented a regulation (18 AAC 50.076) and ordinance (21.28.030.F established with Ordinance No. 2015-11 on February 27, 2015) that requires the use of dry wood as a heating fuel in Fairbanks limiting solid fuels to: dry wood (20% moisture content or lower), pellets, or wood energy logs/pucks (which have moisture levels well below 20%).

These elements work under 18 AAC 50.076 in complementary fashion to maximize emission benefits. The disclosure program targets commercially sold wood while the seasonal dry wood requirement applies to w ood cut directly by the user as well as commercially sold wood. The methods to calcul ate emission benefits from each of these

* http://fnsb.us/cp/Pages/crc.aspx11 elements involved accounting for reductions in overall wood moisture content resulting from each element and properly accounting fo r the sector of wood use (commercially sold wood) where their benefits overlap. Calculations for each element described separately as follows.

State Wood Seller Moisture Disclosure Program – A “Wood Sales” database collected and maintained by DEC was used to estimate the effects of the Moisture Disclosure Program during the current voluntary phase of the program. Data were compiled by DEC for participating sellers in the program for a little over one year (starting in October 2015). For each record in the database, the amount of wood sold is provided (in cords) along with either a moisture level estimate (from three measurements as required under the program) or a designation that the wood was sold wet or frozen. These data were analyzed to develop an estimate of the change in average wood moisture for commercially sold wood with these disclosure requirements in place. It was found that average moisture content for commercially sold wood dropped from 64% (based on average moisture of commercially sold wood from a 2011 CCHRC study) to 33% based on analysis of the Wood Sale s database. (Its effect incr eases compliance with the dry wood requirement)

Based on known commercial wood sellers in the nonattainment area, DEC staff has estimated that roughly 75% of these wood sellers are curre ntly participating in the voluntary disclosure program (based on w ood volume). Combining this estimated participation rate with the composite mois ture levels from the Wood Sales database yields a reduction on average moisture cont ent for all wood burned (including wood cut and stored by residents as well as the rema ining 25% of commercially sold wood outside the disclosure program) from 36.4% to 30.3%. The increase in heati ng efficiency yields an estimated 4.5% reduction in wood use and emission reductions of 0.097 tpd for direct PM 2.5 , 0.004 tpd for SO 2 , 0.017 tpd for NOx and 0.001 tpd for NH 3 by 2017.

Dry Wood Use Requirement – Using methods to translate changes in wood moisture content discussed elsewhere in the Moderate SIP and similar to thos e applied above, an estimate of emission reduction was developed for the state program (and Borough ordinance).

State and Borough staff estimated the complian ce rate for the dry w ood requirement to be 20% as of the end of 2016 (the se cond year of implementation).

Based on this estimated compliance rate a nd after accounting for the effects of the aforementioned Wood Seller Moisture Disclo sure Program within the commercial wood use sector, this dry wood requirement results in an average wood mois ture content for all wood burned in the nonattainment area of 28.3% and an additional 1.5% reduction in wood use.

This translates to emission reduc tions by 2017 of 0.032 tpd for direct PM 2.5 , 0.001 tpd for SO 2 , 0.006 tpd for NOx and 0.001 tpd for NH 3

.12 Episodic SFBA Curtailment Program – The Borough’s Solid Fuel Burning Appliance (SFBA) Curtailment Program requires manda tory cessation of combustion from solidfueled residential space heating devices dur ing Stage 2 and Stage 3 alerts called by the Borough under specific ambient air quality and temperature regimes summarized as follows:

 Stage 2: 35 μg/m3 24-hour PM 2.5 < 55 μg/m3

 Stage 3, ≥ -15°F: 24-hour PM 2.5 > 55 μg/m3, ambient temperature , ≥ -15°F

 Stage 3, < -15°F: 24-hour PM 2.5 > 55 μg/m3, ambient temperature , < -15°F

(The program also includes a Stage 1 volunt ary component for which emission benefits were not analyzed.)

Under Stage 2, burning is permitted in all EPA-certified SFBAs, EPA Phase II qualified hydronic heaters with emission ratings of 2.5 g/hour or less, masonry heaters, pelletfueled appliances, cook stoves and fireplaces . Burning is prohibited from all other devices including non-EPA certified devices and waste oil devices.

Stage 3 includes separate restrictions de pending on whether ambient temperatures are above or below -15°F (as measured in real tim e at the Fairbanks International Airport). Above -15°F, burning is prohibited in a ll SFBAs, masonry heaters, pellet-fueled appliances, cook stoves, firepl aces and waste oil devices. When temperatures drop below -15°F, burning is permitted in EPA-certi fied SFBAs, EPA Phase II qualified hydronic heaters with emission ratings of 2.5 g/hour or less, masonry heaters and pellet-fueled appliances. (Fireplaces are prohibited from operating under Stage 3 with temperatures ≤ - 15°F.)

The alert stages can be called for two separa te air quality control zones (AQCZs) within the nonattainment area:

 Fairbanks (covering all of the nonattainme nt area except the Goldstream Valley and North Pole); and

 North Pole (the portion of the nonattainment area largely south and east of Badger Road).

Since the alert stages are AQCZ-specific a nd occur under different ambient conditions, the first step in analyzing pr ogram benefits consisted of identifying the frequency of the days and average temperature conditions under which they occurred during calendar year 2015, separately for each stage and AQCZ. (The 182-day nonattainment season runs from October 1 through March 31.) In 2015, Fa irbanks alerts were based on the NCORE monitor, while North Pole alerts were base d on the North Pole Fire Station monitor.

Since daily space heating emissions are a function of the ambient temperature, Table 3-1 shows average daily temperatures associ ated with each alert stage and AQCZ. (Fairbanks had no Stage 3 days above -15°F in 2015). It also shows the alert frequencies13 for each stage and AQCZ, expressed as the fraction of nonattainment season days each alert condition is expected to occur based on 2015 data.

Table 3-1 Curtailment Program Alert Condition s and Frequencies of Occurrence

Alert Condition Avg Daily Temp (°F) Alert Frequencies (%) Fairbanks North Pole Fairbanks North Pole Stage 2 - Days ≥ 35 μg/m 3 and < 55 μg/m 3 -26.8 -4.7 6.6% 10.4% Stage 3 - Days ≥ 55 μg/m 3 , Temp ≤ -15°F -29.2 -19.8 1.6% 12.6% Stage 3 - Days ≥ 55 μg/m 3 , Temp > -15°F n/a -0.4 0.0% 4.4%

Data collected by the Borough for operation of the curtailment program in calendar years 2015 and 2016 were used to estimate the progr am’s compliance rate as of the end of 2016. The Borough developed a compliance rate estimate of 10% for the first year of operation (2015). Based on a doubling of the number of citizens signed up to receive electronic burn restriction alerts and a quadr upling of the number of air quality violation notices sent between 2015 and 2016, it was estim ated that the program’s compliance rate by 2017 was 20%.

Baseline day-specific emissions by device/fue l under this set of temperatures were extracted from the episodic emission inventor y and adjusted at the SCC level to reflect emission changes from the preceding control measures. Next, emission reductions (at assumed 20% compliance) were calculated for the day-specific emission levels of each AQCZ (Fairbanks and North Pole) and alert stage (S2, S3>-15, S3<-15) by eliminating emissions from the specific devices and fuel for which burn restrictions occur under each stage. Logic was applied to account for emi ssion increases associated with substitution of heating energy from curtailment-restricted devices to a substitute device/fuel: a central oil furnace. Heating efficiency (as well as emission factor) differences between each restricted device and central o il were also accounted for. In addition to account for the “No Other Available Source of Heat” (NOASH) waiver provisions in the curtailment program, an estimate of NOASH households was developed from Fairbanks Home Heating Survey data. In the combined 2011-2015 surveys, it was found that 5.6% of surveyed households only had wood-burning de vices in the home; this percentage was used to estimate the fraction of potential NOASH households for which burn restrictions would be waived.

These emission calculations were performed separately for each AQCZ and accounted for the fact that the Goldstream Valley porti on of the nonattainment area is not subject to these restrictions. (Goldstream Valley emi ssions were scaled from the nonattainment area total based on occupied household counts from block-leve l tabulations in the 2010 Census).14 In the emission inventory (unlike for woods toves and inserts), hydronic heaters were treated as a single source category weighted as 80% unqua lified and 20% EPA Phase II qualified devices. To account for the fact that Phase II hydronic heaters with emission rates below 2.5 g/hour are allowed to operate during Stage 2 and Stag e 3 (<-15°F) alerts, an estimate of the population of Phase II devices under 2.5 g/hour of 38% was developed from the list of Phase II qualified hydronic heaters from EPA’s “Burn Wise” database.

Using these inputs and assumptions, estimat ed average daily emission reductions for direct PM 2.5 and SO 2 on days of each alert stage for each AQCZ are shown below in Table 3-2. (The negative values repr esent the marginal increase in SO 2 emissions associated with substituting wood-based heat with that from central oil.) Although North Pole has a higher fraction of wood-burni ng devices than Fairbanks, its average PM 2.5 emission reductions under each stage are lowe r because warmer temperatures can still trigger alert stages there as shown earlier in Table 3-1.

Table 3-2 Alert Stage Curtailment Program Emi ssion Reductions (20% Compliance)

AQCZ Stage-Specific Daily Emission Reductions (tons/day)
PM 2.5 Reductions SO 2 Reductions

Stage 2 Stage 3 >-15°F Stage 3 <-15°F Stage 2 Stage 3 >-15°F Stage 3 <-15°F Fairbanks 0.048 0 0.096 -0.005 0 -0.005 North Pole 0.035 0.118 0.076 -0.002 -0.015 -0.002

These reductions are specific to those days (and areas) for which alerts were called. Using the frequencies of each alert stag e for each area based on 2015 monitoring and meteorology data, nonattainment episodic aver age daily reductions are shown below. (Again, negative numbers reflect emission increases.)

Table 3-3 Curtailment Program Average Daily Emission Reductions (20% Compliance)

Pollutant Episodic Average Daily Emi ssion Reductions (tons/day)
Fairbanks North Pole Nonattainment Area
PM 2.5 0.058 0.067 0.125

SO 2 -0.005 -0.004 -0.009

Emission benefits for the curtailment pr ogram were not quantified for NOx and NH 3

. Although real reductions occurred for these pollutants, their be nefits were not required to meet inventory milestone targets by 2017.15 

### 3.2 Summary of Emission Reductions

Table 3-4 summarizes the estimated 2015 and 2016 emission reductions for each of the control measures analyzed in th is report. (Although all appli cable measures are listed in Table 3-4, those for which additional reductions in this period were not quantified are noted with “.........” entries.) As denoted by “PB” entries at the bottom of Table 3-4, turnover reductions from motor vehicles and old uncertified woodstoves are not explicitly listed in the table but are incorporated with the 2017 baseline inventory.

Table 3-4 Summary of 2015 & 2016 Control Measure Emission Reductions

Control Measure Episodic Average Daily Emission Reductions (tons/day)
PM 2.5 SO 2 NOx NH 3 Voluntary Measures

.......... .......... .......... .......... Hydronic Heater Retrofits

.......... .......... .......... .......... Wood Stove Change Out Program 0.145 0.000 -0.055 0.002 State Standards in New Homes 0.021 0.000 0.004 0.001 Dry Wood – State Wood Seller Moisture Disclosure Program 0.097 0.004 0.017 0.004 Dry Wood Requirement 0.032 0.001 0.006 0.001 Borough SFBA Curtailment Program 0.125 -0.009 0.000 0.000 Energy Efficiency Measures

.......... .......... .......... .......... Other Pre-2015 Requirements

.......... .......... .......... .......... Other Post-2015 Requirements

.......... .......... .......... .......... Vehicle/Wood Device Turnover PB PB PB PB
Totals 0.421 -0.004 -0.028 0.008 PB – Accounted for within projected baseline inventory and not explicitly delineated.

As shown, total reductions across all measur es (and accounting for applicable measures overlap) of 0.421 tpd for direct PM 2.5 , -0.004 tpd for SO 2 , -0.028 tpd for NOx and 0.008 tpd for NH 3 as of the end of 2016.

All the analyzed control measures have been implemented and are contained within the Area Source, Space Heating sector of the emi ssion inventory. These control benefits were applied to projected baseline emi ssions in 2017 for all inventory sectors and compared to the total milestone targets established in the Moderate SIP as shown below in Table 3-5 for each applicable pollutant. As shown in each of the pollutant-specific highlighted rows, the projected 2017 inventor y with these controls shown in the “2015/16 Achieved” column meet or are below the 2017 milestone targets established in the SIP reflected in the “2017 RFP” column. This de monstrates that these controls will provide reasonable further progress toward attainment in 2017.16 Table 3-5 Summary of 2015 & 2016 Control Measure Emission Reductions

Source Sector Episodic Average Daily Emissions (tons/day) 2017 Milestone 2015/16 Achieved
PM 2.5 Inventory Point (Actual) 1.41 1.41 Area, Space Heating 2.02 2.02 Area, All Other 0.07 0.07 On-Road Mobile 0.43 0.43 Non-Road Mobile 0.02 0.02 Total PM 2.5 3.96 3.96 SO 2 Inventory Point (Actual) 8.17 8.17 Area, Space Heating 4.76 4.42 Area, All Other 0.00 0.00 On-Road Mobile 0.02 0.02 Non-Road Mobile 0.09 0.09 Total SO 2 13.03 12.59 NOx Inventory Point (Actual) 13.28 13.28 Area, Space Heating 2.42 2.40 Area, All Other 0.00 0.00 On-Road Mobile 2.19 2.19 Non-Road Mobile 1.08 1.08 Total NOx 2 18.97 18.96
NH 3 Inventory Point (Actual) n/a n/a Area, Space Heating 0.148 0.117 Area, All Other 0.000 0.000 On-Road Mobile 0.050 0.050 Non-Road Mobile 0.003 0.003 Total NH 32 0.200 0.169 n/a – not available; NH 3 emissions data was not available for point sources at the time of preparation of the SIP inventory. Note: Table 3-5 reports emissions to two decimal digits for PM 2.5 , SO 2 and NOx and three decimal digits for NH 3 . Totals for each pollutant acro ss all inventory sectors are summ ed based on additional precision and rounded to two or three decimals. Thus, differen ces between the totals and the sum of sector-specific emissions are the result of rounding.

As noted in boldface, all of the analyzed cont rol measure benefits are applied within the “Area, Space Heating” sector of the emission inventory. ###17 

### 4. ATTAINMENT FINDINGS

As required in 40 CFR 51.1013(4)(b)(3) the quan titative milestone repo rt must include a discussion of whether the area will attain the applicable PM 2.5 NAAQS by the projected attainment date for that area. Pursuant to this requirement, DEC acknowledges that consistent with the impracticability demonstration in the Moderate SIP, the Fairbanks Moderate PM 2.5 nonattainment area did not attain the ambient 24-hour PM 2.5 NAQQS by December 31, 2015 as required.

However, this report demonstrates that c ontinuation and addition of control measures implemented in 2015 and 2016 yields benefits re sulting in inventory reductions that meet 2017 quantitative milestone targets for both directly emitted PM 2.5 and all applicable precursors, ensuring reasonable further progre ss “no later than 3 y ears after December 31, 2014” requirements have been met.

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