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 Star 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) 465-5109. 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, ANPMS 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
-iFairbanks 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 PM2.5 ..................................................... 4

Figure 1-2 Quantitative Milestone Analysis for SO2 ........................................................ 5

Figure 1-3 Quantitative Milestone Analysis for NOx....................................................... 5

Figure 1-4 Quantitative Milestone Analysis for NH3 ....................................................... 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 Conditions and Frequencies of Occurrence ........ 13

Table 3-2 Alert Stage Curtailment Program Emission Reductions (20% 

Compliance) ................................................................................................................ 14

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

Compliance) ................................................................................................................ 14

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

Table 3-5 Summary of 2015 & 2016 Control Measure Emission Reductions ............... 16
1 

1. SUMMARY 

1.1 Introduction 

A portion of the Fairbanks North Star Borough (FNSB) that includes the cities of 

Fairbanks and North Pole as well as surrounding areas was designated as a National 

Ambient Air Quality Standard (NAAQS) fine particulate matter (PM2.5) 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 PM2.5 area. 

The key finding of that Plan (subsequently referred to as the Moderate SIP) was that 

attainment of the PM2.5 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 § 51.1013the 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 Technologies (RACT). 

The analysis determined whether forecasted controls (and their benefits) 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 representing 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 correspond to the list of measures for which 

quantitative emission benefits were calculated and incorporated into the Control 

inventories. The entire set of control measures/programs is summarized below in Table 

1-1, along with their respective 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, 2nd 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 which examines RFP progress in 2017 based on 

current conditions and control measure implementation 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 measure 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 - Table 1-2 summarizes the individual control 

measures for which emission benefits were 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 PM2.5, SO2, NOx, NH3

State Wood Device Standards Yes PM2.5, SO2, NOx, NH3

Dry Wood Measures 

 - State Moisture Disclosure 

 - State/Borough Dry Wood Programs 

Yes PM2.5, SO2, NOx, NH3

Borough Mandatory Curtailment Program Yes PM2.5, SO2

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, 2nd 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 that were adopted after the December 2014 

Moderate SIP submittal or provide additional incremental reductions in 2015 or 2016. 

This RFP analysis examined episodic emissions of directly emitted PM2.5 as well as 

precursor pollutants: sulfur dioxide (SO2), nitrogen oxides (NOx) and ammonia (NH3). 

As noted in the rightmost column of Table 1-2, individual benefits were calculated for 

each pollutant, except NOx and NH3 benefits for the curtailment program. (As discussed 

later, although there are benefits 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 presents the quantitative milestone analysis for 

directly emitted PM2.5. The vertical bars labeled “2015 Ctl” and “2019 Ctl” represent the 

2015 and 2019 Control inventories from the SIP. The 2015 Control inventory reflects 

benefits for control measures quantified in the SIP that were implemented prior to 2015. 

The 2019 Control inventory represents that for which attainment was modeled in the SIP 

by calendar year 2019. (Emission contributions from each source sector are shown for 

each inventory bar.) The middle bar, “2017 RFP” represents the linearly-interpolated 

2017 quantitative milestone target from the 2015 and 2019 Control inventories. 

Projected 2017 emissions below this milestone target reflect a demonstration of 
4 

reasonable further progress toward attainment. (Projected 2017 emissions above the 

target would indicate that RFP 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 attainment year for the Moderate SIP. As 

shown in Figure 1-1, total direct PM2.5 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 PM2.5. 

Figure 1-1 

Quantitative Milestone Analysis for PM2.5

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 Ctl

PM2.5 Emissions (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 SO2, NOx and NH3, respectively. For each pollutant, 

2017 Control emissions are expected to be below the applicable milestone targets as seen 

in Figure 1-2 through Figure 1-4. For SO2 (Figure 1-2) and NH3 (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 control strategies in the 2019 attainment 

demonstration that in part reflect switching from wood to other heating fuels that are 

much lower in direct PM2.5 emissions, but result in nominal increases emissions from 

these precursors. (In Figure 1-2, the contribution for on-road SO2 emissions is less than 

0.02 tpd for all inventories and is too small to be displayed.) 

(Section 3 of this report discusses the calculation of the 2017 Control emissions in detail 

and includes detailed breakdowns of the emission benefits for each of the measures 

analyzed in the report.) 
5 

Figure 1-2 

Quantitative Milestone Analysis for SO2

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 Ctl

SO2 Emissions (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 SO2 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 Ctl

NOx Emissions (tons/day)

Inventory

Area, Space Heat

Area, Other

Point (Actual)

On‐Road

Non‐Road

19.23 18.96 18.97 18.71
6 

Figure 1-4 

Quantitative Milestone Analysis for NH3

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 Ctl

NH3 Emissions (tons/day)

Inventory

Area, Space Heat

Area, Other

Point (Actual)

On‐Road

Non‐Road

0.179

0.222

0.169

0.200

Note: NH3 emissions data was not available for point sources at the time of preparation of the Moderate 

SIP inventory. Thus, point source contributions for NH3 appear as zero. 

1.3 Organization of the Report 

Following this summary section, the remainder 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 consistent with the RFP plan. Section 3 describes 

supporting technical calculations sufficient to document and demonstrate that the 

quantitative milestones have been satisfied. It also describes how the emissions 

reductions achieved to date compare to those required or scheduled to meet RFP. Section 

4 provides a discussion of whether the area will attain the applicable PM2.5 NAAQS by 

the projected attainment date for the area. 

### 
### 

7 

2. SIP CONTROL STRATEGY CERTIFICATION 
8 

3. SUPPORTING CALCULATIONS 

This section of the QM report provides detailed discussions of the data, assumptions and 

methods used to calculate emission benefits attributed to each analyzed control measure. 

In the context of the SIP and reasonable further progress demonstration, control measures 

discussed in this section refer 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 between 2015 (the attainment target date) and 

the beginning of 2017 (the RFP milestone year). 

After a discussion of the emission benefit calculations for each control measure, detailed 

tabular results for all pollutants are presented 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-section for each individual control 

measure analyzed under this QM report. These calculations were performed in a serial 

order to avoid double counting of emission benefits where measure effects overlap. 

Since all the analyzed measures apply to the residential space heating source sector, it 

was necessary to account for measure overlap. 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 benefits presented here differ from those provided in DEC’s 

Response to Clarification Request RACM analysis. 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 for 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 NH3 were calculated based on scaling of benefits for directly emitted PM2.5. 

Benefit calculations for PM2.5 and SO2 were based on source classification code (SCC)-

specific emission factors for those pollutants. Relative differences in emission factors for 

NOx and NH3 are similar to those for PM2.5 for the space heating source categories 
9 

represented in this analysis. Thus, the NOx and NH3 benefits are reasonable 

approximations of more rigorously calculated estimates. 

Emission benefit methodologies are presented below by individual measure. 

Wood Stove Change Out Program – As noted 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 replaced with those certified to lower PM2.5

emission levels. The WSCO Program encompasses hydronic heaters, fireplaces, and 

fireplace inserts in addition to wood stoves. The program offers reimbursement 

incentives for replacing, removing or repairing solid fuel burning appliances (SFBAs) 

(i.e. wood or coal stoves; wood- or coal-fired furnaces; wood- or coal-fired hydronic 

heaters; fireplace inserts) or upgrading 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 hydronic 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 are projected to decrease over time as more 

and more uncertified or higher-emitting devices 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 heaters) 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 device. Differences in net heating efficiency 

between replaced and new devices were also accounted for. For removals, emission 

impacts were calculated assuming the heating energy from the removed device was 

supplanted by that from a central oil furnace (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 PM2.5, <-0.001 tpd for SO2, -

0.055 tpd for NOx and 0.002 tpd for NH3. The negative value for SO2 reflects the effects 

of device removal and assumed energy replacement by central oil, which has higher SO2

emission per unit heating energy than wood devices. The nominal increase in NOx 

emissions results from projected population 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 device emission standards* (18 AAC 50.077) were calculated as 

increments in 2015 and 2016 based on effective implementation dates for these standards. 

 

* http://burnwise.alaska.gov/standards.htm 
10 

The implementation dates are February 28, 2015 for hydronic heaters below 350,000 

BTU/hour and all wood-fired devices above 350,000 BTU/hour and August 31, 2015 for 

wood stoves and most pellet stoves. These standards essentially require newly sold 

devices to meet certified 2.5 gram/hour PM2.5 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 devices would be installed. (The wood device 

fraction was based on the 2011 Home Heating survey).

The incremental emission benefits for the state’s wood device emission standards in 2015 

and 2016 were estimated to be 0.021 tpd for direct PM2.5, 0.000 tpd for SO2, 0.004 tpd for 

NOx and 0.001 tpd for NH3. (SO2 emission benefits are negligible because there is no 

difference in SO2 emission factors for all wood device types.) 

Dry Wood Measure – A series of state regulations and local ordinances have been 

adopted and implemented that work in concert 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 PM2.5 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 (established with Ordinance 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 opacity 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 wood sellers must disclose in writing the 

moisture content of commercially sold wood in the nonattainment area. 

3. Dry Wood Requirement – Year-round borough requirement and seasonal state 

requirement. The state and local program 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 wood cut directly by the user as well as 

commercially sold wood. The methods to calculate emission benefits from each of these 

 

* http://fnsb.us/cp/Pages/crc.aspx 
11 

elements involved accounting for reductions in overall wood moisture content resulting 

from each element and properly accounting for 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 Sales database. (Its effect increases 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 currently participating in the 

voluntary disclosure program (based on wood volume). Combining this estimated 

participation rate with the composite moisture levels from the Wood Sales database 

yields a reduction on average moisture content for all wood burned (including wood cut 

and stored by residents as well as the remaining 25% of commercially sold wood outside 

the disclosure program) from 36.4% to 30.3%. The increase in heating efficiency yields 

an estimated 4.5% reduction in wood use and emission reductions of 0.097 tpd for direct 

PM2.5, 0.004 tpd for SO2, 0.017 tpd for NOx and 0.001 tpd for NH3 by 2017. 

Dry Wood Use Requirement – Using methods to translate changes in wood moisture 

content discussed elsewhere in the Moderate SIP and similar to those applied above, an 

estimate of emission reduction was developed for the state program (and Borough 

ordinance). 

State and Borough staff estimated the compliance rate for the dry wood requirement to be 

20% as of the end of 2016 (the second year of implementation). 

Based on this estimated compliance rate and after accounting for the effects of the 

aforementioned Wood Seller Moisture Disclosure Program within the commercial wood 

use sector, this dry wood requirement results in an average wood moisture 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 reductions by 2017 of 0.032 tpd for direct PM2.5, 0.001 tpd for 

SO2, 0.006 tpd for NOx and 0.001 tpd for NH3. 
12 

Episodic SFBA Curtailment Program – The Borough’s Solid Fuel Burning Appliance 

(SFBA) Curtailment Program requires mandatory cessation of combustion from solidfueled residential space heating devices during 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 PM2.5 < 55 μg/m3 

 Stage 3, ≥ -15°F: 24-hour PM2.5 > 55 μg/m3, ambient temperature , ≥ -15°F 

 Stage 3, < -15°F: 24-hour PM2.5 > 55 μg/m3, ambient temperature , < -15°F 

(The program also includes a Stage 1 voluntary 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 depending on whether ambient temperatures are 

above or below -15°F (as measured in real time at the Fairbanks International Airport). 

Above -15°F, burning is prohibited in all SFBAs, masonry heaters, pellet-fueled 

appliances, cook stoves, fireplaces and waste oil devices. When temperatures drop below 

-15°F, burning is permitted in EPA-certified 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 separate air quality control zones (AQCZs) within 

the nonattainment area: 

 Fairbanks (covering all of the nonattainment 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 and occur under different ambient conditions, 

the first step in analyzing program 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, Fairbanks alerts were based on the NCORE 

monitor, while North Pole alerts were based 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 associated with each alert stage and AQCZ. 

(Fairbanks had no Stage 3 days above -15°F in 2015). It also shows the alert frequencies 
13 

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 Conditions and Frequencies of Occurrence 

Alert Condition 

Avg Daily Temp (°F) Alert Frequencies (%)

Fairbanks North Pole Fairbanks North Pole

Stage 2 - Days ≥ 35 μg/m3 and < 55 μg/m3 -26.8 -4.7 6.6% 10.4%

Stage 3 - Days ≥ 55 μg/m3, Temp ≤ -15°F -29.2 -19.8 1.6% 12.6%

Stage 3 - Days ≥ 55 μg/m3, 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 program’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 quadrupling of the number of air quality violation 

notices sent between 2015 and 2016, it was estimated that the program’s compliance rate 

by 2017 was 20%. 

Baseline day-specific emissions by device/fuel under this set of temperatures were 

extracted from the episodic emission inventory 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 emission 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 oil 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 devices 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 portion of the nonattainment area is not subject to 

these restrictions. (Goldstream Valley emissions were scaled from the nonattainment 

area total based on occupied household counts from block-level tabulations in the 2010 

Census). 
14 

In the emission inventory (unlike for woodstoves and inserts), hydronic heaters were 

treated as a single source category weighted as 80% unqualified 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 Stage 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, estimated average daily emission reductions for 

direct PM2.5 and SO2 on days of each alert stage for each AQCZ are shown below in 

Table 3-2. (The negative values represent the marginal increase in SO2 emissions 

associated with substituting wood-based heat with that from central oil.) Although North 

Pole has a higher fraction of wood-burning devices than Fairbanks, its average PM2.5

emission reductions under each stage are lower because warmer temperatures can still 

trigger alert stages there as shown earlier in Table 3-1. 

Table 3-2 

Alert Stage Curtailment Program Emission Reductions (20% Compliance) 

AQCZ 

Stage-Specific Daily Emission Reductions (tons/day) 

PM2.5 Reductions SO2 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 stage for each area based on 2015 monitoring and 

meteorology data, nonattainment episodic average 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 Emission Reductions (tons/day) 

Fairbanks North Pole Nonattainment Area 

PM2.5 0.058 0.067 0.125 

SO2 -0.005 -0.004 -0.009 

Emission benefits for the curtailment program were not quantified for NOx and NH3. 

Although real reductions occurred for these pollutants, their benefits 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 this report. (Although all applicable 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) 

PM2.5 SO2 NOx NH3

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 measures (and accounting for applicable measures 

overlap) of 0.421 tpd for direct PM2.5, -0.004 tpd for SO2, -0.028 tpd for NOx and 0.008 

tpd for NH3 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 emission inventory. These control benefits 

were applied to projected baseline emissions 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 inventory 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 demonstrates 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 

PM2.5 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 PM2.5 3.96 3.96 

SO2 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 SO2 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 NOx2 18.97 18.96 

NH3 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 NH32 0.200 0.169 

n/a – not available; NH3 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 PM2.5, SO2 and NOx and three decimal digits 

for NH3. Totals for each pollutant across all inventory sectors are summed based on additional precision 

and rounded to two or three decimals. Thus, differences between the totals and the sum of sector-specific 

emissions are the result of rounding. 

As noted in boldface, all of the analyzed control measure benefits are applied within the 

“Area, Space Heating” sector of the emission inventory. 

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17 

4. ATTAINMENT FINDINGS 

As required in 40 CFR 51.1013(4)(b)(3) the quantitative milestone report must include a 

discussion of whether the area will attain the applicable PM2.5 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 PM2.5 nonattainment area did not attain the ambient 24-hour PM2.5 NAQQS by 

December 31, 2015 as required. 

However, this report demonstrates that continuation and addition of control measures 

implemented in 2015 and 2016 yields benefits resulting in inventory reductions that meet 

2017 quantitative milestone targets for both directly emitted PM2.5 and all applicable 

precursors, ensuring reasonable further progress “no later than 3 years after December 31, 

2014” requirements have been met. 

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