Redesignation Request and Maintenance Plan

for the 

Truckee Meadows 24-Hour PM10 NonAttainment Area

August 28, 2014

Washoe County Health District 

Air Quality Management Division 

P.O. Box 11130 

Reno, Nevada 89520-0027 

(775) 784-7200 

www.OurCleanAir.com
i 

TABLE OF CONTENTS

 Page

Acknowledgements ....................................................................................................................v 

Chapter 1: Introduction ..............................................................................................................1 

Chapter 2: Attainment of the Standard ......................................................................................2 

National Ambient Air Quality Standard ........................................................................2 

 Washoe County Monitoring Network ............................................................................2 

 Monitoring Data .............................................................................................................4 

Summary ........................................................................................................................7 

Chapter 3: State Implementation Plan Approval .......................................................................8 

Chapter 4: Permanent and Enforceable Improvement in Air Quality ......................................10 

Federally Enforceable Control Programs in the Truckee Meadows Portion 

of the Nevada SIP ........................................................................................................10 

1. Residential Wood Combustion Program ............................................................10 

2. Street Sanding and Sweeping Program ...............................................................11 

3. Dust Control ........................................................................................................11 

4. Emergency Episode Plan ....................................................................................11 

 Other Programs That Provide Additional PM10 Benefits ............................................12 

1. Non-Road Diesel Emission Standards ................................................................12 

2. Ultra Low Sulfur Diesel (ULSD) ........................................................................12 

3. Washoe County Smoke Management Program ..................................................12 

 Economic Conditions ...................................................................................................13 

 Meteorological Conditions...........................................................................................13 

Summary ......................................................................................................................16 

Chapter 5: Section 110 and Part D Requirements ...................................................................17 

 Section 110 Requirements ...........................................................................................17 

Part D Requirements ....................................................................................................18 

Chapter 6: Maintenance Plan ...................................................................................................23 

Attainment Inventory ...................................................................................................23 

 Point Sources ......................................................................................................23 

 Nonpoint Sources ................................................................................................23 

 Non-Road Mobile Sources ..................................................................................24 

 On-Road Mobile Sources ....................................................................................24 

Maintenance Demonstration ........................................................................................24 

 Truckee Meadows Maintenance Emissions Limit ...............................................25 

 Maintenance of the NAAQS ................................................................................26 

1. Baseline Emission Projections .............................................................26 

2. EPA Models .........................................................................................26 

3. Emission Category Surveys .................................................................27 
ii

TABLE OF CONTENTS (continued) 

 Page

 Summary ..............................................................................................................27 

 Motor Vehicle Emissions Budget ................................................................................28 

 Monitoring Network ....................................................................................................29 

Verification of Continued Attainment .........................................................................29 

1. Periodic Emissions Inventories ........................................................................29 

2. Consolidated Emissions Reporting Rule (CERR) and Air Emissions Reporting 

Rule (AERR) ....................................................................................................29 

3. Residential Wood Use Survey .........................................................................29 

 Contingency Plan .........................................................................................................30 

 Contingency Plan “A”.........................................................................................31 

 Trigger Mechanism “A” ............................................................................31 

 Contingency Measure “A” .........................................................................31 

 Summary .............................................................................................................32 

List of Tables ........................................................................................................................... iii 

List of Figures .......................................................................................................................... iii 

Appendices ............................................................................................................................... iii 

Acronyms ................................................................................................................................. iv 
iii

LIST OF TABLES

Table Page

 2-1 Seasonal PM10 Concentrations and Exceedances (1999-2012) ...............................4 

 2-2 Galletti Ambient Air Monitoring Data (2005) .........................................................6 

 2-3 Operational History of PM10 Monitoring Network and Sampling Methods............6 

 4-1 2011 Emission Reductions from Federally Enforceable Programs .......................12 

 4-2 Washoe County Demographic and Economic Indicators (1999-2011) .................13 

 5-1 Part D Requirements and Actions for the Truckee Meadows PM10 NAA ............19 

 6-1 2011 Attainment Inventory (lbs/day) .....................................................................24 

 6-2 Historic Truckee Meadows PM10 Wildfire Emission Inventories (lbs/day) ..........25 

 6-3 Truckee Meadows PM10 Emission Inventories (lbs/day) ......................................26 

 6-4 Truckee Meadows PM10 Maintenance Emission Inventories (lbs/day) .................27 

 6-5 Truckee Meadows PM10 Safety Margin (lbs/day) .................................................28 

 6-6 Truckee Meadows PM10 MVEB (lbs/day) .............................................................28 

 6-7 Potential PM10 Contingency Measures ..................................................................32 

LIST OF FIGURES

Figure Page

 1-1 Washoe County, Nevada ..........................................................................................1 

 2-1 PM10 Monitoring Network (1999-2012) ..................................................................3 

 2-2 Seasonal PM10 Concentrations and Exceedances (1999-2012) ...............................5 

 4-1 Precipitation Days (1990-2012) .............................................................................14 

 4-2 Mean Wind Speed (1990-2012) .............................................................................15 

 4-3 Mean Station Barometric Pressure (1990-2012)....................................................16 

 6-1 South Reno Monitoring Site ..................................................................................29 

APPENDICES

 Appendix 

A. Permanent and Enforceable Reduction Calculations 

B. Growth Factors for 2015, 2020, 2025, and 2030 Projections 

C. Truckee Meadows Projected PM10 Seasonal Emissions 
iv

ACRONYMS

ADT Average Daily Traffic

AERR Air Emissions Reporting Requirements

AIRS Aerometric Information Retrieval System

AQI Air Quality Index 

AQMD Washoe County Health District - Air Quality Management Division

AQS Air Quality System

BACM Best Available Control Measure

BAM Beta Attenuation Monitor

CAA Clean Air Act

CERR Consolidated Emissions Reporting Rule 

CFR Code of Federal Regulations

EI Emissions Inventory

EPA United States Environmental Protection Agency 

FR Federal Register

HA Hydrographic Area

HDD Heating Degree Days

MPO Metropolitan Planning Organization 

MVEB Motor Vehicle Emissions Budget 

NAA Non-Attainment Area

NAAQS National Ambient Air Quality Standard

NCore National Core Multi-Pollutant Monitoring Station

NOx Nitrogen oxides

NRS Nevada Revised Statute

NSR New Source Review

PM10 Particulate matter less than or equal to a nominal 10 microns in aerodynamic 

diameter

PSD Prevention of Significant Deterioration

RACM Reasonably Available Control Measure

RACT Reasonably Available Control Technology 

RE Rule Effectiveness

RP Rule Penetration

RTC Regional Transportation Commission

RWC Residential Wood Combustion 

SIP State Implementation Plan

SLAMS State and Local Air Monitoring Station

SMP Smoke Management Program

SPM Special Purpose Monitoring 

ULSD Ultra Low Sulfur Diesel

VMT Vehicle Miles Traveled

WCDBOH Washoe County District Board of Health
v 

ACKNOWLEDGEMENTS 

Washoe County District Board of Health 

Matt Smith, Chair 

Kitty Jung, Vice Chair 

George Hess, MD 

Denis Humphreys, OD 

Julia Ratti 

David Silverman 

Neoma Jardon 

Washoe County Health District 

Kevin Dick, District Health Officer 

Washoe County Health District, Air Quality Management Division 

Charlene Albee, Director 

Daniel Inouye, Branch Chief 

Yann Ling-Barnes, P.E., Environmental Engineer II, Project leader 

Julie D. Hunter, Senior Air Quality Specialist 

Brendan Schnieder, Air Quality Specialist II 
PM10 Redesignation Request August 28, 2014 

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CHAPTER 1

INTRODUCTION

The Washoe County Health District - Air Quality Management Division (AQMD) is requesting 

the U.S. Environmental Protection Agency (EPA) to redesignate the Truckee Meadows1 nonattainment area (NAA) to attainment/maintenance status for the 24-hour Particulate Matter less 

than 10 microns in aerodynamic diameter (PM10) National Ambient Air Quality Standard 

(NAAQS). The Truckee Meadows has not violated the NAAQS since 2002 and is currently 

classified as a “Serious” NAA.2 

The AQMD also requests that the “Redesignation Request and Maintenance Plan for the Truckee 

Meadows, 24-Hour PM10 Non-Attainment Area” submitted to EPA on July 13, 2009 be 

withdrawn. 

Washoe County is located in the northwest portion of Nevada and is bounded by the states of 

California, Oregon, and the counties of Humboldt, Pershing, Storey, Churchill, Lyon, and Carson 

City (Figure 1-1). The Truckee Meadows is approximately 200 square miles in size and situated 

in the southern portion of Washoe County. It is geographically identified as Hydrographic Area 

(HA) 87 as defined by the State of Nevada, Division of Water Resources. It is surrounded by 

mountain ranges, which can lead to wintertime temperature inversions, where a layer of cold air 

is trapped in the valley. Warmer air above the inversion acts as a lid, containing and 

concentrating air pollutants. Much of Washoe County’s urban population lives in the Truckee 

Meadows. Anthropogenic activities, such as automobile use and residential wood combustion, 

are also concentrated here. 

The Truckee Meadows covers an area governed by three 

political entities - the County of Washoe, the City of Reno, 

and the City of Sparks. The AQMD is the designated agency 

responsible for air quality management throughout the entire 

county. 

This Redesignation Request and Maintenance Plan was 

prepared in accordance with Section 107(d)(3)(E) of the Clean 

Air Act (CAA) as amended in 1990 and follows guidance 

contained in the Calcagni Memorandum.3

 The following five 

sections are structured and organized as presented in 

Subsections (i) through (v) of Section 107(d)(3)(E). 

 

1 Identified as the “Reno Planning Area” in 40 CFR 81.329.

2 40 CFR 81.329.

3 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.

Figure 1-1

Washoe County, Nevada
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 2 

CHAPTER 2

ATTAINMENT OF THE STANDARD

The first condition for redesignation is demonstration of attaining the NAAQS. This condition is 

met when ambient PM10 monitoring data are representative, complete, quality-assured, and 

reported in accordance with 40 Code of Federal Regulations (CFR) 50, 53, and 58, and meet the 

NAAQS. Ambient air monitoring data demonstrate that the Truckee Meadows area attained the 

NAAQS in 2002. The following information further validates the long-term air quality 

improvements within the Truckee Meadows.

National Ambient Air Quality Standard

The level of NAAQS for PM10 is 150 μg/m3 over a 24-hour averaging period; the number of 

times a monitor is expected to exceed this concentration must be less than one per year for the 

NAAQS to be attained. The rounding convention in the standard specifies that values be 

rounded to the nearest 10 μg/m3 (i.e., values ending in 5 or greater are to be rounded up). If less 

than everyday sampling occurs, an adjustment factor must be applied to the number of measured 

exceedances to determine the number of expected exceedances.4

 

Washoe County Monitoring Network 

Between 1999 and 2012, the AQMD maintained eight State and Local Air Monitoring Stations 

(SLAMS), one of which is also a National Core Multi-Pollutant Monitoring Station (NCore), 

within Washoe County (Figure 2-1). Six of the eight active monitoring sites were located within 

the Truckee Meadows. All of these sites were sited in accordance with 40 CFR 58 and utilized 

monitoring equipment designated as reference or equivalent methods under 40 CFR 53. In 

addition, Washoe County’s PM10 monitoring network was reviewed annually pursuant to 40 

CFR 58.10 to ensure the network meets the monitoring objectives defined in 40 CFR 58, 

Appendix D. The data were collected and quality assured in accordance with 40 CFR 58 and 

recorded in the Air Quality System (AQS), formerly referred to as Aerometric Information 

Retrieval System (AIRS). 

 

4 40 CFR 50, Appendix K.
PM10 Redesignation Request August 28, 2014 

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Figure 2-1 

PM10 Monitoring Network (1999-2012) 
PM10 Redesignation Request August 28, 2014 

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Monitoring Data 

PM10 monitoring data were collected, complete, quality assured, recorded in AQS, and available 

for public review in accordance with 40 CFR 58. Expected exceedance rates were calculated 

following guidance in the 40 CFR 50, Appendix K. Table 2-1 summarizes the exceedances and 

expected number of exceedances from 1999 to 2012. These data are from SLAMS and NCore 

sites within Washoe County, including the Truckee Meadows. 

Based on these data, the Truckee Meadows violated the 24-hour PM10 NAAQS as recent as 

2001. However, the long-term trend has been a decline in ambient PM10 exceedances (See Table 

2-1 and Figure 2-2). Since 2002, the Truckee Meadows expected exceedance rate has been equal 

to or less than one and therefore, has attained the NAAQS in accordance with 40 CFR 50.6. 

On April 19, 2011, EPA published a final rule determining that the Truckee Meadows area is 

currently attaining the PM10 NAAQS, based upon complete, quality-assured PM10 air quality

monitoring data during the years 2007-2009.5 Certified data through December 2012 contained 

in EPA’s AQS are also consistent with continued attainment of the 24-hour PM10 NAAQS. 

Because the Truckee Meadows area is currently attaining the PM10 NAAQS, EPA also finalized 

its determination that the obligation to make submissions to meet certain CAA requirements 

related to attainment is not applicable for as long as the area continues to attain the PM10

NAAQS.6

Table 2-1 

Seasonal PM10 Concentrations and Exceedances (1999-2012) 

Monitored Concentration 

and Exceedances* 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

1st High (ug/m3) 215 109 81 97 108 126 172 106 130 87 93 142 121 100

2nd High (ug/m3) 197 100 74 85 100 90 103 104 108 76 91 77 113 92

Exceedances (Measured) 1 0 0 0 0 0 1 0 0 0 0 0 0 0

Exceedances (Expected) 6.0 0.0 0.0 0.0 0.0 0.0 1.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

3-Year Average of 

Expected 2.0 2.0 2.0 0.0 0.0 0.0 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0

* For the PM10 Season (November, December, January). 

 

5 76 FR 21807 (April 19, 2011).

6 Ibid.
PM10 Redesignation Request August 28, 2014 

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Figure 2-2 

Seasonal PM10 Concentrations and Exceedances (1999-2012) 

* For the PM10 Season (January, November, and December). 

** PM10 NAAQS is 150 μg/m3

; however, due to EPA’s rounding convention for PM10, a concentration of 154 

μg/m3 would still be considered not exceeding the NAAQS.

Historically, the regular PM10 sampling schedule using manual methods in the Truckee Meadows 

is once every six days,7 with the exception of air pollution episodes when monitoring was 

conducted more frequently. However, more frequent monitoring after the PM10 exceedance in 

January 1999 was not initiated. In accordance with the procedures in Appendix K of 40 CFR 50, 

this single measured exceedance equals six expected exceedances.

In January 2005, another PM10 episode occurred resulting from record snowstorms followed by 

strong temperature inversions. The storms required many applications of road sand that was 

eventually ground into smaller particles and re-entrained by vehicle traffic. The regular PM10

sample day was Sunday, January 16. Because PM10 concentrations were increasing to unhealthy 

levels at two monitoring sites (Reno3 and Sparks sites), additional PM10 sampling began at the 

Galletti site on Friday, January 14. The PM10 concentration on January 14 was 172 μg/m3 and 

everyday sampling, as required by 40 CFR 58.12, continued at this site through the end of 

calendar year 2005 (Table 2-2). Due to the daily sampling of this site, the single measured 

exceedance equals one expected exceedance for 2005.

 

7 “Waivers for PM10 Sampling Frequency”; William F. Hunt, Jr., Director, Emissions, Monitoring, and Analysis Division (MD-14); December 2, 

1997. 

99 00 01 02 03 04 05 06 07 08 09 10 11 12

Expected Exceedance Rate 2.0 2.0 2.0 0.0 0.0 0.0 0.3 0.3 0.3 0.0 0.0 0.0 0.0 0.0

Exceedance Rate Std. 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0 1.0

1st High PM10* 215 109 81 97 108 126 172 106 130 87 93 142 121 100

2nd High PM10* 197 100 74 85 100 90 103 104 108 76 91 77 113 92

PM10 NAAQS** 154 154 154 154 154 154 154 154 154 154 154 154 154 154

0

50

100

150

200

250

0.0

1.0

2.0

3.0

4.0

5.0

6.0

Expected Exceedance Rate

PM10 Concentration (ug/m3) 
PM10 Redesignation Request August 28, 2014 

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Table 2-2 

Galletti Ambient Air Monitoring Data (2005)

Number of Samples Data 

Capture

Concentration (μg/m3) Exceedances

Quarter Valid Possible 1st High 2nd High Measured Expected

Jan - Mar 74 90 0.82 172 153 1 1 

Apr - Jun 88 91 0.97 116 90 0 0 

Jul - Sep 87 92 0.95 91 86 0 0 

Oct - Dec 79 92 0.86 103 102 0 0 

Summary 172 153 1 1 

Per 40 CFR 50, Appendix K, Section 3.1(f), the number of measured and expected exceedances 

is one because: 1) There was only one exceedance in the calendar quarter, 2) everyday sampling 

was initiated and maintained for four calendar quarters, and 3) data capture of at least 75% was 

achieved for each quarter.

As of 2006, there are six PM10 monitoring sites in the Truckee Meadows (Figure 2-1). 

Currently, each monitoring site utilizes the continuous PM10 Beta Attenuation Monitor (BAM) 

method, with the exception of the Reno site, which has an additional manual PM10 method. 

Table 2-3 delineates the timeline and transition dates of the PM10 monitoring methods from 

manual to continuous sampling for each site. 

Table 2-3 

Operational History of PM10 Monitoring Network and Sampling Methods 

Monitoring Site Sampling Method Sampling Frequency AQS Submittal Period

Galletti Manual 1:6 Jan 1990 - Dec 2012

BAM Continuous Dec 2012 - present

Incline Manual 1:6 Oct 1999 - Mar 2002

Plumb-Kit Manual 1:6 Jan 2006 - Nov 2011

BAM Continuous Nov 2011 - present

Reno

Manual 1:6 Apr 1988 - Mar 2009

Manual 1:3 Mar 2009 - present

BAM Continuous Dec 2010 - present

S. Reno Manual 1:6 Jan 1990 - Oct 2011

BAM Continuous Oct 2011 - present

Sparks Designated Manual 1:6 Apr 1988 - Dec 2012

BAM Continuous Dec 2012 - present

Sparks Collocated Manual 1:6 Jan 1990 - Dec 2012

BAM Continuous Dec 2012 - present

Toll Manual 1:6 Jan 2002 - Oct 2011

BAM Continuous Oct 2011- present
PM10 Redesignation Request August 28, 2014 

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Summary

The EPA has determined that the Truckee Meadows is currently attaining the 24-hour PM10

NAAQS, based upon complete, quality-assured PM10 air quality monitoring data during the years 

2007 - 2009.8 Certified data through December 2012 contained in EPA’s AQS are also 

consistent with continued attainment of the 24-hour PM10 NAAQS. 

From 1999 through 2012, PM10 ambient air monitoring data from the Truckee Meadows: 

• Were collected from a PM10 monitoring network that was sited, operated, and maintained 

in accordance with 40 CFR 53 and 58; and 

• Were complete, quality assured, and reported in accordance with 40 CFR 58. 

From 2002 through 2012, PM10 ambient air monitoring data from the Truckee Meadows:

• Demonstrated that the number of times a monitor was expected to exceed a 24-hour PM10

concentration of 150 μg/m3 (as determined in accordance with 40 CFR 50, Appendix K) 

was less than one per year. 

Therefore, the Truckee Meadows has attained the 24-hour PM10 NAAQS in accordance with 40 

CFR 50.6. 

 

8 76 FR 21807 (April 19, 2011).
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 8 

CHAPTER 3

STATE IMPLEMENTATION PLAN APPROVAL

The second condition for redesignation is that the applicable implementation plan requirements 

have been fully approved by the EPA under Section 110(k) of the CAA. 

On November 15, 1990, the date of enactment of the 1990 CAA Amendments, PM10 areas 

meeting the qualifications of Section 107(d)(4)(B) of the CAA were designated non-attainment 

by operation of law. Once an area is designated non-attainment, Section 188 of the CAA 

outlines the process for classification of the area and establishes the area’s attainment date. 

Pursuant to Section 188(a), all PM10 non-attainment areas were initially classified as “Moderate” 

by operation of law upon designation as non-attainment. The Truckee Meadows “Moderate”

non-attainment designation was codified in 40 CFR 81.329 in a Federal Register (FR) notice 

published on November 6, 1991.9

States containing areas, which were designated as “Moderate” non-attainment by operation of 

law under section 107(d)(4)(B), were to develop and submit state implementation plans (SIPs) to 

provide for the attainment of the PM10 NAAQS. Pursuant to section 189(a)(2), those SIP 

revisions were to be submitted to EPA by November 15, 1991. 

EPA has the responsibility, pursuant to sections 179(c) and 188(b)(2) of the Act, of determining 

within six months of the applicable attainment date, whether PM10 NAAs have attained the 

NAAQS. Section 179(c)(1) of the Act provides that these determinations are to be based upon 

an area’s “air quality as of the attainment date”, and section 188(b)(2) is consistent with this 

requirement. EPA makes the determinations of whether an area’s air quality is meeting the PM10

NAAQS based upon air quality data gathered at monitoring sites in the non-attainment area. 

These data are reviewed to determine the area’s air quality status in accordance with EPA 

guidance in 40 CFR 50, Appendix K. 

Pursuant to Appendix K, attainment of the 24-hour standard is determined by calculating the 

expected number of exceedances of the 150 μg/m3 limit per year. The 24-hour standard is 

attained when the number of times a monitor is expected to exceed this concentration is equal to 

or less than one per year. A total of three consecutive years of clean air quality data is generally 

necessary to show attainment of the 24-hour standard for PM10. A complete year of air quality 

data, as referred to in 40 CFR 50, Appendix K, is comprised of all four calendar quarters with 

each quarter containing data from at least 75% of the scheduled sampling days. 

Under section 188(b)(2)(A), a “Moderate” PM10 NAA must be reclassified as “Serious” by 

operation of law after the statutory attainment date if the Administrator finds that the area has 

failed to attain the NAAQS. Pursuant to section 188(b)(2)(B) of the Act, EPA must publish a 

notice in the FR identifying those areas that failed to attain the standard and the resulting 

reclassifications. As a result, the Truckee Meadows was reclassified to a “Serious” NAA on 

February 7, 2001. 

 

9 56 FR 56694 (November 6, 1991).
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 9 

In response to the “Serious” designation, the AQMD prepared a PM10 SIP. The SIP included a 

periodic emission inventory that identified the significant wintertime PM10 sources in the 

Truckee Meadows as construction/grading, street sanding, street sweeping, and residential wood 

combustion (RWC). In “Serious” PM10 NAAs, Best Available Control Measures (BACM) is

required to be applied to these sources. To ensure that BACM is properly applied, the AQMD 

follows EPA guidance, consults with EPA during the rule development process, and participates 

in the EPA Region IX PM10 SIP BACM working group. This group meets twice per year to 

discuss and share knowledge about control measures affecting “Serious” PM10 NAAs in the 

Pacific Southwest. However, no meeting has taken place after 2009. 

The “Serious” PM10 SIP was adopted by the Washoe County District Board of Health 

(WCDBOH) on July 26, 2002 and submitted to EPA on August 5, 2002. Additional SIP 

elements were submitted in 2006 to address deficiencies in the RWC regulation and emergency 

episode plan. EPA has approved many of these submittals, but has not fully approved the PM10

SIP.
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 10

CHAPTER 4

PERMANENT AND ENFORCEABLE IMPROVEMENT IN AIR QUALITY

The third condition for redesignation is EPA must determine that air quality improvements are 

due to permanent and enforceable emission reductions. Long-term air quality improvements in 

the Truckee Meadows are attributed to permanent and enforceable federal, state, and local 

emission reduction programs. In addition, improvements were not a result of temporary 

reduction in emission rates or unusually favorable meteorology. 

Federally Enforceable Control Programs in the Truckee Meadows Portion of the Nevada SIP 

The following programs have significantly reduced PM10 emissions and contributed to the air 

quality improvements in the Truckee Meadows. These programs are federally enforceable and 

included in the Truckee Meadows portion of the Nevada PM10 SIP. They are implemented by 

federal, state, and local regulatory agencies. Emission reductions from the state and local 

programs are summarized in Table 4-1. Detailed documentation is located in Appendix A. 

1. Residential Wood Combustion Program: RWC has been identified as a significant source 

of wintertime PM10 emissions. WCDBOH Regulation 040.05110 addresses and reduces 

these emissions. This regulation: 1) Establishes wood stove / fireplace insert control 

areas; 2) requires use of seasoned wood; 3) clarifies “Prohibited Fuels”; 4) requires 

removing or upgrading existing solid fuel combustion devices upon real estate sale; and 

5) includes a mandatory burning curtailment during Stage 1 episodes. Approximately 

784 lbs/day of PM10 emissions were reduced from the Truckee Meadows in 2011 due to 

the RWC program. 

In addition, the AQMD implements a “Green, Yellow, Red” Program11 from November 

through February to reduce wintertime RWC PM10 emissions. This public outreach 

program consists of a daily burn code that provides the community a recommendation on 

whether RWC will impact air quality in Washoe County. RWC is discouraged when the 

burn code is Yellow and prohibited when the code is Red. As part of the carbon 

monoxide maintenance plan SIP, the AQMD is committed to conducting an RWC survey 

at least once every three years.

12 A recent survey conducted in 2013 indicated 88% of all 

respondents who burned wood were aware of the “Green, Yellow, Red” Program, and

74% of those respondents followed the Yellow and Red recommendations.13 Emission 

reductions from the “Green, Yellow, Red” Program are quantified under the Emergency 

Episode Plan. 

Additional benefits are realized in the Truckee Meadows because the RWC Program is 

applicable to the entire geographic area of Washoe County. 

 

10 72 FR 33397 (June 18, 2007). 11 The “Green, Yellow, Red” was updated and rebranded to “Keep it Clean, Know the Code” in November 2012. 12 73 FR 38124 (July 3, 2008). 13 “Washoe County Health District; Air Quality Management Division; Residential Wood Use Survey”; InfoSearch International; May 2013.
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 11

2. Street Sanding and Sweeping Program: The Truckee Meadows receives approximately 23 

inches of snow per year. Wintertime traction control is a significant source of PM10

emissions. Emissions are generated directly from application of traction control material 

(i.e., sand, salt, and chlorides) and indirectly from the increased silt loading on the paved 

streets. Motor vehicle traffic grinds and re-entrains the material into the atmosphere. 

In 2002, the WCDBOH adopted revisions to Regulations 040.031 and 040.032.14 These 

revisions required municipalities to: 1) Use a harder and cleaner type of sand, 2) reduce 

the sand application rate by 50% compared to 1999 rates, 3) remove the sand within four 

days after a storm event, and 4) only purchase new sweepers that are PM10 certified.

Approximately 1,555 lbs/day of PM10 emissions were reduced in the Truckee Meadows 

in 2011 because of the Street Sanding and Sweeping program. Additional benefits are 

realized in the Truckee Meadows because the Street Sanding and Sweeping Programs are 

applicable to additional geographic areas of Washoe County. This area encompasses all 

of the urbanized portions of Washoe County south of Township 22N, which includes the 

cities of Reno and Sparks. 

3. Dust Control: Fugitive PM10 generating sources, such as construction activities and 

unpaved roads, are subject to WCDBOH Regulation 040.030.15 The current regulation 

implements BACM and was adopted by the WCDBOH in 2002. In addition, projects that 

disturb one acre of more of land are required to obtain a Dust Control Permit from the 

AQMD. The Dust Control permit includes additional control and contingency measures 

that are to be implemented before, during, and after completion of the project. 

Approximately 431 lbs/day of PM10 emissions were reduced in the Truckee Meadows 

because of the Dust Control program. Additional benefits are realized in the Truckee 

Meadows because the Dust Control regulation is applicable to the entire geographic area 

of Washoe County. 

4. Emergency Episode Plan: WCDBOH Regulation 050.00116 addresses actions that the 

AQMD shall take during periods of elevated ambient PM10 concentrations. When 24-

hour PM10 concentrations reach, or are predicted to reach, Stage 1 levels (154 μg/m3

), the 

regulation: 1) Implements notification procedures to the public about potential health 

problems 2) prohibits all open and prescribed burning, 3) prohibits the use of permitted 

incinerators, crematoriums, and pathological incinerators, 4) prohibits the use of solid 

fuel burning devices, and 5) activates control plans for the largest PM10 sources in the 

county. 

Approximately 4,331 lbs/day of PM10 emissions were reduced in the Truckee Meadows 

because of the Emergency Episode Plan. The Truckee Meadows receives additional 

benefits from the Emergency Episode Plan because it is applicable to the entire 

geographic area of Washoe County. 

 

14 71 FR 14386 (March 22, 2006). 15 72 FR 25969 (May 8, 2007). 16 72 FR 33397 (June 18, 2007).
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 12

Table 4-1 

2011 Emission Reductions from Federally Enforceable Programs

Emissions

(lbs / Typical PM10 Season Day)

Federally Enforceable Program Uncontrolled Controlled Reductions 

Residential Wood Combustion 1,784 1,000 784

Street Sanding and Sweeping 1,894 339 1,555

Dust Control 861 431 431

Emergency Episode Plan 5,888 1,557 4,331

Total 10,427 3,327 7,100

* Totals may not add up due to rounding.

Other Programs That Provide Additional PM10 Benefits

The Truckee Meadows also benefits from other PM10 control programs. Although these 

programs are not part of the Truckee Meadows portion of the Nevada PM10 SIP, they contribute 

to air quality improvements in the area. These programs are applicable to the entire geographic 

area of Washoe County.

1. Non-Road Diesel Emission Standards: The Clean Air Non-Road Diesel Rule, which was 

signed in 2004, established stringent Tier 4 PM and Nitrogen Oxides (NOx) emission 

standards. This rule is the most recent of a series of regulations addressing non-road 

diesel emissions. These standards will dramatically reduce PM emissions nationwide as 

the diesel fleet turns over. 

2. Ultra Low Sulfur Diesel (ULSD): The Clean Air Non-Road Diesel Rule, along with the 

2007 Highway Rule, lowers the sulfur content of diesel fuel. All diesel fuel for on-road 

and non-road uses will have a maximum sulfur content of 15 ppm by 2014. 

3. Washoe County Smoke Management Program: Particulate matter is a major component 

of smoke. The AQMD has developed and implemented a Smoke Management Program 

(SMP) to balance the need for forest fuels management while maintaining clean air 

requirements. Major components of the SMP are: 1) Consideration of alternatives; 2) 

stringent meteorological prescriptions; 3) notification procedures; and 4) contingency 

measures. Section C.2.a.(2) of WCDBOH Regulation 050.001 addresses PM10 impacts 

from prescribed burning by prohibiting these projects during Stage 1 air pollution 

episodes. Washoe County’s SMP was adopted by the WCDBOH in 2003 and submitted 

to EPA Region IX in 2006. 
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Economic Conditions 

Between 1990 and 2011, Washoe County, including the Truckee Meadows, experienced growth 

in population, full and part-time employment, total industry earnings, and vehicle miles traveled 

(VMT). Table 4-2 lists these indicators and their overall rate of growth. 

Table 4-2 

Washoe County Demographic and Economic Indicators (1990-2011) 

Indicator Source* 1990 2011 2011/1990 Ratio

Population A 257,120 421,593 1.640

Full- and Part-time Nonfarm Employment B 173,790 244,438 1.407

Total Nonfarm Industry Earnings** C $4,541,507 $11,732,922 2.583

Vehicle Miles Traveled*** D 4,225,134 7,870,307 1.863

* A: Nevada State Demographer, Washoe County Population.

 B: Bureau of Economic Analysis, “CA25N Total full-time and part-time employment for Washoe County”, 1990 

is by SIC industry and 2011 is by NAICS industry. 

 C: Nevada Workforce Informer, Nevada Department of Employment, Training and Rehabilitation, 2011 Annual

Employment and Wages for Washoe County. 

D: 1990 Emission Inventory of Carbon Monoxide, Amended Final; November 2, 1993; 2011 Periodic Emissions 

Inventory; November 2012; Table 1-2.

** Total Industry Earnings are in 2012 Dollars (1,000’s).

*** Vehicle Miles Traveled are in miles per day and represent only the Truckee Meadows PM10 NAA portion of 

Washoe County. 

Washoe County’s air quality continued to improve despite substantial growth in population, 

economic activity, and VMT. Based on these demographic and economic data, long-term 

improvement in Washoe County’s air quality was not due to temporary reductions in emission 

rates.

Meteorological Conditions 

As described earlier, the Truckee Meadows sits in a valley surrounded by mountain ranges. 

Wintertime high-pressure systems are characterized by stable atmospheric conditions, light 

winds, sunny days, and clear, cold nights. Cold nights, combined with local topography, can 

create temperature inversions where a layer of cold air is contained in the valley. Warm air 

above the inversion acts as a lid trapping and concentrating pollutants. The low winter sun angle 

provides only slight warmth deterring the break-up of the inversion without wind or a storm 

front. This wintertime atmospheric condition is the major contributor to the Truckee Meadows 

experiencing its highest PM10 concentrations. 

An indicator of unusually favorable wintertime meteorology is periods of unstable atmospheric 

conditions. Wind, clouds, milder night temperatures, good dispersion, and precipitation 

characterize these unstable conditions. Figure 4-1 displays the annual number of days of 

precipitation of 0.01 inches or greater during the months of November, December, and January. 

The historic normal number of days (18.3) is also included as a reference. These data were 
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recorded at the Reno-Tahoe International Airport.17 Favorable meteorology conditions leading 

to low PM10 concentrations would mean a greater than normal number of precipitation days. 

Wintertime precipitation data indicate that 12 of the 23 years between 1990 and 2012 were above 

the historic normal number of 18.3 precipitation days per year. Of the four years with PM10

exceedances, two were above (1993 and 2005) and two were below (1991 and 1999) the historic 

normal number of precipitation of days. Over the years, the monitored PM10 exceedances and 

expected exceedance rate declined while the number of precipitation days fluctuated above and 

below the historic normal. Therefore, improvements in air quality cannot be solely attributed to 

favorable precipitation conditions. 

Figure 4-1 

Precipitation Days (1990-2012) 

Wind speed is another meteorological indicator for PM10 concentrations. In the Truckee 

Meadows, higher wind speeds typically reflect unstable conditions and favorable PM10

conditions. Figure 4-2 displays the mean wintertime wind speeds from 1990 through 2012. 

Of the 13 years with wind speeds below the historic mean, three years had at least one PM10

exceedance and the other 10 had zero. Because the monitored PM10 exceedances and expected 

exceedance rate declined while the mean wind speed fluctuated above and below the historic 

mean, improvements in air quality cannot be solely attributed to favorable wind speeds. 

 

17 The official site where precipitation, wind speed, and atmospheric pressure data are recorded was relocated three times since 1931. The 

precipitation data collected were from sites located: 1) within a two mile radius of each other; 2) at the same elevation (less than ten feet 

difference); and 3) within the Truckee Meadows PM10 NAA.

90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12

Precipitation Days 15 10 15 20 18 22 30 24 18 12 14 22 20 13 15 25 15 13 26 17 27 5 22

Historic Normal 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18 18

1st High PM10 150 231 146 167 136 82 151 115 125 215 109 81 97 108 126 172 106 130 87 93 142 121 100

PM10 NAAQS 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154

0

50

100

150

200

250

0.0

10.0

20.0

30.0

40.0

50.0

60.0

70.0

80.0

PM10 Concentrations (ug/m3) 

Precipitation Days

(0.01 inches or greater)

Trend Line
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Figure 4-2 

Mean Wind Speed (1990-2012) 

Another indicator of favorable meteorological conditions is barometric pressure. Lower 

pressures are associated with unstable conditions, increased atmospheric mixing, weaker 

temperature inversions, and lower PM10 concentrations. Figure 4-3 displays the mean barometric 

pressures in the Truckee Meadows. Only January and November data were available for 1996 

and 1998. These years are not included in the figure, but the mean pressures for the two months 

of these two years were below the historic mean.

90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12

Wind Speed 5.0 4.4 6.0 6.2 6.2 5.6 6.0 3.7 5.3 4.4 4.8 4.6 5.3 4.5 3.6 4.8 5.6 3.8 4.5 3.3 4.7 3.5 5.1

Historic Mean 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0

1st High PM10 150 231 146 167 136 82 151 115 125 215 109 81 97 108 126 172 106 130 87 93 142 121 100

PM10 NAAQS 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154

0

50

100

150

200

250

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

16.0

18.0

20.0

PM10 Concentrations (ug/m3) 

Mean Wind Speed (mph)

Trend Line
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Figure 4-3 

Mean Station Barometric Pressure (1990-2012) 

Note: blank cells indicate incomplete data for 1996 and 1998; however, partial data indicated both years 

were below the historic mean.

Of the 21 years with complete mean barometric pressure data, 12 years were above and nine 

years were below the historic mean of 25.63 inches of mercury. Eight of the 12 years with 

barometric pressures at or above the historic mean did not have a monitored PM10 exceedance. 

The monitored PM10 exceedances and expected exceedance rate declined over the years while 

the precipitation days, wind speeds, and barometric pressures fluctuated above and below the 

historic averages. Therefore, improvements in air quality cannot be solely attributed to favorable 

meteorological conditions. 

Summary

The Truckee Meadows experienced long-term air quality improvements attributed to federal, 

state, and local control measures. In addition, Washoe County did not experience an economic 

downturn or unusually consistent favorable meteorology. 

90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07 08 09 10 11 12

Mean Station Pr. 25.6 25.7 25.6 25.6 25.6 25.6 25.6 25.7 25.7 25.6 25.6 25.7 25.7 25.7 25.7 25.7 25.6 25.7 25.4 25.7 25.6

Historic Mean 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6 25.6

1st High PM10 150 231 146 167 136 82 151 115 125 215 109 81 97 108 126 172 106 130 87 93 142 121 100

PM10 NAAQS 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154 154

0

50

100

150

200

250

25.30

25.50

25.70

25.90

26.10

26.30

26.50

PM10 Concentrations (mug/m3) 

Mean Station Pressure (inches of Hg)

Trend Line
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CHAPTER 5

SECTION 110 AND PART D REQUIREMENTS

For the purposes of redesignation, all of the general non-attainment area requirements of the 

1990 CAA Section 110 and Part D must be met. 

Section 110 Requirements 

In general, the requirements of Section 110(a)(2) are: 

• The establishment and implementation of enforceable emission limitations;

• The monitoring, compiling, and analyzing of ambient air quality data; 

• Pre-construction reviews and permitting of new and modified major stationary sources; 

• Consulting with and providing for the participation of local governments that are affected 

by the plan; 

• Assurance that the State has the adequate funds and authority to enforce the SIP element 

and the associated regulations; and 

• Permit fees for stationary sources.

Nevada Revised Statute (NRS) 445B.50018 addresses the Section 110(a)(2) requirements by 

authorizing the WCDBOH to implement and administer air quality management programs within 

the boundaries of Washoe County. These programs are managed through the AQMD. The 

AQMD currently consists of 18 allocated full-time staff with an annual budget of $2.2 million. 

Primary funding sources are: 1) Operating permit fees; 2) EPA grants; 3) Nevada DMV funds; 

and 4) the City of Reno, City of Sparks, and County of Washoe County via an inter-local 

agreement with the Washoe County Health District. 

Should the AQMD be unable to meet the Section 110 requirements, NRS 445B.52019 and 

445B.53020 allows the State Environmental Commission to assume jurisdiction over the local air 

quality management program to ensure that the CAA requirements are satisfied. In addition, 

EPA has authority to impose sanctions on a State where EPA “. . . finds that any requirement of 

an approved plan (or approved part of a plan) is not being implemented . . .”.21

 

18 “Establishment and administration of program; contents of program; designation of air pollution control agency of county for purposes of 

federal act; powers and duties of local air pollution control board; notice of public hearings; delegation of authority to determine violations and 

levy administrative penalties; cities and smaller counties; regulation of certain electric plants prohibited”; May 23, 2007. 19 “Commission may establish or supersede county program”. 20 “Commission may assume jurisdiction over specific classes of air contaminants”. 21 1990 CAAA; Section 179 “Sanctions and Consequences of Failure to Attain”.
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Part D Requirements

The 1990 CAA lists the requirements for “Serious” PM10 NAAs in Part D, Subparts 1 and 4, and 

the General Preamble. These requirements were completed, implemented, and submitted to EPA 

by the dates specified in Section 187(a). A summary of these SIP elements is detailed in Table 

5-1. EPA has not taken formal action on these elements. Table 5-1 also describes current 

activities by AQMD to revise and resubmit certain materials previously submitted to EPA based 

on consultation between the AQMD and EPA. In accordance with the Calcagni Memorandum, 

the AQMD requests that EPA simultaneously approve the applicable SIP elements and 

redesignation request.

PM10 NAAs reclassified as “Serious” under section 188(b)(2) of the CAA are required to submit, 

within 18 months of the area’s reclassification, SIP revisions providing for the implementation of 

BACM no later than four years from the date of reclassification. The SIP must also contain, 

among other things, a demonstration that the implementation of BACM will provide for 

attainment of the PM10 NAAQS no later than December 31, 2001 (See CAA sections 188(c)(2) 

and 189(b)). EPA has provided specific guidance on developing “Serious” area PM10 SIP 

revisions in an addendum to the General Preamble to Title I of the Clean Air Act.22

In response to the “Serious” designation, the AQMD prepared a PM10 SIP. The SIP included a 

periodic emission inventory that identified the significant wintertime PM10 sources in the 

Truckee Meadows as construction/grading, street sanding, street sweeping, and RWC. In 

“Serious” PM10 NAAs, BACM is required to be applied to these sources. To ensure that BACM 

is properly applied, the AQMD follows EPA guidance, consults with EPA during the rule 

development process, and participates in the EPA Region IX PM10 SIP BACM working group. 

This group meets twice per year to discuss and share knowledge about control measures 

affecting “Serious” PM10 NAAs in the Pacific Southwest. However, no meetings have taken 

place since 2009. 

The “Serious” PM10 SIP was adopted by the WCDBOH on July 26, 2002 and submitted to EPA 

on August 5, 2002. Additional SIP elements were submitted in 2006 to address deficiencies in 

the RWC regulation and emergency episode plan. EPA has approved many of these submittals, 

but has not fully approved the PM10 SIP.

In order to ensure that the Prevention of Significant Deterioration (PSD) program will become 

fully effective immediately upon redesignation (to replace the Part D new source review 

program), the County must either be delegated the Federal PSD program or make any needed 

modifications to its rules to have the approved PSD program apply to the affected area upon 

redesignation. EPA granted full delegation of the Federal PSD program (40 CFR 52.21) to 

Washoe County in March 2008. 

 

22 59 FR 41998 (August 16, 1994).
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Table 5-1 

Part D Requirements and Actions for the Truckee Meadows PM10 NAA

CAA

Section Requirement Reference

Submitted to 

EPA Comments

172(c)(1) Reasonably 

Available Control 

Measure (RACM)/ 

Reasonably 

Available Control 

Technology 

(RACT)

--- --- BACM subsumes RACM.

172(c)(2) RFP EPA’s General 

Preamble,23

Calcagni 

Memorandum at 

page 6,24 and 

Clean Data 

Policy25

--- Attained the 24-hour PM10

NAAQS in 2002 based on 

ambient air monitoring 

data. Attained the 24-hour 

PM10 NAAQS based on 

EPA’s clean data finding 

for 2007-2009.26

172(c)(3) Emission 

Inventories 

EPA’s General 

Preamble,27

Calcagni 

Memorandum at 

page 6.28

Baseline and 

periodic 

inventories 

submitted at 

various times, 

most recently in 

January 2013. 

The 2011 periodic 

inventory was also used as 

a baseline for the 2011 

attainment inventory and is 

included in Chapter 6, 

Maintenance Plan.

172(c)(4) Identification and 

Quantification

EPA’s General 

Preamble,29

Calcagni 

Memorandum at 

page 6.30

--- N/A

 

23 57 FR 13498, 13564 (April 16, 1992). 24 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.

25 “Clean Data Policy for the Fine Particulate National Ambient Air Quality Standards”; Stephen D. Page, Director, Office of Air Quality 

Planning and Standards; December 14, 2004.

26 76 FR 21807 (April 19, 2011). 27 57 FR 13498, 13564 (April 16, 1992). 28 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.

29 57 FR 13498, 13564 (April 16, 1992). 30 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.
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Table 5-1 (continued) 

Part D Requirements and Actions for the Truckee Meadows PM10 NAA

CAA

Section Requirement Reference

Submitted to 

EPA Comments

172(c)(5) NSR EPA’s General 

Preamble,31

Calcagni 

Memorandum at 

page 6,32

030.500-

030.508,33 and 

Nichols Memo34

April 7, 1994 Lack of approval of NAA 

NSR program not an 

obstacle to redesignation. 

Washoe County’s PSD 

program will become fully 

effective immediately upon 

redesignation, pursuant to 

EPA delegation.

35

172(c)(6) Other Measures as 

Necessary

EPA’s General 

Preamble,36

Calcagni 

Memorandum at

page 6.37

--- N/A

172(c)(7) Compliance with 

Section 110(a)(2) 

NRS 

445B.50038

--- Addressed earlier (first 

page) in this chapter. 

172(c)(8) Equivalent 

Techniques 

EPA’s General 

Preamble39 and 

Calcagni 

Memorandum at 

page 6.40

--- N/A

 

31 57 FR 13498, 13564 (April 16, 1992). 32 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.

33 WCDBOH Regulations Governing Air Quality Management; Section 030.050-030.508, “Federal New Source Review (NSR)”. 34 “Part D New Source Review (part D NSR) Requirements for Areas Requesting Redesignation to Attainment”; Mary D. Nichols, Assistant 

Administrator for Air and Radiation (6101); October 14, 1994.

35 Agreement for Delegation of the Federal Prevention of Significant Deterioration (PSD) Program by the United States Environmental 

Protection Agency, Region 9 to the Washoe County District Health Department, 3/13/08.

36 57 FR 13498, 13564 (April 16, 1992). 37 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.

38 “Establishment and administration of program; contents of program; designation of air pollution control agency of county for purposes of 

federal act; powers and duties of local air pollution control board; notice of public hearings; delegation of authority to determine violations and 

levy administrative penalties; cities and smaller counties; regulation of certain electric plants prohibited”.

39 57 FR 13498, 13564 (April 16, 1992). 40 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.
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Table 5-1 (continued) 

Part D Requirements and Actions for the Truckee Meadows PM10 NAA

CAA

Section Requirement Reference

Submitted to 

EPA Comments

172(c)(9) Contingency 

Measures

EPA’s General 

Preamble,41

Calcagni 

Memorandum 

at page 12,42

and Clean Data 

Policy

(Maintenance 

plan 

contingency 

measures 

supersede the 

172(c)(9) 

attainment 

contingency 

measure 

requirement.)

Attained the 24-hour 

PM10 NAAQS in 2011 

based on ambient air 

monitoring data. Attained

the 24-hour PM10

NAAQS based on EPA’s

clean data finding for 

2007-2009. 

176(c) Conformity --- March 21, 2013 No EPA action. Lack of 

approval not an obstacle 

to redesignation.

189(a)(1)(A) NSR 030.500-

030.50843 and 

Nichols Memo 

April 7, 1994 No EPA action. Lack of 

approval not an obstacle 

to redesignation. 

189(a)(1)(B) Demonstration of 

Attainment or 

Impracticality

Clean Data 

Policy

--- Attained the 24-hour 

PM10 NAAQS in 2011 

based on ambient air 

monitoring data. Attained

the 24-hour PM10

NAAQS based on EPA’s 

clean data finding for 

2007-2009. 

189(a)(1)(C) RACM --- --- BACM subsumes RACM.

 

41 57 FR 13498, 13564 (April 16, 1992). 42 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.

43 WCDBOH Regulations Governing Air Quality Management; Section 030.500-030.508, “Federal New Source Review (NSR)”.
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Table 5-1 (continued) 

Part D Requirements and Actions for the Truckee Meadows PM10 NAA

CAA

Section Requirement Reference

Submitted to 

EPA Comments

189(b)(1)(A) Attainment 

Demonstration

Clean Data 

Policy

--- Attained the 24-hour 

PM10 NAAQS in 2011 

based on ambient air 

monitoring data. Attained

the 24-hour PM10

NAAQS based on EPA’s 

clean data finding for 

2007-2009. 

189(b)(1)(B) BACM 010.117,44

040.005,45

040.030,46

040.031,47

040.032,48 and 

040.05149 

Various times 

from 2002 

through 2006. 

Adopted BACM for dust 

control, street sanding, 

street sweeping, and 

residential wood 

combustion. 

189(c) Milestones EPA’s General 

Preamble,50

Calcagni

Memorandum at 

page 6,51and 

Clean Data 

Policy 

--- Attained the 24-hour 

PM10 NAAQS in 2011 

based on ambient air 

monitoring data. Attained

the 24-hour PM10

NAAQS based on EPA’s 

clean data finding for 

2007-2009. 

189(e) PM10 Precursors 2011 periodic 

emissions 

inventory and 

attainment of 

the NAAQS

N/A No Major sources of 

direct PM10 or PM10

precursor emissions (NOx, 

SOx, or VOC) sources in 

the Truckee Meadows 

NAA.

 

44 72 FR 33397 (June 18, 2007). 45 72 FR 33397 (June 18, 2007). 46 WCDBOH Regulations Governing Air Quality Management, Section 040.030, “Dust Control”. Submitted to EPA August 2002. 47 71 FR 14386 (March 22, 2006). 48 71 FR 14386 (March 22, 2006). 49 72 FR 33397 (June 18, 2007). 50 57 FR 13498, 13564 (April 16, 1992). 51 “Procedures for Processing Requests to Redesignate Areas to Attainment”; John Calcagni, Director; Air Quality Management Division (MD15); September 4, 1992.
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CHAPTER 6

MAINTENANCE PLAN

Pursuant to the Calcagni Memorandum and Section 107(d)(3)(E) of the CAA, the EPA must 

fully approve a maintenance plan, including a contingency plan, which meets the requirements of 

Section 175A. This maintenance plan meets these requirements by including the following core 

provisions to ensure maintenance of the 24-hour PM10 NAAQS. 

• Attainment Inventory;

• Maintenance Demonstration;

• Motor Vehicle Emissions Budget;

• Monitoring Network; 

• Verification of Continued Attainment; and

• Contingency Plan. 

In accordance with Section 175A(b) of the CAA, the AQMD will prepare and submit another 

maintenance plan eight years after this redesignation/maintenance plan is approved. The purpose 

of this revision is to provide for maintenance of the 24-hour PM10 NAAQS for an additional ten 

years following the first 10-year period. 

Attainment Inventory

According to the Calcagni Memorandum, “The State should develop an attainment emissions 

inventory to identify the level of emissions in the area which is sufficient to attain the NAAQS.” 

Since 1990, the AQMD has been compiling PM10 emissions inventories on a triennial schedule 

with the most recent inventory prepared for 2011. These inventories were prepared using EPA 

guidance and models. 

Below is a summary of procedures used to ensure that PM10 emissions were calculated and 

apportioned accurately for the Truckee Meadows. Complete documentation is included in 

“Washoe County, Nevada 2011 Periodic Emissions Inventory”. 

Point Sources: Latitude/Longitude coordinates are maintained for each point source. 

Geographic Information Systems (GIS) software was used to overlay HA 87 onto all 

point sources to determine if it was to be included in the Truckee Meadows PM10

emissions inventory. 

Nonpoint Sources: Nonpoint sources with an AQMD operating permit are managed in the 

emissions inventory as if it were a point source (see above). Other nonpoint sources are 

grouped by Source Classification Code (SCC) and assigned a surrogate, which is 

spatially representative of that process. Typical surrogates are population, dwelling units, 

employment, and VMT. Surrogates are spatially disaggregated into a variety of 

geographies such as census areas (blocks, block groups, and tracts), Transportation 

Analysis Zones (TAZ), and ZIP codes. GIS is used to determine what portion of each 
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surrogate is included in HA 87. This fraction is applied to county-level emissions for 

each SCC emissions to determine Truckee Meadows PM10 emissions.

Non-Road Mobile Sources: Non-Road Mobile Sources are grouped by SCCs and 

assigned a surrogate which is spatially representative of that process. Surrogate fractions 

are applied to county-level emissions for each SCC emissions to determine Truckee 

Meadows PM10 emissions.

On-Road Mobile Sources: The Metropolitan Planning Organization (MPO) manages the 

regional transportation demand model. The model includes planning assumptions, such 

as population and VMT, for each TAZ in the county. GIS software was used to overlay 

HA 87 onto all TAZs to determine if it was to be included in the Truckee Meadows PM10

emissions inventory. Data from TAZs within HA 87 were combined and incorporated 

into the MOVES model to calculate on-road mobile source PM10 emissions. 

As discussed earlier in Chapter 2, the Truckee Meadows attained the 24-hour PM10 NAAQS in

2002. Because air quality improvements were a result of the SIP, any periodic emissions 

inventory from 2002 to 2011 could represent the attainment inventory. This is consistent with 

the Calcagni Memorandum, which indicated that “any emission inventories available at the time 

and including the emissions during the time period associated with the monitoring data showing 

attainment” can be used to represent the attainment inventory. Therefore, the 2011 emissions 

inventory (Table 6-1)52 is identified as the attainment inventory because it used the best and 

updated methodologies for all sources, and it has the most comprehensive and current emission 

inventory that is sufficient to attain the NAAQS. 

 

Table 6-1 

2011 PM10 Attainment Inventory (lbs/day) 

Category

2011 

Attainment Inventory 

Point Sources 25 

Nonpoint Sources 22,812 

Non-Road Mobile 606 

On-Road Mobile 1,183 

Total* 24,626 

 * Totals may not add up due to rounding.

Maintenance Demonstration

Maintaining the PM10 NAAQS may be demonstrated by showing that future emissions will not 

exceed the level of the attainment inventory. Also, attainment must be demonstrated for the 10-

 

52 Washoe County, Nevada; 2011 Periodic Emissions Inventory; November 2012; Table 1-4.
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year period following EPA’s approval action on the redesignation request. The final year of this 

maintenance demonstration is 2030. 

Truckee Meadows Maintenance Emissions Limit

The 2011 periodic emissions inventory53 was used as a baseline to develop a maintenance 

emissions limit for the Truckee Meadows. This limit is the level considered to be 

sufficient to ensure continued attainment of the NAAQS in future planning years. 

Growth and control factors were applied to many of the emission categories of the 2011 

inventory to generate a 2030 Truckee Meadows emissions budget. The growth factors 

were based on demographic, economic, VMT, and meteorological data (Appendix B, 

Table B-2), and the control factors were based on planned emission reduction strategies. 

Several PM10 categories were recalculated because they were either significant (i.e., 

paved roads and RWC) or had models available that could provide specific year 

emissions (i.e., non-road and on-road motor vehicles). 

2011 was an unusually high emission year for wildfires during the PM10 season. To 

approximate a more normal wildfire emission during the PM10 season, an average of the 

four previous inventory years’ (1999, 2002, 2005, and 2008) wildfire emissions were 

used for planning year projections (Table 6-2). The rationale is that wildfire emission 

alone should not drive future year planning purposes. Future large scale wildfires during 

PM10 season will be treated as exceptional events and will be submitted to the EPA for 

exclusion when they occur. 

Table 6-2 

Historic Truckee Meadows PM10 Wildfire Emission Inventories (lbs/day) 

Inventory Year PM10 Emissions 

1999 19

2002 40

2005 10

2008 15

2011 10,947

Average (1999-2008) 21

Average (1999-2011) 2,206

The 2011 Truckee Meadows PM10 maintenance emissions limit was established at 13,700 

lbs/day (Table 6-3).

 

53 See Appendix C. Washoe County, Nevada; 2011 Periodic Emissions Inventory and Appendices A, B, C
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 26

Table 6-3 

Truckee Meadows PM10 Emission Inventories (lbs/day) 

2011 2011 

Source Category Periodic Inventory Maintenance Emission Limit

Point 25 25

Nonpoint 22,812 11,885

Non-Road Mobile 606 606

On-Road Mobile 1,183 1,183

Total* 24,626 13,700 

* Totals may not add up due to rounding.

The 2011 Truckee Meadows maintenance emission limit satisfies Condition 5.a of the 

Calcagni Memorandum because it:

• Uses the most accurate emissions inventory methodologies; 

• Is a comprehensive and current emissions inventory; 

• Identifies the level of emissions in the Truckee Meadows sufficient to attain the 

NAAQS; and 

• Will be the emissions inventory most consistent with the 2030 projected inventory 

required for demonstrating maintenance of the NAAQS.

Maintenance of the NAAQS

The projected 2030 emissions inventory used the 2011 Truckee Meadows Maintenance 

Emissions Limit as its baseline. Each of the emission categories in the 2011 Truckee 

Meadows Maintenance Emissions Limit (Appendix C) were projected to 2030 levels 

using one of the following EPA emission methodologies or models.54

1. Baseline Emission Projections: Washoe County’s 2030 population, dwelling units, 

employment, and VMT forecasts (Appendix B, Table B-2) were used as surrogates to 

project the 2030 emissions. These forecasts were consistent with those used by the 

local MPO.

2. EPA Models: The non-road and on-road motor vehicle categories accounted for 

approximately 6% of the 2011 Truckee Meadows emissions budget. To ensure 

consistency throughout the maintenance demonstration period, the same non-road and 

on-road models (NONROAD2008a and MOVES2010b) were used to estimate the 

2030 inventory. 

The 2030 on-road vehicles category incorporated the latest planning assumptions for 

the transportation network including VMT and vehicle speeds. As with previous 

 

54 “Procedures for Preparing Emissions Projections” (EPA-450/4-91-019).
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 27

periodic emission inventories, these planning assumptions were consistent with those 

used by the MPO for their transportation plans. 

3. Emission Category Surveys: Residential wood combustion is a significant source of 

PM10 emissions. The RWC category is updated on a regular basis via an emission 

category survey. As part of the carbon monoxide maintenance plan SIP, the AQMD 

is committed to conducting this survey at least once every three years.55

Table 6-5 lists the 2011 Truckee Meadows Maintenance Emission Limit and the 2015, 

2020, 2025, and 2030 projected emissions for the four major PM10 emission categories. 

A more detailed inventory can be found in Appendix C. 

Table 6-4 

Truckee Meadows PM10 Maintenance Emission Inventories (lbs/day)

Category 2011* 2015 2020 2025 2030

Point Sources 25 28 32 37 42 

Nonpoint Sources 11,885 11,510 11,379 11,361 11,512 

Non-Road Mobile 606 501 386 328 307 

On-Road Mobile 1,183 953 839 828 883 

Total** 13,700 12,992 12,637 12,554 12,744 

* Truckee Meadows Maintenance Emissions Limit. 

** Totals may not add up due to rounding.

Summary

Population, households, employment, and VMT are projected to increase through 2030 

and beyond. Federally enforceable PM10 control programs targeting RWC, dieselpowered motor vehicles, and diesel fuel will help offset this growth. Because future 

emissions are not projected to exceed the level of the 2011 Truckee Meadows 

maintenance emissions limit, the 24-hour PM10 NAAQS will be maintained through the 

attainment demonstration period. 

Although more stringent control strategies will be in place for RWC, direct PM10 and 

PM10 precursor emissions from RWC are likely to increase on cold winter nights. Their 

proportion of the entire inventory is also likely to increase. If PM10 concentrations 

approach the 24-hour NAAQS, Washoe County’s emergency episode plan56 is activated 

and includes a mandatory curtailment. A recent survey indicated that this program 

reduces RWC emission 74% during Stage I alerts.57 This contributes to a 22% reduction 

of total PM10 emission for the Truckee Meadows for the horizon year of 2030. 

 

55 73 FR 38124 (July 3, 2008). 56 72 FR 33397 (June 18, 2007). 57 “Washoe County Health District; Air Quality Management Division; Residential Wood Use Survey”; InfoSearch International; May 2013.
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 28

Motor Vehicle Emissions Budget 

Transportation conformity is required by Section 176(c) of the CAA. Under EPA’s 

transportation conformity regulations,58 transportation plans and improvement programs must be 

consistent with, or conform to, the motor vehicle emissions budget (MVEB) defined in the 

applicable SIP. These budgets specify the level of on-road motor vehicle emissions that are 

consistent with attainment and maintenance of air quality standards and should include an 

adequate safety margin.59

Emissions inventory data for the years 2015 through 2030 were used to establish the MVEB. 

The MVEB includes road construction fugitives, paved road fugitives, unpaved road fugitives, 

on-road vehicles, diesel idling, and a safety margin. The safety margin is the excess emissions 

between the total projected emissions for a specific year and the 2011 maintenance emissions 

limit (Table 6-5). 

Table 6-5 

Truckee Meadows PM10 Safety Margin (lbs/day)

Category 2015 2020 2025 2030 

2011 Maintenance Emissions Limit 13,700 13,700 13,700 13,700 

PM10 Maintenance Emissions Inventory* 12,992 12,637 12,554 12,744 

Safety Margin 708 1,063 1,146 955 

* Projected 2015, 2020, 2025, 2028, and 2030 emission inventories from Table 6-4.

The MVEB is set at a level that keeps the intermediate (2015, 2020, and 2025) and horizon 

(2030) year Truckee Meadows emissions less than the 2011 Truckee Meadows maintenance 

emissions limit. For years beyond 2030, the MVEB will remain at the 2030 level of 6,927 

bs/day (Table 6-6). 

Table 6-6 

Truckee Meadows PM10 MVEB (lbs/day) 

Category 2015 2020 2025 2030 

Road Construction 183 189 185 180 

Paved Roads - Fugitives 1,414 1,517 1,627 1,736 

Unpaved Roads - Fugitives 2,380 2,479 2,688 3,174 

On-Road Vehicles 946 835 825 880 

Diesel Idling 7 4 3 3 

Safety Margin 708 1,063 1,146 955 

Motor Vehicle Emissions Budget 5,638 6,088 6,473 6,927 

 

58 40 CFR 93. 59 Safety margin means the amount by which the total projected emissions from all sources of a given pollutant are less than the total emissions 

that would satisfy the applicable requirement for reasonable further progress, attainment, or maintenance. (40 CFR 93.101)
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 29

Monitoring Network 

Once the Truckee Meadows has been redesignated to an 

attainment/maintenance area, the AQMD will continue to operate 

an appropriate PM10 monitoring network, in accordance with 40 

CFR 58, to verify the attainment status of the area. In addition, 

Washoe County’s PM10 monitoring network will be reviewed 

annually pursuant to 40 CFR 58.10 to ensure the network meets 

the monitoring objectives defined in 40 CFR 58, Appendix D. 

Funding to meet these objectives has, and will be, primarily 

obtained from: 1) EPA Section 105 grants, and 2) Nevada 

Department of Motor Vehicles funds. 

Ambient PM10 monitoring data will be collected and quality 

assured in accordance with 40 CFR 58, recorded in the AQS, and 

will be available for public review. Figure 6-1 features the South 

Reno monitoring site as an example, and Figure 2-1 is a map of 

all current PM10 monitoring sites in Washoe County. 

Verification of Continued Attainment 

As described in the previous section, the AQMD will continue to operate and maintain an 

appropriate PM10 monitoring network. Ambient air monitoring data will be used to verify 

attainment and maintenance of the 24-hour PM10 NAAQS.

Tracking actual emissions can identify potential increases in ambient PM10 levels. The AQMD 

has three existing mechanisms to track emissions. These mechanisms, listed below, will remain 

in place and be used to screen for significant increases in actual PM10 emissions. 

1. Periodic Emissions Inventories: The AQMD will continue to prepare, and submit to EPA, 

comprehensive periodic PM10 emissions inventories via the Emissions Inventory 

Gateway on a triennial schedule. The last periodic emissions inventory was prepared for 

calendar year 2011. 

2. Consolidated Emissions Reporting Rule (CERR) and Air Emissions Reporting Rule 

(AERR): The CERR and AERR simplify and streamline emissions reporting 

requirements. It requires regular updates of point and area sources within Washoe 

County. The AQMD will continue to meet the requirements of the CERR and AERR. 

3. Residential Wood Use Survey: Residential wood combustion is a significant PM10 source 

during the winter season. The AQMD has completed nine residential wood use surveys 

between 1993 and 2013. These surveys estimated the device (fireplaces, woodstoves, 

and pellet stoves) population, amount of wood burned, and PM10 emissions in Washoe 

County. As part of this maintenance plan, as well as the carbon monoxide maintenance 

plan,60 the AQMD is committed to conducting this survey at least once every three years. 

 

60 73 FR 38124 (July 3, 2008).

Figure 6-1

South Reno Monitoring Site
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 30

Furthermore, the AQMD’s Enforcement Branch will continue to enforce the permanent and 

enforceable programs addressed in Chapter 4. Currently, the Enforcement Branch consists of 

five inspectors to ensure compliance with local air quality regulations. They inspect for permit 

conditions, respond to complaints (dust and permit), patrol and enforce no-burn days during the 

burn season, and issue warnings and citations for any violations found. 

When no-burn days are issued, the enforcement staff will patrol neighborhoods for visible smoke 

from chimneys. They also respond to complaints from neighbors of the home owners who are 

burning their wood burning devices during a no-burn day. They will order the home owner to 

stop burning immediately and issue the home owner a warning for the first offense. Then they 

will return three to four hours later to ensure that the smoke has ceased to be emitted from the 

chimney. If the smoke continues, the home owner would then be issued a citation. 

To ensure an effective Street Sanding and Sweeping Program (DBOH regulations 040.031 and 

040.032), the AQMD holds working group meetings twice a year. The street sanding and 

sweeping working group is made up of public works road department personnel from all the 

municipalities. It meets twice a year (once in Fall, before snow fall, and once in Spring) to share 

information on sweeping/sanding equipment and discuss sanding and sweeping related issues. 

As part of the enforcement and compliance component of the program, each jurisdiction is 

required to submit its sanding and sweeping report on an annual basis (July to June), which 

included such information as date of each storm event, amount of sand and salt or brine applied 

to roadways, as well as the sand pick up date after each storm event. 

There is a gradual shift over the last several years from sand to more brine solutions for roadway 

deicing. The shift was in part due to the proactive approach taken by the jurisdictions to apply 

the brine solutions before an impending storm to prevent accidents. In doing so, it also saves 

vehicle fuel, reduces emissions, and lowers the need for manpower and time associated with sand 

removal after a storm event.

Continued ambient air monitoring, emissions tracking, and enforcement will ensure verification 

of continued attainment and maintenance of the 24-hour PM10 NAAQS.

Contingency Plan 

Section 175A of the CAA requires that a maintenance plan include contingency provisions, as 

necessary, to promptly correct any violation of the PM10 NAAQS that occurs after redesignation 

of the area. The plan should clearly identify: 

• Specific indicators, or triggers, which will be used to determine when contingency 

measures need to be implemented;

• The contingency measures to be adopted; 

• A schedule and procedure for adoption and implementation; and 

• A specific time limit for action.

The typical PM10 season in the Truckee Meadows is November, December, and January. This is 

when the highest ambient PM10 concentrations, and possible exceedances, are most likely to 
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 31

occur. If monitoring data indicate a PM10 violation, then Contingency Plan “A” begins control 

measure development and implementation. 

Contingency Plan “A” 

Trigger Mechanism “A”: A violation of the 24-hour PM10 NAAQS verified from any 

SLAMS, Special Purpose Monitor (SPM), or NCore site operated by the AQMD. 

Violation of the NAAQS is defined as when the expected number of days per calendar 

year with a 24-hour concentration above 150 μg/m3

, as determined in accordance with 40 

CFR 50, Appendix K, is greater than one. 

Contingency Measure “A”: The AQMD will maintain a list of potential contingency 

measures and provide recommendations for implementation to the WCDBOH. 

Recommendations to the WCDBOH shall occur at their next regularly scheduled 

meeting, but no later than 45 days after reaching Trigger Mechanism “A” levels. The 

recommendations will also include a timeline for adoption and implementation. 

Contingency measures recommended to the WCDBOH shall be adopted and 

implemented as promptly and expediently as possible. Any rule revision should be 

adopted and implemented before the next PM10 season (November, December, and 

January). Prompt action and implementation of contingency measures may prevent 

future exceedances and violations of the PM10 NAAQS.

The list of potential contingency measures will concentrate on the significant emission 

categories impacting PM10 season emissions. Table 6-7 summarizes the current list. 

Because of changes in growth and technology, the effectiveness of each measure may 

vary over time. A triennial review and reprioritization of the measures in coordination 

with the periodic PM10 emissions inventory should be adequate to anticipate the need for 

additional emission reductions. In addition, the EPA Regional Office will be notified 

within 30 days of implementation of Contingency Measure “A”. 
PM10 Redesignation Request August 28, 2014 

and Maintenance Plan 32

Table 6-7 

Potential PM10 Contingency Measures 

Emission Category Potential Contingency Measure 

Paved Streets • Increase stringency of street sanding and sweeping programs

• Improve unpaved shoulders 

• Transportation control measures to reduce VMT 

Unpaved Streets • Improve unpaved streets and shoulders

• Post speed limits to decrease vehicle speeds

• Restrict access to decrease Average Daily Trips (ADT) and VMT 

Dust Control • Phased mass grading

• Mass grading allocation system

• Stabilize projects during PM10 season

• Decrease one acre dust control permit exemption

Residential Wood 

Combustion 

• Increase one acre lot size exemption

• Mandatory curtailment at lower PM10 concentrations 

• Change-out program to cleaner burning device

Mobile Sources 

(Diesel)

• Non-road & on-road diesel engine repowers and rebuilds

• Non-road & on-road diesel tailpipe controls (i.e., filters and 

catalysts)

• Truck Stop Electrification systems for heavy-duty vehicles 

• More stringent heavy-duty diesel vehicle idling limits

• Fleet modernization

• More stringent inspection & maintenance program of light-duty, 

medium-duty, and heavy-duty vehicles 

Summary

The AQMD contingency plan meets Condition 5.e of the Calcagni Memorandum by 

promptly and expediently addressing future exceedances of the PM10 NAAQS with 

clearly defined trigger mechanisms, contingency measures, adoption schedules, and 

implementation schedules.
Appendix A 

Permanent and Enforceable Reduction Calculations 
Appendix A.1 – Quantification of RWC Program

The 2011 PM10 emission reductions from Washoe County’s RWC program are summarized 

below. 

 Methodology: 

1. The emission reductions were determined by applying the difference between the 

uncertified (30.6 lbs/ton) and certified (17.15 lbs/ton) woodstove emission factors 

to the certified woodstove activity level (6,630 [NAA] and 14,051 tons [County]). 

 Assumptions: 

1. Washoe County’s RWC program is responsible for 100% of the certified 

woodstoves/inserts within Washoe County. Without this program, all 

woodstoves/inserts in Washoe County would be uncertified. 

 

References:

1. Activity levels, SAF, days per week, emission factors, and PM fractions from 

Washoe County, Nevada’s 2011 Periodic Emissions Inventory; “2011 RWC Em 

projected from 2009-10 RWC survey.xlsx”. 

The same methodology and assumption were also used to determine CO and PM2.5 emission 

reductions. 

Activity Level and Emission Factors – Certified Woodstoves/Inserts

Emission Factor*

(lbs/ton of wood burned)

Area

Tons of

Wood Burned CO PM10 PM2.5

HA 87 6,630 71.5 13.45 13.45

County 14,051 71.5 13.45 13.45

Emission Benefits – Certified Woodstoves/Inserts

Emission Reductions

(lbs/typical PM10 season day)

Area CO PM10 PM2.5

HA 87 4,167 784 784

County 8,832 1,662 1,662

* Difference between uncertified and certified woodstoves/inserts.
Appendix A.2 – Quantification of Street Sanding and Sweeping Programs

The 2011 PM10 emission reductions in the Truckee Meadows from Washoe County’s street 

sanding and sweeping programs are summarized below. 

 1999 emissions = 1,894 lbs/day 

 2011 emissions = 339 lbs/day 

 2011 emission reductions = 1,555 lbs/day 

 Methodology: 

1. The emission reductions were determined by the difference between the 1999 and 

2011 emission inventories. 

 Assumptions: 

1. The 1999 emissions inventory assumed no controls. 

2. The 2011emissions inventories assumed full implementation of WCDBOH 

Regulations Governing Air Quality Management Sections 040.031 and 040.032. 

3. Weather conditions in 1999 were similar to 2011. 

 

References:

1. PM10 “Serious” SIP submittal, Section V, Control Strategies, pages 12-16, August 

2002. 

2. Washoe County, Nevada; 1999 Emissions Inventory for Particulate Matter; Table 

3-4. 

3. Washoe County, Nevada; 2011 Periodic Emissions Inventory; Table 3-4. 
Appendix A.3 – Quantification of Dust Control Program

The 2011 PM10 emission reductions from Washoe County’s Dust Control program are 

summarized below. 

 2011 controlled emissions = 430.5 lbs/day 

 2011 uncontrolled = 2 x 430.5 lbs/day = 861 lbs/day 

2011 emission reductions = 430.5 lbs/day 

 Methodology: 

1. Activity level and emission factors obtained from Table 3-10 of the 2011 Periodic 

Emissions Inventory.

2. Emission calculations same as those used for the 2011 inventory with the 

exception of control efficiency. Control efficiency used is the difference between 

uncontrolled (0%) and controlled (50%) efficiencies.

 Assumptions: 

1. Washoe County’s dust control program is responsible for the 50% control 

efficiency used in the periodic emissions inventory calculations. 

 

References:

Washoe County, Nevada; 2011 Periodic Emissions Inventory; Table 3-10. 
Appendix A.4 - Quantification of the Emergency Episode Plan

The 2011 PM10 emission reductions in the Truckee Meadows from Washoe County’s street 

emergency episode plan are summarized below.

1) RWC

 2011 PM10 RWC emissions = 5,888 lbs/day 

 2011 PM10 RWC emission from emergency episode = EMRWC x [1-(RP)(RE)(CE)]

= (5,888)[1-(0.85)(0.86)(1.00)] = 1,584 lbs/day 

2011 PM10 RWC emission reductions from emergency episode = 4,304 lbs/day 

2) Prescribed Burnings

2011 PM10 emissions from prescribed burning = 0 lbs/day 

2011 PM10 prescribed burning emission reductions from emergency episode = 0 lbs/day 

3) Open/Permit Burns 

2011 PM10 emissions from open/permit burns = 18 lbs/day 

2011 PM10 open/permit burns emission reductions from emergency episode = 18 lbs/day 

4) Human/Animal Cremation

2011 PM10 emissions from human/animal cremation = 9 lbs/day

2011 PM10 human/animal cremation emission reductions from emergency episode = 9 

lbs/day 

5) Total Emission Reductions = (4,304 + 0 + 18 + 9) lbs/day = 4,331 lbs/day 

 Methodology: 

1. The emission reductions for RWC were determined by applying rule effectiveness 

(RE), rule penetration (RP), and a control efficiency (CE) to the RWC category. 

2. The emission reductions for the other categories are enforced by Health District 

regulations, which included mandatory no burn days during episodic events. 

 Assumptions: 

1. For the RWC emission reduction: RP = 0.85, RE = 0.86, and CE = 1.00. 

 

References:

1. Washoe County, Nevada; 2011 Periodic Emissions Inventory; Table 3-4. 

2. “Washoe County Health District, Air Quality Management Division, Residential 

Wood Use Survey”; InfoSearch International; May 2010. 
Appendix B 

Growth Factors for Emission Projections
Appendix B.1 – Growth Factors for 2015, 2020, 2025, and 2030 Projections 

Appropriate and reasonable growth and control assumptions ensure that planning emissions for 

2015 through 2030 are realistically projected. Control factors were developed based on historic 

data and reasonable assumptions. 

Growth and control factors for each emission category are listed in Table B-1. Detailed data for 

the growth factors are further listed in Table B-2. 

Portions of the growth factors are based on various data from the Washoe County Consensus 

Forecast, used by the MPO in the development of its 2035 Regional Transportation Plan (RTP), 

provided in 5-year increment.

The historic climatic data were obtained from the National Oceanic and Atmospheric Agency, 

with future data based on 30-year normal averages between 1980 and 2010. 
Table B-1 – Growth & Control Factors used for Truckee Meadows PM10 Emissions Projection

Major 

Category Sub-Category

Growth 

Surrogate(s) Control Factor(s)

POINT SOURCES

Geothermal POP None

Printing EMP None

Airports & Heliports

GSE AP None

Military Aircraft UNI None

Commericial Aircraft AP None

Gen Aviation - piston AP None

Gen Aviation - turbine AP None

Air Taxi - piston AP None

Air Taxi - turbine AP None

APU AP None

Buffer Zone POP&EMP None

NONPOINT SOURCES

Stationary Source Fuel Combustion

Industrial Fuel Combustion EMP None

Com/Inst Fuel Combustion EMP None

Res. Fuel Combustion HH&HDD None

Res. Wood Combustion

Fireplaces HDD No new solid fuel device is allowed w/in HA87, unless the property has ≥ 1 acre. 

Since not many parcels w/in HA87 are ≥ 1 acre, assumed that no new FPs will 

be installed. Also assumed that 1%/year of wood FPs will be replaced with gas 

FPs.

Woodstoves/Inserts

Non-certified HDD No new non-certified WS allowed. Older stoves being removed upon real estate 

transaction. Assumed future replacement apportionment of 75% Phase II WS, 

20% Pellet stoves, and 5% gas FPs. Replacement % derived from historic data 

for Ph II WS & PS.

Certified, Phase 1 HDD No new Phase I WS allowed. Older stoves gradually being removed due to 

age. Assumed 5% reduction per year.

Certified, Phase 2 Growth&HDD 

Pellet Stoves Growth&HDD 

Industrial Processes

Chemical Manufacturing EMP None

Commercial Cooking POP None

Food & Kindred Products - Manufacturing EMP None

Mineral Processes EMP None

Rubber/Plastic Processes EMP None

Fabricated Metals EMP None

Construction - Stationary

Road Construction* PGR None

Residential Dust Projects (Non-Road 

Const.) PGR None

Commercial Dust Projects (Non-Road 

Const.) EGR None

Asphalt, Sand and Gravel, Abrasive 

Blasting EGR None

Machinery EMP None

Mining and Quarrying - Stationary EMP None

Miscellaneous Industrial Processes EMP None

Solvent Utilization

Architectural Coatings HH None

Auto Refinishing EMP None

Wood Furniture EMP None

Paper EMP None

Plastic Products EMP None

Machinery & Equipment EMP None

Electronic & Other Electrical EMP None

Misc. Manufacturing EMP None

Other Solvent Utilization

Degreasing EMP None

Dry Cleaning EMP None

Graphic Arts EMP None

Misc. Industrial Processes EMP None

Misc. Commercial Processes EMP None

Misc. Consumer/ Com. Solv. EMP None

Cutback Asphalt Application EMP None
Emulsified Asphalt Appl. EMP None

Pesticide, Fungicide & Rodenticide EMP None

Storage and Transport

Gas Service Station EMP None

Organic Chemical Storage EMP None

Waste Disp/Treat/Recovery

Commercial/Industrial Incineration EMP None

Publicly Owned Treatment Works POP/HH None

Remediation/Reclamation/ Recycle EMP None

Misc. Non-Point Sources

Paved Road Fugitive Emissions* VMT(RTP) 

Paved Road Fugitive Emissions, Sanding & Salting SNO Sand:Salt ratio shifted over the years. Based on historic data, anticipate 15% 

reduction in sand usage per year.

Unpaved Road Fugitive Emissions* LVMT Assumed 2.6% per year of all future unpaved roads to be paved based on WC 

historic averages from 1985 - 2011 and past EI unpaved:paved road ratio.

Dirt Road Fugitive Emissions - -

Wildfires UNI None

Structure Fires UNI None

Motor Vehicle Fires UNI None

Firefighting Training UNI None

Open/Permit Burning UNI None

Prescribed Burning UNI None

Refuse Fires UNI None

Auto & Misc. Repair Shops POP None

Health Services, Hospitals POP None

Essay Labs EMP None

Human & Animal Cremation POP None

NON-ROAD MOBILE SOURCES

CNG Engines NR2008a None

Diesel Engines NR2008a None

Gasoline Engines NR2008a None

LPG Engines NR2008a None

Locomotives EMP None

ON-ROAD MOBILE SOURCES

On-Road Vehicles* MOVES2010b None

HDDV Diesel Idling* MOVES2010b None

 * Sub-Category included in MVEB

 
Table B-2 – Growth Factors for 2015-2030 Projections for the Truckee Meadows Hydrographic Area 

Growth Factors 2010 2011 2015 2020 2025 2030 Reference

Uniform (UNI) 1.000 1.000 1.000 1.000 1.000 1.000 ---

Daily Vehicle Miles Traveled (VMT) 5,773,560 6,080,990 6,157,848 6,596,915 7,040,489 7,390,867

Ratio using 2011 Baseline 1.000 1.013 1.085 1.158 1.215

Local Vehicle Miles Traveled (LVMT) 472,725 497,198 503,316 539,802 585,265 634,418

Ratio using 2011 Baseline 1.000 1.012 1.086 1.177 1.276

Population (POP) 280,881 283,288 292,914 313,771 328,272 341,696

Ratio using 2011 Baseline 1.000 1.034 1.108 1.159 1.206

Population Growth Rate (PGR) 1.000 1.009 1.034 1.071 1.046 1.016

Ratio using 2011 Baseline 1.000 1.025 1.062 1.037 1.007

Households (HH) 113,418 114,468 118,666 127,912 134,278 140,216

Ratio using 2011 Baseline 1.000 1.037 1.117 1.173 1.225

Household Growth Rate (HHGR) 1.000 1.009 1.037 1.078 1.050 1.017

Ratio using 2011 Baseline 1.000 1.027 1.068 1.040 1.008

Employment (EMP) 211,596 215,663 231,931 252,698 274,153 297,252

Ratio using 2011 Baseline 1.000 1.075 1.172 1.271 1.378

Employment Growth Rate (EGR) 1.000 1.019 1.075 1.090 1.085 1.032

Ratio using 2011 Baseline 1.000 1.055 1.069 1.064 1.013

Ag/Mining/Constr Employment (AMC) 14,869 15,114 16,096 17,439 18,847 20,348

Ratio using 2011 Baseline 1.000 1.065 1.154 1.247 1.346

AMC Emp Growth Rate (AMCGR) 1.000 1.017 1.065 1.083 1.081 1.030

Ratio using 2011 Baseline 1.000 1.048 1.066 1.063 1.014

Mfg/Trans/Com/Util/wholesale (MTCUW) 29,049 29,531 31,457 34,059 36,803 39,768

Ratio using 2011 Baseline 1.000 1.065 1.153 1.246 1.347

MTCUW Emp Growth Rate (MTCUWGR) 1.000 1.017 1.065 1.083 1.081 1.031

Ratio using 2011 Baseline 1.000 1.048 1.065 1.063 1.014

Service & Office Emp (SVCOF) 61,942 63,181 68,139 74,567 81,173 88,221

Ratio using 2011 Baseline 1.000 1.078 1.180 1.285 1.396

SVCOF Emp Growth Rate (SVCOGR) 1.000 1.020 1.078 1.094 1.089 1.033

Ratio using 2011 Baseline 1.000 1.057 1.073 1.067 1.013

RNO Airport Passenger (AP) 3,823,393 3,945,186 4,432,360 5,138,320 5,876,196 6,720,031

Ratio using 2011 Baseline 1.000 1.123 1.302 1.489 1.703

2010 is actual data, the rest projected.

Airport Passenger Growth Rate (APGR) 1.000 1.032 1.123 1.159 1.144 1.053

Ratio using 2011 Baseline 1.000 1.089 1.123 1.108 1.020

2010 is actual data, the rest projected.

Heating Degree Days (HDD)* 2,368 2,499 2,501 2,501 2,501 2,501 National Climatic Data Center.

Ratio using 2011 Baseline 1.000 1.001 1.001 1.001 1.001 Normal, Means and Extremes; Reno, NV (RNO)

30-year Normals (1980-2010) for 2015 forward.

Rainfall >= 0.01 inch (Rain)* 34.0 5.0 18.3 18.3 18.3 18.3 National Climatic Data Center.

Ratio using 2011 Baseline 1.000 3.660 3.660 3.660 3.660 Normal, Means and Extremes; Reno, NV (RNO)

30-year Normals (1980-2010) for 2015 forward.

Snowfall >= 1 inch (SNO)* 3.0 1.0 3.8 3.8 3.8 3.8 National Climatic Data Center.

Ratio using 2011 Baseline 1.000 3.800 3.800 3.800 3.800 Normal, Means and Extremes; Reno, NV (RNO)

30-year Normals (1980-2010) for 2015 forward.

Episodic RWC EI Factors:

Rule Penetration 0.85 0.85 0.88 0.88 0.88 0.88

Rule Effectiveness 0.86 0.86 0.74 0.74 0.74 0.74

Control Efficiency 1.00 1.00 1.00 1.00 1.00 1.00

Note: 2011 data is from Washoe County's Emissions Inventory compilation.

* Includes Jan, Nov, & Dec., 2015 - 2030 data are 30-year normal from 1981-2010, from 2013 NOAA Weather Summary file.

RTC of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

Note: The population and employment data are not specifically included in the main body of the RTP, but were used 

as inputs for the transportation model that generates VMT data. These data (2010, 15, 20, 25, 30) came from 2012 

Washoe County Consensu Forecast, as provided by Judy Althoff/RTC. Airport passenger data, which was also 

used in the RTP, were provided by Peter Bang/RTC.

Washoe County Residential Wood Use Survey 

Reports compiled by InfoSearch for 2009-2010 

(May 2010) & 2012-2013 (May 2013).

RTC of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

RTC of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

RTC of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.

2012 WC Consensus data, as interpreted by RTC 

of Washoe County; "2035 Regional 

Transportation Plan", April 19, 2013.
Appendix B.1 – Residential Wood Combustion 

The 2009-2010 RWC survey was used for the 2011 emissions inventory calculation. An 

adjustment factor of 0.921 based on heating degree days and households was applied to the 

2009-2010 survey to estimate the 2011 emission. This factor accounts for the colder 2009-2010 

winter season and higher population as compared to the 2011-2012 winter season and 

population. 

The most recent survey was completed for the 2012-2013 winter season. Likewise, adjustment 

factor based on heating degree days (HDD) was applied to the 2012-2013 survey to calculate the 

emissions from 2015 through 2030. Since non-certified woodstoves are not allowed within the 

Truckee Meadows, and new installation of certified phase II or fireplaces are only allowed on a 

property with greater or equal to one acre in size, the growth factors for the various RWC 

devices vary. Table A-3 is a summary of the adjustment methodologies used to project future 

RWC emissions. This factor accounts for the milder 2011-2012 winter season (2,499 heating 

degree days) compared to the historic normal (2,501 heating degree days) (Appendix A). This 

estimate is conservative and assumes that projected PM10 emissions stay consistent with the 

heating degree days and allowable future RWC devices within the Truckee Meadows. It is used 

because RWC in the Truckee Meadows is controlled by a regulation that: 1) is permanent and 

enforceable, 2) does not allow non-EPA certified devices in new dwelling units, and 3) requires 

non-EPA certified devices to be upgraded or removed upon real estate transactions. 

Table B-3 – Truckee Meadows PM10 Emission Projection Calculation Methodologies for RWC 

RWC Device Future Emission Projection 

Methodology

Rationale

Fireplaces Device number set at 2011 EI level, 

adjusted by HDD.

No new fireplaces can be installed within the 

Truckee Meadows unless the property is greater or 

equal to 1 acre in size.

Also assumed when aging fireplaces are replaced 

with newer ones, 1% per year will be replaced by 

gas fireplaces.

Non-certified 

woodstoves

Device number decreases by 128 per 

annum from 2011 EI level, based on 

the average number of devices 

removed from 2006 - 2012, adjusted 

by HDD.

Non-certified woodstoves are prohibited from 

installation within the Truckee Meadows.

Assumed 100% of the non-certified woodstoves are 

replaced by 75% Phase II woodstoves, 20% pellet 

stoves, and 5% gas fireplaces.

EPA Certified 

Phase I 

woodstoves

Device number is capped at the 2011 

EI level, adjusted by HDD and 5% 

replacement per year.

Since these Phase I devices were replaced by Phase 

II devices in 1990, no new Phase I devices are 

allowed within the Truckee Meadows.

EPA Certified 

Phase II 

woodstoves

Device number increases by 96 per 

annum from 2011 EI level, which is 

75% of the average non-certified 

stoves being removed annually, 

adjusted by HDD.

Assumed that 75% of the non-certified woodstoves 

are replaced with EPA certified phase II devices. 

This is a more conservative estimate, not accounting 

for some of the non-certified woodstoves that could 

have been removed without being replaced.

Pellet stoves Device number increases by 26 per 

annum from 2011 EI level, which is 

20% of the average non-certified 

stoves being removed annually, 

adjusted by HDD.

Assumed that 20% of the non-certified woodstoves 

are replaced with pellet stoves. This is a more 

conservative estimate, not accounting for some of 

the non-certified woodstoves that could have been 

removed without being replaced.
Appendix B.2 – Paved Road Fugitive Emissions

Paved road fugitive emissions were calculated using the Predictive Emission Factor equations 

from AP-42, section 13.2.1.3, updated January 2011. Equation 1 is the annual predictive 

emission factor and Equation 2 is the Daily predictive emission factor, derived from Equation 1. 

E = k (sL)0.91 W1.02 Equation 1 

Where:

E = particulate emission factor (having units matching the units of k); 

K = particle size multiplier for particle size range and units of interest;

sL = road surface silt loading (grams per square meter, g/m2); and

W = average weight (in tons) of the vehicles traveling the road 

Eext = [k (sl)0.91 W1.02](1 − P

4N) Equation 2

Where:

Eext = annual or other long-term average emission factor (in the same units as k);

P = number of "wet" days ≥ 0.01 inch of precipitation during the averaging period; and

N = number of days in the averaging period (e.g., 365 for annual, 91 for seasonal, 30 for 

monthly). 

Facility class Average Daily Trips (ADT) were based on RTC planning assumption when they 

generated the corresponding VMTs . 

Silt loading factors for different road way classifications were based on a combination of 

Washoe County and EPA data. A survey of Clark County and San Joaquin Valley Air Pollution 

Control District determined that a silt loading factor of 0.02 g/m2 were used to calculate paved 

road fugitive emissions for interstate freeways, highways and expressways. 0.02 is between the 

range of AP-42’s data of 0.015 - 0.03 for high ADT roadways. 

Table B-4 – Silt Loading Assumption for Facility Types 

Facility Type ADT 

Classification

Silt Loading 

(g/m2)

Source

Interstate >10,000 0.02 AP-42, 13.2.1.3, updated 1/11

Other FWYs & ExpWays >10,000 0.02 AP-42, 13.2.1.3, updated 1/11

Other Principal Arterial >10,000 0.02 AP-42, 13.2.1.3, updated 1/11

Minor Arterial 5,000 – 10,000 0.06 AP-42, 13.2.1.3, updated 1/11

Collector 500 – 5,000 0.16 Washoe County

Local 500 – 5,000 0.16 Washoe County
Appendix B.3 – Unpaved Road Fugitive Emissions 

The following assumptions were made when calculating the unpaved road emissions: 

1. Dirt roads were not included in the emissions calculation because they have very low 

ADT and are used for weekend recreational activities, such as dirt biking. 

2. Paving records for the Washoe County Community Services Department (formally Public 

Works Department) indicated on average between 1985 and 2011, 8.2% of unpaved roads 

were paved per annum. More recent data from 1990 to 2011 showed a 6.4% paving rate. 

However, either of these rates may be too optimistic for future projections; instead, a 

lower rate of 2.6% was used for calculating unpaved road emissions. This rate was based 

on the information from GIS for the average rate of unpaved roads being paved across 

jurisdiction for 2011 and 2013. The rationale was that because 2011 and 2013 data 

reflect more current conditions. It is assumed that the region would pave at least 2.6% of 

the unpaved roads, as the economy continues to improve. 
Appendix B.4 – Paved Road Fugitive Emissions, Sanding & Salting

Historically, various jurisdictions in Washoe County used more sand than salt for winter time 

anti-skid reduction. Over the years, the practices have shifted to a higher ratio of salt being used 

instead of sand, partly due to the fact that sand had to be swept up after a storm event, whereas 

the salt just melted into the snow and discharged into drain basins. Based on historic data, a 15% 

sand reduction was applied in addition to the growth factor to project emissions from 2015 

through 2030. 
Appendix C 

Truckee Meadows Projected PM10 Seasonal Emissions 
Table C-1 – Truckee Meadows Projected PM10 Seasonal Emissions (lbs/day) 

Major Category Sub-Category

2011

Attain EI 

2011

Maint Em Limit 

Projected Emissions (lbs/day)

2015 2020 2025 2030

POINT SOURCES

Geothermal N/A N/A N/A N/A N/A N/A 

Printing N/A N/A N/A N/A N/A N/A 

Airports & Heliports

GSE 5 5 5 6 7 8 

Military Aircraft - - - - - -

Commericial Aircraft 12 12 13 15 18 20 

Gen Aviation - piston N/A N/A N/A N/A N/A N/A 

Gen Aviation - turbine 1 1 1 2 2 2 

Air Taxi - piston N/A N/A N/A N/A N/A N/A 

Air Taxi - turbine 0 0 1 1 1 1 

APU 6 6 7 8 10 11 

Buffer Zone N/A N/A N/A N/A N/A N/A 

Subtotal 25 25 28 32 37 42 

NONPOINT SOURCES

Stationary Source Fuel Combustion

Industrial Fuel Combustion 56 56 60 65 71 77 

Com/Inst Fuel Combustion 37 37 39 43 47 50 

Res. Fuel Combustion 18 18 19 20 21 22 

Res. Wood Combustion

Fireplaces 3,535 3,535 3,396 3,229 3,070 2,919 

Woodstoves/Inserts

Non-certified 1,266 1,266 1,062 805 549 292 

Certified, Phase 1 550 550 445 334 250 141 

Certified, Phase 2 449 449 551 671 783 814 

Pellet Stoves 88 88 93 98 104 106 

Subtotal 5,998 5,998 5,663 5,264 4,893 4,420 

Industrial Processes

Chemical Manufacturing 8 8 8 9 10 11 

Commercial Cooking 519 519 537 575 602 626 

Food & Kindred Products - Manufacturing 159 159 171 186 202 219 

Mineral Processes 40 40 43 47 51 55 

Rubber/Plastic Processes 68 68 73 80 87 94 

Fabricated Metals 10 10 11 12 13 14 

Construction - Stationary

Road Construction* 178 178 183 189 185 180 

Residential Dust Projects (Non-Road Const.) 143 143 146 151 148 144 

Commercial Dust Projects (Non-Road Const.) 110 110 116 117 117 111 

Asphalt, Sand and Gravel, Abrasive Blasting 29 29 31 31 31 29 

Machinery 6 6 6 7 7 8 

Mining and Quarrying - Stationary 85 85 92 100 109 118 

Miscellaneous Industrial Processes 34 34 37 40 43 47 

Subtotal 1,389 1,389 1,453 1,545 1,603 1,655 

Solvent Utilization

Architectural Coatings - - - - - -

Auto Refinishing - - - - - -

Wood Furniture - - - - - -

Paper - - - - - -

Plastic Products - - - - - -

Machinery & Equipment - - - - - -

Electronic & Other Electrical - - - - - -

Misc. Manufacturing - - - - - -

Subtotal - - - - - -

Other Solvent Utilization

Degreasing - - - - - -

Dry Cleaning - - - - - -

Graphic Arts - - - - - -

Misc. Industrial Processes - - - - - -

Misc. Commercial Processes - - - - - -

Misc. Consumer/ Com. Solv. - - - - - -

Cutback Asphalt Application - - - - - -

Emulsified Asphalt Appl. - - - - - -

Pesticide, Fungicide & Rodenticide - - - - - -

Subtotal - - - - - -
Storage and Transport

Gas Service Station - - - - - -

Organic Chemical Storage

Subtotal - - - - - -

Waste Disp/Treat/Recovery

Commercial/Industrial Incineration - - - - - -

Publicly Owned Treatment Works N/A N/A N/A N/A N/A N/A 

Remediation/Reclamation/ Recycle - - - - - -

Subtotal - - - - - -

Misc. Non-Point Sources

Paved Road Fugitive Emissions* 1,453 1,453 1,414 1,517 1,627 1,736 

Paved Road Fugitive Emissions, Sanding & Salting 339 339 516 490 466 442 

Unpaved Road Fugitive Emissions* 2,623 2,623 2,380 2,479 2,688 3,174 

Dirt Road Fugitive Emissions - - - - - -

Wildfires 10,947 21 21 21 21 21 

Structure Fires 15 15 15 15 15 15 

Motor Vehicle Fires 3 3 3 3 3 3 

Firefighting Training - - - - - -

Open/Permit Burning 18 18 18 18 18 18 

Prescribed Burning - - - - - -

Refuse Fires 16 16 16 16 16 16 

Auto & Misc. Repair Shops 0 0 0 0 0 0 

Health Services, Hospitals - - - - - -

Essay Labs 0 0 0 0 0 0 

Human & Animal Cremation 9 9 9 10 10 11 

Subtotal 15,425 4,499 4,394 4,571 4,865 5,437 

TOTAL NONPOINT SOURCES 22,812 11,885 11,510 11,379 11,361 11,512 

NON-ROAD MOBILE SOURCES

CNG Engines 1 1 1 1 1 1 

Diesel Engines 377 377 302 174 102 65 

Gasoline Engines 192 192 176 186 198 211 

LPG Engines 22 22 7 8 8 9 

Locomotives 15 15 16 17 19 21 

Subtotal 606 606 501 386 328 307 

ON-ROAD MOBILE SOURCES

On-Road Vehicles* 1,171 1,171 946 835 825 880 

HDDV Diesel Idling* 12 12 7 4 3 3 

Subtotal 1,183 1,183 953 839 828 883 

Grand Total 24,626 13,700 12,992 12,637 12,554 12,744 

Safety Margin 708 1,063 1,146 955 

 * Sub-Category included in MVEB 5,638 6,088 6,473 6,927