STATE OF COLOR!\DO
 

Bill Ritter, Jr., Governor
 

Martha E. RudOlph, Executive Director
 

Dedicated to protecting and improving the health and environment of the people of Colorado 

4300 Cherry Creek Dr. S. Laboratory Services Division
 

Denver, Colorado 80246-1530 8100 Lowry Blvd.
 

Phone (303) 692-2000 Denver, Colorado 80230-6928
 

TOD Line (303) 691-7700 (303) 692-3090
 Colorado Department Located in Glendale, Colorado of Public Health 

http://www.cdphe.state.co.us and Environment 

RECEIVED 

March 31, 2010 U.S. EPA Region 8 

RA's Offloe 

Carol Rushin 

Acting Regional Administrator 

US EPA Region VIII .............
 1595 Wynkoop St. 

Denver, CO 80202 

Dear Ms. Rushin: 

The following actions are submitted to EPA for final approval and incorporation into the Colorado State 

Implementation Plan pursuant to 40 CFR Part 51, Appendix V, 2.1 (a). Two copies of the materials 

needed for your review of each action are included with this letter. 

•	 Colorado Springs Carbon Monoxide Maintenance Plan - The Colorado Air Quality Control 

Commission (COlmnission) adopted a second ten-year maintenance plan for the Colorado 

Springs area using the Limited Maintenance Plan option. There were no revisions to the control 

measures in the plan. 

•	 Greeley Carbon Monoxide Maintenance Plan - The Commission adopted a second ten-year 

maintenance plan for the Greeley area using the Limited Maintenance Plan option. There were 

no revisions to the control measures in the plan. 

•	 Pagosa Springs PMl 0 Maintenance Plan - The COlmnission adopted a second ten-year 

maintenance plan for the Pagosa Springs area. There were no revisions to the control measures 

in the plan, however, the mobile source emissions budget was reduced. 

•	 Telluride PMlO Maintenance Plan - The Commission adopted a second ten-year maintenance 

plan for the Telluride area. There were no revisions to the control measures in the plan, 

however, the mobile source emissions budget was reduced. 

•	 Common Provisions - The Commission adopted a revision to the Common Provisions 

Regulation to revise the definitions of "negligibly reactive volatile organic compound" and 

"volatile organic compound" (VOC) in Section I.G. to be consistent with the federal definitions 

for these terms. 
Carol Rushin
 

March 31, 2010
 

Page 2
 

•	 Interstate Air Pollutant Transport State Implementation Plan - the Commission adopted a 

proposal to revise the interstate transport element of the State Implementation Plan to address 

outstanding issues that the US EPA had identified with plan previously adopted by the 

Commission. 

We look forward to your timely review and approval of this request. The office of the Colorado Air 

Quality Control Commission may submit any additional teclmical support documentation or information 

that you may need for review directly to the EPA. Should there be any questions regarding these 

materials, please contact the Commission office at 303-692-3478. Thank you. 

Martha E. Rudolph 

Executive Director 

Colorado Department of Public 

Health and Environment 

cc.	 Paul Tourangeau 

Doug Lempke 

Mark Komp 
Pagosa Springs PMIO Maintenance Plan 

including the Ambient Air Quality Standards 

ADMINISTRATIVE MATERIALS 

Copies of the following administrative materials are included in this submittal of revisions to 

Pagosa Springs PM1 0 Maintenance Plan including the Ambient Air Quality Standards. 

Hearing held on November 19,2009. 

•	 Hearing Notice and Proposed Language as Published in the CCR 40 CFR Part 51 

Appendix V 2.1 (f) 

•	 Meeting Agenda where Public Hearing Occurred and Notice published in the Legal 

Ads of the Denver Post 40 CFR Part 51 Appendix V 2.1 (f) 

•	 Procedural Documents of the Commission (this includes the Agenda Item Control 

Sheet, the Memorandum ofNotice, the Economic Impact Analysis) 

•	 Parties Hearing Documents (this includes a list of the parties, the parties prehearing 

statements and rebuttal statements, and any orders by the Commission - - do not 

include all the attachments from the parties) 

•	 Revised Proposed Language and State Implementation Plan Elements 

•	 Technical Support Document 40 CFR Part 51 Appendix V 2.2 

•	 Public Comments 40 CFR Part 51 Appendix V 2.1 (h) 

•	 Adopted Statement of Basis, Specific Statutory Authority and Purpose 

•	 Adopted Language by the Commission (in redline & footer noting adoption date and 

page numbers) 

•	 State Implementation Plan Element Adopted by the Commission 40 CFR Part 51 

Appendix V 2.1 (d) 

•	 Colorado Air Quality Control Commission Meeting Minutes 40 CFR Part 51
 

Appendix V 2.1 (g)
 

•	 Legal Opinion ofthe Colorado State Attorney General 40 CFR Part 51 Appendix V 

2.1 (c) and (e) 

•	 Regulation or Regulation Revisions as Published in the Colorado Code of
 

Regulations 40 CFR Part 51 Appendix V 2. 1(b)
 
Hearing Notice as Published 

on the Commission Website 

40 CFR Part 51 Appendix V 2.1 (f) 
STATE OF COLORADO
 

Bill Ritter, Jr., Governor
 

James B. Martin, Executive DIrector
 

Dedicated to protecting and Improvmg the health and enVironment ofthe people ofColorado 

COLORADO AIR QUALITY CONTROL COMMISSION 

hltp:llwww.cdphestate.co.us 

EDO-AQCC-A5 

4300 Cherry Creek Drive South 

Denver, Colorado 80246-1530 

Phone (303) 692-3100 Colorado Department Fax (303) 691-7702 of Public Health TOO (303) 691-7700 

and Environment 

NOTICE OF PUBLIC RULEMAKING HEARING 

BEFORE THE 

COLORADO AIR QUALITY CONTROL COMMISSION 

Regarding proposed revisions to: 

Ambient Air Quality Standards Regulation, the SIP Specific Regulation and 

the Pagosa Springs PMIO Maintenance Plan 

SUBJECT: 

The Air Quality Control Commission will hold a public rulemaking hearing to consider revisions 

to the PMIO maintenance plan for Pagosa Springs. This is the second of two IO-year plans that 

are required by the Clean Air Act. The Division is proposing to revise the Ambient Air Quality 

Standards regulation to modify the mobile source emissions budget. 

FEDERAL REQUIREMENTS: 

The federal act requires the adoption of a second IO-year maintenance plan to demonstrate long 

term compliance with the National standard. A proposed Statement of Basis, Specific Statutory 

Authority, and Purpose and a regulatory analysis (if one has been requested) will be available for 

inspection no later than five (5) days prior to the hearing. The proposed language for the rule 

revision is attached to and made a part of this notice. 

HEARING SCHEDULE: 

DATE: November 19, 2009 

TIME: 9:00 AM 

PLACE: Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South, Sabin Conference Room
 

Denver, Colorado 80246
 

The hearing may be continued at such places and time as the Commission may announce. 

Interested parties may contact the Commission Office at 303-692-3476 to confirm meetmg dates 

and times. 
PUBLIC COMMENT: 

The Commission encourages all interested persons to provide their views either orally at the 

hearing or in writing prior to or at the hearing. The Commission especially solicits comments 

and analyses from persons who will incur directly some cost or benefit from the proposed 

revisions. Public testimony will be taken as close to the start of the hearing as possible and 

during the hearing as necessary. Written and/or electronic submissions prior to the hearing are 

requested to allow review prior to presentation at the hearing. Written and/or electronic 

submissions should be mailed to the Commission Office at least 14 days prior to the hearing. 

PARTY STATUS: 

In order to obtain party status at the hearing, compliance with several requirements as defined in 

the Commissions Procedural Rules is necessary. A petition for party status must be filed by 

electronic mail with the Office ofthe Air Quality Control Commission no later than close of 

business on September 15,2008. The petition must: 1) identify the applicant; 2) provide the 

name, address, telephone andfacsimile numbers, and email address ofthe applicants 

representative; and 3) briefly summarize what, ifany, policy, factual, and legal issues the 

applicant has with the proposal(s) as ofthe time offiling the application. Electronically mailed 

copies must also be received, by this same date, by the Division staff person and the Assistant 

Attorneys General representing the Division and the Commission identified below. Any person 

may petition the Commission to file documents in paper copy format ifthey are unable for any 

reason to not comply with the requirements of 1.3.8(2) of the Commissions Procedural Rules. 

An original and a specified number of paper copies must be filed in the Office of the Air Quality 

Control Commission, Colorado Department of Public Health and Environment, 4300 Cherry 

Creek Drive South, Denver, Colorado 80246. 

Individuals may also obtain party status through the submittal of an initial alternative rule to the 

proposed rule. The submittal of an alternative proposal must be accompanied by an electronic 

copy ofthe initial alternative proposed rule and all other associated documents as required by the 

Commission's procedural rules and must be filed by electronic mail with the Office of the 

Commission by the date specified for party status requests. Initial alternative rules must also be 

filed by electronic mail with the Division staff person and with each of the Assistant Attorneys 

General. 

Air Quality Control Commission Air Pollution Control Division 

Theresa L. Martin Curt Taipale 

EDO-AQCC-A5 APCD-Bl 

4300 Cherry Creek Drive South 4300 Cherry Creek Drive South 

Denver, CO 80246 Denver, CO 80246 

Theresa.Martin@state.co.us Curtis.Taipale@state.co.us 

Jerry Goad Thomas Roan 

Attorney for the Commission Attorney for the Division 

Attorney General's Office Attorney General's Office 

1525 Sherman St., 5th Floor 1525 Sherman St., 5th Floor 

Denver, CO 80203 Denver, CO 80203 

Jerry.Goad@state.co.us Tom.Roan@state.co.us 
Requests received beyond the above stated deadline shall only be considered upon a written 

motion for good cause shown. The Commission reserves the right to deny party status to anyone 

that does not comply with the Commission's procedural rules. 

STATUS CONFERENCE: 

A status conference will be held September 18th at 9:00 a.m., at the Department of Public 

Health and Environment to ascertain and discuss the issues involved, and to ensure that parties 

are making all necessary efforts to discuss and resolve such issues prior to the submission of 

prehearing statements. Attendance at this status conference is mandatory for anyone who has 

requested party status. 

PREHEARING CONFERENCEIPREHEARING STATEMENTS: 

Attendance at the prehearing conference is mandatory for all parties to this hearing. A 

prehearing conference will be held October 20, 2009 at 1:30 p.m. in the Commission Offices at 

4300 Cherry Creek Drive South, Denver. All parties must submit by electronic mail a 

preliminary prehearing statement to the Commission Office by close of business October 14, 

2009. In addition, electronically mailed copies ofthese documents must be delivered by that 

date to all persons who have requested party status. A copy of the prehearing statement must 

also be electronically mailed to the Division point of contact and each ofthe Assistant Attorney's 

General identified above by close of business October 14, 2009. Any revisions to the 

prehearing statement must be submitted to the Administrator of the Commission at the 

prehearing conference and by electronic mail to the Commission Office on the day ofthe 

prehearing conference. Any exhibit included in the prehearing statements will be electronically 

mailed to individual Commissioners for review prior to the hearing, provided the party files 

electronic copies of such exhibit. Rebuttals to the prehearing statement may be submitted to the 

Commission Office and all other parties by close of business October 27,2009. 

EXCEPTIONS TO FILE DOCUMENTS BY ELECTRONIC MAIL: 

The Commission's Procedural Rules provide for an exception to file documents by electronic 

mail. If granted an exception to electronic filing pursuant to the provisions of 1.3.8(3) ofthe 

Commissions Procedural Rules, the applicant for party status shall file an original and fifteen 

copies of the prehearing statement in the Office ofthe Air Quality Control Commission, and 

shall also deliver copies to each other party, applicant for party status, the Assistant Attorneys 

General representing the Commission and Division, and the Division staff person for the 

proceedings, by electronic mail or as otherwise provided by the exception granted under 

Subsection 1.3.8(3), by that same day. 
STATUTORY AUTHORITY FOR THE COMMISSION'S ACTIONS: 

The Commission proposes these regulatory changes pursuant to its authority under Sections 25­

7-105(1) and 25-7-109(1) and (2), C.R.S. The rulemaking hearing will be conducted in 

accordance with sections 24-4-103 and 25-7-110, C.R.S., as amended, the Procedural Rules of 

the Commission and as otherwise stated in this notice. This list of statutory authority is not 

intended as an exhaustive list of the Commission's statutory authority to act in this matter. 

Dated this 25th day of August 2009 at Denver, Colorado 

Colorado Air Quality Control Commission 

Douglas A. Lempke, Administrator 
DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
 

Air Quality Control Commission
 

AMBIENT AIR QUALITY STANDARDS
 

5 CCR 1001-14
 

V.	 Emission BUdgets for Attainment/Maintenance Areas in the State of Colorado 

V.A.	 Budgets 

V.A.1	 The following Motor Vehicle Emission BUdgets shall be utilized to assess the conformity of 

Transportation Plans, TIPs, and where appropriate, ProJects, for the applicable periods and 

geographic areas Indicated: 

Denver 

Attainment/Maintenance 

Area (Modeling 

Domain) 

PM10: 2015 through 2021 54 tons/day; 2022 

and beyond: 55 tons/day 

Nitrogen OXides: 2015 through 2021 70 

tons/day; 2022 and beyond: 56 tons/day 

Trading provIsions: Trading of PM 10 for NOx, or 

NOx for PM1 0 to adjust emiSSion budgets for 

purposes of demonstrating transportation 

conformity shall be allowed uSing the emiSSion 

trading formula as follows: 

For trades necessary to Increase a primary 

PM10 budget, 15.0 tons/day of NOx will be 

taken from the NOx budget to Increase the 

primary PM1 0 bUdget by 1.0 tons/day, a ration 

of 15 to 1 

For trades necessary to Increase a NOx budget, 

1.0 tons/day of primary PM10 will be taken from 

the primary PM10 budget to Increase the NOx 

budget by 12.0 tons/day, a ratio of 1 to 12. 

Implementation of trading prOVIsions: In the 

event the MPO cannot demonstrate consIstency 

with the specific PM10 and NOx mobile source 

emiSSIon budgets, the trading prOVIsions may be 

utilized only after the MPO has conSidered all 

reasonably available local control measures to 

meet the budgets. The MPO must demonstrate 

the need for trading through the usual 

consultation procedures for state Implementation 

plan development delineated In Section IV (F) of 

AQCC Regulation Number 10, Criteria for 

AnalysIs of Conformity 

If trading IS utilized, the MPO shall Include the 

follOWing Information In the transportation 

conformity determination: 
(1 ) The budget for primary PM10 and NOx 

for each required year of the conformity 

determination, before trading IS employed; (2) 

The portion of the original budget to be used to 

supplement a wanting budget, for each required 

year for the conformity determination; (3) The 

Increased budget that results from trading, along 

with relevant calculations, and (4) the resulting 

pnmary PM10 and NOx budgets for each 

reqUired year of the conformity demonstration. 

The MPO shall then compare prOjected 

emiSSIons to the adjusted PM10 and NOx motor 

vehicle emiSSion budgets to demonstrate 

conformity 

Denver Attainment Ozone Precursors (attainment/maintenance 

Maintenance Area area boundary) NOx 2002 and beyond 134 tpsd 

VOC 2002 and beyond 119 tpsd (tpsd = tons per 

summer day) Carbon MonOXide 

(attainment/maintenance area boundary) 2013 

through 2020: 1625 tons/day: 2021 and beyond: 

1600 tons/day 

Denver Metro 

Area/North Front Range 

Regional EmiSSions Budgets 

NOx: 122.9 tons/day 

VOCs: 109.2 tons/day 

Southern SUb-Regional EmISSions Budgets 

NOx: 102.4 tons/day 

VOCs: 89.7 tons/day 

Northern Sub-Regional EmiSSions Budgets 

NOx: 20.5 tons/day 

VOCs: 19.5 tons/day 

8-Hour Ozone 

Nonattamment Area 

Aspen (Modeling Area) PM10.2015 and Beyond: 16,2441bs.lday 

Caf'ion City PM10.2020 and Beyond: 1,613 Ibs.lday 

~2015 and Beyond: 7,534 Ibs.lday 

PM10~2021 and Beyond: +,489946 

Ibs.lday 

Lamar (Modeling Area) 

Pagosa Springs 

(Modeling Area) 

Steamboat Springs 

(Modeling Area) 

TellUride (Modeling 

Area) 

PM102015 and Beyond: 21,773lbs.lday 

PM102012 and Beyond: 10,OO1lbs.lday 
Longmont 

Attainment/Maintenance 

Area 

Carbon Monoxide 2010 through 2014: 43 

tons/day 2015-2019: 43 tons/day 2020 and 

Beyond: 43 tons/day 

T-hrough-2O-14.--44-tons/day..2-Gt5..furoogh-2-G~.Q.:·

44 tons/day 

Carbon Monoxide 2010 and Beyond: 531 

tons/day 

Carbon Monoxide 2005 through 2009: 99 

tons/day2010 through 2014: 98 tons/day2015 

and Beyond: 94 tons/day 

Carbon Monoxide 2005 through 2009: 63 

tons/day2010 through 2014: 62 tons/day2015 

and Beyond: 60 tons/day 

Atta+AmeRtlMa+AteAaflGe 

Area 

Colorado Springs 

Attainment/Maintenance 

Area 

Ft. Collins 

Attainment/Maintenance 

Area 

Greeley Area 

Attainment/Maintenance 

Area 

V.A.2.	 Geographic Coverage 

Unless otherwise specified, the geographic coverage of each of the area Motor Vehicle 

Emissions BUdgets shall be the nonattalnment or attainment maintenance area as defined In the 

respective state Implementation plans. 

V.A.3.	 The Motor Vehicle Emissions Budget for PM1 0 applies to total primary PM1 0 emiSSions, Including 

emiSSions from tailpipe exhaust, unpaved roads (except for the Denver PM10 nonattalnment 

area), re-entralned road dust and street sand. It does not Include precursor or secondary 

emiSSions, WhiCh, where appropriate, are covered under separate bUdgets. 

V.A.4.	 Effective Dates 

V.A.4.a. Denver Carbon Monoxide 

The 1,520 tons per day (2013 and beyond) carbon monoxide emiSSion budget 

established In Section V.A.1 shall take effect as a matter of state law when such bUdget 

takes effect as a matter of federal law pursuant to 40 CFR Section 93.118. Until such 

time as the 1,520 tons per day bUdget takes effect pursuant to this section and 40 CFR 

Section 93.118, the carbon monoxide emiSSion budgets for the Denver CO 

attainment/maintenance area shall be 800 tons per day (2002 and beyond). 

V.A.4.b.Colorado Springs Carbon Monoxide 

The 531 tons per day carbon monoxide emiSSion bUdget established In Section V.A.1 

shall take effect as a matter of state law when such budget takes effect as a matter of 

federal law pursuant to 40 CFR Section 93,118. Until such time as the 531 tons per day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the carbon 

monoxide emiSSion budget for the Colorado Springs CO attainment/maintenance area 

shall be 270 tons per day (2001 and beyond). 

V.A.4.c. Reserved 

V.A.4.d. Reserved 
V.A.4.e.Aspen PM10 

The 16,244 pounds-per-day PM1 0 emISSion budget established In Section V.A.1 shall 

take effect as a matter of state law when such bUdget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 16,244 pounds-per-day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the PM1 0 

emiSSion budget for the Aspen PM10 Nonattalnment Area shall be 13,974 pounds-perday 

V.A.4.f. Reserved Pagosa Spnngs PM10 

The 946 pounds-per-day PM1 0 emISSion bUdget established In Section V.A.1 shall take 

effect as a matter of state law when budget takes effect as a matter of federal law 

pursuant to 40 CFR Section 93.118. Until such time as the 946 pounds-per-day bUdget 

takes effect pursuant to thIs section and 40 CFR Section 93.118, the PM1 0 emission 

bUdget for the Pagosa Spnngs PM1 0 attalnmenUmalntenance area shall be 7.486 

pounds-per-day 

V.A.4.g. Ca~on City PM 10 

The 1,1613 pounds-per-day PM10 emiSSion bUdget established In Section V.A.1 shall 

take effect as a matter of state law when such bUdget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 1,613 pounds-per-day 

bUdget takes effect pursuant to this section and 40 CFR section 93.118, the PM1 0 

emiSSion bUdget for the Ca~on City PM10 attalnmenUmalntenance area shall be 7,439 

pounds-per-day 

V.A.4.h.Lamar PM10 

The 7,534 pounds-per-day PM1 0 emiSSIon budget established In Section V.A.1 shall 

take effect as a matter of state law when such budget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 7,534 pounds-per-day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the PM1 0 

emiSSion bUdget for the Lamar PM10 Nonattalnment Area shall be 1,884 pounds-perday 

V.A.4.1. Steamboat Springs PM10 

The 21,773 pounds-per-day PM1 0 emiSSion budget established In Section V.A.1 shall 

take effect as a matter of state law when such budget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 21,773 pounds-per-day 

bUdget takes effect pursuant to this section and 40 CFR Section 93.118, the PM1 0 

emission budget for the Steamboat Spnngs PM1 0 Nonattalnment Area shall be 20,682 

pounds-per-day 

VIII. Statements of Basis, Specific Statutory Authority and Purpose 

VII/.X Pagosa Springs PM10 

Adopted November 19, 2009 

The amendments to the "Ambient Air Quality Standards for the State of Colorado" Regulation adopted by 

the Commission establish mobile source emissions budgets for the Pagosa Spnngs PM1 0 attainment 

area. 
Federal Requirements 

Nothing In this rule change exceeds the minimum requirements of the federal act. 

Statutory Authority 

The authority to establish emissions budgets and to establish criteria for transportation conformity 

determinations IS Included In the general authority to adopt a State Implementation Plan set out In Section 

25-7-105(1}, C.R.S. (2001). 

Findings pursuant to Section 25-7-110.8 

The mobile source emiSSions budgets are based on EPA's MOBILES emiSSions model and EPAapproved methods for calculating fugitive dust emiSSions as required by federal regulations. All 

methodologies and Information made available by Interested parties have been conSidered. The 

emiSSions budgets reduce the potential for air pollution by capping emiSSions from mobile sources. In 

adopting this rule. the Commission chose the most cost-effective alternative. 

Further. these reVISions will Include any typographical, grammatical and formatting errors throughout the 

regulation. 
Meeting Agenda where Public Hearing Occurred and
 

Notice published in the Legal Ads ofthe Denver Post
 

40 C·PR Part 51 Appendix V 2.1(f)
 
STATE OF COLORADO
 

Bill Ritter, Jr., Governor 

James B. Martin, Executive Director 

COLORADO AIR QUALITY CONTROL COMMISSION 

http://www.cdphe.stale.co.us 

4300 Cherry Creek Drive South 

OED-OLRA-A5 

Denver, Colorado 80246-1530 

Phone (303) 692-3100 Colorado Department Fax (303) 691-7702 of Public Health TDD (303) 691-7700 and Environment 

Notice of Meeting and Agenda
 

Air Quality Control Commission
 

November 19, 2009 

Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South, Sabin Room 

Denver, Colorado 

1:00 p.m. 

Call to Order: Detennination of a Quorum 

Approval of Minutes: ReviewlApproval of the October 17, 2009 meeting min

Air Quality Control Commission. 

utes of the 

Public Comment: The public is invited to comment on any air pollution is

the agenda. The Commission will not take action 

discussed under this agenda item today; however, item

scheduled for further discussion or action. 

sue 

on 

s m

not on 

issues 

ay be 

Agenda Review: The Commission Administrator will review the meeting 

and discuss any proposed revisions to the agenda for the 

Commission's consideration. 

agenda 

REQUEST FOR PUBLIC HEARINGS DECEMBER 17, 2009 

1.	 Denver Regional Council of Governments (DRCOG) Conformity 

(10 minutes presentation, 10 minutes discussion) 

The DRCOG will request that the Commission hold a public hearing in December for its 

anticipated Transportation Confonnity findings regarding the 2035 Regional Transportation 

Plan and the 2008/2013 TIP. 
RULEMAKING HEARINGS 

2.	 Pagosa Springs PMIO Maintenance Plan Revision 

(10 minutes presentation, 10 minutes discussion) 

The Division will present to the Commission revisions to the PMIO maintenance plan for 

Pagosa Springs. This is the second of two 10-years plans that are required by the Clean Air 

Act. The Ambient Standards and the SIP Specifics regulations will require revisions. 

3.	 Telluride PMIO Maintenance Plan Revision 

(10 minutes presentation, 10 minutes discussion) 

The Division will present to the Commission revisions to the PM10 maintenance plan for 

Telluride. This is the second of two lO-years plans that are required by the Clean Air Act. 

The Ambient Standards and the SIP Specifics regulations will require revisions. 

BRIEFINGS, DISCUSSIONS AND REpORTS 

4.	 Regulation Number 9: Smoke Management Program 

(20 minutes presentation, 20 minutes discussion) 

The Division will provide the annual update to the Commission on the projected costs for 

the Smoke Management Program. Program costs are not currently projected to cause a 

change to in the annual fees assessed to those covered by the program. 

5.	 Coordinating tbe Development of Plans for Regional Haze/Ozone/Rocky Mountain 

National Park 

(10 minutes presentation, 25 minutes discussion) 

The Commission and Division will discuss the requirements for each of these programs and 

how individual program proposals will be developed in a coordinated fashion to avoid 

unnecessary regulatory overlap or duplication and provide for the efficient consideration, 

adoption and implementation of each proposal. The Commission and Division will discuss 

the steps necessary to complete the requirements for each program and the relative timing to 

develop the proposals. 

6.	 Commissioner Informational Items 

Commissioners will discuss among themselves activities that they have participated in over 

the past month that they believe other Commissioners and/or members of the public may be 

interested in hearing about. 

7.	 Division Director's Report - Paul Tourangeau 

Monthly activities report 

8.	 Attorney General's Report - Jerry Goad 

Update of any recent court actions on air quality issues 

9.	 Administrator's Report. Doug Lempke 

• December meeting agenda items review 

• Review of Action Items from Today's Commission Meeting 

• Status of Pending Action Items 

Adjourn 

2 
6:00 p.m. 

Public Service Company - Cherokee Station
 

Renewal of the Title V Operating Permit
 

The Commission will hold a public comment hearing pursuant to the request of the WildEarth 

Guardians, Clean Energy Action and the Sierra Club and the provisions of§25-7-114.5 Colorado 

Revised Statutes to consider the renewal of the Title V Operating Permit for the Public Service 

Company's Cherokee Coal-Fired Electric Generating Station located at 6198 Franklin Street in 

Denver, Colorado. §25-7-114.5 Colorado Revised Statutes provides an opportunity for the 

applicant or interested parties to request a public hearing before the Commission to elicit and 

record the comment of any interested person regarding the sufficiency of the preliminary 

analysis and whether the permit(s) should be approved or denied. The draft operating permit(s) 

and preliminary analysis can be viewed at the Office of the Adams County Clerk and Recorder at 

450 South 4th Avenue, Brighton, Colorado, 80601, Phone: 303-654-6026 during regular business 

hours or at the offices of the Colorado Department of Public Health and Environment, Air 

Pollution Control Division at 4300 Cherry Creek Drive South, Glendale, Colorado 80246. This 

information is also available on the Department of Public Health and Environment's website at 

http://www.cdphe.state.co.us/ap/airpublicnotices.html 

3
 
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DENVER, CO
 

PUBLISHER'S AFFIDAVIT 

City and County of Denver, 

STATE OF COLORADO, 88. 

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C." .' .. . ......... J.-.~ J ' .
 .... 1 Notery Public. 

My comml..lon expire•••••• September 14, 2013 ••••• 
Procedural Documents ofthe Commission 

- Agenda Item Control Sheet 

- Memorandum ofNotice 

- Economic Impact Analysis (initial and final) 
- -

COLORADO AIR QUALITY CONTROL COMMISSION 

AGENDA ITEM CONTROL SHEET 

Item Title Proposed Pagosa Springs PM10 Maintenance Plan revision 

Meeting date November 19, 2009 

TYPES OF ACTION 

NON-HEARING ACTIONS REQUEST FOR HEARING HEARING 

Administrative X Public Rulemaking _ Public Rulemaking -

_ Briefing Informational Informational 

_ Policy 

_ Area Designations 

RECOMMENDED ACTION
 

_Adoption X Approval Denial
 -

MOTION
 

X Required Attached _ Not applicable
 -

STATUTORY AUTHORITY 

General 25-7-105 Specific 25-7-106, -107, -109 -302 

EPA SUBMITTAL 

Is this issue considered a SIP revision? Yes X No 

Which SIP? Pagosa Springs PM10 Date of EPA submission deadline: 06-15-09 

Agenda Item Control Sheet - Proposed Pagosa Springs PM10 Maintenance Plan Revision 

November 2, 2009 Page 1 
ISSUE STATEMENT: 

The Division is requesting that the.Commission approve the proposed revision of the 

Pagosa Springs PM10 Attainment/Maintenance Area Plan. The Division has received 

verbal concurrence of the proposed plan from the City Manager of the Town of Pagosa 

Springs although no written concurrence has been received. 

The documentation shows that Pagosa Springs will continue to attain the PM10 

National Ambient Air Quality Standard through 2021, and has never violated the PM10 

NAAQS in the past 10 years, although one exceedance of the standard was recorded in 

2000. No additional control measures are required for Pagosa Springs to maintain the 

standard. 

By accounting for anticipated growth, it is projected that Pagosa Springs will 

demonstrate maintenance of the PM10 NAAQS through the year 2021 with a 

concentration of approximately 146 micrograms per cubic meter (the NAAQS is 150 

ug/m\ 

This revision will satisfy the federal requirement for showing attainment for the second 

ten-year period after redesignation to attainment/maintenance. No additional revisions 

of the Pagosa Springs maintenance plan are anticipated. If future changes in mobile 

source models or other unforeseen considerations raise potential issues with 

maintaining the PM10 standard, the State will address the.need to revise the 

maintenance plan at that time. 

Please note that this maintenance plan was to be submitted to EPA by June 15, 2009 

(which is 8 years after EPA's approval of the initial redesignation request and 

maintenance plan, as required by the CAA). Although the Pagosa Springs PM10 

Attainment/Maintenance Area Plan update is late, no adverse environmental or 

administrative impact has occurred. 

Agenda Item Control Sheet - Proposed Pagosa Springs PM10 Maintenance Plan Revision 

November 2, 2009 Page 2 
ATTACHMENTS: 

1.	 Presentation on Revised PM10 Maintenance Plan for Pagosa Springs 

2.	 Draft Revised PM10 Maintenance Plan for the Pagosa Springs 

Attainment/Maintenance Area 

3.	 Final Economic Impact Analysis 

4.	 Proposed Revisions to Ambient Air Quality Standards 

5.	 Technical Support Document - Emission Inventory 

Date 

Date 

tJTtjl(,~
 Date 

Agenda Item Control Sheet - Proposed Pagosa Springs PM10 Maintenance Plan Revision 

November 2, 2009 Page 3 
MEMORANDUM OF NOTICE 

Date: August 4, 2009 

To: Interested Parties 

Subject: Revisions to the Air Quality Control Commission's "Ambient Air Quality 

Standards" Regulation in Support of Revisions to the Pagosa Springs PMIO 

Maintenance Plan 

GENERAL DESCRIPTION 

The Air Pollution Control Division (Division) proposes this rulemaking package with the intent 

ofrevising the Colorado "Ambient Air Quality Standards" regulation, specifically to revise the 

PM10 emission budget for the Pagosa Springs AttainmentlMaintenance Area. 

Nothing in this rule change exceeds the minimum requirements ofthe federal act. 

RULEMAKING PACKAGE 

Attachments to this memorandum provide details on the proposal as follows: 

•	 Attachment A: The actual language of the proposed revisions to the "Ambient Air 

Quality Standards" regulation; 

•	 Attachment B: A statement describing the initial economic impact analysis of the
 

proposed revisions to the "Ambient Air Quality Standards" regulation; and
 

•	 Attachment C: The Revised PM10 Maintenance Plan for the Pagosa Springs
 

AttainmentlMaintenance Area
 

•	 Attachment D: Technical Support Document - Emissions Inventory 

EXPLANATION OF THE PROPOSED RULES 

Adoption ofthe revised Pagosa Springs Maintenance Plan and the above-mentioned Ambient Air 

Quality Standards regulation revisions would establish a revised PM I0 emission budget for the 

Pagosa Springs area. The Division requests approval and adoption ofthe revised maintenance 

plan and the proposed regulation revisions as part of the State Implementation Plan (SIP) 

MATERIALS TO BE INCORPORATED BYREFERENCE IN THE PROPOSED RULES 

There are no materials to be incorporated by reference in the proposed rule revisions. 
PUBLIC MEETINGS 

You are invited to review these materials and present written or oral comments to the Division in 

accordance with the following: 

Date: (3rd week after publication of proposed rule in the Colorado Register) 

Time: 8:00 a.m. - 5:00 p.m. 

Place: 4300 Cherry Creek Drive South, Denver, CO 80246 

Deadline for Submittal of Written Comments: October 1, 2009 

Curt Taipale is lead Division staff for the Pagosa Springs PMI0 Maintenance Plan revision 

process. Following the close of the public comment period, Mr. Taipale will prepare a Division 

Response to Public Comments that summarizes all public comments received, that discusses 

options for addressing the concerns, and makes recommendations from the Division for each 

issue. The Air Quality Control Commission (AQCC) will receive a copy of the Division 

Response to Public Comment and all written comments submitted to the Division. 

The AQCC will hold a public hearing on November 19,2009. Interested parties may request 

meetings with Division staff three (3) weeks prior to the AQCC public hearing regarding this 

matter. To schedule a meeting, please contact Curt Taipale, who will make arrangements for a 

meeting regarding this proposed rulemaking. 

If you wish to be kept advised of these proceedings and/or receive a copy of the Division 

Response to Public Comments, you may request that your name be placed on the mailing list for 

this rulemaking proposal by contacting Curt Taipale at the following address: 

Curt Taipale
 

Air Pollution Control Division
 

4300 Cherry Creek Drive South
 

Denver, CO 80246-1530
 

Phone: (303) 692-3265
 

Fax: (303) 782-5493
 

E-mail: Curtis.taipale@state.co.us
 

BACKGROUND ONDEVELOPMENTOF THE PROPOSED RULES 

What are the problems? 

The Air Pollution Control Division is submitting a 2009 revised maintenance plan for the Pagosa 

Springs area as required by the U.S. EPA to assure attainment for a second 10-year period 

beyond the initial maintenance period. The initial 10-year maintenance period extended from the 

June 2001 date when EPA approved the initial redesignation request and the associated 

attainment/maintenance plan. The second 10-year period extends to 2021. 

As part ofthe 2009 revised maintenance plan, a new PMI0 emissions budget has been 

established for transportation conformity. 
How do the proposed rules help solve the problems? 

The proposed changes to the Ambient Air Standard assign an updated emissions budget for 

transportation confonnity using the latest emissions inventory data. This updated emissions 

budget is also reflected in the revised PMIO Maintenance Plan for Pagosa Springs. 

Nothing in these rule changes exceeds the minimum requirements of the federal act. 

RULES' EFFECTS ON PUBLIC, REGULATED COMMUNITY, AND OTHER AGENCIES 

The proposed emission budget reflects the latest estimate of emissions. The establishment of a 

budget will impact the planning of federally funded/approved highway plans and projects and 

could require the implementation of mitigation efforts in order to comply with the emissions 

budget cap. No direct costs to the public are anticipated by establishing the emission budget. 

RELATIONSHIP TO FEDERAL AND ADJACENT STATE REQUIREMENTS 

Federal Requirements: 

The revision to the emission budget confonns to federal regulation. 

Adjacent State Requirements: 

The revisions to the Ambient Air Quality Standards regulation are in confonnance with the same 

federal requirements affecting attainment/maintenance areas in the adjacent states. 

IMPLEMENTATION OF THE RULES 

The revised emission bUdget will be implemented through confonnity determinations made 

under the transportation conformity regulations. The SIP Specific Regulation contingency 

measures will cease upon AQCC adoption and EPA approval of this rule change. No additional 

contingency measures are necessary unless the area records a violation of the PMIO NAAQS in 

the future. 

TIME CONSTRAINTS 

The proposed rule changes are to be completed in 2009 in order for the state to submit a Pagosa 

Springs SIP revision to EPA in a timely manner to show attainment for the second ten-year term. 

In accordance with CAA 176A(b), it is required that a maintenance plan revision be submitted to 

the EPA within eight years after the original redesignation (which was on June 15,2001) to 

address maintenance of the standard for a second ten-year period beyond redesignation. The 

purpose of this maintenance plan revision is to provide for maintenance of the PMIO standard for 

the additional ten years (through 2021) following the first ten-year period. 

There are no known specific time constraints except that these regulatory revisions are directly 

associated with, and are companion to, the 1O-year maintenance plan update. 

RANGE OFREGULATORYALTERNATIVES AND THE NO-ACTION ANALYSIS 

No competing or alternative control measures were rejected when compiling these proposed 

revisions as no new controls are being proposed. 

By taking no action, there would not be a second ten-year maintenance plan for this area as 

required by federal law. 
JUSTIFICATION FOR DIFFERING FROM FEDERAL REQUIREMENTS 

The proposed rules meet all requirements applicable to the area as required by federal regulation 

and the Clean Air Act. The proposed rules do not differ from or exceed the federal requirements. 
FINAL ECONOMIC IMPACT ANALYSIS
 

Per C.R.S. 25-7-110.5
 

Revisions to the "Ambient Air Quality Standards" Regulation 

November 19, 2009 

The revisions to the Pagosa Springs PM10 maintenance plan revise the PM10 emission 

budget in the Ambient Air Quality Standards regulation. The rule changes should not 

result in an increase in costs to industry, the public or the Air Pollution Control Division. 

The updated emission budget does not impose direct costs on any party, but may affect 

the manner in which transportation funds are allocated and expended. The emission 

budget applies to transportation agencies such as the town of Pagosa Springs and the 

Colorado Department of Transportation, but do not impose any direct costs on these 

agencies. Rather than increasing costs, the emission budget may change the mix of 

projects eligible for transportation dollars. 

Final Economic Impact Analysis - Proposed Pagosa Springs PM10 Emissions Budget 

November 2, 2009 
INITIAL ECONOMIC IMPACT ANALYSIS 

Per C.R.S. 25-7-110.5 

Revisions to the "Ambient Air Quality Standards" Regulation 

August 20, 2009 

The revisions to the Pagosa Springs PM10 maintenance plan revise the PM10 emission 

budget in the Ambient Air Quality Standards regulation. The rule changes should not 

result in an increase in costs to industry, the public or the Air Pollution Control Division. 

The updated emission budget does not impose direct costs on any party, but may affect 

the manner in which transportation funds are allocated and expended. The emission 

budget applies to transportation agencies such as the town of Pagosa Springs and the 

Colorado Department of Transportation, but do not impose any direct costs on these 

agencies. Rather than increasing costs, the emission budget may change the mix of 

projects eligible for transportation dollars. 
Pagosa Springs PM 10 Mainenance Plan Errata Sheet 

Changes to the August 20,2009 proposed Draft Revised PM10 Maintenance Plan for 

the Pagosa Springs Attainment/Maintenance Area include three pages 1, 21 and 23 that 

are highlighted in red strikeout. 
Draft Revised PM10 Maintenance Plan for the
 

Pagosa Springs Attainment/Maintenance Area
 

Colorado Department 

of Public Health 

and Environment 

Revised PM10 Maintenance Plan Submittal; 

U.S. EnVironmental Protection Agency: submitted on -TBD 

Colorado Air Quality Control Commission, adopted on - TBD 

,Qa§'9u $;pFJ1=I§'. 7"9wR C91J1=IGU. appr9vefJ 91=1 Til:) 

PM10 Maintenance Plan Submittal: 

U.S. Environmental Protection Agency: approved on 06115/01, effective on 08114/01 

Colorado A" Quality Control Commission, adopted on 03116100 

Pagosa Springs Town Council, approved on February 2000 

PM10 State Implementation Plan Sybmittal 

u.s. Environmental Protection Agency: approved 05119/94, effective 06120194 

Colorado Air Quality Control Commission. approved ont1/t9/92; 11/12/93 

Revisions Prepared By: 

Air Pollution Control DiVision 

Colorado Department of Public Health and Environment 

4300 Cherry Creek Df/va South 

Denver. Colorado 80246 
CMB analysis, so the following five samp,es from 1994, 2006 and 2008 are considered 

to representative of high concentration episooes in the area. 

The average CMS source apportionment. in percent contribution. for geologic, burning, 

nitrate. sulfate and unknown source categories is indicated in Table 5. 

1. CMS Source Apportionments of liigh Concentrations 

Table 5 Chemical Mass Balance Source Apportionment 

Town Hall and High School Monitoring Site! 

Date PM10 

(ua/m3) 

Geologic 

(%) 

Burning 

(%) 

Nitrate 

(%) 

Sulfate 

(%) 

Unknown 

(%) 

Valid 

CMB? 

02116/94 101 74 14 1 1 10 Y 

03:03/94 105 71 9 0 1 19 Y 

05:05/94 109 87 0 1 2 10 y 

02/15/06 122 82 7.3 1 2 7.7 Y 

OS.'01/0B 149 81 6.4 2 2 8.6 Y 

Average 117.2 79.0% 7.3Yo 1.0% 1.6% 11.1% 100% 

Geologic =sources rich tn crus:al elements (street sand, soil, road dust) 

Burning =carbon-rich sources sucn as wood buming and coal burning 

Nitrate =NH"N03 particulate formed in the atmosphere from NO~ and NH3 

Sulfate"" (NH4hS04 particulate formed in the atmosphere from S02 and NH3 

2. CMS Roll-forward Analysis 

Subtract the Background Concentration from the Design Value Concentration: 

The background concentration is subtracted from the 102 ug/m3 design day 

concentration (see Section 2.8) because the background concentration would remain if 

all emissions in the emissions inventory were reduced to zero. A background PM10 

concentration of B uglm3 is assumed to occur on any given day in the area, as 

described in the November 1994 SIP Element. 

Design Day Concentration: 102 ugim3 

Background Concentration: - 8 uglm3 

94 ugim3 

Apportion the Design Day Concentration with the eMB Apportionments: 

GeologiC: 94 x 0.790 = 74.3 ug/m3 

Burning: 94 x 0.073 = 6.9 ug/m3 

Nitrate: 94 )( 0.010 = 0.9 ug/m3 

Sulfate: 94)( 0.016 = 1.5 ug/m3 

Unknown: 94 x 0.111 = 10.4 ug/m3 

94.0 ug/m3 

Revi$ed PM10 Maintenonce Plan for Paqosg Springs AttainlJ7ont/MQintcnancc Arpa Page 21 cf25 
Total Projected 2021 Concentration (PM1~21):
 

(sum or 2021 aRDon/oned components plus the baclcacound concentration)
 

PM102021 =G+ B+ N + S+ U + background =146.3 J!gJm3 

PM10lUll -115.1+ 10.4 + 0.9 + 1.5 + 10.4 + 8.0 =146.3 J.1g1m3 

Since the PM10'011 value is below the daily PM10 NAAQS (150 uglm3). 

maintenance of the standard is demonstrated 

D. PM10 EMISSION BUDGET 

Federal "transportation conformity" regulations provide for the use of mob~e source 

emission budgets in mak.ing conformity determinations in the area. The emission 

budget serves as a ceiling on mobile source emissions that federally funded or 

approved transportation projects must comply or conform. 

This revised maintenance plan establishes a mobile source PM10 emission budget for 

the AttainmentJMaintenance area of Q461bslday for 2021 and beyond. This budget is 

the total of the 2021 mobile source PM10 emissions (see Section 5.B.~~. above), which 

includes PM10 emissions from highways, paved roads, and unpaved roads. 

This budget has been adopted in the AQCC's "Ambient Air Quality Standards for the 

State of Colorado" regUlation. 

E. MONITORING NETWORKNER/F/CAnON OF CONTINUED 

ATTAINMENT 

The APeD has monitored ambient PM10 concentrations in the Pagosa Springs area 

since 1986. The APCD has operated, and will continue to operate, the Pagosa Springs 

PM10 monitoring network in full accordance with the federal provisions of 40 CFR Part 

58 and the EPA-approved Colorado Monitoring SIP Element. The APCD 'Nill also 

analyze the monitoring data to verify continued attainment of the PM10 NMOS. This 

information will provide the necessary information to determine whether the Pagosa 

Springs area continues to attain the PM10 NMOS. Detailed information regarding the 

State's monitoring efforts and historical monitoring data can be found in Section 2 of 

this document. 

F. CONTINGENCY PLAN 

Section 175(A)(d) of the CAA requires that the maintenance plan contain contingency 

provisions to assure that the State ""ill promptly correct any violation of the PM10 

NAAOS that may occur after the redeslgnation of the area to attainment. EPA's 

redesignation guidance notes that the State is not required to have fully adopted 

contingency measures that will take effect without further action by the State. However, 

the contingency plan should ensure that contingency measures are adopted 

expediently once the need is triggered. The primary elements of the contingency plan 

involve the tracking and triggering mechanisms to determine when contingency 

Revised PM1Q Maintenance PJan fpc PallAS' S0tin4s Attaioment!MajntenanCl Area page 23pt25 
Parties Hearing Documents
 

(this includes a list ofthe parties, the parties prehearing statements
 

and rebuttal statements, and any orders by the Commission)
 
RECEIVED 

DCT 14 2009 

BEFORE THE AIR QUALITY CONTROL COMMISSION 

STATE OF COLORADO 

AIR QUAlITY 

COOlQ. CXMtIlSSlOII' 

PREHEARING STATEMENT OF COLORADO DEPARTMENT OF PUBLIC
 

HEALTH AND ENVIRONMENT, AIR POLLUTION CONTROL DIVISION
 

REGARDING AMBIENT AIR QUALITY STANDARDS REGULATION, SIP 

SPECIFIC REGULATION AND THE TELLURIDE AND PAGOSA SPRINGS PMI0 

MAINTENANCE PLANS 

The Colorado Department of Public Health and Environment, Air Pollution 

Control Division ("Division") submits the following Prehearing Statement in this matter: 

EXECUTIVE SUMMARY 

The Division is proposing revisions for the Pagosa Springs and Telluride PM I0 

AttainmentlMaintenance Area Plans. The Division is unaware of any parties to these 

actions. Neither Pagosa Springs nor Telluride has violated the PMIO National Ambient 

Air Quality Standard (NAAQS) in the past 10 years. Pagosa Springs recorded one 

exceedance of the standard in 2000. Telluride has had no exceedance. No additional 

control measures are required for Pagosa Springs or Telluride to maintain the standard. 

The Division projects that both towns will continue to attain the PM I0 NAAQS 

through 2021, with Pagosa Springs at a concentration of approximately 146 micrograms 

per cubic meter, compared with the NAAQS of 150 micrograms per cubic meter, and 

Tellunde at 127 micrograms per cubic meter. This revision would satisfy the federal 

requirement for showing attainment for the second ten-year period after redesignation to 

attaInment/maintenance. 

The proposed changes to the Ambient Air Standard assign an updated emissions 

budget for transportation conformity using the latest emissions inventory data. This 

updated emissions budget is also reflected in the revised PMlO Maintenance Plans. 

The Division has conclud~d that these actions would result in no increased cost for 

the regulated industry, the public or the DiVIsion. This proposal is supported by the 

Towns of Pagosa Spnngs, Tellunde. Mountain Village and San Miguel County 

STATEMENT OF FACTUAL AND LEGAL ISSUES 

The Division is aware of no Issues. 
WITNESSES 

1.	 Curt Taipale, Colorado Department of Public Health and Environment, Air 

Pollution Control Division. Mr. Taipale may testify regarding the Pagosa 

Springs plan. 

2.	 Chris Dann, Colorado Department ofPublic Health and Environment, Air 

Pollution Control Division. Mr. Dann may testify regarding the Telluride 

plan. 

3.	 Other employees of the Colorado Department of Public Health and 

Environment, Air Pollution Control Division may, if necessary due to 

scheduling or availability, replace the witnesses listed above. If the above 

witnesses are unavailable to testify, the Division will notify the Commission 

of any replacement witness as soon as possible. 

EXHIBITS 

The Division has no exhibits at this time. 

DATED this 14th day of October, 2009. 

JOHN W. SUTHERS
 

Attorney General
 

HO A. ROAN, 30867* 

Assistant Attorney General 

Environmental Quality 

Natural Resources and Environment Section 

Attorneys for AIR POLLUTION CONTROL 

DIVISION 

1525 Sherman Street, 5th Floor 

Denver, Colorado 80203 

Telephone: (303) 866-5280 

*CounselofRecord 
Revised Proposed Language and State Implementation
 

Plan Elements
 
Draft Revised PM10 Maintenance Plan for the
 

Pagosa Springs Attainment/Maintenance Area
 

Colorado Department 

of Public Health 

and Environment 

Revised PM10 Maintenance Plan Submittal: 

U. S. Environmental Protection Agency: submitted on -TBD 

Colorado Air Quality Control Commission, adopted on - TBD 

Pagosa Spr.'ngs Town COI:JRci.', appr:o~d on TBD 

PM10 Maintenance Plan Submittal: 

U.S. Environmental Protection Agency: approved on 06/15/01, effective on 08/14/01 

Colorado Air Quality Control Commission, adopted on 03/16/00 

Pagosa Springs Town Council, approved on February 2000 

PM10 State Implementation Plan Submittal 

U.S. Environmental Protection Agency: approved 05/19/94, effective 06/20/94 

Colorado Air Quality Control Commission, approved on 11/19/92; 11/12/93 

Revisions Prepared By: 

Air Pollution Control Division 

Colorado Department ofPublic Health and Environment 

4300 Cherry Creek Drive South 

Denver, Colorado 80246 
[Blank Page] 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 2 of 25
 

September 1, 2009
 
Table of Contents 

SECTION 1: INTRODUCTION	 5
 

A. BACKGROUND	 6
 

.1. PM10 National Ambient Air Quality Standard 6
 

Health and Welfare Effects of PM1 0 6
 

3.	 Pagosa Springs Nonattainment Area Classification History 7
 

4.	 Pagosa Springs Attainment/Maintenance Area Boundaries 7
 

B. ORGANIZA nONS INVOLVED IN PREPARING AND APPROVING
 

PLAN 8
 

C. REQUIREMENTS FOR REDESIGNATION AND MAINTENANCE 8
 

.1. Attainment of the Standard 9
 

2. State Implementation Plan (SIP) Approval 9
 

Permanent and Enforceable Improvement in Air Quality 9
 

4.	 Section 110 and Part 0 Requirements 9
 

5. Maintenance Plan '" 9
 

SECTION 2: PM10 ATTAINMENT HISTORY 10
 

A. MONITORING HiSTORy	 10
 

B. DESIGN VALUE DETERMINATION	 11
 

SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL .. 12
 

A.	 1988 SIP ELEMENT 12
 

B.	 1992 and 1993 SIP ELEMENTS 12
 

C.	 1994 SIP ELEMENT REVISION 12
 

D.	 PM10 MAINTENANCE PLAN 12
 

SECTION 4: PERMANENT AND ENFORCEABLE
 

IMPROVEMENT IN AIR QUALITY 13
 

A. OVERViEW	 13
 

B. CONTROL MEASURES	 13
 

1."	 Control of Emissions through Road Paving 14
 

2.	 Street Sanding Controls 14
 

3.	 Control of Emissions from Stationary Sources 14
 

4.	 Federal Motor Vehicle Emission Control Program 15
 

5. Voluntary and State-Only Measures 15
 

SECTION 5: MAINTENANCE PLAN 16
 

A. REQUiREMENTS	 16
 

B. EMISSION INVENTORIES	 16
 

1."	 2007 Base Emission Inventory 17
 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 3 of 25
 

September 1, 2009
 
	 2015 Interim Emission Inventory 18
 

3.	 2021 Emission Inventory 19
 

C.	 MAINTENANCE DEMONSTRATION 20
 .L CMS Source Apportionments of High Concentrations 21
 

CMS Roll-forward Analysis 21
 

D.	 PM10 EMISSION BUDGET 23
 

E. MONITORING NETWORKIVERIFICATION OF CONTINUED
 

ATTAINMENT 23
 

F.	 CONTINGENCY PLAN 23
 

.L Tracking 24
 

Trigger and Response 24
 

Potential Contingency Measures 24
 

G.	 SUBSEQUENT MAINTENANCE PLAN REVISIONS 25
 

Revised PM10 Maintenance Plan for Pagosa Springs AttainmentiMaintenance Area Page 4 of25 

September 1, 2009 
SECTION 1: INTRODUCTION 

This document is the second revision of the PM10 Maintenance Plan for the Pagosa 

Springs Attainment/Maintenance Area. The Environmental Protection Agency (EPA) 

first approved a particulate matter under 10 microns redesignation request and 

maintenance plan for the Pagosa Springs area on June 15, 2001 (66 FR 32556), which 

became effective on August 14,2001. The Pagosa Springs redesignation request and 

maintenance plan was adopted by the Colorado Air Quality Control Commission 

(AQCC) on March 16, 2000. 

This second maintenance plan, as revised in 2009, supersedes and replaces the first 

maintenance plan adopted by the Commission in 2000. The 2009 revised plan includes 

updated the emissions inventories and projections using the latest EPA-approved tools. 

This maintenance plan also revises the PM10 emission budget from 7,486 pounds per 

winter-time day in 2012 to 1,546 pounds per average day in 2021 and beyond. 

The Town of Pagosa Springs, Archuleta County, and the State of Colorado request 

continuation of "attainment/maintenance" status for the Pagosa Springs PM10 

nonattainment area. The Pagosa Springs area was originally designated as 

nonattainment for the National Ambient Air Quality Standards (NMQS) for particulate 

matter with an aerodynamic diameter of ten microns or less (PM10) since 1990, 

although the area is presently demonstrating attainment with the PM10 NMQS. The 

Maintenance Plan section of this document has been updated and will demonstrate that 

the area will be able to maintain the NMQS through the year 2021. The benefits of 

maintaining a redesignation to attainment status include: 

1.	 Areas redesignated to attainment lose the stigma associated with nonattainment 

of the NMOS. 

2.	 Areas redesignated to attainment do not become "serious" nonattainment areas 

even if a violation of the NAAQS occurs. This means that specific control 

measures can be applied to address a violation without going through a rigorous 

federal process, where serious areas must implement mandatory control 

measures and be subject to numerous administrative activities. 

3.	 Prevention of Significant Deterioration (PSD) permitting requirements replace 

New Source Review (NSR) permitting requirements for new and modified major 

stationary sources. These permitting requirements are important for large 

industrial facilities that are not currently located, nor likely to locate, in the 

Pagosa Springs area. 

This analysis is designed to document and ensure continuing attainment and 

maintenance of the NMQS for PM10 in the Pagosa Springs area. This document is 

intended to comply with requirements of the federal Clean Air Act (CM), and with 

relevant procedures and policies of the United States Environmental Protection Agency 

(EPA). 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 5 of25 

September 1, 2009 
A. BACKGROUND 

1. PM10 National Ambient Air Quality Standard 

In 1971, the EPA set NAAQS for several air pollutants, including total suspended 

particulates (TSP), defined as particles with an aerodynamic diameter of less than 40 

microns. In 1987, the EPA changed the TSP standard to thePM10 NAAQS. The 

current PM1 0 NAAQS allow for a maximum 24-hour average of 150 ug/m3. The 24­

hour PM1 0 NAAQS may not be exceeded more than three times over any three year 

period. 

There are both primary and secondary air quality standards. The primary standards are 

set to protect human health, with a margin of safety to protect the more sensitive 

persons in the population, such as the very young, elderly and the ill. Secondary 

standards are set to protect property, materials, aesthetic values and general welfare. 

For PM1 0, the national primary and secondary standards are the same. The numerical 

levels of the standards are subject to change, based on new scientific evidence 

summarized in air quality criteria documents. In 2006, the EPA revoked the annual 

PM10 standard but maintained the 24-hour average of 150 ug/m3 (see 71 FR 61144) 

for both the primary and secondary NAQQS. 

In general, demonstrating attainment requires collecting representative air monitoring 

data and using approved measuring instruments and procedures, with adequate quality 

assurance and quality control. Air quality measurements in the Pagosa Springs area 

satisfy this requirement, as shown in Section 2 - "Table 1 - PM1 0 Monitoring Record". 

2. Health and Welfare Effects of PM1 0 

Particulate matter is the term given to tiny particles of solid or semi-solid material 

suspended in the atmosphere, and PM10 is inhaleable particulate matter 10 

micrometers in diameter and smaller. In the Pagosa Springs area, PM1 0 is created 

from re-entrained road dust, carbon black (from automobile and diesel engines) and 

soot (from fireplaces, woodstoves, and coal stoves). PM10 from these combustion 

sources contains a large percentage of elemental and organic carbon, which 

contributes to atmospheric haze and to health problems. 

Epidemiological studies and laboratory studies of humans and animals indicate that fine 

particles can be inhaled deeply into the respiratory system, resulting in aggravation of 

existing respiratory and heart diseases, damage to lung tissue, impairment of breathing 

and respiratory functions, alterations to the body's physical and immune system 

defenses, and even premature death. Many fine particles are also composed of 

compounds that are known or suspected human carcinogens. People most sensitive to 

particulate matter are the elderly, children, and those with chronic lung disease, 

cardiovascular disease, influenza, and asthma. 

The welfare effects of particulate air pollution are wide-spread. Because of the 

potential for extremely long-range transport of fine particles it is thought that no place 

on earth is free of particulate pollution generated by urban and rural sources. Chemical 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 60f25 

September 1, 2009 
and photo-chemical reactions involving the particles may occur in the air, or once they 

have been deposited on environmental media or structures. Such soiling and acid 

deposition cause visibility degradation, climate changes, and damage to crops, natural 

vegetation, water bodies, and aquatic life. In addition, sculpture and architecture may 

be damaged or destroyed by particulate soiling and acid deposition--both of which have 

been detected in the most remote areas of the world. 

3. Pagosa Springs Nonattainment Area Classification History 

Because of observed problems with air particles, monitoring of total suspended 

particulates (TSP) began in 1975, and continued through 1987. In 1987, based on 

relatively high TSP levels, the Pagosa Springs area was designated as a "Group I" area 

for PM10. Pagosa Springs was then designated a "moderate" nonattainment area in 

1990 pursuant to section 107(d)(4)(B) of the CAA. 

4. Pagosa Springs Attainment/Maintenance Area Boundaries 

The boundary for the Pagosa Springs PM10 attainment/maintenance area is defined as 

follows: 

Township 35 North & Range 2 West 

Sections 13, 14,15 

Section 23 NE, N SE 

Section 24 all except SWSW 

Section 25 N NE, NENW 

Township 35 North & Range 1 West 

Section 18 W 

This area essentially includes the Town of Pagosa Springs, some additional area along 

the San Juan River, some areas along U.S. Highway 160 outside of the Town's limits. 

A map illustrating the area boundary is shown in Figure 1. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 7 of 25 

September 1, 2009 
Figure 1: Map of the Pagosa Springs Attainment/Maintenance Area 

045 09 

Ipagosa~ln9s PM:Cttainmenr-a 

I 

Designation_Boundanes 

Legend 

+ AIRPORTS 

• POint Sources 

- Local Roads 

B. ORGANIZA TlONS INVOLVED IN PREPARING AND APPROVING 

PLAN 

Preparation of this revised maintenance plan was a cooperative effort of the Town of 

Pagosa Springs, Archuleta County, and the Air Pollution Control Division (APCD) of the 

Colorado Department of Public Health and Environment. The document was approved 

by the the Colorado Air Quality Control Commission (AQCC) on November 19, 2009. 

The EPA, through its regional office in Denver, provided policy advice and technical 

assistance, and is responsible for final approval of this revised maintenance plan. 

C. REQUIREMENTS FOR REDESIGNA TlON AND MAINTENANCE 

Section 107(d)(3)(D) and (E) of the CAA defines the five required cornponents of a 

redesignation request and maintenance plan. These components and their 

descriptions follow: 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 8 0(25 
1. Attainment of the Standard 

The State must show that the area is attaining the PM 10 NAAQS. This demonstration 

must be based on monitoring data representative of the location of the expected 

maximum concentrations of PM10 in the nonattainment area. 

2. State Implementation Plan (SIP) Approval 

The State must demonstrate that it has a fully approved State Implementation Plan 

(SIP) Element for Pagosa Springs under Section 11 O(k) of the CAA. 

3. Permanent and Enforceable Improvement in Air Quality 

The State must demonstrate that the improvement in air quality leading to redesignation 

is due to permanent and federally enforceable emissions reductions. 

4. Section 110 and Part D Requirements 

The State must meet all requirements of Section 110 and Part D of the CAA. Section 

110 describes general requirements of SIPs, while Part D pertains to requirements 

applicable to nonattainment areas. 

5. Maintenance Plan 

The State must have a fully approved maintenance plan that meets the requirements of 

Section 175A of the CAA. This plan must provide for the maintenance of the NAAQS 

for at least 10 years following redesignation, and the plan must contain a contingency 

plan that describes potential control measures that could be implemented to ensure 

continued maintenance of the PM1 0 NAAQS. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 90f25 
SECTION 2: PM10 ATTAINMENT HISTORY 

A. MONITORING HISTORY 

Monitoring for total suspended particulates (TSP) in Pagosa Springs began in August 

1975 at the Pagosa Springs High School and continued through September 1987. TSP 

monitoring was also conducted at the Towll Hall from March 1987 through September 

1987. Concentrations at both of these monitoring locations exceeded the 24-hour TSP 

NAAQS of 260 ug/m3 and the annual NAAQS of 75 ug/m3. The historic TSP levels 

were the basis for Pagosa Springs being designated as a "Group I" area for the new 

PM10 standards, which were promulgated by the EPA in 1987. Group I locations were 

those areas estimated to have a greater than 95 percent probability of exceeding the 

new PM10 standards. 

Monitoring for PM 10 began in August 1985 at the Pagosa Springs High School and an 

additional PM10 monitor was established at the Town Hall in January 1988. The Town 

Hall site was determined to be more representative of maximum PM concentrations and 

accordingly the High School site was decommissioned in August 1990. The Town Hall 

location was operated until 2001 when a major building renovation necessitated 

relocation of the PM monitor back to the High School location. 

Table 1 lists the yearly maximum, second maximum and estimated exceedances for the 

Town Hall and High School monitoring sites for the 1a-year period from 1998 through 

2008. Only one exceedance of the 24-hour PM1 a NAAQS was recorded in 2000 at the 

Town Hall site. 

Table 1: Pagosa Springs PM10 Monitoring Record 

Year 

Maximum 

Concentration 

(ug/m3 

) 

2nd Maximum 

Concentration 

(ug/m3) 

Yearly 

Estimated 

Exceedances 

3-yr Average 

Estimated 

Exceedances 

Monitoring Site 

1998 66 66 0 0 Town Hall 

1999 138 82 0 0 Town Hall 

2000 165 87 1 0.33 Town Hall 

2001 123 121 0 0.33 Town Hall 

2001 66 61 0 0.33 High School 

2002 107 82 0 0.33 High School 

2003 123 111 0 0 High School 

2004 79 61 0 0 High School 

2005 82 77 0 0 High School 

2006 122 53 0 0 High School 

2007 102 59 0 0 High School 

2008 149 74 0 0 High School 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 10 of25 
B. DESIGN VALUE DETERMINA TION 

The "design value" is the critical air quality value from which the maintenance plan is 

based. The design value, and the conditions that occurring on the day which it was 

measured, are utilized to develop emission inventories and serve as a baseline for 

modeling ambient concentrations into the future. The selection of this design value 

utilized EPA's table look-up method from EPA's "PM10 SIP Development Guideline" 

document. Based on the number of samples collected during the 2006 - 2008 period 

(1,069), the third highest concentration is the design value, according to this guidance. 

The three highest concentrations measured during the period 2006 -2008 are as 

follows: 

149 ug/m3 - May 1, 2008 

122 ug/m3 - February 15, 2006 

102 ug/m3 - June 6, 2007 

Consequently, the design value for this revised maintenance plan is 102 ug/m3. 

It is important to note that the May 1st , 2008 value of 149 ug/m3 may be the result of a 

blowing dust event, which could be considered as an "exceptional event". The APCD is 

investigating the circumstances surrounding this event, but this value is still being used 

in the design value calculation. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 11 of 25 
SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL 

The following presents a brief summary of the development and the approval of the 

Pagosa Springs PM10 nonattainment SIP Element. 

A. 1988 SIP ELEMENT 

The first PM10 SIP Element was adopted by the Colorado AQCC in July 1988, and the 

emission controls consisted of paving unpaved roads. EPA Region VIII intended to 

approve the SIP Element, though it eventually was rejected once the Clean Air Act was 

amended in 1990 and new, more stringent requirements were in place. 

B. 1992 and 1993 SIP ELEMENTS 

A new Pagosa Springs SIP Element was adopted by the AQCC in November 1992 and 

supplemented in November 1993. The control measures included the paving of local 

roads adopted for the 1988 SIP Element and street sanding requirements on the State 

highways. New street sweeping requirements were adopted as contingency measures. 

EPA approved the SIP Element on May 19,1994 (59 FR 26126). 

C. 1994 SIP ELEMENT REVISION 

The Pagosa Springs SIP Element was revised by the AQCC in November 1994. This 

revision consisted of updating the technical and administrative information. EPA had 

previously approved these technical and administrative revisions in the May 1994 action 

because they were submitted directly to EPA by the APCD in December 1993. 

D. PM10 MAINTENANCE PLAN 

The Pagosa Springs Town CounCil approved the PM Maintenance Plan on February 

2000 that was adopted by the Commission on March 16,2000. The U.S. 

Environmental Protection Agency approved the plan on June 15, 2001 which became 

effective on August 14, 2001. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 12 of25 
SECTION 4: PERMANENT AND ENFORCEABLE 

IMPROVEMENT IN AIR QUALITY 

The State must demonstrate, based on Section 107(d)(3)(E) of the CAA, that the 

improvement in air quality leading to attainment of the NAAQS and the redesignation 

request is based on permanent and enforceable measures, and that the reductions are 

not the result of temporary reductions in emissions or unusually favorable meteorology. 

A~ OVERVIEW 

It is reasonable to attribute the attainment of the PM1 0 NAAQS in the Pagosa Springs 

nonattainment area to emission reductions that are permanent and enforceable. These 

emission reductions are the result of local, State, and federal actions, not economic 

factors or unusual meteorology. 

Economic conditions are clearly not responsible for improved ambient levels in the 

Pagosa Springs attainment/maintenance area. It is assumed that growth in population 

and sales tax revenue are indicators of increased activities that cause increased PM1 0 

emissions and the potential for elevated PM10 concentrations. Information obtained 

for the Town of Pagosa Springs shows that during the period 2000 through 2007, sales 

tax revenues increased by 45.8 percent while Archuleta County population increased by 

26 percent over the same period. During this period of rapid growth, attainment of the 

PM10 NMQS was demonstrated with only one exceedance (165 ug/m3 in 2000) and 

few concentrations over a 100 ug/m3 threshold. 

Favorable meteorology is also an unlikely reason why the area's PM1 0 concentrations 

are below the NAAQS. Although winter and spring meteorological conditions are highly 

variable in mountain settings, there is no evidence to suggest that meteorological 

conditions experienced in the 2000's have not been "typical" (though it is difficult to 

make concrete conclusions based on short-term meteorological records). Because 

there has not been a violation of the PM1 0 NAAQS in Pagosa Springs since the 

NAAQS was promulgated in 1987, and because there have only been three 

concentrations since 1987 that have exceeded the 24-hour PM 10 NAAQS (258 ug/m3 

and 262 ug/m3 are thought to be due to malfunctioning or poorly operated street 

sweeping equipment and 165 ug/m3in 2000), the APCD concludes that the good air 

quality in the Pagosa Springs area is the result of the implementation of emission 

reduction measures, not meteorological fluctuations. 

B. CONTROL MEASURES 

The following control measures resulted in the area's attainment of the PM10 NAAQS, 

and these measures should ensure continued maintenance of the PM10 NAAQS 

through the year 2021, which is the duration of the maintenance period. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 13 of 25 
1. Control of Emissions through Road Paving 

The Town of Pagosa Springs paved 6.5 miles of unpaved roads during 1992,1993, and 

1994 in order to reduce PM1 0 emissions. This strategy was adopted locally in 1991 

and included in State regulation in 1992 (Section 1.8. of the "State Implementation PlanSpecific Regulations for Nonattainment - AttainmenUMaintenance Areas (Local 

Elements)). The rule was approved by EPA in 1994 and was removed from the 

Colorado regulation in 2000 as the paving requirements had been completed. 

2. Street Sanding Controls 

There is a requirement that any user that applies street sanding material on Highway 

160 and Highway 84 in the Pagosa Springs attainmenUmaintenance area must use 

materials containing less than one percent fines. Users of street sand on these 

highways must also use 15 percent less sand than an established base sanding 

amount. These strategies were adopted in 1992 and approved by EPA in 1994, and 

they are defined in detail in Sections LB. and C., respectively, of the "State 

Implementation Plan-Specific Regulations for Nonattainment - AttainmenUMaintenance 

Areas (Local Elements) Regulations (5 CCR 1001-20). 

3. Control of Emissions from Stationary Sources 

Although there are no stationary sources located in the Pagosa Springs 

attainmenUmaintenance area, the State's comprehensive permit rules will limit 

emissions from any new source that may, in the future, locate in the area. These rules 

include: 1) Regulation No.3, "Air Pollution Emission Notices, Construction Permits and 

Fees, Operating Permits, and Including the Prevention of Significant Deterioration," 2) 

the "Common Provisions" regulation, and 3) Regulation No.6, "Standards of 

Performance for New Stationary Sources." 

The Common Provisions, and Parts A and B of Regulation No.3, are already included 

in the approved SIP. Regulation NO.6 implements the federal standards of 

performance for new stationary sources. The maintenance plan makes no changes to 

these regulations. This reference to Regulation NO.6 shall not be construed to mean 

that this regulation is included in the SIP. 

As indicated above, emissions from new or modified major stationary sources 

emissions of PM1 0 are controlled under Regulation No. 3's nonattainment-area (NAA) 

new source review (NSR) permitting requirements. The NSR provisions require all new 

and modified major stationary sources to apply emission control equipment that 

achieves the "lowest achievable emission rate" (LAER) and to obtain emission offsets 

from other stationary sources of PM1 O. 

The EPA approval of the original PM1 0 Maintenance Plan, effective on 08/14/01, 

reinstates the prevention of significant deterioration (PSD) permitting requirements in 

the Pagosa Springs AttainmenUMaintenance area. The federal PSD requirements are 

considered a relaxation from the NAA NSR requirements, as LAER is no longer 

required and is replaced by the less stringent "best available control technology" 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 14 of 25 
(BACT), along with the removal of the requirement to offset PM 10 emissions. The 

future reapplication of NAA NSR provisions appears unlikely in the Pagosa Springs 

AttainmenVMaintenance area based on current PM10 monitoring trends. 

4. Federal Motor Vehicle Emission Control Program 

The federal motor vehicle emission control program has reduced PM10 emissions 

through a continuing process of requiring diesel engine manufacturers to produce new 

vehicles that meet tighter and tighter emission standards. As older, higher emitting 

diesel vehicles are replaced with newer vehicles; the PM1 0 emissions in the Pagosa 

Springs area will be reduced. 

5. Voluntary and State-Only Measures 

In addition to the mandatory control measures discussed above, there are other 

activities that result in the reduction of PM10 emissions that are not classified as 

"federally enforceable control measures." Some notable examples include: 

•	 The Town of Pagosa Springs has historically cleaned Highway 160 in town 

throughout the winter and spring using regenerative air vacuum sweepers. The 

frequency of this voluntary sweeping/cleaning has been about once after each street 

sanding deployment. For the future, the Town of Pagosa Springs has committed to 

regularly vacuum sweep/clean Highway 160 within four days of the roadway 

becoming free and clear of snow and ice following each street sanding deployment, 

as weather, temperature, and street conditions permit, between the intersections of 

Highway 84 to the east and 14th street to the west. 

•	 The Town of Pagosa Springs requires that all new developments have paved 

streets. 

•	 The Town of Pagosa Springs encourages private businesses to properly 

clean/sweep private parking lots on a regular basis. 

•	 Archuleta County commits to pave the unpaved portion of Hot Springs Boulevard 

from the existing pavement to the boundary of the airshed. 

•	 Any owner or operator responsible for the construction or maintenance of any 

existing or new unpaved roadway which has vehicle traffic exceeding 200 vehicles 

per day in the attainmenVmaintenance area and surrounding areas must stabilize 

the roadway in order to minimize fugitive dust emissions. These State-wide 

requirements are defined in detail in Section III.D.2.a.(I) of the AQCC's Regulation 

NO.1. 

These strategies are considered to be voluntary local initiatives and State-only 

requirements, and are intended to reduce PM10 emissions. These strategies are not 

intended to be federally enforceable. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 15 of 25 
SECTION 5: MAINTENANCE PLAN 

A. REQUIREMENTS 

Section 107(d)(3)(E) of the CAA provides that for an area to be redesignated to an 

attainment classification, EPA must fully approve a maintenance plan which meets the 

requirements of CAA Section 175A. The maintenance plan will constitute a SIP 

revision and must provide for maintenance of the relevant NAAQS in the area for at 

least ten years after redesignation. Since the requirement is for ten years after 

redesignation, some lead time for the EPA approval process (up to 18 months per CAA 

Section 107(d)(3)(D)) should be considered in establishing the maintenance year, which 

the State determines to be 2021. An additional requirement (Section 175A(d)) is the 

submittal of a SIP revision eight years after the original redesignation 

request/maintenance plan is approved that provides for maintenance of the NAAQS for 

an additional ten years following the first ten-year period. The State of Colorado has 

satisfied this commitment by submitting this revised maintenance plan as required by 

the CAA and EPA requirements. 

Section 175A further states that the plan shall contain such additional control measures 

as necessary to ensure maintenance. All current nonattainment area control measures 

shall remain in place, except for the most stringent NSR stationary source permitting 

requirements (see Section 4.8.3.). The maintenance plan shall contain a contingency 

plan to ensure the prompt correction of any unforeseen violation of the PM1 0 NAAQS. 

Failure to maintain the NAAQS and triggering of the contingency plan will not 

necessitate a revision of the SIP Element, unless required by the EPA Administrator, as 

stated in CAA Section 175A(d). 

The provisions that are addressed in this maintenance plan include emission 

inventories (for a base year and a future year), a maintenance demonstration, an 

emission budget, an approved monitoring network, verification of continued attainment, 

and a contingency plan. 

B. EMISSION INVENTORIES 

The below emission inventories include the 2007 base year, 2015 interim year and the 

2021 maintenance year. These inventories reflect the base and projected conditions in 

the Pagosa Springs Attainment/Maintenance Area, and account for the emission control 

measures that have been adopted as part of the original redesignation request and the 

previous 1O-year maintenance plan. Unlike the previous Pagosa Springs plans where 

the emission inventories were based on a grid system of the attainment/maintenance 

area and an average winter-time day, the updated emission inventories, for 2007,2015 

and 2021, are based on an all-seasons average day for the whole maintenance area. 

Consequently there are significant differences between the emission inventories in the 

previous Plan and this updated PM10 Maintenance Plan. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 16 of 25 
1. 2007 Base Emission Inventory 

The 2007 base emission inventory for the Pagosa Springs Attainment/Maintenance 

Area is presented below. This updated emission inventory incorporates the most 

current estimates for the following nine (9) source categories: 

•	 Commercial Cooking 

•	 Construction 

•	 Fuel Combustion 

•	 Non-Road 

•	 Structure Fires 

•	 Wood-burning 

•	 Unpaved Road Dust 

•	 Paved Road Dust 

•	 Highway Vehicles 

•	 Agriculture 

The mobile source inventories (unpaved road dust, paved road dust, and highway 

vehicles) have been updated to reflect the following: 

•	 Latest traffic (VMT) estimates from the Colorado Department of Transportation 

(COOT) 

•	 Revised emission factors and methods for determining paved road emissions 

•	 Road paving of unpaved roads that has occurred in the area 

•	 Vehicle exhaust emissions based on most up-to-date fleet mix 

All emission estimates were prepared by using EPA-approved methods and assigned to 

the area comprising the Attainment/Maintenance area. 

Table 2 presents the 2007 PM10 emission estimates for each source category in tons 

per year and pounds per average day. 

Table 2: 2007 PM10 Emission Inventory for the
 

Pagosa Springs Attainment/Maintenance Area
 

Source Category 2007 PM10 [tons/year] 2007 PM10 [Ibs/day] 

Commercial Cooking 1.18 6.44 

Construction 52.11 285.52 -

Fuel Combustion 0.01 0.07 

Non-Road 1.73 9.49 

Structure Fires 0.02 0.09 

Wood Burning 17.77 97.38 

Unpaved Road-Dust 16.27 89.16 

Paved Road-Dust 93.10 510.13 

Highway Vehicles 2.06 11.31 

AQriculture 0.03 0.15 

Totals: 184.3 1,009.8 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 17 of 25 
2. 2015 Interim Emission Inventory 

Table 3 presents the 2015 PM 10 emission estimates for each source category in tons 

per year and pounds per average day. 

The 2015 emissions for the following source categories: commercial cooking; 

construction; fuel combustion; non-road; structure fires; and wood burning, were 

increased by an annual compounded rate of 2.90 percent per year (1.02897 or 23.18% 

total), which is based on the population forecast (from State Demography Office) for 

Archuleta County over the period 2007 to 2015 as indicated in Figure 2. Detailed 

information on the growth rate may be found in the Technical Support Document. 

Figure 2: Population Forecasts for Archuleta County 

Population Forecasts 

for Archuleta County 

20,000 

c 15,000 

.~.... 

III 10,000 :J 

a. 

0 

Co. 5,000 

0 ., 

The 2007 mobile source re-entrained dust emissions for all road categories (paved and 

unpaved) were increased by an annual compounded rate of 4.013 percent to 2015 

(1.040125 or 32.100 total). This growth rate was based on COOTs highest projected 

traffic growth rates for different segments of the State highways in the Pagosa Springs 

area. 

The 2007 mobile source tailpipe PM emissions were reduced by an annual 

compounded rate of 0.81 percent to 2015 (-0.008125 or -6.500% total). The reduction 

in PM emissions is associated with anticipated fleet turnover projected by MOBILE 6.2. 

The Pagosa Springs Attainment/Maintenance Area is urbanized with mountainous 

terrain that is largely unsuitable for agriculture, so the future growth in agriculture 

emissions is assumed to be flat. 

The road paving that the Town of Pagosa Springs and Archuleta County plan on 

completing is not assumed in the 2015 inventory as the paving is considered voluntary 

and not enforceable by the State. Detailed information on the growth rates may be 

found in the Technical Support Document. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 18 of 25 
Table 3: 2015 PM10 Emission Inventory for the
 

Pagosa Springs Attainment/Maintenance Area
 

Source Category 2015 PM10 

[tons/year] 

2015 PM10 

[Ibs/day] 

Change from 2007 

Base Year rio] 

Commercial Cooking 1.45 7.93 23.176% 

Construction 64.18 351.69 23.176% 

Fuel Combustion 0.02 0.09 23.176% 

Non-Road 2.13 11.69 23.176% 

Structure Fires 0.02 0.12 23.176% 

Wood BurninQ 21.89 -------­

119.95 1-­23.176% 

Unpaved Road-Dust 21.49 117.78 32.087% 

Paved Road-Dust 122.98 673.89 32.102% 1-­

Highway Vehicles 1.93 10.58 -6.500% 

Agriculture 0.03 0.15 0.000% 

Totals: 236.1 1,293.9 

3. 2021 Emission Inventory 

Table 4 presents the 2021 PM10 emission estimates for each source category in tons 

per year and pounds per average day. 

The 2021 emissions for the following source categories: commercial cooking; 

construction; fuel combustion; non-road; structure fires; and wood burning, were 

increased by an annual compounded rate of 3.59 percent per year (1.03592 or 50.28% 

total), which is based on the population forecast (from State Demography Office) for 

Archuleta County over the period 2007 to 2021 as indicated in Figure 2 above. Detailed 

information on the growth rate may be found in the Technical Support Document. 

The 2007 mobile source re-entrained dust emissions for all road categories (paved and 

unpaved) were increased by an annual compounded rate of 4.013 percent to 2021 

(1.04125 or 56.175% total). This growth rate was based on COOTs highest projected 

traffic growth rates for different segments of the State highways in the Pagosa Springs 

area. 

The 2007 mobile source tailpipe PM emissions were reduced by an annual 

compounded rate of 0.81 percent to 2021 (-0.008125 or -11.374% total). The reduction 

in PM emissions is associated with anticipated fleet turnover projected by MOBILE 6.2. 

The Pagosa Springs Attainment/Maintenance Area is urbanized with mountainous 

terrain that is largely unsuitable for agriculture, so the future growth in agriculture 

emissions is assumed to be flat. 

The road paving that the Town of Pagosa Springs and Archuleta County plan on 

completing is not assumed in the 2021 inventory as the paving is considered voluntary 

and not enforceable by the State. Detailed information on the growth rates may be 

found in the Technical Support Document. 

The projected emissions for the year 2021 are 1,546 pounds/day, as indicated in Table 

4, which are higher than the 2015 interim year emission projections of 1,294 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 19 of 25 
pounds/day. Consequently, the demonstration of maintenance of the PM1 0 NAAQS for 

2021 is adequate to demonstrate maintenance for all years before 2021. 

Table 4: 2021 PM10 Emission Inventory for the
 

Pagosa Springs Attainment/Maintenance Area
 

Source Category 2021 PM10 

[tons/year] 

2021 PM10 

[lbs/day] 

Change from 2007 

Base Year rk] 

Commercial Cookinq 1.77 9.70 50.28% 

Construction 78.31 429.10 50.28% 

Fuel Combustion 0.02 0.11 50.28% 

Non-Road 2.60 14.25 50.28% 

Structure Fires 0.03 0.16 50.28% 

Wood Burnillq 26.71 146.36 50.28% 

Unpaved Road-Dust 25.41 139.23 56.18% 

Paved Road-Dust 145.40 796.71 56.18% 

Hiqhway Vehicles 1.83 10.03 -11.37% 

Agriculture 0.03 0.15 0% 

Totals: 282.1 1,545.8 

C. MAINTENANCE DEMONSTRATION 

Data presented throughout this document are utilized to demonstrate continued 

maintenance of the PM 10 NAAQS for the Pagosa Springs area. Chemical Mass 

Balance (CMB) data are used to generally identify the sources of emissions that 

influence ambient PM 10 concentrations. The 2007 emission inventory is used to 

further refine this CMB-source identification. This information is then used to apportion 

the design day concentration (see Section 2.B.), which becomes the basis for the "roll 

forward" modeling. The apportioned design day concentration is then projected, or 

rolled forward, into the future based on the changes that occur in the emissions 

inventory from 2007 to 2021. If the 2021 projection is below the 24-hour PM10 NAAQS 

of 150 ug/m3, then maintenance is demonstrated. Based on the analysis presented 

below, the 2021 maintenance concentration for the Pagosa Springs 

attainment/maintenance area is calculated at 146.3 ug/m3. Consequently, continued 

maintenance of the PM1 0 NAAQS is demonstrated. 

The CMB roll-forward methodology used to calculate the 2021 maintenance 

concentration is based on CMB data for concentrations above 100 ug/m3 that were 

collected in 1994, 2006 and 2008. The source apportionments from each of these days 

were averaged to develop a design day apportionment for use in the roll-forward 

modeling. Concentrations that occurred prior to 1994 underwent CMB analyses, but 

the results are not utilized here because the control measures adopted as part of the 

nonattainment SIP Element had not been fully implemented. Also, the CMB data from 

the two highest values measured in 1994 (262 ug/m3 and 258 ug/m3), are not included 

because they would heavily bias the CMB results (geologic emissions were greatly 

elevated on these days due to malfunctioning or poorly operated street cleaning 

equipment, and these emissions are not representative of typical conditions that occur 

in the winter months). Finally, not all years with values exceeding 100 ug/m3 have 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 20 of 25 
CMS analysis, so the following five samples from 1994, 2006 and 2008 are considered 

to representative of high concentration episodes in the area. 

The average CMS source apportionment, in percent contribution, for geologic, burning, 

nitrate, sulfate and unknown source categories is indicated in Table 5. 

1.	 CMS Source Apportionments of High Concentrations 

Table 5 Chemical Mass Balance Source Apportionment 

Town Hall and High School Monitoring Site§. 

Date PM10 

(ug/m3) 

Geologic 

(%) 

Burning 

(%) 

Nitrate 

(%) 

Sulfate 

(%) 

Unknown 

(%) 

Valid 

CMB? 

02/16/94 101 74 14 1 1 10 y 

03/03/94 105 71 9 0 1 19 y 

05/05/94 109 87 0 1 2 10 y 

02/15/06 122 82 7.3 1 2 7.7 Y 

05/01/08 149 81 6.4 2 2 8.6 y 

Average 117.2 79.0% 7.3% 1.0% 1.6% 11.1% 100% 

Geologic =sources rich in crustal elements (street sand, soil, road dust) 

Burning = carbon-rich sources such as wood burning and coal burning 

Nitrate =NH4N03 particulate formed in the atmosphere from NOx and NH3 

Sulfate =(NH4hS04 particulate formed in the atmosphere from S02 and NH3 

2. CMS Roll-forward Analysis 

Subtract the Background Concentration from the Design Value Concentration: 

The background concentration is subtracted from the 102 ug/m3 design day 

concentration (see Section 2.S) because the background concentration would remain if 

all emissions in the emissions inventory were reduced to zero. A background PM10 

concentration of 8 ug/m3 is assumed to occur on any given day in the area, as 

described in the November 1994 SIP Element. 

Design Day Concentration: 102 ug/m3 

Background Concentration: - 8 ug/m3 

94 ug/m3 

Apportion the Design Day Concentration with the CMB Apportionments: 

Geologic:	 94 x 0.790 = 74.3 ug/m3 

Burning:	 94 x 0.073 = 6.9 ug/m3 

Nitrate:	 94 x 0.010 = 0.9 ug/m3 

Sulfate:	 94 x 0.016 = 1.5 ug/m3 

Unknown:	 94 x 0.111 = 10.4 ug/m3 

94.0 ug/m3 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 210'25 
Percent Change in Emissions between 2007 and 2021 

rY.,alues used to roll-forward the CMS apportionments to the year 2021) 

Highways. Paved Roads. and Unpaved Roads: PM10 emissions increased by 

335.4 Ibs./day, or 54.9% 

Wood burning and structure fires: PM 10 emissions increased by 49.1 Ibs/day, or 

50.3% 

Roll-forward Apportionments to 2021 :
 

(Calculated by applying the Percent Change in emissions from 2007 to 2021)
 

Geologic (G):	 Re-entrained fugitive dust from highways, paved roads, 

and unpaved roads are assumed to contribute all geologic 

emissions that resulted in 74.3 ug/m3 of PM1 o. This 

concentration will change by the percent change in 

emissions from these sources. 

74.3 ug/m3 x 1.549 = 115.1 ug/m3 

Burning (8):	 Wood burning and structure fires are assumed to 

contribute to the burning emissions that resulted in 6.9 

ug/m3 of PM1 o. This concentration will change by the 

percent change in emissions from these sources. 

6.9 ug/m3 x 1.503 = 10.4 ug/m3 

Nitrate (N):	 Unknown sources contributed emissions that resulted in 

0.81 ug/m3 of secondary PM10. It is assumed that this 

concentration remains constant because no emissions can 

be assigned to this category. 

0.9 ug/m3 x 1.000 = 0.9 ug/m3 

Sulfate (5):	 Unknown sources contributed emissions that resulted in 

1.5 ug/m3 of secondary PM1 O. It is assumed that this 

concentration remains constant because no emissions can 

be assigned to this category. 

1.5 ug/m3 x 1.000 = 1.5 ug/m3 

Unknown (U): Unknown sources contributed emissions that resulted in 

10.4 ug/m3 of PM1 o. It is assumed that this concentration 

remains constant because no emissions can be assigned 

to this category. (Mobile exhaust emissions could be 

assigned to this category, but mobile emissions go down 

slightly from 2007 to 2021; thus leaving this concentration 

constant is a conservative approach.) 

10.4 ug/m3 x 1.000 =10.4 ug/m3 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 22 of25 
Total Projected 2021 Concentration (PM102021 ):
 

(sum of 2021 apportioned components plus the background concentration)
 

PM 102021 =G+ B+ N + S+ U + background =146.3 ~g/m3

PM102021 =115.1+ 10.4 + 0.9 + 1.5 + 10.4 + 8.0 =146.3 ~g/m3

Since the PM102021 value is below the daily PM10 NAAQS (150 ug/m3), 

maintenance of the standard is demonstrated 

D. PM10 EMISSION BUDGET 

Federal "transportation conformity" regulations provide for the use of mobile source 

emission budgets in making conformity determinations in the area. The emission 

budget serves as a ceiling on mobile source emissions that federally funded or 

approved transportation projects must comply or conform. 

This revised maintenance plan establishes a mobile source PM10 emission budget for 

the Attainment/Maintenance area of 946 Ibs/day for 2021 and beyond. This budget is 

the total of the 2021 mobile source PM10 emissions (see Section 5.B.2~. above), which 

includes PM 10 emissions from highways, paved roads, and unpaved roads. 

This bUdget has been adopted in the AOCC's "Ambient Air Quality Standards for the 

State of Colorado" regulation. 

E. MONITORING NETWORKIVERIFICATION OF CONTINUED 

ATTAINMENT 

The APCD has monitored ambient PM1 0 concentrations in the Pagosa Springs area 

since 1986. The APCD has operated, and will continue to operate, the Pagosa Springs 

PM10 monitoring network in full accordance with the federal provisions of 40 CFR Part 

58 and the EPA-approved Colorado Monitoring SIP Element. The APCD will also 

analyze the monitoring data to verify continued attainment of the PM 10 NMOS. This 

information will provide the necessary information to determine whether the Pagosa 

Springs area continues to attain the PM10 NMOS. Detailed information regarding the 

State's monitoring efforts and historical monitoring data can be found in Section 2 of 

this document. 

F. CONTINGENCY PLAN 

Section 175(A)(d) of the CM requires that the maintenance plan contain contingency 

provisions to assure that the State will promptly correct any violation of the PM10 

NMOS that may occur after the redesignation of the area to attainment. EPA's 

redesignation guidance notes that the State is not required to have fully adopted 

contingency measures that will take effect without further action by the State. However, 

the contingency plan should ensure that contingency measures are adopted 

expediently once the need is triggered. The primary elements of the contingency plan 

involve the tracking and triggering mechanisms to determine when contingency 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 23 of 25 
measures would be needed and a process for implementing appropriate control 

measures. 

1. Tracking 

The tracking plan for the Pagosa Springs area will consist of monitoring and analyzing 

PM 10 concentrations. In accordance with 40 CFR Part 58, Colorado will continue to 

operate and maintain the Pagosa Springs PM1 0 monitoring network. 

2. Trigger and Response 

Triggering of the contingency plan does not automatically require a revision of the SIP 

nor is the area necessarily redesignated once again to nonattainment. Instead, the 

State will normally have an appropriate time-frame to correct the violation with 

implementation of one or more adopted contingency measures. In the event that 

violations continue to occur, additional contingency measures will be adopted until the 

violations are corrected. 

Upon notification of a PM10 NAAQS exceedance, the APCD and local government staff 

in the Pagosa Springs area will develop appropriate contingency measure(s) intended 

to prevent or correct a violation of the PM10 standard. Information about historical 

exceedances of the standard, the meteorological conditions related to the recent 

exceedance(s), and the most recent estimates of growth and emissions will be 

reviewed. The possibility that an exceptional event occurred will also be evaluated.· 

(Notification to EPA, and to the local governments in the Pagosa Springs area, of any 

exceedance will generally occur within 30 days, but no later than 45 days.) This 

process will be completed within six months of the exceedance notification. 

If a violation of the PM10 NAAQS has occurred, a public hearing process at the State 

and local level will begin. If the AQCC agrees that the implementation of local 

measures will prevent further exceedances or violations, the AQCC may endorse or 

approve of the local measures without adopting State requirements. If, however, the 

AQCC finds locally adopted contingency measures to be inadequate, the AQCC will 

adopt State enforceable measures as deemed necessary to prevent additional 

exceedances or violations. Contingency measures will be adopted and fully 

implemented within one year of a PM10 NAAQS violation. Any State-enforceable 

measures will become part of the next revised maintenance plan, submitted to the 

Colorado Legislature and EPA for approval. 

3. Potential Contingency Measures 

The APCD and local government staff may choose one or more of the following 

contingency measures to recommend to local officials and the AQCC for consideration. 

Contingency measures will be selected that quickly bring the area back into 

compliance with the PM1 0 NAAQS and that specifically meet the needs of the Pagosa 

Springs area. It is likely that no federal or State monies will be available to fund the 

implementation of the selected contingency measure(s). Most, if not all, of the costs 

will be borne by local citizens and governments, local businesses, and State 

government agencies. 

• Increased street sweeping requirements 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 24 of25 
•	 Additional road paving requirements 

•	 More stringent street sand specifications 

•	 Voluntary or mandatory coal and/or wood burning curtailment 

•	 Bans on all coal and/or wood burning 

•	 Expanded use of alternative de-icers 

•	 Re-establishing new source review permitting requirements for stationary 

sources 

•	 Transportation control measures designed to reduce vehicle miles traveled 

•	 Other emission control measures appropriate for the area based on the following 

considerations: cost-effectiveness, PM 10 emission reduction potential, economic 

and social concerns, and/or other factors that the State deems appropriate. 

G.	 SUBSEQUENT MAINTENANCE PLAN REVISIONS 

This revised maintenance plan provides for continued maintenance of the PM10 

NMQS for an additional ten years beyond the original ten-year period. Consequently, 

no further maintenance plan updates are anticipated. 

Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 25 of 25 
Technical Support Document 

40 CFR Part 51 Appendix V 2.2 
PM10 Maintenance Plan
 

Pagosa Springs
 

Technical Support Document 

Emission Inventory 

FINAL 

August 4, 2009 

Colorado Department of Public Health and Environment
 

Air Pollution Control Division
 

4300 Cherry Creek Drive South
 

Denver, Colorado 80246
 
Colorado Department of Public Health and Environment / Air POllution Control Division 

Table of Contents 

1. EMISSION INVENTORY METHODOLOGy 1
 

2. ARCHULETA COUNTY POPULATION PROJECTIONS FROM STATE DEMOGRAPHY OFFICE ....2
 

3. 2007 BASELINE EMISSION INVENTORY SUMMARY 2
 

4. 2015 INTERIM EMISSION INVENTORY SUMMARy 3
 

5. 2021 MAINTENANCE EMISSION INVENTORY SUMMARY 3
 

6. REFERENCES 4
 

PM10 Maintenance Plan for Pagosa Springs- Technical Support Document - Emission Inventory 

October 3D, 2009 

ii 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

1. Emission Inventory Methodology 

The Air Pollution Control Division (APCD) developed the 2007,2015 and 2021 emission 

Inventones in the "PM10 Maintenance Plan for Pagosa Spnngs" using U.S. 

Environmental Protection Agency (EPA) approved emissions modeling methods, 

including EPA's MOBILE6 model and local VMT data for on-road mobile source 

emissions, EPA's non-road model, local demographic information for area and off-road 

sources, and reported actual emissions for point sources. Estimates for future emissions 

are based on the above-mentioned tools and the EPA's Economic Growth and Analysis 

System (EGAS) model for estimating future pOint sources activity, and VMT growth for 

on-road mobile sources. 

Highway mobile source emissions are from the EPA model MOBILE6, an emiSSion factor 

model for predicting gram per mile emissions of Hydrocarbons (HC), Carbon Monoxide 

(CO), Nitrogen Oxides (NOx), Carbon Dioxide (C02), Particulate Matter (PM), and tOXICS 

from cars, trucks, and motorcycles under vanous conditions. 

Non-road source emissions are from the EPA Non-Road Model. This model includes the 

Impact of future controls on non-road engines, which is used in equipment such as lawn 

and garden equipment and construction equipment. 

Area source emissions (including heating, construction, railroads, etc.) are from the 2002 

EPA National Emissions Inventory (NEI), grown to 2007,2015 and 2021 by Archuleta 

County population growth from data from the State Demography Office that is provided in 

Table 1. For more documentation for these categories, refer to the NEI documentation 

(EPA, 2008). 

Under Air Quality Control Commission Regulation No.3, the APCD requires any source 

that emits two tons per year or greater to submit an Air Pollutant Emission Notice (APEN) 

(APCD, 2008). This means that sources that emit less than two tons per year are not 

necessarily accounted for in an emIssIons inventory. The point source emiSSIons for 

Pagosa Springs were obtained from this tracking system. The emission estimates are 

made using a variety of methodologies. Data from source-specific emission tests, or 

continuous emission monitors are preferable, but not always available. The EPA has 

developed a variety of emission factors to estimate emissions as well. Emission factors 

are frequently the best or only method available for estimating emissions. 

There are no point sources in the Pagosa Spnngs Attainment Area. 

PM10 Maintenance Plan for Pagosa Springs- Technical Support Document - Emission Inventory 

October 30, 2009 

I 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

2. Archuleta County Population Projections from State 

Demography Office 

Table 1: Archuleta County Population Projections (July 2009) 

2007 

2008 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

2020 

2021 

12,625 

12,704 

12,933 

13,283 

13,659 

14,085 

14,539 

15,044 

15,551 

16,061 

16,598 

17,162 

17,750 

18,361 

18,973 

3. 2007 Baseline Emission Inventory Summary 

This section presents the 2007 emission inventories for the maintenance plan. 

Table 2: 2007 Baseline PM10 Emission Inventory 

1.18 

52.11 

0.01 

1.73 

0.02 

17.77 

16.27 

93.10 

2.06 

0.03 

6.44 

285.52 

0.07 

9.49 

0.09 

97.38 

89.16 

510.13 

11.31 

0.15 

TOTAL: 184.28 1,009.7

PM10 Maintenance Plan for Pagosa Springs- Technical Support Document - Emission Inventory 

October 30, 2009 

2 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

4. 2015 Interim Emission Inventory Summary 

This section presents the 2015 emission inventories for the maintenance plan. 

Table 3: 2015 Interim PM10 Emission Inventory 

1.45 7.93 

64.18 351.69 

0.02, 0.09 

2.13 11,69 

0.02 0.12 

21.89" 119.95 

21 49 117.78 

122.98 673.89 

1.93 10.58 

0.03 0.15 

TOTAL: 236.13 1,293.85 

5. 2021 Maintenance Emission Inventory Summary 

This section presents the 2021 emIssion inventories for the maintenance plan. 

Table 4: 2021 Maintenance PM10 Emission Inventory 

1.77 9.70 

78.31 42910 

0.02 0.11 

2.60 14.25 

0.03 0.16 

26.71 146.36 

25.41 139.23 

14540 796.71 

1.83 10.03 

003 0.15 

TOTAL: 282.11 1,545.79 

PM10 Maintenance Plan lor Pagosa Springs- Technical Support Document - Emission Inventory 

October 30/ 2009 

3 
Colorado Department of Public Health and Environment / Air Pollution Control Division 

6. References 

APCD, 2008. Air Quality Control Commission Regulation Number 3. Stationary Source 

Permitting and Air Pollutant Emission Notice Requirements. 5 CCR 1001-5. 

< http://www.cdphe.state.co.us/regulations/airregs/l 00 103stationarysourcepermitting.pdf > 

U.S. EPA, 2008. "2002 National Emissions Inventory Data & Documentation." 

< http://www.epa.gov/ttn/chief/net/2002inventory.html#documentation > 

PM10 Maintenance Plan for Pagosa Springs- Technical Support Document - Emission Inventory 

October 30, 2009 

4 
Public Comments
 

40 CFR Part 51 Appendix V 2.1 (h)
 
551 Hot Springs Boulevard 

Post Office Box 1859 

Pagosa Springs, CO 81147 

P: 970.264.4151 

F: 970.264.4634 

Town of Pagosa Springs
 

Town Manager
 

November 16,2009 

Barbara Roberts 

Commission Chair 

Colorado Air Quality Control Commission 

4300 Cherry Creek Drive South 

Denver, CO 80246 

.RE: Town of Pagosa Springs - PMIO Attainment and Maintenance Plan Endorsement 

Dear Ms. Roberts: 

The Town of Pagosa Springs is in full support of the revised PMIO Attainment 

and Maintenance Plan for our community. 

Our citizens value the cleaner environment that has been made possible by the 

implementation ofthe PMIO Attainment and .Maintenance Plan. The assistance in 

keeping our air free ofpollution provided by the Colorado Department ofPublic Health 

and Environment's Air Pollution Control Division is greatly appreciated. It has been our 

pleasure to work with Mr. Curt Taipale as the PMlO Plan was updated. He has been both 

patient and helpful. 

We applaud the Colorado Air Quality Control Commission's efforts to update the 

Plan's emissions inventories and demonstration of attainment with the 24-hour National 

Ambient Air Quality Standard (NAAQS) for PMIO through 2021. 

Again, after reviewing the PMl 0 Plan, the Town ofPagosa Springs concurs with 

and endorses its findings. The To\\<n is committed to assuring good air quality for our 

citizens and appreciates the efforts of the Colorado Air Quality Control Commission. 

ez;~-- David D. Mitchem 

Town Manager 

C: Curt Taipale E.I.T. 

(E.!.T., Planning & Policy Program) 

Paul Tourangeau 

(Director, Colorado Air Pollution Control Division) 

Douglas A. Lempke 

(Administrator, Colorado Air Quality Control Commission) RECEIVED 

NOV 16 2009 

AIR QUAUTY 

;:;ON\nC(JMISSIOl\i 
Adopted Statement ofBasis,
 

Specific Statutory Authority and Purpose
 
VIII.X Pagosa Springs PM10 

Adopted November 19, 2009 

The amendments to the "Ambient Air Quality Standards for the State of Colorado" Regulation adopted by 

the Commission establish mobile source emiSSions budgets for the Pagosa Spnngs PM10 attainment 

area. 

Federal Requirements 

Nothing In this rule change exceeds the minimum reqUirements of the federal act. 

Statutory Authority 

The authority to establish emissions budgets and to establish critena for transportation conformity 

determinations IS Included In the general authority to adopt a State Implementation Plan set out In Section 

25-7-105(1), C.R.S. (2001). 

Findings pursuant to Section 25-7-110.8 

The mobile source emissions bUdgets are based on EPA's MOBILE6 emiSSions model and EPAapproved methods for calculating fugitive dust emiSSions as required by federal regulations. All 

methodologies and Information made available by Interested parties have been considered. The 

emiSSions budgets reduce the potential for air pollution by capping emissions from mobile sources. In 

adopting this rule, the CommissIon chose the most cost-effective alternative. 

Further, these reVISions will Include any typographical, grammatical and formatting errors throughout the 

regulation. 
Adopted Language by the Commission
 

(in redline & footer noting adoption date and page numbers)
 
DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT
 

Air Quality Control Commission
 

AMBIENT AIR QUALITY STANDARDS
 

5 CCR 1001-14 

V.	 Emission Budgets for Attainment/Maintenance Areas in the State of Colorado 

V.A.	 Budgets 

V.A.1.	 The following Motor Vehicle Emission Budgets shall be utilized to assess the conformity of 

Transportation Plans, TIPs, and where appropriate, Projects, for the applicable periods and 

geographic areas indicated: 

Denver 

Attainment/Maintenance 

Area (Modeling 

Domain) 

PM10: 2015 through 2021: 54 tons/day; 2022 

and beyond: 55 tons/day. 

Nitrogen Oxides: 2015 through 2021: 70 

tons/day; 2022 and beyond: 56 tons/day 

Trading provisions: Trading of PM10for NOx, or 

NOx for PM10to adjust emission budgets for 

purposes of demonstrating transportation 

conformity shall be allowed using the emission 

trading formula as follows: 

For trades necessary to increase a primary 

PM10 budget, 15.0 tons/day of NOx will be 

taken from the NOx budget to increase the 

primary PM10 budget by 1.0 tons/day, a ration 

of 15 to 1. 

For trades necessary to increase a NOx bUdget, 

1.0 tons/day of primary PM10 will be taken from 

the primary PM10 budget to increase the NOx 

budget by 12.0 tons/day, a ratio of 1 to 12. 

Implementation of trading provisions: In the 

event the MPO cannot demonstrate consistency 

with the specific PM10 and NOx mobile source 

emission bUdgets, the trading provisions may be 

utilized only after the MPO has considered all 

reasonably available local control measures to 

meet the bUdgets. The MPO must demonstrate 

the need for trading through the usual 

consultation procedures for state implementation 

plan development delineated in Section IV (F) of 

AQCC Regulation Number 10, Criteria for 

Analysis of Conformity. 

If trading is utilized, the MPO shall include the 

foliowinQ information in the transportation 

Ambient Air Quality Standards 

Adopted: November 19, 2009 Page 1 
conformity determination: 

(1) The budget for primary PM 10 and NOx 

for each required year of the conformity 

determination, before trading is employed; (2) 

The portion of the original budget to be used to 

supplement a wanting budget, for each required 

year for the conformity determination; (3) The 

increased budget that results from trading, along 

with relevant calculations, and (4) the resulting 

primary PM 10 and NOx budgets for each 

required year of the conformity demonstration. 

The MPO shall then compare projected 

emissions to the adjusted PM10 and NOx motor 

vehicle emission budgets to demonstrate 

conformity. 

Denver Attainment Ozone Precursors (attainment/maintenance 

Maintenance Area area boundary) NOx 2002 and beyond 134 tpsd 

VOC 2002 and beyond 119 tpsd (tpsd = tons per 

summer day) Carbon Monoxide 

(attainment/maintenance area boundary) 2013 

through 2020: 1625 tons/day; 2021 and beyond: 

1600 tons/day. 

Denver Metro 

Area/North Front Range 

Regional Emissions Budgets 

NOx: 122.9 tons/day 

VOCs: 109.2 tons/day 

Southern Sub-Regional Emissions Budgets 

NOx: 102.4 tons/day 

VOCs: 89.7 tons/day 

Northern Sub-Regional Emissions Budgets 

NOx: 20.5 tons/day 

VOCs: 19.5 tons/day 

8-Hour Ozone 

Nonattainment Area 

Aspen (Modeling Area) PM10:-2015 and Beyond: 16,2441bs.lday 

Calion City PM1 0:-2020 and Beyond: 1,613 Ibs.lday 

PM 10:-2015 and Beyond: 7,534lbs.lday 

PM10:2G-1-2- 2021 and Beyond: -7-,489946 

Ibs.lday 

Lamar (Modeling Area) 

Pagosa Springs 

(Modeling Area) 

Steamboat Springs 

(Modeling Area) 

PM102015 and Beyond: 21,773 Ibs.lday 

Ambient Air Quality Standards 

Adopted: November 19, 2009 Page 2 
Telluride (Modeling 

Area) 

Longmont 

Attainment/Maintenance 

Area 

Attainment/Maintenance 

Afea 

Colorado Springs 

Attainment/Maintenance 

Area 

Ft. Collins 

Attainment/Maintenance 

Area 

Greeley Area 

Attainment/Maintenance 

Area 

PM102012 and Beyond: 10,001 Ibs./day 

Carbon Monoxide 2010 through 2014: 43 

tons/day 2015-2019: 43 tons/day 2020 and 

Beyond: 43 tons/day 

Through 2014: 44 tons/day 2015 through 2019: 

44 tons/day 

Carbon Monoxide 2010 and Beyond: 531 

tons/day 

Carbon Monoxide 2005 through 2009: 99 

tons/day2010 through 2014: 98 tons/day2015 

and Beyond: 94 tons/day 

Carbon Monoxide 2005 through 2009: 63 

tons/day2010 through 2014: 62 tons/day2015 

and Beyond: 60 tons/day 

V.A.2.	 Geographic Coverage 

Unless otherwise specified, the geographic coverage of each of the area Motor Vehicle 

Emissions Budgets shall be the nonattainment or attainment maintenance area as defined in the 

respective state implementation plans. 

V.A.3.	 The Motor Vehicle Emissions Budget for PM 10 applies to total primary PM1 0 emissions, including 

emissions from tailpipe exhaust, unpaved roads (except for the Denver PM10 nonattainment 

area), re-entrained road dust and street sand. It does not include precursor or secondary 

emissions, which, where appropriate, are covered under separate budgets. 

V.A.4.	 Effective Dates 

V.A.4.a. Denver Carbon Monoxide 

The 1,520 tons per day (2013 and beyond) carbon monoxide emission budget 

established in Section V.A.1. shall take effect as a matter of state law when such budget 

takes effect as a matter of federal law pursuant to 40 CFR Section 93.118. Until such 

time as the 1,520 tons per day budget takes effect pursuant to this section and 40 CFR 

Section 93.118, the carbon monoxide emission bUdgets for the Denver CO 

attainment/maintenance area shall be 800 tons per day (2002 and beyond). 

V.A.4.b.Colorado Springs Carbon Monoxide 

The 531 tons per day carbon monoxide emission budget established in Section V.A.1. 

shall take effect as a matter of state law when such budget takes effect as a matter of 

federal law pursuant to 40 CFR Section 93.118. Until such time as the 531 tons per day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the carbon 

monoxide emission budget for the Colorado Springs CO attainment/maintenance area 

shall be 270 tons per day (2001 and beyond). 

Ambient Air Quality Standards 

Adopted: November 19, 2009 Page 3 
V.A.4.c. Reserved 

V.A.4.d. Reserved 

V.A.4.e.Aspen PM 10 

The 16,244 pounds-per-day PM 10 emission budget established in Section V.A.1. shall 

take effect as a matter of state law when such budget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 16,244 pounds-per-day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the PM 10 

emission buqget for the Aspen PM10 Nonattainment Area shall be 13,974 pounds-perday. 

V.A.4.f. Reserved Pagosa Springs PM10 

The 946 pounds-per-day PM 10 emission budget established in Section V.A.1. shall take 

effect as a matter of state law when budget takes effect as a matter of federal law 

pursuant to 40 CFR Section 93.118. Until such time as the 946 pounds-per-day budget 

takes effect pursuant to this section and 40 CFR Section 93.118. the PM10 emission 

budget for the Pagosa Springs PM10 attainment/maintenance area shall be 7,486 

pounds-per-day. 

V.A.4.g.Calion City PM10 

The 1,1613 pounds-per-day PM 10 emission buqget established in Section V.A.1. shall 

take effect as a matter of state law when such budget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 1,613 pounds-per-day 

budget takes effect pursuant to this section and 40 CFR section 93.118, the PM 10 

emission budget for the Calion City PM1 0 attainment/maintenance area shall be 7,439 

pounds-per-day. 

V.A.4.h.Lamar PM10 

The 7,534 pounds-per-day PM1 0 emission budget established in Section V.A.1. shall 

take effect as a matter of state law when such budget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 7,534 pounds-per-day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the PM 10 

emission budget for the Lamar PM 10 Nonattainment Area shall be 1,884 pounds-perday. 

V.A.4.i. Steamboat Springs PM 10 

The 21,773 pounds-per-day PM 10 emission budget established in Section vA1. shall 

take effect as a matter of state law when such buqget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 21,773 pounds-per-day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the PM1 0 

emission budget for the Steamboat Springs PM 10 Nonattainment Area shall be 20,682 

pounds-per-day. 

VIII. Statements of Basis, Specific Statutory Authority and Purpose 

VIII.X Pagosa Springs PM10 

Adopted November 19, 2009 

Ambient Air Quality Standards 

Adopted: November 19, 2009 Page 4 
The amendments to the "Ambient Air Quality Standards for the State of Colorado" Regulation adopted by 

the Commission establish mobile source emissions budgets for the Pagosa Springs PM1 0 attainment 

area, 

Federal Requirements 

Nothing in this rule change exceeds the minimum requirements of the federal act. 

Statutory Authority 

The authority to establish emissions budgets and to establish criteria for transportation conformity 

determinations is included in the general authority to adopt a State Implementation Plan set out in Section 

25-7-105(1t C,R,S. (2001). 

Findings pursuant to Section 25-7-110.8 

The mobile source emissions budgets are based on EPA's MOBILE6 emissions model and EPAapproved methods for calculating fugitive dust emissions as required by federal regulations. All 

methodologies and information made available by interested parties have been considered. The 

emissions budgets reduce the potential for air pollution by capping emissions from mobile sources. In 

adopting this rule, the Commission chose the most cost-effective alternative. 

Further, these revisions will include any typographical, grammatical and formatting errors throughout the 

regulation. 

Ambient Air Quality Standards 

Adopted: November 19, 2009 Page 5 
State Implementation Plan Element
 

Adopted by the Commission
 

40 CFR Part 51 Appendix V 2.1(d)
 
Final Revised PM10 Maintenance Plan for the
 

Pagosa Springs Attainment/Maintenance Area
 

Colorado Department 

of Public Health 

and Environment 

Revised PM10 Maintenance Plan Submittal: 

US. EnvIronmental Protection Agency: submitted on -TBD 

Colorado Alf Quality Control CommIssIon, adopted on - 11/19/09 

PM10 Maintenance Plan Submittal: 

US. EnvIronmental Protection Agency: approved on 06/15/01, effective on 08/14/01 

Colorado Air Quality Control CommissIon, adopted on 03/16/00 

Pagosa Sprmgs Town Council, approved on February 2000 

PM10 State Implementation Plan Submittal 

US. Envlfonmental Protection Agency' approved 05/19/94, effective 06/20/94 

Colorado Air Quality Control CommIssion, approved on 11/19/92; 11/12/93 

Revisions Prepared By: 

Air Pollution Control DIVIsIon 

Colorado Department of Public Health and Environment 

4300 Cherry Creek Dnve South 

Denver, Colorado 80246 
[Blank Page] 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 2 of25 

November 19, 2009 
Table of Contents 

SECTION 1: INTRODUCTION 5
 

A. BACKGROUND 6
 .L PM10 National Ambient Air Quality Standard 6
 

£. Health and Welfare Effects of PM10 6
 

Pagosa Springs Nonattainment Area Classification History 7
 

4. Pagosa Springs AttainmenUMaintenance Area Boundaries 7
 

B. ORGANIZATIONS INVOLVED IN PREPARING AND APPROVING
 

PLAN 8
 

C. REQUIREMENTS FOR REDESIGNATION AND MAINTENANCE 9
 .L Attainment of the Standard 9
 

£. State Implementation Plan (SIP) Approval 9
 

Permanent and Enforceable Improvement in Air Quality 9
 

1. Section 110 and Part 0 ReqUirements 9
 

Maintenance Plan 9
 

SECTION 2: PM10 ATTAINMENT HISTORY 10
 

A. MONITORING HISTORY 10
 

B. DESIGN VALUE DETERMINATION 11
 

SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL .. 12
 

A. 1988 SIP ELEMENT 12
 

B. 1992 and 1993 SIP ELEMENTS 12
 

C. 1994 SIP ELEMENT REVISION 12
 

D. PM10 MAINTENANCE PLAN 12
 

SECTION 4: PERMANENT AND ENFORCEABLE
 

IMPROVEMENT IN AIR QUALITY 13
 

A. OVERViEW 13
 

B. CONTROL MEASURES 13
 .L Control of Emissions through Road Paving 14
 

£. Street Sanding Controls 14
 

3. Control of Emissions from Stationary Sources 14
 

4. Federal Motor Vehicle Emission Control Program 15
 

5. Voluntary and State-Only Measures 15
 

SECTION 5: MAINTENANCE PLAN 16
 

A. REQUIREMENTS 16
 

B. EMISSION INVENTORIES 16
 .L 2007 Base Emission Inventory 17
 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 3 of 25
 

November 19, 2009
 
2. 2015 Interim Emission Inventory 18
 

3. 2021 EmIssion Inventory 19
 

C. MAINTENANCE DEMONSTRATION 20
 

CMS Source Apportionments of High Concentrations 21
 

2. CMS Roll-forward Analysis 21
 

D. PM10 EMISSION BUDGET 23
 

E. MONITORING NETWORKIVERIFICATION OF CONTINUED
 

ATTAINMENT 23
 

F. CONTINGENCY PLAN 23
 

Tracking 24
 

2. Trigger and Response 24
 

Potential Contingency Measures 24
 

G. SUBSEQUENT MAINTENANCE PLAN REVISIONS 25
 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 4 of 25
 

November 19, 2009
 
SECTION 1: INTRODUCTION 

This document is the second revision of the PM1 0 Maintenance Plan for the Pagosa 

Sprmgs Attainment/Maintenance Area. The Environmental Protection Agency (EPA) 

first approved a particulate matter under 10 microns redesignation request and 

maintenance plan for the Pagosa Springs area on June 15, 2001 (66 FR 32556), which 

became effective on August 14, 2001. The Pagosa Springs redesignation request and 

maintenance plan was adopted by the Colorado Air Quality Control Commission 

(AQCC) on March 16, 2000. 

This second maintenance plan, as revised in 2009, supersedes and replaces the first 

mamtenance plan adopted by the Commission in 2000. The 2009 revised plan includes 

updated the emissions inventories and projections using the latest EPA-approved tools. 

This maintenance plan also revises the PM10 emission budget from 7,486 pounds per 

winter-time day in 2012 to 1,546 pounds per average day in 2021 and beyond. 

The Town of Pagosa Springs, Archuleta County, and the State of Colorado request 

continuation of "attamment/maintenance" status for the Pagosa Springs PM 10 

nonattainment area. The Pagosa Springs area was originally designated as 

nonattamment for the National Ambient Air Quality Standards (NAAQS) for particulate 

matter with an aerodynamic diameter of ten microns or less (PM1 0) since 1990, 

although the area is presently demonstrating attainment with the PM10 NAAQS. The 

Mamtenance Plan section of this document has been updated and will demonstrate that 

the area will be able to maintam the NAAQS through the year 2021. The benefits of 

maintaining a redesignation to attainment status include: 

1.	 Areas redesignated to attainment lose the stigma associated with nonattainment 

of the NAAQS. 

2.	 Areas redesignated to attainment do not become "serious" nonattamment areas 

even if a violation of the NAAQS occurs. This means that specific control 

measures can be applied to address a violation without going through a rigorous 

federal process, where serious areas must implement mandatory control 

measures and be sUbject to numerous administrative activities. 

3.	 Prevention of Significant Deterioration (PSD) permitting requirements replace 

New Source Review (NSR) permitting requirements for new and modified major 

stationary sources. These permitting requirements are important for large 

industrial facilities that are not currently located, nor likely to locate, m the 

Pagosa Springs area. 

This analysis is designed to document and ensure continuing attainment and 

maintenance of the NAAQS for PM 10 in the Pagosa Springs area. This document is 

mtended to comply with requirements of the federal Clean Air Act (CAA), and with 

relevant procedures and policies of the United States Environmental Protection Agency 

(EPA). 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 5 of 25 

November 19, 2009 
A. BACKGROUND 

1. PM10 National AmbIent Air Quality Standard 

In 1971, the EPA set NAAQS for several air pollutants, including total suspended 

particulates (TSP), defined as particles with an aerodynamic diameter of less than 40 

microns. In 1987, the EPA changed the TSP standard to the PM10 NAAQS. The 

current PM1 0 NAAQS allow for a maximum 24-hour average of 150 ug/m3. The 24­

hour PM1 0 NAAQS may not be exceeded more than three times over any three year 

period. 

There are both primary and secondary air quality standards. The primary standards are 

set to protect human health, with a margin of safety to protect the more sensitive 

persons in the population, such as the very young, elderly and the ill. Secondary 

standards are set to protect property, materials, aesthetic values and general welfare. 

For PM10, the national primary and secondary standards are the same. The numerical 

levels of the standards are subject to change, based on new scientific evidence 

summarized in air quality criteria documents. In 2006, the EPA revoked the annual 

PM10 standard but maintained the 24-hour average of 150 ug/m3 (see 71 FR 61144) 

for both the primary and secondary NAQQS. 

In general, demonstrating attainment requires collecting representative air monitoring 

data and using approved measuring instruments and procedures, with adequate quality 

assurance and quality control. Air quality measurements in the Pagosa Springs area 

satisfy this requirement, as shown In Section 2 - "Table 1 - PM1 0 Monitoring Record". 

2. Health and Welfare Effects of PM1 0 

Particulate matter is the term given to tiny particles of solid or semi-solid material 

suspended in the atmosphere, and PM1 0 is Inhaleable particulate matter 10 

micrometers in diameter and smaller. In the Pagosa Springs area, PM10 IS created 

from re-entrained road dust, carborl black (from automobile and diesel engines) and 

soot (from fireplaces, woodstoves, and coal stoves). PM10 from these combustion 

sources contains a large percentage of elemental and organic carbon, which 

contributes to atmospheric haze and to health problems. 

Epidemiological studies and laboratory studies of humans and animals indicate that fine 

particles can be Inhaled deeply into the respiratory system, resulting in aggravation of 

existing respiratory and heart diseases, damage to lung tissue, impairment of breathing 

and respiratory functions, alterations to the body's physical and immune system 

defenses, and even premature death. Many fine particles are also composed of 

compounds that are known or suspected human carcinogens. People most sensitive to 

particulate matter are the elderly, children, and those with chronic lung disease, 

cardiovascular disease, Influenza, and asthma. 

The welfare effects of particulate air pollution are wide-spread. Because of the 

potential for extremely long-range transport of fine particles it is thought that no place 

on earth is free of particulate pollution generated by urban and rural sources. Chemical 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 6 of 25 

November 19, 2009 
4 

and photo-chemical reactions involving the particles may occur in the air, or once they 

have been deposited on environmental media or structures. Such soiling and acid 

deposition cause visibility degradation, climate changes, and damage to crops, natural 

vegetation, water bodies, and aquatic life. In addition, sculpture and architecture may 

be damaged or destroyed by particulate soiling and acid deposition--both of which have 

been detected in the most remote areas of the world. 

3. Pagosa Springs Nonattainment Area Classification History 

Because of observed problems with air particles, monitoring of total suspended 

particulates (TSP) began in 1975, and continued through 1987. In 1987, based on 

relatively high TSP levels, the Pagosa Springs area was designated as a "Group I" area 

for PM1 O. Pagosa Springs was then designated a "moderate" nonattainment area in 

1990 pursuant to section 107(d)(4)(B) of the CAA. 

Pagosa Springs Attainment/Maintenance Area Boundaries 

The boundary for the Pagosa Springs PM10 attainment/maintenance area is defined as 

follows: 

Township 35 North & Range 2 West 

Sections 13, 14, 15 

Section 23 NE, N 1f2 SE 

Section 24 all except SWSW 

Section 25 N 1f2 NE, NENW 

Township 35 North & Range 1 West 

Section 18 W 1f2 

This area essentially includes the Town of Pagosa Springs, some additional area along 

the San Juan River, some areas along U.S. Highway 160 outside of the Town's limits. 

A map illustrating the area boundary is shown in Figure 1. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 7 of 25 

November 19, 2009 
Figure 1: Map of the Pagosa Springs Attainment/Maintenance Area 

o 04; 0,9

L.-'--'_..1-'-,--'----'---'----'f--=J~.

\ 

Pagosa Springs PM-10 Attainment Area l.,·,·------T . \,---­ l\ , '?­ \ \,/ \ ~- .r---::--') . \ 

}. 

,-,·11 l-J......... -, 

.} 

-'1 

/L__

\Legend 

oft AIRPORTS 

-1 • Point Sources 

\ ),._.- LiXai Roa ds " ! 

\ i - Malor Roads 

Ii..... ; • - HIGHIJI.AYS 

\~OeS'9nalJon_Bou"danes

l\· U CITIES /\ 

-'-.~ 0 COUNTIES / 

t""" 

B. ORGANIZA TlONS INVOLVED IN PREPARING AND APPROVING 

PLAN 

Preparation of this revised maintenance plan was a cooperative effort of the Town of 

Pagosa Springs, Archuleta County, and the Air Pollution Control Division (APCD) of the 

Colorado Department of Public Health and Environment. The document was approved 

by the Colorado Air Quality Control Commission (AQCC) on November 19, 2009. The 

EPA, through its regional office in Denver, provided policy advice and technical 

aSSistance, and is responsible for final approval of this revised maintenance plan. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 8 of 25 

November 19, 2009 
C. REQUIREMENTS FOR REDESIGNA TION AND MAINTENANCE 

Section 107(d)(3)(D) and (E) of the CAA defines the five required components of a 

redesignation request and maintenance plan. These components and their 

descnptions follow: 

1 Attainment of the Standard 

The State must show that the area is attaining the PM10 NAAQS. This demonstration 

must be based on monitoring data representative of the location of the expected 

maximum concentrations of PM1 0 in the nonattainment area. 

2. State Implementation Plan (SIP) Approval 

The State must demonstrate that it has a fully approved State Implementation Plan 

(SIP) Element for Pagosa Springs under Section 11 O(k) of the CAA. 

3. Permanent and Enforceable Improvement in Air Quality 

The State must demonstrate that the improvement In air quality leading to redesignation 

is due to permanent and federally enforceable emissions reductions. 

4 Section 110 and Part D Requirements 

The State must meet all reqUirements of Section 110 and Part D of the CAA. Section 

110 describes general requirements of SIPs, while Part D pertains to requirements 

applicable to nonattainment areas. 

5. Maintenance Plan 

The State must have a fully approved maintenance plan that meets the requirements of 

Section 175A of the CAA. This plan must provide for the maintenance of the NAAQS 

for at least 10 years following redesignation, and the plan must contain a contingency 

plan that describes potential control measures that could be implemented to ensure 

continued maintenance of the PM1 0 NAAQS. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 9 0(25 

November 19, 2009 
SECTION 2: PM10 ATTAINMENT HISTORY 

A. MONITORING HISTORY 

Monitoring for total suspended particulates (TSP) in Pagosa Springs began In August 

1975 at the Pagosa Springs High School and continued through September 1987 TSP 

monitoring was also conducted at the Town Hall from March 1987 through September 

1987. Concentrations at both of these monitoring locations exceeded the 24-hour TSP 

NMOS of 260 ug/m3 and the annual NMOS of 75 ug/m3. The historic TSP levels 

were the basis for Pagosa Springs being designated as a "Group I" area for the new 

PM10 standards, which were promulgated by the EPA in 1987 Group I locations were 

those areas estimated to have a greater than 95 percent probability of exceeding the 

new PM1 0 standards. 

Monitoring for PM1 0 began in August 1985 at the Pagosa Springs High School and an 

additional PM10 monitor was established at the Town Hall in January 1988. The Town 

Hall site was determined to be more representative of maximum PM concentrations and 

accordingly the High School site was decommissioned In August 1990. The Town Hall 

location was operated until 2001 when a major building renovation necessitated 

relocation of the PM monitor back to the High School location. 

Table 1 lists the yearly maximum, second maximum and estimated exceedances for the 

Town Hall and High School monitoring sites for the 1O-year period from 1998 through 

2008. Only one exceedance of the 24-hour PM10 NMOS was recorded in 2000 at the 

Town Hall site. 

Table 1: Pagosa Springs PM10 Monitoring Record 

Year 

Maximum 

Concentration 

(ug/m3 

) 

2nd Maximum 

Concentration 

(ug/m3) 

Yearly 

Estimated 

Exceedances 

3-yr Average 

Estimated 

Exceedances 

Monitoring Site 

1998 66 66 0 0 Town Hall 

1999 138 82 0 0 Town Hall 

2000 165 87 1 0.33 Town Hall 

2001 123 121 0 0.33 Town Hall 

2001 66 61 0 0.33 High School 

2002 107 82 0 0.33 High School 

2003 123 111 0 0 High School 

2004 79 61 0 0 High School 

2005 82 77 0 0 High School 

2006 122 53 0 0 High School 

2007 102 59 0 0 High School 

2008 149 74 0 0 High School 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 10 of 25 

November 19, 2009 
B. DESIGN VALUE DETERMINATION 

The "design value" is the critical air quality value from which the maintenance plan is 

based. The design value, and the conditions that occurring on the day which it was 

measured, are utilized to develop emission inventories and serve as a baseline for 

modeling ambient concentrations into the future. The selection of this design value 

utilized EPA's table look-up method from EPA's "PM10 SIP Development Guideline" 

document. Based on the number of samples collected during the 2006 - 2008 period 

(1,069), the third hlghest concentration is the design value, according to this guidance. 

The three highest concentrations measured during the period 2006 -2008 are as 

follows: 

149 ug/m3 - May 1, 2008 

122 ug/m3 - February 15, 2006 

102 ug/m3 - June 6, 2007 

Consequently, the design value for this revised maintenance plan is 102 ug/m3. 

It IS important to note that the May 151 , 2008 value of 149 ug/m3 may be the result of a 

blowing dust event, which could be considered as an "exceptional event". The APCD is 

investigating the circumstances surrounding this event, but this value is still being used 

In the design value calculation. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 11 of 25 

November 19, 2009 
SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL 

The following presents a brief summary of the development and the approval of the 

Pagosa Springs PM1 0 nonattainment SIP Element. 

A. 1988 SIP ELEMENT 

The first PM10 SIP Element was adopted by the Colorado AQCC in July 1988. and the 

emission controls consisted of paving unpaved roads. EPA Region VIII Intended to 

approve the SIP Element, though it eventually was rejected once the Clean Air Act was 

amended in 1990 and new. more stringent requirements were in place. 

B. 1992 and 1993 SIP ELEMENTS 

A new Pagosa Springs SIP Element was adopted by the AQCC in November 1992 and 

supplemented in November 1993. The control measures included the paving of local 

roads adopted for the 1988 SIP Element and street sanding requirements on the State 

highways. New street sweeping requirements were adopted as contingency measures. 

EPA approved the SIP Element on May 19, 1994 (59 FR 26126). 

C. 1994 SIP ELEMENT REVISION 

The Pagosa Springs SIP Element was revised by the AQCC In November 1994. This 

revision consisted of updating the technical and administrative information. EPA had 

previously approved these technical and administrative revisions in the May 1994 action 

because they were submitted directly to EPA by the APCD in December 1993. 

D. PM10 MAINTENANCE PLAN 

The Pagosa Springs Town Council approved the PM Maintenance Plan on February 

2000 that was adopted by the Commission on March 16.2000. The U.S. 

Environmental Protection Agency approved the plan on June 15. 2001 which became 

effective on August 14. 2001 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 120(25 

November 19, 2009 
SECTION 4: PERMANENT AND ENFORCEABLE 

IMPROVEMENT IN AIR QUALITY 

The State must demonstrate, based on Section 107(d)(3)(E) of the CAA, that the 

improvement In air quality leading to attainment of the NAAQS and the redesignation 

request IS based on permanent and enforceable measures, and that the reductions are 

not the result of temporary reductions in emissions or unusually favorable meteorology 

A. OVERVIEW 

It is reasonable to attribute the attainment of the PM10 NAAQS in the Pagosa Springs 

nonattainment area to emission reductions that are permanent and enforceable. These 

emission reductions are the result of local, State, and federal actions, not economic 

factors or unusual meteorology. 

Economic conditions are clearly not responsible for improved ambient levels In the 

Pagosa Springs attainment/maintenance area. It is assumed that growth in population 

and sales tax revenue are indicators of increased activities that cause increased PM10 

emissions and the potential for elevated PM10 concentrations. Information obtained 

for the Town of Pagosa Springs shows that during the period 2000 through 2007, sales 

tax revenues increased by 45.8 percent while Archuleta County population increased by 

26 percent over the same period. During this period of rapid growth, attainment of the 

PM10 NAAQS was demonstrated with only one exceedance (165 ug/m3 in 2000) and 

few concentrations over a 100 ug/m3 threshold. 

Favorable meteorology is also an unlikely reason why the area's PM10 concentrations 

are below the NAAQS. Although winter and spring meteorological conditions are highly 

variable in mountain settings, there is no evidence to suggest that meteorological 

conditions experienced in the 2000's have not been "typical" (though it is difficult to 

make concrete conclusions based on short-term meteorological records). Because 

there has not been a violation of the PM10 NAAQS in Pagosa Springs since the 

NAAQS was promulgated in 1987, and because there have only been three 

concentrations since 1987 that have exceeded the 24-hour PM1 0 NAAQS (258 ug/m3 

and 262 ug/m3 are thought to be due to malfunctioning or poorly operated street 

sweeping equipment and 165 ug/m3 in 2000), the APCD concludes that the good air 

quality In the Pagosa Springs area is the result of the implementation of emission 

reduction measures, not meteorological fluctuations. 

B. CONTROL MEASURES 

The following control measures resulted in the area's attainment of the PM1 0 NAAQS, 

and these measures should ensure continued maintenance of the PM1 0 NAAQS 

through the year 2021, which is the duration of the maintenance period. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 13 of 25 

November 19, 2009 
1. Control of Emissions through Road Paving 

The Town of Pagosa Springs paved 6.5 miles of unpaved roads during 1992, 1993, and 

1994 In order to reduce PM10 emissions. This strategy was adopted locally in 1991 

and Included in State regulation In 1992 (Section LB. of the "State Implementation PlanSpecific Regulations for Nonattainment - Attainment/Maintenance Areas (Local 

Elements)). The rule was approved by EPA in 1994 and was removed from the 

Colorado regulation in 2000 as the paving requirements had been completed. 

2. Street Sanding Controls 

There is a requirement that any user that applies street sanding matenal on Highway 

160 and Highway 84 in the Pagosa Springs attainment/maintenance area must use 

materials containing less than one percent fines. Users of street sand on these 

highways must also use 15 percent less sand than an established base sanding 

amount. These strategies were adopted in 1992 and approved by EPA in 1994, and 

they are defined in detail in Sections LB. and C., respectively, of the "State 

Implementation Plan-Specific Regulations for Nonattainment - Attainment/Maintenance 

Areas (Local Elements) Regulations (5 CCR 1001-20). 

3. Control of Emissions from Stationarv Sources 

Although there are no stationary sources located in the Pagosa Springs 

attainment/maintenance area, the State's comprehensive permit rules will limit 

emissions from any new source that may, in the future, locate in the area. These rules 

include: 1) Regulation No.3, "Air Pollution Emission Notices, Construction Permits and 

Fees, Operating Permits, and Including the Prevention of Significant Deterioration," 2) 

the "Common Provisions" regulation, and 3) Regulation No.6, "Standards of 

Performance for New Stationary Sources." 

The Common Provisions, and Parts A and B of Regulation No.3, are already included 

in the approved SIP. Regulation NO.6 implements the federal standards of 

performance for new stationary sources. The maintenance plan makes no changes to 

these regulations. This reference to Regulation No.6 shall not be construed to mean 

that this regulation is included in the SIP. 

As indicated above, emissions from new or modified major stationary sources 

emissions of PM1 0 are controlled under Regulation No. 3's nonattainment-area (NAA) 

new source review (NSR) permitting requirements. The NSR provisions require all new 

and modified major stationary sources to apply emission control equipment that 

achieves the "lowest achievable emission rate" (LAER) and to obtain emission offsets 

from other stationary sources of PM10. 

The EPA approval of the original PM1 0 Maintenance Plan, effective on 08/14/01, 

reinstates the prevention of significant deterioration (PSD) permitting requirements in 

the Pagosa Springs Attamment/Maintenance area. The federal PSD requirements are 

considered a relaxation from the NAA NSR requirements, as LAER is no longer 

required and is replaced by the less stringent "best available control technology" 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 140'25 

November 19, 2009 
4 

(BACT), along with the removal of the requirement to offset PM1 0 emissions. The 

future reapplication of NAA NSR provisions appears unlikely in the Pagosa Springs 

Attainment/Maintenance area based on current PM1 0 monitoring trends. 

Federal Motor Vehicle Emission Control Program 

The federal motor vehicle emission control program has reduced PM10 emissions 

through a continuing process of requiring diesel engine manufacturers to produce new 

vehicles that meet tighter and tighter emission standards. As older, higher emitting 

diesel vehicles are replaced with newer vehicles; the PM1 0 emissions in the Pagosa 

Springs area will be reduced. 

5. Voluntary and State-Only Measures 

In addition to the mandatory control measures discussed above, there are other 

activities that result in the reduction of PM1 0 emissions that are not classified as 

"federally enforceable control measures." Some notable examples include: 

•	 The Town of Pagosa Springs has historically cleaned Highway 160 in town 

throughout the winter and spring using regenerative air vacuum sweepers. The 

frequency of this voluntary sweeping/cleaning has been about once after each street 

sanding deployment. For the future, the Town of Pagosa Springs has committed to 

regularly vacuum sweep/clean Highway 160 within four days of the roadway 

becoming free and clear of snow and ice following each street sanding deployment, 

.as weather, temperature, and street conditions permit, between the intersections of 

Highway 84 to the east and 14th street to the west. 

•	 The Town of Pagosa Springs requires that all new developments have paved 

streets. 

•	 The Town of Pagosa Springs encourages private businesses to properly 

clean/sweep private parking lots on a regular basis. 

•	 Archuleta County commits to pave the unpaved portion of Hot Springs Boulevard 

from the existing pavement to the boundary of the airshed. 

•	 Any owner or operator responsible for the construction or maintenance of any 

existing or new unpaved roadway which has vehicle traffic exceeding 200 vehicles 

per day in the attainment/maintenance area and surrounding areas must stabilize 

the roadway in order to minimize fugitive dust emissions. These State-wide 

requirements are defined in detail in Section III.D.2.a.(I) of the AQCC's Regulation 

No.1 

These strategies are considered to be voluntary local Initiatives and State-only 

requirements, and are Intended to reduce PM1 0 emissions. These strategies are not 

intended to be federally enforceable. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 15 of 25 

November 19, 2009 
SECTION 5: MAINTENANCE PLAN 

A. REQUIREMENTS 

Section 107(d)(3)(E) of the CM provides that for an area to be redesignated to an 

attainment classification, EPA must fully approve a maintenance plan which meets the 

requirements of CM Section 175A. The maintenance plan will constitute a SIP 

revision and must provide for maintenance of the relevant NMOS in the area for at 

least ten years after redeslgnation. Since the requirement is for ten years after 

redesignation, some lead time for the EPA approval process (up to 18 months per CM 

Section 107(d)(3)(D)) should be considered in establishing the maintenance year, which 

the State determines to be 2021. An additional requirement (Section 175A(d)) is the 

submittal of a SIP revision eight years after the original redesignation 

request/maintenance plan is approved that provides for maintenance of the NMOS for 

an additional ten years following the first ten-year period. The State of Colorado has 

satisfied this commitment by sUbmitting this revised maintenance plan as required by 

the CM and EPA requirements. 

Section 175A further states that the plan shall contain such additional control measures 

as necessary to ensure maintenance. All current nonattainment area control measures 

shall remain In place, except for the most stringent NSR stationary source permitting 

requirements (see Section 4.8.3.). The maintenance plan shall contain a contingency 

plan to ensure the prompt correction of any unforeseen violation of the PM10 NMOS. 

Failure to maintain the NMOS and triggering of the contingency plan will not 

necessitate a revision of the SIP Element, unless required by the EPA Administrator, as 

stated in CM Section 175A(d). 

The provIsions that are addressed In this maintenance plan include emission 

Inventories (for a base year and a future year), a maintenance demonstration, an 

emission budget, an approved monitonng network, verification of continued attainment, 

and a contingency plan. 

B. EMISSION INVENTORIES 

The below emission inventories include the 2007 base year, 2015 interim year and the 

2021 maintenance year. These inventories reflect the base and projected conditions in 

the Pagosa Springs Attainment/Maintenance Area, and account for the emission control 

measures that have been adopted as part of the original redesignation request and the 

previous 10-year maintenance plan. Unlike the prevIous Pagosa Springs plans where 

the emiSSion inventories were based on a grid system of the attainment/maintenance 

area and an average winter-time day, the updated emission inventories, for 2007, 2015 

and 2021, are based on an all-seasons average day for the whole maintenance area. 

Consequently there are significant differences between the emission inventories in the 

prevIous Plan and this updated PM10 Maintenance Plan. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 16 of 25 

November 19, 2009 
1. 2007 Base Emission Inventory 

The 2007 base emission inventory for the Pagosa Springs Attainment/Maintenance 

Area is presented below. This updated emission inventory Incorporates the most 

current estimates for the following nine (9) source categories: 

•	 Commercial Cooking 

•	 Construction 

•	 Fuel Combustion 

•	 Non-Road 

•	 Structure Fires 

•	 Wood-burning 

•	 Unpaved Road Dust 

•	 Paved Road Dust 

•	 Highway Vehicles 

•	 AgricuIture 

The mobile source inventories (unpaved road dust, paved road dust, and highway 

vehicles) have been updated to reflect the following: 

•	 Latest traffic (VMT) estimates from the Colorado Department of Transportation 

(COOT) 

•	 Revised emission factors and methods for determining paved road emissions 

•	 Road paving of unpaved roads that has occurred in the area 

•	 Vehicle exhaust emissions based on most up-to-date fleet mix 

All emission estimates were prepared by using EPA-approved methods and assigned to 

the area comprising the Attainment/Maintenance area. 

Table 2 presents the 2007 PM10 emission estimates for each source category in tons 

per year and pounds per average day. 

Table 2: 2007 PM10 Emission Inventory for the
 

Pagosa Springs Attainment/Maintenance Area
 

............... ((. Y 

Commercial Cooking 

Construction 

Fuel Combustion 

Non-Road 

Structure Fires 

Wood Burning 

Unpaved Road-Dust 

Paved Road-Dust 

Highway Vehicles 

Agriculture 

Totals: 

.\\.210':, ... \( 1,\( . 'iUi .JI 

1.18 6.44 

52.11 285.52 

0.01 0.07 

1.73 9.49 

0.02 0.09 

17.77 97.38 

16.27 89.16 

93.10 510.13 

2.06 11.31 

0.03 0.15 

184.3 1,009.8 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 17 of 25 

November 19, 2009 
2. 2015 Interim Emission Inventory 

Table 3 presents the 2015 PM 10 emission estimates for each source category In tons 

per year and pounds per average day. 

The 2015 emissions for the following source categories: commercial cooking; 

construction; fuel combustion; non-road; structure 'fires; and wood burning, were 

increased by an annual compounded rate of 2.90 percent per year (1.02897 or 23.18% 

total), which is based on the population forecast (from State Demography Office) for 

Archuleta County over the period 2007 to 2015 as indicated in Figure 2. Detailed 

information on the growth rate may be found in the Technical Support Document. 

Figure 2: Population Forecasts for Archuleta County 

Population Forecasts 

for Archuleta County 

C 15,000 -'''-"'""'''''--''-''''-''''-''-''''--~'--

o 

.... 

III ""5 10,000 , 

D. 

o 

c.. 5,000 '. ". 

o '" "." -,,' '"-" 

c~'\ ~~Cb #' f::J.... c:>....'" C",,,, f::>"''l) C",'I>. C",,'" r::,....fo f::>V C..;"fh c:>...OJ ~",t:::J C",'" ~ ~ ~ ~ ~ ~

The 2007 mobile source re-entrained dust emissions for all road categories (paved and 

unpaved) were increased by an annual compounded rate of 4.013 percent to 2015 

(1.040125 or 32.100 total). This growth rate was based on COOTs highest projected 

traffic growth rates for different segments of the State highways in the Pagosa Springs 

area. 

The 2007 mobile source tailpipe PM emissions were reduced by an annual 

compounded rate of 0.81 percent to 2015 (-0.008125 or -6.500% total). The reduction 

in PM emissions is associated with anticipated fleet turnover projected by MOBILE 6.2. 

The Pagosa Springs AttainmenUMaintenance Area is urbanized with mountainous 

terrain that is largely unsuitable for agriculture, so the future growth in agriculture 

emissions is assumed to be flat. 

The road paving that the Town of Pagosa Springs and Archuleta County plan on 

completing is not assumed in the 2015 inventory as the paving is considered voluntary 

and not enforceable by the State. Detailed information on the growth rates may be 

found In the Technrcal Support Document. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 180'25 

November 19, 2009 
Table 3: 2015 PM10 Emission Inventory for the
 

Pagosa Springs Attainment/Maintenance Area
 

Commercial Cookin 1.45 7.93 23.176% 

Construction 64.18 351.69 23.176% 

Fuel Combustion 0.02 0.09 23.176% 

Non-Road 2.13 11.69 23.176% 

Structure Fires 0.02 0.12 23.176% 

Wood Burnin 21.89 119.95 23.176% 

Un aved Road-Dust 21 49 117.78 32.087% 

Paved Road-Dust 122.98 673.89 32.102% 

Hi hwa Vehicles 1.93 10.58 -6.500% 

A riculture 0.03 0.15 0.000% 

Totals: 236.1 1,293.9 

3. 2021 Emission Inventory 

Table 4 presents the 2021 PM10 emission estimates for each source category in tons 

per year and pounds per average day. 

The 2021 emissions for the following source categories: commercial cooking; 

construction; fuel combustion; non-road; structure fires; and wood burning, were 

increased by an annual compounded rate of 3.59 percent per year (1.03592 or 50.28% 

total), which is based on the population forecast (from State Demography Office) for 

Archuleta County over the period 2007 to 2021 as indicated in Figure 2 above. Detailed 

information on the growth rate may be found in the Technical Support Document. 

The 2007 mobile source re-entrained dust emissions for all road categories (paved and 

unpaved) were increased by an annual compounded rate of 4.013 percent to 2021 

(1.04125 or 56.175% total). This growth rate was based on COOTs highest projected 

traffic growth rates for different segments of the State highways in the Pagosa Springs 

area. 

The 2007 mobile source tailpipe PM emissions were reduced by an annual 

compounded rate of 0.81 percent to 2021 (-0.008125 or -11.374% total). The reduction 

In PM emiSSions is associated with anticipated fleet turnover projected by MOBILE 6.2. 

The Pagosa Springs Attainment/Maintenance Area is urbanized with mountainous 

terrain that is largely unsuitable for agriculture, so the future growth in agriculture 

emissions is assumed to be flat. 

The road paving that the Town of Pagosa Springs and Archuleta County plan on 

completing is not assumed in the 2021 inventory as the paving is considered voluntary 

and not enforceable by the State. Detailed information on the growth rates may be 

found in the Technical Support Document. 

The projected emiSSions for the year 2021 are 1,546 pounds/day, as indicated in Table 

4, which are higher than the 2015 interim year emission prOjections of 1,294 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 19 of 25 

November 19,2009 
pounds/day. Consequently, the demonstration of maintenance of the PM1 0 NAAQS for 

2021 is adequate to demonstrate maintenance for all years before 2021. 

Table 4: 2021 PM10 Emission Inventory for the
 

Pagosa Springs Attainment/Maintenance Area
 

Commercial Cookin 

Construction 

Fuel Combustion 

Non-Road 

Structure Fires 

Wood Burnin 

Un aved Road-Dust 

Paved Road-Dust 

Hi hwa Vehicles 

A riculture 

Totals: 

1.77 

78.31 

0.02 

2.60 

0.03 

26.71 

25.41 

145.40 

1.83 

0.03 

282.1 

9.70 

429.10 

0.11 

14.25 

0.16 

146.36 

139.23 

796.71 

10.03 

0.15 

1,545.8 

50.28% 

50.28% 

50.28% 

50.28% 

50.28% 

50.28% 

56.18% 

56.18% 

-11.37% 

0% 

C. MAINTENANCE DEMONSTRA TION 

Data presented throughout this document are utilized to demonstrate continued 

maintenance of the PM10 NAAQS for the Pagosa Springs area. Chemical Mass 

Balance (CMB) data are used to generally identify the sources of emissions that 

Influence ambient PM1 0 concentrations. The 2007 emission Inventory is used to 

further refine this CMB-source identification. This information is then used to apportion 

the design day concentration (see Section 2.B.), which becomes the basis for the "roll 

forward" modeling. The apportioned design day concentration is then projected, or 

rolled forward, into the future based on the changes that occur in the emissions 

Inventory from 2007 to 2021. If the 2021 projection is below the 24-hour PM10 NAAQS 

of 150 ug/m3, then maintenance is demonstrated. Based on the analysis presented 

below, the 2021 maintenance concentration for the Pagosa Springs 

attainmenUmaintenance area is calculated at 146.3 ug/m3. Consequently, continued 

maintenance of the PM10 NAAQS is demonstrated. 

The CMB roll-forward methodology used to calculate the 2021 maintenance 

concentration is based on CMB data for concentrations above 100 ug/m3 that were 

collected in 1994, 2006 and 2008. The source apportionments from each of these days 

were averaged to develop a design day apportionment for use in the roll-forward 

modeling. Concentrations that occurred prior to 1994 underwent CMB analyses, but 

the results are not utilized here because the control measures adopted as part of the 

nonattalnment SIP Element had not been fUlly implemented. Also, the CMB data from 

the two highest values measured in 1994 (262 ug/m3 and 258 ug/m3), are not included 

because they would heavily bias the CMB results (geologic emissions were greatly 

elevated on these days due to malfunctioning or poorly operated street cleaning 

equipment, and these emissions are not representative of typical conditions that occur 

in the winter months). Finally, not all years with values exceeding 100 ug/m3 have 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 20 of 25 

November 19, 2009 
1 

CMB analysis, so the following five samples from 1994, 2006 and 2008 are considered 

to representative of high concentration episodes in the area.
 

The average CMB source apportionment, In percent contribution, for geologic, burning,
 

nitrate, sulfate and unknown source categories is indicated in Table 5.
 

CMB Source Apportionments of High Concentrations 

Table 5 Chemical Mass Balance Source Apportionment 

Town Hall and High School Monitoring Sites 

Date PM10 

(ug/m3) 

Geologic 

(Ok) 

Burning 

(%) 

Nitrate 

lo/ll) 

SUlfate 

(%) 

Unknown 

(%) 

Valid 

CMB? 

02/16/94 101 74 14 1 1 10 Y 

03/03/94 105 71 9 0 1 19 Y 

05/05/94 109 87 0 1 2 10 Y 

02/15/06 122 82 7.3 1 2 7.7 Y 

05/01/08 149 81 6.4 2 2 8.6 y 

Average 117.2 79.0% 7.3% 1.0% 1.6% 11.1% 100% 

Geologic =sources rich in crustal elements (street sand, soil, road dust) 

Burning =carbon-rich sources such as wood burning and coal burning 

Nitrate =NH4N03 particulate formed in the atmosphere from NOx and NH3 

Sulfate =(NH4)2S04 particulate formed in the atmosphere 'from S02 and NH3 

2. CMB Roll-forward Analysis 

Subtract the Background Concentration from the Design Value Concentration: 

The background concentration is subtracted from the 102 ug/m3 design day 

concentration (see Section 2.B) because the background concentration would remain if 

all emissions in the emissions inventory were reduced to zero. A background PM10 

concentration of 8 ug/m3 is assumed to occur on any given day In the area, as 

described in the November 1994 SIP Element. 

Design Day Concentration: 102 ug/m3 

Background Concentration: - 8 ug/m3 

94 ug/m3 

Apportion the Design Day Concentration with the CMB Apportionments: 

Geologic: 94 x 0.790 = 74.3 ug/m3 

Burning: 94 x 0.073 = 6.9 ug/m3 

Nitrate: 94 x 0.010 = 0.9 ug/m3 

Sulfate: 94 x 0.016 = 1.5 ug/m3 

Unknown: 94 x 0.111 = 10.4 ug/m3 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 21 of 25 

November 19, 2009 
94.0 ug/m3 

Percent Change in Emissions between 2007 and 2021
 

O!.alues used to roll·forward the CMS apportionments to the year 2021)
 

Highways. Paved Roads. and Unpaved Roads: PM10 emissions rncreased by 

335.4 Ibs.lday, or 54.9% 

Wood burning and structure fires: PM 10 emiSSions increased by 49.1 Ibs/day, or 

50.3% 

Roll-forward Apportionments to 2021 : 

(CalCUlated by applying the Percent Change in emissions from 2007 to 2021) 

Geologic (G):	 Re-entrained fugitive dust from highways, paved roads, 

and unpaved roads are assumed to contribute all geologiC 

emissions that resulted in 74.3 ug/m3 of PM10. This 

concentration will change by the percent change in 

emissions from these sources. 

74.3 ug/m3 x 1.549 =115.1 ug/m3 

Burnrng (B):	 Wood burning and structure fires are assumed to 

contribute to the burnrng emissions that resulted in 6.9 

ug/m3 of PM1 O. This concentration will change by the 

percent change in emissions from these sources. 

6.9 ug/m3 x 1.503 =10.4 ug/m3 

Nitrate (N):	 Unknown sources contributed emiSSions that resulted in 

0.81 ug/m3 of secondary PM10. It is assumed that this 

concentration remains constant because no emissions can 

be assigned to this category 

0.9 ug/m3 x 1.000 =0.9 ug/m3 

Sulfate (8):	 Unknown sources contributed emissions that resulted in 

1.5 ug/m3 of secondary PM10. It is assumed that this 

concentration remarns constant because no emissions can 

be assigned to this category. 

1.5 ug/m3 x 1.000 = 1.5 ug/m3 

Unknown (U): Unknown sources contributed emissions that resulted in 

10.4 ug/m3 of PM1 O. It is assumed that this concentration 

remains constant because no emissions can be assigned 

to this category. (Mobile exhaust emissions could be 

assigned to this category, but mobile emissions go down 

slightly from 2007 to 2021, thus leaving this concentration 

constant is a conservative approach.) 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 22 of 25 

November 19, 2009 
10.4 ug/m3 x 1.000 =10.4 ug/m3 

Total Projected 2021 Concentration (PM102021):
 

(sum of 2021 apportioned components plus the background concentration)
 

PM102021 =G+ B+ N + S+ U + background =146.3 Jlg/m3 

PM102021 =115.1 + 10.4 + 0.9 + 1.5 + 10.4 + 8.0 =146.3 1l9/m3 

Since the PM102021 value is below the daily PM10 NAAQS (150 ug/m3), 

maintenance of the standard is demonstrated 

D. PM10 EMISSION BUDGET 

Federal"transportation conformity" regulations provide for the use of mobile source 

emission budgets in making conformity determinations in the area. The emission 

budget serves as a ceiling on mobile source emissions that federally funded or 

approved transportation projects must comply or conform. 

This revised maintenance plan establishes a mobile source PM10 emission budget for 

the AttalnmenVMaintenance area of 946 Ibs/day for 2021 and beyond. This budget IS 

the total of the 2021 mobile source PM10 emissions (see Section 5.B.3. above), which 

includes PM 10 emissions from highways, paved roads, and unpaved roads. 

This budget has been adopted in the AQCC's "Ambient Air Quality Standards for the 

State of Colorado" regulation. 

E. MONITORING NETWORKIVERIFICATION OF CONTINUED 

ATTAINMENT 

The APCD has monitored ambient PM1 0 concentrations In the Pagosa Springs area 

since 1986. The APCD has operated, and will continue to operate, the Pagosa Springs 

PM10 monitoring network In full accordance with the federal provisions of 40 CFR Part 

58 and the EPA-approved Colorado Monitonng SIP Element. The APCD will also 

analyze the monitonng data to verify continued attainment of the PM10 NMQS. This 

information will provide the necessary information to determine whether the Pagosa 

Springs area continues to attain the PM1 0 NMQS. Detailed information regarding the 

State's monitoring efforts and historical monitoring data can be found in Section 2 of 

this document. 

F. CONTINGENCY PLAN 

Section 175(A)(d) of the CM requires that the maintenance plan contain contingency 

provisions to assure that the State will promptly correct any violation of the PM10 

NMQS that may occur after the redesignation of the area to attainment. EPA's 

redesignation guidance notes that the State is not required to have fully adopted 

contingency measures that will take effect without further action by the State. However, 

the contingency plan should ensure that contingency measures are adopted 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 23 0{25 

November 19, 2009 
expediently once the need IS triggered. The primary elements of the contingency plan 

mvolve the trackmg and triggering mechanisms to determme when contingency 

measures would be needed and a process for implementing appropriate control 

measures. 

1. Tracking 

The tracking plan for the Pagosa Springs area will consist of monitoring and analyzing 

PM10 concentrations. In accordance with 40 CFR Part 58, Colorado will continue to 

operate and maintain the Pagosa Springs PM1 0 monitoring network. 

2. Trigger and Response 

Triggering of the contingency plan does not automatically require a revision of the SIP 

nor is the area necessarily redesignated once again to nonattainment. Instead, the 

State will normally have an appropriate time-frame to correct the violation with 

implementation of one or more adopted contingency measures. In the event that 

violations continue to occur, additional contingency measures will be adopted until the 

violations are corrected. 

Upon notification of a PM10 NAAQS exceedance, the APCD and local government staff 

in the Pagosa Springs area will develop appropriate contingency measure(s) mtended 

to prevent or correct a violation of the PM1 0 standard. Information about historical 

exceedances of the standard, the meteorological conditions related to the recent 

exceedance(s), and the most recent estimates of growth and emissions will be 

reviewed. The possibility that an exceptional event occurred will also be evaluated. 

(Notification to EPA, and to the local governments m the Pagosa Springs area, of any 

exceedance will generally occur within 30 days, but no later than 45 days.) This 

process will be completed within six months of the exceedance notification. 

If a violation of the PM1 0 NAAQS has occurred, a public hearing process at the State 

and local level will begin. If the AQCC agrees that the implementation of local 

measures will prevent further exceedances or violations, the AQCC may endorse or 

approve of the local measures without adopting State requirements. If, however, the 

AQCC finds locally adopted contingency measures to be inadequate, the AQCC will 

adopt State enforceable measures as deemed necessary to prevent additional 

exceedances or violations. Contingency measures will be adopted and fully 

Implemented within one year of a PM10 NAAQS violation. Any State-enforceable 

measures will become part of the next revised maintenance plan, submitted to the 

Colorado Legislature and EPA for approval. 

3. Potential Contingency Measures 

The APCD and local government staff may choose one or more of the following 

contingency measures to recommend to local officials and the AQCC for consideration. 

Contingency measures will be selected that quickly bring the area back into 

compliance with the PM1 0 NAAQS and that specifically meet the needs of the Pagosa 

Sprmgs area. It is likely that no federal or State monies will be available to fund the 

Implementation of the selected contingency measure(s). Most, if not all, of the costs 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 24 of 25 

November 19, 2009 
will be borne by local citizens and governments, local businesses, and State 

government agencies. 

•	 Increased street sweeping requirements 

•	 Additional road paving requirements 

•	 More stringent street sand specifications 

•	 Voluntary or mandatory coal and/or wood burning curtailment 

•	 Bans on all coal and/or wood burning 

•	 Expanded use of alternative de-icers 

•	 Re-establishing new source review permitting requirements for stationary 

sources 

•	 Transportation control measures designed to reduce vehicle miles traveled 

•	 Other emission control measures appropriate for the area based on the following 

considerations: cost-effectiveness, PM10 emission reduction potential, economic 

and social concerns, and/or other factors that the State deems appropriate. 

G.	 SUBSEQUENT MAINTENANCE PLAN REVISIONS 

This revised maintenance plan provides for continued maintenance of the PM10 

NAAQS for an additional ten years beyond the original ten-year period. Consequently, 

no further maintenance plan updates are anticipated. 

Final Revised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 25 of 25 

November 19, 2009 
Colorado Air Quality Control Commission 

Meeting Minutes 

- Action of the Commission to SIP Element Revision 

40 CFRPart 51 Appendix V 2.1(g) 
STATE OF COLORADO
 

Bill Rlller, Jr., Governor 

Ned Calonge, M.D., Inteflm Executive Dlfector 

COLORADO AIR QUALITY CONTROL COMMISSION 

http://www.cdphe.state.co.us 

4300 Cherry Creek Dflve South 

OED-OLRA-A5 

Denver, Colorado 80246-1530 

Phone (303) 692-3100 Colorado Department 

Fax (303) 6~J -7702 of Public Health TOO (303) 691-7700 and Environment 

Colorado Air Quality Control Commission
 

November 19,2009
 

MEETING MINUTES
 

Location:	 Colorado Department of Public Health & Environment 

4300 Cherry Creek Drive South, Sabin Room 

Denver, CO 80246 

Members Present:	 Robert Arnott Radford Byerly Ashley Campsie 

Teresa Coons John Loewy Dawn Meyers 

Barbara Roberts Jon Slutsky Jim Wilson 

Members Absent:	 None 

Commission Staff:	 Doug Lempke Theresa Martin 

Division Staff:	 Paul Tourangeau Mike Silverstein Curt Taipale Gordon Pierce 

Chris Dann Curt Taipale Lisa Silva Dan Ely 

Attorney General's Office: Jerry Goad 

CALL TO ORDER AND DETERMINATION OF A QUORUM 

Chair Roberts called the meeting to order at 1:00 PM and determined that a quorum of 

Commissioners was now present with nine Commissioners. 

ApPROVAL OF MEETING MINUTES FOR OCTOBER 15,2009 

Chair Roberts asked the Commission if there were any modifications to the minutes. Roberts 

noted that on Page 8, 4th line down a comment that she made should be stricken. 

Motion: To approve the October 15, 2009 Meeting Minutes as modified by Commissioner 

Roberts 

Moved: Commissioner Slutsky 

Second: Commissioner Byerly 

Discussion: none 

Carried: 9-0 
PUBLIC COMMENT 

Chair Roberts asked if there were any members of the public who wished to make a comment on 

any air pollution issue not on the agenda. Dr. Doug Lawson of NREL spoke briefly regarding 

weekday versus weekend changes in emissions and whether ambient data could be used to 

represent VMT and NOx reductions without relying upon any models or assumptions. Lawson 

asked the Commission to convene a technical meeting to review the effects of NOx emissions on 

air quality along the Front Range. Eddie Lind of Fort Morgan commented that he represented 

concerned citizens of the area regarding the Sugar Beet factory. Lind stated concerns regarding 

jurisdiction of the factory noting that the County regulates but the City had no control. Lind 

commented that the settling ponds were worrisome due to the potential toxic odors. Lind noted 

that citizens were interested in volunteering to read monitors; would like soil/water/river samples 

ran; would like conversations held with the health staff regarding the decreased health of the 

citizens; dust control is an issue. Lind noted he could get at least 1,000 signatures on a petition 

in a week. Lind commented that there wasn't a problem until Western Sugar took over the 

factory. Tourangeau noted that there was a Title V permit and the factory was inspected 

regularly. Tourangeau noted that there hadn't been any odor violations. Roberts explained the 

difference between pollution issues versus odor issues. Lind asked where the readings were 

being conducted and if the citizens could be part of the inspections. Tourangeau noted that 

inspections were primarily complaint driven and that there were normally yearly inspections. 

Lind expressed great concerns that inspections were only yearly and that even employees of the 

plant that he knows personally have commented that the factory was in violation. Arnott asked if 

there was a northeastern health department and Tourangeau noted that the Division didn't have a 

contract with them. Arnott noted it appeared that there was also a water issue at hand too and 

that this was worth looking into. Roberts thanked Lind for expressing his concerns and 

commented that this would be looked into. Lind thanked the Commission for hearing his 

concerns and reiterated that he would be happy to assist with inspections. David Wolfsey of 

Sonic Spark re-presented the Commission with documentation regarding his concerns regarding 

the HHO convertor noting that he believed it produces major destructive ECO pollutants such as: 

nitric acid, hydrogen cyanide and nitrogen oxides and that his concerns had not been addressed 

previously and wishes the Commission to look into this matter and his findings of this product. 

AGENDA REVIEW 

Chair Roberts asked Lempke to review the meeting agenda noting any items that may have 

changed, been added or deleted. Lempke commented that there weren't any changes to the 

agenda. 

REQUEST FOR PUBLIC HEARING DECEMBER 17, 2009 

Denver Regional Council of Governments (DRCOG) Conformity 

At 1:38 PM Lisa Silva of the Division noted that the presentation would include information 

from the DRCOG regarding its anticipated Transportation Conformity findings regarding the 

2035 Regional Transportation Plan second cycle amendments and the 200812013 TIP. Silva 

commented that the NFRMPO was also in concurrence. Silva noted that neither the NFRMPO 

nor the Upper Front Range Transportation Planning Region had amended their plans but because 

they were part of the 8-Hour Ozone Nonattainment area, transportation conformity must be 

assured for those areas as well as the Denver region until the emission budgets for the individual 

are approved. Emily Chen of the DRCOG reviewed the Cycle 2 Amendments to the 2035 

Regional Transportation Plan and the 2008/2013 TIP. 

2
 
Chen noted that the amendments included a new toll facility to the regional system and three 

partial interchanges associated with the Jefferson Parkway, widening to the roadway system on 

Federal Blvd and also on 144th Avenue, and a RTD station location change in the North Metro 

corridor. Chen reviewed with the Commission the conformity tests conducted and what the 

results indicated. The DRCOG, the NFRMPO and the Division requested that the Commission 

hold a public hearing in December for its anticipated Transportation Conformity findings 

regarding the 2035 Regional Transportation Plan and the 2008/2013 TIP. Byerly asked if this 

was a way to complete the beltway and Steve Cook of the DRCOG noted it was not, it is just a 

proposal at this time. Byerly commented that isn't it true that improving or widening roadways 

brings more traffic and more emissions. Cook noted that there still needs to have in depth 

studies environmentally and vehically. Campsie commented that she had received an email 

regarding concerns about vanpools. Campsie noted she would forward email to Lempke and 

Lempke would forward on to the other Commissioners. Wilson asked that all the maps be 

provided. 

Motion: To approve the motion for hearing on December 17,2009 

Moved: Commissioner Byerly 

Second: Commissioner Wilson 

Discussion: none 

Carried: 9-0 

RULEMAKING HEARINGS 

Pagosa Springs PMIO Maintenance Plan Revision 

At 1:59 PM Curt Taipale of the Division presented to the Commission revisions to the PMlO 

maintenance plan for Pagosa Springs. Taipale noted that this was the second oftwo lO-year 

plans that were required by the Clean Air Act. Taipale explained that the documentation 

reflected that Pagosa Springs would continue to attain the PMI0 National Ambient Air Quality 

Standard through 2021 and had never violated the PMlO NAAQS in the past ten years though 

one exceedance had been recorded in 2000. Taipale commented that no additional control 

measures were required in order to maintain the standard. Taipale explained that this revision 

would satisfy the federal requirement for showing attainment for the second ten-year period after 

redesignation to attainment/maintenance and that no additional revisions of the PMl 0 

Maintenance Plan was expected. Taipale did note that if future changes in mobile source models 

or other unforeseen considerations arose that the Division would address them at that time. 

Motion: To adopt Pagosa Springs PMI0 Maintenance Plan revisions as proposed by 

the Division 

Moved: Commissioner Loewy 

Second: Commissioner Campsie 

Discussion: none 

Carried: 9-0 

3
 
Telluride PMIO Maintenance Plan Revision 

At 2:06 PM Chris Dann of the Division presented to the Commission revisions to the PM10 

maintenance plan for Telluride. Dann noted that this was the second oftwo lO-year plans that 

are required by the Clean Air Act. Dann explained that the documentation reflected that 

Telluride would continue to attain the PM10 National Ambient Air Quality Standard through 

2021 and had never violated the PM10 NAAQS. Dann commented that no additional control 

measures were required in order to maintain the standard. Dann explained that this revision 

would satisfy the federal requirement for showing attainment for the second ten-year period after 

redesignation to attainment/maintenance and that no additional revisions of the PM10 

Maintenance Plan was expected. Dann did note that if future changes in mobile source models 

or other unforeseen considerations arose that the Division would address them at that time. 

Arnott questioned the 54% increase in emissions and Dann responded that it was a standard 

modeling growth factor that had been used. 

Motion: To adopt Telluride PM10 Maintenance Plan revisions as proposed by the 

Division 

Moved: Commissioner Amott 

Second: Commissioner Meyers 

Discussion: none 

Carried: 9-0 

BRIEFINGS, DISCUSSIONS AND REpORTS 

Regulation Number 9: Smoke Management Program 

At 2:14 PM Dan Ely of the Division provided an overview of the Smoke Management Program 

(SMP) noting that it addresses smoke/pollution from prescribed fires on public and private lands 

and that the program had been implemented in 1990 to protect public health and visibility. Ely 

discussed the current activities which included the permits required, inspections, emissions 

inventory, stakeholder meetings, and the many relationships involved in the program. Ely 

commented that the projected costs for the SMP were proposed per regulation requirements and 

to cover the operating costs of the program. Ely noted that the Division would evaluate the SMP 

rules and implementation so as to support and increase where possible the appropriate 

responsible use of prescribed fire and to report the recommendations to the Commission by June 

30,2010. Ely indicated that the Division could not project the costs for 2010 with reasonable 

certainty until recently because of the unknown fiscal impacts on the SMP from HB09-1l99 and 

that the Division concluded that a fee increase was not necessary. Ely reviewed the cost 

projection spreadsheet with the Commission. Ely concluded noting that overall there weren't 

any systemic issues with revenue recovery. Loewy asked what was included in the permits and 

Ely replied that the permit looked at locations such as vicinity in relation to homes, cubic feet of 

piles, fuel loading, and dispersion. Loewy asked how the Division assures compliance and Ely 

responded that a lot of it is a trust factor and the Division also conducts site visits. Roberts asked 

about the new program related to the standard and Ely responded that the Division didn't have all 

the answers, but would have a specific individual from the HB09-1l99 funding in the Division to 

do additional studies of smoke and its impacts. Roberts asked about the role of the Division in 

implementing HB09-l199 and Ely indicated that the Division didn't know yet, but would return 

to the Commission with an approach. 

4 
Coordinating the Development of Plans for Regional Haze/OzonelRMNP 

At 2:50 PM Mike Silverstein of the Division provided an overview of the plans including 

planning goals, backgrounds and activities, and timelines. Silverstein discussed the requirements 

for each of these programs and how individual program proposals would be developed in a 

coordinated fashion to avoid unnecessary regulatory overlap or duplication and provide for the 

efficient consideration, adoption and implementation of each proposal. Silverstein discussed the 

steps necessary to complete the requirements for each program and the relative timing to develop 

the proposals. Silverstein concluded noting that a lot of work had been accomplished over the 

past several months and that the Division would be evaluating and formulating an approach for 

advancing emission controls that benefit ozone, Regional Haze and Rocky Mountain National 

Park. Silverstein also commented that upon development of the proposals the Division would be 

conducting stakeholder meetings and then coming to the Commission for discussion. Roberts 

asked what near term meant regarding the interim plan and Silverstein responded that the 

Division should be ready to bring a proposal to the Commission in the June/July time frame. 

Meyers commented that there had been talks early that ozone had gone up in the Denver area and 

asked how these strategies were affecting the Denver monitor. Silverstein noted that where 

industrial reductions in NOx occur unfortunately there may be ozone increases at nearby 

monitors. 

Coons commented that it appeared that the focus was on ozone and Silverstein agreed that it was 

however the Division would be taking into consideration Regional Haze and RMNP. Roberts 

expressed concerns as the Division moves forward with all three programs together regarding 

technology, costs, air quality improvement; and doesn't want the Commission to be surprised by 

learning about these things at a hearing. Roberts suggested that the Commission should be kept 

in the loop as problematic issues emerge. Wilson asked where other states were in their 

Regional Haze SIP process and Silverstein commented that most of the states were in the public 

comment or just beginning the BART process of the SIP. Silverstein also noted that EPA 

Region 8 was looking at Colorado as being one of the last ofthe western states to comply now 

because ofthe BART rework that had occurred; Colorado was originally one of the first to 

complete the SIP. Coons asked about the stakeholder process and if the Division was working 

with the same group of people and Silverstein responded that the Division was working with the 

same group of people as well as bringing in anyone that may have new interest. Wilson asked 

about the step change of nitrogen deposition in years 1993 and 1994 and what the dramatic 

contributions were. Silverstein commented that the Division would be able to provide this 

information regarding the increase for 1993/1994 for the nitrogen deposition in RMNP at the 

February meeting. Byerly asked that the Commission be made aware ofthe synergies between 

the programs and that if additional modeling was done, an evaluation of how accurate the model 

is be conducted. 

Commissioner Informational Items 

Commissioner Wilson discussed the Boulder Clean Air Challenge that he was involved in over 

the summer noting that results reflected reduced vehicle miles by 10,000 miles which amo~ted

to a savings of 5600 gallons of gasoline and a reduction of 54 tons of carbon dioxide. Wils'on 

noted that it was a great program. Commissioner Loewy commented on a new book titled "How 

the West Was Warmed" responding to climate change in the Rockies by Beth Conover who was 

the creator of the Denver Greenprint Program for the Mayor. Loewy noted that it was a 

collection of 42 essays from writers around the region on issues related to climate change and 

was a very informative piece of work. 

5 
Division Director's Report 

Tourangeau reviewed a number of issues: 

•	 Enforcement Evaluation Report published by EPA Inspector General: the need for 

improvement regarding oversight and policies for high priority violations of the Clean 

Air Act. Tourangeau noted that this means Colorado would need to work with EPA on 

the use ofthe Notice of Violations (NOV) and timelines associated with closures ofthe 

NOV's. 

•	 PM2.5 NAAQS designations: provided a handout that summarized the PM2.5 

designations for NAAQS and noted that Colorado was in attainment and EPA was in 

agreement with the attainment and the technical analysis. 

•	 NAAQS review schedule by EPA: provided a handout of the schedule and summary of 

the S02 NAAQS proposal which was new and expected to go final this coming summer. 

Tourangeau noted that the N02 standard was proposed between 80 and 100 ppb in which 

Colorado currently had two monitors that could reflect nonattainment ifthe standard gets 

set at 80 ppb. Tourangeau commented that the S02 standard was proposed between 50 

and 100 ppb in which Colorado would be in attainment. Tourangeau also noted that 

secondary standards could become significant drivers for the Commission. 

•	 New Mexico imposed more stringent standards than the federal sector specifically for the 

oil and gas programs in the San Juan area south of Durango and the ozone data recently 

reflected that it had dropped dramatically over a three-year average by about 4 ppb 

(between 71-75 ppb). 

•	 Vehicle Inspection, Readjustment Program, and High Emitter Program: provided 

handouts ofthe Executive Summary ofthe Office of the State Auditors 3-year audit and a 

Division report that had been submitted to the Transportation Legislative Review 

Committee. Roberts asked for the web link for the report. 

•	 EPA Order on Oil and Gas for the Frederick Natural Gas Compressor Station: Order 

served based upon petition from WildEarth Guardians to 32 states. EPA's Order notes 

that the Division must complete an aggregation analysis and supplement the record based 

on the analysis and either amend, modify or keep the permit intact. 

•	 NSR Tailoring Rule from EPA: this is a proposed rule that raises the applicability 

thresholds to 25,000 tons per year C02e for Title V and PSD and comments are due to 

EPA by December 28. The Division believes that approximately 143 stationary sources 

would be in exceedence based upon fuel-burning alone and EPA estimates there would 

be about 40 new sources; this doesn't include methane. 

Attorney General's Report 

Goad discussed with the Commission: 

•	 Kasel case filed in Denver District Court but no date had been set 

•	 Consent Decree filed in the US District Court in Northern California by WildEarth 

Guardians complaining that Lisa Jackson of EPA allegedly failed to perform a nondiscretionary duty to either approve a SIP or a FIP for several states including Colorado 

with regard to the 1997 NAAQS for 8-hour ozone and PM2.5. 

6
 
Administrator's Report 

Lempke reviewed the agenda items for the December meeting. Lempke also reviewed with the 

Commission the Action Items Follow-Up list noting that Gordon Pierce had provided input 

requested by Commissioner Byerly regarding NOx monitoring sites around the state. 

ACTION ITEMS 

Lempke reviewed the current actions from today' s meeting: 

•	 DRCOG conformity/van pool information 

•	 Discuss role of APCD with regard to the overall Smoke Management Program 

•	 Provide 1M Audit Report web link to Commission 

•	 Send RAQC Executive Order to Commission 

•	 Response to Doug Lawson regarding forming a committee to investigate NOx as a 

contributor to ozone pollution 

•	 Explain the step increase for 93/94 nitrogen deposition at RMNP 

Adjourn at 5:10 

7
 
Legal Opinion ofthe Colorado State Attorney General
 

40 CFR Part 51 Appendix V 2.1(c) and (e)
 
AUUpmlOn Page lof 

JOHN W. SUTHERS STATE SERVICES Attorney General STATE OF COLORADO 

DEPARTMENT OF LAW BUILDING

CYNTHIA H. COFFMAN 1525 Shennan Street - 7th Floor Chief Deputy Attorney General OFFICE OF THE ATTORNEY Denver, Colorado 80203 DANIEL D. DOMENICO GENERAL Phone (303) 866-4500 Solicitor General 

Fax (303) 866-5691 

Tracking Number: 2009-00772 

OPINION OF THE ATTORNEY GENERAL RENDERED IN
 

CONNECTION WITH THE RULES ADOPTED BY THE
 

Air Quality Control Commission
 

ON 11/19/2009
 

5 CCR 1001-14
 

AMBIENT AIR QUALITY STANDARDS
 

The above-referenced rules were submitted to this office on 11120/2009 as required by section 24-4-103, C.R.S. This 

office has reviewed them and finds no apparent constitutional or legal deficiency In their fonn or substance. 

November 23, 2009 03:09:10 MST 

JOHN W. SUTHERS 

Attorney General 

by DANIEL D. DOMENICO 

Solicitor General 

1ttp://www.sos.state.co.us/CCRIOpinion.do?forview=true&trackingNum=2009-00772 11/30/200' 
Regulation or Regulation Revisions as Published in the
 

Colorado Code of Regulations
 

40 CFR Part 51 Appendix V 2.1 (b)
 
DEPARTMENT OF PUBLIC
 

HEALTH AND ENVIRONMENT
 

AIR QUALITY CONTROL COMMISSION 

AMBIENT AIR QUALITY STANDARDS 

5 CCR 1001-14 

EDITOR'S NOTES* 

Authority Cited: 

Sections 25-7-105(1), 25-7-106(1), (2.5) and (4) C.R.S. 

Section 25-7-302 regarding SIP contents and 25-7-109(2)() regarding authority to regulate carbon monoxide 

(CO) 

History and Amendments: 

Amended 9/11/77,1 CR 1. Added 5/25/78, I CR 6. Amended 12/14/78,2 CR 1. Amended 4/12/79, 2 CR 5. 

Redisignated 8/23/79, 2 CR 9. Adopted 12/20/79, effective 1/30/80,3 CR 1. Amended 3/27/80, effective per 

approval by the General Assembly, 3 CR 5. Adopted 3/1 0/83, effective 4/30/83, 6 CR 4. Adopted 10/17/83, 

effective 11/30/83,6 CR 11. Repealed 7/20/89, effective 8/30/89,12 CR 8. Adopted 12/21/89, effective 1/1/93, 

13 CR 2. Adopted as emergency regulation 2/21/91, effective 2/21/91,14 CR 4. Adopted as emergency 

regulation 5/16/91, effective 5/16/91,14 CR 6. ~dopted 6/20/91, effective 7/30/91,14 CR 7. Adopted 6/16/92, 

effective 7/30/92; Visibility Standard adopted 8/20/91, effective 1/1/93,15 CR 7. Visibility Standard effective 

date postponed on an emergency basis 12/17/92, postponement effective 12/17/92; .Visibility Standard effective 

1/1/95, 16 CR 1. Adopted 3/1 8/93, effective 1/1/95,16 CR 4. Adopted 6/24/93, effective 8/30/93, 16 CR 8. 

Adopted 9/22/94, effective 11/30/94,17 CR 11. Adopted 2/16/95, effective 4/30/95,18 CR 4. Adopted 

6/15/95, effective 8/30/85,18 CR 8. Adopted 3/21/96, EFFECTIVE 5/30/96,19 CR 5. 

A.G. Opinions:
 

1 AG 241; 2 AG 15; 2 AG 113; 2 AG 225; 3 AG 19; 3 AG 122; 6 AG 110-111; 8 AG 328; 13 AG 53; 14 AG
 

118; 14 AG 193; 14 AG 225; 15 AG 256; 16 AG 23; 16 AG 114; 16 AG 278; 17 AG 423; 18 AG 148; 18 AG
 

286; 19 AG 130; 19 AG 338; 19 AG 389;
 

Annotations:
 

Rule 16(c)(3)(b) and 16(c)(3)(c) was not extended by Senate Bill 92-132 and therefore expired June I, 1992.
 

·Thls Title Page does not constitute an offiCIal part of any regulatIOn. InformatIon contamed on the Title Page IS provIded by the Publisher 

from sources deemed reliable and IS solely for mformaltonal and hIstorIcal pwposes. See caultonary note ID Introductory MaterIals, How to 

Use the CCR. 

© 2008 State ofColorado 

All Rights Reserved. (800) 833-9844 
EDITOR'S NOTES (continued) 

Rmlation Histou 

Amended: 

Amended: 

Amended: 

Amended: 

Redesignated: 

Adopted: 

Effective: 

Amended: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Repealed: 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Visibility Adopted: 

Effective: 

.Visibility Postponed: 

Effective: 

Visibility Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted 

Effective: 

Adopted; 

9/1/77 

5/25/78 

12114178 

4/12179 

8123179 

11120179 

1130/80 

3/27/80 

3/10/83 

4/30/83 

10/17/83 

11/30/83 

7120/89 

8/30/89 

11121189 

1/1/93 

1121/91 

2121191 

5/16/91 

5/16/91 

6/20191 

7130191 

6/l8192 

7/30192 

6120/91 

1/1/93 

12117/92 

12117/92 

1/1/95 

3118/93 

1/1/95 

6124/93 

8/30/93 

9/22/94 

11130/94 

2/16/95 

4/30/95 

6/15/95 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted: 

Effective: 

Adopted: . 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

RevIsed: 

Effective: 

Revised: 

Effective: 

Revised: 

Effective: 

8/30/95 

3/21/95 

5/30/96 

9/19/96 

11130196 

10/17/96 

12130/96 

12118/98 

312198 

1/15/98 

3/30/98 

9117/98 

11/30/98 

1/10/00 

3/1100 

2117/00 

4130/00 

1111/01 

3/31101 

3/16101 

5130101 

4/19/01 

6/30/01 

11115/01 

12130/01 

7/18/02 

9/30102 

12119/02 

03/02103 

06/19/03 

08/30/03 

12118103 

02102104 

03112104 

05131104 

5 CCR 1001-14 Page 2 
EDITOR'S NOTES (continued) 

History and Amendments:
 

Adopted 9/19/96, EFFECTIVE 11130/96, 19 CR n. Adopted 10/17/96, EFFECTIVE 12/30/98,19 CR 12.
 

Adopted 12/18/98. EFFECTIVE 3/2/98, 21 CR 2. Adopted 1115/98, EFFECTIVE 3/30/98,21 CR 3. Adopted
 

9/17/98, EFFECTIVE 11130/98,21 CR n. Adopted 1/10/00, EFFECTIVE 3/1/00, 23 CR 2. Adopted
 

2/17/00, EFFECTIVE 4/30/00, 23 CR 4. Adopted 3/16/00, EFFECTIVE 5/30/00, 23 CR 5. Adopted 1/11/01,
 

EFFECTIVE 3/2/01, 24 CR 2. Adopted 4/19/01, EFFECTIVE 6/30/01, 24 CR 6. Adopted 11115/01,
 

EFFECTIVE 12/30/01,24 CR 12. Adopted 7/18/02, EFFECTIVE 9/30/02, 25 CR 9. Adopted 12/19/02,
 

EFFECTIVE 03/02/03, 26 CR 2. Sections V through vn Adopted 06/19/03, EFFECTIVE 08/31/03, 26 CR
 

8. Parts V through vn Adopted 12/18/03, EFFECTIVE 03/01104, 27 CR 2. Parts m.F, m.M, vm.s adopted
 

03/12/04, EFFECTIVE 05/31104,27 CR 5. Parts m.E, m.M, Vm.T adopted 12/16/04, EFFECTIVE
 

03/02/05,28 CR 2. pp. 20-21, 59-60 adopted 12/15/05, EFFECTIVE 03/02/06, 29 CR 2. Rule replaced in its
 

entirety, adopted 11/20/08. EFFECTIVE 12/30/08,31 CR 12. Rule replaced in its entirety, adopted 12/12/08,
 

EFFECTIVE 01130/09, 32 CR 1. Rules V.A, vm.x, vm.Y, adopted 11/19/09, EFFECTIVE 12/30/09,32
 

CR12.
 

A.G. Opinions:
 

21 AG 48; 21 AG 86; 21 AG 353; 23 AG 44; 23 AG 99; 23 AG 116; 24 AG 60-60A; 24 AG 168; 24 AG
 

364; 25 AG 314; 26 AG 73; 26 AG 332; 27 AG 81; 27 AG 174; 28 AG 46; 29 AG 80; 31 AG Dec 1001-14;
 

32 AG Jan 1001-14; 32 AG Dec 1001-14 -1001-14a
 

Annotations: 

© 2009 State of Colorado Page 3 5 CCR 1001-14 

All Rights Reserved. (800) 833-9844 
«;) 2009 State ofColorado 32 CR 12, 12-09 Page 21 

All Rights Reserved 

V.	 Emission BUdgets for Attainment/Maintenance Areas In the State of Colorado 

V.A.	 Budgets 

V.A.1.	 The following Motor Vehicle Emission BUdgets shall be utilized to assess the conformity of 

Transportation Plans, TIPs, and where appropriate, ProJects, for the applicable periods and 

geographic areas indicated: 

Denver Attainment/Maintenance 

Area (Modeling Domain) 

PM10: 2015 through 2021· 54 tons/day; 2022 and beyond: 55 

tons/day. 

Nitrogen Oxides: 2015 through 2021: 70 tons/day; 2022 and 

beyond: 56 tons/day 

Trading provisions: Trading of PM10for NOx, or NOx for PM10 

to adjust emission budgets for purposes of demonstrating transportation conformity shall be allowed uSing the emiSSion trading 

formula as follows: 

For trades necessary to increase a primary PM10 bUdget, 15.0 

tons/day of NOx will be taken from the NOx bUdget to Increase 

the pnmary PM10 bUdget by 1.0 tons/day, a ration of 15 to 1. 

For trades necessary to increase a NOx budget, 1.0 tons/day of 

pnmary PM10 will be taken from the primary PM10 bUdget to 

increase the NOx bUdget by 12.0 tons/day, a ratio of 1 to 12. 

Implementation of trading provisions: In the event the MPO 

cannot demonstrate consistency with the specific PM10 and 

NOx mobile source emission budgets, the trading provisions 

may be utilized only after the MPO has considered all reasonably available local control measures to meet the budgets. The 

MPO must demonstrate the need for trading through the usual 

consultation procedures for state implementation plan development delineated in Section IV (F) of AQCC Regulation Number 

10, Criteria for Analysis of Conformity. 

If trading is utilized, the MPO shall Include the follOWing information in the transportation conformity determination: 

(1) The budget for primary PM10 and NOx for each required year of the conformity determination, before trading is 

employed; (2) The portion of the onginal budget to be used to 

supplement a wanting budget, for each required year for the 

conformity determination; (3) The increased budget that results 

from trading, along with relevant calculations, and (4) the resultIng primary PM10 and NOx budgets for each required year of 

the conformity demonstration. 

The MPO shall then compare projected emiSSions to the adjusted PM10 and NOx motor vehicle emission budgets to demonstrate conformity. 

CODE OF COLORADO REGULATIONS	 5 CCR 1001-14
 
Page 22 32 CR 12, 12-09 

Denver Attainment Maintenance Ozone Precursors (attainment/maintenance area boundary) 

Area NOx 2002 and beyond 134 tpsd VOC 2002 and beyond 119 

tpsd (tpsd = tons per summer day) Carbon MonOXide (attainment/maintenance area boundary) 2013 through 2020: 1625 

tons/day: 2021 and beyond: 1600 tons/day. 

Denver Metro Area/North Front Regional Emissions Budgets 

Range 8-Hour Ozone Nonattainment Area NOx: 122.9 tons/day 

VOCs: 109.2 tons/day 

Southel1fSiib-ReaioriarEmfssions ffiJagefs -

NOx: 102.4 tons/day 

VOCs: 89.7 tons/daY 

Northern Sub-Regional Emissions Budgets 

NOx: 20.5 tons/day 

VOCs: 19.5 tons/day 

Aspen (Modeling Area) PM102015 and Beyond: 16,244lbs.lday 

Calion City PM102020 and Beyond: 1,613lbs.lday 

Lamar (Modeling Area) PM102015 and Beyond: 7,534 Ibs.lday 

Pagosa Springs (Modeling Area) PM102021 and Beyond: 946lbs.lday 

Steamboat Springs (Modeling PM102015 and Beyond: 21,7731bs.lday 

Area) 

Tellunde (Modeling Area) PM102021 and Beyond: 1,108lbs.lday 

Longmont Attain- Carbon Monoxide 2010 through 2014: 43 tons/day 2015-2019: 

mentlMaintenance Area 43 tons/day 2020 and Beyond: 43 tons/day 

Colorado Springs Attain- Carbon Monoxide 2010 and Beyond: 531 tons/day 

mentlMaintenance Area 

Ft. Collins Attain- Carbon Monoxide 2005 through 2009: 99 tonS/day2010 through 

mentlMaintenance Area 2014: 98 tons/day2015 and Beyond: 94 tons/day 

Greeley Area Attain- Carbon Monoxide 2005 through 2009: 63 tonS/day2010 through 

mentlMaintenance Area 2014: 62 tonS/day2015 and Beyond: 60 tons/day 

5 CCR 1001-14 CODE OF COLORADO REGULATIONS
 
02009 State ofColorado 32 CR 12, 12-09 Page 23 

All Rights Reserved 

V.A.2. 

V.A.3. 

V.A.4. 

Geographic Coverage 

Unless othelWlse specified, the geographic coverage of each of the area Motor Vehicle 

Emissions BUdgets shall be the nonattainment or attainment maintenance area as defined In 

the respective state Implementation plans. 

t 

The Motor Vehicle Emissions Budget for PM10 applies to total primary PM10 emiSSions, inclUding emissions from tailpipe exhaust, unpaved roads (except for the Denver PM10 nonattainment area), re-entralned road dust and street sand. It does not include precursor or secondary emissions, WhiCh, where appropriate, are covered under separate budgets. 

Effective Dates 

VA4.a.Denver Carbon Monoxide 

The 1,520 tons per day (2013 and beyond) carbon monoxide emission budget established in Section VA1. shall take effect as a matter of state law when such bUdget 

takes effect as a matter of federal law pursuant to 40 CFR Section 93.118. Until such 

time as the 1,520 tons per day budget takes effect pursuant to this section and 40 

CFR Section 93.118, the carbon monoxide emiSSion budgets for the Denver CO attainment/maintenance area shall be 800 tons per day (2002 and beyond). 

V.A.4.b.Colorado Springs Carbon Monoxide 

The 531 tons per day carbon monoxide emiSSion budget established In Section 

V.A.1. shall take effect as a matter of state law when such budget takes effect as a 

matter of federal law pursuant to 40 CFR Section 93.118. Until such time as the 531 

tons per day budget takes effect pursuant to thiS section and 40 CFR Section 93.118, 

the carbon monoxide emission budget for the Colorado Spnngs CO attainment/maintenance area shall be 270 tons per day (2001 and beyond). 

VA4.c. Reserved 

V.AA.d. Reserved 

V.AA.e.Aspen PM10 

The 16,244 pounds-per-day PM10 emission budget established in Section V.A.1. 

shall take effect as a matter of state law when such budget takes effect as a matter of 

federal law pursuant to 40 CFR Section 93.118. Until such time as the 16,244 

pounds-per-day budget takes effect pursuant to this section and 40 CFR Section 

93.118, the PM10 emiSSion budget for the Aspen PM10 Nonattainment Area shall be 

13,974 pounds-per-day 

VA4.f. Pagosa Springs PM10 

The 946 pounds-per-day PM10 emission budget established in Section VA1. shall 

take effect as a matter of state law when budget takes effect as a matter of federal 

law pursuant to 40 CFR Section 93.118. Until such time as the 946 pounds-per-day 

budget takes effect pursuant to this section and 40 CFR Section 93.118, the PM10 

emission budget for the Pagosa Springs PM10 attainment/maintenance area shall be 

7,486 pounds-per-day. 

CODE OF COLORADO REGULATIONS 5 CCR 1001-14
 
Page 24 32 CR 12, 12-09 

V.A.4.g.Carion City PM10 

The 1,613 pounds-per-day PM10 emission budget established in Section V.A.1. shall 

take effect as a matter of state law when such budget takes effect as a matter of federallaw pursuant to 40 CFR Section 93.118. Until such time as the 1,613 poundsper-day ~udget takes effect pursuant to this section and 40 CFR Section 93.118, the 

PM10 emission budget for the Carion City PM10 attainment/maintenance area shall 

be 7,439 pounds-per-day. 

V.A.4.h.Lamar PM10 

The 7,534 pounds-per-day PM10 emission budget established in Section V.A.1. shall 

take effect as a matter of state law when such bUdget takes effect as a matter of federallaw pursuant to 40 CFR Section 93.118. Until such time as the 7,534 poundsper-day bUdget takes effect pursuant to this section and 40 CFR Section 93.118, the 

PM10 emission bUdget for the Lamar PM10 Nonattainment Area shall be 1,884 

pounds-per-day. 

V.A.4.i. Steamboat Springs PM10 

The 21,773 pounds-per-day PM10 emission bUdget established in Section V.A.1. 

shall take effect as a matter of state law when such budget takes effect as a matter of 

federal law pursuant to 40 CFR Section 93.118. Until such time as the 21,n3 

pounds-per-day budget takes effect pursuant to this section and 40 CFR Section 

93.118, the PM10 emission bUdget for the Steamboat Springs PM10 Nonattainment 

Area shall be 20,682 pounds-per-day. 

V.A.4.j. Telluride PM10 

The 1,108 pounds-per-day PM10 emission budget established in Section V.a.1. shall 

take effect as a matter of state law when such budget takes effect as a matter of federal law pursuant to 40 CFR Section 93.118. Until such time as the 1,108 poundsper-day bUdget takes effect pursuant to this section and 40 CFR Section 93.118, the 

PM10 emission bUdget tor the Telluride PM10 Attainment Area shall be 10,001 

pounds-per-day (2012 and beyond). 

V.B. Reserved 

v.c. Additional Requirements for the Denver PM10 Attainment/Maintenance Area 

V.C.1. Geographic Coverage 

The geographic coverage for the Denver PM10 Motor Vehicle Emissions Budget is the modeling domain contained in the most recent revision to the Denver PM10 state implementation 

plan and technical support documentation, which are available tor inspection at the offices of 

the AQCC located at 4300 Cherry Creek Drive South, Denver, Colorado. 

V.C.2. Regional Emissions AnalySIS 

The emiSSions bUdgets set out in this section shall be used for regional emiSSions analyses 

requIred tor conformity determinations. 

5 CCR 1001-14 CODE OF COLORADO REGULATIONS
 
o 2009 State of Colorado­ 32 CR 12, 12-09 Page 24.1 

AU Rights Reserved 

V.D. Addltlonal.Requirements for the Denver CO Attainment/Maintenance Area 

V.D.1. Geographic CoveFageThecgeographtc;coverage for the Denver CO Motor Vehicle Emissions Budget IS the Denver 

CO attalnment/malt1tenance area as defined In the section of this Ambient Air Standards 

regulationentitled."Description of Boundanes for Denver CO Attalnment/Maintenance Area." 

VI. Carbon,Monoxlder-Standard within the Eisenhower Tunnel" 

Pursuant to theauthority:of;Section'25-7-106 (1), (b) and (c) and of 25-7-107 (1), (a), and (b) of Colorado Revised::StatuteSt19~3f theColorado Air Pollution Control Commission designated and confines 

of any traveled'portion&otothetroadways within the Eisenhower Tunnel as a control area In which the 

adoption andmamtenanseofartamblent air standard is deemed necessary with particular Identification of"carborl'monoxldeta91ttrE!'pollutant hereby made subject to the following standard to maintain 

an acceptabl81humalaicamoxyhemoglobin level: THE AMBIENT AIR WITHIN THE EISENHOWER 

TUNNEL SHAlLBEMAINJ'TAINEOSO THAT THE LEVELS OF CARBON MONOXIDE SHALL NOT 

EXCEED A 15'MINtJTe'AVERAGoOF 100 PARTS PER MILLION VOLUME (115 MILLIGRAMS 

PER CUBIC MEiI"ER-A1?760fTORR'AND 25N CENTIGRADE) CONCENTRATION. 

* Carbon MonoxidelEisenbowelf,Tunnel: Adopted: 9/5/75 Effective: 12/17/75 

CODE OF> CO!.OIMD~REGULATIONS 5 CCR 1001-14 
Page 24.2 3~ CR 12, 12-09
 

This page intentionally left blank. 

5 CCR 1001-14 CODE OF COLORADO REGULATIONS
 
© 2009 State of Colorado 32 CR 12, 12-09 Page 51 

All Rights Reserved 

require, assignment of some or the entire safety margin to the transportation conformity bUdget. The 

reservation of a portion of the carbon monoxide safety margin allows for additional growth In other 

sectors, but does not make the Sip more stnngent than the federal requirements. 

The authority to establish emissions budgets IS Included In the general authority to adopt a state Implementation plan set out In Section 25-7-105(1), C.R.S. 

The mobile source emiSSions budgets are based on EPA-approved computer models, as required by 

federal regUlations. All methodologies and Information made available by Interested parties have 

been conSidered. The rule allocates most of the margin of safety to mobile sources, but maintains a 

reasonable margin for accommodation of uncertainty and future growth In other sectors. The allocation of most of the safety margin to mobile sources provides flexibility for the transportation community In adopting thiS rule, the Commission chose the most cost-effective option. 

VlII.V Canon City PM10 

Adopted: November 20, 2008 

The amendments to the "Ambient Air Quality Standards for the State of Colorado" Regulation 

adopted by the Commission establish mobile source emiSSions budgets for the Carion City area. 

Federal Requirements 

Nothing In thiS rule change exceeds the minimum requirements of the federal act. 

Statutory Authority 

The authority to establish emiSSions budgets and to establish critena for transportation conformity 

determinations IS Included In the general authority to adopt a State Implementation Plan set out In 

Section 25-7-105(1), C.R.S. (2001). 

Findings pursuant to Section 25-7-110.8 

The mobile source emissions budgets are based on EPA's MOBILE6 emiSSions model and EPAapproved methods for calculating fugitive dust emiSSions as required by federal regulations. All methodologies and Information made available by interested parties have been conSidered. The emissions 

budgets reduce the potential for air pollution by capping emissions from mobile sources. In adopting 

thiS rule, the Commission chose the most cost-effective alternative. 

Further, these revisions Include any typographical, grammatical and formatting errors throughout the 

regUlation. 

VII/.W Denver Metro Area/North Front Range 8-Hour Ozone Emissions Budgets 

Adopted December 11, 2008 

The amendments to the "Ambient Air Quality Standards for the State of Colorado" Regulation 

adopted by the Commission establish mobile source emiSSions budgets for the Denver Metro 

Area/North Front Range 8-Hour Ozone area. 

Federal Requirements 

Nothing In thiS rule change exceeds the minimum requirements of the federal act. 

CODE OF COLORADO REGULATIONS 5 CCR 1001-14
 
Page 52 32 CR 12, 12-09 

Statutory Authority 

The authority to establish emIssions budgets and to establish critena for transportation conformity 

determinations IS Included In the general authority to adopt a State Implementation Plan set out In 

Section 25-7-105(1) and In 25-7-107(1), C.R.S. 

Findings pursuant to Section 25-7-110.8 

The mobile source emissions budgets are based on EPA's MOBILE6 emiSSIons model and EPAapproved methods for calculating fugitive dust emIssIons as reqUired by federal regulations. All methodologIes and Information made available by Interested parties have been considered. The emiSSions 

budgets reduce the potential for air pollution by capping emissions from mobile sources. In adopting 

this rule, the CommIsSIon chose the most cost-effective alternative. 

VIII.X Pagosa Springs PM10 

Adopted November 19, 2009 

The amendments to the "AmbIent Air Quality Standards for the State of Colorado· Regulation 

adopted by the Commission establish mobile source emISSIons budgets for the Pagosa Springs 

PM10 attainment area. 

Federal Requirements 

Nothing In thiS rule change exceeds the mInimum requIrements of the federal act. 

Statutory Authority 

The authority to establish emiSSIons budgets and to establish critena for transportation conformity 

determinations IS Included In the general authority to adopt a State Implementation Plan set out In 

Section 25-7-105(1), C.R.S. (2001). 

Findings pursuant to Section 25-7-110.8 

The mobile source emISSions budgets are based on EPA's MOBILE6 emISSIons model and EPAapproved methods for calculating fugitive dust emissions as reqUired by federal regUlations. All methodologies and Information made available by interested parties have been consIdered. The emIssIons 

budgets reduce the potential for aIr pollution by capping emiSSIons from mobile sources. In adopting 

thIS rule, the CommISSIon chose the most cost-effective alternative. 

Further, these reVIsions will Include any typographical, grammatical and formatting errors throughout 

the regulation. 

V111.Y Telluride PM10 

Adopted November 19, 2009 

The amendments to the "Ambient Air Quality Standards for the State of Colorado· Regulation 

adopted by the CommIsSion establish mobile source'emlSSlons budgets for the Tellunde PM10 attaInment area. 

Federal Requirements 

Nothing In this rule change exceeds the minimum requIrements of the federal act. 

5 CCR 1001-14 CODE OF COLORADO REGULATIONS
 
o 2009 State of Colorado 32 CR 12, 12-09 Page 53 

All Rights Reserved 

Statutory Authority 

The authority to establish emIssions budgets and to establish critena for transportation conformity 

determinations is Included in the general authority to adopt a State Implementation Plan set out In 

Section 25-7-105(1), C.R.S. (2001). 

Findings pursuant to Section 25-7-110.8 

The mobile source emissions bUdgets are based on EPA's MOBILE6 emissions model and EPAapproved methods for calculating fugitive dust emissions as required by federal regulations. All methodologies and Information made available by interested parties have been considered. The emissions 

budgets reduce the potential for air pollution by capping emiSSions from mobile sources. In adopting 

this rule, the Commission chose the most cost-effective alternative. 

Further, these revisions will include any typographical, grammatical and formatting errors throughout 

the regulation. 

CODE OF COLORADO REGULATIONS 5 CCR 1001-14