# 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 

### ofPublicHealth http://www.cdphe.state.co.us andEnvironment
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 submittedto EPA for final approval and incorporation into the Colorado State Implementation Planpursuant to 40 CFRPart 51, Appendix V, 2.1 (a). Two copies ofthe materials needed for your review ofeach 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 secondten-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 PMl0 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 CommonProvisions Regulation to revise the definitions of"negligibly reactive volatile organic compound" and "volatile organic compound" (VOC) in SectionI.G. to be consistent withthe 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 interstatetransport element ofthe State ImplementationPlan to address outstanding issues that the US EPAhad identified with planpreviously adopted by the Commission.
We look forward to your timely review and approval ofthis request. The office ofthe Colorado Air Quality Control Commissionmay 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 ofPublic

Health and Environment

cc. Paul Tourangeau Doug Lempke Mark Komp

# Pagosa Springs PMIO Maintenance Plan including the AmbientAir Quality Standards

ADMINISTRATIVE MATERIALS
Copies ofthe following administrative materials are included in this submittal ofrevisions to Pagosa Springs PM10 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 ofthe Denver Post 40 CFR Part 

### 51 Appendix V

### 2.1 

### (f)
• Procedural Documents ofthe Commission (this includes the Agenda Item Control Sheet, the Memorandum ofNotice, the Economic Impact Analysis)
• Parties Hearing Documents (this includes a list ofthe parties, the partiesprehearing 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 V2.2 

### • Public Comments 40 CFR Part

### 51 Appendix V

### 2.1(h) 

### • Adopted Statement ofBasis, Specific Statutory Authority and Purpose • Adopted Language bythe 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 CommissionMeeting 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 inthe Colorado Code of Regulations 40 CFR Part 

### 51 Appendix V

### 2. 1(b)

# HearingNotice as Published onthe CommissionWebsite
40 CFRPart 51 Appendix V 2.1 (f)

# STATE OF COLORADO

Bill Ritter, Jr., Governor James B. Martin, Executive DIrector
DedicatedtoprotectingandImprovmg the healthandenVironment of thepeopleofColorado COLORADOAIR 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 ofPublic Health TOO (303) 691-7700 and Environment 

### NOTICE OF PUBLIC RULEMAKING HEARING 

## BEFORETHE 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 hearingto considerrevisions to the PMIO maintenance plan for Pagosa Springs. This is the second oftwo IO-year plansthat are required by the Clean Air Act. The Division is proposingto revise the AmbientAir Quality Standards regulation to modify the mobile source emissions budget.
FEDERAL REQUIREMENTS: The federal act requires the adoption ofa second IO-year maintenance planto demonstrate long term compliance withthe National standard. A proposed Statement ofBasis, Specific Statutory Authority, and Purpose and a regulatory analysis (ifone has beenrequested) 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 ofthis notice.
HEARING SCHEDULE: DATE: November 19, 2009 TIME: 9:00 AM PLACE: Colorado Department ofPublic Health & 

### Environment 4300 Cherry Creek Drive South, Sabin Conference Room Denver, Colorado 80246
The hearingmay be continuedatsuchplacesandtime as the Commission mayannounce. Interestedpartiesmay contact the Commission Office at303-692-3476to confirm meetmgdates andtimes.

### PUBLIC COMMENT: The Commissionencourages all interested persons to provide their views either orally atthe hearing orinwriting priorto orat the hearing. The Commission especially solicits comments and analyses from persons who will incurdirectly some costorbenefit from the proposed revisions. Public testimony will be taken as close to the start ofthehearing as possible and during the hearing as necessary. Written and/orelectronic submissions priorto the hearing are requestedto allowreviewpriorto presentationat the hearing. Written and/orelectronic submissions shouldbe mailed to the Commission Office at least 14 days priorto the hearing.


### PARTY STATUS: In order to obtainparty status at the hearing, compliance with several requirements as defined in the Commissions Procedural Rules is necessary. A petition for party statusmust be filed by electronic mail with the Office ofthe Air Quality Control Commission no laterthanclose of business on

### September 15,2008. The petitionmust: 1) 

### identify the applicant; 2)

### provide the name, address, telephone andfacsimile numbers, andemailaddress of the applicants representative; and3) 

### brieflysummarize what, 

## if any, policy,factual, andlegal issues the applicanthaswith theproposal(s) as of the time offilingthe application. Electronically mailed copies must also be received, by this same date, by the Division staffperson and the Assistant Attorneys General representing the Divisionandthe Commission identified below. Any person may petition the Commissionto file documents in papercopy format ifthey are unable for any reason to not comply with the requirements of 1.3.8(2) ofthe CommissionsProcedural Rules. An original and a specified number ofpapercopiesmust be filed inthe Office ofthe Air Quality Control Commission, Colorado Department ofPublic Health and Environment, 4300 Cherry Creek Drive South, Denver, Colorado 80246.
Individuals may also obtainparty status throughthe submittal ofan initial alternative rule to the proposed rule. The submittal ofan alternative proposal mustbe accompaniedby an electronic copy ofthe initial alternative proposedrule and all other associateddocuments as requiredby the Commission'sprocedural rules and mustbe filed by electronic mail with the Office ofthe Commissionby the date specifiedfor party status requests. Initial alternativerules must also be filed by electronic mail with the Division staffpersonand witheach ofthe Assistant Attorneys General.
Air Quality Control Commission AirPollution Control Division Theresa L. Martin CurtTaipale 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 beyondthe above stateddeadline shall only be considered upon a written motion for goodcause shown. The Commissionreserves the right to deny party status to anyone that does not comply with the Commission'sprocedural rules.


### STATUS CONFERENCE: A status conference will be held September 18th at9:00 a.m., at the DepartmentofPublic Health and Environment to ascertain and discuss the issues involved, and to ensure thatparties are making all necessary efforts to discuss andresolve such issues priorto the submission of prehearing statements. Attendance atthis 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 October20, 2009 at 1:30p.m. inthe CommissionOffices at 4300 Cherry Creek Drive South, Denver. All parties must submitby electronic mail a preliminary prehearing statementto the Commission Office by close ofbusiness October 14, 2009. In addition, electronically mailed copies ofthese documents must be delivered bythat date to all persons who have requestedparty status. A copy ofthe prehearing statement must also be electronically mailedto the Division point ofcontact and each ofthe Assistant Attorney's General identified above by close ofbusiness October 14, 2009. Anyrevisions to the prehearing statementmust be submittedto the Administratorofthe Commission at the prehearing conference and by electronic mail to the Commission Office onthe day ofthe prehearingconference. Any exhibit included inthe prehearing statements will be electronically mailed to individual Commissioners for reviewpriorto the hearing, provided the party files electronic copies ofsuch exhibit. Rebuttalsto the prehearing statement may be submitted to the CommissionOffice and all otherparties by close ofbusiness October27,2009.



### EXCEPTIONS TO FILE DOCUMENTSBY ELECTRONIC MAIL: The Commission's Procedural Rules provide for an exceptionto file documents by electronic mail. Ifgranted an exception to electronic filing pursuantto the provisions of 

### 1.3.8(3) ofthe Commissions Procedural Rules, the applicant for party status shall file an original and fifteen copies ofthe prehearing statement in the Office ofthe Air Quality Control Commission, and shall also delivercopies to each other party, applicant for party status, the Assistant Attorneys General representing the Commission and Division, and the Division staffperson for the proceedings, by electronic mail oras otherwise provided by the exception granted under Subsection 

### 1.3.8(3), by that same day.

### STATUTORYAUTHORITY FORTHE COMMISSION'S ACTIONS: 

### The Commissionproposes these regulatory changespursuantto 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 ofstatutory authority is not intended as an exhaustive list ofthe Commission's statutory authorityto act in this matter.
Datedthis 25th day ofAugust 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 ofColorado 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 ofdemonstrating transportation conformity shall be allowed uSing the emiSSion trading formula as follows: For trades necessary to Increase a primary PM10 budget, 15.0tons/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 1to 12. Implementation of trading prOVIsions: In the eventthe 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 meetthe 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 Iftrading 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 ofthe conformity determination, before trading IS employed; (2) The portion ofthe original budget to be used to supplement a wanting budget, for each required yearfor 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 ofthe conformity demonstration. The MPO shall then compare prOjected emiSSIons to the adjusted PM10 and NOx motor vehicle emiSSion budgets to demonstrate conformity
Ozone Precursors (attainment/maintenance Denver Attainment Maintenance Area area boundary) NOx 2002 and beyond 134 tpsd VOC 2002 and beyond 119 tpsd (tpsd =tons per summerday) 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.ldayLongmont 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 ofeach ofthe area MotorVehicle Emissions BUdgets shall be the nonattalnment or attainment maintenance area as defined In the respective state Implementation plans.
V.A.3. The MotorVehicle 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 ofstate law when such bUdget takes effect as a matter offederal 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 ofstate 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. ReservedV.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 ofstate law when such bUdget takes effect as a matter offederal 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 NonattalnmentArea 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 ofstate lawwhen budget takes effect as a matter offederal 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 PM10
The 1,1613 pounds-per-day PM10 emiSSion bUdget established In Section V.A.1 shall take effect as a matter ofstate law when such bUdget takes effect as a matter offederal 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 offederal 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 ofstate lawwhen such budget takes effect as a matter offederal 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 NonattalnmentArea 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 ofthe 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 pursuantto 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 Agendawhere Public Hearing Occurred and Notice published in the Legal Ads ofthe DenverPost
40 C·PR Part 51 Appendix V 2.1(f)

# STATEOFCOLORADO

Bill Ritter, Jr., Governor James B. Martin, Executive Director COLORADOAIR QUALITY CONTROLCOMMISSION 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 ofPublic Health TDD (303) 691-7700 and Environment 

# Notice ofMeeting andAgenda Air QualityControlCommission November19,2009 Colorado DepartmentofPublic Health & 

## Environment 4300 CherryCreekDrive South, Sabin Room Denver, Colorado


## 1:00 p.m.

Call to Order: Detennination ofa Quorum 

### ApprovalofMinutes: ReviewlApproval ofthe October 17, 2009 meeting min Air Quality Control Commission. utes ofthe



### PublicComment: 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 CommissionAdministrator will reviewthe meeting and discuss any proposed revisions to the agenda for the Commission'sconsideration. agenda

REQUEST FOR PUBLIC HEARINGS DECEMBER 

### 17, 2009 

### 1. DenverRegional Council ofGovernments (DRCOG) Conformity (10 minutes presentation, 10 minutes discussion) The DRCOG will requestthat the Commissionhold apublic 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 PlanRevision (10 minutes presentation, 10 minutes discussion) The Division will present to the Commissionrevisions to the PMIO maintenance plan for Pagosa Springs. This is the second oftwo 10-yearsplans that are required by the Clean Air Act. The Ambient Standards and the SIP Specificsregulations will require revisions.


### 3. TelluridePMIO Maintenance PlanRevision (10 minutes presentation, 10 minutes discussion) The Division will present to the Commissionrevisions to the PM10 maintenance plan for Telluride. This is the second oftwo lO-years plans that arerequired by the CleanAir Act. The Ambient Standards and the SIP Specifics regulations will require revisions.
BRIEFINGS, DISCUSSIONS AND REpORTS 

### 4. 

### Regulation Number9: SmokeManagementProgram (20 minutes presentation, 20 minutes discussion) The Division will provide the annual update to the Commission onthe projectedcosts for the Smoke Management Program. Program costs are not currently projected to causea change to inthe annual fees assessed to those coveredby the program. 

### 5. 

### Coordinatingtbe Development ofPlans for Regional Haze/Ozone/Rocky Mountain National Park (10 minutes presentation, 25 minutes discussion) The Commission and Divisionwill discuss the requirements for each ofthese programs and howindividual program proposals will bedeveloped in a coordinated fashion to avoid unnecessary regulatory overlap orduplication andprovide for the efficient consideration, adoption and implementationofeach proposal. The Commissionand Divisionwill discuss the steps necessary to complete the requirements for each program and the relative timingto develop the proposals.


### 6. CommissionerInformationalItems Commissioners will discuss amongthemselves activities that they have participated in over the past monththatthey believe other Commissioners and/ormembers ofthepublic may be interested in hearing about.
7. 

### Division Director's Report

- Paul Tourangeau Monthly activities report
8. 

### Attorney General's Report

- Jerry Goad Update ofany recent court actions on airquality issues
9. 

### Administrator'sReport. Doug Lempke
• Decembermeeting agendaitems review • Review ofAction Items from Today's CommissionMeeting • Status ofPending Action Items Adjourn

2

## 6:00 p.m.

Public Service Company
- Cherokee Station Renewal ofthe Title V Operating Permit
The Commission will hold apublic commenthearingpursuant to the request ofthe WildEarth Guardians, Clean Energy Action and the Sierra Club and the provisions of§25-7-114.5 Colorado Revised Statutesto considerthe renewal ofthe 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 apublic hearingbefore the Commissionto elicit and record the comment ofany interested person regarding the sufficiency ofthe preliminary analysis and whetherthe permit(s) should be approved or denied. The draft operatingpermit(s) and preliminary analysis can be viewed atthe Office ofthe Adams County Clerkand Recorder at 450 South 4th 

### Avenue, Brighton, Colorado, 80601, Phone: 303-654-6026 duringregularbusiness hours or at the offices ofthe Colorado Department ofPublic Health and Environment, Air PollutionControl Division at 4300 Cherry Creek Drive South, Glendale, Colorado 80246. This information is also available onthe Department ofPublic Health and Environment's website at http://www.cdphe.state.co.us/ap/airpublicnotices.html



### 3

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# Procedural Documents ofthe Commission

- AgendaItem Control Sheet

- Memorandum ofNotice

- Economic ImpactAnalysis (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-HEARINGACTIONS REQUESTFOR 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



### -
STATUTORYAUTHORITY 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 PM 10 Date of EPA submission deadline: 06-15-09

Agenda Item Control Sheet

- Proposed Pagosa Springs PM10 Maintenance Plan Revision November2, 2009 Page 1

### ISSUE STATEMENT:
The Division is requesting that the.Commission approve the proposed revision ofthe Pagosa Springs PM10 Attainment/Maintenance Area Plan. The Division has received verbal concurrence ofthe proposed plan from the City Manager ofthe Town of Pagosa Springs although no written concurrence has been received. The documentation shows that Pagosa Springs will continue to attain the PM 10 National AmbientAir Quality Standard through 2021, and has neverviolated the PM10 NAAQS in the past 10 years, although one exceedance ofthe standard was recorded in 2000. No additional control measures are required for Pagosa Springs to maintain the standard. By accounting foranticipated growth, it is projected that Pagosa Springs will demonstrate maintenance ofthe PM10 NAAQS through the year 2021 with a concentration ofapproximately 146 micrograms per cubic meter (the NAAQS is 150 

## ug/m\
This revision will satisfy the federal requirement for showing attainmentfor the second ten-year period after redesignation to attainment/maintenance. No additional revisions ofthe Pagosa Springs maintenance plan are anticipated. Iffuture 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 atthat 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 ofthe 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 forthe Pagosa Springs Attainment/Maintenance Area

3. Final Economic ImpactAnalysis

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 OFNOTICE

Date: August 4, 2009 To: Interested Parties Subject: Revisions to theAir QualityControl Commission's "AmbientAir Quality Standards"Regulation in SupportofRevisions to the Pagosa SpringsPMIO MaintenancePlan



### GENERALDESCRIPTION The AirPollution Control Division (Division) proposes this rulemakingpackage withthe intent ofrevising the Colorado "Ambient AirQuality Standards" regulation, specificallyto revise the PM10 emissionbudget forthe PagosaSprings AttainmentlMaintenance Area. Nothing inthisrule change exceedsthe minimumrequirements ofthefederal act. 

### RULEMAKINGPACKAGE
Attachmentstothis memorandumprovide details ontheproposal as follows:

• Attachment A: The actual language oftheproposedrevisions to the "AmbientAir Quality Standards" regulation;

• Attachment B: A statement describingthe initial economic impact analysis ofthe proposedrevisionsto the "AmbientAir Quality Standards"regulation; and

• Attachment C: TheRevised PM10 Maintenance Plan for the Pagosa Springs AttainmentlMaintenance Area

• Attachment D: Technical Support Document

- Emissions Inventory 

### EXPLANATIONOFTHEPROPOSEDRULES Adoption ofthe revised Pagosa Springs Maintenance Planand the above-mentioned Ambient Air Quality Standards regulation revisions would establish a revised PMI0 emission budget for the Pagosa Springs area. The Divisionrequests approval and adoption ofthe revised maintenance planandthe proposedregulationrevisions as part ofthe State Implementation Plan (SIP) 

### MATERIALS TO BEINCORPORATEDBY REFERENCEINTHEPROPOSEDRULES
There are no materialsto be incorporatedbyreference in the proposedrule revisions.

### PUBLICMEETINGS
You are invited to reviewthese materials andpresent written ororal comments to the Division in accordance with the following: Date: (3rd week after publication ofproposedrule 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 ofWritten Comments: October 1, 2009 CurtTaipale is lead Division stafffor the Pagosa Springs PMI0Maintenance Plan revision process. Following the close ofthepublic commentperiod, Mr. Taipale will prepare a Division Response to Public Comments that summarizes all public commentsreceived, that discusses options for addressing the concerns, and makes recommendations from the Divisionfor each issue. The Air Quality Control Commission (AQCC) will receive a copy ofthe Division Response to Public Comment and all written comments submitted to the Division. The AQCC will hold a public hearing on November 19,2009. Interestedparties mayrequest meetings with Division staffthree (3) weeks priorto the AQCC publichearing regarding this matter. To schedule a meeting, please contact Curt Taipale, who will make arrangements for a meeting regarding this proposed rulemaking. Ifyou wish to be kept advised ofthese proceedings and/orreceive a copy ofthe Division Responseto Public Comments, youmayrequest that your name be placed on the mailing list for this rulemakingproposal 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 ONDEVELOPMENTOFTHEPROPOSEDRULES What are the problems? The Air Pollution Control Divisionis submitting a 2009 revised maintenance planfor the Pagosa Springs areaas required by the U.S. EPA to assure attainment for a second 10-yearperiod beyond the initial maintenanceperiod. The initial 10-yearmaintenance period extended from the June 2001 date when EPA approved the initial redesignationrequest and the associated attainment/maintenanceplan. The second 10-yearperiod extends to 2021. As part ofthe 2009 revised maintenance plan, a newPMI0emissions budget has been established for transportationconformity.

### Howdo the proposed rules help solve the problems? The proposed changes to the Ambient Air Standard assign anupdated emissions budget for transportation confonnityusing the latest emissions inventory data. This updated emissions budgetis also reflected in the revised PMIO Maintenance Plan for Pagosa Springs. Nothing in these rule changes exceeds the minimum requirements ofthe federal act. 

### RULES'EFFECTS ONPUBLIC, REGULATED COMMUNITY,AND OTHERAGENCIES The proposed emissionbudgetreflects the latestestimate ofemissions. The establishmentofa budget will impact the planningoffederally funded/approved highwayplans and projects and could require the implementationofmitigationefforts in orderto comply with the emissions budget cap. No direct costs to the public are anticipated by establishingthe emission budget. 

### RELATIONSHIP TO FEDERALANDADJACENTSTATEREQUIREMENTS Federal Requirements: The revision to the emissionbudgetconfonnsto federal regulation. Adjacent State Requirements: Therevisionsto the AmbientAir Quality Standardsregulation are in confonnance withthe same federal requirements affecting attainment/maintenance areas inthe adjacent states. 

### IMPLEMENTATIONOFTHERULES The revised emission bUdget will be implemented through confonnity determinations made underthe transportation conformity regulations. The SIP Specific Regulation contingency measures will cease upon AQCC adoption and EPA approval ofthisrule change. No additional contingencymeasures are necessaryunless the arearecords a violation ofthe PMIO NAAQS in the future. 

### TIME CONSTRAINTS The proposedrule changes are to be completed in 2009 in order for the state to submit a Pagosa Springs SIP revision to EPA in atimely mannerto showattainment for the second ten-yearterm. In accordance with CAA 176A(b), it is required that amaintenance plan revision be submittedto the EPA within eight years after the original redesignation (which was onJune 15,2001)to address maintenance ofthe standard for a second ten-yearperiodbeyond redesignation. The purpose ofthis maintenanceplanrevision is to provide for maintenance ofthe PMIO standard for the additional tenyears (through2021) following the first ten-yearperiod. There are no known specific time constraints except that these regulatory revisions are directly associated with, and are companionto, the 1O-year maintenance planupdate. 

### RANGEOFREGULATORY ALTERNATIVESAND THENO-ACTIONANALYSIS
No competing oralternative control measures were rejected when compilingtheseproposed revisions as no new controls are beingproposed. By taking no action, there would not be a second ten-yearmaintenanceplan for this areaas required by federal law.

### JUSTIFICATIONFORDIFFERINGFROMFEDERALREQUIREMENTS Theproposedrules meetall requirements applicable to the areaas required by federal regulation and the CleanAirAct. Theproposedrules do not differ from orexceed the federal requirements.

### FINAL ECONOMIC IMPACTANALYSIS Per C.R.S. 25-7-110.5 

### Revisions to the "AmbientAir Quality Standards" Regulation
November 19, 2009

The revisions to the Pagosa Springs PM10 maintenance plan revise the PM10 emission budget in the AmbientAir Quality Standards regulation. The rule changes should not result in an increase in costs to industry, the public orthe 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 ofTransportation, but do not impose any direct costs on these agencies. Ratherthan increasing costs, the emission budget may change the mix of projects eligible for transportation dollars.

Final Economic ImpactAnalysis

- Proposed Pagosa Springs PM10 Emissions Budget November2, 2009

### INITIAL ECONOMIC IMPACTANALYSIS 

### Per C.R.S. 25-7-110.5 Revisions tothe "Ambient Air Quality Standards" Regulation 

### August 20, 2009

The revisions to the Pagosa Springs PM10 maintenance plan revise the PM10 emission budget in theAmbient Air Quality Standards regulation. The rule changes should not result in an increase in costs to industry, the public orthe 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 ofTransportation, but do not impose any direct costs on these agencies. Ratherthan 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/MaintenanceArea

ColoradoDepartment 

# ofPublicHealth andEnvironment

Revised PM10 Maintenance Plan Submittal; U.S. EnVironmental Protection Agency: submitted on -TBD Colorado AirQuality Control Commission, adopted on - TBD ,Qa§'9u $;pFJ1=I§'. 7"9wR C91J1=IGU. appr9vefJ91=1 Til:)

PM10 Maintenance Plan Submittal: U.S. Environmental Protection Agency: approved on 06115/01, effective on 08114/01 Colorado

### A" Quality Control Commission, adoptedon 03116100 Pagosa Springs Town Council, approvedon February2000

PM10 State Implementation Plan Sybmittal 

## u.s. Environmental Protection Agency: approved 05119/94, effective 06120194 Colorado AirQuality Control Commission. approvedont1/t9/92; 11/12/93

Revisions Prepared By: AirPollution Control DiVision Colorado DepartmentofPublic Health andEnvironment 4300 Cherry Creek Df/va South Denver. Colorado 80246CMB 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 atmospherefrom S02 and NH3 

### 2. CMS Roll-forward Analysis Subtractthe Background Concentrationfrom 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 inventorywere reduced to zero. A background PM10 concentration of 

### Buglm3 is assumed to occuron 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 Apportionthe Design DayConcentration 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 forPaqosg Springs AttainlJ7ont/MQintcnancc Arpa Page 21 cf25Total Projected 2021 Concentration**(PM1~21):** 

### (sum

# or2021 

### aRDon/onedcomponentsplus 

## the baclcacoundconcentration)
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
Sincethe PM10'011 value is belowthe daily PM10 NAAQS (150 uglm3). 

### maintenance ofthe

### 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 ofQ461bsldayfor 2021 and beyond. This budget is the total ofthe 2021 mobile source PM10 emissions (see Section**5.B.~~.** above), which includes PM10 emissionsfrom highways, paved roads, and unpaved roads. This budget has been adopted in the AQCC's "AmbientAir Quality Standards forthe State of Colorado" regUlation. 

## E. MONITORING NETWORKNER/F/CA

## nONOF CONTINUED ATTAINMENT The APeD hasmonitored ambient PM10 concentrations in the Pagosa Springs area since 1986. The APCD has operated, and will continueto operate, the Pagosa Springs PM10 monitoring network in full accordance with the federal provisions of40 CFR Part 

### 58 and the EPA-approved Colorado Monitoring SIP Element. TheAPCD 'Nill also analyze the monitoringdata to verify continued attainment ofthe PM10 NMOS. This information will provide the necessary information to determinewhetherthe Pagosa Springs area continues to attain the PM10 NMOS. Detailed information regarding the State's monitoring efforts and historical monitoring data can befound in Section 2 of this document.


### F. CONTINGENCYPLAN Section 175(A)(d)ofthe CAA requires that the maintenance plan contain contingency provisionsto assure that the State ""ill promptly correct any violation ofthe PM10 NAAOS that may occurafterthe redeslgnation ofthe area to attainment. EPA's redesignation guidance notesthat the State is not requiredto have fully adopted contingency measuresthatwill take effectwithoutfurther action by the State. However, the contingency plan should ensure that contingency measures are adopted expediently once the need istriggered. The primary elements ofthe contingency plan involve the tracking and triggering mechanisms to determinewhen contingency

Revised PM1QMaintenancePJan fpcPallAS' S0tin4sAttaioment!MajntenanClArea page 23pt25

# Parties HearingDocuments (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 QUALITYCONTROL COMMISSION STATE OF COLORADO AIR QUAlITY COOlQ.CXMtIlSSlOII'



### PREHEARING STATEMENT OFCOLORADODEPARTMENT OFPUBLIC HEALTHAND ENVIRONMENT, AIRPOLLUTIONCONTROLDIVISION

REGARDING AMBIENT AIR QUALITY STANDARDS REGULATION, SIP SPECIFIC REGULATION AND THE TELLURIDE AND PAGOSA SPRINGS PMI0 MAINTENANCE PLANS

The Colorado Department ofPublic Health and Environment, Air Pollution Control Division ("Division") submits the following Prehearing Statement in this matter:
EXECUTIVE SUMMARY

The Division is proposingrevisions for the Pagosa Springs and Telluride PMI0 AttainmentlMaintenance Area Plans. The Division is unaware ofany partiesto 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 ofthe standard in 2000. Telluride has had no exceedance. No additional control measures are required for Pagosa Springs orTelluride to maintainthe standard. The Division projects thatboth towns will continue to attain the PMI0 NAAQS through 2021, with Pagosa Springs at a concentration ofapproximately 146 micrograms percubic meter, compared with the NAAQS of 150 micrograms per cubic meter, and Tellundeat 127 micrograms per cubic meter. This revision would satisfy the federal requirement for showing attainment for the second ten-year periodafter 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 orthe DiVIsion. This proposal is supported by the Towns ofPagosa Spnngs, Tellunde. Mountain Village and San Miguel County

STATEMENT OF FACTUAL AND LEGAL ISSUES
The Division is aware ofno Issues.WITNESSES
1. CurtTaipale, Colorado Department ofPublic Health and Environment, Air Pollution Control Division. 

### Mr. Taipale may testify regarding the Pagosa Springsplan.
2. Chris Dann, Colorado Department ofPublic Health and Environment, Air Pollution Control Division. Mr. Dann may testify regarding the Telluride plan.
3. Other employees ofthe Colorado Department ofPublic Health and Environment, Air Pollution Control Division may, ifnecessary due to scheduling or availability, replacethe witnesses listed above. Ifthe above witnesses are unavailable to testify, the Division will notify the Commission ofany replacement witness as soon as possible.

EXHIBITS The Divisionhas no exhibits atthis time.



### DATED this 14th day ofOctober, 2009.

JOHN W. SUTHERS Attorney General

HO A. ROAN, 30867* Assistant Attorney General Environmental Quality Natural Resources and Environment Section Attorneys for AIRPOLLUTION CONTROL

DIVISION
1525 Sherman Street, 5th Floor Denver, Colorado 80203 Telephone: (303) 866-5280 *CounselofRecord

# Revised Proposed Language and State Implementation PlanElements

# DraftRevisedPM10 Maintenance Plan for the Pagosa Springs Attainment/MaintenanceArea

ColoradoDepartment 

# ofPublicHealth andEnvironment

Revised PM10 Maintenance Plan Submittal: U.S. Environmental Protection Agency: submitted on - TBD Colorado AirQuality 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: approvedon 06/15/01, effective on 08/14/01 Colorado AirQuality Control Commission, adoptedon 03/16/00 Pagosa Springs Town Council, approved on February2000

PM10 State Implementation Plan Submittal U.S. Environmental Protection Agency: approved 05/19/94, effective 06/20/94 Colorado AirQuality Control Commission, approved on 11/19/92; 11/12/93

Revisions Prepared By: AirPollution Control Division Colorado Department ofPublic Health and Environment 4300 Cherry Creek Drive South Denver, Colorado 80246[Blank Page]

RevisedPM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 2 of25 September 1, 2009

# TableofContents 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 INVOL VED IN PREPARING ANDAPPROVING PLAN 

## 8 C. REQUIREMENTS FOR REDESIGNA TIONAND MAINTENANCE 

## 8 

## .1. Attainment ofthe 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 DETERMINA TION 

### 11 

## SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL

.. 12

A.

### 1988 SIPELEMENT 

### 12 B. 

### 1992 and 

### 1993 SIP ELEMENTS 12 

### C. 1994 SIP ELEMENTREVISION 

### 12 D. PM10 MAINTENANCEPLAN 

### 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

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 3 of25 September1, 20092015 Interim Emission Inventory 18 3. 2021 Emission Inventory 19 

### C. MAINTENANCE DEMONSTRA TION 

### 20

.L CMS Source Apportionments of High Concentrations 21 CMS Roll-forward Analysis 21 

### D. PM10 EMISSION BUDGET 

### 23 E. MONITORING NETWORKIVERIFICATION OFCONTINUED 

### ATTAINMENT 23 F. CONTINGENCYPLAN 

### 23



### .L Tracking 24 Trigger and Response 24 Potential Contingency Measures 24 

### G. SUBSEQUENTMAINTENANCEPLAN REVISIONS 

### 25

RevisedPM10 Maintenance Plan forPagosa SpringsAttainmentiMaintenanceArea Page 4 of25 September 1, 2009

## SECTION 1: INTRODUCTION This document is the second revision ofthe 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 ofColorado 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 AmbientAir Quality Standards (NMQS) for particulate matterwith an aerodynamic diameter often microns or less (PM10) since 1990, although the area is presently demonstrating attainment with the PM10 NMQS. The Maintenance Plan section ofthis 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 ofthe NMOS. 2. Areas redesignated to attainment do not become "serious" nonattainment areas even if a violation ofthe NAAQS occurs. This means that specific control measures can be applied to address aviolation without going through a rigorous federal process, where serious areas must implement mandatory control measures and be subjectto 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 importantfor 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 ofthe NMQS for PM10 in the Pagosa Springs area. This document is intended to comply with requirements ofthe federal Clean Air Act (CM), and with relevant procedures and policies ofthe United States Environmental Protection Agency (EPA).

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea 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 ofsafety to protectthe 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 ofthe 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 ofsolid 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 ofelemental 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 ofthe potential for extremely long-range transport offine particles itis thought that no place on earth is free of particulate pollution generated by urban and rural sources. Chemical
RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 60f25 September 1, 2009and 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 ofwhich have been detected in the most remote areas ofthe world. 3. Pagosa Springs NonattainmentArea Classification History Because ofobserved problems with air particles, monitoring oftotal 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) ofthe 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 ofthe Town's limits. A map illustrating the area boundary is shown in Figure 1.

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 7 of25 September 1, 2009

### Figure 1: Map ofthe Pagosa Springs Attainment/Maintenance Area

045 09 

# I**pagosa~ln9s** PM:Cttainmenr-a

I

Designation_Boundanes Legend 

# + AIRPORTS

• POint Sources

- Local Roads



### B. ORGANIZA TlONS INVOLVED IN PREPARING ANDAPPROVING PLAN Preparation ofthis revised maintenance plan was a cooperative effort ofthe Town of Pagosa Springs, Archuleta County, and the Air Pollution Control Division (APCD) ofthe Colorado Department of Public Health and Environment. The documentwas 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 ofthis revised maintenance plan.


### C. REQUIREMENTS FOR REDESIGNA TlONAND MAINTENANCE Section 107(d)(3)(D) and (E) ofthe CAA defines the five required cornponents ofa redesignation request and maintenance plan. These components and their descriptions follow:

RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 8 0(251. Attainment ofthe Standard The State must showthat the area is attaining the PM 10 NAAQS. This demonstration must be based on monitoring data representative ofthe location ofthe 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 11O(k) ofthe 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 ofthe 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 ofthe CAA. This plan must provide for the maintenance ofthe 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 forPagosa SpringsAttainment/MaintenanceArea 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 ofthese monitoring locations exceeded the 24-hourTSP NAAQS of260 ug/m3 and the annual NAAQS of75 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 greaterthan 95 percent probability ofexceeding the new PM10 standards. Monitoring for PM 10 began in August 1985 at the Pagosa Springs High School and an additional PM10 monitorwas 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 ofthe 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 ofthe 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-yrAverage 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

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea 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 daywhich it was measured, are utilized to develop emission inventories and serve as a baseline for modeling ambient concentrations into the future. The selection ofthis 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 1 st

, 2008 value of 149 ug/m3 may be the result ofa blowing dust event, which could be considered as an "exceptional event". TheAPCD is investigating the circumstances surrounding this event, but this value is still being used in the design value calculation.

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/Maintenance Area Page 11 of25

## SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL The following presents a briefsummary ofthe development and the approval ofthe 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 ELEMENTREVISION The Pagosa Springs SIP Elementwas 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 MAINTENANCEPLAN 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.

RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 12 of25

## SECTION 4: PERMANENT AND ENFORCEABLE IMPROVEMENT IN AIR QUALITY The State mustdemonstrate, based on Section 107(d)(3)(E) ofthe CAA, that the improvement in air quality leading to attainment ofthe NAAQS and the redesignation request is based on permanent and enforceable measures, and that the reductions are not the result oftemporary reductions in emissions or unusually favorable meteorology.

### A~ 

### OVERVIEW It is reasonable to attribute the attainment ofthe 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 ofthe 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 ofthe 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 ofthe implementation of emission reduction measures, not meteorological fluctuations.


### B. CONTROL MEASURES The following control measures resulted in the area's attainment ofthe PM10 NAAQS, and these measures should ensure continued maintenance ofthe PM10 NAAQS through the year 2021, which is the duration ofthe maintenance period.

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/Maintenance Area Page 13 of251. 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. ofthe "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 userthat 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 ofstreet 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, ofthe "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 ofthe original PM1 0 Maintenance Plan, effective on 08/14/01, reinstates the prevention ofsignificant 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"

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 14 of25(BACT), along with the removal ofthe 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 MotorVehicle Emission Control Program The federal motorvehicle 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 newervehicles; 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 ofthis voluntary sweeping/cleaning has been about once after each street sanding deployment. Forthe future, the Town of Pagosa Springs has committed to regularly vacuum sweep/clean Highway 160 within four days ofthe 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 pavementto the boundary ofthe airshed.
• Any owner or operator responsible forthe construction or maintenance ofany 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 orderto minimize fugitive dust emissions. These State-wide requirements are defined in detail in Section III.D.2.a.(I) ofthe 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.

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 15 of25

## SECTION 5: MAINTENANCE PLAN
A. REQUIREMENTS Section 107(d)(3)(E) ofthe 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 ofthe 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 ofa SIP revision eight years after the original redesignation request/maintenance plan is approved that provides for maintenance ofthe 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 175Afurther 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 ofany unforeseen violation ofthe PM1 0 NAAQS. Failure to maintain the NAAQS and triggering ofthe contingency plan will not necessitate a revision ofthe 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 ofthe 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 ofthe 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.

RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 16 of251. 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 ofTransportation (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 Inventoryfor 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

RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 17 of252. 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 of2.90 percent peryear (1.02897 or23.18% 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 forArchuleta County 

## PopulationForecasts

forArchuleta 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 of4.013 percent to 2015 (1.040125 or 32.100 total). This growth rate was based on COOTs highest projected traffic growth rates for different segments ofthe State highways in the Pagosa Springs area. The 2007 mobile source tailpipe PM emissions were reduced by an annual compounded rate of0.81 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.

RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 18 of25Table 3: 2015 PM10 Emission Inventoryforthe Pagosa Springs Attainment/Maintenance Area Source Category 2015 PM10 [tons/year] 2015 PM10 [Ibs/day] Change from 2007 BaseYear 

### 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 peryear 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 peryear (1.03592 or 50.28% total), which is based on the population forecast (from State Demography Office) for Archuleta County overthe 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 of4.013 percent to 2021 (1.04125 or56.175% total). This growth rate was based on COOTs highest projected traffic growth rates for different segments ofthe 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 bythe 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 higherthan the 2015 interim year emission projections of 1,294

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/Maintenance Area Page 19 of25pounds/day. Consequently, the demonstration of maintenance ofthe PM1 0 NAAQS for 2021 is adequate to demonstrate maintenance for all years before 2021. Table 4: 2021 PM10 Emission Inventoryforthe Pagosa Springs Attainment/Maintenance Area SourceCategory 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 DEMONSTRA TION Data presented throughout this document are utilized to demonstrate continued maintenance ofthe PM 10 NAAQS for the Pagosa Springs area. Chemical Mass Balance (CMB) data are used to generally identify the sources ofemissions 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. Ifthe 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 ofthe 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 ofthese 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 ofthe 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 oftypical conditions that occur in the winter months). Finally, not all years with values exceeding 100 ug/m3 have

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 20 of25

### 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 SourceApportionment 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

# =NH4 N03 

### 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 Subtractthe 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

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/Maintenance Area Page 210'25Percent Change in Emissions between 2007 and 2021 

### rY.,alues used

### to roll-forward the CMS apportionments

### to the year2021) 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 : 

### (Calculatedbyapplying the Percent Change in emissions from 2007to 

### 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 ofsecondary 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 ofsecondary 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

RevisedPM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 22 of25

### Total Projected 2021 Concentration (PM102021): 

### (sum 

### of2021 apportionedcomponents plus the backgroundconcentration) 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 ofthe 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 of946 Ibs/day for 2021 and beyond. This budget is the total ofthe 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 ofColorado" regulation.


### E. MONITORING NETWORKIVERIFICATION OFCONTINUED 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 of40 CFR Part 58 and the EPA-approved Colorado Monitoring SIP Element. The APCD will also analyze the monitoring data to verify continued attainment ofthe 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. CONTINGENCYPLAN Section 175(A)(d) ofthe CM requires that the maintenance plan contain contingency provisions to assure that the State will promptly correct any violation ofthe PM10 NMOS that may occur afterthe redesignation ofthe area to attainment. EPA's redesignation guidance notes that the State is not required to have fully adopted contingency measures that will take effectwithout 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 ofthe contingency plan involve the tracking and triggering mechanisms to determine when contingency

RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/Maintenance Area Page 23 of25measures 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 ofthe contingency plan does not automatically require a revision ofthe 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 ofone or more adopted contingency measures. In the eventthat violations continue to occur, additional contingency measures will be adopted until the violations are corrected. Upon notification ofa 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 ofthe PM10 standard. Information about historical exceedances ofthe 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, ofany exceedance will generally occurwithin 30 days, but no later than 45 days.) This process will be completed within six months ofthe exceedance notification. Ifa violation ofthe PM10 NAAQS has occurred, a public hearing process at the State and local level will begin. Ifthe AQCC agrees that the implementation oflocal measures will prevent further exceedances orviolations, the AQCC may endorse or approve ofthe 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 orviolations. Contingency measures will be adopted and fully implemented within one year ofa PM10 NAAQS violation. Any State-enforceable measures will become part ofthe 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 ofthe 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 ofthe Pagosa Springs area. It is likely that no federal or State monies will be available to fund the implementation ofthe selected contingency measure(s). Most, if not all, ofthe costs will be borne by local citizens and governments, local businesses, and State government agencies.
• Increased street sweeping requirements

RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea 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/orwood burning
• Expanded use ofalternative 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 otherfactors that the State deems appropriate. 

### G. SUBSEQUENTMAINTENANCE PLAN REVISIONS This revised maintenance plan provides for continued maintenance ofthe PM10 NMQS for an additional ten years beyond the original ten-year period. Consequently, no further maintenance plan updates are anticipated.

RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 25 of25

# Technical Support Document

40 CFRPart 51 Appendix V 2.2

# PM10 Maintenance Plan Pagosa Springs

Technical SupportDocument Emission Inventory

FINAL 

# August 4, 2009 Colorado Departmentof

### Public Health andEnvironment AirPollution Control Division 4300 Cherry CreekDrive South Denver, Colorado 80246Colorado Department

### ofPublic Health andEnvironment/ AirPOllution 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 forPagosa Springs- TechnicalSupportDocument

- Emission Inventory October3D, 2009 iiColorado Department ofPublic Health andEnvironment/ AirPollution 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 offuture 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). UnderAir Quality Control Commission Regulation No.3, the APCD requires any source that emits two tons per year or greaterto 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 SupportDocument

- Emission Inventory October30, 2009 IColorado Department ofPublic Health andEnvironment/ AirPollution 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 

### 1,009.7 TOTAL: 184.28

PM10 Maintenance Plan for Pagosa Springs- Technical SupportDocument

- Emission Inventory October30, 2009 2Colorado Department ofPublic Health andEnvironment/ AirPollution 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 lorPagosa Springs- TechnicalSupportDocument

- Emission Inventory October30/2009 3Colorado Department ofPublic Health andEnvironment/ AirPollution Control Division



## 6. References APCD, 2008. Air Quality Control Commission Regulation Number 3. Stationary Source Permitting and Air PollutantEmission Notice Requirements. 5CCR 1001-5. < 

### http://www.cdphe.state.co.us/regulations/airregs/l00 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 forPagosa Springs- TechnicalSupportDocument- Emission Inventory October30, 2009 4

# Public Comments
40 CFRPart 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 ofPagosa Springs Town Manager

November 16,2009 BarbaraRoberts Commission Chair Colorado Air Quality Control Commission 4300 Cherry Creek Drive South Denver, CO 80246

.RE: Town ofPagosa Springs

- PMIO Attainment and Maintenance Plan Endorsement DearMs. Roberts: The Town ofPagosa Springs is in full support ofthe revised PMIO Attainment and Maintenance Plan for ourcommunity. Our citizens value the cleanerenvironmentthathas been made possible bythe implementationofthe PMIO Attainment and .Maintenance Plan. The assistance in keeping ourair free ofpollutionprovided by the ColoradoDepartmentofPublic Health and Environment's Air Pollution Control Divisionis greatly appreciated. It has been our pleasureto work with Mr. CurtTaipale as the PMlO Plan was updated. He has been both patient and helpful. We applaudthe Colorado Air Quality Control Commission's efforts to update the Plan's emissions inventories and demonstration ofattainment with the 24-hourNational AmbientAir Quality Standard (NAAQS)for PMIO through 2021. Again, afterreviewing the PMl0 Plan, the Town ofPagosa Springs concurs with andendorses its findings. The To\\<n is committed to assuring good air quality for our citizensand appreciatesthe efforts ofthe 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 ControlDivision) DouglasA. Lempke (Administrator, Colorado Air Quality Control Commission) 

## RECEIVED NOV 16 2009

AIR QUAUTY ;:;ON\nC(JMISSIOl\i

# Adopted Statement ofBasis, Specific StatutoryAuthority and PurposeVIII.X Pagosa Springs PM10 Adopted November 19, 2009
The amendments to the "AmbientAir 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 ofthe 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.

# AdoptedLanguage bythe Commission (in redline & 

## footer noting adoption date andpage numbers)

### DEPARTMENT OF PUBLIC HEALTH AND ENVIRONMENT 

### Air Quality Control Commission
AMBIENT AIR QUALITY STANDARDS 

### 5 CCR 1001-14
V. Emission Budgetsfor Attainment/Maintenance Areas in the State ofColorado
V.A. Budgets
V.A.1. The following MotorVehicle 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 ofdemonstrating transportation conformity shall be allowed using the emission trading formula as follows: Fortrades necessary to increase a primary PM10 budget, 15.0 tons/day of NOx will be taken from the NOx budgetto increase the primary PM10 budget by 1.0 tons/day, a ration of 15 to 1. Fortrades 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 1to 12. Implementation oftrading provisions: In the eventthe MPO cannot demonstrate consistency with the specific PM10 and NOx mobile source emission bUdgets, the trading provisions may be utilized only afterthe MPO has considered all reasonably available local control measures to meetthe bUdgets. The MPO mustdemonstrate 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 ofConformity. Iftrading is utilized, the MPO shall include the foliowinQ information in the transportation

AmbientAir Quality Standards Adopted: November 19, 2009 Page 1conformity determination: (1) The budget for primary PM 10 and NOx for each required year ofthe conformity determination, before trading is employed; (2) The portion ofthe 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 ofthe conformity demonstration. The MPO shall then compare projected emissions to the adjusted PM10 and NOx motor vehicle emission budgets to demonstrate conformity.
Ozone Precursors (attainment/maintenance DenverAttainment 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 NonattainmentArea

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

AmbientAir QualityStandards Adopted: November 19, 2009 Page 2Telluride (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 ofeach ofthe area MotorVehicle Emissions Budgets shall be the nonattainment orattainment maintenance area as defined in the respective state implementation plans.
V.A.3. The MotorVehicle 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 ofstate law when such budget takes effectas a matter offederal law pursuant to 40 CFR Section 93.118. Until such time as the 1,520 tons per day budget takes effect pursuantto 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 ofstate 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 forthe Colorado Springs CO attainment/maintenance area shall be 270 tons per day (2001 and beyond).

AmbientAir Quality Standards Adopted: November 19, 2009 Page 3V.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 matteroffederal law pursuant to 40 CFR Section 93.118. Until such time as the 16,244 pounds-per-day budget takes effect pursuantto 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 ofstate lawwhen budget takes effect as a matter offederal 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 matteroffederal 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 offederal 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 

### vA 1. shall take effect as a matter ofstate law when such buqget takes effect as a matteroffederal law pursuantto 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

AmbientAir QualityStandards Adopted: November 19, 2009 Page 4The 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.

AmbientAir Quality Standards Adopted: November 19, 2009 Page 5

# State ImplementationPlanElement Adoptedbythe Commission
40 CFRPart 51 AppendixV 2.1(d)

# Final RevisedPM10 Maintenance Plan for the Pagosa Springs Attainment/MaintenanceArea

ColoradoDepartment 

# ofPublicHealth andEnvironment

Revised PM10 Maintenance Plan Submittal: US. EnvIronmental Protection Agency: submitted on - TBD Colorado AlfQuality Control CommIssIon, adoptedon - 11/19/09

PM10 Maintenance Plan Submittal: US. EnvIronmental Protection Agency: approved on 06/15/01, effective on 08/14/01 Colorado AirQuality Control CommissIon, adoptedon 03/16/00 Pagosa Sprmgs Town Council, approved on February2000

PM10 State Implementation Plan Submittal US. Envlfonmental Protection Agency' approved 05/19/94, effective 06/20/94 Colorado AirQuality Control CommIssion, approved on 11/19/92; 11/12/93

Revisions Prepared By: AirPollution Control DIVIsIon Colorado DepartmentofPublic Health and Environment 4300 Cherry CreekDnve South Denver, Colorado 80246

### [Blank Page]

FinalRevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 2 of25 November 19, 2009

# TableofContents 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. ORGANIZA TIONS INVOL VED IN PREPARING AND APPROVING PLAN 

## 8 C. REQUIREMENTS FOR REDESIGNA TIONAND MAINTENANCE 

## 9

.L Attainment ofthe 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 DETERMINA TION 

## 11 

## SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL

.. 12

A. 

## 1988 SIP ELEMENT 

## 12 B. 

## 1992 and 

## 1993 SIP ELEMENTS 

## 12 C. 1994 SIP ELEMENTREVISION 

## 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 forPagosa Springs Attainment/Maintenance Area Page 3 of25 November 19, 20092. 

### 2015 Interim Emission Inventory 18 3. 

### 2021 EmIssion Inventory 19 

### C. 

### MAINTENANCE DEMONSTRA TION 20 CMS Source Apportionments of High Concentrations 21 

### 2. CMS Roll-forward Analysis 21 

### D. PM10 EMISSION BUDGET 

### 23 E. MONITORING NETWORKIVERIFICATION 

## OF CONTINUED A TTAINMENT 

### 23 

### F. CONTINGENCYPLAN 

### 23 Tracking 24 

### 2. Trigger and Response 24 Potential Contingency Measures 24 

### G. 

### SUBSEQUENTMAINTENANCE PLAN REVISIONS 25

FinalRevised PM10 Maintenance Plan for Pagosa Springs Attainment/Maintenance Area Page 4 of25 November 19, 2009

## SECTION 1: INTRODUCTION This document is the second revision ofthe 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 matterwith an aerodynamic diameter often microns or less (PM1 0) since 1990, although the area is presently demonstrating attainment with the PM10 NAAQS. The Mamtenance Plan section ofthis 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 ofthe NAAQS. 2. Areas redesignated to attainment do not become "serious" nonattamment areas even if a violation ofthe 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, mthe Pagosa Springs area. This analysis is designed to document and ensure continuing attainment and maintenance ofthe NAAQS for PM 10 in the Pagosa Springs area. This document is mtended to comply with requirements ofthe federal Clean Air Act (CAA), and with relevant procedures and policies ofthe United States Environmental Protection Agency (EPA).

Final RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 5 of25 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 ofthe 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 - PM10 Monitoring Record". 2. Health and Welfare Effects of PM1 0 Particulate matter is the term given to tiny particles ofsolid 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 ofthe 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 RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 6 of25 November 19, 20094 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 ofwhich have been detected in the most remote areas ofthe world. 3. Pagosa Springs NonattainmentArea Classification History Because ofobserved problems with air particles, monitoring oftotal 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 PM1O. Pagosa Springs was then designated a "moderate" nonattainment area in 1990 pursuant to section 107(d)(4)(B) ofthe 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 ofthe Town's limits. A map illustrating the area boundary is shown in Figure 1.

Final RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 7 of25 November 19, 2009Figure 1: Map ofthe Pagosa Springs Attainment/Maintenance Area

04; 0,9 o

L.-'--'_..1-'**-,--'----'---'----'f--=J~.** \ Pagosa Springs PM-10AttainmentArea 

### l.,·,·------T

. \,---­ 

# l\ , '?­ \ \,/ 

### \**~-** 

## .r---::--') . \ }. 

# ,-,·11 l-J

......... -, 

# .} -'1 /L

__ \Legend



### oft AIRPORTS -1 • Point Sources \ ),._.- LiXai Roads

" ! \ i

- Malor Roads Ii

..... ; • - HIGHIJI.AYS**\~OeS'9nalJon_Bou"danes** 

# l\· U CITIES /\



### -**'-.~** 

### 0 COUNTIES / t"""



### B. ORGANIZA TlONS INVOL VED IN PREPARING ANDAPPROVING PLAN Preparation ofthis revised maintenance plan was a cooperative effort ofthe Town of Pagosa Springs, Archuleta County, and the Air Pollution Control Division (APCD) ofthe 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 ofthis revised maintenance plan.

FinalRevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 8 of25 November 19, 2009

### C. REQUIREMENTS FOR REDESIGNA TIONAND MAINTENANCE Section 107(d)(3)(D) and (E) ofthe CAA defines the five required components of a redesignation request and maintenance plan. These components and their descnptions follow: 1 Attainment ofthe Standard The State must show that the area is attaining the PM10 NAAQS. This demonstration must be based on monitoring data representative ofthe location ofthe 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 11O(k) ofthe 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 ofthe 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 ofthe CAA. This plan must provide for the maintenance ofthe 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 ofthe PM1 0 NAAQS.

Final Revised PM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea 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 ofthese monitoring locations exceeded the 24-hour TSP NMOS of 260 ug/m3 and the annual NMOS of75 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 ofexceeding the new PM1 0 standards. Monitoring for PM1 0 began in August 1985 at the Pagosa Springs High School and an additional PM10 monitorwas 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 ofthe 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 ofthe 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-yrAverage 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 RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 10 of25 November 19, 2009

### 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 ofthis design value utilized EPA's table look-up method from EPA's "PM10 SIP Development Guideline" document. Based on the number ofsamples 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 1 51

, 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.

FinalRevised PM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 11 of25 November 19, 2009

## SECTION 3: STATE IMPLEMENTATION PLAN APPROVAL The following presents a brief summary ofthe development and the approval ofthe 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 ELEMENTREVISION 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 MAINTENANCEPLAN 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

FinalRevisedPM10 Maintenance Plan forPagosa 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) ofthe CAA, that the improvement In air quality leading to attainment ofthe NAAQS and the redesignation request IS based on permanent and enforceable measures, and that the reductions are not the result oftemporary reductions in emissions or unusually favorable meteorology


### A. OVERVIEW It is reasonable to attribute the attainment ofthe 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 percentwhile Archuleta County population increased by 26 percent over the same period. During this period of rapid growth, attainment ofthe 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 ofthe 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 ofthe implementation of emission reduction measures, not meteorological fluctuations.


### B. CONTROL MEASURES The following control measures resulted in the area's attainment ofthe PM1 0 NAAQS, and these measures should ensure continued maintenance ofthe PM1 0 NAAQS through the year 2021, which is the duration ofthe maintenance period.

Final RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 13 of25 November 19, 20091. 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. ofthe "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 ofstreet 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, ofthe "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 ofthe original PM1 0 Maintenance Plan, effective on 08/14/01, reinstates the prevention ofsignificant 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 RevisedPM10 Maintenance Plan forPagosa SpringsAttainment/Maintenance Area Page 140'25 November 19, 20094 (BACT), along with the removal ofthe 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 ofthis voluntary sweeping/cleaning has been about once after each street sanding deployment. Forthe future, the Town of Pagosa Springs has committed to regularly vacuum sweep/clean Highway 160 within four days ofthe 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 ofthe 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 orderto minimize fugitive dust emissions. These State-wide requirements are defined in detail in Section III.D.2.a.(I) ofthe 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 RevisedPM10 Maintenance Plan for Pagosa SpringsAttainment/Maintenance Area Page 15 of25 November 19, 2009

## SECTION 5: MAINTENANCE PLAN
A. REQUIREMENTS Section 107(d)(3)(E) ofthe 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 ofthe 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 ofa SIP revision eight years afterthe original redesignation request/maintenance plan is approved that provides for maintenance ofthe 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 175Afurther 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 ofthe PM10 NMOS. Failure to maintain the NMOS and triggering ofthe contingency plan will not necessitate a revision ofthe 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 ofthe 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 dayfor the whole maintenance area. Consequently there are significant differences between the emission inventories in the prevIous Plan and this updated PM10 Maintenance Plan.

Final RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 16 of25 November 19, 20091. 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
• Ag ricu Iture 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 ofTransportation (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 Inventoryfor 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 RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 17 of25 November 19, 20092. 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 peryear (1.02897 or 23.18% total), which is based on the population forecast (from State Demography Office) for Archuleta County overthe 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 forArchuleta County 

## PopulationForecasts

forArchuleta 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 of4.013 percent to 2015 (1.040125 or 32.100 total). This growth rate was based on COOTs highest projected traffic growth rates for different segments ofthe 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 RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 180'25 November 19, 2009Table 3: 2015 PM10 Emission Inventoryfor 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 of4.013 percent to 2021 (1.04125 or 56.175% total). This growth rate was based on COOTs highest projected traffic growth rates for different segments ofthe State highways in the Pagosa Springs area. The 2007 mobile source tailpipe PM emissions were reduced by an annual compounded rate of0.81 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 RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 19 of25 November 19,2009pounds/day. Consequently, the demonstration of maintenance ofthe PM1 0 NAAQS for 2021 is adequate to demonstrate maintenance for all years before 2021. 

### Table 4: 2021 PM10 Emission Inventoryforthe

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 ofthe PM10 NAAQS for the Pagosa Springs area. Chemical Mass Balance (CMB) data are used to generally identify the sources ofemissions 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. Ifthe 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 ofthe 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 ofthese 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 ofthe 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 oftypical conditions that occur in the winter months). Finally, not all years with values exceeding 100 ug/m3 have

FinalRevisedPM10 Maintenance Plan forPagosa SpringsAttainment/MaintenanceArea Page 20 of25 November 19, 20091 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 NH 3 Sulfate

# =(NH4 )2S04 particulate formed in the atmosphere 'from S02 and NH3 2. CMB Roll-forward Analysis Subtractthe 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 RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 21 of25 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 year2021) 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 : 

### (CalCUlatedbyapplying 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 ofsecondary 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 ofsecondary 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 RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 22 of25 November 19, 2009

### 10.4 ug/m3 x 1.000

# =10.4 

### ug/m3
Total Projected 2021 Concentration (PM102021): 

### (sum of

### 2021 apportionedcomponents plus the backgroundconcentration) 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 ofthe 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 ofthe 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 of40 CFR Part 58 and the EPA-approved Colorado Monitonng SIP Element. The APCD will also analyze the monitonng data to verify continued attainment ofthe 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. CONTINGENCYPLAN Section 175(A)(d) ofthe CM requires that the maintenance plan contain contingency provisions to assure that the State will promptly correct any violation ofthe PM10 NMQS that may occur after the redesignation ofthe 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

FinalRevised PM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 23 0{25 November 19, 2009expediently once the need IS triggered. The primary elements ofthe 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 ofthe contingency plan does not automatically require a revision ofthe 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 ofone 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 ofa 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 ofthe PM1 0 standard. Information about historical exceedances ofthe standard, the meteorological conditions related to the recent exceedance(s), and the most recent estimates ofgrowth and emissions will be reviewed. The possibility that an exceptional event occurred will also be evaluated. (Notification to EPA, and to the local governments mthe Pagosa Springs area, ofany exceedance will generally occurwithin 30 days, but no later than 45 days.) This process will be completed within six months ofthe exceedance notification. Ifa violation ofthe PM1 0 NAAQS has occurred, a public hearing process at the State and local level will begin. Ifthe AQCC agrees that the implementation of local measures will prevent further exceedances or violations, the AQCC may endorse or approve ofthe 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 orviolations. Contingency measures will be adopted and fully Implemented within one year of a PM10 NAAQS violation. Any State-enforceable measures will become part ofthe 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 ofthe 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 ofthe Pagosa Sprmgs area. It is likely that no federal or State monies will be available to fund the Implementation ofthe selected contingency measure(s). Most, if not all, ofthe costs

Final RevisedPM10 Maintenance Plan forPagosa Springs Attainment/MaintenanceArea Page 24 of25 November 19, 2009will 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 ofalternative 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. SUBSEQUENTMAINTENANCE PLAN REVISIONS This revised maintenance plan provides for continued maintenance ofthe PM10 NAAQS for an additional ten years beyond the original ten-year period. Consequently, no further maintenance plan updates are anticipated.

Final RevisedPM10 Maintenance Plan forPagosa Springs Attainment/Maintenance Area Page 25 of25 November 19, 2009

# Colorado Air Quality Control Commission Meeting Minutes

- Action ofthe Commission to SIP ElementRevision 

# 40 CFRPart 51 Appendix V 2.1(g)

# STATEOFCOLORADO

Bill Rlller, Jr., Governor Ned Calonge, M.D., Inteflm Executive Dlfector COLORADOAIRQUALITY 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 ofPublic Health TOO (303) 691-7700 andEnvironment 

# Colorado Air QualityControlCommission November19,2009 MEETINGMINUTES

Location: Colorado Department ofPublic Health & 

### Environment 4300 Cherry Creek Drive South, Sabin Room Denver, CO 80246 

### MembersPresent: Robert Arnott Radford Byerly Ashley Campsie Teresa Coons John Loewy Dawn Meyers BarbaraRoberts Jon Slutsky Jim Wilson 

### MembersAbsent: None 

### Commission Staff: DougLempke TheresaMartin


### DivisionStaff: Paul Tourangeau Mike Silverstein Curt Taipale Gordon Pierce Chris Dann Curt Taipale Lisa Silva Dan Ely 

### Attorney General's Office: Jerry Goad

CALLTO ORDERAND DETERMINATION OFA QUORUM 

### Chair Roberts called the meeting to order at 1:00 PM and determined that a quorum of Commissioners was nowpresentwith nine Commissioners.
ApPROVAL OF MEETING MINUTES FOROCTOBER 

### 15,2009 ChairRoberts asked the Commissionifthere were any modifications to the minutes. Roberts noted that onPage 8, 4th 

### line down a comment that she made should be stricken.
Motion: To approve the October 15, 2009 Meeting Minutes as modifiedby Commissioner Roberts Moved: Commissioner Slutsky Second: CommissionerByerly Discussion: none Carried: 9-0PUBLICCOMMENT 

### Chair Roberts asked ifthere were any members ofthe public who wished to make a comment on any air pollution issue not on the agenda. Dr. Doug Lawson ofNREL 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 meetingto review the effects ofNOx emissions on air quality along the Front Range. Eddie Lind ofFort Morgan commented that he represented concerned citizens ofthe area regarding the Sugar Beet factory. Lind stated concerns regarding jurisdiction ofthe 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 thatcitizens were interested in volunteering to read monitors; would like soil/water/river samples ran; would like conversations held with the health staffregarding the decreased health ofthe 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 ofthe plantthat he knows personally have commentedthat 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 wishesthe Commission to look into this matter and his findings ofthis product.

AGENDA REVIEW 

### ChairRoberts asked Lempke to reviewthe meeting agendanoting any items that may have changed, been added ordeleted. Lempke commentedthat there weren't any changes to the agenda. REQUESTFORPUBLIC HEARING DECEMBER 17, 2009 

### DenverRegional Council ofGovernments (DRCOG) Conformity At 1:38 PM Lisa Silvaofthe Division noted that the presentationwould include information from the DRCOGregarding its anticipated Transportation Conformity findings regarding the 2035 Regional Transportation Plan second cycle amendments andthe 200812013 

### TIP. Silva commented that the NFRMPO was also in concurrence. Silvanoted that neither theNFRMPO nor the Upper Front Range Transportation PlanningRegion had amendedtheirplans but because they werepartofthe 8-Hour Ozone Nonattainment area, transportation conformity must be assured for those areas as well as the Denverregionuntil the emission budgets for the individual are approved. Emily Chen ofthe DRCOGreviewed the Cycle 2Amendmentsto the 2035 Regional Transportation Plan and the 2008/2013 TIP. 2

### Chennoted that the amendments included a newtoll 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 theNorth Metro corridor. Chenreviewed with the Commissionthe conformitytests conducted and whatthe results indicated. The DRCOG, the NFRMPO andthe Divisionrequested thatthe Commission hold a public hearing in Decemberfor its anticipated Transportation Conformity findings regarding the 2035 Regional Transportation Plan and the 2008/2013 

### TIP. Byerly asked ifthis was a wayto complete the beltway and Steve Cookofthe DRCOGnoted it was not, it isjusta proposal at this time. Byerly commentedthat isn'tit true that improving orwidening roadways brings moretraffic and more emissions. Cooknotedthat 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 onto the other Commissioners. Wilson asked that all the maps be provided.
Motion: To approve the motion for hearing onDecember 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 ofthe Divisionpresented to the Commissionrevisions to the PMlO maintenanceplan for Pagosa Springs. Taipale notedthat this was the second oftwo lO-year plans that were required bythe Clean Air Act. Taipale explainedthat the documentation reflectedthat Pagosa Springs would continue to attainthe PMI0National AmbientAir Quality Standardthrough 2021 and had never violatedthe PMlO NAAQS in the pastten years though one exceedance hadbeenrecorded in 2000. Taipale commentedthat no additional control measures were required in orderto maintainthe standard. Taipale explained that this revision would satisfy the federal requirement for showing attainment for the second ten-yearperiod after redesignationto attainment/maintenance and that no additional revisions ofthe PMl0 Maintenance Plan was expected. Taipale did note that iffuture changes in mobile source models orotherunforeseen considerations arose thatthe Division would address them at thattime.
Motion: To adopt Pagosa Springs PMI0Maintenance Plan revisions as proposedby the Division Moved: CommissionerLoewy Second: Commissioner Campsie Discussion: none Carried: 9-0

3

### TelluridePMIO Maintenance Plan Revision 

### At 2:06 PM Chris Dann ofthe Divisionpresented to the Commissionrevisions to the PM10 maintenanceplan for Telluride. Dannnoted thatthis was the second oftwo lO-yearplansthat are requiredby the Clean Air Act. Dannexplainedthat the documentation reflected that Telluride would continue to attain the PM10 National AmbientAir Quality Standardthrough 2021 andhad never violatedthe PM10NAAQS. Danncommented that no additional control measures were required in order to maintain the standard. Dann explained thatthis revision would satisfythe federal requirement for showing attainmentfor the second ten-yearperiod after redesignationto attainment/maintenance andthat no additional revisions ofthe PM10 Maintenance Planwas expected. Danndid note thatiffuture changes in mobile source models or other unforeseen considerations arose that the Divisionwould address them at that time. Arnott questionedthe 54% increase in emissions and Dannresponded that it was a standard modeling growth factor thathad been used.
Motion: To adopt Telluride PM10 Maintenance Planrevisions as proposed by the Division Moved: Commissioner Amott Second: CommissionerMeyers Discussion: none Carried: 9-0
BRIEFINGS, DISCUSSIONS AND REpORTS 

### Regulation Number9: SmokeManagement Program 

### At 2:14 PMDan Ely ofthe Divisionprovided an overviewofthe SmokeManagementProgram (SMP) noting that it addresses smoke/pollution from prescribed fires onpublic and private lands andthat the program had been implementedin 1990to protectpublichealth and visibility. Ely discussedthe current activities which included the permits required, inspections, emissions inventory, stakeholder meetings, and the many relationships involvedinthe program. Ely commentedthatthe projectedcosts for the SMP were proposed per regulationrequirements and to coverthe operating costs ofthe program. Ely notedthatthe Divisionwould evaluate the SMP rules and implementation so as to support and increase where possiblethe appropriate responsible use ofprescribed fire and to report the recommendations to the Commissionby June 30,2010. Ely indicatedthatthe Divisioncould notprojectthe costs for 2010 withreasonable certainty until recently because ofthe unknown fiscal impacts onthe SMP from HB09-1l99 and that the Divisionconcludedthat a fee increase was notnecessary. Ely reviewedthe cost projection spreadsheet withthe Commission. Ely concluded notingthat overall there weren't any systemic issues withrevenue recovery. Loewy asked what was included inthe permits and Ely replied that the permit looked at locations such as vicinity in relation to homes, cubic feet of piles, fuel loading, anddispersion. Loewy asked howthe Division assures compliance and Ely respondedthat a lot ofit is atrust factor and the Divisionalso conducts site visits. Roberts asked aboutthe newprogram related to the standard and Ely responded that the Divisiondidn'thave all the answers, but would have a specific individual from the HB09-1l99 funding inthe Divisionto do additional studies ofsmoke and its impacts. Roberts asked about the role ofthe Division in implementing HB09-l199 andEly indicated thatthe Divisiondidn'tknowyet, butwould return to the Commission withan approach.

4

### Coordinating the DevelopmentofPlans for Regional Haze/OzonelRMNP At 2:50PM Mike Silverstein ofthe Divisionprovided an overviewoftheplansincluding planning goals, backgrounds and activities, and timelines. Silverstein discussedthe requirements for each ofthese programs andhowindividual programproposals wouldbedeveloped in a coordinated fashion to avoid unnecessaryregulatory overlap or duplication andprovide for the efficient consideration, adoptionand implementation ofeachproposal. Silverstein discussed the steps necessary to complete the requirements for eachprogram and the relative timing to develop the proposals. Silversteinconcluded noting that a lot ofworkhadbeenaccomplished overthe past several months andthat the Divisionwouldbe evaluating and formulating anapproach for advancing emissioncontrols thatbenefit ozone, Regional Haze and Rocky MountainNational Park. Silversteinalso commentedthat upon development ofthe proposals the Divisionwould be conducting stakeholder meetings and thencoming to the Commission for discussion. Roberts asked what nearterm meantregarding the interim plan and Silversteinresponded thatthe Division should be ready to bring a proposal to the Commissionin the June/July time frame. Meyers commentedthat there hadbeentalks early that ozone had gone up inthe Denver area and asked howthese strategies were affecting the Denvermonitor. Silversteinnoted that where industrial reductions inNOx occurunfortunately there may be ozone increases atnearby monitors.
Coons commentedthat it appearedthatthe focus was onozone and Silversteinagreedthat it was howeverthe Divisionwouldbe taking into considerationRegional Haze and RMNP. Roberts expressedconcerns as the Division moves forward with all three programs togetherregarding technology, costs, air quality improvement; anddoesn'twant the Commissionto be surprisedby learning aboutthese things at a hearing. Roberts suggested that the Commission should be kept inthe loop as problematic issues emerge. Wilson askedwhere other states were in their Regional Haze SIP process and Silversteincommentedthatmost ofthe states were in the public comment orjustbeginningthe BARTprocess ofthe SIP. Silversteinalso noted that EPA Region 8 was looking at Colorado as being one ofthe last ofthe western statesto comply now because ofthe BARTreworkthathad occurred; Colorado was originally one ofthe first to complete the SIP. Coons asked about the stakeholderprocess and ifthe Divisionwas working withthe same group ofpeople and Silversteinresponded thatthe Divisionwas working with the same group ofpeople as well as bringingin anyone thatmayhave newinterest. Wilson asked about the step change ofnitrogen deposition inyears 1993 and 1994 and what the dramatic contributions were. Silversteincommentedthatthe Divisionwouldbe able to provide this informationregarding the increase for 1993/1994 for the nitrogen deposition in RMNP at the February meeting. Byerly askedthatthe Commissionbe made aware ofthe synergiesbetween the programs and that ifadditional modelingwas done, anevaluation ofhowaccurate the model is be conducted.


### Commissioner

### Informational Items Commissioner Wilson discussed the BoulderClean Air Challenge thathe was involved in over the summernoting thatresults reflectedreduced vehicle miles by 10,000 miles which**amo~ted** to a savings of5600 gallons ofgasoline and a reduction of54 tons ofcarbon dioxide. Wils'on noted that it was a great program. CommissionerLoewy commentedona newbooktitled "How the West Was Warmed"responding to climate change in the Rockies by Beth Conoverwho was the creator ofthe Denver GreenprintProgramfor the Mayor. Loewy noted that it was a collectionof42 essays from writers aroundthe region onissues related to climate change and was a very informative piece ofwork. 5

### Division Director's Report Tourangeaureviewed a number ofissues:
• EnforcementEvaluation Reportpublishedby EPA Inspector General: the need for improvementregarding oversight andpolicies for highpriority violations ofthe Clean AirAct. Tourangeaunoted thatthis means Colorado would needto work with EPAon the use ofthe Notice ofViolations (NOV) and timelines associated with closures ofthe NOV's.
• PM2.5 NAAQS designations: provided a handout that summarizedthe PM2.5 designations for NAAQS and notedthat Colorado was in attainment and EPAwas in agreement withthe attainment andthetechnical analysis.
• NAAQS review schedule by EPA: provided a handoutofthe schedule and summaryof the S02NAAQS proposal which was newand expectedto go final this coming summer. Tourangeau noted thatthe N02 standardwas proposedbetween 80 and 100 ppb in which Colorado currently hadtwo monitors that could reflect nonattainment ifthe standard gets set at 80 ppb. Tourangeau commentedthatthe S02 standard wasproposed between 50 and 100 ppb in which Colorado would be in attainment. Tourangeaualso notedthat secondary standards couldbecome significantdrivers for the Commission.
• NewMexico imposed more stringent standards thanthe federal sector specifically for the oil and gas programs in the SanJuanarea south ofDurango andthe ozone datarecently reflectedthat it had droppeddramatically overa 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 ofthe State Auditors 3-year audit and a Divisionreport that had been submittedto the Transportation Legislative Review Committee. Roberts asked for the web link for the report. • EPA Order onOil and Gas for the FrederickNatural Gas Compressor Station: Order servedbased uponpetition from WildEarth Guardians to 32 states. EPA's Ordernotes that the Divisionmust complete an aggregation analysis and supplementthe recordbased onthe analysis and either amend, modify orkeep the permitintact.
• NSRTailoring Rule from EPA: this is a proposedrule thatraises the applicability thresholds to 25,000 tons peryear C02efor Title V andPSD and comments are due to EPAby December28. TheDivisionbelieves that approximately 143 stationary sources would be inexceedencebased uponfuel-burning alone and EPA estimates there would be about 40 newsources; this doesn't include methane. 

### Attorney General's Report Goad discussed withthe Commission:
• Kasel case filed in Denver District Courtbut no date hadbeenset • ConsentDecree filed in the US District Court inNorthern Californiaby WildEarth Guardians complainingthat Lisa Jackson ofEPA allegedly failed to perform a nondiscretionary duty to eitherapprove a SIP ora FIP for several states including Colorado withregard to the 1997 NAAQS for 8-hourozone and PM2.5.

6

### Administrator's Report Lempke reviewedthe agenda items for the Decembermeeting. Lempke also reviewed withthe Commissionthe Action Items Follow-Up list notingthat Gordon Pierce hadprovided input requestedby CommissionerByerlyregardingNOxmonitoring sites around the state.
ACTION ITEMS 

### Lempke reviewedthe current actions from today's meeting:
• DRCOGconformity/vanpool information • Discuss role ofAPCD withregardto the overall Smoke Management Program • Provide 1M Audit Report web linkto Commission • SendRAQC Executive Orderto Commission • Response to DougLawsonregarding forming a committeeto investigateNOx as a contributorto ozonepollution • Explainthe step increase for 93/94 nitrogen deposition atRMNP Adjourn at 5:10



### 7

# Legal Opinion ofthe Colorado State Attorney General
40 CFRPart 51 Appendix V 2.1(c) and (e)

### AUUpmlOn Page lof

JOHNW. SUTHERS STATE SERVICES Attorney General 

### STATE OF COLORADO BUILDING DEPARTMENTOF LAW CYNTHIAH. COFFMAN 1525 Shennan Street

- 7th Floor ChiefDeputy Attorney General OFFICE OFTHE ATTORNEY Denver, Colorado 80203 DANIELD. DOMENICO GENERAL Phone (303) 866-4500 SolicitorGeneral Fax (303) 866-5691

TrackingNumber: 2009-00772
OPINION OFTHE ATTORNEY GENERAL RENDERED IN

CONNECTION WITH THE RULES ADOPTED BY THE Air QualityControl Commission ON 11/19/2009

5 CCR 1001-14 AMBIENTAIR 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

JOHNW. 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 orRegulationRevisions as Published in the Colorado Code ofRegulations
40 CFRPart 51 Appendix V 2.1(b)

# DEPARTMENT OFPUBLIC HEALTHAND ENVIRONMENT

AIRQUALITYCONTROL COMMISSION



## AMBIENTAIRQUALITY STANDARDS

5 CCR 1001-14

EDITOR'SNOTES* AuthorityCited: Sections25-7-105(1), 25-7-106(1), (2.5) and (4) C.R.S. Section25-7-302 regarding SIP contents and 25-7-109(2)()regarding authority to regulate carbon monoxide (CO) HistoryandAmendments: Amended 9/11/77,1 CR 1. Added 5/25/78, I CR6. Amended 12/14/78,2CR 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 approvalby the General Assembly, 3 CR 5. Adopted 3/10/83, effective4/30/83, 6 CR4. Adopted 10/17/83, effective 11/30/83,6 CR 11. Repealed 7/20/89, effective 8/30/89,12 CR8. Adopted 12/21/89, effective 1/1/93, 13 CR 2. Adopted as emergency regulation 2/21/91, effective 2/21/91,14 CR4. Adopted as emergency regulation 5/16/91, effective 5/16/91,14 CR 6.**~dopted** 6/20/91, effective 7/30/91,14 CR7. Adopted 6/16/92, effective 7/30/92; Visibility Standard adopted 8/20/91, effective 1/1/93,15CR7. Visibility Standardeffective date postponed on an emergency basis 12/17/92,postponement effective 12/17/92;.Visibility Standard effective 1/1/95, 16 CR 1. Adopted3/18/93, effective 1/1/95,16CR4. Adopted 6/24/93, effective 8/30/93, 16 CR8. Adopted 9/22/94, effective 11/30/94,17 CR 11. Adopted 2/16/95, effective 4/30/95,18 CR4. Adopted 6/15/95, effective 8/30/85,18 CR 8. Adopted 3/21/96, EFFECTIVE 5/30/96,19 CR5.

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 expiredJune I, 1992.

·ThlsTitle Page does not constitute an offiCIal part ofany 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 Usethe 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: VisibilityAdopted: Effective:

.VisibilityPostponed: Effective: VisibilityEffective: 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'SNOTES (continued) History and Amendments: Adopted 9/19/96,EFFECTIVE 11130/96, 19 CR

## n.Adopted 10/17/96,EFFECTIVE 12/30/98,19CR 12. Adopted 12/18/98. EFFECTIVE 3/2/98, 21 CR2. Adopted 1115/98, EFFECTIVE 3/30/98,21 CR3.Adopted 9/17/98, EFFECTIVE 11130/98,21 CR

## n.Adopted 1/10/00, EFFECTIVE 3/1/00, 23 CR2. Adopted 2/17/00, EFFECTIVE 4/30/00, 23 CR4. Adopted 3/16/00, EFFECTIVE 5/30/00, 23 CR5. Adopted 1/11/01, EFFECTIVE 3/2/01, 24 CR2. Adopted4/19/01,EFFECTIVE 6/30/01, 24 CR6. Adopted 11115/01, EFFECTIVE 12/30/01,24 CR 12. Adopted 7/18/02,EFFECTIVE9/30/02, 25 CR9. Adopted 12/19/02, EFFECTIVE 03/02/03, 26 CR2. Sections V through vnAdopted06/19/03, EFFECTIVE08/31/03, 26 CR 8. Parts V through vnAdopted 12/18/03, EFFECTIVE 03/01104, 27 CR2. Parts m.F,m.M, vm.s adopted 03/12/04, EFFECTIVE 05/31104,27 CR5.Parts m.E,m.M, Vm.Tadopted 12/16/04, EFFECTIVE 03/02/05,28 CR2.

### pp. 20-21, 59-60 adopted 12/15/05,EFFECTIVE 03/02/06, 29 CR2. Rule replaced in its entirety, adopted 11/20/08.EFFECTIVE 12/30/08,31 CR 12.Rulereplaced inits 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 AG48; 21 AG 86; 21 AG 353; 23 AG 44; 23 AG99; 23 AG 116; 24 AG 60-60A; 24 AG 168; 24 AG 364; 25 AG314; 26 AG 73; 26 AG332; 27 AG 81; 27 AG 174; 28 AG46; 29 AG 80; 31 AGDec 1001-14; 32AGJan 1001-14; 32AGDec 1001-14 -1001-14a

Annotations:

© 2009StateofColorado Page 3 5 CCR 1001-14 All Rights Reserved. (800) 833-9844«;) 2009 State ofColorado 32 CR 12, 12-09 Page21 All RightsReserved
V. Emission BUdgets forAttainment/MaintenanceAreas Inthe State of Colorado
V.A. Budgets
V.A.1. Thefollowing MotorVehicle Emission BUdgets shall be utilized to assess the conformity of Transportation Plans, TIPs, and where appropriate, ProJects, forthe applicable periods and geographic areas indicated:

DenverAttainment/Maintenance Area (Modeling Domain) PM10: 2015through 2021· 54 tons/day; 2022 and beyond: 55 tons/day. Nitrogen Oxides: 2015through 2021: 70tons/day; 2022 and beyond: 56tons/day Trading provisions: Trading of PM10for NOx, orNOxfor PM10 to adjust emission budgets for purposes ofdemonstrating transportation conformity shall be allowed uSing the emiSSion trading formula asfollows:
Fortrades necessaryto increase a primary PM10 bUdget, 15.0 tons/day ofNOxwill be taken from the NOx bUdget to Increase the pnmary PM10 bUdget by 1.0tons/day, a ration of 15to 1.
Fortrades necessaryto increase a NOx budget, 1.0tons/day of pnmary PM10will betaken from the primary PM10 bUdget to increase the NOx bUdget by 12.0tons/day, a ratio of 1to 12. Implementation oftrading provisions: Inthe eventthe MPO cannot demonstrate consistency with the specific PM10 and NOx mobile source emission budgets, thetrading provisions may be utilized only afterthe MPO has considered all reasonably available local control measuresto meetthe budgets. The MPO must demonstratethe need for trading through the usual consultation proceduresfor state implementation plan developmentdelineated in Section IV (F) ofAQCC Regulation Number 10, Criteria forAnalysis ofConformity.
Iftrading is utilized, the MPO shall IncludethefollOWing information in thetransportation conformity determination: (1) The budgetfor primary PM10 and NOxfor each required yearofthe conformity determination, before trading is employed; (2) The portion ofthe onginal budgetto be usedto supplement a wanting budget, for each required yearforthe conformity determination; (3) The increased budgetthat results from trading, along with relevant calculations, and (4) the resultIng primary PM10 and NOx budgets for each required yearof the conformity demonstration.
The MPO shall then compare projected emiSSions tothe adjusted PM10 and NOx motorvehicle emission budgets to demonstrate conformity.

CODE OF COLORADO REGULATIONS 5 CCR 1001-14Page 22 32 CR 12, 12-09

DenverAttainment Maintenance Ozone Precursors (attainment/maintenance area boundary) Area NOx 2002 and beyond 134tpsd VOC 2002 and beyond 119 tpsd (tpsd =tons per summer day) Carbon MonOXide (attainment/maintenancearea boundary) 2013through 2020: 1625 tons/day: 2021 and beyond: 1600tons/day.
Denver MetroArea/North Front Regional Emissions Budgets

Range 8-Hour Ozone NonattainmentArea NOx: 122.9tons/day VOCs: 109.2tons/day Southel1fSiib-ReaioriarEmfssions ffiJagefs

- NOx: 102.4tons/day VOCs: 89.7tons/daY
Northern Sub-Regional Emissions Budgets NOx: 20.5 tons/day VOCs: 19.5tons/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 LongmontAttain- Carbon Monoxide2010 through 2014: 43tons/day 2015-2019: mentlMaintenanceArea 43tons/day 2020 and Beyond: 43tons/day
Colorado SpringsAttain- Carbon Monoxide 2010 and Beyond: 531 tons/day mentlMaintenanceArea
Ft. CollinsAttain- Carbon Monoxide2005 through 2009: 99tonS/day2010 through mentlMaintenanceArea 2014: 98 tons/day2015 and Beyond: 94 tons/day

GreeleyAreaAttain- Carbon Monoxide2005 through 2009: 63 tonS/day2010 through mentlMaintenanceArea 2014: 62tonS/day2015 and Beyond: 60tons/day

5 CCR 1001-14 CODEOF COLORADO REGULATIONS02009State 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 ofeach ofthe area MotorVehicle Emissions BUdgets shall bethe nonattainmentorattainment maintenance area as defined In the respective state Implementation plans.
t The MotorVehicle Emissions Budget for PM10 applies tototal primary PM10 emiSSions, inclUding emissionsfrom tailpipe exhaust, unpaved roads (exceptforthe Denver PM10 nonattainment area), re-entralned road dust and street sand. It does not include precursor orsecondary emissions, WhiCh, where appropriate, arecovered 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 effectas a matterofstate lawwhen such bUdget takes effect as a matter offederal law pursuantto 40 CFR Section 93.118. Until such time asthe 1,520 tons perday budgettakes effect pursuanttothis section and 40 CFR Section 93.118, the carbon monoxide emiSSion budgets forthe Denver CO attainment/maintenance area shall be 800tons perday (2002 and beyond). V.A.4.b.Colorado Springs Carbon Monoxide
The 531 tons per day carbon monoxideemiSSion budget established In Section V.A.1. shall take effect asa matterofstate lawwhen such budgettakes effect asa matter offederal law pursuant to40 CFR Section 93.118. Until such time asthe 531 tons perday budgettakes effect pursuanttothiS section and 40 CFR Section 93.118, the carbon monoxideemission budget forthe Colorado Spnngs COattainment/maintenance area shall be 270tons perday (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 matterofstate lawwhen such budgettakes effect asa matterof federal law pursuantto40 CFR Section 93.118. Until such time asthe 16,244 pounds-per-day budgettakes effect pursuanttothis section and 40 CFR Section 93.118, the PM 10emiSSion budget for the Aspen PM 10 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 VA 1. shall take effectas a matterofstate lawwhen budget takes effect as a matteroffederal law pursuantto 40 CFR Section 93.118. Until such time asthe 946 pounds-per-day budgettakes effect pursuanttothis section and 40 CFR Section 93.118, the PM10 emission budget forthe Pagosa Springs PM10 attainment/maintenance area shall be 7,486 pounds-per-day.

CODE OFCOLORADO REGULATIONS 5 CCR 1001-14Page24 32 CR 12, 12-09
V.A.4.g.Carion City PM10
The 1,613 pounds-per-day PM 10 emission budget established in Section V.A.1. shall take effect as a matter ofstate lawwhen such budgettakes effectas a matteroffederallaw pursuantto40 CFR Section 93.118. Until suchtime asthe 1,613 poundsper-day**~udget** takes effect pursuantto this section and 40 CFR Section 93.118, the PM10 emission budgetforthe 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 asa matter ofstate lawwhen such bUdget takes effect as a matteroffederallaw pursuantto 40 CFR Section 93.118. Until such time as the 7,534 poundsper-day bUdget takes effect pursuantto this section and 40CFR Section 93.118, the PM10 emission bUdget forthe Lamar PM10 NonattainmentArea shall be 1,884 pounds-per-day.
V.A.4.i. Steamboat Springs PM10
The21,773 pounds-per-day PM10 emission bUdget established in Section V.A.1. shall take effect as a matter ofstate lawwhen such budget takes effect as a matterof federal law pursuantto 40CFR Section 93.118. Until such time asthe 21,

## n3 pounds-per-day budget takes effect pursuant to this section and 40CFR Section 93.118, the PM10 emission bUdget forthe Steamboat Springs PM10 Nonattainment Area shall be20,682 pounds-per-day. V.A.4.j. Telluride PM10
The 1,108 pounds-per-day PM10emission budget established in Section V.a.1. shall take effect as a matterofstate lawwhen such budgettakes effectas a matteroffederal law pursuantto 40CFR Section 93.118. Until such time asthe 1,108 poundsper-day bUdget takes effect pursuanttothis section and 40CFR Section 93.118, the PM10 emission bUdget tortheTelluride PM10AttainmentArea shall be 10,001 pounds-per-day (2012 and beyond).
V.B. Reserved 

## v.c. Additional Requirements forthe Denver PM10 Attainment/MaintenanceArea
V.C.1. Geographic Coverage
The geographiccoverageforthe Denver PM10 MotorVehicle Emissions Budget isthe modeling domain contained in the most recent revision tothe Denver PM10state implementation plan and technical support documentation, which areavailable tor inspection atthe offices of theAQCC located at 4300 Cherry Creek Drive South, Denver, Colorado. V.C.2. Regional EmissionsAnalySIS
The emiSSions bUdgets setout in this section shall be used for regional emiSSions analyses requIred torconformity determinations.

5 CCR 1001-14 CODEOF COLORADOREGULATIONSo 2009 StateofColorado­ 32 CR 12, 12-09 Page 24.1 AU Rights Reserved
V.D. Addltlonal.Requirements forthe Denver CO Attainment/MaintenanceArea
V.D.1. GeographicCoveFageThecgeographtc;coverage for the DenverCO MotorVehicle Emissions Budget IS the Denver CO attalnment/malt1tenance area as defined In the section ofthisAmbientAir Standards regulationentitled."Description of Boundanes for DenverCOAttalnment/Maintenance Area."
VI. Carbon,Monoxlder-Standard within the EisenhowerTunnel"
Pursuantto theauthority:of;Section'25-7-106 (1), (b) and (c) and of25-7-107 (1), (a), and (b) ofColorado**Revised::StatuteSt19~3f** theColorado Air Pollution Control Commission designated and confines ofany traveled'portion&otothetroadwayswithin the EisenhowerTunnel as a control area In which the adoption andmamtenanseofartamblentair standard is deemed necessarywith particular Identification of"carborl'monoxldeta91ttrE!'pollutant hereby made subjecttothefollowing standard to maintain an acceptabl81humalaicamoxyhemoglobin level: THE AMBIENTAIR WITHIN THE EISENHOWER TUNNEL SHAlLBEMAINJ'TAINEOSOTHATTHE LEVELS OF CARBON MONOXIDE SHALL NOT EXCEED A 15'MINtJTe'AVERAGoOF 100 PARTS PER MILLION VOLUME (115 MILLIGRAMS PER CUBICMEiI"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 1001-14Page 24.2**3~** CR 12, 12-09

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5 CCR 1001-14 CODE OF COLORADOREGULATIONS© 2009 State ofColorado 32 CR 12, 12-09 Page 51 All Rights Reserved require, assignment ofsome orthe entire safety margin to the transportation conformity bUdget. The reservation ofa portion ofthe carbon monoxide safety margin allows for additional growth In other sectors, but does not makethe Sip more stnngentthan 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 ofthe margin ofsafety to mobile sources, but maintains a reasonable margin foraccommodation ofuncertainty and future growth In other sectors. The allocation of most ofthe safety margin to mobile sources provides flexibility for thetransportation community In adopting thiS rule, the Commission chosethe most cost-effective option. VlII.V Canon City PM10 Adopted: November20, 2008
The amendments to the "Ambient Air Quality Standards forthe State ofColorado" 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 ofthefederal act. StatutoryAuthority
The authority to establish emiSSions budgets and to establish critena fortransportation 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 pursuantto 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 MetroArea/North Front Range 8-Hour Ozone Emissions Budgets Adopted December 11, 2008
The amendments to the "AmbientAir Quality Standards forthe State ofColorado" Regulation adopted by the Commission establish mobile source emiSSions budgets forthe Denver Metro Area/North Front Range 8-Hour Ozone area. Federal Requirements Nothing In thiS rule changeexceedsthe minimum requirements ofthe federal act.

CODE OFCOLORADO REGULATIONS 5 CCR 1001-14Page 52 32 CR 12, 12-09
Statutory Authority
The authorityto establish emIssions budgets andto establish critena fortransportation 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 pursuantto Section 25-7-110.8
The mobile source emissions budgets are based on EPA's MOBILE6emiSSIons model and EPAapproved methodsfor calculating fugitive dust emIssIons as reqUired byfederal 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 chosethe most cost-effective alternative.
VIII.X Pagosa Springs PM10 Adopted November 19, 2009
The amendmentsto the "AmbIentAir Quality Standardsforthe State ofColorado· Regulation adopted by the Commission establish mobilesource emISSIons budgets forthe Pagosa Springs PM10 attainment area. Federal Requirements Nothing In thiS rule change exceedsthe mInimum requIrements ofthefederal act. Statutory Authority
The authorityto establish emiSSIons budgets and to establish critena fortransportation 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 pursuantto Section 25-7-110.8
The mobile source emISSions budgets are based on EPA's MOBILE6emISSIons model and EPAapproved methodsfor calculatingfugitive 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 chosethe most cost-effective alternative. Further, these reVIsions will Include anytypographical, grammatical and formatting errors throughout the regulation.
V111.Y Telluride PM10 Adopted November 19, 2009
The amendmentstothe "AmbientAir Quality Standards forthe State ofColorado· Regulation adopted bythe CommIsSion establish mobile source'emlSSlons budgets fortheTellunde PM10 attaInment area. Federal Requirements Nothing In this rule change exceedsthe minimum requIrements ofthefederal act.

5 CCR 1001-14 CODE OF COLORADOREGULATIONS

### o 2009 State ofColorado 32 CR 12, 12-09 Page 53 All Rights Reserved Statutory Authority
The authority to establish emIssions budgets and to establish critena fortransportation 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 pursuantto Section 25-7-110.8
The mobile source emissions bUdgets are based on EPA'sMOBILE6 emissions model and EPAapproved methodsforcalculating fugitive dust emissions as required byfederal 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 chosethe most cost-effective alternative. Further, these revisions will include anytypographical, grammatical and formatting errorsthroughout the regulation.

CODE OFCOLORADO REGULATIONS 5 CCR 1001-14