1

Vaupel, Claudia

From: Heil, Cynthia L (DEC) <cindy.heil@alaska.gov>

Sent: Friday, January 06, 2017 12:18 PM

To: Suzuki, Debra

Cc: Vaupel, Claudia; Spenillo, Justin

Subject: Response to Clarification request for the FNSB Moderate SIP

Attachments: Final - clarification request 1.06.2017.docx

Debra, please find the response to your list of clarification questions.  Please let me know if there is anything else we can

provide.  I should have another submittal to you here within the next hour or so (QM report).  
Response to Clarification Request January 6, 2017

Page 1

Update of the control measures: Summarize the updates that have been made to the control measures by 

the supplementary submittals. Provide a table that includes all of the control measures and the expected 

emissions reductions from each measure. For each of the identified control measures that were deemed 

technologically infeasible based on the Borough’s referendum prohibiting home heating regulation, please 

identify the measures that have since been adopted and submitted for EPA review. For measures that 

were not adopted and submitted for review, ADEC must provide an explanation as to why the adoption of 

such control(s) is unreasonable. Explain the status of the contingency measures in relation to RACM. 

DEC is providing an updated version of Table 5.7-6 in response to your request for identification of measures 

that have been adopted into the SIP following the initial submittal of the moderate SIP. DEC revised the

technological feasibility of control measures that had been initially identified as infeasible due to a Borough 

referendum, and provided an explanation of infeasibility of measures that were not adopted, and an explanation 

of the impact of contingency measure implementation on RACM.

In the September 7, 2016 adoption, the SIP amendments incorporated eight (8) ordinances approved by the 

Fairbanks North Star Borough (FNSB) between February 2015 and August 2016. The SIP amendments were 

filed on October 27, 2016 and will be effective on November 26, 2016. Vol. III, Appendix III.D.5.7 of the 

Moderate SIP contains the Reasonable Available Control Measure Analysis. The modified Table 5.7-6 provides

context on how the programs and provisions within the new ordinances and regulations have changed the 

original analysis. Only those areas within Table 5.7-6 that have been impacted by the SIP amendments are 

shown below.

Modified Table 5.7-6 showing changes due to approved ordinances and regulations

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

Dry Wood 

Measure

Ban on green 

wood sales No

Addressed 

through 

alternative 

control 

measures

This measure is technologically infeasible but the State has 

implemented alternative control measures. 

The timing and volume of wood sales in the nonattainment area and 

the land available for wood sellers to store and season wood makes a 

total ban on green wood sales technologically infeasible. The 

inability to handle and store large volumes of wood for seasoning is 

compounded by restrictions in accessing state and federal land for 

timber cutting. Areas are only open to cutting in the winter months 

when the ground is firm and chance of forest fire minimal. 

Alternative control measures have been implemented by the Borough 

and State to address the use of green wood in the nonattainment area. 

State regulations require the use of dry wood during wintertime and 

limit opacity during air alerts. Borough Ordinances, adopted in 

February 27, 2015, require that only dry wood may be burned year 

round. A State wood moisture disclosure and recognized dry wood 

seller program has been implemented on a voluntary basis. Wood 

sellers will be required to register with the State in order to sell wood 

upon the area’s reclassification to serious. Both the voluntary and 

mandatory programs assist consumers in understanding the moisture 

content of their wood to improve compliance with the requirements 

to only burn dry wood.

Regional Kiln No

Addressed 

through 

alternative 

Regional firewood drying kilns were considered as a control measure 

to increase the commercial availability of dry wood in the original 

RACM analysis. The measure was categorized as technologically 

infeasible due, in part, to a low consumer demand for dry wood. A 
Response to Clarification Request January 6, 2017

Page 2

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

control 

measures

ban on green wood sales, if feasible, would increase the demand for 

dry wood.

A regional kiln measure envisions a centralized facility where 

commercial sellers and private individuals could deliver split wood 

for drying. The labor and transportation costs associated with use of 

a regional facility would make the service unattractive or 

uneconomical. Additionally, the Borough completed an analysis of 

running a government-operated kiln and determined it would be 

uneconomical and interfere with private industry. 

DEC has not encountered an example of a regional kiln in a review

of implemented control measures throughout the country. 

Since the submittal of the Moderate SIP, a participant in the 

voluntary moisture disclosure program, classified as a recognized 

dry wood seller, has independently constructed a private kiln and 

provides dry wood to consumers. Therefore, a source of dry wood 

that is split stored and covered is available to the public. During the 

2015-2016 winter season, the recognized dry wood seller was unable 

to keep up with demand. The seller has expanded his storage 

capacity for the 2016-2017 winter season. 

Hydronic 

Heaters

Mandatory 

curtailment on 

air quality 

advisory days

No Yes 

This measure has been recategorized as technologically 

feasible due to Borough adoption in February 27, 2015 and 

was adopted into the SIP on September 7, 2016. 

See the Recent Measures Section below for discussion.

Ban new 

installations No

Addressed 

through 

alternative 

control 

measure

This measure is technologically infeasible but the state has 

implemented alternative control measures.

Banning new installations is technologically infeasible for the 

following reasons: 1) due to arctic conditions, alternative 

sources of heat must be an available option to the public to 

protect health, life, and property. Second it would prohibit

change outs from older devices to newer devices that meet 

stringent State and Borough emission standards. Prohibiting 

changeouts conflicts with the device changeout measure.

Change outs of older existing devices provide emission 

reductions that subsume any emission increases resulting from 

the installation of new devices in instances where a device had 

not been previously installed.

State and Borough regulations require new units to meet strict 

emission standards. Borough setback requirements also 

significantly reduce the number and type of lots where a 

hydronic heating device may be installed. By prohibiting the 

installation of new hydronic heaters in portions of the 

nonattainment area, this measure subsumes a portion of the 

emission benefits that could be obtained through banning new 
Response to Clarification Request January 6, 2017

Page 3

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

installations throughout the area with an outright ban on new 

installations.

Remove at time 

of home sale† No Yes

This measure has been recategorized as technologically 

feasible due to Borough adoption in February 27, 2015. 

State regulations include a modified version of this control as 

a contingency measure in the original SIP submission. It will 

be triggered upon the area’s reclassification by EPA to a

“serious” nonattainment area. Uncertified devices will be 

required to be removed or replaced before property sale or 

conveyance. ADEC has begun to implement this program by 

contacting and educating the regulated community, including 

real estate professionals and home inspectors. These 

individuals are likely already informing clients of the 

upcoming requirement, increasing likelihood of early 

compliance.

All units must 

be certified No

Addressed 

through 

alternative 

control 

measure

This measure has not been recategorized as technologically 

feasible, but it has been addressed through an alternative 

control measure.

This measure would accelerate the turnover of uncertified 

devices. The Borough change out program already accelerates 

turnover by facilitating change outs that may have otherwise 

not occurred. 

Borough code amendments, adopted May 4, 2016, also have a 

mechanism to accelerate turnover of uncertified devices by 

requiring the removal of hydronic heaters that do not meet 

emission criteria after repeat code violations. 

Resource priorities are focused on identifying and removing

the worst polluting hydronic heaters.

Ban use No

Addressed 

through 

alternative 

control 

measure

This measure has not been recategorized as technologically 

feasible, but has been addressed through an alternative control 

measure.

Borough regulations adopted February 27, 2015 curtail solid 

fuel fired device use during Stage 2 and 3 air quality alerts. 

This measure subsumes emission benefits that could be 

obtained through banning use at all times because it curtails

use during pollution episodes.

Wood Stoves

Mandatory 

curtailment on 

air quality 

advisory days

No Yes

This measure has been recategorized as technologically 

feasible due to Borough adoption February 27, 2015 and was 

adopted into the SIP on September 7, 2016. 

See the Recent Measures Section below for discussion.
Response to Clarification Request January 6, 2017

Page 4

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

Replace 

uncertified 

stoves at time of 

home sale

No Yes

This measure has been recategorized as technologically 

feasible due to its upcoming implementation as a contingency 

measure. 

State regulations include this control as a contingency measure 

in the original SIP submission. It will be triggered upon the 

area’s reclassification by EPA to “serious”. Uncertified 

devices will be required to be removed before property sale or 

conveyance. ADEC has begun to implement this program by 

contacting and educating the regulated community, including 

real estate professionals and home inspectors. These

individuals are likely already informing clients of the 

upcoming requirement, increasing likelihood of early 

compliance. Initial contacts began in May 2016 with 1400 

letters sent to real estate professionals in addition a dedicated 

webpage has been developed to provide information: 

http://dec.alaska.gov/air/anpms/comm/fbks_pm2-5_realestate.htm

Replace 

uncertified 

devices at time 

of significant 

remodeling

No

Addressed 

through 

alternative 

control 

measure

This measure has not been recategorized as technologically 

feasible but it has been addressed through an alternative 

control measure. The FNSB does not have building code 

requirements. Therefore there are no mechanism to monitor or 

track remodels. It is economically infeasible to set up an 

entire building code program with inspectors only for 

identifying uncertified heating devices. 

This measure would accelerate the turnover of uncertified 

devices. However, the Borough changeout program already 

accelerates turnover by facilitating change outs that may have 

otherwise not occurred.

Resource priorities are focused on identifying and removing 

the worst polluting stoves.

All units must 

be certified No

Addressed 

through 

alternative 

control 

measure

This measure has not been recategorized as technologically 

feasible but it has been addressed through an alternative 

control measure.

This measure would accelerate the turnover of uncertified 

devices. The Borough change out program already accelerates 

turnover by facilitating change outs that may have otherwise 

not occurred.

Resource priorities are focused on identifying and removing 

the worst polluting stoves.

Replace 

uncertified 

stoves in rental 

units

No Yes

This measure has been recategorized as technologically 

feasible due to its upcoming implementation as a contingency 

measure. 
Response to Clarification Request January 6, 2017

Page 5

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

State regulations include this control as a contingency measure 

in the original SIP submission. It will be triggered upon the 

area’s reclassification by EPA to “serious”. Uncertified 

devices will be required to be removed before property lease. 

ADEC has begun to implement this program by contacting and 

educating the regulated community, including real estate 

professionals and rental property owners. These individuals 

are likely already informing clients of the upcoming 

requirement, increasing likelihood of early compliance. Initial 

contacts began in May 2016 with 1400 letters sent to real 

estate professionals in addition a dedicated webpage has been 

developed to provide information: 

http://dec.alaska.gov/air/anpms/comm/fbks_pm2-5_realestate.htm

Require 

alternate heat 

source in rental 

units

No

This measure has not been recategorized as technologically 

feasible. 

The number of rental units containing solid fuel fired heating 

devices as a sole source of heat is low and the benefits of this 

measure are assumed to be small.

Resource priorities are focused on identifying and removing 

worst polluting stoves.

Require 

alternate heat 

source in new 

construction†

No Yes

This measure was adopted in Borough code July 28, 2016. The 

mechanism involves No Other Adequate Source of Heat 

(NOASH) waivers to curtailment actions. No properties 

constructed after December 31, 2016 will be eligible for a 

NOASH waiver, essentially requiring the residence to install 

an alternative heating source to comply with curtailment 

actions.

Ban new 

installations No

This measure is technologically infeasible because in extreme 

cold temperature it can be critical to have a supplemental 

heating source, especially one that does not rely on electricity,

or risk damage from freezing up as well as back-up heat if 

power fails. Resource priorities are being focused on 

identifying and removing the worst polluting stoves.

Disincentive to 

sell used stoves No Yes

This measure has been recategorized as technologically 

feasible and updated State regulations were adopted into the 

SIP on September 7, 2016. 

ADEC has clarified in its regulations that the emission 

standards for new installations also apply to reinstallation of 

devices in the nonattainment area, prohibiting the installation 

of used stoves. 

The Borough change out program offers financial incentive to 

replace devices through the program or to turn in devices 

through a bounty program. It is a requirement that all used 

devices must be turned in for destruction.
Response to Clarification Request January 6, 2017

Page 6

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

Ban use No

Addressed 

through 

alternative 

control 

measure

This measure has not been recategorized as technologically 

infeasible but has been addressed through an alternative 

control measure. 

Borough regulations adopted February 27, 2015 curtail solid 

fuel fired device use during Stage 2 and 3 air quality alerts. 

This measure subsumes emission benefits that could be 

obtained through banning use at all times because it curtails 

use during pollution episodes.

Use stove 

change outs to 

generate NSR 

offsets

No

This measure has not been recategorized as technologically 

feasible and has not been addressed through an alternative 

control measure.

This measure envisions companies providing incentive 

programs for stove change outs in exchange for emission 

offsets needed for new major industrial sources. Major 

industrial growth in the nonattainment area has been expected 

to be minimal and no projects have been identified that would 

take advantage of this type of measure for new source review 

(NSR) offset since the submission of the original moderate 

SIP.

Fireplaces & 

Fireplace 

Inserts

Mandatory 

curtailment on 

air quality 

advisory days

No Yes

This measure has been recategorized as technologically 

feasible due to Borough adoption February 27, 2015 and was 

adopted into the SIP on September 7, 2016. 

See the Recent Measures Section below for discussion.

Recent Measures Adopted into SIP (directly or by reference) on September 7, 2016

Recent

Measures 

Adopted

Borough Programs

Mandatory 

Curtailment 

during Episodes

Yes

The Borough episode program, adopted February 27, 2015, 

adopted into SIP section III.D.5.11 on September 7, 2016, sets 

episode levels and requires mandatory curtailment of certain 

device types based on the severity of the episode. 

Requirement to 

only burn dry 

wood year 

round.

Yes

This Borough measure, adopted February 27, 2015, requires 

that only dry wood be burned in a wood-fired device. The 

effect is to give the Borough program an enforcement 

mechanism when responding to complaints where an 

individual may be burning wet wood.

Air Quality 

Control Zone

Yes

Air quality zones allow the State and Borough the opportunity, 

where appropriate, to focus resources and implement subareaspecific control measures to address localized air pollution 

concerns. 

Restricted Fuels 

List Yes

This Borough measure, adopted February 27, 2015, restricts 

the types of fuels that may be burned in a solid fuel fired 

device. The effect is to give the Borough program an 

enforcement mechanism when responding to complaints 

where an individual may be burning materials that do not burn 

cleanly.
Response to Clarification Request January 6, 2017

Page 7

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

Opacity† Yes

Borough regulations adopted February 27, 2015 require solidfuel heaters to comply with a 20% opacity limit regardless of 

whether an air quality alert is in effect.

Emissions 

crossing 

property lines†

Yes

This control measure adopted February 27, 2015 limits the 

amount of direct PM2.5 emissions which are allowed to cross a 

property line. Concentrations of 25μg/m3 over normal 

neighborhood background are considered illegal inside of the 

nonattainment area.

Hydronic Heater 

Setback 

requirements†

Yes

This Borough measure adopted February 27, 2015 requires 

newly installed hydronic heaters to be located set minimum 

distances away from property lines and sensitive locations. 

The effect of this measure is to limit the installation of 

hydronic heaters to large lots which are unlikely to exist in 

more densely populated areas. This also reduces the total 

number of properties where a hydronic heater may be 

installed.

SFBA 

requirements 

limiting coal 

installation†

Yes

This Borough measure, adopted February 27, 2015, limits the 

types of solid fuel burning appliances (SFBA) that may be 

installed to those that meet emission standards as tested by a 

laboratory or other approved procedure. The effect of this 

measure is to ensure only clean burning devices are installed 

in the nonattainment area. Devices must be EPA certified or 

have been tested to meet the standards by an alternative 

means. Due to the lack of an EPA standard and test method 

for coal devices, this measure has the effect of prohibiting the 

installation of coal devices without undergoing independent 

emission testing. 

Uncertified 

Hydronic Heater 

Nuisance unit 

removal upon 

2

nd conviction of 

violation of 

opacity or 

property line 

crossing†

Yes This Borough measure, adopted May 4, 2016, requires

removal of proven gross polluting units. 

Nuisance 

provision† Yes This measure, adopted February 27, 2015, provides additional enforcement capability for Borough staff. 

Borough 

Chapter 

Penalties†

Yes

Borough code adopted February 27, 2015 includes defined 

penalties for violations of requirements. These penalties are 

intended to increase compliance rates.

State Programs

Curtailment 

during Episodes Yes

A state curtailment program that will only be implemented if 

the Borough is unable to implement its own program was 

adopted into the SIP September 7, 2015.

Moisture 

Disclosure 

Program and 

Yes

A State wood moisture disclosure and recognized dry wood seller 

program has been implemented on a voluntary basis. Wood sellers 

will be required to register with the State in order to sell wood upon 
Response to Clarification Request January 6, 2017

Page 8

Source 

Category Control Measure

Technologically 

Feasible?

Revised 

Technical 

Feasibility Clarification

Wood Seller 

Registration

the area’s reclassification to serious. Both the voluntary and 

mandatory programs assist consumers in understanding the moisture 

content of their wood to improve compliance with the requirements 

to only burn dry wood.

Prohibited Fuels 

and 

Requirement to 

burn dry wood 

October 1 –

March 31

Yes

This State measure was adopted into state regulation prior to 

the initial submittal of the moderate SIP and was inadvertently 

excluded from the RACM analysis. 

† Signifies measures adopted or found technologically feasible since the SIP was submitted for which emission benefits 

have not been explicitly quantified.

As footnoted at the bottom of this modified Table 5.7-6, emission benefits were not separately quantified for 

several measures included table that were adopted and implemented or found to be technologically feasible 

since the SIP was submitted. In general, although benefits from these measures are likely to increase over time,

they are expected to be small as of the required 2015 attainment deadline.

Control Strategy Summary Table - Per the second element of your request, DEC is providing the following “SIP 

Control Strategy Reductions” table which summarizes measure-specific emission reductions in tons per day 

(tpd) and estimated concentration reductions (in μg/m3) for the comprehensive control strategy, which includes 

both original control measures from the SIP as well as measures implemented since the SIP submission. Control 

benefits benefits (during episodic conditions) are shown where feasible, significant, and quantified. (Measures 

not found to be feasible, were too small to quantify, or are addressed through alternative control measures are 

not listed in the table.)

The “Pre-2015” and “Pre and Post-2015” Control Measure Reduction columns delineate benefits through 

December 2014 (the submittal date) from reductions for measures implemented after the submittal but before 

December 31, 2015 (the required attainment date). The “2015-2017 RFP Reductions” column provides 

estimated two-year emission benefits (2015-2016) for all measures through the end of calendar year 2016 to 

demonstrate the additional reductions projected to occur before the first Reasonable Further Progress (RFP) 

milestone year (2017). All of the benefit estimates (except those under the “Voluntary Measures” category) are 

based on data collected by Alaska or the Borough through 2016 to date and represent permanent and enforceable 

reductions.

To further distinguish 2015 measure benefits listed in the SIP versus those from measures adopted since its 

submittal, the “Control Measure” column includes parenthetical identifications of “SIP” and “Clarification” to 

denote the origin of the benefit estimates, either the SIP or this clarification response. 
Response to Clarification Request January 6, 2017

Page 9

SIP Control Strategy Reductions

Control Measure

Pre-2015

Control Measure

Reductions

Pre and Post-2015

Control Measure

Reductions

2015-2017 

RFP

Reductions

(tpd)

Implementation

tpd μg/m Date(s) 3tpd μg/m3

Voluntary Measures (SIP):

 - Mobile Sources†

 - Other Sources††

PM2.5: 0.004

PM2.5: 0.055

0.04

0.50

PM2.5: 0.004

PM2.5: 0.055

0.04

0.50

.................. 2001-2015

Hydronic Heater Retrofits (SIP) PM2.5: 0.005 0.04 PM2.5: 0.005 0.04 .................. 2012

Woodstove Change Out Program (SIP)

PM2.5: 0.392

SO2: -0.014

NOx: 0.033

NH3: 0.014

3.06

PM2.5: 0.392

SO2: -0.014

NOx: 0.033

NH3: 0.014

3.06

PM2.5: 0.145

SO2: 0.000

NOx: -0.055

NH3: 0.002

06/2010

State Wood Device Standards (SIP) n/a n/a n/a n/a

PM2.5: 0.021

SO2:<0.001

NOx: 0.004

NH3: 0.001

2015

Dry Wood Measures (Clarification) 

 - State Moisture Disclosure

 - State/Borough Dry Wood Programs

n/a n/a

PM2.5: 0.112

SO2: 0.004

NOx: 0.019

NH3: 0.004

1.10

PM2.5: 0.129

SO2: 0.005

NOx: 0.022

NH3: 0.005

Discl: 02/2015

DryWd: 02/2015

Borough Mandatory Curtailment Program

(Clarification) n/a n/a PM2.5: 0.077SO2: -0.006 0.73 PM2.5: 0.125SO2: -0.009 03/2015

Energy Efficiency Measures (Clarification) PM2.5: <0.002 <0.02 PM2.5: <0.002 <0.02 .................. 2008

Other, pre-2015 Requirements (18 AAC and 

Borough Code, Title 21):

 - Opacity Limit

 - Open Burning

PM2.5: <0.001

PM2.5: <0.001

<0.01

<0.01

PM2.5: <0.001

PM2.5: <0.001

<0.01

<0.01

.................. 02/2015

Other, post-2015 (setbacks, 2nd conviction, no 

waivers for new buildings) n/a n/a PM2.5: <0.001 <0.01 .................. 2015-2016

Vehicle/Device Turnover (SIP):

 - Federal Motor Vehicle Control Program

 - Uncertified Wood Device Turnover

PM2.5: 0.135‡ 1.50 PM2.5: 0.135‡ 1.50 .................. ..................

TOTALS

PM2.5: 0.591

SO2: -0.014

NOx: 0.033

NH3: 0.014

5.14

PM2.5: 0.780

SO2: -0.016

NOx: 0.052

NH3: 0.018

6.97

PM2.5: 0.420

SO2: -0.004

NOx: -0.033

NH3: 0.007

n/a – Not applicable; these measures not yet implemented prior to 2015.

† Voluntary mobile source measures include vehicle plug-ins, walk/bike/carpool programs, increased transit bus ridership, 

and vehicle idle reduction programs.

†† Voluntary other source measures include Solid Fuel Burning Device (SFBD) cessation alerts, public awareness education 

and improved SFBD operation (as noted in the SIP).

‡ Detailed mission breakdowns not available; motor vehicle fleet turnover accounts for roughly 95% of reductions.

At your request, we have also included the “turnover” increment from the SIP at the bottom of the summary 

table to provide consistency with incremental reductions from the base year design value in the SIP 

(44.7 μg/m3). This turnover increment reflects net reductions in emissions and modeled PM2.5 concentrations 

due to motor vehicle fleet turnover effects from the federal Motor Vehicle Control Program as well as retirement 

of old uncertified woodstoves that has occurred (and continues to occur) outside the Wood Stove Change Out 

Program. Roughly 95% of these net reductions result from motor vehicle fleet turnover.
Response to Clarification Request January 6, 2017

Page 10

Total emission reductions and estimated concentration reductions are shown at the bottom of the summary table. 

The totaled reductions and incremental benefits shown were calculated in a manner that accounted for 

overlapping effects; thus the benefits reflect additive reductions with the effects of double-counting removed.

The Voluntary Measures category includes the following elements:

Area Source Sector

 Voluntary Solid Fuel Burning Device (SFBD) Cessation – alerts with multiple notification systems 

(email, text, social media, radio, TV, newspaper, etc.)

 Public awareness education – Split/Stack/Store/Save, sniffer maps, Take the Pledge program, annual 

maintenance, etc.

 Improved SFBD operation – as noted in the SIP

Mobile/Transportation Sector

 Plug-in

 Walk, bike, carpool

 MACS Transit bus

 Idle reduction

 Diesel idle reduction

Emission Reduction Calculation Methods and Data Sources - Following this summary table for additional 

context, are brief category-specific summaries of the emission benefits and the methods used to 

calculate them for the recent measures adopted since the SIP was submitted. Benefits are calculated 

for the required 2015 attainment year unless otherwise noted. When the benefits of measures overlap

(for those quantified), the sum of the individual measure’s benefits will be lower than achievable 

emission reductions because one measure may impact the implementation and emission reduction 

potential of another measure when they are both operating together.

An example of such overlap are individual emission benefits reported for the Wood Seller Registration/Moisture 

Disclosure Program and the State program requiring only dry wood to be burned during the October 1 through 

March 31 nonattainment season. Both measures reduce PM2.5 emissions1 by either educating (Moisture 

Disclosure) or mandating (Dry Wood Requirement) use of more dry wood than would occur in the absence of 

either measure. Since they both target the same source (in this case the amount of wet or “non-dry” wood 

burned in the nonattainment area), their effects overlap each other. Thus summing their individually-estimated 

benefits will overstate combined reductions if both are applied.

Moisture Disclosure Program and Wood Seller Registration – A “Wood Sales” database collected and 

maintained by DEC was used to estimate the effects of the Moisture Disclosure Program and Wood Seller 

Registration program on the average moisture level of wood burned for space heating during winter episodes 

since the program was implemented. The database contains records of commercial wood sales in the 

nonattainment area from October 2015 through September 2016 (a 12-month period). For each record, the 

amount of wood sold is provided (in cords) along with either a moisture level estimate (from three 

measurements as required under the program) or a designation that the wood was sold wet or frozen. These data 

were analyzed to develop an estimate of the change in average wood moisture for commercially sold wood with 

these disclosure requirements in place. It was found that average moisture content for commercially sold wood 

dropped from 64% (based on average moisture of commercially sold wood from a 2011 CCHRC study) to 33% 

based on analysis of the Wood Sales database. This reduced the average moisture content for all wood 

 

1 PM2.5 emissions decrease with lower moisture levels in wood. Stated simply, it takes more wet wood to provide a 

specific quantity of “effective” heat than dry wood since a portion of the combustion energy is used to evaporate the 

moisture bound in the wood.
Response to Clarification Request January 6, 2017

Page 11

(including wood cut, split and stored by residents) from 36.4% to 30.3%, which produced an estimated 4.5% 

reduction in wood use and a reduction in PM2.5 emissions of 0.096 tons/day.

Prohibit Fuels and Requirement to Burn Dry Wood – Using methods to translate changes in wood moisture 

content discussed elsewhere in the SIP and similar to those applied above, a separate estimate of PM2.5 emission 

reduction was developed for the State program requiring only dry wood use during the winter nonattainment 

season. Based on a DEC-estimate of 10% initial compliance for the first year of the program, the average 

wintertime wood moisture content would be further reduced to 29.3% (beyond the moisture reduction attained 

through commercially-sold wood moisture disclosure). This translates to a reduction in wood use of 0.7% and a 

PM2.5 reduction for wood-based space heating within the nonattainment area of 0.016 tons/day based in an initial 

year 10% compliance rate.

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

Program requires mandatory cessation of combustion from solid-fueled residential space heating devices during 

Stage 2 and Stage 3 alerts called by the Borough under specific ambient air quality and temperature regimes 

summarized as follows:

 Stage 2: 35 μg/m3 24-hour PM2.5 < 55 μg/m3

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

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

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

Under Stage 2, burning is permitted in all EPA-certified SFBAs, EPA Phase II qualified hydronic heaters with 

emission ratings of 2.5 g/hour or less, masonry heaters, pellet-fueled appliances cook stoves and fireplaces. 

Burning is prohibited from all other devices including non EPA certified devices and waste oil devices.

Stage 3 includes separate restrictions depending on whether ambient temperatures are above or below -15°F (as 

measured in real time at the Fairbanks International Airport). Above -15°F, burning is prohibited in all SFBAs, 

masonry heaters, pellet-fueled appliances, cook stoves, fireplaces and waste oil devices. When temperatures 

drop below -15°F, burning is permitted in EPA-certified SFBAs, EPA Phase II qualified hydronic heaters with 

emission ratings of 2.5 g/hour or less, masonry heaters and pellet-fueled appliances. (Fireplaces are prohibited 

from operating under Stage 3 with temperatures ≤ -15°F.)

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

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

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

Since the alert stages are AQCZ-specific and occur under different ambient conditions, the first step in 

analyzing program benefits consisted of identifying the frequency of the days and average temperature 

conditions under which they occurred during calendar year 2015, separately for each stage and AQCZ. Tables 

in the Temperature Exemption section show these alert stages frequencies. (The 182-day nonattainment season 

runs from October 1 through March 31.) In 2015, Fairbanks alerts were based on the NCORE monitor, while 

North Pole alerts were based on the North Pole Fire Station (NPFS) monitor. 

Since daily space heating emissions are a function of the ambient temperature, the table below shows average 

daily temperatures associated with each alert stage and AQCZ. (Fairbanks had no Stage 3 days above -15°F in 

2015). Baseline day-specific emissions by device/fuel under this set of temperatures were extracted from the 

episodic emission inventory and these temperatures are shown in the following table.
Response to Clarification Request January 6, 2017

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Alert Condition

Average Daily Temp (°F)

Fairbanks North Pole

Stage 2 - Days ≥ 35 μg/m3and < 55 μg/m3-26.8 -4.7

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

Stage 3 - Days ≥ 55 μg/m3, Temp > -15°F n/a -0.4

Data collected by the Borough for operation of the curtailment program in calendar year 2015 (its first year of 

implementation) were used to estimate the program’s compliance. The Borough developed a compliance rate 

estimate of 10% for the first year of operation (2015).

Next, emission reductions (at 10% compliance) were then calculated for the day-specific emission levels of each 

AQCZ (Fairbanks and North Pole) and alert stage (S2, S3>-15, S3<-15) by eliminating emissions from the 

specific devices and fuel for which burn restrictions occur under each stage. Logic was included to account for 

emission increases associated with substitution of heating energy from curtailment restricted devices to a 

substitute device/fuel: a central oil furnace. Heating efficiency (as well as emission factor) differences between 

each restricted device and central oil were also accounted for. In addition to account for the “No Other 

Available Source of Heat” (NOASH) waiver provisions in the curtailment program, an estimate of NOASH 

households was developed from Fairbanks Home Heating Survey data. In the combined 2011-2015 surveys, it 

was found that 5.6% of surveyed households only had wood-burning devices in the home; this percentage was 

used to estimate the fraction of potential NOASH households for which burn restrictions would be waived.

These emission calculations were performed separately for each AQCZ and accounted for the fact that the 

Goldstream Valley portion of the nonattainment area is not subject to these restrictions. (Goldstream Valley 

emissions were scaled from the nonattainment area total based on occupied household counts from block-level 

tabulations in the 2010 Census). 

In the emission inventory (unlike for woodstoves and inserts), hydronic heaters were treated as a single source 

category weighted as 80% unqualified and 20% EPA Phase II qualified devices. To account for the fact that 

Phase II hydronic heaters with emission rates below 2.5 g/hour are allowed to operate during Stage 2 and Stage 

3 (<-15°F) alerts, an estimate of the population of Phase II devices under 2.5 g/hour of 38% was developed from 

the list of Phase II qualified hydronic heaters from EPA’s “Burn Wise” database.

Using these inputs and assumptions, estimated average daily emission reductions on days of each alert stage for 

each AQCZ are shown below. Though not reported in the earlier Emissions Benefits table, emission impacts for 

SO2 are also shown. (The negative values represent the marginal increase in SO2 emissions associated with 

substituting wood-based heat with that from central oil.) Although North Pole has a higher fraction of woodburning devices than Fairbanks, its average PM2.5 emission reductions under each stage are lower because 

warmer temperatures can still trigger alert stages there as shown in the preceding table.

AQCZ

Alert Stage Emission Reductions (10% Compliance)

PM2.5 Reductions (tons/day) SO2 Reductions (tons/day)

Stage 2

Stage 3

>-15

Stage 3

<-15 Stage 2

Stage 3

>-15

Stage 3

<-15

Fairbanks 0.033 0 0.062 -0.004 0 -0.004

North Pole 0.021 0.063 0.043 -0.001 -0.008 -0.002

These reductions are specific to those days (and areas) for which alerts were called. Using the frequencies of 

each alert stage for each area based on 2015 monitoring and meteorology data, nonattainment episodic average 

daily reductions are shown below. (Again, negative numbers reflect emission increases.)
Response to Clarification Request January 6, 2017

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Pollutant

Episodic Average Daily Emission Reductions (tons/day)

With NOASH Waiver (10% Compliance)

Fairbanks North Pole Nonattainment Area

PM2.5 0.039 0.038 0.077

SO2 -0.004 -0.002 -0.006

Regarding enforcement and resources for enforcement, Chapter III.D.5.11 of the Moderate SIP, Episode Plan 

that was updated and adopted September 7, 2016 to include the FNSB ordinances has an expanded discussion on 

enforcement and resources. Excerpts from the SIP chapter have been provided below. 

Ordinance 2015-01 grants the FNSB Air Quality Division the ability to receive, log, and 

investigate complaints as well as issue warnings and citations for verified violations of FNSB 

code. In June of 2015 the division added two complaint investigation and response staff 

members. These two postions utilize a mobile air quality monitoring vehicle (sniffer) to track 

PM2.5 concentrations in real time as well as a camera based opactiy reading service (EPA 

Method ALT 082) to verify air quality violations. Once verified, the staff members have the 

ability to engage the resident, discuss emissions reduction strategies, or issue mandatory 

warnings and citations in accordance with FNSB Code 21.28.030 and 1.20.080. Fines range 

from $100 to $1,000 depending on violation and number of offenses. 

Property owners or managers may obtain a “No Other Adequate Source of Heat” (NOASH) 

waiver to episode burn cessation requirements if a property relies on a solid fuel-fired heating 

device as its sole source of heat. To ensure no new construction occurs that would be eligible 

for a NOASH waiver, Ordinance 2016-37 limits the waiver eligibility to properties constructed 

prior to December 31, 2016. NOASH applicants are urged to participate in the Borough 

change out program to help reduce emissions by installing an eligible wood or pellet-fired 

device or replace a solid fuel-fired device with a non solid-fuel fired device.

On August 11, 2016, the assembly passed Ordinance 2016-20-1A to allow design and 

operation of a “low cost” air quality monitoring network in the Air Quality Control Zone. This 

network will be comprised, initially, of six Thermo Scientific pDR-1500 monitors and 20 

MetOne Neighborhood monitors. A pDR-1500 network will monitor air quality throughout the 

Air Quality Control Zone and supplement regulatory monitor data when issuing advisories and 

alerts and tracking air quality trends. A network of MetOne Neighborhood monitors will be 

used to locate and identify high-emitting sources by deploying a small grid of monitors 

centered around “Hot Spot” areas identified by the “sniffer vehicle” or through complaints. 

Staff will investigate high-emitting sources and seek compliance with regulations through 

education and will issue warnings or citations on a case-by-case basis. The MetOne monitors 

will be relocated to other hot spot areas in the Air Quality Control Zone as needed. Future 

operation of this air quality monitoring network is contingent on FNSB appropriations. This 

enforcement strategy will focus limited resources to areas that are most affected by poor air 

quality as identified through complaints, sniffer vehicle data, and other information. The 

ability to detect large emitters in nightime conditions with monitoring equipment will provide 

for more effective enforcement of the Borough episode program than visual detection of smoke 

alone, especially when a smoke stack’s emissions are obscured or cannot be seen or 

photographed from a public right-of-way. Locating and engaging high-polluting device 
Response to Clarification Request January 6, 2017

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operators with enforcement efforts will provide greater emission reductions than traditional 

program enforcement methods alone.

The two borough compliance staff will enforce the mandatory curtailment and other borough ordinances 

through; responding to complaints, driving the ‘sniffer’ vehicle daily and using the network of MetOne

Neighborhood monitors once they are in place. Resources at the Borough’s disposal are the two compliance 

employees that provide complaint response 7 days a week. The Borough also has two mobile vehicles that are 

driven from 5:00 am – 9:00 pm. One vehicle supports the hot spot program and the other vehicle is dedicated for 

complaint response. This is in addition to the MetOne monitors that will be deployed. 

Effect on the impracticability demonstration: Explain the impact on the impracticability demonstration 

from the updated control measures in the supplementary submittals. Provide an analysis as to whether 

attainment would still have been impracticable had all of the measures been implemented earlier. 

On October 8, 2014 a renewal of the citizen initiative limiting borough authority to implement solid fuel burning 

controls was defeated by local voters; the vote was certified by the Borough on October 23, 2014. Subsequent 

to the vote, the State had completed the proposed SIP and released it for public comment on November 14, 

2014, with the expectation that the borough would implement SFBA’s (solid fuel burning appliance) control 

measures. Given the holidays and time required to propose, notice and debate/agree on the selection of controls, 

ordinances for eight separate control measures were not passed by the Borough until February 2015. This 

sequence of events is entirely consistent with the Memorandum of Understanding (MOU) between the State of 

Alaska and FNSB, where FNSB is the designated lead planning agency for the nonattainment area. Since 

measures are not effective without local support, it was/is appropriate for the borough to take the lead and 

follow its process in selecting controls. Prior to and during this period, the State continued to provide education 

about the need for changes in behavior and options for reducing emissions. It would have been extremely 

difficult for the state to implement controls on a more expedited basis and if successful, their implementation 

would have received much less public support and diminished compliance relative to borough implemented 

measures. 

Quantitative Analysis of Recent Measures – To verify the findings of impracticable attainment by 2015, 

modeling results from the 2015 SIP Control inventory were re-examined to assess whether the additional 

emission benefits from the measures adopted since the SIP submittal listed earlier would be sufficient to 

demonstrate attainment across the entire PM2.5 nonattainment area. Given the individual benefits shown earlier 

in the Emission Benefits table (which assumed 100% compliance or were based on reported compliance), an 

analysis was performed to combine the emission reductions from all recent measures and properly account for 

instances when individual measure benefits overlap (e.g. multiple types of dry wood programs). This analysis 

also incorporated realistic estimates of compliance rates for each measure in 2015 where actual compliance data 

were not available, reflecting initial but not fully-realizable emission benefits as enforcement efficiency and 

compliance improves over time. Finally, the analysis utilized CMAQ results from the 2015 Control modeling to 

translate these combined emission benefits (in tons/day, averaged over the modeling episodes) to reductions in 

24-hour PM2.5 concentrations across the nonattainment area. The analysis supports the finding of impracticable 

attainment by 2015, even after accounting for the benefits of recent measures implemented since the SIP was 

submitted.

The following table summarizes the results of the recent measures analysis for the episodic conditions in the 

SIP. The 2015 Control inventory and modeling results upon which it is based already incorporated benefits 

shown in the earlier Emission Benefits table for subsidizing change outs of hydronic heaters, wood stoves and 

fireplaces/inserts through continuation of the Borough’s WSCO program.
Response to Clarification Request January 6, 2017

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2015 Attainment Analysis of Recent Measures

Measure Category

PM2.5 Emission Reductions Maximum 

24-Hour PM2.5

Impacts (μg/m3 Tons/day % of Inventory ) 

State/Borough Dry Wood Measures

(State Moisture Disclosure + State/Borough Dry 

Wood programs)

0.112 2.5% 1.10

Borough Mandatory Curtailment Program 0.077 1.7% 0.73

Energy Efficiency Measures <0.002 <0.05% <0.02

All Other Measures (including all inventory sectors) <0.001 <0.02% <0.01

TOTALS 0.192 4.4% 1.83

Estimated PM2.5 emission reductions realized in 2015 (averaged over all episode days) from the recent measures 

are shown on both a tons/day basis as well as a percentage reduction in total inventory emissions (from 2015 

Control levels). As stated earlier, the emission reductions estimates avoid double-counting and account for 

overlap between measures where applicable. The measure order listed in the table (from top to bottom) account 

for overlap with the preceding measure(s).

These emission reductions are based on actual data where available (e.g., the aforementioned Wood Moisture 

Disclosure database). As noted earlier, initial 2015 compliance rates of 10% were estimated for the

State/Borough Dry Wood programs and the Borough Mandatory Curtailment program based on discussions with 

DEC and Borough staff responsible for program enforcement. The rightmost column shows calculated 

maximum reductions in ambient 24-hour PM2.5 levels across the entire nonattainment area for each measure 

category. These estimated concentration impacts were based on source elimination runs performed in 

conjunction with the 2015 Control attainment modeling and are corrected to monitor-based “design value space” 

(i.e., they are not “raw” model concentration estimates).

As shown at the bottom of the table, the combined emission reductions of 0.192 tons/day represent an estimated 

maximum reduction in 24-hour PM2.5 concentration of 1.8 μg/m3. The 2015 Control modeling in the SIP (Table 

5.8-12) resulted in a combined reduction from all measures of 5.14 μg/m3. Coupled with the reductions for the 

recent measures shown above (and accounting for measure overlap) yields a total benefit of 6.97μg/m3. (This 

combined benefit is consistent with that reported earlier in the SIP Control Strategy Reductions summary table.)

The attainment modeling in the SIP predicted a design value-corrected concentration of 39.4 μg/m3in 2015 at 

the Fairbanks SOB monitor (as well as higher concentrations elsewhere across the nonattainment area). 

Subtracting the maximum impact of 1.8 μg/m3estimated from combining all recent measures results in an 

estimated 24-hour PM2.5 concentration of 37.8 μg/m3. This is still above the 35 μg/m3standard and thus 

supports the finding of impracticable attainment by 2015, even after accounting for the benefits of recent

measures implemented since the SIP was submitted.

Further analysis was conducted using the methods above to estimate the levels of compliance needed for the 

State/Borough Dry Wood requirements and the Borough Curtailment program. It was found that 40% or higher 

compliance for both measures would be required to demonstrate attainment in the nonattainment area (including 

unmonitored grid cell areas). Over time, compliance rates at these levels can be achieved through increased 

public awareness and adaptation as well as increased and more efficient program enforcement.

Air Quality Trends in 2014 and 2015 – The SOB FRM data did show a clean data year in 2014 and in 2015. 

However, unmonitored grid cell analysis prepared for the Moderate SIP and the data from special purpose 

monitors showed that other areas within the nonattainment area had values greater than the standard. In early 

2015, EPA also determined that the North Pole Fire Station (NPFS) monitor would be designated as a regulatory 
Response to Clarification Request January 6, 2017

Page 16

monitor. This North Pole monitor’s 2012-2014 design value was 139 μg/m3. Clearly, while the SOB FRM may 

have showed the possibility of reaching attainment in 2015, the rest of the monitoring data clearly shows that the 

impracticability determination of the Moderate SIP was correct. 

Implications for Reasonable Further Progress (RFP) – As discussed in Section III.D.5.6.5 of the SIP, Section 

172(c)(2) of the CAA requires that plans for non-attainment areas “shall require reasonable further progress” 

and include a “current inventory of actual emissions from all sources of relevant pollutants in such area ... to 

assure that the requirements of this part are met.” The goal of RFP is to achieve generally linear progress 

toward attainment (as opposed to deferring implementation of some measures until the end or projected 

attainment date). Calendar year 2017 was established as the year for which RFP must be demonstrated 

beyond the required attainment year of 2015 in the Moderate Area SIP. This sub-section provides a brief 

assessment of the implications on RFP in 2017 when measures adopted since the SIP was submitted are 

accounted for, along with other updated control measure information. It focuses only on primary PM2.5 since 

this was the only pollutant for which benefits were fully analyzed from these measures.

The quantitative milestone targets set in the SIP for the 2017 RFP year were 3.96 tons/day of PM2.5 for the entire 

inventory within the nonattainment area. (This was linearly interpolated between the 2015 Control and 2019 

Control inventories of 4.40 and 3.52 tons/day, respectively.) Thus, average episodic emissions in the 

nonattainment area must be reduced from 4.40 tons/day in 2015 to 3.96 tons/day in 2017, a reduction of 

0.44 tons/day. As discussed in the preceding sub-section, the recent measures adopted since the SIP was 

submitted are estimated to provide a combined PM2.5 emission reduction of 0.192 tons/day beyond the original 

2015 Control inventory estimates. Based on initial compliance rates estimated for several key measures, this 

combined benefit in 2015 is below the 2017 milestone target. However, compliance rates for these key Dry 

Wood Use and SFBA Curtailment measures are likely to increase over time and are expected to meet the 

milestone target by 2017. DEC and the Borough will monitor compliance from these programs and update 

current benefits estimates to assess their greater benefit potential over time. This element, as well as other 

updated information (e.g. fuel switching implications for point source emissions from Flint Hills Refinery 

shutdown and progress in natural gas expansion) will be examined in preparation of the RFP report required to 

be submitted to EPA within 90 days of the end of the RFP year (i.e. March 2018).

Fireplaces and certified devices during Stage 2 alerts: Please clarify the rationale for allowing fireplaces 

and certified wood-heating devices to operate during a Stage 2 alert when ambient concentrations of 

PM2.5 exceed the NAAQS. Providing a comparison of the emissions to a program that includes these 

devices in the Stage 2 alert would be helpful. Explain how any impacts on the effectiveness of the 

curtailment program will be mitigated. 

In February 2015, the FNSB Assembly established a solid-fuel fired burning curtailment program for the first 

time. The new program established a framework to evaluate its effectiveness and allow adjustments over time. 

The program has three stages. Stage 1 asks for voluntary curtailment. Stage 2 acknowledges those devices that 

are EPA-certified and allows continued burning, but no un-certified devices may be used. Stage 3 is a full 

curtailment. 

EPA-Certified Devices:

The Stage 2 portion of the episode program requirements exempt EPA-certified devices, EPA Phase II qualified 

hydronic heaters <2.5 g/hr, masonry heaters, pellet burning devices, fireplaces, and cook stoves. By exempting 

these devices during a Stage 2 alert, the Borough is calling attention to EPA-certified devices and demonstrating 

the benefits of installing lower-emitting units. This assists in promoting use of the Borough’s change out 
Response to Clarification Request January 6, 2017

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program. The benefits of this approach have been recognized in control programs implemented in other PM2.5

nonattainment areas.2

While certified devices may be exempt from curtailment during Stage 2, it should be noted that the opacity 

requirement and dry wood requirement are still in effect. Compliance staff will still address certified device use 

during a Stage 2 alert if there are opacity violations and emissions crossing property lines. Allowing certified 

devices during a Stage 2 is an educational tool that compliance personnel use when educating residents using a 

non-certified devices. This feature of the episode plan is important because it demonstrates the benefits of

change-outs to lower emitting heaters, which is a priority for the community. It also provides an option for noncertified devices found in noncompliance. Replacing a non-certified device with a cleaner burning device 

results in emissions benefits throughout the heating season. The emissions of properly operated certified devices 

are low in comparison to uncertified devices which are curtailed under a Stage 2 alert. 

 

Fireplaces: 

Fireplaces include a mixture of combustion components, including: no inserts, uncertified inserts, certified 

inserts (catalytic and non-catalytic) and pellet inserts. Roughly 50% of the 1,210 fireplaces included in the 2015 

emission inventory for the nonattainment area are estimated to have no inserts. Since fireplaces without inserts 

are highly inefficient, their use in Fairbanks is largely limited to ornamental operation. Borough discussions 

with owners has found that roughly 95% of fireplaces without inserts are not used at all. Instead, most units are 

plugged with insulation and used as display centers. Thus, they are not viewed as contributing emissions during 

Stage 2 alerts. Two thirds of the remaining fireplaces have inserts that are EPA certified. For these reasons, 

fireplaces are not viewed as a significant source of emissions.

Fireplace operation must still meet the opacity requirements and property lines emission restrictions. The 

borough assembly is focusing its resources in identifying and addressing compliance when individuals are not 

operating their devices correctly. 

The PM2.5 Stage 2 alert day emissions reductions associated with 100% compliance with a current Stage 2 alert 

is 0.522 tpd in Fairbanks and 0.326 tpd in North Pole. If fireplaces were removed from the exemption, 0.837 

tpd would be reduced in Fairbanks and 0.491 tpd reduced in North Pole. If fireplaces and EPA-certified devices 

were removed from the exemption, meaning no devices could operate without a NOASH waiver, 1.337 tpd 

would be reduced in Fairbanks and 0.765 tpd in North Pole. The potential emission reductions not realized 

during a Stage 2 alert due to the current exemption for EPA-certified devices and fireplaces in Fairbanks are 

0.500 tpd for EPA-certified devices and 0.315 tpd for fireplaces. In North Pole, unrealized emission reductions 

are 0.274 tpd for EPA-certified devices and 0.165 tpd for fireplaces. 

Alert Stage Zone Certified Devices Exempted Fireplaces Exempted PM2.5 Reduction, tpd*

at 100% Compliance

2

Fairbanks

X X 0.522

X 0.837

1.337

North Pole

X X 0.326

X 0.491

0.765

 

2 For example, the San Joaquin Valley PM2.5 nonattainment area wood burning curtailment program was amended in 2014 

to include exemptions for EPA-certified devices during air quality episodes. The program allows EPA-certified 

woodstoves to burn at concentrations between 20 and 65 μg/m3 when all other devices are prohibited from burning. To 

qualify for an exemption, the program requires registration and triennial inspection by a professional. The purpose of the 

exemption is to encourage change outs to EPA-certified devices. Public survey results indicated that reducing the number 

of no-burn days by exempting devices during curtailment episodes would incentivize change outs. 
Response to Clarification Request January 6, 2017

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*The emissions estimates of fireplaces based on home heating survey data used in the analysis above may be 

biased high and not representative of actual conditions in the nonattainment area during wintertime 

conditions. Borough staff do not perceive fireplaces to be a significant contributor to PM2.5 emissions in the 

nonattainment area. Fireplaces are generally not used as heating sources during the winter in conditions when a 

Stage 2 alert may occur. Fireplaces are inefficient heaters and create a passage for significant heat loss in the 

home. Staff have observed many instances where the fireplace was rendered inoperable through the use of 

insulation or plywood during pre-verification visits for the change out program. Survey data may instead 

represent wood usage during shoulder seasons that may have been incorrectly reported or interpreted as 

wintertime home heating. Staff reported that there were no complaints or enforcement cases against fireplace 

operators during the 2015-2016 winter. For these reasons, further examination of the significance of wintertime 

fireplace emissions will be performed in the development of the Serious SIP.

Temperature exemption: Provide a rationale for the suspension of the mandatory curtailment program 

when temperatures reach -15 °F and a justification for why this temperature was selected. Also, explain 

how the exemption impacts the effectiveness of the curtailment program. We request that you provide 

information about past PM2.5 levels at the North Pole and Fairbanks monitors during days that are below 

-15 °F including how many of those days had PM2.5 levels above 35 μg/m3. Explain how impacts on the 

effectiveness of the curtailment program will be mitigated. 

As mentioned above, the curtailment program established in February 2015 established an initial framework. 

During public testimony taken while the curtailment program was being considered, a temperature threshold 

was proposed by the public and established in response to the public testimony received. Therefore, the

temperature threshold is a feature of the episode program recognizing the unique challenges faced by residents 

during periods of extreme cold. Residents use wood heating as a form of supplemental heat to maintain livable 

conditions and mitigate economic hardships associated with high heating costs. The threshold was selected by 

the Borough Assembly as warranted to provide a balance to heating costs and to improve compliance rates. 

Local survey data collected by DEC and the Borough support the establishment of this threshold and economic 

challenges faced by residents who lean toward more wood-burning under colder temperatures. The 2013 Wood 

Tag telephone-based survey randomly sampled 216 wood-burning households within the nonattainment area. 

For those 196 households that had alternative heating sources in addition to their wood device (e.g. a central oil 

furnace), a series of questions were asked related to their heating practices and reasons under colder 

temperatures. These questions and their responses are summarized below (counts are shown in parentheses):

 Do you always burn wood at colder temperatures as a secondary source of heat?

Yes = 62.2% (122), No = 37.8% (74)

 Why (for those answering “Yes” above)?

Need extra heat = 13.9% (14), To save money = 50.0% (61), Both = 32.0% (39)

 At what temperature do you burn wood (for those answering “Yes” above)?

Average = -2.1°F, Median = 0°F, with 57% of responses above -15°F threshold

These survey results clearly reflect residents’ cost and supplemental heat-driven concerns. Based on the 

heating energy model used to develop the space heating inventory, over 340,000 additional BTU/day are needed
Response to Clarification Request January 6, 2017

Page 19

to heat a typical 2,200 square foot home in Fairbanks at -30°F than at 0° F

3

, an increase in heating energy of 

over 40%. Assuming heating oil costs $3 per gallon, this 340,000 BTU increment would represent a cost 

increase of roughly $270 per household per month using oil, a significant additional expense for many residents. 

The -15°F triggering threshold is also well below the average mean of -2.1 °F and median of 0°F when 

respondents of the survey indicated that they burned wood. 

Stage 3 alerts are announced regardless of temperature to comply with Borough Code and provide information 

to the public about air quality conditions so they may take precautions to guard their health. If after a Stage 3 

alert is called and the temperature drops, the Borough does not announce that the temperature is below

- 15 degrees nor does it officially cancel the State 3 alert. It should also be noted, residents exempted under the 

threshold still must comply with other restrictions such as a 20% opacity limit and limits on emissions crossing 

property lines. Borough compliance staff still respond to complaints and conduct business as usual regardless of 

the temperature. Therefore, impacts to Stage 3 alert effectiveness are mitigated through the enforcement of other 

Borough Code requirements on high emitting devices such as an opacity requirement and limits on emissions 

crossing property lines.

Please see the Emissions Benefit table above for an estimate of emission impacts. 

Historical publicly available 24-hour average correlated BAM concentrations obtained through EPA’s Air 

Quality System were compared to publicly available daily minimum temperatures at the Fairbanks International 

Airport. The tables below provide the requested information for the State Office Building, NCORE, and North 

Pole Fire Station BAM monitors during the years in which they operated. BAM monitoring was discontinued at 

the State Office Building in April 2013. BAM monitoring continues at the NCORE and North Pole Fire Station 

Sites and is used for calling the curtailment Stages and advisories.

Number of Days with 24-hour average BAM concentrations > 55 μg/m3

SOB NCORE NPFS

Year ≤ -15°F > -15°F ≤ -15°F > -15°F ≤ -15°F > -15°F

2006 1 0

2007 1 0

2008 6 0

2009 2 0

2010 7 0

2011 3 0 0 0

2012 8 0 9 0

2013 0 0 1 0 21 7

2014 0 0 14 26

2015 3 0 23 8

Total 28 0 13 0 58 41

Number of Days with 24-hour average BAM concentrations > 35 μg/m3and < 55 μg/m3

SOB NCORE NPFS

Year ≤ -15°F > -15°F ≤ -15°F > -15°F ≤ -15°F > -15°F

2006 17 4

2007 6 2

2008 11 9

2009 13 8

 

3 These temperatures were chosen at equidistant departures from the -15°F threshold to represent average conditions 

below and above the threshold for the purpose of estimating incremental heating costs.
Response to Clarification Request January 6, 2017

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2010 14 1

2011 18 4 4 1

2012 23 0 21 0

2013 8 1 9 0 5 12

2014 6 3 7 19

2015 12 0 10 10

Total 110 29 52 4 22 41

RACT analysis: Clarify whether all current controls were identified accurately in the RACT analysis. For 

example, table 1 (Appendix III.D.5.7-64) does not identify facilities with water injection for NOx control, 

however in the SO2 and PM2.5 RACT analysis section some facilities were described as being equipped 

with water injection for NOx control. Also provide clarification on Alaska costs to support the 

explanation that control measure costs would be higher in Alaska. In particular, EPA does not agree that 

$1000/per ton is an adequate cost threshold for NOx controls. 

Thank you for pointing out some inconsistencies between our Appendix text and tables. Table 1. Emission 

Units, located at major stationary sources, with actual emissions of PM2.5, or a precursor, greater than 5 TPY 

(Appendix III.D.5-7-64) should have listed water injection as a current control on GT #3, a gas turbine at GVEA 

North Pole. That table has been clarified and is below.

“Table 1. Emission units, located at major stationary sources, with actual emissions of PM2.5, or a precursor, 

greater than 5 TPY.”

Facility Source

Source 

Category Unit Sizea

Actual Emissionsb

Current 

PM2.5 SO2 NOx Controls Proposed RACT

Fort 

Wainwright

Boiler 3 Coal-fired 

boiler

230 MMBtu/hr 2 109 101 Baghouse Baghouse

Fort 

Wainwright

Boiler 4 Coal-fired 

boiler

230 MMBtu/hr 2 101 99 Baghouse Baghouse

Fort 

Wainwright

Boiler 5 Coal-fired 

boiler

230 MMBtu/hr 2 126 117 Baghouse Baghouse

Fort 

Wainwright

Boiler 6 Coal-fired 

boiler

230 MMBtu/hr 1 87 91 Baghouse Baghouse

Fort 

Wainwright

Boiler 7 Coal-fired 

boiler

230 MMBtu/hr 3 171 197 Baghouse Baghouse

Fort 

Wainwright

Boiler 8 Coal-fired 

boiler

230 MMBtu/hr 2 122 168 Baghouse Baghouse
Response to Clarification Request January 6, 2017

Page 21

Aurora 

Energy, 

Chena

Boiler 1, 2, 

3, 5c

Coal-fired 

boiler

5 MW each 

(Boilers 1,2,3); 

20 MW (Boiler 

5)

7.81 

(total)

838.9 

(total)

792.7 

(total)

Baghouse Baghouse

North Pole 

Refinery

H-2001 

Crude 

Heater

Liquid Fuel 

Fired Process 

Heater

325.6 MMBtu/hr 5.1 3.3 62.0 Ultra low 

NOx burners

No additional 

controls

North Pole 

Refinery

H-241 

Crude 

Heater

Liquid Fuel 

Fired Process 

Heater

120 MMBtu/hr 2.0 1.0 44.6 Note (d)

North Pole 

Refinery

H-1001 

Crude 

Heater

Liquid Fuel 

Fired Process 

Heater

62.5 MMBtu/hr 0.3 0.8 20.6 Note (d)

North Pole 

Refinery

B-401 

Steam 

Generation

Liquid Fuel 

Fired Boiler

25 MMBtu/hr 0.3 0.1 11.8 Note (d)

North Pole 

Power Plant

Gas 

Turbine #1

Gas Turbine 60.5 MW 15.5 42.3 50.3 Continued use of 

HAGO

Gas 

Turbine #2

Gas Turbine 60.5 MW 131 326 464 Continued use of 

HAGO

GT #3 Gas Turbine 43 MW 16.8 1.86 367 Water 

injection

Continued use of 

naptha and LSR

Zehnder GT#1 Gas Turbine 16.05 39.83 54.3 Continued use of 

HAGO

GT#2 Gas Turbine 10.77 25.73 36.4 Continued use of 

HAGO

UofA, 

Fairbanks

Boiler #1 Coal-fired 

boiler

84.5 MMBtu/Hr 3.62 123.8 250 Baghouse Baghouse

Boiler #2 Coal-fired 

boiler

84.5 MMBtu/Hr 3.77 128.93 260 Baghouse Baghouse

Boiler #3 Dual Fuelfired Boiler180.9 MMBtu/Hr 2 17.7 5.72 Continued use of 

No. 2 Distillate

NOTES:

aFrom each facility’s Title V Permit Application.

bActual emissions are based on information submitted in by facility operators 2013 for operations in 2011. The information 

was requested by Alaska Department of Environmental Conservation to satisfy the requirement to prepare a statewide 

point-source emission inventory (40 CFR 51.30). The inventory report has not been completed.

cEmissions shown for the Chena boilers, which share a common stack, are the combined emissions for all four boilers. 

dNo RACT determined for this source because the only pollutant above the threshold is NOx.

The $1000/per ton cost threshold in the RACT analysis contained in the Moderate SIP reflects the information 

that DEC had at the time of submittal. Since submitting the Moderate SIP, DEC has been working on gathering

new information in preparation of developing the Serious SIP. In April 2015, DEC requested that all stationary 

sources greater than 70 tons/per year develop a BACT analysis. DEC has received preliminary Alaska specific 

cost estimates from various stationary sources and has provided that information in the table below (Appendix 

III.D.5.7-70, Table 1). 

For the Serious SIP, DEC has done some initial modeling work for a major stationary source precursor 

demonstration for NOx as provided under the new PM2.5 implementation rule. DEC is investigating the NOx 
Response to Clarification Request January 6, 2017

Page 22

contribution in the formation of ammonium nitrate to PM2.5. Early findings using the 2015 projected baseline 

from the Moderate SIP shows that removing all NOx emissions from point sources reduces the ammonium 

nitrate at the State Office Building monitor by 0.3 μg/m3 and therefore NOx controls on point sources do not 

significantly reduce PM2.5. The analysis will need to be finalized for the Serious SIP using the new 2013 

baseline before NOx controls can be eliminated in the context of BACT. We are supplying this information at 

this time to provide context to the RACT analysis. Regardless of the cost threshold, RACT controls for NOx

would not significantly reduce PM2.5 based on this preliminary precursor analysis. DEC intends to further 

discuss the full major stationary source precursor analysis with EPA as development of the serious SIP 

continues. These discussions will allow DEC to more fully develop its analysis, which it intends to submit in 

accordance with the new PM2.5 implementation rule along with the new Serious SIP. 

“Table 1 a. NOx Control Techniquesa “(For Clarity, the Tables are is separated into a. Coal Fired Boilers, b. Oil 

Fired Boilers and c. Turbines) 

(NA, is not applicable and that particular source does not have those types of units)

Source 

Category

Control 

Technique

Cost 

Effectiveness 

($/ton of NOx 

removed)a,b

Alaska source specific cost effectiveness 

($/ton of NOx removed) 

UAF f Aurora Doyon (FT WW)c

Coal-Fired Boilers (and Dual Fuel-Fired Boilers)

Industrial 

Boilers firing 

coal (stoker)

Low NOx 

burner

$1,526 (<250 

MMBtu/hr)

NA $4,877i Evaluated as good 

combustion practice and 

O2 trim technology 

already included

Coal and 

Biomass-fired 

Boiler

Coal 

Fluidized 

Bed with 

stage 

combustion

Not in original 

RACT

Already included 

in new boilerh

NA NA

Boiler firing 

coal

SCR $1,550 $28,425 $20,242j $17,417

Boilers firing 

coal

SNCR $1,370 $10,192 $5080 

(ID 5) 

$11,792 (ID1,2,3)

Technologically 

infeasible

Boilers firing 

coal

NSCR Not in original 

RACT

Technologically 

infeasibleg

This technology did 

not come up in their 

RBLC search and 

was not evaluated

This technology did not 

come up in their RBLC 

search and was not 

evaluated

aData from EPA Menu of Control Options (Updated 4/12/2012). The values shown are the bottom of the range, 

if a range was provided.

b2006 dollars

cFort Wainwright Boilers 3-8

F draft BACT analysis submitted ahead of Serious Area designation, RBLC 10 years reviewed for NOx control 

technologies. 

G not a rich burn design unit
Response to Clarification Request January 6, 2017

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hUAF Fairbanks Boiler EU ID 113

iAurora 1,2 and 3, Unit 5 already has LNB

j Aurora EU ID 1,2,3 and 5 combined

Table 1b. NOx Control Techniques for Oil Fired Boilers

Oil Fired Boilers

Source 

Category

Control 

Technique

Cost 

Effectiveness 

($/ton of NOx 

removed)a,b

UAF

Mid-size dual 

fired oil boilers

SCR Not in original 

RACT

$8,416

Mid-size dual 

fired oil boilers

SNCR Not in original 

RACT

Technologically 

infeasible

Mid-size dual 

fired oil boilers

LNB/FGR Not in original 

RACT

$3,634/($189,312 

operational 

restriction UAF

EU 4)

Mid-size dual 

fired oil boilers

Natural Gas Not in original 

RACT

Technologically 

infeasible

aData from EPA Menu of Control Options (Updated 4/12/2012). The values shown are the bottom of the range, 

if a range was provided.

b2006 dollars

Table 1c. NOx Control Techniques for Turbinesa

Turbinese

Source

Category

Control 

Technique

Cost 

Effectiveness 

($/ton of NOx 

removed)a,b

GVEA-Zehner and 

North Polek

Turbines, oil 

fired

Water 

Injection & 

SCR

$3,691 $3,200/$12,800

Turbines, oil 

fired

Water 

Injection

$2,070 $2,000/$7,800

aData from EPA Menu of Control Options (Updated 4/12/2012). The values shown are the bottom of the range, 

if a range was provided.

b2006 dollars

eNorth Pole Power Plant GT1-3; Zehnder GT 1-2.

k GVEA cost are PTE first and actual based emissions second, PTE $ are in draft form and not completed yet for 

BACT

University Of Alaska, Fairbanks (UAF)

The UAF source for the purpose of RACT, evaluated the new large coal and biomass fired boiler and two 

existing mid-sized diesel fired and dual fuel fired boilers (duel fuel on the second boiler is diesel and natural gas 

capable) as part of their draft BACT analysis for the Serious SIP. In Table 1a, the coal fired unit at UAF has a 

fluidized bed and not a stoker feed coal boiler and therefor NA (not applicable) as noted. The large coal and 
Response to Clarification Request January 6, 2017

Page 24

biomass fired boiler was evaluated for controls SCR, SNCR, LNB/OFA, FGR/Stage Combustion, CFB

(fluidized bed combustion), low excess air and good combustion practices. The SCR and SNCR costs are listed 

in Table 1a. The LNB/OFA/FGR/CFB is already included in the proposed boiler and the following was stated 

for the CFB technology:

“Upon closer review of the RBLC data, staged combustion technology is the only LNB

technology that has been identified as NOX BACT for large CFB boilers. Only pulverized coal

boilers have used OAF and FGR for NOX emission control. The proposed CFB boiler design

includes staged combustion with the primary air jets raising the coal and limestone to be above

the boiler feed bed and with secondary air being injected above the fed bed through the walls of

the boiler. As a result, staged combustion is available for the CFB boiler and will be the only

version of LNB technology considered in this BACT analysis.”

The last control technology for the coal boiler is NSCR and is technology infeasible and the following clarifies 

the reason: 

“The RBLC search discovered no applications of NSCR for large boilers since 2005. This result

occurred because boilers operate under conditions far more fuel-lean (with excess oxygen) than

required to support feasible application of this technology. The boiler is anticipated to have

exhaust gas between 1,550 degrees F and 1,650 degrees F, which is well above the

recommended exhaust temperature range. Flue gas cooling would be required. The RBLC did

not identify NSCR as a technology available to boilers of this size and design. NSCR is not an

available control technology because the proposed large boiler is not of a rich-burn design.”

In addition to the coal and biomass fired boiler, UAF has two mid-size oil fired boilers, they are very close to 

the proposed cut of 5 TPY and were not included in the original RACT., The table has been updated to include 

these two units. The costs are listed in Table 1b and the two technologically infeasible option clarifications for 

SNCR and natural gas are listed below:

“An RBLC search discovered no applications of SNCR for mid-sized diesel or natural gas-fired

boilers since 2005. SNCR is expected to achieve 30 to 50 percent NOX control without LNB and

65 to 75 percent when operated with LNB according to the EPA fact sheet (EPA-452/F-03-031).

Although no applications of SNCR for mid-sized boilers could be identified, SNCR is an

available control technology for the mid-sized boilers.”

And 

“EU ID 3 is not configured to burn natural gas. Because Fairbanks does not have a pipeline

source, natural gas is not an available fuel for consideration for this boiler. During the times that

EU ID 4 is firing natural gas, operators have noticed a pressure loss in the natural gas supply.

Operating both boilers on natural gas at the same time would only exacerbate this pressure loss

unless the natural gas delivery system was to be changed. For the above reasons, switching to only fire natural 

gas as a control technology is not an available option for either EU ID 3 or 4.”

Doyon (Ft WW)

Doyon Utilities has six stoker fed coal fired boiler units evaluated for RACT. The costs for SCR are noted in 

Table 1a. The technologies that are infeasible SNCR are described below from their draft BACT analysis for the 

Serious SIP: 

“...the outlet stack temperatures for EU IDs 1through 6 are, in general, between 300°F and

350°F, which is well below the recommended SNCR temperature range of 1,550°F to
Response to Clarification Request January 6, 2017

Page 25

1,950°F. A considerable amount of heat would be required to achieve the specified

temperature range, especially given the number of days on which subzero temperatures

occur at FWA. Generating energy for heating would require additional fuel combustion and

would result in additional emissions of direct PM2.5 and PM2.5 precursors. As noted above,

ammonia slip is anticipated with SNCR use, resulting in additional PM2.5 precursor emissions.

Ammonia is more toxic than NOx and is classified by EPA as a hazardous material.

Page 1-7of the EPA Air Pollution Cost Control Manual [Section 4, Chapter 1,May 2016)

states, "SNCR is not suitable for sources where the residence time is too short, 

temperatures are too low, NOx concentrations are low, the reagent would contaminate the

product, or no suitable location exists for installing reagent injection ports." DU agrees

with EPA and has determined that SNCR is not a technically feasible control measure due

to the temperature differential of the stack gas as compared to the recommended NSCR

operating temperature range.”

Aurora

The Aurora source has four coal fired boilers that produce electricity and locally distributed steam. Units 1,2 and

3 have a grate stoker and are equipped with conventional burners and unit 5 has a spreader stoker and a Low 

NOx burner. The control costs are listed in Table 1a. NSCR was not evaluated by this source and did not come 

up in their RBLC data search. 

Flint Hills

Please note, the table above has been modified to remove the liquid fuel-fired process heating units that were 

only at the Flint Hill Refinery. The Flint Hill Refinery is preparing for permanent shut down of the refinery and 

the RACT/BACT process heating units are currently under contract for demolition. The company is in the 

process of rescinding their title V permit in the next few weeks and those units were removed from the updated 

table. 

GVEA

The GVEA source has two locations, North Pole and Zehnder. Both source locations have turbines and the costs 

for controls are evaluated and listed in Table 1c. The low end of the range of costs were calculated using PTE 

emissions and high end of the cost were calculated using actual emissions. 

Initial Major Stationary Source Precursor Demonstration: NOx

Sierra Research, on behalf of DEC, employed photochemical grid modeling to demonstrate that oxides of 

nitrogen (NOx) emitted from major stationary sources within the Fairbanks North Star Borough 24-hour PM2.5 

nonattainment area do not contribute significantly to PM2.5 concentration exceedances at the State Office 

Building (SOB) monitor. The modeling framework was previously described in the Moderate SIP section 5.8.7. 

In brief, Sierra configured the Community Multiscale Air Quality (CMAQ) model version 4.7.1 with emissions 

processed through the Sparse Matrix Operator Kernel Emissions (SMOKE) model version 2.7.5b and 

meteorological data generated by the Weather Research Forecasting (WRF) model version 3.1 for two severe 
Response to Clarification Request January 6, 2017

Page 26

PM2.5 winter episodes. The two episodes represent conditions between January 23rd- February 10th and 

November 2nd – 17th; their selection is described in section 5.3 of the Moderate SIP.

The baseline 2015 emissions inventories with actual point source emissions served as the starting point for 

emissions for all sources in the precursor demonstration. The details of these inventories are described in the 

Moderate SIP section 5.6.3 and supporting appendix. NOx emissions were removed from all major stationary 

sources in the inventory before reprocessing the point sources through SMOKE. CMAQ-model simulations 

were conducted for both winter episodes and both emissions scenarios: 2015 baseline and 2015 baseline without 

point source NOx. The multi episode 24-hour average PM2.5 concentration was then calculated for all grid cells 

with the first two and last one day removed. Sierra calculated future design values (FDVs) for both the 2015 

projected baseline and the 2015 projected baseline without NOx from point sources using the Speciated 

Modeled Attainment Test (SMAT) methodology incorporating relative response factors (RRF). Per EPA 

guidance the changes in total PM2.5 due to the changes in ammonium nitrate portion of the PM2.5 were 

determined while particle-bound water impacts were not adjusted. Sierra found that the total PM2.5 FDV for the 

SOB monitor is reduced by 0.3 μg/m3 when comparing the 2015 baseline to the 2015 major stationary source 

NOx elimination run. As a result the impact of NOx from major stationary sources appear to be insignificant in 

terms of attaining the 24-hour PM2.5 National Ambient Air Quality Standard.

Additional Comprehensive Precursor Demonstration Clarification: VOC

The Moderate SIP presents information in addressing VOC as a precursor based on the 2008 baseline modeling. 

DEC would like to further clarify that the 2015 contributions of VOC from all sources to the 24-hour average 

PM2.5 at the SOB monitor grid cell are 0.007 g/m3. The VOC contribution to PM was determined through the 

CMAQ-model outputs averaged across all episode days. CMAQ tracks organic carbon that is contributed due to 

secondary organic aerosol formation. Since there is good performance for the organic carbon component of 

PM2.5 determined for the baseline modeling there is a high confidence that this VOC contribution number is 

accurate and very small. The model configuration in this scenario matches the one described for the NOx Major 

Stationary Source Precursor Demonstration 2015 baseline.

Motor Vehicle Emission Budgets

Table 5.6-28 has been edited to remove unnecessary extraneous text. 

Table 5.6-1

Fairbanks Non-Attainment Area Motor Vehicle Emission Budgets

Calendar Year

Motor Vehicle Emission Budgets 

(tons/day)

PM2.5 NOx

2017 0.33 2.13