From: John J. Englander

To: Tax, Wienke

Cc: LEVIN, NANCY; Law, Nicole; Lisa M. Tomczak; Phil B. Denee; Steve M. Calderon

Subject: RE: Payson & Bullhead LMP questions

Date: Tuesday, July 16, 2013 5:18:37 PM

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Copy of Bullhead City CDV summary only.xls

Wienke, Nancy & Nichole,

Please see the following for the requested additional information following our 07/02/13 call. If you

need any additional information regarding the questions we addressed on the call, please let me

know.

1.a. The exceptional event package for the August 19, 2011 event should be released for public

comment July 15, 2013.

1.b. ADEQ believes the August 19, 2011 event qualifies for exclusion based on the exceptional

events policy and, therefore, did not include the calculation of the design value for continued LMP

eligibility for the Bullhead City area in the annual report submitted 08/29/12.

1.c. The CDV calculation including the August 19, 2011 event is attached.

2.a.i. Analysis of the change in VMT for both Payson (Gila County) and Bullhead City (Mohave

County).

On the Arizona Department of Transportation (ADOT) website at the time the Payson and Bullhead

City Limited Maintenance Plans (LMP) were being written (2009) the previous ten year data had

some very large swings and the linearly interpolated data showed an annual VMT increase of about

30% for both cities. The large data swings were brought to ADOT’s attention by ADEQ and ADOT

promised to review the data. A plot of both the old (1999 to 2008) and the new (2001 to 2010) Gila

County data is shown in Figures 1 along with their linear trendlines. The Currently ADOT website

was revised and ADEQ was able to use the previous ten year linearly interpolated data to establish

an annual VMT increase of 4.3% for Payson (Gila County). This is shown in Figure 2.
Figure 1

Figure 2

2.a.ii. The DVmv value in the Bullhead City document was miscalculated. It appears that only the
unpaved road portion of the onroad inventory was considered in the submittal. The DVmv

calculation should have also included emissions in the area and should have been calculated to be

8.232 μg/m3. The VMTpi should have been noted as 31.8% as well (based on our original motor

vehicle growth projections). With these two numbers, the calculation in Figure 4.2 should be 98 +

(0.318 * 8.232) = 100.62.

2.c. A plot of both the old (1999 to 2008) and the new (2001 to 2010) Mohave County data is shown

in Figures 3 along with their linear trendlines. The Currently ADOT website was revised and ADEQ

was able to use the previous ten year linearly interpolated data to establish an annual VMT increase

of 6.3% for Bullhead City (Mohave County). This is shown in Figure 4.

Figure 3
Figure 4

3. Seasonality of Payson Data – ADEQ reviewed quarterly data for the Payson Area and it appears

that, seasonally, the first quarter of the year (the one with incomplete data) does not have

significantly higher, or lower, observed PM10 concentrations. Please take a look at the following

table for recent data:

Year Quarter No. Of Actual

Samples

Average PM10

(ug/m3)

Max 24-hour

Sample

2nd Highest

Sample

No. of Actual

Exceedances

2004 1 15 15.7 37 32 0

2 14 19.4 32 24 0

3 14 20.4 53 49 0

4 14 20.6 36 30 0

Annual 57 19.0 53 49 0

2005 1 7 22.9 81 24 0

2 15 19.7 33 29 0

3 14 19.6 33 30 0

4 14 26.2 47 47 0

Annual 50 81

2006 1 15 32.3 66 62 0

2 15 21.4 32 29 0

3 14 14.6 41 22 0

4 16 26.3 43 40 0

Annual 60 23.7 66 62 0

2007 1 14 22.2 43 31 0

2 15 23.5 62 34 0

3 15 18.8 32 31 0
4 15 27.8 41 39 0

Annual 59 23.1 62 43 0

2008 1 14 22.3 32 30 0

2 15 25.3 43 38 0

3 15 14.2 20 17 0

4 15 25.5 39 39 0

Annual 59 21.8 43 39 0

2009 1 13 25.0 36 34 0

2 16 21.0 40 39 0

3 15 18.7 38 28 0

4 14 23.1 38 34 0

Annual 58 22.0 40 39 0

John J. Englander

ADEQ – Air Quality Division

Phone: (602) 771-4781

Please consider the environment before printing this email.

From: Tax, Wienke [mailto:Tax.Wienke@epa.gov] 

Sent: Wednesday, June 19, 2013 2:07 PM

To: John J. Englander

Cc: LEVIN, NANCY; Law, Nicole

Subject: LMP questions

Hi John –

Even though we are rescheduling the call, here are the remaining questions.

Thanks

Wienke

Wienke Tax

Senior Air Quality Planner

USEPA Region 9

tax.wienke@epa.gov

415.947.4192

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