Since 1934 

ARIZONA CHAPTER ASSOCIATED GENERAL CONTRACTORS 

1825 Wesl Adnms Phoenix, Anxona 85007 (602) 252-3326 Fax (602) 252-5870 

August 1, 2006 

Daniel Blair 

Janet Travis 

Air Quality Specialists 

Gila River Indian Community 

Department of Environmental Quality 

P.O. Box 97 

Sacaton, Arizona 85247 

Dear Mr. Blair & Ms. Travis, 

The Arizona Chapter Associated General Contractors (AGC) would like to thank the Gila River Indian Community 

Department of Environmental Quality (GRIC DEQ) for the opportunity to submit comments in response to the 

recently drafted Tribal Implementation Plan (TIP). The AGC is a statewide construction association representing 

highwayheavy contractors throughout Arizona since 1934. Our association has a long history of working with 

agencies and other stakeholders to develop regulatory structure that result in both environmental and public health 

benefits while maintaining strong economic opportunities within the state. 

Thank you for taking the time to discuss the TIP over the phone. I really appreciate your willingness to accept 

AGC's comments to the process after the closing date and I look forward to participating in hture air quality 

initiatives as an industry stakeholder. 

AGC TIP Comments: 

It is our understanding that since the TIP is contingent on Reasonably Achievable Control Measures (RACM) only 

technically and economically feasible alternative control measures that satis@ the objective outlined in the TIP would 

be considered and incorporated into the final plan. 

With respect to the proposed TIP an economic, small business, consumer impact statement should be performed by 

GRIC. The Impact Statement would provide a comprehensive economic and technical review of the candidate 

control measures necessary for compliance. For example, the TIP does not identi@ the emission reductions expected 

from the imposition of various control practices, nor does it calculate the expected reduction in emissions per dollar 

spent on control. Without this analysis, it is impossible to determine whether the proposed controls are effective at 

all, let alone cost-effective. It is not enough to simply include a measure used in another jurisdiction without 

conducting a GRIC-specific economic and technical feasibility analysis. 

AGC would like to request consideration of alternative emission controls. This approach will provide benefits to all 

because it would foster control technology innovation by allowing regulated companies to develop and implement 

improved control measures that address the specific and unique conditions they face. This provision was implemented 

in Pirna County and has been found to be an effective way to control emissions. By including a provision in Section 

V of the TIP for alternative measures that achieve equivalent or better emissions control, contractors are provided the 

opportunity to demonstrate why a control measure is not possible, applicable or effective in a specific situation and to 

make a showing of an equivalent or better alternative that would meet the requirements of the rule. 
PARTBV. Area Source Emission Limits 

4.0 Unpaved Parking Lots - Please include water as an option to employ on unpaved parking lot surfaces. 

Do you have a list of palliatives accepted by GIUC for use on unpaved parking lots? 

5.0 Unpaved HauVAccess Road -Please include water as an option to employ on unpaved hauVaccess road 

surfaces. Do you have a list of palliatives accepted by GRlC for use on unpaved hauVaccess roads'? 

6.2 Require only a primary control measure be identified for each fugitive dust source in 

the dust control plan. Requiring contingency measures have no effect on emission reduction. If the 

primary control measure is not working, contractors should cease operations until the primary control 

measure becomes the effective means of controlling emissions. 

6.4. Normal farming practices should have a section which states this does not include 

certain farm practices that create fugitive dust emissions greater than 20% opacity. 

7.3A. Require only a primary control measure be identified for each fugitive dust source 

in the dust control plan. Requiring contingency measures have no effect on 

emission reduction. If the primary control measure is not working, contractors 

should cease operations until the primary control measure becomes the effective 

Means of controlling emissions. 

10.5 Open Storage Piles 

10.5(B) 1. - Stockpiles are active and routinely change shape or position. They cannot be covered. During 

a wind event covering stockpiles would create incredible safety and logistical issues. AGC does not consider 

this measure a viable option for active construction sites. 

10.5(B) 2. - Apply water to maintain a soil moisture content at a minimum of twelve (12) percent is 

unnecessary and not practical (material would be too wet to use). According to the revised AP-42 Emission 

Factors > 1.5% moisture content is considered "controlled" material. 

AGC also requests the addition of maintaining a visible crust meets stabilization requirements in this section. 

12.1(A) - AGC as well as other industry stakeholders has grave concerns with the adoption of Maricopa 

County Appendix C which would include test methods that are not currently necessary for compliance with 

the TIP. (1.e. stabilization for open areas other than construction sites) Further, Modified Method 9 is under 

litigation and should not be considered in the TIP. 

Table 1: 

Unpaved Parking Lots: add apply water as a control measure for consideration similar to language written 

in Unpaved HauVAccess Roads. 

Temporary Stabilization During Weekends, After Hours, and on Holidays: add apply water as a 

control measure for consideration similar to language written in Unpaved HauVAccess Roads. 

Once again, thank you for accepting AGC's comments to GRlC Tribal Implementation Plan. I look forward to 

meeting both of you in the near future. Please feel free to contact me, should you have questions. I can be reached at 

(602) 252-3926 or 

Sincerely, 

Amanda McGennis 

Vice President, Pubiic Affairs 
5,r<, /#,Id 

Arizona Chapter Associated General Contractors 

1825 West Ada~ns - Phoenix, Arizona 85007 (602) 252-3926 Fax (602) 252-5870 

URGENT Fax Transmission - I page total 

Request for Extension of Public Comments 

Gila River lndian Community Tribal Implementation Plan 

July 27, 2006 

To: Daniel Blair, Air Quality Specialist 

Gila River lndian Community Department of Environmental Quality 

Jane Travis, Air Quality Speclalist 

Gila River lndian Community Department of Environmental Quality 

From: Amanda McGennis, Vice President - Urban Public Affairs 

Arizona Chapter Associated General Contractors 

Re: Gila River lndian Community Air Quality Management Program 

Tribal Implementation Plan 

Mr. Blair and Ms. Travis. 

The Arizona Chapter Associated General Contractors (AGC) is a trade association representing highway heavy 

contractors statewide since 1934. The AGC has always partnered and been a major stakeholder with all agencies 

within the state that have regulated air quality. We were surprised to hear a Tribal Implementation Plan (TIP) was 

almost ready to be adopted by the Gila River lndian Community without input from this industry, particularly when 

Section 5 of your TIP pertains to activities our contractors perform on a daily basis. 

AGC has been informed that there have been public hearings as well as stakeholder meetings on the TIP. We 

understand comments are due this afternoon at 5:00 pm. I respectfully ask that you allow AGC to forward 

comments on the TIP to your office no later than 500 prn on Monday, July 31,2006. AGC would also request to be 

placed on your list of stakeholders to notify on any air quality regulations additions or revisions. 

Thank you for considering this request. I would like to arrange a meeting with you and Ms. Travis as soon as your 

schedule permits to discuss some of the concerns industry has with language included in your document. I look 

forward to meeting both of you in the near future. Should you need to contact me I have listed my information below. 

Amanda McGennis 

Arizona Chapter 

Associated General Contractors 

1825 W. Adams Phoenix, AZ 85007 

(602) 252-3926 Fax: (602) 252-5870 

amcgennis@azagc.org