Alaska Department of Environmental Conservation

Amendments to State Air Quality Control Plan

Vol. II: Analysis of Problems, Control Actions

Section III.D.2 Eagle River PM-10 Limited Maintenance Plan

Adopted

August 20th, 2010
Adopted August 20th, 2010

(This page serves as a placeholder for two sided printing)
Adopted August 20th, 2010

III.D.2-1

SECTION III.D.2 

EAGLE RIVER PM10

III.D.2.1. Introduction

LIMITED MAINTENANCE PLAN

Between 1985 and 1987 Eagle River frequently violated the national ambient air quality 

standard (NAAQS) for particulate matter air pollution with an aerodynamic diameter less 

than or equal to 10 micrometers (μm) in size. This particulate air pollution is known as 

PM10. As a consequence, in 1991 the U.S. Environmental Protection Agency (EPA)

designated a nine square kilometer area in Eagle River as a moderate nonattainment area 

for PM10 and required the submission of an air quality attainment plan to bring the area 

into compliance with the NAAQS.*

In 1991, the Municipality of Anchorage (MOA) and the Alaska Department of 

Environmental Conservation (ADEC) prepared a State Implementation Plan (SIP) to 

address the PM10 problem in Eagle River. This plan was entitled the Eagle River PM10

Control Plan. The plan identified the main source of PM10

58 FR 43084

as unpaved roads and 

outlined an ambitious road paving program to reduce emissions from this source. EPA 

approved the plan as an amendment to the SIP on August 13, 1993 ( ).

Air quality monitoring data now show that Eagle River has attained the standard. 

However, in order for EPA to formally re-designate Eagle River to an attainment area, 

the Clean Air Act (CAA) requires the State to submit a maintenance plan to EPA that 

demonstrates that the air quality control measures in place in Eagle River are sufficient to 

ensure continued maintenance of the PM10 NAAQS. Once approved by EPA, this section 

of the state’s Air Quality Control Plan, the Eagle River PM10 Limited Maintenance Plan, 

will replace the earlier Eagle River PM10

The State has delegated the responsibility for air quality planning in Anchorage and 

Eagle River to the MOA. The MOA has worked with ADEC to prepare this new plan 

using the Limited Maintenance Plan (LMP) option provided under EPA guidance. It

demonstrates that Eagle River is now in attainment with the federal air quality standard 

for PM

Control Plan in the Alaska SIP. 

10

The plan includes a request to the EPA Administrator to re-designate the Eagle River 

PM

as a result of the road paving program and that continued maintenance of the 

standard is expected for a minimum of ten years. The plan also demonstrates that Eagle 

River qualifies for the LMP option and meets the SIP planning requirements stipulated in 

the Clean Air Act.

10

It should be noted that this plan is predicated on the presumption that EPA will approve 

an exceptional event waiver for a PM-10 exceedance that occurred due to high winds on 

December 2, 2007. 

nonattainment area to attainment.

 

* Under the Clean Air Act, states are ultimately responsible for the submission of air quality plans. These 

plans are known as SIPs or State Implementation Plans.
Adopted August 20th, 2010

III.D.2-2

III.D.2.2. Local Planning Process

This plan was prepared in accordance with the provisions of sections 110 and 174 of the 

CAA which require the consultation and participation of local political subdivisions and 

local elected officials. Under Section 174 (42 U.S.C. 7504), the revised plan submitted to 

EPA as a formal SIP amendment must be prepared by "an organization certified by the 

State, in consultation with elected officials of local governments." Such an organization 

is required to include local elected officials and representatives of the state air quality 

planning agency (i.e., ADEC), the state transportation planning agency (i.e., Alaska 

Department of Transportation & Public Facilities (ADOT/PF), and the metropolitan 

planning organization (MPO) responsible for the transportation planning process for the 

affected area. 

In 1976, the governor designated the MOA as the MPO for the Anchorage urbanized area 

which includes Eagle River. In Anchorage, the MPO is known as Anchorage 

Metropolitan Area Transportation Solutions or AMATS. Consequently, the MOA 

conducts the transportation planning process required under federal regulation, in 

cooperation with ADEC and ADOT/PF, through the AMATS organization. In 1978, the 

governor designated MOA as the lead air quality planning agency in Anchorage. Based 

on this designation, MOA has continued its role as the lead planning agency in the 

Anchorage area and prepared this plan. The air quality planning process is outlined in the 

AMATS Intergovernmental Operating Agreement for Transportation and Air Quality 

Planning. This agreement was last revised in August 2002 and became effective January 

1, 2003. This operating agreement establishes the roles and relationships between 

governmental entities involved in the Anchorage air quality planning process. 

The AMATS Policy Committee provides guidance and control over studies and 

recommendations developed by support staff. Voting members of the Policy Committee 

are listed below. 

MOA Mayor;

ADOT/PF Central Regional Director;

MOA Assembly representative;

MOA Assembly representative; and

ADEC Commissioner or designee.

The AMATS Technical Advisory Committee (TAC) and member support staff analyze 

transportation and land use issues and develop draft recommendations for the Policy 

Committee. Voting members include the following:

MOA Traffic Director;

MOA Project Management and Engineering Director;

MOA Planning Director;

MOA Public Transportation Director;

MOA Department of Health & Human Services representative;

MOA Port of Anchorage Director;

ADOT/PF Chief of Planning & Administration;

ADOT/PF Regional Pre-Construction Engineer;
Adopted August 20th, 2010

III.D.2-3

ADEC representative;

Alaska Railroad representative; and

AMATS Air Quality Advisory Committee representative.

In addition, to help provide public input into the current air quality planning process by 

interested local groups and individual citizens, a third AMATS committee, the Air 

Quality Advisory Committee was appointed by the Policy Committee. The Air Quality 

Advisory Committee is comprised of nine members. Committee membership has 

generally included at least one physician or health professional, a representative of the 

I/M industry, a representative of the environmental community, and a representative from 

the Municipal Planning and Zoning Commission.

Section 110(a) of the CAAA (42 U.S.C. 7410(a)) requires that a state provide reasonable 

notice and public hearings of SIP revisions prior to their adoption and submission to 

EPA. To ensure that the public had adequate opportunity to comment on revisions to the 

Anchorage air quality attainment and maintenance plans, a multi-phase public 

involvement process, utilizing AMATS and the Anchorage Assembly was used.

Public Participation Process

AMATS Air Quality Advisory Committee – The AMATS Air Quality Advisory 

Committee held a public meeting on the limited maintenance plan on October 21, 2009.

During this meeting they recommended that the AMATS Technical and Policy 

Committees adopt the plan as submitted. 

AMATS Technical and Policy Committees – The AMATS Technical Advisory 

Committee released the limited maintenance plan for 30-day public review on September 

17, 2009; no comments were received. After reviewing the recommendation of the 

AMATS Citizen Air Quality Advisory Committee, on September 10, 2009 the AMATS 

Technical Committee recommended that the AMATS Policy Committee adopt the plan. 

Subsequent to this recommendation, the AMATS Policy Committee met on November 

19, 2009

Anchorage Assembly – The Anchorage Assembly adopted the plan during its regular 

public meeting held on January 12, 2010. A copy of Assembly Resolution AR 2010-4 is 

included in the Appendix to Section III.D.2.2.

to review and adopt the the plan. 

ADEC hearings – The final opportunity for public involvement occurs at the state 

administrative level. Prior to regulatory adoption of SIP revisions, ADEC holds public 

hearings on the revisions in the affected communities. ADEC held a public hearing on 

the Eagle River PM-10 Limited Maintenance Plan on August 2nd, 2010. This provided 

another forum for the public to comment on the air quality plan prior to state adoption 

and submission to EPA. No public comments were received. 
Adopted August 20th, 2010

III.D.2-4

III.D.2.3. Boundary of the Eagle River Maintenance Area

Eagle River is a community of about 30,000 located roughly 10 miles northeast of 

downtown Anchorage and is part of the Municipality of Anchorage. It is located at the 

end of a glacial river valley bounded on the west by Cook Inlet and on the south by the 

Eagle River and the Chugach Mountains on the northeast. Eagle River is a bedroom 

community to Anchorage and land use in the area is largely suburban and rural residential 

with some commercial development. When the Eagle River PM10

A description of the maintenance area boundary follows. 

Control Plan was 

prepared in 1991, it identified a nine square kilometer nonattainment area that 

encompassed all of the central business district and most of the more densely populated 

suburban sections of the community. This maintenance plan retains this same boundary. 

It will become the maintenance area boundary effective upon approval of this plan. 

Beginning from the point where the centerline of the southbound section of the Glenn 

Highway crosses Eagle River, thence

Northward three kilometers to point approximately 200 meters west of the Glenn 

Highway along the westward extension of Mercy Street, thence, 

Eastward along the alignment of Mercy Street two kilometers to an undeveloped point, 

thence,

Southward two kilometers to a point approximately 150 meters west of Eagle River 

Loop Road and approximately 70 meters southwest of the intersection of Kantishna and 

Iditarod Streets (near the point where the Loop road crosses Meadow Creek); thence, 

Eastward three kilometers to an undeveloped point; thence,

Southward one kilometer to a point approximately 100 meters southeast of the 

intersection Eagle River Road and Greenhouse Street, thence,

Westward five kilometers approximately 70 meters south of the alignment of Eagle 

River ending at the centerline of the southbound section of the Glenn Highway which is 

the point of the beginning. 
Adopted August 20th, 2010

III.D.2-5

Figure III.D.2-1

Eagle River PM10 Limited Maintenance Area Boundary

with Parkgate PM10 Monitoring Site
Adopted August 20th, 2010

III.D.2-6

III.D.2.4. Demonstration that Eagle River has Attained the PM10 NAAQS

The EPA designated Eagle River as a “moderate” nonattainment for PM10 on 

November 6, 1990 pursuant to Clean Air Act Section 107(d)(4)(B). The nonattainment 

designation was based on data collected at the Parkgate site in Eagle River. The primary 

and secondary NAAQS for PM10 is set at 150 micrograms per cubic meter (μg/m3

Monitoring has been performed in the nonattainment area at the Parkgate monitoring site

since 1985. The Parkgate site is located on the east side of a commercial strip that runs 

along the Old Glenn Highway. The land use to the north, west and east of the site is 

generally commercial while the land to the east is primarily residential. Prior to 1988, this 

site was bounded on two sides by gravel roads. The location of the site is identified in 

Figure III.D.2-1, presented earlier in this section.

). The 

NAAQS used to also include an annual average standard but that standard was recently

revoked by the EPA (71FR 61144; October 17, 2006).

Figure III.D.2- 2

Looking North from the Parkgate Site in Eagle River (2006)

In 1987 there were over 22 miles of unpaved gravel roads in the nonattainment area. The 

Eagle River PM10 Control Plan called for paving or surfacing about one-third of the 

unpaved roads in the area. By 2007, all roads in the area had been paved or surfaced with 
Adopted August 20th, 2010

III.D.2-7

recycled asphalt. As illustrated in Figure III.D.2-3, data suggest that paving has 

successfully lowered PM10 concentrations. Exclusive of natural events, the highest PM10

concentrations measured since 1988 have been roughly half the 24-hour standard. 

Figure III.D.2-3

First and Second Highest 24-Hour Average PM10

Parkgate Site, Eagle River (1985-2007)

Concentrations

PM10

Starting December 1989, Mt. Redoubt, about 100 miles southwest of Eagle River, 

erupted intermittently for six months. On April 12, 1990, the 24-hour average PM

concentrations measured in the Eagle River non-attainment area have been well 

below the NAAQS for over 15 years. The only incidents that have approached or 

exceeded the 24-hour NAAQS since 1988 were due to ash from volcanic eruptions or

wind/dust storms.

10

concentration reached 143 μg/m3

. However polarized light microscopic (PLM) analysis

of PM10 filters deployed on April 7, 9, and 11 showed that volcanic ash comprised 40-

50% of the total PM10 

The eruption of Mt. Spurr (approximately 80 miles west of Eagle River) on August 18, 

1992 also raised PM

assemblage (Microlab Northwest Laboratory Report No. 1062-94, 

October 17, 1994).

10 concentrations in both Anchorage and Eagle River for an extended 

period following the eruption. PLM analysis indicated that the ash content of the PM10

was 87-95% of total assemblage immediately after the eruption (August 19 and 20) and 

remained as a major component (20-38%) of the PM10 for several years. On September 

16, 1992 concentrations reached 165μg/m3 at the Parkgate site in Eagle River, an 

exceedance of the 24-hour standard. Similarly high concentrations were observed at other 

PM10

0

100

200

300

400

500

600

1985 1990 1995 2000 2005

Year

PM10 (ug/m3

)

1st Max

2nd Max

Street clean-up, 

paving program 

starts (1988)

Mt. Spurr 

eruption (1992)

exceptional 

events due to 

strong wind

24-hr standard 

(150 ug/m3

)

Mt. Redoubt 

eruption 

(1989-90)

monitors in the Anchorage bowl. This event was attributed to re-entrained volcanic 

ash.
Adopted August 20th, 2010

III.D.2-8

The Eagle River PM10 Control Plan identified fall “freeze-up” and spring “break-up” as 

the two periods when the highest PM10 concentrations occur and it focused on controlling 

emissions during those times. Figure III.D.2-4 compares PM10 concentrations before 

paving (1985-87) with concentrations over the past ten years (1998-2007) after the 

completion of the paving program. The largest declines in Eagle River PM10 have been 

observed in the fall period. The data show that the 95th percentile PM10 concentration 

during fall freeze-up has dropped by about 75% while the concentration during spring 

break-up has fallen 5% to 20%. These declines are roughly consistent with those 

predicted in 1991 when the Control Plan was drafted. In the late-80’s and early-90’s, 

high fall season PM10 concentrations were a greater concern than spring. The highest 

PM10 concentrations in Eagle River now typically occur in spring break-up rather than 

the fall freeze-up period. 

Figure III.D.2-4

95th Percentile PM10

Implementation of Road Paving Program in Eagle River

Concentrations Before and After

The highest, second highest and number of days exceeding the NAAQS are tabulated in 

Table III.D.2-1 for the period 1998-2007. The table provides clear evidence that Eagle 

River is in attainment with the NAAQS.

0

50

100

150

200

250

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

PM10 Concentration (ug/m3

)

Before Paving (1985-1987)

After Paving (1998-2007)
Adopted August 20th, 2010

III.D.2-9

Table III.D. 2-1

Maximum, 2nd

Year

Maximum and Number of Exceedances at

Parkgate Site, Eagle River 1998-2007

24-hour Max

(μg/m3

2

)

nd Highest

24-hour

(μg/m3

Number of Days 

Exceeding

) NAAQS

1998 59 55 0

1999 90 66 0

2000 64 53 0

2001 69 66 0

2002 46 40 0

2003 92 # 90 0

2004 70 43 0

2005 90 65 0

2006 65 60 0

2007 48 # 46 0

#

Note: This table does not include wind-related exceptional events that occurred in 2003 and 

2007. The 24-hour PM10 concentration was 590 μg/m3 on March 12, 2003, and 223 μg/m3 on 

December 2, 2007.

III.D.2.5. Demonstration that Eagle River Qualifies for the LMP Option 

On August 9, 2001 EPA issued guidance on streamlined maintenance plan provisions for 

certain PM10 nonattainment areas seeking redesignation to attainment (Limited 

Maintenance Plan Option for Moderate PM10 Nonattainment Areas, Wegman 2001). 

The EPA observed that areas meeting certain statistical criteria have a high degree of 

probability of continued compliance with the NAAQS. Based on this analysis, they 

developed specific criteria to qualify for the LMP option. Elements of these criteria 

follow:

1. The area should be attaining the PM

LMP Qualification Criteria

10

2. The average 24-hour PM

NAAQS; 

10 design value (DV) for the area, based on the most recent 

five years of air quality data at all monitors in the area, should be at or below 

98 ug/m3 with no violations at any monitor in the nonattainment area;*

3. The area should expect only limited growth in on-road motor vehicle PM

and

10

 

* EPA also established a procedure for determining an alternate, site-specific criteria (called the Critical 

Design Value) that allows area with design values with little inter-annual variability to qualify for the LMP 

option if their DV is above 98 μg/m3

.

emissions (including fugitive dust) and should have passed a motor vehicle regional 

emissions analysis test.
Adopted August 20th, 2010

III.D.2-10

The next three sub-sections will demonstrate that Eagle River meets these three criteria.

1. Eagle River is attaining the PM10

Section II.D.2-4 provided a demonstration that Eagle River has been in attainment with 

the NAAQS for over 15 years. Except for uncontrollable natural events such as volcanic 

eruptions and wind/dust storms, Eagle River last exceeded the NAAQS in 1987.

NAAQS

2. The average DV for the Eagle River area is below 98 ug/m

Computational methods for determining the 24-hour DV are outlined in the PM

3

10 SIP 

Development Guideline (EPA-450/2-86-001, June 1987). The empirical frequency 

distribution approach (see Section 6.3.3. of the guideline) was used to determine the DV 

which is defined as the site-specific PM10 concentration that would be expected to be 

exceeded at a frequency of once every 365 days. Table III.D.2-2 shows that Eagle River 

has a computed DV for the last 5 years that is below the LMP criteria of 98 μg/m3

(details of this computation can be found in the Appendix to III.D.2.5.). The table also 

demonstrates that there is no increasing trend over the last decade. Exceedances of the 

NAAQS were recorded on March 12, 2003 and December 2, 2007. Both incidents, 

however, have been flagged as exceptional events due to blowing dust from high winds. 

These incidents were therefore not considered when determining attainment or included 

in the DV computation. 

Table III.D. 2-2*

Parkgate Site, Eagle River 1998-2007

DV Computed from Empirical Data Distribution

Three-year Period Used to 

Compute DV

DV

(computed from empirical 

data distribution of 3 years 

data)

(μg/m3

1998-2000

)

84.5

1999-2001 95.5

2000-2002 89.7

2001-2003 108.0

2002-2004 94.1

2003-2005 102.7

2004-2006 88.2

2005-2007 86.0

Average DV for the last 5 years 

(2003-2007) 92.3

LMP criteria 98.0

 

* Assuming that EPA accepts data from 12/2/07, 10/30/09 and 10/31/09 as exceptional events, the 

computed DV was 81 ug/m3 for 2006-08 and 85 ug/m3 for 2007-09.
Adopted August 20th, 2010

III.D.2-11

3. Eagle River Passes Motor Vehicle Regional Emissions Analysis Test

Increases in emissions from on-road mobile sources must be taken into account over the 

next 10 years to help ensure that PM10 concentrations will remain below the NAAQS.*

Projected DV in 2020 = DV

 

The EPA LMP guidance recommends the use of the following equation to assess the 

impact of future emission increases from motor vehicle travel:

2007 + (VMTpi x DVmv

Where:

) ≤ MOS

DV = the area’s average DV in μg/m3

VMT

for the period used to demonstrate 

attainment (base year 2007). 

pi =

DV

the projected % increase in vehicle miles traveled (VMT) between 2007 and 

2020.

mv = Portion of DV for the attainment year (2007) inventory in μg/m3

MOS = margin of safety for the relevant PM

that is 

derived from on-road emissions

10 standard in μg/m3 for a given area. 

This can be = 98 μg/m3 or a site-specific value computed from data 

collected at the site of interest using methods outlined in Attachment A of 

the LMP guidelines. For the Parkgate site in Eagle River this value was

computed to be 116.6 μg/m3

. (See Appendix to III.D.2.5 for details of this 

computation.)

In the preceding sub-section, the average DV was computed to be 92.3 μg/m3

VMT

. 

pi was estimated using VMT estimates made for the air quality conformity analysis 

for the Chugiak/Eagle River Long Range Transportation Plan (CE/LRTP). The analysis 

included VMT estimates for analysis years 2007, 2017, and 2027. for the Eagle River 

PM10 non-attainment area. Total VMT in 2007 was 165,934. VMT for year 2020 was 

estimated by interpolating between 2017 and 2027 VMT. By 2020, VMT is projected to 

grow by 36.3% to 226,221. Thus the projected increase in VMT (VMTpi

As will be shown in the PM

) is 0.363.

10 emission inventory presented later in Section III.D.2.6, the 

proportion of total PM10 from on-road mobile emissions varies with season in the Eagle 

River maintenance area. In the base year 2007 emission inventory, on-road mobile 

emissions, including fugitive dust emissions, were responsible for 50.6% of total daily 

emissions in spring and 44.4% in the fall (see Table III.D.2-3 for details). For the 

purposes of the Motor Vehicle Regional Emissions Analysis Test, the higher spring 

season proportion was assumed. The portion of 2007 DV that is attributed to on-road 

mobile sources (DVmv) can be readily calculated as follows:

DVmv = DV x 0.506 = 92.3 μg/m3x 0.506 = 46.7 μg/m3

 

* This emissions analysis demonstration assumes that EPA will re-designate Eagle River a maintenance 

area in 2010. The year 2020 was selected because it is ten years hence.
Adopted August 20th, 2010

III.D.2-12

Knowing the values of the four variables, the projected DV in 2020 can be readily 

computed:

Projected DV in 2020 = DV2007 + (VMTpi x DVmv

 = 93.6 μg/m

)

3 + (0.363 x 47.4 μg/m3

Projected DV in 2020 = 109 μg/m

)

3 < MOS 

The projected DV in 2020 is less than the 116.6 μg/m3 margin of safety value or MOS, 

demonstrating that the Eagle River Maintenance Area meets the Motor Vehicle Regional 

Emissions Analysis Test.

III.D.2.6. Attainment Year Emission Inventory for Eagle River

The base year attainment inventory for this LMP was selected to be 2007. An emission 

inventory was also prepared for 2020, the final year of a ten-year maintenance period.

*

As noted in Section III.D.2.4, over the past ten years the highest PM10

Five sources of PM

concentrations 

have typically occurred during spring break-up and fall freeze-up. For this reason, the 

emission inventories reflect conditions and activity levels (e.g., amount of silt loading on 

roads, residential wood heating rates) that commonly occur during these two times of 

year. The assumptions, methods and computations used to generate the 2007 and 2020 

emission inventories are described in detail in the Appendix to III.D.2.6. 

10

The emission inventory prepared for the Eagle River PM

emissions were identified and inventoried. These include (1) dust 

from paved roads; (2) wind-generated dust from roads, parking lots and un-vegetated 

areas; (3) fireplaces and woodstoves, (4) natural gas combustion; and (5) exhaust, tire and 

brake wear emissions from motor vehicles.

10

The EPA publication, AP-42, Compilation of Air Pollutant Emission Factors, outlines 

recommended assumptions and methods for estimating emission factors for various 

sources.

Control Plan (base year 1987) 

also included emission estimates for unpaved roads. However, as noted earlier in this 

document, all roads in the maintenance area have been paved since that plan was 

prepared. Thus, unpaved road emissions are not included in the 2007 or 2020 

inventories.

†

 

* Again, this assumes that EPA will approve this maintenance plan in 2010.

 AP-42 methods were used to estimate emission factors for four of the five 

sources inventoried. Instead of AP-42, the EPA mobile source emission factor model, 

MOBILE6.2 was used to estimate the emission factor for motor vehicle exhaust, tire and 

brake wear emissions. Methods, assumptions and computations are described in detail in 

the Appendix to III.D.2.6. 

† An emission factor is a representative value that attempts to relate the quantity of a pollutant release to the 

atmosphere with an activity associated with the release of that pollutant.
Adopted August 20th, 2010

III.D.2-13

The results of the inventory are presented in Table III.D.2-3. Paved road dust, wind 

blown dust and fireplace and wood stove emissions are the main sources of PM10

Table III.D. 2-3

in the 

Eagle River maintenance area.

Eagle River Limited Maintenance Area PM10

(All Emissions in tons/day with % of Total)

Emissions Inventory

Spring Break-up

(March, April)

Fall Freeze-up

(October, November)

Source Category 2007 2020 2007 2020

Paved Roads

2.88 

(50.6%)

3.97

(57.8%)

0.83

(44.4%)

1.13

(50.8%)

Wind blown Dust from Paved Roads, Parking 

Lots and Un-Vegetated Areas 

2.47

43.5%

2.53

(36.8%)

0.70

(37.6%)

0.72

(32.5%)

Fireplaces and Wood Stoves 

0.32

(5.7%)

0.36

(5.2%)

0.32

(17.3%)

0.36

(16.1%)

Natural Gas Combustion

0.008

(0.1%)

0.009

(0.1%)

0.008

(0.4%)

0.009

(0.4%)

Exhaust, Tire and Brake Wear Emissions 

from Motor Vehicles

0.005

(0.1%)

0.006

(0.1%)

0.005

(0.3%)

0.006

(0.3%)

TOTAL

5.69

(100%)

6.87

(100%)

1.87

(100%)

2.22

(100%)

III.D.2.7. Section 110 and Part D Requirements

Before the EPA administrator can re-designate an area to attainment the CAA requires

that a state containing a nonattainment area meet all applicable requirements including 

those in Section 110 and Part D of the Act. Section 110 of the Act outlines requirement 

for SIPs and Part D contains general requirements applicable to all designated 

nonattainment areas. Subpart 4 of Part D includes specific provisions for particulate 

matter nonattainment areas.

EPA designated Eagle River as a “moderate” nonattainment for PM

Section 110

10 on November 6, 

1990 pursuant to Clean Air Act Section 107(d)(4)(B). EPA required nonattainment areas 

like Eagle River to prepare plans to attain the standard. The approval of the Eagle River 

nonattainment plan by EPA in 1993 is evidence that applicable requirements of Section 

110 have been satisfied. EPA approved the Eagle River PM10 attainment plan (58 FR 

43084) as an amendment to the Alaska SIP for air quality on August 13, 1993. 

There are a number of requirements in Part D that are pertinent to the approval of the 

Eagle River LMP. These include requirements for air quality monitoring, contingency 

measures, and transportation conformity. These are addressed later in this document. 

Part D Requirements

The Part D NSR rules for PM10 nonattainment areas in Alaska were approved by EPA.

In Eagle River, NSR requirements will be replaced by the Prevention of Significant 
Adopted August 20th, 2010

III.D.2-14

Deterioration (PSD) program in the maintenance area NSR program upon effective date 

of redesignation. The federal PSD regulations found in 40 CFR 52.21 are the PSD rules 

in effect for Alaska. These regulations will apply after Eagle River is redesignated as a 

maintenance area.

Subpart 4 of Part D established an attainment date of December 31, 1994 for Eagle River. 

Eagle River met this deadline. In addition, a milestone report demonstrating that Eagle 

River met the milestone requirements was submitted by MOA and approved by EPA in 

1995 as required.

III.D.2.8. Maintenance Demonstration 

EPA guidance on the LMP option (Wegman, 2001) states that if an area qualifies for the 

LMP option “demonstration of maintenance is presumed to be satisfied.” Section 

III.D.2.4 of this document shows that monitored PM10 concentrations in Eagle River are 

low and “stable” enough to qualify for the LMP option. Thus, Eagle River has satisfied 

the maintenance demonstration requirement. 

III.D.2.9. Demonstration of Permanent and Enforceable Emission Reductions

As noted earlier in Section III.D.2.4, a large decline in PM10

The MOA and the Alaska Department of Transportation and Public Facilities 

(ADOT&PF) have also implemented permanent changes in street maintenance practices

on paved roads. Both the MOA and ADOT&PF have set new winter traction sand 

specifications that limit the amount fines or silt allowed in the material that is applied to 

roads within the MOA. In addition, the MOA is continuing to explore new and more 

efficient ways to improve road traction during snow and ice conditions without 

compromising air quality. New methods for controlling PM

concentrations has been 

observed in Eagle River and this decline is attributed primarily to the paving of local 

gravel roads in the area. In 1987, almost one-half of all the roads in the area (22 miles) 

were unpaved. By 2007 all of these roads were paved either with traditional hot asphalt 

paving or surfaced with RAP. The MOA is committed to the maintenance of these roads. 

In particular, all RAP-surfaced roads in the maintenance area have now been chip-sealed 

to improve their durability. The effective lifetime of these chip-sealed roads is estimated 

to be 10 to 15 years. When these roads have reached the end of their lifetime a new lift 

of chip seal (a mix of crushed aggregate or “chips” and asphalt emulsion) is applied 

which serves as a new wearing course for the road.

10

Eagle River has not violated the NAAQS since 1988; this is clear evidence that the 

controls implemented have provided permanent and enforceable emission reductions. 

The Anchorage Assembly recently adopted a revised land use code that requires paving 

during the spring break-up 

period are being investigated. These include the use of chemical dust palliatives and the 

use of new technology “waterless” sweepers which offer promise of more thorough 

clean-up of roadways.
Adopted August 20th, 2010

III.D.2-15

of all streets except those in low density residential areas zoned R-6, R-7, R-8 or R-9.

*

Although most of the Eagle River maintenance area is “built out” and few new roads are 

likely to be constructed, the requirements stipulated in Anchorage Municipal Code 

21.08.050 will help ensure that new streets constructed in the Municipality, including 

Eagle River, will not cause new PM10

The MOA is committed to continued maintenance of existing RAP/chip-sealed roads in 

the maintenance area and the MOA and ADOT&PF are committed to maintaining 

traction sand specifications that allow no more than 2% fines or silt. All controls that 

were relied on to demonstrate attainment will remain in place.

problems.

III.D.2.10.Compliance with Air Quality Monitoring Requirements and Verification 

of Continued Attainment

According to CAA Section 110(a)(2), once an area is redesignated, the State must 

continue to operate an appropriate air monitoring network in accord with 40 CFR Part 58 

to verify the attainment status of the area. The ADEC has delegated responsibility for air 

quality monitoring to the MOA. The MOA is committed to the continued operation of at 

least one EPA-approved PM10

Monitoring will be used to verify continued maintenance of the standard through the 

maintenance plan period. The MOA will annually recalculate the design value using the 

most recent five years of monitor data in order to verify the area continues to qualify for 

the LMP option. The result will be reported to the EPA.

monitoring site in the Eagle River maintenance area 

through the end of the maintenance planning period (2020). Monitoring will be 

conducted in accordance with 40 CFR Part 58. 

In the event the area does not continue to qualify for the LMP option a full maintenance 

plan will be prepared as required by the LMP policy.

III.D.2.11.Natural Events Action Plan

The MOA prepared a Natural Events Action Plan (NEAP) entitled A Natural Events 

Action Plan for Windblown Dust Events in Anchorage Alaska in September 2002. This 

plan was submitted to ADEC in response to a wind blown dust-related exceedance that 

occurred in Anchorage on March 18, 2001. ADEC forwarded the NEAP to EPA; EPA 

approved it on May 5, 2003. A copy of the NEAP is included in the Appendix to

III.D.2.11.

One of the most important features of the NEAP is that it outlines procedures for issuing 

health advisories to help reduce PM10 exposure to the public during the events. However 

the issuance of health advisories for the Eagle River area have been impeded by a lack of 

“real time” PM10 monitoring data. Up until 2008, all PM10

 

* R-6, R-7, R-8 and R-9 are residential zoning designations defined in Title 21 of the Anchorage Municipal 

Code. R-7 zoning allows between one and two dwelling units per acre. The maximum dwelling unit 

density allowed in R-6, R-8 and R-9 varies from one per acre (R-6) to one per four acres (R-9). 

data in Eagle River was 
Adopted August 20th, 2010

III.D.2-16

collected using federal reference method (FRM) monitors. Because FRM monitoring 

requires that PM10 filter samples be retrieved after the required 24-hour sampling period, 

the data necessary to declare a health advisory are not available until the event is over.

Although a health advisory was declared for the March 12, 2003 exceptional event in 

Eagle River, no such advisory was declared for the December 2, 2007 wind-blown dust 

episode.* The MOA has now installed “real time,” continuous PM10 monitoring 

equipment in Eagle River that should remedy this shortcoming. 

III.D.2.12.Contingency Provisions

Section 175A of the CAA requires that a maintenance plan include contingency measures 

in order to promptly correct any violation of the standard that occurs after the 

redesignation of the area to attainment.†

This section identifies a process and a timeline to identify and evaluate appropriate 

contingency measures in the event of a violation of the PM

Normally, the implementation of contingency 

measures is triggered by a violation of the NAAQS. Contingency measures do not have 

to be fully adopted at the time of redesignation, but they must be readily adopted if they 

are triggered.

10 NAAQS. 

Within 30 days following a violation of the PM

Contingency Measures Assessment

10

Within 120 days of the violation, the assessment team will prepare a report that identifies

the cause or causes of the violation and recommends appropriate measures for mitigating 

future violations. The report shall be presented to the AMATS Policy Committee for 

review and adoption and then forwarded to the ADEC for approval.

NAAQS, the MOA will convene an 

assessment team to identify control measures that appropriately address the source(s) and 

circumstances causing the violation.

The report should include an analysis of the PM10 monitoring data before and after the 

violation and a discussion of how the PM10 

 

* A health advisory was issued during the March 12, 2003 episode because data from “real time” monitors 

in Anchorage indicated very high PM10 levels. Although data in Eagle River, 10 miles north were not

available, PM10 concentrations were presumed to be high there also. However, on December 2, 2007 real 

time data from Anchorage suggested that PM10 concentrations were not likely to exceed the NAAQS. 

Without specific data for Eagle River, it was assumed that an exceedance was also unlikely there and no 

health advisory was declared.

source or sources leading to the violation 

were determined. Other possible contributing factors such as weather conditions should 

be discussed. The effectiveness of existing controls, particularly those included in this 

† The Eagle River PM10 Control Plan drafted in 1991 included two contingency measures. The first 

contingency measure called for the surfacing of two additional miles of gravel roadway in the 

nonattainment area with RAP. The second called for “sweetening” existing RAP roads with asphalt 

emulsion to improve their PM10 reduction effectiveness. Even though these measures were never triggered 

by a violation of NAAQS, all roads in the nonattainment area have now been surfaced with RAP or paved. 

In addition, all RAP roads have been enhanced with a chip-seal coating to improve their effectiveness at 

reducing dust and to increase their durability.
Adopted August 20th, 2010

III.D.2-17

maintenance plan, should be discussed and any lapses in the implementation of such 

controls should be identified.

The assessment team shall review the list of possible contingency measures offered in 

this Plan and recommend the implementation of one or more for them to address the 

source or sources of the PM10 

Local actions resulting from the assessment team recommendations will be at the 

discretion the Municipal Mayor and Assembly. Several of the possible contingency 

measures would require changes to local ordinance by the Anchorage Assembly before 

they could be implemented.

violation. The team has the option of recommending 

alternative measures not included on this list if circumstances warrant.

The attainment inventory suggests that the primary sources of PM

List of Potential Contingency Measures

10 in Eagle River are 

traffic-related paved road dust emissions, wind-blown dust emissions from roadways, 

parking lots and cleared areas, and fireplace and wood stove emissions. As such, if a 

future violation were to occur, a combination of one or more of these sources is most 

likely to be the cause.

A list of potential contingency measures for each of these three sources follows:

Traffic-Related Paved Road Dust

1. Apply chemical dust palliatives to high volume roadways upon prediction of high 

PM10

The highest emissions typically occur along major roads during the spring break-up 

period when they are heavily laden with a winter’s worth of accumulated traction 

sand and other road sediment. Road sediment accumulates primarily in gutters, 

shoulders, medians and in the dividing strip between turn lanes and through lanes of 

high volume roadways. During the spring break-up period of 2008 the MOA 

performed a field study of the dust palliative magnesium chloride brine (MgCl

.

2).*

The study concluded that absent significant precipitation, an application of MgCl2

substantially reduced dust emissions for at least a week after application. This 

suggests that MgCl2 could be used to mitigate roadway PM10

2. Sweep major roadways prior to spring break-up and other periods when elevated 

PM

emissions when 

concentrations are predicted to approach or exceed the NAAQS.

10

Although sweeping has been included here as a potential contingency measure, it 

should be noted that its effectiveness and practicality as a control measure during the 

spring break-up period is questionable. Many studies have shown that without 

extensive back-flushing, traditional mechanical sweeping methods do not effectively 

is anticipated.

 

* A draft report, entitled Field Evaluation of Suitability of Magnesium Chloride Brine for PM10 Control on 

Paved Roads in Anchorage was completed by the MOA Department of Health and Human Services in 

September 2008.
Adopted August 20th, 2010

III.D.2-18

reduce PM10 emissions. In late March and early April when PM10 is often highest, 

subfreezing temperatures make the use of water back-flushing impractical. 

Moreover, ice and snow on roadway shoulders prevent effective sweeping where the 

road is most heavily laden with sediment. The MOA is experimenting with 

alternatives to “traditional” sweeping such as post-sweep application of a dust 

palliative and/or “double-pass” waterless sweeping. The MOA plans to continue to 

experiment with alternative sweeping procedures and one or more may prove viable 

as a contingency measure in the future.

Wind-blown Dust from Roadways, Parking Lots and Cleared Areas

1. Implement one or more of the traffic-related paved road dust measures discussed 

above.

Paved roadways comprise over 75% of the cleared area in the Eagle River PM10 

maintenance area. Thus, the same measures suggested for controlling traffic-related 

PM10 emissions are suitable for reducing wind-blown dust. For example, the 

application of MgCl2

2. Require application of dust palliatives to paved parking areas.

brine would also be expected to reduce wind-generated dust 

from roads.

Parking lots, playgrounds and other similar paved areas comprise about 20% of the 

cleared area in the maintenance area. The application of dust palliatives to these areas 

would be expected to reduce emissions.

3. Establish required specifications for traction sand materials applied to parking lots.

Currently there are no requirements placed on the quality or quantity of traction sand 

materials applied to parking lots. New MOA regulations could be established that 

would limit the amount of fines or silt allowed in the traction sand applied to 

contiguous parking lots and paved areas greater than five acres in size, for example.

Fireplaces and Wood Stoves

1. Curtail fireplace and wood stove use when high PM10

Although fireplace and wood stove emissions currently make up a relatively small 

part of total PM

is predicted.

10 emissions, it is possible that future increases in natural gas heating 

costs could drive more households to heat with wood. If this is the case, emissions of 

PM10 would increase over time. Presumably air quality monitoring data would 

provide evidence if such a trend were occurring. An increase in wood heating would 

likely jeopardize attainment of the PM2.5 (fine particulate) NAAQS before PM10. 

Nevertheless, in some circumstances it may be appropriate to consider regulating fire 

place and wood stove use as means to addressing PM10 violations.
Adopted August 20th, 2010

III.D.2-19

III.D.2.13. Air Quality Conformity for LMP Areas

The transportation conformity rule and general conformity rule apply to nonattainment 

and maintenance areas. Under either rule, an acceptable method of demonstrating that a 

federal action conforms to the applicable SIP is to demonstrate that expected emissions 

from the planned action are consistent with emissions budget for the area.

Although EPA policy does not exempt LMP areas from the need to demonstrate 

conformity, it allows the area to do so without submitting an emissions budget, because 

data demonstrates no violation of the NAAQS will occur due to reasonable growth 

projections. For transportation purposes, the emissions in a qualifying LMP area need 

not be capped for the maintenance period and thus no regional emissions analysis is 

required. Regional transportation conformity is presumed due to the limited potential for 

emission growth in the area during the LMP period. A regional emissions analysis and 

associated regional conformity requirements (40 CFR 93.118 and 93.119) are no longer 

necessary. Similarly, federal actions subject to the general conformity rule would 

automatically satisfy the “budget test’ specified in Section 93.158(a)(5)(i)(A) for the 

same reasons.

When Eagle River is designated by EPA as a LMP, transportation conformity 

determinations will still be required for transportation plans, programs (TIPs) and 

projects. The conformity determination for the plan and TIP should state that a regional 

emission analysis is not required because the area has an approved LMP. The Plan and 

the TIP must still be made available for public review. The portions of the conformity 

rule that still apply are found in 40 CFR 93.112 and 93.113 and the consultation 

requirements as specified under state regulation, 18 AAC 50 .715 and 50.720. 

In addition transportation projects would still need to meet the criteria for PM10 hot spots 

(40 CFR 93.116 and 93.123) and for PM10 control measures (40 CFR 93.117). The 

MOA will work with ADEC and interested parties to develop an evaluation criteria and 

process to meet these transportation conformity requirements.

III.D.2.14. Redesignation Request

The MOA and ADEC believe this document contains all necessary information and 

adequately demonstrates that Eagle River should be reclassified to attainment under the 

LMP option. Therefore, ADEC, on behalf of the MOA, requests that EPA find this plan 

complete and approve the redesignation of the Eagle River nonattainment area to 

attainment under the LMP option.