Alaska Department of Environmental Conservation

Juneau’s Mendenhall Valley 

PM10 Limited Maintenance Plan

Adopted

February 20, 2009
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Table of Contents

III.D.3.1. Background ........................................................................................................ 1

III.D.3.2. Maintenance Area Boundary ............................................................................. 1

III.D.3.3. Limited Maintenance Plan (LMP) Requirements............................................... 1

III.D.3.4. Demonstration of PM10 Attainment .................................................................... 1

III.D.3.5. Fully Approved SIP Under Section 110(k) of the Clean Air Act ....................... 1

III.D.3.6. Historical Attainment Plan Contingency Measures............................................ 1

III.D.3.7. Approval of Section 110 and Part D Requirements............................................ 1

III.D.3.8. Air Quality Maintenance Plan ............................................................................ 1

III.D.3.9. Maintenance Demonstration ............................................................................... 1

III.D.3.10 Contingency Provisions ..................................................................................... 1

III.D.3.11 Conformity for LMP Areas................................................................................ 1

III.D.3.12 Redesignation Request....................................................................................... 1

Appendix Documents

Section III.D.3.5:

City & Borough of Juneau Ordinances # 83-63; #88-59; #91-52; #91-53; #93-01; 

#93-06; #2008-28; 

City & Borough of Juneau Resolution #2448

Fiscal Year 1994 CP-1s

City & Borough of Juneau Resolution #1612

1992/1993 Memorandum of Understanding between ADEC, ADOT/PF, and CBJ 

Section III.D.3.8:

Mendenhall Valley PM10 Emission Inventory

Section III.D.3.9:

EPA Region 10 Analysis of PM10 Design Value
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III.D.3.1-1 Adopted February 20, 2009

SECTION III.D.3 JUNEAU PARTICULATE (PM10) CONTROL PROGRAM

III.D.3.1. Background

EPA designated the Mendenhall Valley area of Alaska as a moderate nonattainment for 

the National Ambient Air Quality Standards (NAAQS) for particulate matter with an 

aerodynamic diameter less than or equal to a nominal 10 micrometers (PM10), upon 

enactment of the federal Clean Air Act Amendments of 1990 (56 FR 56694, November 6, 

1991). The nonattainment classification was based on violations of the 24-hour standard 

that occurred throughout the 1980s. The EPA fully approved Alaska’s moderate PM10

nonattainment area plan as a State Implementation Plan (SIP) revision for the Mendenhall 

Valley PM10 nonattainment area in 1994 (Federal Register: March 24, 1994). There has 

been no measured violation of EPA’s PM10 standard since 1994.

The Mendenhall Valley, surrounded by mountains on the east, west and north, is the 

largest residential area within the City and Borough of Juneau, Alaska. The mountains 

and short winter days contribute to wintertime inversions which historically have 

elevated particulate matter concentrations causing them to exceed the PM10 NAAQS. 

The Clean Air Act states an area can be redesignated to attainment if specific criteria are 

met. Section 107(d)(3)(E) of the Clean Air Act details the criteria necessary, including 

an approved maintenance plan. In August 2001, the U.S. Environmental Protection 

Agency (EPA) issued the Limited Maintenance Plan (LMP) option for more easily 

redesignating qualifying low risk moderate PM10 nonattainment areas. This option allows 

states to submit a more streamlined maintenance plan than normally required when future 

PM10 violations are unlikely.

The Alaska Department of Environmental Conservation has demonstrated, through 

ambient monitoring, that the Mendenhall Valley is highly unlikely to violate the PM10

NAAQS within the next 10 years. EPA approved the Mendenhall Valley nonattainment 

plan in 1994. In the 1980s and early 1990s, Mendenhall Valley PM emissions were 

attributed to smoke from home heating with wood and fugitive dust from travel on roads. 

The 1994 PM10 nonattainment plan included a wood smoke control program 

incorporating public education, real-time monitoring, open burning prohibitions in 

winter, new stove certification and enforcement of a borough wood smoke ordinance. 

For fugitive dust, the SIP focused on paving unpaved roads.

Monitoring data shows that the Mendenhall Valley nonattainment area last violated the 

24-hour PM10 standard in 1993 (at only the Trio Street site).* The PM10 levels measured 

since 2000 are roughly a third of the 24- hour standard and well under the 98 ug/m3

threshold established by EPA to qualify for the LMP option. Because of these low PM10

concentrations and the pollution controls and plans currently in place, the Mendenhall 

Valley is at minimal risk of violating the PM10 standard and therefore qualifies for EPA’s 

LMP option. Figure III.D.3.1-1 illustrates the trends in PM10 concentrations since the 

early 1990s.

 

*

http://www.epa.gov/aqspubl1/select.html
III.D.3.1-2 Adopted February 20, 2009

Figure III.D.3. 1-1

First and second highest daily PM10 concentrations 

measured at Floyd Dryden Middle School 

Juneau, Alaska 1992-2005.

Floyd Dryden 1st and 2nd Maximum PM10 Values

0

50

100

150

200

250

300

1992199419961998200020022004

Year

μg/m3

1st max

2nd max

24 hour standard - 150 ug/m3

This LMP demonstrates that the Mendenhall Valley meets Clean Air Act requirements 

for attainment of the NAAQS for PM10, and that the PM10 reductions seen over the past 

15 years in the Mendenhall Valley are permanent and enforceable. Since 1995, the 

Mendenhall Valley has met federal PM10 standards. The Alaska Department of 

Environmental Conservation (ADEC), through this LMP, requests EPA re-designate the 

Mendenhall Valley area as attainment.
III.D.3.2-1 Adopted February 20, 2009

III.D.3.2. Maintenance Area Boundary

The Mendenhall Valley maintenance area extends from the northern boundary of the 

Juneau Airport north through the Valley to the southern edge of the Mendenhall Glacier 

near Nugget Creek. The easterly and westerly boundaries are bound by steep ridge crests 

rising more than 1000 feet from the Valley floor. These boundaries are identical to the 

nonattainment boundary identified in the previous plan. The maintenance area boundaries 

become effective with the approval of this LMP.

Figure III.D.3.2-1

Maintenance Area Boundary
III.D.3.2-2 Adopted February 20, 2009

The sources of particulate matter within the valley include residential wood smoke, ball 

fields and playgrounds, automobile exhaust, and fugitive dust. To the north a gravel pit 

and the Mendenhall Glacier each may contribute to dust during windy conditions. On 

occasion, wildfire smoke from Western Canada has affected air quality in the Mendenhall 

Valley. 

Juneau International Airport (JIA), with 275,000 enplanements per year, is just outside 

the maintenance area at the south end of the valley, and may affect monitoring sites when 

winds are from the south. Flight operations at JIA totaled 105,487 in 2005 according to 

Federal Aviation Administration statistics. 
III.D.3.3-1 Adopted February 20, 2009

III.D.3.3. Limited Maintenance Plan (LMP) Requirements

This PM10 LMP for the Mendenhall Valley nonattainment area demonstrates how the 

LMP requirements have been met. These requirements are set out in the August 9, 2001 

EPA issued guidance on streamlined maintenance plan provisions for certain PM10

nonattainment areas seeking redesignation to attainment [entitled “Limited Maintenance 

Plan Option for Moderate PM10 Nonattainment Areas” (Wegman 2001)]. The guidance 

provides a statistical demonstration that areas meeting certain criteria will have a high 

degree of probability of maintaining the standard 10 years into the future, thus 

demonstrating maintenance of the standard as required for redesignation. To qualify for 

the LMP option:

 The area should have attained the PM10 NAAQS; 

 The average 24-hour PM10 design value for the area, based on the most recent 5 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; and

 The area should expect only limited growth in on-road motor vehicle PM10 emissions 

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

analysis test;

In addition, the LMP must include:

 an attainment year emission inventory;

 assurance of continued operation of an EPA-approved air quality monitoring network; 

and 

 contingency provisions.

The final approval of an LMP for a nonattainment area requires:

 a determination by EPA that the NAAQS has been attained.

 an EPA fully-approved PM10 state implementation plan as set out in Section 110(k) of 

the Clean Air Act.

 a determination by EPA that air quality improvement is due to permanent and 

enforceable reductions in emissions.

 a demonstration by the State that it has met all applicable requirements under section 

110 and part D of the Clean Air Act.

 Approval by EPA of this LMP, including a contingency plan, for the area designated 

under section 175A of the Clean Air Act.
III.D.3.3-2 Adopted February 20, 2009

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III.D.3.4-1 Adopted February 20, 2009

III.D.3.4. Demonstration of PM10 Attainment 

On July 1, 1987, EPA revised Title 40, Part 50, of the Code of Federal Regulations to 

change the National Ambient Air Quality Standard (NAAQS) from total suspended 

particulate (TSP) to particulate matter less than 10 micrometers in diameter (PM10). The 

primary and secondary NAAQS for PM10 standards follow:

24-Hour Standard

The NAAQS for PM10 is 150 μg/m3for 24-hour average concentration. The 

standard is attained when the expected number of days per calendar year with a 

24-hour average concentration above 150 μg/m3is less than or equal to one, as 

determined in accordance with 40 CFR 50, Appendix K.

Annual Standard

In 1987, the annual NAAQS for PM10 was set at 50 μg/m3calculated as an annual 

arithmetic mean. Due to lack of evidence linking health problems to long-term 

exposure to coarse particle pollution, the EPA revoked the annual standard on 

September 21, 2006. 

Monitored Attainment

EPA determines whether an area’s air quality meets the PM10 NAAQS based upon 

monitored data gathered in accordance with federal standards in 40 CFR Part 58. Since 

2000, measured PM10 levels are roughly a third of the 24 hour standard and well under 

the 98 μg/m3threshold established by EPA to qualify for the LMP. 

ADEC operated multiple PM10 monitoring sites in the Mendenhall Valley in the 1980s 

and 1990s. Three sites in the Mendenhall Valley were designed as part of the State and 

Local Air Monitoring Stations. Trio Street operations occurred from 1989 to 1997. The 

Glacier Auto site operated from 1988 to 1993. From 1986 onward, monitoring has 

continued for PM10 at one site, Floyd Dryden Middle School, where operations began 

initially for total suspended particulate in 1980.

The Floyd Dryden site is located on the roof of Floyd Dryden Middle School in the 

Mendenhall Valley of Juneau. The monitors are on the far side of the school from the 

parking lot. Three General Metal Works high-volume PM10 samplers operate at the site. 

These samplers are also operated on a 1 in 3 schedule with collocated sampling on every 

sixth day. The PM10 samplers were installed on January 1, 1986. The elevation for the 

monitors is 15 meters. 

The school location is suburban-residential and approximately 65 meters east of 

Mendenhall Loop Road, the main arterial intersecting the eastside of the valley. 

According to 2005 traffic counts, the Loop has an average daily traffic of 14,000 near the 

school, increasing to nearly 22,000 near its terminus with Egan Drive to the south. Floyd 

Dryden is a neighborhood-scale, population-oriented site and is not within a metropolitan 

statistical area. 
III.D.3.4-2 Adopted February 20, 2009

Table III.D.3.4-1 

1st and 2nd Highest 24-Hour PM10 Concentrations, 1992 – 2005

Floyd Dryden Middle School 

Year 1st Max 2nd Max

1992 241 207

1993* 81 79

1994 61 59

1995 86 76

1996 86 79

1997 70 63

1998 48 40

1999 28 27

2000 33 27

2001 28 28

2002 29 29

2003 26 22

2004 34 31

2005 42 35

* Although concentrations at Floyd Dryden were well below the standard in 1993, there were three 

exceedances that year at the Trio site.
III.D.3.5-1 Adopted February 20, 2009

III.D.3.5. Fully Approved SIP under Section 110(k) of the Clean Air Act

Initial Designation

The Clean Air Act requires each state to develop air pollution regulations and control 

strategies to meet the PM10 standard and other federal health-based standards. The State 

Implementation Plan (SIP) contains these regulations and strategies. The Clean Air Act 

requires states to submit SIPs to EPA for review and approval.

EPA designated the Mendenhall Valley nonattainment for PM10 and classified it as 

“moderate” upon enactment of the 1990 Clean Air Act Amendments, Section 

107(d)(4)(B). EPA required Alaska to prepare a plan to attain the standard as a revision to 

the Alaska State Air Quality Plan (SIP). Nonattainment plans must include a source 

inventory, emission estimates, projected emissions to the attainment year and control 

strategies. The must also demonstrate the adequacy of the control program and include 

contingency measures to implemented if the area fails to attain by the attainment date.

EPA approved ADEC’s attainment plan for PM10 in March 24, 1994 for an effective date 

of April 25, 1994. The SIP implemented a wood smoke control program and a fugitive 

dust abatement program. Elements of the wood smoke control program included a public 

education program, implementation of a real-time monitoring system linked to episodic 

controls of wood burning, prohibition of open burning during winter months, new stove 

certification requirements, and enforcement of the CBJ wood-smoke ordinance. The 

fugitive dust abatement program focused on paving unpaved roads in the Mendenhall 

Valley.

Historical Source Inventory

Air quality characterization in the Mendenhall Valley began in the early 1980s with 

phone surveys on wood combustion. In 1988, EPA conducted an emission inventory of 

all sources of spring and fall emissions, when monitoring had shown the highest levels of 

PM10 occurring. EPA worked with the State to determine appropriate emissions factors. 

Studies indicated fugitive dust constituted over 50% of PM10 in the Mendenhall Valley. 

Fugitive dust sources include dust particles carried by wind and abrasion of surfaces such 

as traffic on dirt roads. In addition to fugitive dust, historical PM10 sources in the 

Mendenhall Valley include:

 Residential and commercial oil-fired furnaces;

 Residential wood-fired heating devices;

 Open burning of construction/residential waste;

 Tailpipe, tire, and brake wear emissions from surfaces;

 Jet and propeller-driven aircraft exhaust emissions;

 Wind-generated fugitive dusts from exposed soils/roadways;

 Vehicle-generated fugitive dusts from paved/unpaved roadways;

 Marine aerosols; and

 Road sanding for winter driving.
III.D.3.5-2 Adopted February 20, 2009

The 1988 emission inventory developed predictive emission factor equations and 

emission rates for paved and unpaved roads. At that time, there were a number of 

unpaved roads in the Mendenhall Valley. On dry days, vehicle movement disturbed high 

levels of dust from unpaved roads. EPA estimated peak hour vehicle counts on a limited 

number of roads. Emission estimates were based on vehicle counts from selected roads 

which were extrapolated to non-selected roads by a function of housing density. For 

wood smoke, emission factors from EPA Region 10 were combined with survey data.

Table III.D.3.5-1 shows estimates by season and source. Maximum 24-hour emission 

estimates are highest in spring and fall due to road sanding and windblown dust. These 

conditions are reduced in winter due mainly to wet and snow-covered conditions.

Table III.D.3.5-1

Worst Case Valley 24-Hour Emission Estimates by Season for 1988 (tons/day)

Spring Summer Fall Winter

Source 

Category

PM10 TSP PM10 TSP PM10 TSP PM10 TSP

Paved Streets –

Fugitive Dust

21.45 51.36 0.49 1.24 21.45 51.36 0.49 1.24

Unpaved 

Streets –

Fugitive Dust 0.08 0.23 9.13 20.28 0.08 0.23 0.08 0.23

Windblown 

Dust

11.51 23.00 5.75 11.50 11.51 23.00 5.75 11.50

Woodstoves 

and Fireplaces

N N N N N N 1.32 1.32

Others 0.33 0.68 0.21 0.24 0.21 0.24 0.21 0.24

TOTAL 33.37 75.27 15.58 33.26 33.25 74.83 7.85 14.53

Projected Emission to Attainment Year

Attainment was projected to occur by December 31, 1994. This did not occur and EPA 

extended the attainment deadline by one year to December 31, 1995. Attainment did 

occur by this date. Table III.D.3.5-2 summarizes the original projection of attainment by 

the extended attainment date. Monitoring data shows attainment by the end of 1995.
III.D.3.5-3 Adopted February 20, 2009

Table III.D.3.5-2

Expected Reductions in PM10 Emissions 1993-1995

Due to Historical Emission Control Measures

Source Year Reductions Reductions 

Tons/Year

Projected Growth 

Tons per Source

Paved Roads11993 15% of 801 

tons/year

120 11

1994 15% of 681 102

1995 0% of 579 0

Unpaved Roads 1993 20% x 698 140 34

1994 69% x 558 385

1995 90% x 173 156

Woodstoves21993 20% x 149 30 3

1994 20% x 119 24

1995 0% x 95 0

Grand Total 961 tons 48 tons

1 Track out control and winter sand control

2 Estimated annual replacement of stoves – USFS/CBJ and ordinance 91-52

Historical and On-Going Control Measures

The City & Borough of Juneau ordinances and information related to wood smoke and 

road dust control as included in the attainment plan are found in the Appendix to Section 

III.D.3.5.

Wood Smoke

Programs were in place to control wood smoke through the 1980s. The program 

consisted of a 50% opacity standard at the point of emission, air emergencies announced 

when particulate levels reached 260 ug/m3(24 hour average), and banned open burning in 

the affected area between November 1 and March 31. The City and Borough lowered the 

threshold for an air emergency to 150 ug/m3in 1984, 100 ug/m3in 1986, 92 ug/m3in 

1988, and 75 ug/m3in 1991. During air emergencies, the use of wood stoves or fireplaces 

was prohibited unless the stove burned pellets. A secondary air emergency level existed

at higher concentrations where no wood stove or fireplace use was allowed. These 

programs were codified into the attainment plan.

CBJ police enforced wood smoke bans. Initially fines were $100 for a first offense and 

$300 for a second. These were later dropped to $50 for a first offense and $75 for a 

second. Warnings were commonly issued at the beginning of the program, but later fines 

were primarily issued.

CBJ required wood stove users to not burn any materials other than paper, cardboard, and 

untreated wood. Building codes were passed with minimum insulation requirements and 

restrictions on window coverage. Regulations were adopted that did not allow wood 

stoves to be the sole source of heat. 
III.D.3.5-4 Adopted February 20, 2009

Fugitive Dust

Fugitive dust control primarily relies on reasonably available control measures (RACM). 

Examples of RACM include paving unpaved streets, sweeping and sanding mitigation 

programs, dust suppressants, use of coverings and enclosures, planting, and reducing 

speeds.

For roads already paved, the CBJ and Alaska Department of Transportation optimized 

sanding and de-icing materials to maximize road safety and keep entrainment of fine dust 

into the air to a minimum. CBJ implemented street sweeping in spring to remove excess 

sand. CBJ used Congestion Mitigation Air Quality funds to add sweepers to the fleet in 

the early 1990s.

Through the normal progression of Juneau’s transportation infrastructure, many 

improvements occurred through paving of dirt roads. The SIP was amended in 1991 to 

account for a newer, cheaper form of “hot-mix” asphalt surfacing. A paving program was 

quickly adopted as the primary solution to dust problems in the non-attainment area. In 

the span between 1991 and 1994, 89 percent of targeted dirt roads were paved with most 

being paved in 1993 and 1994. Targeted roads unpaved by 1994 still needed 

improvements to drainage and easements. Most of these roads were eventually paved.

For the remaining unpaved roads, CBJ relied on natural precipitation to keep dust down. 

Tested dust suppressants tended to increase rutting of roads during rare dry stretches 

causing unsafe conditions. Eventually, CBJ applied alternative road surfaces with smaller 

capacity for developing fine particles. For high traffic roads, a D-1 gravel was used, and 

for low traffic roads, a coarser, rockier material was used. 

Adequate Demonstration of Control Program

One method of measuring effectiveness of control programs is to determine the number 

of days where PM concentrations were high enough to warrant calling an air alert or 

emergency. Table III.D.5-3 looks at the number of wood use curtailment days.

Table III.D.3.5-3

Wood Use Curtailment Days

Winter Season No. Days

1982/83 2.1

1983/84 7.8

1984/85 10.4

1985/86 28.9

1986/87 7.4

1987/88 14.1

1988/89 12.6

1989/90 3.7

1990/91 18.3

1991/92 6.0

1992/93 9.2

There appears to be a small trend toward fewer days requiring curtailed wood use over 

time. However, the number of days varies dramatically from year to year depending on 
III.D.3.5-5 Adopted February 20, 2009

weather patterns. This includes the fact that the threshold for air alerts were decreased in 

1984, 1986, 1988, and 1991. In recent years, no air alerts have been issued.

Further measures of success include a switching of heating purchases to pellet stoves 

over wood burning stoves, such that by 1993, 70% of new wood burning stove purchases 

were pellet stoves.

The 1993 plan projected ambient PM10 levels after the implementation of the fugitive 

dust control measures would range from 77 μg/m3to 101 μg/m3. The plan needed to

reduce PM10 by approximately 460 tons per year to meet the standard in the Mendenhall 

Valley. Controlling unpaved roads contributed most to the emission reductions. The 

1993 plan also estimated growth at 5% per year through 1997. Given the projections, 

ambient PM10 levels were projected to remain significantly below the standard into the 

future. Table III.D.3.5-2 summarizes expected reductions in emissions against expected 

growth.
III.D.3.5-6 Adopted February 20, 2009

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III.D.3.6-1 Adopted February 20, 2009

III.D.3.6. Historical Attainment Plan Contingency Measures

Fugitive Dust

Less than two miles of unpaved road remain in the Mendenhall Valley after the initial 

attainment plan paving effort. If attainment had not been reached by December 31. 1995, 

these stretches of unpaved road could have been paved. Further, the CBJ had a number 

of other mechanisms to reduce PM10 if needed. These included using coarser sand in 

winter, sweeping roads during dry spells, limiting use to chemical deicers, increasing 

public awareness, covering truck loads, focusing on construction sites, addressing 

transitions from paved to unpaved roads, using plants to stabilize road beds, and 

controlling outdoor storage piles. In addition the following control measures were listed 

as other options to be investigated:

 Controlling spills from trucks hauling particulate-producing materials;

 Requiring installation of liners on truck beds;

 Requiring watering of loads;

 Requiring cargo that cannot be controlled by other measures to be covered;

 Requiring trucks to maintain a freeboard;

 Establishing controls on construction carryout and entrainment;

 Requiring construction activities to limit and remove the accumulation of dust 

generating materials;

 Requiring paving of construction site access roads;

 Requiring the developer of a construction site to clean soil from access road 

and public roadway;

 Requiring control of vehicle entrainment from unpaved areas adjacent to 

paved roadways;

 Requiring stabilization of unpaved areas adjacent to paved roads, such as 

shoulders; 

 Controlling storm water from washing eroded materials onto the street;

 Developing adequate storm water control systems;

 Requiring vegetation to stabilize road sides;

 Developing programs for the rapid clean up of street debris after events;

 Controlling wind erosion from outdoor storage of loose material that could be 

direct emitters of PM10 ;

 Requiring covers over outdoor material that may produce dust in wind storms; 

and

 Requiring wind breaks in the vicinity of outdoor storage piles. 

Woodstoves

The CBJ attainment plan listed a number of programs to implement if necessary to 

further control PM10 from woodstoves. These included:

 Establishing an enhanced public information campaign including education in 

stove selection, sizing, installation, operation, and maintenance practices to 

minimize emissions; 

 Establishing an enhanced public information campaign including education on 

health risks from wood smoke, new technology stoves, and alternatives to wood 

heating;
III.D.3.6-2 Adopted February 20, 2009

 Encouraging improved performance of wood burning devices such as providing 

voluntary dryness certification programs for dealers and/or making inexpensive 

wood moisture checks available to wood burners; 

 Providing inducements that would lead to reductions in the stove and fireplace 

population and/or use by:

o Slowing the growth of wood burning devices in new housing units by 

taxes, installation permit fees, or other incentives

o Encouraging a reduction in the number of wood stoves (i.e. Removing or 

disabling the devices) through tax credits or other incentives;

o Discouraging the resale of used stoves through taxes, fees, or other 

incentives;

o Discouraging the availability of free (or very inexpensive) firewood by 

increasing cutting fees or limiting the cutting season.
III.D.3.7-1 Adopted February 20, 2009

III.D.3.7. Approval of Section 110 and Part D Requirements

Section 107(d)(3)(E)(v) of the Act requires that a state containing a nonattainment area 

must meet all applicable requirements under section 110 and Part D of the Act. This

means the state must meet all requirements that applied to the area prior to, and at the 

time of, the submission of a complete redesignation request. The following is a summary 

of how Juneau’s Mendenhall Valley nonattainment area meets these requirements.

Clean Air Act Section 110 Requirements

Section 110(a)(2) of the Act contains general requirements for nonattainment plans. 

These requirements include, but are not limited to, submittal of a SIP that has been 

adopted by the State after reasonable notice and public hearing; provisions for 

establishment and operation of appropriate apparatus, methods, systems and procedures 

necessary to monitor ambient air quality; implementation of a permit program; provisions 

for Part C--Prevention of Significant Deterioration (PSD) and Part D--New Source 

Review (NSR) permit programs; criteria for stationary source emission control measures, 

monitoring and reporting, provisions for modeling; and provisions for public and local 

agency participation.*

 

For purposes of redesignation, Alaska’s Mendenhall Valley PM10 SIP (fully-approved by 

EPA in Federal Register: March 24, 1994) shows that the state has satisfied all 

requirements under section 110(a)(2) of the Act. 

Part D Requirements

Part D contains general requirements applicable to all areas designated nonattainment.

The general requirements are followed by a series of subparts specific to each pollutant. 

All PM10 nonattainment areas must meet the general provisions of Subpart 1 and the 

specific PM10 provisions in Subpart 4, “Additional Provisions for Particulate Matter 

Nonattainment Areas.” The following paragraphs discuss these requirements as they 

apply to the Mendenhall Valley area.

Subpart 1, Section 172(c)

Subpart 1, section 172(c) contains general requirements for 

nonattainment area plans. A thorough discussion of these requirements 

may be found in the General Preamble. See 57 FR 13538 (April 16, 1992). 

The requirements for reasonable further progress, identification of 

certain emissions increases and other measures needed for attainment 

were satisfied with the approved PM10 nonattainment plan for the 

Mendenhall Valley area. 

Section 172(c)(3)--Emissions Inventory

Section 172(c)(3) of the Act requires a comprehensive, accurate, 

current inventory of actual emissions from all sources in the 

PM10 nonattainment area. Alaska has included an emissions inventory 

 

* See the General Preamble for further explanation of these requirements. 57 FR 13498 (April 16, 1992).
III.D.3.7-2 Adopted February 20, 2009

for the calendar year 2004 with this submittal of the LMP for the 

Mendenhall Valley area. The requirement for a current, accurate and 

comprehensive emission inventory is satisfied by the inventory contained 

in the LMP.

Section 172(c)(5)--New Source Review (NSR)

The Clean Air Act Amendments of 1990 contained revisions to the new 

source review (NSR) program requirements for the construction and 

operation of new and modified major stationary sources located in 

nonattainment areas. The Act requires states to amend their SIPS to 

reflect these revisions, but does not require submittal of this element 

along with the other SIP elements. The Act established June 30, 1992 as 

the submittal date for the revised NSR programs (Section 189 of the 

Act). In the Mendenhall Valley, the requirements of the Part D NSR 

program will be replaced by the Prevention of Significant Deterioration 

(PSD) program and the maintenance area NSR program upon effective 

date of redesignation. The Part D NSR rules for PM10 nonattainment 

areas in Alaska were approved by EPA. The federal PSD regulations 

found at 40 CFR 52.21 are the PSD rules in effect for Alaska under 

maintenance.

Section 172(c)(7) Compliance With CAA Section 110(a)(2): Air 

Quality Monitoring Requirements

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 attainment status of the area. The Mendenhall Valley’s current 

monitoring network is described in Section III.D.4 of this LMP.

Monitors are operating in accord with 40 CFR part 58. The State commits

to continued operation of the monitoring network.

Section 172 (c)(9) Contingency Measures

The Clean Air Act requires that contingency measures take effect if 

the area fails to meet reasonable further progress requirements or 

fails to attain the NAAQS by the applicable attainment date. Since the 

Mendenhall Valley area attained the NAAQS for PM10 by the attainment 

date of December 31, 1995, contingency measures are no longer required 

under Section 172(c)(9) of the Act. However, contingency provisions are 

required for maintenance plans under Section 175(a)(d). The state

describes its contingency measures in Section III.D.3.10 of this LMP. 

Part D Subpart 4

Part D Subpart 4, Section 189(a), (c) and (e) requirements apply to 

any moderate nonattainment area before the area can be redesignated to 

attainment. The requirements which were applicable prior to the 

submission of the request to redesignate the area must be fully 

approved into the SIP before redesignating the area to attainment. 

These requirements include:

 Provisions to assure that RACM was implemented by December 10, 

1993;
III.D.3.7-3 Adopted February 20, 2009

 Either a demonstration that the plan provided for attainment as 

expeditiously as practicable but not later than December 31, 1994, or a 

demonstration that attainment by that date was impracticable;

 Quantitative milestones which were achieved every 3 years and 

which demonstrate reasonable further progress (RFP) toward 

attainment by December 31, 1994; and

 Provisions to assure that the control requirements applicable 

to major stationary sources of PM10 also apply to major stationary 

sources of PM10 precursors except where the Administrator determined 

that such sources do not contribute significantly to PM10 levels which 

exceed the NAAQS in the area.

These provisions were fully met in the SIP upon EPA approval of the PM10

nonattainment area plan for the Mendenhall Valley area. Juneau’s Mendenhall Valley 

was classified as moderate nonattainment for PM10 upon enactment of the Clean Air Act 

Amendments in 1990. The requirements applicable to the Mendenhall Valley 

nonattainment area for inclusion in the Alaska SIP included an attainment demonstration, 

a 1988 base year emission inventory, a wood smoke control program, a fugitive dust 

control program of paving unpaved roads, contingency measures, conformity measures 

and a permit program for new or modified stationary sources. EPA approved all these 

elements into the Alaska SIP in March 1994 (Federal Register: March 24, 1994). Thus 

the area has a fully approved nonattainment area SIP under section 110(k) of the Act.
III.D.3.7-4 Adopted February 20, 2009

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III.D.3.8-1 Adopted February 20, 2009

III.D.3.8. Air Quality Maintenance Plan

The approved attainment SIP included implementation of RACM for PM10 sources and 

demonstrated attainment by December 31, 1994. ADEC applied for and was granted in 

September 1995 a one year extension of the attainment deadline. Monitoring data shows 

the controls are working. Between 1982 and 1987, maximum 24 hour total suspended 

particulate concentrations reduced from 600 μg/m3to 100 μg/m3. Between 1992 and 

1995, maximum 24 hour PM10 concentrations reduced from 207 μg/m3to 86 μg/m3.

Permanent and Enforceable Emission Reductions

Emission reductions are permanent and enforceable as demonstrated through this LMP. 

Implemented control measures including enforceable wood smoke ordinances, permanent 

wood stove technology advances, and paving of unpaved roads are responsible for air 

quality improvements in the Mendenhall Valley and all existing controls will remain in 

place in this LMP. Neither local economic downturns nor unusual weather patterns have 

contributed to air quality improvements. In fact, Juneau’s population has grown since 

EPA’s attainment plan approval, and Juneau has experienced a number of dry summers. 

In spite of these outside factors, PM10 measurements continue to decline. ADEC believes 

the combination of approved SIP provisions and federal measures continue to result in 

permanent and enforceable reductions in ambient PM10 levels that allow the Mendenhall 

Valley to continue to attain the PM10 standard. 

EPA’s LMP Option for Moderate PM10 Nonattainment Areas allows states to submit a 

more streamlined maintenance plan than ordinarily permitted. The LMP option is 

designed to redesignate areas at little risk of violating the PM10 standard. A maintenance 

plan is developed to ensure that attainment of the health standard will continue into the 

future. 

A maintenance plan must contain the following requirements: source inventory, current 

and projected emission estimates, control strategies, and demonstrated program 

adequacy. The LMP presumes current PM10 levels and potential for future growth in 

mobile source emissions provide minimal risk of violating the NAAQS. For this reason, 

under a LMP regional transportation conformity is assumed and the motor vehicle 

emissions budget need not be capped. This means that under an LMP a regional 

emissions analysis is not required for conformity determinations on plans or TIPs. The 

conformity determination should note this.

Attainment Year Emission Inventory

In January 2006, the department completed an annual emission inventory for years 2004 

and 2018 for PM10 emissions in the Mendenhall Valley nonattainment area. This 

inventory is located in the Appendix to Section III.D.3.8. Table III.D.3.8-1 presents a 

summary of 2004 and 2018 PM10 emissions for Mendenhall Valley in Juneau. Overall, 

the PM10 inventory is estimated to have declined by almost 30% between 1993 and 2004.
III.D.3.8-2 Adopted February 20, 2009

Table III.D.3.8-1

Summary of Mendenhall Valley PM10 Emissions

By Season and Source Category (tons/day)

Source Category Calendar Year 2004 Calendar Year 2018

Winter PM10 Emissions

On-Road 0.022 0.011

Non-Road 0.027 0.012

Area 

Residential – Wood 0.091 0.099

Residential – Pellet 0.006 0.007

Residential – Oil 0.002 0.002

Residential Burn Barrels 0.000 0.000

Paved Road Fugitive Dust 1.478 1.612

Unpaved Road Fugitive Dust 0.161 0.176

Other Area Sources 0.182 0.181

 Area Subtotal 1.920 2.077

Point 0.000 0.000

Total All Sources 1.969 2.100

Summer PM10 Emissions

On-Road 0.021 0.011

Non-Road 0.049 0.021

Area 

Residential – Wood 0.031 0.034

Residential – Pellet 0.002 0.002

Residential – Oil 0.001 0.001

Residential Burn Barrels 0.057 0.062

Paved Road Fugitive Dust 4.135 4.510

Unpaved Road Fugitive Dust 0.190 0.207

Other Area Sources 0.182 0.183

Area Subtotal 4.598 4.999

Point 0.155 0.155

Total All Sources 4.823 5.186

Annual Average 3.400 3.647

The general approach followed the source-specific data collection and modeling 

procedures detailed in the EPA emission inventory guidance document “PM-10 Emission 

Inventory Requirements,” Final Report, September 1994. Key emission sources 

identified in the previous inventory were smoke from residential wood combustion and 

fugitive dust from both paved and unpaved roads. Given the significance of these 

sources and past efforts to control their emissions, the inventory focused on collecting 

new data to characterize activity levels for these sources. A home heating survey 

conducted in 2005 provided insight into the impact of technology changes and activity 

levels on residential heating emissions. No similar survey is available to support an 

update of fugitive dust from paved and unpaved roads. 
III.D.3.8-3 Adopted February 20, 2009

In order to prepare an accurate update for paved and unpaved roads, the DEC contractor 

contacted the Alaska Department of Transportation and Public Facilities and local CBJ 

agencies to obtain data on the miles of paved and unpaved roads in the Valley, traffic 

counts and related speed estimates. A key element of fugitive dust calculations is the silt 

loading on roads. The last emission inventory prepared for the Mendenhall Valley*

occurred in 1988. A review of the 1988 inventory shows silt loadings were collected 

locally to support the preparation of fugitive dust emissions for unpaved roads and 

national average silt loadings were used to estimate on-road levels. Since no controls 

have been targeted at controlling silt loadings for unpaved roads, there was no need to 

update those estimates. However, CBJ enacted a paving program reducing the miles of 

unpaved roads. A corollary benefit of these controls should be a reduction of silt loadings 

(from fugitive dust) on paved roads. Given resource constraints, ADEC has not collected 

new data on silt loadings for the paved roads, resulting in conservative emission 

estimates.

In the 1988 emission inventory, fugitive dust from unpaved roads was estimated to 

account for 40% of the overall inventory. In 2004, unpaved roads accounted for 5.2% of 

the overall inventory. In 2018, the projection is 5.3%. The projected level of emissions 

from unpaved roads in 2018 is based on the conservative assumption that all unpaved 

roads in the Mendenhall Valley in 2004 would remain unpaved in 2018. Efforts by CBJ 

and the State to continue to pave sections of unpaved roads in the Valley will likely 

reduce the projected percent emission contributions below the 2018 estimate.

PM10 emissions from wood burning (both fireplaces and stoves) were estimated to 

account for almost 9% of the annual inventory in 1988. In 2004, that share declined to 

less than 2% and is projected to remain roughly at that level in 2018. Based on the 

results of an extensive survey of homeowners conducted in 2004, it is estimated that the 

combination of new technology, related shifts in wood use, and implementation of wood 

burning control measures reduced emissions by 85% from 1993 to 2004. These trends 

should continue into the future.

Other trends of note are that emissions from both the on-road and non-road source 

categories represent a trivial portion of the overall inventory. On-road and nonroad 

source emissions are projected to decline despite the increase in activity projected to 

occur between 2004 and 2018. This is the result of replacing older, higher-emitting 

vehicles/equipment populations with newer, lower-emitting populations and stricter 

federal requirements for cleaner fuels. 

There is only one permitted stationary source located in the Valley, an asphalt plant, and 

its operations are limited to 5 months per year during the summer season.

Control Measures Necessary to Maintain the NAAQS

The Mendenhall Valley relied on the RACM measures summarized previously to attain 

the standard. The RACM measures continue to be implemented and have proven 

effective at reducing PM10 emissions in the Mendenhall Valley nonattainment area.

 

*

. “PM10 Emission Inventories for the Mendenhall Valley and Eagle River Areas,” prepared for U.S. 

Environmental Protection Agency, Region X, by Engineering Science, February 1988.
III.D.3.8-4 Adopted February 20, 2009

In accordance with the EPA’s LMP policy, all controls relied on to demonstrate 

attainment will remain in place through the maintenance plan period. The RACM 

measures selected were chosen from a list of proven controls developed by the EPA. EPA 

approved Mendenhall Valley control measures effective April 25, 1994 (59 FR 6954, 

March 24, 1994). No additional LMP control measures are necessary to maintain the 

NAAQS.

The following measures have been adopted into municipal code under Chapter 36.40 

Solid Fuel-Fired Devices; 03.30.055 Woodsmoke Control Fine Schedule; and Chapter 

19.11 Thermal Code and will remain in the LMP (also see Appendix III.D.3.5):

City & Borough of Juneau Ordinances:

• #83-63 – “An Ordinance Regulating Open Burning and the Use of Wood-Fired 

Heating Devices in Smoke Hazard Areas”

• #88-59 – “An Ordinance Amending the Woodsmoke Control Code to 

Implement a New Measurement System for Measuring Air Pollution, to Adopt Federal 

Standards for the Issuance of Class I Permits for NonCatalytic Solid Fuel-Fired Heating

Devices, and to Delete References to Oregon State Woodstove Standards.”

• #91-52 – “An Ordinance Amending the Woodsmoke Control Code to Lower the

Particulate Count Threshold for Declaring Air Alerts, to Authorize the Manager to 

Declare an Air Alert According to Certain Qualitative Criteria, to Provide for the 

Expiration of All Existing Class I Permits on July 1, 1997, to Terminate the Manager’s 

Authority to Issue New Class I Permits, and to Prohibit the Burning in Woodstoves of 

Substances Other Than Paper, Cardboard, and Untreated Wood.”

• #91-53 – “An Ordinance Amending the Woodsmoke Control Fine Schedule to 

Increase the Fines for Violations of the Woodsmoke Control Code.”

• #93-01 – Ordinance on Local Improvement Districts

• #93-06 – An Ordinance Creating Local Improvement District No. 76 of the City 

and Borough of Juneau.

• Fiscal Year 1994 CP-1s

• Resolution #1612

• #2008-28 “An Ordinance Amending the Woodsmoke Control Program

Regarding Solid Fuel-Fired Burning Devices”. This ordinance has been incorporated into 

CBJ Code at Title 36.40.040 “Air pollution alert and emergencies”. Under this 

ordinance, the manager shall declare an air pollution emergency to be in effect whenever the 

ambient concentration of particulate matter within the air pollution zone equals or exceeds 30 

micrograms per cubic meter (μg/m3) averaged over a 24-hour period and will remain at or 

above 30 μg/m3if an emergency is not called. This ordinance is more stringent than the 

previous ordinance which set the particulate matter limit at 75 μg/m3. Refer to Appendix 

III.D.3.5 for complete ordinance language. 

• Resolution #2448- With this resolution, the City & Borough of Juneau approved 

the draft PM10 Limited Maintenance Plan, dated May 10, 2007. Resolution approved 

August 11, 2008.
III.D.3.9-1 Adopted February 20, 2009

III.D.3.9. Maintenance Demonstration

The Maintenance Plan will continue the controls of the attainment plan. The following 

are the criteria that must be met to demonstrate maintenance and meet LMP 

requirements. With each criteria is a description of how the criteria are being met.

Policy: “The area is attaining the NAAQS and the average PM10 design value for 

the area, based on the most recent 5 years of air quality data at all monitors in the 

area, is at or below 40 μg/m3for the annual and 98 μg/m3for the 24-hr PM10

NAAQS with no violations at any monitor in the nonattainment area.”

The Mendenhall Valley:

 is attaining the standard.

 has a 24-hour average design value based on 1995-2004 of 53.8 μg/m3.

 has had no violations of the 24-hour PM10 NAAQS since 1992.

Policy: “The area expects only limited growth in on-road motor vehicle PM10 

emissions (including fugitive dust).”

When adjusted for future on-road mobile emissions, the Mendenhall Valley passes 

a motor vehicle regional emissions analysis test with a design value of 56.85 μg/m3. 

This is less than the 98 μg/m3used as the margin of safety in the LMP guidance.

The following equation was used in the analysis of motor vehicle emissions for the 

Mendenhall Valley. The analysis determines eligibility of the Mendenhall Valley 

for a LMP. The equation is based on the U.S. EPA guidance titled “Limited 

Maintenance Plan Option for Moderate PM10 Nonattainment Areas.” (Attachment 

B: Motor Vehicle Regional Analysis Methodology). The equation set forth in this 

guidance is:

DV + (VMTpi * DVmv) ≤ MOS

Where

DV = design value in μg/m3

VMTpi = projected increase in vehicle miles traveled (VMT) over the next 

10 years

DVmv = product of the design value and the fraction of the inventory 

represented by on-road mobile sources in the attainment year; and

MOS = margin of safety for PM10 or critical design value, which are 40 

μg/m3for the annual standard and 98 μg/m3for the 24-hour standard.

ADEC has assumed the attainment year to be 2004, the year for which the most 

recent Mendenhall Valley nonattainment area emissions inventory was prepared. 

VMT is projected to increase over the next 10 years based on the projected 
III.D.3.9-2 Adopted February 20, 2009

population growth. Travel modeling data are not available for Mendenhall Valley. 

The 24-hour and annual PM10 design values were derived from the data obtained 

from William Puckett of EPA Region 10 (Appendix to Section III.D.3.9). The EPA 

analysis conservatively used 10 years of monitoring data to estimate the design 

value. ADEC applied the same design values for this analysis. The left hand term 

of the above equation was estimated using seasonal (summer and winter) and 

annual inventories. Based on the criteria given above, the Mendenhall Valley 

qualifies for the LMP option for the 24-hour and annual PM10 standard for all 

considered cases. Details of the calculations are shown below:

The parameter values used for the calculations are as follows:

 24-hour DV = 53.8 μg/m3;

 Annual average DV = 9.4 μg/m3; and

 Projected % increase in VMT in next 10 years, VMTpi = 6.39%. 

 The percentages of the total inventory from on-road mobile 

sources in 2004 are: 

- Summer fraction = 90%,

- Winter fraction = 84%, and

- Annual fraction = 88%.

The results of the calculations are shown in Table III.D.3.9-1 compared to the margin of 

safety (MOS) or critical design values for the 24-hour and annual standard. As shown, 

the calculated values are much less than the critical design values and the area passes the 

regional analysis criteria. Criterion 4 is met.

Table III.D.3.9-1

Calculated [DV + (VMTpi * DVmv)] for Mendenhall Valley

Standard Summer Winter Annual MOS Criteria

Annual 9.90 9.86 9.89  40

24-Hour 56.90 56.71 56.85  98

Based on the analysis of the LMP criteria, ADEC requests EPA consider the Mendenhall 

Valley nonattainment area as qualified for the LMP option. 

Monitoring Network

A PM10 monitoring network was established in the Mendenhall Valley area in 1984.

Total suspended particulate was monitored at some sites starting in the 1970s. 

Monitoring sites have been located in nine different locations since that time. The 

monitoring network was developed and has since been maintained in accordance with 

federal siting and design criteria set forth in 40 CFR Part 58, Appendices D and E and in 

consultation with EPA Region 10.
III.D.3.9-3 Adopted February 20, 2009

Primary monitoring for PM10 in the Mendenhall Valley occurs at the Floyd-Dryden 

Middle School monitoring site described in III.D.3.4. Monitoring will continue through 

the LMP period. The network will be maintained in accordance with federal siting and 

design criteria set forth in 40 CFR Part 58.

Verification of Continued Attainment

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

maintenance plan period. ADEC 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.

In the event the area does not continue to qualify for the LMP option, ADEC will 

implement one or more of the LMP contingency measures, described in III.D.3.10. If the 

area fails a second time to qualify for the LMP option, a full maintenance plan will be 

prepared as required by the LMP policy.

Natural Events

There have been no exceedances attributed to natural events in the Mendenhall Valley 

area.
III.D.3.9-4 Adopted February 20, 2009

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III.D.3.10-1 Adopted February 20, 2009

III.D.3.10 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. Normally, the implementation of contingency 

measures is triggered by a violation of the NAAQS but the state may choose to establish 

more stringent triggers, such as an exceedance of the NAAQS, in order to prevent a 

violation. Contingency measures do not have to be fully adopted at the time of 

redesignation, but they must be readily adopted if they are triggered.

This section identifies a process and a time-line to identify and evaluate appropriate 

contingency measures in the event of a quality assured violation of the PM10 NAAQS. 

ADEC and CBJ may, however, voluntarily initiate this or a similar local process to 

identify and evaluate appropriate contingency measures necessary to prevent such a 

violation.

Contingency Measures Assessment

Within 30 days following a violation of the PM10 NAAQS, ADEC and CBJ will convene 

a team to identify appropriate measures needing to be implemented. Identified 

contingency measures may include but are not limited to those listed below.

The assessment team will prepare and deliver a report containing its recommendation, 

within 120 days for the ADEC Commissioner, City Manager, and assembly based on 

evaluation of the:

 monitor data before and during the event;

 weather conditions that may have caused and/or contributed to violation.

 normal and unusual emissions occurring prior to and during the event.

 effectiveness of existing controls in reducing the magnitude and/or duration of 

the event(s).

 appropriateness of modifying and/or implementing one or more LMP 

contingency measures

 possible changes to the LMP, monitoring network, and public information 

strategies; and 

 the need for additional voluntary or regulatory controls to reduce future 

emissions.

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

discretion of the ADEC Commissioner and City Manager and assembly. The assembly 

may adopt and implement contingency measures as needed.

LMP Contingency Measures

The following LMP contingency measures may come into effect in the event of a PM10

NAAQS violation, subject to the assessment described above. One applies to unpaved 
III.D.3.10-2 Adopted February 20, 2009

roads and parking lot emissions and one applies to residential wood combustion 

emissions.

Fugitive Dust

Paving of Unpaved Roads: The Mendenhall Valley still has a number of unpaved 

roads. In the event of a NAAQS violation, the CBJ will determine whether or not 

to pave any or all of the remaining roads. 

Other contingency measures remain in the SIP, including:

 Controlling spills from trucks hauling particulate-producing materials;

 Requiring installation of liners on truck beds;

 Requiring watering of loads;

 Requiring cargo that cannot be controlled by other measures to be covered;

 Requiring trucks to maintain a freeboard;

 Establishing controls on construction carryout and entrainment;

 Requiring construction activities to limit and remove the accumulation of dust 

generating materials;

 Requiring paving of construction site access roads;

 Requiring the developer of a construction site to clean soil from access road

and public roadway;

 Requiring control of vehicle entrainment from unpaved areas adjacent to 

paved roadways;

 Requiring stabilization of unpaved areas adjacent to paved roads, such as 

shoulders;

 Controlling storm water from washing eroded materials onto the street;

 Developing adequate storm water control systems;

 Requiring vegetation to stabilize road sides;

 Developing programs for the rapid clean up of street debris after events;

 Controlling wind erosion from outdoor storage of loose material that could be

direct emitters of PM10 ;

 Requiring covers over outdoor material that may produce dust in wind storms; 

and

 Requiring wind breaks in the vicinity of outdoor storage piles.

Wood Smoke

Burn Bans: CBJ code contains provisions to ban wood burning on bad air days 

and enforce the ban with fines. 

Other contingency measures remain in the SIP to address wood smoke, including:

 Establishing an enhanced public information campaign including education in 

stove selection, sizing, installation, operation, and maintenance practices to 

minimize emissions; 

 Establishing an enhanced public information campaign including education on 

health risks from wood smoke, new technology stoves, and alternatives to 

wood heating;
III.D.3.10-3 Adopted February 20, 2009

 Encouraging improved performance of wood burning devices such as 

providing voluntary dryness certification programs for dealers and/or making 

inexpensive wood moisture checks available to wood burners; 

 Providing other inducements that would lead to reductions in the stove and 

fireplace population such as discouraging the availability of free (or very 

inexpensive) firewood by increasing cutting fees or limiting the cutting 

season.

The assessment team will also consider recommending other contingency measures that 

may more appropriately address the most probable source contributing to the violation. 

The CBJ, or other appropriate agency, may adopt and implement contingency measures 

other than those listed above, as needed.
III.D.3.10-4 Adopted February 20, 2009

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III.D.3.11-1 Adopted February 20, 2009

III.D.3.11. 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’s LMP policy does not exempt an area 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.

However, since the Mendenhall Valley will still be a maintenance area after 

redesignation, transportation conformity determinations are still 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 should 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). ADEC 

will continue to work with the affected jurisdictions and interested parties to develop an 

evaluation criteria and process to meet these transportation conformity requirements.
III.D.3.11-2 Adopted February 20, 2009

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III.D.3.12-1 Adopted February 20, 2009

III.D.3.12 Redesignation Request

The department is requesting redesignation of the Juneau Mendenhall Valley PM10

nonattainment area to attainment of the PM10 NAAQS. In order to qualify for the LMP 

option, an area must satisfy criteria summarized previously. The following is a 

description of how the criteria are being met:

1. The area should be attaining the National Ambient Air Quality Standards – Juneau 

has met the air quality standard since 1994.

2. The average PM10 design value for the area, based on the most recent 5 years of air 

quality data at all monitors in the area, should be at or below 40 ug/m3for the annual 

and 98 ug/m3for the 24 hour PM10 NAAQS with no violations at any monitor in the 

nonattainment area – There have been no violations in the nonattainment area. The 

average 24 hour design value over the last 10 years of data is 53.8 ug/m3.

3. If criteria 2 cannot be met, the average design values of the site should be less than 

their respective site-specific critical design value (CDV). Criteria 2 has been met.

4. The area should expect only limited growth in on-road motor vehicle PM10 emissions 

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

analysis test. Fugitive dust from unpaved roads is only projected to increase by 0.1% 

between 2004 and 2018. This assumes no additional roads are paved. The analysis of 

regional motor vehicle emissions shows values well below the critical design values.

In part, criteria for the LMP qualification are based on a statistical analysis such that, 

when satisfied, demonstration of maintenance is established. It is apparent that the 

Mendenhall Valley nonattainment area qualifies for the LMP option. Having qualified for 

the LMP option, maintenance of the standard is presumed to be satisfied.

ADEC believes this document contains all necessary information and adequately 

demonstrates the Mendenhall Valley should be reclassified as attainment under the 

Limited Maintenance Plan option. Therefore, ADEC formally requests that EPA approve 

redesignation of the Mendenhall Valley nonattainment area to attainment under this 

Limited Maintenance Plan.
III.D.3.12-2 Adopted February 20, 2009

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