## MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

APPENDICES
VOLUME TWO

MAY 2012

## MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

APPENDICES

MAY 2012

### MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA APPENDICES
APPENDIX A Exhibit 1: 2008 PM-10 Periodic Emissions Inventory for the Maricopa County, Arizona, Nonattainment Area. Ma ricopa County Air Quality Department. Revised June 2011.
APPENDIX B Exhibit 1: Technical Document in Suppor t of the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. Maricopa Association of Governments. Exhibit 2: Calculation of B enefits from PM-10 Certified Street Sweepers Purchased with CMAQ Funds in 2001-2009. APPENDIX C Exhibit 1: Arizona Revised Statutes Listed in Table 4-1. Exhibit 2: Maricopa County Resolution to Evaluate Measures in the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. Exhibit 3: Arizona Department of Environmental Quality Du st Action General Permit. Exhibit 4: Arizona Department of Environmental Quality Commitment to Revise the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area if Necessary for the Emerging and Voluntary Measure.
APPENDIX D Exhibit 1: Agricultural Best Management Practices Program.
APPENDIX E Exhibit 1: Public Hearing Process Documentation. Exhibit 2: Certification of Adoption.

## APPENDIX B

## APPENDIX B

EXHIBIT 1:

Technical Document in Support of the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. Maricopa Association of GovernmentsTECHNICAL DOCUMENT IN SUPPORT OF THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

May 2012

Maricopa Association of Governments 302 North 1 stAvenue, Suite 300 Phoenix, Arizona 85003TABLE OF CONTENTS CHAPTER PAGE I INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . I-1 II BASE CASE PM-10 EMISSIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 POINT SOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 AREA SOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-1 NONROAD MOBILE SOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-7 ONROAD MOBILE SOURCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-10 SUMMARY OF BASE CASE PM-10 EMISSIONS . . . . . . . . . . . . . . . . . . . . . II-17 III EVALUATION OF RULE EFFECTIVENESS . . . . . . . . . . . . . . . . . . . . . . . . . III-1 IV EVALUATION OF CONTINGENCY PROJECTS . . . . . . . . . . . . . . . . . . . . . IV-1 PM-10 CERTIFIED STREET SWEEPING . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-2 PAVING AND STABILIZING UNPAVED ROADS AND ALLEYS . . . . . . . . . . IV-7 PAVING AND STABILIZING UNPAVED SHOULDERS . . . . . . . . . . . . . . . . IV-12 REDUCED SPEED LIMITS ON UNPAVED ROADS AND ALLEYS . . . . . . IV-12 OVERLAYS WITH RUBBERIZED ASPHALT . . . . . . . . . . . . . . . . . . . . . . . IV-16 DEMONSTRATION THAT THE PM-10 REDUCTION PROJECTS IMPLEMENTED IN 2008-2011 MEET CONTINGENCY REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-16 PM-10 REDUCTIONS DUE TO ALL MEASURES AND PROJECTS IN THE FIVE PERCENT PLAN . . . . . . . . . . . . . . . . . . . . . . . . IV-19
V ATTAINMENT MODELING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-1 CONCEPTUAL MODEL . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-2

iTABLE OF CONTENTS (Continued) CHAPTER PAGE TEMPORARY MONITOR INSIGHTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-7 SOURCE WEIGHTING ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-21 BACKGROUND CONDITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-28 DESIGN DAY SELECTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-41 MODELING DOMAINS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-53 INVENTORY DEVELOPMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-62 CONTROL MEASURE ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-79 DEMONSTRATION OF ATTAINMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-80

iiLIST OF TABLES
TABLE PAGE Table II-1 Growth Factor for the PM-10 Nonattainment Area . . . . . . . . . . . . . . . . II-2 Table II-2 2007-2012 Base Case Emissions in the PM-10 Nonattainment Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-3 Table II-3 Growth Factors for Aircraft and Ground Supoort Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-8 Table II-4 Growth Factors for Other Nonroad Mobile Sources . . . . . . . . . . . . . . . II-9 Table II-5 2007-2012 PM-10 Emissions from Exhaust, Tire Wear and Break Wear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-12 Table II-6 PM-10 Emission Rates from PM-10 Certified and Conventional Sweepers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . II-14 Table II-7 Usage Factors for P M-10 Certified Street Sweepers . . . . . . . . . . . . . II-15 Table III-1 Impact of Increased Rule Effectiveness on 2008-2012 PM-10 Emissions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . III-2 Table III-2 2008-2012 PM-10 Emissions with Increased Rule Effectiveness

............................................ III-4 Table III-3 PM-10 Emission Reductions and Five Percent Reduction Requirements

................................... III-5 Table IV-1 2008-2012 PM-10 Emission Reductions for Contingency Projects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-3 Table IV-2 PM-10 Emission Reductions for ADOT Sweeping . . . . . . . . . . . . . . . . IV-5 Table IV-3 PM-10 Reductions for Paving and Stabilizing Unpaved Roads/Alleys . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-9 Table IV-4 PM-10 Reductions for Paving and Stabilizing Unpaved Shoulders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-13 Table IV-5 PM-10 Reductions for Reduced Speed Limits on Unpaved Roads and Alleys . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-17
iiiLIST OF TABLES (Continued)
TABLE PAGE Table IV-6 PM-10 Reductions for ADOT Overlays with Rubberized Asphalt . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-18 Table IV-7 2008-2012 PM-10 Emissions with All Plan Measures and Contingency Projects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-20 Table V-1 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at West 43rd Avenue/Broadway and West 43rd Avenue Monitors when Winds Exceeded 12 mph (0-175 degrees) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-12 Table V-2 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at West 43rd Avenue/Broadway and West 43rd Avenue Monitors when Winds Exceeded 12 mph (180-360 degrees) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-13 Table V-3 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at West 43rd Avenue/Broadway and West 43rd Avenue Monitors when Winds are Between 6-12 mph (0-175 degrees) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-14 Table V-4 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at West 43rd Avenue/Broadway and West 43rd Avenue Monitors when Winds are Between 6-12 mph (180-360 degrees) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-15 Table V-5 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at West 43rd Avenue/Broadway and West 43rd Avenue Monitors when Winds are Greater than 2 mph, but do not Exceed 6 mph (0-175 degrees) . . . . . . . . . . V-16 Table V-6 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at West 43rd Avenue/Broadway and West 43rd Avenue Monitors when Winds are Greater than 2 mph, but do not Ex ceed 6 mph (180-360 degrees) . . . . . . . . V-17 Table V-7 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at 51st Avenue and West 43rd Avenue/Broadway (lagged 5-minutes) Monitors when Winds Exceeded 12 mph (180-355 degrees) . . . . . . V-18

ivLIST OF TABLES (Continued)
TABLE PAGE Table V-8 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at 67th Avenue and 51st Avenue (lagged 10-minutes) Monitors when Winds Exceeded 12 mph (180-355 degrees) . . . . . . . . . . . . . . . . . . V-19 Table V-9 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at 115th Avenue and 67th Avenue (lagged 25-minutes) Monitors when Winds Exceeded 12 mph (180-355 degrees) . . . . . . . . . . . . . . . . . . V-20 Table V-10 Particle Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-22 Table V-11 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at Arlington and Buckeye Monitors when are Greater than 12 mph . . . . . . . . . . . . . . . . . . . . . . V-32 Table V-12 Data Used to Calculate High Wind PM-10 Background Concentrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-35 Table V-13 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at Arlington and Buckeye Monitors when are Less than 12 mph . . . . . . . . . . . . . . . . . . . . . . . . V-38 Table V-14 Data Used to Calculate Low Wind PM-10 Background Concentrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-40 Table V-15 24-Hour Average N AAQS Exceedance Dates, Measured Concentrations and Associated Meteorological Conditions in 2007 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-42 Table V-16 Hourly PM-10 Concentrations and Wind Speeds at the Higley Monitor at 8:00 - 11:00 PM on August 23, 2007 . . . . . . . . . . . V-44 Table V-17 Hourly PM-10 Concentrations and Wind Speeds at the South Phoenix Monitor on August 13, 2007 . . . . . . . . . . . . . . . . . . . V-46 Table V-18 Comparison of PM-10 Concentrations During 2007 Exceedance Days Under Different Wind Regimes . . . . . . . . . . . . . . V-47 Table V-19 Peak Hourly PM-10 Concentrations and Wind Speeds in the Maricopa Nonattainment Area During 2007 . . . . . . . . . . . . . . V-47

vLIST OF TABLES (Continued)
TABLE PAGE Table V-20 Breakout of High and Low Wind Hours on Modeled Design Days at Each Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-54 Table V-21 Dust Plume Arc as a Function of Wind Speed . . . . . . . . . . . . . . . . . V-56 Table V-22 Results of Aerial Photography Analysis of Percentage of Bare Soil on Land Uses with both Bare and Covered Surfaces . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-64
Table V-23 Windblown PM-10 Emissi on Factors (tons/acre-five-minute) by 10-Meter Wind Speed Bin and Soil Stabilization . . . . . . . . . . . . . V-64 Table V-24 Calendar Year Rule Effectiveness Rates as Surrogates for Soil Disturbance Rates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-65 Table V-25 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for May 4, 2007 Design Day at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-68 Table V-26 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Central Phoenix Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-69 Table V-27 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Durango Complex Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-70 Table V-28 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Greenwood Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-71 Table V-29 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Higly Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-72 Table V-30 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West Phoenix Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-73

viLIST OF TABLES (Continued)
TABLE PAGE Table V-31 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-74 Table V-32 Annual Low Wind PM-10 Emission Inventory Allocated by Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-76 Table V-33 Annual Low Wind PM-10 Tons per Acre Emission Rates in the Nonattainment Area . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-77 Table V-34 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Salt River Area Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-77 Table V-35 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Central City Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-78 Table V-36 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Higley Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-78 Table V-37 2012 Attainment Demonstration High Wind Design Day (May 4, 2007) at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . . V-81 Table V-38 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Central Phoenix Monitor . . . . . . . . . . . . . . . . . V-82 Table V-39 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Durango Complex Monitor . . . . . . . . . . . . . . . V-83 Table V-40 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Greenwood Monitor . . . . . . . . . . . . . . . . . . . . . V-84 Table V-41 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Higley Monitor . . . . . . . . . . . . . . . . . . . . . . . . . V-85 Table V-42 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the State Super Site Monitor . . . . . . . . . . . . . . . . . V-86

viiLIST OF TABLES (Continued)
TABLE PAGE Table V-43 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West Phoenix Monitor . . . . . . . . . . . . . . . . . . . V-87 Table V-44 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West 43 rd Avenue Monitor . . . . . . . . . . . . . . . . V-88

viiiLIST OF FIGURES FIGURE PAGE Figure III-1 Demonstration of Reasonable Further Progress

................. III-7 Figure IV-1 Map of Highways in the PM-10 Nonattainment Area Swept by ADOT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-4 Figure IV-2 Map of Road and Alley Paving Projects Completed in January 2008 - September 2011 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IV-8 Figure V-1 Location of Temporary and Long-Term PM-10 Monitoring Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-7 Figure V-2 Relationship Between PM-10 Concentration and Source Distance at Different Wind Speeds . . . . . . . . . . . . . . . . . . . . . . . . . . V-23 Figure V-3 Relationship Between PM-10 Concentration and Source Distance Increments at 12 mph Wind Speed . . . . . . . . . . . . . . . . . . V-25 Figure V-4 Relationship Between PM-10 Concentration and Increasing Source Distances at 12 mph Wind Speed . . . . . . . . . . . . V-26 Figure V-5 Location of Temporary and Long-Term PM-10 Monitoring Sites . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-28 Figure V-6 Comparison of WD, WSPD and PM-10 Observations at Arlington, Buckeye and West 43rd Monitoring Sites During 4/28/2010 - 4/29/2010 High Wind Events . . . . . . . . . . . . . . . V-30 Figure V-7 Comparison of WD, WSPD and PM-10 Observations at Arlington, Buckeye and West 43rd Monitoring Sites During 5/22/2010 - 5/23/2010 High Wind Events . . . . . . . . . . . . . . . V-31 Figure V-8 Close-In View of Arlington Temporary Monitor and Angular Segments Included and Excluded from the Background Calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-36 Figure V-9 Hourly Average Wind Speed and PM-10 Concentration at West 43rd Avenue Monitor on June 6, 2007 . . . . . . . . . . . . . . . . V-49 Figure V-10 Hourly Average Wind Speed and PM-10 Concentration at Higley Monitor on June 6, 2007 . . . . . . . . . . . . . . . . . . . . . . . . . . . V-50

ixLIST OF FIGURES (Continued) FIGURE PAGE Figure V-11 Hourly Average Wind Speed and PM-10 Concentration at West 43rd Avenue Monitor on May 4, 2007 . . . . . . . . . . . . . . . . . V-51 Figure V-12 Example High Wind Trajectory and Resulting High Wind Domain (Hour 15 from West 43 rd Avenue Monitor on June 6, 2007) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-58 Figure V-13 Salt River Area Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . V-59 Figure V-14 Higley Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-60 Figure V-15 Central City Low Wind Domain . . . . . . . . . . . . . . . . . . . . . . . . . . . . . V-61 Figure V-16 Land Uses Capable of Producing Windblown Dust Within the Hour 15, West 43 rd Avenue Monitor, High Wind Domain (June 6, 2007) . . . . . . . . . . . . . . . . . . . . . . . . . . V-63

xI. INTRODUCTION The Technical Document in Support of the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area (TSD) descr ibes the base case emission inventories, quantification of measures used to meet the five percent and contingency requirements, and the modeling that demonstrates attain ment in the PM-10 nonattainment area. The U.S. Environmental Prot ection Agency (EPA) published a final notice on June 6, 2007 that the Maricopa County PM-10 Nonattainment Area had failed to attain the 24-hour PM10 standard by December 31, 2006. Section 189( d) of the Clean Air Act requires Serious nonattainment areas that do not meet the applicable attainment date to prepare a plan that reduces PM-10 emissions by at least five per cent per year until the standard is attained at all monitors. The Clean Air Act specifies t hat the plan must be bas ed on the most recent emissions inventory for the area, meet contingency requir ements, and include a modeling demonstration of attainment. The 2008 PM-10 Periodic Emission Inventory for the Maricopa County, Arizona, Nonattainment Area, revised in June 2011 (PEI), is the most recent emissions inventory for the area (Appendix A, Exhibit 1). This inventory has been used as the basis for the five percent and contingency reductions and the attain ment modeling requir ed by the Clean Air Act. Chapter II of the TSD describes the development of the 2007-2012 base case emission inventories that we re derived from the 2008 PEI. Chapter III discusses the methods used to quant ify rule effectiveness for Maricopa County Rules 310, 310.01 and 316. As described in the Pl an, the increases in rule effectiveness between 2007 and 2012 are sufficient to meet the annual five percent reduction requirements (Chapter Five) and demonstrate modeled attainment (Chapter Six). Chapter IV describes the technical assumpti ons used to meet cont ingency requirements of the Clean Air Act. The requirement is me t by quantifying the PM-10 emission reductions due to numerous projects completed in t he nonattainment area in 2008-2011. These projects include PM-10 certified street sweeping; paving and stabilizing unpaved roads, alleys and shoulders; reduci ng speed limits on unpaved roads and alleys, and overlaying payment with rubberized asphalt. As discussed in Chapter Six of the Plan, cumulatively, these reductions are sufficient to meet EPA’s contingency guideline of one year of reasonable further progress (RFP). Chapter V documents the technical assumpti ons underlying the rollback modeling used to demonstrate attainment by 2012. As discussed in Chapter Six of t he Plan, the modeling concludes that the PM-10 standard will be a ttained on high wind days at the West 43 rd Avenue monitor and throughout the PM-10 nonattain ment area by December 31, 2012.

I - 1II. BASE CASE PM-10 EMISSIONS Section 189(d) of the Clean Ai r Act requires that the plan provide an annual reduction in PM-10 emissions of not less than five percent of the emissions in the most recent inventory prepared for the area. The MAG 2012 Five Pe rcent Plan for PM-10 provides reductions of five percent per year from the 2007 base y ear until the attainment year of 2012. This chapter describes the devel opment of the base case emissions for 2007 through 2012. “Base case” emissions do not include reductions due to measures quantif ied in either the MAG 2007 Five Percent Plan or the MAG 2012 Five Percent Plan. In June 2011, the Maricopa County Air Quality Department finalized the latest version of the 2008 PM-10 Periodic Emissions Inventory (PEI). The 2007-2012 base case emissions are derived from the 2008 PEI (A ppendix A, Exhibit 1). Growth factors have been applied to the 2008 PEI emissions to estimate 2007 and 2009-2012 base case emissions. For most source categories, the growth factors are derived from projections for the PhoenixMesa metropolitan area released in August 2011 by Marshall Vest of the University of Arizona, Economic and Business Research C enter. These projections are based on the 2010 U.S. Census and the latest economic fo recasts for the Phoenix metropolitan area. Since the economic outlook for the United St ates and Arizona remains extremely volatile, the actual population and employment leve ls in 2011 and 2012 may differ from the projections. However, the University of Ariz ona growth factors represent the most reliable data currently available. Table II-1 summari zes the annual projection factors, relative to 2008, for population, construction employ ment and manufacturing employment. The remainder of this chapter documents the derivation of the 2007-2012 base case emissions in Table II-2. The discussion is or ganized by major source category, i.e., point, area, nonroad mobile and onr oad mobile. The order of the su bcategories is consistent with the source category sequence in Table II-2. All tonnage estimates referred to below represent annual PM-10 emissions in the Maricopa County PM-10 nonattainment area. POINT SOURCES Point sources of PM-10 emissions are those permitted sources that emit more than five tons per year of PM-10. T he 2008 PEI estimate of 149.84 tons from point sources is backcast to 2007 and projected to 2009-2012 usi ng the manufacturing employment growth factors shown in Table II-1. AREA SOURCES Area sources of PM-10 emissions include f uel combustion, wildfires, agriculture, construction, travel on unpaved parking lots, o ff-road recreational vehicles, leaf blowers, windblown dust, and industrial processes that are not large enough to qualify as point sources. The derivation of 2007-2012 base case emissions for each of these area sources is discussed below. As noted previously, t he source subcategories are organized in the same sequence as Table II-2. II - 1Table II-1Growth Factors for the PM-10 Nonattainment AreaFactors Relative to 20082007 2008 2009 2010 2011 2012Population0.981 1.000 1.005 1.008 1.012 1.021Construction Employment1.216 1.000 0.689 0.588 0.569 0.578Manufacturing Employment1.058 1.000 0.886 0.849 0.852 0.898Note: The growth factors above are based on the 3rdQuarter 2011 baseline projections for the Phoenix-Mesa metropolitanarea published by Marshall Vest, Economic and Business ResearchCenter, University ofArizona. The Phoenix-Mesametropolitan area includes all of Maricopaand Pinal Counties. The table below shows the Marshall Vest annual projectionsand percentage changes relative to each previous year, beginningin 2009. For 2007, the percent change is shown relativeto 2008, since 2008 is the year for the latest PM-10 emissions inventory (Appendix A, Exhibit 1).Year Population %ConstructionEmployment %ManufacturingEmployment %20074,087,390 -1.9% 169,392 21.6% 137,242 5.8%20084,167,019 139,358 129,68320094,186,131 0.5% 96,008 -31.1% 114,883 -11.4%20104,200,427 0.3% 82,021 -14.6% 110,047 -4.2%20114,215,500 0.4% 79,283 -3.3% 110,444 0.4%20124,251,802 0.9% 80,580 1.6% 116,448 5.4%II - 2Table II-22007-2012 Base Case Emissions in the PM-10 Nonattainment Areatons/yearSource Category 2007 2008 2009 2010 2011 2012POINT158.53 149.84 132.76 127.18 127.69 134.59AREAFuel combustion 1,275.94 1,300.65 1,307.15 1,311.07 1,316.32 1,328.17Commercial cooking 974.17 993.04 998.01 1,001.00 1,005.00 1,014.05Construction (includes windblown dust) 16,671.97 13,811.01 9,691.77 8,359.38 8,102.20 8,222.78Tilling, harvesting and cotton ginning 936.27 893.20 893.20 893.20 893.20 893.20Travel on unpaved farm roads 768.69 731.03 731.03 731.03 731.03 731.03Livestock 260.95 260.95 260.95 260.95 260.95 260.95Travel on unpaved parking lots 2,375.50 2,421.51 2,433.62 2,440.92 2,450.68 2,472.74Offroad recreational vehicles 2,138.74 2,180.16 2,191.06 2,197.63 2,206.42 2,226.28Leaf blowers 877.98 894.98 899.45 902.15 905.76 913.91Windblown agriculture 447.85 447.85 447.85 447.85 447.85 447.85Other windblown sources 5,430.01 5,430.01 5,430.01 5,430.01 5,430.01 5,430.01Fires 496.71 496.71 496.71 496.71 496.71 496.71Mining/quarrying (includes windblown dust) 752.18 721.38 660.84 641.08 642.89 667.32Travel on industrial paved/unpaved roads 770.71 728.46 645.41 618.31 620.78 654.30Other industrial sources 1,032.62 976.01 864.74 828.43 831.74 876.65NONROADAircraft 193.54 183.80 151.52 141.54 143.44 145.50Airport ground support equipment 28.64 26.99 23.32 20.94 20.11 19.90Locomotives 34.16 34.16 34.16 34.16 34.16 34.16Other nonroad equipment 1,709.76 1,682.91 1,660.64 1,640.88 1,595.22 1,513.25ONROADExhaust 2,943.36 2,835.65 2,647.20 2,371.05 1,843.23 1,407.06Tire wear 245.80 255.82 256.50 257.23 257.94 261.41Brake wear 727.66 758.17 767.49 770.58 772.79 787.25Paved roads 7,749.01 8,154.57 8,213.92 8,289.47 8,322.90 8,421.72Unpaved roads and alleys 10,217.66 10,312.22 10,284.04 10,284.04 10,284.04 10,312.22TOTALS 59,218.38 56,681.08 52,123.36 50,496.80 49,743.06 49,673.01II - 3Fuel Combustion This category includes residential, commerc ial and industrial gas, wood and oil burning. The 2008 PEI estimate of 1,300.65 tons from fuel combustion is back-cast to 2007 and projected to 2009-2012 using the population growth factors shown in Table II-1. Commercial Cooking This category includes restaurant cooking with five types of equipment: chain-driven charbroilers, under-fired charbroilers, deep-fat fryers, flat griddles and clamshell griddles. The 2008 PEI estimate of 993.04 tons for co mmercial cooking is back-cast to 2007 and projected to 2009-2012 using the populati on growth factors in Table II-1. Construction The 2008 PEI estimates of annual PM-10 emi ssions from construction are 1,692.38 tons for residential construction, 4,057.29 tons fo r commercial construction, 2,051.78 tons for road construction, and 162.41 t ons for other land clearing. The other land clearing category includes site preparati on, weed control and trenching. Rule Effectiveness (RE) rates for earth-movi ng activities permitted under Maricopa County Rule 310 have been calculated by the Maric opa County Air Quality Department using actual earthmoving inspection data for t he years 2007-2010. The methodology used in calculating the RE rates was developed in c onsultation with the Envi ronmental Protection Agency. The RE rate for Rule 310 in 2007 was 76 percent and in 2008, 90 percent. This major increase in rule effectiveness is attributable to st rengthened and increased enforcement of Rule 310. The 2008 PEI estimate of 7,963.86 tons for construction emissions was adjusted to account for the decrease in RE from 90 percent to 76 percent, resulting in non-windblown construction emissions of 13,245.15 tons. These 2008 emissions were back-cast to 2007 and projected to 2009-2012 using the construction employment growth factors in Table II-1. The addition of the windblown construction em issions of 565.86 tons, discussed in the Windblown Dust section below, produced the total 2008 base case construction emissions of 13,811.01 tons shown in Table II-2. Agriculture The 2008 PEI estimates of PM-10 emissions fr om agriculture include tilling and harvesting (888.34 tons), travel on unpaved farm roads (731. 03 tons), cotton ginning (4.86 tons), and livestock (260.95 tons). The factor to back-ca st agricultural activity from 2008 to 2007 was derived from the trends in Arizona Agricultur al Statistics Bulletins for Maricopa County between 2000 and 2004. (Complete data on crop acreage in Maricopa County was not available after 2004). Based on these trends , tilling and harvesting acreage was expected to decline by 4.6 percent between 2007 and 2008. This 4.6 percent decline between 2007
II - 4and 2008 translates into a 4.8 percent incr ease between 2008 and 2007. The agricultural emissions for 2009-2012 are held constant at 2008 PEI levels, due to reductions in agricultural product demand associated with t he economic recession that began in 2008. Travel on Unpaved Parking Lots The 2008 PEI estimate of 2, 365.07 tons of PM-10 emi ssions generated by vehicles traveling on unpaved parking lots was back- cast to 2007 and proj ected to 2009-2012 based on the population growth factors in Table II-1. Off-Road Recreational Vehicles The PEI estimate of 2,014.17 tons of PM- 10 generated off-road recreational vehicles was back-cast to 2007 and projected to 2009-2012 based on the population growth factors in Table II-1. Leaf Blower Fugitive Dust The PEI estimate of 894.98 tons of PM-10 produced by leaf bl owers was back-cast to 2007 and projected to 2009-2012 based on the populat ion growth factors in Table II-1.
Windblown Dust The 2008 PEI estimate for windblown dust from all sources is 4,814.80 tons. This includes windblown dust from construction (391.00 tons), mining/quarrying (131.57 tons), agriculture (354.24 tons) and vacant l and and other sources (3,937.99 tons) including open space, landfills and test tracks. Details concerning the methodology and data used to estimate the 2008 windblown dust emissions are provided in Appendix 4 of the 2008 PEI. To obtain base case emissions for windblown s ources, the rule effectiveness (RE) rates for each category in 2008 have been adjusted to the appropriate 2007 RE. Between 2007 and 2008, RE rates for construction increased from 76 to 90 percent; mining/quarrying increased from 40 to 65 percent; and vacant land increased from 85 to 95 percent. Adjusting the 2008 PEI emissi ons to these 2007 RE rates results in 565.86 tons for windblown construction, 190.36 tons for mini ng/quarrying, 5,430.01 tons for vacant land and other sources, and 447. 85 tons for agriculture. In the case of windblown agricultural, the non-cropland portions of windblown agricultu re emissions are assumed to have the same RE rates as vacant lands in the 2008 PEI and are thus affected by changes in RE rates from 2007 to 2008. The cropland portion of windblown agricultural emissions are calculated using a separate methodology in the 2008 PEI and are hel d constant between 2008 and 2007. The 2007 base case emissions for all windblow n categories are held constant from 2008 through 2012. Windblown construction and mi ning/quarrying emissions are added to the corresponding non-windblown categories in Table II-1, while windblown agriculture and II - 5other windblown sources are s hown as separate categories.
Fires This category include wildfires, prescribed fires, structure fires and vehicle fires. The 2008 PEI estimate for this category is 469.03 tons. This 2008 estimate is held constant in 2007 and 2009-2012 because the biggest contributor to this category is wildfires (90 percent), which are not possible to predict or control. Non-Metallic Mineral Processing and Mining/Quarrying Non-metallic mineral processing includes conc rete batch plants, ceramic clay and tile manufacturing, brick manufacturing and gypsum mining. The Mining/Quarrying category includes sand and gravel operations and other ty pes of mining. The 2008 PEI estimates are 187.73 tons for non-metallic mineral proc essing and 156.60 tons for mining/quarrying. Rule Effectiveness (RE) rates for non-metallic mineral processing and sand and gravel operations permitted under Maricopa County Rule 316 have been calculated by the Maricopa County Air Quality Department using actual inspection data for the years 2007- 2010. The methodology used in calculating the RE rates was developed in consultation with the Environmental Protecti on Agency. The RE rate fo r Rule 316 was 40 percent in 2007 and 65 percent in 2008. This major increas e in rule effectiveness is attributable to strengthened enforcement and increas ed compliance with Rule 316. The 2008 PEI emissions for non-metallic mineral processing and mining/quarrying were adjusted to account for the decr ease in RE from 65 percent to 40 percent, resulting in total non-windblown emissions of 531.01 tons. T hese 2008 emissions were back-cast to 2007 and projected to 2009-2012 based on the manufacturing employ ment growth factors in Table II-1. The addition of the windblown mining/ quarrying emissions of 190.36 tons, discussed in the Windblown Dust section abov e, produced base case non-metallic mineral processing and mining/quarrying emissions of 721.38 tons. These two categories are combined and denoted as “mining/quarrying” in Table II-2.
Travel on Industrial Roads
Travel on Industrial Roads includes emissions from motor vehicles traveling on paved and unpaved roads within the boundaries of a facility that is permitte d by Maricopa County. The 2008 PEI emissions for this category are 472.36 tons. The 2008 PEI estimate was adjusted to account for the decr ease in rule effectiveness for Rule 316, as discussed in the previous section. Decreas ing the RE from 65 percent to 40 percent produced 2008 base case emissions for travel on industrial roads of 728.46 tons. The base case 2008 emissions were back-cast to 2007 and proj ected to 2009-2012 based on the manufacturing employment growth factors in Table II-1.

II - 6Other Industrial Sources This category includes manufacturing and other i ndustrial activities that do not individually produce enough emissions to qualify as point s ources and are not addressed in any of the other Area Source categories above. The 2008 PEI estimate of PM-10 emitted by these other industrial sources is 976. 01 tons. The other industrial source emissions were backcast to 2007 and projected to 2009-2012 using the manufacturing employment growth factors in Table II-1. NONROAD MOBILE SOURCES
Nonroad mobile sources are those that move or are movable within a 12-month period and are not licensed or cert ified as highway vehicles. This category includes exhaust emissions from equipment used in agriculture, constructi on, mining, landscaping, commerce, industry and recreation. The category also includes aircraft, airport equipment and locomotives. The growth factors vary by equipment type. The 2008 PEI estimate of PM-10 emissions fr om all nonroad mobile sources is 1,927.89 tons per year for the PM-10 nonattainment area. The major source categories and emission estimates for 2007-2012 are discussed in the sections that follow. Aircraft and Airport Ground Support Equipment The 2008 PEI estimate of PM-10 emissions fr om aircraft is 183.80 tons, while airport ground support equipment (GSE) em issions, which include emi ssions from auxiliary power units (APUs), are 26.99 tons. These 2008 es timates were back-cast to 2007 and grown to 2009-2012 based on the growth fact ors shown in Table II-3. The aircraft growth factors were derived from estimates of landings and takeoffs (LTO) obtained from the Federal Aviation Administration (FAA). The growth factors for GSE were estimated using the FAA Emissions Dispersion Modeling Syst em (EDMS), version 5.1.3.
Locomotive Emissions The 2008 PEI PM-10 emissions estimate of 34. 16 tons for locomotives was derived from surveys of the three railroad companies t hat have operations in Maricopa County (Burlington Northern Santa Fe, Union Pacific and Amtrak). The 2008 locomotive emissions are held constant in 2007-2012. Other Nonroad Mobile Source Equipment The 2008 PEI estimate for other nonroad sources besides aircraft, airport GSE and locomotives is 1,682.94 tons. MAG ran the EPA NONROAD2008 model to estimate 2007- 2012 PM-10 emissions by source type using the same inputs assumed in the 2008 PEI (Appendix A, Exhibit 1). The 2007-2012 emissions by source type for other nonroad mobile source equipment and the corresponding growth factors are shown in Table II-4. The
II - 7Table II-3Growth Factors for Aircraft and Ground Support EquipmentPM-10 Annual Emissions from Aviation Sources in PM-10 NAA(metric tons) Growth Factors Relative to 2008Source Type 200712008 200922010 2011 2012 2007 2008 2009 2010 2011 2012Aircraft3254.80 241.98 199.49 186.34 188.84 191.56 1.053 1.000 0.824 0.770 0.780 0.792GSE+APUs430.74 28.97 25.03 22.48 21.59 21.36 1.061 1.000 0.864 0.776 0.745 0.737Total285.54 270.95 224.52 208.82 210.43 212.92 1.054 1.000 0.829 0.771 0.777 0.7861Landings and takeoffs (LTOs) for the years 2007,2008, and 2009 are extracted from the FAA website(http://aspm.faa.gov/opsnet/sys/Airport.asp);LTOs for years 2010-2013 are extracted fromthe FAA Terminal Area Forecast(TAF) (http://aspm.faa.gov/main/taf.asp).2LTOs for military aircraft in all airports, except Luke AirForce Base, are assumed to remain constant from 2009 -2012.3PM-10 emissions from aircrafts are calculatedby using emission factors from EPA’s guidance,Documentation for theNONROAD Model Criteria Air Pollutant Component of the National Emissions Inventory (NEI) for Base Years 1970–2001.Report prepared by E.H. Pechan & Associates for U.S. EPA Office of Air Quality Planning and Standards, Sept. 2003.4PM-10 emissions from Ground Support Equipment (GSE) and Auxiliary Power Units (APUs) are calculated using EDMS 5.1.3.II - 8Table II-4Growth Factors for Other Nonroad Mobile SourcesNONROAD2008 Annual PM-10 Emissions by Source Type for Maricopa CountyGrowth Factors Relative to 2008Source Type 2007 2008 2009 2010 2011 2012 2007 2008 2009 2010 2011 2012Agricultural Equipment 35.86 34.27 32.74 31.25 29.44 27.28 1.047 1.000 0.955 0.912 0.859 0.796Commercial Equipment 118.35 117.97 117.32 116.26 114.80 111.38 1.003 1.000 0.995 0.985 0.973 0.944Construction and Mining Equipment 1,286.45 1,260.98 1,240.09 1,222.25 1,178.71 1,105.11 1.020 1.000 0.983 0.969 0.935 0.876Industrial Equipment 105.13 102.60 100.81 99.24 97.06 90.98 1.025 1.000 0.983 0.967 0.946 0.887Lawn and Garden Equipment 179.69 182.19 184.91 187.72 190.75 192.37 0.986 1.000 1.015 1.030 1.047 1.056Logging Equipment 0.00 0.00 0.00 0.00 0.00 0.00 1.000 1.000 1.000 1.000 1.000 1.000Pleasure Craft 9.79 9.19 8.61 7.81 7.06 6.37 1.066 1.000 0.937 0.850 0.768 0.693Railroad Equipment 1.15 1.13 1.10 1.07 1.03 0.99 1.023 1.000 0.976 0.950 0.917 0.877Recreational Equipment 45.44 45.58 45.12 44.49 43.65 42.59 0.997 1.000 0.990 0.976 0.958 0.934Total (tons/year) 1,781.87 1,753.90 1,730.69 1,710.09 1,662.50 1,577.08 1.016 1.000 0.987 0.975 0.948 0.899II - 9growth factors for total other nonroad mobile source equipment shown at the bottom of the table were used to back-cast 2008 emissions to 2007 and project 2008 emissions to 2009- 2012. ONROAD MOBILE SOURCES There are three categories of PM-10 emissions from onroad mobile sources: exhaust, tire wear and brake wear; reentrained dust from paved roads; and travel on unpaved roads and alleys. Each of these categories is discussed in a separate section below. Exhaust, Tire Wear and Brake Wear Emissions The 2008 PEI estimate of PM-10 emissions fr om exhaust, tire wear and brake wear is 3,144.17 tons. The 2008 PEI emissions were estimated by MAG using the new EPA MOVES2010a model. The MOVES input assumptions are detailed in Chapter Five of the 2008 PEI (Appendix A, Exhibit 1). MAG re-estimated onroad mobile source emi ssions using the MOVES2010a model and the latest planning assumptions available in August 2011. The latest planning assumptions included July 1, 2011 vehicle registration dat a provided by the Arizona Department of Transportation. Due to the recession, the 2011 vehicle registrations contain a larger proportion of older vehicles than the 2010 vehicl e registrations used in estimating mobile source emissions for the 2008 PE I. In addition, the vehicle m iles of travel (VMT) and linklevel speeds were based on the latest MAG tr ansportation models, which incorporate a new truck model and updated volume/delay functions. The traffic assignments produced by the MAG transportation models in August 2011 had al so been validated against the most recent (2008-2010) traffic counts. Due to these changes in vehicle registrations and transportation modeling and the use of updated factors to c onvert from weekday to annual average daily traffic, the exhaust, tire wear and brake w ear emissions estimated with MOVES2010a for the 2008 base case PM-10 emissi ons are 3,849.64 tons, which is 22.4 percent higher than the 2008 PEI. The emission rates produced by MOVES for 2007- 2012 were applied to VMT estimates for the PM-10 nonattainment area. For 2008, the MOVES emission rates were applied to VMTs produced by the 2008 MAG traffic assignmen t. The 2007 VMT was derived from the 2008 VMT, using historical, pre-recession trends in VMT growth produced by MAG traffic assignments. The traffic counts MAG has c onducted since 2008 indicate that traffic volumes have not increased at their historic al rate. Therefore, for 2009-2012, the MOVES emission rates were applied to VMT estima tes based on the population growth factors in Table II-1, rather than VMTs output by t he MAG traffic assignments. The population projections shown in Table II-1 take into account the 2010 U.S. Census, as well as the economic downturn after 2007. In contrast, t he MAG traffic assignments utilize the official population projections adopted by the MAG R egional Council in May 2007. The adopted projections, which are based on the 2005 Special Census for Maricopa County, significantly overstate the socioeconomic growth in the area since 2008. MAG is working on new
II - 10population and employment projecti ons by traffic analysis zone that are consistent with the 2010 U.S. Census, but these will not be availabl e to use as input to the transportation models until early 2013. In t he meantime, the VMT estimates during the recession years of 2009-2012 are based on the best available popul ation projections for the area shown in Table II-1. The base case exhaust, tire w ear and brake wear emissions for 2007-2012 and the growth factors, relative to 2008, are shown in Table II-5.
Reentrained Dust from Paved Roads The 2008 PEI estimate of PM-10 emissions from dust reentrained by vehicles traveling on paved roads is 6,694.22 tons. The estimate is based on the new AP-42 equation for paved roads that was revised by EPA in January 2011. The PEI em issions include a reduction of 1,172.8 tons for PM-10 certified street sweepers purchased by December 31, 2006 with Congestion Mitigation and Air Quality Improvement (CMAQ) funds. The PEI estimate also includes reductions of 996.0 tons for five meas ures in the MAG 2007 Five Percent Plan that were implemented in 2008. The 2008 base case PM-10 emissions for the MAG 2012 Five Percent Plan were developed using the assumptions in the 2008 PEI, with one exception; the average vehicle weights for freeways and arterials have been re-estimated usi ng July 1, 2011 vehicle registrations and the EPA default vehicle weight of 3.18 tons, while the 2008 PEI used Ju ly 1, 2010 vehicle registrations and an average vehicle weight of 3 tons. The new vehicle weights for freeways (3.91 tons) and arterials (2.73 tons) were deriv ed from July 1, 2011 vehicle registrations and a 2008 traffic assignment. When weighted by VMT, these freeway and arterial weights average 3.18 tons. Other AP-42 input assumptions used in calculating paved road emissions are consistent with the 2008 PEI. The silt loadings in grams per square meter are 0.02 for freeways, 0.067 for high traffic arterials (> 10,000 average daily traffic (ADT)), and 0.23 for low traffic arterials (<10,000 ADT). The number of “w et” days per year is 39, while the annual number of days in the leap year of 2008 was 366. Applying these inputs to the AP-42 equation produces paved road emission rates of 0.11 grams per VMT for freeways, 0. 23 grams per VMT for high tra ffic arterials, and 0.71 grams per VMT for low traffic arterials. These emission rates are multiplied by the 2008 annual average daily VMTs used in the PEI, which are 30,835,329 for freewa ys, 42,498,543 for high traffic arterials, and 13,819,127 for low traffic arterials. The resultant uncontrolled paved road emissions for 2008 are 9,270. 34 tons, which is five perc ent higher than the 2008 PEI estimate without benefits for str eet sweepers and the five other measures in the 2007 Plan.
The uncontrolled paved road emissions do not include credit for PM-10 certified street sweepers that were purchased in 2001 through 2006. During this six year period, MAG member agencies purchased 94 PM-10 certified street sweepers to replace conventional (non-certified) sweepers, increase the fr equency of sweeping, and expand the area swept
II - 11Table II-52007-2012 PM-10 Emissions from Exhaust, Tire Wear and Brake WearPM-10 Emissions (tons/year) Growth Factors Relative to 20082007 2008 2009 2010 2011 2012 2007 2008 2009 2010 2011 2012Exhaust 2,943.36 2,835.65 2,647.20 2,371.05 1,843.23 1,407.06 1.038 1.000 0.934 0.836 0.650 0.496Tire Wear 245.80 255.82 256.50 257.23 257.94 261.41 0.961 1.000 1.003 1.005 1.008 1.022Brake Wear 727.66 758.17 767.49 770.58 772.79 787.25 0.960 1.000 1.012 1.016 1.019 1.038Total 3,916.81 3,849.64 3,671.19 3,398.86 2,873.96 2,455.72 1.017 1.000 0.954 0.883 0.747 0.638II - 12in the PM-10 nonattainment area. The agencies purchas ed the sweepers with Congestion Mitigation and Air Quality Improvement (CMA Q) funds and paid a minimum local match of 5.7 percent of the cost of each sweeper. As part of the funding request, the agencies provided MAG with data on the lane miles to be swept, the traffic volume per lane swept and the sweeping cycle length. These data hav e been used to quantify the PM-10 emission reductions attributable to the PM-10 cert ified sweepers purchased with CMAQ funds in 2001-2006. There were 94 PM-10 certif ied sweepers purchased with CMAQ funds between January 1, 2001 and December 31, 2006. An ADOT street sweeper inventory dated April 2, 2010 indicated that only 72 of these sweepers were st ill in service as of December 31, 2009. To be conservative in estima ting the emissions reduced by PM-10 certified sweepers, the benefits of the sweepers that were not in service as of December 31, 2009 have been removed. In addition, no credit is taken fo r the one sweeper purchased to replace an older PM-10 certified sweeper during this period. The sweeper-specific assumptions are shown in Appendix B, Exhibit 2. The equations used to quantify the benefit of the PM-10 certified sweepers are documented in the CMAQ Methodologies (MAG, 2011). The average unswept emission factors used in calculating the sweeper benefits for non-freeways is 0.35 grams per vehicle mile of travel (VMT). This represents a 2008 VMT-weighted average of 0.71 grams per VMT for low traffic arterials and 0.23 grams per VMT for hi gh traffic arterials. Table II-6 shows the emission rates for sweeping freeways, non-freewa ys and streets in the Sa lt River Area with PM-10 certified and conventional sweepers for sweeping cycle lengths of one to thirty days. In converting from daily to annual reductions, it was assumed that a new PM-10 certified unit would sweep 95 percent of the days during the first year, with the remainder of the time devoted to routine maintenance and holiday downtime. It was also assumed that the rate of utilization (and attendant emission reducti ons) would decline according to the usage factors shown in Table II-7 due to the need fo r increased mainten ance as the equipment ages. The usage factors are based on maint enance data provided by agencies requesting CMAQ funding for a new PM-10 certified sw eeper to replace an older PM-10 certified sweeper. The total PM-10 emissions reduction attrib utable to PM-10 certified street sweepers purchased in 2001 through 2006 and st ill in service as of De cember 31, 2009 is 1,115.77 tons in 2008. The uncontrolled paved road emissi ons estimate of 9,270.34 tons is reduced by the benefit of t he CMAQ-funded street sweepers, resu lting in 2008 base case paved road emissions of 8,154.57 tons. For 2007, 2009, and 2010, the reductions due to the sweepers purchased in 2001-2006 vary slightly, because the aging of the sweepers and increased dow ntime reduces the benefits over time. As a result, the reduction in 2007 is slightly higher than 2008: 1,153.93 tons, while the reductions in 2009 and 2010 are slightly lower: 1,077.32 tons and 1,029.63 tons, respectively. The 2008 uncontrolled base case paved road emissions are back-cast
II - 13Table II-6 PM-10 Emission Rates for PM-10 Ce rtified and Conventional Sweepers Cycle Length (days) Composite Emission Rates (g/VMT) - PM-10 Certified Sweeper Composite Emission Rates (g/VMT) - Conventional Sweeper Freeway Non-Freeway Salt River Freeway Non-Freeway Salt River 1 0.031 0.098 0.364 0.065 0.208 0.778 2 0.037 0.118 0.441 0.070 0.223 0.832 3 0.043 0.137 0.510 0.074 0.237 0.884 4 0.048 0.154 0.574 0.079 0.250 0.934 5 0.053 0.170 0.634 0.083 0.263 0.983 6 0.058 0.185 0.692 0.087 0.276 1.029 7 0.063 0.200 0.746 0.090 0.286 1.069 8 0.067 0.214 0.799 0.092 0.294 1.099 9 0.072 0.228 0.850 0.094 0.300 1.122 10 0.075 0.240 0.895 0.096 0.305 1.141 11 0.079 0.250 0.933 0.097 0.309 1.156 12 0.081 0.258 0.964 0.098 0.313 1.168 13 0.083 0.265 0.990 0.099 0.316 1.179 14 0.085 0.271 1.013 0.100 0.318 1.188 15 0.087 0.277 1.033 0.101 0.320 1.196 16 0.088 0.281 1.050 0.101 0.322 1.203 17 0.090 0.285 1.065 0.102 0.324 1.209 18 0.091 0.289 1.078 0.102 0.325 1.215 19 0.092 0.292 1.091 0.103 0.327 1.220 20 0.093 0.295 1.101 0.103 0.328 1.224 21 0.094 0.298 1.111 0.103 0.329 1.228 22 0.094 0.300 1.120 0.104 0.330 1.231 23 0.095 0.302 1.128 0.104 0.331 1.235 24 0.096 0.304 1.136 0.104 0.331 1.238 25 0.096 0.306 1.143 0.104 0.332 1.241 26 0.097 0.308 1.149 0.105 0.333 1.243 27 0.097 0.309 1.155 0.105 0.333 1.245 28 0.098 0.311 1.160 0.105 0.334 1.248 29 0.098 0.312 1.165 0.105 0.335 1.250 30 0.098 0.313 1.170 0.105 0.335 1.252

II - 14Table II-7 Usage Factors for PM-10 Certified Street Sweepers Usage Factor Table
Year of Use Usage Factor 1st 0.950 2nd 0.919 3rd 0.888 4th 0.857 5th 0.826 6th 0.795 7th 0.764 8th 0.734 9th 0.703 10th+ 0

II - 15to 2007 based on the vehicle miles of travel (VMT) estimated by the MAG transportation models for 2008 versus 2007. The reduction for sweepers purchased in 2001-2006 (1,153.93 tons) is then subtracted to der ive 2007 base case paved road emissions. To account for the economic recession, the 2008 uncontrolled base case paved road emissions are projected to 2009 and 2010 using the Marshall Vest population projections in Table II-1. The reductions for sweepers purchased in 2001-2006 (1,077.32 tons in 2009 and 1,029.63 tons in 2010) are then applied to estima te 2009 and 2010 base case paved road emissions. The 2010 base case paved road emissions with st reet sweeper reductions are projected to 2011-2012 based on the population growth factors in Table II-1. Travel on Unpaved Roads and Alleys The 2008 PEI estimate of PM-10 emissions fr om vehicles traveling on unpaved roads and alleys is 11,710.70 tons. This estimate is based on the EPA AP-42 equation for unpaved roads (assuming a speed of 25 mph) and unpav ed alleys (assuming a speed of 10 mph). The PEI estimate included a reduction of 2,065.4 tons for four measur es in the MAG 2007 Five Percent Plan that were implemented in 2008. Assumptions for calculating base case unpaved road and alley emissions for the MAG 2012 Five Percent Plan are consistent with the 2008 PEI, with the exception of the aver age daily traffic (ADT) on unpaved alleys and the ADT, speeds, and miles assumed for private unpaved roads. MAG conducted traffic counts on a statistically significant sample of unpaved alleys and private unpaved roads in the PM-10 nonattainment area in February 2011. The survey indicated that the ADT on unpaved alleys s hould be 4, rather than 10, and the ADT on private unpaved roads should be 26, rather than 28. In August-September 2011, MAG conducted a pr ivate unpaved road inventory. The MAG contractor drove most of the private unpaved roads identified in the MAG 2009 Unpaved Road Inventory (URI) and collect ed data on the location, length, condition and function of each road. The 2009 URI esti mate of 1,270.6 miles of private unpaved roads was based on a GIS analysis of aerial photographs, rather than actual field data. The 2011 field inventory concluded that ther e are 927.3 miles of privat e unpaved roads, which is 343.3 miles lower than estimated by the 2009 URI. The principal reason for this difference was the mis-classification of driveways, trails , utility and canal roads, barricaded routes, and inaccessible rights-of-way as private unpaved roads. The contra ctor also reported that the maximum speed that could be driven on the pr ivate unpaved roads was 15 to 20 miles per hour, rather than the 25 miles per hour assu med in the 2008 PEI. Unlike public unpaved roads, which typically carry higher traffic volumes and are better-maintained, private unpaved roads have rough surfaces and poor ali gnments, which reduces vehicle speeds. To be conservative, the speed used in quantif ying the private unpaved road emissions for the MAG 2012 Five Percent Plan was assumed to be 20 mph, which is the higher end of the range. Other inputs to the AP-42 equati on for paved roads are consist ent with the 2008 PEI. These include a silt content of 11.9 percent, a soil moisture content of 0.5 percent, and average
II - 16speeds of 25 mph on public unpaved roads and 10 mph on unpaved alleys. The average number of “wet” days in 2008 wa s 36, with the annual number of days in 2008, a leap year, of 366. The resultant emission factors for 2008 are 660.16 grams per VMT for public unpaved roads, 590.45 grams per VMT for private unpaved roads, and 417.45 grams per VMT for unpaved alleys. These factors are applied to annual average daily 2008 VMT estimates of 19,956 for public unpaved roads , 22,255 for private unpaved roads, and 2,600 for unpaved alleys in the PM-10 nonattainment area. Converting to annual emissions results in total 2008 base case emissions from public unpaved roads, private unpaved roads and unpaved alleys of10,312.22 tons. Base case public unpaved road and alley emissi ons are held constant between 2008 and 2007. The 2008 private unpaved r oad emissions are back-cast to 2007 assuming a growth rate of 1.46 percent between 2007 and 2008. This growth rate is based on a longitudinal analysis of historical lot split data con ducted by MAG that showed an average annual increase in private unpaved road mileage, prior to the recession, of 1.46 percent. Due to the economic downturn in 2008, base case em issions for public and private unpaved roads and alleys are held constant in 2008 through 2012. SUMMARY OF BASE CASE EMISSIONS
Table II-2 summarizes the 2007-2012 base case P M-10 emissions by source category that were developed using the methods and assumpti ons described in this chapter. The base case emissions include no reduction credit fo r measures quantified in the MAG 2012 Five Percent Plan. Credit for rule effectiveness rates in 2007 has been applied to the base case emissions for construction, other windblow n sources, mining/quarrying, and travel on industrial roads. In addition, reduction credit for PM-10 certified st reet sweepers purchased with CMAQ funds in 2001 through 2006 and still in service on December 31, 2009 was applied to the base case paved road emissions. The benefits quantified for increases in rule effectiveness and contingency projects in the MAG 2012 Five Percent Plan are discussed in the next two chapters of the TSD. The total 2012 base case emissions are 49, 673.01 tons, which is 9,545.37 tons (16.1 percent) lower than the 2007 emissions. Most of this decrease is due to reductions in construction activity between 2007 and 2012. T he sources contributing the largest share of base case PM-10 emissions in 2012 are unpaved roads and alleys, paved roads, construction and other windblown sources (vacant lots). The next chapter discusses the methods and a ssumptions used to quantify the increases in rule effectiveness for Maricopa County Ru les 310, 310.01 and 316. These increases are sufficient to demonstrate annual five percent reductions in PM-10 emissions between the base year of 2007 and the attain ment year of 2012. Credit for the increases in rule effectiveness is applied to the base case emi ssions in Table II-2 to meet the annual five percent reduction requirement of Clean Air Act Section 189(d).

II - 17REFERENCES MAG, 2011. Methodologies for Evaluating Congestion Mitigation and Air Quality Improvement Projects . Maricopa Association of Governments. September 30, 2011.

II - 18III. EVALUATION OF RULE EFFECTIVENESS This chapter describes the increases in rule effectiveness that have been quantified to meet the annual five percent reduction requirement in Section 189(d) of the Clean Air Act. The PM-10 emission reductions due to increased rule effectiveness are also used in demonstrating attainment, as discu ssed in Chapter V of the TSD. Increases in rule effectiveness have been ac hieved due to strengthene d enforcement and increased compliance with Maricopa County Rules 310, 310.01 and 316 in 2008-2010. Rule effectiveness rates are held constant fr om 2010 forward except for a 1% increase in 2012 on Rule 310.01 windblown dust sources due to the new Dust Action General Permit measure. In 2009 EPA approved Rule 316, which controls emissions from permitted sources of nonmetallic mineral processing and mining and qua rrying operations, as part of the State Implementation Plan for the Maricopa Count y PM-10 Nonattainment Area (SIP) (EPA, 2009). In 2010 EPA approved Rule 310, which controls emissions from permitted earthmoving sources, and Rule 310.01, which controls sources such as vacant lots and public unpaved roads, as part of the SIP (EPA, 2010). The benefit of increased compliance with thes e rules has been quantif ied, using actual inspection data and a methodology developed by the Maricopa County Air Quality Department, in consultation with EPA. The me thodology for quantifying rule effectiveness (RE) is described in the 2008 PEI (Appendix A, Exhibit 1). The RE rates calculated for 2007 through 2010 using this EPA-approved met hodology are shown in Table III-1.
Table III-1 also includes base case emissions (with 2007 RE rates), controlled emissions (with increased RE rates), and emission reduc tions (obtained by subtracting controlled emissions from base case emissions) for each subcategory. The derivation of the base case emissions is discussed in Chapter II of the TSD. For all years, the base case emissions assume the 2007 RE rates of 76 per cent for Rule 310, 85 percent for Rule 310.01, and 40 percent for Rule 316, while the controlled emi ssions incorporate the actual RE rate calculated for each year (2008-2010). The RE rates used in calculating controlled emissions are held constant after 2010. As shown in Table III-1, the rule effectiv eness (RE) rates increas ed dramatically between 2007 and 2008. Since 2008, the RE rates have continued to increase on an annual basis. Between 2007 and 2010, Rule 310 RE increased from 76 to 94 percent; Rule 310.01 RE increased from 85 to 96 percent; and Rule 316 RE increased from 40 to 73 percent. In addition to the increases in rule effectiv eness discussed above, the 2012 Plan takes credit for one new measure, the Dust Action General Permit, which were passed by the Arizona Legislature in April 2 011. This new measure is expected to increase rule effectiveness for Rule 310.01 by one percent dur ing high wind hours, resulting in the 2012 RE rate of 97 percent for windblown vacant land, open space, landfills and test tracks, as III - 1Table III-1Impact of Increased Rule Effectiveness on 2008-2012 PM-10 EmissionsCategories Affected by Rule EffectivenessBase Case Emissions (tons/year) Rule Effectiveness Rates2007 2008 2009 2010 2011 2012 2007 2008 2009 2010 -2011 2012Residential Construction 3,423 2,815 1,939 1,656 1,602 1,627 76% 90% 92% 94% 94%Commercial Construction 8,205 6,748 4,649 3,971 3,839 3,901 76% 90% 92% 94% 94%Road Construction 4,150 3,412 2,351 2,008 1,942 1,973 76% 90% 92% 94% 94%All Other Earthmoving 328 270 186 159 154 156 76% 90% 92% 94% 94%Non-metallic mineral mining 306 290 257 246 247 260 40% 65% 69% 73% 73%Mining & Quarrying 256 242 214 205 206 217 40% 65% 69% 73% 73%Industrial paved/unpaved road travel 771 728 645 618 621 654 40% 65% 69% 73% 73%Windblown Agriculture 448 448 448 448 448 448 n/a n/a n/a n/a n/aWindblown Construction 566 566 566 566 566 566 76% 90% 92% 94% 94%Windblown Vacant, Open, Landfill, Test Tracks 5,430 5,430 5,430 5,430 5,430 5,430 85% 95% 96% 96% 97%Windblown Sand & Gravel, Mining 190 190 190 190 190 190 40% 65% 69% 73% 73%TOTALS: 24,073 21,139 16,876 15,497 15,244 15,422Categories Affected by Rule EffectivenssControlled Emissions (tons/year) Benefits from RE Increases (tons/year)2007 2008 2009 2010 2011 2012 2008 2009 2010 2011 2012Residential Construction 3,423 1,692 1,056 807 780 793 1,122 884 849 821 834Commercial Construction 8,205 4,057 2,531 1,935 1,871 1,901 2,691 2,119 2,036 1,968 2,000Road Construction 4,150 2,052 1,280 979 946 961 1,361 1,071 1,029 995 1,011All Other Earthmoving 328 162 101 77 75 76 108 85 81 79 80Non-metallic mineral mining 306 188 152 132 132 139 102 105 114 114 121Mining & Quarrying 256 157 127 110 110 116 85 87 95 96 101Industrial paved/unpaved road travel 771 472 382 331 333 351 256 263 287 288 304Windblown Agriculture 448 448 448 448 448 448 0 0 0 0 0Windblown Construction 566 391 366 341 341 341 175 200 225 225 225Windblown Vacant, Open, Landfill, Test Tracks 5,430 3,938 3,788 3,788 3,788 3,639 1,492 1,642 1,642 1,642 1,791Windblown Sand & Gravel, Mining 190 132 123 113 113 113 58 68 77 77 77TOTALS: 24,073 13,689 10,353 9,062 8,939 8,879 7,450 6,523 6,435 6,305 6,543III - 2shown in Table III-1.
EPA allows an emission reduction to be taken for the new Dust Action General Permit, as an emerging measure (EPA, 2004). Accordi ng to EPA guidance, emerging measures do not have the same high level of certainty as traditional measures for quantification purposes in a State Implementation Plan. The PM- 10 emission reduction increment necessary to demonstrate attainment in 2012, (i.e., tota l 2012 base case emissions in Table II-2 of 49,673 tons minus total 2012 emissions with in creased rule effectiveness in Table III-2 of 43,130 tons), is 6,543 tons. EPA allows up to si x percent of this increment, in this case, a maximum of 393 tons, to be credited to em erging and voluntary measures in the SIP. The one percent increase in RE for Rule 310.01 during high wind hour s will reduce PM-10 emissions by 149.27 tons in 2012. Since this reduction is less than 393 tons, benefit for this new measure may be used in meeting t he annual five percent reduction requirement and demonstrating attainment in this Plan. As required by EPA’s emerging and voluntar y measure guidance, Maricopa County has made a commitment to retrospectively assess the performance of t he Dust Action General Permit. MCAQD will evaluate the effectivene ss of Rules 310, 310.01 and 316 to ensure that this measure achieves at least a 149 ton reduction during calendar year 2012. The County’s commitment and the method to be used in calculating rule effectiveness are described in Chapter Four and Appendix C, Exhibit 2. As discussed above, increases in Rule E ffectiveness (RE) for Rules 310, 310.01 and 316 have been quantified to meet the annual five per cent reductions requi red in Section 189(d) of the Clean Air Act. The annual five percent reduction target was calculated by multiplying the total 2007 PM-10 emissions in Table II-2 ( 59,218.38 tons) by five percent, which results in 2,960.92 tons. To meet the 189(d) requirement, the 2008 emissions with increased rule effectiveness must be at least 2,961 tons less than the 2007 base case emissions. Each year after 2008 imposes yet another 2,961 ton reduction requirement. Thus, the cumulative reduction requirements (relative to 2007 base case emissions) are at least 5,922 tons in 2009, 8,883 tons in 2010, 11, 844 tons in 2011, and 14,805 tons in 2012. Table III-2 shows the impact of the increases in rule effectiveness on PM-10 emissions in 2008 through 2012. A comparis on of the five percent reduction requirements with reductions actually achieved by increased rule effectiveness is provided at the bottom of the table. The actual reducti ons represent the difference between the total 2007 base case emissions in Table II-2 minus the total emissi ons with increased rule effectiveness in Table III-2 for 2008-2012. The total reduction in PM-10 emission between 2007 and 2012 with the increases in RE is 16, 088.55 tons, which represents a 27.2 percent reduction in 2007 base case emissions. Table III-3 confirms that the annual five percent reduction targets are met in 2008-2012 and there is a surplus margin of benefit in each year. The total surplus in 2012 is 1,284 tons. This surplus is needed to model attainment at all monitors in the PM-10 nonattainment area. The rollback m odeling that demonstrates attainment with the III - 3Table III-2 2008-2012 PM-10 Emissions with Increased Rule Effectiveness

Source Category 2008 2009 2010 2011 2012 (tons/year) POINT 149.84 132.76 127.18 127.69 134.59 AREA Fuel combustion 1,300.65 1,307.15 1,311.07 1,316.32 1,328.17 Commercial cooking 993.04 998.01 1,001.00 1,005.00 1,014.05 Construction (includes windblown dust) 8,354.86 5,333.29 4,139.15 4,013.81 4,072.58 Tilling, harvesting and cotton ginning 893.20 893.20 893.20 893.20 893.20 Travel on unpaved farm roads 731.03 731.03 731.03 731.03 731.03 Livestock 260.95 260.95 260.95 260.95 260.95 Travel on unpaved parking lots 2,421.51 2,433.62 2,440.92 2,450.68 2,472.74 Offroad recreational vehicles 2,180.16 2,191.06 2,197.63 2,206.42 2,226.28 Leaf blowers 894.98 899.45 902.15 905.76 913.91 Windblown agriculture 447.85 447.85 447.85 447.85 447.85 Other windblown sources 3,937.57 3,788.33 3,788.33 3,788.33 3,639.06 Fires 496.71 496.71 496.71 496.71 496.71 Mining/quarrying (includes windblown dust) 476.33 401.27 354.88 355.85 368.94 Travel on industrial paved/unpaved roads 472.36 382.21 331.37 332.70 350.67 Other industrial sources 976.01 864.74 828.43 831.74 876.65 NONROAD Aircraft 183.80 151.52 141.54 143.44 145.50 Airport ground support equipment 26.99 23.32 20.94 20.11 19.90 Locomotives 34.16 34.16 34.16 34.16 34.16 Other nonroad equipment 1,682.91 1,660.64 1,640.88 1,595.22 1,513.25 ONROAD Exhaust 2,835.65 2,647.20 2,371.05 1,843.23 1,407.06 Tire wear 255.82 256.50 257.23 257.94 261.41 Brake wear 758.17 767.49 770.58 772.79 787.25 Paved roads 8,154.57 8,213.92 8,289.47 8,322.90 8,421.72 Unpaved roads and alleys 10,312.22 10,284.04 10,284.0410,284.04 10,312.22 Totals 49,231.34 45,600.42 44,061.7543,437.87 43,129.84 5% Reduction Targets (tons/year) 2,961.00 5,922.00 8,883.0011,844.00 14,805.00 Actual Plan Reductions (tons/year) 9,987.05 13,617.97 15,156.6415,780.51 16,088.55

III - 4Table III-3 PM-10 Emission Reductions and Fi ve Percent Reduction Requirements

Year 5% Reduction Requirement Total PM-10 Emission Reductions due to Increases in Rule Effectiveness Excess Benefit = Total PM-10 Emission Reductions minus 5% Reduction Requirement (tons/year) (tons/year) (tons/year) (%) 2008 2,961 9,987 7,026 237% 2009 5,922 13,618 7,696 130% 2010 8,883 15,157 6,274 71% 2011 11,844 15,781 3,937 33% 2012 14,805 16,089 1,284 9%

III - 5increased rule effectiveness quantified in th is chapter is described in Chapter V.
The annual incremental reductions that dem onstrate reasonable further progress (RFP) between 2007 and 2012 are graphed in Figure III-1. After 2007, the RFP line represents total emissions in the PM-10 nonattainment area after credit is applied for the increases in rule effectiveness quantified in this chapter. The RFP requirement is met by showing incremental emission reductions sufficient to maintain linear progress towards attainment. The annual emissions in Figure III-1 show a dow nward linear trend. The slope of the line becomes less steep after 2008, because most of the measures in the MAG 2007 Five Percent Plan that increased compliance wit h Rules 310, 310.01 and 316 were implemented in 2008. Figure III-1 demonstrates that RFP will be achieved between 2007 and the attainment date of 2012. This chapter has quantified the increases in rule effectiveness between 2008 and 2012 in order to meet the five per cent reduction and reasonable furt her progress requirements of the Clean Air Act. Chapter V shows how thes e increases in rule effectiveness are also sufficient to demonstrate atta inment by 2012 through rollback modeling. The next chapter discusses the quantification of additional PM-10 emission reductions needed to meet the contingency requirements of the Clean Air Act.

III - 6Figure III-1 Demonstration of Reasonable Further Progress

III - 7REFERENCES EPA, 2004. Incorporating Emerging and Voluntary M easures in a State Implementation Plan. EPA Office of Air Quality Standards. September 2004.

III - 8IV. EVALUATION OF CONTINGENCY PROJECTS The increases in rule effectiveness due to measures in the MAG 2007 Five Percent Plan were quantified in Chapter III to demonstrate annual five percent reductions and reasonable further progress (RFP). The PM-10 emissi on reductions attributable to increased rule effectiveness are also used to model attainmen t, as discussed in Chapter V. This chapter discusses emission reductions above and beyond the increases in rule effectiveness that meet the contingency require ments of the Clean Air Act. Section 172(c)(9) of the Clean Air Act requi res that nonattainment plans contain contingency measures. Such m easures are to be undertaken wit hout further action by the State or the EPA Administrator if the area fails to make r easonable further progress or meet the standard by the attainment date. The contingency measures must achieve em ission reductions above and beyond those relied upon for progress (five percent reductions, milestones, and reasonable further progress) and the modeled attainment demonstr ation. The benefits of the contingency measures must not be required to show attainment and can not hasten attainment. Although there is no mandated emissions reduction level, EPA has recommended that contingency measures provide the emissions reduction equival ent of one year’s average increment of RFP. EPA enc ourages early implementation of contingency measures, so that emissions are reduced as expeditiously as practicable (EPA, 1993). The contingency requirement is met in the MAG 2012 Five Pe rcent Plan by quantifying the benefits of PM-10 reduction projects that we re implemented in 2008-2011. A large number of PM-10 r eduction projects have been impl emented in the nonattainment area since the MAG 2007 Five Percent Plan wa s submitted to EPA in December 2007. As required for contingency measur es, the emission reductions attributable to these projects are above and beyond the credit taken for the meas ures in Chapter Five. In the Fall of 2011, MAG updated the inventory of PM-10 reduction projects in the nonattainment area that were completed in 2008-2011 by the cities, towns, Maric opa County, Pinal County, the Arizona Department of Transporta tion (ADOT) and the Indian communities. These projects included paving and stabilizing unpaved roads, a lleys and shoulders; r educing speed limits on unpaved roads and alleys; and overlaying st ate highways with rubberized asphalt. In addition, MAG quantified the benef it for the freeways being sw ept by an ADOT contractor with PM-10 certified street sw eepers and the arterials being swept by local jurisdictions with PM-10 certified street sweepers purchased wit h Congestion Mitigation and Air Quality Improvement (CMAQ) funds between January 1, 2007 and December 31, 2009. The RFP graph shown in Figure III-1 indicates t hat total PM-10 emissions, after reductions due to increased rule effectiveness in 2008-2012, are 43,129.84 tons in 2012. Subtracting these 2012 emissions from the total 2007 emissi ons of 59,218.38 tons and dividing by five years produces a contingency target of 3,218 tons. Therefore, completed projects that reduce total PM-10 emissions by at least 3,218 tons in 2012 must be qua ntified to meet the contingency requirement. IV - 1The emission reductions for all projects quantified to meet t he contingency requirement are summarized in Table IV-1. This table incl udes the benefits of PM-10 certified street sweeping on freeways and arterials and PM-10 reduction projects completed in 2008-2011 that paved and stabilized unpaved roads, alleys and shoulders; reduced speed limits; and overlaid highways with rubberized asphalt. These projects were implemented in the PM-10 nonattainment area by twenty-one cities and towns, Maricopa County, Pinal County, ADOT and the Gila Riv er Indian Community. All of the projects for which credit was tak en were open to traffic between January 1, 2008 and September 30, 2011. The assumptions used in quantifying the PM-10 reductions needed to meet the contingency target are discu ssed below for each of the five project categories shown in Table IV-1. PM-10 CERTIFIED STREET SWEEPING PM-10 certified street sweepers m eet the certification criteria specified in South Coast Air Quality Management District Rule 1186. PM-10 certified street sweepers reduce the silt loadings on paved roads, relative to the use of conventional sweepers. The reentrainment of dust by vehicles traveling on the roads is reduced, which, in turn, decreases emissions and ambient concentrations of PM-10. ADOT Contracted Sweeping A new contract awarded by t he Arizona Department of Trans portation (ADOT), effective February 20, 2010, require s freeways, ramps and frontage roads in the PM-10 nonattainment area to be swept with PM-10 cert ified street sweepers. The ADOT contract also requires sweeping frequencies of every seven days for freeways and every fourteen days for ramps and frontage roads. A map of the specific highways being swept with PM-10 certified units by the ADOT contractor is provided in Figure IV-1. T he emission reduction calculations are shown in Table IV-2. The vehicle miles of travel (VMT) for freeways and ramps/frontage roads being swept in 2010 was estimated by summing the traffic vo lumes and link lengths from a 2010 traffic assignment for the routes identified in Figur e IV-1. In 2010, the freeways being swept with PM-10 certified sweepers by the ADOT cont ractor carry nearly 30 million VMT per day, which is 86 percent of the tota l daily freeway VMT in the P M-10 nonattainment area. All of the freeways and ramps/front age roads being swept by the AD OT contractor carry about 35 percent of the total daily VMT in the nonattainment area. The PM-10 emission reductions were derived by subtracting the emi ssion rate for PM-10 certified sweepers from the emission rate for conventional (non-certified) sweepers and

IV - 2Table IV-12008-2012 PM-10 Emission Reductionsfor Contingency ProjectsCompleted Projects Implementing Entities2008 2009 2010 2011 2012(tons/year)Sweep streets with PM-10 certified sweepersContracted sweeping of freeways, ramps and frontage roads100% compliant, effective 2/20/1025 PM-10 certified sweepers purchased with CMAQ funds:1/1/07-12/31/09ADOT 0 0 293.59 341.57 344.24Cities, towns 59.04 115.60 153.20 153.82 155.22Total for Street Sweeping 59.04 115.60 446.79 495.39 499.46Pave or stabilize existing public dirt roads and alleysPaving/stabilization projects completed in 2008-2011 Cities, towns, Maricopa and Pinal County,and Gila River Indian Community 461.30 1,351.81 2,124.38 2,662.09 2,625.41Total for Road/Alley Paving/Stabilization 461.30 1,351.81 2,124.38 2,662.09 2,625.41Lower speed limits on dirt roads and alleysSpeed limits lowered in 2008-2011Cities, towns, Maricopa County 3.61 78.42 160.97 160.97 161.41Total for Lower Speed Limits 3.61 78.42 160.97 160.97 161.41Pave or stabilize unpaved shouldersPaving/stabilization projects completed in 2008-2011Cities, towns, Maricopa County 173.31 241.75 264.70 293.34 150.01Total for Shoulder Paving/Stabilizing 173.31 241.75 264.70 293.34 150.01Repave or overlay paved roads with rubberized asphaltRubberized asphalt overlays completed in 2008-2011ADOT 0 2.61 2.61 2.61 2.61Total for Overlays 0 2.61 2.61 2.61 2.61Total for Completed Projects 697.25 1,790.19 2,999.45 3,614.40 3,438.90IV - 3Figure IV-1Map of Highways in the PM-10 Nonattainment Area Swept by ADOTIV - 4Table IV-2 PM-10 Emission Reductions for ADOT Sweeping

Facilities Swept in the PM-10Nonattainment Area VMT Swept in 2010 PM-10 reduction in tons/year 2008 2009 2010* 2011** 2012** Freeways 29,964,835 0.00 0.00 282.58 328.76 331.33 Ramps/Frontage Roads 2,153,217 0.00 0.00 11.01 12.81 12.91 Total 32,118,052 0.00 0.00 293.59 341.57 344.24 *2010 reductions are multiplied by 0.863 to reflect t he start date of the new ADOT contract - 2/20/10 **2011-2012 emission reductions are grown from 2010, based on 3 rd quarter 2011 population projections published by Marshall vest, University of Arizona, for the Phoenix-Mesa metro area (See Table II-1) Contract Requires Sweeping Cycle of 7 Days PM-10 EFs (g/mi) Non PM-10 PM-10 Difference in g/mi Freeways 0.090 0.063 0.027 Contract Requires Sweeping Cycle of 14 Days PM-10 EFs (g/mi) Non PM-10 PM-10 Difference in g/mi Ramps/Frontage Roads 0.100 0.085 0.015

IV - 5multiplying this difference by the VMT (i.e ., for freeways or ramps/frontage roads). The emission rates for sweeping cycle lengths of one to thirty days on freeways, non-freeways, and all roads in the Salt RiverArea are shown in Table II-6. The unswept emission factor based on the new EPA AP-42 emissions equation for paved roads is 0.11 grams per VMT for freeways and 0.35 grams perVMT for ramps/frontage roads. Other assumptions used in developing the street sweeping emission ra tes in Table IV-2 are detailed in the Methodologies for Evaluating Congestion Mitigat ion and Air Quality Im provement Projects (MAG, 2011). PM-10 Certified Street Sw eepers Purchased with CMAQ Funds PM-10 certified street sweeper s reduce PM-10 emissions generated by vehicles traveling on paved roads. Therefore, purc hase of these sweepers is elig ible for federal Congestion Mitigation and Air Quality Improvement (CMAQ) funding. Since 2001, more than 150 PM10 certified sweepers have been purchased with CMAQ funds by MAG member agencies. When purchasing a sweeper with CMAQ funds, the agency must provide a local match of at least 5.7 percent of the cost of the sweeper. PM-10 certified sweepers are eligible for MAG CMAQ funds if they replace a conventional sweeper, replace a PM-10 certified unit that is at least eight years old, increase the sweeping frequency, expand the area t hat is swept, or a combination of these functions. The equations used to calculate the benefit s of the CMAQ-funded sweepers are described in the CMAQ Methodologies (MAG, 2011). Data on sweeping frequency, lane miles swept and average weekday traffic per lane mile swept is provided to MAG by the agency r equesting funds to purchase the sweeper. The agency also identifies the functions to be per formed by the new sweeper. If the sweeping frequency or area is to be incr eased, the agency provides t he frequencies or lane miles to be swept before and after deployment of the new sweeper. Data provided by the requesting agencies is applied to calculate the PM-10 emission reductions associated with each purchased sw eeper. The detailed assumptions used to calculate the emission reductions for t he sweepers purchased between January 1, 2001 and December 31, 2006 are discussed in ChapterII under Reentrained Dust from Paved Roads. These reductions were applied to the 2007-2012 base case emissions. Contingency reduction credit is taken for 25 PM-10 certified sweepers purchased with CMAQ funds between January 1, 2007 and Decem ber 31, 2009. There were 28 sweepers purchased during this period, but no credit is taken for the three sweepers that replaced older PM-10 certified units. The methods us ed to calculate the benefit of these sweepers is consistent with those described in Chap ter II. The sweeper-specific assumptions are shown in Appendix B, Exhibit 2. The tota l emission reductions attributable to these 25 sweepers is 153.20 tons in 2010. The 2010 credit is pr ojected to 2011 and 2012 based on the population growth factors in Table II-1.

IV - 6PAVING AND STABILIZING UNPAVED ROADS AND ALLEYS In September 2011, MAG contacted its mem ber agencies to request detailed information on paving and stabilization of unpaved road and alley projec ts that had been implemented in January 2008- Septem ber 2011. The information collect ed included the location of the projects, the year of comple tion, the length in miles, av erage daily traffic before paving, whether the unpaved surface was stabilized prior to paving, and the funding source. This section describes the paving and stabilization pr ojects that were completed and open to traffic in 2008 through 2011 and the associ ated PM-10 emission reductions. The assumptions used in calculating the emi ssion rates for unpaved roads and alleys are consistent with those descr ibed under Travel on Unpaved Roads and Alleys in Chapter II. A map showing the location of the road and alley paving projects completed between January 2008- September 2011 is presented in Figure IV-2. The benefits of paving a public unpaved road is 660.16 minus 1.47 grams per VMT or 658.69 grams per VMT paved. The benefits of paving an unpaved alley is 417.45 minus 1.47 grams per VMT or 415.98 grams per VMT paved. The 1.47 grams per VMT represents the average emission rate for a paved road or alley without paved shoulders or curb and gutter. These emission rates are multiplied by the estimated VMT on each road before it is paved. If the unpaved road was st abilized prior to paving, the reduction credit is reduced by 50 percent. Credit for paving projects is only taken in the years after the project was completed. For example, credit fo r a paving project completed in 2009 is taken in 2010 through 2012; no credit is taken in 2009. The benefit of projects that stabilize unpaved roads and alleys is calculated using the same paving factors, but the benefit is reduced by 50 percent. Credi t for stabilization projects is only taken in the single year that the project was completed. For example, credit for a stabilization project completed in 2009 is taken only in 2009. Table IV-3 shows the miles and PM-10 benef its of paving and stabilizing unpaved roads and alleys in the PM-10 nonattainment area by jurisdiction. A summary of the paving and stabilization project mileage and PM-10 reductions is shown at the bottom of the table. Twenty cities and towns, Maricopa and Pinal Counties, and the Gila River Indian Community reported information on paving and stab ilization projects completed in January 2008-September 2011. During this period, 83.21 miles of unpaved roads and 133.69 miles of unpaved alleys were paved. Another 144. 75 miles of unpaved r oads and 500.66 miles of unpaved alleys were stabilized. The total PM-10 emissions reduced by the paving and stabilization of unpaved roads and alle ys is 2,625.41 tons in 2012. It is important to note t hat no credit is taken for stabilizati on projects in 2012, because these projects have not yet been impl emented. It is clear, howev er, based on the stabilization projects that were implem ented in 2008-2011, that some jurisdictions will be stabilizing unpaved roads and alleys in 2012 and therefore, the reduction cr edit calculated for paving unpaved roads and alleys in 2012 is conservative.

IV - 7IV - 8Table IV-3 PM-10 Reductions for Paving and Stabilizing Unpaved Roads/Alleys

Jurisdiction 2008 2009 2010 2011 2012 Total Miles Paved/Stabilized Apache Junction Miles of roads paved 8.72 2.00 0.77 11.49 Miles of roads stabilized 0.25 0.25 Miles of alleys stabilized 4.00 0.04 4.04 Total miles of paved/stabilized 12.97 2.04 0.77 0.00 0.00 15.78 PM-10 reductions (tons/year) 1.94 41.61 50.23 53.90 54.05
Avondale Miles of roads stabilized 0.22 0.22 Miles of alleys stabilized 5.50 2.79 8.29 Total miles of paved/stabilized 0.00 5.50 0.22 2.79 0.00 8.51 PM-10 reductions (tons/year) 0.00 1.84 1.05 4.45 0.00 Buckeye Miles of roads paved 2.50 1.66 1.30 0.30 5.76 Miles of roads stabilized 0.63 0.63 Miles of alleys paved 0.07 0.07 Miles of alleys stabilized 0.86 0.86 Total miles of paved/stabilized 3.99 1.73 1.30 0.30 0.00 7.32 PM-10 reductions (tons/year) 3.30 283.57 407.10 425.06 427.66
Cave Creek Miles of roads stabilized 10.00 10.00 10.00 10.80 40.80 Miles of alleys stabilized 2.00 2.00 2.00 2.00 8.00 Total miles of paved/stabilized 12.00 12.00 12.00 12.80 0.00 48.80 PM-10 reductions (tons/year) 48.51 48.37 48.37 52.19 0.00
Chandler Miles of roads paved 1.00 1.00 Miles of alleys stabilized 10.64 15.80 13.40 39.84 Total miles of paved/stabilized 11.64 15.80 13.40 0.00 0.00 40.84 PM-10 reductions (tons/year) 3.57 29.67 28.87 24.38 24.45 El Mirage Miles of roads stabilized 3.40 3.40 Miles of alleys paved 0.50 0.50 Miles of alleys stabilized 0.50 0.50 Total miles of paved/stabilized 4.40 4.40 PM-10 reductions (tons/year) 15.53 0.33 0.33 0.33 0.34
Fountain Hills Miles of alleys paved 0.19 0.25 0.45 0.89 PM-10 reductions (tons/year) 0.00 0.59 4.40 15.06 15.10

IV - 9Jurisdiction 2008 2009 2010 2011 2012 Total Miles Paved/Stabilized
Gilbert Miles of roads stabilized 3.62 3.62 3.62 0.75 11.61 Miles of alleys stabilized 3.00 3.00 Total miles of paved/stabilized 3.62 6.62 3.62 0.75 0.00 14.61 PM-10 reductions (tons/year) 17.32 18.27 17.27 3.58 0.00
Glendale Miles of alleys stabilized 0.25 0.25 PM-10 reductions (tons/year) 0.08 0.00 0.00 0.00 0.00 Goodyear Miles of roads paved 3.40 1.25 4.65 PM-10 reductions (tons/year) 0.00 184.13 214.61 214.61 215.20 Gila River Indian Community Miles of roads paved 3.40 5.00 1.00 9.40 PM-10 reductions (tons/year) 0.00 156.63 278.53 302.91 303.74
Litchfield Park Miles of alleys paved 1.60 1.60 PM-10 reductions (tons/year) 0.00 0.54 0.54 0.54 0.54 Maricopa County Miles of roads paved 1.05 4.38 2.00 10.68 18.11 Miles of roads stabilized 0.86 0.86 Total miles of paved/stabilized 1.05 4.38 2.00 11.54 0.00 18.97 PM-10 reductions (tons/year) 0.00 38.13 155.98 238.79 461.56
Mesa Miles of alleys stabilized 1.50 0.26 0.20 1.96 PM-10 reductions (tons/year) 0.50 0.09 0.07 0.00 0.00
Peoria Miles of roads stabilized 1.00 1.00 1.00 6.10 9.10 PM-10 reductions (tons/year) 4.78 4.77 4.77 29.10 0.00
Phoenix Miles of roads paved 5.70 1.54 3.16 10.40 Miles of alleys stabilized 66.81 40.30 25.70 13.25 146.06 Miles of alleys paved 60.53 63.30 123.83 Total miles of paved/stabilized 133.04 41.84 25.70 79.71 0.00 280.29 PM-10 reductions (tons/year) 22.36 106.88 116.28 112.13 198.09 Pinal County Miles of roads paved 15.22 2.30 1.53 1.95 21.00 PM-10 reductions (tons/year) 0.00 100.02 129.84 143.04 172.91

IV - 10Jurisdiction 2008 2009 2010 2011 2012 Total Miles Paved/Stabilized Queen Creek Miles of roads stabilized 1.00 1.00 PM-10 reductions (tons/year) 0.00 2.34 0.00 0.00 0.00
Scottsdale Miles of roads stabilized 16.68 16.80 17.36 12.02 62.86 Miles of alleys stabilized 36.00 16.00 80.00 85.00 217.00 Total miles of paved/stabilized 52.68 32.80 97.36 97.02 279.86 PM-10 reductions (tons/year) 297.99 285.85 316.62 291.26 0.00 Surprise Miles of roads paved 0.30 1.10 1.40 Miles of roads stabilized 3.49 6.30 4.00 13.79 Miles of alleys stabilized 3.69 3.69 Total miles of paved/stabilized 3.49 10.29 5.10 0.00 0.00 18.88 PM-10 reductions (tons/year) 16.69 30.05 337.46 738.60 740.63 Tempe Miles of roads stabilized 0.15 0.15 Miles of alleys stabilized 34.20 19.02 2.80 3.10 59.12 Total miles of paved/stabilized 34.35 19.02 2.80 3.10 59.27 PM-10 reductions (tons/year) 12.20 6.37 0.94 1.04 0.00
Tolleson Miles of alleys stabilized 0.50 0.75 1.25 PM-10 reductions (tons/year) 0.17 0.25 0.00 0.00 0.00 Youngtown Miles of roads stabilized 0.08 0.08 Miles of alleys paved 3.10 3.70 6.80 Miles of alleys stabilized 6.80 6.80 Total miles of paved/stabilized 9.90 3.78 0.00 0.00 0.00 13.68 PM-10 reductions (tons/year) 16.35 11.50 11.12 11.12 11.15
Total Miles 2008 2009 2010 2011 2008-2011 Miles of dirt roads paved 40.99 18.43 7.70 16.09 83.21 Miles of dirt roads stabilized 39.22 38.80 36.20 30.53 144.75 Miles of dirt alleys paved 65.92 4.02 0.45 63.30 133.69 Miles of dirt alleys stabilized 164.06 106.36 124.10 106.14 500.66 Total miles paved/stabilized 310.19 167.61 168.45 216.06 862.31 Total PM-10 Emissions Reduced (Tons/Year) 2008 2009 2010 2011 2012 Projects that paved or stabilized public dirt roads and alleys 461.30 1,351.81 2,124.38 2,662.09 2,625.41

IV - 11PAVING AND STABILIZING UNPAVED SHOULDERS In September 2011, MAG contacted its mem ber agencies to request detailed information on paving and stabilization of unpaved shoulderprojects that had been implemented in 2008- September 2011. The info rmation collected included the loca tion of the projects, the year of completion, the length in curb mile s, average daily traffic on the adjacent road, whether the unpaved surface was stabilized prior to paving, whether curb and gutter was also constructed and the fundi ng source. This section descr ibes the shoulder paving and stabilization projects that were comple ted in 2008 through 2011 and the associated PM-10 emission reductions. The emission rates for unpaved shoulders are described in the CMAQ Methodologies (MAG, 2011).
The emission reductions associated with paving an unpaved shoulder without curb and gutter are 0.29 grams per VMT on low traffic arterials, 0.20 grams per VMT on high traffic arterials and 0.49 grams per VM T in the Salt River Area. If adding curb and gutter, the emission rates are 0.38 grams perVMT for low traffi c arterials, 0.27 grams per VMT for high traffic arterials, and 0.66 grams per VMT in the Salt River Area. These emission rates are multiplied by the estimated VMT on the road adjacent to the paving or stabilization project. If the shoulders were stabilized prio r to paving, the benefit is reduced by 50 percent. Credit for paving shoulders is taken in the years after the project was completed. The benefit of projects that stabilize unpaved shoulders is calculated using the paving emission factors, but the benefit is reduced by 50 percent. Credit for stabilization projects is taken only in the year the project was completed.
Table IV-4 shows the curb miles and P M-10 benefits of paving and stabilizing unpaved shoulders in the PM-10 nonattainment area by jurisdiction. A summary of the paving and stabilization project mileage and PM-10 reductions is shown at the bottom of the table. Seventeen cities and towns, Maricopa Count y and ADOT reported information on paving and stabilization projects completed in 2008- September 2011. Duri ng this period, 232.73 miles of unpaved shoulders and 19.26 miles of curb and gutter were paved. Another 906.32 miles of unpaved shoulders were stabiliz ed. The total PM-10 emissions reduced by the paving and stabilization of unpav ed shoulders is 150.01 tons in 2012. It is important to note that no credit is tak en for shoulder stabilization projects in 2012, because these projects have not yet been implem ented. It is clear, however, based on the projects implemented in 2008-2011, that so me jurisdictions will be stabilizing unpaved shoulders in 2012 and therefor e, the reduction credit calculated for paving unpaved shoulders in 2012 is conservative. REDUCED SPEED LIMITS ON UNPAVED ROADS AND ALLEYS In September 2011, MAG cont acted its member agencies to request detailed information on reduced speed limits on unpav ed roads and alleys that had been implemented in 2008- September 2011. The information collected included the location of the projects, the year
IV - 12Table IV-4 PM-10 Reductions for Paving and Stabilizing Unpaved Shoulders

Jurisdiction 2008 2009 2010 2011 2012 Total Curb Miles Paved/Stabilized
ADOT Curb miles of shoulders paved 49.47 77.00 126.47 Curb miles of curb and gutter paved 19.26 19.26 Total miles paved & stabilized 68.73 77.00 145.73 PM-10 reductions (tons/year) 0.00 21.03 49.84 49.84 49.98 Apache Junction Curb miles of shoulders stabilized 6.26 6.26 1.50 14.02 PM-10 reductions (tons/year) 0.77 0.77 0.14 0.00 0.00
Avondale Curb miles of shoulders stabilized 6.05 6.05 12.10 PM-10 reductions (tons/year) 0.00 1.31 1.31 0.00 0.00 Buckeye Curb miles of shoulders paved 4.65 1.16 9.30 15.11 Curb miles of shoulders stabilized 8.10 8.10 Total miles paved & stabilized 4.65 1.16 17.40 23.21 PM-10 reductions (tons/year) 0.00 0.77 2.14 3.36 3.37
Chandler Curb miles of shoulders paved 3.30 3.30 Curb miles of shoulders stabilized 7.30 2.00 9.30 Total miles paved & stabilized 7.30 2.00 3.30 0.00 0.00 12.60 PM-10 reductions (tons/year) 8.22 2.25 0.00 7.41 7.43 El Mirage Curb miles of shoulders paved 1.62 1.62 Curb miles of shoulders stabilized 16.00 0.25 16.25 Total miles paved & stabilized 16.00 0.25 1.62 17.87 PM-10 reductions (tons/year) 5.52 0.03 0.00 0.63 0.63
Gilbert Curb miles of shoulders stabilized 15.88 15.88 15.88 15.88 63.52 PM-10 reductions (tons/year) 6.25 6.23 6.23 6.23 0.00
Glendale Curb miles of shoulders paved 2.46 2.46 Curb miles of shoulders stabilized 6.40 6.61 13.01 Total miles paved & stabilized 2.46 0.00 6.40 6.61 0.00 15.48 PM-10 reductions (tons/year) 0.00 3.35 5.13 6.65 3.36 Guadalupe Curb miles of shoulders paved 1.60 1.60 1.60 0.50 5.30 PM-10 reductions (tons/year) 0.00 0.45 0.91 1.36 1.51
IV - 13Jurisdiction 2008 2009 2010 2011 2012 Total Curb Miles Paved/Stabilized Maricopa County Curb miles of shoulders paved 13.17 13.17 PM-10 reductions (tons/year) 0.00 0.00 0.00 14.89 14.93
Mesa Curb miles of shoulders paved 5.31 23.70 12.11 41.12 Curb miles of shoulders stabilized 0.75 0.75 Total miles paved & stabilized 5.31 23.70 12.86 0.00 0.00 41.87 PM-10 reductions (tons/year) 0.00 41.01 41.35 41.01 41.12
Peoria Curb miles of shoulders stabilized 43.13 43.13 43.13 43.13 172.52 PM-10 reductions (tons/year) 8.96 8.94 8.94 8.94 0.00
Phoenix Curb miles of shoulders paved 3.85 3.56 1.29 3.90 12.60 PM-10 reductions (tons/year) 0.00 0.97 1.99 2.35 3.21 Queen Creek Curb miles of shoulders paved 1.85 1.85 Curb miles of shoulders stabilized 9.03 25.02 26.94 60.99 Total miles paved & stabilized 10.88 25.02 26.94 0.00 0.00 62.84 PM-10 reductions (tons/year) 6.48 18.44 17.32 0.53 0.53
Scottsdale Curb miles of shoulders paved 4.00 2.00 6.00 Curb miles of shoulders stabilized 131.60 132.20 123.80 134.60 522.20 Total miles paved & stabilized 131.60 132.20 127.80 136.60 0.00 528.20 PM-10 reductions (tons/year) 136.47 135.48 128.65 147.83 21.64 Surprise Curb miles of shoulders paved 2.67 2.67 Curb miles of shoulders stabilized 2.82 2.74 3.50 9.06 Total miles paved & stabilized 2.82 2.74 6.17 0.00 0.00 11.73 PM-10 reductions (tons/year) 0.36 0.28 0.52 2.08 2.09 Tempe Curb miles of shoulders paved 0.06 0.06 Curb miles of shoulders stabilized 0.50 0.50 Total miles paved & stabilized 0.50 0.06 0.00 0.00 0.00 0.56 PM-10 reductions (tons/year) 0.06 0.00 0.01 0.01 0.01
Tolleson Curb miles of shoulders paved 1.00 1.00 PM-10 reductions (tons/year) 0.00 0.22 0.22 0.22 0.22

IV - 14Jurisdiction 2008 2009 2010 2011 2012 Total Curb Miles Paved/Stabilized Youngtown Curb miles of shoulders stabilized 2.00 2.00 4.00 PM-10 reductions (tons/year) 0.22 0.22 0.00 0.00 0.00
Total Curb Miles 2008 2009 2010 2011 2008-2011 Curb miles of dirt shoulders paved 70.19 107.08 49.06 6.40 232.73 Curb miles of curb and gutter paved 19.26 0.00 0.00 0.00 19.26 Curb miles of dirt shoulders stabilized 234.52 235.53 236.06 200.22 906.32 Total curb miles paved & stabilized 323.97 342.61 285.11 206.62 1,158.31 Total PM-10 Emissions Reduced (Tons/Year) 2008 2009 2010 2011 2012 Pave or stabilize unpaved shoulders 173.31 241.75 264.70 293.34 150.01

IV - 15of completion, the length of the roads im pacted by the reduced speed limits, and the average daily traffic on the unpaved road or alle y. This section describes the reduced speed limit projects that were complet ed in 2008 through 2011 and the associated PM-10 emission reductions. Table IV-5 provides the miles of roads and alleys for which speed limits were reduced and the associated PM-10 reductions by jurisdiction. Two towns and Maricopa County posted lo wer speed limits on unpaved roads and alleys in 2008-2009. Buckeye posted 15 mph signs on 5.4 miles of unpaved roads; the average speed prior to posting was assumed to be 25 mph, which is the ADOT Department of Motor Vehicles speed limit if ther e are no signs posted. Youngt own posted 10 mph speed limits on 6.8 miles of unpaved alleys; it was assum ed that the average speed prior to posting was 15 mph. Maricopa County pos ted 15 mph speed limits on 6. 42 miles and 25 mph speed limits on 1.74 miles of unpaved roads. It was assumed t hat the speeds on these County roads decreased by 10 mph as a result of the lower speed limits. It was also assumed that compliance with all of these new speed lim its would be 70 percent. The unpaved road and alley emission rates used in calculating credi t for these lower speed limits are consistent with those used in the 2008 PEI. OVERLAYS WITH RUBBERIZED ASPHALT In September 2011, MAG cont acted the Arizona Department of Transportation (ADOT) to request detailed information on the state hi ghways that had been overlaid with rubberized asphalt in 2008-September 2011. The in formation collected included the year of completion, route names, the start and end poi nts, the number of lanes, and the average traffic volume per lane. Table IV-6 shows the assumptions used to calculate the PM-10 reductions in tire wear emissions for the highways that were overlaid with rubberized asphalt in 2008 by ADOT. The total PM-10 emi ssion reductions associat ed with this project are 2.61 tons in 2009-2012. DEMONSTRATION THAT THE PM-10 RE DUCTION PROJECTS IMPLEMENTED IN 2008-2011 MEET CONTINGENCY REQUIREMENTS As shown in Table IV-1, the total PM-10 em issions reduction in 2012 due to implementation of the projects described above is 3,439 tons . This reduction exceeds the contingency target of 3,218 tons by 221 tons. Therefor e, the emission reductions from the projects described in this chapter meet the cont ingency requirements of the Clean Air Act. As discussed previously, no credit has been taken for unpaved road, alley and shoulder stabilization projects in 2012, because these projects have not yet been implemented. It is clear, however, based on the projects impl emented in 2008-2011, that some jurisdictions will be stabilizing unpaved roads, alleys and s houlders in 2012 and therefore, the contingency reduction credit calculated for 2012 is conservative. The projects that have been quant ified for contingency credit are not required to meet the five percent requirement, model attainmen t, or demonstrate reas onable further progress. IV - 16Table IV-5 PM-10 Reductions for Reduced Speed Limits on Unpaved Roads and Alleys

Jurisdiction 2008 2009 2010 2011 2012 Total Miles Buckeye Miles of roads with lower speeds 2.50 2.90 5.40 PM-10 reductions (tons/year) 0.00 78.42 155.06 155.06 155.48 Maricopa County Miles of roads with lower speeds 8.16 8.16 PM-10 reductions (tons/year) 0.00 0.00 5.91 5.91 5.93 Youngtown Miles of alleys with lower speeds 6.80 6.80 PM-10 reductions (tons/year) 3.61 0.00 0.00 0.00 0.00 Total Miles Impacted 2008 2009 2010 2011 2008-2011 Miles of roads/alleys with lower speed limits 6.80 10.66 2.90 0.00 20.36 Total PM-10 Emissions Reduced (tons/year) 2008 2009 2010 2011 2012 Lower speed limits on unpaved roads/alleys 3.61 78.42 160.97 160.97 161.41

IV - 17Table IV-6PM-10 Reductions for ADOT Overlays with Rubberized AsphaltAvg # ofLanesAvg VehiclesPer LaneReduction*(tons/lanemile/year)PM-10 reduction (tons/year)Route Start End Miles 2008 2009 2010 2011 2012Interstate 10 Ray RoadWildhorsePass2.84 6.68 15,065 0.0301 0.57 0.57 0.57 0.57Interstate 17 ArizonaCanalThunderbirdRd2.75 8.00 25,837 0.0517 1.14 1.14 1.14 1.14State Route 143 Interstate 10 Van Buren St 2.80 5.73 18,443 0.0369 0.59 0.59 0.59 0.59State Route 202L,Red Mtn FreewayPower Road University Dr 4.64 6.23 5,363 0.0107 0.31 0.31 0.31 0.31Totals 13.03 0.00 2.61 2.61 2.61 2.61*ADOT indicated in the MAG 2007 Five Percent Plan that an averageof 17,000 vehicles per lane result in a PM-10 emission reduction of 0.034tons/lanemile/year for rubberized asphalt overlaysIV - 18In addition, these projects will not hasten atta inment. As discussed in Chapter V, the earliest attainment date that can be demonstrated via modeli ng is December 31, 2012. This chapter demonstrates t hat PM-10 emissions will be reduc ed by 3,439 tons more than the reductions achieved by m easures used to show progress and model attainment. The contingency projects implement ed in 2008-2011 are assisting in producing the three years of clean data necessary to attain the standard at all monitors by December 31, 2012. PM-10 EMISSION REDUCTIONS DUE TO ALL MEASURES AND PROJECTS IN THE FIVE PERCENT PLAN Table IV-7 shows the PM-10 emissions fo r 2008-2012 by source category after increased rule effectiveness and contingency reductions ar e applied. The total reduction attributable to the rule effectiveness increases and conti ngency projects in the MAG 2012 Five Percent is 9,982 tons in 2012. This represents a 17 percent reduction, relative to 2007 emissions. Total PM-10 emissions with all measures and contingency projects decline by 19,527 tons or 33 percent between 2007 and 2012.

IV - 19Table IV-7 2008-2012 PM-10 Emissions with All Plan Measures and Contingency Projects Source Category 2008 2009 2010 2011 2012 POINT 150 133 127 128 135 AREA Fuel combustion 1,301 1,307 1,311 1,316 1,328 Commercial cooking 993 998 1,001 1,005 1,014 Construction (includes windblown dust) 8,355 5,333 4,139 4,014 4,073 Tilling, harvesting and cotton ginning 893 893 893 893 893 Travel on unpaved farm roads 731 731 731 731 731 Livestock 261 261 261 261 261 Travel on unpaved parking lots 2,422 2,434 2,441 2,451 2,473 Offroad recreational vehicles 2,180 2,191 2,198 2,206 2,226 Leaf blowers 895 899 902 906 914 Windblown agriculture 448 448 448 448 448 Other windblown sources 3,938 3,788 3,788 3,788 3,639 Fires 497 497 497 497 497 Mining/quarrying (includes windblown dust) 476 401 355 356 369 Travel on industrial paved/unpaved roads 472 382 331 333 351 Other industrial sources 976 865 828 832 877 NONROAD Aircraft 184 152 142 143 146 Airport ground support equipment 27 23 21 20 20 Locomotives 34 34 34 34 34 Other nonroad equipment 1,683 1,661 1,641 1,595 1,513 ONROAD Exhaust 2,836 2,647 2,371 1,843 1,407 Tire wear 256 254 255 255 259 Brake wear 758 767 771 773 787 Paved roads 7,922 7,857 7,578 7,534 7,772 Unpaved roads and alleys 9,847 8,854 7,999 7,461 7,525 Totals 48,534 43,810 41,062 39,823 39,691 Total PM-10 Emissions Reduction 2007-2012: 19,527 tons, 33.0%

IV - 20REFERENCES EPA, 1993. Early Implementation of Contingency Measures for Ozone and Carbon Monoxide (CO) Nonattainment Areas. August 1993. MAG, 2011. Methodologies for Evaluating Conges tion Mitigation and Air Quality Improvement Projects . Maricopa Association of Governments. September 30, 2011.

IV - 21V. ATTAINMENT MODELING INTRODUCTION
In order to show attainment with the 24-hour PM-10 National Ambient Air Quality Standard for the Maricopa County PM-10 nonattainment area under high wind conditions, modeling was performed for both the PM-10 nonattainm ent area and a subset of the nonattainment area known as the Salt River area. The sect ions in this chapter of the TSD provide a detailed discussion of the elements necessaryto perform the attainment modeling and demonstrate that attainment is me t in 2012; specifically including:

! The reasons for choosing distance-wei ghted rollback as a conceptual model for the attainment demonstration;

! An analysis of the insights gained thr ough operation of a short-term PM-10 temporary monitor saturation study;

! The application of a PM-10 emissions source weighting factor based upon distance from the exceeding monitor;

! An analysis of the non-anthropogenic lo w and high wind background PM-10 concentrations in the Maricopa County nonattainment area;

! The process for selecting design days;

! The development of low and high wind modeling domains;

! The creation of model-ready low and high wind emissions inventories;

! Application of the benefits of the control measures; and

! A demonstration of attainment in 2012. An overview of the attainment modeling c an be found in Chapter Five of the main plan document.

V - 1CONCEPTUAL MODEL In December 2007, the Maricopa Association of Governments (MAG) submitted the “MAG Five Percent Plan for PM-10 for the Maric opa County Nonattainment Area” (Five Percent Plan) to the U.S. Environment al Protection Agency (EPA) in fulfillment of federal Clean Air Act requirements after a failure to attain the 24-hour PM-10 ambient air quality standard (standard) by the statutory dead line of December 31, 2006. The MAG 2007 Five Percent Plan for PM-10 included fifty-three control m easures that demonstr ated PM-10 emissions reductions of five percent per year and a ttainment of the PM-10 standard in 2010. In 2008, there were a number of exceedances of the 24-hour PM- 10 standard due to high winds in the Maricopa County nona ttainment area. EPA indicated that it did not concur with four high wind exceptional events at the West 43 rd Avenue monitor, which constituted a violation. The region then did not have the three years of clean data needed for attainment. In September 2010, EPA published a notice to propose a partial approval and disapproval of the MAG 2007 Five Percent Plan for PM-10. The two major reasons for the proposed disapproval were inaccuracies in t he 2005 baseline emissions inventory and EPA’s nonconcurrence with the four high wind exceptional events. In January 2011, the Arizona Department of Environmental Q uality (ADEQ) withdrew the MAG 2007 Five Percent Plan for PM-10 to address the technical approvability issues identified by EPA, and to include new informa tion such as the new EPA equation for paved road dust emissions. EPA has indicated that t he revised plan needs to show how high wind emissions will be adequately mitigated.
Presented below is a review of the issues considered in assessing available modeling concepts and the steps leading to the selecti on of distance-weighted rollback as the conceptual model. Modeling Domain Due to the uniform pattern and di rection of wind flows upwind of the Salt River monitors during high wind events in the Spring, the use of modeling domai ns extending along wind back-trajectories from these monitors focuse s the areal extent of these modeling domains to the areas of significant em ission contribution. Past analyse s of back-trajectories related to exceptional event evaluations in the Spring have shown that many are from the west/southwest and lie along the Salt River channel due to prevailing synoptic wind fields and the topographic influence of the Estrella M ountains lying directly south and running parallel to the river channel. Furthermore, past modeling analyse s indicate that the lands significantly contributing to elevated PM-10 concentrations recorded at a monitoring site lie generally within a mile of ei ther side of the back-trajectorypath upwind of the monitor. Since the areal extent impacting monitors is largely a function of wind speed, it necessary to divide selected design days into low and high wind hours. High wind hours need to represent sources located along back trajec tories and low wind hours need to represent V - 2sources within a modeling domai n surrounding the selected moni toring site. A significant amount of work was devoted to developing t he Salt River area m odeling domain in the withdrawn Five Percent Plan which is employ ed to assess emissions impacting Salt River monitors during low wind hours. As part of a regional demons tration of attainment, other low wind modeling domains that represent similar distribut ions of land use around modeled monitors are developed as necessary. The basis for distinguishing between low and high wind hours is the 12 mph aerodynamic entrainm ent threshold (i.e., five-minute average) established in the 2008 PM-10 Peri odic Emissions Inventory (Appendi x A, Exhibit 1). Both, five-minute and hourly wind measur ements at selected monitori ng sites are available and can screen to determine which hours are “hi gh wind” hours. The remaining hours are assumed to be “low wind” hours. Modeling Inventory Development The withdrawn Five Percent Plan expended consi derable resources in collecting sourcespecific activity data (e.g., traffic counts, aggregate facility operating records, silt measurements, etc.) within t he modeling domain to provide an accurate representation of emissions on the days selected for modeling. The focus of that e ffort, however, was on characterizing emissions under low wind stagnant conditions. While emission estimates were also prepared for a high wind day, t he model performance resulting from that inventory was considerably poorer than for the inventories developed for days with stagnant conditions. Given that experi ence, it suggests a different emissions inventory methodology is needed (i.e., one along the lines of quantifyi ng upwind emissions along a back trajectory during high wind hours and low wind emissions within a modeling domain surrounding the selected monitoring site). Due to the limited contribution of low wind hours to the 24- average values recorded on high wind days it is suggested that design-day specific low wind inventories are not necessary to charac terize low wind hour emissions within the Salt River modeling domain and the PM-10 nonattainm ent area as a whole. Instead, it is planned that existing annual emission estimates be employed through allocation of those emissions to the land uses withi n each of the modeling domains. For high wind hours, the methodology employed in the windblown dust emissions inventory developed for the 2008 PM-10 Periodic Emissions In ventory is used to quantify fugitive dust emissions at upwind sources located along back-trajectory domains from each of the modeled monitors. One question that had not been previously researched, was how far back along a back-trajectory line the modeling domain should extend. Insight into this question is provided in the discussion below of data collected at a temporary monitor upwind of the West 43 rd Ave. monitoring site. Temporary Monitoring Insights An analysis of matched pair meas urements between the West 43 rd Ave. long-term monitor and 43rd Ave. & Broadway tempor ary monitor (a distance of 0.42 miles) was prepared for the period between April 2010 and March 2011. The data were organized into five-degree increments so concentration differences could be computed as a functi on of wind direction V - 3and wind speed. Measurements were organized in to three categories of wind speed: 2-6 mph, 6-12 mph, and >12 mph ( both monitors had to have wind speeds falling into these categories to be included in the analysis). Tabulations of the results for these monitors and other temporary monitors are presented in the subsequent secti on entitled Temporary Monitoring Insights. The result s for these monitors show thatat 240°, the angular direction traveling southwest from the West 43 rd Ave. monitor to the West 43 rd Ave. & Broadway temporary monitor, average c oncentrations at the West 43 rd monitor are consistently higher than at the temporary site:

! At 2-6 mph, the difference (West 43 rd - West 43 rd & Broadway/West 43 rd ) is 13.5% (6.38 μ g/m 3 );

! At 6-12 mph, the difference is 9% (3.2 μ g/m 3 ); and

! At >12 mph, the difference is 37.3% (39.78 μ g/m 3 ) The >12 mph differences increase as the angular direction increases from 240° - 290°, suggesting that fugitive dust from land lo cated between those sites disproportionately impacted concentrations at the West 43 rd Ave. monitoring site ( particularly since emissions impacting the monitor at that hour are coming from a minimum distance of 12 miles and the distance between the monitors is 0.42 miles). This finding s uggests that that any modeling analysis prepared to support an attainment demonstration needs to account for the distance between the location where fugitive dust is emitted and the monitoring site impacted during high wind conditions (eit her through dispersion/deposition or some weighting function). Available Modeling Concepts Simple Rollback– Simple rollback analysis provides the least rigorous approach to determining the levels of emission control needed to reduce ambient PM-10 concentrations. A fundamental assumption underlying this met hod is that pollutant concentrations are directly proportional to total emissions over t he area of interest. This assumption acquires some validity if emissions from significant source categories are uniformly distributed throughout the modeling domain, and if cont rol measures will reduce emissions equally from each parcel in a particular source cat egory. The benefits of using simple rollback include a quick turnaround in com puting emission reductions nec essary to meet a desired air quality improvement goal and the need for very limited emission inventory data to complete the calculation. The drawbacks of using this approach include the loss of accuracy in forecasting air quality improvement s if sources are not uniformly distributed and if control measures produce va rying benefits on a parcel-by-par cel basis. Simple rollback can be used with some success in modeling over microscale domains, but loses accuracy as the modeling domain grows because of the effects of particle dispersion and deposition over longer travel distances. Additionally, the microscale inventories surrounding each PM10 monitoring site are differ ent, and one microscale invent ory cannot be used to assess inventory/air quality relationships at another site . Demonstrating that a control strategy is
V - 4effective at all sites recording exceedances requires the development of separate microinventories for each monitoring site. This appr oach would also suffer accuracy losses if the modeling domains extended more than about one- half mile from the monitoring site. Weighted Rollback– A weighted rollback approach applie s a distance reduction factor to emissions of each source in the modeling dom ain. The reduction factor is calculated on the basis of the distance between each sour ce and the impacted monitoring site. This method requires the separate analysis of dist ance reduction factors in addition to the development of modeling domain emission inventories upwind of each impacted monitoring site. The selection of a mathematical form fo r the calculation of distance reduction factors, ranging from 1/distance to in volved equation forms based on hourly meteorological data, requires testing to refine. Coordinates of the centroid of each parcel of land within each back-trajectory swath would need to be extract ed from land use GIS files to facilitate the calculation of parcel-specific weighting fact ors. The benefits of using this method also include a relatively quick turnaround in com puting emission reductions and, hence, air quality improvements after inv entory data are compiled and di stance reduction factors are computed. This approach also takes advantage of the limited-term saturation monitoring data collected in 2010 and early 2011 to inform the calculation of distance reduction factors at this site. Principle Component Analysis – Principle Component Analysi s (PCA) is a multivariate statistical technique that uses eigenvectors to represent varied inter-relationships present in datasets. The latent r oot regression form extracts relationships among variables that include a dependent variable (here, PM-10) and its predictors (e.g., wind speed, wind direction, soil moisture levels, emissions). PC A is an attractive alternative to photochemical and dispersion modeling when performance is poor due to problems with secondary chemistry and/or meteorological modeling. PCA also provi des a framework for assessing the probability of attainment by contrasti ng meteorological conditions on design day(s) relative to an extended historical record. The downside of the methodology is that it requires assembly of relevant metrics for a long-term, multi-ye ar meteorological record and preparation of an emissions inventory over multiple years so that vectors representing the bulk of the variance in the assemb led dataset can be extracted. AERMOD – The use of dispersion models like AERMOD to quantify the relationship between emissions and air quality can increase the accuracy of the reported results. Because of the complexities of the mathem atical algorithms coded into the models to quantify a number of disper sion components, the output of dispersion models like AERMOD shows less linearity between emi ssion strength and ambient pollutant concentration than is inherent in rollback model s. These complexities require detailed assessments of the combinations of control measures converging to a solution that attains air quality targets and minimizes instabilities in the economies of regul ated sources. Some sophisticated dispersion models, like ISCST3, contain particle deposition algorithms that can be toggled to simulate this ambient re moval mechanism. AERMOD does not contain this capability, which is important in t he modeling of windblown PM-10 emissions. An additional concern is that AERMOD provides no carryover of entrained emissions from one V - 5hour to the next, which can lead to underesti mates of concentrations under both stagnant and high wind conditions. Conclusion Since high wind AERMOD model performance wa s poor in the withdrawn Five Percent Plan, a weighted rollback approach was chosen to quantify the benefits of adopted controls on individual low and high wind hour concentrations for both the Salt River area domain and the regional nonattainment area demonstration. The 12 mph five-minute wind speed threshold was chosen to distinguish betw een low and high wind hours on selected design day(s). High wind hour emissions along the back trajectories are initially calculated based upon land use type at 2007 base levels and then calculated again with the benefits of the control measures through 2012 as identified in the new Five Pe rcent Plan. The difference in high wind emissions will prov ide the expected reduction benefit of the controls included in the new Five Percent Plan. The aggr egate weighted benefit computed for each high wind hour should be applied to the correspondi ng high wind hour recorded concentration. Since there have been no stagnation exceedances of the PM-10 standard since 2007, it is assumed that control measures im plemented since 2007 have been successful in eliminating exceedances during stagnant condi tions. The successful elimination of stagnation exceedances dictate that new lo w wind microscale, design day-specific inventories are not needed. As such, existing annual low wind emissions are allocated by land use in each of the low wind modeling dom ains as necessary. The 24-hour average of benefit-adjusted low and high wind concentrations in 2012 are lastly contrasted with the ambient 24-hour PM-10 standard to demonstrate attainment.

V - 6TEMPORARY MONITOR INSIGHTS In an effort to better understand source contributions impacting the West 43 rd Ave monitoring site during high wind events, Ma ricopa County, with s upport from the Arizona Department of Environmental Quality (A DEQ) and the Maricopa Association of Governments (MAG) deployed a series of tem porary PM-10 monitors along the dominant upwind trajectory in the spring of 2010. A total of five tem porary monitors were deployed at the following si tes: Arlington, 115 th Avenue, 67th Avenue, 51 stAvenue, and West 43 rd & Broadway. The locations of the five temporary monitors and two nearby long-term monitors, Buckeye and West 43 rd Ave., are displayed in Figure V-1. Figure V-1 Location of Temporary and Long- Term PM-10 Monitoring Sites

Monitor Placement The location of each of the temporary monito rs is identified below, along with a brief description of the insight that itwas expected to provide.
West 43 rd Avenue and Broadway (Temp #1) – The objective was to obtain measurements at the western-most edge of the industr ialized area located between the West 43 rd Ave. monitor and the river bed (roughly 0.4 miles west of the monitor). Differences between monitored values at this location and the West 43 rd Ave monitor will provide a basis to assess contributions coming from nearby sources when the wind is from the west/southwest.

V - 751 stAvenue and W. Roeser Road (Temp #2) – The goal was to locate monitors on the eastern side of 51 stAve. Differences between measur ements at this site and Temp #1 would provide insight into contributions from aggregate facilit ies located between 51 stAve. and 43 rd Ave (a distance of roughly 1 mile). 67th Avenue and Southern Avenue (Temp #3) – The goal was to loca te monitors on the eastern side of 67 th Ave. between the river bed and Sout hern Ave. Differences between measurements at this site and Temp #2 would pr ovide insight into emissions from facilities located within the 2 mile area located between 67 th Ave. and 51 stAve.
115 th Avenue – South side of PIR Bridge (Temp #4) – The purpose of this site was to obtain information on particulate mass being transpor ted by drainage flow down the Agua Fria River during morning commutes. Concern had been expressed that drainage mass accumulates on the river bed and surroundi ng area over time and is subsequently reentrained under high wind conditions and impacting the West 43 rd Ave. monitor. This location also has the advantage of providi ng a rough mid-point measurement of PM-10 concentrations between the Buckeye and West 43 rd Ave. monitors (it is located roughly 10 miles southwest of the West 43 rd Ave. monitor). Arlington School (Temp #5) – The 5% Plan relied on m easurements collected at Organ Pipe National Monument to obtain estima tes of background concentrations being transported off the desert. The goal was to place a monitor beyond the western boundary of agricultural fields located to the west of the Buckeye monitor to gain a true measurement of background concentrations being transported o ff the desert into the Salt River area. Initially, it was thought that ADEQ could utilize the former monitoring site at Palo Verde; subsequent investigation, however, determi ned this site was not available. Analysis Presented below are comparisons of pairs of measurements colle cted between the fixed and temporary sites moving west from the West 43 rd Ave. monitor, highlighted in the box displayed in Figure V-1. Comparisons between the Arlington and Buckeye sites are presented in a separate section addressi ng Background Conditions. To aid the comparison of site measurem ents, the data were organized into five-degree increments so concentration differences could be comput ed as a function of wind direction and wind speed. Comparisons between site measurement s were adjusted to account for time it takes air mass to travel between the two si tes. This was done by lagging the upwind measurement from the downwi nd measurement by the appropr iate number of five-minute intervals (the increment in which the data we re collected) needed to account for the time required for air mass to trav erse the distance between the two sites along the angular increment between the two sites. Thus, if the angle between the two sites is 260 degrees, the average wind speed computed fo r that increment was used to adjust all of the angular increments between 180 and 360 degrees. The reason is that the most accurate comparison is along that angle connecting t he two sites. Comparisons at other increments reflect the impact of sources notlocated directly al ong the line/angle between V - 8the two sites. As the difference between t he angular increment and the angle between the two sites grows, the effects of these sources and dispersion become greater. Similarly, as the distance between the two sites gr ows, the effects of nonaligned sources, dispersion, and deposition continue to growand the comparisons provide less insight. Fortunately, the sites are located to the southwest of the West 43 rd Avenue monitor, which is the dominant direction for high winds impac ting that site. Co mparisons along the arc between 230 to 290 degrees generally have the largest measurement count and provide the most relevant insight for the analysis. To simplify the presentation, comparisons of winds coming from the east (i.e., 0 to 175 degr ee increments) are not included for any of the lagged data sets for each site pair and wind speed category. All tables are presented at the end of this section for ease of review.
West 43 rd Avenue versus West 43 rd Avenue & Broadway (Temp #1) – An analysis of matched pair measurement s between the West 43 rd Ave. long-term monitor and 43rd Ave. & Broadway temporary monitor was prepared fo r the period between April 2010 and March 2011. The data were organized into five- degree increments so concentration differences could be computed as a function of wind di rection and wind speed. Since the distance between the two sites is 0.4 miles, no lags we re introduced into the data comparisons. With the comparisons all on a consistent time basis, results are presented for winds coming from all directions not just the west. Measurements were organized into three cat egories of wind speed: 2-6 mph (Tables V-5 & V-6), 6-12 mph (Tables V-3 & V-4), and > 12 mph (Tables V-1 & V-2). To ensure matched pair comparisons, both monitors had to have wind speeds falling into these categories to be included in the analysis. The results show that at 240 degrees, the angular direction traveling s outhwest from the West 43 rd Ave. monitor to the West 43 rd Ave. & Broadway temporary monitor, aver age concentrations at the West 43 rd monitor are consistently higher than at the temporary site:

! At 2-6 mph, the difference (West 43 rd - West 43 rd & Broadway/West 43 rd ) is 13.5% (6.38 μ g/m 3 );

! At 6-12 mph, the difference is 9% (3.2 μ g/m 3 ); and

! At >12 mph, the difference is 37.3% (39.78 μ g/m 3 ). The >12 mph differences increase as the angular direction increases from 240 – 290 degrees, suggesting that fugitive dust fr om land located between those sites disproportionately impacted conc entrations at the West 43 rd Ave. monitoring site (particularly since emissions impacting the monitor at that hour are coming from a minimum distance of 12 miles and the distance between the moni tors is 0.4 miles). This finding suggests that any modeling analysis prepared to support an attainment demonstration needs to account for distance between the location where fugitive dust is emitted and the monitoring site impacted during high wind conditions (either through dispersion/deposition or some weighting function). V - 9West 43 rd Avenue & Broadway (Temp #1) versus 51 stAvenue & W. Roeser Road (Temp #2) – An analysis of matched pair measurement s between these sites was also prepared for the period between April 2010 and March 2011. Only the high wind category (>12 mph), was analyzed from this pai r to get the insights of the emissions between these two monitors. Low wind conditions (< 12 mph) were excluded because of the relatively long distances of the sources to the West 43 rd monitor and the great wind variability during low wind conditions. To account for the time ittakes wind to travel the 1-mile distance between the two sites, the Temp #2 site meas urement was lagged by five minutes relative to the Temp 1 measurement (for winds coming from the west). T abulations of the high wind results are presented in Table V-7. The results show that at 250 degrees, the angular direction when wind is tr aveling from the southwest from Temp #2 to Temp #1, average concentrations at Temp #1 were consistently higher than at Temp #2:

! At >12 mph, 250 degrees, the difference is 33.8% (28.5 μ g/m 3 ). A similar relationship was observed between t he two sites when the wind was coming from a broader arc from southwest (200 to 270 degr ees), average concentrations at Temp #1 were consistently higher than they were at Temp #2. Wind directions between 270 and 300 degrees produced the opposite relationship, with Temp #2 concentra tions consistently higher than Temp #1. This indicates that when the wind is coming from the southwest, fugitive dust from disturbed land located bet ween the two monitors is contributing to elevated concentrations at West 43 rd & Broadway and therefor e impacting concentrations recorded at the West 43 rd Avenue monitoring site. It also suggests that there is considerably less disturbed land located in the 270 and 300 degree arc between the two sites.
51 stAvenue & W. Roeser Road (Temp #2) versus 67th Av enue & Southern Avenue (Temp #3) – Similar to the previous analysis, comparisons between the April 2010 and March 2011 data set were prepared only for high wind conditions. The data were lagged by ten minutes to account for the time required for air mass to transit the 2-mile distance between the two sites (i.e., Temp #3 measurements we re lagged 10 minutes relative to Temp #2 measurements). A summary of the compar isons for winds coming from the west is presented in Table V-8.
The results show that at 255 degrees, the angular direction traveling southwest from the Temp 2 to Temp 3 monitor, average concentra tions at the 51st Ave. monitor are lower than at the 67th Ave monitor:

! At >12 mph, 255 degrees, the difference is -7.4% (-4.6 μg/m 3 ). This pattern of higher upwind values is seen c onsistently in an arc r anging from 240 to 300 degrees. It is also opposite of the patterns s een in the previous site comparisons. This suggests that upwind s ources impacting the 67 th Ave. monitor had a significantly greater impact than sources located between the two sites had on the 51 stAve monitor. Another factor to consider is that the greater distance between these sites also allows more V - 10time/distance for dispersion and deposition rela tive to the previous site comparisons. Given the limitations of the data, it is not possible to know which effect is stronger (i.e., the influence of nearby upwind sources at bot h sites versus dispersion/deposition). Nevertheless, it suggests some form of dist ance weighting should be incorporated into the modeling because the greatest impacts at the West 43 rd Avenue monitor appear to be coming from nearby upwind land.
67 th Avenue & Southern (Temp#3) versus 115 th Avenue (Temp #4) – Similar to the previous analysis, comparisons between the April 2010 and March 2011 data set were only prepared for high wind conditions. The dat a were lagged by 25 minutes to account for the time required for air ma ss to transit the 6-mile dist ance between the two sites (i.e., Temp #4 measurements were lagged 25 minutes relative to Temp #3 measurements). A summary of the comparisons for winds comi ng from the west is presented in Table V-9.
The results show that at 255 degrees, the angular direction tr aveling southwest from the Temp 2 to Temp 3 monitor, average conc entrations at the 51st Ave. monitor are consistently lower than at the 67th Ave monitor:

! At >12 mph, 255 degrees, the diffe rence is -48.0% (-33.1 μg/m 3 ). This pattern is consistent with that observed in the previous comparison between Temp #2 and #3, but inconsistent with the pattern seen in the sites closer to the West 43 rd Avenue monitor. The differences observed at 255 degrees between Temp #3 and #4, however, are not generally seen over the broader arc between 230 to 290 degrees. Generally, the pattern is the opposite—hi gher values are recorded at the 67 th Avenue monitor, suggesting land located between the tw o sites, but not directly along the angle between them, is contributing to emissions impacting that site.
115 th Avenue (Temp #4) versus Buckeye – Due to the 18-mile distance between the sites, no comparisons were prepared. Summary Analysis of data collected along a line of fix ed and temporary PM-10 monitors located on a southwest trajectory from the West 43 rd Avenue monitor between April 2010 and March 2011 shows a pattern of elevated impacts fr om nearby lands. Similar impacts were observed in comparisons between concentrations recorded at the next set of upwind sites. Subsequent site comparisons produced inconsist ent and contradictory results, indicating a lessening impact of lands lo cated between the monitored pai rs. These findings suggest that lands with the greatest impacts on concentrations recorded at the West 43 rd Avenue site are nearby and diminish with distance. The trajectory modeling used to estimate concentrations during high wind hours should inco rporate a form of distance weighting or dispersion to account for this effect.

V - 11Table V-1 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at West 43rd Ave/Broadway and West 43rd Monitors When Winds Exceeded 12 mph (0 - 175 degrees)
WD Sector

(Degree) Measurement Count 43rd & Broadway (μg/m 3 ) West 43 rd (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 0 21 116.39 113.54 -2.85 -2.5% 5 40 80.27 89.04 8.77 9.8% 10 36 75.15 86.64 11.49 13.3% 15 38 52.07 41.29 -10.78 -26.1% 20 38 43.94 29.64 -14.31 -48.3% 25 38 58.74 27.68 -31.07 -112.3% 30 28 128.18 70.54 -57.64 -81.7% 35 11 167.49 72.14 -95.35 -132.2% 40 11 96.82 45.57 -51.25 -112.4% 45 8 122.26 50.31 -71.95 -143.0% 50 8 66.86 31.31 -35.55 -113.5% 55 1 94.40 47.90 -46.50 -97.1% 60 7 58.56 68.64 10.09 14.7% 65 8 52.56 40.15 -12.41 -30.9% 70 14 50.38 44.15 -6.23 -14.1% 75 27 50.50 46.56 -3.94 -8.5% 80 27 64.63 63.34 -1.29 -2.0% 85 25 56.80 50.55 -6.25 -12.4% 90 19 68.35 62.76 -5.58 -8.9% 95 22 49.96 50.95 0.98 1.9% 100 53 79.18 67.96 -11.22 -16.5% 105 35 141.95 101.19 -40.77 -40.3% 110 21 150.54 104.44 -46.10 -44.1% 115 12 22.78 40.67 17.89 44.0% 120 13 248.30 153.05 -95.25 -62.2% 125 15 166.12 87.01 -79.11 -90.9% 130 23 296.25 139.17 -157.07 -112.9% 135 15 418.20 318.69 -99.51 -31.2% 140 14 177.39 148.76 -28.62 -19.2% 145 12 123.76 118.34 -5.42 -4.6% 150 8 234.20 173.84 -60.36 -34.7% 155 6 796.67 1013.33 216.67 21.4% 160 8 529.34 601.58 72.24 12.0% 165 13 764.37 365.05 -399.32 -109.4% 170 4 273.75 398.73 124.98 31.3% 175 16 630.31 305.08 -325.24 -106.6%

V - 12Table V-2 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at West 43rd Ave/Broadway and West 43rd Monitors When Winds Exceeded 12 mph (180 - 360 degrees)
WD Sector

(Degree) Measurement Count 43rd & Broadway (μg/m 3 ) West 43 rd (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 180 15 720.92 320.11 -400.81 -125.2% 185 3 310.43 156.47 -153.97 -98.4% 190 3 46.30 38.80 -7.50 -19.3% 195 2 105.20 94.25 -10.95 -11.6% 200 5 147.90 152.32 4.42 2.9% 205 3 646.00 774.00 128.00 16.5% 210 14 144.09 266.19 122.10 45.9% 215 16 373.00 419.85 46.85 11.2% 220 34 130.21 150.99 20.79 13.8% 225 32 66.88 109.71 42.82 39.0% 230 57 69.08 103.92 34.84 33.5% 235 104 63.30 102.79 39.50 38.4% 240 130 66.92 106.70 39.78 37.3% 245 158 88.30 132.58 44.29 33.4% 250 153 78.77 134.13 55.36 41.3% 255 182 68.66 129.96 61.30 47.2% 260 246 68.12 130.17 62.05 47.7% 265 271 48.46 91.98 43.53 47.3% 270 205 51.11 110.52 59.40 53.7% 275 141 64.33 124.81 60.48 48.5% 280 94 62.54 150.43 87.89 58.4% 285 51 62.39 124.07 61.68 49.7% 290 20 85.40 195.19 109.79 56.2% 295 24 51.48 74.85 23.37 31.2% 300 7 87.66 164.27 76.61 46.6% 305 8 45.71 46.89 1.18 2.5% 310 12 53.38 64.98 11.61 17.9% 315 15 52.79 53.25 0.45 0.9% 320 13 67.18 84.66 17.48 20.6% 325 8 62.76 56.28 -6.49 -11.5% 330 14 32.36 24.97 -7.39 -29.6% 335 23 57.46 49.74 -7.72 -15.5% 340 41 81.66 79.40 -2.26 -2.8% 345 49 49.45 43.17 -6.28 -14.6% 350 20 141.52 142.74 1.22 0.9% 355 30 126.71 105.82 -20.89 -19.7% 360 3 20.53 25.37 4.83 19.1%

V - 13Table V-3 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at West 43rd Ave/Broadway and West 43rd Monitors When Winds Are Between 6-12 mph (0 - 175 degrees)
WD Sector

(Degree) Measurement Count 43rd & Broadway (μg/m 3 ) West 43 rd (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 0 61 20.32 16.66 -3.66 -22.0% 5 47 27.47 22.41 -5.06 -22.6% 10 45 31.10 26.73 -4.37 -16.3% 15 53 24.12 20.18 -3.94 -19.5% 20 55 20.65 20.55 -0.10 -0.5% 25 49 25.99 20.67 -5.33 -25.8% 30 41 29.32 22.95 -6.37 -27.8% 35 46 30.43 22.58 -7.85 -34.8% 40 57 27.96 20.81 -7.15 -34.3% 45 59 29.15 21.02 -8.13 -38.7% 50 66 28.94 21.84 -7.09 -32.5% 55 104 29.37 25.18 -4.19 -16.7% 60 141 36.94 29.59 -7.35 -24.8% 65 157 35.87 29.32 -6.55 -22.3% 70 264 37.52 59.90 22.38 37.4% 75 330 35.36 86.99 51.63 59.4% 80 279 36.85 64.04 27.18 42.5% 85 256 34.53 47.96 13.43 28.0% 90 319 30.11 31.37 1.26 4.0% 95 301 30.76 43.93 13.17 30.0% 100 275 32.54 34.14 1.59 4.7% 105 221 33.60 51.44 17.84 34.7% 110 206 26.63 24.19 -2.45 -10.1% 115 189 29.78 27.39 -2.39 -8.7% 120 156 30.39 26.72 -3.68 -13.8% 125 129 51.33 46.01 -5.33 -11.6% 130 125 30.62 24.80 -5.82 -23.5% 135 117 40.18 35.45 -4.73 -13.3% 140 110 39.70 39.48 -0.23 -0.6% 145 94 52.01 37.78 -14.24 -37.7% 150 109 56.90 59.36 2.47 4.2% 155 115 62.44 68.93 6.50 9.4% 160 105 49.32 41.58 -7.74 -18.6% 165 116 67.84 66.32 -1.53 -2.3% 170 82 50.22 66.74 16.52 24.8% 175 74 43.92 49.20 5.28 10.7%

V - 14Table V-4 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at West 43rd Ave/Broadway and West 43rd Monitors When Winds are Between 6-12 mph (180 - 360 degrees)
WD Sector

(Degree) Measurement Count 43rd & Broadway (μg/m 3 ) West 43 rd (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 180 63 35.47 51.12 15.65 30.6% 185 57 26.91 27.85 0.95 3.4% 190 50 26.95 25.52 -1.43 -5.6% 195 74 28.78 38.80 10.02 25.8% 200 54 26.78 28.81 2.03 7.1% 205 65 28.55 30.41 1.86 6.1% 210 78 29.71 32.21 2.50 7.8% 215 93 25.50 36.73 11.23 30.6% 220 133 29.03 33.54 4.51 13.4% 225 219 32.26 34.84 2.58 7.4% 230 375 30.65 33.38 2.73 8.2% 235 389 30.89 34.32 3.43 10.0% 240 429 32.38 35.58 3.20 9.0% 245 514 33.45 42.23 8.78 20.8% 250 478 33.18 42.14 8.96 21.3% 255 629 35.81 41.11 5.30 12.9% 260 880 33.41 38.89 5.48 14.1% 265 951 32.05 37.10 5.05 13.6% 270 838 32.56 36.81 4.25 11.6% 275 763 32.53 37.56 5.03 13.4% 280 651 30.68 35.33 4.65 13.1% 285 509 27.87 30.98 3.11 10.0% 290 390 27.76 28.06 0.29 1.0% 295 228 27.45 29.60 2.15 7.3% 300 149 27.40 24.79 -2.62 -10.6% 305 96 32.92 27.19 -5.73 -21.1% 310 70 22.01 19.45 -2.56 -13.2% 315 60 35.80 26.73 -9.07 -33.9% 320 60 26.63 22.79 -3.84 -16.8% 325 58 23.16 22.42 -0.74 -3.3% 330 64 23.18 22.59 -0.58 -2.6% 335 50 23.22 16.96 -6.26 -36.9% 340 45 22.04 15.34 -6.70 -43.7% 345 55 25.49 15.47 -10.02 -64.8% 350 70 18.35 14.71 -3.64 -24.8% 355 64 20.18 19.90 -0.28 -1.4% 360 7 20.13 17.17 -2.96 -17.2%

V - 15Table V-5 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at West 43rd Ave/Broadway and West 43rd Monitors When Winds are Greater Than 2 mph, but do not Exceed 6 mph (0 - 175 degrees)
WD Sector

(Degree) Measurement Count 43rd & Broadway (μg/m 3 ) West 43 rd (μg/m 3 ) Difference* (μg/m 3 ) Difference (Percent) 0 518 46.53 40.66 -5.86 -14.4% 5 536 45.97 45.20 -0.77 -1.7% 10 601 52.61 50.22 -2.39 -4.8% 15 609 52.82 45.26 -7.56 -16.7% 20 638 47.23 43.22 -4.01 -9.3% 25 639 49.91 43.46 -6.45 -14.8% 30 636 51.64 42.89 -8.75 -20.4% 35 723 50.86 45.73 -5.13 -11.2% 40 708 48.95 41.29 -7.66 -18.6% 45 803 48.89 41.39 -7.50 -18.1% 50 859 46.98 41.00 -5.98 -14.6% 55 961 46.18 43.81 -2.38 -5.4% 60 1,113 47.28 43.02 -4.26 -9.9% 65 1,159 46.63 45.47 -1.16 -2.6% 70 1,373 44.75 50.10 5.35 10.7% 75 1,424 43.21 54.39 11.18 20.6% 80 1,316 43.92 49.60 5.68 11.5% 85 1,264 42.95 47.16 4.21 8.9% 90 1,341 40.62 42.41 1.78 4.2% 95 1,361 40.10 46.95 6.85 14.6% 100 1,340 41.59 40.95 -0.64 -1.6% 105 1,240 44.05 45.02 0.96 2.1% 110 1,078 43.69 40.22 -3.47 -8.6% 115 1,014 41.27 39.82 -1.45 -3.6% 120 978 45.21 42.08 -3.12 -7.4% 125 982 50.38 45.33 -5.04 -11.1% 130 958 52.45 48.14 -4.31 -8.9% 135 819 56.34 47.72 -8.63 -18.1% 140 874 54.13 47.03 -7.10 -15.1% 145 825 53.75 46.78 -6.97 -14.9% 150 796 55.61 48.67 -6.94 -14.3% 155 833 59.45 56.67 -2.78 -4.9% 160 790 57.46 52.65 -4.81 -9.1% 165 828 67.32 55.33 -11.99 -21.7% 170 841 52.88 51.87 -1.01 -1.9% 175 870 63.00 52.76 -10.24 -19.4%

V - 16Table V-6 Angular Comparison of Matched Five-Minute PM-10 Concentrations Collected at West 43rd Ave/Br oadway and West 43rd Monitors When Winds are Greater Than 2 mph, but do not Exceed 6 mph (180 - 360 degrees)
WD Sector

(Degree) Measurement Count 43rd & Broadway (μg/m 3 ) West 43 rd (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 180 913 63.96 53.33 -10.64 -19.9% 185 952 52.75 48.40 -4.35 -9.0% 190 954 50.78 50.93 0.15 0.3% 195 1,014 54.49 56.53 2.04 3.6% 200 1,007 52.77 58.15 5.38 9.3% 205 1,035 48.48 50.77 2.28 4.5% 210 1,080 47.35 51.14 3.79 7.4% 215 1,043 49.25 57.43 8.18 14.3% 220 1,126 43.43 47.65 4.23 8.9% 225 1,234 40.96 46.57 5.62 12.1% 230 1,479 38.28 45.15 6.87 15.2% 235 1,564 39.60 46.77 7.17 15.3% 240 1,733 40.90 47.28 6.38 13.5% 245 2,115 42.33 51.05 8.72 17.1% 250 2,154 43.65 56.51 12.86 22.8% 255 2,514 43.70 48.68 4.99 10.2% 260 2,795 44.17 51.20 7.04 13.7% 265 2,907 41.10 49.44 8.33 16.9% 270 2,755 41.13 45.52 4.39 9.7% 275 2,646 41.49 45.26 3.76 8.3% 280 2,515 39.15 42.85 3.70 8.6% 285 2,360 37.96 43.91 5.94 13.5% 290 1,964 37.29 35.66 -1.63 -4.6% 295 1,542 37.81 41.53 3.72 9.0% 300 1,243 39.00 41.53 2.53 6.1% 305 1,012 39.05 35.26 -3.79 -10.7% 310 929 40.86 36.68 -4.18 -11.4% 315 823 42.02 36.28 -5.74 -15.8% 320 769 39.93 38.25 -1.68 -4.4% 325 726 41.51 36.75 -4.76 -13.0% 330 639 43.14 38.31 -4.83 -12.6% 335 644 45.94 37.05 -8.89 -24.0% 340 587 45.38 40.66 -4.73 -11.6% 345 626 43.47 39.32 -4.15 -10.6% 350 624 47.85 40.69 -7.17 -17.6% 355 617 46.02 41.83 -4.19 -10.0% 360 52 37.66 41.61 3.95 9.5

V - 17Table V-7 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at

51st Avenue and West 43rd Ave/Broadw ay (lagged 5-minutes) Monitors When Winds Exceeded 12 mph (180 - 355 degrees)
WD Sector

(Degree) Measurement Count 51st Avenue (μg/m 3 ) 43rd & Broadway (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 180 9 274.6 839.6 565.0 67.3% 185 14 171.2 442.3 271.1 61.3% 190 3 27.4 83.1 55.7 67.0% 195 2 38.2 102.5 64.3 62.8% 200 NA NA NA NA NA 205 1 32.3 82.3 50.0 60.8% 210 4 34.3 154.3 120.0 77.8% 215 6 59.6 294.4 234.9 79.8% 220 8 182.0 278.3 96.4 34.6% 225 8 197.8 428.8 231.0 53.9% 230 14 219.7 298.2 78.5 26.3% 235 11 135.9 132.7 -3.3 -2.5% 240 18 38.8 78.8 39.9 50.7% 245 24 48.3 64.7 16.5 25.4% 250 34 55.7 84.2 28.5 33.8% 255 45 60.0 85.0 25.0 29.4% 260 52 37.7 57.5 19.8 34.4% 265 68 61.8 72.8 10.9 15.0% 270 76 49.4 62.2 12.8 20.5% 275 95 51.8 52.0 0.2 0.4% 280 90 43.9 39.8 -4.1 -10.3% 285 62 49.9 36.6 -13.4 -36.6% 290 35 47.0 29.7 -17.3 -58.2% 295 12 35.6 26.7 -8.8 -33.1% 300 6 49.8 46.8 -3.1 -6.6% 305 4 47.4 58.7 11.4 19.3% 310 5 37.5 51.7 14.2 27.5% 315 10 36.5 40.2 3.7 9.2% 320 13 60.9 73.3 12.4 16.9% 325 11 88.7 91.9 3.3 3.6% 330 4 21.0 21.8 0.8 3.6% 335 9 186.6 118.6 -68.0 -57.3% 340 40 50.2 55.9 5.7 10.2% 345 32 73.9 55.1 -18.8 -34.2% 350 15 111.3 86.0 -25.3 -29.4% 355 18 286.0 231.6 -54.4 -23.5%

V - 18Table V-8 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at 67th Avenue and 51st Avenue (lagge d 10-minutes) Monitors When Winds Exceeded 12 mph (180 - 355 degrees)
WD Sector

(Degree) Measurement Count 67th Avenue (μg/m 3 ) 51 stAvenue (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 180 10 517.4 181.8 -335.5 -184.5% 185 15 402.3 132.5 -269.8 -203.6% 190 6 64.5 71.0 6.5 9.2% 195 3 29.0 38.8 9.9 25.4% 200 NA NA NA NA NA 205 1 93.4 15.7 -77.7 -494.9% 210 1 221.5 320.7 99.2 30.9% 215 4 59.0 144.7 85.7 59.2% 220 8 106.2 164.9 58.7 35.6% 225 7 124.4 131.8 7.4 5.6% 230 13 154.1 226.6 72.5 32.0% 235 9 102.3 191.1 88.8 46.5% 240 25 55.7 37.9 -17.8 -46.9% 245 24 99.1 68.1 -31.1 -45.7% 250 37 88.3 53.5 -34.8 -65.1% 255 52 66.6 62.0 -4.6 -7.4% 260 63 60.3 45.2 -15.0 -33.2% 265 88 80.8 62.7 -18.2 -29.0% 270 93 72.3 55.0 -17.3 -31.4% 275 106 62.1 55.9 -6.2 -11.0% 280 102 53.6 62.1 8.5 13.7% 285 84 62.9 44.9 -18.0 -40.0% 290 58 148.4 73.2 -75.2 -102.7% 295 18 184.1 95.7 -88.5 -92.5% 300 13 114.0 51.8 -62.2 -120.0% 305 9 69.6 40.4 -29.2 -72.2% 310 18 70.9 71.7 0.8 1.1% 315 23 34.3 17.8 -16.4 -92.0% 320 16 97.7 49.3 -48.4 -98.3% 325 12 164.6 74.9 -89.8 -119.9% 330 3 27.6 20.9 -6.7 -32.3% 335 11 109.9 92.8 -17.1 -18.4% 340 36 47.5 40.7 -6.8 -16.7% 345 28 50.0 70.7 20.7 29.3% 350 16 85.3 84.4 -1.0 -1.1% 355 12 114.2 208.8 94.6 45.3%

V - 19Table V-9 Angular Comparison of Five-Minute P M-10 Concentrations Collected at 115th Avenue and 67th Avenue (lagged 25-minutes) Monitors When Winds Exceeded 12 mph (180 - 355 degrees)
WD Sector

(Degree) Measurement Count Avondale (μg/m 3 ) 67th Avenue (μg/m 3 ) Difference (μg/m 3 ) Difference (Percent) 180 NA NA NA NA NA 185 NA NA NA NA NA 190 2 59.7 499.5 439.9 88.1% 195 3 45.2 140.4 95.2 67.8% 200 3 27.7 303.8 276.1 90.9% 205 6 16.1 28.3 12.2 43.1% 210 11 56.3 58.4 2.1 3.6% 215 4 55.8 42.2 -13.6 -32.2% 220 11 125.2 164.7 39.5 24.0% 225 16 71.9 55.4 -16.5 -29.8% 230 22 68.5 158.7 90.2 56.8% 235 19 38.3 81.3 43.0 52.9% 240 33 50.8 56.5 5.8 10.2% 245 47 37.5 80.2 42.7 53.2% 250 84 42.4 113.7 71.3 62.7% 255 72 36.2 74.5 38.3 51.4% 260 87 102.3 69.1 -33.1 -48.0% 265 61 75.7 63.2 -12.5 -19.8% 270 86 38.2 44.2 5.9 13.4% 275 58 51.2 68.9 17.7 25.6% 280 56 50.5 88.3 37.8 42.8% 285 39 83.7 130.9 47.2 36.1% 290 30 112.5 177.6 65.1 36.7% 295 8 26.4 45.7 19.3 42.2% 300 4 25.9 81.5 55.7 68.3% 305 6 38.3 75.5 37.2 49.3% 310 2 25.4 66.0 40.7 61.6% 315 8 52.2 80.5 28.4 35.2% 320 25 36.8 66.3 29.5 44.5% 325 27 60.4 95.9 35.5 37.0% 330 5 140.7 35.9 -104.8 -291.8% 335 3 100.0 25.2 -74.8 -297.2% 340 19 25.9 37.6 11.7 31.1% 345 16 63.3 40.3 -23.0 -57.1% 350 9 173.8 79.1 -94.7 -119.6% 355 NA NA NA NA NA

V - 20SOURCE WEIGHTING ANALYSIS A modified rollback analysis is used to assess the benefits of controls to reduce windblown dust emissions on disturbed soil areas. Alt hough these benefits can be quantified in terms of emissions, the corresponding reductions in ambient PM-10 concentrations at fixed monitoring sites cannot be determined withou t additional analysis of the relationships between emissions reductions and reductions in downwind concentrations. This relationship is typically quantified through use of dispersion modeling, and dispersion modeling is used in a screening mode here to in form modifications to the basic rollback process. Rollback analysis basically assumes a linear relationship between levels of pollutant emissions and levels of resulting pollutant c oncentrations in downwind ambient air. Under this approach, a fractional reduction in emi ssions is assumed to produce an equivalent reduction in downwind ambient concentrati ons after backing out the contribution of background air quality. In the case of entrained PM-10 generated by high wind events, however, we know that two primary factors inva lidate this principle of linearity: (1) the settling and deposition from the ai rstream of entrained particula te with increasing time and distance from the point of ent rainment, and (2) the dispersion of particulate both laterally and vertically within the airstream due to increased boundary layer turbulence at higher wind speeds. Both of thes e phenomena cause PM-10 concentra tions to drop dramatically as air parcels holding these concentrati ons continue moving downwind from the soils generating windblown dust during high wind events. Fortunately, quantitative esti mates of the impacts of these two phenomena can be derived from the use of steady state, Gaussian-di spersion models configured to site-specific conditions found in the Salt River area. One of these models, AERMOD, was used to quantify source-receptor relationships in the previous version of the Maricopa Area Five Percent Plan. For this reason, AERMOD was used to generate PM-10 concentrations downwind of a hypothetical disturbed soil par cel producing windblown dust to assess the rate at which the combination of particl e deposition and dispersion reduced concentrations at varying distances downwind of the source. The hypothetical disturbed soil parcel was configured to repr esent such parcels typically found in the windblown dust corridor straddling the Salt River. The area of the parcel was specified to be 40 acres, repres entative of larger cultivated par cels in the area. The parcel was assumed to be square with sides orient ed north-south and east- west and measuring 401.54 meters each. The plume release hei ght was set at 0.5 meters, the ambient temperature at 297.9 °K (76. 6 °F), and Monin-Obukhov lengt hs—relating to atmospheric stability—were set at -304.2 meters. These am bient conditions were the same as those that occurred at the W. 43rd monitoring st ation on the high wind hour of February 15, 2006, the single high wind day eval uated in the Technical SupportDocument to the initial Five Percent Plan. The ur ban dispersion toggle was set to represent albedo from a population center of 1.5 million. Both source and receptor elevations were set to zero to generally represent the topogr aphical gradient along the Salt River. The surface
V - 21roughness was set at 0.04 meters based on Ni ckling and Gillies 1986 wind tunnel testing in the Salt River area. The particle size ranges of loose soil particles entrained by high wind conditions from this parcel were assum ed to be the same as the size distribution used in the initial Five Percent Plan modeli ng of high wind conditions. This distribution, as adapted from ambient air monitoring conduct ed by T&B Systems in the Salt River area in 2006, is shown in Table V-10.
Table V-10 Particle Characteristics Diameter (micron) 1.229 3.263 4.949 6.802 8.724 Mass Fraction 0.189 0.27 0.231 0.206 0.105 Density (g/cm 3 ) 2.5 2.5 2.5 2.5 2.5 The emission rate for the 40-acre parcel was set at 1,000 pounds of PM-10 per hour, or 7.815x10 -4 g/sec-m 2 , which is consistent with emission rates published in the 2008 Periodic Emissions Inventory fo r PM-10 (Appendix A, Exhibit 1). Receptor sites were located at regular inte rvals downwind of the trailing edge of the area source. Receptor spacing was set at 100 meters between 0 and 1,000 meters; at 200 meters between 1,000 and 3,000 meters; and then at 500 meters between 3,000 and 30,000 meters. All receptors were configured to lie on a radius pointing due east from the source. Meteorological conditions for this screening r un included winds blowing from due west at a series of elevated wind speeds. Hourly average wind velocities ranged from 12 to 24 mph in 1-mph increments. The resulting hourly-average PM-10 concent rations reported by the AERMOD screening run are shown in Appendix A. These results show concentrati ons varying by three orders of magnitude over the downwi nd distance span of 0 to 30,000 meters. At the threshold of high wind conditions, 12 mph, concentrations drop by a factor of 10 between 0 and 500 meters, between 500 and 2,800 meters, and bet ween 2,800 and 30,000 meters. In other words, emissions from source s proximate to or within 500 me ters upwind of a monitoring station will overwhelm the em ission contributions of sources more than 500 meters upwind. The trends of modeling results were analyzed us ing the curve-fitting functions of Excel. In the first analytical series , plots of PM-10 concentrations vs. downwind distance were mapped for the wind speeds of 12, 16, 20, and 24 mph. These plots are shown in Figure V-2.

V - 22Figure V-2Relationship Between PM-10 Concentration and Source Distance at Different Wind Speeds12 MPH16 MPH24 MPH20 MPHV - 23This progression of plots includes the bes t fit curve statistics for each AERMOD wind speed. Because of the rapidi ty at which concentrations decline with increasing downwind distance, a power curve was found to provide the best equation fit to these data. From observation, the correlation coefficients (r 2 ) of these plots are ve ry high—exceeding 0.96 in all cases. Similarly, the exponent of x in each best fit power curve hovers near -1.9, suggesting that concentrations roughly dec line with downwind distances on a 1/x 2 basis. Further analysis of the modeling data, however , suggests a somewhat different picture. In each of the plots in Figur e V-2, modeling results straddle the best fit curve in a sinusoidal fashion. The first plot in Figure V-2, that of the 12 mph modeling results, was disaggregated into separate sinusoid cycles to determine whether the power equation exponent remained constant over each block of downwind receptors contained within a cycle. The sinusoid cycles were chosen to encom pass the receptor intervals of 0 to 1,000 meters; 1,000 to 3,000 meters; 3,000 to 15,000 meters; and 15,000 to 30,000 meters. The resulting plots of PM-10 concentration vs. distance are presented in Figure V-3. The plots in Figure V-3 show similarly high r 2 values, but the power exponents vary substantially from -0.2 to -1.2. Also, t he trend in power exponents is somewhat linear, starting at the high end of -1.233 for receptor s in the 0 to 1,000 me ter range, and steadily decreasing to -0.173 in the 15,000 to 30,000 meter range. These results point dramatically to a concentration-distance re lationship much closer to 1/x than 1/x 2
, especially in the critical zone of nearest receptors, from 0 to 1,000 meters, in which source impacts significantly overwhelm the contributions of sources farther upwind of a receptor. A similar, but less dramatic, result is seen when the modeling data are evaluated over different portions of the right tail (i.e., toward increasing dist ances) of these plots in Figure V-2. This analysis was conducted to determi ne the effect of removing the highest—and most dominant—concentrations reported for near-downwind receptors from the analysis in order to study that portion of the curve wit h the flatter gradient. In this analysis, power equation curves were fitted to the distributions of PM-10 concentrations (1) over the full range of receptors, (2) over the range of receptors equal to or greater than 500 meters downwind of the source, (3) equal to or greater than 1,000 me ters downwind, (4) equal to or greater than 2,000 meters downwind, and (5) equal to or greater than 4,000 meters downwind. The plots of these ranges are shown in Figure V-4. The power curve statistics of pl ots in Figure V-4, like those in Figure V-3, show a declining trend in negative power curve exponents with incr easing distance, but also stable and very high values of r2 with increasing distance. Over the full range of receptors, the power curve exponent is -1.803, again suggesting a roughly 1/x 2 relationship of PM-10 concentration with increasing downwind distanc e. Excluding the receptors within 500 meters of the source, however, causes t he exponent to decline to -1.391. Removing receptors within 1,000 meters, 2,000 meters, and 4,000 meters of the source causes the power curve exponent to drop to -1.098, -0.825, and -0.504, respectively. These exponents conversely suggest rough relationships between PM 10 concentration and distance of 1/x to 1/ %x. V - 24Figure V-3Relationship between PM-10 Concentration and Source Distance Increments at 12 mph Wind Speed12 MPH, 0-1000 M12 MPH, 1000-3000 M12 MPH, 3000-15000M12 MPH, 15000-30000MV - 25Figure V-4Relationship between PM-10 Concentration andIncreasing Source Distances at 12 mph Wind Speed12 MPH, RECEPTORS > 0M 12 MPH, RECEPTORS > 500M12 MPH, RECEPTORS > 4000M12 MPH, RECEPTORS > 2000M12 MPH, RECEPTORS > 1000MV - 26Without question, receptors close to an up wind source will be much more dramatically impacted by emissions from that source —emission rates being equal—than by similar sources at increasing distances upwind of re ceptors. As a result, the power curve exponents produced by the modeling of impacts in the near downwind field (0 to 1,000 meters) from this modeling analysis must be given greatest weight because of the exponentially smaller impacts at receptors at greater downwind distances. The first curve in Figure V-3 represents this receptor in terval, and reports a power curve exponent of - 1.233. Because the remainder of the plot s report exponents straddling this value, this exponent represents the best singular va lue for the adjustment of downwind concentrations with increasing distance. Also , because of the range of exponents reported in these plots, an exponent of -1.0—equiva lent to 1/x—is reasonably equivalent and should be used to adjust windblown dust em ission impacts with increasing downwind distance in any modified rollback analysis in the Salt River area.

V - 27BACKGROUND CONDITIONS As discussed in the section addressing Tempor ary Monitoring Insights, Maricopa County, with support from the Arizona Department of Environmental Quality (ADEQ) and the Maricopa Association of Governments (MAG ), deployed a series of temporary PM-10 monitors along the dominant upwind trajectory in the spring of 2010. A total of five temporary monitors were deployed at the following sites: Arlington, 115 th Avenue, 67th Avenue, 51 stAvenue, and West 43 rd & Broadway. The locations of the five temporary monitors and two nearby long-term monitors, Buckeye and West 43 rd Avenue, are displayed in Figure V-5. Figure V-5 Location of Temporary and Long- Term PM-10 Monitoring Sites

The Arlington monitor is located westof Buckeye, beyond the edge of active agricultural/irrigation land, both are highlighted in Figure 1. Data collected at the Arlington site are intended to provide insight into non-anthropogenic concentrations coming in from the desert. Despite its remote location, ther e are a number of source s located to the west of the site that impact monitored concentrations—examples include the Palo Verde Nuclear Generating Stat ion, located three miles to the west/northwest; and the Mesquite Power Plant, located three miles to the sout hwest. All of the remaining monitors are directly impacted by emissions from upwi nd anthropogenic sources. Buckeye, located 11 miles east of Arlington, is the nearest moni tor and is surrounded by agricultural lands.

V - 28Temporal Variations Figures V-6 and V-7 compare wind speed, wind direction, and concentrations recorded at the Arlington, Buckeye, and West 43 rd Ave. monitoring sites for two separate episodes that occurred on April 28-29, 2010, and May 22-23, 2010, respectively. Because wind speed and wind direction were not recorded at the Arlington site, wind speed and wind direction data fr om the Buckeye and West 43 rd monitors were used instead. Both low and high wind speeds were observed during these high wind events. During low winds, the wind direction showed c onsiderable variation, coming from all directions; however, during high winds ( wind speed > 12mph), constant west and southwest wind flow was observed. These wi nd flows represent the frontal winds coming from the west, the dominant di rection for high wind events. During the high wind periods, PM-10 spikes were observed at a ll three sites, with much higher PM 10 concentrations usually observed at the Buckeye and West 43 rd monitors than at Arlington. Clearly, the lower values recorded at Arlington are mo re representative of PM-10 background concentrations transported by frontal winds coming in off the desert. Those values, however, may be impacted by upwind anthropogenic sources—additional analysis of concentrations as a function of wind direction is needed to assess their impacts. Data Analysis Differences between matched pair measurem ents from Arlington and Buckeye were calculated to provide insight into which upwind sources could be impacting Arlington concentrations. The data were organized into five-degree increments so the concentration differences could be computed as a functi on of wind direction and wind speed. Only measurements with wind speeds greater than 12 mph were us ed to represent the high wind events. The five-degree angular values for measurement count and average PM-10 and related standard deviations are presented in Table V-11. The angular direction traveling from the Arlington m onitor to the Buckeye monitor is about 265°. The results show that average PM-10 concent rations at the Arlington moni tor are consistently lower than the Buckeye monitor within an arc be tween 230° and 290°. This indicates that fugitive dust emissions east of Arli ngton are impacting the Buckeye monitor.

V - 29Figure V-6 Comparison of WD, WSPD and PM-10 Ob servations at Arlington, Buckeye and

West 43rd Monitoring Sites During 4/28/2010 - 4/29/2010 High Winds Events

V - 30Figure V-7 Comparison of WD, WSPD and PM-10 Ob servations at Arlington, Buckeye and

West 43rd Monitoring Sites During 5/22/2010 - 5/23/2010 High Winds Events

V - 31If a monitor is overwhelmed by emissions from nearby sources dur ing high wind events, the variability of PM-10 over the shortest averaging periods (the five-minute data) should be greater (due to the equivalent variability of soil emissions forced by ground-level turbulence) than the corresponding variability co mputed at a station that is impacted by more distant sources (whose emissions dis perse axially along the plume centerline, in addition to vertically and horizonta lly, thus reducing significant va riations). Data for PM-10 at each five-degree angular direction (Table V-11) show that w hen the wind comes from Arlington to Buckeye (230° to 290°), the st andard deviations for the Arlington monitor are usually, but not always, lower than the Buckeye monitor values.
Table V-11 Angular Comparison of Matched Five-Minut e PM-10 Concentrations Collected at Arlington and Buckeye Monitors When Winds Are Greater Than 12 mph
WD Sector (Degree) Measurement Count Arlington (μg/m 3 ) Buckeye (μg/m 3 ) Difference (μg/m 3 ) Standard Deviation (Arlington) Standard Deviation (Buckeye) 0 2 233.7 314.1 80.4 31.3 427.6 10 1 18 19.9 1.9 N/A N/A 20 2 41.6 30.4 -11.3 35.2 12 25 5 25.4 27.1 1.8 12.8 9.2 30 23 21.3 24 2.7 20.2 9 35 24 17.1 39.4 22.3 9.1 19.5 40 29 17.3 29.6 12.3 9.6 7.7 45 21 19.1 26.9 7.8 8.7 7.5 50 11 21.3 29.9 8.7 10.6 4 55 3 28.8 40.3 11.6 22.4 18.6 75 2 33.4 36.5 3.1 17.5 15.5 80 3 32.3 33.5 1.3 17.8 19.5 85 1 36.6 20.8 -15.8 N/A N/A 90 1 19.9 29.5 9.6 N/A N/A 140 1 88.1 107 18.9 N/A N/A 155 1 122.8 563.2 440.4 N/A N/A 185 7 40.4 27.7 -12.7 19 13.1 190 4 45.7 50.1 4.4 12.4 31.9 195 6 65.3 60.9 -4.5 74.2 61.9 200 16 55.4 118.6 63.2 67.5 178.5 205 24 55.4 85.4 30 79 136.7 210 26 33.6 80.4 46.8 28.6 190.7 215 36 42.8 60.8 17.9 71.1 54.8 220 36 68.8 84.4 15.7 119.5 67.5 225 32 49.2 44.3 -4.8 80.8 47.9 230 30 34.7 64.2 29.5 36.7 59.3 235 66 44.9 74 29.2 43.7 46.3 240 119 37.5 79.6 42.2 43.8 50.3 245 136 46.4 84.7 38.3 81.9 64.2 V - 32WD Sector (Degree) Measurement Count Arlington (μg/m 3 ) Buckeye (μg/m 3 ) Difference (μg/m 3 ) Standard Deviation (Arlington) Standard Deviation (Buckeye) 250 122 38.9 71.5 32.5 38.4 55.5 255 110 28.7 51 22.3 25.5 38.1 260 48 35.2 85.5 50.3 48.3 196.4 265 66 36.7 83.6 46.9 52.6 196.7 270 58 37.5 62.2 24.7 46 96.4 275 43 127.9 141.2 13.4 375.5 224.9 280 54 78.2 136.9 58.8 146.4 288.1 285 55 94.2 169 74.8 155.8 243.4 290 45 107.2 157.3 50.1 199.8 195.8 295 19 110.7 105.8 -4.9 174.5 151.2 300 8 298 191.2 -106.8 406.6 293.6 305 4 414.4 234.6 -179.8 321.5 193.4 310 5 217 240.8 23.8 286.5 319.5 315 14 347.7 270.6 -77.1 523.8 406.2 320 18 369.7 188.6 -181.1 653.1 288.7 325 27 473.6 184.1 -289.5 974.7 225 330 27 78.1 50.3 -27.8 180.2 95.8 335 16 26.8 35 8.1 21.5 30.5 340 20 24.6 54.6 30 30.6 131.1 345 11 30.4 36.5 6 21.7 36.8 350 1 16.6 25.1 8.5 N/A N/A 355 4 149.4 67.9 -81.6 132.9 101.8 Calculation of High Wind Background Concentrations As shown by the measurementcount data in Table V-11, the most common direction of high winds was from the west and southwest (from 200° to 300°). Much lower PM-10 concentrations were observed at both sites w hen the wind came from the southwest (200° to 270°), whereas the opposite is true when the wind came fr om the northwest (270° to 300°). For Arlington, the Palo Verde Nuclear Generating Stat ion, located to the northwest (270° to 325°), appears to be t he source of elevated concentrations. Similarly, the Mesquite Power Plant located to the sout hwest (245° to 250°) appears to be the cause of the higher PM-10 standard deviation at the Arlington monitor relative to Buckeye.
Another consideration is that the distance from the Arlington site to the Buckeye site is roughly 11 miles. Any comparison between the two sites should be offset to account for the time it takes for the wind to travel between the two site s. The values presented in Table V-11 did not address this offset. Still another consideration is the magnitude of the concentrations recorded at the two sites. Given the differences in sources surrounding the two sites, the concentrations located at Arlington should always be lower than those recorded at Buckeye for individual matched/o ffset five-minute pairs since the wind should be picking up anthropogenic emission located between the two sites.

V - 33In light of these considerations, the following steps and criteria were used to select the data used to quantify high wind background concentrations:

! Wind speed greater than 12 mph at both the Arlington and Buckeye monitors;

! Consistent with the methodology empl oyed in the temporary monitoring analysis, measurements at Arlington were lagged 45 mi nutes to account for the time it takes for air mass to travel the 11 miles to Buckeye along the 260 degree angle between the two sites (it ta kes 45 minutes to travel that distance with a wind speed of 15.2 mph, the value computed for winds in excess of 12 mph along that angle);

! 230° < WD < 245°, and 250°<WD<270° (Figur e V-9) at the Arlington monitor and at the one-hour-lagged Buckeye monitor; and

! Exclusions of data points where the concentration at Arlington was greater than that at the Buckeye monitor. These criteria selected a total of 400 pairs of offset (i.e., lagged) five-minute data at the Arlington and Buckeye monitoring sites. T he average concentration computed from the selected Arlington data was 27.8 μg/m 3 ; the median concentration was 21.9 μg/m 3 . The difference between these values indicates that the distribution of concentrations (and related wind speeds) is not uniform above 12 mph. Since a higher pr oportion of the data is based on lower wind speeds which produce lower concentrations, the median value is considered to be a more representativ e measure of non-anthropogenic high wind background PM-10 concentrations impacting the MAG nonattainment area. A summary of the selected five-minute pairs at the tw o sites is presented in Table V-12. When contrasted with the values in T able V-11, it shows that the abov e criteria reduced both the counts of available data and the concentrations recorded at the Arlington site. Figure V-8 presents a plot of the angular segments included and excluded from the datasets included in Table V-12.

V - 34Table V-12 Data Used to Calculate High Wind PM-10 Background Concentrations

WD Sector

(Degree) Measurement Count Arlington (μg/m 3 ) Buckeye (μg/m 3 ) Difference (μg/m 3 ) Standard Deviation (Arlington) Standard Deviation (Buckeye) 230 22 27.1 73.5 46.4 20.5 62.4 235 46 27.4 66.6 39.2 18.8 38.2 240 97 31.1 79.6 48.4 28.2 48.5 245 0 N/A N/A N/A N/A N/A 250 88 31.1 72.7 41.5 31.6 59.2 255 80 25.7 61.5 35.8 21.9 42.8 260 29 19.5 47.4 27.9 22.3 38.5 265 33 23.7 51.2 27.5 20.3 55.8 270 5 17.9 32.9 15.0 15.3 20.1 Total/Average 400 27.8 67.4 39.6 25.5 50.4 Median N/A 21.9 55.6 33.7 N/A N/A

V - 35Figure V-8 Close-In View of Arlington Temporary Monitor and Angular Segments Included and Excluded from the Background Calculations

V - 36Calculation of Low Wind Background Concentrations The Arlington monitoring data can also be used to quantify non-anthropogenic concentrations coming in from the desert duri ng low wind conditions. Table V-13 lists the five-degree angular values for measurementcount, average PM-10, and related standard deviations for low wind conditions (wind speed <=12mph) at t he Arlington and Buckeye monitoring sites. It shows that Arlington concentrations are consistently lower than Buckeye at any given five degree segment. The lowest Arlington values occur when wind is coming from the west and southwest (from 200° to 325°). As not ed earlier, the upwind sources from this wind direction are mostly non-anthropogenic, except for the Palo Verde Nuclear Generating Stat ion and the Mesquite Power Plant. Impacts from these facilities are much less evident in t he data as there is no significant concentration increase; the same is true for standard deviations, with a few notable exceptions (e.g., 290o). It is also more difficult to relate t he data at Arlington to Buckeye because the wind direction shifts more frequently, and it takes longer for air parce ls to travel from Arlington to Buckeye at lower wind speeds. For this reason it was determined that the se lection of Arlington values should not be conditioned on Buckeye measurements.

! Given these considerations, the follo wing steps and criteria were used to select the data used to quantify lo w wind background concentrations:

! Wind speed less than or equal to 12 mph at Arlington monitor; and 230° < WD < 245°, and 250°<WD<270° (Figur e V-8) at the Arlington monitor (to be consistent with high wind background calculation).
These criteria selected a tota l of 17,381 values at Arlingt on. The average concentration computed from the data was 18.2 μg/m 3 ; the median concentration was 14.9 μg/m 3 . The difference between these values indicates that the distribution of concentrations is not uniform at wind speeds below 12 m ph. Similar to the high wind analysis, the median value is considered to be a more represent ative measure of non-anthropogenic low wind background PM-10 concentrations impacting the MAG nonattainment area. A summary of the selected five-minute values is presented in Table V-14.

V - 37Table V-13 Angular Comparison of Matched Five-Mi nute PM-10 Concentrations Collected at Arlington and Buckeye Monitors When Winds Are Less Than 12 mph
WD Sector (Degree) Measurement Count Arlington (μg/m 3 ) Buckeye (μg/m 3 ) Difference (μg/m3) Standard Deviation (Arlington) Standard Deviation (Buckeye) 0 871 24.6 49.3 24.7 39.0 78.2 5 929 23.5 48.2 24.8 27.9 102.5 10 956 25.1 44.4 19.4 21.7 48.7 15 941 27.3 44.8 17.5 59.7 67.1 20 961 26.0 45.4 19.3 37.0 46.5 25 861 23.2 40.6 17.4 18.9 44.1 30 950 25.3 37.7 12.3 84.2 37.6 35 1035 25.5 40.7 15.2 29.9 60.2 40 1154 26.1 39.0 12.9 50.2 54.2 45 1366 27.6 40.5 12.9 113.2 57.0 50 1592 30.8 37.7 6.9 220.0 51.1 55 1924 33.1 36.3 3.2 152.4 44.7 60 2333 32.8 36.6 3.8 89.4 38.1 65 2423 32.1 36.7 4.6 118.1 36.9 70 2716 31.7 38.0 6.3 76.8 45.2 75 3066 31.5 40.4 9.0 67.5 36.4 80 3027 32.6 40.1 7.5 102.7 32.6 85 2433 30.5 42.2 11.8 26.5 39.0 90 1929 29.5 41.1 11.6 27.2 39.6 95 1682 29.5 42.1 12.6 26.0 45.3 100 1400 28.9 39.4 10.5 29.0 34.9 105 1158 32.9 40.0 7.1 125.3 30.8 110 950 26.7 40.5 13.8 22.1 34.2 115 739 24.5 40.8 16.3 20.4 42.4 120 587 25.4 39.8 14.3 20.8 32.2 125 553 25.7 42.5 16.8 19.7 38.7 130 475 28.0 42.9 14.9 83.9 81.5 135 480 22.6 37.2 14.6 17.5 35.9 140 475 22.3 36.3 14.1 19.5 34.4 145 480 23.2 38.5 15.3 20.8 36.6 150 473 21.5 41.9 20.4 15.9 81.1 155 520 22.0 42.2 20.1 19.4 52.8 160 475 21.8 39.1 17.3 29.2 62.3 165 458 20.5 36.2 15.7 16.8 36.1 170 466 21.3 36.0 14.7 15.0 32.0 175 470 20.8 33.5 12.7 19.7 34.8 180 465 21.1 34.6 13.5 15.9 32.3 185 508 32.3 33.8 1.5 222.4 31.8 190 507 20.2 32.8 12.7 14.9 37.3
V - 38WD Sector (Degree) Measurement Count Arlington (μg/m 3 ) Buckeye (μg/m 3 ) Difference (μg/m3) Standard Deviation (Arlington) Standard Deviation (Buckeye) 195 630 20.8 31.3 10.5 17.9 36.8 200 687 20.9 34.3 13.4 16.4 54.3 205 774 19.5 33.1 13.6 13.5 44.4 210 832 20.0 31.6 11.6 17.4 33.0 215 994 19.4 30.7 11.3 16.9 32.5 220 1249 18.1 29.0 10.9 14.2 28.3 225 1331 19.2 30.2 11.0 18.3 28.4 230 1539 18.8 33.9 15.0 22.6 32.3 235 2073 17.4 35.2 17.8 12.2 32.2 240 2434 19.1 36.7 17.7 33.4 37.7 245 2347 17.7 36.4 18.6 16.7 37.6 250 2547 18.3 37.6 19.3 24.4 46.4 255 2688 18.0 34.6 16.6 45.7 34.1 260 2489 17.7 32.2 14.4 20.2 33.3 265 1939 18.0 32.2 14.2 20.2 34.6 270 1672 18.3 32.5 14.2 17.5 32.3 275 1723 18.1 34.2 16.1 14.2 36.8 280 1543 18.8 32.3 13.5 17.1 28.7 285 1544 18.4 32.2 13.8 16.1 27.3 290 1405 21.6 35.2 13.6 100.7 61.7 295 1258 18.2 35.9 17.7 14.4 56.8 300 1132 19.6 34.7 15.1 25.9 35.7 305 1134 19.1 35.7 16.6 19.5 35.1 310 1138 19.1 40.1 21.0 15.8 49.7 315 1182 19.0 39.7 20.7 13.5 49.7 320 1291 18.4 37.0 18.5 14.3 41.1 325 1184 20.1 37.6 17.5 17.6 38.6 330 1268 19.9 40.4 20.5 16.2 71.8 335 1228 20.7 39.7 19.0 17.0 52.9 340 1216 20.2 42.9 22.7 14.9 67.3 345 1091 22.2 43.2 21.0 25.6 71.2 350 1037 21.7 43.9 22.3 20.2 51.1 355 868 21.6 42.1 20.5 18.3 48.6

V - 39Table V-14 Data Used to Calculate Low Wind PM-10 Background Concentrations
WD Sector

(Degree) Measurement Count Arlington (μg/m 3 ) Standard Deviation (Arlington) 230 1539 18.8 22.6 235 2073 17.4 12.2 240 2434 19.1 33.4 245 0 N/A N/A 250 2547 18.3 24.4 255 2688 18 45.7 260 2489 17.7 20.2 265 1939 18 20.2 270 1672 18.3 17.5 Total /Average 17381 18.2 27.6 Median N/A 14.9 N/A

V - 40DESIGN DAY SELECTION This section describes the process used to select design days for the PM-10 attainment demonstration in the Maricopa nonattainment ar ea. It identifies th ree wind speed regimes that are responsible for PM- 10 exceedances in 2007, the year just prior to implementation of new control measures under the 2007 Five Percent Plan. Since exceedances under low wind or stagnant conditions have been curta iled by existing controls, the design day selection is only focused on high wind days. The analysis first eliminates exceedance days that do not qualify for c onsideration, then weights the remaining days according to 24-hour average PM-10 concentra tion, exceedance location, and the number of stations exceeding on each day. The end result is t hat June 6, 2007, is recommended as the design day for the Maricopa PM-10 nona ttainment area, and May 4, 2007, is recommended as the design day for the Salt River modeling domain.
Introduction
An attainment demonstration r equires a baseline, or design day, starting point. Selecting one or more design days for a PM-10 attainm ent demonstration in the Maricopa area is a non-trivial exercise, given the existence of high wind days— when some of the highest PM-10 concentrations are recorded—that may qualify for exceptional event status under EPA guidelines. This analysis examines all exceedances that were recorded in the Maricopa area in 2007 and evaluates which of these are best qualified for a high wind design day selection. Exceedance Days The selection of PM-10 design days was lim ited to exceedance days recorded in 2007. This year was selected because it was the la st full year prior to the implementation of control measures under the MAG 2007 Fi ve Percent Plan, which was adopted in December 2007. During 2007, exceedances of the 24-hour federal PM-10 ambient air quality standard were recorded at six m onitoring sites in the Maricopa PM-10 nonattainment area. These sites included Coyote Lakes, Central Phoenix, Durango, Higley, South Phoenix, and West 43 rd Avenue. The Buckeye st ation also exceeded the standard on two days in 2007, but this monito r is outside the nonattainment area and therefore was not modeled in this plan. A listing of exceedance days by monitoring site, together with 24-hour average c oncentrations and the general meteorological conditions, is presented in Table V-15.

V - 41Table V-15 24-Hour Average NAAQS Exceedance Dates, Measured Concentrations and Associated Meteorological Conditions in 2007

Monitor Date PM-10 Conc. ( μ g/m 3 ) Meteorological Conditions Buckeye July 19 195.0 Low Winds November 15 166.2 Irregular Winds Coyote Lakes July 19 273.4 Thunderstorm Outflow October 21 312.9 Frontal System High Winds Central Phoenix July 19 267.8 Thunderstorm Outflow Durango Complex November 15 155.7 Irregular Winds Higley June 6 181.0 Frontal System High Winds July 19 199.5 Thunderstorm Outflow August 16 195.6 Thunderstorm Outflow August 23 230.4 Thunderstorm Outflow October 24 174.8 Frontal System High Winds South Phoenix April 12 171.1 Frontal System High Winds August 13 159.5 Thunderstorm Outflow West 43 rd Avenue March 27 227.9 Frontal System High Winds April 12 202.7 Frontal System High Winds

May 4 197.3 Frontal System High Winds June 6 225.7 Frontal System High Winds July 19 178.0 Thunderstorm Outflow August 16 215.1 Thunderstorm Outflow Note: The selected design days are highlighted in bol d italics and gray shading. The Buckeye monitor is located outside the PM-10 nonattainment area and is not part of this design day analysis. The Coyote Lakes monitor was a special purpose monitor that no longer operates and has since been replaced by the Zuni Hills monitor in late 2009. As such, the Coyote Lakes monitor is not a good candidate for the development of a design day. Wind Regimes All of the exceedances but one occurred on hi gh wind days. The single exception was July 19, 2007, at the Buckeye st ation. A high wind day is defined as any day in which fiveminute average wind speeds exc eed 12 mph. This cut-point is based upon the work done in developing the windblown dust emissions inventory in the 2008 Periodic Emissions Inventory (Appenidx A, Exhibit 1) which shows that generation of windblown dust emissions on average (throughout the nonattainment area) occurs when five-minute wind speeds exceed 12 mph. Since not all of the m onitoring stations have access to five minute data, days in which the hour ly average wind speed is above 12 mph are thus qualified as high wind days, as a conservative metric. High wind conditions generally occur in the Maricopa area under one of two different meteor ological regimes: frontal system passage and thunderstorm outflow. Frontal systems pa ssing over the Maricopa area produce high winds because of the pressure differences ac ross the front. Air ma sses move from areas of high pressure to areas of low pre ssure, generating winds whose strengths are
V - 42dependent on the differences in pressure. Be cause the leading edges of frontal systems extend for hundreds of miles, the movements of frontal systems produce high winds over large areas. In the Maric opa area, this phenomenon is charac terized by rapid increases in wind speeds almost simultaneously at manymonitoring stations, followed by elevated wind speeds for several hours afterward as fronts move slowly over the urban area. Depending on the strength of the winds associ ated with a frontal pa ssage, such an event may overcome the capability of BACM to protect soil surfaces from dust entrainment. When this happens, the event may qualify as an exceptional event under EPA guidance. Thunderstorm outflows, or monsoon winds, produc e high velocity winds that are shorter lived and less geographically expansive than thos e produced by the passage of frontal systems. Thunderstorm outflows result from the strong downflows that occur when a thunderhead collapses. The downflows have suffi cient velocity to cause sand saltation and dust entrainment in areas at the bases of thunderstorms and along the paths of travel as the downflows expend energy. Both undisturbed desert soils and disturbed soils controlled by BACM generate significant quant ities of PM-10 emissions during these events. As a result, high PM-10 concentrati ons resulting from thunderstorm outflows may qualify for exceptional event status under EPA guidelines. The July 19, 2007 exceedance at the Bucke ye monitor occurred during a period of relatively low wind conditions at this si te. The low hourly average wind speeds and peak gust velocities that occurred in the early morning hours of this day at Buckeye suggest that mechanical disturbance—such as by nighttime plowing of fields—was responsible for elevated PM-10 concentrations from midnight to 7:00 am, when the highest concentrations of the day were recorded. Meteorological conditions on days such as July 19, 2007, do not qualify as exceptional events but rather are candidates for design days at stations within the nonattainment area. Because the Buckeye station is outside the nonattainment area, July 19, 2007, is not a design day candidate. The November 15, 2007 exc eedance at the Buckeye and Durango monitors occurred under a mix of low and high wind speeds. Conc entrations were elevated throughout the nonattainment area on this day, suggesting a mi x of regional and loca l sources contributed to the exceedances. The exceedance at Bucke ye is not a candidate for a design day as it is outside the nonattainm ent area. The exceedance at Durango barely exceeded the standard (155.7 μg/m 3 ), making it a poor candidate for a design day as even the slightest control measure would result in attainment of the standard. Given the rare mix of both low and high wind elevated concentrations, a day like this is unlikely to recur, and indeed has not been replicated since. Monsoon Days The days on which monsoon, or thunderstorm outflow, winds occurred are possible candidates for exceptional event status and not good candidates for design day status. These days are distinguished from frontal events that usually occur in spring or fall as a transport of dust from source regions outside the nonattainment area is clearly associated V - 43with monsoon events. On these days, exceptionally high gust ve locities occurred for brief durations— typically only an hour or two—thatentrained dust from all types of exposed soils, including undisturbed desert soils. Additi onally, the source ar ea of the thunderstorm outflows on these days originated in the nat ural desert areas outside of the PM-10 nonattainment area, transporting large to massive amounts of dust into the PM-10 nonattainment area. The days on which thes e conditions occurred were July 19 and August 13, 16, and 23, 2007. On July 19 and August 16, 2007, peak gust velocities exceeded 40 mph for one or two hours and caused hourly PM-10 concentrations to rise to levels in the range of 1,700 to 4,000 μ g/m 3 at the stations with meteorological towers that recorded exceedances (Centra l Phoenix, Higley, and West 43 rd Avenue). Although these sharp rises in concentration occurred only for an hour or two, the magnitudes were sufficient to cause the 24-hour average on that day to exce ed the standard. These days, at these stations, would not have been exc eedances but for the contributions generated by thunderstorm outflow winds. Peak gust velocities were lower on August 23, 2007, at the Higley m onitor, but hourly PM10 concentrations still rose and fell with the a rrival of the dust front associated with a thunderstorm outflow that had begun to lose strength once encount ering the urban edge of the nonattainment area.. The peak gus t velocity ranged between 17 and 28 mph from 8:00 pm to 11:00 pm, as hourly PM-10 c oncentrations hovered between 900 and 1,800 μ g/m 3 . The pattern of average wind speed, peakgust velocity, and PM-10 concentration during these three hours strongly suggests t he contribution of transported particulate to the monitor from outside the i mmediate area. These trends ar e displayed in Table V-16.
Table V-16 Hourly PM-10 Concentrations and Wind Speeds at the Higley Monitor at 8:00 – 11:00 PM on August 23, 2007

Hour Hourly PM-10 μ g/m 3 Avg. Hourly Wind Speed, mph Peak Gust Speed, mph 7:00 PM 73.7 4.8 27.2 8:00 PM 1865.1 9.2 28.7 9:00 PM 916.9 2.2 9.9 10:00 PM 1065.8 4.3 17.1 11:00 PM 595.2 6.1 13.8 In the hour between 7:00 and 8:00 pm, wind gust speeds rose dramatically near the end of the hour, causing the peak to reach 27.2 mph while the hourly average wind speed remained relatively low at 4.8 mph. In the following hour, gust velocities remained elevated while the average wind speed clim bed to 9.2 mph and the hourly PM-10 concentration climbed to 1,865 μ g/m 3 . Then, in the next hour, both gust speeds and the average hourly wind speed dropped dramatically while the hourly PM-10 concentration remained at a relatively high 920 μ g/m 3 . Between 10:00 and 11:00 pm, wind speeds rose again, doubling in magnitude, but the hourly PM-10 concentration rose by only 16%. In
V - 44the subsequent hour, the PM-10 concentrati on drops by 44% while the average hourly wind speed increases by 42%. This pattern is typical of thunderstorm outflows that dissipate in strength when reaching the increased surface roughness of the urban boundaries of the nonattainment area where t he wind speeds and gust are typically low to moderate, but the associat ed transported dust remains in the air and can take several hours to deposit out of the atmosphere. A similar, but shorter, episode occurred on A ugust 13, 2007, at the South Phoenix monitor. On this day, the peak gust velocity rose to 24.9 mph between 11:00 pm and midnight, while the hourly PM-10 c oncentration rose to 2,600 μ g/m 3 . During the remainder of the day, PM-10 concentrations and wind speeds were typical of a light wind day. The contribution of this last hour of the day caus ed the 24-hour average PM-10 concentration to rise to 159.5 μ g/m 3 , resulting in an exceedance. T he hourly PM-10 concentrations and wind speeds for this day are shown in Table V-17. During the last hour of this day, the peak gust velocity exceeded the second highest value of the day by 40%, but the hourly aver age wind speed was greater than the second highest value in this column by only 4% . At the same time, the hourly PM-10 concentration was 2,639% higher than the second highest value of the day. Similar to the August 23 rd event, the implication of these data is that the thunderstorm outflow that reached the South Phoenix monitor just befor e midnight transported significant PM-10 from upwind sources south of the monitor, which includes a limited fetch of urban area and a significant swath of undistur bed desert soils, even as the t hunderstorm outflow itself had lost energy on arrival at the South Phoenix monitor. The significant contribution of transported PM-10 on August 13 and 23, 2007, leads to the same result: further control of sources near this monitor will not eliminate this type of exceedance, and these episodes should be designated exceptional events under EPA guidance.

V - 45Table V-17 Hourly PM-10 Concentrations and Wind Speeds at the South Phoenix Monitor on August 13, 2007

Hour Hourly PM-10, μ g/m 3 Avg. Hourly Wind Speed, mph Peak Gust Speed, mph 0:00 AM 31.2 0.4 3.3 1:00 AM 32.9 1.2 4.4 2:00 AM 23.9 1.0 4.1 3:00 AM 30.9 0.4 1.9 4:00 AM 35.9 1.6 4.5 5:00 AM 46.9 1.3 3.5 6:00 AM 75.9 2.4 7.7 7:00 AM 64.8 6.1 12.2 8:00 AM 53.4 5.0 10.5 9:00 AM 47.9 5.1 12.3 10:00 AM 40.9 2.4 11.2 11:00 AM 42.1 3.0 12.2 12:00 PM 52.1 7.0 15.1 1:00 PM 98.5 6.5 16.4 2:00 PM 97.2 5.2 15.5 3:00 PM 87.5 5.0 15.2 4:00 PM 69.0 7.1 16.4 5:00 PM 51.3 6.6 15.4 6:00 PM 43.1 6.7 13.5 7:00 PM 51.4 4.9 12.0 8:00 PM 38.9 3.2 9.8 9:00 PM 41.6 4.4 10.8 10:00 PM 71.9 5.8 17.8 11:00 PM 2599.2 7.4 24.9 Frontal Wind Days On frontal wind days, peak hourly PM-10 conc entrations are lower than those occurring on monsoon days, high winds occur for longer durations, and peak gust speeds range a little lower than those recorded on monsoon days. Frontal wind days produced significantly more hours during 2007 in which PM-10 concentrations exceeded the level of the 24-hour standard than are produced on monsoon days. Table V-18 compares some of the totals in 2007 for PM-10 exceedanc e days and high wind hours as grouped by wind regime. A listing of the frontal wind da ys on which the 24-hour standard was exceeded in 2007 within the Maricopa nonattainment area is presented in Table V-19.

V - 46Table V-18 Comparison of PM-10 Concentrations During 2007 Exceedance Days Under Different Wind Regimes

Wind Regime Average of Highest PM-10 Concentrations, μ g/m 3 Annual Hours that Exceed the Standard Percentage of Annual Hours that Exceed the Standard Frontal 831.5 69 60.5% Monsoon 2445.1 28 24.6%

Other 1 355.5 17 14.9% 1 Includes data from days with low and irregular winds. Table V-19 Peak Hourly PM-10 Concentrations and Wind Speeds In the Maricopa Nonattainment Area During 2007

Site Date Hours Exceeding Standard Highest PM Max Wind Gust High Wind Hours Higley 6/6/2007 9 580.2 37.7 8 West 43 rd 3/27/2007 11 794.4 44.6 11 West 43 rd 4/12/2007 9 774.9 45.5 7 West 43 rd 5/4/2007 11 570 35.2 10 West 43 rd 6/6/2007 12 662.3 33.4 12 Coyote Lakes 10/21/2007 10 1569.2 NA 15 Higley 10/24/2007 7 869.8 33.2 4 Days on which the peak gust velocity were the highest may be flagged as exceptional events due to the capability of such winds to overcome BACM controls and the possible presence of transported PM-10 from sour ces both within and outside the nonattainment area. While the previous sections in this chapter describing t he temporary monitoring insights and source weighting point to the importance of near-by sources during high wind events, long range transport can also o ccur on these days when wind speeds are unusually high. Evidence of such transport can be seen on days such as April 12, 2007, when the State Super Site moni tor recorded hourly PM-10 concentrations as high as 337.9 μ g/m 3 in the presence of minimal significant localized fugitive dust sources around the monitor. Such a designation as an excepti onal event eliminates March 27 (one monitor exceeded) and April 12, 2007 (two monito rs exceeded), because the exceedances on these days are associated with peak gust veloci ties that can easily generate PM-10 from controlled and natural surfaces. Several other monitors in nearby Arizona counties and eastern Californian desert counties also re corded exceedances on these days, suggesting the presence of regionally transported PM-10 along with the elevated wind speeds.

V - 47The exceedance recorded at Coyote Lakes on October 21, 2007, is also not considered in this analysis as this temporary installati on was a special-purpose monitor that no longer operates and has since been replaced by the near by (approximately 1. 75 miles) Zuni Hills monitor in late 2009. No exceedances of t he PM-10 standard were recorded at the Zuni Hills monitor in 2009 or 2010. As such, the Co yote lakes monitor is a poor candidate for the development of a design day. Of the remaining days, June 6, 2007, is t he only day on which more than one monitor exceeded the standard during the pa ssage of a storm front. On this day, hourly average wind speeds began at moderate levels and rose dur ing daylight hours to peak in the early afternoon. Wind speeds then dropped to the lowest levels of the day by midnight. Hourly PM-10 concentrations followed a similar tr end with sharper increases when hourly wind speeds exceeded about 12 mph, with faster dec lines due to exhaustion of particulate entrainment from limited reservoir soils even as wind speeds remained steady for a few hours. Plots of hourly average wind speed and PM-10 concentrations for the West 43 rd Avenue and Higley sites are presented in Figures V-9 and V-10, respectively. The relationships between wind speeds and PM- 10 concentrations at these two sites on June 6, 2007, suggest that loca l sources were primarily re sponsible for PM-10 impacting the monitors. As Figure V-9 indicates, elevated wind speeds above 12 mph (the speed at which wind entrainment of dust commences in the Maricopa area) were present at West 43 rd Avenue for 12 hours, generating 73% of t he 24-hour PM-10 concentration of 225.7 μ g/m 3 . The 24-hour concentration value at West 43 rd Avenue is also the maximum concentration seen for an exceedance day that is not a clear candi date for an exceptional event. Elevated wind speeds above 12 mph we re present for 8 hours on June 6 at the Higley site, accounting for 66% of the av erage 24-hour PM-10 concentration of 181.0 μ g/m 3 . In comparison to the Higley monitor, this day is also similar to the exceedance seen at the Higley monitor un der frontal winds on October 24, 2007, implying that the controls that would bring attainment to Higley on June 6, 2007, would also provide attainment at Higley on October 24, 2007. On this basis, June 6, 2007, is the best design day for an attainment demonstrati on throughout the nonattainment area.

V - 48Figure V-9 Hourly Average Wind Speed and PM-10 Concentration at West 43rd Avenue Monitor on June 6, 2007

V - 49Figure V-10 Hourly Average Wind Speed and PM-10 Concentration at Higley Monitor on June 6, 2007

V - 50Of the eight exceedance days that occurred in the Salt River area modeling domain (encompassing the Durango Comple x, South Phoenix, and West 43 rd Avenue monitors), only one exceedance day remains that has not been previously ruled out (November 15, 2007, at Durango) or modeled (June 6, 2007), or may be an exceptional event: May 4, 2007. A concentration of 197.3 μ g/m 3 was measured at the West 43 rd Avenue site on this day, which experienced 10 hours with average hour ly wind speeds in excess of 12 mph. These high wind hours contribut ed 74% of the 24-hour average PM-10 concentration. The pattern of hourly wind speeds and PM-10 concent rations on this date suggests that local sources contributed the predominant fracti on of PM-10 recorded at the West 43 rd Avenue monitor, making this day the design day choice for the Salt River ar ea modeling. A plot of hourly average wind speeds and PM-10 conc entrations is included in Figure V-11. Figure V-11 Hourly Average Wind Speed and PM-10 Concentration at West 43rd Avenue Moni toring Station on May 4, 2007

V - 51Conclusions In 2007, the 24-hour PM-10 standard was exceeded 19 times, on 11 unique days at the monitoring stations in the Maricopa County. Two of these exceedances were recorded at the Buckeye station, which is outside t he PM-10 nonattainment area, and two were recorded at the Coyote Lakes site, which wa s a temporary special studies site no longer in operation. The Coyote Lakes monito r has since been replaced with the nearby Zuni Hills monitor in late 2009 which has not re corded an exceedance in 2009 or 2010. As such the Coyote Lakes monitor is a poor choice for development of a design day and these exceedances, along with those at t he Buckeye monitor, have been excluded as candidates for design days within the nona ttainment area. Of the remaining 15 exceedances, seven occurred on monsoon (t hunderstorm outflow) days, which likely qualifies these exceedances for exceptional ev ent status but not for consideration as design days. An additional three exceedances occurred during very strong synoptic frontal winds, which may also qualifies these exceedanc es for exceptional ev ent status. Of the remaining five exceedances, two occurred on June 6, 2007, which is recommended to be the design day for the Maricopa nonattainment area. Of the furt her remaining three exceedances, one occurred at the Higley moni tor (October 24, 2007) and is similar in nature to the modeled June 6, 2007 design day. The other two exceedances (May 4, 2007, and November 15, 2007) occurred withi n the Salt River modeling domain. November 15, 2007 was excl uded as an outlier event and bec ause its 24-hour value was barely over the standard (155.7 μg/m 3 ), leaving the exceedance of May 4, 2007 at the West 43 rd Avenue monitor as the final choice to of a design day for the Salt River area domain.

V - 52MODELING DOMAINS As explained earlier in the conceptual model section, separate modeling domains were developed for the high and low wind hours on each of the design days. Hourly high wind domains were developed using back trajectori es calculated with wind speed and direction data from the modeled monitor. Domains fo r the low wind hours are represented by the sources and land uses surrounding each of the monitors. The basis for distinguishing between high and low wind hours is the 12 m ph windblown dust threshold developed in the 2008 PM-10 Periodic Emissi ons Inventory (Appendix A, Exhibit 1). This section discusses in detail the developm ent of the low and high wind domains. Table V-20 shows the breakout between high and low wind hour s for each of the design day-modeled monitors.

V - 53Table V-20 Breakout of High and Low Wind Hours on M odeled Design Days at Each Monitor

Hour 5/4/2007 6/6/2007
West 43 rd West 43 rd Central Phoenix Durango Greenwood Higley State SuperSite West Phoenix (Hourly Average Wind Speed in mph ) 0 2.5 13.3 12.5 8.9 8.1 7.4 7.6 7.1 1 1.4 9.9 13.1 6.3 5.7 5.8 6.3 7.8 2 0.4 9.1 8.6 5.0 4.9 8.8 5.4 8.4 3 5.5 7.8 8.0 1.0 2.9 9.0 5.4 4.2 4 6.7 10.6 10.9 2.6 2.1 9.1 6.7 5.1 5 8.5 14.5 10.3 7.3 5.4 7.4 7.2 6.1 6 7.2 14.9 12.4 9.1 6.7 9.4 7.2 8.5 7 4.9 11.4 12.8 8.7 7.7 9.4 6.5 10.3 8 4.5 11.3 11.1 10.5 8.3 10.8 7.2 8.7 9 9.2 12.0 11.3 11.2 10.0 11.6 6.7 8.6 10 9.4 13.8 12.1 11.9 11.0 14.6 6.9 8.8 11 10.6 16.0 13.9 12.5 10.8 15.2 9.4 12.1 12 13.4 16.6 15.3 13.9 12.7 17.6 8.9 13.6 13 17.6 15.1 15.4 13.5 12.6 15.3 9.8 15.1 14 17.4 17.6 16.9 15.7 15.4 15.8 10.5 15.1 15 18.7 18.1 17.8 17.9 13.9 15.6 11.4 13.5 16 17.7 17.0 15.7 14.5 11.9 15.3 10.1 12.0 17 19.4 14.5 14.0 12.9 11.7 13.5 9.2 11.7 18 17.6 14.9 14.0 10.3 11.4 10.1 11.2 10.0 19 15.5 12.0 11.9 8.9 8.7 6.9 9.6 9.3 20 9.8 8.8 11.1 6.4 7.4 6.6 7.8 9.1 21 13.6 9.3 11.7 7.5 7.0 7.1 6.3 6.8 22 15.6 7.0 8.8 6.3 5.1 2.9 3.8 5.3 23 11.6 6.8 8.5 5.2 4.0 3.2 3.6 4.8 Note: High wind hours are higlighted in bold italics. High Wind Domains High wind back trajectories are developed for any monitor-specific design-day hour with an average wind speed over 12 mph. When av ailable, five-minute average wind speed and direction, as measured by the modeled monitor, was used to develop the back trajectories from which the modeling dom ains are developed. When five-minute data is unavailable, hourly wind speed and direction is us ed. The length of t he back trajectory is
V - 54determined by the magnitude of the wind speed (e.g., an hourly average wind speed of 15 mph will produce a back trajectory 15 miles in length). The back trajectory plots are generated based on either hourly or the five-minute surface wind speed (WS) and wind direction (WD) data. This back trajectory calculation only considers the horizontal air mo vement and ignores the vertical movement of the air. The trajectories are presented as a sequence of UTM coordinates for the endpoints of each specific time interval being simulated. Us ing five-minute data as an example, The X and Y of the UTM coordinates for each five mi nute interval are calculated as following: X=X1+WS*0.447*60*5*SIN(WD*2*PI/360) Y=Y1+WS*0.447*60*5*COS(WD*2*PI/360) Where X and Y are the UTM coordinates of the current five minutes interval back trajectory endpoints; X1 and Y1 are the endpoints for the previous five minutes interval back trajectory; WS and WD are the wi nd speed (MPH) and Wind direction (degree) observation during the current five minutes. 0.447 ms -1 /mph is the WS unit conversion factor from MPH to m/s, 60 seconds/minute * 5 minute is the air traveling time (seconds) during the five minutes, and 2* PI/360 is the conversion fact or from degrees to Radians. This process is completed and mapped for each high wind hour back trajectory in ArcGIS. Establishing the Boundaries of a High Wind Domain - Once all of the back trajectories have been mapped, it is necessary to determine how far to extend the domain from either side of the back trajectory. This issue was explored in modeling efforts that focused on the West 43 rd Avenue monitor in the Salt River area. A summary of those efforts are presented below and conclude that a one mile bu ffer on either side of the back trajectory is a conservative representation of the domain for high wind sources. The analysis of emissions impacting the West 43 rd Avenue monitoring station during high wind events included inventories of emissions in upwind areas. Defining the specific domain boundaries of upwind areas within which to focus emission data collection was both necessitated by the significance of sour ce proximity to the monitor during high wind hours, and facilitated by the land use database maintained in GIS format by MAG. Analysis of wind directions and s peeds during hours when the West 43 rd Avenue station exceeded 150 μg/m 3 found that winds were primarily fr om the west-southwest along the Salt River, possibly influenced by orographi c affects. Exceedance hours generally began when average hourly wind speeds exceeded 12 mph. At this speed, sources that may be located three hours upwind – a period of time during which the coarse fraction of windentrained dust will settle out of the air - w ould be located beyond the urban and agricultural boundaries to the west of the West 43 rd Avenue station. Thus, the western boundary of each back-trajectory emission inventory domain was set at the edge of development (whether for agricultural or other use), typically just east of the Buckeye monitoring station. The eastern boundary was invariably set at the location of the West 43 rd station.

V - 55Entrained dust plumes from disturbed lands spread horizontally and vertically as winds carry suspended particulate downwind. Analysi s of in-plume concentrations predicted by a computer dispersion model ( AERMOD) shows that the rate of spread decreases as wind speed increases. The modeling scenario used to determine the distance-related reduction factor to use in weighting emissions in a m odified rollback analysis, as described in Source Weighting Analysis section, was also used to estimate the angular arc of a dust plume perpendicular to its centerline at different wind speeds. Receptor sites lateral to the plume cent erline were located at the same downwind distances from the hypothetical area source as those sit ed along the plume centerline. As in the weighting factor analysis, the AER MOD model was run at several different wind speeds ranging from 12 to 24 mph. The edge of each plume was identified in the output as the location of the lateral receptor closes t downwind to the source that first registered a non-zero PM-10 concentration. A tabulati on of the arcs subtended by plumes at increasing wind speeds, as report ed by the modeling output data, is shown in Table V-21. At the minimum high wind speed of 12 m ph, the arc subtended by a dust plume is estimated to be 34.2 degrees, or 17.1 degrees on each side of the downwind centerline.
Table V-21 Dust Plume Arc as a Function of Wind Speed Hourly Average Wind Speed (mph) Plume Arc (degrees) 12.0 34.2 15.0 33.1 18.0 28.8 21.0 25.9 24.0 22.7
The Estrella Mountains to the south of the Salt River have the potential to channelize high speed wind flows approaching from the west. This suggests that winds can be converging upwind of the West 43 rd Avenue station in a manner that would not be detected by the wind instruments operating at the monitoring site. Such convergence would bring emissions from lands outside t he 34.2 degree arc upwind of the station into the wind field bounded by the arc and impact the monitor. In or der to account for th is potential, and in an exercise of conservatism, the angl e subtended by the modeled arc was doubled to assure that all upwind cont ributing sources were included within the high wind inventory domain. This assumption increased the upwi nd arc to a full angle of 68.4 degrees, or 34.2 degrees on each side of the back trajectory centerline. The emission weighting analysis demonstr ated that PM10 concentrations drop dramatically with increasing distance dow nwind of an area source under high wind conditions. For example, under an hourly average wind speed of 12 mph, PM10 concentrations decline by two orders of magni tude, or 99%, between a fence line location

V - 56at the downwind edge of an area source and a plume centerline location 1.74 miles downwind. This reduction factor of 99% wa s considered to be significant and was used as a basis for the design of the emission inventory domain straddling the back trajectory centerline.
At a location 1.74 miles upwind of the West 43 rd Avenue monitor, the width of a 68.4 degree arc would be 2.36 miles. Within this arc and downwind distance, sources contributing a significant majority of emissi ons impacting the monitor will be located – if the emission density of windblown PM10 is reasonably uniform wit hin the upwind Salt River belt. A full arc width of 2.36 miles translate s into an arc width on each side of the back trajectory centerline of 1.18 miles. Th is value was rounded downward to 1.0 miles to represent the width of the modeling domain on each side of the centerline. In summary, all of the land uses within t he resulting high wind dom ain that can generate windblown dust are included as emissions sour ces for the attainment modeling. Figure V-12 provides an example of a calculated high wind back trajectory and resulting domain.

V - 57Figure V-12 Example High Wind Back Trajectory and Resulting High Wind Domain (Hour 15 from West 43 rd Avenue Monitor on June 6, 2007)

Low Wind Domains Spatial domains for the low wind hours we re developed based upon the predominant land uses surrounding each modeled moni tor. The nonattainment area as a whole is too large to be representative of the PM-10 emissi ons around the modeled monitors. As such, smaller subsets of the nonattain ment area are necessary in or der to accurately represent the mix of sources around each modeled moni tor. Three separate low wind modeling domains were developed as part of the attainm ent demonstration to aid in focusing on the low wind sources around each monitor. Considerable effort has been expended in previ ous PM-10 air quality plans in developing the Salt River area domain. This area is modeled both on its own and as part of the

V - 58regional nonattainment area demons tration. This domain is considered to contain the worst-case representation of PM-10 sour ces in the nonattainment area and has the highest density of PM-10 emissions under low wi nd conditions. All major sources of PM10 emissions, except unpaved roads, are represent ed in this area. These sources include light and heavy dust-generating industries, acti ve agricultural land, active earthmoving sites, vacant lots and unpaved par king areas. There are three active PM-10 monitors that lie within the Salt Riv er domain: West 43 rd Avenue, South Phoenix and Durango Complex. This 36 square mile domain is bounded by Van Buren Street to the north, Baseline Road to the south, 59 th Avenue to the west and 7 th Street to the east. Figure V-13 displays the Salt River area low wind domain. Figure V-13 Salt River Area Low Wind Domain

A second domain, located around the east valley Higley monitor was developed to represent the mix of sources in that area. This area is modeled as part of the regional attainment demonstration on June 6, 2007. Predominant PM-10 sour ces within the Higley domain include active agricultural fields, active earthmoving operations and a major V - 59regional freeway. This 16 square mile dom ain is bounded by Warner Road to the north, Germann Road to the south, Val Vista Driv e to the west and Power Road to the east. Figure V-14 displays the Higley low wind domain. Figure V-14 Higley Low Wind Domain

The last low wind domain developed for the atta inment demonstration contains four PM-10 monitors (modeled as part of t he regional attainment demonstrat ion) located in the center of the nonattainment area: Central Phoeni x, Greenwood, State Super Site and West Phoenix. These monitors are all located in areas that have similar land uses of dense residential and light industrial/commercial/retail. In terms of PM-10 sources, the largest sources are light dust-generating industrie s, active earthmoving sites and major transportation corridors. This 40 square m ile domain is bounded by Missouri Avenue to the north, Harrison Str eet to the south, 51 stAvenue to the west and 24 th Street to the east. Figure V-15 displays the Central City low wind domain.

V - 60Figure V-15 Central City Low Wind Domain

V - 61INVENTORY DEVELOPMENT Under a rollback modeling scheme, reductions of emissions that im pact the monitor are assumed to result in an equal reduction in monitor concentrations. As such, both base case (2007) low and high wind inventories must be developed along with control case (2012) low and high wind inventor ies. This following descri bes in detail how the 2007 base year and 2012 control/attainment year hi gh and low wind inventories were developed. Details on how the base and attainment year inventories are developed for the entire nonattainment area are presented in Chapters II and III of this TSD. High Wind Inventories For the high wind hours, hourly windblown PM-10 emissions are calculated based upon the land uses that fall within each of the hour ly high wind domains. Land use data, with the exception of construction data, come s from the MAG information services and represents land use patterns as of 2009. Land use is held c onstant between calculation of 2007 and 2012 year inventories. A detailed write-up of how the l and use data is created is included in the 2008 PM-10 Periodic Emissions Inventory as an Appendix to the windblown dust section. Construction data was provided by the Maricopa County Air Quality Department for the year 2007. To be c onservative this data is also held constant through 2012 even though there is substantially less construction occurring due to the economic recession. Windblown PM-10 emissions for the subject land uses are calculated per the methodology described in the 2008 PM- 10 Periodic Emissions Inventory (Appendix A, Exhibit 1). As an example, emissions from the West 43 rd Avenue monitor hour 15 high wind domain (June 6, 2007 design day) are explai ned below. All of the hourly high wind emissions are calculated in the same manner shown in this example. Initially, through the use of ArcGIS, the land uses subject to windblown dust emissions within the high wind domain are identified. For the hour 15 example, 11 unique land uses within the high wind domain are subject to windbl own dust as shown in Figure V-16. They include the land uses of Active Open Spac e (i.e., parks), Agriculture, Commercial, Construction, Coreslab (a large combinati on of sand and gravel and industrial facility), Industrial, Passive/Restricted Open Space (i .e., preserves), Public/Military Space (i.e., jails, bases), Sand and Gravel facilities, Vac ant, and Dry Washes. These land uses are chosen because either all or some of their acreage is bare soil from which windblown dust can be generated. Land uses such as residentia l or golf courses are not included as land uses subject to windblown dust since none (or a very limited amount) of the acreage associated with these land uses is bare soil. Land uses on the steep slopes of mountain preserves are also excluded as the surfac e roughness of the slope severely limits the production of windblown dust. After the land uses are identified, a 10-acre fi shnet grid is applied to the land uses, so that no individual land use parcel is larger than ten acres. This allows for calculating the distance from each parcel boundary to the modeled monito r; which is West 43 rd Avenue in this example. The distance of the parcel to the monitor is necessary in order to apply V - 62the distance weighting factor to the calc ulated emissions as discussed earlier in this chapter. Figure V-16

Land Uses Capable of Producing Windblown Dust Within the Hour 15, West 43 rd Avenue Monitor, High Wind Domain (June 6, 2007)

To be conservative, all but f our of the land uses shown above are assumed to have 100% of their acreage capable of emitting windblown dust. The land uses of Commercial, Coreslab, Industrial and Public/Military are ex empted from this assumption because these land uses are known to have a mix of lar ge buildings and paved parking lots/access roads in addition to areas of bare so il. Over 2500 aerial photographs of these types of parcels in the Salt River area were evaluated to det ermine the average percentage of bare soil present on each of these land uses. The result s of that analysis are listed in Table V-22. To be conservative, the mean value was c hosen to represent t he average percentage of bare soil on these land uses, as this value was higher than the median in all cases. Note that Coreslab is considered an industrial parcel, and as such is assigned the average of 24% for the amount of bare soil present. V - 63Table V-22 Results of Aerial Photography Analysis of Percentage of Bare Soil on Land Uses with Both Bare and Covered Surfaces
Land Use Mean Median Std. Deviation Commercial 26% 20% 23% Industrial 24% 17% 21% Public/Military 35% 21% 35% After the land uses within the high wind dom ain have been classified and selected, the process for calculating windblown emissions from these land uses can begin. The 2008 PM-10 Periodic Emissions Inventory developed emission factors for two classes of bare soil: disturbed and stable. Distu rbed soils emit at a much higher rate than stabilized soils because there is more loose soil available to be entrained by the wind. As wind speeds increase, both disturbed and stable so ils emit at higher rates, as the extra energy from the wind entrains more material from both su rfaces. Thus, the main elements needed to calculate windblown PM-10 emissions are t he number of acres of bare soil, the wind speeds over that soil, and the percentage of the acres that are disturbed or stable. Table V-23 displays the emission factors by wind speed bins as developed in the 2008 Periodic Emissions Inventory. These em ission factors were developed based upon local testing of Arizona soils. The units of the em ission factors are tons per acre per fiveminute, as the input wind speed data for most of the high wind domains is a five-minute average wind speed.
Table V-23 Windblown PM-10 Emission Fact ors (tons /acre-five-minute) by 10-Meter Wind Speed Bin and Soil Stabilization
Soil Stabilization Wind Speed 12-15 mph Wind Speed 15-20 mph Wind Speed 20-25 mph Wind Speed 25-30 mph Wind Speed 30-35 mph Disturbed 5.44E-05 1.69E-04 5.14E-04 1.24E-03 2.57E-03 Stable 1.10E-05 2.93E-05 7.68E-05 1.64E-04 3.10E-04 Continuing with the use of the hour 15, West 43 rd Avenue, high wind domain example, the hourly average wind speed for that hour was 18.1 mph. An examination of the five-minute wind speed data for that hour reveals that ten of the five minute periods had wind speeds between 15-20 mph and two of the five minute periods had wind speeds between 20-25 mph. This means that the emissions fact ors from only two wind speed bins (15-20 and 20-25) will be used to calculate emissions for this hour. At this point, the amount of acreage by l and use and the five minute wind speeds have been determined for the example high wind domain. The one variable that is left to be
V - 64determined is how much of the land use ac reage is disturbed or stable. A direct measurement of this variable is not possible, as stabilization rates change over time with meteorological and anthropogenic activities unique to each individual parcel. Therefore, a surrogate variable is needed to assume an average disturbance level for each land use subject to producing windblown dust. As discu ssed in Chapter Five of the main plan and the 2008 PM-10 Periodic Emissions Inventory, rule effectiveness has been chosen as the surrogate for the disturbance leve ls of bare soils. As an ex ample, a rule effectiveness of 80% would assume that 80% of the acreage is stable and 20% is disturbed. Maricopa County Air Quality Department per formed rule effectiveness studi es for three fugitive dust rules: Rule 310, earthmoving activities, Ru le 310.01, open and vacant areas, and Rule 316, sand and gravel sites. These studies were done on an annual basis and are shown in Table V-24. The values for cal endar years 2007, 2008 and 2010 were all derived per the methodology listed in the 2008 PM-10 Periodic Emissions Inventory. The increases in rule effectiveness through time is a direct result of the implementation of the control measures in this plan. The value for 2012 is the assumed value achieved as a result of the control measures in th is plan projected out through 2012 (See Chapter Five of main plan for more explanation).
Table V-24 Calendar Year Rule Effectiveness Rates as Surrogates for Soil Disturbance Rates
Rule 2007 2008 2010 2012 310 76% 90% 94% 94% 310.01 85% 95% 96% 97% 316 40% 65% 73% 73% The 11 land uses identified earlier in Figur e V-16 are thus assigned disturbance rates based upon the rule effectiveness rates in Tabl e V-24. Rule 310 serves as a surrogate value for construction land uses, Rule 316 serves as a surrogate for sand and gravel land uses, and Rule 310.01 serves as a surrogate for all remaining land uses. Rule 310.01 directly regulates all open ar eas and industrial/commercial areas that are permitted or unpermitted. The only land use under which Ru le 310.01 does not regulate is agriculture. However, because there are no quantitative rule effectiveness or disturbance rates studies available that are applicable to agricultura l land, Rule 310.01 disturbance rates are assumed to apply, as was assumed in the 2008 PM-10 Periodic Emissions Inventory. It is important to point out how ever, that because there are no benefits for agricultural land taken as part of the attainment demonstration or the five percent reductions, the assumed 2007 rule 310.01 effectiveness rate of 85% is held constant th rough 2012, meaning windblown dust emissions from agricultural lands in 2012 are the same as in 2007. All other land uses besides agriculture exper ience a reduction in emissions between 2007 and 2012 as a result of the benefit of increased rule effectiv eness; which is pragmatically translating as an assumption of less dist urbed soil in the windblown dust inventory.

V - 65Now that all of the requir ed elements (acreage, percent disturbed, and wind speeds) have been determined, the elements are simply mult iplied in order to obtain PM-10 windblown dust emissions for each land us e within the high wind domain. An example equation using data from the hour 15 example high wind domain is shown below to detail how high wind emissions are calculated: Example for calculating base year (2007) windblown dust emissions from Commercial land uses: (1) Land use * % acreage * 15-20 mph wind * % Stable * Stable 15-20 mph = Stable Emissions Acreage of bare soil speed periods emission factor (250.2) * (26%) * (10) * (85%) * (2.93E-05) = 1.62E-02 Tons

+ (2) Land use * % acreage * 20-25 mph wind * % Stable * Stable 20-25 mph = Stable Emissions Acreage of bare soil speed periods emission factor (250.2) * (26%) * (2) * (85%) * (7.68E-05) = 8.49E-03 Tons

+ (3) Land use * % acreage * 15-20 mph wind * % Disturbed * Disturbed 15-20 mph = Disturbed Emissions Acreage of bare soil speed periods emission factor (250.2) * (26%) * (10) * (15%) * (1.69E-04) = 1.65E-02 Tons

+ (4) Land use * % acreage * 20-25 mph wind * % Disturbed * Disturbed 20-25 mph = Disturbed Emissions Acreage of bare soil speed periods emission factor (250.2) * (26%) * (2) * (15%) * (5.14E-04) = 1.00E-02 Tons Sum of above equations (1 through 4) = 5.12E-02 Tons of PM-10 emissions from Commercial land uses. This process is repeated for all land uses and then summed to calculate total PM-10 emissions from all land uses within the hi gh wind domain. The only difference between 2007 and 2012 year emissions is that the disturbance ra tes change based upon gains in rule effectiveness, thus the reductions in emissions between 2007 and 2012 are solely attributable to increases in rule effectiveness. The emissions that are calculated per the st eps above, represent maximum potential PM10 emissions from windblown dust. As ex plained in the 2008 PM-10 Periodic Emissions Inventory, a whole host of other factors including supply limitations, surface roughness, soil moisture content, vegetative cover, soil te xture, etc. and would likely limit the PM-10 emissions from windblown dust to levels below what is calculated in each of the high wind domains. The 2008 PM-10 Emissions Inventory corrects for these limiters by standardizing PM-10 emissions as compared to concentrations seen at the monitor under high wind conditions. This helps to ensure the scale of the emissions estimate is not too
V - 66large. However, this step is not necessaryfor high wind emission inventories prepared for use in an attainment demonstrati on, as what is important in this rollback modeling is the difference between 2007 and 2012 emissions, no t the scale of those emissions as compared to low wind emission sources. Since both 2007 and 2012 high wind emissions are calculated in the same way, the differ ence between the two inv entories provides the reductions needed to model attainment at the monitors. The unit and scale of the inventories thus do not matte r, only that the methodology is the same between the base and controlled inventories in order to claim t he benefits of the measures in this plan as applied to the modeled concentrations. Once high wind PM-10 emissions have been ca lculated for the land uses, one final step is required to prepare the emissions for atta inment modeling. The calculated emissions for each land use parcel are divided by the di stance (feet) from the modeled monitor. As discussed in an earlier section in this chapt er, distance weighting is applied to this emissions in order to account for their diminishing impact on monitor concentrations with distance. The best weighting function was determined to be a simple inverse distance ratio (1/d) through analysis of dispersion behavior provided by sample AERMOD model runs (see earlier sections on source we ighting and temporary monitor insights). Tables V-25 through V-31 provide the results of the high wind emissions inventories for the high wind domains of eac h modeled monitor, based upon the process outlined above. They list both the calculated emissions and the inverse-distance weighted emissions for the base and controlled year inventories.

V - 67Table V-25 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for May 4, 2007 Design Day at the West 43 rd Avenue Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 12 3.05 2.09 2.872E-04 1.900E-04 33.8% 13 9.49 6.36 6.529E-04 4.245E-04 35.0% 14 9.94 6.67 6.866E-04 4.454E-04 35.1% 15 13.94 9.19 8.721E-04 5.581E-04 36.0% 16 13.36 8.81 8.921E-04 5.699E-04 36.1% 17 19.01 12.39 1.190E-03 7.505E-04 36.9% 18 11.84 7.86 7.837E-04 5.033E-04 35.8% 19 6.58 4.44 5.158E-04 3.364E-04 34.8% 21 4.02 2.72 3.236E-04 2.129E-04 34.2% 22 6.63 4.48 5.104E-04 3.330E-04 34.8% Total 97.86 65.02 6.714E-03 4.324E-03 35.6%

V - 68Table V-26 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Central Phoenix Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 0 1.90 1.32 7.549E-05 5.230E-05 30.7% 1 0.99 0.74 5.184E-05 3.687E-05 28.9% 6 1.69 1.18 6.873E-05 4.797E-05 30.2% 7 0.99 0.74 5.254E-05 3.730E-05 29.0% 10 0.88 0.64 4.939E-05 3.485E-05 29.4% 11 2.01 1.41 7.319E-05 5.123E-05 30.0% 12 4.01 2.91 1.706E-04 1.166E-04 31.7% 13 7.52 5.04 2.448E-04 1.625E-04 33.6% 14 7.28 4.96 2.265E-04 1.520E-04 32.9% 15 4.33 3.04 1.657E-04 1.121E-04 32.3% 16 4.27 3.13 1.737E-04 1.192E-04 31.4% 17 2.29 1.60 8.494E-05 5.855E-05 31.1% 18 2.21 1.55 7.971E-05 5.545E-05 30.4% Total 40.39 28.25 1.517E-03 1.037E-03 31.7%

V - 69Table V-27 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Durango Complex Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 11 1.99 1.37 1.340E-04 9.011E-05 32.8% 12 3.69 2.55 2.267E-04 1.543E-04 31.9% 13 3.12 2.15 1.876E-04 1.281E-04 31.7% 14 8.02 5.49 4.672E-04 3.093E-04 33.8% 15 9.84 7.07 4.992E-04 3.379E-04 32.3% 16 5.62 3.79 3.247E-04 2.160E-04 33.5% 17 2.47 1.72 1.619E-04 1.110E-04 31.4% Total 34.74 24.13 2.001E-03 1.347E-03 32.7%

V - 70Table V-28 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Greenwood Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 12 1.05 0.77 5.872E-05 4.191E-05 28.6% 13 1.03 0.80 6.482E-05 4.701E-05 27.5% 14 3.03 2.16 1.618E-04 1.110E-04 31.4% 15 2.34 1.75 1.266E-04 8.868E-05 30.0% Total 7.45 5.49 4.119E-04 2.886E-04 29.9%

V - 71Table V-29 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the Higley Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 10 0.74 0.55 6.103E-05 4.481E-05 26.6% 11 3.00 2.05 1.944E-04 1.330E-04 31.6% 12 2.15 1.54 1.805E-04 1.270E-04 29.6% 13 2.41 1.69 1.824E-04 1.268E-04 30.4% 14 5.61 3.83 2.282E-04 1.553E-04 31.9% 15 5.70 3.98 2.113E-04 1.442E-04 31.8% 16 5.65 3.90 2.065E-04 1.403E-04 32.1% 17 1.50 1.11 6.687E-05 4.791E-05 28.4% Total 26.76 18.64 1.331E-03 9.195E-04 30.9%

V - 72Table V-30 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West Phoenix Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 11 0.65 0.53 2.164E-05 1.680E-05 22.4% 12 1.78 1.33 5.329E-05 3.930E-05 26.2% 13 3.35 2.45 8.177E-05 5.933E-05 27.4% 14 4.27 3.08 1.123E-04 8.105E-05 27.8% 15 1.63 1.21 4.623E-05 3.396E-05 26.5% Total 11.67 8.60 3.152E-04 2.304E-04 26.9%

V - 73Table V-31 Base Case 2007 and Controlled 2012 High Wind PM-10 Emissions Inventories for June 6, 2007 Design Day at the West 43 rd Avenue Monitor High Wind Hour Un-weighted Emissions (tons) Distance-Weighted Emissions (tons/feet from monitor) % Reduction of Weighted

Emissions 2007 2012 2007 2012 0 2.29 1.59 2.064E-04 1.388E-04 32.8% 5 3.31 2.29 2.894E-04 1.924E-04 33.5% 6 5.05 3.43 4.359E-04 2.860E-04 34.4% 10 3.44 2.38 2.835E-04 1.898E-04 33.1% 11 6.67 4.51 4.937E-04 3.237E-04 34.4% 12 6.02 4.06 5.697E-04 3.704E-04 35.0% 13 5.66 3.82 4.721E-04 3.088E-04 34.6% 14 9.67 6.48 6.830E-04 4.425E-04 35.2% 15 13.99 9.12 9.717E-04 6.168E-04 36.5% 16 9.67 6.48 6.630E-04 4.304E-04 35.1% 17 5.10 3.45 4.285E-04 2.812E-04 34.4% 18 4.94 3.34 3.857E-04 2.526E-04 34.5% Total 75.81 50.97 5.883E-03 3.833E-03 34.8%

V - 74Low Wind Inventories Even though high wind design days are being model ed for this attainment demonstration, there are still several hour s, if not the majority of hours, in the design day when winds are not high enough to produce windblown dust. Emissi ons from these hours contribute to the design day value and need to be accounted for. Significant reductions from the control measures in this plan have also occurred during low wind or stagnant conditions, so much so that a stagnant PM-10 exceedance has not been seen since 2007 in the nonattainment area. The success of the low wind m easures in this plan negates the need to develop complex design day-specific emission inventories. But rather, annual low wind emissions can simply be assigned to the land uses within each of the three low wind domains. The difference in 2007 and 2012 low wind inventories provide the benefits of the measures in this plan under low wind or stagnant conditions. Initially, an investigation was made to see if the low wind inventory for the nonattainment area as a whole could be used instead of s patially unique low wind domains. However, because the nonattainment area is so large, substantial differ ences in the distribution of land uses within the nonattainment area provi de for drastically diffe rent mix of PM-10 sources throughout sub-areas of the nonattain ment area. As such, it became apparent that low wind emissions needed to be estimated for the areas immediately surrounding the modeled monitors in order to accurately re flect the benefits of the control measures at each monitor in the attainment demonstrations. Low wind emissions are assigned to each of the three domains based upon land use distribution within each of the domains. The values for the low wind emissions are taken from Chapter Five of this Plan (the devel opment of those emissions are explained in Chapters II through III of this TSD). As a firs t step, the 2007 base and 2012 controlled low wind inventories are assigned to the PM-10 nona ttainment area as a whole. After the allocation is complete, the allocated emissions are divided by the number of acres in each land use to produce an annual tons/acre rate which can then be applied to the land uses in each of the three low wind domains to estimate the low wind emissions in each domain. Table V-32 lists the low wind emission cat egories and the land uses to which those emissions are allocated and Table V-33 lis ts the resulting tons/acre annual PM-10 emission rate for the PM-10 nonattainment ar ea. Tables V-34 through V-36 display the resulting low wind emissions in each of the three low wind domains.

V - 75Table V-32 Annual Low Wind PM-10 Emission Inventory Allocated by Land Use Category Source Category 2007 Emissions (tons) 2012 Emissions (tons) Land Use Category
POINT 158.53 134.59 Industrial AREA Residential Fuel Combustion 514.20 535.25 Residential Commercial Fuel Combustion 283.26 294.85 Commercial Industrial Fuel Combustion 478.48 498.06 Industrial Commercial Cooking 974.17 1,014.05 Commercial Construction 16,106.11 3,731.54 Construction Tilling, Harvesting, Cotton Ginning 936.27 893.20 Agriculture Travel on Unpaved Farm Roads 768.69 731.03 Agriculture Livestock 260.95 260.95 Agriculture Travel on Unpaved parking Lots 2,3750.50 2,472.74 Vacant/Open Offroad Recreational Vehicles 2,138.74 2,226.28 Vacant/Open Leaf Blowers 877.98 913.91 Residential Fires 496.71 496.71 Vacant/Open Mining/Quarrying 561.81 255.62 Industrial Travel on Industrial Haul Roads 770.71 350.67 Industrial Other Industrial Sources 1,032.62 876.65 Industrial NONROAD Aircraft 193.54 145.50 Transportation Airport Ground Support Equipment 28.64 19.90 Transportation Locomotives 34.16 34.16 Transportation Agricultural Equipment 15.37 13.60 Agriculture Commercial Equipment 119.54 105.78 Commercial Construction & Mining Equipment 1,269.88 1,123.64 Constr./Indust. 50/50 Industrial Equipment 103.04 91.18 Industrial Lawn & Garden Equipment 185.95 164.53 Residential Pleasure Craft 7.13 6.31 Vacant/Open Railway Maintenance Equipment 1.15 1.02 Transportation Recreation Vehicles 7.80 6.90 Vacant/Open ONROAD Exhaust 2,943.36 1,407.06 Transportation Tire Wear 245.80 261.41 Transportation Brake Wear 727.66 787.25 Transportation Paved Roads 7,749.01 8,421.72 Transportation Unpaved Roads 10,217.66 10,312.22 See Note TOTAL 52,584.31 38,588.59 N/A Note: Unpaved roads are allocated based upon the land uses that they are nearest to: Residential 26%, Commercial 3%, Agriculture 13%, Vacant/O pen 45%, Industrial 2% and Construction 11%.

V - 76Table V-33 Annual Low Wind PM-10 Tons per Acre Emission Rates in the Nonattainment Area
Land Use Acres 2007 Tons 2012 Tons 2007 Tons/Acre 2012 Tons/Acre Residential 435,720 4,235 4,295 9.72E-03 9.86E-03 Commercial 123,742 1,684 1,724 1.36E-02 1.39E-02 Agriculture 133,761 3,310 3,239 2.47E-02 2.42E-02 Vacant/Open 1,026,817 9,624 9,849 9.37E-03 9.59E-03 Transportation 28,856 11,923 11,078 4.13E-01 3.84E-01 Industrial 54,364 3,944 2,975 7.25E-02 5.47E-02 Construction* 43,795 17,865 5,428 4.08E-01 1.24E-01 TOTAL 1,847,054 52,584 38,588 2.86E-02 2.09E-02 *Construction acreage comes from Maricopa County Air Q uality Department permit re cords for the year 2007. Only locations that were verifiable were included in the acreage total.

Table V-34 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Salt River Area Low Wind Domain

Land Use Acres 2007 Emissions (tons) 2012 Emissions (tons) % Reduction Residential 6,296 61.19 62.05 (1.4%) Commercial 4,508 61.34 62.81 (2.4%) Agriculture 1,180 29.19 28.57 2.1% Vacant/Open 2,984 27.97 28.62 (2.3%) Transportation 405 167.28 155.42 7.1% Industrial 6,410 465.10 350.77 24.6% Construction 1,073 437.70 132.98 69.6% Total 22,856 1,249.76 821.23 34.3%

V - 77Table V-35 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Central City Low Wind Domain

Land Use Acres 2007 Emissions (tons) 2012 Emissions (tons) % Reduction Residential 12,161 118.19 119.87 (1.4%) Commercial 6,419 87.33 89.43 (2.4%) Agriculture 0 0.00 0.00 0.0% Vacant/Open 2,745 25.73 26.33 (2.3%) Transportation 244 100.82 93.67 7.1% Industrial 3,619 262.58 198.03 24.6% Construction 404 164.80 50.07 69.6% Total 25,592 759.46 577.41 24.0%

Table V-36 Annual Base Case 2007 and Controlled 2012 Low Wind PM-10 Emissions Inventories for the Higley Low Wind Domain

Land Use Acres 2007 Emissions (tons) 2012 Emissions (tons) % Reduction Residential 4,216 40.97 41.55 (1.4%) Commercial 1,123 15.28 15.65 (2.4%) Agriculture 1,865 46.15 45.17 2.1% Vacant/Open 1,774 16.62 17.01 (2.3%) Transportation 389 160.74 149.34 7.1% Industrial 36 2.58 1.95 24.6% Construction 765 312.06 94.81 69.6% Total 10,167 594.41 365.49 38.5%

V - 78CONTROL MEASURE ANALYSIS Under rollback modeling, the reductions achiev ed by the control measures are reflected as a comparison between the bas e case (2007) and controlled case (2012) inventories. Calculation of the emission reductions asso ciated with these control measures for the entire nonattainment area are pr esented in Chapters II and III of this TSD, as part of the requirement to show five percent annual reductions in PM-10 emissions. Since high wind days are being modeled for this attainment demonstration, both high wind and low wind inventories were developed to co mpare the effectiveness of the control measures in this plan. For the high wind hours, reductions between the 2007 and 2012 inventories is solely due to t he benefits of the contro l measures in this plan (increased rule effectiveness), as land use is conservati vely held constant between 2007 and 2012. No adjustment for economic growth or re cession has been applied to the high wind inventories. These reductions have been show n as part of the high wind inventory tables presented earlier (Tables V-25 through V-31) . Although no credit has been taken, in practice, land use conversion has also re duced PM-10 emissions within the high wind domains, as construction activity has been limited due to the ec onomic recession and as agricultural land within the PM-10 area slowly converts to other uses. The reductions seen during the low wind hours ar e a result of both the control measures and economic growth factors. Because of t he large size of the nonattainment area, the reductions of PM-10 emissions between t he base case 2007 and controlled case 2012 inventories were calculated for three low wind domains within the nonattainment area. These reductions have been shown in Tables V-34 through V-36 as part of the discussion of the creation of t he low wind inventories.

V - 79DEMONSTRATION OF ATTAINMENT As discussed earlier in the Chapter, May 4, 2007 was selected as the high wind design day to demonstrate attainment in the Salt River area, where the West 43 rd Avenue monitor alone had exceeded the 24-hour P M-10 standard. June 6, 2007 was chosen as the high wind design day for the entire nonattainment area when two monitors in the nonattainment area exceeded on this date (West 43 rd Avenue and Higley). The control measures in this plan are designed to reduce PM-10 emissions and their resulting concentrations to the point where the design days can be shown to attain the standard. Rollback modeling assumes a linear relations hip between PM-10 emissions sources and their contribution to observed ambient P M-10 concentrations. Hours where the wind speeds are low (< 12 mph), lim it the emissions sources to those within the predetermined low wind domain. Because all of the low wind sources are within a few miles of the modeled monitor, all sources are weight ed equally. During high wind hours, PM-10 emission sources follow the back trajectory of the prevailing winds at the monitor, forming a high wind domain whose distance from the monitor stretches back based upon the magnitude of the wind speeds. This creates hi gh wind domains that c an be over 20 miles in length. To account for the distance of the windblown P M-10 sources from the modeled monitor, these sources are weighted by thei r relative distance to the impacted monitor.
The reductions observed between the base case 2007 and controlled case 2012 low inventory and the high wind (distance-wei ghted) inventory provides the expected reductions of concentrations at the impac ted monitor. Holding background values constant, the reductions seen in the inventor ies are applied to the low and high wind hourly concentrations of the design day to demonstrat e that the control m easures in the plan will achieve attainment. Attainment in 2012 has been shown for both the May 4, 2007 and June 6, 2007 design days. Results of the a ttainment demonstrations are presented in Tables V-37 through V-44.

V - 80Table V-37 2012 Attainment Demonstration High Wind Design Day (May 4, 2007) at the West 43 rd Avenue Monitor
Hour Wind Speed (mph) May 4, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 2.5 25.9 14.9 22.1 1 1.4 19.8 14.9 18.1 2 0.4 27.0 14.9 22.8 3 5.5 31.5 14.9 25.8 4 6.7 50.7 14.9 38.4 5 8.5 82.7 14.9 59.4 6 7.2 117.3 14.9 82.2 7 4.9 71.9 14.9 52.3 8 4.5 73.5 14.9 53.4 9 9.2 73.0 14.9 53.1 10 9.4 144.2 14.9 99.9 11 10.6 147.0 14.9 101.7 12 13.4 196.6 21.9 137.5 13 17.6 521.0 21.9 346.4 14 17.4 451.6 21.9 300.6 15 18.7 449.9 21.9 295.8 16 17.7 311.2 21.9 206.7 17 19.4 570.0 21.9 367.7 18 17.6 357.2 21.9 237.2 19 15.5 204.0 21.9 140.7 20 9.8 174.7 14.9 119.9 21 13.6 148.8 21.9 105.4 22 15.6 281.1 21.9 191.0 23 11.6 205.6 14.9 140.2 24-Hour Avg. 197.3 134.1 Note: High wind hours highlighted in bold italics.

V - 81Table V-38 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Central Phoenix Monitor
Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 12.5 138.5 21.9 102.7 1 13.1 176.2 21.9 131.6 2 8.6 133.6 14.9 105.1 3 8.0 109.7 14.9 86.9 4 10.9 92.9 14.9 74.2 5 10.3 81.5 14.9 65.5 6 12.4 99.6 21.9 76.1 7 12.8 104.0 21.9 80.2 8 11.1 80.2 14.9 64.5 9 11.3 73.2 14.9 59.2 10 12.1 69.6 21.9 55.6 11 13.9 96.1 21.9 73.8 12 15.3 106.2 21.9 79.5 13 15.4 150.5 21.9 107.3 14 16.9 211.2 21.9 148.9 15 17.8 255.7 21.9 180.1 16 15.7 111.7 21.9 83.5 17 14.0 71.0 21.9 55.7 18 14.0 74.4 21.9 58.4 19 11.9 72.5 14.9 58.7 20 11.1 59.8 14.9 49.0 21 11.7 70.6 14.9 57.2 22 8.8 63.0 14.9 51.5 23 8.5 66.9 14.9 54.4 24-Hour Avg. 107.0 81.7 Note: High wind hours highlighted in bold italics.

V - 82Table V-39 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Durango Complex Monitor
Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 8.9 132.6 14.9 92.2 1 6.3 166.4 14.9 114.4 2 5.0 133.6 14.9 92.9 3 1.0 112.7 14.9 79.2 4 2.6 124.4 14.9 86.8 5 7.3 101.4 14.9 71.7 6 9.1 164.5 14.9 113.2 7 8.7 113.4 14.9 79.6 8 10.5 93.6 14.9 66.6 9 11.2 86.3 14.9 61.8 10 11.9 83.3 14.9 59.8 11 12.5 130.3 21.9 94.8 12 13.9 168.1 21.9 121.4 13 13.5 202.7 21.9 145.4 14 15.7 405.5 21.9 275.9 15 17.9 398.1 21.9 276.5 16 14.5 119.9 21.9 87.1 17 12.9 70.0 21.9 54.9 18 10.3 53.9 14.9 40.5 19 8.9 57.0 14.9 42.6 20 6.4 61.1 14.9 45.3 21 7.5 83.0 14.9 59.6 22 6.3 67.8 14.9 49.7 23 5.2 79.6 14.9 57.4 24-Hour Avg. 133.7 94.6 Note: High wind hours highlighted in bold italics.

V - 83Table V-40 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Greenwood Monitor
Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 8.1 138.4 14.9 108.8 1 5.7 159.9 14.9 125.1 2 4.9 123.4 14.9 97.4 3 2.9 105.2 14.9 83.5 4 2.1 105.6 14.9 83.8 5 5.4 86.5 14.9 69.3 6 6.7 112.6 14.9 89.2 7 7.7 103.8 14.9 82.5 8 8.3 77.9 14.9 62.8 9 10.0 79.0 14.9 63.6 10 11.0 74.7 14.9 60.3 11 10.8 103.2 14.9 82.0 12 12.7 172.2 21.9 129.2 13 12.6 194.6 21.9 147.1 14 15.4 442.1 21.9 310.3 15 13.9 240.6 21.9 175.1 16 11.9 93.5 14.9 74.6 17 11.7 96.9 14.9 77.2 18 11.4 82.5 14.9 66.3 19 8.7 68.3 14.9 55.5 20 7.4 61.3 14.9 50.2 21 7.0 67.9 14.9 55.2 22 5.1 63.5 14.9 51.8 23 4.0 68.3 14.9 55.5 24-Hour Avg. 121.7 94.0 Note: High wind hours highlighted in bold italics.

V - 84Table V-41 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the Higley Monitor
Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 7.4 39.6 14.9 30.1 1 5.8 72.9 14.9 50.6 2 8.8 135.2 14.9 88.9 3 9.0 130.9 14.9 86.2 4 9.1 104.9 14.9 70.3 5 7.4 96.4 14.9 65.0 6 9.4 113.4 14.9 75.5 7 9.4 90.9 14.9 61.6 8 10.8 187.2 14.9 120.9 9 11.6 195.1 14.9 125.7 10 14.6 580.2 21.9 431.9 11 15.2 379.0 21.9 266.3 12 17.6 568.8 21.9 406.7 13 15.3 408.1 21.9 290.5 14 15.8 387.9 21.9 271.1 15 15.6 268.9 21.9 190.5 16 15.3 167.5 21.9 120.8 17 13.5 96.4 21.9 75.3 18 10.1 45.2 14.9 33.5 19 6.9 50.7 14.9 36.9 20 6.6 43.1 14.9 32.2 21 7.1 60.5 14.9 42.9 22 2.9 55.7 14.9 40.0 23 3.2 66.9 14.9 46.9 24-Hour Avg. 181.1 127.5 Note: High wind hours highlighted in bold italics.

V - 85Table V-42 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the State Super Site Monitor
Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 7.6 99.3 14.9 79.0 1 6.3 149.6 14.9 117.3 2 5.4 112.2 14.9 88.8 3 5.4 95.8 14.9 76.4 4 6.7 92.4 14.9 73.8 5 7.2 80.6 14.9 64.8 6 7.2 80.2 14.9 64.5 7 6.5 82.7 14.9 66.4 8 7.2 63.5 14.9 51.8 9 6.7 60.8 14.9 49.8 10 6.9 53.6 14.9 44.3 11 9.4 65.5 14.9 53.4 12 8.9 77.8 14.9 62.7 13 9.8 107.8 14.9 85.5 14 10.5 142.1 14.9 111.6 15 11.4 109.4 14.9 86.7 16 10.1 62.3 14.9 50.9 17 9.2 54.4 14.9 44.9 18 11.2 57.5 14.9 47.3 19 9.6 53.9 14.9 44.5 20 7.8 60.9 14.9 49.9 21 6.3 62.5 14.9 51.1 22 3.8 55.1 14.9 45.5 23 3.6 54.8 14.9 45.2 24-Hour Avg. 80.6 64.8

V - 86Table V-43 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West Phoenix Monitor
Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 7.1 134.4 14.9 105.7 1 7.8 164.9 14.9 128.9 2 8.4 123.8 14.9 97.7 3 4.2 106.1 14.9 84.2 4 5.1 99.1 14.9 78.9 5 6.1 84.4 14.9 67.7 6 8.5 94.4 14.9 75.3 7 10.3 102.9 14.9 81.8 8 8.7 75.2 14.9 60.7 9 8.6 70.3 14.9 57.0 10 8.8 62.1 14.9 50.8 11 12.1 122.2 21.9 99.7 12 13.6 169.6 21.9 130.8 13 15.1 256.6 21.9 192.2 14 15.1 259.8 21.9 193.6 15 13.5 132.1 21.9 102.9 16 12.0 88.2 14.9 70.6 17 11.7 71.9 14.9 58.2 18 10.0 66.7 14.9 54.3 19 9.3 65.1 14.9 53.1 20 9.1 66.7 14.9 54.3 21 6.8 67.3 14.9 54.7 22 5.3 62.6 14.9 51.2 23 4.8 63.7 14.9 52.0 24-Hour Avg. 108.8 85.7 Note: High wind hours highlighted in bold italics.

V - 87Table V-44 2012 Attainment Demonstration High Wind Design Day (June 6, 2007) at the West 43 rd Avenue Monitor
Hour Wind Speed (mph) June 6, 2007 PM-10 Concentration ( μ g/m 3 ) Background Concentration ( μ g/m 3 ) 2012 Controlled PM-10 Concentration ( μ g/m 3 ) 0 13.3 175.1 21.9 124.9 1 9.9 177.0 14.9 121.4 2 9.1 150.0 14.9 103.7 3 7.8 115.5 14.9 81.0 4 10.6 145.0 14.9 100.4 5 14.5 318.0 21.9 218.8 6 14.9 267.2 21.9 182.9 7 11.4 208.1 14.9 141.8 8 11.3 131.4 14.9 91.4 9 12.0 152.0 14.9 105.0 10 13.8 180.8 21.9 128.3 11 16.0 438.3 21.9 294.9 12 16.6 449.1 21.9 299.6 13 15.1 394.9 21.9 265.9 14 17.6 643.1 21.9 424.3 15 18.1 662.3 21.9 428.4 16 17.0 237.5 21.9 161.8 17 14.5 92.3 21.9 68.1 18 14.9 77.9 21.9 58.6 19 12.0 56.1 14.9 42.0 20 8.8 87.3 14.9 62.5 21 9.3 98.1 14.9 69.6 22 7.0 82.6 14.9 59.4 23 6.8 78.3 14.9 56.6 24-Hour Avg. 225.7 153.8 Note: High wind hours highlighted in bold italics.

V - 88

## APPENDIX B

EXHIBIT 2:

Calculation of Benefits from PM-10 Certified Street Sweepers Purchased with CMAQ Funds in 2001-2009CMAQ Funded PM-10 Certified Street Sweepers Purchased in 2001-2009Sweeper AADT Per Lane Lane Cycle Cycle Total Reduction Benefit with Month of Age in Usage# Agency Requesting Sweeper Lane MIles Old Miles New LenOld LenNew Replace Expand Incr Freq Process Reduction by Unit Usage Factor Purchase Dec-09 Factor1 Apache Junction 832 98 118 45 30 0.41 1.20 1.61 1.61 1.28 Mar-04 5.8 0.7954 Chandler 5,260 131 131 14 14 32.30 0.22 32.51 32.51 22.86 Nov-01 8.1 0.7036 Chandler 8,313 165 165 7 7 118.53 0.54 119.08 119.08 94.67 Aug-04 5.3 0.7958 El Mirage 1,469 129 108 30 15 -1.13 5.83 4.70 4.70 3.73 Jan-04 5.9 0.7959 Fort McDowell 1,500 21 21 30 30 0.69 0.02 0.71 0.71 0.52 Dec-01 8.0 0.73421 Litchfield Park 4,518 12 12 30 30 1.19 0.01 1.20 5.34 4.24 Jun-04 5.5 0.7952,259 23 28 14 14 2.44 0.89 0.05 3.37 Jun-04 5.5 0.795244 35 50 14 14 0.40 0.29 0.08 0.77 Jun-04 5.5 0.79523 Mesa 229 342 342 38 38 1.35 0.21 1.56 1.56 1.34 Oct-06 3.2 0.85724 Paradise Valley 10,000 20 20 90 30 1.46 4.90 0.02 6.37 15.41 10.83 Jul-01 8.4 0.7037,000 22.5 22.5 90 30 1.15 3.86 0.02 5.02 Jul-01 8.4 0.7033,000 18 18 90 45 0.39 0.66 0.01 1.06 Jul-01 8.4 0.7031,000 147 147 90 45 1.07 1.80 0.08 2.95 Jul-01 8.4 0.70326 Peoria 4,500 53.4 53.4 25 25 6.31 0.05 6.36 7.88 6.02 Nov-03 6.1 0.7641,000 18 18 35 35 0.34 0.01 0.35 Nov-03 6.1 0.764500 116.8 116.8 35 35 1.09 0.08 1.17 Nov-03 6.1 0.76427 Phoenix 4,205 302 302 21 14 33.33 33.33 33.33 23.43 Aug-01 8.3 0.70328 Phoenix 4,205 302 302 21 14 33.33 33.33 33.33 23.43 Aug-01 8.3 0.70329 Phoenix 4,205 302 302 21 14 33.33 33.33 33.33 23.43 Aug-01 8.3 0.70330 Phoenix 4,205 302 302 21 14 33.33 33.33 33.33 23.43 Aug-01 8.3 0.70331 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 47.72 Jun-04 5.5 0.79532 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 47.72 Jun-04 5.5 0.79533 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76434 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76435 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76436 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76437 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76438 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76439 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76440 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76441 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76442 Phoenix 4,205 302 302 14 14 59.52 0.50 60.02 60.02 45.86 Oct-03 6.2 0.76443 Scottsdale 8,450 49 49 7 7 35.78 0.16 35.94 37.45 26.33 Oct-01 8.2 0.703150 310 310 25 25 1.22 0.29 1.51 Oct-01 8.2 0.70344 Scottsdale 7,100 101 101 7 7 61.97 0.33 62.30 62.33 49.55 Sep-04 5.3 0.795350 4 4 42 42 0.02 0.00 0.02 Sep-04 5.3 0.79545 Scottsdale 7,000 73 73 7 7 44.16 0.24 44.40 46.54 37.00 Sep-04 5.3 0.7952,000 11 11 21 21 0.69 0.01 0.70 Sep-04 5.3 0.795350 240 240 42 42 1.31 0.13 1.44 Sep-04 5.3 0.79549 Tempe 6,600 111.75 111.75 21 5 23.05 94.15 0.51 117.71 133.09 97.69 Jul-02 7.4 0.7344,750 26.75 26.75 21 10 3.97 7.34 0.06 11.37 Jul-02 7.4 0.734800 153.75 153.75 21 21 3.84 0.17 4.01 Jul-02 7.4 0.73450 Tempe 6,600 111.75 111.75 21 5 23.05 94.15 0.51 117.71 133.09 105.81 Feb-04 5.8 0.7954,750 26.75 26.75 21 10 3.97 7.34 0.06 11.37 Feb-04 5.8 0.795800 153.75 153.75 21 21 3.84 0.17 4.01 Feb-04 5.8 0.79552 Youngtown 1,492 26 26 90 30 0.28 0.95 0.02 1.25 1.25 0.96 Oct-03 6.2 0.76453 Queen Creek 1,365 20 20 30 15 0.60 1.00 0.03 1.63 2.21 1.76 Nov-04 5.1 0.795910 6 6 30 15 0.12 0.20 0.01 0.33 Nov-04 5.1 0.79568 46 46 30 15 0.07 0.12 0.07 0.25 Nov-04 5.1 0.79554 Chandler 1,492 60 60 30 30 1.96 0.05 2.00 5.92 4.89 Jan-05 4.9 0.826291 548 548 30 30 3.49 0.42 3.91 Jan-05 4.9 0.82655 Glendale 5,706 175 175 12 12 54.60 0.34 54.94 64.60 51.35 Sep-04 5.3 0.795910 110 110 15 15 4.38 0.17 4.55 Sep-04 5.3 0.795PM-10 Emission Reductions (kg/day)1CMAQ Funded PM-10 Certified Street Sweepers Purchased in 2001-2009Sweeper AADT Per Lane Lane Cycle Cycle Total Reduction Benefit with Month of Age in Usage# Agency Requesting Sweeper Lane MIles Old Miles New LenOld LenNew Replace Expand Incr Freq Process Reduction by Unit Usage Factor Purchase Dec-09 FactorPM-10 Emission Reductions (kg/day)228 445 445 15 15 4.43 0.68 5.11 Sep-04 5.3 0.79556 Tempe 6,006 12 12 7 5 6.23 2.16 0.06 8.45 11.11 9.18 Apr-05 4.7 0.8264,323 6 6 10 10 1.70 0.01 1.72 Apr-05 4.7 0.826728 40 40 21 21 0.91 0.04 0.95 Apr-05 4.7 0.82658 Surprise 6,066 6 17 28 15 0.85 2.63 3.52 0.03 7.02 8.08 6.43 Jul-04 5.4 0.795218 6 43 28 15 0.03 0.32 0.32 0.07 0.74 Jul-04 5.4 0.79567 46 103 42 28 0.05 0.10 0.09 0.08 0.32 Jul-04 5.4 0.79559 Surprise 6,066 112 123 28 15 2.63 25.46 28.09 28.90 22.97 Jul-04 5.4 0.795218 7 44 28 15 0.32 0.33 0.65 Jul-04 5.4 0.79567 15 72 42 28 0.10 0.06 0.16 Jul-04 5.4 0.79560 Peoria 4,095 242 248 25 25 1.08 1.08 3.96 3.27 Dec-04 5.0 0.826910 91 111 30 30 0.67 0.67 Dec-04 5.0 0.826601 576 676 30 30 2.21 2.21 Dec-04 5.0 0.82661 Buckeye 3,640 6 6 7 7 1.89 0.02 1.91 3.04 2.42 Aug-04 5.3 0.795776 10 10 7 7 0.67 0.03 0.70 Aug-04 5.3 0.795194 40 40 14 14 0.36 0.07 0.43 Aug-04 5.3 0.79562 Gila River IC 6,825 6 6 7 7 3.54 0.02 3.56 4.56 3.77 Aug-05 4.3 0.826444 24 24 7 7 0.92 0.08 1.00 Aug-05 4.3 0.82663 Gila River IC 2,730 4 4 7 7 0.94 0.01 0.96 1.19 0.98 Aug-05 4.3 0.826228 10 10 7 7 0.20 0.03 0.23 Aug-05 4.3 0.82664 Gila River IC 3,640 16 16 25 14 2.02 2.02 2.54 2.10 Aug-05 4.3 0.826375 40 40 25 14 0.52 0.52 Aug-05 4.3 0.82665 Gila River IC 228 4 4 25 14 0.03 0.03 0.15 0.13 Aug-05 4.3 0.826118 30 30 25 14 0.12 0.12 Aug-05 4.3 0.82666 El Mirage 3,550 4 11 30 10 0.91 2.87 3.78 6.42 5.30 Jan-05 4.9 0.8261,755 12 12 30 12 1.16 1.16 Jan-05 4.9 0.826910 44 44 30 15 1.47 1.47 Jan-05 4.9 0.82667 Phoenix 4,205 302 302 21 14 33.33 33.33 66.66 55.06 Feb-05 4.8 0.8264,205 302 302 21 14 33.33 33.33 Feb-05 4.8 0.82668 Phoenix 4,205 302 302 21 14 33.33 33.33 66.66 55.06 Feb-05 4.8 0.8264,205 302 302 21 14 33.33 33.33 Feb-05 4.8 0.82669 Tempe - Arterials 6,006 12 12 12 12 3.94 0.02 3.96 6.63 5.69 Mar-06 3.8 0.857Tempe - Collectors 4,323 6 6 10 10 1.70 0.01 1.72 Mar-06 3.8 0.857Tempe - Res Streets 728 40 40 21 21 0.91 0.04 0.95 Mar-06 3.8 0.85770 Chandler - Collectors 898 46 46 30 30 0.90 0.04 0.94 2.22 1.90 Mar-06 3.8 0.857Chandler - Res Streets 106 414 414 30 30 0.96 0.32 1.28 Mar-06 3.8 0.85771 Chandler - Collectors 1,356 43 43 30 30 1.28 0.03 1.31 3.37 2.89 Mar-06 3.8 0.857Chandler - Res Streets 208 387 387 30 30 1.76 0.30 2.06 Mar-06 3.8 0.85772 Apache Junction - Arterials 3,458 28.25 28.25 20 20 3.21 0.03 3.24 4.16 3.56 Mar-06 3.8 0.857Apache Junction - Collectors 496 10.75 10.75 20 20 0.17 0.01 0.19 Mar-06 3.8 0.857Apache Junction - Res Streets 137 61.5 61.5 20 20 0.28 0.07 0.35 Mar-06 3.8 0.857Apache Junction - Other mid sect 1,274 9 9 20 20 0.38 0.01 0.39 Mar-06 3.8 0.85773 Queen Creek - Arterials 1,365 0 9.7 15 15 0.97 0.97 1.46 1.25 Jan-06 3.9 0.857Queen Creek - Collectors 455 0 6.8 15 15 0.23 0.23 Jan-06 3.9 0.857Queen Creek - Res Streets 228 0 31.3 30 30 0.26 0.26 Jan-06 3.9 0.85774 Phoenix - Arterials 4,488 450 450 14 7 144.23 144.23 221.40 189.74 Mar-06 3.8 0.857Phoenix - Collector/Res Streets 2,401 450 450 14 7 77.17 77.17 Mar-06 3.8 0.85775 Phoenix - Arterials 4,488 450 450 14 7 144.23 144.23 221.40 189.74 Mar-06 3.8 0.857Phoenix - Collector/Res Streets 2,401 450 450 14 7 77.17 77.17 Mar-06 3.8 0.85776 Scottsdale - Arterials 3,185 0 260 30 30 30.43 30.43 30.43 27.02 Dec-06 3.0 0.88877 Fountain Hills- Arterials 4,550 85 85 15 15 16.92 0.13 17.05 25.80 22.11 Dec-05 4.0 0.857Fountain Hills - Collectors 1,820 140 140 45 30 3.72 3.12 0.11 6.94 Dec-05 4.0 0.857Fountain Hills - Res Streets 273 350 350 60 45 1.05 0.59 0.18 1.81 Dec-05 4.0 0.8572CMAQ Funded PM-10 Certified Street Sweepers Purchased in 2001-2009Sweeper AADT Per Lane Lane Cycle Cycle Total Reduction Benefit with Month of Age in Usage# Agency Requesting Sweeper Lane MIles Old Miles New LenOld LenNew Replace Expand Incr Freq Process Reduction by Unit Usage Factor Purchase Dec-09 FactorPM-10 Emission Reductions (kg/day)79 Gilbert - Arterials - 9,087 269 506 15 15 158.28 158.28 238.43 34.06 Feb-08 1.8 0.143Gilbert - Collector/Res Streets 2,730 0 799 30 30 80.15 80.15 Feb-08 1.8 0.14380 Gilbert - Arterials 9,087 269 506 15 15 158.28 158.28 238.43 34.06 Feb-08 1.8 0.143Gilbert - Collector/Res Streets 2,730 0 799 30 30 80.15 80.15 Feb-08 1.8 0.14381 Buckeye - Arterials 1,593 0 24 7 7 5.74 5.74 5.74 4.92 Mar-06 3.8 0.85782 ADOT - Freeway 30,030 175 250 14 7 55.74 168.50 224.23 301.18 248.77 Jun-05 4.5 0.826ADOT - Other Frontage Roads 7,818 375 500 14 14 76.95 76.95 Jun-05 4.5 0.82683 ADOT - Freeway 30,030 175 250 14 7 55.74 168.50 224.23 301.18 248.77 Jun-05 4.5 0.826ADOT - Other Frontage Roads 7,818 375 500 14 14 76.95 76.95 Jun-05 4.5 0.82684 Surprise- Arterials 8,964 120 120 20 15 19.76 19.76 20.15 16.65 Oct-05 4.2 0.826Surprise- Collectors 198 16 40 28 20 0.19 0.12 0.31 Oct-05 4.2 0.826Surprise - Res Streets 61 36 67 120 45 0.02 0.06 0.08 Oct-05 4.2 0.82685 Guadalupe - Collectors 5,678 5 5 1 1 0.00 0.52 0.44 Nov-06 3.1 0.857Guadalupe - Res Streets 578 25 25 4 2 0.52 0.52 Nov-06 3.1 0.85786 Williams Gateway- Arterials 410 12 12 14 5 0.50 0.50 0.50 0.43 Apr-06 3.7 0.85787 Mesa - Collectors 1,759 35 35 40 40 1.01 0.02 1.03 1.86 1.59 Oct-06 3.2 0.857Mesa - Res Streets 200 215 215 40 40 0.71 0.12 0.83 Oct-06 3.2 0.85788 Mesa - Collectors 1,759 35 35 40 40 1.01 0.02 1.03 1.86 1.59 Oct-06 3.2 0.857Mesa - Res Streets 200 215 215 40 40 0.71 0.12 0.83 Oct-06 3.2 0.85789 Avondale - Collectors 4,550 44 44 7 7 17.30 0.14 17.45 27.85 23.00 Aug-05 4.3 0.826Avondale - Res Streets 910 127 127 7 7 9.99 0.42 10.40 Aug-05 4.3 0.82690 Chandler Airport - Arterials 523 4 4 5 5 0.20 0.02 0.21 2.61 2.24 Mar-06 3.8 0.857Chandler Airport - Collectors 91 1 1 5 5 0.01 0.00 0.01 Mar-06 3.8 0.857Chandler Airport - Other 683 35 35 5 5 2.23 0.16 2.39 Mar-06 3.8 0.85791 Goodyear - Arterials 3,185 176 176 14 14 26.27 0.29 26.56 30.52 26.15 Dec-05 4.0 0.857Goodyear - Collectors 601 84 84 14 14 2.36 0.14 2.50 Dec-05 4.0 0.857Goodyear - Res Streets 218 122 122 14 14 1.25 0.20 1.45 Dec-05 4.0 0.85792 Goodyear - Arterials - 2005 3,185 176 176 14 14 26.27 0.29 26.56 30.52 26.15 Dec-05 4.0 0.857Goodyear - Collectors 601 84 84 14 14 2.36 0.14 2.50 Dec-05 4.0 0.857Goodyear - Res Streets 218 122 122 14 14 1.25 0.20 1.45 Dec-05 4.0 0.85793 Gilbert - Arterials 6,104 679 679 15 15 181.32 1.04 182.36 236.73 33.82 Oct-05 4.2 0.143Gilbert - Collectors 3,000 70 70 20 20 6.89 0.08 6.97 Oct-05 4.2 0.143Gilbert - Res Streets 3,000 714 714 30 30 46.85 0.55 47.40 Oct-05 4.2 0.14394 Gilbert - Arterials 6,982 697 697 15 15 212.90 1.07 213.97 268.34 38.33 Oct-05 4.2 0.143Gilbert - Collectors 3,000 70 70 20 20 6.89 0.08 6.97 Oct-05 4.2 0.143Gilbert - Res Streets 3,000 714 714 30 30 46.85 0.55 47.40 Oct-05 4.2 0.14395 Gilbert - Arterials 5,954 697 697 15 15 181.55 1.07 182.62 236.99 33.86 Oct-05 4.2 0.143Gilbert - Collectors 3,000 70 70 20 20 6.89 0.08 6.97 Oct-05 4.2 0.143Gilbert - Res Streets 3,000 714 714 30 30 46.85 0.55 47.40 Oct-05 4.2 0.14396 Phoenix - Arterials 5,918 465 465 10 10 142.52 142.52 227.87 0.00 Jun-06 3.5 0.000Phoenix - Collector/Res Streets 3,167 460 460 14 14 85.36 85.36 Jun-06 3.5 0.00097 Phoenix - Arterials 5,918 465 465 10 10 142.52 142.52 205.40 0.00 Sep-07 2.3 0.000Phoenix - Collector/Res Streets 3,167 460 460 7 7 62.89 62.89 Sep-07 2.3 0.000100 Surprise - Arterials 10,000 54 54 20 3 85.52 85.52 85.52 73.29 Dec-05 4.0 0.857101 Tempe - Arterials 6,600 48 48 12 6 23.11 23.11 33.73 32.05 Aug-09 0.3 0.950Tempe - Collectors 4,750 32 32 10 5 10.63 10.63 Aug-09 0.3 0.950102 Goodyear - Arterials 3,750 234 234 30 14 36.85 36.85 36.85 32.72 Sep-07 2.3 0.888Goodyear - Collectors 675 114 114 14 14 0.00 0.00 Sep-07 2.3 0.888Goodyear - Res Streets 240 130 130 14 14 0.00 0.00 Sep-07 2.3 0.888103 Tolleson - Collectors 1,500 26 26 14 7 1.83 2.79 0.09 4.70 5.55 4.93 May-07 2.6 0.888Tolleson - Res Streets 250 26 26 14 7 0.30 0.46 0.09 0.85 May-07 2.6 0.888104 Mesa - Collectors 1,759 40 40 52 43 0.31 0.31 0.49 0.45 May-08 1.6 0.919Mesa - Res Streets 182 215 215 52 43 0.17 0.17 May-08 1.6 0.9193CMAQ Funded PM-10 Certified Street Sweepers Purchased in 2001-2009Sweeper AADT Per Lane Lane Cycle Cycle Total Reduction Benefit with Month of Age in Usage# Agency Requesting Sweeper Lane MIles Old Miles New LenOld LenNew Replace Expand Incr Freq Process Reduction by Unit Usage Factor Purchase Dec-09 FactorPM-10 Emission Reductions (kg/day)Mesa - Other (Alleys) 109 5 5 52 43 0.00 0.00 May-08 1.6 0.919105 Mesa Falcon Field - Arterials 1,320 7 7 7 7 0.80 0.02 0.82 0.82 0.73 Nov-07 2.1 0.888106 Litchfield Park - Arterials 4,111 12 16 30 21 0.60 1.04 1.64 4.07 3.62 Nov-07 2.1 0.888Litchfield Park - Collectors 2,056 23 25 14 10 0.32 1.62 1.94 Nov-07 2.1 0.888Litchfield Park - Res Streets 222 35 45 14 10 0.17 0.31 0.49 Nov-07 2.1 0.888107 Buckeye - Arterials 546 0 62 7 7 5.08 5.08 5.57 4.95 Sep-07 2.3 0.888Buckeye - Collectors 273 0 4 7 7 0.16 0.16 Sep-07 2.3 0.888Buckeye - Res Streets 27 0 80 7 7 0.33 0.33 Sep-07 2.3 0.888108 Surprise - Arterials 2,093 48 48 16 7 8.16 8.16 8.97 7.96 Aug-07 2.3 0.888Surprise - Collectors 1,638 24 24 5 5 0.00 Aug-07 2.3 0.888Surprise - Res Streets 455 0 48 30 30 0.80 0.80 Aug-07 2.3 0.888109 Queen Creek - Arterials 4,550 15 51 15 7 12.04 17.79 29.83 31.88 28.31 May-07 2.6 0.888Queen Creek - Collectors 2,730 0 5 15 7 1.00 1.05 2.05 May-07 2.6 0.888110 Gilbert - Arterials 4,572 256 256 15 15 51.20 0.39 51.59 85.82 12.26 Feb-08 1.8 0.143Gilbert - Collectors 2,275 300 300 15 15 29.86 0.46 30.32 Feb-08 1.8 0.143Gilbert - Res Streets 228 340 340 15 15 3.38 0.52 3.91 Feb-08 1.8 0.143111 Gilbert - Arterials 4,576 256 256 15 15 51.25 0.39 51.65 85.87 12.27 Feb-08 1.8 0.143Gilbert - Collectors 2,275 300 300 15 15 29.86 0.46 30.32 Feb-08 1.8 0.143Gilbert - Res Streets 228 340 340 15 15 3.38 0.52 3.91 Feb-08 1.8 0.143112 Chandler - Arterials 5,098 0 34.5 30 30 6.46 6.46 6.46 5.74 Jun-07 2.5 0.888113 Cave Creek - Arterials 3,731 0 10 180 14 0.23 2.71 2.94 22.69 20.15 Jan-07 2.9 0.888Cave Creek - Collectors 1,593 0 20 180 30 0.20 0.98 1.17 Jan-07 2.9 0.888Cave Creek - Res Streets 228 0 25 180 60 0.03 0.07 0.10 Jan-07 2.9 0.888Cave Creek - Major Intersection 7,963 0 10 180 2 0.49 17.99 18.48 Jan-07 2.9 0.888114 Goodyear - Collectors 655 65 65 21 14 1.12 1.12 1.73 1.59 Jan-08 1.9 0.919Goodyear - Res Streets 237 99 99 21 14 0.61 0.61 Jan-08 1.9 0.919115 Fountain Hills - Arterials 4,550 85 85 15 15 16.92 0.13 17.05 31.59 28.06 Sep-07 2.3 0.888Fountain Hills - Collectors 1,820 140 140 45 30 3.72 3.12 0.11 6.94 Sep-07 2.3 0.888Fountain Hills - Res Streets 273 350 350 60 45 1.05 0.59 0.18 1.81 Sep-07 2.3 0.888Fountain Hills - Downtown 2,730 15 15 45 7 0.60 5.15 0.05 5.79 Sep-07 2.3 0.888120 Chandler - Arterials 7,745 66 66 14 14 29.95 29.95 32.83 0.00 Jul-08 1.4 0.000Chandler - Collectors 1,201 15 15 30 30 1.22 1.22 Jul-08 1.4 0.000Chandler - Other 6,120 4 4 30 30 1.66 1.66 Jul-08 1.4 0.000121 Surprise - Arterials 6,461 0 31 15 15 14.72 14.72 26.71 24.55 Mar-08 1.8 0.919Surprise - Collectors 3,185 0 37 15 15 8.66 8.66 Mar-08 1.8 0.919Surprise - Res Streets 546 0 166 30 30 3.33 3.33 Mar-08 1.8 0.919122 Avondale - Arterials 8,190 91 97 7 7 7.38 7.38 9.10 8.36 Jul-08 1.4 0.919Avondale - Collectors 1,820 41 43 14 14 0.29 0.29 Jul-08 1.4 0.919Avondale - Res Streets 910 244 264 14 14 1.43 1.43 Jul-08 1.4 0.919123 Queen Creek - Arterials 3,640 29 46 15 7 4.55 12.84 17.38 17.46 16.58 Dec-08 1.0 0.950Queen Creek - Res Streets 68 29 58 30 30 0.07 0.07 Dec-08 1.0 0.950126 Mesa - Collectors 1,759 42 44 43 40 0.09 0.15 0.24 0.37 0.35 May-09 0.6 0.950Mesa - Res Streets 182 225 235 43 40 0.05 0.08 0.13 May-09 0.6 0.950Mesa - Other 109 5 5 43 40 0.00 0.00 May-09 0.6 0.950127 Paradise Valley - Arterials 6,825 18 18 15 15 0.00 0.00 0.29 0.28 Feb-09 0.8 0.950Paradise Valley - Collectors 364 15 15 35 28 0.04 0.04 Feb-09 0.8 0.950Paradise Valley- Res Streets 319 100 100 35 28 0.25 0.25 Feb-09 0.8 0.950131 Maricopa County - Arterials 364 0 534 14 14 15.31 15.31 24.51 23.28 Jun-09 0.5 0.950Maricopa County - Res Streets 364 0 367 16 16 9.20 9.20 Jun-09 0.5 0.950132 Maricopa County - Arterials 364 0 534 14 14 15.31 15.31 24.51 23.28 Jun-09 0.5 0.950Maricopa County - Res Streets 364 0 367 16 16 9.20 9.20 Jun-09 0.5 0.950133 ASU - Res Streets 2,527 17 29.32 1 1 4.76 7.86 0.67 13.29 21.25 20.19 Apr-09 0.7 0.950ASU - Pedestrian Paths 4,095 10.04 13.04 1 1 4.55 3.10 0.30 7.96 Apr-09 0.7 0.9504CMAQ Funded PM-10 Certified Street Sweepers Purchased in 2001-2009Sweeper AADT Per Lane Lane Cycle Cycle Total Reduction Benefit with Month of Age in Usage# Agency Requesting Sweeper Lane MIles Old Miles New LenOld LenNew Replace Expand Incr Freq Process Reduction by Unit Usage Factor Purchase Dec-09 FactorPM-10 Emission Reductions (kg/day)145 Scottsdale - Arterials 5,897 44 44 7 7 20.84 20.84 41.47 0.00 Apr-09 0.7 0.000Scottsdale - Collectors 3,898 62 62 7 7 19.41 19.41 Apr-09 0.7 0.000Scottsdale - Res Streets 91 108 108 25 25 1.21 1.21 Apr-09 0.7 0.000Total purchased through December 31, 2009 2,756.22 919.95 1,570.24 25.35 5,271.77 5,271.77 2,939.89 kg/day 1,182.83 tons/yrSweepers purchased 1/1/01-12/31/062,559.12kg/day 1,029.63 tons/yrSweepers purchased 1/1/07-12/31/09380.77kg/day 153.20 tons/yrNotes:(1) Missing sweeper #s in column A represent units that were purchased with CMAQ funds, but were no longer in service as of December 31, 2009(2) EFs are based on the Jan 2011 AP-42 Paved Road equation; EFs for Arterials <10,000 ADT (0.71 g/mi) and >10,000 ADT (0.23 g/mi) were weighted by 2008 VMT to obtain 0.35 g/mi for all arterials(3) If Benefits with Usage Factor = 0.00, the sweeper is replacing an older PM-10 certified sweeper and no credit is taken5

## APPENDIX C

## APPENDIX C

EXHIBIT 1:

Arizona Revised Statutes Listed in Table 4-1ARIZONA REVISED STATUTES LISTED IN TABLE 4-1
9-500.04. Air quality control; definitions A. The governing body of a city or town in area A or area B as defined in section 49-541 shall: 3. In area A, beginning on January 1, 2008, develop and implement plans to stabilize targeted unpaved roads, alleys and unpaved shoulders on targeted arterials. The plans shall address the performance goals, the cr iteria for targeting the roads, alleys and shoulders, a schedule for implementation, funding options and reporting requirements. priority shall be given to the following: (a) Unpaved roads with more than one hundred average daily trips. (b) Unpaved shoulders on arterial roads and other road segments where vehicle use on unpaved shoulders is evident or antic ipated due to projected traffic volume. 5. In area A, in order to reduce particulate matter in ambient air: (a) Beginning March 31, 2008, on any high pollution advisory day forecast by the department of environmental quality prohibit employees or cont ractors of that city or town from operating leaf blowers except while in vacuum mode and prohibit those employees or contractors from blowing landscape debr is into public roadways at any time. (b) No later than March 31, 2008, adop t, implement and enfor ce an ordinance that bans the blowing of landscape debris into public roadways at any time by any person. 6. In area A, no later than March 31, 2008, adopt or amend codes or ordinances and, no later than October 1, 2008, commence enforcement of thos e codes or ordinances as necessary to require that parking, maneuvering, ingress and egress areas at developments other than residentia l buildings with four or fe wer units are maintained with one or more of the following dustproof paving methods: (a) Asphaltic concrete. (b) Cement concrete. (c) Penetration treatment of bituminous ma terial and seal coat of bituminous binder and a mineral aggregate. (d) A stabilization method approved by the city or town. 7. In area A, no later than March 31, 2008, adopt or amend codes or ordinances and, no later than October 1, 2009, commence enforcement of thos e codes or ordinances as necessary to require that parking, maneuvering, ingress and egress areas that are three thousand square feet or more in size at resi dential buildings with four or fewer units are maintained with a paving or stabilization method authorized by the city or town by code, ordinance or permit. 8. In area A, no later than March 31, 2008, adopt or amend codes or ordinances as necessary to restrict vehicle parking and use on unpaved or unstabilized vacant lots. 9. In area A, no later than March 31, 2008, require that new or renewed contracts for street sweeping on city st reets must be conducted with st reet sweepers that meet the south coast air quality management district rule 1186 street sweeper certification specifications for pick up efficiency and PM-10 emissions in effect on January 1, 2007. H. Subsection A, paragraphs 5 through 8 of this section do not apply to any site that
1has a permit issued by a control officer as defined in section 49-471 for the control of fugitive dust from dust generating operations. 9-500.27. Off-road vehicle ordinance; app licability; violation; classification A. No later than March 31, 2008, in area A, as defined in section 49-541, a city or town shall adopt, implement and enforce an ordi nance that prohibits the operation of any vehicle, including an off-highway vehicle, an a ll-terrain vehicle or an off-road recreational motor vehicle, on an unpaved surface that is not a public or private r oad, street or lawful easement and that is closed by the landowner by rule or regul ation of a federal agency, this state, a county or a municipality or by proper posting if the land is private land. B. This section does not apply to the operation of vehicles used in the normal course of business or the normal course of government operations. C. This section does not prohibit or preempt the enforceme nt of any similar ordinance that is adopted by a city or town in area A, as defined in section 49-541, before March 31, 2008 for purposes of dust abatement. D. A person who violates an ordinance adopted pursuant to subsection A of this section is guilty of a class 3 misdemeanor. E. In addition to or in lieu of a fine purs uant to this section, a judge may order the person to perform at least eight but not more than twenty-four hours of community restitution or to complete an approved safety course related to the off-highway operation of motor vehicles, or both. 11-871. Emissions control; no burn; exemptions; penalty A. A county that contains any part of ar ea A, as defined in section 49-541, shall develop, implement, and enforce in area A, as defined in section 49-541, an ordinance relating to residential wood burning restrict ions, including a no burn restriction when monitoring or forecasting by the department of environmental quality predicts the carbon monoxide standard is likely to be exceeded. B. On or before October 31, 2007, a count y that contains any part of area A, as defined in section 49-541, shall amend the or dinance prescribed by subsection A of this section to include a no burn restriction for any high pollution advisory day forecast by the department of environmental quality for particulate matter. D. The ordinance shall provide that a person who violates an ordinance adopted pursuant to this section is subject to: 4. The imposition of a civil penalty of tw o hundred fifty dollars for the fourth or any subsequent violation. 11-877. Air quality control measures A. In order to reduce particulate matter in ambient air, the board of supervisors of any county that contains any portion of area A, as defined in section 49-541, shall develop, implement and enforce in area A the fo llowing air quality control measures: 1. Beginning on the effective date of this section, prohibi t employees or contractors of that county from operating leaf blowers on any high pollution advisory day forecast by the department of envir onmental quality except while in vacuum mode and prohibit those employees or contractors from blowing landscape debris into public roadways at any time. 2. No later than March 31, 2008, adopt, implement and enforce an ordinance that bans the blowing of landscape debris into public roadways at any time by any person. 3. No later than March 31, 2008, adopt, implement and enforce an ordinance that
2prohibits the operation of leaf blowers except on surfaces that have been stabilized with asphaltic concrete, cement concrete, hard scape, penetration treatment of bituminous material and seal coat of bituminous bi nder and a mineral aggregat e, decomposed granite cover, crushed granite cover, aggregate cover, gravel cover, or grass or other continuous vegetative cover, or any comb ination of those stabilizers. B. This section does not apply to any si te that has a permit issued by a control officer as defined in section 49-471 for the c ontrol of fugitive dust from dust generating operations. 28-1098. Vehicle loads; restrictions; civil penalties A. For the purpose of highway safety or air pollution prevention, a person shall not drive or move a vehicle on a highway unless the vehicle is constructed or loaded in a manner to prevent any of its load from dropping, sifting, leak ing or otherwise escaping from the vehicle, except the following are permitted: 1. Sufficient sand may be dropped for the purpose of securing traction. 2. Water or another substance may be sprinkled on a roadway in cleaning or maintaining the roadway. 3. Minor pieces of agricultural materials such as leaves and stems from agricultural loads. C. If a person is found in violati on of this section and the violation: 1. Does not cause any damage or injury and is the person's: (a) First violation in a sixty month period, the person is subjec t to a civil penalty of not more than two hundred fifty dollars. (b) Second or subsequent violation in a sixty month period, the person is subject to a civil penalty of not more than three hundred fifty dollars. 49-424. Duties of department The department shall: 11. Develop and disseminate air quality dust forecasts for the Maricopa county PM-10 nonattainment area. Each forecast shall identify a low, moderat e or high risk of dust generation for the next five consecutive days and shall be issued by noon on each day the forecast is generated. At a minimum, the forecasts shall be posted on the department's website and distributed electronically. When developing these forecasts, the department shall consider all of the following: (a) Projected meteorological conditions fo r the Maricopa county area, including all of the following: (i) Wind speed and direction. (ii) Stagnation. (iii) Recent precipitation. (iv) Potential for precipitation. (b) Existing concentrations of air po llution at the time of the forecast. (c) Historic air pollution concentrations that have been observed during meteorological conditions similar to those t hat are predicted to occur in the forecast. 49-457.01. Leaf blower use re strictions and training; leaf blower equipment sellers; informational material; outreach; applicability A. This section applies in a county with a population of two m illion or more persons or any portion of a county within an area des ignated by the environmental protection
3agency as a serious PM-10 nonattainment area or a maintenance area that was designated as a serious PM-10 nonattainment area. B. After March 31, 2008, no person may use a leaf blower to blow landscape debris into public roadways. C. After March 31, 2008, no person may oper ate a leaf blower except on surfaces that have been stabilized with asphaltic concrete , cement concrete, hardscape, penetration treatment of bituminous material and seal coat of bituminous binder and a mineral aggregate, decomposed granite cover, crushed granite cover, aggregate cover, gravel cover, or grass or other continuous vegetat ive cover, or any combination of those stabilizers. D. At least once every three years, any person operating a leaf blower for remuneration shall successfully complete training approved by the department on how to operate a leaf blower in a manner designed to minimize the generation of fugitive dust emissions. Any person who is required to be trained under this subsection shall complete initial training no later than December 31, 2008. E. Any person who rents orsells in the normal course of business equipment that is used for blowing landscape debris shall provi de to the buyer or r enter of the equipment printed materials that are approved by the department pursuant to this section. F. The department shall produce printed materials and distribute those materials to persons who sell or rent equipment used for blowing landscape deb ris. The printed materials shall be designed to educate and info rm the user of the equipment on the safe and efficient use of the equipment, including me thods for reducing the generation of dust, and shall include information regarding dust contro l ordinances and restrictions that may be applicable. G. This section does not apply to any si te that has a permit issued by a control officer as defined in section 49-471 for the c ontrol of fugitive dust from dust generating operations. 49-457.03. Off-road vehicles; pollution advisory days; applicability; penalties A. In area A, as defi ned in section 49-541, a person shall not operate an off-highway vehicle, an all-terrain vehicle oran off-road recreational motor vehicle on an unpaved surface that is not a pub lic or private road, street or lawful easement during any high pollution advisory day forecast for particulate matter by the department. B. This section does not apply to: 1. An event that is intended for off-highwayvehicles, all-terrain vehicles or off-road recreational motor vehicles and that is endor sed, authorized, permitt ed or sponsored by a public agency, that occurs on a designated rout e or area and that in cludes dust abatement measures at all staging areas , parking areas and entrances. 2. An event that occurs at a facility fo r which an admission or user fee is charged and that includes dust abatement measures. 3. A closed course that is ma intained with dust abatement measures. 4. An off-highway vehicle, all-terrain v ehicle or off-road recreational motor vehicle used in the normal course of business or the normal course of government operations. 5. Golf carts that are used as part of a private or public golf course operation. C. A person who violates this section is subject to: 1. A warning for the first violation.
42. The imposition of a civil penalty of fifty dollars for the second violation. 3. The imposition of a civil penalty of one hundred dollars for the third violation. 4. The imposition of a civil penalty of tw o hundred fifty dollars for the fourth or any subsequent violation. D. For violations of this se ction, the control officer or other enforcement officer shall use a uniform civil ticket and complaint substant ially similar to a uniform traffic ticket and complaint prescribed by the ru les of procedure in civil tra ffic cases adopted by the supreme court. The control officer or other enforcem ent officer may issue ci tations to persons in violation of this section. 49-457.04. Off-highway vehicle and all- terrain vehicle dealers; informational material; outreach; applicability A. Any person who rents or sells in t he normal course of business off-highway vehicles, all-terrain vehicles or off-road re creational motor vehicles, other than golf carts sold to public or private golf c ourses, shall provide to the buy er or renter of the vehicle printed materials that are approved by the department pursuant to this section. B. The department shall produce printed ma terials and distribute those materials to persons who sell or rent off-highway vehicl es, all-terrain vehicles or off-road recreational motor vehicles. The print ed materials shall be designed to educate and inform the user of the vehicle on methods for reducing the generat ion of dust and shall include information regarding dust control ordinances and restricti ons that may be applicable. The department shall make available on the department’s websit e the printed materials in a format that is accessible to the public. C. This section applies in a county with a population of two million or more persons or any portion of a county in an area desi gnated by the environmental protection agency as a serious PM-10 nonattainment area or a maintenance area that was designated as a serious PM-10 nonattainment area. 49-457.05. Dust action general permit; best management practices; applicability; definitions A. This section applies in a county with a population of two million or more persons or any portion of a county within an area designated by the environmental protection agency as a serious PM-10 nonattainment area or a maintenance area that was designated as a serious PM-10 nonattainment area. B. The director shall issue a dust action general permit for regulated activities, which shall specify the best management practices nec essary to reduce or to prevent PM-10 particulate emissions as soon as practicable before and during a day that is forecast to be at high risk of dust generation under a fore cast issued by the department pursuant to section 49-424. C. A person that has a permit issued by t he director or a control officer for the control of fugitive dust from dust-generating operations is not required to obtain a dust action general permit under subsection D of this section, except that the person shall implement the control measures required in the permit issued by the director or control officer, including those measures related to wind, to reduce orto prevent PM-10 particulate emissions as soon as practicabl e before and during a day that is forecast to be at high risk of dust generation under a foreca st issued by the department pursuant to section 49-424. Failure to implement a control measure under this subsection shall only be enforced by the
5director or control officer that issued the pe rmit. The director or control officer shall not recover penalties for violati ons of both this subsection and the permit based on the same act or omission. D. A dust action general permit may be required for any person that owns or conducts a dust-generating operation that is found by the directorto have failed to choose and implement an applicable best management prac tice listed in the dust action general permit as soon as practicable before and during a day that is forecast to be at high risk of dust generation. I. For the purposes of this section: 1. "Applicable implementati on plan" means that term as defined in 42 United States Code section 7602(q). 2. "Best management practices" means tec hniques that are verified by scientific research and that on a case-by-case basis are practical, economically feasible and effective in reducing PM-10 particulate emissions from a regulated activity. 3. "Control officer" has the same meaning prescribed in section 49-471. 4. "Disturbed surface area" means a portion of the earth's surface or material that is placed on the earth's surf ace that has been physically mo ved, uncovered, destabilized or otherwise modified from its undisturbed native condition if t he potential for the emission of fugitive dust is increased by the mo vement, destabilization or modification. 5. "Dust-generating operation" means di sturbed surface areas, including those of open areas or vacant lots that are not defined as agricultu ral land and are not used for agricultural purposes according to secti ons 42-12151 and 42-12152, or any other area or activity capable of generating fugitive dust, including the following: (a) Land clearing, maintenance and land clean up using mechanized equipment. (b) Earthmoving. (c) Weed abatement by discing or blading. (d) Excavating. (e) Construction. (f) Demolition. (g) Bulk material handling, including haul ing, transporting, stacking, loading and unloading operations. (h) Storage or transporting operat ions, including storage piles. (i) Operation of outdoor equipment. (j) Operation of motorized machinery. (k) Establishing or using staging areas , parking areas, material storage areas or access routes. (l) Establishing or using unpaved haul or access roads. (m) Installing initial landscapes using mechanized equipment. 6. "Fugitive dust" means particulate matte r that could not reasonably pass through a stack, chimney, vent or ot her functionally equivalent opening, that can be entrained in the ambient air and that is caused by human or nat ural activities, including the movement of soil, vehicles, equipment, blasting and wind. Fugitive dust does not include particulate matter emitted directly from the exhaust of mo tor vehicles and other internal combustion engines, from portable brazing, soldering orwelding equipment or from pile drivers. 7. "Regulated activity" means all dust-generating operations except for the following:
6(a) Normal farm cultural practices as prescribed in section 49-504, paragraph 4 or section 49-457. (b) Emergency activities that may dist urb the soil and that are conducted by any utility or government agency in orderto prevent public injury or to restore critical utilities to a functional status. (c) Establishment of initial landscapes without the use of mechanized equipment, conducting landscape maintenance without the us e of mechanized equipment and playing on or maintaining a field used for nonmotorized spor ts, except that these activities shall not include grading or trenching performed to establis h initial landscapes or to redesign existing landscapes. (d) Rooftop operations for cutting, drilling, grinding or coring roofing tile if that activity is occurring on a pitched roof. 49-474.01. Additional board duties in vehi cle emissions control areas; definitions A. The board of supervisors of a county which contains any portion of area A or area B as defined in section 49-541 shall: 4. In area A, beginning J anuary 1, 2008, develop and implement plans to stabilize targeted unpaved roads, alleys and unpaved shoulder s on targeted arterials. The plans shall address the performance goals, the criteria for ta rgeting the roads, alleys and shoulders, a schedule for im plementation, funding options and reporting requirements. Priority shall be given to the following: (a) Unpaved roads with more than one hundred average daily trips. (b) Unpaved shoulders on arterial roads and other road segments where vehicle use on unpaved shoulders is evident or antic ipated due to projected traffic volume. 5. In a county with a population of two m illion or more persons or any portion of a county in an area designated by the environment al protection agency as a serious PM-10 nonattainment area or a maintenance area t hat was designated as a serious PM-10 nonattainment area, no later than March 31, 2008, adopt or amend codes or ordinances and, no later than October 1, 2008, commence enforcement of thos e codes or ordinances as necessary to require that parking, maneuvering, ingress and egress areas at developments other than residentia l buildings with four or fe wer units are maintained with one or more of the following dustproof paving methods: (a) Asphaltic concrete. (b) Cement concrete. (c) Penetration treatment of bituminous ma terial and seal coat of bituminous binder and a mineral aggregate. (d) A stabilization method approved by the county. 6. In a county with a population of two milli on or more persons orany portion of a county in an area designated by the environment al protection agency as a serious PM-10 nonattainment area or a maintenance area t hat was designated as a serious PM-10 nonattainment area, no later than March 31, 2008, adopt or amend codes or ordinances and, no later than October 1, 2009, commence enforcement of thos e codes or ordinances as necessary to require that parking, maneuvering, ingress and egress areas three thousand square feet or more in size at resi dential buildings with four or fewer units are maintained with a paving or stabilization method authorized by the county by code, ordinance or permit.
77. In area A, no later than March 31, 2008, adopt or amend codes or ordinances as necessary to restrict vehicle parking and use on unpaved or unstabilized vacant lots. 8. In area A, require that new or renewed contracts for street sweeping on city streets must be conducted with street sweepers that meet the south coast air quality management district rule 1186 st reet sweeper certification specifications for pick up efficiency and PM-10 emissions in effect on January 1, 2007. 11. In a county with a population of two m illion or more persons or any portion of a county within an area designated by the env ironmental protection agency as a serious PM-10 nonattainment area or a maintenance ar ea that was designated as a serious PM-10 nonattainment area, no later t han March 31, 2008, adopt rule pr ovisions, and, no later than October 1, 2008, commence enforcement of those rule provisions regarding the stabilization of disturbed surfaces of vacant lots that include the following: (a) Reasonable written notice to the owneror the owner's authorized agent or the owner's statutory agent that t he unpaved disturbed surface of a va cant lot is required to be stabilized. The notice shall be given not le ss than thirty days before the day set for compliance and shall include a legal description of the property and the estimated cost to the county for the stabilization if the owner does not comply. The notice shall be either personally served or mailed by certified mail to the owner's statutory agent, to the owner at the owner's last known address or to the address to which the ta x bill for the property was last mailed. (b) Authority for the county to enter the lo t to stabilize the disturbed surface at the expense of the owner if the vacant lot has not been stabilized by the day set for compliance. (c) Methods for stabilization of the dist urbed surface of the vacant lot, the actual cost of stabilization and the fine that may be imposed for a violation of this section. B. For the purposes of subsecti on A, paragraph 11 of this section: 1. "Disturbed surface" means a portion of the earth's su rface or material placed on the earth's surface that has been physically moved, uncover ed, destabilized or otherwise modified from its undisturbed native condition if the potential for the emission of fugitive dust is increased by the movement, destabilization or modification. 2. Vacant lots do not include any site of disturbed surface area that is subject to a permit issued by a control officer that requi res control of PM-10 emissions from dust generating operations. H. Subsection A, paragraphs 5, 6 and 7 of this section do not apply to any site that has a permit issued by a contro l officer as defined in sect ion 49-471 for the control of fugitive dust from dust generating operations. 49-474.05. Dust control; tr aining; site coordinators A. This section applies in a county with a population of two million or more persons or any portion of a county in an area desi gnated by the environmental protection agency as a serious PM-10 nonattainment area or a maintenance area that was designated as a serious PM-10 nonattainment area. B. No later than January 1, 2008, the c ontrol officer shall develop and implement basic and comprehensive training programs for the suppression of P M-10 emissions from sources of PM-10 that are s ubject to a permit issued by a control officer that requires control of PM-10 emissions from dust generat ing operations. The control officer may
8approve training developed and provided by a thir d party and the board of supervisors may adopt rules prescribing standards for dust control training. C. At least once every three years, the following persons are required to successfully complete basic dust control training: 1. The site superintendent or other designated on-site r epresentative of the permit holder if present at a site that has more than one acre of disturbed surface area that is subject to a permit issued by a control offi cer requiring control of PM-10 emissions from dust generating operations. 2. Water truck and water pull drivers. D. Persons who are required to be trained under this section shall complete the training no later than December 31, 2008. A ll persons who have successfully completed training during the 2006 and 2007 calendar years are deemed to have satisfied this requirement if the training pr ogram completed was conducted or approved by a county air pollution control officer. Completion of t he training required under subsection G satisfies the requirements of this subsection. E. No later than June 30, 2008, the permittee for any site of five acres or more of disturbed surface area subject to a permit iss ued by a control office r requiring control of PM-10 emissions from dust generating operati ons shall have on site at least one dust control coordinator trained in accordance with this section at all times during primary dust generating operations related to the purposes for which the dust control permit was obtained. F. A dust control coordinator has full aut hority to ensure that dust control measures are implemented on site, including conducting in spections, deployment of dust suppression resources and modification or shutdown of acti vities as needed to control dust. The dust control coordinator shall be responsible for managing dust prevention and dust control on the site. G. At least once every thr ee years, the dust control c oordinator shall successfully complete a comprehensive dust control cl ass conducted or approv ed under subsection A by the county air polluti on control officer with jurisdiction over the site. The dust control coordinator shall have a valid dust training certif ication identification card readily accessible on site while acting as a dust control coordinator. All persons having successfully completed training during the 2006 and 2007 cal endar years are deemed to have satisfied this requirement if the trai ning program completed was c onducted or approved by a county air pollution control officer. H. Subsections C and D do not apply when on-site dust generating operations are conducted by a permittee who is required to obtain a single permit for multiple noncontiguous sites that is issued by a contro l officer and that requires control of PM-10 emissions. I. The requirements of subsections E and F lapse if all of the following apply: 1. The area of the disturbed surf ace area is less than five acres. 2. The previously disturbed areas are stabilized in accordance with the requirements of applicable rules. 3. The permittee provides notice of t he acreage stabilized to the control officer. J. Permittees who are required to obtai n a single permit for multiple noncontiguous sites that is issued by a control officer and that requires control of PM-10 emissions from
9dust generating operations shall have on site s with greater than one acre of disturbed surface area at least one individual who is designated by the permittee as a dust control coordinator trained in accordanc e with subsection C. The dust control coordinator shall be present on site at all times dur ing primary dust generating activiti es that are related to the purposes for which the permit was obtained. This subsection does not apply to permittees subject to subsections B and C. 49-474.06. Dust control; subc ontractor registration; fee A. In an area designated by the environmental protection agency as a serious PM-10 nonattainment area or a maintenance ar ea that was designated as a serious PM-10 nonattainment area, a subcontractor who is engaged in dust generating operations at a site that is subject to a permit that is issued bya control officer and that requires control of PM-10 emissions from dust generat ing operations shall registerwith the control officer by submitting information in the manner prescribed by the control officer. The control officer shall issue a registration number after paym ent of the fee authoriz ed under subsection C. B. The subcontractor shall have its r egistration number readily accessible on site while conducting any dust generating operations. C. The control officer may establish and assess a fee for the registration required under subsection a based on the total cost of processing the registration and issuance of a registration number. 49-501. Unlawful open burning; exceptions; fine; definition A. Notwithstanding the provisions ofany other section of this article: 2. From May 1 through September 30 each year, it is unlawful for any person to ignite, cause to be ignited, pe rmit to be ignited or suffer, a llow or maintain any open outdoor fire in area A as defined in section 49-541. B. The following fires are excepted from this section: 1. Fires used only for cooking of food or for providing warmth for human beings or the branding of animals or the use of orchard heaters for the purpose of frost protection in farming or nursery operations. C. Permission for the setting of any fire given by a public officer in the performance of official duty under sebsection B, paragraph 2, 3 or 4 of this section shall be given in writing and a copy of the wri tten permission shall be transmitted directly to the director of environmental quality and the contro l officer of the county, district or region in which such fire is allowed. The setting of any such fi re shall be conducted in a manner and at such time as approved by the control officer or the director of environmental quality, unless doing so would defeat the pur pose of the exemption. F. Nothing in this section is intended to permit any practice which is a violation of any statute, ordinance, rule or regulation in a county with a population in excess of one million two hundred thousand persons. Notwithst anding any other law, such a county shall prohibit by ordinance the use of wood burning chimineas, outdoor fire pits and similar outdoor fires on those days for which the c ounty has issued a no burn day restriction. G. A person who violates any provision of this section may be served a notice of violation and be subject to the enf orcement provisions of this article to the same extent as a person violating any rule or regulation adopted pursuant to this article, except that a violation that lasts no more than twenty-four hours and that is the first violation committed by that person is subject to a civil penalty of no more than five hundred dollars.
1049-541. Definitions In this article, unless the context otherwise requires: 1. "Area A" means the area delineated as follows: (a) In Maricopa county: Township 8 north, range 2 east and range 3 east Township 7 north, range 2 west through range 5 east Township 6 north, range 5 west through range 6 east Township 5 north, range 5 west through range 7 east Township 4 north, range 5 west through range 8 east Township 3 north, range 5 west through range 8 east Township 2 north, range 5 west through range 8 east Township 1 north, range 5 west through range 7 east Township 1 south, range 5 west through range 7 east Township 2 south, range 5 west through range 7 east Township 3 south, range 5 west through range 1 east Township 4 south, range 5 west through range 1 east (b) In Pinal county: Township 1 north, range 8 east and range 9 east Township 1 south, range 8 east and range 9 east Township 2 south, range 8 east and range 9 east Township 3 south, range 7 east through range 9 east (c) In Yavapai county: Township 7 north, range 1 east and range 1 west through range 2 west Township 6 north, range 1 east and range 1 west

11

## APPENDIX C

EXHIBIT 2:

Maricopa County Resolution to Evaluate Measures in the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area

## APPENDIX C

EXHIBIT 3:

Arizona Department of Environmental Quality Dust Action General PermitARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY Air Quality Division 1110 West Washington Street  Phoenix, AZ 85007  Phone: (602) 771-2308 

# DUST ACTION GENERAL PERMIT

(As required by Arizona Revised Statutes, Title 49, Chapter 3, Article 2, Section 49-457.05)



### This air quality control permit does not relieve applicant of responsibility for meeting all air pollution regulations

THIS GENERAL PERMIT ISSUED SUBJECT TO THE FOLLOWING Conditions contained in Attachments “A”, “B” and “C” ADEQ GENERAL PERMIT NUMBER NA EXPIRATION DATE December 30, 2016
PERMIT ISSUED THIS 30 th DAY OF December , 2011
Eric C. Massey, Director, Air Quality Division SIGNATURE TITLEDust Action General Permit 2 of 18 December 30, 2011 This page left blank intentionallyDust Action General Permit 3 of 18 December 30, 2011 DUST ACTION GENERAL PERMIT TABLE OF CONTENTS
INTRODUC TION ................................................................................................................... ......................................................... 4 ATTACHMENT "A": GENERAL PROVISIONS............................................................................................. ......................... 5 I. APPLIC ABILITY............................................................................................................................................................. 5 II. DEFINTIONS................................................................................................................. .................................................. 5 III. GENERAL PERMIT EX PIRATION AND RENEWA L..................................................................................... ............. 7 IV. COMPLIANCE WITH PERMIT C ONDITION S.......................................................................................... ................... 7 V. ISSUANCE OF A DUST ACTION GENERAL PERM IT REQUIREMENT TO OPERATE FOR CAUSE .................. 7 VI. COMPLIANCE CE RTIFICATION.................................................................................................................................. 9 VII. INSPECTI ON AND ENTRY ...................................................................................................... ................................... 10 VIII. RECORD KEEP ING REQUIRE MENTS.............................................................................................. ......................... 10 IX. REPORTING REQUIREMENTS..................................................................................................... .............................. 10 X. DUTY TO PROVIDE INFORMATION ................................................................................................. ....................... 10 XI. PROPERTY RIGHTS............................................................................................................ ......................................... 11 XII. SEVE RABILITY CLAUSE.................................................................................................. .......................................... 11 XIII TERMINATION FOR C AUSE

..................................................................................................... ................................. 11 XIV. RENTING OR LEASING A REGULATED ACTIVITY ................................................................................... ........... 11 ATTACHMENT "B": SPECIFIC CONDITIONS ............................................................................................ ........................ 12 I. GENERAL CONDITI ONS

.......................................................................................................... ................................... 12 II. BEST MANAGEMENT PR ACTICES RE QUIREME NT ...................................................................................... ....... 12 III. ALTERNATIVE BEST MANAGEMENT PRACTICE S NOT INCLUDED IN TH E GENERAL PERMIT ............... 12 ATTACHMENT “C”: BEST MANAG EMENT PRACTICE EXAMP LES............................................................................ 14 I. VEHICLE USE IN OPENAREAS AND VAC ANT LOTS................................................................................... ........ 14 II. OPEN AREAS AND VACANT LOTS ................................................................................................. ......................... 14 III. UNPAVED PA RKING LOTS...................................................................................................... .................................. 14 IV. UNPAVED ROADWAYS, ALLEYW AYS AND ROAD SHOULDE RS..................................................................... 15 V. LIVESTOCK SPECIAL EVENTS NOT OTHERWISE COVERED UNDER A.R.S . § . 49-457 .................................. 15 VI. EASEMENTS, RIGHTS OF WAY, AND ACCESS ROADS FOR UTIL ITIES ........................................................... 16 VII. TRACKOUT FROM UNPERMITTED SOURCE S......................................................................................... .............. 16 VIII. MANAGED OFF HIGH WAY VEHIC LE ROUTES ...................................................................................... .............. 16Dust Action General Permit 4 of 18 December 30, 2011 DUST ACTION GENERAL PERMIT
INTRODUCTION Since the start of Calendar Year 2008, the majority of exceedances of the PM 10 National Ambient Air Quality Standard (NAAQS) in the Maricopa County serious PM 10 nonattainment area have been related to high wind events. High wind events, along with a nu mber of other meteorological conditions that can lead to the generation of dust can be pr edicted through meteorological forecasts. In accordance with A.R.S. § 49-424(11), ADEQ is developing and disseminating an air quality dust forecast for the Maricopa County serious PM 10 nonattainment area. Based upon knowledge of historical and recent meteorological conditions, and the prediction of such factors as wind speed and wind direction, forecasts identify the potential risk of dust entrainment as “Low”, “Moderate” or “High” for the next five consecutive days. ADEQ updates this five-day Maricopa County Dust Control Forecast every Sunday through Friday, and posts it on its website at http://www.azdeq.gov/environ/air/ozone/mcdust.pdf

. In accordance with A.R.S. § 49-457.05, this DustAction General Permit identifies a series of Best Management Practices (BMPs) for specific dust generating operations. When ADEQ’s Maricopa County Dust Control Forecast predicts that a day is at high risk for dust generation, those dust generating operations that are not already required to control dust through a permit issued by the Arizona Department of Environmental Quality (ADEQ) or the Maric opa County Air Quality Department (MCAQD) are expected to choose and implement at least one BMP to reduce or prevent PM 10 emissions. Implementation of a BMP is expected to occur as soon as practicable before and during the high risk event. Although the BMPs in the Dust Action General Permit only apply to those sources that do not already have a permit, dust generating operations with an air quality permit are also expected to implement the dust controls in their permit at the same time. According to statute, BMPs identified in the Dust Action General Permit are expected to be employed absent the requirement to obtain an air quality permit. If the owner or operator of a dust-generating operation is found by ADEQ’s Director to have failed to choose and implement an applicable BMP as soon as practicable before and during a day that is forecast to be at high risk of dust generation, then the owner or operator can be required to obtain a Re quirement to Operate (RTO) under the Dust Action General Permit. The process by which ADEQ’s Direct or makes such a finding is identified within the Dust Action General Permit. Violations of the Dust Action General Permit are subject to the enforcement requirements of Arizona Revised Statutes Title 49, Chap ter 3, Article 2, including civil penalties of up to ten thousand dollars per day, per vi olation, pursuant to Section 463. In accordance with A.R.S. § 49-457.05(E) this Dust Action General Permit is subject to a 30-day public comment period and shall be effective for a period of five-years.Dust Action General Permit 5 of 18 December 30, 2011 DUST ACTION GENERAL PERMIT ATTACHMENT “A”: GENERAL PROVISIONS
I. APPLICABILITY
A. This Dust Action General Permit is applicab le to the owner or operator of a regulated activity within a county with a population of two million or more persons, or any portion of a county within areas designated by the environmental protection agency as a serious PM 10 nonattainment area or a maintenance area that was previously designated as a serious PM 10 nonattainment area who is required by the Director to obtain a general permit in accordance with Condition IV of this Attachment.
B . Each owner or operator of a regulated activity that is required by the Director to obtain this Dust Action General Permit shall obtain a Requirement to Operate that includes the following information: 1. The regulated activity; 2. The legal owner or operato r of the regulated activity; and 3. The physical address, location, or parcel number where the regulated activity occurs. C. Each Requirement to Operate (RTO) issued under this general permit shall only apply to those regulated activities that are identified pur suant to Section V of this attachment and in the RTO, are under the control of the same Permittee, and are located on one or more properties that are adjacent or contiguous to the location of the regulated activity.
II. DEFINITIONS For the purposes of the Dust Action General Pe r mit the following terms are defined as follows: A. "Applicable implementation plan" means that term as defined in 42 United States Code section 7602( q). B. "Best management practices" means techniqu es that are verified by scientific research and that on a case-by-case basis are practical, economically feasible and effective in reducing PM 10 particulate emissions from a regulated activity. C. "Control officer" has the same meaning pr escribed in Arizona Revised Statutes § 49-471. D. “Designated, managed or open trail syst e m” means roads, highways, multiple use corridors, trails or routes that are part of a system of trails and routes that are designated, managed or opened to public motor vehicl e travel by government land management agency by rule, order, travel management pl an, sign, or map approved by such agency. E. "Disturbed surface area" means a portion of the earth's surfa ce or material that is placed on the earth's surface that has been physi cally moved, uncovered, destabilized or otherwise modified from its undisturbed native condition if the potential for the emission of fugitive dust is increased by the movement, destabilization or modification. F. "Dust-generating operation" means distur bed surface areas, including those of open areasDust Action General Permit 6 of 18 December 30, 2011 or vacant lots that are not defined as agricu ltural land and are not used for agricultural purposes according to Arizona Revised Statutes §§ 42-12151 and 42-12152, or any other area or activity capable of generating fugitive dust, including the following: 1. Land clearing, maintenance and land clean-up using mechanized eq uipment. 2. Earthmoving. 3. Weed abatement by discing or blading. 4. Excavating.
5. Construction.
6. Demolition. 7. Bulk material handling, including hauling, transporting, stacking, loading and unloadin g operations. 8. Storage or transporting operations, including storage piles. 9. Operation of outdoor equipment. 10. Operation of motorized machinery. 11. Establishing or using staging areas, parking areas, material storage areas or access routes. 12. Establishing or using unpa ved haul or a ccess roads. 13. Installing initial landscapes using m echanized equipment. G. “Dust Suppressant” means water, hygroscopi c material, a solution of water and chem ical surfactant, foam, non-toxic chemical stabilizer , or any other dust palliative, which is not prohibited for ground surface application by the Environmental Protection Agency (EPA) or the Arizona Department of Environmenta l Quality (ADEQ), or any applicable law, rule, or regulation, as a treatment materi al for reducing fugitive dust emissions. H. "Fugitive dust" means particulate matter that could not reasonably pass through a stack, chim ney, vent or other functionally equivale nt opening, that can be entrained in the ambient air and that is caused by human or natural activities, including the movement of soil, vehicles, equipment, blasting and wind. Fugitive dust does not include particulate matter emitted directly from the exhaust of mo tor vehicles and other internal combustion engines, from portable brazing, soldering or welding equipment or from pile drivers. I. “Livestock special event” means displaying, racing, training or exercising livestock during an event at which a fee is collected, or is open to 24 or more persons including staff, participants and spectators, and is conducted at a facility specifically designed for this purpose and is not already subject to A.R.S. § 49-457.” J. “Owner or operator” means any person who owns, leases, operates, controls, or supervises a regulated activity subject to the requirements of this general permit.Dust Action General Permit 7 of 18 December 30, 2011 K. "Regulated activity" means all dust-ge nerating operations except for the following: 1. Normal farm cultural practices as prescribed in A.R.S. §§ 49-504(4) or 49-457. 2. Emergency activities that may disturb the soil and that are conducted by any utility or government agency in order to prevent public injury or to restore critical utilities to a functional status. 3. Establishment of initial landscapes with out the use of mechanized equipm ent, conducting landscape maintenance without th e use of mechanized equipment and playing on or maintaining a field used for nonmotorized sports, except that these activities shall not include grading or tr enching performed to establish initial landscapes or to redesign existing landscapes. 4. Rooftop operations for cutting, drilling, grinding or coring roofing tile if that activity is occurring on a pitched roof.
III. GENERAL PERMIT EXPIRATION, RENEWAL AND RE-OPENING
A. This Dust Action General Permit is valid fo r a period of five years from the date of issuance. The Director of ADEQ (Director) shall review and may renew this General Permit every five years from its date of issuance. The Permittee’s RTOs shall coincide with the term of this General Permit, regard less of when the RTO was issued during this five year period. The Director may require an existing RTO to be renewed at the time that this General Permit is renewed.
B. The Director may periodically reexamine, evaluate and modify the Dust Action General Permit as prescribed in A.R.S. Section 49-426(H)(2) through (6). After approval by the Director, any modifications to the Dust Ac tion General Permit shall be provided to the Control Officer and shall be submitted to the United States Environmental Protection Agency as a revision to the applicable State Implementation Plan.
C. At the time that the public notice is required, pursuant to issuance of the proposed General Permit renewal, the Director shall notify in writing all Permittees with existing RTOs that have been renewed. The writte n notice shall describe the source’s duty to comply with the conditions of the General Permit.
IV. COMPLIANCE WITH PERMIT CONDITIONS
A. The Permittee shall comply with all Conditio ns of this General Permit including all applicable requirements of Arizona air quality statutes and the air quality rules. Any permit noncompliance constitutes a violation of the Arizona Revised Statutes and is grounds for enforcement action, including, but not limited to civil penalties. In addition, non-compliance with any federally enforceable requirements constitutes a violation of the Clean Air Act.
B. It shall not be a defense for a Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this General Permit.
V. ISSUANCE OF A DUST ACTION GENERAL PERMIT FOR CAUSE
A. The Director may require the owner or operator of a regulated activity to obtain aDust Action General Permit 8 of 18 December 30, 2011 Requirement to Operate under the Dust Acti on General Permit at any time if it can be demonstrated that: 1. The regulated activity is not otherwise subject to an air quality permit issued by the Director or the Maricopa County Air Quality Department Control Officer; and 2. The owner or operator of a regulated ac tivity did not choose or implement a Best Management Practice as soon as practicable before and during a day forecast to be at high risk of dust generation.
B. A demonstration that the owner or operator of a regulated activity did not choose or implement a Best Management Practice shall include the following: 1. Documentation that includes a description of the regulated activity; 2. Documentation that clearly identifies the legal owner or operator of the regulated activity; 3. Documentation that clearly identifies the physical address(es), location(s), or parcel number(s) where the regulated activity occurred; 4. Documentation that includes records, field reports or photographic evidence that demonstrates that the owner or operator of the regulated activity was not implementing a Best Management Practice as soon as practicable before and during a day forecast to be at high risk of dust generation; 5. A description of the actions taken by the owner or operator of the regulated activity to comply with the required Best Management Practice(s) at the time of the inspection; 6. Documentation that identifies any previous inspections associated with the owner, operator, physical address(es), location(s), or parcel number(s) as well as results of those inspections; and 7. Documentation that demonstrates that the owner or operator of the regulated activity has been provided with a copy of the documentation identified in Condition III.B.1 through 6 above.
C. Upon receipt of a demonstration that the owner or operator of a regulated activity did not choose or implement a Best Management Practice, the Director shall: 1. Notify the owner or operator of the receipt of the demonstration; and 2. Provide the owner or operator with five (5) business days to demonstrate that a Best Management Practice was employed at the time of the inspection; or provide a document that identifies the B est Management Practice(s) that will be employed at the address(es), location(s), or parcel number(s) identified in the Director’s letter.
D. If the Director determines that the owner or operator of a regulated activity was not in compliance with the required Best Manageme nt Practices as soon as practicable before and during a day forecast to be at high risk of dust generation, and has not adequatelyDust Action General Permit 9 of 18 December 30, 2011 identified the Best Management Practices that will be employed as soon as practicable before and during future days forecast to be at high risk of dust generation the Director shall issue a RTO under the Dust Action Gene ral Permit and shall require the owner or operator to choose and implement Best Management Practices within five (5) business days of the determination. VI. TERMINATION FOR CAUSE
A. The Permittee may apply to the Director for termination of a RTO under the general permit if it can be demonstrated that: 1. The regulated activity is subject to an air quality permit issued by the Director or the Maricopa County Air Quality Department Control Officer; 2. The Permittee is no longer the legal owne r or operator of the regulated activity by demonstrating one of the following; a. The regulated activity has been so ld, transferred or otherwise been dispossessed by the Permittee; or b. The regulated activity is no longer capable of being operated at the physical address(es), location(s), or parcel number(s) where the regulated activity occurred; or 3. The Permittee provides documentation that a Best Management Practice has been chosen and implemented for each applicable regulated activity as soon as practicable before and during a day forecast to be at high risk of dust generation by submitting one of the following:

a. Demonstrating that a Best Management Practice of a permanent nature has been applied to the regulated activity; b. Submitting a copy of the records required in Attachment “B” Conditions I.D and II.C for the two most recent consecutive years after the time that the Dust Action General Permit has been issued; or c. Submitting a copy of the records required in Attachment “B” Conditions I.D and II.C for a different time period than that prescribed in Condition VI.A.3.b above based upon a demonstration that: (1) A regulated activity was not owned or operated at the location during the two most recent consecutive years; or (2) There were no days forecast to be at high risk of dust generation during the two most recent consecutive years.
B. The Director may terminate a RTO under the general permit if the Director makes an independent finding that: 1. The regulated activity is subject to an air quality permit issued by the Director or the Maricopa County Air Quality Department Control Officer;
2. In accordance with Condition VI.A.2 ab ove, the Permittee is no longer the legalDust Action General Permit 10of 18 December 30, 2011 owner or operator of the regulated activity.
VII. COMPLIANCE CERTIFICATION
A. The Permittee shall submit to the Director a compliance certification once each year, which describes the compliance status of the source with respect to each General Permit condition and the methods used for determining the compliance status. This certification shall be submitted by January 31 stand shall cover the previous calendar year. The compliance certification shall include the following: 1. Identification of the dust-generating operation owner or operated by the Permittee. 2. Identification of the Best Management Practice(s) used by the Permittee to comply with the terms and cond itions of this General Permit.
B. The Director may request additional inform ation to support the compliance certification.
VIII. INSPECTION AND ENTRY Upon presentation of credentials and other documen ts as may be required by law, the Permittee shall allow the Department, or an authorized re presentative (including an authorized contractor acting as a representative of the Depart ment), to perform the following:
A. Enter upon the Permittee’s premis es where a regulated activity is located or conducted, or where records must be kept under the conditions of th is General Permit;
B. Have access to and copy, at reasonable times, any records that are required to be kept under the conditions of this General Permit;
C. Inspect, at reasonable times, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this General Permit;
D. Sample or monitor at reasonable times, substances or parameters for the purpose of assuring compliance with the General Permit or other applicable requirements; and
E. Record any inspection by use of written, electronic, magnetic and photographic media. IX. RECORD KEEPING REQUIREMENTS Until the RTO under the general permit is termin ated pursuant to Section XIII of Attachment “A”, the Permittee shall retain records of a ll required records and supporting information and shall make the records availabl e to the Director upon request. X. REPORTING REQUIREMENTS The Permittee shall submit the following reports:
A. Compliance certifications in accordance with Section IV of Attachment “A”.
B. Other reports required by any condition in Attachment “B”.Dust Action General Permit 11 of 18 December 30, 2011 XI. DUTY TO PROVIDE INFORMATION
A. The Permittee shall furnish to the Director, w ithin a reasonable time, any information that the Director may request in writing to determine whether cause exists for revoking the General Permit coverage, or to determine co mpliance with this General Permit. Upon request, the Permittee shall also furnish to the Director copies of records that the Permittee is required to keep under the Ge neral Permit. For information claimed confidential, the Permittee shall furnish an add itional copy of such records directly to the Director along with a claim of confidentiality.
B. If the Permittee has failed to submit any rele vant facts or if the Permittee has submitted incorrect information in a General Permit cove rage application, the Permittee shall, upon becoming aware of such failure or inco rrect submittal, promptly submit such supplementary facts or corrected information.
XII. PROPE RTY RIGHTS This General Permit does not convey any property ri g hts of any sort, or any exclusive privilege.
XIII. SEVERABILITY CLAUSE The provisions of this General Permit are severable . In the event of a challenge to any portion of this General Permit, or if any portion of th is permit is held invalid, the remaining permit conditions remain valid and in force.
XIV. RENTING OR LEASING A REGULATED ACTIVITY In the case that a regulated activity covered under th is general permit is rented or leased, a copy of this General Permit and relevant RTOs shall be provided by the owner to the renter or lessee, and the renter or lessee shall be bound by this pe rmit's provisions. In the event a copy of this General Permit and relevant RTOs are not provided to the renter or lessee, both the owner and the renter or lessee shall be responsible for the implementation of a Best Management Practice in compliance with the General Permit cond itions and any violations thereof.Dust Action General Permit 12 of 18 December 30, 2011 DUST ACTION GENERAL PERMIT
ATTACHMENT “B”: SPECIFIC CONDITIONS

I. GENERAL CONDITIONS A. The Permittee shall obtain a copy of the Maricopa County Dust Control Forecast each day that it is updated by: 1. Accessing the forecast through ADEQ’s website at: http://www.azdeq.gov/environ/air/ozone/mcdust.pdf ; or 2. Signing up for ADEQ’s electronic mailing system. B. The Permittee shall register to receive all available electronic updates from all Maricopa County Air Quality Department air quality monitors within 4 miles of the regulated activity. C. The Permittee shall notify employees who conduct or operate a regulated activity when the Maricopa County Dust Control Forecast identifies the following day as being at high risk of dust generation. D. The Permittee shall keep a record of each Maricopa County Dust Action Control Forecast that identifies the next calendar day as be ing at high risk of dust generation and a log of the date, time and method used to notify employees.
II. BEST MANAGEMENT PRACTICES REQUIREMENT A. As soon as practicable before, and during a day identified by the Maricopa County Dust Control Forecast as being at high risk of dust generation, the Permittee shall take reasonable precautions to reduce or prevent particulate matter from becoming airborne. Examples of Best Management Practices for specific source categories are included in Attachment “C” of this permit. B. The Permittee shall choose and implemen t a Best Management Practice for each regulated activity owned or operated by the Permittee. C. The Permittee shall keep records of the Best Management Practices that are employed in advance of and during a day identified by the Maricopa County Dust Control Forecast as being at high risk of dust generation.
III. ALTERNATIVE BEST MANAGEMENT PRACTICES NOT INCLUDED IN THE GENERAL PERMIT
A. The Permittee may choose and implement an a lternative Best Management Practice that is not included in Attachment “C” of this permit provided that the Permittee maintains records of documentation demonstrating that the alternative Best Management Practice that was selected and implemented achieves an equivalent or greater control of PM 10 particle emissions than an example included in Attachment “C”;
B. Any person may petition the Director to make a determination that an alternative BestDust Action General Permit 13 of 18 December 30, 2011 Management Practice achieves an equivalent or greater control of PM 10 emissions than the examples included in Attachment “C”. These petitions shall include the following: 1. A description of the alternative Best Management Practice; and 2. A demonstration that the alternative Best Management Practice achieves an equivalent or greater control of PM 10 emissions than an example included in Attachment “C”.
C. Upon renewal or re-opening of this general permit, the Director shall add to the Best Management Practices examples in Attachme nt “C” any alternative Best Management Practices that were appr oved under Condition III.B above.Dust Action General Permit 14 of 18 December 30, 2011 DUST ACTION GENERAL PERMIT
ATTACHMENT “C”: BEST MANAG EMENT PRACTICE EXAMPLES

I. VEHICLE USE IN OPEN AREAS AND VACANT LOTS
A. This condition does not apply to design ated, managed or opened trail systems. B. As soon as practicable before and during a day forecast to be at high risk of dust generation, the Permittee shall: 1. Reduce or prevent motor vehicle acces s to the open area or vacant lots by: a. Installing barriers, curbs, fences, gates, posts, shrubs, trees or other effective control measures; or b. Installing no trespassing, no parking or no access signs that comply with local, County, State or Federal sign standards; or 2. Uniformly apply and maintain surface grav el or chemical or organic stabilizers to all areas disturbed by motor vehicles. C. As soon as practicable before and during th e day forecast to be at high risk of dust generation the Permittee shall inspect, maintain and repair as necessary the best management practice selected in Condition I.B. above.
II. OPEN AREAS AND VACANT LOTS A. This condition does not apply to design ated, managed or opened trail systems. B. As soon as practicable before and during a day forecast to be at high risk of dust generation, the Permittee shall control PM 10 emissions from open areas and vacant lots by: 1. Establishing vegetativ e ground cover on all disturbed surface area; or 2. Increasing the use of dust suppressants on the open area or vacant lot; or 3. Uniformly applying and maintaining surface gravel or chemical or organic stabilizers to all disturbed areas. C. As soon as practicable before and during th e day forecast to be at high risk of dust generation the Permittee shall inspect, main tain, and repair, as necessary, the best management practice selected in Condition II.B above.
III. UNPAVED PARKING LOTS
A. This condition does not apply to design ated, managed or opened trail systems. B. This condition applies to parking, maneuveri ng, ingress and egress ar eas at developments other than residential buildings with four or fewer units.Dust Action General Permit 15 of 18 December 30, 2011 C. As soon as practicable before and during a day forecast to be at high risk of dust generation, the Permittee shall control PM 10 emissions from unpaved parking lots by: 1. Increasing the use of dust suppressants other than water on the unpaved parking lot; or 2. Uniformly applying and maintaining surface gravel or chemical or organic stabilizers to all disturbed areas. D. As soon as practicable before and during th e day forecast to be at high risk of dust generation the Permittee shall inspect, main tain, and repair, as necessary, the best management practice selectedin Condition III.C above. IV. UNPAVED ROADWAYS, ALLEYWAYS AND ROAD SHOULDERS
A. This condition does not apply to design ated, managed or opened trail systems. B. This condition applies to u npaved roadways or alleyways that experience an average of 150 vehicle trips or more per day. C. As soon as practicable before and during a day forecast to be at high risk of dust generation, the Permittee shall control PM 10 emissions by: 1. Reducing or preventing motor vehicle access as prescribed in Condition I.B above; 2. Increasing the use of dust suppressants other than water on the unpaved roadway or alleyway; or 3. Uniformly applying and maintaining surface gravel or chemical or organic stabilizers to the unpaved roadway or alleyway. D. As soon as practicable before and during th e day forecast to be at high risk of dust generation the Permittee shall inspect, main tain, and repair, as necessary, the best management practice selected in Condition IV.C above. V. LIVESTOCK SPECIAL EVENTS NOT COVERED UNDER A.R.S. § 49-457 A. This condition applies to livestock facilities at which special events that are not already covered under A.R.S. § 49-457 occur. B. As soon as practicable before and during th e day forecast to be at high risk of dust generation the Permittee shall control PM 10 emissions by: 1. Increasing the use of dust suppressants , including water, on unpaved access connections and feed lane access areas at the livestock special event; or 2. Uniformly applying and maintaining surface gravel or chemical or organic stabilizers to all areas disturbed by mo tor vehicles other than areas where such application will create a documentable hazard for livestock activities; or.Dust Action General Permit 16 of 18 December 30, 2011 3. Reducing or preventing motor vehicle access on unpaved access connections and feed lane access areas at the livestock special event by: a. Installing barriers, curbs, fences, gates, posts, shrubs, trees or other effective control measures; or b. Installing no trespassing, no parking or no access signs that comply with local, County, State or Federal sign standards; or C. As soon as practicable before and during th e day forecast to be at high risk of dust generation the Permittee shall inspect, main tain, and repair, as necessary, the best management practice selected in Condition V.B above. VI. EASEMENTS, RIGHTS-OF-WAY, AND ACCESS ROADS FOR UTILITIES
A. This condition does not apply to design ated, managed or opened trail systems. B. This condition applies to easements, rights-of-way, and access roads for utilities (transmission of electricity, natural gas, oil, water, and gas) that experience an average of 150 vehicle trips or more per day. C. As soon as practicable before and during a day forecast to be at high risk of dust generation, the Permittee shall control PM 10 emissions by: 1. Reducing or preventing motor vehicle access as prescribed in Condition I.B above;2. Increasing the use of dust suppressants other than water on the easement, rightof-way or access road; or 3. Uniformly applying and maintaining surface gravel or chemical or organic stabilizers to the easement, right-of-way or access road. D. As soon as practicable before and during th e day forecast to be at high risk of dust generation the Permittee shall inspect, main tain, and repair, as necessary, the best management practice selected in Condition VI.C above.

VII. TRACKOUT OR DEPOSITS OF BULK MATERIAL As soon as practicable befo re and during a day forecast to be at high risk of dust generation, the Permittee shall clean-up loose material or remove deposits of bulk material from areas accessible to the public on day before and during high risk day. VIII. DESIGNATED, MANAGED OR OPENED TRAIL SYSTEMS A. During the course of each calendar year, the Permittee shall control PM 10 emissions from designated, managed or opened trail systems by employing adaptive management techniques such as: 1. Posting public information to educate the riding public about at the impacts of air quality regulation on the use of off-highway vehicles,Dust Action General Permit 17 of 18 December 30, 2011 including the restricti on of operation during hi gh pollution advisories, through methods similar to kiosks, distri bution of material at major events and dealerships, and other Public Service Announcements; and 2. Conducting mechanized trail repair a nd maintenance at slow speeds that: a. Reduce the speed of water run-off on the designated, managed or opened trail system; b. Reduce the amount of silt that w ould otherwise accumulate on the designated, managed or open trail system; c. Add grade dip or water controls to the designated, managed or open trail system; or d. Add or repair silt traps on water drains; or 3. Re-routing an existing designated, ma naged or opened trail that causes traffic to avoid soils susceptible to dust generation; or constructing a new designated, managed or opened trails that allow for appropriate trail repair and maintenance and include speed limiting features such as turns and climbs; or 4. Rehabilitating open parking areas, mi ne sites, and old unpaved roads that are not designated, managed or opene d trail systems. Rehabilitation includes re-contouring the areas, re planting trees and spreading native seed to hold soil together and reduce windblown dust; or B. As soon as practicable before and during a day forecast to be at high risk of dust generation, the Permittee shall control PM 10 emissions from disturbed areas along the designated, managed or opened trail system by employing adaptive management techniques such as: 1. Applying a proven dust surfactant; 2. Repairing roads and other unpaved su rfaces to control the water run-off and silt; 3. Using soil binders and compaction to allow for light to moderate traffic flow; or 4. Installing an engineered road or surface that: a. Raises the road or surface bed above grade; b. Uses an ABC road mix and binder; c. Compacts the road or surface; and d. Crowns to drain water; or C. As soon as practicable before and during the day forecast to be at high risk of dust generation the Permittee shall inspect, maintain, and repair, as necessary, the best management practice selected in Conditions VI.A or B above; orDust Action General Permit 18of 18 December 30, 2011 D. When the Maricopa County Dust Control Forecast identifies the following day as being at high risk of dust the Permittee shall post information at kiosks or use equivalent methods to notify users of designated, managed or opened trail system.

## APPENDIX C

EXHIBIT 4:

Arizona Department of Environmental Quality Commitment to Revise the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area if Necessary for the Emerging and Voluntary Measure

## APPENDIX D

## APPENDIX D

EXHIBIT 1:

Agricultural Best Management Practices ProgramAGRICULTURAL BEST MANAGEMENT PRACTICES PROGRAM Throughout the course of the development of the MAG 2012 Five Percent Plan for PM-10 for the Maricopa Nonattainment Area (Five Percent Plan) the Governor’s Agricultural Best Management Practices (BMP) Committee has worked to enhance its Best Management Practices program. On December 9, 2011, the Ag BMP Committee approved enhancements to the BMP program. On behalf of the Governor’s Agricultural BMP Committee, the Arizona Department of Environmental Quality (ADEQ) sent a Notice of Ex empt Rule Making to the Secretary of State’s Office on December 29, 2011, making the enhanced BMP program effective on that same date. The enhanced BMP program is enforceable as a matter of State law. ADEQ has determined that implementation of the program will result in a numerically quantifiable air quality benefit throughout the Maricopa nonattainment area. ADEQ has also determined that the program will result in reduced concentrations of PM-10 at the monitors throughout the same area. The program will also have benefits outside of Maricopa County. According to the 2011 rule enhancements, the Agricultural BMP program automatically becomes effective in any area of the State that is designated as nonattainment for the PM-10 National Ambient Air Quality Standard (NAAQS) after June 1, 2009. For areas designated as moderate nonattainment, one BMP must be employed, whereas in areas that are designated as serious nonattainment, two BMPs must be employed. ADEQ has determined that the revised Five Per cent Plan already meets EPA’s requirements for annual five percent reductions in PM-10 emissions and a demonstration that the plan will result in the area’s attainment with the 24-hour PM-10 NAAQS without the inclusion of the enhanced Agricultural BMP program. As part of the public comment period, ADEQ requested comments about whether the Department should make a commitment to EPA to include the enhanced Agricultural BMP program as part of the Five Percent Plan or, given its statewide benefits, if the Department should include the enhanced Agricultural BMP program as a stand alone revision to the State Implementation Plan. No public comments were made in response to ADEQ’s request. Based on the facts listed above, and because the program is now implementable on a statewide basis, ADEQ has determined that it will submit the program as a separate, independent revision to the State Implementation Plan.

Prepared by the Arizona Department of Environmental Quality.

## APPENDIX E

## APPENDIX E

EXHIBIT 1:

Public Hearing Process DocumentationCERTIFICATION OF HOLDING OF PUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN FORPM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

I affirm that a public hearing was held jointly by the Arizona Department of Environmental Quality and the Maricopa Association of Govermnents (MAG) starting at 5:30p.m. Thursday, April12, 2012 at the MAG Offices, Saguaro Room, 302 North 1 ''Avenue, Phoenix, Arizona and that the hearing was held in accordance with the Arizona open meeting laws and 40 CFR 51.102 (d) to receive public comment on the MAG 2012 Five Percent Plan for PM-1 0 for the Maricopa County Nonattainment Area.

Lindy Baus · G Environmental Director

STATE OF ARIZONA ) ) ss. COUNTY OF MARICOPA ) Personally appeared before me the above-named Lindy Bauer known to me to be the same person who executed the foregoing instrmnent and to be the Environmental Director for the Maricopa Association of Governments and acknowledged to me that she executed the same as her free act.
SUBSCRIBED AND SWORN TO before me on this / 

# .J'f'-' day of April2012.

• OFFICIAL SEAL VALERIE DAY NOTARY PUBLIC Stale of Arizona MARICOPA COUNTY My Comm. Expires Aug. 16, 2012

My Commission Expires:

# ~~a dO/ :z.__ Notary PubhcAFFIDAVIT OF PUBLICATION



## THE ARIZONA REPUBLIC

STATE OF ARIZONA } COUNTY OF MARICOPA SS.



### Tabitha Antoniadis, being first duly sworn, upon oath deposes and says: That she is a legal advertising representative of the Arizona Business Gazette, a newspaper of general circulation in the county of Maricopa, State of Arizona, published at Phoenix, Arizona, by Phoenix Newspapers Inc., which also publishes The Arizona Republic, and that the copy hereto attached is a true copy of the advertisement published in the said paper on the dates as indicated.
The Arizona Republic

March 12, 13, 2012

Sworn to before me this 14 7 H day of March A.D. 2012**~"'=-~~~~c<ilkO..,_~~.FJ** 1 I' \**""p!l.L~"** BRIAN BILLINGS tf**<-j~,~·r:-£i~:'J'\i** il!ctacy _Public. /Hlzona 

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### :?!)?"' Mane cpa Count;**~- ~**  ·**~l-fr1** •**~** My Comrn. Expires Jill 25, 2014 

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### MARICOPA ASSOCIATION 

### of GOVERNMENTS 302 North 1st Avenue, Suite 300 .t. Phoenix, Arizona 85003 Phone (6021 254-6300 A FAX (8021 254-6490 E-mail: mag@azmag.gov A Web site: www.azmag.gov March 12,2012

TO:
FROM:
SUBJECT: Interested Parties for Air Quality Lindy Bauer, Environmental Director
PUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTYNONATTAINMENT AREA
Public Hearing Apri112, 2012 at 5:30p.m. MAG Offices, Saguaro Room 302 North 1 '' Avenue, Second Floor Phoenix, Arizona 85003

The Arizona Department of Environmental Quality and Maricopa Association of Governments (MAG) will jointly conduct a public hearing on the Draft MAG 2012 Five Percent Plan for PM-1 0 for the Maricopa County Nonattainment Area on April 12, 2012 at 5:30p.m. The purpose of this hearing is to receive public comments. According to Section 189 (d) of the federal Clean Air Act, the Five Percent Plan for PM-1 0 is required to be submitted to the Environmental Protection Agency. The plan contains a wide variety of existing control measures and projects that have been implemented to reduce PM-1 0 and a new measure to reduce PM-10 during high risk conditions, including high winds. The measures apply to unpaved roads and shoulders, leaf blowers, unpaved parking lots, vacant lots, sweeping streets with certified sweepers, off-road vehicle use, open and recreational burning, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. The plan demonstrates that the measures will reduce PM-10 emissions by at least five percent per year and demonstrates attainment of the PM-1 0 standard as expeditiously as practicable, which is 2012.
For your information and convenience, a copy of the public hearing notice is enclosed. The draft document is available for public review at the MAG Offices, third floor, from 8:00a.m. to 5:00p.m. Monday through Friday. In addition, the draft document is available for agency and public review on the MAG website at www.azmag.gov.

Attachment

A Voluntary Association of Local Governments in Maricopa County City of Apache Junction A City of Avondale ..._Town of Buckeye .t. Town of Carefree .t. Town of Cave Creek .t. City of Chandler .to. City of El Mirage .t. Fort McOO\\Iell Yavapai Nation 4 Town of Fountain Hills "-Town of Gila Bend Gila River Indian Community .1o. Tovm of Gilbert .t. City of Glendale • City of Gaodyear A Tovm of Guadalupe J. City of litchfield Park .t. Maricapa County A City of Mesa A Town of Parad"ISe VaUey .A. City of Peoria .A. City of Phoenix Town of Oueen Cr£ek .A. Satt River Pima-Maricopa Indian Community .A. City of Scottsdale .A. City of Surprise .A. City of Tempe • City ofToi!esan .A. Tai'm**ofWi~kenburg** .A. To'Ml ofYoungtovm .A. Arizona Department of Transpof'UitioflPUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA Aprili2, 20I2 at 5:30p.m. MAG Offices, Saguaro Room 302 North I'' Avenue, Second Floor Phoenix, Arizona 85003

The Arizona Department of Environmental Quality (ADEQ) and Maricopa Association of Governments (MAG) will jointly conduct a public hearing on the Draft MAG 2012 Five Percent Plan for PM-10 for the Maricopa CountyNonattainment Area on April12, 20I2 at 5:30p.m. The purpose of this hearing is to receive public comments. According to Section I89 (d) of the federal Clean Air Act, the Five Percent Plan for PM -I 0 is required to be submitted to the Environmental Protection Agency (EPA). The plan contains a wide variety of existing control measures and projects that have been implemented to reduce PM-I 0 and a new measure to reduce PM-I 0 during high risk conditions, including high winds. The measures apply to unpaved roads and shoulders, leaf blowers, unpaved parking lots, vacant lots, sweeping streets with certified sweepers, off-road vehicle use, open and recreational burning, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. The plan demonstrates that the measures will reduce PM-1 0 emissions by at least five percent per year and demonstrates attainment of the PM-IO standard as expeditiously as practicable, which is 20I2.
The draft document is available for public review at the MAG Offices, third floor, from 8:00a.m. to 5:00p.m. Mondaytlu·ough Friday and on the MAG website at www.azmag.gov. Public comments are welcome at the hearing, or may be submitted in writing by 5:30p.m. on April12, 2012 to Lindy Bauer at the address below. After considering the public comments, the MAG Regional Council may take action on the plan on May 23,2012. The ADEQ may then adopt the plan for submittal to the EPA.
Contact Person: Lindy Bauer, MAG (602) 254-6300 302 N. 1" Avenue, Suite 300 Phoenix, AZ 85003 Fax: (602) 254-6490 E-mail: lbauer@azmag.gov

### MARICOPA 

### ASS'CCIATICN of 

### GOVERNMENTS

March I2, 20I2

Ms. Cynthia Zwick Director Arizona Community Action Association 2700 North 3rd Street, Suite 3040 Phoenix, Arizona 85004-II22
Dear Ms. Zwick: TilLE VI LETTER EXAMPLE

302 North 1st Avenue, Suite 300 A Phoenix, Arizona 85003 Phone [6021 254-6300 A FAX [6021 254-6480 E-mail: mag@azmag.gov A Web site: www.azmag.gov



### You are cordially invited to a public hearing on the Draft MAG 20 I2 Five Percent Plan for PM-I 0 for the Maricopa County Nonattainment Area. The hearing will be held jointly by the Arizona Department of Environmental Quality and Maricopa Association of Governments on Thursday, Aprili2, 20I2 at 5:30p.m. in the Saguaro Room at the MAG Offices, 302 North 

### pt Avenue, Second Floor, Phoenix, Arizona, 85003. The purpose of this hearing is to receive public comments. Written and verbal comments are welcomed at the public hearing. After considering public comments, the MAG Regional Council may take action on the plan on May 23, 20I2. According to Section I89 (d) of the federal Clean Air Act, the Five Percent Plan for**PM~** 

### I 0 is required to be submitted to the Environmental Protection Agency. The plan contains a wide variety of existing control measures and projects that have been implemented to reduce PM-I 0 and a new measure to reduce PM -I 0 during high risk conditions, including high winds. The measures apply to unpaved roads and shoulders, leafblowers, unpaved parking lots, vacant lots, sweeping streets with certified sweepers, off-road vehicle use, open and recreational burning, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. The plan demonstrates that the measures will reduce PM-I 0 emissions by at least five percent per year and demonstrates attainment ofthe PM-IO standard as expeditiously as practicable, which is 20I2. The draft document is available for review at the MAG Offices, third floor, from 8:00 a.m. to 5:00p.m. Monday through Friday. In 

### addition, the draft document is available for agency and public review on ) 

### the MAG website at www.azmag.gov. We hope to see you or your representative at the hearing and to include your input in future planning efforts. For your convenience, a copy of the public hearing notice is attached. If you have any questions or would like to set up a time for us to meet with your organization, please call me at (602) 254-6300. Sincerely,

## ~~~· BCAAJJA_,/

.. 

### Lindy Bauer Environmental Director Attachment

A Voluntary Association of Local Governments in Maricopa County City of Apanhe Junntion A City of Avondale A Town of Buckeye A Town of Carefree A Town of Cave Creek A City of Chandler A City of E1 Mirage A Fort McDowell Yavapai Nation A Town of Fountain Hills A Town of Gila Bend Gila River Indian Community A Town of Gilbe£A City of Glendale A. City of Goodyear A Town of Guadalupe A City of Litchfield Park A Marinopa County A City of Mesa A. Town of Paradise Valley A City of Peoria A City of Phoenix Town of Queen Creek A Salt River Pima-Maricopa Indian Community A. City of Scottsdale A. City of Surprise A City of Tempe A City of Tolleson A Town of Wickenburg A Town of Youngtown A Arizona Department ofTransportationPUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPACOUNTYNONATTAINMENT AREA April12, 2012 at 5:30p.m. MAG Offices, Saguaro Room 302 North 1st Avenue, Second Floor Phoenix, Arizona 85003

The Arizona Department of Environmental Quality (ADEQ) and Maricopa Association of Governments (MAG) will jointly conduct a public hearing on the Draft MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area on April12, 2012 at 5:30p.m. The purpose of this hearing is to receive public comments. According to Section 189 (d) of the federal Clean Air Act, the Five Percent Plan for PM-10 is required to be submitted to the Environmental Protection Agency (EPA). The plan contains a wide variety of existing control measures and projects that have been implemented to reduce PM -10 and a new measure to reduce PM -10 during high risk conditions, including high winds. The measures apply to unpaved roads and shoulders, leaf blowers, unpaved parking lots, vacant lots, sweeping streets with certified sweepers, off-road vehicle use, open and recreational burning, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. The plan demonstrates that the measures will reduce PM-10 emissions by at least five percent per year and demonstrates attainment of the PM-10 standard as expeditiously as practicable, which is 2012.
The draft document is available for public review at the MAG Offices, third floor, from 8:00a.m. to 5:00p.m. Monday through Friday and on the MAG website at www.azmag.gov. Public comments are welcome at the hearing, or may be submitted in writing by 5:30p.m. on April12, 2012 to Lindy Bauer at the address below. After considering the public comments, the MAG Regional Council may take action on the plan on May 23, 2012. The ADEQ may then adopt the plan for submittal to the EPA.
Contact Person: Lindy Bauer, MAG (602) 254-6300 302 N. 1st A venue, Suite 300 Phoenix, AZ 85003 Fax: (602) 254-6490 E-mail: lbauer@azmag.gov

### MARICOPA ASSOCIATION of 

### GOVERNMENTS--------------- 302 North 1st Avenue, Suite 300 J.. Phoenix, Arizona 85003 Phone (602) 254-6300 J.. FAX (6021 254-6490 E-mail: mag@azmag.gov J.. Web site: www.azmag.gov March 12, 2012

TO:

FROM:
SUBJECT: Leslie Rogers, Federal Transit Administration Karla Petty, Federal Highway Administration John Halikowski, Arizona Department of Transportation Henry Darwin, Arizona Department of Environmental Quality Neal Young, City of Phoenix Public Transit Department Stephen Banta, METRO/RPTA William Wiley, Maricopa County Air Quality Department Brian Tapp, Central Arizona Association of Governments Donald Gabrielson, Pinal County Air Quality Control District Gregory Nudd, U.S. Environmental Protection Agency, Region IX Lindy Bauer, Environmental Director
TRANSMITTAL OF THE DRAFT MAG 2012 FIVE PERCENT PLAN FOR PM-10

FOR THE MARICOPA COUNTY NONATTAINMENT AREA
The Maricopa Association of Governments has prepared a Draft MAG 2012 Five Percent Plan for PM-1 0 for the Maricopa County Nonattainment Area. The draft document is available for review at the MAG Offices, third floor, from 8:00a.m. to 5:00p.m., Monday through Friday. In addition, the draft document is available for agency and pubiic review on the MAG website. Any comments are requested by 5:30p.m. on April12, 2012. According to Section 189 (d) of the federal Clean Air Act, the Five Percent Plan for PM-10 is required to be submitted to the Environmental Protection Agency (EPA). The plan contains a wide variety of existing control measures and projects that have been implemented to reduce PM-1 0 and anew measure to reduce PM-10 during high risk conditions, including high winds. The measures apply to unpaved roads and shoulders, leaf blowers, unpaved parking lots, vacant lots, sweeping streets with certified sweepers, off-road vehicle use, open and recreational burning, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. The plan demonstrates that the measures will reduce PM-1 0 emissions by at least five percent per year and demonstrates attainment of the PM-10 standard as expeditiously as practicable, which is 2012.
On April 12, 2012, a public hearing will be held jointly by the Arizona Department of Environmental Quality (ADEQ) and MAG at the MAG Offices, Saguaro Room, Second Floor, Phoenix, Arizona at 5:30p.m. After considering public comments, the MAG Regional Council may take action on the plan on May 23, 2012. The ADEQ may then adopt the plan for submittal to the EPA. If you have any questions, please do not hesitate to contact me at (602) 254-6300.

cc: Eric Massey, Arizona Department of Environmental Quality Scott Orner, Arizona Department of Transportation
A Voluntary Association of Local Governments in Maricopa County City of Apache Junction J.. City of Avondale J.. Town of Buckeye J.. Town of Carefree J.. Town of Cave Creek J.. City of Chandler J.. City of El Mirage J.. Fort McDowell Yavapai Nation J.. Town of Fountain Hills A. Town of Gila Bend Gila River Indian Community J.. Town of Gilbert J.. City of Glendale J.. City of Goodyear J.. Town of Guadalupe J.. City of Utchfield Park J.. Maricopa County J.. City of Mesa J.. Town of Paradise Valley J.. City of Peoria J.. City of Phoenix Town of Queen Creek J.. Salt River Pima-Maricopa Indian Community J.. City of Scottsdale J.. City of Surprise J.. City of Tempe J.. City of Tolleson J.. Town of Wickenburg J.. Town of Youngtown J...Arizona Department of TransportationPUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPACOUNTYNONATTAINMENT AREA April12, 2012 at 5:30p.m. MAG Offices, Saguaro Room 302 North P 1 Avenue, Second Floor Phoenix, Arizona 85003

The Arizona Department of Environmental Quality (ADEQ) and Maricopa Association of Governments (MAG) will jointly conduct a public hearing on the Draft MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area on Aprill2, 2012 at 5:30p.m. The purpose ofthis hearing is to receive public comments. According to Section 189 (d) of the federal Clean Air Act, the Five Percent Plan for PM -10 is required to be submitted to the Environmental Protection Agency (EPA). The plan contains a wide variety of existing control measures and projects that have been implemented to reduce PM -10 and a new measure to reduce PM -10 during high risk conditions, including high winds. The measures apply to unpaved roads and shoulders, leaf blowers, unpaved parking lots, vacant lots, sweeping streets with certified sweepers, off-road vehicle use, open and recreational burning, residential woodburning, covered vehicle loads, dust generating operations, nonmetallic mineral processing, and other unpermitted sources. The plan demonstrates that the measures will reduce PM-10 emissions by at least five percent per year and demonstrates attainment of the PM-10 standard as expeditiously as practicable, which is 2012.
The draft document is available for public review at the MAG Offices, third floor, from 8:00a.m. to 5:00p.m. Monday through Friday and on the MAG website at www.azmag.gov. Public comments are welcome at the hearing, or maybe submitted in writing by 5:30p.m. onApril12, 2012 to Lindy Bauer at the address below. After considering the public comments, the MAG Regional Council may take action on the plan on May 23,2012. The ADEQ may then adopt the plan for submittal to the EPA.
Contact Person: Lindy Bauer, MAG (602) 254-6300 302 N. 1 51 Avenue, Suite 300 Phoenix, AZ 85003 Fax: (602) 254-6490 E-mail: lbauer@azmag.govMARICOPA ASSOCIATION OF GOVERNMENTS ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY

PUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN
FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

Phoenix, Arizona

April 12, 2012 5:30 p.m.

Prepared By: Prepared By: Maricopa Association of Governments KARA JOHNSON (Original) Administrative Assistant1
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2 I N D E X

PUBLIC SPEAKERS: PAGE

Mr. Greenberg 16
Ms. Bahr 191
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3 MARICOPA ASSOCIATION OF GOVERNMENTS ARIZONA DEPARTMENT OF ENVIRONMENTAL QUALITY

PUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN
FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

commenced at 5:30 p.m. on April, 12, 2012 at the offices of Maricopa Association of Governments, 302 North First Avenue, Suite 300, Phoenix, Arizona before KARA JOHNSON, Administrative Assistant for the Environmental Division of Maricopa Association
of Governments.

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A P P E A R A N C E S

Maricopa Association of Governments: Lindy Bauer Cathy Arthur Arizona Department of Environmental Quality: Eric Massey1
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4 Phoenix, Arizona April 12, 2012 5:30 p.m.

PROCEEDINGS

MS. BAUER: I’d like to welcome everyone to our public hearing this evening. My name is Lindy Bauer and I am the
Environmental Director with MAG. This public hearing is being held jointly by the Arizona Department of Environmental Quality and the Maricopa Association of Governments to receive public comments on the Draft MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area. MAG serves as a designated regional air quality planning agency. Our regional air quality plans are prepared through a coordinated effort with the Arizona Department of Environmental Quality, Maricopa County Air Quality Department, and the Arizona Department of Transportation. Those driving to the meeting this evening, who parked in the garage, can have their tickets validated by the MAG staff. Kara has the validation for the parking tickets. Now the public hearing this evening will begin with some introductory remarks by the Arizona Department of Environmental Quality and then there will be an overview presentation by the MAG staff. Following the presentation hearing participants are invited1
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5 to make comments for the public record. A record of the public hearing will be prepared. Written comments are also welcome at this public hearing. For those participants wishing to speak, please fill out a form on the table and place it in the box. If you need to leave early because of a bus schedule, please tell the MAG staff; and we will accommodate your request. As you come up to the podium, please state some information for the record: your name and who you represent.
I would like to note that we have a timer to assist the public with their presentations. We have a three minute time limit. When two minutes have elapsed, the yellow light will come on, notifying the speaker that they have one minute to sum up. At the end of the three minute time period, the red light will come

on. And now I would like to introduce Eric Massey, the Director of the Air Quality Division at the Arizona Department of Environmental Quality. MR. MASSEY: Thank you, Lindy. I will try to keep my comments pretty brief, but what I wanted to acknowledge was that today’s activities are really the culmination of the efforts of many people, through our stakeholderprocess that ran through the entirety of 2011. The process was cochaired by Representative Amanda Reeve and also our Director Henry Darwin and included a number of efforts from the people that were1
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6 in our stakeholder group which also included Maricopa County, MAG, ADEQ staff. And so I wanted to take just a moment to appreciate the efforts of everybody that was involved because we were meeting sometimes twice a month trying to come up with a solution to the
issues that EPA had ad dressed in-- or had raised in its proposed partial approval/partial disapproval back in 2010. For me, the project is one of collaboration. It’s a real source of pride for me because I think we’ve had a chance to work closely together as regulatory entities with our regulated community to find a solution to a problem that has persisted here in the valley for a very long time. And what I really liked about our major efforts, was the collaboration, specifically between ADEQ, MAG, Maricopa County, and even EPA as we work through some of the technical meetings that occurred behind the scenes, once every two weeks for nearly the entirety of 2011.
So there was a tremendous amount of technical effort that went into this, a tremendous amount of effort from all of the stakeholders involved and I think the result is a really effective piece of work. And the other piece that I really like, about what we’ve done in this plan, is that we built upon prior efforts. One of the things that was important to MAG, to Maricopa County, to ADEQ through this whole process is that we were, um, cognizant of
the efforts that went into 2007's Senate Bill 1552 and that we didn’t wipe out the benefits that really came from that rule. Some of the things that we have seen is just a declining1
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7 concentration of PM-10 here in Phoenix. And while there has been some work to do and some issues like exceptional events that have clouded our issues; there has been a tremendous amount of effort that’s been done throughout the entire air shed. And we really wanted to take a moment to acknowledge that and notice that we’re building on past efforts. We also have some really new innovative ideas that are part of this plan, some of the forecasting that DEQ is doing, the
Dust Action General Permit which came as a collaborative effort from all of us here, to really find a solution to the ongoing issues of high wind days and its just a great opportunity to kind of meld the past effort with new thinking and its been a true honor for me to have been involved in this particular process. I’m looking forward to the continued process that goes through with EPA review and working together with our partners to make sure that this plan itself is one that can be approved. With that Lindy, I just wanted to say thank you again and the opportunity to be here today. And this is really a tremendous effort and I think a day to be celebrated. MS. BAUER: Thank you very much, Eric. We really appreciate all of your efforts as well as the efforts of all of the stakeholders that worked with us and Representative Reeve’s leadership as well. So, thank you for your comments. And now we will have an overview presentation on the MAG
2012 Five Percent Plan for PM-10.1
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8 Cathy Arthur with the Maricopa Association of
Governments. MS. ARTHUR: Thank you, Lindy and Eric. This is an overview of this plan. And as those of you have read it know, that it would probably take quite some time to go into a lot of detail so we are just going to do the highlights and hopefully look at the very important points that this plan represents. The new plan has a large number of control measures that address a variety of sources and many of these have already been implemented. In fact, most of them were in the 2007 Five Percent Plan- there were 53 measures in that plan. And although that plan was withdrawn in January of 2011 by the Arizona Department of Environmental Quality, most of those measures continue to be implemented. And we are resubmitting many of those measures in table 4-1 of the plan. There is one new measure in this plan and it focuses on high wind events. And this is generally because our 2007 plan focused on stagnant conditions and PM-10 exceedances during those
conditions. So we needed to look at additional measures that would help us control PM-10 levels during high wind events and this plan
does that.
There have been no violations of the PM-10 standard under stagnant conditions since the 2007 plan was submitted in December 2007. So we feel the plan that we submitted was very1
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9 effective-- the control measures were very effective with respect to PM-10 violations under stagnant conditions, but we needed to do additional work under high wind events. Just to show you some of the sources that we are controlling through the measures in this 2012 Five Percent Plan and you can see there is a large variety of sources, including: trackout, open burning, unpaved shoulders, unpaved roads, vacant lots, earthmoving activities, ATV’s, weed abatement operations, leaf blowing activity, street sweeper requirements- PM-10 Certified Street Sweepers, and then nonmetallic mineral processing operations are all being controlled through the measures that are in the 2012 plan. In terms of monitoring data and this is a fairly complicated bar graph here, we can focus on the fact that in 2010, there was only one exceedance of the PM-10 standard. In 2011, however, you will see that there are 22; 21 of those, however, we feel are exceptional events. Now an exceptional event is an uncontrollable natural event, which here in the Phoenix area tends to be high wind caused. ADEQ is in the process of documenting 21 exceptional events that occurred in 2011 and in addition we will be working on seven of them that are in purple
here for 2009. Just to add a little information, in 2012 we have already had 3 days that would be considered in purple, so there is going to have to be documentation of those as well by DEQ. And MAG and the1
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10 Maricopa County Air Quality Department are working with DEQ to prepare that documentation which is very time consuming, but it is necessary for us to show attainment by 2012. This is a pie chart that shows you the total emissions of PM-10 in the nonattainment area in 2008 and it totals about 50,000 tons per year. And the top two contributors in 2008, which is the first year of the plan, were unpaved roads at 24 percent and if you add up all the construction activities- 17 percent. So those are the top two in 2008. Keep those in mind because it changes by the time we get to the attainment year of 2012. Not only do the emissions go down, but the sources that contribute the most are
different.
The 2012 Five Percent Plan relies on a number of measures in order to demonstrate five percent reductions and show reductions due to contingency measures. And the most important one in terms of the five percent reductions is increasing rule effectiveness for three rules that Maricopa County Air Quality Department has passed. And EPA has approved these rules. Rule 310, which is for dust generating operations, such as earthmoving. Rule 310.01, which is for sources of nontraditional dust, such as unpaved roads, vacant lots, and unpaved parking lots. And Rule 316, which is nonmetallic mineral processing, which is for mining and sand and gravel operations. So those just give you an idea of the types of sources1
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11 covered by these rules. Compliance with these rules has increased every year since 2007 and that is being measured by the county using a method that was approved by EPA. So we are using the increases in compliance with these three rules to demonstrate five percent reductions per year. And we are also using the new Dust Action General Permit, which I will
talk about in a minute. The other bullet points here- PM-10 certified street sweeping, road/alley/shoulder paving and stabilization projects, speed limit reductions, and rubberized asphalt overlay- are all measures that have been accomplished. In other words, they are projects that have been completed and we are taking credit for those as contingency measures.
Now I mentioned that we have one new measure called the Dust Action General Permit that addresses high wind events. And the Dust Action General Permit identifies best management practices that need to be implemented before and during a high risk event. And ADEQ is going to give the sources-- hopefully up to five days of notice, when a high risk day is going to occur. And then they are going to expect sources that are uncontrolled to implement at least one best management practice before and during that event. The Dust Action General Permit was passed by the legislature in April 2011 and went into full effect on January 1, 2012. Now I am just going to go over briefly what the1
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12 requirements are for a five percent plan under section 189(d) of the Clean Air Act. First of all it requires five percent reductions per year and in our case we are saying attainment is going to be achieved in 2012. So we need to show five percent per year in 2008, 2009, 2010, 2011, and 2012. So if we look at the base year emissions in 2007, it is actually close to 60,000 tons and we multiply that by five percent; that tells us what amount of reduction, about three thousand tons that you need each year for five years. So our target is almost 15 thousand tons, over that period. And you can see from the second bullet point, um, under total PM-10 emissions that we’ve been able to achieve by applying increased rule effectiveness for those three rules, plus the Dust
Action General Permit. We have been able to achieve a reduction to 43,000 tons which means that we exceed the requirement by 1,284 tons or nine percent. So we have been able to meet that five percent reduction requirement. Now I also mentioned that there are measures or projects that have been implemented which will achieve the requirement for contingency. And the Clean Air Act requires this as well and EPA gives you guidance as to how much you should achieve in the way of tonnage reduction and it’s one year of reasonable further progress, which turns out to be about 3,000 tons. And so you need to show that you are reducing 3,000 tons more than you did in order to achieve the five percent reductions. There are quite a few1
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13 projects that have been implemented and I will show you a table in a minute and with all of those projects- which cover paving, stabilization, speed limit reduction, and street sweeping- we are able to achieve 3,400 tons. So, we are 220 tons higher than we need to be to achieve the contingency requirement. Now this slide is just a summary of all of the projects that were completed-- and by the w ay these were all completed by September 2011 so that way we knew they had been open to traffic when we produced this plan. You can see just as a summary the total miles of roads and alleys that have been paved and stabilized over the period of 2008 to 2011 is 862 miles. So quite a lot of mileage has been stabilized and of course that significantly
reduces PM-10. And then the other major statistic here is the total miles of shoulders paved and stabilized over that same period which is 1,158. So between the shoulder and the road paving/stabilization we are able to achieve a very large percentage of what we needed for the contingency requirement. On the next page it shows you that the benefit we took for PM-10 Certified Street Sweeping-- there are really two aspects to this, ADOT signed a contract on February 20, 2010 which requires their contractor that’s sweeping freeways, ramps and frontage roads
in the PM-10 nonattainment area to use PM-10 Certified Street Sweepers. Most of the credit, is due to that, but in addition there were 27 PM-10 Certified Street Sweepers purchased between 2007 and 2009 with Congestion Mitigation Air Quality Improvement1
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14 funds through MAG. Those are being used to sweep arterials in the
PM-10 nonattainment area. Here is another pie chart. Now this one is for 2012 and so I told you to keep in mind what the top two contributors were in
2008 before a lot of these measures were taken into consideration and now we are showing really the highest contributor is paved roads and unpaved roads which was the highest before is now second at 19 percent. So the percentages change, but more importantly the total amount of tons contributed is down almost 10,000, between
2007 and 2012. This is how we are able to achieve the reductions that we need for both five percent per year and contingency. So in conclusion the plan meets the five percent reduction requirement, the contingency requirement,-- something I haven’t talked about is that EPA requires that your plan demonstrate through modeling that you can attain this standard in 2012 as well. There were two days that we modeled, both high PM-10 and high wind days and one was May 4, 2007 and the other June 6,
2007 and we were able to show attainment in 2012 for both of those scenarios using the same measures that we did to show the five percent reductions which is the increase in rule effectiveness and the Dust Action General Permit. So, those things allowed us show attainment through modeling as well as for five percent reductions. Now this plan also includes a request to extend the
attainment date for a little over six months- from June 6, 2012, which is the date that we were required to meet the five year1
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15 extension past 2006. And, we are asking for an extension because the Dust Action General Permit was not implemented fully until January 1, 2012 and we really need a whole year of benefit for the high wind days in order to be able to demonstrate attainment through modeling. So that’s why we are asking for this six month
extension. Now in general the overall reduction as I mentioned is about 10,000 tons which is about a third, versus 2007 emissions. The reductions are due to the broad sweeping measures for many, many sources that were included in this plan. And then perhaps most importantly, the bottom line here, is that we need three years of clean data at the monitors, in 2010, 2011, and 2012 in order to demonstrate attainment in the real world as opposed to through this plan. Of course that is going to be dependent on exceptional event documentation that DEQ is preparing for 2011 and 2012. So EPA will
need to concur with our documentation in order for us to be able to show attainment and we are hopeful that we will not have any more days in the remainder of 2012, but there are a few months left to go. If they are exceptional events that will put a burden again on us to document them. But we will be up to the task. And then finally, this is the schedule that we are under for this plan. The plan was released for public review on March
the 12 thand today is the public hearing. In two weeks we will go to our Air Quality Technical Advisory Committee and ask for a recommendation and then we will be going to the Management1
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16 Committee the first part of May. Assuming those two committees recommend that this plan go forward then the Regional Council will adopt the plan on May 23 rd . And then at that point we turn the plan over to DEQ and they submit the plan to EPA. Two other important dates- August 14 thof 2012 is the deadline, about two and a half months we are going to give EPA to find this plan to be complete. If they do that by this date, then that will stop the sanction clocks that are currently ticking. The 18 month and 24 month sanction clocks are ticking right now because we withdrew the 2007 plan. And then February 14 thof 2013 is the
deadline for EPA to approve the plan, not just find it complete, but approve all the control measures and all the other things that
were fulfilled in the plan in order to avoid EPA developing a federal implementation plan. That completes my overview here and I think we will turn it over to Lindy to entertain comments. MS. BAUER: Okay, Thank you very much, Cathy. And now for the public comment period.

PUBLIC COMMENTS

MS. BAUER: At this time public comments are welcome at the hearing. Again, if you would like to speak, please fill out a speaker form and place it in the box and please adhere to the three minute time limit. We have the speaker forms over here, to1
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17 the left. So first we have a speaker form from Jerry Greenberg. MR. GREENBERG: Hello, my name is Jerry Greenberg and I am from Chandler. Uh, first of all I would like to thank you for all of your hard work, for those of you who have been involved in this; I really appreciate it. Let me tell you a little about who I am and why in the world I am here in the middle of rush hour and everything else to participate in this meeting. I have kind of an interesting background. I am a retired registered nurse. I am also a retired Air Force officer, served our Country during two wars and believe it or not, I was a first responder to both the Oklahoma City bombing and 9/11 at the Pentagon. As a result, my lungs were affected because needless to say none of us were protected against everything that was in the air. Particularly pieces of building, fiberglass, you name it, including literally glass fibers, um, that we all inhaled. As a result, I am kind of sensitive and I had no idea when we moved here from the east coast, in 2007, that perhaps my lung sensitivity would come to the forefront. However, they did. Last, we bought a foreclosed home, sunk a bit of our life savings into it in Chandler in just a regular, nice neighborhood. Last fall, after living in the home for about a year and a half I was having trouble breathing. And so I went to the doctor and they kind of checked me out, did a chest X-ray,1
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18 that kind of thing. On my way back I stopped at the intersection of McClintock and Chandler. It was a little bit windy and I looked over to my right, with, and its all vacant lots on the north of that area and dust was just blowing like crazy right into my neighborhood. And so I thought perhaps-- okay, you know where I am going from there. I looked around and I realized my neighborhood, Twelve Oaks, Stellar Air Park, that neighborhood there is surrounded-- I have one minute left? Okay-- is surrounded by dirt lots. So all of sudden I became interested. I called the City; I called the County, and made formal complaints which were responded to. However, frankly if I kept my front yard like the people keep the vacant lots that they owned, I’d be fined, but yet people are allowed to dump construction dirt on these-- in these lots. They are allowed to dump construction debris. They are allowed to just let it be bare dirt, literally bare dirt, on these lots. And, so, what I would ask of you is why are we coddling these vacant lot owners? The economic recovery is well, you know, going on and another is would you please, maybe you are doing this and I don’t know, monitor residential areas for PM-10 and then report on them. Can I go over just a little bit? I have a new grandson who was born at Chandler Regional Hospital. On the way, on Frye Road, which was at sunset, I saw huge tractor with a plow on the back of it, raising huge clouds of dust half mile from where my grandson is and I called the City1
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19 the next day. They said we’ll talk to him about it and they said he’ll stop doing that. Thank you, he should have known not to do
that and he did it at sunset because he knew that all the offices
were closed. We can’t have that kind of thing going on in a City. Chandler is over 250,000 residents and yet this is the kind of thing that is going on. I can’t speak for Glendale, or any place else, I can only speak for the City I live in and so what I would ask you is, please continue to enforce this. Lobby the State, the Government, to really be stronger on this and help us to grow up as a community, so that it can be healthier. Thank you. MS. BAUER: Thank you very much. Next we have Sandy
Bahr. MS. BAHR: Hi, good afternoon. Thank you for the opportunity to speak this afternoon. My name is Sandy Bahr; I am the Chapter Director for the Sierra Club here in Arizona. And I
live in Phoenix and in the PM-10 nonattainment area and have
lived in the PM-10 nonattainment area ever since there has been
one. Because as far as I know ever since there has been one we
haven’t met the standards. Um, as you know PM-10 has been a serious problem in the Valley for more than two decades and there’s a long history of inadequate plans being submitted and failure to reach attainment. We have raised the issue before about the Maricopa1
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20 Association of Governments not being the right entity for leading this effort. No offense, I know people work really hard, but I think politically it is a difficult place to try to get clean air when the purpose of the organization is really about transportation and facilitating expenditure of federal highway
dollars. A couple of things, specific to-- so that is kind of an overarching comment and I don’t expect that MAG will address that one, but I just wanted to make sure that you were aware that we
continue to have that concern.
One of the issues that I wanted to raise this afternoon is this issue of three years of clean data and the fact that you are looking at seeking to identify 21 of the 22 exceedances for 2011 as exceptional events. Uh, I think by anyone’s common sense definition, when you start having that many exceptional events they fail to be exceptional, and we strongly question that. We have, I know-- probably used most of my time so I’ll try to be quick. We are submitting some written comments. The other thing is this plan is supposed to demonstrate
best available control measures and maximum measures as well and we didn’t see where you had demonstrated that in the plan. And, so, I would love for someone to point that out, but I believe you have to demonstrate in the plan as well. One thing we have raised before, and it just doesn’t make a whole lot of sense-- from just when you think about a1
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21 contingency measure? How can it be a contingency measure if its already implemented. Contingency measures are supposed to be for, you know, if something else doesn’t work, you have a contingency. And what has happened with a lot of previous measures is, we are implementing a contingency and then there is no contingency, right, there is nothing left. And so, we would like to have you take a look at that as well. Finally, we just continue to have concerns about enforcement and I think the gentleman before me raised some of the issues with that and I know that there have been changes relative to the BMP’s for agriculture, but I still think there are good questions about whether those are truly, uh, enforceable and would like to see more information in the plan on that as well. And there are some other issues, but I am out of time. I appreciate the opportunity. Thank you. MS. BAUER: Thank you very much. Do we have any other forms for people wishing to speak? Okay, thank you very much. The Maricopa Association of Governments appreciates your interest in regional air quality and your comments. Your comments will be presented to the MAG Air Quality Technical Advisory Committee at the April 26, 2012 meeting at 1:30 p.m. A response to comments will be prepared and included in the plan documents. Again, we thank you for your participation this evening.1
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22 (The proceedings concluded at approximately 6:05 p.m.)

### MARICOPA ASSOCIATION of 

### GOVERNMENTS**-~30~2~No~rth~1s-t Pl~~~e-nu-e,** **S~uit-e 3~0o~**  ...**~P~hoe~nix~. Ar~iz-ona~B~50~03-­**  Phone [602] 254-6300 A FAX [602] 254-6490 mag@mag.maricopa.gov 

### Meeting: Public Hearing on the MAG 2012 FIVE PERCENT PLAN FOR PM-10
Room: Saguaro Room
Date: April12. 2012

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MARICOPA ASSOCIATION of GOVERNMENTS

PUBLIC HEARING ON THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

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# )4"1 RESPONSE TO PUBLIC COMMENTS ON THE DRAFT MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA APRIL 12, 2012 PUBLIC HEARING The Maricopa Association of Governments (M AG) appreciates the comments made during the public comment period for the Draft MAG 2012 Fi ve Percent Plan for PM-10 for the Maricopa County Nonattainment Area. An advertised public hearing was conducted on April 12, 2012. Verbal testimony was presented at the April 12, 2012 public hearing. One submittal of written comments was received. COMMENTS FROM JERRY GREENBURG (Testimony at the April 12, 2012 public hearing)
Comment : We bought a foreclosed home, sunk a bit of our life savings into it, in Chandler, in just a regular, nice neighborhood. Last fall, after living in the home for about a year and a half I was having trouble breathing. So I went to the doctor and they checked me out, did a chest X-ray, that kind of thing. On my way back I stopped at the intersection of McClintock and Chandler and it was a little bit windy and I looked over to my right and its all vacant lots on the nor th of that area and dust was just blowing like crazy right into my neighborhood. So I thought perhaps, OK, you know where I am going, from there. I looked around and I realized my neighborhood, Twelve Oaks, Stellar Air Park, is surrounded by dirt lots. So all of a sudden I became interested. I called the City, I called the County, and made formal complaints which were responded to. However, frankly, if I kept my front yard like the people keep the vacant lots that they owned, I’d be fined, but yet people are allowed to dump construction dirt on these lots . They are allowed to dump construction debris. They are allowed to just let it be bare dirt, literally bare dirt, on these lots. What I would ask you is, why are we coddling these vacant lot owners? The economic recovery is well going on and another is, would you please, maybe you are doing this and I don’t know, monitor residential areas for PM-10 and then report on them? Response : Thank you for your concern. Fugitive dust produced by vacant lots is regulated under Maricopa County Air Pollution Control Rule 310.01, Fugitive Dust from Non-Traditional Sources of Fugitive Dust. http://www.maricopa.gov/aq/divisions/planning_analysis/rules/docs/310.01.pdf. The Rule requires the owner and/or operator of a vacant lot to keep the soil stabilized at levels that pass tests specified in the rule. A stabilized surface can appear to be bare dirt. Control measures commonly utilized include applying dust suppressants, establishing vegetative ground cover, and covering the surface with gravel. All County Dust Control inspectors have been trai ned to inspect vacant lots and regularly conduct proactive as well as complaint inspections throughout Maricopa County. Between 2008 and 2010, Maricopa County conducted a total of 21,753 vacant lo t inspections. Given the size of the County and the large number of vacant lots, Maric opa County Air Quality Department (MCAQD) encourages residents to call and report any problem vacant lot or dust creating activity such as illegal2 dumping. To report a violati on, call (602)372-2703 or log onto http://www.maricopa.gov/aq/contact_us/ReportViolation.aspx

. Vehicles traveling or parking on vacant lots (e.g., to dump construction dust or debris) are also restricted by both County and local government ordina nces. The City of Chandler has an ordinance that restricts vehicular use and parking on vacant lo ts. If you observe vehicles traveling or parking on vacant lots in your neighborhood, call City of Chandler Code Enforcement at (480) 782-4320. The Maricopa County Air Quality Department operates a monitoring network with a number of monitors sited to measure particulate matter at the neighborhood scale where residents live. Other monitors represent various source types and pr ofiles common in the county such as industrial, commercial, etc. Monitoring data is summarized annually by location in a network review report submitted to the Environmental Protection Agency. In addition, the department prepares an annual report that summarizes its compliance inspection and enforcement activity. Both documents are available on the Maricopa County Air Quality De partment website. The network review reports available at http://www.maricopa.gov/aq/divisions/monitoring/network.aspx and the annual report at http://www.maricopa.gov/AQ/media/docs/pdf/NewsItemDocs/2011%20- %20Annual%20Report.pdf

. Comment : I have a new grandson who was born at Ch andler Regional Hospital. On the way, on Frye Road, at sunset, I saw a huge tractor with a plow on the back of it, raising huge clouds of dust, a half mile from where my grandson is and I called the City the next day. They said they would talk to him about it and they said oh, he’ll stop doing that. Thank you, he should have known not to do that and he did it at sunset because he knew that a ll the offices were closed. We can’t have that kind of thing going on in a City. Chandler is over 250,000 residents and yet this is the kind of thing that is going on. I can’t speak for Glendale, or any place else, I can only speak for the City I live in and so what I would ask you is, please continue to enforce this lobby. The State, the Government, to really be stronger on this and really help us to grow up as a community, so that it can be healthier. Response : The Arizona Department of Environmental Quality (ADEQ) is responsible for controlling dust emissions from agricultural ac tivities in Area A, which includes the Maricopa County PM-10 nonattainment area. Under Senate Bill 1552, passed by the Arizona Legislature in 2007, farmers are required to implement two best management practices (BMPs) to reduce PM-10 emissions in each of the following categories: tillage and harvest, non-cropland, and cropland. Additional informa tion on the BMPs can be obtained at http://www.azdeq.gov/environ/air/ plan/download/webguide.pdf. When you observe high levels of dust being generated by a tractor or vacant par cel that is being farmed, you should call Emily Bonnani, ADEQ, (602) 771-2324, to issue a complaint. COMMENTS FROM SANDY BAHR, SIERRA CLUB IN ARIZONA (Testimony at the April 12, 2012 public hearing)
Comment: We have raised the issue before about the Maricopa Association of Governments not being the right entity for leading th e effort. No offense, I know peopl e work really hard, but I think3 politically it is a difficult place to try to get clean air when the purpose of the organization is really about transportation and facilitating expenditure of federal highway dollars. A couple of things, so that is kind of an overarching comment and I don’t expect that MAG will address that one, but I just wanted to make sure that you were aware that we continue to have that concern. Response: The Maricopa Association of Governments serves as the designated Regional Air Quality Planning Agency for the Maricopa area. The regional air quality plans are prepared through a coordinated effort with the Arizona Department of Environmental Quality, Arizona Department of Transportation, Maricopa County Air Quality Department, and Maricopa Association of Governments. Over time, signi ficant progress has been made to improve air quality due to the implementation of the aggressive measures in the MAG regional air quality plans by the State and local governments. The MAG region has met the federal air quality standard for carbon monoxide. There have been no violations of the carbon monoxide standard since 1996. The Environmental Protection Agency redesignated the Maricopa nonattainment area to attainment for carbon monoxide on April 8, 2005. EPA also approved the MAG Ca rbon Monoxide Redesignation Request and Maintenance Plan, which demonstrated that the standard would be maintained through 2015. The MAG region has met the federal air quality sta ndard for one-hour ozone. There have been no violations of the one-hour ozone standardsince 1996. EPA redesignated the Maricopa nonattainment area to attainment on June 14, 2005. EPA also approved th e MAG One-Hour Ozone Redesignation Request and Maintenance Plan, whic h demonstrated that the standard would be maintained through 2015. The MAG region has met the federal air quality st andard for the 1997 eight-hour ozone standard of 0.08 parts per million. There have been no violations of the 1997 standard since 2004. On April 12, 2012, EPA published a proposed rule to approve the MAG 2007 Eight-Hour Ozone Plan. Regarding the newly implemented, stricter ozone standard of 0.075 parts per million, the region had only one monitor that violated the standard in 2011. The MAG region meets the fine particulate standard for PM-2.5. Regarding PM-10, the Revised MAG 1999 Serious Area Particulate Plan for PM-10 was one of the first in the nation and included 77 aggressive measur es to reduce coarse particulate matter. On July 25, 2002, the Environmental Protection Agency approved the Revised MAG 1999 Serious Area Particulate Plan for PM-10. The plan was heralded by EPA as one of the most comprehensive in the country. Every city and town within the nonattainment area and Maricopa County have implemented dust control measures to reduce PM -10. In addition, the MAG Regional Council has allocated $24.9 million in Congestion Mitigation a nd Air Quality Improvement Funds over the last 12 years to purchase clean, dust-reducing street sweepers. While the MAG 2007 Five Percent Plan for PM-10 was voluntarily withdrawn, the aggressive measures in that plan continue to be impl emented to reduce PM-10. In 2010, there were no4 violations of the PM-10 standard. Again, significant strides have been made to im prove air quality in the MAG region. Air quality is an important issue to the Maricopa Association of Governments.

Comment : One of the issues that I want ed to raise this afternoon is this issue of three years of clean data and the fact that you are looking at seeking to identify 21 of the 22 exceedances for 2011 as exceptional events. I think by anyone’s common sense definition, when you start having that many exceptional events, they fail to be exceptional, and we strongly question that. Response : The EPA Exceptional Event Rule (EER ) became effective on May 21, 2007. The EER allows the ambient air quality data which is submitted to EPA and used in making regulatory decisions, to be flagged and, where appropriate, ex cluded from calculations in determining whether or not an area has attained the standard. The data flagged as “exceptional” must have been affected by an exceptional event, which is defined as an event that affects air quality; is not reasonably controllable or preventable; is an event caused by human activity that is unlikely to recur at a particular location or a natural event; and is determined by the EPA in accordance with 40CFR 50.14 to be an exceptional event. In order for PM-10 monitoring data on an exceedance day to be excluded from the attainment calculations for the nonattainment area, ADEQ must prepare documentation that meets requirements of the EER and receives approval from EPA. For the Maricopa County PM-10 nonattainment area, exceptional events are generally caused by high winds. In 2010, there was only one exceedance of the PM-10 standard at one monitor in the nonattainment area, which did not occur on a windy day. In 2011, the PM-10 standard was exceeded on 21 of 22 days during either strong frontal system winds or summer monsoon thunderstorm outflows. The summer thunderstorm outflows produced dust storms (haboobs) that were so unusual that they received national media attention (e.g., July 5, 2011). ADEQ is in the process of preparing documentation that meets EER requirements and justifies that the 21 exceedances were unavoidable due to the uncontrollable meteorological conditions that occurred during 2011. Additionally, while crafting the EER, EPA acknowle dged that natural events like high winds need not be rare in order to qualify as an exceptional event, “It is important to note that natural events, which are one form of exceptional events according to this definition, may recur, sometimes frequently (e.g. western wildfires)” (72 FR 13563). The fact th at 2011 had an unusually high amount of dust storms does not preclude those dust storms from being considered as exceptional events under the current definition of exceptional events in EPA’s EER.
Comment : The other thing is this plan is supposed to demonstrate best available control measures and maximum measures as well and we didn’t see where you had demonstrated that in the plan. And so, I would love for someone to point that out , but I believe you have to demonstrate in the plan as well.5 Response : The MAG 2012 Five Percent Plan for PM-10 is designed to meet the requirements in Section 189(d) of the Clean Air Act. Section 189(d) indicates that “In the case of a Serious PM-10 nonattainment area in which the PM-10 standard is not attained by the applicable attainment date, the State in which such area is located shall, after notice and opportunity for public comment, submit within 12 months after the applicable attainment date, plan revisions which provide for attainment of the PM-10 air quality standard and, from the da te of submission until attainment, for an annual reduction in PM-10 or PM-10 precursor emissions w ithin the area of not less than 5 percent of the amount of such emissions as reported in the most recent inventory for such area.” The Best Available Control Measure (BACM) a nd Most Stringent Measure (MSM) demonstrations are required under Section 189(b)(1) and 188(e) of the Clean Air Act. The MAG 2012 Five Percent Plan for PM-10 includes control measures above and beyond the measures in the Revised MAG 1999 Serious Area Plan for PM-10, which addressed the BACM/MSM requirements. On July 25, 2002, the Environmental Protection Agency approved the Revised MAG 1999 Serious Area Plan for PM-10 that included the BACM/MSM demonstrations. On August 14, 2008, EPA again took final action to approve the Best Av ailable Control Measure and the Most Stringent Measure demonstrations in the Revised MAG 1999 Serious Area Plan for PM-10 for the Maricopa County Nonattainment Area (see 73 FR 47542).
Comment : One thing we have raised before, and it just doesn’t make a whole lot of sense - from just when you think about a contingency measure. How can it be a contingency measure if it’s already implemented? Contingency measures are supposed to be for, you know, if something else doesn’t work, you have a contingency. And what has happene d with a lot of previous measures is, we are implementing a contingency and then there is no c ontingency, right, there is nothing left. And so, we would like to have you take a look at that as well. Response : Section 172(c)(9) of the Clean Air Act requires that nonattainment plans contain contingency measures. Such measures are to be undertaken without further action by the State or the EPA Administrator if the area fails to make r easonable further progress or meet the standard by the attainment date. EPA encourages early implementation of contingency measures to reduce emissions as expeditiously as practicable. (See EPA, Early Implementation of Contingency Measures for Ozone and Carbon Monoxide (CO) Nonattainment Areas, August 13, 1993.) The contingency requirement is met in the MAG 2012 Five Percent Plan by quantifying the benefits of PM-10 reduction projects that were implemented early (i.e., in 2008-2011). These projects included PM-10 certified street sweeping of freew ays and arterials; paving and stabilizing unpaved roads, alleys and shoulders; reducing speed limits on unpaved roads and alleys; and overlaying state highways with rubberized asphalt. It is important to note that there were many other measures in the MAG 2007 Five Percent Plan that have been implemented, for which no credit is taken in the MAG 2012 Five Percent Plan. These additional measur es will also assist the area in demonstrating attainment at all monitors by 2012.
Comment : Finally, we just continue to have concerns about enforcement and I think the gentleman6 before me raised some of the issues with that and I know that there have been changes relative to the BMPs for agriculture, but I still think there are good questions about whether those are truly enforceable and would like to see more information in the plan on that as well. Response : The Arizona Department of Environmen tal Quality (ADEQ) is responsible for controlling dust emissions from agricultural ac tivities in Area A, which includes the Maricopa County PM-10 nonattainment area. Under Senate Bill 1552, passed by the Arizona Legislature in 2007, farmers are required to implement two best management practices (BMPs) to reduce PM-10 emissions in each of the following categories: tillage and harvest, non-cropland, and cropland. Additional information on agricultural BMPs is available at http://www.azdeq.gov/environ/air/ plan/download/webguide.pdf. For more information on enforcement of agricultural BMPs, contact Emily Bonnani at ADEQ, (602) 771-2324.
COMMENTS FROM THE ARIZONA CENTER FOR LAW IN THE PUBLIC INTEREST (Letter from Joy E. Herr-Cardillo dated April 12, 2012)
1. BACM and MSM
Comment : As a serious nonattainment area for PM-10, the Phoenix area plan must include BACM for all significant sources of PM-10 and PM-10 precu rsors. BACM, best available control measures, are the maximum degree of emissions reductions possible after considering technical and economic feasibility and environmental impacts of the contro l. These must be implemented independent of attainment requirements. Also, because Phoenix obtained a five year extension of its attainment deadline, its plan must include MSM (most stringe nt measures). In the General Preamble (59 FR 41998), EPA sets forth a multi-step process for id entifying BACM/BACT for serious areas. The proposed 5% plan does not include a BACM or MSM demonstration that follows this process, therefore, it is initially difficult to even determine whether the plan satisfies the BACM/MSM requirement. The state cannot rely upon the BACM /MSM demonstrations in the 1999 Serious Area SIP, as that demonstration was prepared more th an ten years ago, and, as the EPA recognized in its proposed disapproval of the 2007 Draft 5% Plan, cont rol measures that previously satisfied the BACM requirement, may no longer represent the “best available” control measure. See, 75 FR 54806, 54812. Therefore, an updated BACM/MSM analysis should be included in the 5% plan. Response : The MAG 2012 Five Percent Plan for PM- 10 is designed to meet the requirements in Section 189(d) of the Clean Air Act. Section 189(d) indicates that “In the case of a Serious PM-10 nonattainment area in which the PM-10 standard is not attained by the applicable attainment date, the State in which such area is located shall, after notice and opportunity for public comment, submit within 12 months after the applicable attainment date, plan revisions which provide for attainment of the PM-10 air quality standard and, from the da te of submission until attainment, for an annual reduction in PM-10 or PM-10 precursor emissions w ithin the area of not less than 5 percent of the amount of such emissions as reported in the most recent inventory for such area.” The Best Available Control Measure (BACM) a nd Most Stringent Measure (MSM) demonstrations are required under Section 189(b)(1) and 188(e) of the Clean Air Act. The MAG 2012 Five Percent7 Plan for PM-10 includes control measures above and beyond the measures in the Revised MAG 1999 Serious Area Plan for PM-10, which addressed the BACM/MSM requirements. On July 25, 2002, the Environmental Protection Agency approved the Revised MAG 1999 Serious Area Plan for PM-10 that included the BACM/MSM demonstrations. On August 14, 2008, EPA again took final action to approve the Best Av ailable Control Measure and the Most Stringent Measure demonstrations in the Revised MAG 1999 Serious Area Plan for PM-10 for the Maricopa County Nonattainment Area (see 73 FR 47542).

2. 2008 PM-10 Emissions Inventory
Comment : In its proposed disapproval of the 2007 Draft 5% Plan, EPA found that the 2005 emissions inventory relied upon by the state to be insufficiently accurate because it overestimated the baseline emissions for construction and other sources. See 75 FR 54808. In the current plan, MAG is relying upon a 2008 periodic emissions inventory which, like the 2005 inventory, was prepared by Maricopa County Air Quality Department . At first glance, this more recent inventory appears to address EPA’s concerns as it shows emissions from residential construction to be a smaller percentage of the overall emissions. Howe ver, a comparison of the two inventories (and the two draft plans) reveals a discrepancy that MAG does no appear to either acknowledge or explain, and that is drastic reductions in the estimated emissions overall. In the 2005 inventory, total PM-10 emissions in the nonattainment area were calculate d to be 84,753 tons per y ear. The 2008 inventory puts that total at 48,148 tons per year - a reduction of more than 40% in just three years. It seems highly unlikely that the area achieved such a reduction in emissions by the implementation of control measures. As noted above, we did not see anywhere in the plan where this huge disparity in the data was acknowledged or explained. This oversight s hould be addressed,. Also, because the inventory is the principal basis for calculating the 5% annual reduction required under the CAA, it is important to the public health that the amount of current emissions are not understated. Response : The 2008 PM-10 Periodic Emissions Inventory for the Maricopa County, Arizona, Nonattainment Area was revised by the Maricopa County Air Quality Department (MCAQD) to address EPA concerns about the 2005 PM-10 Periodi c Emission Inventory (PEI) expressed in the proposed partial approval and disapproval of th e MAG 2007 Five Percent Plan published by EPA on September 9, 2010. (See 75 FR 54808.) MCAQD and EPA staff worked together to revise the 2008 PEI finalized in June 2011. In accordance w ith EPA guidance, MAG used the revised 2008 PEI as the basis for developing 2007-2012 emissions for the Draft MAG 2012 Five Percent Plan. Ninety-two percent of the reduction in total PM -10 emissions from 84,753 t ons per year in the 2005 PEI to 48,148 tons per year in the revised 2008 PEI can be attributed to four factors: (1) a decrease in the number of acres permitted for construc tion activities and increases in compliance with Maricopa County Rule 310, (2) a reduction in the mate rial burned by wild fires, (3) annual variations in meteorological data and use of a new a nd improved methodology to estimate windblown dust emissions, and (4) decreases in PM-10 emissions frompaved roads due to application of a new AP42 equation released by EPA in January 2011. Each of these factors is discussed in more detail8 below. (1) One reason for the reduction in PM-10 emissions between 2005 and 2008 is the significant decline in construction activity that took place during that period. In 2005, MCAQD issued construction permits for 68,664 acres in Maricopa County; in 2008, this number was reduced to 42,130 acres, a 39 percent decline in three years. In addition, to address EPA concerns (in 75 FR 54808) regarding potential overestimation of PM-10 emissions from construction activities, MCAQD staff worked closely with EPA to improve the methodology used to quantify rule effectiveness (i.e., compliance with Maricopa County dust control rules). (See Appendix 3 of the revised 2008 PEI c ontained in Appendix A, Exhibit 1 of the Draft MAG 2012 Five Percent Plan.) The new methodology developed in concert with EPA is used in the revised 2008 PEI, as well as the Draft MAG 2012 Five Percent Plan, to estimate rule effectiveness for Rule 310 (Fugitive Dust from Dust-Generating Operations), Rule 301.01 (Fugitive Dust from Non-Traditional Sources of Fugitive Dust), and Rule 316 (Nonmetallic Mineral Processing). Table 5-1 in the Draft MAG 2012 Five Percent Plan shows the new rule effectiveness rates that were calculated for 2007 through 2010 us ing the new methodology and actual compliance data. The rule effectiveness rate for construction activities in the 2005 PEI was 51 percent; using the new methodology, the rule effectiveness ratefor construction activities in the 2008 PEI is 90 percent. This represents a 76 percent increas e in compliance with Rule 310 between 2005 and 2008. Due to the 39 percent reduction in construction activ ity and 76 percent increase in rule effectiveness, the PM-10 emissions from construction activities in 2005, 32,130 tons, declines to 7,964 tons in 2008, a 75 percent reduction. This reduction of 24,166 tons per year represents the largest proportion (66 percent) of the decrease in to tal PM-10 emissions (36,605 tons) between 2005 and 2008. (2) In the 2005 PEI, wild fires produced 4,860 tons of PM-10 emissions based on 345,909 tons of material burned within the nonattainment area. In the 2008 PEI, the comparable values for wild fires are 424 tons of PM-10 emissions based on 33,479 tons of material burned. Due to the significant reduction in material burned in the nonattainme nt area between 2005 and 2008, the PM-10 emissions for wild fires are 91 percent lower in the 2008 PEI. This reduction of 4,436 tons explains another 12 percent of the decrease in total PM-10 emissions between 2005 and 2008. (3) Windblown dust PM-10 emissions in the 2005 PEI are 7,380 tons for the nonattainment area, compared with 4,815 tons in the 2008 PEI. MCAQD contracted with ENVIRON to estimate windblown dust emissions for the 2005 PEI. ENVIRON applied the windblown dust emissions model developed by the Western Regional Air Partnership (WRAP) to 2004 land use and 2005 meteorological data for Maricopa County. Th e ENVIRON methodology is documented in Appendix 3.2 of the 2005 PEI. For the revised 2008 PEI, MAG developed a ne w PM-10 emissions estimation methodology using the latest scientific research on windblown dust inthe arid southwest. (See Appendix 4 of the revised 2008 PEI contained in Appendix A, Exhib it 1 of the Draft MAG 2012 Five Percent Plan.)9 The methodology uses local data from observed wi ndblown dust events, combined with empirical data from wind tunnel studies performed in the deserts of the southwest. The windblown dust estimates in the 2008 PEI are based on 2008 wind speed and precipitation data from 34 meteorological stations and the most recent land use data (2009) available for the nonattainment area. The new methodology produces a more accura te estimate of the contribution of windblown dust to the 2008 PEI. The 35 percent reduction in PM-10 emissions from windblown dust between 2005 and 2008 can be attributed to the use of different methodologies, as well as different land use and meteorological data for these years. The 2,565 ton reduction in 2008 repres ents seven percent of the decrease in total PM-10 emissions between 2005 and 2008. (4) In January 2011, EPA released a new version of the AP-42 equation that estimates particulate emissions from vehicles traveling on paved ro ads. The new equation is documented in EPA, Emission Factor Documentation for AP-42, Section 13.2.1, Paved Roads , January 2011. The paved road PM-10 emissions in the revised 2008 PEI were developed using this new equation. Application of the previous AP-42 equation (November, 2006) for the 2005 PEI resulted in paved road PM-10 emissions of 13,783 tons for the nonattainment area; paved road emissions estimated with the new AP-42 equation are 6,694 tons, a reduction of 51 percent in the 2008 PEI. The reduction in paved road PM-10 emissions of 7,089 tons in the 2008 PEI is partially offset by increases in emissions from exhaust, tire wear, brake wear, and vehicles traveling on unpaved roads. The exhaust, tire wear and brake wear emissions are 1,404 tons higher in 2008, due to use of the new EPA MOVES2010a mobile source emissions model, rather than the EPA MOBILE6.2 model used in the 2005 PEI. In the 2008 PEI, unpaved road PM-10 emissions are also 3,221 tons higher, due to use of updated information collected on unpaved roads and alleys. Overall, PM-10 emissions from all onroad mobile sources are reduced fr om 24,013 tons in the 2005 PEI to 21,549 tons in the 2008 PEI. This net decline of 2,464 tons represents seven percent of the decrease in total PM-10 emissions between 2005 and 2008. The sum of the emission reductions discussed in (1) through (4) above is 33,631 tons, which represents 92 percent of the total decrease in PM-10 emissions between 2005 and 2008. The remaining eight percent reduction can be attributed to factors such as increased rule effectiveness for Rules 310.01 and 316 and decreased industrial activity, due to the economic recession that commenced in 2008. The factors described above (decline in construction activity, increased compliance with Rule 310, reduced impact of wild fires, improved windblown dust methodology using 2008 meteorological and 2009 land use data, and the new EPA paved road dust equation) explain the reduced emissions in the 2008 PEI and reinforce the accuracy of the 2008 PM-10 emissions used as the basis for the Draft MAG 2012 Five Percent Plan. It is also important to note that the calculation of annual five percent reductions in the Draft MAG 2012 Five Percent Plan is based on 2007 base case emissions of 59,218 tons per year, which are 23 percent higher than the 2008 emissions of 48,148 tons per year in the revised 2008 PEI. (See Page ES-2 and Table ES-1 in the Draft MAG 2012 Five Percent Plan.) Therefore, the five percent10 reductions calculated in the Draft MAG 2012 Five Percent Plan are not understated. 3. Reliance upon EPA’s Concurrence Regarding Exceedances Claimed As Exceptional Events:
Comment: We are concerned that the attainment demonstration in the 2012 5% Plan, like the 2007 5% Plan, relies upon the concurrence by EPA re garding exceptional events. As the plan acknowledges there were 7 exceedances in 2009 alone th at must be treated as exceptional events in order for the area to meet the extended attainment deadline. Further, although the 2011 data has not yet been finalized, the initial data indicates that there [sic] once again a significant number of exceedances over multiple days and multiple monitors . The likelihood of eliminating all of these exceedances as exceptional events would appear both remote and contrary to the public interest. Therefore, we believe that a plan that proposes to achieve “attainment” simply by whitewashing over severely unhealthful conditions is both irresponsible and contrary to the public interest. Response : Section 319(b)(2) of the Clean Air Act re quired EPA to publish and finalize regulations governing the review and handling of air quality m onitoring data influenced by exceptional events. In establishing the requirement, Congress provided EPA with a definition of exceptional event that recognized that not all episodes of air pollu tion can be controlled or prevented by means of implementing the Clean Air Act. Specifically, S ection 319(a)(1)(A) defined the term exceptional event to include, among other things, those ev ents that are not “reasonably controllable or preventable” or are “...an event caused by human activity that is unlikely to recur at a particular location or a natural event”. On March 22, 2007, EPA adopted the Exceptional Even ts Rule, codified in Code of Federal Regulations, Title 40, Parts 50 and 51. In the implementing rules, EPA allows States to request the exclusion of data showing exceedances or violations of the national ambient air quality standard that are directly the result of an ex ceptional event, provided the State submits a demonstration justifying the exclusion of the data. All such demonstrations must undergo public comment prior to submission for concurrence by EPA. Section 110 of the Clean Air Act requires all State Implementation Plans (SIPs) to address reasonably controllable sources of air pollution, as well as any reasonably controllable or preventable activities. Through the developmen t of the proposed 5% Plan, ADEQ, MAG and MCAQD have evaluated the exceedances that o ccurred in 2009 and 2011, and have compared them to the requirements in EPA’s Exceptional Events Rule, as well as EPA’s Draft 2011 Exceptional Events Guidance document. Based upon that analysis it was concluded that the overwhelming majority of exceedances that occurred during 2009 and 2011 were the direct result of events that could not be prevented or that overwhelmed th e controls required by the existing non-attainment area plans. On March 14, 2012, after 30 days of public comment and in accordance with EPA’s Exceptional Event Rule and Draft 2011 Exceptional Events Guidance document ADEQ submitted to EPA11 documentation demonstrating that the PM-10 exceed ances recorded between July 2 and July 8, 2011, were the result of exceptional events that were not preventable or were beyond any reasonable control. EPA’s decision regarding this documen tation is expected by July 2012. Based on the submitted analysis, the similarity of other 2011 exceedances to those observed between July 2 through 8, and a review of the likelihood of EP A concurrence under both the Exceptional Events Rule and the Draft 2011 Exceptional Events Guid ance, ADEQ, MCAQD, and MAG have concluded that there is a relatively low risk of nonconcurrence. Finally, recognizing that the public is still exposed to these high concentrations of PM-10, regardless if they are reasonably preventable or controllabl e, ADEQ is required by Ar izona Revised Statute § 49-424(11) to develop and disseminate air quality dust forecasts for the Maricopa County PM-10 nonattainment area. These forecasts are required to identify the risk of dust generation for the next five consecutive days, and must be posted, at a mi nimum, on ADEQ’s web site, five days each week. In addition to the dust forecasts, ADEQ also publishe s a forecast that predicts the air quality index for the upcoming days, and issues health watc hes or high pollution advisories on days where exceedances of the PM-10 standard are expected to occur. ADEQ has taken the additional step of making these forecasts available to any interested party via electronic mail. To sign up for these or other ADEQ issued forecasts, please visit https://public.govdelivery.com/accounts/AZDEQ/subscriber/new

. 4. General Permit BMPs and Agricultural Permit BMPs : Comment : While we generally support the adoption of the general permit requirement for all dust generating activities and the increased stringency of the agricultural permit requirements, the plan does not adequately demonstrate that either of these control measures satisfy the BACM and MSM requirement. The plan did not mention the concerns raised by EPA in its proposed rulemaking in 2010 regarding the agricultural BMPs or indicate whether or how these concerns have been addressed. Response : As part of the stakeholder process for th is revision to the State Implementation Plan, ADEQ, MCAQD and MAG analyzed the conditions under which Maricopa County’s PM-10 exceedances occurred. Since 2007, the most common factor associated with PM-10 exceedances in Maricopa County was elevated wind speed. Inreviewing other PM-10 control programs, ADEQ, MCAQD and MAG were unable to identify anot her comprehensive SIP program that was specifically designed to control dust on days with high winds. As a result, a new, innovative method for controlling dust was required. ADEQ agreed to legislation that requires the Depart ment to issue a pollution forecast that identifies the risk of dust generation on subsequent days. Based upon ADEQ’s forecast, all owners or operators of dust generating activities within Maricopa County are required to implement air pollution controls as soon as practicable before a nd during a day forecast to be at high risk of dust generation. Those owners and operators that already have an air quality permit are required to continue complying with the conditions of their permit on those days. If the owner or operator of12 the dust generating activity did not require an ai r quality permit, ADEQ was given the authority to require these owners or operators to obtain a DustAction General Permit. The controls that were included in the Dust Action General Permit build upon the existing Best Available Control Measure (BACM) requirements of MCAQD Rule 310 thatwas approved into the Arizona State Implementation Plan on July 25, 2002 (at 67 FR 48716). In addition to these controls, the permit also adds additional monitoring, record keeping and reporting requirements that enhance the enforceability of these control measures. Because there is no other program in the Country that is similar to the Dust Action General Permit, the control measure is being submitted in accordance with EPA’s September 2004 guidance entitled Incorporating Emerging and Voluntary Measures in a State Implementation Plan (SIP) , and there are no benchmarks for it. This plan is being submitted pursuant to Clean Air Act § 189(d) which provides for annual emission reductions of 5% until attainment is demonstrated. This plan includes a commitment to evaluate the effectiveness of MCAQD Rule 310.01 in calendar y ear 2013. If the evaluation does not result in sufficient emissions reductions, ADEQ has committe d to submitting a SIP revision that contains replacement measures to reduce PM 10 emissions by an amount equal to or more than the total PM 10 emissions reductions that were not achieved by these measures. With respect to the Agricultural Best Management Practices (Ag BMP) program, portions of the current program have already been approved into the SIP and those commitments remain on-going. This Section 189 plan did not rely on any im provements to the previously approved Ag BMP program to achieve the required annual 5% emissions reductions or to demonstrate that the plan results in attainment. As a result, the improve ments that were made to the program in 2007, 2009, 2010 and in 2011, have not been included as part of this SIP revision. In 2009 and 2010, the statutes authorizing the Ag BM P program have changed such that after June 1, 2009, this program automatically becomes effective in all areas that are re-designated as moderateor serious nonattainment for PM-10. Operations subject to the program in areas that are redesignated as moderate nonattainment are required to apply at least one BMP in each applicable category, whereas operations in ar eas that are re-designated as serious nonattainment are required to apply at least two BMPs in each applicable category. Because of the statewide applicability of this program, the Arizona Depart ment of Environmental Quality will submit the program as a separate, independent revision to the State Implementation Plan. 5. Enforceability of Control Measures:
Comment: We have concerns about the enforceability of control measures in the plan. As you know, citizen enforcement is encouraged under the Cl ean Air Act. However, in recent years, when citizens have brought actions to enforce control measures that the state is responsible for implementing, the state has invoked the Eleventh Ame ndment in an effort to avoid the enforcement of its obligation to comply with the SIP. See Paisley v. Brewer , CV2:10-cv-01253-DGC (D.Ariz.) and Sweat v. Hull , 200 F. Supp. 2d. 1162 (D. Ariz. 2001). Although the defense did not preclude injunctive relief in either case, it unnecessarily pr otracted the litigation and demonstrated the lack13 of commitment on the part of the state to fulf illing its obligation under the SIP. Therefore, we believe that where the state or one of its subdivi sions (i.e., a county) assumes responsibility for the implementation of specific control measures, the commitment should include an unequivocal consent to federal jurisdiction if enforcement is sought under the citizen suit provision. This consent will ensure that the measures are fully enfor ceable by both EPA and affected citizens, as the enforcement scheme adopted by the Act contemplates. Response : As noted in the comment, the legal strategy employed by Arizona did not preclude injunctive relief and it did not affect the enforceability of the SIP by either EPA or affected citizens. Because the merits of each lawsuit must be revi ewed on a case-by-case basis, the response to the lawsuit must address the merits of each case, and the defense strategy in question did not affect the enforceability of the SIP, it is not prudent to unnecessarily limit future defense strategies.
6. Technical Issues and Concerns : GENERAL
Editorial Comments:
Comment : • The report provides very limited examples and few calculations to support the reported values. • The report is also lacking equations to support reported values. • The reported values are in a variety of units, which makes comparisons difficult. Response : The technical analyses conducted to support the attainment demonstration in the Draft MAG 2012 Five Percent Plan for PM-10 were pe rformed by MAG, with assistance from Sierra Research. Some of the calculations and equations used to perform the rollback modeling for the attainment demonstration were too voluminous to be included in the Draft Plan. However, all of the technical assumptions, equations and reported values documented in the Draft MAG 2012 Five Percent Plan have been reviewed by and received concurrence from EPA and other members of the 5% PM-10 Plan Technical Committee. The 5% PM-10 Plan Technical Committee was formed by the Arizona Department of Environmental Quality (ADEQ) in response to a stakeholder meeting conducted on February 8, 2011. The meeting was held to discuss the withdrawal of the MAG 2007 Five Percent Plan for PM10 for the Maricopa County Nonattainment Area and to allow EPA to directly discuss what portions of the 5% Plan required additional work in order to be consider ed an approvable plan. During the meeting it was determined that a technical workgroup comprise d of members from ADEQ, the Maricopa County Air Quality Department, the Maricopa Associa tion of Governments and the U.S. EPA would be formed to meet on Wednesday of every other week. The first meeting of the 5% PM-10 Plan Technical Committee occurred on February 9, 2011.14 The stated mission and purpose of the Maricopa5% PM-10 Plan Technical Committee was to provide technical work to support a SIP submissi on to EPA by January 2012; investigate and resolve stated plan deficiencies and support improvements in emission inventories, exceptional event documentation and conceptual model of air quality problem/control measures.
The 5% PM-10 Plan Technical Committee met more than twenty times to review technical work related to the revised 2008 PM-10 emissions inve ntory, exceptional events documentation, the Dust Action General Permit, and the modeling assump tions and protocol fo r the Draft MAG 2012 FivePercent Plan. The Technical Support Document for the Draft Plan describes the Committeeendorsed modeling methodology that demonstrates attainment of the PM-10 standard in 2012.
MODELING
Model Selection:
Comment : • The air quality modeling demonstration for the 24-hour PM10 standard is based on U.S. EPA’s rollback modeling method. Federal regulations state that “all applications of air quality modeling involved in this subpart shall be based on the applicable models, data bases, and other requirements specified in appendix W of this part (Guideline on Air Quality Models).” 40 CFR Part 51.160(f). • Appendix W section 5.2.2.2 PM10; “Refined models such as those discussed in subsection 4.2.2 are recommended for PM-10.” • Appendix W Section 4.2.2(b) Refined Analyti cal Techniques: “For a wide range of regulatory applications in all types of terrain, the recommended model is AERMOD.” • Appendix W Section 5.2.2.2(e): “Due to the diffi cult nature of characterizing and modeling fugitive dust and fugitive emissions, it is recommended that the proposed procedure be cleared by the Regional Office for each specific situation before the modeling exercise is begun.” • The rollback approach is not one of U.S. EPA’s preferred methods for demonstrating attainment of the PM10 NAAQS Response : Use of distance-weighted rollback was clear ed by staff from EPA Region IX before the modeling exercise for the Draft M AG 2012 Five Percent Plan began. As discussed in the previous response to the editorial comments, EPA was an active member in the 5% PM-10 Plan Technical Committee and reviewed all of the technical assumptions and methods to be used prior to the commencement of attainment modeling for the draft Plan.15 In an August 5, 2011 e-mail from Greg Nudd, EPA, to the 5% PM-10 Plan Technical Committee, Scott Bohning, EPA, provided the following comments on the Draft Conceptual Model for Demonstrating PM-10 Attainment document, July 25, 2011: “The chosen distance-weighted rollback seems like a good approach. It gets the main bene fit of dispersion modeling over simple rollback in that it accounts for source distance from the monitor, but with less work and without the misleading precision that can accompany dispersion modeling of fugitive dust. Back-trajectories along with judgement based on available wind speed and dir ection measurements are a reasonable basis for choosing the emission inventory domain.” Although AERMOD was used to model attainment in the MAG 2007 Five Percent Plan for PM-10,EPA’s preferred model for demonstrating attainment in the replacement 2012 Plan is distanceweighted rollback, rather than AERMOD. In addition to model selection, EPA provided other technical recommendations that are reflected in th e attainment modeling described in Chapter V of the Technical Support Document in Appendix B, E xhibit 1 of the Draft MAG 2012 Five Percent Plan. Weighted Rollback:
Comment : The report does not present any of the ro llback questions used so it is unclear which rollback method was used. Response : The calculations made using the rollback model are better understood through stepwise text descriptions rather than by a single or set of equations. The steps used in the weighted rollback model used in the 2012 Five Percent Plan are described as follows: 1. Determine the hourly concentrations recorded at the designated monitoring station on the design day. 2. Parse the hourly concentrations into high wind and low wind bins. 3. Determine the background PM 10 concentration for the design day. High Wind Hours (Baseline Year): 4. Plot hourly back-trajectories for each high wind hour using the 5-minute meteorological data recorded at the designated monitoring station. 5. From a GIS land use database, extract the la nd use designations and coordinates of each 10- acre grid cell within 1 mile laterally of the back-trajectory path. 6. For each 5-minute segment of a high wind hour, use the average measured windspeed to calculate the emissions for each of 11 land use classes and 2 disturbance states (disturbed and undisturbed) and then sum the 5-minute contributions to derive an hourly emission rate for each land use and disturbance state.16 7. For each 10-acre grid cell, apply the appropriate hourly emission rate and then divide by the distance in feet between the grid cell and th e monitor to calculate the distance-weighted emission rate for that parcel. 8. Sum over all of the 10-acre grid cells in the hourly modeling domain to compute total distance-weighted emissions for that hour and domain. High Wind Hours (Attainment Year): 9. Apply the appropriate reduction factor by land use and disturbance state to the emissions from each 10-acre grid cell. Divide the resulting emissions by the distance to the monitor to calculate the attainment year distance-weighted emissions for each grid cell. 10. Sum over of the 10-acre grid cells to compute total distance-weighted emissions for that hour and domain. High Wind Hour Reduction Factor: 11. Divide each hour’s Attainment Year total distance-weighed emissions by the appropriate baseline year total distance-weighted emissions and subtract these fractions from one to compute the high wind hourly reduction factors. 12. Compute the attainment year high wind hour PM 10 concentration at the monitor by subtracting the background concentration from the baseline year high wind hour concentration, multiply this result by the appropriate high wind hour reduction factor, and add this result to the background concentration. Low Wind Hours (Baseline Year): 13. Compute annual ton/acre PM 10 emission rates by dividing nonattainment area-wide land usespecific annual emissions by total acres devoted to that land use to derive annual ton/acre emission rates by land use. 14. Extract total acres per land use within th e low wind modeling domai n from a GIS land use database. 15. Multiply total acres per land use by the appropriate annual emission rate to derive total annual emissions per land use type in the low wind modeling domain. Sum over all land uses to derive total annual baseline emissions within the low wind modeling domain. Low Wind Hours (Attainment Year):17 16. Apply land use-specific reduction factors to appropriate annual baseline emissions by land use to derive total attainment year emissi ons by land use category in the low wind modeling domain. Sum over all land uses to compute tota l annual attainment year emissions with the low wind modeling domain.
Low Wind Hour Reduction Factor: 17. Divide the annual attainment year domain-wide emissions by the annual baseline year domain-wide emissions and subtract from one to determine the low wind hour reduction factor. 18. Compute the attainment low wind hour PM10 concentration at the monitor by subtracting the background concentration from the baselin e year low wind hour concentration, multiply this result by the appropriate low wind hour reduction factor, and add this result to the background concentration. Design Day Attainment Year PM10 Concentration: 19. Sum over all high and low wi nd hourly attainment year PM 10 concentrations to determine the attainment year 24-hour PM 10 concentration for the design day. The basic equations for high wind and low wind hour PM10 concentrations are: For a high wind hour: C future= ((C baseline– C background ) * (1 – HW reduction )) + C background For a low wind hour: C future= ((C baseline– C background ) * (1 – LWreduction )) + C background where: C = PM 10 concentration, ug/m3 HW = percent high wind reduction, LW = percent low wind reduction. This methodology is described in more detail on p. V-62 to V-78 in Appendix B, Exhibit 1.
Comment : If the analysis is based on the modified rollback method, was a spatial distribution analysis performed? Response : A spatial analysis was performed when the reductions in distance-weighted emissionswere evaluated for high wind hours on the June 6, 2007 design day. For each high wind hour, backtrajectories were plotted, and emissions per gridcell in the back-trajectory modeling domain were calculated. Control factors applicable to individual land uses in the attainment year, 2012, were applied to 2007 baseline emissions. Baseline and horizon year emissions for each grid cell were adjusted by the distance-related weighting factorand then summed over the entire back-trajectory to arrive at total distance-weighted emissions. The overall fractional reductions in emissions were1 Rollback Modeling Basic and Modified, Air Wast e Management Association 25:9 (September 1975)

18 calculated for each high wind hour, and the results were presented in Table V-31 of Appendix B, Exhibit 1. The results in percent reduction of weighted emissions shown in this table for each high wind hour cluster remarkably closely. During the June 6 thdesign day, wind directions measured at the West 43 rdAvenue station varied from 220° to 255°, resu lting in corresponding variations in fractional land uses between each hourly back-trajectory. Regard less of these differences, the resulting fractional reductions in weighted emissions varied by less than 12%, from a low of 33.2% to a high of 37.1%. This result demonstrates that reductions in concentrations measured at the monitoring station are relatively independent of wind azimuth – and acco mpanying emission source spatial distribution - during high wind hours.
Comment : In appendices Volume 2 p. V-5, under the We ighted Rollback section, the report states: “The reduction factor is calculated on the basi s of the distance between each source and the impacted monitoring site” • Please provide the equation(s) used for the weighted rollback analysis. Based on the statement above, it is not clear how MAG ha s calculated the emissions weighting. The equations 1 used in EPA’s proportional or modified rollback method do not involve any interactions among individual sources, only each individual source and a monitor. Response : Please see the Response to the first Weighted Rollback Comment above.
Comment : Rollback typically requires speciated prof iles of soil dust from ambient measurements and chemical analysis for sour ce apportionment calculations, using CMB (Chemical Mass Balance). Did MAG use any source profiles to support the mode ling analysis? Please refer to “Guidelines to Sampling and Analysis Applicable to Receptor Modeling” Response : The first sentence of the referenced report states “Chemical characterization of suspended particles is necessary, along with the application of receptor models to apportion ambient concentrations to their sources for the development of emission reduction strategies.” The methods outlined in the report are designed to guide the co llection and chemical characterization of ambient aerosol samples. The role of CMB is to then establish the relative contribution of sources with known unique chemical signatures to the ambient sa mples collected in the field. Under high wind conditions, the dominant PM-10 emission source is fugitive dust. Unfortunately, there are no chemical signatures available to characterize fugitive dust from different land uses within the nonattainment area. Without this information, it is not possible for the rollback methodology to use CMB to address source apportionment.
Comment : MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA. P. 6-44: “ The attainment modeling for the nonattainment area demonstrates that the 24-hour PM -10 standard will be met by a relatively narrow margin in 201219 (i.e., 153.8 ug/m 3 at the West 43 rdAvenue monitor).” Was a sensitivity analysis performed to evaluate the degree of confidence in the results? A sensitivity analysis may reveal conditions where the modeling fails or requires improvement, so as to ensure NAAQS are attainment according to the plan. Response : The dominance of near upwind sources on monitored concentrations during high wind hours, as evidenced by the analysis conducted to determine the appropriate distance-weighting factor, and the tight cluster of back-trajector y hour reduction factors presented in Tables V-25 through V-31, demonstrate the relativ e insensitivity of monitored PM 10 concentrations to emission source spatial distribution during high wind hours. The variability in source spatial distribution is the greatest uncertainty w ith respect to determining locations of peak PM 10 concentrations. Distributions of meteorological parameters and soil surface emissions rates during high wind conditions have been measured and better characterized than land use distributions. Thus, a sensitivity analysis was conducted on the emission parameter possessing the greatest uncertainty, and no further analysis is needed.
Comment : Rollback only works if the monitor is at th e point of highest impact. Since air pollution standards must be attained within the entire planning area and not simply at the monitors, how confident is MAG in their choice to use a singl e point to represent the entire Maricopa County nonattainment area? Dispersion modeling typically provides for a more credible product, since they more realistically account for spatial and temporal patterns. Response : The analysis of the temporary monitoring data shows that when winds exceeded 12 mph and were coming from the dominant high wind direction (220° to 290°), the maximum concentrations were always recorded at the West 43 rdAvenue monitoring site. Additional analysis, presented in Table V-19, demonstrates that the hi ghest wind gusts in 2007 were recorded at the West 43 rdAvenue monitor. Given the frequency a nd magnitude of exceedances at this site, it is reasonable that it was selected and approved by EPA for one of the design day attainment demonstrations (i.e., May 4 th ). However, to ensure that a single location does not bias the attainment demonstration, a second high wind day was selected, one in which multiple monitors exceeded the standard (i.e., June 6 th ) and attainment demonstrations were prepared for the six monitoring sites in the nonattainment area with me teorological measurements. The use of rollback to demonstrate attainment at six widely dispersed monitoring sites with varying back trajectories capturing a variety of land uses, activity and emi ssions provides ample evidence that a single point was not used to demonstrate attainment. The fact that EPA participated in the development of this approach and ultimately approved it further demonstrates the validity of the methodology.
Comment : Is MAG confident that the receptor location in the high-wind micro inventory domain is representative of worst case conditions? Are there any locations within the high-wind domain where predicted concentrations can be potentially higher than the monitor site? Response : The temporary monitoring study provides insight into concentrations recorded at multiple locations between the West 43 rdAvenue monitor and the e dge of the desert (west of20 Buckeye at the Arlington monitor), a distance of roughly 35 miles. The results of that study, presented in V-7 – V-20, show that when wi nds exceeded 12 mph and were coming from the dominant high wind direction (220° to 290°), the maximum concentrations were always recorded at the West 43 rdAvenue monitoring site. Empirically this data supports the conclusion that the receptor location in the high-wind micro inventory is located at the worst case location. The fact that attainment was demonstrated on June 6 that six widely dispersed monitoring sites adds further confidence that the modeled domain represents worst case conditions.
Comment : According to the charts in Fig. V4 Appendix 2. ~98.6% of the total exceeding PM10 concentration originates from sources within 2km of the monitor. Under the current modeling scenario, sand & gravel sources are by far the gr eatest contributor to PM10. Yet, the source sand and gravel source category is also the source cat egory with the greatest estimated improvement in Rule Effectiveness. While nearly all of the vacant lots, agricultural sources and open areas are beyond 2km from the W43rd monitor and contribut e less than to 1.4% of their total potential emissions to the monitor. Response : It is incorrect to assume that sand and gr avel land uses are by far the greatest contributor to PM10 under the distance-weighted rollback modeling performed at the West 43rd Avenue monitor. In fact, a close examination of the land uses nearest to the West 43rd Avenue monitor within the high wind domains do not support that conclusion. The land uses nearest the monitor in the high wind domains are industrial and commercial lots. Under the distance-weighted rollback methodology, these high wind emissions have the highest weight. There are also vacant lots that are closer to the monitor within the high wind domain than sand and gravel land uses. Also, open areas of the Salt River that are not mined for sand and gr avel (displayed as "wash" land use in Figure V-16 as an example) within the high wind domain are closer to the West 43rd Avenue monitor than active sand and gravel operations. As such, these la nd uses contribute far more distance-weighted emissions than 1.4% assumed by the commenter.
Comment : So, the weighted emissions scenario for this model design favors an increase in Rule Effectiveness of approximately 73%, from 40% yielding a net change of ~33%. Response : Between 2007 and 2012, rule effectiveness for sand and gravel operations (Rule 316) does increase from 40% to 73%. The impact of this increase directly impacts un-weighted emissions and has an indirect effect on di stance-weighted emissions, as dist ance to the modeled monitor has a greater impact on distance-weighted emissions thanincreases in rule eff ectiveness in the land use categories.
Comment : A quick comparison with the average % Reduced of Weighted Emissions in Appendix 2. P. V – 68, Tables V-25 : V-36, provides a check of the assumptions. The average reduction according to the current model design is very close to the net increase in Ru le Effectiveness for sand and gravel operations.2 AERMOD ADERMD Evaluations Under the Evaluations Under the 1-hour NO 2 and SO 2 NAAQS. 10 th Conference on Air Quality Modeling March 14, 2012; AERMOD Evaluation for Non-Guideline Applications. 9 thConference on Air Quality Modeling Octobe r 9, 2008; AERMOD Latest Features and Evaluation Results: U.S. EPA, 2003

21 Response : The average percent reduction in distance-weighted high wind emissions ranges from 26.9% to 35.6% in Tables V-25 through V-31 from a variety of monitors across the nonattainment area, not just the monitor located at West 43r d Avenue. Many of the modeled high wind emissions are from domains that have little to no sand and gravel land uses (e.g., Central Phoenix monitor, Table V-26 or Higley monitor, Table V-29). The commenter's observation that the percent reductions in high wind emissions is around the increase in rule effectiveness for sand and gravel operations (33%) is merely a mathematical coincidence.
Comment : If a receptor is placed in the middle of the domain, where there are no sand and gravel sources, will the emissions still work? What are th e new impacts from vacant lots and other nearby sources? Response : As noted above, many of the modeled high wind emissions are from domains where sand and gravel land use is limited or nonexistent. The increased rule effectiveness impacting these land uses is clearly not required to demonstrate attainment within these domains. General Modeling:
Comment : There are a number of inaccuracies in Vo lume 2 p. V-5, Available Modeling Concepts. Response : Without identification of the specific in accuracies alleged, it is impossible to respond.
Comment : MAG’s assertion that AERMOD is less accurate than rollback models is baseless. There are a number of model evaluation studies 2 that test AERMOD against a variety of regulatory scenarios. In the vast majority of cases, AERM OD provides an adequate level of conservatism for NAAQS protection. Response : The limitations of using AERMOD in high wind day attainment demonstrations are discussed on p. V-5 and V-6 of Appendix 2, Exhibit 1.
Comment : MAG concludes that AERMOD model performance is poor for high winds. Yet, the weighted rollback (1/d) method used in the 2012 5% plan attainment modeling is calculated from AERMOD model results. Response : AERMOD was used in the attainment demons tration to determine the appropriate width of high wind hour modeling domains and to dete rmine the appropriate form of the distanceweighting factor. These model runs used hypotheti cal source configurations typical of bare soil areas predominately contributing to fugitive dus t emissions on high wind hour s. Further detail on these analyses are provided on pp. V-21 to V-27 and V-55 to V-58.22 Back Trajectory:
Comment : Appendix 2, V-55. Please provide a citation for the back trajectory equations?

• X=X1+WS*0.447*60*5*SIN(WD*2*PI/360) • Y=Y1+WS*0.447*60*5*COS(WD*2*PI/360) Response : The back trajectory equations are based on the wind direction and wind speed measurements recorded at each monitoring site. The equations back calculate where the air parcel would be based on these 2 variable s in a 2_D wind field. The calcu lations begin with the ending 5- minute values recorded each hour and calculate the location of where the air parcel was located at the end of the previous 5-minute period, etc. A similar approach has been used in “Analysis of Ozone in the Southeast Desert Air Basin on the Case Study Day of April 29, 1989, June 25, 1991. Sierra Research Inc.”
Comment : It appears that the trajectories may actua lly be tangential streamlines and not parcel trajectories. According to the equations above, X and Y are calculated for each hour of meteorological data. This method creates a simplif ied representation path, because streamlines are actually a series of straight line tangents to a path, in this case one tangent for each new hourly record. Trajectories are based on motion equations are more representative of a true path. Considering the “relatively narrow margin” of m odeled attainment, MAG should perform additional trajectory sensitivity analysis so that the most conservative domain size and source mix is selected for modeling. Response : It is correct that X and Y represent the end point of tangential streamlines, however, they are based on 5-minute measurements, not hourly measurements. It is important to note that the weighted rollback methodology places a premium on the accuracy of the location of sources producing nearby emissions relative to those located farther away. Thus, insight provided by 5- minute measurements have much higher value than those provided by hourly values. The principle difference between the air parcel-based method and the method used in the report is 3D versus 2D (i.e., representation of vertical air movement). High wind conditions, however, are usually characterized by elevated mixing layers and great er instability. Under these conditions, emissions from upwind sources should be well mixed in the vertical structure, therefore, the gradient between concentrations aloft and nearer the ground are not exp ected to be significant. Thus, the air parcelbased method and the one employed in this effort are expected to produce similar results if they employ the same time step and employ a similar spatial representation. With regard to investigating alternate domains and source mixes, the attainment demonstration methodology has rendered domain size to be mute because emissions from nearby sources have dramatically greater influence on monitored concentrations than emissions from sources located farther upwind. A review of trajectories over nearby sources, however, shows that they vary substantially as the high wind arc shifts with in the southwest quadrant (roughly 220° to 260°). Within this domain the share of passive open space drops by an order of magnitude as the arc shifts23 toward the west. While this shift produces a large change in the land use distribution and the related distance weighted emissions, there is little di fference in the 2007 versus 2012 reductions observed across any the high wind days. A review of Tables V-25 to V 31 show s little variance between individual high wind hourly reductions and the overall daily mean reduction, despite the fact that there are large differences in the hourly wind dir ections and land uses. Given the relatively tight cluster of observed reductions there is no need to i nvestigate the effect of alternate source mixes on demonstrating attainment.
Comment : Did MAG consider using ensemble ormatrix trajectories using NOAA’s HYSPLIT model? The variation in trajectory start times a nd location could prove to be a valuable form of sensitivity test for calculating domain size and source mix. Response : Yes, we considered using HYSPLIT, but the following technical and accuracy concerns led us to choose the method we used in the report. 1. HYSPLIT is structured to run on an hourly basi s. Meteorological data is typically supplied from hourly 3-D meteorological model (e.g., WR F, MM5, etc.) outputs. Readily available meteorological models addressing the PM-10 nona ttainment area are structured to represent a relatively coarse hourly 12 km by 12 km grid domain. 2. 5-minute wind speed and wind direction measurements are available from many of the monitoring sites. These data provide the best representation of air movement impacting each of these monitors. To use these data in HYSPL IT requires that they be assimilated into one of the available meteorological models.
3. Discussions with NOAA indicated the data need to be gridded into a specific format and the preferred approach would be to use something like WRF-ARW.
Our concern is that once the 5-minute data is en tered into WRF or a similar model, it would be modified to reflect the physical principals govern ing the operation of the model. Uncertainty about the magnitude of these changes and the coarse size of the available grid structure were considered relative to the demands of the weighted rollb ack methodology which places a premium on emissions of nearby sources relative to those located farther away. We determined that more accurate estimates of the location of nearby sources imp acting the monitors would be produced by using unaltered 5-minute measurements in the back traject ory calculations and for that reason did not pursue the use of HYSPLIT.
Comment : Are high wind back trajectories calculate d for each monitor and event with high winds in 2007? How about other years? Will 2008, 2009, 2010 and 2011 have a day that is more conservative? Response : High wind back trajectories were calculated for May 4 thfor the West 43 rdAvenue monitor (when it alone exceeded the standard) and on June 6 thfor six monitors (i.e., West 43 rd24 Avenue, Central Phoenix, Durango Complex, Greenw ood, Higley, and West Phoenix) that collected meteorological data (when both the West 43 rdAvenue and Higley monitors exceeded the standard). Since EPA accepted and approved the selection of these design days, there was no need to investigate high wind conditions on other days or years. Emissions:
Comment: Appendix 2. P. V – 62 High Wind Inventories; Were emissions calculated based on wind speeds from meteorological monitor, or wind sp eeds calculated at each back trajectory location? Response : High wind emissions were calculated usi ng the five-minute or hourly average wind speeds as measured by the anemometer co-locatedat each modeled PM-10 monitor (i.e., West 43 rd Avenue, Higley, etc.).
Comment : Appendix 2. P. V – 67 “The calculated emi ssions for each land use parcel are divided by the distance (feet) from the modeled monitor.” Please provide these calculations. Response : As described on page V – 62, the maximum size of a land use parcel within the high wind domain is 10 acres. Many of the parcels w ithin the high wind domain are less than 10 acres, as land use types and property boundaries change frequently within the high wind domain. Through the use of GIS, the distance from each parcel w ithin the high wind domain to the modeled monitor is calculated. This distance can then be used to weight the high wind emi ssions of each parcel by distance from the modeled monitor (i.e., emissions from land uses closest to the monitor are weighted higher than land uses farther away from the monitor). There are thousands of individual land uses parcels within each hourly high wind domai n. It would be impractical to provide each individual land use parcel distance-weighted calculation, for each modeled high wind hour (over 200,000 individual calculations). As such, the sum of un-weighted and dist ance-weighted emissions for all land use parcels within each hourly high wind domain are provided in Tables V – 25 through V – 31 (pages V – 68 through V – 73).
Comment : Appendix 2. P. V – 68, Tables V – 25 : V – 36. It is very difficult to compare tons to tons/feet (if at all). Please explain the units t ons/feet. Are the tons/feet estimates the emissions equivalent to the source receptor interaction coefficient (x/Q)? If so, please explain. Response : In Tables V – 25 through V – 31 both un-wei ghted and distance weighted emissions are provided for each modeled high wind hour. The unit of measure for un-weighted emissions is tons. The descriptor of tons/feet in the distance-we ighted column of tables V – 25 through V – 31 is provided to remind the reader that these tons have been weighted by distance from the monitor (1/d), as measured in feet. For example: If land use parcel X in the high wind domain has un-weighted emissions of 100 tons, and is 1000 feet away from the monitor, its distance weighted emissions are 0.1. If land use parcel Y in the high wind domain has un-weight ed emissions of 100 tons and is 2000 feet away from the monitor, its distance weighted emissions are 0.05. If there were only land use parcels X and Y in a hypothetical high wind domain, to tal un-weighted emissions for that25 hypothetical high wind domain would be 200 tons a nd distance-weighted emissions would be 0.15. As such, Tables V – 25 through V – 31 provide the sum of un-weighted and distance-weighted emissions for all land use parcels within each hourly high wind domain. (Note: Tables V – 32 through V – 36 do not discuss distance-weighted emi ssions (tons/feet) as incorrectly implied by the comment.)
Comment : Appendix 2. P. V – 68, Tables V – 25 : V – 36. A comparison of % Reduction of Weighted Emissions for both un-weighted and distance-wei ghted emissions would be helpful. Response : The percent reduction of un-weighted emi ssions in Tables V – 25 through V – 31 can be obtained by a simple formula; 1-(2012 emissions/ 2007 emissions). For example: In Table V – 25, the un-weighted emissions for high wind hour 12 are 3.05 tons in 2007 and 2.09 tons in 2012. Using the formula above (1-(2.09/3.05)) the percent reduction of un-weighted emissions for hour 12 in Table V – 25 is 31.5%. This compares to 33.8% reduction in distance-weighted emissions. (Note: Tables V – 32 through V – 36 do not discuss pe rcent reductions of high wind emissions as incorrectly implied by the comment.)
Comment : Dust Action General Permit claims a 1% benefit in 2012. The DAGP is for windblown emissions, yet windblown inventory is largely crushing & screening. Response : The one percent increase in 2012 rule effectiveness attributable to the Dust Action General Permit applies to land use parcels that are regulated by Maric opa County Rule 310.01 (e.g., vacant lots, unpaved roads, etc.). Each hi gh wind domain, upon which high wind emissions are calculated, contains a wide variety of land uses beyond crushing or screening or other sand & gravel activities. Each hourly high wi nd domain is unique (see Figure 6–5 on page 6–17 of main plan) based upon the local meteorology of that hour. There are many high wi nd domains that do not include crushing and screening or other sand and gravel activities as sources of windblown PM-10 emissions. The largest land uses by area within the high wind domains are vacant and open areas. Also, as shown in Figure 3–1 on page 3–5 of the main plan, the 2008 PM-10 emissions inventory for the nonattainment area list windblown PM-10 from sand and gravel sources as less than 0.5% of the inventory, while windblown PM-10 from v acant and open areas each comprise 4% of the nonattainment area PM-10 inventory. It is therefore inaccurate to assume that the windblown inventory within the high wind domains is largely crushing and screening activities. Temporary Monitor Insights:
Comment : • In the Temporary Monitor Study, did the temporary meteorological sites conform to EPA Meteorological Monitoring Guidance for Regulatory Modeling Applications? • What was the height of each met tower?26 • Were they monitors calibrated before the research started? Were they audited during the study? • Did the study meet data completeness standards? • The wind direction data are organized into five-degree increments, so concentration differences could be computed as a functi on of wind direction V-3. Did the anemometer used to collect the data provide an accuracy better than +- 5 degrees? Response : The Temporary Monitor Insights, desc ribed on pages V-7 through V-20, in Chapter V of the Technical Support Document, Appendix B, Exhibit 1 of the Draft MAG 2012 Five Percent Plan, were derived from monitoring data collect ed by the Maricopa County Air Quality Department (MCAQD) beginning in February 2010. Consis tent with the study protocol, MCAQD sited, installed, operated and maintained all instruments in conformance with applicable EPA regulations and guidance. MCAQD uses the same instruments and applies the same protocols to its existing monitoring network. Specifically: • All of the temporary meteorological sites c onformed to the EPA Meteorological Monitoring Guidance for Regulatory Modeling Applications.

• Both met towers were ten meters high (above ground level).

• All anemometers were calibrated before, during and after the study. In addition, all EPA quality assurance methods were followed for all particulate monitors.

• All particulate and anemometer instruments had data completeness ratios above 90% meeting EPA’s data completeness standards.

• The anemometer used to collect the data provided an accuracy better than ± 3 degrees.

# ACLPI AHJZONA CENTER FOR LAW IN THE PUBLIC INTEREST



### . .

VIA 

### FACSIMILF (602) 254yi1490 Lindy Bauer Maricopa Association of Governments 

### 302 N. h Avenut.:, Suite 300 Phoenix, AZ 85003 April 12,2012

RE: Drat\ 

### I\ 1 1AG 2012 Five Percl:'!nt Plan for 

### PI\·1-10 for the. !Vl<U"icopa 

### County Nonattainment r\rea
Dear M.s. Bauer:**'J~Gia•ec** ra**or,;~;rrng g~vern:n~.nt**  oc·:ounrJ.::d;r,,**il~ci** ;mner.rlng**~~~** 1»;3.**ria~·~** or**Ar'z.~:1•:1:**

Tbank you**'l~)r** the opp(,rhnrit)' to comment on the draft State Implementation Plan revision ("5%) Plan")**referenc(~'d** above. \A/e provide the follov.;ing comments. Particulate p01lution has**be~n** t1. serious problem in the Valley for the past two decades. Since they were first**adoptt~d.** the Phoenix metropolitan area has never attained the PM-1 0 standards and has 

### a long history of prl)p('tsing i.rmclequate pl.ans to address the problem. Now, having once again failed to meet its attainment deadline, the :;tate is required under Section 189(d) ofthe Clean Air Act (CA.A) to submit ''plan revisions "vhich provide for a.t1a1n

.. ment of the PM-1 0 air quality standard and, from the date of such submis.si.t;n until nttainr;1,;;nt.**/~)r** an annual reduction in PM-1 0 or PM-1 0 precursor emissions within the**ar~a** ofn.ot les.-: than 5 percent ofthe amount of such emissions as reponed in the most recent inve.ntory prepared f(x such area." 42 U.S.C. §7513(a)(d). In addition to the attainment demonstration and 5 ·perc.ent**requir~ments.** the plans under section 189(d) must address all applicable requirements oftbe C /\.A. Wi1.h res peel to 1 he draft plan, we raise the follo\ving cone ems: l. BACM and**MS~.'L,** As a serious nonattainrnent area fr)r PMJ 0, the Phoenix area 

### plan must include BACM for all significant sources of Pt.'.! 1 0 :ilnd I'M.! 0 precursors. BACM, best available control measures, are the 

### maxinltun degree of 

### cnussio.ns**r~duetions** possible after considering technical and economic feasibiUty and envir(rn.rrlcnta! impa<;ts of the control. These must be implemented independent of attainment requirements. Also, becmt5¢ Phoenix obtained a five year extension ofits attainment deadline, irs plan must inc-lude .MSt\1[**(nw~;t** stri.ngent measures). In the General Preamble (59 FR 41998), EPA sets 

### f<m·.h .a JYtLllti-ste·p proctss fur ident.ifYing**BACM/Bl~CT** for serious areas. The proposed 5% plan**doc;:~;** not include a**B.-~C.i'vf** or !\.'fSJ-.I demonstration that follows this process,·04/11/2012 14:22 52052'32927



### Comment Letter 

### n: :::!.012 5 1 % 

### P:VH U**Pl~ln** PAGE 02

Apri112, 2012 Page 2 of 3
therefore. it is 

### in.itiid.ly difficult to evt:n determine whether the plan satisfies the BACMIJ\.1SM 

### requirement. The**st~te** 

### cannor rely upon 

### the BACM/MS1vf demonstrations 

### in the 1999 Serious Area SIP, as that demonstration wu;:; prepared more than ten years ago, and, and as the EPA recognized in 

### its proposed disappmval of t:be. 2007 Drafl. 5% Plan, control measures that previously satisfied the BACM requirernent. 

### !.nay nQlonger re:prescnt the ''best availabk' control measure. See, 75 FR**54806~** 54812.**Thert.:·r~)J:'e,** an upcbrcd BACtvf/MS!vt analysis should be included in the 5% plan.

In its 

### propcsd disapprovn.l of 

### the 2007 Draft 5% Plan, EPA found that the 2005 emissions inventory relieclupt)l1 

### by the state t.c' be insufficiently accurate because 

### it overestimated the baseline emissions for construed on :a.nd otbcr sourc:;s. Sec 75 FR 54808. In the current plan, MAG is relying 

### ttpon a 2008 periodk ,:·missions**.~nvenlory** 

### which, like 

### the 2005 inventory, 

### was prepared by Jvfaricopa County Air Quality**.Dc:.~pa.rtment..** At H.r:::;t glc:u1ce. this rnore recent invento1y appears to address EPA's concerns as it sho\.vs**~~rn.i.ssior1s** from rec;idcntiat constn1ction to be a smaller percentage ofthe overall emissions. However,('!. comparison oftbe tW(l i.twentories (and the two draf't plans) reveals a discrepancy that MAO doe::: .not appe;:tr to either acknowledge or explain, and that is drastic reduction in the estimated e!ni.ssi.ons overall ln the 

### 200.5 inventory) total PM-10 emissions in the nonattainment area were 

### calculiltecl i!) he 84.753 tons per yea.r. The 2008 inventory puts that total at 48,148 tons per year--a reduction of rnore. !han 40% in just tbree years. It seems highly unlikely that the area achieved such a reduction in**cmis~ions** 

### by the implementa,t.ion of control**measw~es.** As noted above. we did not see any,;vhere in the**p.!<-~rl** when:.' this huge disparity in the data was acknowledged or explained. This oversight should be addressed.**Also~** because the inventory is the principal basis for calculating the**5t;.·1~** annual reducti0n required under the CAA. 

### tt is imp011ant 

# to the public health that the amotllit of

. . . cmTent emissions (l!C not**und.er~~tated.** 3.**Reli<!!.~£9...ill2QJ1-** ..**~ftL~** 

## .. LQncurrence Regarding Exceedances Claimed As Exceptional**f,ve.!l1:~** We are**concern~d th~1t** **tht~·** att·;.,inmenr.demonstr:ation in the 2012 5% Plan, lil<e the 2007 5% Plan, relies upon the**C:\)ncurren,~e** by EPA regarding exceptional events. As the plan acknowledges there were 7**exceed~{;1ccs** in 2009 alone rh.<tt must be treated as exceptional events in order for the area to meet the extended <1ttainm.ent dea.dltne. Further, although the 201 I data has not yet been finalized, the injtial data indicat.<:.'.s that**tbt.~h::** once ngain a significant nun1be:r of exceedances over multiple days and multiple**mon1tc;r~:.** 'I11e like.iihood of eliminating all ofthese exceedances as exceptional events would appear both remote and**~.~ontrary** te> the public interest. Therefore, we believe that a plan that proposes to achieve "·;l.(taimnent'· simply by white\vashing over severely unhealthf1.tl conditio11S is both irresponsible and contrary**~o** tbt public interest.

\\'bile we:! generally support the ;)doption of the general permit requirement for all dust generating activities**;.u~d** the i.!')Cl'C<Lo:;ed stringency of the agricultural permit requirements, the plan does not adequately de.!n.onstt::'i.k that**t~i11K:r** of these control measllres satisfy the BACM and MSM requirement. The plan di.d no1·**mcntio!~** iJ1c concerns raised by EPA in its proposed ruler:naking in04/11/2812 14:22**52852'3~':lL** I

Comment Letter r·e**;~()!** 2 5% PM.- J 0 Plan A£. Ct:.Nit:.l"< t"UI"< LAW


### April 12,2012 Page 3 of3
2010 regarding the agricultural BMPs or inr.licate whether and ho"v those 

### concerns had been addressed.

We have**C(':ltt~rn::;** <lhour: 

### the •.::nforceah[Jity of 

### control. measures in the pian. As you know, citizen enforcement b**~.::ncoun1ged** u.ndcr the Cican 

### Air Act. However, in recent years, when citizens have brought**action~;** to**e'nfcJt'Cl~** control rneasurcs that the state is responsible for implementing, the state has 

### invoked t:he 

### El.eventh A.rn.ench.ncnt in**~U'l.** 

### effort to avoid the enforcement 

### of its obligation to comply 

### with the SIP. 

### See Paisley\'. Brewer, CV 2:10-cv-01253-DGC ( D.Ariz.) and 

### Sv.·eat v. 

### Hull, 200 F. Supp. 2d. 1162 (D. Ariz. 20() l ). Although the defense did not preclude injunctive relief in either case, it**tmnec·~ssarily** ptotracted the litigation and demonstrated a Jack of commitment on the part of the state to rultlHing its obligatiN1S under the SlP. Therefore, we believe that where the state or one of its subdivision;:; (i.e. :,1 cotmty) <J:;sumes responsibility for the implementation of specific control measures, that comm1tment**sh~)tdd** i.ndude an unequivocal consent to federal jurisdiction 

### if enforcement is sought under rhe citizen suit provision. This consent will ensure that the measures are ft.tlly enforceable by both EPA r;n1d affected citizens, as the enforcement scheme adopted by the Act contemplates.

Attached to**thi~;** lctier .i:) a tcclmical revkw of the plan which raises qLtestions and concems regarding the**mock:J.in~-,** incluck.d in. the plan and $UppOJting documents.
These comment:' :-lre submitted •,Jn bch<1lf of the Sierra Club-Grand Canyon Chapter.



## r··

.. '84/11/2812 14:22 5285292927 AZ Ca-HER FOR LAW

Technical Reviev.- of MAG 2011 FIVE PERCENT PLAN FOR PM-10 FOR THE 

### MARICOPA COUNTY NONATTAINMENT 

### AREA
On March 12, 20 1.2, The**.M~).ricopCI** Association of Governments (MAG) published a new 2012 

### Draft Five Percent 

### P!a.n [(Jl' 

### 24--hom PM.l 0 for public review. This 

### paper provides comments based on the techn.i.c;,d \Vc:>rk <:()mprlsing the draft plan. 

### GENERAL Ed.itorial CommC'r1t's:

o The report. pn-:ntides very limited e::xzunples and few calculations to support the reported values.
• The report i.s**<'li~o** lacking equ.ations to support reported values.
• The reported vetlue:;**<1!'<~** i.n a variety of units, which makes comparisons difficult.
·MODELING

Model Selection:

• The air qual.ity mode-ling den1.onstrat.ion fnr the 24-hour PM I 0 standard is based on U.S. 

### EPA's roll**bad~** modeling 

### method, Federal regulations state that 

### "all applications of 

### air quality t11odelin;· inv,)!ved in this subpart shall be based on the applicable models, data bases, and other reqttin::ments specified in appendix \V of this part (Guideline on Ai:r Quality Mode b). '' 40 CFR pa.rt 

### § 5 .l.l60(f).
• Appendix W section 5.:2.2.2 PM I 0; "Re.fined models such as those discussed m subsection 4.1.2 are recommended for PM-1 0."
• Appendix \V Sectio.n. 4.2.2(b) Refined Analytical Techniques; "For a wjde range of regulatory applications in al! types of terrain, the recommended model is AERMOD."


### • Appendix W 

### Se-ction 5.2.2.2(e): ''Due to the difficult nature of characterizing and modeling fugitive dust a.ncl fi.1gitive emissions, 

### it is recommended that the proposed procedure be 

### deared hy U1e Regional 

### Offi.ce for each specific situation before the modeling exet:d3e is begun."
• The rol!back approach !s noi nne of U. S. EPA's preferred methods for demonstrating attainmetlt ofdv:; PMlO Ni\/\.QS04/11/2012 14:22 5205292927 AZ CErHER FOR LAW PAGE r.J5

Weighted Rollback:

• The report**dr~.:.-s** not**pre~}~nl** j:o1y 

# or the rollback equations used and so 

### it is LJnc!ear which rollback me:tllod '"'as**us~c!.** • If the**a:nJ.l,Y:>i~** i1'**b~1:sed** on the modified rollback method, was a spatial distJibution analysis pcrfl.lrmecl?
• In appendice::;**Voi~Ime:** 2 p. V

- 5, under the Weighted Rollback section, the report states: HThe reduct i.(\11 factor**i~** calculated on the basis of the distance between each source and the impact.ed rnonito.ri.ng**site.~·** o Plea;=;.: pwvicle the equation(s) used for the weighted rollback analysis. Based on 

### the**s~:Hem.e.nt.** 

### above:: it 

### is not clear how MAG has calculated the emissions \Vr:dghting. 

### The equations 1 used in EPA's proportional or modified rollback method do not involve any interactions among individual sources, only each individtw.l :source and a monitor.
• Rollback**typicall~y** r<:quires speciatecl profiles of soil dust from ambient measurements and chem.k<'l.l analysis for**~OLirce** apportionment calculations, using CMB (Chemical Mass**Balan<.~·;::).** Did t\·1ACJ**u::;~** 

### .:my source profiles to support the modeling analysis? Please re.fer m: "Guidelines**t~i** PMlO Sampling and Analysis Applicable to Receptor Model.i.ng"



### ,. MAG 2012 r:[VE 

### PERCENT PLAN 

### FOR PM-10 FOR THE MARICOPA COUNTY NONATTAlNMENT AREA. 

### P. 6-44: ''Tbe attainment modeling for the nonattainment 

### area demons:r:J.te$ 

### that !.be**24~hour** 

### PM.- 1 0 standard 

### will be 

### met by 

### a relatively narrow margin in201 2 (i.e

.. J 53.8 

### ugh113 at the \Vest 43rd Avenue monitor)." Was a sensitivity analysis perf.lm1ed to**t~va.l** uate the dt!:gree of contidence in their results? A sensitivity analysis n1ay**t'~vca.!** conditions where the modeling fails or requires improvement, so as to ensure the NAAQS are**attainr~d** according to the plan. 

## • Rollback 

### onty 'Narks if 

### rhc monitor is at the point 

### of highest impact. Since 

### air pollution standards i1.1\.lSt be atta..\.ned \vi thin the entire planning area and not simply at the monitors, how cont1dcnt is MA.G in 1·bcir choice to use a single point to represent the entire Maricopa County non<:J!.t.:tinment area'? Dispersion modeling typically provides for a more credible product, si nee they more real istica) ly account for spatial and temporal 

### patterns. 

### •



### • Is MAG**co.nf;.d:;~l\:** that. the recept0r location in the high-wind micro inventory domain is representat:i vt of worsl**ca~e** conditicms? Are there any locations within the high-wind domain when: predi.ded concentration::> can be potentjaJly higher than the monitor site? According to l"he cbart.s in Fig. V4. Appendix 2. -98.6% of the total exceeding PMIO concentra1ion ori.gi.natcs from sources within 2km of the monitor. Under the current modeling sccnariQ, ::;and & gravel sources are by far the greatest contributor to PMl 0. Yet, the**sourc(~** sand**~md** gravel source category is also the source category with the**-------.~---------~** 1 Rollback Modeling:**8a~i(:** and Mod!fii!d. Air Waste a11d Management Association 25:9 (September 1975)04/ll/2812 14:22 5205292927 AZ CENTER FOR LAW PAGE 05

greatest**~sti.mated** improvement in R.ul.e Effectiveness. While nearly all of the vacant lots, agricultural**source:~** 

### and op-::1.1 areas are beyond 2km 

### from the W43rd monitor and contribute**l~~s~~** than to 1 .4**~,..n** \){their total potential emissions to the monitor.
• So, the weighted emissions scenario for this model design favors an increase in Rule**Effectivene~;s** oLapproximatel.y**7]<~...;,~** from 40% yielding a net change of -33%.

111 A quick cotnparison wi.th the average % Reduced o,{Weighted Emissions in Appendix 2. P. V

- 68, TO\.ble:s V ·25 : V -36, provides a check of the assump6ons. The average reduction nccarding lo the cLu-rent: mode! design is very close to the net increase in Rule Effectiveness for sand 

### and gmvel operations. • If a receptor is 

### pl<w:d in lhe middle of the 

### domain, "vhere there are no sand and 

### gravel 

### sources. 'vvi.JI**th~** 

### <:missions bt:ne6ts still work? What 

### are the new 

### impacts from vacant lots and other nearby :>01.1rces?
General Modeling:

• There are: a**i.1umb~~!.'** of' inaccuracies in appendix 2 p. V-5, Available Modeling Concepts.
• MAG's**ass•~.rtion** tht•t 

### .AERMOD is l.es:) accurate than 

### rollback models is baseless. There


### are a numbr:·.r of model 

### e·Ja!Ltation studies 

### 2 that test 

### AER.J\10D 

### against a variety of 

### regulatory sc(·narios. Jn tile vast majority 

### of cases, 

### AERl'vfOD provides an adequate 

### level of conservati::.rn for N AAQS proter.:.tio11.
• MAG**con.clu.dc~;** that AEPJv100 model performance is poor for high winds.**Yet~** the weighted .rollback (lid) meth(Kl**u~ed** in the 2012 5% pl.an attainment modeling is calculated fr0n1 AEJU

.. .fO [) model result 

### Back trajectory:

• Appendix. 2, V- 55. Please provide a citation for the back**tr~uectory** equations?
o X=·XJ -;-WS*OA47*60*5*SlN(\VD*2*PI/360) 

### o Y=Y (t \VS"'0.447*'fi0"'**5*COS(WD*2'~PJ/360)** • It appears t!iEtt the trnjet:.tories 

### may actually be tangential streamlines and not parcel trajectories. According !.0 the t>:qua.tions**above~** X and Y are calculated for each hour of meteorologica.l duta.. This method creates a simplified representation of a path, because streamlines are r:tctua!l;• a series of straight line tangents to a path, in this case one tangent for each .nev
.. ' hottrly n:x:ord. Trajectories are based on motion equations are more representative 

## or a**trm~** path. C{)nsidering the "relatively narrow margin" of modeled attainment, MAG should perform an additional trajectory sensitivity analysis so 

### that the most**conservativ,~** donw[n**si7.l~** and solJ.rce mix is selected for modeling.

'- AERMOD AERMOD Eva!U;)t!cms**U11d~~:** the F.valur.:tions Under the 1-hour N02 and S02 NAAQ.S. lOth Conference on Air Quality Modeling: Marc::h 14·, 2012;**AEJ~MCD** Evaluation for Non-Guideline Applications. 9th Conference on J.\ir Quality Modeling October 9. 2008;**~ERMOD:** I.·!! test Feettures and Evaluation Results. U.S. EPA, 200384/11/2812 14:22 5285292'327 AL. U:.N I t:.t--: 1- Ut--: LA\!.J

1 

### Did**~1/\.G** 

### consider using ensemble or matrix trajectories using NOAA's 

### HYSPLIT model? The \·miation in. 

### trajectory slart 

### times and location could prove 

### to 

### be a valuable 

### form of**sen~;itivil:y** 

### test D)r 

### ('akulating 

### clomaii1 size 

### and 

### source-mix,

• Are high 

### v,:in.d back**tr~~jectori~s** calculated for each monitor and event with high winds in 2007? How ahnut olhcr yeJ.r:;(.> Will 2008, 2009, 2010 or 2011 have a day that is more conservnti v
.. ::':'
Emissions:



### • Appendjx 

### 1. P. V- 62 

### High Wind Inventories; Were emissions calculated based 

### on winds speeds 

### f!·o:n rnctcoro!.ogjc:al mo11itor, or wind speeds calculated at each back trajectory location?
• Appendix 2. P. V- 67**'·Tb~** calculated emissions for each land use parcel are divided by the distance (ket) 

### from tbe. rnod·:ded monitor." 

### Please provide these calculations.
• Appendix ?

.. 

### P. V - 

### 68,**Table~** V

### -25 : V -36. It is very difficult to compare tons to tons/feet (if 

### at aln

.**.Pl.~a~e** cxple1in the units tons/feet. Are the tons/feet estimates the 

### emissions**eqaiv~.l.enl** t(, 

### lJ.1t.! sottrce receptor interaction coefficient ( 

### x/Q)? If 

### so, please explain,
• Appendix 2. P V-**6~, labl~s**  V -25 : V -36. A comparison of% Redl.lcf.ion of W'"eighted Emissions for both un-v-·cighti!d a.nd distance-weighted emissions would be helpflll.
• Dust Action Cencra! Permit**claim~>** a 1% benefit in 2012. The DAGP 

### is for windblown emissions, yet '-Vindblown i:wcntory is largely crushing & screening. Temporary Monitor .fnsights:

• In 

### the Tempomry 

### :tvfonitor Stt.,.dy, did 

### the temporary meteorological sites conform to 

### EPA. Meteorological Monitoring Guidance for Re&,rttlatory Modeling Applications? • What was**th·~ l·K~ight**  of**~~acl.1** met tower'? • Were they**rnon~tors** caJibmtcd before the research started? Were they audited during the study?
• Did the study**rn~d d:~lil**  completeness standards? • The wind din;:ction d<m'l arc-**c~rganized** into fivt)-degree**increments~** so concentration differences could be cornrmte::cl os a function of wind direction V- 3. Did the anemometer used to collect the data provide ;;m accuracy better than +-5 degrees?

## APPENDIX E

EXHIBIT 2:

Certification of AdoptionRESOLUTION TO ADOPT THE MAG 20 12 FIVE PERCENT PLAN FOR PM-I 0 FOR THE MARICOPA COUNTY NONATIAINMENT AREA

WHEREAS, the Maricopa Association of Governments (MAG) is a Council of Governments composed of twenty-five cities and towns within Maricopa County and the contiguous urbanized area, the County of Maricopa, the Gila River Indian Community, the Salt River Pima-Maricopa Indian Community, Fort McDowell Yavapai Nation, Arizona Department of Transportation, and Citizens Transportation Oversight Committee; and WHEREAS, the Governor of Arizona designated MAG as the regional air quality planning agency and metropolitan planning organization for transportation in Maricopa County; and WHEREAS, the Maricopa County nonattainment area is classified as a Serious Area for PM-I 0 particulate matter according to the Clean Air Act; and WHEREAS, the MAG 2007 Five Percent Plan for PM-I 0 was required by the Clean Air Act since the Maricopa County nonattainment area failed to attain the PM-I 0 standard by December 3 I, 2006; and WHEREAS, the MAG 2007 Five Percent Plan for PM-I 0 was voluntarily withdrawn on January 25, 20 I I to include new information, such as the new Environmental Protection Agency equation for paved road dust emissions; and WHEREAS, the MAG 20 12 Five Percent Plan for PM-I 0 is a replacement for the 2007 plan that was withdrawn; and WHEREAS, the plan is required to reduce PM-I 0 emissions by at least five percent per year until the standard is met; and WHEREAS, MAG has prepared the 20 12 Five Percent Plan for PM-I 0 for the Maricopa County Nonattainment Area; and WHEREAS, A.R.S. 49-406 H. requires that the governing body of the metropolitan planning organization adopt the nonattainment area plan.
NOW THEREFORE, BE IT RESOLVED BY THE MARICOPA ASSOCIATION OF GOVERNMENTS REGIONAL COUNCIL as follows:
SECTION I

. That the MAG Regional Council adopts the MAG 20 12 Five Percent Plan for PM-I 0 for the Maricopa County Nonattainment Area which contains control measures from the State and local governments.
SECTION 2. That the MAG Regional Council further recommends implementation of the appropriate measures by the MAG cities and towns, Maricopa County, and the State of Arizona and authorizes the submission of the plan to the Arizona Department of Environmental Quality and the U.S. Environmental Protection Agency.PASSED AND ADOPTED BY THE REGIONAL COUNCIL OF THE MARICOPA ASSOCIATION OF GOVERNMENTS THIS TWENTY-THIRD DAY OF MAY 2012.

ATTEST: MAG Regional Council

Dennis Smith Executive DirectorCERTIFICATION OF ADOPTION OF THE MAG 2012 FIVE PERCENT PLAN FOR PM-10 FOR THE MARICOPA COUNTY NONATTAINMENT AREA

An Excerpt from the May 23, 2012 MAG Regional Council Meeting Minutes Mayor Michael LeVault moved to adopt the MAG 2012 Five Percent Plan for PM -10 for the Maricopa County Nonattainment Area. Supervisor Max Wilson seconded, and the motion passed unanimously.

I certify that on May 23, 2012, the MAG Regional Council adopted the MAG 2012 Five Percent Plan for PM-10 for the Maricopa County Nonattainment Area.

Date· wu<.tv couH f14¥UIIM"

...

· 

### OFFICE: OF 

### THE GOVERNOR**S'i'~TI!:** HOUSI!: PHOCNIX, ARIZONA 85007 

### 'February 

## 1, 1918



### Tho Honorable Dougla.s M. 

### Costlo Ad!nin.Utr:1tor. United**Stat~** 

### Environmental Protection A&cncy 

### 401 .nM,. 

### Street, 

### S.W. \Vuhiniton, DC 

### 20460 · Deu M'r. 

### Costte: 

### In accordance with**s~ction** 

### t 

### 74(a) of the Clean 

### Nr 

### Ao: as**am~:tded** 

### August 

### 7, )911, 

### I hereby**d~iilltnte** 

### the· Maricopa A.uociati()n of Ciovcmrnents u 

### the**le:~d** 

### planning orpniutlon for Maricopa ·county, (PhoeniX) Arl%ona nnd tho Ptma Association**oi'Co~rnments** 

### u the lc:td planiling**o~tlon** 

### for Pima Colinty, (Tuaon) Alitonn for tlte purpose of determi.1lng which 

### elements or 

### .a· revised Nr c. 

### Quallt'/ lmplemencaUon Plan:will be planned, !mp!em;ntcd and ftnfotced by the State and local sovemments in 

### Arl%ona. Attached :tre 

### lett<iss Crom each 

### agcn1::t requesting suCh**d~ignatiom..** 

### · ·

. . 

### This aC:t!o.n is requited**be~we n:~tional**  

### prim:Ur**am.bi~nt** 

# rur quality scandimu' for oarl;lon monoxide and photochem!c::11 oxidants will not be**atc~b1ed** 

### In metropolitan PhoeniX and Tuaon by July 1, 1919. 

### De.l3ilcd**a~ements** 

### with the ·above organiutlons of elected ofilc!:ls of loc:tl· govem.ments' nnd I 

### he**~lute** 

### of Ari:ona · arc 

### now**bein~** 

### de•te!opcd. These 

### ug:recments wUI Identify the**rcspon~ibillllcs** 

### of each · of the partlc:ipnnts, I.e. the Maricopa Association of**Ciovernm~nts,** 

### the Pima Association of Governments,: the Maricopa· County f{ealth Depa.rtme:u, and the Arizona Department of Hedth Scrvlc=:**~pon** 

### completion oi such agreements, they will 

### be ccrtifled by this 

### office and for.vardcd to the U.S.**E.1vironmen~** 

### P:otection**Ai=n~/·** 

## ·**~**



## ws:vabcim Attac:lunen u ·

cc::**Su~Me** 

### Dandoy Bruce Scott 

### 0. Kenneth Driggs 

### 11tomn:s L. Sw:utson Paul De Fdco, Ir. 

## 0-2STATE OF A;RIZONA EXECUTIVE OFFICE
FIFE SYMINGTON Oovernor



### The Honorable Charles Hayes Chairman, MAG Regional Council· 1820 West Washington

. Phoenix, 

### P(Z 85007

Dear Mayor Hayes: June 24, 1993

. I concur with your May lOth**letter-~MAG** 

### should coordinate its aviation planning with the statewide ·aviation planning effort. Please inform the Regional Council that I support their .continuation as the Metropolitan Planning Organization. I believe the MAG Regional Aviation System Plan will do much .to help your region of the state make decisions on airport improvements. I salute your process. · · If you are not aware, however, my Regional Airport Feasibility Assessment · (RAFA) was a statewide aviation planning effort. In the case of the RAFA, regional does not mean a limited area like MAG but means the Southwestern United States. My RAFA study was paid for by FAA funding and focused on the statewide issue of a· new major airport facility to serve needs throughout Arizona and the entire

. Southwest within the next 20 to 30 years. 

### It also considers long-term economic

effects on the state. Your MAG RASP was also paid for by FAA funding but focused on 10 to 20 years of airport improvements 

### in Maricopa County. As you can see, the two studies differ greatly in scope and substance. ·



# RECTi j 

# u N ?!.:

### )~ 

# ·;993

1700 WEST WASHINGTON. PHOENIX, ARIZONA 85007 • (602) 542·4331

### The Honorable Charles Hayes June 24,1993 Page Two

. I**~otice** 

### that about a dozen of your MAG RASP Committ.ee Members were also on my GRAAC Committee. It 

### seems to me that this overlap of membership provides a good b.asis for the coordination**y~m** 

### seek. · Thank you for yo11r continued concern to keep Arizona's aviation industry viable and vital in the 21st century._

FS/JL:me Sincereiy,

Fife .Symington GOVERNOR.



### cc: Joe Lane, Executive Assistant for the Governor Marvin Cohen, GRAAC Chairman Linda Brock-Nelson, GRAAC Vice Chairman GRAAC Committee Members MAG Regional Council · . 

### '



### .,49-406

. Nonattainment area plan A. For any ozone, carbon monoxide or particulate nonattainment or maintenance area the governor shall certify the metropolitan planning organization designated to conduct the continuing, cooperative and comprehensive transportation planning process for that area under 23 United States Code section 134 as the agency responsible for the development of a nonattainment or maintenance area plan for that area. B. For any ozone, carbon monoxide or particulate nonattainment or maintenance area for which no metropolitan planning organization exists, the department shall be certified as the agency responsible for development of a nonattainment or maintenance area plan for that area. C. For any ozone, carbon monoxide or particulate nonattainment or maintenance area, the department, the planning agency certified pursuant to subsection A of this section on behalf of elected officials of affected local government, the county air pollution control department or district, and the department of transportation shall, by November 15, 1992, and from time to time as necessary, jointly review and update planning procedures or develop new procedures. D. In preparing the procedures described in subsection C of this section, the department, the planning agency certified pursuant to subsection A of this section on behalf of elected officials of affected local government, the county air pollution control department or district, and the department of transportation shall determine which elements of each revised implementation plan will be developed, adopted, and implemented, through means including enforcement, by the state and which by local governments or regional agencies, or any combination of local governments, regional agencies or the state. E. The department, the planning agency certified pursuant to subsection A of this section on behalf of elected officials of affected local government, the county air pollution control department or district, and the department of transportation shall enter into a memorandum of agreement for the purpose of coordinating the implementation of the procedures described in subsection C and D of this section. F. At a minimum, the memorandum of agreement shall contain: 1. The relevant responsibilities and authorities of each of the coordinating agencies. 2. As appropriate, procedures, schedules and responsibilities for development of nonattainment or maintenance area plans or plan revisions and for determining reasonable further progress. 3. Assurances for adequate plan implementation. 4. Procedures and responsibilities for tracking plan implementation. 5. Responsibilities for preparing demographic projections including land use, housing, and employment. 6. Coordination with transportation programs. 7. Procedures and responsibilities for adoption of control measures and emissions limitations. 8. Responsibilities for collecting air quality, transportation and emissions data. 9. Responsibility for conducting air quality modeling. 10. Responsibility for administering and enforcing stationary source controls. 11. Provisions for the timely and periodic sharing of all data and information among the signatories relating to: (a) Demographics. (b) Transportation. (c) Emissions inventories. (d) Assumptions used in developing the model. (e) Results of modeling done in support of the plan. (f) Monitoring data. G. Each agency that commits to implement any emission limitation or other control measure, means or technique contained in the implementation plan shall describe that commitment in a resolution adopted by the appropriate governing body of the agency. The resolution shall specify the following: 1. Its authority for implementing the limitation or measure as provided in statute, ordinance or rule. 2. A program for the enforcement of the limitation or measure. Format Document http://www.azleg.state.az.us/FormatDocument.asp?format=print&inDoc=/...

1 of 2 5/15/2012 11:39 AM3. The level of personnel and funding allocated to the implementation of the measure. H. The state, in accordance with the rules adopted pursuant to section 49-404, and the governing body of the metropolitan planning organization shall adopt each nonattainment or maintenance area plan developed by a certified metropolitan planning organization. The adopted nonattainment or maintenance area plan shall be transmitted to the department for inclusion in the state implementation plan provided for under section 49-404. I. After adoption of a nonattainment or maintenance area plan, if on the basis of the reasonable further progress determination described in subsection F of this section or other information, the control officer determines that any person has failed to implement an emission limitation or other control measure, means or technique as described in the resolution adopted pursuant to subsection G of this section, the control officer shall issue a written finding to the person, and shall provide an opportunity to confer. If the control officer subsequently determines that the failure has not been corrected, the county attorney, at the request of the control officer, shall file an action in superior court for a preliminary injunction, a permanent injunction, or any other relief provided by law. J. After adoption of a nonattainment or maintenance area plan, if, on the basis of the reasonable further progress determination described in subsection F of this section or other information, the director determines that any person has failed to implement an emission limitation or other control measure, means or technique as described in the resolution adopted pursuant to subsection G of this section, and that the control officer has failed to act pursuant to subsection I of this section, the director shall issue a written finding to the person and shall provide an opportunity to confer. If the director subsequently determines that the failure has not been corrected, the attorney general, at the request of the director, shall file an action in superior court for a preliminary injunction, a permanent injunction, or any other relief provided by law. K. Notwithstanding subsections A and B of this section, in any metropolitan area with a metropolitan statistical area population of less than two hundred fifty thousand persons, the governor shall designate an agency that meets the criteria of section 174 of the clean air act and that is recommended by the city that causes the metropolitan area to exist and the affected county. That agency shall prepare and adopt the nonattainment or maintenance area plan. If the governor does not designate an agency, the department shall be certified as the agency responsible for the development of a nonattainment or maintenance area plan for that area. Format Document http://www.azleg.state.az.us/FormatDocument.asp?format=print&inDoc=/...

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