This document was developed with the assistance of:

Sierra Research Inc.

1801 J Street

Sacramento, CA 95811

Appendix F

RACM Analysis for the West Pinal 

County PM10 Nonattainment Area

Arizona Department of 

Environmental Quality

Final

December 21, 2015
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December 21, 2015 Final West Pinal PM10 RACM Analysis i

TABLE OF CONTENTS

LIST OF TABLES.....................................................................................................................................iii

1.0 INTRODUCTION.................................................................................................................................1

1.1 Purpose and Background ....................................................................................................................1

1.2 EPA Guidance ....................................................................................................................................1

1.2.1 RACM/RACT Guidance ..........................................................................................................1

1.2.2 BACM Guidance for Additional Clarification .........................................................................2

1.3 RACM Analysis Process Summary....................................................................................................3

2.0 SOURCE EVALUATION FOR THE WEST PINAL PM10 NONATTAINMENT AREA............4

2.1 Identification of Significant Sources (Direct/Primary Emissions) .....................................................4

2.2 Description of Significant Sources.....................................................................................................8

2.3 PM10 Precursors................................................................................................................................11

3.0 CONTROL MEASURE ANALYSIS FOR SIGNIFICANT SOURCES .......................................14

3.1 Review of Existing Measures...........................................................................................................14

3.2 Identification of Available Measures................................................................................................18

3.2.1 Initial List of Available Control Measures.............................................................................18

3.2.2 Measures Adopted in Other Areas..........................................................................................19

3.2.3 Discussion of Candidate Measures.........................................................................................20

3.2.4 Stakeholder Process................................................................................................................27

4.0 SELECTED MEASURES..................................................................................................................29

4.1 Construction......................................................................................................................................30

4.1.1 Measure Title(s)......................................................................................................................30

4.1.2 Copy of Ordinance, Rule or Regulation .................................................................................30

4.1.3 Implementation Schedule .......................................................................................................30

4.1.4 Basis for Consideration ..........................................................................................................30

4.1.5 Applicable to the Following Land Use Categories and Emission Generating Activities.......30

4.1.6 Discussion of Measure Benefits.............................................................................................30

4.1.7 Discussion of Technical and Economic Considerations.........................................................31

4.1.8 Comparison of the Pinal County Rule with Measures Adopted in Other Areas ....................32

4.2 Agriculture........................................................................................................................................33

4.2.1 Measure Title(s)......................................................................................................................33

4.2.2 Copy of Ordinance, Rule or Regulation .................................................................................33

4.2.3 Implementation Schedule .......................................................................................................33

4.2.4 Basis for Consideration ..........................................................................................................33

4.2.5 Applicable to the Following Land Use Categories and Emission Generating Activities.......34

4.2.6 Measure Benefits....................................................................................................................34

4.2.7 Technical and Economic Considerations................................................................................35

4.3 Fugitive Dust (General Rule) ...........................................................................................................40

4.3.1 Measure Title(s)......................................................................................................................40

4.3.2 Copy of Ordinance, Rule or Regulation .................................................................................40

4.3.3 Implementation Schedule .......................................................................................................40

4.3.4 Basis for Consideration ..........................................................................................................40

4.3.5 Applicable to the Following Land Use Categories and Emission Generating Activities.......40

4.3.6 Discussion of Measure Benefits.............................................................................................41

4.3.7 Discussion of Technical and Economic Considerations.........................................................41

4.3.8 Comparison of the Pinal County Rule with Measures Adopted in Other Areas ....................51

Exhibit F-I – Available Measures.........................................................................................................FI-1
December 21, 2015 Final West Pinal PM10 RACM Analysis ii

Exhibit F-II – Construction Comparison........................................................................................... FII-1

Exhibit F-III – Agriculture Comparison ..........................................................................................FIII-1

FIII-1 Crop Operations Overarching ................................................................................................ FIII-2

FIII-2 Tillage .................................................................................................................................. FIII-10

FIII-3 Ground Operations and Harvest........................................................................................... FIII-12

FIII-4 Noncropland......................................................................................................................... FIII-14

FIII-5 Roads (Commercial Farm)................................................................................................... FIII-16

FIII-6 Cropland............................................................................................................................... FIII-18

FIII-7 Animal Operations Overarching Requirements................................................................... FIII-20

FIII-8 Commercial Dairy................................................................................................................ FIII-26

FIII-9 Commercial Beef Feedlot .................................................................................................... FIII-32

FIII-10 Commercial Poultry ........................................................................................................... FIII-38

FIII-11 Commercial Swine............................................................................................................. FIII-44

FIII-12 Irrigation Districts.............................................................................................................. FIII-50

Exhibit F-IV – Fugitive Dust Comparison........................................................................................FIV-1

Exhibit F-V –Information On a Gallons per Head Standard Providing More Benefits over a Strict 

Moisture Percentage for Feed Yard Pens.......................................................................................... FV-1
December 21, 2015 Final West Pinal PM10 RACM Analysis iii

LIST OF TABLES

Table 1: Summary of the West Pinal County Design Day (24-hour) Modeled Source Impacts for 2008 

(μg/m3) .........................................................................................................................................................7

Table 2: Summary of Source Sector Secondary Pollutant Impacts at the Cowtown and PCH Monitors..13

Table 3: Control Programs Applicable to PM10 Sources in the West Pinal PM10 Planning Area (as of 

2008)...........................................................................................................................................................15

Table 4: Fugitive Dust Control Measures Required To Be Considered .....................................................18

Table 5: Estimated Annual Emissions Reductions due to Implementation of the Construction Rule........31

Table 6: Construction and Earthmoving* ...................................................................................................31

Table 7: Agriculture rule applicable sources ..............................................................................................34

Table 8: Agricultural Best Management Practices Rule Reductions (Attainment and Contingency) ........35

Table 9: Fugitive Dust Rule Applicable Sources........................................................................................40

Table 10: Estimated Annual Emissions Reductions due to Implementation of the Fugitive Dust Rule.....41

Table 11: Open Areas and Vacant Lots* ....................................................................................................42

Table 12: West Pinal County Nonattainment Area Fugitive Dust Complaints (ATV/OHV).....................43

Table 13: Unpaved Lots*............................................................................................................................45

Table 14: Unpaved Roads*.........................................................................................................................46

Table 15: Paved Roads*..............................................................................................................................48
December 21, 2015 Final West Pinal PM10 RACM Analysis iv

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December 21, 2015 Final West Pinal PM10 RACM Analysis 1

1.0 INTRODUCTION

1.1 Purpose and Background

This document provides Arizona Department of Environmental Quality’s (ADEQ) analysis of reasonably 

available control measures (RACM) for emission sources within the West Pinal PM10 Nonattainment 

Area. 

Effective July 2, 2012, the U.S. Environmental Protection Agency (EPA) redesignated a portion of 

western Pinal County, Arizona from "unclassifiable” to “nonattainment” for the 1987 24-hour PM10

National Ambient Air Quality Standard (NAAQS).

1 Redesignation was based on recorded violations of 

the air quality standard at ambient monitoring sites within the area. In the same action, the EPA also

classified the area as a “moderate” nonattainment area, triggering specific Clean Air Act (CAA) 

requirements for Arizona to revise its State Implemenation Plan (SIP) in a manner demonstrating that the 

area would attain the 1987 PM10 NAAQS. 

CAA Sections 172(c)(1) and 189(a)(1)(C) require that moderate nonattainment area SIP revisions include 

emissions reductions from existing sources of PM-10 emissions, as may be obtained through RACM and

reasonably available control technology (RACT). RACM and RACT must be implemented as 

“expeditiously as practicable” and “shall provide for the attainment of the [NAAQS].”

2 However, if an 

area is classified as moderate, a State must implement RACM no later than four years after designation.3

The “General Preamble” to the 1990 CAA Amendments and other policy and guidance documents 

partially describe the methodology to determine RACM.

According to the law and interpretive guidance, all significant4 point, area, onroad and nonroad sources

are herein evaluated for existing and potential control through RACM/RACT measures. 

1.2 EPA Guidance

1.2.1 RACM/RACT Guidance

The U.S. EPA’s April 1993, PM-10 Guideline Document (1993 Guidance) and the General Preamble

both outline how to evaluate control strategies for moderate PM10 nonattainment areas. EPA advises that 

“[t]he suggested starting point for specifying RACM in each SIP is the listing of available control 

measures for fugitive dust, residential wood combustion, and prescribed burning, including measures 

selected from among those listed in the appendices to the General Preamble.” 5 

Control measures may not be reasonable for all sources because some sources produce “insignificant (i.e., 

de minimis)” levels of emissions.

6

 Measures to control insignificant sources may then be excluded for 

 

1 See generally, Designation of Areas for Air Quality Planning Purposes; State of Arizona; Pinal County; PM10, 77 

FR 32024, May 31, 2012.

2 Clean Air Act § 172(c)(1), 42 U.S.C. 7502(c)(1) (1990).

3 Clean Air Act § 189(a)(1)(C), 42 U.S.C. 7513(a)(1)(C) (1990).

4

i.e. control measures for such sources result in more than de minimis emission reduction levels

5 Office of Air Quality Planning and Standards, U.S. Envtl. Prot. Agency, PM-10 Guideline Document 8-10 (April 

1993) [hereinafter PM-10 Guideline Document]; see also General Preamble for the Implementation of Title I of the 

Clean Air Act Amendments of 1990, 57 FR 13498, 13540, Apr. 16, 1992.

6 General Preamble, 57 FR 13540.
December 21, 2015 Final West Pinal PM10 RACM Analysis 2

further consideration if it can be shown the sources are in fact insignificant.

7

 Hence, a good starting point 

for a RACM analysis is to identify reasonable sources to control, which are those sources that contribute 

more than insignificant (i.e. significant) emissions. 

RACT is the lowest emission limitation that a particular existing source can meet by applying control 

technology that is reasonably available considering technological and economic feasibility.8 In moderate 

nonattainment areas, existing “major stationary sources should be the minimum starting point for a RACT 

analysis.”

9 However, guidance further indicates that a RACT analysis should not be limited to major 

stationary sources, and should apply to other existing stationary sources in the area that are reasonable to 

control given the area's attainment needs.10

A preliminary list of control measures may be 1) found in the General Preamble appendices, 2) 

introduced by public comment, and 3) found in other similar areas’ SIPs.11 However, not all controls are 

required to be adopted and implemented.

12 A state should evaluate for reasonableness the preliminary list 

of “available” control measure, and through this process, some measures may be rejected, in full or in 

part, as unreasonable.

13 The General Preamble characterizes “reasonableness” as the “technological 

feasibility and the cost of control in the area to which the SIP applies.”14 A SIP submittal should contain 

a reasoned and documented justification for partial or full rejection of any available control measures, 

explaining the infeasibility and unreasonableness of the measures.

For the control of public sector sources, specifically, [the RACM/RACT] evaluation “should consider the 

impact of the reasonableness of the measures on the municipal or other governmental entity that must 

bear the responsibility for their implementation (e.g., paving of unpaved public roads).”15 If control 

measures are infeasible to implement in full, “a State should consider the feasibility of implementing 

measures in part.”16

Finally, when the process for determining RACM is completed, the selected measures should be

“converted into a legally enforceable vehicle (e.g., a regulation or permit program)” and should meet 

“EPA’s criteria regarding the enforceability of SIPs and SIP revisions.”17 

1.2.2 BACM Guidance for Additional Clarification 

The CAA Amendments of 1990 established two tiers of PM10 nonattainment area classifications: 

moderate and serious. Areas newly designated nonattainment for the PM10 standard, such as Western 

Pinal County, are typically classified as moderate areas. If an area is not forecast to attain within four 

years of the effective date of nonattainment, then EPA is required to classify the area as serious and the 

area must adopt best available control measures (BACM) to affect emissions reductions. 

The available guidance depicts BACM as being more stringent than RACM, but concludes that BACM 

should be developed in a very similar manner as RACM. Consequently, during the RACM process, 

 

7

Id.; See also PM-10 Guideline Document, supra note 6, at 8-11.

8

Id.

9 General Preamble, 57 FR 13541; see also PM-10 Guideline Document, supra note 6, at 8-11.

10 Id.

11 See General Preamble, 57 FR 13540.

12 General Preamble, 57 FR 13540-13541; see also PM-10 Guideline Document, supra note 6, at 8-10 – 8-11.

13 Id.

14 Id.

15 General Preamble, 57 FR 13541.

16 Id.

17 Id.; see also PM-10 Guideline Document, supra note 6, at 8-11.
December 21, 2015 Final West Pinal PM10 RACM Analysis 3

ADEQ referred to BACM guidance for clarification of terms and processes not explained in RACM 

guidance. 

For example, in a moderate area RACM analysis, candidate measures can be excluded from consideration 

if the measures would reduce emissions only from sources or source categories that are determined to be 

de minimis, or not contributing significantly to exceedances of the PM10 standards. EPA guidance does 

not define de minimis or significant impact levels in RACM determinations. Some specificity is 

provided, however, in the clarification of these terms in BACM guidance. According to BACM 

guidance, a source category “will be presumed to contribute significantly to a violation of the 24-hour 

NAAQS if its PM-10 impact at the location of the expected violation would exceed 5 μg/m3.”18 ADEQ 

bases its significant source conclusions on this BACM guidance statement.

1.3 RACM Analysis Process Summary

The step-by-step process for evaluating potential control measure application to point, area, onroad, and 

nonroad emission source categories follows:

1. Determine the significant sources contributing to violations of the air quality standards,

2. List available control measures (General Preamble, other air districts, public comment),

3. Evaluate the list of “available” measures for “reasonableness” (technological and economic 

feasibility),

4. Provide reasoned justification for the rejection, in whole or in part, of any candidate control 

measure affecting a significant source,

5. Determine the emissions reductions due to the selected measures and evaluate whether the 

measures will lead to attainment of the NAAQS as expeditiously as practicable,

6. Ensure final measures are legally enforceable (codified in rule, permit, etc.).

Evaluation of significant sources and potential new control measures for the West Pinal area are discussed 

in Sections 2 through 4 below.

 

18 Addendum to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990, 59 

FR 41998, 42011, Aug. 16, 1994.
December 21, 2015 Final West Pinal PM10 RACM Analysis 4

2.0 SOURCE EVALUATION FOR THE WEST PINAL PM10 NONATTAINMENT AREA

2.1 Identification of Significant Sources (Direct/Primary Emissions)

To guide the preparation of PM10 control strategies for the West Pinal County Nonattainment Area, 

ADEQ analyzed ambient monitoring and emissions data for a period when violations of the PM10 standard

occurred. Analysis of 2008 base year monitoring data showed that two separate meteorological scenarios 

produce exceedances of the 24-hour PM10 NAAQS at or above 155μg/m3:

19

 high wind and stagnation 

(i.e., low wind speed and mixing height) conditions.20 The emission source combinations that contribute 

to elevated concentrations are fundamentally different under each meteorological scenario. On stagnation 

days, emissions are activity based (e.g., re-entrained dust from a vehicle driving on a roadway). On high 

wind days, additional emissions are generated by wind blowing across disturbed surfaces (e.g., an area 

cleared of vegetation). Therefore, for control strategy analysis, ADEQ chose representative design days 

(days with recorded exceedances of the 24-hour PM10 NAAQS) for high wind conditions and for

stagnation conditions.

ADEQ selected the following monitors and correlated dates as representative of stagnant (low wind) 

meteorological conditions leading to elevated ambient concentrations:

 Cowtown – October 30, 2008,

 Pinal County Housing (PCH) – October 29, 2008, and

 Stanfield – October 29, 2008.

ADEQ selected the following monitors and correlated dates as representative of high wind conditions:

 Cowtown – April 27, 2008,

 Pinal County Housing (PCH) – January 1, 2008,

 Stanfield – November 21, 2008, and

 Maricopa – October 27, 2008.

Separate modeling domains were defined for each monitor and base scenario (pre-attainment-controls) 

emissions inventories developed for each domain for 2008 and 2018. Inventories for both windblown and 

activity-based emissions were created. Dispersion modeling was then performed to identify emissions 

sources that have significant impacts on elevated ambient PM10.

21

 Source categories that did not 

contribute more than 0.5% of the design day emissions in any of the modeling domains were not included 

in stagnation or high-wind day source apportionment (ambient impact) modeling because their 

contributions were negligible. None of the source categories listed below individually contributed more 

than 0.5% to any of the emissions inventories:

 Nonroad,

 

19 While the PM-10 NAAQS is 150μg/m3

, a violation does not occur until monitor concentrations are above the 

rounded value as dicated by 40 CFR 50, Appendix K. Appendix K states, “Exceedance means a daily value that is 

above the level of the 24-hour standard after rounding to the nearest 10 μg/m3(i.e., values ending in 5 or greater are 

to be rounded up).” Hence, a level of 155 μg/m3rounds up to an exceedance level of 160 μg/m3, and any value 

between 150-154.9 rounds down to 150μg/m3and does not qualify as an exceedance. 

20 See Appendix B, Pinal County PM10 Nonattainment Area Emissions Inventories for 2008 and 2018 Base Years 

and Design Days (EI TSD).

21 See Appendix C, Pinal County PM10 Nonattainment Area Source Apportionment Modeling for 2008 and 2018 

Base Scenario Design Days (Modeling TSD).
December 21, 2015 Final West Pinal PM10 RACM Analysis 5

 Railroads,

 Fires,

 Residential Fuel Combustion, and

 Open Burning.22 

Combined, these five categories totaled 0.19% of the base year nonattainment area-wide emissions 

inventory in 2008, 0.20% in 2018, and not more than 0.6%23 in any of the design day modeling domains 

in either 2008 or 2018.24 All other source categories individually contributed more than 0.5% to the 

emissions inventory on at least one of the design days within the associated modeling domain, and were 

therefore included in the source apportionment modeling.25

The EPA’s BACM guidance definition of significant sources (and impacts), discussed in Section 1.2 EPA

Guidance above, is sufficiently clear as to avoid challenges to interpretation. Thus, a point source or an 

area source category was not deemed significant unless its modeled contribution to PM10 concentrations 

on a stagnation or high wind design day exceeded 5 μg/m3, on a 24-hour average basis.

Significant Sources/Land Uses that contribute more than 5 μg/m3for any design day are as follows:

 Agriculture (County),

 CAFOs,

 Construction,

 Cleared Areas,

 Desert Shrubland (County, Tribal),

 Developed Rural Lands,

 Developed Urban Lands,

 Unpaved Roads (Agricultural, Public, Private, Trails),

 Unpaved Parking Lots (activity-based, excludes windblown), and

 Paved Roads.

Some of the significant sources listed above are consistent with standard emissions source categories (e.g. 

unpaved roads, paved roads, construction, etc.). Certain area sources, such as wind blown emissions from 

vacant lots and unpaved parking areas, are grouped into more general land use categories for inventory 

purposes (e.g. Developed Rural Lands and Developed Urban Lands). Section 2.2 Description of 

Significant Sources lists the types of emitting activities found in each land use category.

Insignificant Sources/Land Uses modeled as individually contributing less than 5 μg/m3are described 

below:

 Unpaved Roads (Tribal, Test Tracks),

 Point Sources,

 

22 These source categories each comprise less than 0.5% of the annual PM10 emissions inventory for the West Pinal 

County nonattainment area. See Appendix B, Pinal County PM10 Nonattainment Area Emissions Inventories for 

2008 and 2018 Base Years and Design Days (EI TSD).

23 Without rounding or truncation the maximum actual combined value for any of the design days is 0.564% 

(Maricopa high-wind 2018).

24 Because these values so small they may include noticeable rounding errors.

25 See Appendix B, Pinal County PM10 Nonattainment Area Emissions Inventories for 2008 and 2018 Base Years 

and Design Days (EI TSD) and Appendix C, Pinal County PM10 Nonattainment Area Source Apportionment 

Modeling for 2008 and 2018 Base Scenario Design Days (Modeling TSD).
December 21, 2015 Final West Pinal PM10 RACM Analysis 6

 Agriculture (Tribal),

 Dairies, and

 Other Windblown Dust [unclassified].

Combined, the maximum modeled 24-hour average impact of these five de minimis sources at any 

monitor is 3.7 μg/m3in 2008 (and 4.1 μg/m3in 2018; in either case, less than 5 μg/m3). Because of the 

minimal impact of these sources, only some of which are under State or County jurisdiction, additional 

control would not advance attainment of the PM10 NAAQS. Non-significant source categories are more 

fully described in Appendix C, Pinal County PM10 Nonattainment Area Source Apportionment Modeling 

for 2008 and 2018 Base Scenario Design Days (Modeling TSD).

Emissions impacts in year 2018 were also calculated based on expected changes for each source category 

(e.g. planned road paving projects that have dedicated funding and schedules for completion) assuming no 

other additional controls.

26

 If a source category was found to be significant for either the 2008 or 2018 

base years at any of the monitors, the source category will be controlled as reasonable. No changes to the 

list of significant source categories were necessary, however, when comparing the ambient impacts of 

2008 and 2018 emissions at each of the monitors. Apportionment modeling results for 2008 and 2018 are 

detailed in an accompanying report.

27 Source impact data for 2008 are summarized here in Table 1.

 

26 See Appendix B, Pinal County PM10 Nonattainment Area Emissions Inventories for 2008 and 2018 Base Years 

and Design Days (EI TSD).

27 See Appendix C, Pinal County PM10 Nonattainment Area Source Apportionment Modeling for 2008 and 2018 

Base Scenario Design Days (Modeling TSD).
December 21, 2015 Final West Pinal PM10 RACM Analysis 7

 

28 Bold values indicate modeled concentrations are greater than the 5 μg/m3 24-hour average significance threshold. N/M means “not modeled,” indicating these 

source categories were not evaluated for low wind conditions. A Hyphen (-) indicates no emission sources of this type are located in the modeling domain. 

29 The “Unpaved Parking Lots” source category only includes activity-based emissions. The windblown dust emissions from unpaved parking lots are a subset of 

the windblown dust emissions from the land use categories on which the lots sit: Cleared Areas, Developed Rural Lands, and Developed Urban Lands. 

30 These totals only include the impacts of local sources, i.e., those within each modeling domain. Regional background concentrations of PM10 are not included.

Table 1: Summary of the West Pinal County Design Day (24-hour) Modeled Source Impacts for 2008 (μg/m3)

Source Category Low-Wind Modeled Impacts28 High-Wind Day Modeled Impacts28

Cowtown PCH Stanfield Cowtown PCH Stanfield Maricopa

Point Sources (permitted) 0.2 0.0 N/M 0.2 0.0 N/M -

Construction Sites 0.9 0.0 0.2 10.8 0.0 0.0 77.0

Cleared Areas N/M N/M N/M 1.2 5.7 2.6 15.4

Desert 

Shrubland

Non-Tribal N/M N/M N/M 35.1 20.5 18.4 8.5

Tribal N/M N/M N/M 6.9 - - -

Total N/M N/M N/M 42.0 20.5 18.4 8.5

Developed Rural Lands N/M N/M N/M 3.5 9.9 3.8 6.3

Developed Urban Lands N/M N/M N/M 0.1 0.9 - 6.9

Other Windblown Dust [unclassified] - - - 0.0 - - 0.8

Dairies - 0.0 0.0 - - 0.0 -

CAFOs 199.5 - 22.2 9.8 - 14.9 0.0

Agriculture

(Cropland)

Non-Tribal 0.1 6.3 6.3 48.4 173.1 78.5 19.2

Tribal 0.1 - - 0.1 - - 0.0

Total 0.2 6.3 6.3 48.5 173.1 78.5 19.2

Unpaved 

Roads

Agricultural 9.6 28.5 60.0 13.6 21.2 21.6 3.5

Public 13.5 72.5 24.5 10.0 7.6 13.3 0.6

Private (including irrigation) 1.2 39.2 25.1 6.6 5.9 4.6 1.9

Trail 0.0 10.3 1.5 0.7 2.2 2.7 0.1

Tribal 1.4 - - 2.0 - - 0.3

Test Track 0.8 - - 1.4 - - --

Total 26.5 150.5 111.1 34.3 36.9 42.1 6.4

Unpaved Parking Lots29 0.1 5.6 5.2 0.1 0.1 0.2 0.3

Paved Roads 5.6 4.1 5.6 0.3 0.1 0.6 0.9

Total30 233.0 166.5 150.5 150.8 247.4 161.1 141.9
December 21, 2015 Final West Pinal PM10 RACM Analysis 8

2.2 Description of Significant Sources

Based on the modeling results, the sources within significant land use categories are listed below.31 

Paved Roads (Public, Private)

Definition:

Any roadway or alleyway which has been covered by concrete or asphalt pavement. 

Types of emitting sources/activities in this land use category include activity-based emissions from:

 Road dust (from airborne deposition) reentrained by motor vehicle travel over the road surface.

 Reentrained road dust from material tracked out onto paved roads from unpaved traffic surfaces

(including track-out from agricultural, construction, and industrial sites).

 Emissions from shoulders of paved roads (including bow wake).

 Tailpipe exhaust, tire and brake wear.

 Reentrained road dust from water erosion and material spills onto paved roads.

Unpaved Roads (Public, Private, Agricultural)

Definition:

Any roadway or alleyway which has not been covered by concrete or asphalt pavement.

Types of emitting sources/activities in this land use category include activity-based and windblown 

emissions from:

 Dirt roads (County maintained, private).

 Trails.

 Roads with asphalt rock dust palliative (ARDP) applied.

 Railroad roadways.

 Agricultural roadways.

 Windblown dust from unpaved roadways under construction.

 Canal roads.

 Permanent unpaved haul/access roads (commercial, municipal, or industrial facilities) [generally 

included in point source emissions category up to the land ownership boundary, otherwise 

included in unpaved roads category].

Unpaved Parking Lots

Definition:

A land parcel that is not paved and that is used for parking, maneuvering, material handling, or 

storing motor vehicles and equipment. This significant source category only includes activity-based 

emissions. Windblown dust emissions from unpaved parking lots are included as a subset of the 

windblown dust emissions from the significant land use categories Cleared Areas, Developed Rural 

Lands, and Developed Urban Lands. Unpaved parking/staging areas for construction and agriculture 

are not included here, but are instead included under the construction and agriculture categories.

Types of emitting sources/activities in this land use category include activity-based emissions from:

 Road dust from motor vehicle travel over the unpaved or non-stabilized surface. 

 

31 Land use/source categories are more fully described in Appendix B, Pinal County PM10 Nonattainment Area 

Emissions Inventories for 2008 and 2018 Base Years and Design Days (EI TSD).
December 21, 2015 Final West Pinal PM10 RACM Analysis 9

Construction (Residential Construction, Commercial Construction, Site Development)

Definition:

Residential – A land parcel which is permitted for residential construction by Pinal County Air 

Quality Control District (PCAQCD) or which contains visible evidence of residential construction 

from aerial photography (e.g. unfinished residential structures and construction equipment).

Commercial – A land parcel which was permitted by PCAQCD for commercial construction for year 

2008.

Site Development – A land parcel which had been significantly cleared of natural desert vegetation 

and is undergoing grading, filling, cutting, or trenching for infrastructure.

Road construction – A segment of road on which dust-producing construction or maintenance 

activities (such as milling or grading) occur. Only activity-based emissions from road work sites are 

included in the Construction category.

Types of emitting sources/activities in this land use category include activity-based and windblown 

emissions from:

 Land clearing and earthmoving activities.

 Haul trucks.

 Material handling, storage, and transport.

 Unpaved haul/access roads.

 Unpaved parking or staging areas.

 Other construction and demolition related activities.

Cleared Areas

Definition:

A land parcel which has been significantly cleared of natural desert vegetation, but does not contain a 

man-made structure or significant coverage by non-native vegetation. Includes areas subject to 

occasional vehicular traffic or other disturbance.

Types of emitting sources/activities in this land use category include windblown dust from:

 Unpaved parking and traffic areas.

 Vacant lots.

 Abandoned farms. 

 Abandoned construction sites.

 Other cleared/disturbed areas.

Developed Lands – Urban

Definition:

A primarily residential land parcel which has been significantly cleared of natural desert vegetation, 

contains a man-made structure, and has a total area of land which is greater than ~50% covered by 

non-native vegetation (e.g. lawn grass), rock, buildings, or pavement. The average portions of these 

properties that are comprised of open, disturbed soils are estimated to be 5%. The significant source 

category most similar to the disturbed portions of developed urban lands is cleared areas. This land 

use category may also include commercial, municipal, or industrial facilities.
December 21, 2015 Final West Pinal PM10 RACM Analysis 10

Types of emitting sources/activities in this land use category include windblown dust from:

 Man-made surfaces (from airborne deposition).

 Unpaved parking areas.

 Permanent unpaved haul/access roads, and parking or staging areas at commercial, municipal, or 

industrial facilities. [non-point source emissions]

 Smaller cleared areas (including vacant lots).

 Open areas subject to other disturbance (i.e. motorized vehicle traffic).

Developed Lands – Rural

Definition:

A primarily residential land parcel (generally ranging from 0.5 to 15 acres) which has been 

significantly cleared of natural desert vegetation, contains a man-made structure, but has a total area 

of land which is less than ~50% covered by non-native vegetation (e.g. lawn grass), rock, buildings, 

or pavement. Land coverage fractions on these parcels are small and have substantial portions of 

exposed soils, at least a portion of which is typically disturbed and susceptible to wind erosion during 

high wind conditions. May include commercial, municipal, or industrial facilities.

Types of emitting sources/activities in this land use category include windblown dust from:

 Unpaved parking areas.

 Permanent unpaved haul/access roads, and parking or staging areas at commercial, municipal, or 

industrial facilities. [non-point source emissions]

 Smaller cleared areas (including vacant lots).

 Open areas subject to other disturbance (i.e. motorized vehicle traffic).

Desert Shrublands

Definition:

A land parcel which has no significant clearing of natural vegetation and contains no man-made 

structures. These lands are generally undisturbed, although some areas are subject to limited 

recreational activities and livestock grazing. This land use category is a combination of public (BLM, 

State trust, etc.) and private land.

Types of emitting sources/activities in this land use category include windblown dust from:

 Off-road (“off-trail”) recreational vehicle travel on open land. [exhaust is included in non-road 

calculations]

 Livestock grazing. [only relevant to the degree to which overgrazing may occur]

Agricultural Operations (Croplands)

Definition:

A land parcel identified through aerial photography as actively growing or showing signs of 

previously growing cultivated crops for agricultural purposes (this land use was verified by an 

external source from the Agricultural community for areas near ambient monitors and further 

subdivided into the types of crops grown in each field surrounding the Maricopa, Cowtown, Pinal 

County Housing, and Stanfield air monitors). When considering significant sources, tribal agriculture 

is excluded from this category. 
December 21, 2015 Final West Pinal PM10 RACM Analysis 11

Types of emitting sources/activities in this land use category include activity-based and windblown 

emissions from:

 Agricultural cropland activities (e.g. harvesting and/or tilling emissions).

 Windblown dust from croplands.

 Permanent unpaved haul/access roads, and parking or staging areas.

Confined Animal Feeding Operations (CAFOs)

Definition:

A land parcel identified as a Confined Animal Feeding Operation.

Types of emitting sources/activities in this land use category include activity-based and windblown 

emissions from:

 Animal movement.

 Animal waste.

 Permanent unpaved haul/access roads, parking or staging areas, and feed lanes.

 Handling and transport of feed and animal waste. 

2.3 PM10 Precursors

Clean Air Act Section 189(e) requires the evaluation of precursor emissions from major stationary 

sources to determine whether emissions from these sources contribute significantly to PM10 levels which 

exceed the air quality standards. Under Section 189(e), a nonattainment plan’s control requirements 

applicable to major sources of primary PM10 emissions (directly emitted), shall also apply to major 

stationary sources of PM10 precursors, but only if the sources contribute significantly to levels which 

exceed the air quality standard in the area. 

Precursors are chemicals that can be converted in the atmosphere to form particles (secondary PM10),

which contribute to ambient PM10 levels. For example, emitted precursor compounds such as nitrogen 

oxides (NOx), sulfur oxides (SOx), or ammonia (NH3) can react to form particulate sulfates, nitrates, and 

ammonium (ammonium sulfate and nitrate). 

While “contribute significantly” is not defined in the Clean Air Act, EPA suggests that for serious PM10

nonattainment areas, “a source category will be presumed to contribute significantly to a violation of the 

24-hour NAAQS if its PM10 impact at the location of the expected violation would exceed 5 μg/m3.”32 

EPA further defines source categories for which regulation will be required in serious PM10 areas as 

“categories of area-wide sources or large individual stationary sources of PM10 or PM10 precursor 

emissions that may be regulated under a specific rule, generic emission limit, or standard of performance, 

or a specific control program in a SIP.”

33

 

ADEQ estimated secondary PM10 emissions impacts at the Cowtown and Pinal County Housing (PCH) 

monitors by correlating worst impact day monitoring data, recorded during a year-long chemical mass 

balance characterization study, with sector-based annual emissions data from the 2008 EPA National 

Emissions Inventory (NEI).

34 These data were evaluated to determine which, if any, emissions sectors 

impact the monitors in question at a level exceeding 5 μg/m3(averaged over a 24-hr period), thus 

significantly contributing to violations of the PM10 24-hour NAAQS. Any source that contributed

 

32 See 59 FR 42011, August 16, 1994.

33 Id. at 42010.

34 2008 NEI Version 3.
December 21, 2015 Final West Pinal PM10 RACM Analysis 12

secondary PM10 to the monitor below this level was not considered significant. Details of the analysis are 

contained in the West Pinal County PM10 Precursor Significance Determination (see Appendix B, Exhibit 

BXVI).

As a result of the evaluation, ADEQ concluded that no source category exceeds the 5 μg/m3significant 

impact threshold for secondary PM10. Table 2 summarizes the source sector secondary pollutant impacts 

at the Cowtown and PCH monitors (Nitrate, Sulfate, and Ammonium). The highest estimated 

contributing source category, on-road mobile, contributes less than 3.5 μg/m3 of secondary PM to either 

monitor on the design days. No source of precursor emissions significantly contributes to exceedances of 

the PM10 standards, mitigating the need to develop control strategies for precursor source categories. 
December 21, 2015 Final West Pinal PM10 RACM Analysis 13

Table 2: Summary of Source Sector Secondary Pollutant Impacts at the Cowtown and PCH Monitors

Cowtown Concentration (μg/m3) PCH Concentration (μg/m3)

Emissions Inventory Sector Ammonium Nitrate Sulfate Total 

Secondary Ammonium Nitrate Sulfate Total Secondary

Total Agriculture 0.84 0.00 0.00 0.84 0.39 0.00 0.00 0.39

Biogenics - Vegetation and Soil 0.00 0.30 0.00 0.30 0.00 0.36 0.00 0.36

Commercial Cooking 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Total Fires 0.00 0.00 0.08 0.09 0.00 0.00 0.05 0.06

Total Fuel Comb - Comm/Institutional 0.00 0.04 0.16 0.20 0.00 0.05 0.10 0.15

Total Fuel Comb - Electric Generation 0.01 0.04 0.05 0.10 0.01 0.05 0.03 0.08

Total Fuel Comb - Industrial Boilers, 

ICEs 0.00 0.06 1.54 1.60 0.00 0.07 0.99 1.05

Total Fuel Comb - Residential 0.00 0.01 0.01 0.03 0.00 0.02 0.01 0.03

Total Industrial Processes 0.01 0.04 0.32 0.37 0.00 0.05 0.21 0.26

Miscellaneous Non-Industrial NEC 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Mobile - Aircraft 0.00 0.00 0.01 0.01 0.00 0.00 0.01 0.01

Mobile - Locomotives 0.00 0.38 0.18 0.56 0.00 0.46 0.11 0.57

Total Mobile - Non-Road 0.00 0.37 0.38 0.76 0.00 0.45 0.25 0.69

Total Mobile - On-Road 0.03 2.35 0.98 3.36 0.01 2.82 0.63 3.46

Solvent - Industrial Surface Coating & 

Solvent Use 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Waste Disposal 0.01 0.05 0.07 0.14 0.01 0.07 0.05 0.12
December 21, 2015 Final West Pinal PM10 RACM Analysis 14

3.0 CONTROL MEASURE ANALYSIS FOR SIGNIFICANT SOURCES

3.1 Review of Existing Measures

As a first step to selecting control strategies for significant sources, ADEQ reviewed existing control 

measures as of 2008 to determine which could be considered for strengthening and where the addition of 

new measures were necessary. A 2005 construction rule and a 2004 fugitive dust rule that apply to

numerous significant emitting activities were in place in 2008 (see Table 3). Agriculture Operations 

(Croplands) and Confined Animal Feeding Operations (CAFOs) were also determined to be a significant 

contributor to exceedances of the NAAQS. The Agricultural Best Management Practices (BMP) rules at 

AAC R18-2-Article 6 did not contain measures applicable to the West Pinal area in 2008.

Strengthening of the existing construction and fugitive dust rules and revision of the existing State 

agriculture rules to include RACM provisions for the West Pinal Nonattainment Area were determined 

necessary. 
December 21, 2015 Final West Pinal PM10 RACM Analysis 15

Table 3: Control Programs Applicable to PM10 Sources in the West Pinal PM10 Planning Area (as of 2008)

Regulation Number/

Program Name Description Applicable to Source Category

Applicable SIP

(Citation) Last Revised

Pinal County Code of Regulations

Chapter 4. Emissions from Existing and New Non-Point Sources;

Article 2. Fugitive Dust

4-2-020. General Statement of purpose to reasonably regulate 

operations which periodically may cause fugitive 

dust emissions into the atmosphere.

Applicable in Pinal County.

Residential/Commercial 

Construction, Land Clearing, 

and Earthmoving Activities; 

Open Areas and Vacant 

Lots; Parking Areas; 

Agricultural Operations; 

Material Storage, Transport, 

and Handling; Paved Roads; 

Commercial Feedlots or 

Livestock Areas

75 FR 17307; 

04/06/2010

12/04/2002

4-2-030. Definitions Definitions. 75 FR 17307; 

04/06/2010

12/04/2002

4-2-040. Standards Requires reasonable precautions to prevent fugitive 

dust from becoming airborne for activities such as: 

construction; earthmoving; vehicular traffic on 

vacant lots and open areas; parking areas, 

agricultural practices; land clearing; material 

handling, transport, and storage; paved road track 

out; commercial livestock area activities; road and 

alley construction or repair; and construction of 

mineral tailing piles.

72 FR 41896; 

08/01/2007

10/27/2004 

(06/29/1993 

version in SIP)

4-2-050. Monitoring and 

Records

Sources subject to §4-2-040. are subject to the 

visible opacity limitations in Chapter 2, Article 8 

[20%] as determined by opacity observations 

conducted in accordance with techniques specified 

in Reference Method 9 in the Arizona Testing 

Manual for Air Pollutant Emissions.

72 FR 41896; 

08/01/2007

10/27/2004 

(05/14/1997)
December 21, 2015 Final West Pinal PM10 RACM Analysis 16

Table 3: Control Programs Applicable to PM10 Sources in the West Pinal PM10 Planning Area (as of 2008)

Regulation Number/

Program Name Description Applicable to Source Category

Applicable SIP

(Citation) Last Revised

Pinal County Code of Regulations

Chapter 4. Emissions from Existing and New Non-Point Sources;

Article 3. Construction Sites - Fugitive Dust

4-3-060. General 

Provisions

Statement of intent, applicability, and exceptions.

Applicable throughout Pinal County for "affected 

activities" if the disturbed surface area is greater 

than 0. 1 acre. Includes exception for facilities 

operating under authority of a permit issued 

pursuant to ARS §§49-426 or 49-480. 

Residential/Commercial/

Roadway Construction

12/4/2002

4-3-070. Definitions Definitions (includes specified control measures 

and work practices).

10/27/2004

4-3-080. Registration 

Requirements

Requires registration, description of planned 

activity, explanation of mitigation measures and 

evidence of implementation. Allows annual 

“Block Registration” for selected activities. 

Projects greater than or equal to five acres require 

onsite posting of contact information for public 

dust complaints.

12/21/2005

4-3-090. Universal 

Performance Standards

Requires the opacity of dust leaving the property 

not to exceed twenty percent (20%) as measured 

using Test Method 9 (40 CFR 60, Appendix A) or 

approved equivalent method.

Authorizes Control Officer to order a cessation for

noncompliant activities. Violators may be subject 

to an order of abatement, a civil action for 

injunctive relief or civil penalties, or may be found 

guilty of a Class I Misdemeanor. Includes 

exception for wind event provided all required

measures were in place.

10/27/2004
December 21, 2015 Final West Pinal PM10 RACM Analysis 17

Table 3: Control Programs Applicable to PM10 Sources in the West Pinal PM10 Planning Area (as of 2008)

Regulation Number/

Program Name Description Applicable to Source Category

Applicable SIP

(Citation) Last Revised

Pinal County Code of Regulations

Chapter 4. Emissions from Existing and New Non-Point Sources;

Article 6. Restrictions on Vehicle Parking and Use on Vacant Lots

4-6-200. Unpaved and 

Disturbed Vacant Lots, 

Restriction on Vehicle 

Parking and Use; 

Applicability

Rule is applicable only in the “Area A”35 portion of 

the West Pinal PM10 Planning Area.

Property subject to the rule includes any unpaved 

or disturbed vacant lot.

Vacant Lots

9/10/2008

4-6-210. Control 

Requirements

Contains provisions for restricting vehicle parking 

and use on distubed vacant lots.

9/10/2008

 

35

“Area A” is defined at A.R.S. § 49-541.
December 21, 2015 Final West Pinal PM10 RACM Analysis 18

3.2 Identification of Available Measures

3.2.1 Initial List of Available Control Measures

Appendix C1 to the General Preamble for the Implementation of Title I of the Clean Air Act lists 15 

specific available Fugitive Dust control measures that are required to be considered in any RACM 

analysis.36 These measures, together with the relevant West Pinal significant source categories are listed 

in Table 4. Measures identified in Appendices C2 – Residential Wood Combustion and C3 – Prescribed 

Burning of the General Preamble are not applicable to any significant source categories in the West Pinal 

PM10 planning area and are, therefore, not included in the discussion below. Similarly, measures and 

analyses recommended in Appendix C4 – RACT Determinations for Stationary Sources are not applicable

to any significant sources. No major point sources of PM10 are located in any of the modeling domains. 

Of the three major sources in the Nonattainment Area (outside the individual modeling domains), all are 

natural gas fired power plants with inherently low PM10 emissions. Two of the facilities hold Prevention 

of Significant Deterioration (PSD) permits with Best Available Control Technology (BACT) 

determinations that list “good combustion practices.” 

Table 4: Fugitive Dust Control Measures Required To Be Considered

Control Measure

Applicable to West Pinal Significant 

Land Use/Source Category

1. Pave, vegetate, or chemically stabilize access points 

where unpaved traffic surfaces adjoin paved roads.

Paved Roads. 

2. Require dust control plans for construction or land 

clearing projects. 

Construction and Agricultural 

Operations. 

3. Require haul trucks to be covered. Paved Roads, Construction, and 

Agricultural Operations. 

4. Provide for traffic rerouting or rapid cleanup of 

temporary (and not readily preventable) sources of dust on 

paved roads (water erosion, runoff, mud/dirt carryout areas, 

material spills, skid control sand). Delineate who is 

responsible for cleanup.

Paved Roads. 

5. Require paving, chemically stabilizing, or otherwise 

stabilizing permanent unpaved haul roads, and parking or 

staging areas at commercial, municipal, or industrial 

facilities.

Construction, Agricultural Operations, 

Developed Urban, Developed Rural, 

Cleared Areas, Unpaved Parking Lots, 

and CAFOs. 

6. Develop traffic reduction plans for unpaved roads. Use 

of speed bumps, low speed limits, etc., to encourage use of 

other (paved) roads.

Unpaved Roads. 

7. Limit use of recreational vehicles on open land (e.g., 

confine operations to specific areas, require use permits, 

outright ban).

Desert Shrublands, Cleared Areas, 

Developed Urban, Developed Rural. 

(includes the insignificant “Trails” 

portion under the Unpaved Roads 

category)

8. Require improved material specification for and reduction 

of usage of skid control sand or salt (e.g., require use of 

coarse, nonfriable material during snow and ice season).

Not applicable to any significant 

source. 

 

36 State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments 

of 1990; Supplemental, 57 FR 18070-18077, April 28, 1992. 
December 21, 2015 Final West Pinal PM10 RACM Analysis 19

Table 4: Fugitive Dust Control Measures Required To Be Considered

Control Measure

Applicable to West Pinal Significant 

Land Use/Source Category

9. Require curbing and pave or stabilize (chemically or with 

vegetation) shoulders of paved roads.

Paved Roads.

10. Pave or chemically stabilize unpaved roads. Unpaved Roads. 

11. Pave, vegetate, or chemically stabilize unpaved parking 

areas.

Construction Sites, Agricultural 

Operations, Cleared Areas, Developed 

Urban, Developed Rural, and Unpaved 

Parking Lots. 

12. Establish dust control measures for material storage 

piles.

Construction. 

13. Provide for storm water drainage to prevent water 

erosion onto paved roads.

Paved Roads. 

14. Require vegetation, chemical stabilization, or other 

abatement of wind erodible soil, including lands subjected to 

water mining, abandoned farms, and abandoned construction 

sites.

Cleared Areas. 

15. Rely upon the soil conservation requirements (e.g., 

conservation plans, conservation reserve) of the Food 

Security Act to reduce emissions from agricultural 

operations.

Agricultural Operations.

3.2.2 Measures Adopted in Other Areas

Although few PM10 moderate area plans containing RACM measures were developed in the early 1990s 

after the enactment of the 1990 CAA amendments, one resource of available measures is a 1999 Federal 

Implementation Plan (FIP) in which EPA promulgated RACM for several fugitive dust source categories

in the Phoenix, Arizona PM10 planning area. 

There were, however, several serious area plans containing BACM measures that were submitted to and 

approved by EPA. Many of these plans were developed by jurisdictions in the Pacific Southwest, 

including those listed below.

 San Joaquin Valley Air Pollution Control District (SJVAPCD), California

 Great Basin Unified Air Pollution Control District (GBUAPCD), California

 South Coast Air Quality Management District (SCAQMD), California

 Coachella Valley, California (Part of the SCAQMD)

 Mojave Desert Air Quality Management District (MDAQMD), California

 Imperial County Air Pollution Control District (ICAPCD), California

 Clark County Department of Air Quality, Nevada

 Maricopa County Air Quality Department, Arizona
December 21, 2015 Final West Pinal PM10 RACM Analysis 20

PM10 emissions control rules developed by these areas were reviewed, summarized, and grouped by 

source category for use in assessing commonalities and differences in control approach.37 These results 

were used as the starting point for first identifying appropriate measures applicable to significant PM10

sources in Western Pinal County and then, in the case of available BACM, formulating corresponding 

RACM measures using the relationships between BACM and RACM as defined in EPA guidance. 

BACM and RACM strategies relevant to the West Pinal PM10 Nonattainment Area are summarized in 

Exhibit 1and discussed in Section 3.2.3 below. 

3.2.3 Discussion of Candidate Measures

Paved Roads (Public, Private)

Several measures applicable to paved roads are listed in Appendix C1 of the General Preamble. These 

measures, primarily designed to reduce silt loading, include undefined requirements for prevention and 

cleanup of trackout and water erosion runoff from unpaved surfaces onto paved roads and stabilization of 

road shoulders or installation of curbing, as well as provisions for storm water drainage to prevent erosion 

onto paved roads. 

Available BACM measures incorporate the listed preamble measures with the addition, in some cases, of

street sweeping and reduced speed limits. Most BACM include de minimis daily traffic levels below 

which controls are not required or restrict applicability to certain higher impact areas. For example, road 

shoulder paving or stabilization measures are based on road type and usage. Minimum paved or 

stabilized shoulder width requirements may range from 2 to 8 feet depending on average daily vehicle 

trips. The width requirements may also vary depending on type of road: arterial, collector, local, etc. 

Measures for PM10 efficient street sweepers might only be applicable to urban areas. 

After consideration of available measures relevant to paved roads and the needs of the West Pinal area, 

potential RACM measures might include the following:

• Pave or stabilize (chemically or with vegetation) shoulders of paved roads or install curbing;

• Ensure stabilization during weed abatement/vegetation management on unpaved shoulders of 

paved roads;

• Stabilize medians;

• Pave, vegetate, or chemically stabilize access points where unpaved traffic surfaces adjoin paved 

roads;

• Rapid clean up of sources of dust on paved roads (water erosion runoff, mud/dirt carryout areas, 

material spills);

• Provide for storm water drainage to prevent water erosion onto paved roads;

• Employ street sweepers; and

• Reduce speed limits.

Unpaved Roads (Public, Private, Agricultural)

 

37 The results of this effort are contained in Control Measures Applicable to the West Pinal County PM10

Nonattainment Area Significant Sources, February 20, 2015. Because of its large size it is not included in this 

document but is available upon request.
December 21, 2015 Final West Pinal PM10 RACM Analysis 21

Unpaved Roads (Public, Private38)

Several RACM measures are available for unpaved roads including paving or other stabilization and 

reduced usage and speed limits. RACM guidance published by EPA requires that traffic reduction plans 

and paving or chemical stabilization be evaluated for unpaved road control. Traffic reduction plans can 

be effective in areas of dense roadway networks, where the traveling public is not significantly 

inconvenienced by having to use alternative paved roads in place of unpaved roads. In the rural portions 

of the West Pinal County PM10 nonattainment area, however, this measure will not be feasible because of 

the substantial increases in route lengths that would have to be driven through the selective closure of 

unpaved roads. The use of paving or chemical stabilization for unpaved road emission control is 

addressed by the requirements of the model RACM measure offered in this analysis. In the Phoenix area 

RACM FIP control strategies are applicable only to unpaved roads open to public access and owned or 

operated by governmental or quasi-governmental agencies with average daily trips of 250 vehicles or 

greater.

BACM measures applicable to unpaved roads to which the public has access generally include emission 

limits framed in units of plume opacity and requirements for road owners to use acceptable surface 

treatments from lists included in regulations. Several measures require local governments to treat 

increasing fractions of unpaved roads under government ownership or control over a period of years 

commencing with rule adoption dates. This staging of control implementation is intended to recognize 

expenditure limitations imposed on some local governments. Most BACM measures also include 

de minimis daily traffic levels below which controls are not required. 

The typical plume opacity limit allowed for vehicle travel over unpaved roads is 20% in reviewed RACM 

and BACM. Some BACM measures further include a surface silt loading limit of 0.33 oz/ft2. Because of 

the commonality of the opacity limit among RACM and BACM measures, this limit of 20% should be 

given consideration for inclusion in a RACM measure for the Western Pinal County nonattainment area.

As noted above, many BACM measures for public unpaved roads include a schedule for treating or 

paving increasing or fixed fractions of the total miles of unpaved roads within the nonattainment area or 

within a jurisdiction’s boundaries. Some BACM measures contain fixed schedules (e.g., conversion to 

asphalt concrete pavement of 10% of original unpaved road inventory annually), while others allow the 

affected jurisdiction to propose a schedule with economic justification for consideration by the regulatory 

agency.

Under most BACM, low traffic volume roads are exempted from controls on the basis of costeffectiveness considerations. The traffic volume thresholds for control range from 26 to 150 vehicles per 

day, with a mode of 50 vehicles per day. The threshold in the one reviewed RACM measure was 250 

vehicles per day.

Based on the analysis of RACM and BACM measures applicable to public unpaved roads, control 

strategies for the West Pinal areamay include, as one option, the requirements outlined below:

 Exempt from controls on the basis of de minimis emissions public unpaved roads that experience 

250 or fewer vehicles per day;

 Limit visible opacity to 20% for emission plumes from vehicle travel on unpaved roads subject to 

control requirements;

 

38 In this context, “Private” does not include unpaved agricultural, irrigation district, or construction roads. These 

sources are included under the construction and agricultural categories.
December 21, 2015 Final West Pinal PM10 RACM Analysis 22

 Limit controls to those typically listed in BACM measures with the option to propose new 

controls upon review and approval of the Pinal County Air Quality Control District (PCAQCD);

 Require local governments maintaining public road networks within the PM10 nonattainment area 

to submit plans and schedules for applying stabilization measures to increasing fractions of nonexempt unpaved roads, for review and action by the PCAQCD;

 Develop traffic reduction plans to encourage use of paved roads (non-rural areas); and

 Require speed restrictions.

Unpaved Roads (Agriculture)

Arizona Revised Statutes (ARS) §49-457 authorizes control of PM10 emissions from agricultural sources 

including crop and animal operations and irrigation districts.

39

 As currently enacted, the statute requires 

each owner/operator of an agricultural operation required to have an agricultural PM10 general permit to 

implement at least one Best Management Practice (BMP) for each emitting activity in a moderate PM10

nonattainment area. This program requires adoption of BMPs for agricultural and irrigation district road 

PM10 emission control.

New agricultural rules for the West Pinal County Nonattainment Area could include the following 

measures:

 Pave or stabilize unpaved roads, access connections, and high traffic areas;

 Limit vehicle access to unpaved roads, access connections, and high traffic areas; and

 Reduce vehicle speed.

Unpaved Parking Lots

Discussion of measures for unpaved parking lots is included under Developed Lands – Urban and 

Developed Lands – Rural.

Construction (Residential Construction, Commercial Construction, Site Development)

Construction sites were determined to be a significant source category only on high-wind design days. 

Therefore, analysis of RACM for construction sites in Western Pinal County focused on measures that 

reduce emissions from disturbed soil surfaces during high wind conditions such as disturbed surface 

stabilization. There may also be some co-benefit of measures designed primarily to reduce emissions on 

low-wind days such as speed limits for vehicles traveling on unpaved surfaces, covering haul truck 

(tarping), and unpaved-to-paved road track-out cleanup. Therefore, low-wind measures were also 

included in the review of existing rules. 

BACM control measures adopted by PM10 serious nonattainment areas typically require specific work 

practices to be performed to control emissions during high wind conditions. This is due primarily to the 

present lack of cost-effective temporary solutions to effectively control windblown PM10 emissions under 

the range of wind speeds experienced in areas like Western Pinal County from soil surfaces continuously 

disturbed during bare-land construction activities. Emission limits in rules applicable to construction sites 

are usually suspended by regulatory exemption when average hourly wind speeds exceed thresholds of 15 

 

39 Irrigation district includes unpaved operation and maintenance roads, canals, and utility access roads.
December 21, 2015 Final West Pinal PM10 RACM Analysis 23

to 25 mph. Preventive or remedial work practices are specified in several rules in advance of or during 

high wind conditions. Work practices applicable to these sources include the application of water or dust 

palliatives, and the installation of wind fencing or vegetative barriers to reduce emissions from disturbed 

soil areas; and the surface application of water or dust palliatives, tarping, or the construction of wind 

shelters or enclosures to control emissions from fine material storage piles. Many construction control 

rules also require the shutdown of earthmoving and other soil-disturbance activities whenever the 

specified threshold wind speed is exceeded.

Several, but not all, adopted BACM measures for large construction sites require the development and 

approval of dust control plans prior to commencement of construction. Such plans typically are required 

to address PM10 emissions from each phase of construction, including periods of high wind conditions. 

Plans developed under these rules are site-specific and may include innovative techniques for controlling 

windblown PM10 that are typically pre-negotiated with the regulatory agency before plans are submitted 

for evaluation and approval. Such control techniques, however, are required to be equivalent in control 

effectiveness to applicable BACM measures listed in construction control rules. 

EPA PM10 SIP guidance requires that dust control plans be evaluated as a candidate RACM if 

construction or land clearing activities are significant sources. The guidance assumes that construction 

PM10 emissions are significant in the absence of high wind conditions. Because construction emissions 

are significant in Western Pinal County only during high wind conditions, a substantial portion of benefits 

anticipated by the U.S. EPA in drafting this guidance will not be realized here. The remaining portions of 

dust control plans that address high wind PM10 emissions from disturbed soil surfaces are addressed by 

the BACM measures reviewed in this analysis. As a result, RACM strategies extrapolated from these 

BACM measures will satisfy requirements of the U.S. EPA guidance. 

Based on the analysis of BACM measures applicable to construction sites, a RACM measure derived 

from applicable BACM regulations may include, as one option, the requirements outlined below:

 Cease soil disturbance activities whenever hourly average wind speeds exceed a specified mph 

threshold as indicated by dust plume opacities exceeding 20% on a three-minute average basis,

 Apply water to disturbed soil and fine material storage pile surfaces during work hours whenever 

peak hourly average wind speeds exceed a given threshold,

 Apply water to disturbed soil and fine material storage pile surfaces at the end of a work day 

whenever high wind speeds are forecast by PCAQCD to occur prior to construction resuming 

either the following day or the next scheduled work day,

 Exempt construction sites of less than 0.5 acres total disturbed area from control requirements,

 Control spillage and cover haul vehicles, and

 Restrict site access or limit vehicle speeds.

Cleared Areas

Cleared areas were found through air quality modeling to be a significant source category on high wind 

days in Western Pinal County. These are areas from which vegetation has been removed and the land 

leveled in preparation for construction, agricultural cultivation, or other future purpose, but which are not 

currently in active use. BACM measures applicable to these areas are primarily designed to control the 

emissions from high wind entrainment of loose surface soil particles.

Adopted BACM measures in serious area PM10 plans applicable to cleared areas primarily focus on 

mitigation and, to a lesser extent, prevention of additional soil disturbance activities at such sites. These 
December 21, 2015 Final West Pinal PM10 RACM Analysis 24

rules typically require the use of one or more listed work practices to achieve stabilized soil specifications 

and to limit visible plumes generated during high wind conditions to 20% opacity. The work practices 

listed in a number of these BACM rules include water application, application of dust palliatives, 

establishment of protective vegetation, or the application of a gravel blanket or asphalt concrete pavement 

to protect exposed soils. Stabilized soil specifications in BACM measures commonly specify crust 

strength as measured by a simple field test, surface soil texture as measured by a hand sieving protocol, or 

horizontal or vertical vegetation coverage fractions as measured by visual estimation. Prevention 

measures, which are typically required only when illegal vehicle trespass is observable and continuous, 

include the installation of “No Trespassing” signage and/or barriers to block vehicle access. Applicability 

thresholds in reviewed BACM generally range from 0.1 to 3.0 acres. An available RACM measure 

provides a 5,000 square foot threshold only for disturbance by motor vehicle traffic.40

Based on the analysis of measures applicable to cleared areas, a RACM measure would include, as one 

option, the following requirements:

 Exempt from controls, on the basis of de minimis emissions, parcels within areas zoned for 

residential or commercial development that contain less than 0.5 acres of disturbed soils and 

parcels under other zoning designations that contain less than 3.0 acres of disturbed soils;

 Install “No Trespassing” signs at the vehicle entry points to areas containing more than 0.1 acre

of surface area disturbed by motor vehicle trespass;

 Establish ground cover vegetation sufficient to stabilize;

 Restore to a natural state;

 Apply dust suppressants; and

 Apply surface gravel.

Developed Lands - Urban

Developed urban lands were determined through air quality modeling to be a significant source 

contributing to exceedances of the 24-hour PM10 standard during high wind conditions at the Maricopa 

monitoring site. Developed urban lands are parcels hosting urban development at densities and with 

amenities that result in almost 100% soil coverage with structures, asphalt concrete or Portland concrete 

pavement, and landscaping vegetation. Rergardless, the average portions of these properties that are 

comprised of open, disturbed soils were estimated by PCAQCD to be 5%.41 

The disturbed portions of developed urban land typically include smaller cleared areas (including vacant 

lots), dedicated unpaved parking and traffic areas, and open areas subject to disturbance (i.e. motorized 

vehicle traffic). Because of the suggested exemption threshold for cleared areas, cleared-area RACM 

applied in developed urban areas may not be as cost-effective for the control of windblown PM10 when 

applied to areas estimated to be as small as 0.008 acres42 on individual parcels of developed urban land. 

RACM for developed urban land may include:

 Limit vehicle access,

 Establish ground cover vegetation sufficient to stabilize,

 Restore to a natural state,

 

40 Five thousand (5,000) square feet is approximately equal to 0.11 acres. For certain comparisons, however, the 

value is rounded to 0.1 acres.

41 Email communication from Don Gabrielson, Pinal County AQCD, to Bob Dulla, Sierra Research, dated May 23, 

2013.

42 Based on a smaller urban parcel size of 7,260 ft2

(1/6th acre). Sierra Research 2014.
December 21, 2015 Final West Pinal PM10 RACM Analysis 25

 Apply dust suppressants,

 Apply surface gravel, and

 Pave.

Developed Lands - Rural

Developed rural lands were also determined to be a significant source impacting the Maricopa monitoring 

station on high wind days. Developed rural lands are parcels primarily hosting single-family residences 

on larger land areas, ranging from 1 to 15 acres. Land coverage fractions on these parcels are small and 

have substantial portions of exposed soils, at least a portion of which are typically disturbed and 

susceptible to wind erosion during high wind conditions. Similar to developed urban land, the disturbed 

portions of developed rural areas typically include smaller cleared areas, unpaved parking areas, and open 

areas subject to other disturbance. 

Disturbed open areas are required under BACM rules to have soil surfaces sufficiently stabilized to 

prevent windblown plume opacities from exceeding 20%. Because developed rural lands may contain 

disturbed areas greater than the suggested cleared area de minimis threshold, soil stabilization 

requirements could be applied to developed rural lands as a BACM measure. While the costeffectiveness of soil stabilization may be reasonable on these lands, the ability of property owners to 

satisfy such requirements would be challenging.

On the basis of this analysis, a RACM measure applicable to developed rural lands would include, as one 

option, the following requirement:

 Limit vehicle access,

 Establish ground cover vegetation sufficient to stabilize,

 Restore to a natural state,

 Apply dust suppressants,

 Apply surface gravel,

 Pave.

Desert Shrublands

Desert shrublands are those undeveloped lands in Western Pinal County that are owned by public or 

private entities and that mostly have not been previously disturbed from a natural state. Desert shrublands 

were found through air quality modeling to be a significant source category on high wind design days at 

each of the four analyzed monitoring stations recording exceedances of the 24-hour standard in 2008. 

The sources of PM10 emissions from these lands are the emissive soil areas disturbed by off-road or offhighway recreational vehicle (OHV) traffic and limited livestock grazing (only relevant to the degree to 

which overgrazing may occur). Grazing leases issued by the Arizona State Land Department (ASLD) are 

based on the carrying capacity of the land parcel that is leased. The lessee cannot exceed the established 

carrying capacity and is responsible to repair any damage caused by his/her livestock. In the interest of 

the lessees own grazing operation the lessee can, with ASLD approval, make range improvements to the 

leased allotment for future grazing seasons. 

Applicable rules generally require minimizing soil disturbance by limiting operations of off-road 

recreational vehicles to specific areas. Some rules require vehicle owners to first obtain authorization 

from public land managers or consent from private owners. One area requires a dust control plan for 
December 21, 2015 Final West Pinal PM10 RACM Analysis 26

activity on public land. Some areas operated by land managers (ASLD) have been closed to OHV traffic 

due to overuse.

Based on the analysis of measures applicable to desert shrublands, a RACM measure derived from 

adopted BACM rules would include, as one option, the following requirement:

 Require vehicles operating on either undeveloped public or private properties to remain on 

maintained roads or comply as specified with the following: on public property, obtain lawful 

authority; and on private property, obtain the consent of the owner.

Agricultural Operations (Croplands)

Agricultural operations occupy a considerable portion of the Western Pinal County PM10 nonattainment 

area. Air quality modeling found that these operations qualified as significant sources on both low wind 

and high wind days. As a result, BACM measures that control PM10 emissions during both stagnation 

and high wind days were considered in this analysis.

BACM rules applicable to agricultural operations have been developed by only a few serious PM10 

nonattainment areas where agricultural operations constitute significant portions of the local economy and 

the PM10 emission inventory. The regions in which the most work has been done to identify emissions 

characteristics of individual activities and to evaluate the effectiveness and feasibility of alternative 

control approaches have been San Joaquin Valley and Imperial County in California and Maricopa 

County in Arizona. For that reason, the analysis of agricultural operation BACM measures was focused 

on these three programs. In each program, owners or operators of agricultural operations are required to 

implement Best Management Practices (BMPs) to control PM10 emissions from each dust-generating 

activity conducted on agricultural parcels. Under Arizona state law, owner/operators in the Maricopa 

County serious area are required to implement two BMPs for each affected activity. BMPs are detailed 

and compiled into handbooks in each jurisdiction, and are periodically updated to reflect the findings of 

new research. Both of these programs also require each owner/operator of an operation exceeding 40 to 

100 acres in size to develop and submit for approval a dust control plan identifying each BMP 

commitment for each affected activity.

Based on the analysis of BACM measures applicable to agricultural operations, a RACM measure derived 

from adopted BACM rules would include, as one option, the following requirements:

 Exempt from controls, on the basis of de minimis emissions, agricultural operations on parcels of 

100 acres or less that are 1.0 mile or greater from any zoned residential area;

 Implement one BMP each to control emissions from agricultural activities that collectively 

produce 50% of annual PM10 emissions from an individual commercial agricultural operation;

and

 Develop a BMP plan for each affected agricultural operation.

Confined Animal Feeding Operations (CAFOs)

Confined animal feeding operations (CAFO) are facilities in which animals bred for human consumption 

are fattened prior to transport to meatpacking facilities. CAFOs in Western Pinal County are used 

primarily to fatten beef cattle for market. Air quality modeling determined that CAFOs were a significant 

source of PM10 emissions on both stagnation and high wind design days.
December 21, 2015 Final West Pinal PM10 RACM Analysis 27

BACM regulations specific to CAFOs have been adopted in those serious PM10 nonattainment areas 

where agricultural operations are significant in terms of the local economy and PM10 emissions. The most 

extensive work in controlling PM10 emissions from CAFOs has been done in San Joaquin Valley, 

Imperial County, and in Maricopa County. In these jurisdictions, CAFO regulations are designed to 

parallel those applicable to agricultural operations, requiring the development and submittal of BMP plans 

and commitment to at least one listed BMP for each PM10 emission activity occurring within a CAFO. In 

two of the applicable regulations, CAFO owner/operators are also required to submit annual emission 

inventories for their facilities and apply for and maintain industrial source operating permits. These two 

regulations also contain specific requirements for the management of manure, both within livestock pens 

and after removal.

Based on the analysis of BACM measures applicable to CAFOs in San Joaquin Valley, Imperial County,

and in Maricopa County, a RACM measure derived from adopted BACM rules would include, as one 

option, the following requirement:

 Develop and implement PM10 control plans addressing all PM10 emission sources designed to 

reduce facility-wide PM10 emissions by 50% on a per-head basis from a 2016 baseline within 

each affected facility. 

3.2.4 Stakeholder Process

ADEQ and the Pinal County Air Quality Control District worked with their partners to analyze emissions 

and develop control strategies for the West Pinal PM10 Nonattainment Area. Participation was 

encouraged and technical advice sought through meetings and discussion with governmental departments 

and agencies, municipalities, members of the regulated community, and other interested parties; and 

through the public comment process for rulemakings (construction and fugitive dust rules). Participating 

entities include those listed below.

Arizona Governor’s Agricultural Best Management Practices Committee

The best management practices committee was established under A.R.S. § 49-457 to develop an 

agricultural general permit specifying best management practices to reduce PM10 emissions from

regulated agricultural activities. The fifteen member committee currently consists of representatives 

from: ADEQ, Arizona Department of Agriculture, University of Arizona College of Agriculture (2), U.S. 

Natural Resources Conservation Service, Pinal County Air Quality Control District, and members 

engaged in the cotton, vegetable, grain, alfalfa, citrus, poultry, beef cattle, swine, and dairy industries.

Arizona Chapter, Associated General Contractors (The Associated General Contractors of 

America)

The Associated General Contractors is an association of general contractors, subcontractors, and other 

construction industry affiliated firms engaged in highway, heavy, industrial and municipal-utility 

construction.

Home Builders Association of Central Arizona

The Home Builders Association of Central Arizona is a trade association for the residential construction 

and development industry.

Maricopa Association of Governments

The Maricopa Association of Governments is the regional air quality planning agency (ozone, carbon 

monoxide, particulate matter) and metropolitan planning organization for transportation planning for all 
December 21, 2015 Final West Pinal PM10 RACM Analysis 28

jurisdictions in Maricopa County and the contiguous urbanized area in Pinal County (a member agency), 

including the Town of Florence, City of Maricopa, and the City of Apache Junction. 

Sun Corridor Metropolitan Planning Organization

The Sun Corridor Metropolitan Planning Organization provides transportation planning services to the 

communities of Casa Grande, Coolidge, Eloy and rural portions of Pinal County. 

Pinal County Public Works Department

The Pinal County Public Works Department provides, among other services, transportation infrastructure, 

engineering, flood control, and emergency management services. The County storm water management 

program includes management of flooding and erosion control. 

Bureau of Land Management - Arizona

The Bureau of Land Management administers public lands under its jurisdiction within the state

providing field management for areas that include recreational, commercial, scientific and cultural 

interests.

Arizona State Land Department

The Arizona State Land Department manages lands that are the subject of a public Trust created to 

support public schools and education in the State. The Trust accomplishes this goal in a number of ways,

including the sale and lease of Trust lands for grazing, agriculture, municipal, residential, commercial and 

open space purposes. 

Arizona Game and Fish Department

The Arizona Game and Fish Department manages wildlife resources, regulates watercraft use, and 

enforces off-highway vehicle laws. The Department works in cooperation with sovereign tribes, local 

governments, and private land owners.

Municipalities (e.g., City of Maricopa, City of Casa Grande)

Arizona Department of Transportation

The Arizona Department of Transportation is the agency responsible for planning, building, and operating 

the State highway system and bridges.

Indian Communities (e.g., Gila River Indian Community, Ak-Chin Indian Community)

United States Environmental Protection Agency

Other Members of the Regulated Community

Members of the Public
December 21, 2015 Final West Pinal PM10 RACM Analysis 29

4.0 SELECTED MEASURES

Reasonably available control measures for the West Pinal PM10 Nonattainment Area are encompassed in 

three rulemakings: one for construction sources, one for agricultural sources, and one for general fugitive 

dust sources. Sections 4.1 through 4.3 present these rules and provide discussion and comparison to 

control strategies adopted in other planning areas in the pacific southwest. The listed measures achieve 

emissions reductions sufficient to demonstrate attainment by the December 2018 deadline as well as meet 

contingency plan goals. 

In this analysis, measures are considered technologically feasible if the relevant control is currently 

available and implemented elsewhere, shown to be enforceable and practicable in the West Pinal planning 

area, and achieves emissions reductions prior to the December 2018 attainment date.43 Because a 

violation of the standard is a calculated 3-year average, emissions reductions from measures relied upon 

for attainment must generally begin in January 2016. Contingency measures are not required to be 

implemented unless the area fails to meet RFP goals or attain the NAAQS by the attainment date. 

ADEQ determined that attainment measures should be selected from rules with the earliest effective date 

and scheduled to be fully implemented by January 1, 2016. Other measures were determined more 

appropriate to meet contingency and “weight of evidence” goals, such as those that are incrementally 

implemented over time (e.g. paving of unpaved roads). 

In the process of evaluating the economic feasibility of potential measures, a number of criteria may be 

considered regarding the cost of reducing emissions, including capital and operational costs, availability 

of funding and resources, and cost effectiveness measured in dollars per ton of emissions reduced. The 

General Preamble suggests that in the case of public sector sources and control measures, the cost 

evaluation should consider the impact on the government entity that must assume responsibility for 

implementation of those measures.44 No fixed dollar per ton cost effectiveness threshold was considered 

for reasonableness in this analysis. Instead, measures were evaluated and justified on a case by case basis 

considering implementation costs and technical feasibility. 

 

43 Regarding RACM, EPA “... indicated that where measures that might in fact be available for implementation in 

the nonattainment area could not be implemented on a schedule that would advance the date for attainment in the 

area, EPA would not consider it reasonable to require implementation of such measures.” 57 FR 13560, April 16, 

1992.

44 See 63 FR 15932, April 1, 1998.
December 21, 2015 Final West Pinal PM10 RACM Analysis 30

4.1 Construction

4.1.1 Measure Title(s) 

Pinal County Air Quality Control District (PCAQCD) Code of Regulations, Chapter 4, Article 3, 

Construction Sites – Fugitive Dust

Arizona Revised Statutes (ARS) § 49-424(11) (Authorizing and implementing statute for high risk 

forecast)

4.1.2 Copy of Ordinance, Rule or Regulation

See Appendix G, Exhibit G-VII for the Notice of Final Rulemaking as published in the Arizona 

Administrative Register.

4.1.3 Implementation Schedule

The effective date of the rule is January 1, 2016; measures will be fully implemented after this date.

4.1.4 Basis for Consideration

In Appendix C1 of the General Preamble, EPA identified these measures for control of PM10 under the 

category Available Fugitive Dust Control Measures (see Table 4, Section 3.2.1). 

Also considered were several rules adopted in the pacific southwest including: Imperial County Air 

Pollution Control District Regulation VIII, Rule 800 General Requirements for Control of Fine 

Particulate Matter (PM-10), Rule 801 Construction and Earthmoving Activities, Rule 802 Bulk Materials,

Rule 803 Carry-out and Track-out, Rule 805 Paved and Unpaved Roads, Rule 806 Conservation 

Management Practices; Maricopa County Rule 310, Fugitive Dust from Dust-Generating Operations; San 

Joaquin Rule 8010 Fugitive Dust Administrative Requirements For Control Of Fine Particulate Matter 

(PM10), Rule 8020 Fugitive Dust Requirements For Control Of Fine Particulate Matter (PM10) From 

Construction, Demolition, Excavation And Extraction Activities, Rule 8021 Construction, Demolition, 

Excavation, Extraction, And Other Earthmoving Activities; and South Coast Rule 403 Fugitive Dust.

4.1.5 Applicable to the Following Land Use Categories and Emission Generating Activities

The construction rule contains emissions reduction strategies for windblown and activity-based emissions 

from:

• Construction (Residential, Commercial, Site Development, Roadway). 

The rule also provides benefit for reducing paved road emissions by reducing airborn deposition and 

trackout.

4.1.6 Discussion of Measure Benefits

Construction activity was found to be a significant source on high-wind days. The new construction rule 

replaces and strengthens the existing construction rule in the West Pinal Planning Area and will reduce 

emissions from this source category under both high-wind and low-wind design day conditions.
December 21, 2015 Final West Pinal PM10 RACM Analysis 31

The contingency measure obligation for the nonattainment area is 7,475.4 tons per year (tpy), 

implementable by 2018, if needed.45 The measures which satisfy this requirement will be implemented 

proactively, starting on January 1, 2016. The new strategies contained in the construction rule help meet 

contingency goals by reducing PM10 emissions by at least 4,686.6 tons per year in 2018 (see Table 5). 

Table 5: Estimated Annual Emissions Reductions due to Construction Rule Implementation

Control Strategy Emission Reduction Credit Reduction (tpy)

Construction (Residential, Commercial, Site 

Development, Roadway)

Contingency 4,686.6

Trackout Contingency < 5.046

Total ≈ 4,691.6

4.1.7 Discussion of Technical and Economic Considerations

Table 6 lists the technical feasibility and cost standings of available measures appropriate to construction, 

earthmoving, and related activities. The table is followed by a brief discussion of the feasibility of the 

West Pinal control strategy. 

Table 6: Construction and Earthmoving*

Measure Technically 

Feasible

Reasonable 

Implementation 

Cost

Construction Rule 

Measure

1. Pave or stabilize [trackout control 

device] access points where unpaved 

traffic surfaces adjoin paved roads.

Y Y Y

2. Require dust control plans for 

construction or land clearing projects. Y Y Y

3. Require haul trucks to be covered. Y Y Y

4. Provide for traffic rerouting or rapid 

clean-up of temporary sources of dust 

on paved roads (water erosion, runoff, 

mud/dirt track out, material spills).

Y Y Y

5. Develop traffic reduction plans for 

unpaved roads. Use of speed bumps, 

low speed limits, etc., to encourage use 

of other (paved) roads.

Y Y Y

6. Stabilize unpaved parking and traffic 

areas [haul/access roads].

Y Y Y

7. Establish dust control measures for 

material handling and storage. Y Y Y

8. Limit trespass in open areas and 

vacant lots [work site].

Y Y Y

9. Require stabilization or other 

abatement of wind erodible soil. Y Y Y

* Y = yes; N = no; P = partial (portions of available measure were found to be feasible); NA = not available or not 

applicable; NE = not evaluated.

 

45 See Section D5.2 of Appendix D to this SIP submittal, “Pinal County PM10 Nonattainment Area 2018 Attainment 

Demonstration and Controlled Emissions Inventories,” ADEQ, 2015.

46 A 5 ton per year reduction is collectively due to trackout provisions in the Construction and Fugitive Dust rules.
December 21, 2015 Final West Pinal PM10 RACM Analysis 32

The Construction Rule requires various measures to reduce fugitive emissions from construction and 

earthmoving activities. In addition to other controls, the rule requires an approved permit and dust control 

plan prior to the start of activity at work sites of 0.1 acre or more. The new rule revises previously 

applicable requirements to include: a 20 percent opacity limit for visible emissions within the work site

(not just at the fenceline); test methods to determine stabilization; inspections and stabilization 

requirements for the day before and the day that is forecast to be at high risk for dust emissions; and 

improved record keeping. 

ADEQ and the Pinal County Air Quality Control District worked with the Arizona Chapter of the 

Associated General Contractors and the Home Builders Association of Central Arizona to develop control 

strategies for construction and earthmoving activities in the West Pinal PM10 Nonattainment Area. 

Participation was encouraged and technical advice sought through meetings and discussion to determine 

the feasibility of implementing the measures contained in the rule.

According to the final construction rule preamble, there are estimated small incremental costs to the 

businesses potentially affected by the construction rule.

47 Costs may be accrued for items such as opacity 

certifications, on-site inspections, recordkeeping, and stabilization requirements.

Regulated community members may incur costs to complete opacity certification in order to comply with 

§§ 4-3-180(A)(1). Depending on an operation’s existing recordkeeping practices, there could be small 

incremental costs associated with keeping the appropriate records that are required under the rules. The 

amount of time required for the regulated community to conduct inspections of their respective work sites 

to determine if all applicable control measures are implemented and all disturbed surface areas are 

stabilized (every other week for work sites 0.1 acres and larger and on the day leading up to and including 

the day of high risk forecasts for work sites 5 acres and larger) will add to overall labor costs associated 

with each construction project. The extent of their specific budgetary impacts, however, is unknown at 

this time. The stabilization requirements of the rules may also add costs to the regulated community. 

Although the specific additional costs of the rule have not been fully estimated, some of the impacts on 

the regulated community will be lessened because rules previously in effect in the West Pinal PM10

Nonattainment Area also included opacity requirements as well as similar application and permitting 

requirements. 

Estimated costs for the Pinal County Air Quality Control District (PCAQCD) are those that accrue from 

development, implementation and enforcement of the new standards. PCAQCD has an ongoing 

assessment of the costs associated with implementation and enforcement of its permitting, administration 

and field services activities associated with dust (construction fugitive dust and general fugitive dust) and 

open burning to determine any needed changes to associated dust and open burning permit fees. 

4.1.8 Comparison of the Pinal County Rule with Measures Adopted in Other Areas

Exhibit F-II compares the Pinal County Construction Rule with BACM and RACM strategies adopted 

and approved for other nonattainment areas in the Pacific Southwest.

 

47 See Appendix G, Exhibit G-VII.
December 21, 2015 Final West Pinal PM10 RACM Analysis 33

4.2 Agriculture

4.2.1 Measure Title(s) 

Arizona Administrative Code, Title 18, Chapter 2, Article 6 – Emissions from Existing and New 

Nonpoint Sources (specifically A.A.C. R18-2-610 & 610.03 for commercial farms and A.A.C. R18-2-611 

& 611.03 for commercial animal operations (CAFOs and Dairies), and A.A.C. R18-2-612 & 612.01 for 

irrigation districts)

4.2.2 Copy of Ordinance, Rule or Regulation

See Exhibit G-VI for the published final rules in the Arizona Administrative Register.

4.2.3 Implementation Schedule

The Arizona Administrative Code Agricultural Rules were effective upon filing with the Arizona 

Secretary of State, as of July 2, 2015. 

The rules must be complied with beginning January 1, 2016. The rules mandate that from and after 

December 31, 2015, agricultural sources engaged in regulated agricultural activity must complete a BMP 

Program General Permit Record Form every year by March 31. While this seems to provide an 

implementation gap, this is not the case. Per the recently revised statute, A.R.S. § 49-457, “[a] person who 

commences a regulated agricultural activity shall immediately comply with the agricultural general permit 

[prescribed by the statute].” The statute dictates that whether or not a BMP form is available for an 

inspector’s review, a farmer/operator must still be complying with the BMP program. Additionally, after 

the program’s first year, the farmer will have at the very least the previous year’s BMP form on file for 

review.

4.2.4 Basis for Consideration

ADEQ considered those measures identified in Appendix C1 of the General Preamble to the 1990 

Amendments, and also considered RACM measures in other representative areas, including those areas as 

shown in Section 3.2 above, and Exhibit F-III, attached.
December 21, 2015 Final West Pinal PM10 RACM Analysis 34

4.2.5 Applicable to the Following Land Use Categories and Emission Generating Activities

Table 7: Agriculture rule applicable sources Windblown dust sources

Unpaved Roads (including permanent unpaved 

haul or access roads, canal roads, unpaved cropland

roadways)

Dairies (including arenas, corrals, and pens, and 

unpaved roads and feed lanes)

CAFOs (including arenas, corrals, and pens, and 

unpaved roads and feed lanes)

Agriculture (cropland and noncropland)

Activity-based emission sources

Ag Fields - Harvesting and Ground Operations

Ag Fields - Tilling

CAFO related activity (including animal waste and 

feed handling and transportation and activity in 

arenas, corrals, and pens, and on unpaved roads 

and feed lanes)

Activity on unpaved crop roads and canal roads

Significant Earthmoving Activities

Dairy operation related activity (including from 

animal waste and feed handling and transportation 

and activity in arenas, corrals, and pens and on 

unpaved roads and feed lanes)

4.2.6 Measure Benefits 

The measures chosen were found to have numerous benefits towards reaching attainment and contingency 

measures by reducing dust from:

 Commercial Farm activity and wind generated dust 

 Commerical Animal Operation activity and wind generated dust (note that controls on

commercial dairy operations were used for contingency measures)

 Irrigation District activity and wind generated dust

These measures resulted in the benefits demonstrated in Table 8 below.
December 21, 2015 Final West Pinal PM10 RACM Analysis 35

Table 8: Agricultural Best Management Practices Rule Reductions (Attainment and Contingency)

ADEQ estimated the following 

reductions to the 2018 

emissions inventory for the NA 

in tons of PM10 per year (TPY).

Attainment Contingency

AgBMP 

Rule 

Subtotal

Unpaved 

apron 

roads

Unpaved 

canal O&M 

roads

Harvesting 

and Tilling CAFOs Dairies

Windblown 

dust

Unpaved Roads 705.2 144.7 849.9

Dairies 65.4 65.4

CAFOs 29.9 29.9

Agriculture 12388.1 12388.1

Subtotal 705.2 144.7 12388.1 29.9 65.4 13333.3

Activity-based 

emissions

Ag Fields -

Harvesting 105.8 105.8

Ag Fields - Tilling 882.3 882.3

CAFOs 251.4 251.4

Unpaved Road 7341.3 577.6 7918.9

Dairy 35.8 35.8

Subtotal 7341.3 577.6 988.1 251.4 35.8 9194.2

Total 8046.5 722.3 13376.2 281.3 101.2 22527.5

4.2.7 Technical and Economic Considerations

ADEQ and the Agricultural Best Management Practices Committee (the “Committee”) have intensely 

deliberated to ensure that the control strategy developed is the best and most cost effective possible to 

control PM10 from agricultural sources in the West Pinal PM10 nonattainment area. Throughout the 

rulemaking process the Agricultural BMP Committee analyzed each BMP and its respective potential cost 

on the industry. The Committee also analyzed technical ability of industry operators to reasonably 

implement each BMP. The Committee, in communication and negotiation with its agricultural industry 

members, has produced a rule it believes is economically and technologically feasible to implement.

PM10 agricultural strategies are intensely reliant on a specific locale’s climate, soil type, growing season, 

crop types, water availability, market conditions, and relations to urban centers.48 A menu option program 

structure has become standard for agricultural industry PM control, in large part because the feasibility of 

implementing pollution controls depends on the factors listed above. Agricultural operation diversity 

dependent on several local and operation specific factors complicate and undermine the establishment 

strict criteria to control PM. Allowing industry operators to choose from an assortment of specified 

options enables particulate matter control in spite of the inherent variable nature of agricultural operations 

 

48 See Latino Issues Forum v. United States EPA, 558 F.3d 936, 948 (9th Cir. 2009) (“Due to the variability of weather 

and market conditions, as well as the diversity among the agricultural operators that fall under [San Joaquin County] Rule 

4550, it is reasonable to provide agricultural operators the flexibility to choose whichever methods of PM-10 reduction 

will be feasible for their individual properties.”); Proposed Approval and Promulgation of Implementation Plans; 

Arizona – Maricopa Nonattainment Area; PM10, 63 FR 71815, 71817 (Dec. 30, 1998) (“In general, EPA believes 

that because agricultural sources in the United States vary by factors such as regional climate, soil type, growing 

season, crop type, water availability, and relation to urban centers, each PM-10 agricultural strategy is uniquely based 

on local circumstances.”). See also Vigil v. Leavitt, 381 F.3d 826, 838 (9th Cir. 2004). 
December 21, 2015 Final West Pinal PM10 RACM Analysis 36

and the wide range of economic circumstances and other factors facing farmers and operators within a 

nonattainment area.

One way in which the Agricultural BMP PM rules accommodate the variable nature of agricultural 

operations and crops, is to provide the option of multiple BMPs to control different sources. Most 

agricultural operations are different from one another and while they are only required to implement one 

BMP, they are encouraged to implement more than one BMP, which they do when feasible. Of course, if 

agricultural operators were required to implement multiple BMPs, there would be fewer emissions, but 

multiple BMPs are not always reasonable for all operators at all times, nor cost effective. Multiple BMPs 

can be very expensive, and the expense may vary over the course of the year, impacting cost

predictability. After careful assessment and deliberation over their operations, the Committee decided that 

the required BMPs are those that can be reasonably implemented. In addition, the rule requires more 

accountability than other PM10 nonattainment area programs,49 in that it requires a three-year survey 

submission to report on crop acreage and BMP activity choices under regular and high risk conditions. 

The Committee’s final rules liken to BACM measures in other areas such as Imperial and San Joaquin 

Counties, as shown in Exhibit F-III – Agriculture Comparison. 

Throughout the development of this rule the Committee has been particularly wary of implementing a 

rule that could result in a high cost to the West Pinal community in terms of present and future supply of 

natural resources. The potential high cost is especially evident when considering the potential 

unavailability and/or rise in monetary price of water in the future.50 The Committee has tried to develop a 

sustainable and holistic rule that furthers the purposes of the SIP and the agricultural best management 

practices statute—to reduce particulate matter emissions—while concurrently accounting and planning 

for soil, water, and other natural resource conservation. 

One of the most important practical limitations to reducing PM emissions in the West Pinal nonattainment 

area is the availability of water. Arizona’s semi-arid climate and rapidly growing population causes 

constant water supply difficulties.51 The limited supply compels the state’s existing inhabitants to 

conserve water as much as possible. 

Arizona has four legal sources of water, “surface water flowing from springs or in natural channels, 

groundwater, Colorado River water, and effluent.”

52 The three primary sources of water are state surface 

water, Colorado surface water, and groundwater.53 Central and southern Arizona heavily relies on 

Colorado River water supplied by the Central Arizona Project (“CAP”), which moves water uphill 

through a 336 mile long canal.54 Central Arizona also “relies on the Salt, Verde and Gila Rivers.”

55

Groundwater is located in aquifers beneath the earth. Statistically, a majority of agricultural water demand 

 

49 E.g. Imperial County Air Pollution Control District, Regulation VIII, Rule 806 (2005).

50 See generally Tony Davis, Farm Water to City Taps: It won’t be cheap, Tucson.com: Arizona Daily Star (May 23, 

2015, 6:00 PM), http://tucson.com/news/local/farm-water-to-city-taps-it-won-t-be-cheap/article_2cbb2c99-dbdb542b-9c1d-2254a82c88d4.html.

51 See Symposium: Water Law and Policy Conference: Good Intentions, Unintended Consequences: The Central 

Arizona Groundwater Replenishment District, 49 Ariz. L. Rev. 339, 339 (2006).

52 Michael J. Pearce, The History of State and Federal Water Laws, in Arizona Water Policy 26, 27 (Bonnie G. 

Colby & Katharine L. Jacobs eds., 2007).

53 See Symposium: Water Law and Policy Conference: Good Intentions, Unintended Consequences: The Central 

Arizona Groundwater Replenishment District, 49 Ariz. L. Rev. 339, 339 (2006).

54 See Michael J. Pearce, The History of State and Federal Water Laws, in Arizona Water Policy 26, 33 (Bonnie G. 

Colby & Katharine L. Jacobs eds., 2007).

55 Symposium: Water Law and Policy Conference: Good Intentions, Unintended Consequences: The Central 

Arizona Groundwater Replenishment District, 49 Ariz. L. Rev. 339, 339 (2006).
December 21, 2015 Final West Pinal PM10 RACM Analysis 37

in Arizona, generally, and in the West Pinal nonattainment area, is from groundwater reserves and CAP 

water.56

Surface water rights in Arizona are allocated according to prior appropriation, the history of which 

reaches back hundreds of years.57 The doctrine essentially means that the first person to put surface water 

to a beneficial use acquires a superior right when weighed with later appropriators.58 Adjudication 

regarding rights to the Gila River, for example, shows that in some cases, “prior appropriation claims 

exceed the amount of surface water available.”59 There is even competition to obtain rights to use CAP 

water.60 According to the Colorado River Basin Project Act of 1968, the legislation authorizing 

construction of CAP, “if there is ever a shortage on the [Colorado River], deliveries to Arizona’s CAP 

will be reduced to zero before California’s apportionment is reduced at all.”61 Additionally, the CAP 

water supply state hierarchy dictates four categories in “descending order of priority in times of shortage:

(1) Native American, (2) municipal and industrial, (3) non-Indian agriculture, and (4) excess water.”62

Agricultural, municipal, and industrial water users are all eligible to enter into a CAP Excess Water 

Contract, but the demand for excess water has increased “at the same time its overall availability has 

decreased.”63

Groundwater rights are granted based on beneficial use in rural areas, and in Active Management Areas 

(“AMA”), areas of quantified and restricted water rights established by the Groundwater Management 

Act, water usage is highly limited order to curb over-drafting of aquifer reserves. Each AMA establishes a 

complex system of quantified rights based on the area-specific goals, such as economic drivers in the 

area, and water user distribution. The West Pinal PM nonattainment area is covered by three AMAs: 

Phoenix, Tucson,64 and predominantly Pinal.65 “In the Pinal AMA, where the economy is primarily 

agricultural, the management goal is to preserve that economy for as long as feasible, while considering 

the need to preserve groundwater for future non-irrigation uses.”66

 

56 See Active Management Areas, Arizona Departement of Water Resources, http://www.azwater.gov/azdwr/

StatewidePlanning/WaterAtlas/ActiveManagementAreas/PlanningAreaOverview/CulturalWaterDemandAgriculture.

htm (last visited Sept. 8, 2015).

57 See generally Michael J. Pearce, The History of State and Federal Water Laws, in Arizona Water Policy 26, 27 

(Bonnie G. Colby & Katharine L. Jacobs eds., 2007).

58 See Michael J. Pearce, The History of State and Federal Water Laws, in Arizona Water Policy 26, 33 (Bonnie G. 

Colby & Katharine L. Jacobs eds., 2007). See generally A.R.S. §§ 45-141 - 45-264; Surface Water Rights, Arizona 

Department of Water Resources, http://www.azwater.gov/AzDWR/SurfaceWater/SurfaceWaterRights/default.htm

(last visited Sept. 8, 2015).

59 Symposium: Water Law and Policy Conference: Good Intentions, Unintended Consequences: The Central 

Arizona Groundwater Replenishment District, 49 Ariz. L. Rev. 339, 340 (2006).

60 Id.

61 Michael J. Pearce, The History of State and Federal Water Laws, in Arizona Water Policy 26, 33 (Bonnie G. 

Colby & Katharine L. Jacobs eds., 2007).

62 Id.

63 Excess Water, Central Arizona Project, http://www.cap-az.com/departments/water-operations/excess-water (last 

visited Sept. 8, 2015).

64 Only a very small relative portion of the Pinal Nonattainment area lies within the Tucson AMA. 

65 Compare Phoenix Active Management Area Map, Arizona Dept. of Water Resources, http://www.azwater. 

gov/AzDWR/WaterManagement/AMAs/PhoenixAMA/documents/Phoenix_AMA_Map.pdf (last visited Sept. 8, 

2015), with Pinal Active Management Area Map, Arizona Dept. of Water Resources, http://www.azwater. 

gov/AzDWR/WaterManagement/AMAs/PinalAMA/documents/ch1-pinal.pdf (last visited Sept. 8, 2015), and

Tucson Active Management Area Map, Ariz. Dept. of Water Resources, http://www.azwater.gov/AzDWR/ 

WaterManagement/AMAs/TucsonAMA/documents/TAMA_map_large.PDF (last visited Sept. 8, 2015).

66 Active Management Areas (AMAs) & Irrigation Non-expansion Areas (INAs), Arizona Dept. of Water Resources, 

http://www.azwater.gov/AzDWR/WaterManagement/AMAs/default.htm (last visited Sept. 8, 2015).
December 21, 2015 Final West Pinal PM10 RACM Analysis 38

Arizona is projected to run short of water within approximately 25 years if the state and its constituents do 

not continue to mitigate the threat of a water shortage through careful and prudent planning.67 Recently, 

the Bureau of Reclamation released confirmation that the Department of Interior will not declare a 

shortage on the Colorado River in 2016, but that there is a possibility of a shortage in 2017.68 No one 

person has control of the water supply. For example, ensuring future Colorado River water supply is an 

intrastate, interstate, and international effort within and between Arizona, other Colorado Basin states, the 

U.S., and Mexico.69

Through AMA enforcement, Arizona has already taken preliminary measures to regulate the agricultural 

community to ensure the availability of water in the coming years. For example, the Pinal AMA restricts 

water use to 20-30 gallons per day per head for use in dairy operations and beef feedlot yards, 

respectively.70 That includes water use necessary for processing feed, water consumption for hydrating 

the animals, and water use for dust suppression. Feedlot industry representatives have explained that their 

processes already almost reach the conservation limit when using 3 to 6 gallons a day to suppress 

particulate matter.71 Hence, the Agricultural BMP rule’s use of a water volume measurement rather than a 

moisture content percentage allows for operational predictability in spite of limited water availability.

From a statistical perspective, the agricultural sector is a significant water stakeholder. Non-Indian 

agriculture is responsible for approximately 80 percent of the total annual groundwater use in the Pinal 

AMA.72 In the years 2001 and 2005, groundwater agricultural demand in the Pinal and Phoenix AMAs 

equated to approximately 45.5 and 42 percent, respectively, of the total agricultural demand in those 

areas.73 In the same years, CAP agricultural demand in the Pinal and Phoenix AMAs equated to 

approximately 47 and 32.5 percent, respectively, of the total agricultural demand in those areas.74

As a significant water stakeholder, the agricultural sector in Arizona must constantly plan for a possible 

imminent water shortage. These PM10 rules were developed to account for this very real concern. 

Although reducing the throughput of the agricultural sector could reduce its water use and PM10

emissions, this is not an economically sustainable approach. Pinal County farmers and commercial animal 

operations must use water to grow food and other commodities to provide essential benefits such as food 

security. According to the USDA, Arizona accounted for $81.5 million in beef exports and $1 billion in 

 

67Ariz. Dept. of Water Resources, Arizona’s Next Century: A Strategic Vision for Water Supply Sustainability 45-46 

(2014), available at http://www.azwater.gov/AzDWR/Arizonas_Strategic_Vision/documents/ArizonasFuture

WaterSuppliesandDemands.pdf (last visited Sept. 8, 2015).

68 See Further Action Needed to Stave Off Future Water Restrictions, Central Arizona Project (Aug. 17, 2015), 

http://www.cap-az.com/public/press-releases/439-bureau-of-reclamation-report-confirms-no-shortage-in-2016. 

69 See id.; See generally Anne Castle, Busting Myths About Water Shortage, The San Diego Union-Tribune (Sept. 

25, 2013, 4:00 PM), http://www.sandiegouniontribune.com/news/2013/sep/26/busting-myths-about-water-shortage/.

70 See Arizona Dept. of Water Resources, Third Management Plan for Pinal Active Management Area: 2000-2010 

6-61-70 (1999) available at http://www.azwater.gov/azdwr/WaterManagement/AMAs/documents/ch6-pinal.pdf. 

See also Exhibit F-V: Information On a Gallons per Head Standard Providing More Benefits over a Strict Moisture 

Percentage for Feed Yard Pens, provided by Bas Aja of the Arizona Cattlemen’s Association.

71 See Exhibit F-V: Information On a Gallons per Head Standard Providing More Benefits over a Strict Moisture 

Percentage for Feed Yard Pens, provided by Bas Aja of the Arizona Cattlemen’s Association.

72 Pinal AMA Agricultural Conservation Program, Arizona Dept. of Water Resources, http://www.azwater.gov/

AzDWR/Watermanagement/AMAs/PinalAMA/PinalAMAAgricunltureConservationProgram.htm (last visited Sept. 

8, 2015).

73 See Active Management Areas, Arizona Departement of Water Resources, http://www.azwater.gov/azdwr/

StatewidePlanning/WaterAtlas/ActiveManagementAreas/PlanningAreaOverview/CulturalWaterDemandAgriculture.

htm (last visited Sept. 8, 2015).

74 See Active Management Areas, Ariz. Dept. of Water Resources, http://www.azwater.gov/azdwr/

StatewidePlanning/WaterAtlas/ActiveManagementAreas/PlanningAreaOverview/CulturalWaterDemandAgriculture.

htm (last visited Sept. 8, 2015).
December 21, 2015 Final West Pinal PM10 RACM Analysis 39

total plant products exports in 2013.75 Pinal agriculture yields approximately a quarter of total plant 

product sales within the state.76 Because of agriculture’s high use of water and the increase of urban 

sprawl and ensuing water value imbalance,77 farm cultural operators have turned their attention to 

effecting required and voluntary water conservation best management practices.78

Additionally, the PM10 rules incorporate Natural Resource Conservation Service (NRCS) standards in an 

attempt to ensure soil conservation for future crops and in order to secure additional funding through the 

U.S. Department of Agriculture’s NRCS Environmental Quality Incentives Program (EQIP). Such 

funding helps to offset the costs of implementing additional BMPs (to prevent PM10 emissions) which 

would otherwise be cost-prohibitive. Animal operations, however, do not benefit from such funding, 

which makes some BMPs, especially those involving a great deal of water and time, economically and 

technically infeasible.

The finalized rules are feasible, effective, and minimize potential negative impacts on local agriculture, 

including cost. Each farmer may select those BMPs that are more economically feasible for their own 

individual operation, providing a flexible and effective control program. ADEQ expects compliance costs 

to be minimal to moderate per new commercial farmer/animal operator/irrigation district. From the Yuma 

Agricultural Best Management Practices rulemaking,

79 it was estimated that the cost range for 

implementing BMPs could range $5.00 to $10.00 per acre, depending upon the BMPs selected. To 

implement some BMPs, the costs could represent one-time costs, whereas other implementation costs 

could be recurring. 

4.2.7 Comparison of Rule to Measures Adopted in Other Areas

Exhibit F-III – Agriculture Comparison compares the Pinal County Rule with BACM measures approved 

for Imperial and San Joaquin Counties.

 

75 U.S. Dept. of Agric., U.S. Agricultural Exports, Commodity detail by State [New series]: Cal Yr 2000-2013 (Apr. 

29, 2015) available at http://www.ers.usda.gov/data-products/state-export-data.aspx (last visited Sept. 8, 2015).

76 Valorie Rice, The Changing Face of Agriculture in Arizona, Table 3, University of Arizona Economic & Business 

Research Center (Sept. 21, 2014), https://www.azeconomy.org/2014/09/featured/the-changing-face-of-agriculturein-arizona/?share=stumbleupon.

77 James Yoo et al., The Value of Water Rights in Agricultural Properties in the Phoenix Active Management Area 4

(Selected Paper prepared for presentation at the Agricultural & Applied Economics Association’s 2012 AAEA 

Annual Meeting, Seattle, Washington, August 12-14, 2012) http://ageconsearch.umn.edu/bitstream/124095/2/

AAEA_Paper_James_Yoo.pdf. 

78 Agriculture Homepage, Ariz. Dept. of Water Resources, http://www.azwater.gov/AzDWR/StatewidePlanning/

Conservation2/Agriculture/default.htm (last visited Sept. 8, 2015).

79 Notice of Final Rulemaking, 24 A.A.R. 2210 (June 10, 2005).
December 21, 2015 Final West Pinal PM10 RACM Analysis 40

4.3 Fugitive Dust (General Rule)

4.3.1 Measure Title(s) 

Pinal County Air Quality Control District (PCAQCD) Code of Regulations, Chapter 4, Article 1, West 

Pinal PM10 Moderate Nonattainment Area Fugitive Dust

Arizona Revised Statutes (ARS) § 49-424(11) (Authorizing and implementing statute for high risk 

forecast)

4.3.2 Copy of Ordinance, Rule or Regulation

See Appendix G, Exhibit G-VIII for the Notice of Final Rulemaking as published in the Arizona 

Administrative Register.

4.3.3 Implementation Schedule

The effective date of the rule is January 1, 2016; most measures will be fully implemented starting at this 

date. Paving and stabilization measures for unpaved roads will begin in 2016 and continue incrementally 

until fully implemented.

4.3.4 Basis for Consideration

In Appendix C1 of the General Preamble, EPA identified these measures for control of PM10 under the 

category Available Fugitive Dust Control Measures (see Table 4, Section 3.2.1). 

Also considered were several rules adopted in the pacific southwest including: Imperial County Rule 800 

General Requirements For Control Of Fine Particulate Matter (Pm-10); South Coast Air Quality 

Management District Rule 1186 PM10 Emissions From Paved And Unpaved Roads, And Livestock 

Operations; the Phoenix RACM FIP at 40 CFR Part 52.128, Rule for unpaved parking lots, unpaved roads 

and vacant lots; and Maricopa County Rule 310.01 Fugitive Dust from Non-Traditional Sources of 

Fugitive Dust.

4.3.5 Applicable to the Following Land Use Categories and Emission Generating Activities

The fugitive dust rule contains emissions reduction strategies for the sources listed in Table 9.

Table 9: Fugitive Dust Rule Applicable Sources

Emissions Type Source Category

Windblown Emissions Open Areas/Vacant Lots

Windblown and Activity-Based 

Emissions

Unpaved Lots (parking, maneuvering, etc.)

Unpaved Roads

Activity-Based Emissions Paved Public Roadway
December 21, 2015 Final West Pinal PM10 RACM Analysis 41

Windblown emissions from disturbed Open Areas and Vacant Lots and Unpaved Lots are included in and 

evaluated as part of the significant land use categories Cleared Areas, Developed Lands – Urban, 

Developed Lands – Rural, and Desert Shrublands. Most windblown emissions from the unpaved 

shoulders of paved roadways are included in these same land use categories, with some additional 

emissions in the Other Windblown Dust [unclassified] category.

4.3.6 Discussion of Measure Benefits

Fugitive dust emissions from disturbed open areas and vacant lots were found to be significant primarily 

on high-wind days. Unpaved [parking] lots and unpaved road emissions were found significant on both 

high-wind and low-wind design days and paved roads were significant on low-wind days. The 

contingency measure obligation for the nonattainment area is 7,475.4 tons per year, implementable by 

2018, if needed.80 The measures which satisfy this requirement will be implemented proactively, starting 

on January 1, 2016. The control strategies contained in the fugitive dust rule help meet contingency goals

by reducing PM10 emissions by approximately 3,000 tons per year in 2018 (see Table 10).

Table 10: Estimated Annual Emissions Reductions due to Implementation of the Fugitive Dust 

Rule81

Control Strategy Emission Reduction Credit Reduction (tpy)

Open Areas and Vacant Lots (all provisions) Contingency 1,727.9

Unpaved [parking] Lots (all provisions) Contingency 143.5

Unpaved Roads (all provisions) Contingency 1,142.7

Paved Public Roadways (shoulders) Contingency 7.6

Paved Public Roadways (trackout) Contingency < 5.082

Paved Public Roadways (erosion) No Credit Taken Not Quantified

Total ≈ 3,026.7

4.3.7 Discussion of Technical and Economic Considerations

Tables 11, 13, 14, and 15 list the technical feasibility and cost standings, where available, of measures 

appropriate to disturbed open areas and vacant lots, unpaved lots, unpaved roads, and paved roads. Each 

table is followed by a discussion of the reasons for including or rejecting individual measures, in whole or 

in part, from the West Pinal controls strategy.

Estimated costs for the Pinal County Air Quality Control District (PCAQCD) are those that accrue from 

development, implementation and enforcement of the new standards. PCAQCD has an ongoing 

assessment of the costs associated with implementation and enforcement of its permitting, administration 

and field services activities associated with dust (construction fugitive dust and general fugitive dust) and 

open burning to determine any needed changes to associated dust and open burning permit fees. 

 

80 See Appendix D, Pinal County PM10 Nonattainment Area 2018 Attainment Demonstration and Controlled 

Emissions Inventories (Attainment TSD).

81 ADEQ estimated the emissions reductions based on 2018 assumptions (e.g., that 30 miles of unpaved road 

controls are in place, implemented in 2016 and 2017). All reductions are in tons per year.

82 A 5 tpy reduction is collectively due to trackout provisions in the Construction and Fugitive Dust rules.
December 21, 2015 Final West Pinal PM10 RACM Analysis 42

Open Areas and Vacant Lots

Table 11: Open Areas and Vacant Lots*

Measure Technically 

Feasible

Reasonable 

Implementation 

Cost

Fugitive Dust 

Rule RACM

1. Require dust control plan for offhighway vehicle use on public lands. N NE N

2. Limit use of recreational vehicles on 

open land (e.g., confine operations to 

specific areas, require use permits, 

outright ban).

Y Y Y

3. Require vegetation, chemical 

stabilization, or other abatement of wind 

erodible soil, including lands subjected 

to water mining, abandoned farms, and 

abandoned construction sites.

Y Y Y

4. Limit trespass in open areas and 

vacant lots (e.g. motor vehicle travel or 

parking).

Y Y Y

5. Employ dust mitigation measures 

during weed abatement. Y Y Y

* Y = yes; N = no; P = partial (portions of available measure were found to be feasible); NA = not 

available or not applicable; NE = not evaluated.

Measure 1. Require dust control plan for off-highway vehicle use on public lands

Arizona law prohibits driving a motorized vehicle “cross-country” on public or private lands where 

prohibited by rule or regulation or, in the case of private lands, by posting.83 Further, off-highway vehicle

(OHV) travel is limited to roads, trails, routes or areas that are “opened” by the land management 

agency.84 Operation of off-highway vehicles is not allowed on roads, trails, routes or areas that are 

“closed” by regulation of a federal agency, the state, a county or a municipality or by proper posting if the 

land is private land. In general, OHVs cannot be operated in a manner that damages the environment, 

including generation of excessive air pollution, where it is prohibited by rule, regulation, ordinance or 

code. The Arizona Game and Fish Department publishes “Arizona Off-highway Vehicle Guide, OHV 

Laws and Places to Ride” to ensure public understanding and compliance, and enforces off-highway 

vehicle laws including on public lands under state or local jurisdiction.

The Bureau of Land Management (BLM) indicates that most lands managed by Arizona BLM are 

designated as “limited areas.”

85

 Vehicle use in limited areas may be restricted to certain times, in certain 

areas, and/or to certain vehicular use. Use is generally limited to designated roads and trails, or in some 

cases dry washes. Overland vehicle travel is not permitted. 

The Pinal County Air Quality Control District tracks dust complaints received from all terrain vehicle

(ATV)/OHV activity. Dust complaints on public lands comprise a relatively small fraction of total OHV 

complaints in the nonattainment area (see Table 12). Requiring additional dust control plans for OHV use 

on public lands was found not reasonable because management of OHV use on public lands is already 

 

83 A.R.S. § 17-454. Citation is provided for reference purposes only and not for approval as part of the SIP.

84 A.R.S. § 28-1174. Citation is provided for reference purposes only and not for approval as part of the SIP.

85 See the Arizona BLM Website at http://www.blm.gov/az/st/en.html.
December 21, 2015 Final West Pinal PM10 RACM Analysis 43

occurring, the measure does not target the primary geographical area of OHV use/complaints (i.e. private 

land), and additional control is unlikely to result in measurable emissions reductions in the West Pinal 

area.

Table 12: West Pinal County Nonattainment Area Fugitive Dust 

Complaints (ATV/OHV)

Year Total ATV/OHV 

Complaints

Public Land 

ATV/OHV 

Complaints

Percent (%) of 

Complaints on 

Public Lands

2008 20 4 20.0%

2009 17 1 5.9%

2010 16 4 25.0%

2011 6 1 16.7%

2012 15 2 13.3%

2013 6 0 0.0%

2014 13 3 23.1%

Measure 2. Limit use of recreational vehicles on open land

As noted under Measure 1, Require dust control plan for off-highway vehicle use on public lands, OHV 

travel is limited to roads, trails, routes or areas that are opened by land management agencies and is not 

allowed on posted private land (see discussion above). 

The Fugitive Dust Rule includes additional measures to restrict trespass, including recreationl vehicles, in 

open areas and vacant lots (§ 4-3-030(2)(B)). The rule contains requirements for posting “no trespassing” 

signs or installing physical barriers to restrict access, upon evidence of tresspass. The size of the open 

area/vacant lot and control measure chosen by the owner and/or operator will determine the additional 

incremental costs potentially affecting them. This measure is discussed in more detail under Open 

Areas/Vacant Lots, Measure 4, Limit trespass in open areas and vacant lots below.

Measure 3. Stabilize wind erodible soil

Section 4-3-030(2)(A) of the Fugitive Dust Rule limits dust emissions in open areas and vacant lots to 20 

percent opacity. Owners and/or operators of open areas and vacant lots 1.0 acre or larger that have a 

cumulative 0.5 acre or more disturbed surface area are required to implement at least one of the specified 

measures to stabilize the area, including: 

• Application of water or dust suppressants,

• Establish vegetation,

• Install/maintain pavement,

• Apply/maintain gravel,

• Apply/maintain chemical/organic stabilizers, or

• An approved alternative method.

Additionally, owners/operators are required to ensure that disturbed areas are stabilized the day before 

and the day that is forecast to be high risk for dust emissions (includes high wind and stagnation events). 

The forecast and stabilization requirements target days with the most potential for elevated PM10. 

For those areas that do reach the 1 acre threshold, there may be some incremental costs associated with 

determining the stability of affected areas and for implementing dust mitigation measures. Sample capital 

cost estimates are as follows:
December 21, 2015 Final West Pinal PM10 RACM Analysis 44

• Establish a vegetative cover, $16,000-21,000 per acre;86

• Restore to native vegetation, $16,208-21,732 per acre;87

• Apply gravel (1 inch depth, 3/8 inch chip), $3,049 per acre;88

• Apply chemical dust suppressant (magnesium chloride/polymer blend), $3,485 per acre;89

• Install asphalt concrete (2 inch depth, 19 mm), $73,616 per acre.90

This measure was determined reasonable because of the wide range of control options (and associated 

costs) available for stabilizing wind erodible soil. 

The Construction Rule also contains provisions for reducing emissions from these sources (see Section 

4.1).

Measure 4. Limit trespass in open areas and vacant lots

Arizona law prohibits trespass, including motorized vehicles, on public or private lands where prohibited 

by rule or regulation or, in the case of private lands, by posting. To minimize initial or additional soil 

disturbance, the West Pinal Fugitive Dust Rule includes measures to restrict trespass in open areas and 

vacant lots (§ 4-3-030(2)(B)). The rule contains requirements for installation of “no trespassing” signs or 

physical barriers to restrict access upon evidence of tresspass. Physical barriers include fences, gates, 

posts, trees, or other measures to effectively prevent access. 

Some incremental costs associated with posting of signs or installation of barriers may be incurred by the 

the owner and/or operator of an open area. Previous evaluation of costs associated with measures for 

restricting access show that expenditures vary widely depending on the size of the affected area and 

control measure chosen. As an example, unit cost estimates include:

• $200 per sign for posting signage,

91

• $11-13 per linear foot for chain link fencing,

92 and 

• $7-8 per linear foot for boulders.93 

Installation costs could range from $1,000.00 (5 signs)

94 to more than $10,000 for fencing on a one-acre 

(square) parcel of land. This measure was determined reasonable because of the wide range of control 

options (and associated costs) available for limiting trespass. 

The Construction Rule also contains provisions for reducing emissions from soil disturbance caused by 

trespass (see Section 4.1).

Measure 5. Dust mitigation measures during weed abatement

Provisions in the Fugitive Dust Rule (§ 4-1-030(2)(E)) include measures to prevent or minimize fugitive 

dust prior to, during, and after vegetation removal (blading, discing, plowing) in open areas and vacant

 

86 Final Revised PM10 State Implementation Plan for the Salt River Area, ADEQ, September 2005.

87 Id.

88 Email communication from Scott DiBiase, Pinal County AQCD, to Bruce Friedl, ADEQ, dated August 20, 2015.

89 Id.

90 Id.

91 2009 Imperial County State Implementation Plan for Particulate Matter Less Than 10 Microns in Aerodynamic 

Diameter, Final, August 11, 2009.

92 Final Revised PM10 State Implementation Plan for the Salt River Area, ADEQ, September 2005.

93 Id.

94 Assumes posting on four sides/corners and at one access point.
December 21, 2015 Final West Pinal PM10 RACM Analysis 45

lots. The rule requires the owner/operator to stabilize disturbed areas by application of gravel, dust 

suppressants, or an alternative measure and to prevent or eliminate material trackout onto paved surfaces 

and access points adjoining paved surfaces. 

Costs associated with application of gravel, dust suppressants, and clean-up of any trackout are discussed 

under Open Areas/Vacant Lots, Measure 3. Stabilize wind erodible soil and Paved Public Roadways,

Measure 3. Provide for traffic rerouting or rapid clean-up of temporary sources of dust on paved roads.

Unpaved Lots

Table 13: Unpaved Lots*

Measure Technically 

Feasible

Reasonable 

Implementation 

Cost

Fugitive Dust 

Rule RACM

1. Require paving, chemically 

stabilizing, or otherwise stabilizing 

permanent unpaved haul roads, and 

parking or staging areas at commercial, 

municipal, or industrial facilities.

Y Y Y

2. Pave, vegetate, or chemically 

stabilize unpaved parking areas. Y Y Y

* Y = yes; N = no; P = partial (portions of available measure were found to be feasible); NA = not 

available or not applicable; NE = not evaluated.

Measure 1. Require paving or stabilizing permanent unpaved haul roads, parking, and staging areas at 

commercial, municipal, or industrial facilities

The Fugitive Dust Rule includes measures to stabilize unpaved parking, maneuvering, material handling, 

and storage areas. See Measure 2 discussion below.

Measure 2. Pave, vegetate, or chemically stabilize unpaved parking areas

Unpaved parking and traffic areas contribute to emissions of PM10 through three separate processes: (1) 

the mechanical re-entrainment of fugitive dust as vehicles travel over an unpaved or non-stabilized 

surface; (2) trackout of material onto adjacent paved surfaces, including public roadways, where it is 

subsequently re-entrained into the air by passing vehicles; and (3) windblown dust generated by wind 

passing over unpaved areas that have been disturbed by vehicles. The Fugitive Dust Rule requires the 

owner and/or operator of an unpaved parking, maneuvering, material handling, or storage areas to pave, 

apply dust suppressants, maintain surface gravel or otherwise stabilize the area (§ 4-3-030(3)). Visible 

emissions are limited to 20 percent opacity. The rule applies to unpaved lots greater than 5,000 square 

feet in size.

95

For those areas that reach the size threshold, there may be some incremental costs associated with 

determining stability of affected areas and for implementing dust mitigation measures. Sample capital 

cost estimates are as follows:

• Apply gravel (1 inch depth, 3/8 inch chip), $305 per 0.1 acre;96

 

95 Five thousand (5,000) square feet is approximately equal to 0.11 acres. For certain comparisons, however, the 

value is rounded to 0.1 acres.

96 Email communication from Scott DiBiase, Pinal County AQCD, to Bruce Friedl, ADEQ, dated August 20, 2015.
December 21, 2015 Final West Pinal PM10 RACM Analysis 46

• Apply chemical dust suppressant (magnesium chloride/polymer blend), $349 per 0.1 acre;97

• Install asphalt concrete (2 inch depth, 19 mm), $7,362 per 0.1 acre.98

• Install concrete (6 inch depth), $9,583 per 0.1 acre.99

This measure was determined reasonable because of the wide range of control options (and associated 

costs) available for stabilizing unpaved parking and traffic areas. 

The Construction and Agriculture BMP rules also contain provisions for reducing emissions from these 

sources (see Sections 4.1 and 4.2).

Unpaved Roads

Table 14: Unpaved Roads*

Measure Technically 

Feasible

Reasonable 

Implementation 

Cost

Fugitive Dust 

Rule RACM

1. Develop traffic reduction plans for 

unpaved roads. Use of speed bumps, 

low speed limits, etc., to encourage use 

of other (paved) roads.

N NE N

2. Pave or chemically stabilize unpaved 

roads. Y Y Y

* Y = yes; N = no; P = partial (portions of available measure were found to be feasible); NA = not 

available or not applicable; NE = not evaluated.

Measure 1. Develop traffic reduction plans

Traffic reduction plans can be effective in areas of dense roadway networks, where the traveling public is 

not significantly inconvenienced by having to use alternative paved roads in place of unpaved roads. In 

the rural portions of the West Pinal County PM10 nonattainment area, however, this measure is not 

feasible because of the substantial increases in route lengths that would have to be driven through the 

selective closure of unpaved roads. 

Measure 2. Pave or chemically stabilize unpaved roads

The Fugitive Dust Rule (§ 4-1-030(4)) requires the owner and/or operator of unpaved roads with average 

daily trips (ADT) greater than 150 to limit fugitive dust emissions to no greater than 20 percent opacity 

and to apply one of the following measures: 

• Pave,

• Apply/maintain dust suppressants (other than water), or

• Apply/maintain surface gravel.

Control requirements apply to roads owned by federal, state, county, municipal, or other governmental or 

quasi-governmental agencies, which is consistent with previously approved Phoenix area RACM 

 

97 Id.

98 Id.

99 Id.
December 21, 2015 Final West Pinal PM10 RACM Analysis 47

measures.

100

 Controls must be annually implemented on 15 miles of roadway per year. The selection of a

15 mile per year incremental schedule is based on capital and maintenance costs, available funding, and 

the amount of emissions reductions necessary to meet contingency measure goals. This approach is 

consistent with measures applied in other areas in the southwest U.S. See Exhibit F-IV, Rule Section 4-1-

030(4), for a comparison to controls adopted in other PM10 planning areas. Measures applicable to 

private unpaved farm roads, irrigation district roads, and unpaved construction roads are included in the 

Agriculture and Construction Rules (see Sections 4.1 and 4.2). 

Costs associated with the listed unpaved road measures are estimated below: 

• Apply gravel (1 inch depth, 3/8 inch chip, 28 feet wide), $10,000 per mile and for a maintenance 

cycle of one month, yearly cost is $120,000;101

• Apply chemical dust suppressant (magnesium chloride/polymer blend, 28 feet wide), $12,000 per 

mile, and for a maintenance cycle of four months, yearly cost is $48,000;

102

• Install asphalt concrete (2 inch depth, 19 mm, 28 feet wide), $250,000 per mile;

103

• Install concrete (6 inch depth, 28 feet wide), $325,000 per mile;

104

• Install chip-seal (28 feet wide), > $100,000 per mile.105

The regulated community in the rule includes Pinal County, Casa Grande, Maricopa, Florence, Coolidge, 

Eloy and Queen Creek. The unpaved road requirements will add significant costs to all these regulated 

entities. Because of the gross cost and burden on the nonattainment area infrastructure that will be 

incurred due to paving or otherwise stabilizing unpaved roads, a multi-year implementation schedule was 

chosen. Pinal County estimates an additional expenditure of $3,000,000 per year will be required to 

achieve a 15 miles per year paving goal (contracted chip-seal) from 2016-2018.

106

 According to the ADT 

estimates used for the base year inventory (2008), there were 180 miles of unpaved roads over 150 ADT 

in the West Pinal Nonattainment Area. Per the examples above, application of dust suppressants on 180 

miles of roadway would cost approximately $8,640,000 per year and approximately $21,600,000 per year

for gravel.

The form of the PM10 NAAQS is a three year average (calendar year), therefore, emissions reductions for 

measures designed to attain the standards in the West Pinal Nonattainment area must begin in January 

2016, to meet the December 2018 attainment deadline. For this reason, the unpaved road measures are 

not relied upon to advance attainment of the NAAQS or to demonstrate attainment by the applicable date. 

In order to demonstrate attainment, ADEQ chose other measures (see Section 4.2) that would be fully 

implemented upon a rule's effective date, rather than those measures which are implemented on a 

graduated schedule (such as paving of unpaved roads). 

Emissions reductions from unpaved road measures are credited toward contingency objectives. The 

contingency measure obligation for the nonattainment area is an emissions reduction of 7,475.4 tons per 

 

100 See 40 CFR 52.128, Rule for unpaved parking lots, unpaved roads and vacant lots. 64 FR 71308; December 21, 

1999.

101 Email communication from Scott DiBiase, Pinal County AQCD, to Bruce Friedl, ADEQ, dated August 20, 2015.

102 Id.

103 Id.

104 Id.

105 Id. Estimate is based on the case where the work is completed by Pinal County. Application of controls on the 

additional mileage required by this regulation (in addition to what has already been scheduled in 2016-2018) will 

likely be beyond the in-house capacity of the County and the paving work may be done through contract, thereby 

increasing the per mile cost.

106 Email communication from Scott DiBiase, Pinal County AQCD, to Andrew Steckel, U.S. EPA, dated July 30, 

2015.
December 21, 2015 Final West Pinal PM10 RACM Analysis 48

year, implementable by 2018, if needed. Most of the measures designed to satisfy this requirement will 

be applied proactively, starting on January 1, 2016. These measures include:

• Controls on commercial dairy operations, estimated to reduce nonattainment area emissions by 

101.2 tpy (see the Agriculture Rule in Section 4.2);

• Controls on construction, estimated to reduce nonattainment area emissions by 4,686.6 tpy (see 

the Construction Rule in Section 4.1);

• Controls on a variety of other sources of fugitive dust (open areas and vacant lots, unpaved 

parking lots, unpaved shoulders of paved roads), estimated to reduce nonattainment area 

emissions by 1,879.0 tpy (see the Fugitive Dust Rule in Section 4.3); and

• Controls on trackout (construction and other sources), estimated to reduce nonattainment area 

emissions by 5 tpy (see Table 5, Section 4.1.6 and Table 10, Section 4.3.6).

After subtracting the above reductions from the total contingency measure obligation, the unpaved roads 

portion of the Fugitive Dust Rule must make up a shortfall of 803.6 tpy throughout the nonattainment 

area. ADEQ estimates that application of controls on 15 miles of unpaved roads per year will reduce 

emissions by 1,142.7 tons per year by 2018, exceeding contingency reduction objectives.

107

 Details of the 

analysis are fully described in Appendix D, Section D5.2. 

The Fugitive Dust Rule also includes an equivalency option (only effective after the modeled attainment 

date) which allows for the paving of roads with traffic under 150 ADT as long as the resulting emissions 

reductions are equivalent to reductions that would occur by paving 15 miles of roads with 150 ADT or 

above. In 2019, the area may begin paving equivalency roads. Paving a length of road with less than 150 

ADT requires that owner/operators pave a greater distance than 15 miles in order to accomplish the same 

emissions reductions as paving roads with 150 ADT. Because there is no sunset provision that applies to 

the unpaved road section of the rule, the requirement to apply controls to roads above 150 ADT does not 

at this point expire and application of measures on all roads above the threshold must still be achieved. 

Paved Public Roadways

Table 15: Paved Roads*

Measure Technically 

Feasible

Reasonable 

Implementation 

Cost

Fugitive Dust 

Rule Measure

1. Pave, vegetate, or chemically 

stabilize access points where unpaved 

traffic surfaces adjoin paved roads.

P P P

2. Require haul trucks to be covered. P Y N

3. Provide for traffic rerouting or rapid 

clean-up of temporary sources of dust

on paved roads (water erosion, runoff, 

mud/dirt track out, material spills).

Y Y Y

4. Require curbing and pave or stabilize 

road shoulders.

P P P

5. Provide for storm water drainage to 

prevent water erosion onto paved roads.

N NE N

6. Employ certified street sweepers. N Y N

 

107 Emissions reduction estimate is based on application of a combination of controls (e.g., synthetic palliative; chipsealing, double-chip-sealing, or cape-sealing; paving).
December 21, 2015 Final West Pinal PM10 RACM Analysis 49

* Y = yes; N = no; P = partial (portions of available measure were found to be feasible); NA = not 

available or not applicable; NE = not evaluated.

Measure 1. Pave, vegetate, or chemically stabilize access points where unpaved traffic surfaces adjoin 

paved roads

The Agricultural Best Management Practices (AgBMP) Rule includes trackout requirements for 

agricultural activities including unpaved traffic surfaces (see Section 4.2). The Construction Rule 

contains “prevention of trackout” requirements, including installation of trackout control devices and 

chemical stabilization, for construction related activities (see Section 4.1). Trackout control device is 

defined as a gravel pad, grizzly, wheel wash system, or a paved area, located at the point of intersection of 

an unpaved area and a paved public roadway that controls or prevents vehicular trackout.

Weed abatement provisions (for open areas and vacant lots) in the Fugitive Dust Rule (§ 4-1-030(2)(E)) 

include requirements to prevent or eliminate material trackout onto paved surfaces and access points 

adjoining paved surfaces. Measures require stabilization of disturbed areas including application of 

gravel and dust suppressants and clean-up of any trackout that does occur (see discussion of Open Areas 

and Vacant Lots above).

Additionally, measures to reduce emissions from unpaved (parking, material handling, storage) lots (§ 4-

1-030(3)) require stabilization of these surfaces (paving, gravel, dust supressants) where they may adjoin 

paved roadways (see discussion of Unpaved Lots above). 

Estimated costs associated with controlling trackout and carryout onto paved roadways include: paving, 

$6,000 to $8,500 per access point; chemical stabilization, $984; gravel, $680 to $1,360 per year per 

access point; and trackout control devices, $3,500 to $4,800 plus maintenance costs.

108

 Actual costs are 

dependent on the control option selected and local material and labor costs.

Measure 2. Require haul trucks to be covered

Material handling, transport, and storage contributing to dust emissions in the nonattainment area are 

primarily due to construction, earthmoving, and agriculture related activites. As such, measures to 

mitigate emissions from these activities are included in the Construction and Agriculture Rules discussed 

in Sections 4.1 and 4.2 of this document.

Measure 3. Provide for traffic rerouting or rapid clean-up of temporary sources of dust on paved roads

The requirements for clean up of trackout and erosion caused deposition in the Fugitive Dust Rule are 

provided at § 4-1-030(5)(A). Additional trackout provisions for construction and earthmoving activities 

are included in the Construction Rule at § 4-3-170(4) (see Section 4.1).

Clean-up of deposition on paved roads will create incremental costs to the regulated entities

(owner/operator of property where trackout originated). Choices for clean-up include manual sweep and 

pick-up, rotary brush or broom, and PM10 efficient street sweeper. Current business practice by most of 

the regulated community is to address cleanup of trackout by conducting street sweeping on the affected

portion of the paved road. Actual costs depend on the size of the trackout or erosion event and method of 

 

108 2009 Imperial County State Implementation Plan for Particulate Matter Less Than 10 Microns in Aerodynamic 

Diameter, Final, August 11, 2009.
December 21, 2015 Final West Pinal PM10 RACM Analysis 50

clean-up. Estimates for clean-up from other districts are as low as several hundred dollars per event.109

This measure was determined reasonable because the technology is available and because of the broad

range of options (and associated costs) available for clean-up. 

Mesure 4. Require curbing and pave or stabilize road shoulders

The rule includes stabilization requirements for work done on unpaved shoulders and requires the 

owner/operator of an existing paved public roadway to apply a dust suppressant(s) (water, hygroscopic 

material, chemical stabilizers, other as approved) to the total surface area subject to the disturbance in 

sufficient quantity and frequency to maintain a stabilized surface (§ 4-1-030(5)(A)). There is also a 

trackout provision attributed to the treatment of unpaved shoulders which requires the application of a 

dust suppressant but also potentially the use of a PM10 efficient street sweeper (see discussion under 

Measure 3. Provide for traffic rerouting or rapid clean-up of temporary sources of dust on paved roads 

above). The stabilization requirements associated with any work done on unpaved shoulders will also add 

incremental costs to the regulated community. Costs associated with potential paved road shoulder 

measures are estimated below: 

• Install asphalt concrete (2 inch depth, 19 mm), $1.69 per square foot or $35, 693 for an area 4 feet 

wide and one mile long;

110

• Watering Control Measure: total treatment cost (for approximately 11,733 square yards) $1,615; 

assuming a maintenance cycle of four times/month equates to a yearly cost of $77,524.80. For 

treating an area 4 feet wide and one mile long the annual cost is $15,505.111

Curbing in urban areas is already required under many municipal zoning codes for new developments and 

is not a feasible option in rural areas. Paving shoulders may remove some of the available funding for 

paving public unpaved roads. Paving/stabilizing unpaved roads likely has a larger emissions reduction 

impact in the nonattainment area. Therefore, it is generally more cost effective (and better for emissions 

reductions) to pave or treat more miles of public unpaved roads rather than paving fewer miles and adding 

paving to selected road shoulders.

Measure 5. Provide for storm water drainage to prevent water erosion onto paved roads

Water erosion runoff occurs only infrequently during periods of heavy rain; usually generated by intense, 

localized thunderstorms that occur in the late summer and early fall. In areas of higher terrain, with 

greater topographic relief, runoff is generally contained in stream and normally dry wash channels. Any 

erosion onto paved surfaces is usually narrowly restricted to where these flows may cross roadways. 

Because emissions from entrainment of erosion sediment on paved roads are very localized and minimal, 

and rerouting of storm water channels or roadways require significant time and infrastructure investment, 

this measure is not feasible in these areas. 

Much of the remainder of the nonattainment area is comprised of broad flat basins where topographic 

relief is minimal and floodwater can spread widely (desert, open areas, agricultural areas, etc.). Due to 

the low gradient in these areas, drainage channels may not be well defined, their positions may shift 

 

109 An estimate for clean-up of a 3 ton water-borne deposition event for San Joaquin, CA, totaled $640.00 for the 

county public works department utilizing three personel, a grader, and a water truck for four hours. See Final

BACM Technological and Economic Feasibility Analysis, San Joaquin Valley Unified Air Pollution Control District. 

Sierra Research, March 2003.

110 Email communication from Scott DiBiase, Pinal County AQCD, to Bruce Friedl, ADEQ, dated August 20, 2015.

111 Email communication from Scott DiBiase, Pinal County AQCD, to Bruce Friedl, ADEQ, dated August 28, 2015.
December 21, 2015 Final West Pinal PM10 RACM Analysis 51

during flooding, and inundation can be widespread.112 Drainage control requires substantial research and 

infrastructure investment. Additional measures, beyond those already accomplished by the local flood 

control district and public works departments, cannot likely be achieved by the January 2016 

implementation date or prior to the attainment date. Therefore, this measure would not significantly 

advance attainment of the NAAQS and is not feasible in these areas. 

Because this measure is unlikely to result in significant emissions reductions prior to the attainment date,

the control strategy for erosion onto paved roads focuses on access restrictions for safety during flooding 

and rapid cleanup following these infrequent events. 

Measure 6. Streetsweeping

Street sweeping reduces PM10 on paved roads, which consequently reduces reentrainment of PM10 by 

vehicles traveling on the roadway. PM10 efficient street sweepers provide additional emissions reductions 

over conventional sweepers by further reducing the silt load present on the road surface cleaned by the 

sweeper and by the reduction in dust from the actual sweeping process.113 

A typical BACM measure requires that future purchases or replacement of street sweeping equipment in 

urban areas be certified PM10 efficient. A recent report estimated capital costs for purchasing a (full size 

municipal) street sweeper ranging from $140,000 to $250,000 depending upon the sweeper type 

(mechanical, regenerative-air, vacuum, etc.) and the options included.114 PM10 efficient street sweepers 

are typically purchased through the Congestion Mitigation and Air Quality (CMAQ) process which 

includes a requirement for the local agency to match a certain percentage of the cost of the street sweeper. 

In this case the local match requirement for CMAQ funding is 5.7% which is approximatly $13,500.00

per PM10 efficient street sweeper. In addition, labor costs associated with each street sweeper for 

maintenance and operation is ongoing. The majority of the incorporated cities and towns in the West 

Pinal PM10 Planning Area already implement street sweeping programs, employing both conventional and 

PM10 efficient street sweepers. For example; Coolidge operates one PM10 efficient street sweeper, Casa 

Grande operates four PM10 efficient street sweepers, Maricopa utilizes four PM10 efficient street sweepers 

with two new ones expected by the end of the year, and Eloy employs one conventional sweeper.

ADEQ determined that (1) PM10 efficient street sweeping is already being implemented in local 

jurisdictions (e.g. the largest incorporated cities and towns in the West Pinal Planning Area) and the 

addition of a new measure is unlikely to result in significant emissions reductions; and (2) for those areas 

not operating PM10 efficient sweepers, existing equipment may not be scheduled for replacement in the 

near term, and acquiring dedicated funding and procurement of equipment cannot feasibly be

accomplished by the January 2016 implementation date and therefore would not significantly advance 

attainment of the NAAQS.

4.3.8 Comparison of the Pinal County Rule with Measures Adopted in Other Areas

Exhibit F-IV compares the Pinal County Fugitive Dust Rule with BACM and RACM strategies adopted 

and approved for other nonattainment areas in the Pacific Southwest.

 

112 Geology and Geologic Hazards of the Casa Grande Area, Pinal County, Arizona. Arizona Geological Survey, 

Open-File Report 98-23 (Preliminary). September, 1998.

113 Procedures for determining the PM10 efficiency of street sweeping equipment were established in Rule 1186: 

Appendix A; South Coast Air Quality Management District Test Protocol, Rule 1186-Certified Street Sweeper 

Compliance Testing. September 1999.

114 2008 RIC06, Resource for Implementing a Street Sweeping Best Practice. Minnesota Department of 

Transportation. February 2008.
December 21, 2015 Final West Pinal PM10 RACM Analysis 52

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December 21, 2015 Final West Pinal PM10 RACM Analysis FI-1

Exhibit F-I – Available Measures

List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area 

Significant Sources
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-2

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

Paved Roads

SCAQMD Rule 1186, 

PM10 Emissions from 

Paved and Unpaved 

Roads, and Livestock 

Operations

Owners of public paved roads must remove trackout within 72 hours. 

Government contracts for street sweeping shall use only certified 

sweeping equipment. Beginning in January 2006, new construction or 

widening of paved roads must meet specified curb and shoulder 

requirements and pave medians.

[South Coast Rule 403 includes BACM measures for road shoulder 

maintenance (water prior to clearing, chemical suppressants and/or 

washed gravel to maintain a stabilized surface after shoulder 

maintenance). Guidance encourages curbing or paving. Applicable to 

all construction activity sources.]

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14, 

2005). New version 

approved on March 7, 

2012 (77 FR 13495), but 

did not change paved 

road portion.

BACM

ICAPCD Rule 800, 

General Requirements for 

Control of Fine 

Particulate Matter (PM10); Rule 801, 

Construction and 

Earthmoving Activities; 

Rule 802, Bulk Materials; 

Rule 803, Carry-out and 

Track-out; Rule 805, 

Paved and Unpaved 

Roads; Rule 806 

Conservation 

Management Practices

Rules contain measures addressing PM10 emissions from carry-out and 

track-out onto paved surfaces, and unpaved shoulders and medians.

Rule 800 revised October 

16, 2012 (78 FR 23677, 

April 22, 2013). Rules 

801,802,803 revised 

November 8, 2005 (75 

FR 39366, July 8, 2010). 

Rules 804, 805, 806 

revised October 16, 2012 

(78 FR 23677, April 22, 

2013).

BACM

Maricopa County Rule 

310.01, Fugitive Dust 

From Non-Traditional 

Sources of Fugitive Dust

Rule contains various measures including emissions mitigation 

procedures for erosion-caused deposition of bulk materials onto paved 

surfaces.

Rule 310.01 revised 

January 27, 2010 (75 FR 

78167, December 15, 

2010). 

BACM/MSM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-3

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

SJVAPCD Rule 8061, 

Paved and Unpaved 

Roads; Rule 8021, 

Construction, Demolition, 

Excavation, Extraction, 

and Other Earthmoving 

Activities

Rule includes measures for reducing emissions from paved roads 

including stabilization of road shoulders and medians, curbing, street 

sweepers, and post-event clean-up and track out.

Rules 8061 and 8021 

revised August 19, 2004 

(71 FR 8461, February 

17, 2006). 

BACM

Clark County Rule 93, 

Fugitive Dust from Paved 

Roads and Street 

Sweeping Equipment

Includes measures for stabilizing road shoulders and medians, curbing, 

and street sweeping.

Rule 93 revised April 15, 

2014 (79 FR 60078, 

October 6, 2014)

Unpaved Roads

SJVAPCD Rule 8061, 

Paved and Unpaved 

Roads

Requires 20% opacity limit for use ≥ 75 vehicle trips/day; 20% opacity 

and stabilized surface for use ≥ 100 trips/day. The District committed to 

lower this threshold to 26 vehicle trips, add new requirements for city 

owned roads, and modify the format and reporting requirements of Rule 

8061. Units used are Average Daily Traffic (ADT).

2003 PM10 SIP1 (68 FR 

8830-8835; February 26, 

2003)

RACM

Requires 20% opacity limit and stabilized surface for use ≥ 26 trips/day 

(see comment above); pave 20% of unpaved roads each year. By 

January 1, 2010, pave an average of 20% annually of all unpaved roads 

identified in Section 5.2.3.1.1 up to a maximum of 5 cumulative miles 

within any one urban area, with priority given to roads with the highest 

AADT levels. In meeting this requirement each jurisdiction must show 

incremental progress (Section 5.2.3.1.3).

Section 5.2.3.1.1 requires; by January 1, 2005, entities provide the 

District with a list of all unpaved roads under its jurisdiction in any 

urban area(s), including data on length of, and ADT on,each unpaved 

road segment.

2003 PM10 SIP1(69 FR 

30006-30036;

May 26, 2004)

BACM

SCAQMD Rule 1186, 

PM10 Emissions from 

Section 186(d)(5) requires owners of public unpaved roads to pave 1 

mile, treat 2 miles, or extend speed control to 3 miles of unpaved road 

1998 South Coast 

AQMP2 (70 FR 69081-

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-4

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

Paved and Unpaved 

Roads, and Livestock 

Operations

per year (for 9 calendar years). Roads treated must be roads that have 

greater than the average ADT of all roads in the owner’s jurisdiction. 

69085; November 14, 

2005). New version 

approved on 3-7-2012 (77 

FR 13495), but did not 

change unpaved road 

portion.

MDAQMD Rule 403.2, 

Fugitive Dust Control for 

the Mojave Desert 

Planning Area

Requires cities, towns, and the county to stabilize publicly maintained 

heavily traveled unpaved roads to reduce fugitive dust entrainment and 

wind erosion by at least 1,541 tons per year of PM10 emissions within 

the MDPA. 

1995 PM10 SIP3 [Rule 

was adopted on July 22, 

1996, submitted to EPA 

on October 18, 1996. 

EPA has not taken any 

action.]

RACM

ICAPCD Rule 805, Paved 

and Unpaved Roads 

Requires cities and county to stabilize (to achieve 20% opacity) 10% of 

public unpaved roads with AADT ≥ 50 vehicles/day each year from 

2005 to 2015

The compliance schedule (Section E.7.b) requires, for the period 2006 

through 2015, a 10% per year compliance rate for 20% VDE and the 

requirements for a Stabilized Unpaved Road (Treatment in excess of the 

annual requirement can be credited toward future year requirements). 

The compliance plan shall identify the control measures implemented or 

that will be implemented at each Unpaved Road segment with 50 or 

more Average Vehicle Trips per Day. The plan shall clarify that the 

10% stabilized each year differ from the roads previously stabilized so 

that 100% of roads are stabilized by 2015.

2009 PM10 SIP4

(75 FR 39366-39390; 

July 8, 2010. 78 FR 

23677-23683; April 22, 

2013)

BACM

Clark County Rule 91, 

Fugitive Dust from 

Unpaved Roads, Unpaved 

Alleys, and Unpaved 

Easement Roads

Requires unpaved roads with AADT ≥ 150 vehicles/day to be controlled 

by paving, palliatives, or other approved measure. 

Fugitive dust emissions from unpaved roads and alleys must not exceed 

20% opacity and equal or exceed 0.33 oz/ft2silt loading, or not exceed 

6% silt content (determined by Subsection 91.4.1).

2001 PM10 SIP5(69 FR 

32273-32277; June 9, 

2004).

Initial adoption by Clark 

County on June 22, 2000. 

Amended on November 

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-5

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

Rule includes a staggered implementation schedule for unpaved roads 

constructed before 2000 and a separate section for roads prior to 2002. 

Requires control measures to be implemented on 1/3 of unpaved roads 

over 150 ADT by 6/1/2001; 2/3 of unpaved roads by 6/1/2002; and all 

unpaved roads by 6/1/2003 [for roads prior to 2000]. Section 91.4 

includes test methods for opacity and silt content.

16, 2000; December 21, 

2000; June 3, 2003; July 

1, 2004; April 15, 2014.

The submitted plan 

included the November 

16, 2000 version of the 

rule. This action 

approved revised versions 

of Sections 90 – 93 that 

were dated November 20, 

2001 and submitted to 

EPA on October 24, 

2002, which supersede 

earlier versions. 

Maricopa County Rule 

310.01 Fugitive Dust 

From Non-Traditional 

Sources of Fugitive Dust

Requires unpaved roads with AADT ≥ 150 vehicles/day to be controlled 

by paving, applying surface gravel, or other dust suppressants so visible 

dust emissions do not exceed 20% opacity. Rule limits silt loading 

equal to or greater than 0.33 oz/ft2. If silt loading is equal to or greater 

than 0.33 oz/ft2, then the owner and/or operator shall not allow the silt 

content to exceed 6%.

1999 PM10 SIP6

(67 FR 48718-48739; 

July 25, 2002)

Revised rule approved as 

part of EPA’s 12/15/2010 

action (75 FR 78167). 

No changes to unpaved 

road requirements. 

Adopted by Maricopa 

County on 1/27/2010.

BACM

40 CFR 52.128, Rule for 

unpaved parking lots, 

unpaved roads and vacant 

lots

Requires public unpaved roads with AADT ≥ 250 vehicles/day to be 

controlled by paving, palliatives, gravel, or other approved measure to 

meet stabilization standards.

1998 PM10 FIP7 (63 FR 

41326-41356; August 3, 

1998. 64 FR 71308; 

December 21, 1999)

RACM

1993 SIP for Nogales 

PM10 Nonattainment 

City commits to paving the remainder of unpaved streets within the City 

limits within 5 years.

1993 PM10 SIP8 (76 FR 

1532-1535; January 11, 

RACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-6

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

Area (Section 4.1)

2012 Nogales PM10 SIP

Requires paving or chemically stabilizing unpaved roads; pave, vegetate 

or chemically stabilize unpaved access points.

2011)

2012 PM10 SIP (77 FR 

58962; September 25, 

2012)

Texas Administrative 

Code, Title 30, Part 1, 

Chapter 111, Subchapter 

A, Division 4, Rule 

§111.147; Roads, Streets, 

and Alleys

New alleys in the City of El Paso must be paved; existing alleys shall 

not be used for residential garbage and recycling pickup.

1991 PM10 SIP9 (59 FR 

2532-2541; January 18, 

1994).

RACM

Unpaved Parking Lots

Measures for unpaved parking lots are discussed under Developed Land 

– Urban and Developed Land – Rural.

Construction

SJVAPCD Rule 8021, 

Construction, Demolition, 

Excavation, Extraction, 

And 

Other Earthmoving 

Activities

Rule includes a 20% opacity limit; specifies that a Dust Control Plan 

must be submitted for areas of 40 acres or larger where earth movement 

of 2500 cubic yards or more on at least 3 days is intended; compliance 

with specified measures.

2003 PM10 SIP1 (68 FR 

8830-8835; February 26, 

2003)

RACM

Rule includes 20% opacity limit and compliance with specified BACM 

measures. 

An owner/operator is required to submit a Dust Control Plan to the 

APCO prior to the start of any construction activity on any site that will 

include 10 acres or more of disturbed surface area for residential 

developments, or 5 acres or more of disturbed surface area for nonresidential development, or will include moving, depositing, or 

relocating more than 2,500 cubic yards per day of bulk materials on at 

least three days. 

BACM measures include: limit vehicle speed to 15 mph on uncontrolled 

unpaved surfaces, access/haul roads, within construction site; cease 

(FR Vol. 69, 30006-

30036, May 26, 2004) 

[Rule was amended 

August 19, 2004.]

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-7

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

earthmoving activities when high winds cause visible plumes ≥ 20% 

opacity; cease outdoor construction, excavation, extraction, and other 

earthmoving activities that disturb the soil whenever VDE exceed 20% 

opacity; use of specified trackout devices and immediate removal of 

carryout and trackout when it extends 50 feet or more from

the nearest unpaved surface exit point of a site.

SCAQMD Rule 403, 

Fugitive Dust

Rule contains: a prohibition on visible dust plumes crossing property 

line or ≥ 20% opacity; compliance with specified BACM measures; 

PM10 concentrations must be ≤ 50 μg/m3 between upwind and 

downwind property boundaries; install trackout control device for 

projects ≥ 5 acres; clean public road when visible trackout ≥ 25 feet and 

at the end of the work day; Dust Control Plans, signage, and dust control 

supervisor required for projects ≥ 50 acres.

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14, 

2005. Updated version 

approved at 73 FR 12639; 

March 2008.)

BACM

SCAQMD Rule 403.1, 

Supplemental Fugitive 

Dust Control 

Requirements for 

Coachella Valley Sources

Rule requires: monitoring onsite wind speed; stabilizing bulk material 

piles within 24 hours of placement; compliance with specified BACM 

for inactive disturbed surfaces; Dust Control Plan required for disturbed 

areas ≥ 5,000 ft2.

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14, 

2005).

BACM

MDAQMD Rule 403.1, 

Fugitive Dust Control for 

the Searles Valley 

Planning Area

Rule requires: Dust Control Plan; staging of construction in specified 

phases; covering of haul truck transporting bulk materials; removal of 

trackout on public paved roads.

1995 PM10 SIP.3 ( Rule 

was partially approved 

and partially disapproved 

at 74 FR 40750; 

August13, 2009.)

RACM

ICAPCD Rule 801, 

Construction and 

Earthmoving Activities 

Rule requires: 20% opacity limit; compliance with specified BACM for 

earthmoving activities; Dust Control Plan for construction sites of 10 

acres or more in size for residential developments or 5 acres or more for 

non-residential developments; cease dust generating activities for wind 

gusts greater than or equal to 25 mph. 

The 20% opacity limit shall not apply when Wind Gusts exceed 25 miles 

per hour, provided that specified control measures are implemented for 

each applicable Fugitive Dust source type including: ceasation of dust 

2009 PM10 SIP4

(75 FR 39366-39390; 

July 8, 2010. 78 FR 

23677-23683; April 22, 

2013) 

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-8

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

generating activities for a period of one hour after Wind Gusts last 

exceed the 25 mph threshold. If operations cease for the remainder of 

the day, stabilization measures must be implemented. 

Clark County Air Quality 

Regulations Section 94 –

Permitting and Dust 

Control for Construction 

Activities

A Dust Control Permit is not required for soil disturbing or construction 

activities less than 0.25 acres, mechanized trenching less than 100 ft in 

length, or for mechanical demolition of any structure smaller than 1000 

ft2. 

The Dust Control Permit application for a construction project 10 acres 

or more in area, for trenching 1 mi or greater, or for structure demolition 

using implosive or explosive blasting techniques, shall include a detailed 

supplement to the Dust Mitigation Plan that includes: the project 

description, the area and schedule of the phases of land disturbance, the 

Control Measures and the Contingency Measures to be used for all 

construction activities. The supplement becomes part of the Dust 

Control Permit as an enforceable permit condition. 

An application for a Dust Control Permit for a Construction project 50 

acres or more in area requires a soils analysis of the entire project to 

determine silt content and optimum moisture of the sample(s). The 

application for the Dust Control Permit shall contain the particulate 

emission potential (PEP) for each soil type identified calculated from the 

results of the soils analysis and the Silt Content vs. Optimum Moisture 

Content Chart (figure 2) in the Construction Activities Dust Control 

Handbook. The choice of Best Management Practices for the Dust 

Mitigation Plan may be different for each soil type area, if not, the 

highest PEP identified on the project shall be used. 

A trained Dust Control Monitor is required for projects greater than or 

equal to 50 acres. Rule requires ceasation of construction activities 

when high winds cause dust plumes greater than or equal to 20% 

opacity; no visible dust plume greater than or equal to 100 yards in 

2001 PM10 SIP5

(69 FR 32273-32277; 

June 9, 2004). [This 

action approved the 

November 16, 2000, 

versions of Section 94. 

EPA notes action on 

subsequent revision (July 

1, 2004) will be in a 

separate rulemaking.] 

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-9

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

length; clean paved roads when trackout is greater than or equal to 50 

feet. 

Maricopa County Rule 

310, Fugitive Dust From 

Dust-Generating 

Operations

Rule requires: 20% opacity limit; prohibition of visible dust plume 

(determined by using EPA Reference Method 22) crossing property 

boundary; ensure that control measures and requirements are 

implemented during high winds that cause dust emissions to exceed 20% 

opacity; cease dust generating activities and stabilize any disturbed area 

when high winds cause dust emissions to exceed 20% opacity; stabilize 

inactive disturbed surfaces; compliance with specified BACM for 

affected activities; dust control training required for site superintendents 

and water truck drivers; trained Dust Control Coordinator required for 

projects 5 acres or greater of disturbed soil; Dust Control Plan required 

for projects 0.10 acres or greater of disturbed soil.

1999 PM10 SIP6

(67 FR 48718-48739; 

July 25, 2002. 75 FR 

78167; December 15, 

2010.)

BACM

Maricopa County Rule 

310.01, Fugitive Dust 

From Non-Traditional 

Sources of Fugitive Dust

Clean erosion caused deposition of bulk materials (trackout) onto paved 

surfaces within 24 hours of the deposits’ identification.

1999 PM10 SIP6

(67 FR 48718-48739; 

July 25, 2002. 75 FR 

78167; December 15, 

2010)

BACM

Cleared Areas

SJVAPCD Rule 8051 

Open Areas

Requires compliance with specified measures for disturbed surfaces ≥ 

3.0 acres that have been inactive for ≥ 7 days 

Requires water/dust suppressants, vegetation, paving, applying gravel, 

or applying stabilizers to limit VDE to 20% opacity. Upon evidence of 

trespass, requires posting of “no trespass” signs or installing barriers to 

prevent access to area. 

2003 PM10 SIP1

(68 FR 8830-8835; 

February 26, 2003)

RACM

Compliance with specified BACM and 20% opacity limit for disturbed 

surfaces. The rule applies to any open area having 0.5 acres or more 

within urban areas, or 3.0 acres or more within rural areas; and contains 

at least 1000 square feet of disturbed surface area. 

2003 PM10 SIP1

(69 FR 30006-30036; 

May 26, 2004)

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-10

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

Whenever open areas are disturbed or vehicles are used in open areas, an 

owner/operator shall implement one or a combination of specified 

control measures to comply with the conditions of a stabilized surface at 

all times and to limit VDE to 20% opacity. 

SCAQMD Rule 403 

Fugitive Dust

Requires compliance with specified BACM measures for storage piles 

and disturbed surface areas. Rule includes 20 percent opacity limit. 

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14, 

2005. Updated version 

approved at 73 FR 12639; 

March of 2008.)

BACM

SCAQMD Rule 403.1 

Supplemental Fugitive 

Dust Control 

Requirements for 

Coachella Valley Sources

Requires compliance with specified BACM measures including 

stabilization of inactive disturbed surface areas within 20 days of 

activity cessation.

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14, 

2005)

BACM

MDAQMD Rule 403.2, 

Fugitive Dust Control for 

the Mojave Desert 

Planning Area

Requires stabilization of graded site surfaces when development is 

delayed, or expected to be delayed for more than 30 days.

1995 PM10 SIP3 (No 

action on rule)

RACM

ICAPCD Rule 804, Open 

Areas 

Requires compliance with 20% opacity limit and stabilized surface using 

specified BACM measures. Applicable to to any open area having 0.5 

acres or more within urban areas, or 3.0 acres or more within rural areas; 

and contains at least 1000 square feet of disturbed surface area.

Measures include prevention of vehicle trespass by signage or physical 

barriers.

2009 PM10 SIP4

(75 FR 39366-39390; 

July 8, 2010. 78 FR 

23677-23683; April 22, 

2013.)

BACM

Clark County Air Quality 

Regulations Section 90, 

Fugitive Dust from Open 

Areas and Vacant Lots

Requires prevention of vehicle trespass on open areas greater than 5,000 

ft2 within 30 days of initial discovery; application of gravel or palliatives 

satisfying stabilization standards to all areas disturbed by motor 

vehicles. 

Dust Mitigation Plans are required for open areas and vacant lots having 

2001 PM10 SIP5

(69 FR 32273-32277; 

June 9, 2004. Action 

approved revised versions 

of Sect 90 – 93 dated 

November 20, 2001, 

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-11

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

a cumulative area greater than or equal to 10,000 ft2; if machinery is 

used to clear weeds and/or trash from open areas and vacant lots of 5000 

ft2 or greater then specified control measures shall be applied (pre-wet 

surface soil; maintain dust control measures during activity; and pave, 

apply gravel, apply water, or apply a palliative in compliance with 

specified BACM.

which supersede earlier 

versions.) [Adopted on 

June 22, 2000. Amended 

November 16, 2000; 

November 20, 2001; 

December 17, 2002; June 

3, 2003, July 1, 2004, 

April 15, 2014.]

Clark County Air Quality 

Regulations Section 92, 

Fugitive Dust from 

Unpaved Parking Lots 

and Storage Areas

Rule includes various measures addressing: paving and stabilization of 

unpaved parking lots (5,000 square feet), material storage and handling 

areas, and staging areas. 

2001 PM10 SIP5

(69 FR 32273-32277; 

June 9, 2004)

BACM

Maricopa County Rule 

310.01 Fugitive Dust 

From Non-Traditional 

Sources of Fugitive Dust

Requires stabilizing open area soils sufficient to meet stabilization 

standards and prevent visible dust plumes from crossing property 

boundaries. 

Rule is applicable to open areas, vacant lots, and unpaved parking lots. 

Contains specified long-term BACM for open areas and vacant lots that 

are 0.10 acre or larger. Measures include paving, clean-up of track-out 

from unpaved parking areas that extends 25 feet or more, and prevention 

of vehicle trespass by signage or physical barrier. 

1999 PM10 SIP6

(67 FR 48718-48739; 

July 25, 2002. Revised 

rule approved at 75 FR 

78167; December 15, 

2010.)

BACM

40 CFR 52.128, Rule for 

unpaved parking lots, 

unpaved roads and vacant 

lots

Rule contains measures addressing: stabilization, re-vegetation, vehicle 

access restriction, paving, etc. Includes mitigation requirements for 

public and private unpaved parking lots, urban and suburban vacant lots 

and disturbed surfaces. Also includes certain exemptions for parking 

areas (parking lots or open areas/vacant lots disturbed by motor vehicle 

traffic) less than 5,000 square feet and vacant lots (not disturbed by 

motor vehicles) with less than 0.5 acre of disturbed surface area. 

40 CFR 52.128 (64 FR 

71308, December 21, 

1999)

RACM

Developed Land – Urban

Clark County Rule 

Section 90, Fugitive Dust 

Rule contains various measures addressing: stabilization, paving, and 

vehicle access for open areas greater than 5,000 square feet, additional 

2001 PM10 SIP5

(69 FR 32273-32277; 

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-12

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

from Open Areas and 

Vacant Lots

dust mitigation plans for owners of open areas and vacant lots with a 

cumulative area of 10,000 acres or greater, etc. 

June 9, 2004. Action 

approved revised versions 

of Sect 90 – 93 dated 

November 20, 2001, 

which supersede earlier 

versions.) [Adopted on 

June 22, 2000. Amended 

November 16, 2000; 

November 20, 2001; 

December 17, 2002; June 

3, 2003, July 1, 2004, 

April 15, 2014.]

Clark County Rule 

Section 92, Fugitive Dust 

from Unpaved Parking 

Lots and Storage Areas

Rule contains various measures addressing: paving and stabilization of 

unpaved parking lots (5,000 square feet), material storage and handling 

areas, and staging areas. 

2001 PM10 SIP5

(69 FR 32273-32277; 

June 9, 2004)

BACM

40 CFR 52.128, Rule for 

unpaved parking lots, 

unpaved roads and vacant 

lots

Rule contains measures addressing: stabilization, re-vegetation, vehicle 

access restriction, paving, weed abatement, etc. Includes mitigation 

requirements for public and private unpaved parking lots, urban and 

suburban vacant lots and other disturbed surfaces. Also includes certain 

exemptions for parking areas (parking lots or open areas/vacant lots 

disturbed by motor vehicle traffic) less than 5,000 square feet and vacant 

lots (not disturbed by motor vehicles) with less than 0.5 acres of 

disturbed surface area. 

40 CFR 52.128 (64 FR 

71308, December 21, 

1999)

RACM

Maricopa County Rule 

310.01, Fugitive Dust 

From Non-Traditional 

Sources of Fugitive Dust

Rule contains various measures addressing open areas, vacant lots, and 

unpaved parking lots including paving, stabilization, vehicle access 

restrictions, etc. Includes measures for open areas and vacant lots that 

are 0.10 acre or larger. The rule also requires clean-up of track-out from 

unpaved parking areas that extends 25 feet or more. 

1999 PM10 SIP6

(67 FR 48718-48739; 

July 25, 2002. Revised 

rule approved at 75 FR 

78167; December 15, 

2010.)

BACM

SCAQMD Rule 403, 

Fugitive Dust and Rule 

Rules include measures addressing storage piles and disturbed surface 

areas.

1998 South Coast 

AQMP2 (70 FR 69081-

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-13

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

403.1, Supplemental 

Fugitive Dust Control 

Requirements for 

Coachella Valley Sources

69085; November 14, 

2005. Updated version 

approved at 73 FR 12639; 

March of 2008.)

ICAPCD Rule 804, Open 

Areas

Includes measures addressing: stabilization, re-vegetation, vehicle 

access (posting, barriers), etc. Applies to 0.5 acres or more within urban 

areas, or 3.0 acres or more within rural areas. 

2009 PM10 SIP4

(75 FR 39366-39390; 

July 8, 2010. 78 FR 

23677-23683; April 22, 

2013.)

BACM

SJVAPCD Rule 8051, 

Open Areas

Contains measures addressing: stabilization, vehicle access, etc. 2003 PM10 SIP1

(69 FR 30006-30036; 

May 26, 2004)

BACM

Developed Land – Rural

SJVAPCD Rule 8071, 

Unpaved 

Vehicle/Equipment 

Traffic Areas

Fugitive PM10 Management Plan and compliance with specified BACM 

required on unpaved vehicle areas ≥ 1.0 acres that receive ≥ 75 vehicle 

trips per day. 

Regulation VIII currently contains a daily trip exemption threshold of 75 

for unpaved agricultural roads and for unpaved vehicle and equipment 

parking and traffic areas which is based on the SJVAPCD Governing 

Board plan Adoption of the 2003 PM10 Plan, June 19, 2003, however 

this measure is in Rule 8081(Agricultural Sources), not in Rule 8071.

2003 PM10 SIP1

(68 FR 8830-8835; 

February 26, 2003)

RACM

Requires compliance with specified BACM on unpaved vehicle areas 

receiving ≥ 50 average annual daily trips, to limit visible dust emissions 

to 20% opacity and meet stabilization requirements. 

The owner/operator shall comply with the requirements of a stabilized 

unpaved road by application and/or re-application/maintenance of at 

least one of the specified control measures, or shall implement an APCO 

approved Fugitive PM10 Management Plan as specified in Rule 8011. 

2003 PM10 SIP1

(69 FR 30006-30036; 

May 26, 2004)

BACM

SJAPCD Rule 8051, 

Open Areas

Contains measures addressing: stabilization, vehicle access, etc. 2003 PM10 SIP1

(69 FR 30006-30036; 

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-14

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

May 26, 2004)

ICAPCD Rule 804, Open 

Areas 

Requires compliance with 20% opacity limit and stabilized surface 

requirements using specified BACM measures.

Measures address: stabilization, re-vegetation, vehicle access (posting, 

barriers), etc. Applies to 0.5 acres or more within urban areas, or 3.0 

acres or more within rural areas. 

2009 PM10 SIP4

(75 FR 39366-39390; 

July 8, 2010. 78 FR 

23677-23683; April 22, 

2013.)

BACM

SCAQMD Rule 403, 

Fugitive Dust and Rule 

403.1, Supplemental 

Fugitive Dust Control 

Requirements for 

Coachella Valley Sources

Rules include measures addressing storage piles and disturbed surface 

areas.

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14,

2005. Updated version 

approved at 73 FR 12639; 

March of 2008.)

BACM

Clark County Air Quality 

Regulations Section 90 –

Fugitive Dust from Open 

Areas and Vacant Lots

Includes measures addressing: stabilization, paving, and vehicle access 

for open areas greater than 5,000 square feet, additional dust mitigation 

plans for owners of open areas and vacant lots with a cumulative area of 

10,000 acres or greater, etc. 

2001 PM10 SIP5

(69 FR 32273-32277; 

June 9, 2004)

BACM

Clark County Air Quality 

Regulations Section 92 –

Fugitive Dust from 

Unpaved Parking Lots 

and Storage Areas

Includes measures addressing: paving and stabilization of unpaved 

parking lots (5,000 square feet), material storage and handling areas, and 

staging areas. 

2001 PM10 SIP5

(69 FR 32273-32277; 

June 9, 2004)

BACM

Maricopa County Rule 

310.01, Fugitive Dust 

From Non-Traditional 

Sources of Fugitive Dust

Contains various measures addressing open areas, vacant lots, and 

unpaved parking lots including paving, stabilization, vehicle access 

restrictions, etc. Includes measures for open areas and vacant lots that 

are 0.10 acre or larger. The rule also requires clean-up of track-out from 

unpaved parking areas that extends 25 feet or more. 

Requires prevention of dust plumes from crossing property boundaries 

or exceeding 20% opacity; silt loading limit of 0.33 oz/ft2.

1999 PM10 SIP6

(67 FR 48718-48739; 

July 25, 2002. Revised 

rule approved at 75 FR 

78167; December 15, 

2010.)

BACM

40 CFR 52.128, Rule for 

unpaved parking lots, 

Rule contains measures addressing: stabilization, re-vegetation, vehicle 

access restriction, paving, weed abatement, etc. Includes mitigation 

40 CFR 52.128 (64 FR 

71308, December 21, 

RACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-15

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

unpaved roads and vacant 

lots

requirements for public and private unpaved parking lots, urban and 

suburban vacant lots and disturbed surfaces. Also includes certain 

exemptions for parking areas (parking lots or open areas/vacant lots 

disturbed by motor vehicle traffic) less than 5,000 square feet and vacant 

lots (not disturbed by motor vehicles) with less than 0.5 acres of 

disturbed surface area. 

1999)

Desert Shrubland

MDAQMD Rule 403.1, 

Fugitive Dust Control for 

the Searles Valley 

Planning Area

Rule requires a dust control plan to reduce PM10 emissions by at least 

20% relative to 1990 levels on BLM lands. Rule lists items that may be 

included in the plan.

1995 PM10 SIP.3 

(Rule partially approved 

and partially disapproved 

at 74 FR 40750; August 

13, 2009.)

RACM

ICAPCD Rule 800, 

General Requirements for 

Control of Fine 

Particulate Matter (PM10)

Rule includes measures addressing: recreational off-highway vehicle use 

on Public lands and Dust Control Plan Requirements, etc. 

78 FR 23677; April 22, 

2013

BACM

Agriculture (Croplands)

SJVAPCD Rule 4550,

Conservation 

Management Practices

The owner/operator of agricultural operation ≥ 100 acres must prepare 

and submit a CMP application committing to one CMP for each 

applicable source category and implement the CMPs upon approval by 

SJVAPCD of the application. The Air District's rule requires farmers to 

implement five CMPs for each crop including one from each of the 

following categories:

• Land preparation and cultivation

• Harvest activities

• Unpaved roads

• Unpaved equipment yards

• Other cultural practices

2003 PM10 SIP1

(69 FR 30006-30036; 

May 26, 2004)

BACM

SJVAPCD Rule 8081, 

Agricultural Sources

The owner/operator of an agricultural operation must limit visible dust 

plumes to 20% opacity through application of specified BACM 

2003 PM10 SIP1

(68 FR 8830-8835;

RACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-16

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

alternatives for each of several specified sources. February 26, 2003)

2003 PM10 SIP1

(69 FR 30006-30036;

May 26, 2004)

BACM

ICAPCD Rule 806, 

Conservation 

Management Practices

The owner/operator of an agricultural operation ≥ 40 acres must prepare 

and submit a CMP Plan committing to one CMP for each applicable 

source category and implement the CMPs upon approval by ICAPCD of 

the application. Includes special provisions on acres implementing the 

Conservation Tillage CMP.

2009 PM10 SIP4

(75 FR 39366-39390; 

July 8, 2010. 78 FR 

23677-23683; April 22, 

2013.)

BACM

SCAQMD Rule 403.1,

Supplemental Fugitive 

Dust Control 

Requirements for 

Coachella Valley Sources

Requires any person involved in agricultural tilling or soil mulching 

activities to cease operations when wind speeds exceed 25 mph (with 

some exceptions).

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14, 

2005).

BACM

Confined Animal Feeding Operations (CAFOs)

SJVAPCD Rule 4570, 

Confined Animal 

Facilities

The owner/operator of a beef feedlot holding ≥ 3,500 head must prepare 

and submit an emission mitigation plan identifying one BACM control 

for each of two operational phases and for each applicable source 

category 

Owners/operators subject to the provisions of the rule are required to 

submit a Permit to Operate (PTO) application by December 15, 2006, 

detailing an emission mitigation plan listing all chosen mitigation 

measures.

2003 PM10 SIP1

(69 FR 30006-30036; 

May 26, 2004. 77 FR 

2228: January 17, 2012.)

BACM

SCAQMD Rule 1186, 

PM10 Emissions from 

Paved and Unpaved 

Roads, and Livestock 

Operations

An owner/operator is prohibited from hay grinding between 2:00 and 

5:00 pm each day if visible emissions extend beyond 50 feet from 

grinder; treat all unpaved access connections and unpaved feed lane

access areas with gravel, pavement, or asphaltic road-base.

1998 South Coast 

AQMP2 (70 FR 69081-

69085; November 14, 

2005. New version 

approved at 77 FR 13495; 

March 7, 2012, but did 

not change CAFO 

portion.

BACM
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-17

Exhibit F-I: List of Available Control Measures Relevant to West Pinal County PM10 Nonattainment Area Significant Sources

Control Measure* Requirements

Applicable SIP

(U.S. EPA Approval 

Citation)

Measure Type

ICAPCD Rule 420, 

Livestock Feed Yards 

(Beef Feedlots)

Requires operator to maintain manure between 20% and 40% moisture 

content in the top 3 inches in occupied pens; manage manure to 

effectively control dust and to prevent adverse public health conditions. 

[Rule 420, Beef Feedlots, formerly Livestock Feed Yards adopted 

11/19/85; revised 9/14/99, 08/13/2002, and 10/10/2006]

2009 PM10 SIP4

(68 FR 8839; February 

26, 2003) 

BACM

SCAQMD Rule 403,

Fugitive Dust

Requires compliance with specified BACM measures (conservation 

management practices).

(73 FR 12639; March 

2008)

BACM

12003 PM10 Plan, San Joaquin Valley Plan to Attain Federal Standards for Particulate Matter 10 Microns and Smaller, August 19, 2003.

21998 South Coast Air Quality Management District, Air Quality Management Plan.

3Final Mojave Desert Planning Area Federal Particulate Matter (PM10) Attainment Plan, July 31, 2005.

42009 Imperial County State Implementation Plan for Particulate Matter Less Than 10 Microns in Aerodynamic Diameter, Final, August 11, 2009.

5PM–10 State Implementation Plan for Clark County, July 25, 2001.

6Revised Maricopa Association of Governments 1999 Serious Area Particulate Plan for PM-10 for the Maricopa County Nonattainment Area, 

February 2000.

7Federal Implementation Plan for Arizona – Phoenix Moderate PM10 Area at 40 CFR 52.128 (64 FR 71308, December 21, 1999).

8 Final State Implementation Plan for the Nogales PM10 Nonattainment Area, June 1993.

9Texas State Implementation Plan for PM-10 in El Paso, November 5, 1991.

*Air Quality Control Districts Referenced:

 San Joaquin Valley Air Pollution Control District (SJVAPCD), California

 Great Basin Unified Air Pollution Control District (GBUAPCD), California

 South Coast Air Quality Management District (SCAQMD), California

 Coachella Valley, California (Part of the SCAQMD)

 Mojave Desert Air Quality Management District (MDAQMD), California

 Imperial County Air Pollution Control District (ICAPCD), California

 Clark County Department of Air Quality, Nevada

 Maricopa County Air Quality Department, Arizona
December 21, 2015 Final West Pinal PM10 RACM Analysis FI-18

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December 21, 2015 Final West Pinal PM10 RACM Analysis FII-1

Exhibit F-II – Construction Comparison

Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites 

– Fugitive Dust, to Measures Adopted in Other Areas
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-2

In Exhibit F-II, the Pinal County Construction Rule is compared to applicable BACM requirements adopted for the Imperial County Air Pollution 

Control District (ICAPCD) in California. For some Pinal County rule sections, comparison is also made with applicable requirements 

implemented in the San Joaquin Valley Air Pollution Control District (SJVAPCD) and South Coast Air Quality Management District (SCAQMD)

in California, and Maricopa County (MC), Arizona.

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Intent and Applicability

PCCR 4-3-160. General 

Provisions; Section (A), 

Intent and Applicability

The intent of the rule is to control 

dust emissions associated with 

CONSTRUCTION activities. 

Applicable in the West Pinal County 

PM10 Moderate Nonattainment area.

Imperial County Rule 801(A): 

Purpose is to reduce the amount of 

PM-10 emissions due to Construction 

and Earthmoving Activities. 

Although not specified in the Pinal 

County applicability section, 

earthmoving is included as a dust 

generating activity in definition.

General Prohibition and Exemptions

PCCR 4-3-160. General 

Provisions; Section (B) 

General Prohibition and 

Exemptions

Prohibits DUST GENERATING 

OPERATION at any WORK SITE, 

without complying with the Article.

Provides exemptions for:

- Other Permits. Provides 

application and permit 

requirement exemptions for 

facilities permitted under 

ARS §§ 49-426 or 49-480 

(State and county permitting 

programs including CAA 

Title V compliance). 

Standards under PCCR 4-3-

180(A) and (B) and 

recordkeeping requirements 

under 180(C)(2)(b) still 

apply.

- Emergencies (unforeseen 

events beyond control of 

Exemptions included in Imperial 

County Rule 800 (General Rule):

- Flood Control Channels and 

water spreading basins 

(Emergency maintenance) 

[ICAPCD Rule 800(E.3)]

- Public Health and Safety 

(emergency activities less 

than 30 days) [ICAPCD Rule 

800(E.4)]

- Endangered Species (Actions 

required by the Federal or 

State Endangered Species 

Act) [ICAPCD Rule 

800(E.1)]

- Off-Field Agricultural 

Air districts primarily incorporate 

area specific exemptions. 

Pinal County rule does not include an 

exemption for “Single Family 

Residential Construction and 

Demolition” as in Imperial County 

rules. Size threshold, however, limits 

applicability to Work Sites 0.1 acre 

or larger.

Imperial County provides exemption 

from requirement for 20% opacity 

when wind exceeds 25mph. Pinal 

County rule provides similar 

exemption from violation during high 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-3

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

operator, acts of God). 

Action may be taken to 

stabilize before submitting 

permit application.

- Vehicle Test Facilities 

(activities required to test 

vehicles and equipment)

- Road maintenance 

(application and permit 

requirements only, standards 

and record keeping apply)

- Emergency Utility Repair 

(application and permit 

requirements only)

- Landscaping and Sports 

Fields (without mechanized 

equipment, no grading or 

trenching)

- Roofing (cutting, drilling, 

grinding, or coring tile 

roofing on pitched roofs)

Sources (necessary to 

minimize adverse effects on 

crops during freezing 

temperatures) [ICAPCD 

Rule 800(E.2)]

- Blasting Operations 

(permitted by the California 

Division of Industrial Safety) 

[ICAPCD Rule 800(E.5)]

- Military Training Activities 

(does not apply to unpaved 

roads, staging areas, parking 

lots) [ICAPCD Rule 

800(E.6)]

Exemptions included in Imperial 

County Rule 801, Construction and 

Earthmoving Activities:

- Single Family Residential 

Construction and Demolition 

at existing single family 

residential dwellings are 

exempt from construction 

and earthmoving measures.

[ICAPCD Rule 801(D.1)]

- Wind Event. 20% opacity 

limit does not apply when 

Wind Gusts exceed 25 miles 

per hour, provided that 

specified control measures 

are implemented. [ICAPCD 

Rule 801(D.2)]

risk events provided all measures are 

implemented and the area is 

stabilized. See PCCR 4-3-180(B) 

and 190.

Pinal County rule also provides 

violation exemption for emergency 

maintenance of flood control 

channels and water retension basins 

at section 4-3-190.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-4

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Exemptions included in Imperial 

County Rule 802, Bulk Materials:

- Outdoor storage, transport, or 

handling of Bulk Materials 

(including, but not limited to, 

organic or inorganic 

fertilizer, grains, seed, soil 

amendments, and feed) 

which would be damaged by 

wetting with water or by the 

application of Chemical 

Stabilization/Suppression, 

provided owners/operators 

demonstrate to the 

satisfaction of the APCO that 

none of the control measures 

required by this rule can be 

implemented to limit VDE to 

20% opacity or provide a 

Stabilized Surface, as 

defined in Rule 800. 

[ICAPCD Rule 802(D.1)]

- Outdoor storage or handling 

of any Bulk Material at a 

single site where no material 

is actively being added or 

removed at the end of the 

workday or overnight and 

where the total material 

stored is less than 100 cubic 

yards. [ICAPCD Rule 

802(D.2)]

- Transport of a Bulk Material 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-5

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

in an outdoor area for a 

distance of twelve feet or less 

with the use of a chute or 

conveyor device. [ICAPCD 

Rule 802(D.3)]

- Transport/hauling of Bulk 

Materials when conducted 

within the boundaries of a 

premises, are exempt from 

the requirements specified in 

Sections F.3.a and F.3.d. 

[ICAPCD Rule 802(D.4)]

Exemptions included in Imperial 

County Rule 803, Carry-Out and 

Track-Out:

- Agricultural Operation Sites 

defined in and subject to 

Rule 806, Conservation 

Management Practices, are 

exempt from the 

requirements specified in 

Sections F.1.b and F.1.c

[related to track-out 

prevention devices, paving, 

chemical stabilization, and 

gravel pads at access points 

where Unpaved Roads adjoin 

Paved Roads]. [ICAPCD 

Rule 803(D.1)]

- Any operation site that 

operates no more than 10 

days within a 90 days period 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-6

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

at each location is exempt 

from the requirements 

specified in Sections F.1.b 

and F.1.c [related to trackout prevention devices, 

paving, chemical 

stabilization, and gravel pads 

at access points where 

Unpaved Roads adjoin Paved 

Roads]. [ICAPCD Rule 

803(D.2)]

Definitions (Selected)

PCCR 4-3-170. 

Definitions

See Chapter 1, Article 3 (General 

Provisions and Definitions) of this 

code for definitions of terms that are 

used but not specifically defined in 

this Article.

PCCR 4-3-170(1). 

“BULK MATERIAL”

"BULK MATERIAL" as used in 

this Article, means any material 

including but not limited to earth, 

rock, silt, sediment, sand, gravel, soil, 

fill, aggregate less than 2 inches in 

length or diameter, dirt, mud, 

demolition debris, trash, cinders, 

pumice, saw dust, and dry concrete, 

which are capable of producing 

fugitive dust at an industrial, 

institutional, commercial, 

governmental, construction and/or 

demolition site.

BULK MATERIAL: Earth, rock, 

Silt, sediment, sand, Gravel, soil, fill, 

Aggregate, dirt, mud, debris, and 

other organic and/or inorganic 

material consisting of or containing 

Particulate Matter with five percent 

or greater Silt content. For the 

purpose of this Regulation, the Silt 

content level is assumed to be 5 

percent or greater, unless the Person 

responsible for the Active Operation 

conducts the applicable laboratory 

tests and demonstrate that the Silt 

content is less than 5 percent. Active 

Operations seeking to determine if 

the Silt content is less than five 

Imperial County rule includes

additional definitions for aggregate

and silt.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-7

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

percent are required to conduct the 

laboratory analysis in accordance 

with ASTM method C-136-a 

(Standard Test Method for Sieve 

analysis of Fine and Coarse 

Aggregates), or other equivalent test 

methods approved by EPA, ARB, 

and the APCD. [ICAPCD Rule 

800(C.10)]

AGGREGATE MATERIALS:

Consists of sand, Gravel, quarried 

stone and/or rock fragments that are 

typically used in Construction. 

Aggregates may be natural, artificial 

or recycled. [ICAPCD Rule 

800(C.2)]

SILT: Any Aggregate Material with 

a particle size less than 75 

micrometers in diameter as measured 

by a No. 200 sieve as defined in 

ASTM D-2487 and as tested by 

ASTM-C-136 or other equivalent test 

methods approved by EPA, ARB, 

and the APCD. [ICAPCD Rule 

800(C.36)]

PCCR 4-3-170(2). 

“BULK MATERIAL 

HANDLING, STORAGE 

AND/OR 

TRANSPORTING 

OPERATION”

"BULK MATERIAL HANDLING, 

STORAGE AND/OR 

TRANSPORTING OPERATION" 

as used in this Article, means the 

processing of BULK MATERIALS, 

including but not limited to, the 

Imperial County rule does not 

include additional definition.

Pinal County rule includes detailed

explanation of material handling and 

transport.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-8

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

loading, unloading, conveying, 

transporting, piling, stacking, 

screening, grading, or moving of bulk 

materials.

PCCR 4-3-170(3). 

“CONSTRUCTION”

“CONSTRUCTION” as used in this 

Article means building, maintaining 

or modifying a capital improvement 

resting upon, connected to or buried 

in the earth. Construction includes, 

but is not limited to, vertical 

construction, residential construction, 

installing underground utilities, 

installing above-ground utilities, and 

building physical infrastructure 

including roads, highways, railways, 

flood structures, drainage works and 

irrigation works. Notwithstanding 

any other exemption under these 

rules, weed abatement by discing or 

blading and conducted for the 

purpose of enabling Development 

Activity or maintaining a work site 

shall qualify as construction.

CONSTRUCTION: Any on-site 

mechanical activities preparatory to 

or related to the building, alteration, 

rehabilitation, or demolition of an 

improvement on real property, 

including, but not limited to, land 

clearing, excavation related to 

construction, land leveling, grading, 

cut and fill grading, and the erection 

or demolition of any structure. As 

used in Regulation VIII, a 

construction site may encompass 

several contiguous parcels, or may 

encompass only a portion of one 

parcel, depending on the relationship 

of the property boundaries to the 

actual construction activities. 

[ICAPCD Rule 800(C.13)]

Pinal County and Imperial County 

include similar descriptions.

PCCR 4-3-170(4). 

“CONTROL 

MEASURE”

"CONTROL MEASURE" as used 

in this Article means, a preemptive or 

concurrent technique used to 

minimize the generation, emission, 

entrainment, suspension, and/or 

airborne transport of fugitive dust at 

a WORK SITE in order to comply 

with applicable standards in section 

4-3-180. CONTROL MEASURES 

include but are not limited to:

Requires Best Available Control 

Measures for Fugitive Dust (PM-10) 

[ICAPCD Rule 801(F)]

Construction and Earthmoving 

Activities shall comply with the 

following requirements: [ICAPCD 

Rule 801(F.1)]

The Pinal and Imperial rules are 

structured differently. The Imperial 

County rule specifies controls 

separately under each dust generating 

activity. The Pinal County rule lists 

control strategies in a single list in 

definitions, to be applied as 

appropriate to dust generating 

activities. Additional control 

measures for specific circumstances 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-9

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

are detailed elsewhere in the rule.

Watering (pre-wetting): 

‘Application of water by means of 

trucks, hoses, and/or sprinklers prior 

to conducting any DUST 

GENERATION OPERATION. This 

will increase the moisture content of 

the soils and increase stability of the 

soil.’

Pre-Activity:

1. Pre-water site sufficient to limit 

visible dust emisions (VDE) to 20% 

opacity, and

2. Phase work to minimize the 

amount of disturbed surface area at 

any one time. [ICAPCD Rule 

801(F.1.a)]

Watering (operational control): 

‘For DISTURBED SURFACE 

AREAS and DUST GENERATING 

OPERATIONS water is applied at 

sufficient intervals and quantity to 

increase the moisture content of the 

soils and increase stability of the soil. 

Also during stacking, loading and 

unloading operations on open storage 

piles, apply water as necessary.’

During Active Operations:

1. Apply water or Chemical 

Stabilization as directed by product 

manufacturer to limit VDE to 20% 

opacity, or

2. Construct and maintain wind 

barriers sufficient to limit VDE to 

20% opacity. If utilizing wind 

barriers, control measure F.1.b.1 

above shall be implemented.

3. Apply water or Chemical 

Stabilization as directed by product 

manufacturer to unpaved haul/access 

roads and Unpaved Traffic Areas 

sufficient to limit VDE to 20% 

opacity and meet the conditions of a 

Stabilized Unpaved Road. [ICAPCD 

Rule 801(F.1.b)]

Temporary Stabilization During 

Periods of Inactivity:

1. Restrict vehicular access to the 

area by fencing or signage; and 

2. Apply water or Chemical 

Pinal and Imperial rules are 

structured differently; similar 

measures.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-10

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Stabilization, as directed by product 

manufacturer, sufficient to comply 

with the conditions of a Stabilized 

Surface. If an area having 0.5 acres 

or more of disturbed surface area 

remains unused for seven or more 

days, the area must comply with the 

conditions for a Stabilized Surface 

area. [ICAPCD Rule 801(F.1.c)]

Applying chemical stabilizers or 

DUST SUPPRESSANTS:

‘Apply chemical stabilizers/DUST 

SUPPRESSANTS to DISTURBED 

SURFACE AREAS and DUST 

GENERATING OPERATIONS. 

Effective in areas which are not 

subject to daily disturbances.’

During Active Operations:

1. Apply water or Chemical 

Stabilization as directed by product 

manufacturer to limit VDE to 20% 

opacity, or

2. Construct and maintain wind 

barriers sufficient to limit VDE to 

20% opacity. If utilizing wind 

barriers, control measure F.1.b.1 

above shall be implemented.

3. Apply water or Chemical 

Stabilization as directed by product 

manufacturer to unpaved haul/access 

roads and Unpaved Traffic Areas 

sufficient to limit VDE to 20% 

opacity and meet the conditions of a 

Stabilized Unpaved Road. [ICAPCD 

Rule 801(F.1.b)]

Temporary Stabilization During 

Periods of Inactivity:

1. Restrict vehicular access to the 

area by fencing or signage; and 

2. Apply water or Chemical

Pinal and Imperial rules are 

structured differently; similar 

measures.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-11

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Stabilization, as directed by product 

manufacturer, sufficient to comply 

with the conditions of a Stabilized 

Surface. If an area having 0.5 acres 

or more of disturbed surface area 

remains unused for seven or more 

days, the area must comply with the 

conditions for a Stabilized Surface 

area. [ICAPCD Rule 801(F.1.c)]

Altering load-in/load-out 

procedures and watering:

‘Confine load-in-load out procedures 

to downwind side of the material and 

mist material with water prior to 

loading. Empty loader slowly and 

keep bucket close to the truck while 

dumping.’

Bulk Material handling operations at 

the site shall comply with Rule 802. 

[ICAPCD Rule 801(F.1.f)]

Bulk Material handling:

No Person shall cause, suffer, allow 

or engage in any Bulk Material 

handling operation including, but not 

limited to stacking, loading, 

unloading, conveying and reclaiming 

of Bulk Material, for industrial or 

commercial purposes without 

complying with one or more of the 

requirements of Section F.1 so as to 

limit VDE to 20% opacity. 

[ICAPCD Rule 802(E.1)]

BULK MATERIAL 

HANDLING/TRANSFER: 

[BACM for Fugitive Dust]

a. Spray with water prior to handling 

and/or at points of transfer; or

b. Apply and maintain Chemical 

Stabilization, or

Imperial rule provides exemption for 

certain bulk material (including, but 

not limited to, organic or inorganic 

fertilizer, grains, seed, soil 

amendments, and feed) and where 

the total material stored is less than 

100 cubic yards. [ICAPCD Rule 

802(D.1 and D.2)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-12

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

c. Protect from wind erosion by 

sheltering or enclosing the operation 

and transfer line. [ICAPCD Rule 

802(F.1)]

Reducing vehicular speeds:

‘Restrict maximum vehicular speeds 

to 15 miles per hour on unpaved 

easements, right of way, unpaved 

haul/access roads and parking lots.’

Unpaved Roads and Unpaved Traffic 

Areas at the site shall comply with 

Rule 805. [ICAPCD Rule 

801(F.1.e)]

Unpaved Haul/Access Roads:

No Person shall cause, suffer or 

allow the operation, use, or 

maintenance of any unpaved 

Haul/Access Road without 

complying with one or more of the 

requirements of Section F.1 so as to 

limit VDE to 20% opacity. 

[ICAPCD Rule 805(E.1.)]

Unpaved Traffic Areas:

All Persons who cause, suffer or 

allow the operation, use or 

maintenance of any Unpaved Traffic 

Area larger than one (1) acre and 

with 75 or more Average Vehicle 

Trips per Day shall comply with one 

or more of the requirements of 

Section F.3 and limit VDE to 20% 

opacity. [ICAPCD Rule 805(E.5)]

UNPAVED ROADS, INCLUDING 

UNPAVED HAUL AND ACCESS 

ROADS: [BACM for Fugitive Dust]

In addition to reducing vehicle speed,

all other control measures in the 

Pinal rule are applicable (as 

appropriate) to UNPAVED 

PARKING LOTS, haul/access roads

and traffic areas within a WORK 

SITE. These areas are included in 

the definition of DUST 

GENERATING OPERATION at 

Section 4-3-170(6).
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-13

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

a. Pave.

b. Apply Chemical Stabilization as 

directed by product manufacturer to 

control dust on Unpaved Roads.

c. Apply and maintain Gravel, 

recrushed/recycled asphalt or other 

material of low Silt (<5%) content to 

a depth of three or more inches.

d. Wetting. Apply water one or more 

times daily

e. Permanent road closure

f. Restrict unauthorized vehicle 

access.

g. Any other method that effectively 

limits VDE to 20% opacity and 

meets the conditions of a Stabilized 

Unpaved Road. [ICAPCD Rule 

805(F.1)]

UNPAVED TRAFFIC AREAS: 

[BACM for Fugitive Dust]

a. Pave.

b. Apply Chemical Stabilization as 

directed by product manufacturer to

control dust on Unpaved Roads.

c. Apply and maintain Gravel, 

recrushed/recycled asphalt or other 

material of low silt (<5%) content to 

a depth of three or more inches.

d. Wetting. Apply water one or more 

times daily. [ICAPCD Rule 

805(F.3)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-14

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Controlling Freeboard and spillage 

and covering haul vehicles: ‘Load 

all trucks such that the 

FREEBOARD is not less than three 

inches; and prevent spillage or loss 

of BULK MATERIAL from holes or 

other openings in the conveyance; 

cover all haul trucks (empty or full) 

with an anchored tarp or other 

suitable anchored material.’

Material transport of Bulk Material 

to, from, or around the site shall 

comply with Rule 802. [ICAPCD 

Rule 801(F.1.g)] Haul trucks 

transporting Bulk Material to, from, 

or around the site shall comply with 

Rule 802. [ICAPCD Rule 

801(F.1.h)]

Material transport:

no Person shall cause, suffer, allow 

or otherwise engage in the 

transportation of Bulk Materials for 

industrial or commercial purposes, 

without complying with all of the 

requirements of Section F.3 so as to 

limit VDE to 20% opacity. 

[ICAPCD Rule 802(E.3)]

Haul Trucks: 

no Person shall cause, suffer, allow 

or otherwise engage in the use or 

operation of any Haul Truck, for 

industrial or commercial purposes, of 

transporting or storing Bulk Material 

without complying with all of the 

requirements of Section F.3 so as to 

limit VDE to 20% opacity. 

[ICAPCD Rule 802(E.4)]

MATERIAL 

TRANSPORT/HAULING: 

[BACM for Fugitive Dust]

Imperial rule provides exemption for

the transport of Bulk Material for a 

distance of twelve feet or less with 

the use of a chute or conveyor device 

and from requirements specified in 

Sections F.3.a and F.3.d (covering 

haul loads and cargo compartment 

cleaning of haul trucks) when

transport is conducted within the 

boundaries of a premises. [ICAPCD 

Rule 802(D.3 and D.4)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-15

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

a. Completely cover or enclose all 

Haul Truck loads of Bulk Material.

b. Haul Trucks transporting loads of 

Aggregate Materials shall not be 

required to cover their loads if the 

load, where it contacts the side, front, 

and back of the cargo container area 

remains six inches from the upper

area of the container area, and if the 

load does not extend, at its peak, 

above any part of the upper edge of 

the cargo container area (As defined 

in Section 23114 of the California 

Vehicle Code for both public and 

private roads).

c. The cargo compartment(s) of all 

Haul Trucks are to be constructed 

and maintained so that no spillage 

and loss of Bulk Material can occur 

from holes or other openings in the 

cargo compartment's floor, side, 

and/or tailgate. Seals on any 

openings used to empty the load 

including, but not limited to, bottomdump release gates and tailgates to be 

properly maintained to prevent the 

loss of Bulk Material from those 

areas.

d. The cargo compartment of all Haul 

Trucks is to be cleaned and/or 

washed at delivery site after removal 

of Bulk Material. [ICAPCD Rule 

802(F.3)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-16

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

TRACKOUT CONTROL 

DEVICE: ‘Install a TRACKOUT 

CONTROL DEVICE for WORK 

SITES 5 acres or larger. When 

TRACKOUT extends a cumulative 

distance of 50 linear feet or more, be 

cleaned up as soon as practicable; 

but, in any case, by the end of the 

work day.’

Track Out/Carry Out of Bulk 

Materials at the site shall be 

mitigated in compliance with Rule 

803. [ICAPCD Rule 801(F.1.d)]

Track Out/Carry Out: 

Any Person who causes the 

deposition of Bulk Material by 

tracking out or carrying out onto a 

Paved Road surface shall comply 

with the requirements of Section F.1, 

as specified, to prevent or mitigate 

such deposition. [ICAPCD Rule 

803(E.1)]

TRACK OUT/CARRY OUT: 

[BACM for Fugitive Dust]

F.1.a. Clean up any Bulk Material 

tracked out or carried out onto a 

Paved Road on the following timeschedule:

(1) Within urban areas, immediately, 

when Track-Out or Carry-Out 

extends a cumulative distance of 50 

linear feet or more; and

(2) At the end of the workday, for all 

other Track-Out or Carry-Out.

F.1.b In addition to F.1.a, all sites 

with access to a Paved Road and with 

150 or more Average Vehicle Trips 

per Day, or 20 or more Average 

Vehicle Trips per Day by vehicles 

with three or more axles shall install 

Imperial rule provides exemption 

from Sections F.1.b and F.1.c (related 

to track-out prevention devices, 

paving, chemical stabilization, and 

gravel pads at access points where 

Unpaved Roads adjoin Paved Roads)

for Agricultural Operations subject to 

Rule 806, Conservation Management 

Practices and any operation site that 

operates no more than 10 days within 

a 90 days period. [ICAPCD Rule 

803(D.1 and D.2)]

The Pinal rule requires trackout clean

up as soon as practicable when it 

extends a cumulative distance of 50 

feet or more. The Imperial rule 

requires immediate clean up for 50 or 

more feet and South Coast 25 feet or 

more. Both districts require clean up 

of trackout by the end of the day.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-17

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

one or more Track-Out Prevention 

Devices or other APCO approved 

Track-Out control device or wash 

down system at access points where 

unpaved traffic surfaces adjoin Paved 

Roads; or

F.1.c In addition to F.1.a, all sites 

with access to a Paved Road and with 

150 or more Average Vehicle Trips 

per Day, or 20 or more Average 

Vehicle Trips per Day by vehicles 

with three or more axles shall apply 

and maintain paving, Chemical 

Stabilizeation, or at least 3 inch depth 

of Gravel (using Gravel or other low 

Silt (<5%) content material), for a 

distance of 50 or more consecutive 

feet at access points where Unpaved 

Roads adjoin Paved Roads. 

[ICAPCD Rule 803(F.1)]

No person shall allow track-out to 

extend 25 feet or more in cumulative

length from the point of origin from 

an active operation. Notwithstanding

the preceding, all track-out from an 

active operation shall be removed at

the conclusion of each workday or 

evening shift. [SCAQMD Rule 

403(d)(4)]

Limit, restrict or reroute MOTOR 

VEHICLES access to work site: 

‘Erect signs or install physical 

Temporary Stabilization During 

Periods of Inactivity:

1. Restrict vehicular access to the 

Pinal and Imperial rules are 

structured differently; similar 

measures; Pinal requirement applies 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-18

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

barriers to limit access of WORK 

SITE.’

area by fencing or signage; and

2. Apply water or Chemical 

Stabilization, as directed by product 

manufacturer, sufficient to comply 

with the conditions of a Stabilized 

Surface. If an area having 0.5 acres 

or more of disturbed surface area 

remains unused for seven or more 

days, the area must comply with the 

conditions for a Stabilized Surface 

area. [ICAPCD Rule 801(F.1.c)]

at all times.

Other measures as proposed by 

registrant: ‘Specific measures that 

are adequate to address applicable 

standards in section 4-3-180 at the 

WORK SITE. Alternative measures 

must be approved by the Control 

Officer and the EPA Administrator.’

The Pinal County rule provides 

flexibility for alternative measures 

approved by EPA.

PCCR 4-3-170(5). 

“DISTURBED 

SURFACE AREA”

"DISTURBED SURFACE AREA" 

as used in this Article, means any 

portion of the earth's surface that has 

been physically moved, uncovered, 

destabilized, or otherwise modified 

from its undisturbed natural 

condition. 

This definition excludes those 

permanently stabilized areas that 

have:

a. Been restored to a natural 

condition, such that vegetative 

ground cover and soil characteristics 

are similar to adjacent or nearby 

DISTURBED SURFACE AREA: An 

area in which naturally occurring 

soils, or soils or other materials 

placed thereon, have been physically 

moved, uncovered, destabilized, or 

otherwise modified by grading, land 

leveling, scraping, cut and fill 

activities, excavation, bush and 

timber clearing, or grubbing, and 

soils on which vehicle traffic and/or 

equipment operation has occurred. 

An area is considered to be disturbed 

until the activity that caused the 

disturbance has been completed, and 

the disturbed area meets the 

The Imperial County rule is 

somewhat more specific regarding 

what constitutes a disturbed surface; 

the Pinal rule is broader. Both rules 

exclude stabilized areas. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-19

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

natural conditions;

b. Been paved or otherwise covered 

by a permanent structure; or

c. Sustained a vegetative ground 

cover over at least 70 percent of the 

area for at least 30 days. 

stabilized surface conditions 

specified in this rule, or the area has 

been paved or otherwise covered by a 

permanent structure. [ICAPCD Rule 

800(C.15)]

PCCR 4-3-170(6). 

“DUST GENERATING 

OPERATION”

"DUST GENERATING 

OPERATION" as used in this 

Article, means any activity capable 

of generating fugitive dust, including 

but not limited to:

a. EARTHMOVING 

ACTIVITIES

b. Land clean-up, leveling, back 

filling 

c. Drilling

d. CONSTRUCTION

e. Demolition

f. BULK MATERIAL 

HANDLING, STORAGE AND/OR 

TRANSPORTING OPERATIONS

g. Operation of motorized 

machinery used in 

CONSTRUCTION

h. Establishing and/or using 

UNPAVED PARKING LOTS, 

haul/access roads within a WORK 

SITE

i. Installing initial landscapes 

using mechanized equipment.

For the purpose of this rule, 

landscape maintenance and/or 

Imperial County Rule 800 has a 

similar definition for ACTIVE 

OPERATION: Activities capable of 

generating Fugitive Dust (PM-10), 

including but are not limited to, 

Earthmoving Activities, Construction 

activities, Unpaved Roads, TrackOut/Carry-Out, Bulk Material storage 

and transport, Unpaved Haul/Access 

Roads. [ICAPCD Rule 800(C.1)]

Applicability section of San Joaquin 

Rule 8020 identifies the following 

activities: construction, demolition, 

excavation, extraction, and water 

mining related disturbances of soil, 

including land clearing, grubbing, 

scraping, ground excavation, land 

leveling, grading, cut and fill 

operations, travel on the site, travel 

on access roads to and from the site, 

and demolition activities. [SJVAPCD 

Rule 8020(2)]

The scope of the Pinal County rule is 

consistent with reviewed BACM 

level rules.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-20

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

playing on a ball field shall not be 

considered a dust generating 

operation.

PCCR 4-3-170(7). 

“DUST 

SUPPRESSANT”

"DUST SUPPRESSANT" means 

hygroscopic material, solution of 

water and chemical surfactant foam, 

non-toxic chemical stabilizer or any 

other dust palliative, which is not 

prohibited by the U. S. 

Environmental Protection Agency 

(EPA) or the Arizona Department of 

Environmental Quality (ADEQ), or 

any applicable law, rule, or 

regulation, as a treatment material for 

reducing fugitive dust emissions.

San Joachin Rule defines Dust 

Suppressants as: includes water, 

hygroscopic materials, chemical 

stabilization and suppression 

materials (see also Definition 3.4

“Chemical 

Stabilization/Suppression”), and 

other approved substances. 

[SJVAPCD Rule 8010(3.7)]

Chemical Stabilization/Suppression: 

a means of dust control implemented 

by any person to mitigate PM-10 

emissions by applying petroleum 

resins, asphaltic emulsions, acrylics, 

adhesives, or any other approved 

materials. [SJVAPCD Rule 

8010(3.4)]

Imperial County Construction rules 

do not explicitly define dust 

suppressant. Chemical 

Stabilization/Suppression definition 

similar to San Joaquin. [ICAPCD 

Rules 800 and 801]

Pinal County Rule refers primarily to 

chemical stabilizers. Water is 

specified separately as a control 

elsewhere in the rule.

PCCR 4-3-170(8). 

“EARTHMOVING 

ACTIVITY”

"EARTHMOVING ACTIVITY" 

means any land clearing, land cutting 

and filling operations, blasting, 

trenching, ROAD 

CONSTRUCTION, grading, 

EARTHMOVING ACTIVITIES: 

The use of any equipment for an 

activity that may generate Fugitive 

Dust emissions, including, but not 

limited to, cutting and filling, 

Imperial County rule specifically 

identifies adding to or removing from 

storage piles as an earth moving 

activity whereas the Pinal rule does 

not. Pinal rule however is broad 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-21

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

landscaping, landfill operations, 

weed abatement through discing, soil 

mulching, or any other activity 

associated with land development 

where the objective is to disturb the 

surface of the earth.

grading, leveling, excavation, 

trenching, loading or unloading of 

Bulk Materials, demolishing, drilling, 

adding to or removing bulk materials 

from open storage piles, weed 

abatement through disking, and back 

filling. [ICAPCD Rules 800(C.17)]

enough to include these activites and 

emissions reduction provisions for 

these sources are included elsewhere 

in the rule. 

PCCR 4-3-170(17). 

“PAVED PUBLIC 

ROADWAY”

“PAVED PUBLIC ROADWAY” 

means a publicly owned paved 

roadway, owned by federal, state, 

county, municipal, or other 

governmental or quasi-governmental 

agencies as evidenced by a formal 

acceptance by the state or a political 

subdivision of the state of either:

1. An on-going maintenance 

obligation for the roadway; or

2. A title or easement for the 

roadway.

PAVED ROADS: An improved 

street, highway, alley, public way, 

that is covered by concrete, asphaltic 

concrete, or asphalt. [ICAPCD Rules 

800(C.31)]

The Pinal County Rule defines Paved 

Road as a government owned public 

roadway, consistent with the Phoenix 

RACM FIP application of controls 

for unpaved roadways. [40 CFR 

52.128] 

PCCR 4-3-170(18). 

“PINAL COUNTY 

DUST CONTROL 

FORECAST”

“PINAL COUNTY DUST 

CONTROL FORECAST” means a 

forecast, which shall identify a low, 

moderate 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. When developing these 

forecasts, the Department of 

Environmental Quality shall consider 

all of the following:

a) Projected meteorological 

conditions, including:

i) Wind speed and direction,

N/A The Pinal County rule provides an 

added level of protection by 

providing a notification system for 

high risk meteorological events 

during which additional precautions 

are required to prevent poor air 

quality. See also PCCR 4-3-180(B).
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-22

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

ii) Stagnation,

iii) Recent precipitation, and

iv) Potential for precipitation;

b) Existing concentrations of air 

pollution at the time of the forecast; 

and

c) Historic air pollution 

concentrations that have been 

observed during meteorological 

conditions similar to those that are 

predicted to occur in the forecast.

PCCR 4-3-170(21). 

“STABILIZE”

“STABILIZE” means any 

previously disturbed surface area 

which, through application of water 

or DUST SUPPRESSANTS, shows 

visual or other evidence of surface 

crusting and is resistant to winddriven fugitive dust. Stabilization 

shall be demonstrated by application 

of the drop ball test in Article 9 (§4-

9-320.B.1).’

The Pinal County rule also defines 

“permanently stabilized areas” under 

the definition of DISTURBED 

SURFACE AREA at 4-3-170(5). 

Permanently stabilized areas have:

a. Been restored to a natural 

condition, such that vegetative 

ground cover and soil characteristics 

are similar to adjacent or nearby 

natural conditions;

b. Been paved or otherwise covered 

STABILIZED SURFACE: Any 

disturbed surface area or open bulk 

storage pile that is resistant to wind 

blown Fugitive Dust emissions. A 

surface is considered to be stabilized 

if it meets at least one of the 

following conditions specified in this 

Section and as determined by the test 

methods specified in Appendix B, 

Section A, B and D-G tests of this 

rule:

a. A visible crust; or

b. A threshold friction velocity 

(TFV) for disturbed surface areas 

corrected for non-erodible elements 

of 100 centimeters per second or 

greater; or

c. A flat vegetative cover of at least 

50 percent that is attached or rooted 

vegetation; or unattached vegetative 

debris lying on the surface with a 

predominant horizontal orientation 

The definitions for stabilized surfaces 

in the Pinal and Imperial County 

rules are generally consistent. The 

Pinal rule, however, distinguishes 

between temporary and permanent 

forms of stabilization. 

The Pinal rule requires demonstration 

of stabilization by application of the 

drop ball test. This is also a 

demonstration method contained in 

the Imperial rule. Although not 

specified in rule, the Pinal County 

Control Officer will use the “Line 

Transect Method” for determining 

vegetative cover for permanently 

stabilized areas.

The Pinal County construction rule 

does not contain a separate definition 

for stabilized unpaved roads as in the 

Imperial rule. Unpaved roads used 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-23

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

by a permanent structure; or

c. Sustained a vegetative ground 

cover over at least 70 percent of the 

area for at least 30 days.

that is not subject to movement by 

wind; or

d. A standing vegetative cover of at 

least 30 percent that is attached or 

rooted vegetation with a predominant 

vertical orientation; or

e. A standing vegetative cover that is 

attached or rooted vegetative with a 

predominant vertical orientation that 

is at least 10 percent and where the 

TFV is at least 43 centimeters per 

second when corrected for nonerodible elements; or

f. A surface that is greater than or 

equal to 10 percent of non-erodible 

elements such as rocks, stones, or 

hard-packed clumps of soil. 

[ICAPCD Rule 800(C.37)]

STABILIZED UNPAVED ROAD: 

Any Unpaved Road or unpaved 

vehicle/equipment traffic area surface 

which meets the definition of 

Stabilized Surface as determined by 

the test method in Appendix B, 

Section C of this rule, and where 

VDE is limited to 20% opacity. 

[ICAPCD Rule 800(C.38)]

for construction activities and 

stabilization of those roads are 

considered subsumed in the 

definitions and control requirements 

for DISTURBED SURFACE 

AREAS.

PCCR 4-3-170(22). 

“TRACKOUT”

"TRACKOUT" means visible 

material deposited onto any PAVED 

PUBLIC ROADWAY, as defined in 

this Article, by traffic leaving a 

WORK SITE.

TRACK-OUT/CARRY-OUT: Any 

and all Bulk Materials that adhere to 

and agglomerate on the exterior 

surfaces of motor vehicles and/or 

equipment (including tires) that may 

Similar definition with Imperial 

County Rule.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-24

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

then fall onto the pavement. 

[ICAPCD Rule 800(C.42)]

PCCR 4-3-170(25). 

“UNPAVED 

HAUL/ACCESS ROAD”

"UNPAVED HAUL/ACCESS 

ROAD" as used in this Article, 

means any on-site UNPAVED 

ROAD used by commercial, 

industrial, institutional, and/or 

governmental traffic.

UNPAVED ROADS: Streets, alley 

ways, or roadways that are not 

covered by one of the following: 

concrete, asphaltic concrete, asphalt, 

or other similar materials specified 

by the U.S.EPA, CARB and/or the 

APCO. [ICAPCD Rule 800(C.44)]

Pinal County definition is consistent 

with Appendix C1 of the General 

Preamble.

PCCR 4-3-170(26). 

“UNPAVED PARKING 

LOT”

"UNPAVED PARKING LOT" as 

used in this Article, means any area 

larger than 5,000 square feet that is 

not paved and that is used for 

parking, maneuvering, or storing 

MOTOR VEHICLES on a WORK 

SITE.

UNPAVED TRAFFIC AREA: Any 

nonresidential area that is:

a. Not covered by asphalt, recycled 

asphalt, asphaltic concrete, concrete, 

or concrete pavement, and

b. Used for fueling and servicing; 

shipping, receiving and transfer; or 

parking or storing equipment, haul 

trucks, vehicles, and any 

conveyances. [ICAPCD Rule 

800(C.45)]

PCCR 4-3-170(27). 

“UNPAVED ROAD”

"UNPAVED ROAD" as used in this 

Article, means any unsealed or 

unpaved roads, equipment path, or 

travel ways that are not covered by 

typical roadway materials. Public 

unpaved roads are any unpaved 

roadway owned by federal, state, 

county, municipal, or other 

governmental or quasi-governmental 

agencies. Private unpaved roads are 

all other unpaved roadways not 

defined as public. For the purpose of 

this rule, an unpaved road is not a 

UNPAVED ROADS: Streets, alley 

ways, or roadways that are not 

covered by one of the following: 

concrete, asphaltic concrete, asphalt, 

or other similar materials specified 

by the U.S.EPA, CARB and/or the 

APCO. [ICAPCD Rule 800(C.44)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-25

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

horse trail, hiking path, bicycle path, 

or other similar path used exclusively 

for purposes other than travel by 

MOTOR VEHICLES.

PCCR 4-3-170(28). 

“WORK SITE”

"WORK SITE" as used in this 

Article, means any property upon 

which DUST GENERATING 

OPERATIONS occur during 

CONSTRUCTION, and which 

covers an area of 0.1 acres or larger.

a. TRENCHES that are equal 

to or larger than the following 

dimensions are considered WORK 

SITES and are subject to the 

requirement of this Article:

i. TRENCHES less than 

four feet in depth, that exceed a 

length of 726 feet;

ii. TRENCHES that are 

four feet or greater in depth, that 

exceed a length of 363 feet;

b. For calculations of 

DISTURBED SURFACE AREAS 

for land clearing or earthmoving 

activities, 25 feet will be added to 

each dimension of all structures, 

driveways, concrete pads, and other 

construction projects being built on 

the site to allow for an equipment 

utilization zone. If this final figure 

equals or exceeds 0.1 acres, a DUST 

GENERATING OPERATION 

application is required for the site.

CONSTRUCTION: Any on-site 

mechanical activities preparatory to 

or related to the building, alteration, 

rehabilitation, or demolition of an 

improvement on real property, 

including, but not limited to, land 

clearing, excavation related to 

construction, land leveling, grading, 

cut and fill grading, and the erection 

or demolition of any structure. As

used in Regulation VIII, a 

construction site may encompass 

several contiguous parcels, or may 

encompass only a portion of one 

parcel, depending on the relationship 

of the property boundaries to the 

actual construction activities. 

[ICAPCD Rule 800(C.13)]

All Persons who own or operate a 

Construction site of 10 acres or more 

in size for residential developments 

or 5 acres or more for non-residential

developments shall develop a dust 

control plan. The dust control plan 

shall be made available to the APCD 

upon request. The dust control plan 

shall comply with the requirements 

of Section F. [ICAPCD Rule 

This definition defines construction 

and earthmoving activities subject to

controls and establishes the size 

threshold for control strategies and 

permits. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-26

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

c. If the registrant identifies 

situations in which the amount of 

surface area for TRENCHES, land 

clearing or EARTHMOVING 

ACTIVITIES should be calculated 

differently, a case-by-case 

determination may be made.

801(E.1.c)]

Standards

PCCR 4-3-180(A). DUST 

GENERATING 

OPERATIONS 

Standards, Application, 

Permit and 

Recordkeeping 

Requirements

Requirements within WORKSITE 

(0.1 acre or larger) include:

- 20% opacity limit for dust on 

the property. (Test method 

per PCCR 4-9-340.) [4-3-

180(A)(1)]

- Stabilize any DISTURBED 

SURFACE AREA. [4-3-

180(A)(2)]

- Every other week inspections

by OWNER/OPERATOR to 

ensure that the WORK SITE 

is STABILIZED. [4-3-

180(A)(2)]

- Ensure all applicable 

CONTROL MEASURES 

[described in CONTROL 

MEASURE definition at 4-3-

170(4)], as specified in the 

permit, are implemented on 

DUST GENERATING 

OPERATIONs and 

DISTURBED SURFACE 

AREAs are STABILIZED.

[4-3-180(A)(2)]

Requirements for Construction sites 

and Earthmoving Activities include:

- 20% opacity limit [ICAPCD 

Rule 801(E.1.a) and (E.1.b)]

- Comply with the Best 

Available Control Measure 

(BACM) requirements of 

Section F.1 [ICAPCD Rule 

801(E.1.a) and (E.1.b)]

- Comply with conditions for 

Stabilized Surface when 

applicable. [ICAPCD Rule 

801(E.1.a) and (E.1.b)]

Both Pinal and Imperial County 

Rules include 20% opacity limit. 

Imperial County requires compliance 

with Best Available Control 

Measures for Fugitive Dust (PM-10) 

for Construction and Earthmoving 

Activities as specified in Section 

801(F.1) Subsections a through h. 

See Control Measure definitions 

under PCCR 4-3-170(4) for 

comparison to Pinal County RACM 

requirements.

Pinal County rule contains additional 

requirement for inspections by the 

Owner/Operator to ensure 

stabilization. Imperial County rule 

does not specify.

Imperial rule requires area meet 

Stabilized Surface conditions when 

applicable (temporary inactivity, high 

wind events, etc.). Pinal rule requires 

that DISTURBED SURFACE 

AREAs are STABILIZED at all 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-27

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

WORKSITES of 0.1 acres or greater. 

[PCCR 4-3-180(A)] 

PCCR 4-3-180(B). DUST 

GENERATING 

OPERATIONS 

Standards, Application, 

Permit and 

Recordkeeping 

Requirements

Where an OWNER/OPERATOR 

obtains a DUST GENERATING 

OPERATION permit for a

WORKSITE or combination of 

worksites 5 acres or larger; requires:

- Trackout Control Device. 

Installation of suitable 

TRACKOUT CONTROL 

DEVICE prior to start of 

DUST GENERATING 

OPERATIONs. [4-3-

180(B)(1)]

- Temporary Inactivity. 

For areas or portions of areas 

where DUST 

GENERATING 

OPERATIONS have ceased 

or will cease for more than 

30 days, erect signs or install 

physical barriers to limit 

trespass. [4-3-180(B)(2)]

- Wind Events/High Risk 

Days. 

Ensure WORK SITE is 

STABILIZED the day 

leading up to and the day that 

is forecast to be high risk for 

dust emissions, as noticed by 

the Pinal County Dust 

Control Forecast. Ensuring 

Trackout Control Device. 

Sites with access to a Paved Road 

and with 150 or more Average 

Vehicle Trips per Day, or 20 or more 

Average Vehicle Trips per Day by 

vehicles with three or more axles:

- Install one or more TrackOut Prevention Devices or 

control device or wash down 

system at access points with

Paved Roads; or

- Apply and maintain paving, 

Chemical Stabilizeation, or 

at least 3 inch depth of 

Gravel for a distance of 50 or 

more consecutive feet at 

access points. 

- Operation site that operates 

no more than 10 days within 

a 90 days period at each 

location is exempt. [ICAPCD 

Rule 803(F)]

Temporary Inactivity. 

Temporary Stabilization During 

Periods of Inactivity: 

- Restrict vehicular access to 

the area by fencing or 

signage; and 

- Apply water or Chemical 

Trackout Control Device.

In the Pinal County rule a 

TRACKOUT CONTROL DEVICE 

is required for all WORKSITES 5 

acres or larger. Imperial rule is 

dependant on vehicle type and 

Average Vehicle Trips per Day.

Temporary Inactivity.

Both Pinal and Imperial rules require 

access restriction; Pinal specifies 30 

days of inactivity (5 acres), Imperial 

does not specify. 

Imperial rule requires 0.5 acre areas 

unused for seven days or more to 

meet requirements for a Stabilized 

Surface area. Pinal rule requires that 

DISTURBED SURFACE AREAs 

are STABILIZED at all 

WORKSITES of 0.1 acres or greater. 

[PCCR 4-3-180(A)] 

Wind Events/High Risk Days.

Imperial County rule exempts area 

from 20% opacity limit when wind 

gusts exceed 25 mph provided that 

specified controls are implemented. 

Controls include watering once per 

hour, maintining 12% soil moisture, 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-28

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

the WORK SITE is 

STABILIZED includes a 

site-wide inspection to 

ensure either:

a. All applicable CONTROL 

MEASURES [as described in 

4-3-170.4] as specified in the 

permit, are implemented on 

DUST GENERATING 

OPERATIONs, and 

DISTURBED SURFACE 

AREAS are STABILIZED; 

or

b. All DUST GENERATING 

OPERATIONs are ceased 

and DISTURBED 

SURFACE AREAS are 

STABILIZED. [4-3-

180(B)(3)]

Stabilization. If an area 

having 0.5 acres or more of 

disturbed surface area 

remains unused for seven or 

more days, the area must

comply with the conditions 

for a Stabilized Surface area. 

[ICAPCD Rule 801(F.1.c)]

Wind Events/High Risk Days. 

When Wind Gusts exceed 25 miles 

per hour area is exempt from 20% 

opacity limit provided that at least 

one of the following is implemented 

for each applicable Fugitive Dust 

source type:

- Cease dust generating 

activities for a period of one 

hour after Wind Gusts last 

exceed the threshold. If 

operations cease for the 

remainder of the day, 

stabilization measures must 

be implemented.

- Apply water or dust 

Suppressants once per hour.

- Apply water to maintain 12% 

soil moisture content.

- Construct fences 3-5 feet 

high with 50% or less 

porosity, and must be done in 

conjunction with another 

measure, as above. 

ceasing activities for 1 hour after 

after last wind gust. 

Pinal rule requires the entire WORK 

SITE to be stabilized prior to (the day 

before) and during a high risk event 

(includes high wind and stagnation 

events). Rule provides choice to 

implement all control measures on 

DUST GENERATING 

OPERATIONS and DISTURBED 

SURFACE AREAS or stabilize and 

cease operations. If any operations 

continue, must maintain 

documentation that activity does not 

contribute to opacity violation. See 

also PCCR 4-3-190(B). 

Rule is reliant on the high risk 

forecast which provides more 

protection on high risk days when 

predicted winds may be below a 25 

mph threshold (Imperial’s 

threshhold). According to Arizona 

Revised Statutes (ARS) § 49-

424(11), when developing the 

forecast, the Department is required 

to evaluate –

(a) Projected meteorological 

conditions for the nonattainment 

area, including all of the following:

(i) Wind speed and direction.

(ii) Stagnation.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-29

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

[ICAPCD Rule 801(D.2)] (iii) Recent precipitation.

(iv) Potential for precipitation.

(b) Existing concentrations of air 

pollution at the time of the forecast.

(c) Historic air pollution 

concentrations that have been 

observed during meteorological 

conditions similar to those that are 

predicted to occur in the forecast.

Application (Permit)

PCCR 4-3-180(C). DUST 

GENERATING 

OPERATIONS 

Standards, Application, 

Permit and 

Recordkeeping 

Requirements

Prior to engaging in any DUST 

GENERATING OPERATIONS on a 

WORK SITE, the OWNER 

AND/OR OPERATOR shall file a 

DUST GENERATING 

OPERATION application form with 

the Control Officer, pay the 

appropriate fee in Appendix C, and 

receive a signed permit from the 

Control Officer.

All Persons who own or operate a 

Construction site of 10 acres or more 

in size for residential developments 

or 5 acres or more for non-residential 

developments shall develop a dust 

control plan. The dust control plan 

shall be made available to the APCD 

upon request. The dust control plan 

shall comply with the requirements 

of Section F. [ICAPCD Rule 

801(E.1.c)]

The owner or operator required to 

develop a dust control plan shall 

provide written notification to the 

APCD within 10 days prior to the 

commencement of any Construction 

activities via fax or mail. [ICAPCD 

Rule 801(E.1.d)]

South Coast Rule 403 requires 

additional Dust Control Measures for 

Pinal County rule requires an 

approved permit (and dust control 

plan) prior to commencing DUST 

GENERATING OPERATIONS on a 

WORK SITE. WORK SITE is 

defined as 0.1 acre or more. The 

approved permit requirement and 

relatively low size threshold improve 

the penetration and effectiveness of 

the Pinal County rule relative to other 

districts.

Not all districts require an approved 

permit. Imperial County rule 

requires the development of a dust 

control plan for construction of 

residential developments 10 acres or 

larger and for construction of nonresidential developments 5 acres or 

larger. Plan is made available to the 

Control District upon request. 

Explicit approval prior to activity is 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-30

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Large Operations (50 acres or larger). 

Requirements include submittal of a 

“Large Operation Notification” to the 

“Executive Officer,” documentation 

and recordkeeping. [SCAQMD Rule 

403(e)]

San Joachin rule requires submittal of 

a Dust Control Plan prior to the start 

of any construction activity on any 

site that will include 10 acres or more 

of disturbed surface area for 

residential developments, or 5 acres 

or more of disturbed surface area for 

non-residential development, or will 

include moving, depositing, or 

relocating more than 2,500 cubic 

yards per day of bulk materials on at 

least three days. Construction 

activities cannot commence until the 

Dust Control Plan has been 

approved. An owner/operator shall 

provide written notification to the 

APCO within 10 days prior to the 

commencement of earthmoving 

activities. [SJVAPCD Rule 

8021(6.3.1)]

Maricopa County prohibits operation 

of dust-generating operations of 0.10 

acre (4,356 square feet) or more 

without first obtaining a permit or 

permit revision from the Control 

not required. South Coast rules

require notification for operations 50 

acres or larger. Approval of a plan 

prior to activity is not required.

The size threshold in comparable 

districts that require an approved 

permit or plan is 5 or 10 acres 

compared to the Pinal County 0.1 

acre threshold. The San Joaquin rule 

requires submittal and approval of a 

Dust Control Plan prior to the start of 

construction activity on any site that 

will include 10 acres or more of 

disturbed surface area for residential 

developments, or 5 acres or more of 

disturbed surface area for nonresidential development
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-31

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Officer. [MC Rule 310]

PCCR 4-3-180(C)(1). 

DUST GENERATING 

OPERATIONS 

Standards, Application, 

Permit and 

Recordkeeping 

Requirements

DUST GENERATING 

OPERATIONS Application Form

requirements include:

- Separate application for 

noncontiguous areas.

- Subscribe to the Pinal 

County Dust Control 

Forecast as part of the permit 

application process.

- A plot plan with total area to 

be disturbed and indication 

of the sources of fugitive 

dust emissions.

- Explanation of how the 

applicant will demonstrate 

compliance by selection of at 

least one CONTROL 

MEASURE for each DUST 

GENERATING 

OPERATION.

Annual Area Block Application is 

available to political subdivisions,

Public Utility Corporations, and 

contractors or subcontractors for 

Political subdivisions or Public 

Utility Corporations for:

- Maintenance of existing 

underground or aboveground lines.

- Effecting end-user 

connections, including but 

Dust control plan requirements 

include:

- A plot plan with type and 

location of each project.

- Total area of land surface to 

be disturbed, estimated daily 

throughput volume of 

earthmoving in cubic yards, 

and total area in acres of the 

entire project site.

- Expected start and 

completion dates of dust 

generating and soil 

disturbance activities.

- The actual and potential 

sources of Fugitive Dust 

emissions and the location of 

Bulk Material handling and 

storage areas, Paved and 

Unpaved Roads, entrances 

and exits where Track 

Out/Carry Out may occur, 

and Unpaved Traffic Areas.

- Dust Suppressants to be 

applied, including: product 

specifications; 

manufacturer's usage 

instructions (method, 

frequency, and intensity of 

application); type, number, 

and capacity of application 

equipment; and information 

The information contained in the 

Pinal County permit application and 

the Imperial County dust control plan 

are generally consistent. 

Pinal rule includes provisions for an

Annual Area Block Application

(available to political subdivisions,

Public Utility Corporations, and 

contractors or subcontractors for 

Political subdivisions or Public 

Utility Corporations) for 

infrastructure projects.
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-32

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

not limited to water 

connections, sewer 

connections, natural gas 

connections, electrical power 

connections, and 

communication connections.

- Underground utility line 

extensions not exceeding 

500’ in length.

- Overhead utility line 

extensions.

- Expansion or extension of 

paved roads, UNPAVED 

ROADS, road shoulders, 

and/or alleys and public right 

of ways at non-contiguous 

sites.

Annual block application:

- The OWNER AND/OR 

OPERATOR may submit to 

the Control Officer one 

DUST GENERATING 

OPERATION application for 

more than one DUST 

GENERATING 

OPERATION at which 

CONSTRUCTION will 

commence within 12 months 

of permit issuance.

- Must include all the 

requirements listed for the 

DUST GENERATING 

on environmental impacts 

and approvals or 

certifications related to 

appropriate and safe use for 

ground application.

- Specific surface treatment(s) 

and/or control measures 

utilized to control Track 

Out/Carry Out, and 

sedimentation where 

unpaved and/or access points 

join paved public access 

roads.

- Description of Fugitive Dust 

control measures to be 

implemented before, during, 

and after any dust generating 

activity. [ICAPCD Rule 

801(F.2.c)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-33

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

OPERATIONS Application. 

[4-3-180(C)(1)(a) through 

(d)]

- Adhere to the requirements 

of all current permits issued 

to the WORK SITE.

- For any project not listed in 

the DUST GENERATING 

OPERATION Annual Block 

Application, the applicant 

must notify the Control 

Officer in writing at least 

three working days prior to 

commencing the DUST 

GENERATING 

OPERATION. Such 

notification must include the 

site location, size, and type 

of DUST GENERATING 

OPERATION, selected 

control measures, and start 

date.

Permit and Recordkeeping Requirements

PCCR 4-3-180(C)(2). 

DUST GENERATING 

OPERATIONS 

Standards, Application, 

Permit and 

Recordkeeping 

Requirements

The signed DUST GENERATING 

OPERATION permit from the 

control officer will contain the 

requirements set under §4-3-180 (A) 

and (B), and conditions regarding the 

necessary CONTROL MEASURES 

specific to the applicable project as 

proposed by the registrant.

Imperial County Rule recordkeeping 

requirements include:

- Retain a copy of the dust control 

plan at the project site. 

[ICAPCD Rule 801(F.2.a)]

- Comply with the requirements of 

the approved dust control plan. 

[ICAPCD Rule 801(F.2.b)]

- Compile and retain records that 

The Pinal County permit is valid for 

only one year and thereafter must be 

renewed. Special provisions are 

included for sites 5 acres or larger. 

Imperial County rule requires a dust 

control plan but no explicit permit 

approval or expiration date. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-34

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

The signature of the OWNER 

AND/OR OPERATOR on the DUST 

GENERATING OPERATION 

permit form constitutes agreement to 

accept responsibility for meeting the 

conditions of the permit and for 

ensuring the applicable CONTROL 

MEASURES are implemented 

throughout the WORK SITE, at all 

times that DUST GENERATING 

OPERATIONS are being performed 

and during the duration of the 

project. 

Recordkeeping requirements include:

- Maintain a copy of the signed 

permit and provide it upon 

request.

- Keep records of every other 

week inspections and site-wide 

inspection reports from the day 

leading up to and the day that is 

forecast to be high risk for dust 

emissions including any 

necessary corrective actions.

- Demonstration of compliance 

shall include inspections of the 

work site conducted pursuant 

to, and any actions taken to 

comply with, 4-3-180 sections 

(A)(2) and (B)(3) [inspection 

and stabilization requirements 

for high risk and non-high risk 

provide evidence of control 

measure application (i.e., 

receipts and/or purchase 

records). Describe, in the 

records, the type of treatment or 

control measure, extent of 

coverage, and date applied. For 

control measures which require 

multiple daily applications, 

recording the frequency of 

application will fulfill the 

recordkeeping requirements of 

this rule (i.e., water being 

applied three times a day and the 

date). [ICAPCD Rule 801(G)] 

- Records shall be maintained and 

be readily accessible for two 

years after the date of each entry 

and shall be provided to the 

APCD upon request. [ICAPCD 

Rule 801(G)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-35

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

days].

- Upon verbal or written request 

by the Control Officer, 

inspection records shall be 

provided no later than 72 

hours, excluding weekends. If 

the Control Officer is at the 

WORK SITE where the 

requested records are kept, the 

records shall be provided 

without delay. 

- Records of inspections or a 

summary report of the records 

of inspections shall be 

submitted within 30 days 

following the termination or 

expiration of the permit.

- Owners and/or Operators shall 

notify the Control Officer as

soon as practicable, but no later 

than 30 days, of the completion 

of the project.

- Notify Control Officer as soon 

as practicable, but no later than 

30 days, of the completion of 

the project.

Permit Renewal Requirements:.

- The first permit obtained for an 

affected project must cover a 

contiguous area (unless it is an 

"annual area block permit") and 

is valid for one year from the 
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-36

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

date of issue. 

- If the project has not been 

completed at the end of the 

one-year period, the permit 

must be renewed. 

- The OWNER AND/OR 

OPERATOR shall reapply for 

a DUST GENERATING 

OPERATION permit prior to 

the expiration date of the 

original permit. 

- Upon renewal, the new permit 

will be valid starting on the 

first calendar day after the 

completion of the initial one 

year period of the first permit 

and is valid for one year from 

that date. 

- Upon renewal, the total acreage 

covered by the DUST 

GENERATING OPERATION 

permit does not have to be 

contiguous, although all 

acreage covered by the 

renewed DUST 

GENERATING OPERATION 

permit must have been 

included in the original DUST 

GENERATING OPERATION 

permit. 

Requirements for sites five acres or 

larger:
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-37

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

- Erect a project information 

sign at the main entrance that 

is visible to the public or at 

each end of the ROAD 

CONSTRUCTION project 

site. 

- Sign shall be a minimum of 

24 inches tall by 30 inches 

wide, have a white 

background, and have the 

words "DUST CONTROL" 

shown in black block 

lettering which is at least 

four inches high. 

- Sign shall contain the 

following information; 

Project Name; Name and 

phone number of person(s) 

responsible for conducting 

project; Pinal County Air 

Quality Control District 

phone number.

Violations

PCCR 4-3-190. 

Violations

A. Failure by any person to comply 

with the applicable requirements of 

this Article shall constitute a 

violation.

B. Violation Exemptions:

If all records were maintained in 

accordance with 4-3-180 section 

(C)(2)(b), the provisions of section 4-

3-180 (A)(1) shall not apply to a 

Failure to comply with any 

provisions of this rule shall constitute 

a violation of Regulation VIII. 

[ICAPCD Rule 801(H)]

Wind Event. 20% opacity limit does 

not apply when Wind Gusts exceed 

25 miles per hour, provided that 

specified control measures are 

implemented. [ICAPCD Rule 

Imperial County provides exemption 

from requirement for 20% opacity 

when wind exceeds 25mph. Pinal 

County rule provides similar 

exemption from violation during

wind events provided all measures 

are implemented and the area is 

stabilized. See also PCCR 4-3-160 

and 180(B).
December 21, 2015 Final West Pinal PM10 RACM Analysis FII-38

Exhibit F-II: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites – Fugitive Dust, to Measures 

Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

WORK SITE during:

1. Wind conditions that cause 

FUGITIVE DUST to exceed the 

opacity requirements of 4-3-180 

(A)(1), if all CONTROL 

MEASURES as specified in the 

permit, are implemented, applied and 

maintained, all DISTURBED 

SURFACE AREAs are 

STABILIZED, and one of the 

following:

a. All DUST GENERATING 

OPERATIONs are ceased until the 

opacity requirements of 4-

30180(A)(1) no longer being 

exceeded; or

b. Maintain documentation that any 

DUST GENERATING 

OPERATIONs that are still being 

performed are not the cause of and do 

not contribute to the opacity 

violation. Documentation may 

include onsite opacity observations 

by a certified observer.

2. EMERGENCY maintenance of 

flood control channels and water 

retention basins if all CONTROL 

MEASURES, as specified in the 

permit are implemented, applied, and 

maintained.

801(D.2)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-1

Exhibit F-III – Agriculture Comparison

Comparison of Pinal County PM Nonattainment Area Agricultural Best Management Practices 

Rules (A.A.C. R18-2-610 & 610.03; A.A.C. R18-2-611 and 611.03; and A.A.C. R18-2-612 and 

612.01) to Measures Adopted in Other Areas
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-2

FIII-1 Crop Operations Overarching

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

Purpose

To reduce PM dust generation from 

commercial farming activities in West 

Pinal County.

To reduce the amount of PM-10 “generated from 

Agricultural Operation Sites” of forty acres or more.

. To limit fugitive dust from agricultural operation 

sites through use of Conservation Management 

Practice Plans.

(Rule 4550)

Farm Activity/ Source 

Definitions

“Commercial farmer” means an individual, 

entity, or joint operation in general 

control of a “Commercial farm.” 

“Commercial farm.” means 10 or more 

contiguous acres of land used for 

agricultural purposes within the boundary 

of the Maricopa PM nonattainment area 

and Maricopa County portion of Area A, or 

the Pinal County PM Nonattainment Area.

meaning 10 or more contiguous acres of 

land used for agricultural purposes within 

the boundary of the Maricopa PM 

nonattainment area and Maricopa County 

portion of Area A, or the Pinal County PM 

Nonattainment Area.

“Commercial farm road” means a road that 

is unpaved, owned by a commercial 

farmer, and is used exclusively to service a 

commercial farm.

“Tillage” means any mechanical practice 

that physically disturbs the soil, and 

includes preparation for planting, such as 

plowing, ripping, or discing. 

“Cropland” means land on a commercial 

farm that:

a.Is within the time-frame of final harvest to 

plant emergence, but does not include 

tillage activities;

b.Has been tilled in a prior year and is 

suitable for crop production, but is 

currently fallow; or

c. Is a turn-row.

“Ground operation” means an agricultural 

AGRICULTURAL OPERATIONS: The growing and harvesting of 

crops for the primary purpose of earning a living. 

AGRICULTURAL OPERATION SITE: One or more agricultural 

parcels that meet the following: 

a Are under the same or common ownership or operation, 

or which are owned or operated by entities which are 

under common control; and 

b Are located on one or more contiguous or adjacent 

properties wholly within Imperial County. 

AGRICULTURAL PARCEL: A portion of real property used by 

an owner or operator for carrying out a specific 

agricultural operation. Roads, vehicle/equipment traffic 

areas, and facilities, on or adjacent to the cropland are 

part of the agricultural parcel

(The rule only applies to Agricultural Operation Site of forty 

(40) acres or more in size)

“Agricultural operation site” is one or more 

agriculture parcels that are both under the same 

or common ownership or operation or common 

control and are located on one or more 

contiguous or adjacent properties wholly within 

the San Joaquin Valley Air Basin 

Agricultural Operations: the growing and harvesting 

of crops or the raising of fowl or animals, for the 

primary purpose of earning a living, or of 

conducting agricultural research or instruction by 

an educational institution.

Agricultural Parcel: a portion of real property, 

including, but not limited to, cropland, and 

animal feeding operation (AFO) used by an 

owner/operator for carrying out a specific 

agricultural operation. Roads, vehicle/equipment 

traffic areas, and facilities, on or adjacent to the 

cropland or AFO are part of the

agricultural parcel.

(This rule only applies to Agricultural operations 

sites where total acerage of all parcels is 100 

acres or more or parcels above 3000 or more feet 

above sea level)
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-3

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

operation that is not a tillage operation, 

which involves equipment passing across 

the field. A ground operation includes 

harvest activities. A pass through the field 

may be a subset of a ground operation.

“Harvest” means the time after planting up 

through harvest, including gathering 

mature crops from a commercial farm, as 

well as all actions taken immediately after 

crop removal, such as cooling, sorting, 

cleaning, and packing.

“Noncropland” means any commercial farm 

land that:

a.Is no longer used for agricultural 

production;

b.Is no longer suitable for production of 

crops;

c. Is subject to a restrictive easement or 

contract that prohibits use for the 

production of crops; or

d.Includes a ditch, ditch bank, equipment 

yard, storage yard, or well head.

“Commercial farm road” means a road that 

is unpaved, owned by a commercial 

farmer, and is used exclusively to service a 

commercial farm.

Basic Program Structure

Commercial farmer must complete a 

(feeless) agricultural PM permit record 

form (essentially a general permit) 

demonstrating compliance with the 

applicable rules. 

A commercial farmer must (1) choose a BMP 

to implement for Significant Agricultural 

Earth Moving Activities, (2) must 

implement at least one BMP from each 

applicable BMP lists for the categorical 

activity or source of emissions (e.g. tillage 

or commercial farm roads), unless

exemptions apply, and (3) apply a BMP for 

high risk dust control forecast days, unless 

an exemption applies. 

“Dust Control Forecast” 

means a forecast, 

which shall identify a 

low, moderate 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. 

When developing 

these forecasts, the 

department shall 

consider all of the 

following:

a)Projected 

meteorological 

Reduce PM by requiring Agricultural Operation Site of forty 

(40) acres or more in size to implement practices in each 

Agricultural parcel at least one Conservation Management 

Practice from each of the following to prevent, reduce, or 

mitigate PM-10. 

D.1.a Land preparation and cultivation, CMPs in Section E.1; 

*

D.1.b Harvest activities, CMPs in section E.2; *

D.1.c Unpaved Roads, CMPs in Section E.3; 

D.1.d Unpaved Traffic Areas, CMPs in Section E.4; 

D.1.e Cropland-Other, CMPs in Section E.5; and *

An owner/operator shall prepare and submit a CMP 

Application for each agricultural operation site, 

pursuant to Section 6.0, to the APCO for 

approval.

A CMP Application approved by the APCO shall 

constitute a CMP Plan.

An owner/operator shall implement the applicable 

selected CMPs for each agricultural operation 

site.

Owner/operator shall submit a CMP application if 

any operational, administrative or other 

modification necessitates a revision of the CMP 

Plan.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-4

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

The commercial farmer will submit a survey 

every three years to update logistical 

information and BMP choices.

Records of any changes to the Best 

Management Practices shall be noted on 

the Best Management Practices Program 

General Permit Record Form and shall be 

kept by the commercial farmer onsite and 

made available for review by the Director 

within two business days of notice to the 

commercial farmer.

The commercial farmer will maintain records 

demonstrating compliance with permit 

record form.

conditions, including:

i) Wind speed and 

direction,

ii) Stagnation,

iii) Recent precipitation, 

and

iv) Potential for 

precipitation;

b) Existing 

concentrations of air 

pollution at the time 

of the forecast; and

c) Historic air pollution 

concentrations that 

have been observed 

during meteorological 

conditions similar to 

those that are 

predicted to occur in 

the forecast.

NOTE: Arizona may 

have a high risk 

forecast day with very 

low wind speeds, far 

below what other 

states may consider 

high wind speeds, but 

existing 

concentrations or arid 

conditions may call 

for a high risk forecast 

nonetheless.

D.1.f Windblown Dust Control, CMPs in Section E.6. 

* see exceptions below.

Persons may choose the same CMP for D.1.c and D.1.d since 

they apply to different land, but must choose a unique and 

individual CMP for each of D.1.a, D.1.b, D.1.e and D.1.f 

(unless using Conservation Tillage CMP) since they apply to 

the same land. 

Agricultural unpaved roads and unpaved equipment or 

traffic areas with certain thresholds of vehicle daily trips 

must meet respective specific stabilization and opacity 

requirements.

To Implement the CMPs, the owner or operator shall 

prepare a CMP Plan for each Agricultural Operation Site.

The plan, along with records supporting implementation and 

technical evaluations for alternative CMPs 

 

Overarching BMPs for all 

commercial farmers

When conducting “Significant Agricultural 

Earth Moving Activities” a commercial 

farmer shall implement at least one of the 

following BMPs:

a.Apply water prior to such activities and/or 

time conducting such activities to coincide 

with precipitation. Soil must have a 

minimum soil moisture content of 50% of 

field capacity. Compliance shall be 

determined by NRCS Estimating Soil 

Moisture by Feel and Appearance Method, 

“Significant Agricultural 

Earth Moving 

Activities” means 

either leveling 

activities conducted 

on a commercial farm 

that disturb the soil 

more than 4 inches 

below the surface, or 

the creation, 

maintenance and 

See above. n/a
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-5

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

amended through April 1998 (and no 

future editions);

b.Apply water during Significant Agricultural 

Earth Moving Activities. Soil must have a 

minimum soil moisture content of 30% of 

field capacity. Compliance shall be 

determined by NRCS Estimating Soil 

Moisture by Feel and Appearance Method, 

amended through April 1998 (and no 

future editions);

c. Limit activities on a high risk forecast day 

for PM; or

d.Conduct such activities in a manner to 

reduce a minimum of one ground 

operation across a commercial farm by 

using equipment that is the most efficient 

means of moving the soil.

relocation of: ditches, 

canals, ponds, 

irrigation lines, 

tailwater recovery 

systems (agricultural 

sumps) and other 

water conveyances, 

not to include 

activities performed 

on cropland for 

tillage, ground 

operations or harvest.

“Ground operation” 

definition is above in 

farm activity 

definitions.

Categorical BMP 

Exceptions/Exemptions

If, for the tillage category, a commercial 

farmer implements the Conservation 

tillage or Reduced tillage system best 

management practice, the farmer does 

not have to implement a best 

management practice for either “Ground 

Operations and Harvest” or “Cropland.”

Also,

A person may develop different BMPs from 

those listed in the rule and may submit 

such practices that are prove4n effective 

through on-farm demonstration trials to 

the [Agricultural Best Management 

Practices] Committee...[but] the newly 

developed BMPs are not effective unless 

submitted as described in A.R.S. §49-

457(L) which states:

L. The committee may periodically 

reexamine, evaluate and modify best 

management practices. Any approved 

modifications shall be submitted to the 

United States environmental protection 

agency as a revision to the applicable 

implementation plan.

Persons who own or operate an Agricultural Operation Site 

of 40 acres or more shall choose at least one of the 

Conservation Management Practices from each of D.1.a 

through D.1.f. unless they implement the Conservation 

Tillage CMP. On acres implementing the Conservation 

Tillage CMP, persons do not need to select additional 

measures for D.1.a, D.1.b or D.1.e, (land prep and 

cultivation, harvest, or cropland categories)but do need to 

implement at least one CMP each from D.1.c, D.1.d and 

D.1.f (unpaved roads, unpaved traffic areas, and 

windblown dust control)

Also,

The owner or operator of an Agricultural Operation Site may 

develop alternative CMPs. The owner or operator shall 

submit to the APCD a technical evaluation of the 

alternative CMPs, demonstrating that the alternative CMP 

achieves PM-10 emission reductions that are at least 

equivalent to the most effective CMPs available for the 

applicable operation (e.g., by eliminated equivalent passes 

or operations). The APCD will review the technical 

evaluation, and the alternative CMP must receive approval 

by the APCD before being included in the CMP Plan.

CONSERVATION 

TILLAGE (e.g.: no 

tillage, minimum 

tillage): A tillage 

system that reduces 

a minimum of three 

tillage operations. 

This system reduces 

soil and water loss 

by reducing the 

number of passes 

and by leaving crop 

residue on the field 

after harvest as well 

as managing the 

residue so that it 

remains intact 

during the planting 

season. It reduces 

the number of 

passes and amount 

of soil disturbance. 

It improves soil 

because it retains 

plant residue and 

increases organic 

Exemptions:

The provisions of this rule, except for the 

recordkeeping provisions of Section 6.5.2, shall 

not apply to any of the following sources:

4.1.1 Agricultural operation site where the total 

acreage of all agricultural parcels is less than 100 

acres excluding the AFO and exempted lands 

pursuant to Section 4.1.2 thru Section 4.1.5.

4.1.2 Woodland and wasteland not actually under 

cultivation or used for pasture.

4.1.3 Land placed in the Conservation Reserve 

Program meeting the definition and criteria set by 

the NRCS.

4.1.4 Agricultural parcel that are 3000 feet or more 

above mean sea level.

4.1.5 Agricultural operation parcel used for the 

purpose of:

4.1.5.1 Propagating young trees, shrubs, and other 

miscellaneous crops for transplanting, and 

exhibiting plants under controlled

conditions inside a building with walls and roof, or
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-6

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

matter. 4.1.5.2 Providing grazing rangeland or pasture, or

4.1.5.3 Forestry, including but not limited to timber 

harvest operations, silvicultural practices, forest 

management burning, or forest protection 

practices.

Exceptions:

An owner/operator shall select one (1) CMP from 

the list for each category for each agricultural 

parcel, except::

6.2.1 If an agricultural operation site or agricultural 

parcel has crop rotation, an owner/operator shall 

select one (1) CMP from the CMP list for each of 

the applicable CMP categories for each rotated 

crop type.

6.2.2 If a CMP can only be selected for 

implementation on a portion of an agricultural 

operation site, an owner/operator shall select an 

additional CMP within the CMP category to be 

implemented on the remaining acreage or 

remaining AFO.

6.2.3 An owner/operator may select a substitute 

CMP from another CMP category when no 

feasible CMP can be identified from one category. 

This provision shall not apply for the unpaved 

road, and unpaved vehicle/equipment traffic area 

CMP categories.

6.2.3.1 An owner/operator may identify or develop 

a new CMP not on the CMP list to be used to 

comply with the requirements of this rule. Prior 

to use of the new CMP the owner/operator must 

obtain the interim approval of the APCO to use a 

new CMP to meet the requirements of Section 

6.2. The owner/operator shall demonstrate that 

the new CMP achieves PM10 emission reductions 

that are at least equivalent to other CMPs on the 

CMP list that could be selected for the applicable 

operation.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-7

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

6.2.3.2 The APCO will perform an independent 

analysis of proposed CMPs to determine that 

they achieve PM10 emission reductions that are 

at least equivalent to other CMPs on the CMP 

list....This analysis shall be made using the most 

recent emission factors provided by EPA or CARB 

when available...

6.2.3.3 An owner/operator may satisfy the 

requirements of Rule 8081 by implementing 

CMPs for the unpaved road and unpaved 

vehicle/equipment traffic area CMP categories 

that are equivalent to the control measures 

specified in Rule 8081.

(Rule 4550)

BMP General Permit Record 

Form

Beginning December of 2015, a commercial 

farmer who engages in a regulated activity 

shall complete a Best Management 

Practices Program General Permit Record 

Form every year. The form shall include 

the following information:

1.The name of the commercial farmer, 

signature, and date signed;

2.The mailing address or physical address of 

the commercial farm; and

3.The best management practices selected 

for tillage, ground operations and harvest, 

cropland, noncropland, commercial farm 

roads, and significant earth moving 

activities (if applicable); and

4.Any additional best management practices 

selected for high risk days as predicted by 

the Pinal County Dust Control Forecast.

Records of any changes to the Best 

Management Practices shall be noted on 

the Best Management Practices Program 

General Permit Record Form and shall be 

kept by the commercial farmer onsite and 

made available for review by the Director 

within two business days of notice to the 

commercial farmer.

The owner or operator shall prepare a CMP Plan for each 

Agricultural Operation Site. The CMP Plan shall be made 

available to the APCD upon request. The CMP Plan shall be 

provided to the APCD within 72 hours of notice to the 

owner or operator. 

Each CMP Plan shall include, but is not limited to, the 

following information: 

F.1 The name, business address, and telephone number of 

the owner or operator responsible for the preparation and 

implementation of the CMP Plan. 

F.2 The signature of the owner or operator and the date that 

the CPM Plan was signed. 

F.3 The location of the Agricultural Operation Site: cross 

roads; canal and gate number. 

F.4 The crop grown at each location covered by the CMP 

Plan, total acreage for each crop, the length (miles) of 

unpaved roads, and the total area (acres or square feet) of 

the unpaved equipment and traffic areas to be covered by 

the CMP Plan 

F.5 The CMPs being implemented for each crop, unpaved 

road, unpaved equipment and traffic area, and windblown 

dust control. The CMPs implemented should be described 

An owner/operator shall prepare and submit a CMP 

Application for each agricultural operation site, 

pursuant to Section 6.0, to the APCO for 

approval.

A CMP Application approved by the APCO shall 

constitute a CMP Plan.

Owner/operator shall keep records of CMP 

implementation and a permit application copy.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-8

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

to verify that implementation is consistent with the CMP 

definitions in this rule. 

F.6 Other relevant information as determined by the APCD. 

BMP Survey

(A.A.C. R18-2-

611.03(D)(1)(a)-(m))

Beginning in 2017 and at least every three 

years thereafter, the commercial farmer 

shall complete a Best Management 

Practices Program 3-year Survey with data 

from the preceding calendar year. The 

survey will include the following 

information:

1.The name, business address, and phone 

number of the commercial farmer 

responsible for the preparation and 

implementation of the best management 

practices;

2.The signature of the commercial farmer 

and the date the form was signed; 

3.The acreage of each crop type 

planted/growing during the calendar year 

that the survey is conducted;

4.The total miles of commercial farm roads 

at the commercial farm;

5.The total acreage of the noncropland at 

the commercial farm; 

6.The best management practices selected 

for tillage, ground operations and harvest, 

cropland, noncropland, commercial farm 

roads, and significant earth moving 

activities (if applicable); and

7.Any additional best management practices 

selected for high risk days as predicted by 

the Pinal County Dust Control Forecast.

Only CMP plan. A CMP Application approved by the APCO shall 

constitute a CMP Plan.

Within 60 days of any operational, administrative, 

or other modification that necessitates the 

revision of the CMP Plan. A modification includes, 

but is not limited to, the following:

6.3.4.1 Administrative changes to any information 

provided pursuant to Section 6.0,

6.3.4.2 Implementation of a CMP other than the 

CMP listed in a CMP Plan,

6.3.4.3 Change of the crop or AFO on a agricultural 

parcel, and

6.3.4.4 Any other changes as determined by the 

APCO.

Maintaining Records & 

Compliance

A commercial farmer shall maintain records 

demonstrating compliance with the 

applicable rules for three years.

Records of any changes to the Best 

Management Practices shall be noted on 

the Best Management Practices Program 

General Permit Record Form and shall be 

Violations - Failure to comply with any provisions of this rule 

shall constitute a violation of Regulation VIII. Failure to 

comply with the provisions of a CMP Plan shall also 

constitute a violation of Regulation VIII. 

Record of Control Implementation - Any Person subject to 

the requirements of this rule shall maintain a copy of the 

6.5.1. An owner/operator subject to Section 5.0 

shall maintain the following

records for a minimum of five (5) years:

6.5.1.1 A copy of each CMP Application and CMP 

Plan.

6.5.1.2 Supporting information necessary
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-9

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Overarching Program Elements/Requirements

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550)

kept by the commercial farmer onsite and 

made available for review by the Director 

within two business days of notice to the 

commercial farmer.

ADEQ shall document noncompliance with 

the applicable rules before issuing a 

compliance orders. 

A commercial farmer who is not in 

compliance with the applicable rules is 

subject to the provisions in A.R.S. § 49-

457(I), (J), and (K)

CMP Plan and any supporting documentation necessary to 

confirm implementation of the CMPs. 

The owner or operator shall prepare a CMP Plan for each 

Agricultural Operation Site. The CMP Plan shall be made 

available to the APCD upon request. The CMP Plan shall be 

provided to the APCD within 72 hours of notice to the 

owner or operator.

An owner or operator implementing alterative CMPs shall 

maintain a copy of technical evaluation for alternative 

CMPs and documentation of APCD approval of alternative 

CMPs. 

Records shall be maintained for two years after the date of 

each entry and shall be provided to the APCD upon 

request.

6.5.2 An owner/operator claiming exemption 

pursuant to Section 4.0 (agricultural operations 

listed in the BMP section above)) shall maintain 

records for a minimum of five (5) years that 

demonstrate that the agricultural operation site 

or agricultural parcel qualified for the exemption.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-10

FIII-2 Tillage

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Tillage Farm Practice Category

Overarching Program 

Element/Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/Explana

tory Definitions 

re: Imperial

San Joaquin

(Rule 4550 CMP List)

BMPs

A commercial farmer shall implement at least 

one of the following: 

 Combining tractor operations,

 Equipment modification,

 Multi-year crop,

 Cessation of night tilling,

 Planting based on soil moisture,

 Precision farming,

 Tillage based on soil moisture,

 Timing of a tillage operation,

 Transgenic crops, 

 Transplanting, 

 Reduced tillage system, or*

 Conservation tillage.*

*See exceptions in the overarching program 

elements section

Combining Tractor 

Operations has basically 

the same definitions as 

Imperial’s combined 

operations definitions. 

However, if Equipment 

modification is also 

chosen as a BMP, and 

uses the same practices 

as in Combining Tractor 

Operations BMP, this 

action is considered one 

BMP.

Equipment modification" 

means reducing PM10

emissions and soil 

erosion during tillage or 

ground operations by 

modifying and 

maintaining an existing 

piece of agricultural 

equipment, installing 

shielding equipment, 

modifying land planting 

and land leveling, 

matching the equipment 

to row spacing, or 

grafting to new varieties 

or technological 

improvements. If 

combining tractor 

operations is also chosen 

as a BMP, and uses the 

same practices as 

described in this BMP, 

this action is considered 

one BMP.

ADEQ’s compliance section 

will be ensuring that if a 

farmer is tilling a multiyear crop one year, then 

The owner or operator of an Agricultural Operation Site 

shall implement at least one of the following CMPs in 

each Agricultural Parcel to reduce PM10 emissions from 

land preparation and cultivation (CMP Category D.1.a). If 

the owner or operator selects “Fallow Land” as its CMP, 

the owner/operator must comply with section E.6 of this 

rule. 

E.1.a Alternative Tilling, 

E.1.b Bed/Row Size Spacing, 

E.1.c Chemigation/Fertigation, 

E.1.d Combined Operations, 

E.1.e Conservation Irrigation, 

E.1.f Cover Crops, 

E.1.g Equipment Changes/Technological Improvements, 

E.1.h Fallow Land, 

E.1.i Integrated Pest Control, 

E.1.j Mulching, 

E.1.k Night Farming, 

E.1.l Non Tillage /Chemical Tillage, 

E.1.m Organic Pesticides, 

E.1.n Precision Farming (GPS), or 

E.1.o Transgenic Crops 

Alternate Till - Rotate tillage leaving residue on 

Soil

Bed-row size or spacing- Increase or decrease the 

size of the planting area bed (can be done for 

field and permanent crops)

Chemigation/Fertigation- Application of 

chemicals thru an irrigation system

Combined operations- To combine equipment, to 

perform several operations during one pass

Conservation irrigation- To conserve the quantity 

of water use, e.g.: drip, sprinkler, 

buried/underground line

Conservation tillage (e.g.:no tillage, minimum 

tillage)- Types of tillage that reduce loss of soil 

and water in comparison to conventional tillage

Cover crops- Use seeding or natural 

vegetation/regrowth of plants to cover soil

surface

Equipment changes/Technological 

improvements- To modify the equipment such 

as combines, cotton pickers, tilling and 

harvesting equipment, increase equipment size, 

modify land planing and land leveling, matching 

the equipment to row spacing, grafting to new 

varieties or technological improvements

Fallowing land - temporary or permanent removal 

from production. (e.g.: vineyard pullout, Raisin 

Industry Diversion program, wildlife/wetlands 

conservation program)

Floor management - Smoothing and flattening the 

soil surface after nut harvest to remove postharvest residue; maintain clean, smooth, firm 

floor throughout season by elimination of 

disking

Integrated Pest Management - A decision process 

which uses a combination of techniques 

including organic, conventional, biological 

farming practices to suppress pests problems 

Mulching - Applying or leaving plant residue or 

other material to soil surface 

Night farming- Operate at night where practical 

when moisture levels are higher and winds are 

lighter 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-11

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Tillage Farm Practice Category

Overarching Program 

Element/Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/Explana

tory Definitions 

re: Imperial

San Joaquin

(Rule 4550 CMP List)

they must implement a 

tillage bmp, the farmer 

must be actually 

complying with the rule. 

It is common sense that 

if farmer is tilling a multiyear crop, he/she is 

conducting a dust 

generating activity that 

falls under the tilling 

category. One can only 

claim a multi-year crop 

as a BMP if he/she is not 

tilling. 

Non tillage / Chemical Tillage - Use flail mower, 

low volume sprayers, use heat delivery system ( 

as harvest preconditioner) 

Organic Practices - Use biological control 

methods, use non-chemical control methods 

Precision farming (GPS) - e.g.: GPS, using satellite 

navigation to calculate position in the field, 

therefore manage/treat selective area 

Time of planting - To modify the time of planting 

Transgenic crops - Use of GMO or Transgenic 

crops Transplanting - Planting plants already in 

a growth state 

Additional Requirements for 

High Risk Forecast Days

Unless choosing “limited tillage activity”, a 

commercial farmer shall ensure 

implementation of at least one of the 

following on the day before and during a 

high risk forecast day: 

 Multi-year crop, 

 Planting based on soil moisture, 

 Tillage based on soil moisture, 

 Reduced tillage system, or 

 Conservation tillage.

Need definitions here 

"Limited tillage activity " 

means performing no 

tillage operations on a 

day identified by the 

Maricopa or Pinal County 

Dust Control Forecast to 

be high risk for dust 

generation. Note that 

“limited tillage activity” is 

only implemented the 

day of a high risk 

forecast.

For windblown dust control (CMP Category D.1.f), the 

owner or operator of an agricultural operation site shall 

implement E.6.1. In addition to following E.6.1, if the 

owner or operator of an Agricultural Operation Site 

has fields that are in between crops or more permanently 

fallow, the owner or operator shall implement at least 

one of the CMPs in E.6.2. 

E.6.1 When preparing a field for planting, minimize the 

time that newly tilled soil is smooth and dry by leaving 

the field surface with large clods for as long as possible 

and bedding and planting the field as soon as possible 

once it no longer has large clods.

E.6.2 For fields that are in between crops or are 

permanently fallow, the owner shall implement at least 

one of the CMPs below: 

E.6.2a Cover Crop 

E.6.2b Conservation Tillage 

E.6.2c Crop Residue Management 

E.6.2d Cross Wind Stripcropping 

E.6.2e Field Windbreaks 

E.6.2f Ridge Roughness 

E.6.2g Surface Roughening 

E.6.2h Wind Barrier 

Imperial does not 

have a similar 

high wind forecast 

day. 

n/a
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-12

FIII-3 Ground Operations and Harvest

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Ground Operations and Harvest

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

BMPs

A commercial farmer shall implement at least 

one of the following: 

 Combining tractor operations, 

 Equipment modification, 

 Chemical irrigation, 

 Green chop, 

 Integrated pest management, 

 Multi-year crop, 

 Precision farming, 

 Reduced harvest activity, 

 Transgenic crops, or 

 Shuttle System/Larger Carrier.

(NOTE that none of the 

BMPs for Ground 

Operations and Harvest 

are required if the farmer 

implements conservation 

or reduced tillage for the 

tillage category—see 

exceptions in the 

overarching program 

elements section. )

The owner or operator of an Agricultural Operation Site 

shall implement at least one of the following CMPs in 

each Agricultural Parcel to reduce PM10 emissions 

from harvest activities (CMP Category D.1.b). If the 

owner or operator selects “Fallow Land” as its CMP, the 

owner/operator must comply with Section E.6 of this 

rule. 

E.2.a Baling /Large Bales 

E.2.b Combined Operations 

E.2.c Equipment Changes/Technological Improvements 

E.2.d Green Chop 

E.2.e Hand Harvesting 

E.2.f Fallow Land 

E.2.g Night Harvesting 

E.2.h No Burning 

E.2.i Pre-Harvesting Soil Preparation 

E.2.j Shed Packing 

E.2.k Shuttle System/Large Carrier 

The owner or operator of an Agricultural Operation Site 

shall implement at least one of the following CMPs in 

each Agricultural Parcel to reduce PM10 emissions 

from cropland-others (Category D.1.e). 

If the owner or operator selects “Fallow Land” as its CMP, 

the owner/operator must comply with Section E.6 of 

this rule. 

E.5.a Alternate Tilling 

E.5.b Application Efficiencies 

E.5.c Bailing/Large Bales 

E.5.d Bulk Materials Control 

E.5.e Chemigation/Fertigation 

E.5.f Conservation Irrigation 

E.5.g Fallow Land E.5.h Grinding/Chipping/Shredding 

E.5.i Integrated Pest Management 

E.5.j Irrigation Power Units 

E.5.k Mulching 

E.5.l Night Farming 

E.5.m No Burning 

E.5.n Non Tillage/Chemical Tillage 

Baling/Large Balers - Using balers to harvest crop 

Combined operations - To combine equipment, 

performing several operations during one pass 

Continuous tray/D.O.V., New drying techniques 

for dried fruit - Any technology to reduce labor 

and tillage 

Equipment changes/Technological improvements 

- To modify the equipment such as combines, 

cotton pickers, tilling and harvesting equipment, 

increase equipment size, modify land planing 

and land leveling, matching the equipment to 

row spacing, and technological improvements 

Fallowing land - temporary or permanent removal 

from production. (e.g.: vineyard pullout, Raisin 

Industry Diversion program, wildlife/wetlands 

conservation program)

Floor management - Smoothing and flattening the 

soil surface after nut harvest to remove postharvest residue; maintain clean, smooth, firm 

floor throughout season by elimination of 

disking 

Green Chop - The harvesting of a forage crop 

without allowing it to dry in the field. 

Hand harvesting - Harvesting crop by hand 

Night Harvesting - Implementing cultural practices 

at night, or at times of high humidity. 

No burning - Switching to a crop/system that 

would not require waste burning 

Pre-Harvest soil preparation - Applying a light 

amount of water or stabilizing material to soil 

prior to harvest ( when possible) 

Shed Packing - Packing commodities in a covered 

or closed area 

Shuttle system/larger carrier - multiple bin/trailer 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-13

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Ground Operations and Harvest

Overarching Program 

Element/ Requirement West Pinal County

Comments/Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

E.5.o Organic Practices 

E.5.p Permanent Crops 

E.5.q Reduced Pruning 

E.5.r Soil Amendments 

E.5.s Soil Incorporation 

E.5.t Sulfur: Reduction or Elimination of Dusting 

E.5.u Surface Roughening 

E.5.v Transgenic Crops 

E.5.w Wind Barrier 

Additional Requirements for 

High Risk Forecast Days

Unless choosing “limited harvest activity”, a 

commercial farmer shall ensure 

implementation of at least one of the 

following on the day before and during a 

high risk forecast day: 

 Green chop, 

 Integrated pest management, 

 Multi-year crop

(note that none of the 

BMPs are required for 

Ground Operations and 

Harvest if the farmer 

implements conservation 

or reduced tillage for the 

tillage category—see 

exceptions in the 

overarching program 

elements section) 

"Limited harvest activity 

" means performing no 

ground operations on a 

high risk forecast day. 

Note that “limited 

harvest activity” is only 

implemented the day of 

a high risk forecast.

For windblown dust control (CMP Category D.1.f), the 

owner or operator of an agricultural operation site shall 

implement E.6.1. In addition to following E.6.1, if the 

owner or operator of an Agricultural Operation Site 

has fields that are in between crops or more permanently 

fallow, the owner or operator shall implement at least 

one of the CMPs in E.6.2. 

E.6.1 When preparing a field for planting, minimize the 

time that newly tilled soil is smooth and dry by leaving 

the field surface with large clods for as long as possible 

and bedding and planting the field as soon as possible 

once it no longer has large clods. 

E.6.2 For fields that are in between crops or are 

permanently fallow, the owner shall implement at least 

one of the CMPs below: 

E.6.2a Cover Crop 

E.6.2b Conservation Tillage 

E.6.2c Crop Residue Management 

E.6.2d Cross Wind Stripcropping 

E.6.2e Field Windbreaks 

E.6.2f Ridge Roughness 

E.6.2g Surface Roughening 

E.6.2h Wind Barrier 

Imperial has no 

similar forecast.

No such forecast.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-14

FIII-4 Noncropland

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Noncropland

Overarching Program 

Element/ Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

BMPs

A commercial farmer shall implement at least 

one of the following best management 

practices: 

 Access restriction, 

 Aggregate cover, 

 Wind barrier, 

 Critical area planting, 

 Organic material cover, 

 Reduce vehicle speed, 

 Synthetic particulate suppressant, or 

Watering. 

In addition to following E.6.1, if the owner or operator of an 

Agricultural Operation Site has fields that are in between 

crops or more permanently fallow, the owner or operator 

shall implement at least one of the CMPs in E.6.2. 

E.6.1 When preparing a field for planting, minimize the time 

that newly tilled soil is smooth and dry by leaving the field 

surface with large clods for as long as possible and 

bedding and planting the field as soon as possible once it 

no longer has large clods. 

E.6.2 For fields that are in between crops or are permanently 

fallow, the owner shall implement at least one of the 

CMPs below: 

E.6.2a Cover Crop 

E.6.2b Conservation Tillage 

E.6.2c Crop Residue Management 

E.6.2d Cross Wind Stripcropping 

E.6.2e Field Windbreaks 

E.6.2f Ridge Roughness 

E.6.2g Surface Roughening 

E.6.2h Wind Barrier 

Agricultural unpaved equipment or traffic areas with fifty 

(50) or more VDT, or twenty (20) or more VDT with 3 or 

more axle vehicles, must meet the stabilization and 

opacity requirements in Section E.4. 

The owner or operator of an agricultural operation site shall 

implement at least one of the following CMPs for each 

unpaved traffic area (CMP Category D.1.d) to reduce PM10 

emissions at all times: 

E.4.a Chips/Mulches, Organic Materials, Polymers, Road Oil 

and Sand, 

E.4.b Gravel 

E.4.c Paving 

E.4.d Restricted Access 

E.4.e Speed Limit 

E.4.f Track-Out Control 

E.4.g Water Application 

E.4.h Field windbreak 

Arizona’s includes 

currently fallow 

land in its 

cropland 

definition, 

whereas Imperial 

has BMPs for 

temporarily and 

permanently 

fallow in its 

noncropland 

definition. Fallow 

land BMPs are 

repeated below 

under the 

cropland category, 

as well. 

Chips / Mulches, 

Organic Materials, 

Polymers, 

Road oil

Sand

Gravel - Placing a layer of gravel with enough 

depth to minimize dust generated from 

vehicle movement and to dislodge any excess 

debris which can become entrained

Paving- To pave currently unpaved areas

Restricted Access - To restrict public access to 

private roads

Speed Limits-Enforcement of speeds that 

reduce visible dust emissions

Track out control-Minimize any and all material 

that adheres to and agglomerates on all 

vehicles and equipment from unpaved roads 

and falls onto a paved public road or the 

paved shoulder of a paved public road

Water- Application of water to unpaved roads 

and traffic areas

Wind barrier-Artificial or vegetative wall/fence 

that disrupts the erosive flow of wind over 

unprotected land

Application of any nontoxic chemical or organic 

dust suppressant which 

meets any specification 

required by any federal, 

state, or local water 

agency and is not 

prohibited for use by any 

applicable regulations.

See Regulation VIII for 

additional requirements
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-15

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Noncropland

Overarching Program 

Element/ Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

[and]

On each day that high traffic accounts for 50 or more vehicle 

daily trips (VDT), or 20 or more VDT with 3 or more axles, 

on an Unpaved Traffic Area larger than one (1) acre, the 

owner/operator of an Agricultural Operation Site shall 

comply with the requirements of a stabilized unpaved 

road and limit VDE to 20% opacity by implementing or 

maintaining one or more of the following CMPs: 

E.4.i Pave. 

E.4.j Apply Chemical Stabilization as directed by product 

manufacturer to control dust on Unpaved Roads. 

E.4.k Apply and maintain Gravel, recrushed/recycled asphalt 

or other material of low Silt (<5%) content to a depth of 

three or more inches. 

E.4.l Water Application. 

Additional Requirements for 

High Risk Forecast Days

Unless choosing “watering on a high risk day”, a 

commercial farmer shall ensure 

implementation of at least one of the

following on the day before and during a 

high risk forecast day: 

 Aggregate cover, 

 Wind barrier, 

 Critical area planting, 

 Organic material cover, or

 Synthetic particulate suppressant

Need definitions here 

"Watering on a high risk 

day" means reducing PM 

emissions and wind 

erosion by applying 

water to commercial 

farm road bare soil 

surfaces until the 

surfaces are visibly moist, 

on a high risk forecast 

day. Note that 

“watering on a high risk 

day” is only implemented 

the day of a high risk 

forecast.

For windblown dust control (CMP Category D.1.f), the 

owner or operator of an agricultural operation site shall 

implement E.6.1. In addition to following E.6.1, if the 

owner or operator of an Agricultural Operation Site 

has fields that are in between crops or more permanently 

fallow, the owner or operator shall implement at least one 

of the CMPs in E.6.2. 

E.6.1 When preparing a field for planting, minimize the time 

that newly tilled soil is smooth and dry by leaving the field 

surface with large clods for as long as possible and 

bedding and planting the field as soon as possible once it 

no longer has large clods. 

E.6.2 For fields that are in between crops or are permanently 

fallow, the owner shall implement at least one of the 

CMPs below: 

E.6.2a Cover Crop 

E.6.2b Conservation Tillage 

E.6.2c Crop Residue Management 

E.6.2d Cross Wind Stripcropping 

E.6.2e Field Windbreaks 

E.6.2f Ridge Roughness 

E.6.2g Surface Roughening 

E.6.2h Wind Barrier 

Imperial has no 

similar forecast.

No such forecast.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-16

FIII-5 Roads (Commercial Farm)

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Commercial Farm Roads

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

BMPs

A commercial farmer shall implement at 

least one of the following BMPs: 

 Access restriction, 

 Reduce vehicle speed, 

 Track-out control system, 

 Aggregate cover, 

 Synthetic particulate suppressant, 

Watering, or, 

 Organic material cover.

Agricultural unpaved roads with greater than fifty (50) or 

more vehicle daily trips (VDT), or twenty (20) or more 

VDT with three (3) or more axle vehicles, must meet 

the stabilization and opacity requirements in Section 

E.3. 

The owner or operator of an Agricultural Operation Site 

shall implement at least one of the following CMPs for 

each unpaved road (CMP Category D.1.c) to reduce 

PM10 emissions at all times: 

E.3.a Chips/Mulches, Organic Materials, polymers, road

oil and sand, 

E.3.b Gravel 

E.3.c Paving, 

E.3.d Restricted access 

E.3.e Speed limit 

E.3.f Track-out control 

E.3.g Water Application 

E.3.h Field windbreak 

[and] 

On each day that high traffic accounts for 50 or more 

vehicle daily trips (VDT), or 20 or more VDT with 3 or 

more axles, on an unpaved road segment, the 

owner/operator of an Agricultural Operation Site shall 

comply with the requirements of a stabilized unpaved 

road and limit VDE to 20% opacity by implementing or 

maintaining one or more of the following CMPs: 

E.3.i Pave. 

E.3.j Apply Chemical Stabilization as directed by product 

manufacturer to control dust on Unpaved Roads. 

E.3.k Apply and maintain Gravel, recrushed/recycled 

asphalt or other material of low Silt (<5%) content to a 

depth of three or more inches. 

E.3.l Water Application. 

E.3.m Permanent road closure. 

E.3.n Restrict unauthorized vehicle access. 

Gravel - Placing a layer of gravel with enough 

depth to minimize dust generated from vehicle 

movement and to dislodge any excess debris 

which can become entrained

Paving- To pave currently unpaved areas

Restricted Access - To restrict public access to 

private roads

Speed Limits-Enforcement of speeds that reduce 

visible dust emissions

Track out control-Minimize any and all material 

that adheres to and agglomerates on all vehicles 

and equipment from unpaved roads and falls 

onto a paved public road or the paved shoulder 

of a paved public road

Water- Application of water to unpaved roads and 

traffic areas

Wind barrier-Artificial or vegetative wall/fence 

that disrupts the erosive flow of wind over 

unprotected land Mechanical Pruning - Using a 

machine instead of hand

labor to prune

Chips / Mulches, 

Organic Materials, 

Polymers, 

Road oil

Sand

Application of any nontoxic chemical or organic 

dust suppressant which 

meets any specification 

required by any federal, 

state, or local water 

agency and is not 

prohibited for use by any 

applicable regulations. 

See Regulation VIII for 

additional requirements
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-17

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Commercial Farm Roads

Overarching Program Element/ 

Requirement

Overarching Program Element/ 

Requirement

Overarching Program 

Element/ Requirement Overarching Program Element/ Requirement

Overarching 

Program 

Element/ 

Requirement

Overarching Program Element/ Requirement

Additional Requirements for 

High Risk Forecast Days

Unless choosing “watering on a high risk 

day”, a commercial farmer shall ensure 

implementation of at least one of the 

following on the day before and during a 

high risk forecast day, on a road that 

experiences more than 20 VDT from 2 or 

more axle vehicles: 

 Aggregate cover, 

 Synthetic particulate suppressant, 

 Wind barrier, 

 Organic material cover, or

 Roads are stabilized as determined by 

the silt content test method 

Need definitions here 

"Watering on a high risk 

day" means reducing PM 

emissions and wind 

erosion by applying 

water to commercial 

farm road bare soil 

surfaces until the 

surfaces are visibly moist, 

on a high risk forecast 

day.

No such forecast. No such forecast.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-18

FIII-6 Cropland

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Cropland

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

BMPs

A commercial farmer shall implement at least 

one of the following BMPs: 

 Wind barrier, 

 Cover crop, 

 Cross-wind ridges, 

 Chips/mulches, 

 Sequential cropping 

 Residue management, 

 Surface roughening, 

AND 

 A commercial farmer shall ALSO 

implement at least one of the following 

BMPs: 

 Multi-year crop, 

 Permanent cover, or 

 Stabilization of soil prior to plant 

emergence. 

(note that none of the 

BMPs for Cropland are 

required if the farmer 

implements 

conservation or reduced 

tillage for the tillage 

category—see 

exceptions in the 

overarching program 

elements section)

The owner or operator of an Agricultural Operation Site 

shall implement at least one of the following CMPs in 

each Agricultural Parcel to reduce PM10 emissions 

from cropland-others (Category D.1.e). If the owner or 

operator selects “Fallow Land” as its CMP, the 

owner/operator must comply with Section E.6 of this 

rule. 

E.5.a Alternate Tilling 

E.5.b Application Efficiencies 

E.5.c Bailing/Large Bales 

E.5.d Bulk Materials Control 

E.5.e Chemigation/Fertigation 

E.5.f Conservation Irrigation 

E.5.g Fallow Land 

E.5.h Grinding/Chipping/Shredding 

E.5.i Integrated Pest Management 

E.5.j Irrigation Power Units 

E.5.k Mulching 

E.5.l Night Farming 

E.5.m No Burning 

E.5.n Non Tillage/Chemical Tillage 

E.5.o Organic Practices 

E.5.p Permanent Crops 

E.5.q Reduced Pruning 

E.5.r Soil Amendments 

E.5.s Soil Incorporation 

E.5.t Sulfur: Reduction or Elimination of Dusting 

E.5.u Surface Roughening 

E.5.v Transgenic Crops 

E.5.w Wind Barrier 

E.6 For windblown dust control (CMP Category D.1.f), the 

owner or operator of an agricultural operation site shall 

implement E.6.1. In addition to following E.6.1, if the 

owner or operator of an Agricultural Operation Site has 

fields that are in between crops or more permanently 

fallow, the owner or operator shall implement at least 

one of the CMPs in E.6.2. 

E.6.1 When preparing a field for planting, minimize the 

time that newly tilled soil is smooth and dry by leaving 

the field surface with large clods for as long as possible 

Alternate Till - Rotate tillage, leaving residue on 

soil 

Application Efficiencies - Use compact, low 

volume, or concentrate quantity with spray 

equipment, aerial applications, use microheads or infrared spot sprayer, electrostatic 

sprayers 

Baling/Large Balers - Using balers to harvest crop 

Bulk materials control - Minimize visible dust 

emissions from bulk materials 

Chemigation/ Fertigation - Application of 

chemicals thru an irrigation system 

Conservation irrigation - To conserve the 

quantity of water use, e.g.: drip, sprinkler, 

buried/underground line

Cover crops - Use seeding or natural 

vegetation/regrowth of plants to cover soil 

surface 

Fallowing land - temporary or permanent 

removal from production. (e.g.: vineyard 

pullout, Raisin Industry Diversion program, 

wildlife/wetlands conservation program) 

Grinding/Chipping/ Shredding - Grinding 

prunings and orchard removals, instead of 

burning, incorporate to soil, to reduce 

emissions 

Integrated Pest Management - A decision 

process which uses a combination of 

techniques including organic, conventional, 

biological farming practices to suppress pests 

problems 

Irrigation Power Units - Use cleaner burning 

engines, electric motors (CMP only applicable if 

engines are cleaner than current rule 

requirements) 

Mulching - Applying plant residue or other 

material to soil surface or incorporating into 

soil. 

Night farming - Operate at night where practical 

when moisture levels are higher and winds are 

lighter 

No burning - Switching to a crop/system that 

would not require waste burning 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-19

Crop Operations Rules A.A.C. R18-2-610 & 610.03

Cropland

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rule 806)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

and bedding and planting the field as soon as possible 

once it no longer has large clods. 

E.6.2 For fields that are in between crops or are 

permanently fallow, the owner shall implement at least 

one of the CMPs below: 

E.6.2a Cover Crop 

E.6.2b Conservation Tillage 

E.6.2c Crop Residue Management 

E.6.2d Cross Wind Stripcropping 

E.6.2e Field Windbreaks 

E.6.2f Ridge Roughness 

E.6.2g Surface Roughening 

E.6.2h Wind Barrier 

Non tillage / Chemical tillage - Use flail mower, 

low volume sprayers, e.g.: use heat delivery 

system for cotton defoliation 

Organic Practices - Use biological control 

methods, use non-chemical control methods 

Permanent Crops - Having an established 

permanent crop 

Reduced pruning - Reduce frequency of pruning 

(e.g.: one time per year, or every other year) 

Soil amendments - Organic or chemical materials 

applied to the soil for improvement (e.g.: 

gypsum, lime, polyacrilamide) 

Soil incorporation - Disking residues and/or soil 

incorporation of residue 

Sulfur - reduction or elimination of dusting -

Organic chemical used to control disease in 

crop, ornamental and home and gardens 

Surface roughening - Leaving soil surface as it 

stands or clods of soil when fallow, preparing 

planting surface perpendicular to wind 

direction 

Transgenic crops - Use "herbicide-ready" 

Wind barrier - Artificial or vegetative wall/fence 

that disrupts the erosive flow of wind over 

unprotected land

Additional Requirements for 

High Risk Forecast Days

A commercial farmer shall ensure 

implementation of at least one of the 

following on the day before and during a 

high risk forecast day: Wind barrier, Cover 

crop, Cross-wind ridges, Chips/mulches, 

Surface roughening, Multi-year crop, 

Permanent cover, Stabilization of soil prior 

to plant emergence, or Residue 

management. 

(note that none of the 

BMPs for Cropland are 

required if the farmer 

implements 

conservation or reduced 

tillage for the tillage 

category—see 

exceptions in the 

overarching program 

elements section)Need 

definitions here

No such forecast. No such forecast.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-20

FIII-7 Animal Operations Overarching Requirements

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Overarching Program Elements/Requirements

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

Purpose

To reduce PM emissions from commercial 

agricultural operations through use of best 

management practice (BMP). (A.A.C. R18-2-

611.03(A)) 

PM includes both PM2.5 

and PM10. (A.A.C. R18-

2-611.01(1)(j)) “Best 

Management Practice ” 

(BMP) means a 

technique verified by 

scientific research, that 

on a case-by-case basis 

is practical, 

economically feasible, 

and effective in reducing 

PM emissions from a 

regulated agricultural 

activity. 

To reduce the amount of pollutants generated from Large 

Confined Animal Facilities (beef feedlots and dairy 

operations) by requiring Conservation Management 

Practices to prevent, reduce, or mitigate PM-10. 

Herein, mostly only 

PM-10 related 

requirements are 

listed. Also, 

conservation 

management 

practices per policy

38 only apply to 

dairy and beef 

feedlot operations. 

Rule 420 only 

applies to beef 

feedlots.

To limit fugitive dust from agricultural operation 

sites through use of Conservation Management 

Practice Plans. (Rule 4550) 

Conservation Management Practices (CMP): an 

activity or procedure that reduces air pollutants 

normally emitted by, or associated with, an 

agricultural activity. (Rule 4550 Section 3.9)

Facility Definitions

“Commercial dairy operation” means a dairy 

operation with more than 150 dairy cattle

within the applicable boundaries. (A.A.C. 

R18-2-611.01 (3)(f)) 

“Commercial beef cattle feedlot” means a 

beef cattle feedlot with more than 500 beef 

cattle within the applicable boundaries. 

(A.A.C. R18-2-611.01 (5)(g)) 

“Commercial poultry facility” means a poultry 

operation with more than 25,000 egg laying 

hens within the applicable boundaries. 

(A.A.C. R18-2-611.01 (4)(m)) 

“Commercial swine facility” means a swine 

operation with more than 50 animal units

for more than 30 consecutive days within

the applicable boundaries. One thousand 

pounds equals one animal unit. (A.A.C. 

R18-2-611.01 (2)(f))

Large confined animal facility (LCAF) is any Confined 

Animal Facility that maintains on any one day: 

1,000 or more milk-producing dairy cows; 

3,500 or more beef cattle, calves, heifers, or other cattle; 

100,000 or more turkeys; or 

650,000 more chickens other than laying hens; 

650,000 or more laying hens; or 

3,000 or more swine; 

15,000 or more sheep, lambs, or goats; 

2,500 or more horses; 

650,000 or more ducks; or 

30,000 or more rabbits or other animals. 

AFOs are lots or facilities where animals are or 

will be gathered, fed, stabled for a total of 45 

days or more in any 12 month period and 

where crops, vegetation, etc. are not sustained

on any part.

500 or more mature dairy cows, milked or dry

190 or more cattle (other than mature dairy 

cows or veal calves). Cattle includes but is not 

limited to heifers, steers, bulls and cow/calf 

pairs

55,000 or more turkeys

125,000 or more chickens (other than laying 

hens)

82,000 or more laying hens.

Agricultural operation site” is one or more 

agriculture parcels that are both under the 

same or common ownership or operation or 

common control and are located on one or 

more contiguous or adjacent properties wholly 

within the San Joaquin Valley Air Basin. 

Agricultural parcel includes but is not limited to 

cropland and animal feeding operations (AFOs). 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-21

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Overarching Program Elements/Requirements

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

“Agriculture operations” includes the raising of 

fowl or animals for the primary purpose of 

earning a living or conducting research or 

instruction by educational institution. 

Basic Program Structure

Rules 611 & 611.03 Commercial animal 

operator (“Operator”) must complete a 

(feeless) agricultural PM permit record 

form (essentially a general permit) 

demonstrating compliance with the 

applicable rules. 

An operator must also implement at least 

one BMP from each category (e.g. the 

waste handling category contains multiple 

options) that pertains to the kind of 

commercial facility (i.e. dairy, beef feedlot, 

poultry, or swine). 

The operator will submit a survey every three 

years to update logistical information and 

BMP choices. 

Operator will maintain records 

demonstrating compliance with permit 

record form.

Rule 217 

Any Person using or operating a Large Confined Animal 

Facility shall acquire and maintain a Large Confined 

Animal Facilities (LCAF) permit to control significant 

sources and pollutants, and to let the agency know 

what the significant sources are at the facility. 

Operators of LCAFs shall implement the control measures 

identified in their emissions mitigation plan, which may 

be selected from Policy 38.

The Owner or operator of an LCAF shall apply the control 

measures in the mitigation plan on a six month 

schedule.

Each year, the owner or operator shall submit an annual 

compliance plan that updates the information 

submitted for the permit application.

The mitigation plan demonstrates that the facility will use 

RACT to reduce emissions that contribute to nonattainment. 

Control measures identified in a facility’s emissions 

mitigation plan may be selected from Air District Policy 

Number 38, Recommended Mitigation Measures for 

Large Confined Animal Facilities. 

Policy Number 38 only contains mitigation measures for 

beef feedlots and dairy operations. 

Agricultural paved 

and unpaved roads 

and open areas are 

mitigated 

separately in a 

fugitive dust rule 

(Rule 800). For 

further 

information, see 

the fugitive dust 

rule benchmark.

Per rule 217 (Large 

Confined Animal 

Facilities Permits 

Requires), the rule 

sets for the 

permitting 

requirements for 

agricultural sources 

subject to permit, 

including Large 

Confined Animal 

Facilities (LCAF).

Rule 800 of Imperial 

County applies to 

off-field 

agricultural 

sources:

Regulated facilities submit CMP applications for 

each agricultural operation site, with rule 

dictated details and chosen CMPs. 

Facilities shall implement the CMPs as contained 

in the approved CMP plan. 

An owner/operator shall select one CMP from 

the CMP list for each of the applicable CMP 

categories for each agricultural parcel of an 

agricultural operation site, except as provided 

below ... (See Exceptions Section). (Rule 4550) 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-22

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Overarching Program Elements/Requirements

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

Rule 420 contains more specific requirements for beef 

feedlots (which can be found in the beef feed lot 

program specific requirements below), including a dust 

plan. 

Each year, the owner or operator of a LCAF shall submit 

an annual compliance plan that updates the 

information provided in the original application 

(including logistical and mitigation plan information).

 Operator will keep records that specify daily number of 

animals maintained at the facility. 

Any Agricultural 

Source or activity 

at an Agricultural 

Source that falls 

into one or more of 

the following 

categories: 

C.25.a Outdoor 

handling, storage 

and transport of 

Bulk Material; 

C.25.b Paved Road; 

C.25.c Unpaved 

Road; or 

C.25.d Unpaved 

Traffic Area. 

Because LCAFs are 

agricultural sources 

subject to permit, 

Imperial’s Rule 800 

applies to handling 

of bulk materials, 

paved roads, 

unpaved roads, 

and unpaved traffic 

areas on LCAFs.

Please see the 

fugitive dust 

benchmarking for 

control of these 

sources.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-23

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Overarching Program Elements/Requirements

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

BMP Exceptions

For all facilities: Operators may develop other 

BMPs that are proven effective through onoperation demonstration trials to the 

[Agricultural Best Management Practices] 

Committee...[but] the newly developed 

BMPs are not effective unless submitted as 

described in A.R.S. §49-457(L) which states: 

L. The committee may periodically 

reexamine, evaluate and modify best 

management practices. Any approved 

modifications shall be submitted to the 

United States environmental protection 

agency as a revision to the applicable 

implementation plan.

Off-field Agricultural sources, 

necessary to minimize or respond to adverse effects on 

agricultural crops caused during freezing temperatures 

as declared by the National Weather Service, are 

exempted from dust mitigation regulation per rule 800. 

There are no BMPs 

for anything but 

beef feedlots and 

dairy operations 

(except roads). 

Road fall into what 

is essentially 

Imperial’s fugitive 

dust rule. 

OFF-FIELD 

AGRICULTURAL 

SOURCE: Any 

Agricultural Source 

or activity at an 

Agricultural Source 

that falls into one 

or more of the 

following 

categories: 

C.25.a Outdoor 

handling, storage 

and transport of 

Bulk Material; 

C.25.b Paved Road; 

C.25.c Unpaved 

Road; or 

C.25.d Unpaved 

Traffic Area. 

6.2.2 If a CMP can only be selected for 

implementation on a portion of an agricultural 

operation site, an owner/operator shall select 

an additional CMP within the CMP category to 

be implemented on the remaining acreage or 

remaining AFO. 

6.2.3 An owner/operator may select a substitute 

CMP from another CMP category when no 

feasible CMP can be identified from one 

category. This provision shall not apply for the 

unpaved road, and unpaved vehicle/equipment 

traffic area CMP categories. 

6.2.3.1 An owner/operator may identify or 

develop a new CMP not on the CMP list to be 

used to comply with the requirements of this 

rule. Prior to use of the new CMP the 

owner/operator must obtain the interim 

approval of the APCO to use a new CMP to 

meet the requirements of Section 6.2. The 

owner/operator shall demonstrate that the 

new CMP achieves PM10 emission reductions 

that are at least equivalent to other CMPs on 

the CMP list that could be selected for the 

applicable operation. 

6.2.3.2 The APCO will perform an independent 

analysis of proposed CMPs to determine that 

they achieve PM10 emission reductions that 

are at least equivalent to other CMPs on the 

CMP list....This analysis shall be made using the 

most recent emission factors provided by EPA 

or CARB when available... 

6.2.3.3 An owner/operator may satisfy the 

requirements of Rule 8081 by implementing 

CMPs for the unpaved road and unpaved 

vehicle/equipment traffic area CMP categories 

that are equivalent to the control measures 

specified in Rule 8081. 

An animal operation that operates below the 

animal unit thresholds only have to maintain 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-24

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Overarching Program Elements/Requirements

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

records.

(Rule 4550)

BMP General Permit Record 

Form

A commercial animal operator who engages 

in a regulated agricultural activity shall 

annually complete a Best Management 

Practices Program General Permit Record 

Form. The form shall include the 

following information: 

1.The name of the commercial animal 

operator, signature, and date signed, 2.The 

mailing address or physical address of the 

commercial animal operation, and 

3.The best management practices selected 

for Arenas, Corrals, and Pens, Animal 

Waste Handling and Transporting, Unpaved 

Access Connections, and Unpaved Roads or 

Feed Lanes. 

 Rule 217 (paraphrased in part): 

An The permit application shall include:

Information that the Air Pollution Control Officer deems 

necessary to prepare and emissions inventory.

List of stationary combustion equipment, and other 

details.

List of all other significant sources of air pollution....

Total capacity of the facility in terms of commercial 

production animal and bird population

An emissions mitigation plan that demonstrates that the 

facility will use RACT to reduce emissions of pollutants

that contribute to the non-attainment of any ambient 

air quality standard, and that are within the Air Districts 

regulatory authority. 

In addition, the dust control plan for beef feedlots shall 

adhere to the requirements within Rule 420.

Annual Renewal Permits to Operate for LCAF shall be 

renewed according to the conditions set forth within 

Rule 206 and Rule 301. 

Pursuant to District Rule 212, the APCO may update LCAF 

permits upon annual renewal to include conditions 

necessary for compliance. 

Conservation Management Practice Application 

(CMP Application) is a document prepared and 

submitted by the owner/operator of an 

agricultural operation site that lists the selected 

CMPs for implementation. 

The CMP application also contains, but is not 

limited to: 

contact information for the owner/operator, and 

a site plan or map (maintained on-site) describing 

the location of the agricultural operation site 

and locations of agricultural parcels where 

CMPs will be implemented and 

the location of unpaved roads and unpaved 

equipment/traffic areas to be covered by the 

CMP Plan 

other information describing the extent, duration 

of CMP implementation and 

other information needed by the District to 

calculate emission reductions. (4550) 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-25

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Overarching Program Elements/Requirements

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

BMP Survey (A.A.C. R18-2-

611.03(D)(1)(a)-(m))

Every three years, beginning in calendar year 

2017, the commercial animal operator shall 

complete the Survey with data from the 

preceding calendar year and submit the 

Survey to the Arizona Department of 

Agriculture (ADA). 

The Survey information submitted to the ADA 

shall be compiled by the ADA in a format 

that does not refer to a commercial animal 

operator’s name, shall aggregate the data 

from the Survey’s received, and be 

submitted to the Department. The 3-year 

Survey shall include:

1. The name, business address, and phone 

number of the commercial farmer 

responsible for the preparation and 

implementation of the best management 

practices;

2.The signature of the commercial farmer 

and the date the form was signed; 

3.The number of animals in a commercial 

dairy operation, beef cattle feed lot, 

poultry facility or swine facility;

4. The total miles of unpaved roads at the 

commercial dairy operation, beef cattle 

feed lot, poultry facility or swine facility; 

5. The total acreage of the unpaved access 

connections and equipment areas at the 

commercial dairy operation, beef cattle 

feed lot, poultry facility or swine facility; 

6.The best management practices selected 

for each category; and

7.For commercial dairy operations and beef 

cattle feedlots, an acknowledgement that 

water was applied on the day of a high risk 

day as predicted by the Pinal County Dust 

Control Forecast.

For commercial dairy operations and beef 

cattle feedlots, an acknowledgement that 

water was applied on the day of a high risk 

day as predicted by the Pinal County Dust 

Control Forecast. 

“Dust Control Forecast” 

means a forecast, which 

shall identify a low, 

moderate 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. 

When developing these 

forecasts, the 

department shall 

consider all of the 

following:

a)Projected 

meteorological 

conditions, including: 

i) Wind speed and 

direction, 

ii) Stagnation, 

iii) Recent 

precipitation, and 

iv) Potential for 

precipitation; 

b) Existing concentrations 

of air pollution at the 

time of the forecast; and 

c) Historic air pollution 

concentrations that 

have been observed 

during meteorological 

conditions similar to 

those that are predicted 

to occur in the forecast. 

The owner or operator of a large confined animal facility 

(beef and dairy facility ) shall adhere and apply to the 

selected control measures outlined in their mitigation 

plan (which contains mitigation measures that may be 

selected from the recommended mitigation measures 

policy, Policy No. 38) pursuant to a six month schedule 

approved by the APCO. (Or from rule 420 in the case of 

beef feedlots and dairy operations) 

On or before January 1, each year the owner or operator 

of a LCAF shall submit an annual compliance plan that 

updates the information submitted for the LCAF 

application. 

The survey the same thing as the application in 

San Joaquin.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-26

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Overarching Program Elements/Requirements

Overarching Program Element/ 

Requirement West Pinal County

Comments/ Explanatory 

Definitions re: West 

Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420)

Comments/ 

Explanatory 

Definitions re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

Maintaining 

Records/Compliance (A.A.C. 

R18-2-611.03(J))

A commercial farmer shall maintain records 

demonstrating compliance (including 

records of any changes to BMPs) with the 

applicable rules for three years. 

ADEQ shall document noncompliance with 

the applicable rules before issuing a 

compliance orders. A commercial farmer 

who is not in compliance with the 

applicable rules is subject to the provisions 

in A.R.S. § 49-457(I), (J), and (K)

Any violation of this underlying LCAF permit constitutes a 

violation of Rule 217. 

Recordkeeping All owners of confined animal facilities, 

regardless of size, shall keep records that specify the 

daily number of animals maintained at the facility. 

Current records shall be maintained and kept on-site for 

two years. 

An owner/operator shall, upon request, make 

available to the APCO the records required to 

be kept pursuant to Section 6.5.1 and Section 

6.5.2. 

6.5.1. An owner/operator subject to Section 5.0 

shall maintain the following records for a 

minimum of five (5) years: 

6.5.1.1 A copy of each CMP Application and CMP 

Plan. 

6.5.1.2 Supporting information necessary to 

confirm the implementation of the CMPs. 

6.5.2 An owner/operator claiming exemption 

pursuant to Section 4.0 (animal operations 

operating beneath the animal unit thresholds) 

shall maintain records for a minimum of five (5) 

years that demonstrate that the agricultural 

operation site or agricultural parcel qualified 

for the exemption.

FIII-8 Commercial Dairy

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Dairy Specific Program Requirements other than BMPs

Overarching Program 

Requirement West Pinal County Comments re: West Pinal Imperial(Rules 217 (2006), Policy 38, and Rule 420)

Comments re: 

Imperial

San Joaquin

(Rule 4550 CMP List)

General Program Requirement 

Specific to Commercial Dairy

BMP Choices and Overarching Program Requirements as 

listed above 

and

On the day that is forecast to be high risk for dust 

generation by the Pinal County Dust Control Forecast, 

commercial dairy operations within the Pinal County PM 

Nonattainment Area shall apply and maintain one of the 

four following BMPs on unpaved roads that experience 

more than 20 VDT from 2 or more axle vehicles: 

1. Apply and maintain pavement in high traffic areas,

2. Apply and maintain aggregate cover,

3. Apply and maintain synthetic particulate suppressant, 

or

4. Apply and maintain water as a dust suppressant.

VDT” (Vehicle trips per day) means trips per day made by 

one vehicle, in one direction.

Air Districts Policy Number 38, Recommended Mitigation 

Measures for Large Confined Animal Facilities. 

CMP lists per rule 4550.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-27

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Dairy Specific BMPs

BMP Category within Facility West Pinal County Options Comments re: West 

Pinal

Imperial Requirement

(Rules 217 (2006), Policy 38, and Rule 420)

Comments re: 

Imperial

San Joaquin Requirement

(Rule 4550 CMP List)

Arenas, Corrals, and Pens (A.A.C. 

R18-2-611.03(D)(1)(a)-(m)) 

(means areas where animals 

are confined for the purposes 

of, but not limited to, feeding, 

displaying, safety, racing, 

exercising, or husbandry 

Definitions (1)(b))

Use free stall housing – means enclosing one cow per stall, 

with concrete floors. 

Provide shade in corral - means increasing stocking density 

and reducing animal movement by using a permanent 

structure 

Provide cooling in corral - using cooling systems, increasing 

stocking density in the cool areas of the corrals. 

Cement cattle walkway to milk barn - fencing pathways, 

restricting dairy cattle to concrete floors. 

Groom manure surface - means: Flushing or vacuuming lanes 

daily, Scraping and harrowing pens weekly, and 

i.Removing manure every four months leaving an even corral surface 

of compacted manure on top of the soil.

Pile manure between cleanings means collecting loose surface 

materials within the confines of the surface area of the 

occupied feed pen every two weeks. to contain the loose 

manure materials 

Water misting systems - means using systems that project a 

cloud of very small water particles onto manure surface, 

keeping the surface visibly moist. 

Use drag equipment to maintain pens - means using manure 

equipment pulled behind a tractor instead of using push 

equipment, which avoids dust accumulation in floor 

depressions. 

Push equipment means manure harvesting equipment pushed 

in front of a tractor.

Pile manure between cleanings means reducing PM emissions 

by collecting loose surface materials within the confines of 

the surface area of the occupied feed pen every two weeks.

Feed green chop - means feeding high moisture feed that 

contains at least 30% moisture directly to dairy cattle. Keep 

Calves in barns or hutches Calves means young dairy stock 

under two months of age. 

Hutches means raised, roofed enclosures that protect the 

calves from the elements.

Do not run cattle means reducing PM10 emissions by walking 

dairy cattle to the milking barn Apply fibrous layer 

Apply a fibrous layer means reducing soil movement, and 

preserving soil moisture by spreading shredded or 

deconstructed plant materials to cover loose soil in high 

animal traffic areas. Minimum depth of two inches above 

the soil surface and coverage of 70 %

Wind barrier means constructing a fence or structure, or 

vegetative barrier by planting a row of trees or shrubs to 

reduce wind speed. For fences and structures, wind barrier 

density ≥ 50% and the height proportionate to the 

Freestall Barns:

Owners/operators housing animals in freestalls shall 

incorporate at least two (2) of the following mitigation 

measures in each freestall barn:

1.Vacuum or scrape freestalls during, after, or prior to each 

milking, in accordance with NRCS Agricultural Waste 

Management Field Handbook Chapter 10 Section 651.1002 

2.Inspect water pipes and troughs and repair every 14 days.

3.Use non-manure-based bedding for at least 90% of the 

bedding material, by weight, for freestalls (e.g. rubber 

mats, almond hulls, sand)

4.Remove wet manure from individual cow freestall beds at 

least once every (14) days.

5.Rake, harrow, scrape, or grade bedding in freestalls at least 

twice every seven (7) days.

6.Use a dry manure handling system, such as scraping, 

instead of a liquid manure handling system such as a flush 

system.

7.Have no animals in exercise pens, corrals, or dry lots at any 

time.

8.Flush freestalls more frequently than the milking schedule. 

Flush in accordance with NRCS Agricultural Waste 

Management Handbook Chapter 10 Section 651.1002 or 

more recent NRCS guidance.

9.Implement alternative mitigation measure(s), not listed 

above, subject to approval of the ICAPCO.

Corrals, Pens, etc.

Owner/operators shallincorporate at least (4) of the following 

where animals housed in the last thirty (30) days.

1.Clean manure from corrals at least once every two (2) 

years.

2.Manage corrals such that the manure depth in the corral 

does not exceed thirty-six (36) inches at any time or point, 

except for in-corral mounting.

3.Knockdown fence line manure build-up prior to it exceeding 

a height of twenty-four (24) inches at any time or point.

4.Maintain corrals to ensure drainage and prevent water 

from standing more than seventy-two (72) hours after a 

storm

5.Maintain corrals and drylots so that there are no indentions 

in the surface where puddles may form and remain for 

more than seventy-two (72) hours.

6.Install floats on the troughs or use another method 

approved by the ICAPCD to ensure that the water in the 

troughs does not intentionally or unintentionally overflow 

Imperial’s BMPs are 

in place to 

prevent a 

multitude of 

pollutants and 

are not focused 

on PM10 

prevention or 

mitigation. 

 Use of freestall housing Shaded areas in open 

Corrals - Animals in open pens will loaf in shade 

areas increasing stocking density and reducing 

dust 

 Frequent scraping and or manure removal -

Removal of manure from open corrals 

 Scraping/harrowing - Scraping/ harrowing in 

morning hours when moisture is higher. 

 Sprinkling of open corral - Ensure adequate 

corral surface moisture level to prevent visible 

dust emissions. *This measure is not 

recommended for lactating cows 

 Pull-type Manure harvesting equipment -Using 

a pull-type piece of equipment to leave an even 

corral surface 

 Fibrous layer in dusty areas- Addition of fibrous 

material to working pens 

 Downwind shelterbelts/ boundary trees -

Planting rows of vegetation around facility and 

surrounding to create a barrier for air exiting 

from the facilities (located in overall 

management/feeding category)
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-28

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Dairy Specific BMPs

BMP Category within Facility West Pinal County Options Comments re: West 

Pinal

Imperial Requirement

(Rules 217 (2006), Policy 38, and Rule 420)

Comments re: 

Imperial

San Joaquin Requirement

(Rule 4550 CMP List)

downwind protected area 10:1. For vegetative barriers, 

compliance with NRCS Conservation, Code 380, 

Windbreak/Shelterbelt Establishment (2009).

or spill onto an earthen ground.

7.Inspect water pipes and troughs and repair leaks at least 

once every seven (7) days.

Animal Waste (and Feed) 

Handling and Transporting 

(A.A.C. R18-2-611.03(D)(2)(a)-

(f))

Feed higher moisture feed to dairy cattle means reducing PM 

emissions by feeding dairy cattle one or any combination of 

the following:

i. Add water to ration mix to achieve a 20% minimum 

moisture level,

ii. Add molasses or tallow to ration mix at a minimum of 1%,

iii. Add silage, or

iv. Add green chop. . 

Feed green chop - means feeding high moisture feed that 

contains at least 30% moisture directly to dairy cattle 

Store and maintain feed stock - means reducing PM10 

emissions and wind erosion by storing feed stock in a 

covered area where the commodity is surrounded on at 

least three sides by a structure. 

Covers for silage means reducing PM emissions and wind 

erosion by using large plastic tarps to completely cover 

silage. 

Store silage in bunkers (bunkers being below ground level 

storage systems for storing large amount of silage, which is 

covered with a plastic tarp) 

Cover manure hauling trucks - means reducing PM emissions 

by completely covering the top of the loaded area. 

Do not load manure trucks with dry manure when wind 

exceeds 15 mph

Feed and Silage Operations:

Owners/operators shall incorporate at least three (3) of the 

following feed mitigation measures:

1.Feed according to National Research Council (NRC) 

guidelines.

2.Feed animals high moisture corn or steam-flaked corn and 

not feed animals dry rolled corn.

3.Remove spoiled feed from feed bunks at least once every 

thirty (30) days.

4.Remove spilled feed from feed alleyways at least once 

every thirty (30) days.

5.Remove uneaten wet feed bunks within seventy-two (72) 

hours of a rain event.

6.Feed or dispose of rations within forty-eight (48) hours of 

grinding and mixing rations.

7.Store grain in a weatherproof structure.

8.Cover the horizontal surface of silage piles, except for the 

area where feed is being removed from the pile.

9.Collect leachate from the silage piles and send it to a waste 

treatment system such as a lagoon at least once every 

twenty-four (24) hours.

10.Implement alternative mitigation measure(s), not listed 

above, subject to approval of the ICAPCO.

Owners/operators that handle or store manure or separated 

solids outside the animal housing shall incorporate at least 

one (1) of the following mitigation measures:

1.Cover dry manure piles outside the pens with a waterproof 

covering, except for times, not to exceed twenty-four (24) 

hours per year, when wind events remove the covering.

2.Store no animal waste piles outside the pens.

3.Remove manure from the facility within seventy-two (72) 

hours of removal from the pens or corrals.

4.Remove manure from pans or corrals and transport to an 

on-site composting area utilizing approved composting 

procedures.

5.Implement alternative mitigation measure(s), not listed 

above, subject to approval of the ICAPCO.

Handling Manure in Liquid Form:

Owner/operators that handle manure in a liquid form shall 

incorporate at least one (1) of the following mitigation 

measures:

1.Manage the facility such that lagoons only contain waste 

Imperial’s BMPs are 

in place to 

prevent a 

multitude of 

pollutants and 

are not focused 

on PM10 

prevention or 

mitigation.

 Wet feed during mixing- To increase moisture 

feed levels 

 Feeding near dusk- Feeding young stock during 

evening hours 

 Bulk materials control - Minimize visible dust 

emissions from bulk materials 

 Place wet material in feedwagon first before 

mixing - Mix wet feed with dry feed for 

suppression.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-29

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Dairy Specific BMPs

BMP Category within Facility West Pinal County Options Comments re: West 

Pinal

Imperial Requirement

(Rules 217 (2006), Policy 38, and Rule 420)

Comments re: 

Imperial

San Joaquin Requirement

(Rule 4550 CMP List)

from the milking parlor and storm water.

2.a. Use phototrophic lagoons, or

b. Use an anaerobic treatment lagoon.

3.Remove solids from the waste system with a solid separator 

system, prior to the waste entering the lagoon.

4.Maintain lagoon at a pH between 6.5 and 7.5.

5.Implement alternative mitigation measure(s), not listed 

above, subject to approval of the ICAPCO.

Unpaved Access Connections 

(A.A.C. R18-2-611.03(D)(3)(a)-

(h)) (means any unpaved road 

connection which connects to a 

paved public road)

 Install signage to limit vehicle speed to 15 mph 

 Install speed control devices 

 Restrict access to though traffic Install and maintain a 

track-out control device (a device or system to remove 

mud or soil from a vehicle or equipment before the vehicle 

enters a paved public road (Definitions in R18-2-

611(1)(m))) 

 Apply and maintain pavement in high traffic areas (more 

than 20 vehicle trips per day from 2 or more axle vehicles.) 

 Apply and maintain synthetic particulate suppressant 

(meaning reducing PM emissions and wind erosion by 

providing a stabilized soil surface on a commercial dairy 

operation with a manufactured product such as 

lignosulfate, calcium chloride, magnesium chloride, an 

emulsion of a petroleum product, an enzyme product, or 

polyacrylamide that is used to control particulate matter.) 

 Apply and maintain water as a dust suppressant

Unpaved Roads and Unpaved Vehicle/Equipment Traffic 

Area. The dust control plan shall be implemented on 

all days that traffic exceeds, or is expected to exceed, 

the number of average daily vehicle trips per day as 

specified in sections F.5.c.1 and F.5.c.2 of this rule, 

except where measures are demonstrated by 

owner/operator to be prohibited by federal or state 

laws, regulations, or approved plans concerning 

wilderness preservation and species management and 

recovery. 

F.5.c.1 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved road segment, the 

owner/operator shall limit VDE to 20% opacity and 

comply with the requirements of a stabilized unpaved 

road by application and/or reapplication/maintenance of at least one of the 

following control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated 

that effectively limits VDE to 20% opacity and meets 

the conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved surface area dedicated to 

any vehicle parking and Unpaved Traffic Area, the 

 Speed reduction - Enforcement of speeds that 

reduce visible dust emissions 

 Access restriction - To restrict public access to 

private roads 

 Pavement - To pave currently unpaved areas 

 Dust suppressants-chemical or organic dust 

suppressant which meets any specification 

required by any federal, state, or local water 

agency and is not prohibited for use by any 

applicable regulations. See Regulation VIII for 

additional Requirements 

 Gravel- Placing a layer of gravel with enough 

depth to minimize dust generated from vehicle 

movement and to dislodge any excess debris 

which can become entrained 

 Appropriate equipment and Vehicles -Using 

trip appropriate vehicles
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-30

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Dairy Specific BMPs

BMP Category within Facility West Pinal County Options Comments re: West 

Pinal

Imperial Requirement

(Rules 217 (2006), Policy 38, and Rule 420)

Comments re: 

Imperial

San Joaquin Requirement

(Rule 4550 CMP List)

owner/operator shall limit VDE to 20% opacity and 

comply with the requirements of a stabilized unpaved 

road by application and/or reapplication/maintenance of at least one of the 

following control measures: 

Unpaved Roads or Feed Lanes 

(A.A.C. R18-2-611.03(D)(4)(a)-

(j)) (means roads and feed 

lanes that are unpaved, owned 

by a commercial animal 

operator, and used exclusively 

to service a commercial animal 

operation)

 Install engine speed governors on feed truck to 15 mph 

 Install signage to limit vehicle speed to 15 mph Install 

speed control devices 

 Restrict access to through traffic 

 Apply and maintain pavement in high traffic areas (more 

than 20 vehicle trips per day from 2 or more axle vehicles.) 

 Apply and maintain aggregate cover (meaning reducing PM 

emissions, wind erosion and stabilizing soil by applying and 

maintaining gravel, concrete, recycled road base, caliche, 

or other similar material to unpaved roads or feed lanes. 

The aggregate should be clean, hard and durable, and 

should be applied and maintained to a minimum of three 

inches deep. Definitions 611(2)(a)) 

 Apply and maintain synthetic particulate suppressant 

 Apply and maintain water as a dust suppressant Use 

appropriate vehicles such as electric carts or small utility 

vehicles instead of trucks 

 Apply and maintain pavement or cement feed lanes

“Unpaved roads or 

feed lanes” is the 

mandated statutory 

language in A.R.S. 

49-457, and the 

rules were written 

to match that 

language as much 

as possible. 

However, in A.A.C. 

rule, “unpaved 

roads or feed lanes” 

means roads and

feed lanes that are 

unpaved, owned by 

a commercial 

animal operator, 

and used 

exclusively to 

service a 

commercial animal 

operation. The 

definition of 

unpaved roads or 

feed lanes 

encompasses both 

unpaved roads and 

feed lanes. It has 

been generally 

understood in the 

past and present 

that whether a 

source is an 

unpaved road or a 

feed lane, if it is a 

source of dust, then 

it must be 

controlled. The rule 

is written to require 

controls on both 

((((Unpaved Roads and Unpaved Vehicle/Equipment 

Traffic Area. The dust control plan shall be 

implemented on all days that traffic exceeds, or is 

expected to exceed, the number of average daily 

vehicle trips per day as specified in sections F.5.c.1 and 

F.5.c.2 of this rule, except where measures are 

demonstrated by owner/operator to be prohibited by 

federal or state laws, regulations, or approved plans 

concerning wilderness preservation and species 

management and recovery. 

F.5.c.1 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved road segment, the 

owner/operator shall limit VDE to 20% opacity and 

comply with the requirements of a stabilized unpaved 

road by application and/or reapplication/maintenance of at least one of the 

following control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated 

that effectively limits VDE to 20% opacity and meets 

the conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved surface area dedicated to 

any vehicle parking and Unpaved Traffic Area, the 

owner/operator shall limit VDE to 20% opacity and 

 Speed reduction- Enforcement of speeds that 

reduce visible dust emissions 

 Speed Bumps- Installation of mechanisms to 

slow traffic 

 Access restriction- To restrict public access to 

private roads 

 Gravel- Placing a layer of gravel with enough 

depth to minimize dust generated from vehicle 

movement and to dislodge any excess debris 

which can become entrained 

 Dust suppressants-Application of any non-toxic 

chemical or organic dust suppressant which 

meets any specification required by any

federal, state, or local water agency and is not 

prohibited for use by any applicable 

regulations. See Regulation VIII for additional 

requirements. R8011: Dust Suppressants: 

includes water, hygroscopic materials and, 

chemical/organic stabilization/suppression 

materials. 

 Appropriate equipment and Vehicles- Using 

trip appropriate vehicles 

 Pavement- To pave currently unpaved areas 

 Track out control- Minimize any and all 

material that adheres to and agglomerates on 

all vehicles and equipment from unpaved roads 

and falls onto a paved public road or the paved 

shoulder of a paved public road
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-31

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Dairy Specific BMPs

BMP Category within Facility West Pinal County Options Comments re: West 

Pinal

Imperial Requirement

(Rules 217 (2006), Policy 38, and Rule 420)

Comments re: 

Imperial

San Joaquin Requirement

(Rule 4550 CMP List)

sources, and to 

clarify in the case 

that a feed lane 

may also be called

an “unpaved road”

or vice versa. The 

word “or” in the 

term does not 

indicate that only 

one type of road or 

the other must be 

controlled.

comply with the requirements of a stabilized unpaved 

road by application and/or reapplication/maintenance of at least one of the 

following control measures:

F.5.c.2.1 Watering; 

F.5.c.2.2 Uniform layer of washed gravel;

F.5.c.2.3 Paving;

F.5.c.2.4 Restricted access below the limit;

F.5.c.2.5 Restrict speed limit at or below 15 mph;

F.5.c.2.6 Chemical/organic dust suppressants;

F.5.c.2.7 Roadmix;

F.5.c.2.8 Any other method(s) that can be demonstrated 

that effectively limits VDE to 20% opacity and meets 

the conditions of a stabilized unpaved road. ))))
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-32

FIII-9 Commercial Beef Feedlot

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Beef Feedlot Specific Program Requirements other than BMPs

Overarching Program 

Requirement West Pinal County Comments re: West Pinal

Imperial

(Rules 217 (2006), 420, and 800, and Policy 38) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

General Program 

Requirement Specific to 

Beef Feedlot

BMP Choices and Overarching Program Requirements as listed 

above and In addition to other BMPs, commercial beef 

feedlots within the Pinal County PM Nonattainment Area, shall 

add water to pen surface ( reducing PM emissions and wind 

erosion by applying at least three to six gallons of water per 

head/per day in pens occupied by beef cattle ) on the day that 

is forecast to be high risk for dust generation by the Pinal 

County Dust Control Forecast. 

See Exhibit F-V, 

moisture testing in pens 

is threatens operations

which already have 

conservation limits, and 

need to be able to 

predict the amount of 

water they will be using 

as much as possible. In 

addition, it is unsafe to 

expose on foot 

personnel to over 100 

animals that weigh over 

1,400 pounds in each 

pen. Such a program 

would violate the feed 

yards’ safety plans, 

according to industry 

representatives. Also, 

industry representative 

have stated that 

harvesting manure 

more frequently as a 

means to elevate 

moisture content would 

not be technically 

feasible. Manure 

harvesting is technically 

feasible when the cattle 

is turned over from the 

feedlot to a packing 

plant. In some areas in 

the panhandle or 

central plans, estimated 

turnover rate is based 

on animals only growing 

1.5 to 1.8 times their 

weight from when they 

entered the feedlot. 

However, in Pinal 

Rule Specific to Beef Feedlots (Rule 420): 

In addition to the conditions set forth in the overarching 

Large Confined Animal Facilities an application for a LCAF 

permit shall include a written plan designed to effectively 

control Dust. Such Dust control plan shall contain the 

following: 

B.1 Procedures for assuring Manure at all times is 

maintained at a moisture factor between 20% and 40%, in 

the top three inches (3") in occupied pens. 

B.2 An outline of Manure management practices, including 

standards and time tables for Manure removal, designed 

to effectively control Dust and to prevent adverse public 

health conditions. 

Exceptions; The Air Pollution Control Officer may grant 

exception to the provisions of section B.1 only for the 

following: 

D.1 An exception to the minimum 20% moisture content 

limit may be granted for a period of up to sixty (60) days 

in any fiscal year, provided a written application is 

submitted describing in detail an alternative dust control 

plan. The alternative dust control plan shall contain 

measures to control Dust as effectively as to assure 

compliance with Rule 401, Opacity, and Rule 407, 

Nuisance. 

D.2 An exception to the maximum 40% moisture content 

limit may be allowed during rainy periods, as defined in 

Rule 101, Definitions. 

Compliance : The Air Pollution Control Officer shall grant an 

Authority to Construct (ATC) or a Permit to Operate (PTO) 

upon receiving a Dust control plan which he believes is 

reasonably designed to meet the criteria set forth in B.1 

and B.2 above. Failure to comply with the terms of an 

approved Dust control plan shall be grounds for an ATC or 

PTO revocation and/or for imposition of other penalties 

and sanctions contained in the District's rules and 

regulations. Imperial also has a test method to determine 

manure moisture content within occupied pens.

No additional general program 

requirements to beef feedlots except for 

BMPs below.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-33

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Beef Feedlot Specific BMPs

BMP Category within 

Facility West Pinal County Comments re: West Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

Arenas, Corrals, and 

Pens (A.A.C. R18-2-

611.03(E)(1)(a)-(j))

 Concrete aprons (means reducing PM emissions by using solidly 

formed concrete surface, at least 4 inches thick on top of the soil 

surface, inside the feed pen for 8 feet approaching the feed 

bunk or water trough.) 

 Provide shade in corral (means reducing PM emissions by 

increasing stocking density and reducing animal movement by 

using a permanent structure, which provides at least 16 square 

feet per animal of shaded pen surface.) 

 Add water to pen surface (means reducing PM emissions and 

wind erosion by applying at least three to six gallons of water 

per head/per day in pens occupied by beef cattle.) 

 Manure removal (“Frequent manure removal” means reducing 

PM emissions and wind erosion by harvesting loose manure on 

top of the pen surface at least once every six months.) 

 Pile manure between cleanings (means reducing PM emissions 

by collecting loose manure surface materials, by scraping or 

pushing, within the confines of the surface area of the occupied 

feed pen at least four times per year.) 

 Feed higher moisture feed to beef cattle ( means reducing PM

emissions by feeding beef cattle feed that contains at least 30% 

moisture.) 

 Control cattle during movements (means reducing PM emissions 

by suppressing the animal’s ability to run by driving them 

forward while intruding on their “flight zones” or restraining the 

Owner/operators housing animals in corrals shall incorporate 

at least four (4) of the following mitigation measures in each 

corral where animals have been housed in the last thirty 

(30) days.

Clean manure from corrals at least once every two (2) years

Manage corrals such that the manure depth in the corral does 

not exceed thirty-six (36) inches at any time or point, except 

for in-corral mounting

Knockdown fence line manure build-up prior to it exceeding a 

height of twenty-four (24) inches at any time or point

Maintain corrals to ensure drainage and prevent water from 

standing more than seventy-two (72) hours after a storm

Maintain corrals and drylots so that there are no indentions in 

the surface where puddles may form and remaining for 

more than seventy-two (72) hours.

Install floats on the troughs or use another method approved 

by the ICAPCD to ensure that the water in the troughs does 

not intentionally or unintentionally overflow or spill onto an 

earthen ground

Inspect water pipes and troughs and repair leaks at least once 

every seven (7) days.

Clean the area where the animals stand to consume feed such 

that the depth of animal waste in this area does not exceed 

thirty-six (36) inches at any time or point.

 Shade for animal - Animals in open 

pens will loaf in shade areas 

increasing stocking density and 

reducing dust 

 Sprinkle - Ensure adequate pen 

surface moisture level to prevent 

visible dust emissions 

 Frequent scraping and or manure 

removal – Removal of powdery dust 

 Pull-type Manure harvesting 

equipment -Using a piece of 

equipment to leave an even corral 

surface 

 Fibrous layer in working areas (for 

alley, etc.) -Addition of fibrous 

material to areas

County, the turnover 

rate is less frequent, 

where animals typically 

grow almost five times 

their weigh from when 

they entered the 

feedlot. It takes much 

longer for cattle to grow 

five times their weight 

so that the turnover 

rate is much less 

frequent than in other 

areas. Therefore, 

harvesting manure 

more than two times 

per year because 

growers harvest manure 

during turnover periods, 

of which there are 

typically only two per 

year.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-34

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Beef Feedlot Specific BMPs

BMP Category within 

Facility West Pinal County Comments re: West Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

animal’s movement.) 

 Use drag equipment to maintain pens (means using manure 

harvesting equipment pulled behind a tractor instead of using 

push equipment, which avoids dust accumulation in floor 

depressions) 

 Apply a fibrous layer (reducing PM emissions and soil 

movement, and preserving soil moisture by spreading shredded 

or deconstructed plant materials to cover loose soil in high 

animal traffic areas. Material shall be consistently applied to a 

minimum depth of two inches above the soil surface and 

coverage should be a minimum of 70 percent.) 

 Apply a wind barrier – (means reducing PM10 emissions and 

wind erosion by constructing a fence or structure, or providing a 

woody vegetative barrier by planting a row of trees or shrubs, 

perpendicular or across the prevailing wind direction to reduce 

wind speed by changing the pattern of air flow over the land 

surface. For fences and structures, the wind barrier shall have a 

density of no less than 50% and the height of the wind barrier 

must be proportionate to the downwind protected area. The 

downwind protected area is considered ten times the height of 

the wind barrier. For vegetative barriers, compliance shall be 

determined by NRCS Conservation Practice Standard, Code 380, 

Windbreak/Shelterbelt Establishment, amended through August 

21, 2009 (and no future editions).)

Use a dry animal waste handling system, such as scraping, 

instead of a liquid animal waste handling system, such as a 

flush system.

Implement alternative mitigation measure(s), not listed 

above, subject to approval of the ICAPCO.

Animal Waste (and 

Feed) Handling and 

Transporting (A.A.C. 

R18-2-611.03(E)(2)(a)-

(g))

 Feed higher moisture feed to beef cattle (means reducing PM 

emissions by feeding beef cattle feed that contains at least 30% 

moisture.) 

 Add molasses or tallow to feed (that it equals three percent of 

the total ration.) 

 Store and maintain feed stock ( in a covered area where the 

commodity is surrounded on at least three sides by a structure.) 

 Bulk materials (using a closed conveyor system instead of 

vehicular means to move grain or other feedstuffs (Definitions 

611(3)(e))) 

 Use drag equipment to maintain pens (using manure harvesting 

equipment pulled behind a tractor instead of using push 

equipment, which avoids dust accumulation in floor 

depressions) 

 Cover manure hauling trucks (completely covering the top of the 

loaded area) 

 Do not load manure when wind exceeds 15 mph

Owners/operators that handle or store manure or separated 

solids outside the animal housing shall incorporate at least 

one (1) of the following mitigation measures:

Cover dry manure piles outside the pens with a waterproof

covering, except for times, not to exceed twenty-four (24) 

hours per year, when wind events remove the covering

Store no dry animal waste piles outside the pens

Remove manure from the facility within seventy-two (72) 

hours of removal form the pens or corrals

Remove manure from pens or corrals and transport to an onsite composting area utilizing approved composting 

procedures

Implement alternative mitigation measures not listed, subject 

to approval of the ICAPCO

Owners/operators shall incorporate at least three (3) of the 

following feed mitigation measures:

Feed according to National Research Council (NRC) guidelines.

Feed animals high moisture corn or steam-flaked corn and not 

feed animals dry rolled corn.

Remove spoiled feed from feed bunks at least once every 

thirty (30) days.

 Wet feed during mixing-To increase 

moisture feed levels 

 Place wet material in feedwagon 

first-Mix wet feed with dry feed for 

suppression 

 Bulk materials control - minimize 

visible dust emissions from bulk 

materials 

 Downwind shelterbelts/boundary 

trees-Planting rows of vegetation 

around facility and surrounding to 

create a barrier for air exiting from 

the facility 

 Feeding near dusk-Feeding during 

evening hours
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-35

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Beef Feedlot Specific BMPs

BMP Category within 

Facility West Pinal County Comments re: West Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

Remove spilled feed from feed alleyways at least once every 

thirty (30) days

Remove uneaten wet feed bunks within seventy-two (72) 

hours of a rain event

Feed or dispose of rations within forty-eight (48) hours of 

grinding an mixing rations.

Cover the horizontal surface of silage piles, except fo the area 

where feed is being removed from the pile

Collect leachate from the lisage piles and send it to a waste 

treatment system such as a lagoon at least once every 

twenty-four (24) hours.

Implement alternative mitigation measures, subject to 

approval of the ICAPCO.

Unpaved Access 

Connections (A.A.C. 

R18-2-611.03(E)(3)(a)-

(e))

 Install and maintain a track-out control device Apply and 

maintain pavement in high traffic areas (more than 20 vehicle 

trips per day from 2 or more axle vehicles) 

 Apply and maintain aggregate cover (aggregate cover means 

reducing PM emissions, wind erosion and stabilizing soil by 

applying and maintaining gravel, concrete, recycled road base, 

caliche, or other similar material to unpaved roads or feed lanes. 

The aggregate should be clean, hard and durable, and should be 

applied and maintained to a minimum of three inches deep.) 

 Apply and maintain synthetic particulate suppressant ("Synthetic 

particulate suppressant" means reducing PM emissions and 

wind erosion by providing a stabilized soil surface on a 

commercial beef feedlot with a manufactured product such as 

lignosulfate, calcium chloride, magnesium chloride, an emulsion 

of a petroleum product, an enzyme product, or polyacrylamide 

that is used to control particulate matter.) 

 Apply and maintain water as a dust suppressant

From Rule 800: Unpaved Roads and Unpaved 

Vehicle/Equipment Traffic Area. The dust control plan 

shall be implemented on all days that traffic exceeds, 

or is expected to exceed, the number of average daily 

vehicle trips per day as specified in sections F.5.c.1 and 

F.5.c.2 of this rule, except where measures are 

demonstrated by owner/operator to be prohibited by 

federal or state laws, regulations, or approved plans 

concerning wilderness preservation and species 

management and recovery. 

F.5.c.1 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved road segment, the 

owner/operator shall limit VDE to 20% opacity and 

comply with the requirements of a stabilized unpaved 

road by application and/or re-application/maintenance 

of at least one of the following control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated 

that effectively limits VDE to 20% opacity and meets 

the conditions of a stabilized unpaved road. 

Imperial’s fugitive 

BMPs are listed here 

for convenience from 

Imperial Rule 800, but 

more information on 

the procedure and 

implementation is in 

Fugitive dust 

benchmarking. 

Chemical Stabilization/ 

Suppression: A 

means of Fugitive 

Dust (PM-10) control 

implemented to 

mitigate PM-10 

emissions by applying 

petroleum resins, 

asphaltic emulsions, 

acrylics, adhesives, or 

any other materials 

approved for use by 

the California Air 

Resources Board 

(CARB), U.S. 

Environmental 

Protection Agency 

(U.S. EPA) and/or the 

APCO.

Gravel: 

Gravel travelways 

shall have a three (3) 

 Track out control - Minimize any 

and all material that adheres to and 

agglomerates on all vehicles and 

equipment from unpaved roads and 

falls onto a paved public road or the 

paved shoulder of a paved public 

road 

 Pavement - To pave currently 

unpaved areas 

 Gravel- Placing a layer of gravel with 

enough depth to minimize dust 

generated from vehicle movement 

and to dislodge any excess debris 

which can become entrained 

 Dust suppressants-Application of 

any non-toxic chemical or organic 

dust suppressant which meets any 

specification required by any 

federal, state, or local water agency 

and is not prohibited for use by any 

applicable regulations. See 

Regulation VIII for additional 

Requirements

 R8011: Dust Suppressants: includes 

water, hygroscopic materials and, 

chemical/organic 

stabilization/suppression materials. 

 Access restriction - To restrict public 

access to private roads 

 Speed reduction- Enforcement of 

speeds that reduce visible dust 

emissions 

 Appropriate equipment and 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-36

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Beef Feedlot Specific BMPs

BMP Category within 

Facility West Pinal County Comments re: West Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

F.5.c.2 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved surface area dedicated to any 

vehicle parking and Unpaved Traffic Area, the 

owner/operator shall limit VDE to 20% opacity and 

comply with the requirements of a stabilized unpaved 

road by application and/or re-application/maintenance 

of at least one of the following control measures: 

F.5.c.2.1 Watering; 

F.5.c.2.2 Uniform layer of washed gravel;

F.5.c.2.3 Paving; 

F.5.c.2.4 Restricted access below the limit; 

F.5.c.2.5 Restrict speed limit at or below 15 mph; 

F.5.c.2.6 Chemical/organic dust suppressants; 

F.5.c.2.7 Roadmix; 

F.5.c.2.8 Any other method(s) that can be demonstrated 

that effectively limits VDE to 20% opacity and meets 

the conditions of a stabilized unpaved road. ))))

inch minimum depth 

Stabilized Surface. 

The travelway shall 

have a relative 

compaction of not 

less than 95% as 

determined by Test 

Method No. 

California 216 of 

State of California, 

Business and 

Transportation 

Agency Department 

of Transportation, 

and conforming to 

[certain grading 

listed in the rule]. 

Vehicles - Using trip appropriate 

vehicles

Unpaved Roads or Feed 

Lanes (A.A.C. R18-2-

611.03(E)(4)(a)-(i))

 Install engine speed governors on feed truck to 15 mph 

 Install signage to limit vehicle speed to 15 mph Install speed 

control devices 

 Restrict access to through traffic 

 Apply and maintain pavement in high traffic areas (more than 20 

vehicle trips per day from 2 or more axle vehicles.) 

 Apply and maintain aggregate cover (aggregate cover means 

reducing PM emissions, wind erosion and stabilizing soil by 

applying and maintaining gravel, concrete, recycled road base, 

caliche, or other similar material to unpaved roads or feed lanes. 

The aggregate should be clean, hard and durable, and should be 

applied and maintained to a minimum of three inches deep.) 

 Apply and maintain synthetic particulate suppressant ("Synthetic 

particulate suppressant" means reducing PM emissions and 

wind erosion by providing a stabilized soil surface on a 

commercial beef feedlot with a manufactured product such as 

lignosulfate, calcium chloride, magnesium chloride, an emulsion 

of a petroleum product, an enzyme product, or polyacrylamide 

that is used to control particulate matter.) 

 Apply and maintain water as a dust suppressant 

 Apply and maintain oil on roads or feed lanes

“Unpaved roads or feed 

lanes” is the 

mandated statutory 

language in A.R.S. 49-

457, and the rules 

were written to 

match that language 

as much as possible. 

However, in A.A.C. 

rule, “unpaved roads 

or feed lanes” means 

roads and feed lanes 

that are unpaved, 

owned by a 

commercial animal 

operator, and used 

exclusively to service 

a commercial animal 

operation. The 

definition of unpaved 

roads or feed lanes 

encompasses both 

unpaved roads and 

feed lanes. It has 

((((Unpaved Roads and Unpaved Vehicle/Equipment 

Traffic Area. The dust control plan shall be 

implemented on all days that traffic exceeds, or is 

expected to exceed, the number of average daily 

vehicle trips per day as specified in sections F.5.c.1 and 

F.5.c.2 of this rule, except where measures are 

demonstrated by owner/operator to be prohibited by 

federal or state laws, regulations, or approved plans 

concerning wilderness preservation and species 

management and recovery. 

F.5.c.1 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved road segment, the 

owner/operator shall limit VDE to 20% opacity and 

comply with the requirements of a stabilized unpaved 

road by application and/or re-application/maintenance 

of at least one of the following control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

Imperial’s fugitive 

BMPs are listed here 

for convenience from 

Imperial Rule 800, but 

more information on 

the procedure and 

implementation is in 

Fugitive dust 

benchmarking. 

 Chemical 

Stabilization/ 

Suppression: A 

means of Fugitive 

Dust (PM-10) control 

implemented to 

mitigate PM-10 

emissions by applying 

petroleum resins, 

asphaltic emulsions, 

acrylics, adhesives, or 

any other materials 

approved for use by 

the California Air 

 Speed reduction - Enforcement of 

speeds that reduce visible dust 

emissions 

 Access restriction - To restrict public 

access to private roads

 Pavement - To pave currently 

unpaved areas 

 Gravel - Placing a layer of gravel 

with enough depth to minimize dust 

generated from vehicle movement 

and to dislodge any excess debris 

which can become entrained 

 Dust suppressants-Application of 

any non-toxic chemical or organic 

dust suppressant which meets any 

specification required by any 

federal, state, or local water agency 

and is not prohibited for use by any 

applicable regulations. See 

Regulation VIII for additional 

Requirements R8011: Dust 

Suppressants: includes water, 

hygroscopic materials and, 

chemical/organic 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-37

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Beef Feedlot Specific BMPs

BMP Category within 

Facility West Pinal County Comments re: West Pinal

Imperial

(Rules 217 (2006), Policy 38, and Rule 420) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

been generally 

understood in the 

past and present that 

whether a source is 

an unpaved road or a 

feed lane, if it is a 

source of dust, then it 

must be controlled. 

The rule is written to 

require controls on 

both sources, and to 

clarify in the case that 

a feed lane may also 

be called an 

“unpaved road” or 

vice versa. The word 

“or” in the term does 

not indicate that only 

one type of road or 

the other must be 

controlled.

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated 

that effectively limits VDE to 20% opacity and meets 

the conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or 

Competition that 50 average vehicle daily trips per day 

will occur on an unpaved surface area dedicated to any 

vehicle parking and Unpaved Traffic Area, the 

owner/operator shall limit VDE to 20% opacity and 

comply with the requirements of a stabilized unpaved 

road by application and/or re-application/maintenance 

of at least one of the following control measures:

F.5.c.2.1 Watering; 

F.5.c.2.2 Uniform layer of washed gravel;

F.5.c.2.3 Paving; 

F.5.c.2.4 Restricted access below the limit; 

F.5.c.2.5 Restrict speed limit at or below 15 mph; 

F.5.c.2.6 Chemical/organic dust suppressants; 

F.5.c.2.7 Roadmix; 

F.5.c.2.8 Any other method(s) that can be demonstrated 

that effectively limits VDE to 20% opacity and meets 

the conditions of a stabilized unpaved road. ))))

Resources Board 

(CARB), U.S. 

Environmental 

Protection Agency 

(U.S. EPA) and/or the 

APCO.

Gravel: 

Gravel travelways shall 

have a three (3) inch 

minimum depth 

Stabilized Surface. 

The travelway shall 

have a relative 

compaction of not 

less than 95% as 

determined by Test 

Method No. California 

216 of State of 

California, Business 

and Transportation 

Agency Department 

of Transportation, and 

conforming to [certain 

grading listed in the 

rule]. 

stabilization/suppression materials. 

 Appropriate equipment and 

Vehicles - Using trip appropriate 

vehicles
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-38

FIII-10 Commercial Poultry

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Poultry Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility West Pinal County

Comments 

re: West 

Pinal

Imperial

(Rule 800) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

Arenas, Corrals, and Pens 

(Housing) (A.A.C. R18-2-

611.03(F)(1)(a)-(e))

 Clean fans, louvers, and soffit inlets in a commercial poultry 

facility (means cleaning fans, louvers, and soffit inlets when the 

facility is empty between depopulating and populating the 

facility 

 Use no bedding (“Use no bedding in the production facility” 

means reducing PM emissions by not using bedding such as 

wood shavings, sawdust, peanut hulls, straw, or other organic 

material) 

 Control vegetation on building exteriors (means removing, 

cutting, or trimming vegetation that accumulates PM and 

restricts ventilation of the building, so as to leave approximately 

3 feet between the vegetation and building.) 

 Add moisture through ventilation systems (means using a 

ventilation system that is designed to allow stock to maintain 

their normal body temperature without difficulty while 

maintaining a minimum of 20% moisture in to the air within the 

housing system to bind small particles to larger particles) 

 House in fully enclosed ventilated buildings (utilizing fully 

enclosed buildings with sufficient ventilation.)

 Vegetation- Maintaining some 

vegetation, such as native grasses, on 

vacant land 

 Dust suppressants-Application of any 

non-toxic chemical or organic dust 

suppressant which meets any 

specification required by any federal, 

state, or local water agency and is 

not prohibited for use by any 

applicable regulations. See 

Regulation VIII for additional 

Requirements 

 (R8011: Dust Suppressants: includes 

water, hygroscopic materials and, 

chemical/organic 

stabilization/suppression materials.) 

 Windblocks - To establish a 

perimeter physical barrier to reduce 

windblown dust.

 Reduced tillage - To reduce the 

number of tillings

Animal Waste (and Feed) 

Handling and 

Transporting (A.A.C. 

R18-2-611.03(F)(2)(a)-

(k))

Remove spilled feed (means removing spilled feed from the 

housing facility at least once every 14 days.)

Store feed (means storing feed in a structure that is enclosed and 

weatherproof, which reduces air contact with the feed rations 

during feed storage.)

Add oil and/or moisture to the feed (means adding a minimum of 

1% edible oil and/or moisture to feed rations to bind small 

particles to larger particles.)

Use enclosed feed distribution system (means using an enclosed 

feed conveyance system that distributes feed rations throughout 

the housing facility, which reduces air contact with the feed 

rations during feed conveyance.)

Use flexible discharge spout (means using a flexible discharge spout 

on the end of the feed truck transfer auger.)

Minimize drop distance (means designing the feed distribution 

system so that the distance the feed ration drops from the feed 

distribution system into feeders is approximately 1 foot or less, 

which reduces air contact with the feed rations during feed 

conveyance.)

Enclose transfer points (means enclosing the points of transfer 

 Outdoor storage – use of a structure 

design to store the bulk materials 

(e.g. used poultry litter/manure) or 

to securely cover the bulk materials if 

it must be stored outdoors not 

within any structure 

 Boot or sock – feed is loaded into the 

feed storage bins by employing a 

sock or boot on the feed delivery 

truck auger 

 Cleanout frequency – to adjust the 

frequency of cleanouts from the 

houses 

 Time of manure spreading – to 

spread the manure at a time that 

would help reduce the amount of 

PM10 released in the air
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-39

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Poultry Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility West Pinal County

Comments 

re: West 

Pinal

Imperial

(Rule 800) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

between the enclosed, weatherproof storage structure and the 

enclosed feed distribution system, which reduce air contact with 

the feed rations during feed conveyance.)

Clean floors and walls in a commercial poultry facility (means 

cleaning floors and walls to prevent dried manure, spilled feed, 

and debris accumulation when the facility is empty between 

depopulating and populating the facility.)

Clean aisles between cage rows (means cleaning the aisles between 

cage rows at least twice every 14 days to prevent dried manure, 

spilled feed, and debris accumulation.)

Stack separated manure solids (means reducing the amount of 

exposed surface area of manure solids.)

Maintain moisture in manure solids (means maintaining a moisture

content of a minimum of 15% in the solids sufficient to bind small 

particles to larger particles)

Unpaved Access 

Connections (A.A.C. R18-

2-611.03(F)(3)(a)-(d))

 Install speed control devices 

 Restrict traffic access 

 Install and maintain a track-out control system 

 Install signage to limit vehicle speed to 15 mph

((((Unpaved Roads and Unpaved Vehicle/Equipment Traffic 

Area. The dust control plan shall be implemented on all days 

that traffic exceeds, or is expected to exceed, the number of 

average daily vehicle trips per day as specified in sections 

F.5.c.1 and F.5.c.2 of this rule, except where measures are 

demonstrated by owner/operator to be prohibited by 

federal or state laws, regulations, or approved plans 

concerning wilderness preservation and species 

management and recovery. 

F.5.c.1 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved road segment, the owner/operator shall limit VDE 

to 20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

 Imperial’s 

fugitive BMPs are 

listed here for 

convenience from 

Imperial Rule 800, but 

more information on 

the procedure and 

implementation is in 

Fugitive dust 

benchmarking. 

Chemical Stabilization/ 

Suppression: A means 

of Fugitive Dust (PM10) control 

implemented to 

mitigate PM-10 

emissions by applying 

petroleum resins, 

asphaltic emulsions, 

acrylics, adhesives, or 

any other materials 

approved for use by 

the California Air 

Resources Board 

 Access restriction – to restrict public 

access to private roads 

 Pavement – to pave currently 

unpaved areas 

 Speed reduction - Enforcement of 

speeds thatreduce visible dust 

emissions 

 Gravel – placing a layer of gravel with 

enough depth to minimize dust 

generated from vehicle movement 

and to dislodge any excess debris 

which can become entrained 

 Dust suppressants-Application of any 

non-toxic chemical or organic dust 

suppressant which meets any 

specification required by any federal, 

state, or local water agency and is 

not prohibited for use by any 

applicable regulations. See 

Regulation VIII for additional 

Requirements R

 8011: Dust Suppressants: includes 

water, hygroscopic materials and, 

chemical/organic 

stabilization/suppression materials. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-40

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Poultry Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility West Pinal County

Comments 

re: West 

Pinal

Imperial

(Rule 800) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved surface area dedicated to any vehicle parking and 

Unpaved Traffic Area, the owner/operator shall limit VDE to 

20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the

conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved surface area dedicated to any vehicle parking and 

Unpaved Traffic Area, the owner/operator shall limit VDE to 

20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.2.1 Watering; 

F.5.c.2.2 Uniform layer of washed gravel;

F.5.c.2.3 Paving; 

F.5.c.2.4 Restricted access below the limit; 

(CARB), U.S. 

Environmental 

Protection Agency 

(U.S. EPA) and/or the 

APCO.

Gravel: 

Gravel travelways shall 

have a three (3) inch 

minimum depth 

Stabilized Surface. The 

travelway shall have a 

relative compaction of 

not less than 95% as 

determined by Test 

Method No. California 

216 of State of 

California, Business 

and Transportation 

Agency Department 

of Transportation, and 

conforming to [certain 

grading listed in the 

rule].

 Track out control - minimize any and 

all material that adheres to and 

agglomerates on all vehicles and 

equipment from unpaved roads and 

falls onto a paved public road or the 

paved shoulder of a paved public 

road 

 Vegetation - To establish or maintain 

natural vegetation
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-41

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Poultry Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility West Pinal County

Comments 

re: West 

Pinal

Imperial

(Rule 800) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

F.5.c.2.5 Restrict speed limit at or below 15 mph; 

F.5.c.2.6 Chemical/organic dust suppressants; 

F.5.c.2.7 Roadmix; 

F.5.c.2.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. ))))

Unpaved Roads or Feed 

Lanes (A.A.C. R18-2-

611.03(F)(4)(a)-(h))

 Install engine speed governors on feed trucks to 15 mph 

 Install signage to limit vehicle speed to 15 mph 

 Install speed control devices 

 Restrict traffic access 

 Apply and maintain aggregate cover (means applying and 

maintaining gravel, concrete, recycled road base, caliche, or 

other similar material to unpaved roads or feed lanes. The 

aggregate should be clean, hard and durable, and should be 

applied and maintained to a minimum of three inches deep.) 

 Apply and maintain synthetic particulate suppressant ("Synthetic 

particulate suppressant" means reducing PM emissions and wind 

erosion by providing a stabilized soil surface on a commercial 

poultry operation with a manufactured product such as 

lignosulfate, calcium chloride, magnesium chloride, an emulsion 

of a petroleum product, an enzyme product, or polyacrylamide 

that is used to control particulate matter.) 

 Apply and maintain water 

 Apply and maintain oil on roads or feed lanes

“Unpaved 

roads or 

feed lanes”

is the 

mandated 

statutory 

language in 

A.R.S. 49-

457, and 

the rules 

were 

written to 

match that 

language as 

much as 

possible. 

However, in 

A.A.C. rule, 

“unpaved 

roads or 

feed lanes” 

means 

roads and 

feed lanes 

that are 

unpaved, 

owned by a 

commercial 

animal 

operator, 

and used 

exclusively 

to service a 

commercial 

animal 

operation. 

((((Unpaved Roads and Unpaved Vehicle/Equipment Traffic 

Area. The dust control plan shall be implemented on all days 

that traffic exceeds, or is expected to exceed, the number of 

average daily vehicle trips per day as specified in sections 

F.5.c.1 and F.5.c.2 of this rule, except where measures are 

demonstrated by owner/operator to be prohibited by 

federal or state laws, regulations, or approved plans 

concerning wilderness preservation and species 

management and recovery. 

F.5.c.1 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved road segment, the owner/operator shall limit VDE 

to 20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved surface area dedicated to any vehicle parking and 

Imperial’s fugitive 

BMPs are listed here 

for convenience from 

Imperial Rule 800, but 

more information on 

the procedure and 

implementation is in 

Fugitive dust 

benchmarking. 

Chemical Stabilization/ 

Suppression: A means 

of Fugitive Dust (PM10) control 

implemented to 

mitigate PM-10 

emissions by applying 

petroleum resins, 

asphaltic emulsions, 

acrylics, adhesives, or 

any other materials 

approved for use by 

the California Air 

Resources Board 

(CARB), U.S. 

Environmental 

Protection Agency 

(U.S. EPA) and/or the 

APCO.

Gravel: 

Gravel travelways shall 

have a three (3) inch 

minimum depth 

Stabilized Surface. The 

travelway shall have a 

relative compaction of 

 Speed reduction – enforcement of 

speeds that reduce visible dust 

emissions 

 Access restriction – reduces vehicle 

traffic and thus reduces particulates 

emissions 

 Gravel – placing a layer of gravel with 

enough depth to minimize dust 

generated from vehicle movement 

and to dislodge any excess debris 

which can become entrained 

 Pavement – to pave currently 

unpaved areas 

 Dust suppressants-Application of any 

non-toxic chemical or organic dust 

suppressant which meets any 

specification required by any federal, 

state, or local water agency and is 

not prohibited for use by any 

applicable regulations. See 

Regulation VIII for additional 

Requirements

 R8011: Dust Suppressants: includes 

water, hygroscopic materials and, 

chemical/ organic 

stabilization/suppression materials. 

 Vegetation- to establish or maintain 

natural vegetation 

 Track out control – minimize any and 

all material that adheres to and 

agglomerates on all vehicles and 

equipment from unpaved roads and 

falls onto a paved public road or the 

paved shoulder of a paved public 

road
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-42

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Poultry Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility West Pinal County

Comments 

re: West 

Pinal

Imperial

(Rule 800) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

The 

definition 

of unpaved 

roads or 

feed lanes 

encompass

es both 

unpaved 

roads and 

feed lanes. 

It has been 

generally 

understood 

in the past 

and present 

that 

whether a 

source is an 

unpaved

road or a 

feed lane, if 

it is a 

source of 

dust, then 

it must be 

controlled. 

The rule is 

written to 

require 

controls on 

both 

sources, 

and to 

clarify in 

the case 

that a feed 

lane may 

also be 

called an 

“unpaved 

road” or 

vice versa. 

The word 

“or” in the 

Unpaved Traffic Area, the owner/operator shall limit VDE to 

20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved surface area dedicated to any vehicle parking and 

Unpaved Traffic Area, the owner/operator shall limit VDE to 

20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.2.1 Watering; 

F.5.c.2.2 Uniform layer of washed gravel;

F.5.c.2.3 Paving; 

F.5.c.2.4 Restricted access below the limit; 

F.5.c.2.5 Restrict speed limit at or below 15 mph; 

F.5.c.2.6 Chemical/organic dust suppressants; 

F.5.c.2.7 Roadmix; 

F.5.c.2.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. ))))

not less than 95% as 

determined by Test 

Method No. California 

216 of State of 

California, Business 

and Transportation 

Agency Department 

of Transportation, and 

conforming to [certain 

grading listed in the 

rule].
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-43

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Poultry Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility West Pinal County

Comments 

re: West 

Pinal

Imperial

(Rule 800) Comments re: Imperial

San Joaquin

(Rule 4550 CMP List)

term does 

not indicate 

that only 

one type of 

road or the 

other must 

be 

controlled.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-44

FIII-11 Commercial Swine

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Swine Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility

West Pinal County Comments re: 

West Pinal

Imperial

(Rule 800)

Comments re: Imperial San Joaquin

(None)

Arenas, Corrals, and Pens 

(Housing) (A.A.C. R18-2-

611.03(G)(1)(a)-(g))

 House in fully enclosed ventilated buildings (means utilizing fully 

enclosed buildings with sufficient ventilation.) 

 Use no bedding (means not using bedding such as wood 

shavings, sawdust, peanut hulls, straw, or other organic 

material.) 

 Use slatted floor system (“Slatted flooring” means reducing PM 

emissions by using flooring that is a slotted concrete or wiremesh floor set above a liquid manure collection pit, which allows 

the excrement to fall though the flooring into the liquid pit 

below, which prevents solids build-up. Slats 4 to 8 inches wide 

with spacing of about 1 inch in between are recommended.) 

 Use sloped concrete flooring (“Sloped concrete flooring” means 

reducing PM emissions by pouring concrete with a minimum of 

0.25% grade inside of the barns which provides drainage and 

easier cleaning of floor areas.) 

 Clean fans, louvers, and soffit inlets in a commercial swine 

facility (means cleaning fans, louvers, and soffit inlets between 

transfer of animal groups, but in any case, at least every 6 

months.) 

 Control vegetation on building exteriors (means removing, 

cutting, or trimming vegetation that accumulates PM and 

restricts ventilation of the building, so as to leave approximately 

3 feet between the vegetation and the building) 

 Add moisture through ventilation systems (means using a 

ventilation system that is designed to allow stock to maintain 

their normal body temperature without difficulty while 

maintaining minimum of 15% moisture in the air within the 

housing system to bind small particles to larger particles.)

No swine-specific controls, but AZ listed controls are similar to other 

kinds of facilities, e.g. beef feedlots

No swine-specific controls, but AZ listed 

controls are similar to other kinds of 

facilities, e.g. beef feedlots
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-45

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Swine Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility

West Pinal County Comments re: 

West Pinal

Imperial

(Rule 800)

Comments re: Imperial San Joaquin

(None)

Animal Waste (and Feed) 

Handling and 

Transporting (A.A.C. 

R18-2-611.03(G)(2)(a)-

(m))

 Remove spilled feed (removing spilled feed from the housing 

facility at least once every 14 days)

 Store feed (storing feed in a structure that is enclosed and 

weatherproof, which reduces air contact with the feed rations 

during feed storage)

 Add oil and/or moisture to feed Use enclosed feed distribution 

system (adding a minimum of 0.5% edible oil and/or moisture to 

feed rations to bind small particles to larger particles.)

 Use flexible discharge spout (reducing PM emissions and wind 

erosion at the time of bulk feed deliveries to the housing units by 

using a flexible discharge spout on the end of the feed truck 

transfer auger.)

 Minimize drop distance (designing the feed distribution system 

so that the distance the feed ration drops from the feed 

distribution system into feeders is 3 feet or less, which reduces 

air contact with the feed rations during feed conveyance.)

 Enclose transfer points (enclosing the points of transfer between 

the enclosed, weatherproof storage structure and the enclosed 

feed distribution system, which reduces air contract with the 

feed rations during feed conveyance)

 Clean pens, floors, and walls in a commercial swine facility 

(cleaning pens, floors, and walls between transfer of animal 

groups to prevent dried manure, spilled feed, and debris 

accumulation, but in any case, at least every 6 months.)

 Clean aisles between pens and stalls ( cleaning the aisles 

between pens and stalls at least twice every 14 days to prevent 

dried manure, spilled feed, and debris accumulation.)

 Store separated manure solids in a wind-blocked area ( storing 

manure solids in a wind-blocked area behind a wall, structure, or 

area with natural wind protection to minimize blowing air 

movement over the manure stack.)

 Stack separated manure solids (reducing the amount of exposed 

surface area of manure solids.)

 Maintain moisture in manure solids (maintaining a minimum 

moisture content of 10 % in the solids sufficient to bind small 

particles to larger particles.)

 Maintain liquid lagoon level (“Lagoon” means a liquid manure 

storage and treatment pond.)
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-46

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Swine Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility

West Pinal County Comments re: 

West Pinal

Imperial

(Rule 800)

Comments re: Imperial San Joaquin

(None)

Unpaved Access 

Connections (A.A.C. R18-

2-611.03(G)(3)(a)-(d))

 Install speed control devices 

 Restrict traffic access 

 Install and maintain a track-out control system 

 Install signage to limit vehicle speed to 15 mph

From Rule 800: 

Unpaved Roads and Unpaved Vehicle/Equipment Traffic Area. 

The dust control plan shall be implemented on all days that 

traffic exceeds, or is expected to exceed, the number of 

average daily vehicle trips per day as specified in sections 

F.5.c.1 and F.5.c.2 of this rule, except where measures are 

demonstrated by owner/operator to be prohibited by 

federal or state laws, regulations, or approved plans 

concerning wilderness preservation and species 

management and recovery. 

F.5.c.1 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved road segment, the owner/operator shall limit VDE 

to 20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust BMPs are listed here for 

convenience, but more information on the procedure and 

implementation is in Fugitive dust 

benchmarking.suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved surface area dedicated to any vehicle parking and 

Unpaved Traffic Area, the owner/operator shall limit VDE to 

20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

Imperial’s fugitive 

BMPs are listed here 

for convenience from 

Imperial Rule 800, but 

more information on 

the procedure and 

implementation is in 

Fugitive dust 

benchmarking. 

Chemical Stabilization/ 

Suppression: A means 

of Fugitive Dust (PM10) control 

implemented to 

mitigate PM-10 

emissions by applying 

petroleum resins, 

asphaltic emulsions, 

acrylics, adhesives, or 

any other materials 

approved for use by 

the California Air 

Resources Board 

(CARB), U.S. 

Environmental 

Protection Agency 

(U.S. EPA) and/or the 

APCO.

Gravel: 

Gravel travelways shall 

have a three (3) inch 

minimum depth 

Stabilized Surface. The 

travelway shall have a 

relative compaction of 

not less than 95% as 

determined by Test 

Method No. California 

216 of State of 

California, Business 

and Transportation 

Agency Department 

of Transportation, and 

conforming to [certain 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-47

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Swine Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility

West Pinal County Comments re: 

West Pinal

Imperial

(Rule 800)

Comments re: Imperial San Joaquin

(None)

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved surface area dedicated to any vehicle parking and 

Unpaved Traffic Area, the owner/operator shall limit VDE to 

20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.2.1 Watering; 

F.5.c.2.2 Uniform layer of washed gravel;

F.5.c.2.3 Paving; 

F.5.c.2.4 Restricted access below the limit; 

F.5.c.2.5 Restrict speed limit at or below 15 mph; 

F.5.c.2.6 Chemical/organic dust suppressants; 

F.5.c.2.7 Roadmix; 

F.5.c.2.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. ))))

grading listed in the 

rule].

Unpaved Roads or Feed 

Lanes (A.A.C. R18-2-

611.03(G)(4)(a)-(i))

 Install engine speed governors on feed trucks to 15 mph 

 Install signage to limit vehicle speed to 15 mph 

 Install speed control devices 

 Apply and maintain aggregate cover 

 Apply and maintain synthetic particulate suppressant 

 Apply and maintain water 

 Apply and maintain oil on roads or feed lanes

“Unpaved roads 

or feed lanes” 

is the 

mandated 

statutory 

language in 

A.R.S. 49-457, 

and the rules 

were written 

to match that 

(((Unpaved Roads and Unpaved Vehicle/Equipment Traffic 

Area. The dust control plan shall be implemented on all days 

that traffic exceeds, or is expected to exceed, the number of 

average daily vehicle trips per day as specified in sections 

F.5.c.1 and F.5.c.2 of this rule, except where measures are 

demonstrated by owner/operator to be prohibited by 

federal or state laws, regulations, or approved plans 

concerning wilderness preservation and species 

Imperial’s fugitive 

BMPs are listed here 

for convenience from 

Imperial Rule 800, but 

more information on 

the procedure and 

implementation is in 

Fugitive dust 

benchmarking. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-48

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Swine Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility

West Pinal County Comments re: 

West Pinal

Imperial

(Rule 800)

Comments re: Imperial San Joaquin

(None)

language as 

much as 

possible. 

However, in 

A.A.C. rule, 

“unpaved 

roads or feed 

lanes” means 

roads and 

feed lanes 

that are 

unpaved, 

owned by a 

commercial 

animal 

operator, and 

used 

exclusively to 

service a 

commercial 

animal 

operation. 

The definition 

of unpaved 

roads or feed 

lanes 

encompasses 

both unpaved 

roads and 

feed lanes. It 

has been 

generally 

understood in 

the past and 

present that 

whether a 

source is an 

unpaved road 

or a feed 

lane, if it is a 

source of 

dust, then it 

must be 

controlled. 

The rule is 

written to 

management and recovery. 

F.5.c.1 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved road segment, the owner/operator shall limit VDE 

to 20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.1.1 Watering; 

F.5.c.1.2 Uniform layer of washed gravel; 

F.5.c.1.3 Paving; 

F.5.c.1.4 Restrict access; 

F.5.c.1.5 Restrict speed limit at or below 15 mph; 

F.5.c.1.6 Chemical/organic dust suppressants; 

F.5.c.1.7 Roadmix; 

F.5.c.1.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. 

F.5.c.2 On each day of an Off-Road Event and/or Competition 

that 50 average vehicle daily trips per day will occur on an 

unpaved surface area dedicated to any vehicle parking and 

Unpaved Traffic Area, the owner/operator shall limit VDE to 

20% opacity and comply with the requirements of a 

stabilized unpaved road by application and/or reapplication/maintenance of at least one of the following 

control measures: 

F.5.c.2.1 Watering; 

F.5.c.2.2 Uniform layer of washed gravel;

F.5.c.2.3 Paving; 

F.5.c.2.4 Restricted access below the limit; 

F.5.c.2.5 Restrict speed limit at or below 15 mph; 

F.5.c.2.6 Chemical/organic dust suppressants; 

F.5.c.2.7 Roadmix; 

F.5.c.2.8 Any other method(s) that can be demonstrated that 

effectively limits VDE to 20% opacity and meets the 

conditions of a stabilized unpaved road. ))))

Chemical Stabilization/ 

Suppression: A means 

of Fugitive Dust (PM10) control 

implemented to 

mitigate PM-10 

emissions by applying 

petroleum resins, 

asphaltic emulsions, 

acrylics, adhesives, or 

any other materials 

approved for use by 

the California Air 

Resources Board 

(CARB), U.S. 

Environmental 

Protection Agency 

(U.S. EPA) and/or the 

APCO.

Gravel: 

Gravel travelways shall 

have a three (3) inch 

minimum depth 

Stabilized Surface. The 

travelway shall have a 

relative compaction of 

not less than 95% as 

determined by Test 

Method No. California 

216 of State of 

California, Business 

and Transportation 

Agency Department 

of Transportation, and 

conforming to [certain 

grading listed in the 

rule].
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-49

Animal Operations Agency Comparisons (Rules A.A.C. R18-2-611 and 611.03)

Commercial Swine Facility Specific BMPs (there are no additional program caveats)

BMP Category within 

Facility

West Pinal County Comments re: 

West Pinal

Imperial

(Rule 800)

Comments re: Imperial San Joaquin

(None)

require 

controls on 

both sources, 

and to clarify 

in the case 

that a feed 

lane may also 

be called an 

“unpaved 

road” or vice 

versa. The 

word “or” in 

the term does 

not indicate 

that only one 

type of road 

or the other 

must be 

controlled.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-50

FIII-12 Irrigation Districts

General Permit for Irrigation Districts (Rules A.A.C. R18-2-612 and 612.01)

Overarching Overview

Overarching Program 

Requirement

West Pinal County Comments re: West Pinal Imperial

(Rules 800, 805, and 806)

Comments re: Imperial San Joaquin

(none)

Purpose

To reduce PM emissions from sources in irrigation districts within 

PM nonattainment areas.

The canal regulations 

come from Imperial’s 

general rule for paved 

and unpaved roads.

General Program 

Structure

An irrigation district engaged in a regulated agricultural activity shall 

annually complete a (feeless) Best Management Practices General 

Permit Record Form wherein the district representative will 

choose to implement a best management practice for each 

category under the rule. 

Every three years the district will also complete and submit a survey 

including, among other things, best management practices chosen 

and the mileage of district controlled sources of PM.

Irrigation districts will maintain records to demonstrate compliance.

Basic Definitions

“Unpaved operation and maintenance roads” means unpaved 

roadways that lay adjacent to canals, which provide access for 

irrigation district personnel and equipment for direct operation 

and maintenance of canals, and are under the control of the 

irrigation district.

“Unpaved utility access roads” means unpaved roadways used to 

provide access to canals, and also includes office and shop 

facilities, equipment yards, staging areas and other lands under 

the control of the irrigation district. 

“Canals” means facilities constructed for the sole purpose of the 

control, conveyance, and delivery of water. These facilities may be 

either open earthen channels, lined or unlined, or buried 

pipelines, which are used to convey water uphill and under 

obstructions, such as roadways and wash and river channels. 

These facilities include, but are not limited to, gate, inlet, outlet, 

safety, and measuring structures required to control water along 

the canals and deliver water to irrigation district customers, as 

well as compacted earthen banks constructed to protect these 

facilities from storm runoff events.

CANAL BANK: A rise of land on either side of an 

irrigation canal. 

UNPAVED ROADS: Streets, alley ways, or roadways 

that are not covered by one of the following: 

concrete, asphaltic concrete, asphalt, or other 

similar materials specified by the U.S.EPA, CARB 

and/or the APCO.

C.45 UNPAVED TRAFFIC AREA: Any nonresidential 

area that is:

C.45.a Not covered by asphalt, recycled asphalt, 

asphaltic concrete, concrete, or concrete 

pavement, and

C.45.b Used for fueling and servicing; shipping, 

receiving and transfer; or parking or storing 

equipment, haul trucks, vehicles, and any 

conveyances.

Rules 805 and 806

direct reader to find 

definitions in rule 800. 

(There is no definition 

for “canal road”)

BMP Exceptions

A person may develop different BMPs from those listed in the rule 

and may submit such practices that are prove4n effective through 

on-farm demonstration trials to the [Agricultural Best 

Management Practices] Committee...[but] the newly developed 

BMPs are not effective unless submitted as described in A.R.S. 

§49-457(L) which states: 

L. The committee may periodically reexamine, evaluate and modify 

In addition to the exemptions listed in Rule 800, 

Section E, the following exemptions are established 

for this Rule: 

D.1 Paved and unpaved driveways serving one single 

family residential dwelling. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-51

General Permit for Irrigation Districts (Rules A.A.C. R18-2-612 and 612.01)

Overarching Overview

Overarching Program 

Requirement

West Pinal County Comments re: West Pinal Imperial

(Rules 800, 805, and 806)

Comments re: Imperial San Joaquin

(none)

best management practices. Any approved modifications shall be 

submitted to the United States environmental protection agency 

as a revision to the applicable implementation plan.

D.2 Agricultural Operation Sites subject to Rule 806, 

Conservation Management Practices. 

D.3 Recreational OHV Use Areas on public lands 

subject to Rule 800, General Requirements for 

Control of Fine Particulate Matter (PM-10). 

General Permit Record 

Form

The Best Management Practices General Permit Record Form is to 

be completed annually. 

The form shall include the contact information for and signature of 

representatives responsible and the best management practices 

selected for unpaved operation and utility roads, canals, and 

unpaved utility access roads. 

n/a

BMP Survey

The 3-year Survey shall include the following information:

1.The name, business address, and phone number of the irrigation 

district representative responsible for the preparation and 

implementation of the best management practices;

2.The signature of the irrigation district representative and the date 

the form was signed; 

3.The total miles of canals that the irrigation district controls;

4.The total miles of unpaved operation and maintenance roads;

5.The total miles of the unpaved utility access roads; and

6.The best management practices selected for unpaved operation 

and utility roads, canals, and unpaved utility access roads.

. 

n/a

Maintaining 

Records/Compliance

An irrigation district shall maintain records demonstrating 

compliance (including records of any changes to BMPs) with the 

applicable rules for three years. 

ADEQ shall document noncompliance with the applicable rules 

before issuing a compliance orders. 

An irrigation district that is not in compliance with the applicable 

rules is subject to the provisions in A.R.S. § 49-457(I), (J), and (K)

Any Person subject to the requirements of this rule (Rule 

805) shall compile and retain records that provide 

evidence of control measure application (i.e., receipts 

and/or purchase records). Such Person shall describe, in 

the records, the type of treatment or control measure, 

extent of coverage, and date applied. For control 

measures which require multiple daily applications, 

recording the frequency of application will fulfill the 

recordkeeping requirements of this rule (i.e., water 

being applied three times a day and the date) Records 

shall be maintained and be readily accessible for two 

years after the date of each entry and shall be provided 

to the APCD upon request.

Failure to comply with any provisions of this rule shall 

constitute a violation of Regulation VIII.

General Permit for Irrigation Districts (Rules A.A.C. R18-2-612 and 612.01)
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-52

Irrigation BMPs

BMP Category West Pinal County Comments re: West Pinal Imperial

(Rules 800, 805, and 806)

Comments re: Imperial San Joaquin

(none)

Unpaved operation and 

maintenance roads

a.Access restriction,

b.Apply and maintain aggregate cover,

c. Install supervisory control system to limit vehicle travel,

d.Limit activity,

e.Install signage to limit vehicle speed to 25 mph,

f. Post warning signs for unauthorized use at point of entry to 

roads,

g.Reduce vehicle speed,

h.Install and maintain a track-out control system,

i. Apply and maintain synthetic or natural particulate 

suppressant, 

j. Apply and maintain water before, during, and after major and 

minor earth moving activities, 

k.Apply and maintain water when grading roadways,

l. Use paved non-district or paved public roads to access 

structures, or

m. Install wind barriers.

Reduce vehicle speed means 

to reducing speed so as not 

to exceed 25 mph.

The speed is at 25 mph 

because with 

approximately 900 miles 

(see Table 5-12 of Appendix 

B [the EI TSD]) of road to 

traverse to ensure the 

passage of water, the 

irrigation districts advised 

the Agricultural BMP 

Committee that it would 

make extremely difficult to 

operate if they were only 

able to travel 15 miles in 

one hour. In blockage 

situations, or other daily 

operations, it may be 

necessary to travel long 

distances, and the districts 

decided that any lower 

mandated speed would 

make their jobs technically 

infeasible. Unpaved road 

dust from canal roads 

makes up a relatively small 

portion of the inventory, 

about 1.2% overall (and just 

15% of total uncontrolled 

road dust from unpaved 

private roads). Taking into 

account the reduction to 25 

MPH already included in 

the rule, ADEQ estimates 

that further reduction to 15 

MPH would yield less than 

60 additional TPY of 

reductions, and would not 

in any significant way speed 

the West Pinal 

nonattainment area 

towards attainment.

Besides which, 15 mph 

would be a BACM level 

speed, not necessarily a 

RACM level speed.

Canal Roads: all Persons who cause, suffer or allow 

the operation, use or maintenance of any Canal 

Road with 20 or more Average Vehicle Trips per 

Day shall comply with one or more of the 

requirements of Section F.1 to comply with the 

requirements of a Stabilized Unpaved Road and 

limit VDE to 20% opacity, as determined by the 

test methods in Rule 800, Appendix A, and shall 

also comply with one or more of the 

requirements of Section F.2. 

CANAL ROADS: 

F.2.a Stocking of Triploid Grass Carp in canals to 

reduce maintenance vehicle trips along Canal 

Banks to mechanically remove aquatic weeds. 

F.2.b Installation of remote control delivery gates to 

eliminate manual gate operation by maintenance 

personnel in vehicles along Canal Banks.

F.2.c Implement Silt removal program to delay 

grading of spoil piles deposited on Canal Bank 

after cleaning operations until the next cleaning 

operation to eliminate vehicle access to Canal 

Bank.

F.2.d Permanent road closure.

F.2.e Conversion of open canals to pipeline.

F.2.f Lining canals to eliminate maintenance for 

Silt/weed control.

F.2.g Canal Bank surface maintenance.

Appendix A of Rule 

800: Visual 

Determination of 

Opacity

Section A: Test 

Method for 

Unpaved Roads and 

Unpaved Traffic 

Areas

Section B Test 

Method for TimeAveraged 

Regulations 

(opacity)
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-53

General Permit for Irrigation Districts (Rules A.A.C. R18-2-612 and 612.01)

Irrigation BMPs

BMP Category West Pinal County Comments re: West Pinal Imperial

(Rules 800, 805, and 806)

Comments re: Imperial San Joaquin

(none)

Canals

a.Dredge canals while muck or debris is still wet,

b.Dispose of muck or debris while still damp,

c.Weed management,

d.Biological control of aquatic weeds, or

e.Apply and maintain water before, during and after major and

minor earth moving activities.

See “unpaved maintenance and operation roads” above.

Unpaved utility access 

roads

a.Access restriction,

b.Apply and maintain aggregate cover,

c. Limit activity,

d.Install signage to limit vehicle speed to 25 mph,

e.Post warning signs for unauthorized use at points of entry to 

roads,

f. Reduce vehicle speed,

g.Install and maintain a track-out control system,

h.Apply and maintain pavement,

i. Apply and maintain synthetic or natural particulate 

suppressant, 

j. Apply and maintain water before, during and after major and 

minor earth moving activities,

k.Apply and maintain water when grading roadways,

l. Use paved non-district or paved public roads to access 

structures, or

n.Install wind barriers.

Apply and maintain water when grading roadways, l. Use paved non-district or paved public roads to access structures, or n. Install wind barriers. 

Unpaved Haul/Access Roads: No Person shall cause, 

suffer or allow the operation, use, or 

maintenance of any unpaved Haul/Access Road 

without complying with one or more of the 

requirements of Section F.1 so as to limit VDE to 

20% opacity. 

Unpaved Roads: On any Unpaved Road segment 

with 50 or more Average Vehicle Trips per Day, 

the owner/operator shall limit VDE to 20% 

opacity, as determined by the test methods for 

“Visual Determination of Opacity” in Rule 800, 

Appendix A, and comply with the requirements of 

a 

Stabilized Unpaved Road by application and/or 

maintenance of at least one of the requirements 

of Section F.1. 

Unpaved Traffic Areas: All Persons who cause, 

suffer or allow the operation, use or maintenance 

of any Unpaved Traffic Area larger than one (1) 

acre and with 75 or more Average Vehicle Trips 

per Day shall comply with one or more of the 

requirements of Section F.3 and limit VDE to 20% 

opacity. 

UNPAVED ROADS, INCLUDING UNPAVED HAUL AND 

ACCESS ROADS: 

F.1.a Pave. 

F.1.b Apply Chemical Stabilization as directed by 

product manufacturer to control dust on Unpaved 

Roads. 

F.1.c Apply and maintain Gravel, 

recrushed/recycled asphalt or other material of 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIII-54

General Permit for Irrigation Districts (Rules A.A.C. R18-2-612 and 612.01)

Irrigation BMPs

BMP Category West Pinal County Comments re: West Pinal Imperial

(Rules 800, 805, and 806)

Comments re: Imperial San Joaquin

(none)

low Silt (<5%) content to a depth of three or more 

inches. 

F.1.d Wetting. Apply water one or more times daily 

F.1.e Permanent road closure 

F.1.f Restrict unauthorized vehicle access. 

F.1.g Any other method that effectively limits VDE 

to 20% opacity and meets the conditions of a 

Stabilized Unpaved Road. 

UNPAVED TRAFFIC AREAS: 

F.3.a Pave. 

F.3.b Apply Chemical Stabilization as directed by 

product manufacturer to control dust on Unpaved 

Roads. 

F.3.c Apply and maintain Gravel, 

recrushed/recycled asphalt or other material of 

low silt (<5%) content to a depth of three or more 

inches. 

F.3.d Wetting. Apply water one or more times daily. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-1

Exhibit F-IV – Fugitive Dust Comparison

Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 

Moderate Nonattainment Area Fugitive Dust, to Measures Adopted in Other Areas
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-2

In Exhibit F-IV, the Pinal County Fugitive Dust Rule is compared to applicable BACM requirements adopted for the Imperial County Air Pollution 

Control District (ICAPCD) in California. For some Pinal County rule sections, comparison is also made with applicable BACM requirements 

implemented in the San Joaquin Valley Air Pollution Control District (SJVAPCD) and South Coast Air Quality Management District (SCAQMD) in 

California, Clark County (CC), Nevada, Maricopa County (MC), Arizona, and with requirements in a Phoenix area (Maricopa County) RACM FIP

(40 CFR 52.128).

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

General Applicability

PCCR 4-1-010. General 

Applicability

Controls fugitive dust from nontraditional sources throughout the 

West Pinal PM10 nonattainment area:

 Open areas/vacant lots

 Unpaved roads

 Unpaved parking lots

 Paved public roadways 

The Phoenix FIP, 40 CFR 52.128,

has specific regulations for 

nontraditional sources of PM because 

rules at the time were not seen as 

sufficient:

 Unpaved parking lots

 Unpaved roads

 Vacant lots

Maricopa County has separate rules 

for construction. Maricopa does not 

have the statutory authority to 

regulate agricultural practices. Rule 

310.01 applies to non-traditional 

sources of fugitive dust such as 

disturbed open areas, unpaved 

parking lots, and unpaved roads.

Imperial County Rules 800-806 are 

generally applicable to any active 

operation, and/or man-made/caused 

condition or practice capable of 

generating fugitive dust. Active 

operations:

 Activities capable of 

generating fugitive dust, 

Pinal County and the Agricultural 

BMP committee have developed 

rules specific to construction and 

agricultural operations for fugitive 

dust caused by those operations in 

the West Pinal Nonattainment Area. 

The Fugitive Dust Rule applies to 

sources not covered under the 

Agriculture and Construction Rules.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-3

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

including but limited to those 

listed below

 Earthmoving activities

 Construction activities

 Unpaved roads

 Trackout/carryout

 Bulk material storage and 

transport

 Unpaved haul/access roads

San Joaquin Regulation VIII rules 

are applicable to specified outdoor 

fugitive sources such as:

 Carryout and trackout

 Open areas

 Paved roads

 Unpaved roads

 Unpaved vehicle and 

equipment traffic (lots for 

large special events)

South Coast’s fugitive dust Rule 403 

applies to any activity or man-made 

condition capable of generating 

fugitive dust. The County has a 

separate Rule 1186 applicable to 

specified land uses:

 Paved roads

 Unpaved roads

 Livestock operations

Exemptions

PCCR 4-1-015.  Legitimate vehicle test and FIP exemptions are case specific In general, the Pinal County rule is 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-4

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Exemptions development operations

 Emergency response 

acitivity by utility or 

government agency to 

restore critical function or to

prevent public injury. Does 

not apply in cases of poor 

design, operation, and lack 

of maintenance.

 Normal commercial farm 

cultural practices (precluded 

by statute and already 

covered in State agricultural 

regulations)

 Construction operations 

(already covered by another

construction specific rule)

 Landscaping without 

mechanized equipment 

(except grading or trenching)

 Sports and ensuing field use

within different source categories. 

[40 CFR 52.128(c)]

Maricopa County’s Rule 310.01 does 

not apply to:

 Agricultural practices 

(precluded by statute)

 dust generating operations 

otherwise covered in Rule 

310

 Emergency activities enacted 

to prevent public injury or to 

restore critical utilities

 Landscaping without 

mechanized equipment 

(except grading or trenching)

 Sports and ensuing field use

[MC Rule 310.01(103)]

 

San Joaquin Rules:

 Carryout and trackout caused 

by agricultural sources

 On-field agricultural sources

 Emergency activities (see 

definitions) performed to 

ensure health and safety 

(except those lasting more 

than 30 days as long as 

regulation would not limit 

emergency activity 

effectiveness)

 Activity by essential service 

utilities, up to an hour after 

consistent with other areas in that it 

exempts sources covered by other 

rules (e.g. construction and 

agriculture), non-mechanized 

landscaping, sport, and emergency 

activities.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-5

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

completion of activity

 Activities conducted at 3,000 

+ ft above sea level

 Any weed abatement activity 

utilizing mowing and/or 

cutting, and which leaves at

least three inches of stubble 

immediately after such 

mowing/cutting has 

occurred.

 Various exemptions for 

paved and unpaved road, 

unpaved vehicle/equipment 

traffic areas.

[SJVAPCD Rules 8011(4.0), 

8041(4.0), 8051(4.0), 

8061(4.0), 8071(4.0)]

Imperial County Rules:

 Actions required by Fed. or 

State endangered species act 

or court order or agency 

order

 Off-field agricultural sources 

necessary to responds to 

adverse effects on crops 

during freezing 

 Emergency maintenance of 

flood control channels and 

water spreading basins

 Emergency operation 

activities to ensure public 

health and safety (except 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-6

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

those lasting more than 30 

days as long as regulation 

would not limit emergency 

activity effectiveness)

 Permitted blasting operations

 Specific military training 

activities

 Agricultural Operations 

subject to Rule 806, 

Conservation Management 

Practices, are exempt from 

specified track-out, paved 

and unpaved road, and open 

area requirements.

 Any operation that operates 

no more than 10 days within 

a 90 days period is exempt 

from specified track-out 

requirements.

 Paved and unpaved 

driveways serving one single 

family residential dwelling.

[ICAPCD Rules 800(E), 

803(D), 804(D), 805(D)]

South Coast Fugitive Dust Rule:

 Diary farms

 CAFOs one acre or less

 Crop operations 10 acres or 

less

 Crop operations w/in the 

South Coast Air Basin more 

than 10 acres provided 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-7

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

certain conditions

 Emergency life-threatening 

situations or declared 

disaster or state of 

emergency

 Active operations by 

essential utilities during 

outages and emergency 

disruptions

 Any contractor subsequent to 

the time the contract ends, 

provided the contractor 

implemented the required 

control measures during 

contract period

 Weed abatement operations 

ordered by a governmental 

entity provided mowing 

maintains weeks at least 3 

inches above soil and any 

discing where water is used 

appropriately to prevent 

destabilization 

 Sandblasting operations

[SCAQMD Rule 403(g)]

South Coast Rule for Paved and 

Unpaved Roads and Livestock 

Operations:

 Public services in 

compliance with District 

Rule 403 

 Source specific and case 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-8

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

specific and/or threshold 

exemptions

 Livestock operations whose 

contiguous bounded areas do 

not exceed 10 acres

 Road shoulders as long as 

the area extending 8 ft from 

the pavement is landscaped 

and maintained with 

vegetative cover

[SCAQMD Rule 1186(g)]

Definitions (selected)

PCCR 4-1-020. 

Definitions

DUST SUPPRESSANT – As used 

in this Article, means water, 

hygroscopic material, solution of 

water and chemical surfactant foam, 

non-toxic chemical stabilizer or any 

other dust palliative, which is not 

prohibited by the U. S. 

Environmental Protection Agency 

(EPA) or the Arizona Department of 

Environmental Quality (ADEQ), or 

any applicable law, rule, or 

regulation, as a treatment material for 

reducing fugitive dust emissions.

San Joachin Rule Dust Suppressants

includes: water, hygroscopic 

materials, chemical stabilizers, and

suppression materials (see also 

Definition 3.4 “Chemical 

Stabilization/Suppression.”

[SJVAPCD Rule 8010(3.7)]

Chemical Stabilization/Suppression: 

a means of dust control implemented 

by any person to mitigate PM-10 

emissions by applying petroleum 

resins, asphaltic emulsions, acrylics, 

adhesives, or any other approved 

materials. [SJVAPCD Rule 

8010(3.4)]

Imperial County Construction rules 

do not explicitly define dust 

suppressant. Chemical 

Stabilization/Suppression definition 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-9

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

similar to San Joaquin. [ICAPCD 

Rules 800 and 801]

EMERGENCY– Sudden and 

reasonably unforeseeable events, 

including acts of God, requiring 

immediate corrective action causing 

unavoidable increases in 

emissions...does not include 

applicability to improperly designed 

equipment, lack of maintenance, 

careless or improper operation, or 

operator error.

Maricopa County Rule 310.01–

sudden and reasonably unforeseeable 

events, including acts of God, 

requiring immediate corrective 

action causing unavoidable increases 

in emissions...does not include 

applicability to improperly designed 

equipment, lack of maintenance, 

careless or improper operation, or 

operator error. [MC Rule 

310.01(210)]

San Joaquin Rule 8011–

Emergency activities are basically 

immediate government action 

necessary to protect public and 

timing makes rules impractical to 

follow. [SJVAPCD Rule 

8011(3.14)]

No definition in Imperial County 

Rule 804, Open Areas or Rule 805, 

Paved and Unpaved Roads but term

is employed in the General 

Requirements Rule. [ICAPCD Rule 

800(E)]

Pinal’s definition is restrictive to 

only those absolutely unavoidable 

instances, similar to Maricopa’s 

definition.

OPEN AREAS/VACANT LOTS –

- unsubdivided or 

undeveloped tract of land 

whether or not it is adjoining 

a developed or a partially 

Similar to the OPEN AREAS 

definition in Imperial County Rule 

800(C.29), the Pinal rule includes 

language that unsubdivided or 

undeveloped tracts do not have to be 

Pinal County rule is applicable in 

urban and rural areas resulting in 

greater coverage than found in the 

San Joaquin and Maricopa BACM 

rules. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-10

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

developed residential, 

industrial, institutional, 

governmental, or 

commercial area.

- subdivided residential, 

industrial, institutional, 

governmental, or 

commercial lot that contains 

no approved or permitted 

buildings or structures of a 

temporary or permanent 

nature.

- partially developed 

residential, industrial, 

institutional, governmental, 

or commercial lot and 

contiguous lots under 

common ownership.

adjoining a developed or a partially 

developed area. The San Joaquin 

Rule 8011(3.36) and Maricopa Rule 

310.01(221) exclude these “rural” 

areas from controls.

 

PAVE – As used in this Article, to

apply and maintain asphalt, concrete, 

or other similar material to a 

roadway surface, such as asphaltic 

concrete, concrete pavement, chip 

seal, or rubberized asphalt.

PAVED PUBLIC ROADWAY– a 

publicly owned paved roadway, 

owned by federal, state, county, 

municipal, or other government or 

quasi-governmental agencies as 

evidenced by a formal acceptance by 

the state or a political subdivision of 

the state of either:

a. An on-going maintenance 

Imperial Rule 805 and San Joaquin 

Rule 8061 include both public and 

private paved roadways. However, 

controls differ for each, depending 

on whether the roadway is new, 

modified, or existing. [ICAPCD 

Rules 800(C.31), 805(B), and 

805(F.4). SJVAPCD Rules 

8011(3.43) and 8061(5.1).]

The Pinal County paved public 

roadway definition is consistent with 

the application of controls for 

unpaved public roads in the Phoenix 

RACM FIP.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-11

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

obligation for the roadway; or

b. A title or easement for the 

roadway.

The Phoenix area RACM FIP limits 

control of unpaved roads to roads 

owned by governmental or quasigovernmental agencies. [40 CFR 

52.128(b)(18)]

PINAL COUNTY DUST 

CONTROL FORECAST– a 

forecast, to identify a low, moderate 

or high risk of dust generation

considering:

- Wind speed and direction,

- Stagnation,

- Recent precipitation, and

- Potential for precipitation,

- Existing pollutant 

concentrations, and

- historic recorded concentrations 

during similar conditions

No reviewed rules applicable to the 

covered source categories contained 

provisions for risk forecasting.

The Pinal County rule provides a 

strategy for implementing preventive 

controls prior to high wind or 

stagnant meteorological conditions 

(see Rule Section 4-1-030(2)).

STABILIZED – As used in this 

Article, means any previously 

DISTURBED SURFACE AREA 

which, through the application of 

CONTROL MEASURES, shows 

visual or other evidence of surface 

crusting and is resistant to winddriven fugitive dust.

Imperial Rule 800 defines 

“Stabilized Surface” and “Stabilized 

Unpaved Road.” Stabilized Surface 

must meet one of the specified 

conditions: visible crust, listed 

threshold friction velocity, flat 

vegetative cover of at least 50 

percent, standing vegetative cover of 

at least 30 percent, etc. Stabilized 

road visible dust is limited to 20% 

opacity. [ICAPCD Rule 800(C.37) 

and 800(C.38)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-12

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

UNPAVED LOT– any area that is 

not paved and that is used for 

parking, maneuvering, material 

handling, or storing motor vehicles 

and equipment. An unpaved parking 

lot includes, but is not limited to, 

automobile impound yards, wrecking 

yards, automobile dismantling yards, 

salvage yards, material handling 

yards, and storage yards. For the 

purpose of this rule, maneuvering 

shall not include military maneuvers 

or exercises conducted on federal 

facilities.

Phoenix RACM FIP– privately or 

publicly owned or operated area 

utilized for parking vehicles that is

not paved and is not a Low Use

Unpaved Parking Lot. [40 CFR 

52.128(b)(17)]

Imperial County Rule 800 unpaved 

traffic area definition includes 

parking, storage, and conveyances. 

[ICAPCD Rule 800(C.45)]

San Joaquin Rule 8071 unpaved 

vehicle/equipment traffic area 

definition excludes residential areas. 

[SJVAPCD Rule 8011(3.66)]

Maricopa Rule 310.01 – same 

definition for unpaved parking lots. 

[MC Rule 310.01(230)]

Pinal rule definition is broader in 

scope than the RACM FIP to 

explicitly apply to storage, 

maneuvering, and handling areas. 

UNPAVED ROAD– any roads, 

equipment paths, or travel ways that 

are not PAVED. Unpaved roads are 

owned only by federal, state, county, 

municipal, or other governmental or 

quasi-governmental agencies. For 

the purposes of this Article, an 

unpaved road is not an agricultural 

road, horse trail, hiking path, bicycle 

path, or other similar path used 

exclusively for purposes other than 

travel by MOTOR VEHICLES.

The Phoenix RACM FIP defines as 

and limits control of unpaved roads 

to roads owned by governmental or 

quasi-governmental agencies. [40 

CFR 52.128(b)(18)]

Maricopa Rule 310.01 only 

addresses public unpaved roads. 

[MC Rule 310.01(231)]

Imperial Rule 805 and San Joaquin 

Rule 8061 both apply to public and 

private unpaved roads, however, 

The Pinal County definition and 

applicability for unpaved public 

roads is consistent with the Phoenix 

RACM FIP and Maricopa County 

SIP. Private agricultural and 

irrigation district roads and 

construction roads are included in 

control strategies contained in 

separate rules applicable to the West 

Pinal planning area (see Sections 4.1 

and 4.2).
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-13

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

control requirements depend on 

whether the road is new or existing. 

[ICAPCD Rules 800(C.44), 805(B), 

and 805(E). SJVAPCD Rules 

8011(3.64), 8061(2.0), and 

8061(5.2).]

Standards

PCCR 4-1-030(1) 

General Requirements

• The OWNER AND/OR 

OPERATOR of applicable sources is

subject to the standards and/or 

requirements described in this rule. 

Failure to comply with any such 

standards and/or requirements is 

deemed a violation of this rule.

• The OWNER AND/OR 

OPERATOR is required to

implement applicable CONTROL 

MEASURES.

• CONTROL MEASURES are 

required to be implemented to meet 

the visible emissions requirements, 

stabilization requirements and 

compliance determinations for each 

applicable category.

• Failure to implement CONTROL 

MEASURES as required by the rule, 

as applicable and/or failure to 

maintain stabilization in order to 

prevent wind erosion as measured by 

the requirements of this rule shall be 

deemed a violation of this rule.

PCCR 4-1-030(2) Open Visible Emissions and Stabilization South Coast Rule 403: no visible Pinal County visible emissions 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-14

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Areas/Vacant Lots Requirements: limits opacity of 

fugitive dust to 20%. Test method 

per § 4-9-340 or equivalent approved 

by control officer and EPA.

dust beyond property line, or 20% 

opacity if dust due to motorized 

vehicle. [SCAQMD Rule 403(d)]

Imperial County Rule 804: 20% 

opacity. [ICAPCD Rule 804(E.1)]

San Joaquin Rule 8051: 20% opacity. 

[SJVAPCD Rule 8051(5.0)]

Maricopa County Rule 310.01: no 

visible emissions beyond property 

line. [MC Rule 310.01(302.4) and 

310.01(302.5)]

Clark County Rule 90: visible crust 

etc. [CC Rule 90(90.2.1.2)]

Phoenix RACM FIP: visible crust 

etc. [40 CFR 52.128(b)(16)]

requirements are as or more stringent 

than other district BACM rules. 

Upon evidence of trespass requires 

installation of no trespass signs or

effective physical barriers (curbs, 

fences, gates, posts, shrubs, trees, 

etc.)

San Joaquin rule 8051: upon 

evidence of trespass, no time frame; 

similar measures. [SJVAPCD Rule 

8051(5.0)]

Imperial County rule 804: 30 day 

timeframe after initial discovery; 

similar controls. [ICAPCD Rule 

804(E.2)]

Phoenix RACM FIP: 60 days after 

initial determination of disturbance; 

physical barrier or stabilization (e.g. 

Pinal rule requires owner/operator 

vigilance (“upon evidence” vs. “after 

discovery”).
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-15

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

gravel). [40 CFR 52.128(d)(4)(iii)]

Open Areas/Vacant Lots 1.0 acre or 

larger with 0.5 acre or larger 

Disturbed Surface Area are required 

to apply one Control Measure to 

stabilize:

- water or dust suppressant

- vegetation

- pavement

- gravel

- chemical/organic 

stabilizers/suppressants

- alternative approved by EPA

Imperial County Rule 804: any open 

area 0.5 acres or more within urban 

areas or 3.0 acres or more within 

rural areas and contains at least 1000 

square feet (0.02 acre) of disturbed 

surface area; similar controls. 

[ICAPCD Rule 804(B) and 804(F)]

San Joaquin Rule 8051: rule applies 

to any open area having 0.5 acres or 

more within urban areas, or 3.0 acres 

or more within rural areas; and 

contains at least 1000 square feet of 

disturbed surface area; similar 

controls. [SJVAPCD Rule 

8051(5.0)]

Maricopa County Rule 310.01: 

threshold for certain control elements 

on open areas and vacant lots 0.10 

acre (4,356 square feet) or larger and 

have a cumulative of 500 square feet 

or more that are disturbed; similar 

measures. [MC Rule 310.01(302.4) 

and 310.01(302.5)]

Clark County Rule 90: applicable to 

OPEN AREAS AND VACANT 

LOTS that are 5,000 square feet or 

larger and are disturbed by any 

means; specifies surface gravel or 

dust palliatives for motor vehicle 

The Pinal County applicability 

threshold is generally larger than 

reviewed urban area strategies, 

however, because the Pinal County 

threshold is the same for urban and 

rural areas, the rule likely obtains 

greater coverage and emissions 

reductions than most BACM in rural 

areas. The West Pinal nonattainment 

area has a comparatively larger rural 

portion than some other areas (e.g., 

Maricopa/Phoenix) so the rural 

coverage is relatively more 

important.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-16

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

disturbance. Additional measures 

(dust mitigation plan) for open areas 

and vacant lots with cumulative area 

of 10,000 acres or greater. [CC Rule 

90(90.2.1.2) and 90(90.2.2)]

South Coast Rule 403: no size 

threshold. [SCAQMD Rule 403]

Phoenix RACM FIP : applies to open 

areas/vacant lots disturbed by motor 

vehicle traffic 5,000 square feet or 

larger and vacant lots (not disturbed 

by motor vehicles) with 0.5 acre or 

larger disturbed surface area; similar 

measures include restoration to 

natural state and approved 

alternative. [40 CFR 

52.128(d)(4)(ii)]

Open Areas/Vacant Lots 1.0 acre or 

larger with 0.5 acre or larger 

Disturbed Surface Area. Within 30 

days of discovery of disturbance 

required to receive Pinal County 

Dust Control Forecast. Required to 

stabilize area the day before and the 

day that is forecast as high risk for 

PM10 emissions.

No comparable requirement in 

Imperial County Rule 804 or San 

Joaquin Rule 8051.

More stringent than BACM 

requirements in Imperial County and 

San Joaquin Valley. Forecast and 

stabilization requirements target days 

with the most potential for elevated 

PM10. 

Pinal rule requires that open 

areas/vacant lots be stabilized prior 

to (the day before) and the day that is 

forecast to be high risk for dust 

emissions (includes high wind and 

stagnation events). 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-17

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Rule is reliant on the high risk 

forecast which provides more 

protection on high risk days when 

predicted winds may be below a 25 

mph threshold (Imperial’s 

construction rule threshhold). 

According to Arizona Revised 

Statutes (ARS) § 49-424(11), when 

developing the forecast, the 

Department is required to evaluate –

(a) Projected meteorological 

conditions for the nonattainment 

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 

pollution at the time of the forecast.

(c) Historic air pollution 

concentrations that have been 

observed during meteorological 

conditions similar to those that are 

predicted to occur in the forecast.

Prohibits blading, disking, plowing 

to remove vegetation unless 

implementing all of the following:

- dust suppressant prior to or 

during weed abatement

- prevent trackout

- suppressant, gravel, 

compaction, or alternative 

measure to stabilize 

Phoenix RACM FIP: same measures 

as Pinal County. [40 CFR 

52.128(d)(4)(i)]

The Pinal rule is as stringent as the

Phoenix RACM FIP.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-18

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

following weed abatement

Compliance with stabilization 

determined by:

- visible crust per drop ball 

test (§ 4-9-320.B.1); or

- Threshold Friction Velocity 

(TFV), corrected for nonerodible elements, of 100 

cm/second or higher 

determined by test method in 

Article 9 (§4-9-320.B.2); or

- Flat vegetation cover equal 

to at least 50 percent 

determined by test method in 

Article 9 (§4-9-320.B.3); or

- Standing vegetation cover 

equal to or greater than 30 

percent determined by test 

method in Article 9 (§ 4-9-

320.B.4); or

- Standing vegetation cover 

equal to or greater than 10 

percent determined by test 

method in Article 9 (§4-9-

320.B.4) where threshold 

friction velocity, corrected 

for non-erodible elements, is 

equal to or greater than 43 

cm/second.

Stabilization parameters similar to 

Phoenix RACM FIP and Maricopa 

County Rule 310.01 Section 501.3. 

[40 CFR 52.128(b)(16)]

The Pinal rule is as stringent as the 

Phoenix RACM FIP.

PCCR 4-1-030(3) 

Unpaved Lots

An applicable unpaved lot is any 

unpaved lot greater than 5,000 ft2

used for parking, maneuvering, 

material handling, or storing motor 

The Phoenix RACM FIP, 40 CFR 

52.128, is most similar to this rule. 

The rule only defines lots for parking 

vehicles (see definition in PCCR 4-1-

The Pinal County Rule applicability 

threshold is the same as the RACM 

FIP but does not include the FIP

exemption for low use parking lots. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-19

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

vehicles and equipment. 

Owner/Operator shall :

1. not cause opacity to exceed 

20% AND shall not allow 

silt loading to equal or 

exceed .33 oz/ft2 but if it 

does, owner or operator shall 

not allow silt content to 

exceed 8%; and 

2. shall implement control 

measures sufficient to 

maintain a stabilized surface. 

(pave, dust suppressant 

including water and 

chemical stabilizers, gravel, 

alternative approved by 

EPA).

020 above) and exempts lots 5,000 

ft2 or less. The FIP requires 20% 

opacity and application of controls 

(pave, chemical stabilizers, gravel, or 

approved alternative). [40 CFR 

52.128(b)(17), 52.128 (c), and 

52.128 (d)]

The rule also includes exemptions 

for low use parking lots on days 

when 10 or fewer vehicles enter a 

lot; non-routine or emergency 

maintenance of flood control 

channels and basins; vehicle test and 

development. Owners and operators 

of unpaved parking lots when 

vehicles are parked no more than 35 

days per year, shall implement one of 

the listed control measures on day(s) 

in which over 100 vehicles enter the 

lot. [40 CFR 52.128(b)(8), 

52.128(b)(17), 52.128 (c), and 

52.128 (d)]

Maricopa Rule 310.01 contains the

same definition for unpaved parking 

lots. Maricopa has different control 

measures for lots used 35 plus

days/year versus lots used less than 

35days/year. Also, residential areas 

are treated differently and have a 

3,000 ft2applicability threshold. 

[MC Rule 310.01(302.6)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-20

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

San Joaquin’s Rule 8071 exempts 

unpaved vehicle and equipment 

traffic areas with less than 50 

Average Annual Daily Trips 

(AADT) from control. For other 

areas, applicable measures include 

watering, gravel, chemical 

stabilizers, and paving. Notification 

and stabilization measures apply for 

special events with 1,000 + vehicles 

(Section 5.1.4).

PCCR 4-1-030(4) 

Unpaved Roads

A. The owner and/or operator of 

UNPAVED ROADS with average 

daily trips (ADT) greater than 150 (A 

traffic count shall measure MOTOR 

VEHICLE traffic over a 48-hour 

period, which may consist of two 

non-consecutive 24-hour periods. 

MOTOR VEHICLE traffic shall be 

measured continuously during each 

24-hour period.) is subject to the 

requirements described in 4-1-

030.4.A.i and shall comply with one 

of the CONTROL MEASURES 

described in 4-1-030.4.A.ii:

i. Visible Emissions Requirements 

and Stabilization Requirements: The 

Owner and/or Operator of 

UNPAVED ROADS shall not cause 

or allow visible fugitive dust 

Applicability Threshold

San Joaquin Rule 8061: Control 

threshold of 26 or more Annual 

Average Daily Trips (AADT). 

Threshold does not apply to 

incremental paving of existing 

unpaved roads. [SJVAPCD Rule 

8061(4.0)]

South Coast Rule 1186: Unpaved 

roads that have greater than the 

average ADT of all unpaved roads in 

its jurisdiction. [SCAQMD Rule 

1186(d)(5)]

Imperial County Rule 805: Unpaved 

road segment with 50 or more 

Average Vehicle Trips per Day. 

[ICAPCD Rule 805(E.2) and (E.7)]

Applicability Threshold

The Phoenix RACM FIP (40 CFR 

52.128) contains an average daily 

traffic (ADT) threshold of 250. 

Reviewed BACM level rules range 

from 26 to 150 vehicles per day. The 

Pinal County 150 ADT threshold is 

at a level between those found in 

reviewed RACM and BACM rules.

Visible Emissions and Stabilization

The Pinal County rule is as stringent 

as reviewd RACM and BACM rules.

Control Measures and Compliance 

Schedule

Consistent with the Phoenix RACM 

FIP and South Coast Rule 1186, 

measures in the PinalCounty Fugitive 

Dust Rule are applicable to public 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-21

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

emissions to exceed 20% opacity as 

measured using an opacity method,

as determined by the applicable test 

method in §4-9-340 or an equivalent 

test method approved in writing by 

the Control Officer and the EPA 

Administrator and shall not allow silt 

loading equal to or greater than 0.33 

oz/ft2 as determined by the 

applicable test method in §4-9-

320.A.1. However, if silt loading is 

equal to or greater than 0.33 oz/ft2, 

then the owner and/or operator shall 

not allow the silt content to exceed 

6%;

ii. CONTROL MEASURES:

a. Pave; or

b. Apply and maintain DUST 

SUPPRESANTS other than water; or

c. Uniformly apply and maintain 

surface gravel

B. CONTROL MEASURE(s) in 4-1-

030.4.A.ii shall be considered 

effectively implemented when:

i. One of the CONTROL 

MEASURES described in 4-1-

030.4.A.ii is annually implemented 

on 15 miles per year of UNPAVED 

ROADS having ADT of 150 or 

more.

a. When the CONTROL MEASURE 

Maricopa County Rule 310.01: 

Unpaved roads and Alleys with 150 

vehicle trips per day. [MC Rule 

310.01(302.7)]

Clark County Rule 91: Existing 

unpaved roads with 150 vehicles per 

day; “non-federal” requirement for 

roads below threshold. [CC Rule 

91(91.2.1.1.1)]

Phoenix RACM FIP: Unpaved roads 

with ADT of 250 or greater. [40 

CFR 52.128(d)(3)]

Visible Emissions and Stabilization

San Joaquin Rule 8061: Rule limits 

emissions to 20 percent opacity for 

roads with 26 or more AADT. 

[SJVAPCD Rule 8061(5.2)]

South Coast Rule 1186: No opacity 

limit. [SCAQMD Rule 1186]

Imperial County Rule 805: Rule 

limits emissions to 20 percent 

opacity for roads with 50 or more 

average vehicle trips per day. 

[ICAPCD Rule 805(E.2)]

Maricopa County Rule 310.01: 20% 

opacity; does not allow silt loading 

equal to or greater than 0.33 oz/ft2. 

unpaved roads (see definition of 

unpaved road at PCCR 4-1-020

above). Measures applicable to 

private unpaved roads are included in 

the Pinal County Construction and 

Agricultures Rules (see Sections 4.1 

and 4.2). 

The Pinal County rule contains an 

incremental implementation schedule

which is satisfied when control 

measures are applied on 15 miles of 

road annually. Some BACM rules

require any listed control on roads 

above the established threshold with 

incremental paving of selected public 

roads. Others require a tiered 

approach for application of controls 

which are incrementally applied over 

a number of years (e.g., South Coast 

Rule 1186). See Section 4.3.7 for 

further discussion of Pinal County’s 

unpaved road provisions.

Equivalence Method

Other reviewed rules did not contain 

an equivalence method. The 

equivalency method allows for more 

flexibility but is still just as stringent, 

since it produces the same emissions 

reductions. It’s comparable to a 1-

to-1 offset credit system. 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-22

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

is application and maintenance of 

DUST SUPPRESANTS other than 

water, the application and 

maintenance of the DUST 

SUPPRESANTS shall only be 

counted towards the 15 mile 

threshold when:

1. Done on UNPAVED ROADS 

previously untreated, and

2. Application and maintenance of 

DUST SUPPRESANTS on 

UNPAVED ROADS previously 

treated continues annually until the 

UNPAVED ROAD is paved.

ii. For year 2019 and beyond, 

CONTROL MEASURES applied on 

UNPAVED ROADS with less than 

150 ADT can be used for compliance 

with 4-1-030.4.B.i through use of the 

following equivalency conversion. 

[see rule for conversion table]

However, if silt loading is equal to or 

greater than 0.33 oz/ft2, then the 

owner and/or operator shall not allow 

the silt content to exceed 6%. [MC 

Rule 310.01(302.7)]

Clark County Rule 91: 20% opacity. 

[CC Rule 91(91.2.1.4)]

Phoenix RACM FIP: 20% opacity; 

similar silt loading requirements. [40 

CFR 52.128(b)(16)]

Control Measures and Compliance 

Schedule

San Joaquin Rule 8061: Includes 

measures for existing public and 

private unpaved roads above 

threshold. Requires compliance with 

stabilization measures: watering, 

gravel, stabilizers/suppressants, 

roadmix, paving, or other approved 

method. Includes a schedule to pave 

an average of 20 percent annually of 

all existing public unpaved roads. 

Must show incremental progress on 

paving (average of 20% annually up 

to 5 miles in any urban area). Rule 

also requires a maximum speed limit 

of 25 mph on each unpaved road 

with 26 AADT. Prohibits 

construction of new unpaved roads in 

urban areas (5.2.2). [SJVAPCD Rule 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-23

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

8061(5.2)]

South Coast Rule 1186: The 

owner/operator of unpaved public 

roads is required to pave minimum of 

1 mile, chemically stabilize 2 miles, 

speed restrictions (signage, speed 

bumps) on 3 miles. Applied each 

year of 8 year period (per 

owner/operator); treatment in excess 

of annual requirement can be 

credited toward future year. 

[SCAQMD Rule 1186(d)(5)]

Imperial County Rule 805: Imperial 

Rule 805 applies to any new or 

existing public or private Unpaved 

Road. Requires compliance with 

stabilization measures: pave, 

chemical stabilizers, watering, 

gravel, road closure, or other 

approved method. Includes a 

schedule to pave an average of 10 

percent annualy of all existing public 

unpaved roads. Prohibits 

construction of new unpaved roads in 

urban areas. [ICAPCD Rule 

805(E.2), (E.3), and (E.7)]

Maricopa County Rule 310.01: Pave, 

dust suppressants other than water, 

gravel. Control measures effectively 

implemented when unpaved roadway 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-24

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

meets visible emissions and 

stabilization requirements or listed 

control measures are implemented 

and maintained on 5 miles of 

unpaved roadway (within one 

calendar year). [MC Rule 

310.01(302.7)]

Clark County Rule 91: Pave, dust 

palliative, or alternative approved by 

EPA. Restrictions on new unpaved 

roads. Graduated implementation 

schedule (1/3, 2/3, 3/3) of eligible 

roadways dependant on year built 

and geographic area. [CC Rule 

91(91.2.1.1.1) and (91.2.1.3)]

Phoenix RACM FIP: Pave, 

stabilizers, gravel. Implemented on 

all eligible public roadways by date 

certain (2 years). [40 CFR 

52.128(d)(3)]

PCCR 4-1-030(5) Paved 

Public Roadway

Deposition on Road/Trackout

Upon discovery of mud/dirt on a 

paved public roadway that extends 

50 feet or more from the nearest 

unpaved surface exit, the owner or 

operator of the property from which 

the deposition came from shall, 

within 24 hours of the discovery, 

remove the dirt/mud from the paved 

public roadway and restrict traffic, if 

necessary, until the material can be 

Deposition on Road/Trackout 

San Joaquin’s rule 8061 regulates the 

agency with the primary 

responsibility of clean-up, where as 

Pinal regulates the owner and/or 

operator of the land from which the 

trackout or erosion came. 

San Joaquin’s mandates following 

dust minimizing practices during 

removal, where as Pinal avoids any 

Deposition on Road/Trackout 

Pinal’s trackout section of the rule is 

based on San Joaquin’s rule 8061 

section 5.1.3 and Maricopa’s rule 

310.01. 

Road Shoulders

The Pinal County rule requires 

stabilization of road shoulders

similar to South Coast’s measures for 

road shoulder maintenance.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-25

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

removed. 

Material should be removed so as not 

to cause another source of dust. If 

conditions are unsafe to restrict 

traffic and removal isn’t possible due 

to weekend or holiday, time to 

remove may be extended.

Road Shoulders

The OWNER AND/OR 

OPERATOR of any existing PAVED 

PUBLIC ROADWAYs shall take the 

following actions prior to, during and 

after work on unpaved road 

shoulders: Apply a DUST 

SUPPRESSANT(s) to the total 

surface area subject to the 

disturbance in sufficient quantity and 

frequency to maintain a stabilized 

surface.

ambiguity by saying that in the 

course of removal of dirt, an owner 

or operator of the source of dirt must 

remove it so as not to cause a source 

of fugitive dust (this is similar to 

Maricopa’s rule). San Joaquin also 

requires removal of mud/dirt from 

paved shoulders. [SJVAPCD Rule 

8061(5.1.3)]

There are two separate Maricopa 

County rules for erosion caused 

deposition onto paved roadways 

(310.01) and for trackout onto paved 

roadways (310). Maricopa County’s 

rule 310.01 is similar to San 

Joaquin’s and Pinal’s rule as it 

pertains to erosion caused deposition. 

Maricopa County Rule 310.01 

Section 302.9 is similar to the Pinal 

Rule but requires removal of erosion 

caused deposition using appropriate 

control measures prior to the 

resumption of traffic on the roadway. 

Rule 310 Section 306.2 is not 

applicable here. 

South Coast’s Rule 1186 requires 

any owner or operator of a paved 

public road to remove visible 

material within 72 hours of 

notification and if it cannot be 

completed within 10 days, the 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-26

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

owner/operator shall notify and 

provide location information and 

expected clean-up date. Exemption 

for accumulations on roads with 

fewer than 500 ADT; closed roads; 

during a Governor declared State of 

Emergency, but done as soon as 

feasible. Government contracts for 

street sweeping shall use only 

certified sweeping equipment. 

[SCAQMD Rule 1186(d)(1) through 

(d)(4)]

Road Shoulders

San Joaquin Rule 8061, requires 

curbing or paving of shoulders for 

new or modified roads. Alternative 

includes vegetation or 

chemical/organic dust 

suppressants/stabilizers. Controls for 

new or modified public or private 

paved roads include paving or 

stabilizing shoulders to a width of 4 

or 8 feet or to limit of right-of-way 

whichever is less depending on the 

AADT. Requires paving or 

stabilizing 4-foot shoulders for 50 

percent of existing paved public 

roads with the highest AADT in 

urban areas and 25 percent of 

existing paved public roads with the 

highest AADT in rural areas. . 

[SJVAPCD Rule 8061(5.1)]
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-27

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Imperial County Rule 805: Controls 

for new or modified public or private 

paved roads include paving, curbing, 

vegetation, or chemically stabilizing 

shoulders to a width of 2, 4, or 6 feet 

or to limit of right-of-way whichever 

is less depending on the type of road 

and annual average daily vehicle 

trips (AADVT). Includes additional

provisions for medians. [ICAQCD 

Rule 805(F.4)]

South Coast Rule 1186: Beginning in 

January 2006, new construction or 

widening of paved roads must meet 

specified curb and shoulder 

requirements and pave medians (4 or 

8 foot shoulder width depending on 

average daily traffic). [SCAQMD 

Rule 1186(d)(4)]

[South Coast Rule 403 includes 

BACM measures for road shoulder 

maintenance (water prior to clearing, 

chemical suppressants and/or washed 

gravel to maintain a stabilized 

surface after shoulder maintenance). 

Guidance encourages curbing or 

paving. Applicable to all 

construction activity sources.]

Clark County Rule 93: Requires 
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-28

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

paving, curbing, gravel, or dust 

pallliatives to a width of 4 or 8 feet 

for new or modified public or private 

paved roads. Requires reconstruction 

of existing nonconforming roads 

within one year. [CC Rule 93(93.2)]

RACM in Appendix C.1 of the 

General Preamble requires curbing 

and pave or stabilize (chemically or 

with vegetation) shoulders of paved 

roads.

Recordkeeping

PCCR 4-1-040. 

Recordkeeping

Any person subject to the 

requirements of this rule shall 

compile and retain records that 

provide evidence of CONTROL 

MEASURE application (i.e. receipts 

and/or purchase records). Such 

person shall describe in the records, 

the type of treatment or CONTROL 

MEASURE, extent of coverage, and 

date applied. Upon verbal or written 

request by the Control Officer, such 

person shall provide the records and 

supporting documentation as soon as 

possible but no later than 48 hours, 

excluding weekends. If the Control 

Officer is at the site where requested 

records are kept, such person shall 

provide the records without delay.

San Joaquin Rule 8011(6.2) -

General Requirements: Additional 

requirements for manufacturer’s dust 

suppressant product information 

sheet that identifies the name of the 

dust suppressant and application 

instructions. Records shall be 

provided upon request. 

Imperial County Rule 804(G) Open 

Areas: Similar recordkeeping 

requirements. Records shall be 

provided upon request. Imperial 

County Rule 805(G) Paved and 

Unpaved Roads: Similar 

recordkeeping requirements. Records 

shall be provided upon request. 

Clark County SECTION [Rule] 90 

(90.3.1): FUGITIVE DUST FROM 

The Pinal County rule is generally 

consistent with other district 

requirements.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-29

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

OPEN AREAS AND VACANT 

LOTS: Similar recordkeeping 

requirements. Documents made 

available within 24 hours of written 

request. Clark County SECTION 92 

(92.5.1): FUGITIVE DUST FROM 

UNPAVED PARKING LOTS AND 

STORAGE AREAS: Similar 

recordkeeping requirements. 

Documents made available within 24 

hours of written request.

Reporting Requirements

PCCR 4-1-045. Reporting 

Requirements

Requires each city, county, or state 

agency with primary responsibility 

for any existing PAVED PUBLIC 

ROADWAY and UNPAVED 

ROADS to take the following 

actions:

A. By January 30 of each year 

provide the DISTRICT with a list of 

all UNPAVED ROADS under its 

jurisdiction, including data on length 

of, and ADT (if available) on, each 

UNPAVED ROAD segment.

B. By January 30 of each year, 

submit to the District a list of 

UNPAVED ROADS which were 

paved during the previous year 

including the total number of 

UNPAVED ROADS miles and their 

respective segments.

San Joaquin Rule 8061 - Paved and 

Unpaved Roads: Requires annual 

reporting of progress until 2010 then 

every 2 years. [SJVAPCD Rule 

8061(6.2)]

Imperial County Rule 805 – Paved 

and Unpaved Roads: Requires annual 

reporting of progress until all roads 

above threshold stabilized (10 years). 

[ICAPCD Rule 805(E.7)]

Maricopa County Rule 310.01: No 

requirement.

Clark County Rule 91: Requires 

annual reporting of progress until all 

roads above threshold stabilized (3 

years). [CC Rule 91(91.3.3)]

Phoenix RACM FIP: Requires 

The Pinal County rule is similar to 

other district requirements.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-30

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

agency survey of progress every 

three years. [40 CFR 52.128(e)]

Record Retention

PCCR 4-1-050. Record 

Retention

Copies of the records required by 4-

1-040 (Recordkeeping) and 4-1-045 

(Reporting) of this rule shall be 

retained for at least two years.

San Joaquin Rule 8011(6.2) -

General Requirements: Requires 

record retention for 1 year after 

termination of dust generating 

activities. SAN JOAQUIN RULE 

8061(6.2) - PAVED AND 

UNPAVED ROADS: Also requires 

reporting of progress every 2 years.

Imperial County Rule 804(G) Open 

Areas: Requires record retention for 

2 years. Imperial County Rule 

805(G) Paved and Unpaved Roads: 

Requires record retention for 2 years. 

Additional progress reporting 

requirements.

Clark County Section [Rule] 90 

(90.3.2): Fugitive Dust From Open 

Areas and Vacant Lots:Requires 

retension for 1 year. Clark County 

Section [Rule] 92 (92.5.2): Fugitive 

Dust From Unpaved Parking Lots 

and Storage Areas: Requires 

retention for at least 1 year.

Maricopa County Rule 310.01(503): 

Requires retension of records for at 

least 2 years.

The Pinal County rule is generally 

consistent with other district 

requirements.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-31

Exhibit F-IV: Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area 

Fugitive Dust, with Measures Adopted in Other Areas

West Pinal Rule Section West Pinal Rule Requirement Other District Measures Evaluation

Violations

PCCR 4-1-060. 

Violations

Failure by any person to comply with 

the applicable requirements of this 

Article shall constitute a violation 

subject to penalty as provided in 

these rules and A.R.S. Title 49, 

Chapter 3, Article 3, A.R.S. 49-471 

et. seq.

Violation Exemptions:

A. The opacity requirements of this 

rule shall not apply during:

i. Wind conditions that cause 

FUGITIVE DUST to exceed the 

opacity requirements if applicable 

CONTROL MEASURES are 

implemented, applied and 

maintained, and all dust contributing 

DISTURBED SURFACE AREAs 

are stabilized.

ii. EMERGENCY maintenance of 

flood control channels and water 

retention basins if at least 1 

applicable CONTROL MEASURE is 

applied, and maintained.

Imperial County Rule 804(H) Open 

Areas: Similar requirement. No 

violation exemption for wind 

conditions. Imperial County Rule 

805(H) Paved and Unpaved Roads: 

Similar requirement. No violation 

exemption for wind conditions.
December 21, 2015 Final West Pinal PM10 RACM Analysis FIV-32

(This page intentionally left blank.)
December 21, 2015 Final West Pinal PM10 RACM Analysis FV-1

Exhibit F-V –Information On a Gallons per Head Standard Providing More Benefits over a Strict 

Moisture Percentage for Feed Yard Pens

Emailed Attachment from Bas Aja of Arizona Cattlemen’s Association
December 21, 2015 Final West Pinal PM10 RACM Analysis FV-2

Information on a Gallons per Head Standard Providing More 

Benefits over a Strict Moisture Percentage for Feed Yard Pens

Background

Between 2009 and 2012 we conducted many different trials on sprinkling water to reduce dust emissions 

from feed yard pen surfaces, moving alleys and roadways. These trials revolved around varying the 

amount of water sprinkled, the time of day sprinkled, targeting locations in the pens and spray angle 

degree. We implemented these various components and then we contrasted them with the actual emission 

measurements at the monitor. This trial and error study informed us about the most effective amount 

(depending on meteorological conditions and season), the most effective time of day, and the most 

effective locations within the pen surface. 

Arizona’s regulatory scheme for groundwater use in the Pinal Active Management Area (AMA) 

maintains a strict standard of 20 gallons per day – per head groundwater use for feed yards (ARS Title 45 

AMA Rules). This includes water necessary for processing feed, water consumed by livestock and water 

use for dust suppression. The current experience in feed yards located in Pinal County demonstrates we 

are right at this conservation limit when we utilize the 3 – 6 gallons per head/per day for pen surface dust 

suppression. During the highest months of soil evaporation – between May and September – we are 

pressed up against this conservation limit nearly daily.

While we learned the most effective and efficient methods for suppressing emissions we also learned the 

physical limits of specifically targeting dust suppression. For instance: we learned that in the late 

afternoon and evenings most of the emissions were arising from the back of them pens (opposite from the 

feeding area of the pens). We worked to target these areas to be at peak moisture late in the afternoon and 

we more specifically targeted these areas with the degree angle (and launch points) that provided the 

greatest results as measured at the monitor. However, we discovered that we could not just start targeting 

these areas late in the afternoon as water volume limits, and tight timeframes did not allow us to get the 

full coverage that best suppressed emissions. Therefore, we begin application of more water earlier in the 

day to try and “bank” moisture in these areas that cannot all get water sprayed on them between 5:00 and 

9:00 pm.

Creating a single number percentage moisture across the full pen surface is not the best method to reduce 

emissions. As stated earlier it is sub-locations within the pens at certain times of day. In addition, the 

extreme weather and climate conditions in Arizona during the May to September time frame makes it cost 

prohibitive and impossible to maintain a single consistent moisture percentage across the full pen surface. 

This is why we attempt to “bank” moisture in some pens earlier in the day. Creating a single number 

uniform standard across 100 percent of pen surface would require a 10 percent over application as parts of 

pen will be under shade, near water source or in areas of high urination - studies demonstrate that in 

evening it's the back of pens (away from feed source) that create most emissions which get compressed by 

nighttime lowering of the atmospheric ceiling.

The extreme costs of trying to sample across 6-8 locations of each pen surface (to get a true reading of 

pen moisture levels this would be required) is prohibitive to maintenance and management. In addition, it 

is unsafe to expose on foot personnel to over 100 animals that weigh over 1,400 pounds in each pen. 

Such a program would violate the safety plans of our feed yards.