This document was developed with the assistance of:
Sierra Res earch Inc.
1801 J Street Sacramento, CA 95811



## Appendix F

RACM Analysis for the West Pinal County PM 10 Nonattainment Area

Arizona Department of Environmental Quality

Final December 21 , 2015(This page intentionally left blank.)December 21 , 2015 Final West Pinal PM10 RACM Analysis i TABLE OF CONTENTS LIST OF TABLES

................................ ................................ ................................ ................................ ..... iii

1.0 INTROD UCTION

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

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

................................ ................................ ................................ ................................ .... 1
1.2.1 R ACM/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 PM 10 NONATTAINMENT AREA

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

................................ ..................... 4 2.2 Description of Significant Sources

................................ ................................ ................................ ..... 8
2.3 PM 10 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 Regulat ion

................................ ................................ ................. 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 D iscussion of Measure Benefits

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

................................ ......................... 41 4.3.8 Comparison of the Pinal Coun ty Rule with Measures Adopted in Other Areas

.................... 51 Exhibit F

- I

– Available Measures

................................ ................................ ................................ ......... FI

- 1December 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
FI II

- 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

- 1December 21, 2015 Final West Pinal PM10 RACM Analysis iii LIST OF TABLES

Table 1: Summary of the West Pinal County Design Day (2 4

- 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 E arthmoving*

................................ ................................ ................................ ... 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 Nonatta inment Area Fugitive Dust Complaints (ATV/OHV)

..................... 43 Table 13: Unpaved Lots*

................................ ................................ ................................ ............................ 45 Table 14: Unpaved Roads*

................................ ................................ ................................ ......................... 46 Table 15: Paved Roads*

................................ ................................ ................................ .............................. 48December 21, 2015 Final West Pinal PM10 RACM Analysis iv (This page intentionally left blank.)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 Q uality’s (ADEQ) analysis of reasonably available control measures (RACM) for emission sources within the West Pinal PM 10 Nonattainment
Area.

E ffective July 2, 2012

, t he U.S. Environmental Protection Agency (EPA) redesignated a portion of
western Pinal C ounty , Arizona from "unclassifiable” to “nonattainment” for the 1987 24

- hour PM 10 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 th e 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 PM 10 NAAQS

.

CAA Sect ions 172(c)(1) and 189(a)(1)(C) require that moderate nonattainment area SIP revisions include
emission s 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 p racticable ” 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

T he “General Preamble” to the 1990 CAA Am endments and other policy and guidance documents partially describe the methodology to determine RACM.

According to the law and interpretive guidance, a ll significant 4 point, area, onroad and nonroad source s are her ein evaluated for e xisting 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 G uidance ) and the General Preamble
both outline how to evaluate control st rategies for moderate PM 10 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

C ontrol measures may not be reasonable for all sources because some sources produce “insignificant (i.e.,
de minim i s )” levels of emissions

. 6 Measures to control in significant sources may then be excluded for

1 See generally, Designation of Areas for Air Quality Planning Purposes; State of Arizona; Pinal County; PM 10 , 77
FR 320 24, 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 minim i s emission reduction levels

5 Office of Air Q uality Planning and Standards, U.S. Envtl. Prot. Agency, PM

- 10 Guideline Document 8

- 10 (April 1993) [hereinafter PM

- 10 Guideline Document ]; s ee also General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 , 57 FR 13498, 13 540, 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 contr ibute 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 I n moderate nonattainment areas, existing “ major stationary sources should be the minimum starting point for a RACT analys 

### is. ” 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 i n other similar areas ’ SIPs. 11 However

, not all controls are require d 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 , i n full or in part, as unreasonable

. 13 The General Preamble characterizes “ r easonableness” 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 justificati on for partial or full rejection of any available control measures

, explaining the infeasibility and unreasonableness of the measures.

F or the control of public sector sources

, specifically, [ the RACM/RACT] evaluation “ should consider the impact of the re asonableness 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 consid er 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 PM 10 nonattainment area classifications : moderate and serious. Areas newly desi gnated nonattainment for the PM 10 standard, such as Western
Pina l 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, d uring 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; s ee 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 .; s ee 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, i n 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 R ACM 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/m 3 .” 18 ADEQ bases its significan t source conclusions on this BACM guidance statement

.

1. 3 RACM Analysis Process Summary

The step

- by

- step process for evaluating potential control m easure a pplication 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 c omment),
3. Evaluate the list of “available” measures for “reasonableness ” ( technological and economic feasibility )

, 4. Provide r easoned justification for the rejection, in whole or in part, of any candidate control measure affecting a significant source

, 5. Determ ine the emissions reductions due to the selected measures and evaluat e whether the
measures will lead to attain ment of the NAAQS as expeditiously as practicable

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

Evaluation o f significant sources and potential new control measures for the West Pinal area are discussed
in Section s 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 PM 10 NONATTAINMENT AREA

2.1 Identification of Significant Sources (Direct/Primary Emi ssions)

To guide the preparation of PM 10 control strategies for the West Pinal County Nonattainment Area, ADEQ analyzed ambient monitoring and emissions data for a period when violations of the PM 10 standard
occurred. A nalysis of 2008 base year monitorin g data showed that two separate m eteorological scenarios produce exceedances of the 24

- hour PM 10 NAAQS at or above 15 5 μg/m 3 : 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 road way ). On high wind days , additional emis s ions are generat ed by wind blowing across disturbed surfaces (e.g.

, an area cleared of vegetation)

. Ther e fore, f or control strategy analysis, ADEQ chose representative d esign days (days with recorded exceedances of the 24

- hour PM 10 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)

– Octo ber 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, an d

 Maricopa

– October 27, 2008.

Separate modeling domains were defined for each monitor and base scenario (pre

- attainment

- control s ) emissions inventories developed for each domain for 2008 and 2018

. Inventories for both windblown and activity

- bas ed emissi ons were created. Dispersion modeling was then performed to identify emissions
sources that have significant impact s on elevated ambient PM 10

. 21 S ource categories that did not contribute more than 0.5% of the design day emissions in any of the modeling do mains 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 i nventorie s:

 Nonroad,

19 While the PM

- 10 NAAQS is 150μg/m 3 , 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/m 3 (i.e., values ending in 5 or greater are to be rounded up).” Hence, a level of 155 μg/m 3 rounds up to an exceedance level of 160 μg/m 3 , and any value
between 150

- 154.9 rounds down to 150μg/m 3 and 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, the se 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 i n the source apportionment modeling. 25

The EPA’s BACM guidance definition of signi ficant source s ( and impacts ) , discussed in Section 1. 2 EPA Guidance above, is sufficiently clear as to avoid challenges to interpret ation . Thus, a point source or an area source category was not deemed significant unless its modeled contribution to PM 10 concentrations on a stagnation or high wind design day exceeded 5 μg/m 3

, on a 24

- hour average basis.

Significant Sources /Land Uses that contribute more than 5 μg/m 3 for 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

.

S ome of the significant sources listed above are consistent with standard emissions source categories ( e.g. unpaved roads, paved roads, construction , etc. )

. Certain a rea 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 ). S ection 2.2 Description of Signif icant 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/m 3 are described
below:

 Unpaved Roads ( Tribal

, Test Tracks )

,

 Point Sources

,

22 These source categories each comprise less than 0.5% of the annual PM 10 emissions inventory for the We st Pinal County nonattainment area. See Appendix B, Pinal County PM10 Nonattainment Area Emissions Inventories for 2008 and 2018 Base Years and Design Day s (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 t hese 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 A ppendix C, Pinal County P M10 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/m 3 in 2008 (and 4. 1 μg/m 3 in 2018; in either ca se, less than 5 μg/m 3 ). 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 PM 10 NAAQS. Non

- significant source categories are more fully describ ed 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. p lanned 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 catego ry 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 m odeling 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 D ays (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/m 3 24

- hour average signif icance 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 ca tegory 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 De veloped Urban Lands.

30 These totals only include the impacts of local sources, i.e., those within each modeling domain. Regional backgr ound concentrations of PM 10 are not included. Table 1 : Summary of the West Pinal County Design Day (24

- hour) Modeled Source Impacts for 2008 (μg/m 3 )

Source Category Low

- Win d Modeled Impacts 28 High

- Wind Day Modeled Impacts 28

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 L ands 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

Tota l 0.2 6.3 6.3 48.5 17 3.1 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 Lots 29 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
Total 30 233.0 166.5 150. 5 150.8 247.4 161.1 141.9December 21, 2015 Final West Pinal PM10 RACM Analysis 8

2.2 Description of Signif icant 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 em itting 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 track ed 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 w ater erosion and materia l 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

- base d 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

.

 Permane nt 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 lan d parcel that is not paved and that is used for parking, maneuvering, material handling, or storing mot or vehicles and equipment. This significant source category only includes activity

- based
emissions. W indblown dust emissions from unpaved parking lots ar e included as a subset of the
windblown dust emissions from the significant land use categories Cleared Areas, Developed Rural Lands, and Developed Urban Lands

. U npaved 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 :

 R oad 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

Co nstruction (Residential Construction, Commercial Construction, Site Development)

Definition:
Residential

– A land parcel which is permitted for residential construction by Pinal County Air Quality Control Dist rict (PCAQCD) or which contains visible eviden ce 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 parc el 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 a s milling or grading) occur. Only activity

- based emissions from road work sites are
include d in the Construction category.

Types of emitting sources/activities in this land use category include activity

- based and windblown emissions from :

 Land clearing an d 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 si gnificantly 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/activitie s 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 parce l 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 porti ons 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 commerci al, 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 :

 M an

- made surfaces (from airborne deposition).

 U npaved parking areas.

 P ermanent unpaved haul/access roads, and parking or s taging areas at commercial, municipal, or industrial facilities. [ non

- point source emissions]

 S maller cleared areas (including vacant lots).

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

Developed Lands

– Rural

Definition: A p rimarily 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 vegetatio n (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 condi tions. May include commercial, municipal, or industrial facilities.

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

 Unpaved parking areas.

 P ermanent unpaved haul/access roads, and parking or staging areas at co mmercial, municipal, or industrial facilities. [non

- point source emissions]

 S maller cleared areas (including vacant lots).

 O pen 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 pu blic (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]

 Liv estock 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 f or agricultural purposes ( t his 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 Ho using, 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 Con fin ed 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 u npaved haul/access roads, parking or staging areas, and feed lanes.

 Handling and transport of feed and animal waste

.

2.3 PM 10 Precursors

Clean Air Act S ection 189(e) requires the evaluation of precursor emissions from major stationary sources to determine whether emissions from these sources contribute significantly to PM 10 levels which exceed the air quality standards. Under S ection 189(e), a nonattainment plan’s control requirements applicable to major sources of primary PM 10 emissions (directly emitted)

, shall also apply to major stationary sources of PM 10 precurs ors, 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 PM 10 )

, which contribute to ambient PM 10 leve ls. For example, emitted p recursor compounds such as nitrogen oxides (NO
x ), sulfur oxides (SO
x ), or ammonia (NH 3 ) can react to form particulate sulfates, nitrates, and ammonium (ammonium sulfate and nitrate)

.

While “contribute significantly” is not defin ed in the Clean Air Act, EPA suggests that for serious PM 10 nonattainment area s, “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/m 3 .” 32

EPA further defines source categories for which regulation will be required in serious PM 10 areas as “categories of area

- wide sources or large individual stationary sources of PM 10 or PM 10 precursor emissions that may be regulated under a specif ic rule, generic emission limit, or standard of performance, or a specific control program in a SIP

. ” 33

ADEQ estimated secondary PM 10 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
Emission s Inventory (NEI)

. 34 These data were evaluated to determine which, if any, emissions sectors impact the mo nitors in question at a level exceeding 5 μg/m 3 ( averaged over a 24

- hr period )

, thus significant ly contribut ing to violations of the PM 10 24

- hour NAAQS. Any source that contributed

32 See 59 FR 42011 , August 16, 1994.

33 Id . at 42010

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

secondary PM 10 to the monitor below this level was not considered significa nt

. Details of the analysis are
contained in the West Pinal County P M 10 Precursor Significance Determination (see Appendix B, Exhibit
BXVI )

.

As a result of the evaluation , ADEQ concluded that no source category exceeds the 5 μg/m 3 significant impact thre shold for secondary PM 10

. Table 2 summarizes the s ource s ector s econdary p ollutant i mpacts

at the Cowtown and PCH monitors ( Nitrate, Sulfate, and Ammonium )

. The highest estimated contributing source c ategory, on

- road m obile, contributes less than 3.5 μg/ m 3 of secondary PM to either monitor on the design days. N o source of precursor emissions sign ificantly contributes to exceedances of
the PM 10 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/m 3 ) PCH Concentration (μg/m 3 )

E missions I nventory S ector Ammonium Nitrate Sulfate Total Secondary Ammonium Nitrate Sul fate 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

Tota l 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 0.12December 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 sourc es , ADEQ review ed existing control

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

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

numerous significan t 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 excee dances of the NAAQS. The Agricultural Best Managemen t 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 r evision of the existing State agriculture rules to include RACM prov isions for the West Pinal Nonattainment A rea were determined

necessary.Dece mber 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 Appli cable 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 operation s 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;
Mat erial 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 pre vent 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 s ubject 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 41 896;
08/01/2007 10/27/ 2004

(05/14/1997 )Dece mber 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 Appli cable 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 excep tions.

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 i n place. 10/27/2004Dece mber 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 Appli cable 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 P arking and Use on Vacant Lots
4

- 6

- 200. Unpaved and
Disturbed Vacant Lots, Restriction on Vehicle
Pa rking and Use; Applicability Rule is applicable only in the “Area A” 35 portion of
the West Pinal PM 10 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 p rovisions 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

. M easures ide ntified in Appendices C2

– Residential Wood Combustion and C3

– Prescribed Burning of the General Preamble are not appli cable to any significant source categories in the West Pinal
PM 10 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 a ny significant sources. No major point sources of PM 10 are located in any of the modeling domains.
Of the three major sou rc es in the Nonattainment A rea (outside the individual modeling domains ), a ll are natural gas fired power plants with inherently low PM 10 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, v egetate, or chemically stabilize access points where unpaved traffic surfaces adjoin paved roads

. Paved R oads.

2. Require dust control plans for construction or land clearing projects. Construction and Agricultural Operations. 3. Require haul truc ks 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,

mate rial 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 industr ial
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 applic able to any significant

source.

36 State Implementation Plans; General Preamb le for the Implementation of Title I of the Clean Air Act Amendments of 1990; Supplemental

, 57 FR 18070

- 1807 7, 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 stabili ze 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 wate r 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. Cl eared 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 PM 10 moderate area plans containing RACM measures were developed in the early 1990s
after the enactment of the 1990 CAA amendments

, o ne resource of available measures is a 1999 Federal Implementation Plan (FIP) in which EPA promulgated RACM fo r several fugitive dust source categories
in the Phoenix , Arizona PM 10 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 jurisdiction s 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 Co unty Air Quality Department , ArizonaDecember 21, 2015 Final West Pinal PM10 RACM Analysis 20

PM 10 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 s tarting point for first identifying appropriate measures applicable to significant PM 10 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 define d in EPA guidance.
B ACM and R ACM strategies relevant to the West Pinal PM 10 N onattainment A rea are summar ized in
Exhibit 1 and discussed in Section 3.2.3 below

.

3.2.3 Discussion of Candidate Measures

Pa ved Roads ( Public , Private )

Several measures app licable to paved roads are listed in Appendix C 1 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 on to 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 me asures incorporate the listed p reamble measures with the addition

, in some ca ses , 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 measure s are b ased 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: a r terial, collector, local

, e tc. Measures for PM 10 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

, p otential RACM m easures might include the foll owing:

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

• Ensure stabilization during weed abatement/vegetation management on u npaved shoulders of paved roads;

• Stabilize medians;

• Pave, vegetate, or chemically stabilize acces s points where unpaved traffic surfaces adjoin paved
roads ;

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

ma terial spills);

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

• Emplo y s treet sweepers; and

• Reduce s peed limits.

Unpaved Roads (Public, Private, Agricultural)

37 The results of this effort are contained in Control Measures Applicable to the West Pinal County PM 10 Nonattainment Area Sig nificant 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

, Private 38

)

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 no t significantly inconvenienced by having to use alternative paved roads in place of unpaved roads. In t he rural portions
of the West Pinal County PM 10 nonattainment area, however, this measure will not be feasible because of
the substantial increases in r oute 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. I n 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 gover nments 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 measure s further include a surface silt loading limit of 0.33 oz/ft 2 . 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 nonat tainment 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. So me 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 cost

effectiveness considerations. The traffic volume thresholds for control range from 26 to 150 vehicles per day, with a mode of 50 vehicles pe r 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 out lined below :

 Exempt from controls on the basis of de minimis emissions public unpaved roads that experience
2 50 or fewer vehicles per day ;

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

38 In this context, “Private” does not include unpaved agricultural, irrigation dis trict, or construction roads

. These

source s 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) ;

 Requir e local governments maintaining public road networks within the P M 10 nonattainment area to submit plans and schedules for applyin g stabilization measures to increasing fractions of non

exempt unpaved roads, for review and action by the PCAQCD ;

 Develop traffic reduction plans to encourage use of paved roads (non

- rural a reas) ; and

 Require speed restrictions.

Unpaved Roads (Agriculture)

Arizona Revised Statute s (ARS) §49

- 457 authorizes control of PM 10 emissions from agricultural sources including crop and animal operations and irrigation districts

. 39 As currently enacte d, the statute requires each owner/operator of an agricultural operation required to have an agricultural PM 10 general permit to implement at least one Best Management Practice (BMP) for each emitting activity in a moderate PM 10 nonattainment area

. T his p rogram requires adoption of BMPs for agricultural and irrigation district road
PM 10 emission control.

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

measures :

 Pav e or stabiliz e unpaved roads, access connec tions , and high traffic areas ;

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

 Reduc e vehicle speed

.

Unpaved Parking Lots

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

– Urban an d Developed Lands

– Rural.

Construction (Residential Construction, Commercial Construction, Site Development)

Construction sites were determined to be a significant source category only on hig h

- wind design days. Therefore, a nalysis of RACM for construc tion 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 a lso be some co

- benefit of measures designed primarily to reduc e emiss ions 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 cont rol measures adopted by PM 10 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 effecti vely control windblown PM 10 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 sit es 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. P reventive or remedial work practices are specified in several rules in advance of or during high wind conditions. Work practices applicab le 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 c onstruction 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 PM 10 emissions from each ph ase of construction, including periods of high wind conditions. Plans developed under these rules are site

- specific and may include innovative techniques for controlling
windblown PM 10 that are typically pre

- negotiated with the regulatory agency before pl ans 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 PM 10 SIP guidance requires that dust control p lans be evaluated as a candidate RACM if construction or land clearing activities are significant sources. The guidance assumes that construction
PM 10 emissions are significant in the absence of high wind conditions. Because construction emissions
are si gnificant 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 PM 10 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
th reshold as indicated by dust plume opacities exceeding 20% on a three

- minute average basis

,

 A ppl y water to disturbed soil and fine material storage pile surfaces during work hours whenever peak hourly average wind speeds exceed a given threshold

,

 A ppl y wat er 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

,

 E xempt construction site s of less than 0.5 acres total disturbed area from control requirements

,

 Control s pillage 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 act ive 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 PM 10 plans applicable to cleared areas primarily focus on mitigation and, to a lesser extent, prevention of additional soil disturbance activities at such sites. TheseDecember 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 genera ted 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 vegetat ion 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 vehic le 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 di sturbed soils and parcels under other zoning designations that contain less than 3.0 acres of disturbed soils ;

 I nstall “No Trespassing” signs at the vehicle entry points to areas containing more than 0.1 acre of surface area disturbed by motor vehicle tres pass ;

 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 significan t source contributing to exceedances of the 24

- hour PM 10 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 cove rage 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 portio ns of developed urban land typically inc lude 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 f or cleared areas, cleared

- area RACM applied in developed urban areas may not be as cost

- effective for the control of windblown PM 10 when applied to areas estimated to be as small as 0.008 acres 42 on individual parcels of developed urban land.
RACM for deve loped urban land may include:

 Limit vehicle access

,

 Establish ground cover veg etation sufficient to stabilize

,

 Restore to a natural state

,

40 Five thousand (5,000) square feet is approximately equal to 0.11 acres. For certa in 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 ft 2 (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 day s . Developed rural lands are parcels primarily hosting single

- family residences on larger land areas, ranging from 1 to 15 acres. Land coverage fractions on t hese 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 , t he disturbed portions of developed rur al 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 f rom 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 cost

effecti veness 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 s tabilize,

 Restore to a natural state,

 Apply dust suppressants,

 Apply surface gravel,

 Pave.

Desert Shrublands

Desert shrublands are those undeveloped lan ds 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 des ign days at
each of the four analyzed monitoring stations recording exceedances of the 24

- hour standard in 2008.
The sources of PM 10 emissions from these lands are the emissive soil areas disturbed by off

- road or off

highway recreational vehicle (OHV) tra ffic and limited livestock grazing ( only relevant to the degree to which overgrazing may occur )

. Grazing leases issued by t he Arizona State Land Department (ASLD) are based on the carrying capacity of the land parcel that is leased. The lessee cannot exc eed 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 vehicle s to specific areas. S ome rules require vehicle owners to first obtain authorization from public land managers or cons ent from private owners. One area requires a dust control plan forDecember 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 R ACM measure derived from adopted BACM rules would include, as one option, the following requirement:

 Require v ehicles 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 PM 10 nonattainment area. Air qual ity modeling found that these operations qualified as significant sources on both low wind and high wind day s. As a result, BACM measures that control PM 10 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 PM 10 emissio ns 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 handb ooks 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 pl an 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 f

rom 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 collecti vely produce 50% of annual PM 10 emissions from an individual commercial agricultural operation;
and

 D evelop a BMP plan for each affected agricultural operation.

Confined Animal Feeding Operations (CAFOs)

Confined animal feeding operations (CAFO) are fac ilities 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 significan t source of PM 10 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 PM 10 nonattainment areas where agricultural operations are significant in terms of the local economy and PM 10 em issions. The most extensive work in controlling PM 10 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 ope rations, requiring the development and submittal of BMP plans
and commitment to at least one listed BMP for each PM 10 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 an alysis 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:

 D evelop and implement PM 10 control plans ad dressing all PM 10 emission sources designed to reduce facility

- wide PM 10 emissions by 50% on a per

- head basis from a 201 6 baseline within each affected facility.

3.2.4 Stakeholder Process

ADEQ and the Pinal County Air Quality Control District worked w ith their partners to analyze emissions
and develop control strategies for the West Pinal PM 10 Nonattainment Area. Participation was encouraged and technical advice sought through meetings and discussion with governmental departments
and agencies, municip alities, 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 B est 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 PM 10 emissions f rom 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 , an d 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 a n 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 allDecember 21, 2015 Final West Pinal PM10 RACM Analysis 28

j urisdictions 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 Apach e 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 Count y Public W orks Department The Pinal County Public Works Department provide s, among other services, transportation infrastructure, engineering, flood control, and emergency management services

. The County storm water management program include s management of flooding and erosion control

.

Bureau of Land Management

- Arizona The B ureau of L and M anagement administers public lands under its jurisdiction within the state providing field management for areas that include recreational, commercial, scientific an d cultural
interests.

Arizona State Lan d 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
T he Arizona Game and Fish Department manage s wildlife resources, regulate s watercraft use

, and
enforce s off

- highway vehicle laws. The Department works in cooperation with sovereign tribes, local government s , and private land owners.

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

Arizona Department of Transportation
The Arizona Dep artment 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 Ag ency

Other Members of the Regulated Community

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

4.0 SELECTED MEASURES

Reasonably available control measures for the West Pinal PM 10 Nonattainment Area are e ncompassed in three rulemakings: one for construction sources, one for agr icultural 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

e missions 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 implement ed 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 B ecause a violation of the standard is a calculated 3

- year average, emissions reductions from measures relied up on 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 me asures should be selected from rules with the earliest effective date
and scheduled to be fully implemented by January 1, 2016. Other m easures were determined more appropriate to meet contingency and “ weight of evidence ” goals

, such as those that are incr ementally 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 operationa l 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 conside r 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 (PC AQ C D ) Code of Regulations

, Chapter 4, Article 3,
Construction Sites

– Fugitiv e 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
Ad ministrative 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 C 1 of the General Preamble, EPA identified th ese meas ure s for c ontrol of PM 10 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 V III, Rule 800 General Requirements for Control of Fine Particulate Matter (PM

- 10), Rule 801 Construc tion and Earthmoving Activities, Rule 802 Bulk Materials, Rule 803 Carry

- out and Track

- out, Rule 805 Paved and Unpaved Roads, Rule 806 Conservation Manageme nt Practices ; Maricopa County Rule 310, Fugitive Dust from Dust

- Generating Operations ; San Joaquin R ule 8010 Fugitive Dust Administrative Requirements For Control Of Fine Particulate Matter (P M 10)

, Rule 8020 Fugitive Dust Requirements For Control Of Fine P articulate Matter (P M 10) 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 Fol lowing 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 a lso 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 redu cing PM 10 emissions by at least 4,6 86

. 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 )
Const ruction ( Residential, Commercial, Site Development, Roadway ) Contingency 4

, 6 86.6

Trackout Contingency < 5.0 46

Total ≈ 4

, 6 91.6

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 disc ussion 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 s tabilize [ trackout control
d evice ] 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 othe r 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 PM 10 Nonattainment Area 2018 Attainment
Demonstration and Cont rolled Emissions Inventories,” ADEQ, 2015.

46 A 5 t on p er y ear 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 fugitiv e 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 applicab le 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 foreca st 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 t he Home Builders Association of Central Arizona to d evelop control strategies for construction and earthmoving activities in the West Pinal PM 10 Nonattainment Area. Participation was encouraged and technical advice sought through meetings and discussion to determine the feasibility of implementing the meas ures contained in the rule.

According to the final construction rule preamble, t here are estimated small incremental costs to the businesses potentially affected by the construction rule

. 47 C osts may be accrued for items such as opacity certifications, on

- site inspections

, recordkeeping

, and stabilization requirements

.

R egulated 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 c ould 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. T he 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 spec ific additional cost s 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 PM 10 Nonattainment A rea also include d opacity requirements as well as simi lar application and permitting requirements.

Estimated costs for the Pinal C ounty A ir Q uality C ontrol D istrict ( 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 R ule 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. R 18

- 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 rule s in the Arizona Administrative Regis ter.

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 Recor d Form every year by March 31. While this seems to provide an implementation gap, this is not the case. Per th e 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 ava ilable 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 Conside ration

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

, attach ed

.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 - ba sed 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 )

A ctivity 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

T he 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 dai ry operations were used for contingency measures)

 Irrigation District a ctivity 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 PM 10 per year (TPY). Attainment Contingency AgBMP
Rule
Subtot al Unpaved

apron roads Unpaved
canal O&M
roads Harvesting

and Tilling CAFOs Dairies Windblown dust Unpaved Roads 70 5 .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 7 341.3 577.6 988.1 251.4 35.8 9194. 2

Total 804 6.5 722.3 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 s trategy developed is the best and most cost effective possible to
control PM 10 from agricultural sources in the West Pinal PM 10 nonattainment area. Throughout the rulemaking process the Agricultural BMP Committee analyzed each BMP and its respective potent ial 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 econo mically and technologically feasible to implement.

PM 10 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 opt ion 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. A g r i cultural operation diversity dependent on several local and op eration 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 c hoose 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 be lieves 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 cir cumstances.”). 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 expe nsive, 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 addit ion, the rule requires more accountability than other PM 10 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 rul es 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 implemen ting 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 o f 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 growin g 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 channel s, 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 33 6 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: Ariz ona 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

- dbdb

542b

- 9c1d

- 2254a82c88d4.html.

51 See Symposium: Water Law and Policy Conference: Good Intentions, Unintended Consequences: Th e Central Arizona Groundwater Replenishment District , 49 Ariz. L. Rev. 339, 339 (2006).

52 Michael J. P earce, 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: Wa ter 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 Ari zona, 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 esse ntially 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 clai ms 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 incr eased “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 Groundwate r 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 consi dering the need to preserve groundwater for future non

- irrigation uses.” 66

56 See Active Manag ement 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, T he 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 (B onnie 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
Tucso n 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 carefu l 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 alre ady 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 yar ds, 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 conserv ation limit when using 3 to 6 gallons a day to suppress particulate matter. 71 Hence, the Agricultural BMP rule’s us e of a water volume measurement rather than a moisture content percentage allows for operational predictability in spite of limited water avai lability

.

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, gro undwater 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

app roximately 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 PM 10 rules were devel oped to account for this very real concern

. Although reducing the throughput of the agricultural sector could reduce its water use and PM 10 emissions, this is not an economically sustainable approach. Pinal County farmers and commercial animal operations m

ust 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

67 Ariz. Dept. of Water Resources, Arizona’s Next Century: A Strategic Vision for Water Supply Sustainability 45

- 46 (2014), availabl e at http://www.azwater.gov/AzDW R/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.sandiegounio ntribune.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/docum ents/ch6

- pinal.pdf

. See also Exhibit F

- V: Information On a Gall ons 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 O n a Gallons per Head Standard Providing More Benefits over a Str ict 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, h ttp:// 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/Pl anningAreaOverview/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 yiel ds 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 f arm cultural operators have turned their attention to effecting requ ired and voluntary water conservation best management practices. 78

Additionally, the PM 10 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 PM 10 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 loca l 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 mode rate per new commercial farmer/animal operator/irrigation district. From the Yuma Ag ricultural B est Management P ractices 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 s elected. 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 R ule 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

- agriculture

in

- 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.ed u/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 (PC AQ C D ) 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

- V III for the Notic e 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 C 1 of the General Preamble, EPA identified th ese measure s for c ontrol of PM 10 under the category Available Fugitive Dust C ontrol 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 PM 10 Emissions From Paved And Unpaved Road s, 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

- Trad itional Sources of Fugitive Dust

.

4.3.5 Applicable to the Following Land Use Categor ies 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 a nd Activity

- Based
Emissions Unpaved Lots (parking, maneuvering, etc.)

Unpaved Roads

Activity

- Based Emission s Paved Public Ro adwayDecember 21, 2015 Final West Pinal PM10 RACM Analysis 41

Windblown e missions from disturbed O pen 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. Mo st 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 emi ssio ns from disturbed open areas and vacant lots were found to be significant primarily

on high

- wind days. Unpaved [parking] lots and u npaved 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 c ontrol strate gies contained in the fugitive dust rule help meet contingency goals by reducing PM 10 emissions by approximately 3,000 tons per year in 2018 (see Table 10 )

.

Table 10 : Estimated Annual Emissions Reductions due to Imple mentation of the Fugitive Dust
Rule 81 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) Con tingency 1, 142.7

Paved Public Roadways (shoulders) Contingency 7.6

Paved Public Roadways (trackout) Contingency < 5.0 82

Paved Public Roadways (erosion) No Credit Taken Not Quantified

Total ≈ 3

, 026.7

4.3.7 Discussion of Technical and Economic Considera tions

Table s 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 t he reasons for including or rejecting individual measure s , in whole or in part, from the West Pinal controls strategy

.

Estimated costs for the Pinal C ounty A ir Q uality C ontrol D istrict ( 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 fug itive 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

Implementa tion Cost Fugitive Dust

Rule RACM

1. Require dust control plan for off

highway 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. m otor vehic le 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 . R equire 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 Furthe r, 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 vehicle s is not allowed o n roads, trails, routes or areas that are

“ closed ” by regulation of a fede ral 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 ru le, 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 enforce s off

- highway
vehicle laws including on public lan ds under state or local jurisdiction

.

The Bureau of Land Management (BLM) indicates that m ost lands managed by Arizona BLM are designated as “ limited areas

. ” 85 Vehicle use in l imited areas may be restricted to certain times, in certain areas, and/or to ce rtain vehicular use. U se is generally limited to designated roads and trails

, or in some

case s 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 c omplaints on public lands comprise a relatively small fraction of total OHV complaints in the nonattainment area (see Table 12 )

. Requiring additional dust control plan s for OHV use on public lands was found not reasonable becau se 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 emission s 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 l imited 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 R ule includes additional measures to restrict trespass, including recreationl vehicl es, 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 measur e 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.

Measur e 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,

• A pply/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 (includ es high wind and stagnation events)

. The forecast and stabilization requirements target days with the most potential for elevated PM 10

.

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 i nch 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 wid e 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 vac ant 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, t he West Pinal Fugi tive Dust R ule 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.

S ome incremental costs associated with posting of signs or installation of barriers may be incurred by the

t he owner and/or operator of an open area

. Previou s evaluation of costs associated with measures for

re stricting 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

I nstallation costs could range from $1,000.00 ( 5 signs ) 94 to more than $1 0

, 0 00 for fencing on a one

- acre (square) parcel of land. This measure was determined re asonable b ecause 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 P lan 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 p oint.December 21, 2015 Final West Pinal PM10 RACM Analysis 45

lots. The rule requires the owner/operator to stabiliz e 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 c lean

- 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 otherwis e 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 availa ble 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, muni cipal, or industrial facilities

The Fug itive Dust Rule includes measures to stabilize unpaved parking, maneuverin g, 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 PM 10 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 road ways, where it is subsequently re

- entrained into the air by pass ing 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, maneuverin g, material handling, or storage areas to pave,

a pply 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 lot s gre ater 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), $30 5 per 0.1 acre; 96

95 Five thousand (5,000) square feet is approx imately 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), $34 9 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 als o 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 tra ffic 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 fo und 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 inconve nienced by having to use alternative paved roads in place of unpaved roads. In

t he rural portions of the West Pinal County PM 10 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 15 0 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.

C ontrol requirements apply to roads owned b y 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 th e southwest U.S. See Exhibit F

- IV, Rule Section 4

- 1

- 030(4), for a comparison to controls adopted in other PM 10 planning areas. Measures applicable to private unpaved farm roads , irrigation district roads, and unpaved construction roads are included in th e Agriculture and Construction Rule s (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,
El oy and Queen Creek. The unpaved road requirements w ill add significant costs to all these regulated
entit ies. Because of the gross cost and burden on the nonattainment area infrastructure that will be
incurred due to paving or otherwise stabilizing unpave d 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 mile s per year paving goal ( contracted chip

- seal ) from 2016

- 2018

. 106 According to t he ADT

est imate s used for the base year inventory (2008 ), there were 180 miles of unpaved roads over 150 ADT
in the West Pinal Nonattainment A rea. Per the example s above, application of dust suppressants on 180 miles of roadway would cost approximately $8,640,000 p er year and approximately $21,600,000 per year for gravel

.

T he form of the PM 10 NAAQS is a three year average (calendar year), therefore, e missions reductions for

measu res 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, t he unpaved road measures are not relied upon to advance attainment of the NAAQS or to demonstrate attai nment 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 mea sures 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 ma y 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 t he measures designed to satisfy this requiremen t will
be applied proactively, starting on January 1, 2016. These measures include :

• C ontrols on commercial dairy operations

, estimated to reduce nonattainment area emissions by
101.2 tpy (see the Agriculture Rule in Section 4.2) ;

• C ontrols on constructio n , estimated to reduce nonattainment area emissions by 4,6 86 .6 tpy (see the Construction Rule in Section 4.1) ;

• C ontrols on a variety of other sources of fugitive dust (open areas and vacant lots, unpaved parking lots, unpaved shoulders of paved roads )

, es timated to reduce nonatta inment 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 s ubtracting 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 t hat 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, S ection D5.2

.

The Fugitive Dust R ule also includes an equivalency option (only effective after the modeled attainment date) which allows for the paving of roa ds 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. P av ing 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
emis sions reductions as paving roads with 150 ADT. Because t here is no sunset provision that applies to the unpaved road section of the rule , t he requirement to apply control s to roads above 150 ADT does not at this point expire and application of me a sures on all roads above the threshold must still be achieved.

Paved Public Road

way s

Table 15 : Paved Roads*

Measure Technically Feasible Reasonable

Implementation Cost Fugitive Dust

Rule M easure
1. Pave, vegetate, or chemically
stabil ize 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 o ut, 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 N E N

6. Employ certified street sweepers

. N Y N

107 Emissions reduction estim ate is based on application of a combination of controls (e.g., synthetic palliative; chip

sealing, 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 M anagement Practices ( AgBMP ) R ule includes track out requirements for agricultural activities including unpaved traffic surfaces (see Section 4.2)

. The Construction R ule
contain s “prevention of trackout ” requirements

, including installation of trackout cont rol 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 p aved 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 p revent 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)

.

Additional ly, measures to reduce emissions f rom 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 associate d with controlling trackout and carryout onto paved roadways include : paving, $6,000 to $8,500 per access point ; chemical stabilization, $984 ; g ravel

, $680 to $1,360 per year per access point ; and trackout control device s , $3,5 00 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 Section s 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 R ule 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 t he regulated entities (owner/opera tor of property where trackout originated)

. Choices for clean

- up include manual sweep and pick

- up, rotary brush or broom, and PM 10 efficient street sweeper. C urrent 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
D iameter, 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 dol la rs 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 include s stabil ization 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 subj ect 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 require s the application of a dust suppressant but al so potentially the use of a PM 10 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 c osts to the regulated community

. Costs associated with potential paved road shoulder

measure s 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

• Water ing 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 c ost of $77,524.80

. For treating an area 4 feet wide and o ne 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 fund ing for paving public unpaved r oads . 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 rat her than paving fewer miles and add ing

pav ing to selected road shoulders.

Measure 5. Provide for storm water drainage to prevent water erosion onto paved roads

Water erosion runoff occurs only infrequent ly during periods of heavy rain ; u sually generated by intense,
localized thunderstorms that occu r in the late summer and ea rly 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 t ime 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, a gricultural areas, etc.)

. Due to the low gradient i n 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 Ema il 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 flo oding , and inundation can be widespread. 112 Drainage control requires substantial research and
infrastructure in vestment

. Additional measures, beyond th ose 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

. T herefore , this measure w ould 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 foc uses on access restrictions for safety during f looding
and rapid cleanup following these infrequent events

.

Measure 6. Streetsweeping

Street sweeping reduces PM 10 on paved roads, which consequently reduces reentrainment of PM 10 by
vehicles traveling on the roadway. PM 10 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 proc ess. 113

A typical BACM measure requires that future purchas es or replacement of street sweeping equipment in
urban areas be certified PM 10 efficient. A recent report estimated capital costs for purchasing a (full size municipal) street sweeper ranging fr om $140,000 to $250,000 depending upon the sweeper type (mechanical, regenerative

- air, vacuum, etc.) and the options included. 114 PM 10 efficient street sweepers are typically purchased through the Congestion Mitigation and Air Quality (CMAQ) process which
i ncludes 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 fund ing is 5.7% which is approximatly $13,500 .00 per PM 10 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 PM 10 Planning A rea already implement street sweeping programs, employing both conventional and
P M 10 efficient street sweepers. For example; Coolidge operates one PM 10 efficient street sweeper, Casa Grande operates four PM 10 efficient street sweepers

, Maricopa utilizes four PM 10 efficient street sweepers with two new ones expected by the end of the y ear , and Eloy employs one conventional sw eeper.

ADEQ determined that (1) PM 10 efficient street sweeping is already being implemented in local jurisdictions ( e.g. the largest incorporated cities and towns in the West Pinal P lanning A rea ) and the
addition o f a new measure is unlikely to result in significant emissions reductions; and (2) for those areas not operating PM 10 efficient sweepers, e xisting equipment may not be scheduled for replacement in the

near term

, and a cquiring dedicated funding and procurem ent 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 co mpares the Pinal County Fugitive Dust R ule 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 PM 10 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 (This page intentionally left blank.)December 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 1 E x h ibit F

- I

– Available Measures

List of Available Control Meas ures Relevant to West Pinal County PM 10 Nonattainment Area Significant SourcesDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 2 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 Nonattainment Area Significant Sources

Control Measure * Requirements Applicable SIP (U.S. EPA Approval Citation) Measure Type

Paved Roads SCAQMD Rule 1186,
PM 10 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 (wa ter prior to clearing, chemical suppressants and/or washed gravel to maintain a stabilized surface after shoulder maintenance). Guidance encourages curbing or paving. A pplicable to all construction activity sources

. ] 1998 South Coast AQMP 2 (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 (PM

10); Rule 801,
Construction and Earthmoving Activ ities; 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 PM 10 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 Co unty 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/MSMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 3 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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
includin g stabilization of road shoulders and medians, curbing, street sweepers, and post

- event clean

- up and track out. Rule s 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% opa city 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 requi rements of Rule 8061. Units used are Average Daily Traffic (ADT). 2003 PM 10 SIP 1 (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 requireme nt 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 o f, and ADT on,each unpaved road segment. 2003 PM 10 SIP 1 (69 FR
30006

- 30036; May 26, 2004) BACM

SCAQMD Rule 1186,
PM 10 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 AQMP 2 (70 FR 69081

- BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 4 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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; N ovember 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 mai ntained 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 PM 10 SIP 3 [Rule was adopted on July 22, 1996, submitted to EPA on October 18, 1996.
EPA h as 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 complian ce 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 stabi lized so that 100% of roads are stabilized by 2015. 2009 PM 10 SIP 4 (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 unpave d 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/ft 2 silt loading, or not exceed 6% sil t content (determined by Subsection 91.4.1). 2001 PM 10 SIP 5 (69 FR
32273

- 32277; June 9, 2004).

Initial adoption by Clark County on June 22, 2000. Amended on November BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 5 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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

o ver 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/ft 2 . If silt loading is equal to or greater
than 0.33 oz/ft 2 , then the owner and/or operator shall not allow the silt content to exceed 6%. 1999 PM 10 SIP 6 (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 requireme nts. Adopted by Maricopa County on 1/27/2010. BACM

40 CFR 52.128, Rule for unpaved parking lots, unpaved road s 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 PM 10 FIP 7 (63 FR
41326

- 41356; August 3, 1998. 64 FR 71308; December 21, 1999) RACM

1993 SIP for Nogales
PM10 Nonattai nment City commits to paving the remainder of unpaved streets within the City limits within 5 years. 1993 PM 10 SIP 8 (76 FR
1532

- 1535; January 11, RACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 6 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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 p oints. 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 PM 10 SIP 9 (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 ar eas 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 PM 10 SIP 1 (68 FR
8830

- 8835; February 26, 2003) RACM

Rule includes 20% opacity limit and compliance with sp ecified 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 ac res 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.

BACM measures include: limit vehicle speed to 15 mph o n uncontrolled unpaved surfaces, access/haul roads, within construction site; cease (FR Vol. 69, 30006

- 30036, May 26, 2004) [Rule was amended August 19, 2004.] BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 7 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 Nonattainment Area Significant Sources

Control Measure * Requirements Applicable SIP (U.S. EPA Approval Citation) Measure Type

earthmoving activities when hi gh 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 p lumes crossing property line or ≥ 20% opacity; compliance with specified BACM measures;
PM 10 concentrations must be ≤ 50 μg/m 3 between upwind and downwind property boundaries; install trackout control device for projects ≥ 5 acres; clean public road when v isible 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 AQMP 2 (70 FR 69081

- 69085; November 14, 2005. Updated version approved at 73 FR 12639;
Marc h 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 ina ctive disturbed surfaces; Dust Control Pla n required for disturbed areas ≥ 5,000 ft 2

. 1998 South Coast AQMP 2 (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 spec ified phases; covering of haul truck transporting bulk materials; removal of trackout on public paved roads. 1995 PM 10 SIP. 3 ( Rule was partially approved and partially disapproved at 74 FR 40750; August13, 2009.) RACM

ICAPCD Rule 801,
Construction and
Ea rthmoving 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 deve lopments; 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 Fugit ive Dust source type including: c easation of dust 2009 PM 10 SIP 4 (75 FR 39366

- 39390; July 8, 2010. 78 FR
23677

- 23683; April 22,
2013 ) BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 8 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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 constructio n activities less than 0.25 acres, mechanized trenching less than 100 ft in length, or for mechanical demolition of any structure smaller than 1000
ft 2

.

The Dust Control Permit application for a construction project 10 acres or more in area, for trenchin g 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 projec t 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 ty pe 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 ma y 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 h igh winds cause dust plumes greater than or equal to 20% opacity; no visible dust plume greater than or equal to 100 yards in 2001 PM 10 SIP 5 (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.] BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 9 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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: 2 0% 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; c ease 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 s ite 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 0.1 0 acres or greater of disturbed soil. 1999 PM 10 SIP 6 (67 FR 48718

- 48739;
Ju ly 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 PM 10 SIP 6 (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 tresp ass” signs or installing barriers to prevent access to area. 2003 PM 10 SIP 1 (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 mor e within urban areas, or 3.0 acres or more within rural areas; and contains at least 1000 square feet of disturbed surface area. 2003 PM 10 SIP 1 (69 FR 30006

- 30036; May 26, 2004) BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 10 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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 AQMP 2 (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 AQMP 2 (70 FR 69081

- 69085; No vember 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 PM 10 SIP 3 (No
action on r ule) 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;

a nd contains at least 1000 square feet of disturbed surface area.

Measures include prevention of vehicle trespass by signage or physical
barriers. 2009 PM 10 SIP 4 (75 FR 39366

- 39390; July 8, 2010. 78 FR
23677

- 23683; April 22, 2013.) BACM

Clark County Air Q uality Regulations Section 90, Fugitive Dust from Open
Areas and Vacant Lots Requires prevention of vehicle trespass on open areas greater than 5,000
ft 2 within 30 days of initial discovery; application of gravel or palliatives satisfying stabilization sta ndards to all areas disturbed by motor
vehicles.

Dust Mitigation Plans are required for open areas and vacant lots having 2001 PM 10 SIP 5 (69 FR 32273

- 32277; June 9, 2004. Action approved revised versions of Sect 90

– 93 dated November 20, 2001, BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 11 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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 ft 2 ; 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, Jul y 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 o f unpaved parking lots (5,000 square feet ), ma terial storage and handling areas, and staging areas. 2001 PM 10 SIP 5 (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 s tabilization 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 la rger. 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 PM 10 SIP 6 (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 vehi cle 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 PM 10 SIP 5 (69 FR 32273

- 32277; BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 12 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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, 2 002; 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 PM 10 SIP 5 (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, v ehicle 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

Mar icopa 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 me asures 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 PM 10 SIP 6 (67 FR 48718

- 48739; July 25, 2002. Revised rule approved at 75 FR
7 8167; December 15, 2010.) BACM

SCAQMD Rule 403, Fugitive Dust and Rule Rules include measures addressing storage piles and disturbed surface

areas. 1998 South Coast AQMP 2 (70 FR 69081

- BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 13 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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 PM 10 SIP 4 (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 PM 10 SIP 1 (69 FR 30006

- 30036; May 26, 2004) BACM

Developed Land

– Rural SJVAPCD Rule 8071, Unpaved Vehicle/Equipment
Traffic Areas Fugitive PM 10 Management Plan and compliance with specified BACM required on unpaved vehicle areas ≥ 1.0 acres that r eceive ≥ 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 SJV APCD Governing Board pla n Adoption of the 2003 PM10 Plan, June 19, 2003, however this measure is in Rule 8081(Agricultural Sources), not in Rule 8071. 2003 PM 10 SIP 1 (68 FR 8830

- 8835; February 26, 2003) RACM

Requires compliance with specified BACM on unpaved vehicle areas
recei ving ≥ 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 PM 10 SIP 1 (69 FR 30006

- 30036; May 26, 2004) BACM

SJAPCD Rule 8051, Open Areas Contains measures address ing: stabilization, vehicle access, etc. 2003 PM 10 SIP 1 (69 FR 30006

- 30036; BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 14 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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 PM 10 SIP 4 (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 AQMP 2 (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 gr eater 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 PM 10 SIP 5 (69 FR 32273

- 32277; June 9, 2004) BACM

Clark County Air Quality Regulations Se ction 92

– Fugitive Dust from Unpaved Parking Lots and Storage Areas Includes measures addressing: paving and stabilization o f unpaved parking lots ( 5,000 square feet ), material storage and handling areas, and staging areas. 2001 PM 10 SIP 5 (69 FR 32273

- 3 2277; 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
restri ctions, 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/ft 2

. 1999 PM 10 SIP 6 (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, RACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 15 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 Nonattainment Area Significant Sources

Control Measure * Requirements Applicable SIP (U.S. EPA Approval Citation) Measure Type

unpaved roads and vaca nt lots requirements for public and private unpaved parking lots, urban and
suburban vacant lots and disturbed su rfaces. 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 surf

ace 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 lev els 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 (PM

10) 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)
SJV APCD Rule 4550

, Conservation Management Practices The o wner/operator of agricultural operation ≥ 100 acres must prepare and submit a CMP application committing to one CMP for each applicable source category and implemen t the CMPs upon approval by
SJV APCD of the application. The Air District's rule requires farmers to implement five CMPs f

or 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 PM 10 SIP 1 ( 69 FR 30006

- 30036; May 26, 2004) BACM

SJV APCD R ule 8081, Agricultural Sources The owner/operator of an agricultural operation must limit visible dust plumes to 20% opacity through application of specified BACM 2003 PM 10 SIP 1 (68 FR 8830

- 8835; RACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 16 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 Nonattainment Area Significant Sources

Control Measure * Requirements Applicable SIP (U.S. EPA Approval Citation) Measure Type

alternatives for each of several specified sources. Februa ry 26, 2003)
2003 PM 10 SIP 1 (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 appl icable source category and implement the CMPs upon approval by ICAPCD of the application. Includes special provisions on acres implementing the Conservation Tillage CMP. 2009 PM 10 SIP 4 (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 a ny 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)
SJV APCD Rule 4570,
Confined Animal
Facilities The o wner/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 r ule are required to submit a Permit to Operate (PTO) application by December 15, 2 006, detailing an emission mitigation plan listing all chosen mitigation

measures. 2003 PM 10 SIP 1 ( 69 FR 30006

- 30036; May 26, 2004 . 77 FR 2228: January 17, 2012. ) BACM

SCAQMD Rule 1186,
PM 10 Emissions from Paved and Unpaved Roads, and Livestock Operation s 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 acc ess connections and unpaved feed lane access areas with gravel

, pavement, or asphaltic road

- base. 1998 South Coast AQMP 2 ( 70 FR 69081

- 69085; November 14,
2005

. New version approved at 77 FR 13495 ; March 7, 2012 , but did not change CAFO portion. BACMDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 17 Exhibit F

- I : List of Available Control Measures Relevant to West Pinal County PM 10 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 betwe en 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, 0 8/13/2002, and 10/10/2006] 2009 PM 10 SIP 4 (68 FR 8839; February 26, 2003) BACM

SCAQMD Rule 403

, Fugitive Dust Requires c ompliance with specified BACM measures (conservation management practices). (73 FR 12639 ; March 2008) BACM

1 2003 PM10 Plan, San Joaq uin Valley Plan to Attain Federal Standards for Particulate Matter 10 Microns and Smaller, August 19, 2003

. 2 1998 South Coast Air Quality Management District

, Air Quality Management Plan

. 3 Final Mojave Desert Planning Area Federal Particulate Matter (PM10) Attainment Plan, July 31, 2005

. 4 2009 Imperial County State Implementation Plan for Particulate Matter Less Than 10 Microns in Aerodynamic Diameter, Final, Au gust 11, 2009

. 5 PM

– 10 State Implementation Plan for Clark County, July 25, 2001

. 6 Revised Marico pa Association of Governments 1999 Serious Area Particulate Plan for PM

- 10 for the Maricopa County Nonattainment Area, February 2000

. 7 Federal Implementation Plan for Arizona

– Phoenix Moderate PM 10 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

. 9 Texas State Implementation Plan for PM

- 10 in El Paso, November 5, 1991

.

* Air Quality Control Districts Referenced:

 San Joaquin Valley Air Pollution Control District (SJV APCD), 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 (MDA QMD), California

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

 Clark County Department of Air Quality , Nevada

 Maricopa County Air Quality Department , ArizonaDecember 21, 2015 Final West Pinal PM10 RACM Analysis FI

- 18 (This page intentionally left blank.)December 21, 2015 Final West Pinal PM10 RACM Analysis FII

- 1 Ex hibit F

- II

– Construction Com parison

Comparison of Pinal County Code of Regulations (PCCR), Chapter 4, Article 3, Construction Sites

– Fugitive Dust , to Measures Adopted in Other AreasDecember 21, 2015 Final West Pinal PM10 RACM Analysis FII

- 2

In Exhibit F

- II , the Pinal County C onstruction R ule is compared to applicable BACM requirements a dopted 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 as sociated with
CONSTRUCTION activities.

Applicable in the West Pinal County
PM 10 Moderate Nonattainment area. Imperial County Rule 801(A): Purpose is to reduce the amount of
PM

- 10 emissions due to Construction and Earthmoving A ctivities. Although not s pecified 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 GE NERATING 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 Spe cies Act) [ICAPCD Rule 800(E.1)]

- Off

- Field Agricultural Air districts primarily incorporate area specific exemption s.

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 exempt ion from requirement for 20% opacity
when wind exceeds 25mph . Pinal County rule provides similar exemption from violation during highDecember 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 b efore 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 perm it 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 Rul e 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 a nd Earthmoving Activities :

- Single Family Residenti al
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 con trol measures are implemented. [ICAPCD Rule 801(D.2)] risk events provided all measures are implemented and the area is
stabilized. S ee 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 t he 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 MaterialDecember 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 80 3

, Carry

- Out a nd
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,
chemic al 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 periodDecember 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 track

out 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 great er 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 definition s 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 Aggrega tes), 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, art ificial 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 appro ved 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
T RANSPORTING OPERATION " as used in this Article, means the processing of BULK MATERIALS, including but not limited to, the Imperial County rule d oes 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, gradin g, or moving of bulk
materials.
PCCR 4

- 3

- 170(3)

. “CONSTRUCTION” “ CONSTRUCTION ” as used in this Article means building, maintaining or modifying a capital improvemen t 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
in cluding 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 maintain ing 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
clea ring, 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 porti on 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

- 18 0. CONTROL MEASURES
i nclude 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
definition s , to be applied as appropriate t o dust generating
activities. Additional control measures for specific circumstancesDecember 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 O PERATION. 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 surfa ce 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 increa se 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%

op acity, 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 unpave d 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 r ules 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 f

or 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 che mical 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
manufa cturer 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 p roduct
manufacturer to unpaved haul/access
roads and Unpaved Traf

fic 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. Restr ict vehicular access to the area by fencing or signage ; and
2. A pply 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 s urface 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 procedur es 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 shal l comply with Rule 802. [ICAPCD Rule 801(F.1.f)]

Bulk Material handling : N o 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 M aterial, 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
certai n 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 : ‘Restri ct 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 Tra ffic 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 t o 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 an d 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 me thod 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 Mater ial 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 comp lying 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 pur poses, 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 t ransport of Bulk Material for a
distance of twelve feet or less with
the us e of a chute or conveyor device
and from requirements specified in
Sections F.3.a and F.3.d (covering
ha ul 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 a ll
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, bottom

dump 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
TR ACKOUT extends a cumulative
distance of 50 linear feet or more , b e 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 : A ny 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 time

schedule: (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 A verage 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 a ny 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 di stance of 50
feet or more. The Imperial rule requires immedi ate 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
Stabilizeat ion, 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 si te: ‘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 appliesDecember 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

a rea. [ICAPCD Rule 801(F.1.c)] at all times.

Other measures as proposed by registrant: ‘Specific measures that are adequate to address applicable
standards i n 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 st abilized 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

o therwise 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 a ctivity that caused the disturbance has been completed, and
the disturbed area meets the The Imperial C ounty 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 maintena nce 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,
Earthm oving Activities, Construction activities, Unpaved Roads, Track

Out/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: const ruction, 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 f

rom the site,
and demolition activities. [SJV APCD 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 chem ical 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 regulati on, 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 “Chem ical Stabilization/Suppre ssion” ), and other approved substances. [SJV APCD 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 a ny other approved
materials. [SJV APCD 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
C ONSTRUCTION, 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 broadDecember 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 ma terials 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,
moderat e or high risk of dust generation for the next five consecutive days and shall be issued by noon on each day the forecast is generated. When developing these forecasts, the Department of Environmental Quality shall consider all of the following: a) Project ed 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 meteorologic al 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

con centrations 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 SUPPRESSANT S, shows
visual or other evidence of surface crusting and is resistant to wind

driven 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 sta

bilized areas” under
the definition of DISTURBED
SURFACE AREA at 4

- 3

- 170(5).
P ermanently 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 c onditions; b. Been paved or otherwise covered STABILIZED SURFACE: Any disturbed surface area or open bulk storage pile that is r esistant 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 test s 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 Pin al 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 construct ion rule does not contain a separate definition for stabilized unpaved roads as in the Imperial rule. Unpaved roads usedDecember 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 non

e rodible 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 tr affic 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 D ISTURBED 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 HA UL/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, asph altic 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 P ARKING 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 b y 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
b y 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 o ther 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 oth er 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, a lteration, 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

up on 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

p e r mits.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 d efinition 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 [ICAP CD Rule 801(E.1.a) and (E.1.b) ]

- C omply 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
Rule s 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 throu gh 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 allDecember 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

- 18 0(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:

- T rackout 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 mor e 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
th e Pinal County Dust
Control Forecast . Ensuring Trackout Control Device

. S ites with access to a Paved Road and with 150 or more Average
Vehic le Trips per Day, or 20 or more Average Vehicle Trips per Day by
vehicles with three or more axles :

- I nstall one or more Track

Out Prevention Devices or control device or wash down system at access points with Paved Roads; or

- A pply and maintain paving,
Chem ical 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 Imperi al 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 a re 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 include s 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
OPER ATIONs, 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 o f 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 mus t 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 directi on. (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 SI TE

, 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 SIT E. 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 non

residential developments 5 acres or larger . Plan is made available to the Control District up o n request. Explicit approval prior to activity isDecember 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 recordkeep ing. [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. [ SJV APCD 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 rule s 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 Joa qu in 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 mor e of
disturbed surface area for residential developments, or 5 acres or more of
disturbed surface area for non

residential developmentDecember 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 GENERA TING OPERATIONS Application Form requirements include :

- Separate application for noncontiguous areas.

- S ubscribe to the Pinal County Dust Control Forecast as part of the permit application process

.

- A plot plan with total a rea to be disturbed and indication

o f the sources of fugitive
dust emissions

.

- E xplanation 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,
P ublic Utility Corporations, and

c ontractors or subcontractors for
Political subdivisions or Public Utility Corporations for:

- Maintenance of existing underground or above

ground lines

.

- Effecting end

- user connections, including but D ust control plan requirements
include :

- A plot plan with type and location of each project

.

- T otal area of land surface to
be distu rbed, 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;

ma nufacturer'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

c ontractors 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

conne ctions, 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, UNPA VED ROADS, road shoulders, and/or alleys and public right of ways at non

- contiguous
sites

.

A nnua l block application :

- The OWNER AND/OR OPERATOR may submit to
the Control Officer one
DUST GENERATING OPERATION application for
more than one DUST
GENERATING
O PERATION at which
CONSTRUCTION will
commence within 12 months of permit issuance.

- Must include a ll 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) ]

- A dhere to the requirements of all current permits issu ed
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
notifica tion must include the site location, size, and type
of DUST GENERATING OPERATION, selected control measures, and start
date.

Permit and Recordkeeping Requiremen ts 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 condit ions 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 constitute s agreement to accept responsibility for meet ing 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 requirement s include:

- M aintain a copy of the signed permit and provide it upon request

.

- K eep records of every other week inspection s 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

.

- D emonstration 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 ris k and non

- high risk provide evidence of control measure application (i.e., receipts and/or purchase records). Describe, in the records, the type of treatm ent 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 t imes 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 terminati on 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 Ren ewal Requirements:.

- The first permit obtained for an

a ffected project must cover a contiguous area (unless it is an "annual area block permit") and
is valid for one year from theDecember 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 s ites 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 s hall 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. Fai lure 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) shal l 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 du ring
wind events provided all measures are implemented and the area is
stabilized. S ee 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 ar e 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 a re 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 spe cified 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
Rule s ( 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
61 2 .01) to Measures Adopted in Other AreasDecember 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 far ming 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 wi thin 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

no nattainment 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 an y 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 do es 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 t he 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.

AGRICULT URAL 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 o nly 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 agricultur al 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 opera tion. 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 pa rcels 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 equ ipment 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 productio n 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

- 1 0.

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 prep are 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 B est 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 p recipitation,
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 pred icted 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
nonethe less. 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

requ irements.

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 Agr icultural 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” m eans 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/aDecember 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. S oil 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 f orecast 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

su mps) 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 BMP s 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 environment al 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. un less 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

im plement 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 equivale nt 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 red uces 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, shal l 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 Agr icultural 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, orDecember 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 gr azing 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 eac h 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 AF O.

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 r equirements 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 perfo rm 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 4 550)

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 informa tion:

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, com mercial 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 P ractices 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 s hall 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 CMP s implemented should be described An owner/operator shall prepare and submit a CMP Application for each agric ultural 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

in formation:

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 ac reage 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 pract ices 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 modificat ion 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 agricult ural 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

Mana gement Practices shall be noted on the Best Management Practices Program
General Permit Record Form and shall be Violations

- F ailure 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 su bject 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 f ollowing 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 necessaryDecember 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 Pl an 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 alterna tive 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 

### F III

- 2 Tillage

Crop Operations Rules A.A.C. R18

- 2

- 610 & 610.03 Tillage Fa rm 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 sha ll 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 operati on,

 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 definit ions. 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 PM 10
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 multi

year crop one ye ar, 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 Comb ined 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 permane nt 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, sprin kler, 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, grafti ng 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 flatteni ng the soil surface after nut harvest to remove post

harvest 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, c onventional, 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 lighterDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 11 Crop Operations Rules A.A.C. R18

- 2

- 610 & 610.03 Tillage Fa rm 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 multi

year crop, he/she is conducting a dust generating activity that falls under the tilling category. One ca n 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 sate llite 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

Addi tional 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,

 Plantin g 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

Dus t 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 shal l 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 implemen t 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 Fie ld 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/aDecember 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 Operati ons 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

 Shutt le 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 owne r 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 Harve sting 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 P arcel 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 Mulchi ng 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 planin g 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 post

harvest residue; maintain clean, smooth, firm floor throughout season by elimination of disking Green Chop

- The harvesting of a forage crop without allowing i t 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 p reparation

- 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/trailerDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 13 Crop Operations Rules A.A.C. R18

- 2

- 610 & 610.03 Ground Operati ons 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 Dustin g 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,

 Mu lti

- 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 activ ity " 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 op eration 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 implemen t 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 Stripcrop ping
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 Pro gram 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 f ollowing 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

t hat 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 pe rmanently 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 Su rface 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 San d,
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 ma terial 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 App lication 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 requirementsDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 15 Crop Operations Rules A.A.C. R18

- 2

- 610 & 610.03

Noncropland

Overarching Pro gram 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 m ore 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

maintai ning 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. Fo r 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 o r more permanently
fallow , the owner or operator shall implemen t 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 Cro p 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
Definition s 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,

W atering, 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 Secti on 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 (V DT), 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 a ny 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 barrie r
- 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 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 requireme ntsDecember 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/ Require ment 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
Def initions 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 roughe ning,

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 imple ments 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 Parc el 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 B ailing/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 Nigh t 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 Roughe ning 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 Agricultur al 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 an d dry by leaving the field surface with large clods for as long as possible Alternate Till

- Rotate tillage, leaving residue on

s oil Application Efficiencies

- Use compact, low volume, or concentrate quantity with spray equipment, aerial applications, use micro

heads or infrared spot sprayer, electrostatic

sprayers Baling/Larg e 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 wate r 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 Divers ion 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 combina tion 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 burningDecember 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
Def initions 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

- Hav ing 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 rougheni ng, 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 except ions 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 Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03)

Overarching Prog ram 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 455 0 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) me ans 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
Confi ned 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 ca ttle 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 facilit y” 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;

6 50,000 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 chick ens (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 Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03)

Overarching Prog ram 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 455 0 CMP List)

“ Agriculture operations ” includes the raising of fowl or animals for the primary purpose of

ear ning 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 permi t) 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 fe edlot, 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 operati ng 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 LCAF s 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 non

attainment.

Contr ol 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 feedlo ts and dairy operations. Agricultural p aved 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

perm itting 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 agricultu ral 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 a gricultural 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 Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03)

Overarching Prog ram 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 455 0 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 a nnual 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 f alls
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, Imp erial’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 Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03)

Overarching Prog ram 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 455 0 CMP List)

BMP Exceptions For all facilities: Operators may develop other BMPs that are proven effective through on

operation demonstration trial s 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 agri cultural 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 fal l 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 transpo rt 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 withi n 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 th e 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/ope rator 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 ca tegories that are equivalent to the control measures specified in Rule 8081.

An animal operation that operates below the animal unit thresholds only have to maintainDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 24 Animal Operations Agency Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03)

Overarching Prog ram 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 455 0 CMP List)

records.

(Rule 4550)

BMP General Permit Record

Form A commercial animal operator wh o 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. Cons ervation 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
limit ed 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 Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03)

Overarching Prog ram 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 455 0 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 in clude:

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 numbe r 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 bee f 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 d ay 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 t he 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 r ecommended 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 sub mit 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 Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03)

Overarching Prog ram 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 455 0 CMP List)

Maintaining Records/Compliance (A.A.C.

R18

- 2

- 611.03(J)) A commercial farmer shall maintain recor ds 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 compli ance 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 s ize, 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 t o 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 infor mation 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 de monstrate that the agricultural operation site or agricultural parcel qualified for the exemption.


### FIII

- 8 Commercial Dairy
Animal Operations Agency Compa risons (Rules A.A.C. R18

- 2

- 611 and 611.03) Commercial Dairy Specific Program Requirements other th an 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 Cho ices 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 appl y 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 p articulate 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 An imal Facilities. CMP lists per rule 4550.December 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 27 Animal Operations Agency Compa risons (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

(Rul es 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, feedin g, 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 surf ace

- 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 t he 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 p ushed
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 ca ttle 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 soi l 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 st ructures, wind barrier density ≥ 50% and the height proportionate to the Freestall Barns: Owners/operators hous ing 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 Han dbook 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 fro m 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 suc h 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

mor e 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) day s. 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 p rior 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 indentio ns 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 overflo w Imperial’s BMPs are in place to
prevent a multitude of pollutants and
are not focused

on PM10 prevention or mitigation.  Use of freest all 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 Compa risons (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

(Rul es 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 f eed 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 structur e. 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 wi th 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 inc orporate 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 f eed 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 wa ste 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 c overing. 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 approve d 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 fol lowing mitigation

measures: 1.Manage the facility such that lagoons only contain waste Imperial’s BMPs are in place to
prevent a multitude of

p ollutants 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 mate rials

 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 Compa risons (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

(Rul es 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 separ ator 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 sign age 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 p ublic 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 win d 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 t o 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 preserva tion 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 stabilize d 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

 A ccess 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 vehiclesDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 30 Animal Operations Agency Compa risons (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

(Rul es 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 re

application/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 se rvice 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 are as (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 an d 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
mandate d 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

comm ercial 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 dus t, 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 spec ified 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.

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 wi th 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/suppr ession
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 roadDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 31 Animal Operations Agency Compa risons (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

(Rul es 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 requiremen ts 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 lim it; 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 stabiliz ed 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 t han 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 Ch oices 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

en tered 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% moi sture 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 cont rol 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 con tent 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 W est 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 an d 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 restrai ning 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.

C lean 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 e xceeding 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 tim e or point.  Shade for ani mal

- 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

 P ull

- 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 tur nover rate is much less frequent than in other areas. Therefore, harvesting manure
more than two times per year because growers harvest manure during turnover period s, 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 W est 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 emi ssions 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 a nd 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 acr oss 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 Establishmen t, 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

- 611.0 3(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 equipm ent 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 corr als Remove manure from pens or corrals and transport to an on

site 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 onc e 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

v isible 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 hoursDecember 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 W est 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 mixin g 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 Acce ss 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 vehicl es)

 Apply and maintain aggregate cover (aggre gate 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

co mmercial 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 speci fied 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 b y 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 1 5 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 Fugit ive 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 Age ncy (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 v ehicles 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 exce ss 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 re gulations. 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 r eduction

- Enforcement of speeds that reduce visible dust

emissions

 Appropriate equipment andDecember 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 W est 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 requirement s 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 lim it; 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 stab ilized 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 Calif ornia,
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 eng ine 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 ag gregate 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 clea n, 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 a nd 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

unpave d 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 tri ps 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 meas ures:

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

I mperial 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

unpa ved 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 suppressa nt 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 materi als and, chemical/organicDecember 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 W est 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 t o 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 othe r 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 a n 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 o ne 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 supp ressants; 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) inc h 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
vehiclesDecember 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 Poultr y 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 bed ding 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 tha t 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
th eir 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 building s 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,

s tate, 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 mater ials.)

 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 re moving 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 en closing 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 manu re spreading

– to spread the manure at a time that would help reduce the amount of
PM10 released in the airDecember 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 Poultr y 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 l east 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

averag e 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 a nd 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 requi rements 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; Imperial’s fugitive BMPs are
listed here for
convenience from Imperial Rule 800, but
more information on the procedure and implement ation 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  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

an d 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 us e 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 Poultr y 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 unpa ved 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% o pacity 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.

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/o perator 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 washe d 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 c ompaction 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 vegetationDecember 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 Poultr y 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

e ffectively 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 ap plying 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.)

 Appl y 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, ca lcium 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

op erator, 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 prese rvation 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 stabil ized 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 Fugi tive 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) inch minimum depth
Stabilized Surface. The travelway shall have a relative compaction of  Speed reduction

– enforcement of speeds that redu ce 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 c an 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 f or 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
roadDecember 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 Poultr y 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 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 Pa ving; 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, th e 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 demonstrat ed 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 Poultr y 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) Comment s 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 ven tilation.)

 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 wire

mesh floor set above a liquid manure col lection 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 concret e 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 cleanin g 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

- specif ic controls, but AZ listed
controls are similar to other kinds of facilities, e.g. beef feedlotsDecember 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) Comment s 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 l east 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 sp out 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 co nveyance)

 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 aisl es 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

- bl ocked 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 sol ids (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) Comment s 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.
Th e 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 owne r/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 p er 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 BMPs are listed here for convenience, but more informatio n 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 roa d.

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: 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
benchm arking.

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 Californ ia 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% a s determined by Test
Method No. California
216 of State of California, Business and Transportation Agency Department of Transportation, and conforming to [certainDecember 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) Comment s 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
condit ions 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 grave l;

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
effectiv ely 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

 A pply 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 implemente d 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
th e 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) Comment s re: Imperial San Joaquin (None) language as
much as possible. However, in A.A.C. rule, “unpaved
roads or feed
lanes” me ans 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

genera lly
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 se gment, 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 Unif orm 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

e ffectively 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 veh icle 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 A ny 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 (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) inch minimum depth
Stabilized Surface. The
travelwa y 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) Comment s 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 

### FI II

- 12 Irrigation Districts

General Permit for Irrigation Districts ( Rules A.A.C. R18

- 2

- 61 2 and 61 2.01)
Overarching Overview Overarching Program Requirement West Pinal County Comments re: West Pinal Imperial (Rules 800, 805, and 806) Comments re: Imperia l 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 distri ct 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 rul e.

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 com pliance.

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 irriga tion 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 uphil l 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 dist rict 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 b y 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 rul e 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

Mana gement 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

- 61 2 and 61 2.01)
Overarching Overview Overarching Program Requirement West Pinal County Comments re: West Pinal Imperial (Rules 800, 805, and 806) Comments re: Imperia l San Joaquin (none) best management practices. Any approved modifi cations 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 Requireme nts 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 p hone 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 can als 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, an d 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 no ncompliance 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 requireme nts 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 cove rage, 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 fo r Irrigation Districts ( Rules A.A.C. R18

- 2

- 61 2 and 61 2.01)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. Acce ss 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 approxima tely 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 trave l 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 road s 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 redu ction 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 Stab ilized 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
reduc e 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 remova l 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 Time

Averag ed Regulations (opacity)December 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 53 General Permit fo r Irrigation Districts ( Rules A.A.C. R18

- 2

- 61 2 and 61 2.01)
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 m aintain 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 w hen 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 deter mined 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 limi t 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 a sphalt or other material ofDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIII

- 54 General Permit fo r Irrigation Districts ( Rules A.A.C. R18

- 2

- 61 2 and 61 2.01)
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 effective ly 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 F inal West Pinal PM10 RACM Analysis FIV

- 1 Exhibit F

- IV

– Fugitive Dust Comparison

Comparison of Pinal County Code of Regulati ons (PCCR), Chapter 4, Article 1, West Pinal PM10 Moderate Nonattainment Area Fugitive Dust , to Measures Adopted in Other AreasDecember 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 Imper ial County Air Pollution Control District (ICAPCD) in California. For some Pinal County rule sections, comparison is also made with applicable BACM r equirements implemented in the San Joaquin Valley Air Pollution Control District (SJVAPCD) and South Coast Air Qualit y 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 non

traditional sources throughout the
West Pinal PM 10 nonattainment area:

 Open areas/vacant lots

 Unpaved roads

 Unpaved parking lots

 Paved public roadways The Phoenix FIP

, 40 CFR 52.128

, has specific r egulations 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 regul ate 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 ha ve developed rules specific to construction and agricultural operations for fugitive
dust cause d by those operations in
the West Pinal Nonattainment Area

. The Fugitive Dust Rule appli es to sources not covered under the
A g riculture and Construction Rules.December 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 3

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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/car ryout

 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 tr affic (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
PC CR 4

- 1

- 015.

 Legitimate vehicle test and FIP exemptions are case specific In general, the Pinal County rule isDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 4

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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

r egulations )

 Construction operations ( already cov ered 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 R ule 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 equipmen t (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 a nd 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 agri culture), 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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. [ SJ VAP CD Rule s 80 11 ( 4.0 )

, 8041(4.0), 8051(4.0), 8061(4.0), 8071(4.0) ]

Imperial County Rule s :

 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 cr ops during freezing

 Emergency maintenance of
flood control channels and water spreading basins

 Emergency operation activities to ensure public health and safety (exceptDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 6

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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
activi ty effectiveness)

 Permitted blasting operations

 Specific military training
activities

 Agricultural Operation s subject to Rule 806, Conservation Management Practices, are exempt from specified track

- out, paved and unpaved road, and open area requirements.

 A ny 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 R ule :

 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 providedDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 7

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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

eme rgency

 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 operat ions 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
Un paved Roads and Livestock Operations :

 Public services in compliance with District
Rule 403

 Source specific and caseDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 8

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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

t he 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

- tox ic 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 f or reducing fugitive dust emissions. San Joachin Rule Dust Suppressants
includes : water, hygroscopic

m aterials, chemical stabilizers, and suppression materials (see also
Definition 3.4 “Chemical Stabilization/Suppression.” [SJV APCD Rule 8010(3.7 )]

Chemica l 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. [SJV APCD Rule 8010(3.4 )]

Imperial County C onstruction rules do not explicitly define dust suppressant. Chemical Stabilization/Suppression definitionDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 9

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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

– S udden and
reasonabl y unforeseeable events, including acts of God, requiring
immedi ate 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 un foreseeable 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 er

ror . [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 ARE AS/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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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,

gove rnmental, 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 owne rship

. adjoining a develope d or a partially developed area. The San Joaquin Rule 8011(3.36) a nd 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, count y, 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 roadwa ys . 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 R ules 8011(3.43) and 8061(5.1).] The Pinal County paved public roadway definition is consistent with the appl ication 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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

ro adway. The Phoenix area RACM FIP limits control of unpaved roads to roads owned by governmental or quasi

governmental 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 an y previously
DISTURBED SURFACE AREA which, through the applica tion of CONTROL MEASURES, shows
visual or other evidence of surface crusting and is resistant to wind

driven fugitive dust. Imperial Rule 800 defines “Stabilized Surface” and “Stabilized Unpaved Road.” Stabilized Surface must meet one of the specified

con ditions: 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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, w re cking 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 oper ated 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 th an 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

q uasi

- 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 FI P 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
address es public unpaved roads

. [MC Rule 310.01(231)]

Imperial Rule 805 and San Joaquin
Rul e 8061 both apply to public and private unpaved roads, however, The Pinal County defin it ion and

a p plicability for unpaved public
roads is consistent with the Phoenix
RACM FIP and Maricopa County
SIP

. P rivate agricultural and irrigation district roads and
construction roads are included in control strategies contained in separate rules applic able 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 wi th 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,

st abilization requirements and compliance determinations for each applicable category.

• Failure to implement CONT ROL 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 C oast Rule 403: no visible Pinal County v isible emissionsDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 14

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 co ntrol officer and EPA. dust beyond property line, or 20% opacity if dust due to motorized
vehicle. [SCAQMD Rule 403(d)]

Imperial C ounty Rule 804: 20% opacity. [ICAPCD Rule 804(E.1)]

San Joaquin Rule 8051: 20% opacity. [SJVAPCD Rule 8051(5.0)]

Maricopa C ounty 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)]

P hoenix 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)]

P hoenix 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 a cres 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 ce rtain 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 ge nerally larger than
revi ewed urban area strategies

, however, b ecause 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 nonattai nment 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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]

P hoenix RACM FIP : applies to open areas/vacant lots disturbed by motor
vehicle traffic 5,000 square feet or la rger 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 day s 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
PM 10 emissions

. No comparable requirement in Imperial County Rule 804 or San Joaqu in 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
PM 10

.

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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 b e 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 nonatta inment 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

c oncentrations 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 P hoenix RACM FIP: same measures as Pinal County. [40 CFR 52.128(d)(4)(i)] The Pinal rule is a s 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 non

erodible 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

- Standi ng 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 S ection 501.3

. [40 CFR 52.128(b)(16)] The Pinal rule is a s 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 ft 2 used for p arking, maneuvering, material handling, or storing motor The Phoenix RACM FIP, 40 CFR 52.128, is mos t 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 bu t 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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
ft 2 or less

. The FIP requires 20% opacity and application of controls (pave, chemical stabilizers, gravel, or approved al ternative)

. [40 CFR 52.128(b)(17), 52.128 (c), and 52.128 (d)]

The rule a lso 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 te st and development. Owners and operators of unpaved parking lots when vehicles are par ked 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 di fferent control measures for lots used 35 plus days/y ear versus lot s used less than 35days/y ea r. Also, residential areas

are tr eated differently and have a 3,000 ft 2 applicability 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 , applic able measures include watering, gravel, chemical stabilizers, and paving. Notification
and s tabilization 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
traffi c count shall measure MOTOR
VEHICLE traffic over a 48

- hou r 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 t he requirements described in 4

- 1

- 030.4.A.i and shall comply with one
of the CONTROL MEASURE S
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 R ule 8061: Control
threshold of 26 or more A nnual Average Dai ly Trips (A ADT )

. 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 A verage V ehicle T rips 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 Co unty 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 publicDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 21

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 th an 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 o f 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 C ounty 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 Stabi lization San Joaquin R ule 8061: Rule limits emissions to 20 percent opacity for
roads with 26 or more AADT

. [SJVAPCD Rule 8061( 5.2 )]

South Coast R ule 1186 : No opacity
limit. [SCAQMD Rule 1186]

Imperial County Rule 805: Rule limits emissions to 20 perce nt 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 d efinition of unpaved road at PCCR 4

- 1

- 020 above) . Measures applicable to private unpaved roads are included in the Pinal County Construction and Agricultures R ules (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

app roach 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 revi e wed rules did not c ontain 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 R OADS 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,
roadmi x, 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 requir es 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 RuleDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 23

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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

o wner/operator of unpaved public
road s is r equired to p ave mini mum 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

. R equires compliance with stabilization measures: pave, chemical stabilizers, watering, gravel, road closure, or other approved method. Includ es a schedule to pave an average of 1 0 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 t han water, gravel. Control measures effectively implemented when unpaved roadwayDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 24

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 De position o n 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 disco very, remove the dirt/mud from the paved public roadway and restrict traffic, if necessary, until the material can be Deposition o n Road/Trackout San Joaquin’s rule 8061 regulates the agency with the primary responsibility of cle an

- 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 o n Road/Trackout
Pi nal’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
Th e Pinal County rule requires
stabilization of road shoulders
similar to South Coast ’s measures for
road shoulder maintenanc e.December 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 25

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 remova l 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 require s 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 cause d 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

app licable 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, theDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 26

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 info rmation 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

. Con trols 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 o f 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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

pa ved 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 additiona l 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

av erage 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: RequiresDecember 21, 2015 Final West Pinal PM10 RACM Analysis FIV

- 28

Exhibit F

- IV : Comparison of Pinal County Code of Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 re construction of existing nonconforming roads within one year. [CC Rule 93(93.2)]

RACM in Appendix C.1 of the
General Preamble r equire s curbing and pave or stabilize (chemically or with vegetat ion) 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

suppr essant 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 recordkeepin g 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 writt en request. Reporting Requirements
PCCR 4

- 1

- 045. Reporting Requirements Requires e ach 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 Ja nuary 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 R ule 8061

- Paved a nd Unpaved Roads: Requires annu al 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 )]

Mar icopa 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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 leas t 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 Regula tions (PCCR), Chapter 4, Article 1, West Pinal PM 10 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
F UGITIVE 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
retentio n 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 AssociationDecember 21, 2015 Final West Pinal PM10 RACM Analysis FV

- 2



## Information o n 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 reduc e 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 th e 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 Ru les). 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 efficien t 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 fr om 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 mo nitor. 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
emissi ons. 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 co nsistent 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 a s 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 pers onnel 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.