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Anchorage Anchorage CO Limited Maintenance CO Limited Maintenance

PlanPlan A plan addressing the second 10 A plan addressing the second 10

years of the 2004 -2024 CO years of the 2004 -2024 CO maintenance planning periodmaintenance planning period

Department of Health and Human ServicesDepartment of Health and Human ServicesMunicipality of AnchorageMunicipality of Anchorage

October 2012October 2012

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Anchorage’s twenty year CO Maintenance planning period Anchorage’s twenty year CO Maintenance planning period runs from July 23, 2004 through July 22, 2024.runs from July 23, 2004 through July 22, 2024.

The Anchorage revision must address second ten years The Anchorage revision must address second ten years (July 2014 – July 2024)(July 2014 – July 2024)

The draft Anchorage CO Maintenance Plan revision was The draft Anchorage CO Maintenance Plan revision was prepared using the limited maintenance plan (LMP) option.prepared using the limited maintenance plan (LMP) option.

Section 175A of the Clean Air Act Section 175A of the Clean Air Act requires the submission of a maintenance requires the submission of a maintenance plan revision midway through the twenty plan revision midway through the twenty

year maintenance planning period.year maintenance planning period.

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What the heck is a “limited What the heck is a “limited maintenance plan”?maintenance plan”?

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EPA offers LMP option to areas where the design value is 85% or less of the CO standard.EPA offers LMP option to areas where the design value is 85% or less of the CO standard.

– CO NAAQS = 9 ppm (as 8-hr average)CO NAAQS = 9 ppm (as 8-hr average)– 85% of CO NAAQS = 7.65 ppm85% of CO NAAQS = 7.65 ppm– Anchorage DV (2011) = 6.0 ppmAnchorage DV (2011) = 6.0 ppm

Preparation of the CO maintenance plan revision under the LMP option is simpler and less Preparation of the CO maintenance plan revision under the LMP option is simpler and less rigorous than a full maintenance plan revision. rigorous than a full maintenance plan revision.

Once EPA approves an LMP, regional air quality conformity procedures are greatly simplified.Once EPA approves an LMP, regional air quality conformity procedures are greatly simplified.

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The Anchorage CO LMP was prepared in The Anchorage CO LMP was prepared in accordance with EPA guidance contained in the accordance with EPA guidance contained in the

“Paise memo” drafted in 1995. “Paise memo” drafted in 1995.

This guidance discusses how the five core This guidance discusses how the five core provisions of an LMP should be addressedprovisions of an LMP should be addressed::

1.1. attainment inventoryattainment inventory2.2. maintenance demonstration maintenance demonstration 3.3. monitoring to verify continued attainment of the CO monitoring to verify continued attainment of the CO

NAAQS NAAQS 4.4. a contingency plana contingency plan5.5. conformity determination requirements under an LMP. conformity determination requirements under an LMP.

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Attainment inventoryAttainment inventorySources of CO Emissions in Anchorage Bowl (2007)Sources of CO Emissions in Anchorage Bowl (2007)

Source CategoryCO Emitted

(tons per day) % of total

Motor vehicle – running emissions 40.5 25.4%

Motor vehicle – start emissions 84.8 53.4%

Motor vehicle – extended idling by combination long-haul trucks 0.3 0.1%

Subtotal – Motor Vehicles 125.6 78.9%

Ted Stevens Anchorage International Airport Operations 12.4 7.8%

Merrill Field Airport Operations 0.7 0.4%

Wood burning – fireplaces and wood stoves 6.2 3.9%

Space heating – natural gas 3.8 2.4%

Miscellaneous (railroad, marine, snowmobiles, snow removal, portable electrical generators, welding, etc.) 9.3 5.8%

Point sources (power generation, sewage sludge incineration) 1.3 0.8%

Subtotal – Other Sources 33.7 21.1%

TOTAL – ALL SOURCES 159.3 100%

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GardenSeward

Hwy Turnagain DHHS DVPaise

2002 5.7 5.2 7.7 7.7

2003 5.7 5.4 6.7 6.72004 6.4 5.5 7.9 7.9

2005 6.4 7.9 7.9

2006 4.8 6.1 6.12007 4.3 6.1 6.12008 3.8 5.5 3.1 5.52009 4.4 5.8 3.6 5.82010 4.4 6.0 3.6 6.02011 3.8 6.0 2.8 6.0

Highest 2nd Max 8-hr Concentration Measuredin Preceding Two-Years (all values in ppm)

Maintenance DemonstrationMaintenance DemonstrationThe update must show that the DV in Anchorage qualifies for the LMP option

DV has been ≤ 7.65 ppm since 2006.

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The update continues the commitment to implement the The update continues the commitment to implement the primary control measures currently included in the primary control measures currently included in the maintenance plan:maintenance plan:

Air quality public awareness Air quality public awareness programprogram

Transit marketingTransit marketing

Carpooling and VanpoolingCarpooling and Vanpooling

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Monitoring to verify continued Monitoring to verify continued attainment of the CO NAAQSattainment of the CO NAAQS

The update commits Anchorage and/or State of Alaska to The update commits Anchorage and/or State of Alaska to continued monitoring to verify compliance with the CO continued monitoring to verify compliance with the CO standardstandardThe current CO network includes four sites. The highest concentrations are measured at the Turnagain site in residential Spenard.

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Contingency planContingency plan

The previous plan included a commitment to implement at least one The previous plan included a commitment to implement at least one of six contingency measures if a future violation of the CO standard of six contingency measures if a future violation of the CO standard occurs. The update affirms this commitment.occurs. The update affirms this commitment. Menu of Contingency MeasuresMenu of Contingency Measures

1)1) Increasing public awareness, transit marketing and carpool/vanpool Increasing public awareness, transit marketing and carpool/vanpool effortsefforts

2)2) Curtailing or limiting the use of fireplaces and woodstoves when high CO Curtailing or limiting the use of fireplaces and woodstoves when high CO is predicted is predicted

3)3) Offering reduced fares or free transit for employees of companies that Offering reduced fares or free transit for employees of companies that contribute to transit subsidiescontribute to transit subsidies

4)4) Reinstating the engine block heater installation subsidyReinstating the engine block heater installation subsidy5)5) Reinstating the ethanol blended gasoline requirementReinstating the ethanol blended gasoline requirement6)6) Reinstating the I/M Program Reinstating the I/M Program

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Conformity determinations Conformity determinations under an LMPunder an LMP

A motor vehicle emission budget is not required in an LMP.A motor vehicle emission budget is not required in an LMP.

EPA guidance states that “emissions budgets in limited EPA guidance states that “emissions budgets in limited maintenance plan areas may be treated as essentially not maintenance plan areas may be treated as essentially not constraining.” constraining.”

The EPA has concluded that for transportation purposes, the The EPA has concluded that for transportation purposes, the emissions in a qualifying LMP area need not be capped for the emissions in a qualifying LMP area need not be capped for the maintenance period and thus no emissions budget is required in maintenance period and thus no emissions budget is required in the maintenance plan.the maintenance plan.

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AMATS TAC release of draft CO LMP for 30-day public review Sept 13, 2012

AMATS AQ Committee review and recommendation Oct 2, 2012

AMATS TAC recommendation on CO LMP Oct 11, 2012

AMATS Policy Committee review/approval of CO LMP Oct 25, 2012

Anchorage Assembly considers CO LMP for adoption Nov 13, 2012

ADEC public review process Dec 2012 – Jan 2013

ADEC legal review, adoption of CO LMP as a revision to the SIP Feb 2013 – May 2013

ADEC submits SIP revision to EPA for approval Jun 2013

EPA adequacy review of new conformity procedure (up to 90 days) Jun 2013 – Aug 2013

Tentative Approval Schedule