HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 07/20/2010 - RESOLUTION 2010-043 APPROVING THE REVISED CARBON M DATE: July 20, 2010 AGENDA ITEM SUMMARY
STAFF: Lucinda Smith FORT COLLINSCOUNCIL
Ail
Resolution 2010-043 Approving the Revised Carbon Monoxide Maintenance Plan Fort Collins Attainment/Maintenance
Area and Directing the City's Representative to the North Front Range Metropolitan Planning Organization to Support
the Same.
EXECUTIVE SUMMARY
Fort Collins violated the federal carbon monoxide health standard in the 1980s,with the last violation occurring in 1991.
In 2003,a Carbon Monoxide(CO)Maintenance Plan was adopted by the U.S. Environmental Protection Agency(EPA)
that identified federally-enforceable control measures to maintain compliance with the standard through 2015.
Fort Collins carbon monoxide levels are now well below the federal health standard,largely due to the benefit of federal
new motor vehicle emissions standards. However, as a routine matter,the federal Clean Air Act and the EPA require
a revision to the Maintenance Plan to show continued attainment of the CO standard for a second ten-year term from
2015 through 2025. The Colorado Department of Public Health and Environment has prepared a draft Revised CO
Maintenance Plan for Fort Collins covering the period from 2015 through 2025. The Revised Plan retains all the CO
control measures identified in the original Maintenance Plan. This resolution indicates City Council approval of the
Revised Plan and directs the City's representative to the North Front Range Metropolitan Organization to support the
Revised Plan when it takes formal action on the Plan in August 2010.
BACKGROUND / DISCUSSION
History
Fort Collins violated the federal carbon monoxide health standard in the 1980s,with the last violation occurring in 1991.
In 2003,a Carbon Monoxide(CO)Maintenance Plan was adopted bythe U.S.EPA that identified federally-enforceable
control measures to maintain compliance with the standard through 2015.
In the last two decades carbon monoxide levels have fallen significantly in Fort Collins and across the nation. These
declines are largely attributable to the federal new car emissions standards. See Attachment 1 for the trends in CO
levels locally and nationally.
As a routine matter, the federal Clean Air Act and the U.S. EPA require a revision to the Maintenance Plan to show
continued attainment of the federal CO standard for a second ten-year term from 2015 through 2025. The Colorado
Department of Public Health and Environment has prepared a draft Revised CO Maintenance Plan for Fort Collins
covering the period from 2015 through 2025.
The timeline of carbon monoxide planning and implementation of control strategies in Fort Collins is given below.
1979: Fort Collins designated nonattainment for CO under provisions of the Clean Air Act
1981: Motor vehicle inspection/maintenance program begins.
1982: First State Implementation Plan (SIP) element for Fort Collins adopted by the Colorado Air Quality
Control Commission (AQCC) to bring area into attainment by 1987.
1987-1888: Attainment was not reached, and the EPA notified Colorado of need to correct SIP deficiencies.
1988 Oxyfuels program begins.
1991: Fort Collins designated a"moderate" nonattainment area under the Clean Air Act revisions of 1990
and required to attain the CO National Ambient Air Quality Standards (NAAQS) by December 31,
1995.
1992: Fort Collins attained the CO NAAQS and has shown declining levels of CO since that time.
1997-2000: Emissions inventories updated and submitted to the EPA as required by the 1990 Clean Air Act
Amendments.
July 20, 2010 -2- ITEM 21
2002: The AQCC approves a request to the EPA to redesignate Fort Collins as an attainment area.
2002: Fort Collins City Council passes Resolution 2002-047 indicating support forthe redesignation request
and Maintenance Plan
2003: The redesignation request and Maintenance Plan are approved by the U.S. EPA in 2003. The
inspection/maintenance and oxyfuels programs are removed as a federally-required SIP control
measure effective 2004, but continue as local control programs after 2004.
2005: AQCC votes to discontinue inspection/maintenance and oxyfuels programs effective January 1,2007,
allowing a phase-out period.
2010: AQCC considers revised CO attainment/maintenance plan that shows continued attainment of the
CO standard through a second ten-year period through 2025.
Previous Council Action
In 2002, City Council passed Resolution 2002-047 approving the request for redesignation to attainment for carbon
monoxide and indicating support for the original CO Maintenance Plan.
Elements of draft 2010 Revised Maintenance Plan
• "Limited Maintenance Plan" Approach used for this Revision to the Plan
Because Fort Collins CO levels are well belowthe federal health standard,the Maintenance Plan can be updated using
the"Limited Maintenance Plan Option"allowed by the U.S. EPA. This option is available when CO levels are below
85% of the standard, as they are in Fort Collins. The Limited Maintenance Plan approach requires development of
an emissions inventory but does not require the inventory to be projected for future years. The maintenance
demonstration is considered to be satisfied if ongoing monitoring data shows that the area continues to meet the air
quality criteria for limited maintenance areas, i.e., remains below 85% of the standard.
Transportation conformity is required by the Clean AirAct in areas that violated federal health standards to ensure that
federallyfunded transportation projects will not cause new air quality violations or delay timely attainment of the federal
standards. Conformity determinations are required to ensure that transportation plans do not exceed established
emissions thresholds, or"budgets" for a maintenance area. The Fort Collins Revised Maintenance Plan presumes
transportation conformity past 2015, and emissions budget tests are no longer necessary once Fort Collins'existing
budgets expire in 2015. The EPA's rationale behind allowing this is that it is unreasonable to expect that such an area
will experience so much growth during the maintenance period that a violation of federal health standard would occur.
• CO Control Measures in Place under the Revised Plan
The entire suite of federally-enforceable CO control measures in Fort Collins' original maintenance plan will remain
in place under the Revised Plan, which is effective until 2025. They are:
• Federal new car tailpipe standards
• Federal small engine and non-road emission standards
• AQCC Reg. 3 and Reg. 6—federal performance standards for new stationary sources
• AQCC Reg 4-Wood Stove Program
• AQCC Common Provision Rule (industrial source control program)
• CO Monitoring and Tracking
The Air Pollution Control Division (APCD)will continue to operate a CO monitor to verify the continued attainment of
the CO federal health standard in Fort Collins. If measured mobile source parameters (e.g., vehicle miles traveled,
congestion,fleet mix,etc.)change significantly over time,the APCD will perform the appropriate studies to determine
whether additional and/or re-sited monitors are necessary. In addition, City staff will track CO trends and investigate
any increases in CO concentrations in accordance with City policy to"continually improve air quality as the city grows".
Exceeding the federal health standard would automatically trigger mandatory implementation of contingency measures
listed in the Revised Maintenance Plan. Should elevated CO levels occur that are below the federal health standard,
local, voluntary efforts would be initiated by the City, and potentially the MPO and APCD, to evaluate potential
contingency measures.
July 20, 2010 -3- ITEM 21
• Considerations Leading to Staff Conclusion
City staff has reviewed the draft Revised Maintenance Plan and support its adoption for several reasons:
• The Plan contains monitoring data and an emissions inventory to support an attainment finding through 2025.
• It contains control measures (especially the federal new car emissions standards) that are expected to
adequately limit the growth of carbon monoxide emissions in Fort Collins.
• Continued CO monitoring in Fort Collins will enable tracking of progress and will identify any unanticipated
changes in trend, should they occur.
The enhanced motor vehicle inspection program(IM240)authorized by the AQCC for the North Front Range starting
in November 2010 was put in place to reduce ozone precursor emissions, not carbon monoxide. However, the
program has the co-benefit of reducing CO emissions as well,and will require regular monitoring of light duty fleet CO
emissions which constitute the majority (74%) of all CO emissions in Fort Collins.
Time Line for Revised Maintenance Plan
Following the North Front Range Metropolitan Planning Organization action on the Plan in August,the AQCC will hold
a public hearing in December 2010 to consider its adoption. In 2011, the Revised Plan will be submitted to the
Colorado Legislative and then the EPA for final approval. No additional revisions of the Maintenance Plan will be
needed unless circumstances change.
FINANCIAL / ECONOMIC IMPACTS
There is no financial impact to the City at this time from adoption of the Revised Maintenance Plan. In the long term,
if carbon monoxide levels rise to the point of violating the federal standard,availability of federal transportation funding
might be jeopardized. This is not anticipated to happen because carbon monoxide levels are now 80 percent below
the standard.
ENVIRONMENTAL IMPACTS
It is not anticipated that the health of the physical environment will be impacted at all by this action or that carbon
monoxide levels will increase as a result of this action.
STAFF RECOMMENDATION
Staff recommends adoption of the Resolution.
Larimer County staff support the Revised Maintenance Plan for Fort Collins. See Attachment 4 for their letter of
support to the Colorado Department of Public Health and Environment.
BOARD / COMMISSION RECOMMENDATION
The Air Quality Advisory Board reviewed the draft Revised Maintenance Plan on June 21 and voted unanimously to
recommend its adoption. (Attachment 3)
July 20, 201Q -4- ITEM 21
PUBLIC OUTREACH
No general public outreach was held on this matter because the Revised Plan retains all the CO control measures
identified in the original Maintenance Plan and because Fort Collins' carbon monoxide levels are so far below the
federal standard.
ATTACHMENTS
1. Revised Carbon Monoxide Maintenance Plan: Fort Collins Attain ment/Maintenance Area
2. Graphs of Fort Collins and National Carbon Monoxide Trends
3. Air Quality Advisory Board Minutes from June 21, 2010
4. Larimer County staff letter of support for the Revised Maintenance Plan
Attachment 1
Revised Carbon Monoxide Maintenance Plan
Fort Collins Attainment/Maintenance Area
Attainment/Maintenance Plan Revision for Second 10- year Maintenance Period:
• Submitted to EPA -- TBD
• Adopted by the Colorado Air Quality Control Commission -- TBD
Original Redesignation Request and Attainment/Maintenance Plan :
• Adopted by The Colorado Air Quality Control Commission, July 18, 2002
• Approved by The U. S. Environmental Protection Agency, July, 22, 2003
of .. cal
A o� Revisions prepared by :
Fe. 7 9d
o o The Air Pollution Control Division
r Colorado Department of Public Health & Environment
1876 4300 Cherry Creek Drive South
Colorado Department Denver, CO 80246- 1530
of Public Health ( 303 ) 692-3100
and Environment
Background
The purpose of this revision to the Fort Collins carbon monoxide (CO) attainment/maintenance
plan is to show continued attainment of the federal CO standard for a second ten-year term (from
2015 through 2025 ) as required by the federal Clean Air Act and the U. S . Environmental
Protection Agency (EPA) .
The Fort Collins area was originally designated as nonattainment for CO in 1979 under
provisions of the 1977 Clean Air Act (CAA) . This designation was reaffirmed by the 1990 CAA,
and Fort Collins was designated as a "moderate" CO nonattainment area with a design value of
less than 12 . 7 parts per million, effective November 15 , 1990 (56FR 56694, Nov. 6 ,
1991 ) ,
The EPA approved a CO redesignation request and maintenance plan for the Fort Collins area on
July 22, 2003 (Federal Register Notice : 68 FR 43316) . That plan established an attainment year
of 1992 , and showed continued maintenance through 2015 . The plan removed three control
measures from the federally enforceable SIP effective January 1 , 2004 :
1 . Oxygenated Fuels Program
2 . Basic motor vehicle inspection/maintenance (I/M) program
3 . Contingency measures included in the 1982 attainment SIP element.
The oxygenated fuels program and the basic I/M control measures were removed because they
were no longer needed to show attainment of the CO national ambient air quality standards
(NAAQS) . Removal of the control programs complied with state requirements that maintenance
plans be no more stringent than federal requirements .
The contingency measures in the 1982 attainment SIP were removed because attainment areas
are not required to have pre-selected contingency measures .
History
1979 : Fort Collins designated nonattainment for CO under provisions of the Clean Air Act
1981 : Motor vehicle inspection/maintenance program begins .
1982 : First State Implementation Plan element for Fort Collins adopted by the Colorado Air
Quality Control Commission to bring area into attainment by 1987 .
1987-88 : Attainment was not reached, and EPA notified Colorado of need to correct SIP
deficiencies .
1988 : Oxyfuels program begins.
1991 : Fort Collins designated a "moderate" nonattainment area under the Clean Air Act
revisions of 1990 and required to attain the CO NAAQS by December 31 , 1995 .
1992 : Fort Collins attained the CO NAAQS and has shown declining levels of CO since that
time.
1997-2000 : Emission inventories updated and submitted to EPA as required by the 1990 CAAA.
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June 16, 2010 — Fort Collins Attainment/Maintenance Plan Revision
2001 : Clean Screen pilot program begins in 2001 , with full testing implemented in 2002 . The
program is not a SIP control measure, but rather a local voluntary control effort to screen
clean vehicles out of the mandatory emissions inspection program.
2002 : The AQCC approves a request to EPA to redesignate Fort Collins as an attainment area.
The redesignation request and maintenance plan is approved by EPA in 2003 . The I/M and
oxyfuels programs are removed as a federally-required SIP control measure effective
2004, but continue as local control programs after 2004 .
2005 : AQCC votes to discontinue I/M and oxyfuels effective January 1 , 2007, allowing a phase
out period.
2008 : While not part of a carbon monoxide strategy nor part of this CO SIP, an ozone action plan
is adopted by the AQCC which includes an enhanced I/M program in parts of Larimer and
Weld Counties as a state-only requirement to control ozone . The program is scheduled to
begin by November 2010 .
2010 : AQCC considers revised CO attainment/maintenance plan that shows continued
attainment of the CO standard through a second ten-year period through 2023 .
Limited Maintenance Plan Option
Colorado is using the Limited Maintenance Plan option in preparing this second ten-year
revision. The option is explained in EPA guidance of October 6, 1995 , from Joseph W. Paisie,
Group Leader, Integrated Policy and Strategies Group, U. S . Environmental Protection Agency.
The guidance allows for a less rigorous approach than was previously required in developing
maintenance plans for CO nonattainment areas that have design values at or below 7 . 65 ppm (85
percent of the CO NAAQS) . Fort Collin' s design value in this plan revision is just 3 . 0 ppm (33
percent of CO NAAQS) . The design value was determined by using the highest second-highest
maximum 8-hour value of eight consecutive quarters . This value is referred to as "the highest of
the second highs" in a June 18 , 1990 EPA memo from Willam G. Laxton that describes how to
establish design values for both carbon monoxide and ozone.
The limited maintenance plan approach requires development of an emissions inventory but does
not require the inventory to be projected for future years . The maintenance demonstration is
considered to be satisfied if the monitoring data show that the area is meeting the air quality
criteria for limited maintenance areas (at or below 7 . 65 ppm or 85 percent of the CO NAAQS) .
Transportation conformity is demonstrated by showing that transportation plans are consistent
with the emissions budget. The guidance for limited maintenance plans states that emissions
budgets may be treated as essentially non-constraining for transportation conformity because it is
unreasonable to expect that such an area will experience so much growth during the maintenance
period that a violation of the CO NAAQS would result. Therefore, the "budget test" of the
transportation conformity rule is met, according to the guidance .
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June 16 , 2010 — Fort Collins Attainment/Maintenance Plan Revision
Continued Attainment of the Carbon Monoxide Standard
Attainment of the national ambient air quality standard for carbon monoxide is demonstrated
when monitoring data for each site show no more than one exceedance per year of the 8-hour (9
ppm) and 1 -hour (35 ppm) standards . Fort Collins has never exceeded the 1 -hour standard, so
this maintenance plan only addresses the 8 -hour standard. The 8-hour standard has not been
exceeded in Fort Collins since 1991 .
Monitoring data for 2002-2009 demonstrates that Fort Collins continues to attain/maintain the
national standard for carbon monoxide as required by 40 CFR 50 . 8 . Data from 2002 through
2009 are provided to demonstrate continual attainment/maintenance since the redesignation to
attainment was promulgated in 2003 . This demonstration is based on quality assured monitoring
data representative of the location of expected maximum concentrations of carbon monoxide in
the area (708 S . Mason St. in central Fort Collins) . Data presented is the second highest
maximum value recorded at the monitors . The second maximum value is used by EPA for
determining compliance with the CO NAAQS .
The monitoring data presented in Table 1 verifies that Fort Collins continues to attain the
national 8 -hour standard for carbon monoxide. Data recovery rates for the monitor exceeded the
75 percent completeness requirements for all years . All State and Federal quality assurance
procedures were complied with, further substantiating the validity of the measurements as
indicators of ambient carbon monoxide levels in Fort Collins .
Table 1
2002-2009, 2°d Maximum 8-Hour Carbon Monoxide Summary for Fort Collins
Standard: 2°d Maximum 8-Hour = 9 ppm
Year 2002 2003 2004 2005 2006 2007 2008 2009
CO parts per million 2 . 9 2 . 5 3 . 1 2A 2 . 7 2A 3 . 0 1 . 8
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June 16 , 2010 — Fort Collins Attainment/Maintenance Plan Revision
Figure 1 . Fort Collins Attainment/Maintenance Area
Ft Collins CO Attainment Area
•
7
r �J
Legend
Heliports
Point Sources
• CO Point Sources
Local Roads
r RAI L_LI N ES_100K_FtColl
HIGHWAYS_FtCollins
JL Railroads
I `
CO Attainment Area
HIGHWAYS
�l Major Roads
FLINCCLASS
1 Interstate-Rural
11 Interstate-Urban
PollutionMontitors
J CO Monitor
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June 16 , 2010 Fort Collins Attainment/Maintenance Plan Revision
Emission Inventories
This attainment/maintenance plan revision utilizes 2008 as an attainment year for emission
inventories, which is the same year from which the 3 . 0 ppm design value was derived. Emission
inventories for a typical winter day are presented in Table 2 for the 2008 attainment year. Each
inventory accounts for the emission control programs effective during that period.
The APCD developed the 2008 emission inventory using U. S . Environmental Protection Agency
(EPA) approved emissions modeling methods, including EPA ' s MOVES model and local VMT
data for on-road mobile source emissions, EPA ' s non-road model, local demographic
information for area and off-road sources, and reported actual emissions for point sources . The
inventory represents average daily winter emissions . The MOVES and non-road model inputs
represent these average daily winter conditions. Heating and wood burning emissions were
apportioned from annual emission estimates by heating degree day data from the Western
Regional Climate Center. Other source categories were apportioned from annual to daily by
dividing by 365 .
For more detailed information about inventory development, please see the Technical Support
Document included as an appendix to this maintenance plan.
Table 2 .
Fort Collins 2008 Attainment/Maintenance Area Emissions Inventory
(Tons Per Day)
Emission Inventory Summary CO (t/d )
HELIPORT 0 . 009
Commercial Cooking 0 . 041
Fuel Combustion 0 .428
Non-Road 14 . 161
Structure Fires 0 . 026
Woodburning 7 . 642
Highway Vehicles 64 . 624
Biogenic 0 .275
Railroads 0 .006
Point Sources 0 .503
TOTAL 1 87.715
Note: Results are reported with three decimal place precision to provide representation of smaller source categories.
This level of precision is not intended to suggest a level of accuracy.
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June 16, 2010 — Fort Collins Attainment/Maintenance Plan Revision
Enforceable Control Measures for the Maintenance Period
• Federal Motor Vehicle Emissions Control tailpipe standards and regulations,
including those for small engines and non-road mobile sources . Credit is taken
for these federal requirements, but they are part of a federally administered
program and not a state commitment of the Colorado SIP .
• Air Quality Control Commission (AQCC) Regulation No . 3 , Air Pollution
Emission Notices - Permits
• AQCC Regulation No . 4, Wood Stove Standards
• AQCC Regulation Number 6, New Source Performance Standards
• AQCC Common Provisions Rule
The Common Provisions and Regulation No . 6 delineate industrial source control programs . The
Common Provisions, and Parts A and B of Regulation No . 3 , are already included in the
approved Colorado SIP . Regulation No. 6 and Part C of Regulation No . 3 implement the federal
standards of performance for new stationary sources and the federal operating permit program.
The revised Fort Collins attainment/maintenance plan makes no changes to these regulations .
Maintenance Demonstration
This maintenance plan utilizes EPA ' s Limited Maintenance Plan option, as explained above . The
maintenance demonstration is considered to be satisfied if the monitoring data show that the area
is meeting the air quality criteria for limited maintenance areas (at or below 7 . 65 ppm or 85
percent of the CO NAAQS) . The design value for the Fort Collins CO attainment/maintenance
area is 3 . 0 ppm (33 percent of CO NAAQS), which is the highest second maximum
concentration for the 2008-2009 monitoring period. Therefore, the maintenance demonstration is
satisfied.
Transportation Conformity
Under the limited maintenance plan approach, transportation conformity is demonstrated by
showing that transportation plans are consistent with any existing emissions budgets . When any
existing budgets expire, conformity is then presumed and regional analyses and emission budget
tests for transportation conformity are no longer necessary. The guidance for limited
maintenance plans states that emissions budgets may be treated as essentially non-constraining
for transportation conformity because it is unreasonable to expect that such an area will
experience so much growth during the maintenance period that a violation of the CO NAAQS
would result. Therefore, the "budget test" of the transportation conformity rule is met, according
to the guidance .
6
June 16, 2010 — Fort Collins Attainment/Maintenance Plan Revision
For the Fort Collins attainment/maintenance area, the EPA-approved emission budgets are 99
tons of CO per day (2005 -2009), 98 tons per day (2010-2014), and 94 tons per day (2015 and
beyond) . According to the Limited Maintenance Plan guidance, these budgets are to remain in
place, and conformity with these budgets must be demonstrated, through the year 2015 .
Beginning in 2016, the budgets expire.
Once the Fort Collins CO attainment/maintenance area under the Limited Maintenance Plan
option is not subject to the budget test, the area remains subject to other transportation
conformity requirements .
Monitoring Network / Verification of Continued Attainment
The Air Pollution Control Division (APCD) will continue to operate an appropriate air quality
monitoring network in accordance with 40 CFR Part 58 to verify the continued attainment of the
CO NAAQS . If measured mobile source parameters (e .g. , vehicle miles traveled, congestion,
fleet mix, etc .) change significantly over time, the APCD will perform the appropriate studies to
determine whether additional and/or re-sited monitors are necessary. An annual review of the
NAMS/SLAMS air quality surveillance system will be conducted in accordance with 40 CFR
5 8 . 10 to determine whether additional and/or re-sited monitors are necessary and to determine
whether the system continues to meet the monitoring objectives presented in Appendix D of 40
CFR Part 58 ,
Contingency Plan
Section 175A(d) of the CAA requires that the maintenance plan contain contingency provisions
to assure that the State will promptly correct any violation of the CO NAAQS which occurs in
the Fort Collins attainment/maintenance area.
The contingency plan must ensure that the contingency measures are adopted expeditiously once
the need is triggered. The primary elements of the contingency plan involve the tracking and
triggering mechanisms to determine when contingency measures are needed and a process for
implementing appropriate control measures.
Tracking
The tracking plan for the Fort Collins area consists of continuous carbon monoxide monitoring
and analysis of CO concentrations by the APCD . The APCD will notify the EPA, the AQCC ,
the NFRMPO and local governments of any exceedance of the CO standard within 30 days of
occurrence . The ongoing regional transportation planning process carried out by the NFRMPO
in coordination with the CDOT, the APCD, the AQCC, and the EPA, will serve as another
means of tracking mobile source CO emissions into the future. Since revisions to the regions '
transportation improvement programs are prepared every four years, which must go through a
transportation conformity determination, a process is in place to periodically review the vehicle
miles traveled (VMT) and mobile source emissions of CO presented in this maintenance plan.
Triggering and Response
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June 16 , 2010 Fort Collins Attainment/Maintenance Plan Revision
Triggering of the contingency plan does not automatically require a revision of the SIP, nor is the
area necessarily redesignated once again to nonattainment. Instead, the State will have an
appropriate time-frame to correct a violation by implementing one or more adopted contingency
measures . In the event that violations continue to occur after contingency measures have been
implemented, additional contingency measures will be implemented until the violations are
corrected.
An exceedance of the CO NAAQS (any value over 9 . 5 ppm) may trigger a voluntary, local
process by the NFRMPO and APCD to identify and evaluate potential contingency measures .
However, the only federally enforceable trigger for mandatory implementation of contingency
measures shall be a violation of the CO NAAQS . Specifically, this would be a second value of
9 . 5 ppm or higher at the same monitor during any calendar year.
The State will move forward with mandatory implementation of contingency measures under the
SIP if a violation of the CO NAAQS occurs . No more than 60 days after being notified by the
APCD that a violation occurred, the NFRMPO, in conjunction with the APCD, the AQCC and
local governments, will initiate a subcommittee process to begin evaluating potential
contingency measures . The subcommittee will present recommendations within 120 days of
notification, and the recommended contingency measures will be presented to the AQCC within
180 days of notification.
The AQCC will then hold a public hearing to consider the recommended contingency measures,
along with any other contingency measures the AQCC believes may be appropriate to effectively
address the violation. The necessary contingency measures will be adopted and implemented
within one year after a violation occurs .
List of Potential Contingency Measures
The NFRMPO and the APCD may choose one or more of the following measures to recommend
to the AQCC for consideration. The measures will be designed to bring the area quickly back
into compliance with the CO NAAQS .
• An enhanced vehicle inspection and maintenance (I/M) program as set forth in AQCC
Regulation No. 11 , with the addition of any on-board diagnostics components required by
federal law. While an enhanced inspection and maintenance program is already required
in Fort Collins through the Ozone Action Plan, the program is "state-only" and as such is
not federally enforceable and could be eliminated in the future without regard to the Fort
Collins CO attainment/maintenance plan. By placing an enhanced I/M program in this
Fort Collins CO attainment/maintenance plan, and making any adjustments to achieve
maximum carbon monoxide benefits, the program would become a federally enforceable
contingency measure .
• A 2 . 7% oxygenated gasoline program as set forth in AQCC Regulation No. 13 as of
September 2009 .
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June 16, 2010 — Fort Collins Attainment/Maintenance Plan Revision
• Re-establishing nonattainment new source review permitting requirements for stationary
sources.
• In addition to these potential contingency measures, the State may evaluate other
potential strategies, including but not limited to, transportation control measures and
mandatory wood burning restrictions, in order to address any future violations in the most
appropriate and effective manner possible.
Subsequent Maintenance Plan Revisions
The Clean Air Act requires that a maintenance plan revision be submitted to EPA demonstrating
that the CO standard will be maintained for a second ten-year period. The initial maintenance
plan was approved by EPA in 2003 and showed attainment through 2015 .
The purpose of this final revision is to demonstrate maintenance for a second 10-year period
after the first 10-year period since redesignation, (through 2025) . This plan utilizes the Limited
Maintenance Plan option to demonstrate continued maintenance through a second ten-year
period by showing that CO levels are below 85 % of the CO NAAQS .
No additional revisions of this maintenance plan are anticipated at this time. If future changes in
mobile source models or other unforeseen considerations raise potential issues with the
conformity process, the State will address the need to revise the maintenance plan at that time .
9
June 16, 2010 — Fort Collins Attainment/Maintenance Plan Revision
Attachment 2
Graphs of Fort Collins and National Carbon Monoxide Trends
The following two graphs are intended to illustrate that carbon monoxide levels have declined
significant both locally and nationally. A large portion of this has been the result of the federal
new car emission standards . In Colorado, CDPHE staff estimate that the new car emission
standards are responsible for - 90% of the decline in Colorado ' s carbon monoxide levels.
Figure 1 . Fort Collins Carbon Monoxide Trend
CO data show downward trend
No violation of air quality standard since 1991
18
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1 it Standard=9 ppm
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80 82 84 86 88 90 92 94 96 98 00 02 04 06 08
0 Number of violation days — Standard (9) tgnnual 2nd highest
Figure 2 . National Carbon Monoxide Trends "
CO Air Quality , 1980 - 2008
( Based on annual 2nd Maximum 8 - hour Average )
National Trend based on 124 Sites
16
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- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
t� g
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2
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 2 2 2 2 2 2 2 2 2
9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 9 0 0 0 0 0 0 0 0 0
8 8 8 8 8 8 8 8 8 8 9 9 9 9 9 9 9 9 9 9 0 0 0 0 0 0 0 0 0
0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8
1980 to 2008 ; 79 % decrease in National Average
" Source : U .S . EPA Web site on carbon monoxide : http : //www . epa . gov/airtrends/carbon . html
(Over for information on how to interpret the graph. )
1
How to Interpret the EPA Graph
The blue band shows the distribution of air pollution levels among the trend sites, displaying the
middle 80 percent. The white line represents the average among all the trend sites. Ninety
percent of sites have concentrations below the top line, while ten percent of sites have
concentrations below the bottom line .
90 % of sites have concentrations below this line
10 N Tonal S ndard
$ Average among all sites
e
a
2 10 % of sites have concentrations below this line
0
2
AIR QUALITY ADVISORY BOARD
REGULAR MEETING MINUTES
June 21, 2010 Attachment 3
DATE: Monday, June 21, 2010
LOCATION: 215 N. Mason Conference room 1-A
TIME: 5:30 -8:00 P.M.
Dinner is served starting at 5:15
For Reference: Eric Levine, Chair - 493127 '41
David Roy, Council Liaison - -'`_407-7393
Lucinda Smith, Staff Liaison - _ 22%4=6085
In Attendance, John Schroeer, Dennis Georg, Hugh Mackay,=Eric Levi
e; Dale Adamy, Nancy
York =
Absent—Dave Dietrich, Rich Fisher
Staff Present: Lucinda Smith, Alexis Hmielak, Brian Woodruff'
Call meeting to order =
Eric Levine called the meeting to order a j40^ m.
Introduction of Guests - none
Public Comments- none
X a=o- , -
Review and Approvaliof May 07 }2010 Minutes
;
John Schroeer moved and Dennis Georg seconded a motion to approve the May 17, 2010,
minutes as presented.
Motion Passed Unanimously
• To clarify a question fr(T ale A,dTamy, about the process of updating the International
Buildi g Gbde, Lucinda Smith pointed out air quality issues are naturally imbedded and are
being discussed in the Grp n Building Code, not naturally included in the IBC.
e
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Yf
Lucinda handed out somepersonal ozone indicator wallet-size cards that allow 5 readings of
ambient ozone levels Me board's use and information
CO Attainment Plan Revision for Second 10-year Maintenance Period
Suzette Mallette, head of the Planning and Programs Department of the North Front Range
Metropolitan Planning Organization (MPO), gave a presentation on the Revised Carbon
Monoxide Maintenance Plan for the Fort Collins Attainment/Maintenance Area. Suzette pointed
out the MPO is an air quality planning agency responsible for update to our CO maintenance
plan that has been in place for several years.
1
• As background, Suzette stated in 1979, this area was designated to be in non-attainment of
the carbon monoxide (CO) standard.
o We are currently in the first 10 year plan for CO attainment. The EPA approved a
redesignation request in 2003. The second 10 year plan will continue progressing
down the timeline to 2025.
o The 2010 Revised Maintenance Plan includes monitoring data and emission inventory
to confirm attainment through 2025.
• The purpose of the revision is to show continued attainment of the CO standard in Fort
Collins through 2025.
• Also for clarification, Lucinda defined the term "Design Value"was a statistic based on the air
quality readings of eight of the most recent quarters and is usedrto assess progress and to plan
strategies for attainment. Our region's data currently has the°Design,Ualue of 3.0 ppm, which
OM
is well below the EPA's recommended limit. This eliminate the riessity for future
projections because continued attainment is presumed%
• Suzette stated the 2010 SIP revision will have no changes. No control measures are being
added or removed and changes to the ambient standards regulation will remai unchanged.
Because our Design Value is so low, the EPA is allowing us shave a limitedlit tenance
plan option with emissions budgets until 2015 and aft thatno ping—just watch the
monitors.
• Transportation conformity is a requirement of the Clean AirEA.ct. This means when we do a
long range plan or transportation plan'we have to conform totlie air quality standards and
EEY. C �"YJ54
SIP goals ,�
• To answer a question from John Schroeer;.Lucindaastated�CO levels are coming down across
sN . � � .
the country primarily because of new car emissions standards and reduced travel because of
the economy. An
• Next Steps:
o Seek input and'`approvaLfrom Fort Col s=City Council. However, Council does not
have to vote asabodys n e Ben Manvelrs the City's MPO representative and can
b EaC^I 'M CaE9 Fv
make-a; ecommendation himselfi
4e'm
he revision_will be heard by the MPO on Aug 5 and the public hearing request will
the made at the=Golorado Air Quality Control Commission (AQCC) on Sept 18 for a
ecember 200 earing.o further revisions of the plan will be needed unless circumstances change.
* � wi
• In additidn to-.making recommendations to City Council, Lucinda pointed out that it is also
within the purview of the�AQAB to make a recommendation to the MPO regarding SIP
t-
issues. She will also sen' Council an update to inform them of the Revised Maintenance
Plan.
• To answer John Schroeer, Suzette stated if the CO level rises to a violation level of 9 ppm,
then the federal contingencies would mandate we do something to reduce the level, but she
"'. does not anticipate it would get that high. The MPO does not project much movement in CO
levels out to 2035.
o Lucinda stated that every year the state and Fort Collins reports on the trend of CO.
o Brian Woodruff stated if there were an increase it would most likely be gradual, not a
large jump.
2
o To answer Hugh Mackay, Suzette stated the maximum emissions budget of 94 was
calculated in the Mobil 6 Emissions model. We cannot exceed 94 tons of CO per day
from 2015 and beyond. We are not close to that number.
o Brian stated he thought the budget numbers are for mobile sources only.
o Eric Levine asked what is the percentage of tail pipe emissions vs. industrial
emissions that contributes to the CO budget total. Suzette did not have that
information but will seek an answer.
• Eric Levine stated he is concerned that ozone is increasing and wondered if transportation
strategies will help reduce ozone.
o Suzette stated any actions, such as car emissions testing ozone will also
18
help reduce CO. In August, the EPA will be revising ozone limits down and most of
Colorado and much of the nation will be in non-attainment ,The state is working on
N�ao:
the modeling for this right now on how to reduce ozone thadWill be due in 2011.
There will be two emission budgets; Denver an&North Front Range will have
different, independent, emission budgets foro"o e
• To answer John Schroeer, Lucinda stated ozone,�readings have been pretty fl t�thfe western
Fort Collins ozone monitoring station this year andiwe have not gotten any exceedance
notifications from the health department yet this snrnmer.kredictions for this s mmer's
weather are for temperatures lower than what create persistently high levels of ozone.
o Suzette pointed out all low hanging fruit of ozone*Wntrol has been done and the next
round of measures to control ozone-;will be more expensive for less benefit.
o Lucinda stated ozone is a very complex issue with manycontnbuting factors and
"1=1: °
could not rate one factor as more eontnbufmg,than another.
16� . . "P ,
o Dennis stated there a lot of opportdhiit�i e0t6 havelmore controls on oil and gas and
rSMrM b,
PRPA should;dl"s6develop more emission control
Ar M U
Dennis Georg moved and John Schroeer seconded a motion that the AQAB send a letter
to the MPO supporting the Revised Carbon Monoxide Maintenance Plan for the Fort
Collins Attainment/Maintenance Area and also send letter to Council saying they have
done so.
Motion passed unanimously.
__, --- End of relevant section ---
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3
ATTACHMENT 4
LAMMER DEPARTMENT OF HEALTH AND ENVIRONMENT
COUNTY 1525 Blue Spruce Drive
Fort Collins,Colorado 80524-2004
General Health(970)498-6700
Environmental Health(970)498-6775
Fax(970)498-6772
June 11, 2010
Bob True
Planning and Policy Program
Colorado Air Pollution Control Division
Colorado Department of Public Health & Environment
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Regarding: Fort Collins Carbon Monoxide Maintenance Plan
Dear Mr. True:
I am writing to express the support of the Larimer County Department of Health
and Environment for the Attainment/Maintenance Plan Revision for the Second
10-year Maintenance Period for the Fort Collins carbon monoxide plan. Our
reasons for offering this support are as follows:
• There is a complete and accurate air quality monitoring record indicating that
carbon monoxide levels in Fort Collins are substantially below the 8-hour
National Ambient Air Quality Standard.
• The air quality trend, as outlined in Table 1 of the Revised Maintenance Plan,
has remained below 30% of the 8-hour standard between 2002 and the
current time.
• Use of the limited maintenance plan option is appropriate because the 2008
carbon monoxide design value of 3.0 parts per million is well below the
federally allowed design value of 7.65 parts per million.
• The list of enforceable control measures for the maintenance period is
expected to effectively limit the growth of future emissions of carbon
monoxide. This is especially true with regard to the Federal Motor Vehicle
Control tailpipe standards and regulations that will result in reduced emissions
as fleet turnover occurs.
• Expansion of the motor vehicle inspection program into the North Front
Range for ozone control purposes will allow regular and efficient monitoring of
the light duty fleet for carbon monoxide emissions.
Page 2
• Adequate contingency measures are available in the unlikely event that
carbon monoxide levels increased during the 2"d 10-year maintenance period.
Thank you for the opportunity to review the draft plan revision. I can be reached
at (970) 498-6777 if you would like to discuss these issues in greater detail.
Sincerely,
Doug Ryan
Environmental Health Planner
cc: Tom Donnelly, Larimer County Board of Commissioners
Suzzette Mallette, North Front Range MPO
Lucinda Smith, City of Fort Collins
Page 2 of 2
RESOLUTION 2010-043
OF THE COUNCIL OF THE CITY OF FORT COLLINS
APPROVING THE REVISED CARBON MONOXIDE MAINTENANCE PLAN:
FORT COLLINS ATTAINMENT/MAINTENANCE AREA AND DIRECTING
THE CITY'S REPRESENTATIVE TO THE NORTH FRONT RANGE
METROPOLITAN PLANNING ORGANIZATION TO SUPPORT THE SAME
WHEREAS, the Fort Collins area was designated a "non-attainment" area for carbon
monoxide in 1979 for violations of the National Ambient Air Quality Standard ("NAAQS") for
carbon monoxide,pursuant to Clean Air Act("CAA")and the Colorado State Implementation Plan
("SIP") requirements; and
WHEREAS, no violations of the applicable CAA NAAQS for carbon monoxide have
occurred in the Fort Collins area since 1991; and
WHEREAS, the Fort Collins area was redesignated as an "attainment area" for carbon
monoxide in 2003 by the U.S. Environmental Protection Agency ("U.S. EPA"); and
WHEREAS, the North Front Range Metropolitan Planning Organization ("NFRMPO)",
which has been designated the lead air quality planning agency for the Fort Collins area, is
responsible for preparing and providing to the State of Colorado for review a maintenance plan that
meets the requirements of the CAA, including a demonstration that the area will maintain
compliance with the applicable air quality standard for a period of at least ten years after
redesignation; and
WHEREAS, in connection with the redesignation, a maintenance plan was prepared that
demonstrated attainment of the carbon monoxide standard through 2015; and
WHEREAS, the City Council considered and approved the original Fort Collins
Attainment/Maintenance Plan with its adoption of Resolution 2002-047 on May 7, 2002; and
WHEREAS, the Colorado Air Quality Control Commission and the U.S. EPA adopted the
original Fort Collins Attainment/Maintenance Plan on July 18,2002 and July 22,2003,respectively;
and
WHEREAS,Fort Collins carbon monoxide concentrations have fallen steadily over the past
two decades largely as a result of the federal new vehicle emission standards and are now 20% of
the carbon monoxide NAAQS; and
WHEREAS; federal CAA and the U.S. EPA require a revision to the original Maintenance
Plan to show continued attainment of the carbon monoxide standard for a second ten-year term from
2015 through 2025; and
WHEREAS:the Colorado Department of Public Health and Environment,working together
with the NFRMPO,prepared a draft Revised Maintenance Plan for carbon monoxide for Fort Collins
covering the period from 2015 through 2025; and
WHEREAS; the Revised Maintenance Plan was prepared using the Limited Maintenance
Plan option available to areas such as Fort Collins that are at least 85% of the carbon monoxide
NAAQS; and
WHEREAS,the Limited Maintenance Plan option requires the development ofan emissions
inventory for carbon monoxide but does not require projection of that inventory to future years,
considers that the maintenance demonstration is satisfied if the monitoring data show that the area
remains at 85 percent of the carbon monoxide NAAQS or below, and states that emissions budgets
for transportation conformity may be treated as essentially non-constraining for transportation
conformity because it is unreasonable to expect that such an area will experience so much growth
during the maintenance period that a violation of the carbon monoxide NAAQS would result; and
WHEREAS, the Revised Maintenance Plan retains all the federally-enforceable carbon
monoxide control strategies identified in the original Maintenance Plan and demonstrates that the
applicable federal air quality standards will be met in Fort Collins through 2025; and
WHEREAS,the NFRMPO will consider formal adoption of the Revised Maintenance Plan
on August 5, 2010; and
WHEREAS,the process of adoption and approval of the Revised Maintenance Plan requires
that the Colorado Air Quality Control Commission review and approve the Plan, and requires that
the Colorado General Assembly then adopt legislation approving the Revised Maintenance Plan and
making a parallel revision to the Colorado SIP, to be submitted to the U.S. EPA for final approval;
and
WHEREAS, the Fort Collins Air Quality Advisory Board voted unanimously on June 21,
2010 to recommend that City Council support the Revised Maintenance Plan.
NOW THEREFORE, BE IT RESOLVED BY THE COUNCIL OF THE CITY OF FORT
COLLINS, COLORADO as follows:
Section 1. That the proposed Revised Maintenance Plan, as described hereinabove, is
hereby approved.
Section 2. That the City Council's designated representative to the NRFMPO is hereby
directed to vote in support of the Revised Maintenance Plan, as described herein.
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Passed and adopted at a regular meeting of the Council of the City of Fort Collins this 20th
day of July A.D. 2010.
Mayor
ATTEST:
City Clerk
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