HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 05/07/2002 - RESOLUTION 2002-047 APPROVING THE AIR QUALITY REDE AGENDA ITEM SUMMARY ITEM NUMBER: 25
FORT COLLINS CITY COUNCIL DATE: May 7, 2002
STAFF: Brian Woodruff
SUBJECT:
Resolution 2002-047 Approving the Air Quality Redesignation of the Fort Collins Area to
Attainment Status for Carbon Monoxide and the Related Maintenance Plan and Directing the
City's Representative to the North Front Range Transportation and Air Quality Planning Council
to Support the Same.
RECOMMENDATION:
Staff recommends adoption of the Resolution.
FINANCIAL IMPACT:
There is no financial impact at this time. In the future, however, if transportation plans and
programs do not conform to the air quality Maintenance Plan, Fort Collins' ability to receive
federal transportation funds could be jeopardized.
10
EXECUTIVE SUMMARY:
The Fort Collins area is eligible for redesignation as an air quality attainment area, because
carbon monoxide levels have been cleaner than national standards since 1992. State and federal
regulations require redesignation to attainment status, and the implementation of an
accompanying maintenance plan (the "Plan"), once an area becomes eligible. A draft
Redesignation Request and Maintenance Plan has been prepared for public hearing before the
Air Quality Control Commission in July. The North Front Range Transportation and Air Quality
Planning Council (also referred to as the Metropolitan Planning Organization or "MPO") is
scheduled to adopt the Plan in June. This Resolution would direct the City Council's
representative to the MPO how to vote on the matter and express the Council's support for the
Plan.
BACKGROUND:
Although Fort Collins has since 1982 been designated as "non-attainment" with respect to the
federal carbon monoxide ("CO") standard, the City has not violated the federal air quality
standard since 1992, and is therefore eligible to apply for attainment status. To qualify for
redesignation, the State must adopt an air quality "Maintenance Plan" for Fort Collins. The City
DATE: may 7, 2002
ITEM NUMBER:
Council has limited control over the content of the Maintenance Plan, because statutes and
regulations at both the federal and state levels closely control the redesignation process.
Staff has been working with the North Front Range Metropolitan Planning Organization
("MPO"), the Air Quality Control Commission ("AQCC") and the Air Pollution Control
Division of the Colorado Department of Public Health and Environment ("CDPHE") to draft the
Redesignation Request and Maintenance Plan ("the Plan"), which is scheduled for public hearing
before the Air Quality Control Commission on July 17. The North Front Range MPO is
scheduled to adopt the Plan at its June 6 meeting. City Council approval is needed for
Councilmember Kastein to cast the City's vote at that MPO meeting.
Fort Collins air quality readings have been better than the air quality standard since 1992. A
Maintenance Plan must be put in place following the declaration of attainment, which shows
how air pollution emissions will be kept below the 1992 level for the next ten years. The
Maintenance Plan will affect Fort Collins in two significant ways. First, as a result of a paradox
in the way Colorado's clean air laws are written, once an area is designated as an attainment
area , it is required by state law to remove from its maintenance plan any programs that are not
needed to meet the federal clean air standard. The State of Colorado has therefore proposed to
remove two control programs that are currently lowering emission in the Fort Collins area —
the inspection/maintenance ("IM") and oxygenated fuels programs. Removing these two
programs is expected to worsen air quality somewhat, due to an estimated ten percent increase in
vehicle CO emissions.
Second, the Plan will specify an emissions budget for vehicles. In order to continue to receive
federal transportation funds, transportation planners must show that total vehicle emissions will
fall below the emissions budget. Proposed transportation plans and programs must be evaluated
to determine whether they will result in "nonconformity" with this emissions budget. The
budget allows little room for unanticipated events such as transportation funding shortfalls or
traffic growing faster than expected, which could increase future emissions. Failure to meet the
emissions budget would be devastating — most direct federal transportation funds would be cut
off including federal funds for road building, the CSU Transit Center, and the proposed Mason
Street Corridor project.
State legislation places two significant constraints on the planning process. First, Colorado
Revised Statutes ("C.R.S.") §25-7-107(2.5) requires the State of Colorado to take expeditious
action to redesignate any area that becomes eligible. Because Fort Collins has been eligible for a
decade, the State is eager to complete the redesignation as soon as possible. Second, C.R.S. §25-
7-105.1 stipulates that the Maintenance Plan shall not include any pollution control program that
is not required for meeting minimum federal requirements. As a result, the State will omit the
IM and oxygenated fuels programs from the federally enforceable portions of the Maintenance
Plan,because Fort Collins can maintain clean air standards without these programs.
DATE: May ITEM NUMBER: 25
Synopsis of the Maintenance Plan
• The Fort Collins area will be able to maintain the National Ambient Air Quality standard
("NAAQS") from 2004 through 2015 without an oxygenated fuels program, and,without the
IM Program. These two programs will no longer be federally enforceable after December
31, 2003.
• The Basic IM Program (currently in operation in Fort Collins) will be continued as a State
program (not federally enforceable) until an acceptable alternative can be found to replace it
or until it is no longer practical to continue to implement the 'program, by agreement with
CDPHE.
■ Because projections indicate that mobile source emissions may exceed the emissions budget
after 2026, the Basic IM program (or equivalent) will be reinstated in 2026 to protect
conformity determinations for the year 2030 and beyond.
• Vehicle emissions will be limited to 77 tons per day.
■ CDPHE has committed to work in partnership with the City and the MPO to identify a
feasible replacement for the IM program that could be managed in the future by either the
State or the City.
■ A few outstanding issues exist that may result in minor changes to the Maintenance Plan
prior to AQCC adoption in July, including:
I) Vehicle Miles Traveled ("VMT") data and emissions calculations for the year 2005 may
be revised slightly, although these revisions are not expected to affect control strategy
requirements; and
2) The proposed emissions budget may be revised upward by roughly 10 tons per day if
warranted by new data that are currently being developed on the use of wood burning
lipdevices in the Fort Collins area. City staff believes that wood burning emissions are
overestimated in the Maintenance Plan. A survey of wood burning habits and fuel usage
is now being conducted, and results will be available in time to amend the Maintenance
Plan before the AQCC adopts it. Staff expects to show that wood burning is down 30% to
50% below 1990 levels, which is consistent with experience in other cities. This means
there would be a greater "margin of safety," which could be used to set a higher mobile
source emissions budget and further protect transportation conformity.
Process
These are the remaining steps in the State's process to redesignate Fort Collins as an attainment
area:
1) The Colorado Legislature is now considering HB 1411, which authorizes the AQCC to
adopt a Maintenance Plan for Fort Collins without the Legislature's review, which would
otherwise be required.
2) The North Front Range MPO will consider adopting the Maintenance Plan at its June 6
meeting. The MPO is designated by the Governor as the lead air quality planning agency
for the Fort Collins area.
3) The Air Quality Control Commission will hold a public hearing and consider the
adoption of the Maintenance Plan at its July 17 meeting.
4) Upon approval by the AQCC, the Governor will submit the Maintenance Plan to the
USEPA for approval.
lip 5) Within 24 months of receipt of the Maintenance Plan, the USEPA will promulgate a
regulation approving the Plan in the Federal Register.
DATE: May 7, 2002
4 ITEM NUMBER: 25
Vehicle Inspection and Maintenance Program
If the Maintenance Plan is adopted as proposed, the status of the IM program will be as follows:
• The Basic IM program will no longer be federally enforceable. That step alone would not
end the program, however.
• The Air Quality Control Commission will continue the Basic IM program as part of its
Regulation 11.
• The State Health Department will work in partnership with the City to identify feasible
replacement strategies tobe managed in the future by the State or the City.
Second in effectiveness only to new car standards, IM is a powerful, technology-based strategy
that impacts the emissions from every vehicle. It would be hard to replace the effectiveness of
the IM program with other types of City programs, which rely largely upon behavior change to
reduce emissions. Examples include programs that help reduce the VMT growth rate (e.g., land-
use and transportation planning and providing alternatives to vehicle travel and promoting their
use) and programs that reduce wood burning.
The State's requirement to remove control programs that are not needed to meet federal
requirements would allow air quality to get about 10% worse, although not worse than the
federal air quality standard. In contrast, the City Council's policy is to "continually improve
Fort Collins' air quality as the city grows." Thus, the removal of current air pollution programs
that reduce area-wide emissions does not further existing City policy. Because air quality
requirements are largely controlled by federal and state laws that limit the City's discretion with
respect to these matters, staff is recommending that the City proceed in cooperation with the
proposed redesignation and work locally to take action to mitigate negative impacts associated
with the required Maintenance Plan. In order to keep air quality from worsening, the City's Air
Quality Action Plan could be amended to include strong local controls to prevent CO emissions
from rising. The current Action Plan calls for exploration of programs that could replace the IM
program, and the State Health Department has committed to work in partnership with the City to
that end.
This year the City will complete a feasibility study of potential programs to identify and repair
high-emitting vehicles. If such a program is determined to be feasible, then the City Council
could consider including it in the Air Quality Action Plan for implementation as early as 2004.
Transportation Conformity
Federal regulations require the MPO to certify that its transportation plans and programs
conform to the Maintenance Plan. To show conformity, projected total tailpipe emissions in the
area must fall below the mobile source emissions budget in the Maintenance Plan. Part of the
Maintenance Plan process is to create an emissions budget, within which transportation
programs must operate in the future. The stakes of this analysis are high, because federal
transportation funds would be cut off if there were a lapse in conformity. It is common for the
Maintenance Plan to allocate all or part of the "margin of safety" (the gap between total
projected emissions levels and the emissions limit) to mobile sources in order to accommodate
unanticipated mobile source growth, and, hopefully, to prevent a lapse in conformity.
DATE: may ITEM NUMBER:
The State Health Department has assured the City that the Maintenance Plan would not
jeopardize transportation plan conformity. A potential problem has been identified for 2026 and
later, when mobile source emissions are calculated to exceed the emissions budget. Therefore,
the State Heath Department has proposed to reinstate the Basic IM program, or a similarly
effective program, in 2026.
ATTACHMENTS
1. Draft redesignation request and maintenance plan
RESOLUTION 2002-047
OF THE COUNCIL OF THE CITY OF FORT COLLINS
APPROVING THE AIR QUALITY REDESIGNATION OF THE FORT COLLINS AREA
TO ATTAINMENT STATUS FOR CARBON MONOXIDE
AND THE RELATED MAINTENANCE PLAN,
AND DIRECTING THE CITY'S REPRESENTATIVE TO
THE NORTH FRONT RANGE TRANSPORTATION AND AIR QUALITY PLANNING
COUNCIL TO SUPPORT THE SAME
WHEREAS, the Fort Collins area has,since 1982,been designated a"non-attainment"area
for carbon monoxide, pursuant to federal Clean Air Act ("CAA") requirements and the Colorado
State Implementation Plan ("SIP"); and
WHEREAS, no violations of the applicable CAA National Ambient Air Quality Standard
for carbon monoxide have occurred in the Fort Collins area since 1992,making the area eligible for
redesignation as an "attainment" area for carbon monoxide; and
WHEREAS,in connection with the redesignation of the Fort Collins area as an"attainment"
area, the North Front Range Transportation and Air Quality Planning Council ("NFRTAQ" or the
"MPO"),which has been designated as 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,the process for redesignation and maintenance plan requires that the Colorado
Air Quality Control Commission ("AQCC") review and approve the same, after which legislation
approving the redesignation and maintenance plan and making a parallel revision to the Colorado
SIP must then be adopted by the Colorado General Assembly, to be submitted to United States
Environmental Protection Agency ("EPA") for final approval of the redesignation; and
WHEREAS, the Colorado General Assembly is in the process of adopting House Bill 02-
1411, which authorizes the AQCC to carry out the review and approval of the Fort Collins
redesignation and maintenance plan, and related SIP amendments, with no further action by the
General Assembly; and
WHEREAS, the AQCC has scheduled a public hearing on July 17, 2002, to receive
testimony and consider the redesignation and maintenance plan for Fort Collins; and
WHEREAS, the MPO has worked with City staff, and with the Colorado Department of
Health and Environment ("CDPHE"), to develop a maintenance plan that complies with the
applicable federal and state requirements, subject to possible modification to correct vehicle miles
traveled ("VMT") and emissions projections for 2005, and to reflect more accurate wood burning
emissions data (the "Proposed Maintenance Plan"); and
WHEREAS, the Proposed Maintenance Plan, a draft of which, dated April It, 2002, is on
file in the Office of the City Clerk and available for public inspection, also includes an emissions
budget for vehicle emissions, as required by federal law, which emissions budget will be used for
conformity determinations to be made by the MPO in connection with decision-making for planning
and funding transportation projects in the Fort Collins area; and
WHEREAS,the Proposed Maintenance Plan demonstrates that applicable federal air quality
standards will be met in the Fort Collins area through 2015 without the continuation of existing
inspection and maintenance ("IM") and oxygenated fuels programs; and
WHEREAS, Colorado statute requires that a maintenance plan submitted to the EPA
pursuant to the CAA not require any programs that are not necessary to achieve compliance with
applicable federal air quality standards, and thus the Proposed Maintenance Plan does not include
a continuation of the existing IM and oxygenated fuels programs; and
WHEREAS,in view of the existing City Council policy objective of continually improving
Fort Collins' air quality as the city grows,City staff has raised with the MPO and CDPHE concerns
regarding the removal of these programs, which is likely to result in a deterioration of air quality in
Fort Collins; and
WHEREAS, CDPHE has in response agreed to include as a non-federally enforceable
component of the Proposed Maintenance Plan and to present to the AQCC,a proposal that CDPHE
work with the City to continue the IM program in Fort Collins until an acceptable alternative can be
found to replace it or until it is no longer practical to continue to implement the program; and
WHEREAS, because Colorado law requires that redesignation proceed once an area is
eligible for such redesignation,and because Colorado law further restricts the inclusion of programs
in the SIP that are not required to meet federal air quality standards, cooperation by the City in
carrying out the redesignation in accordance with the above-described arrangements and agreements
is in the best interests of the City; and
WHEREAS, City staff is in the process of working to evaluate additional local control
measures that the City may choose to implement in order to continue to improve air quality in the
Fort Collins area, and will in the future present to the City Council alternatives for action to be
considered in that regard.
NOW,THEREFORE,BE IT RESOLVED BY THE COUNCIL OF THE CITY OF FORT
COLLINS as follows:
Section 1. That the Proposed Maintenance Plan, as described hereinabove, is hereby
approved.
Section 2. That the City Council's designated representative to the MPO is hereby
directed to vote in support of the Proposed Maintenance Plan,as described herein, and to take such
other actions as may be necessary or appropriate to advance the intent of the Council as stated in this
Resolution.
• Section 3. That the City Manager is hereby directed to continue to investigate and
evaluate potential local controls and actions that will advance the City Council's policy objective
of continuing to improve air quality in Fort Collins, and to bring forward possible alternatives for
action in that regard at the next regular update of the City's Air Quality Action Plan.
Passed and adopted at a regular meeting of the Council of the City of Fort Collins held this
7th day of May A.D. 2002.
Mayor
ATTEST:
City Clerk
•
APRIL 11, 2002 DRAFT
Carbon Monoxide Redesignation Request
And Maintenance Plan
For The Fort Collins Non-Attainment Area
NOTE.FORMATTING GLITCHES, INCLUDING TYPEFACE IRREGULATRIES, ARE TO BE FIXED
AFTER THE HEARING REQUEST DATE—LISA
PARTI BACKGROUND..............................................................................................................2
CHAPTER 1: INTRODUCTION............................................................................................................2
A. National Ambient Air Quality Standards for Carbon Monoxide.................................................... 3
B. Health Effects of Carbon Monoxide............................................................................................. 3
C. Fort Collins Carbon Monoxide Area Designation History............................................................4
D. Fort Collins Metropolitan Attainment/Maintenance Area.............................................................4
E. Improvement In Air Quality Due To Permanent And Enforceable Emission Reductions............ 5
CHAPTER 2: CONTROL MEASURES THAT BROUGHT THE FORT COLLINS AREA INTO
ATTAINMENT.............................................................................................................................6
A. Federal Tailpipe Standards.........................................................................................................6
B. Vehicle Inspection &Maintenance Program ...............................................................................6
C. Oxygenated Gasoline Program................................................................................................... 6
D. Industrial Source Controls........................................................................................................... 7
E. Wood Stove Requirements in Colorado Air Quality Control Regulation Number 4..................... 7
F. CAA Section 110 And Part D Reauirements............................................................................... 7
G. Provisions Concerning Transportation Conformity...................................................................... 8
CHAPTER 3: ANALYSES REGARDING POTENTIAL MODIFICATIONS TO CONTROL
STRATEGIES.............................................................................................................................. 9
A. Modeling Considerations............................................................................................................. 9
B. Preliminary Modeling................................................................................................................... 9
C. Analysis of Strategy Options for Maintenance Plan .................................................................... 9
D. City of Fort Collins Local Air Quality Plan.................................................................................. 10
E. Potential Revisions to Inventories and to the Emissions Budget................................................... 10
PART II - REDESIGNATION REQUEST AND MAINTENANCE PLAN ...................................... 11
CHAPTER 1: REQUIREMENTS FOR REDESIGNATION................................................................. 11
A. Reguired Components Of A Redesignation Reguest................................................................ 11
1. Attainment of the Standard............................................................................................................. 11
2. State Implementation Plan Approval.............................................................................................. 11
3. Improvement in Air Quality Due to Permanent and Enforceable Emissions Reductions................ 12
4. CAA Section 110 and Part D Reguirements................................................................................... 12
5. Maintenance Plan........................................................................................................................... 12
B. Fort Collins Area Carbon Monoxide Monitoring......................................................................... 12
C. Quality Assurance Program ...................................................................................................... 14
CHAPTER 2: MAINTENANCE PLAN................................................................................................. 15
A. Emission Inventories and Maintenance Demonstration............................................................ 15
B. Control Measures to be Removed for the Maintenance Period ................................................ 17
C. Enforceable Control Measures for the Maintenance Period...................................................... 17
E. Monitoring Network I Verification Of Continued Attainment...................................................... 18
F. Contingency Plan ...................................................................................................................... 19
1. List of Potential Contingency Measures.........................................................................................19
G. Tracking and Triggering Mechanisms.......................................................................................20
H. Process for Recommending and Implementing Contingency Measures.................................. 20
L Subsequent Maintenance Plan Revisions................................................................................. 21
PART BACKGROUND
CHAPTER 1: INTRODUCTION
The State of Colorado and the North Front Range Transportation &Air Quality Planning Council
(the Council),which serves as the area's lead air quality planning agency, request that the U.S.
Environmental Protection Agency(EPA) redesignate the Fort Collins nonattainment area to
attainment/maintenance status for the National Ambient Air Quality Standards for carbon
monoxide. The Fort Collins area was designated a carbon monoxide nonattainment area
inl979, but has not violated the standard since 1991.Therefore, the area is now eligible for
redesignation.
Part 1 of this document is provided as background information only and is not to be construed to
be part of the State's official submittal to EPA.
Part 2 of this document,which includes a listing of the requirements for redesignation and the
Maintenance Plan, constitutes the State's official submittal to EPA. The Maintenance Plan,
which is being submitted for inclusion in the State's federally enforceable State Implementation
Plan (SIP), provides for maintenance of the national standard for carbon monoxide in the Fort
Collins area through the year 2015. The Maintenance Plan has been approved by the North
Front Range Transportation &Air Quality Planning Council (—date--) and the Colorado Air
Quality Control Commission (—date—), and complies with all State and federal requirements.
• Colorado Air Quality Control Commission
The Colorado Air Quality Control Commission (AQCC) is a regulatory body with responsibility for
adopting air quality regulations consistent with State statute. This includes the responsibility and
authority to adopt State Implementation Plan (SIP)elements and their implementing regulations.
The Commission takes action on SIPS and regulations through a public rule-making process.
The Commission is composed of nine members appointed by the Governor and confirmed by
the State Senate.
• Air Pollution Control Division
The Air Pollution Control Division of the Colorado Department of Public Health & Environment
serves as staff to the Colorado Air Quality Control Commission. It is responsible for developing
emission inventories, mobile modeling of transportation data, and making technical and policy
recommendations regarding State air quality plans and regulations to the Commission. The
Division works in partnership with local Lead Planning Agencies and other stakeholders to
develop and draft SIP elements and proposed regulatory revisions.
• North Front Range Transportation &Air Quality Planning Council
The North Front Range Transportation &Air Quality Planning Council was designated the lead
air quality planning agency for Fort Collins, Greeley and Loveland urban areas by the Governor
in 1993. In this capacity, the Council's mission is to work in partnership with the Air Pollution
Control Division to develop and recommend for adoption effective and cost-efficient air quality
initiatives with input from state and local government, the private sector, stakeholder groups, and
private citizens.
Part I-draft Page 2 -
The North Front Range Council consists of 15 members representing local and state
government agencies, including Larimer and Weld Counties, the City of Fort Collins, the City of
Loveland, the City of Greeley, Garden City, the City of Evans, the Town of Berthoud, the Town of
La Salle, the Town of Windsor, the Town of Timnath, the Town of Milliken, the Town of
Johnstown, the Colorado Transportation Commission and the Colorado Air Quality Control
Commission.
A. National Ambient Air Quality Standards for Carbon Monoxide
There are two national standards for carbon monoxide:
• A rolling 8-hour average concentration of 9.0 parts per million (ppm), and
• A 1-hour concentration of 35 parts per million.
The national standard for carton monoxide allows for no more than one exceedance of either
standard in each calendar year. A violation occurs when two or more exceedances of the
standard are recorded at the same monitoring site during a calendar year.
B. Health Effects of Carbon Monoxide
Carbon monoxide is a colorless, odorless, tasteless gas that enters the body through the lungs
where it is absorbed by the bloodstream and then combined with hemoglobin in the red blood
cells. Hemoglobin is the compound in the red blood cells that normally picks up oxygen from the
lungs and carries it to the tissues. In the lungs, carbon monoxide competes with oxygen for
. available hemoglobin. When carbon monoxide binds with hemoglobin, it forms
carboxyhemoglobin (COHb). Carbon monoxide attaches to hemoglobin much more readily than
does oxygen. Once attached it does not disassociate from the hemoglobin as easily as oxygen.
As a result, COHb levels can continue to increase in the bloodstream and the amount of oxygen
being distributed throughout the body is reduced.
Blood containing carbon monoxide can weaken heart contractions, lowering the blood volume
being distributed through the body. Effects of carbon monoxide poisoning include fatigue,
dizziness, headaches, loss of visual acuity, and mental confusion. Individuals with
cardiovascular or chronic obstructive pulmonary disease, pregnant women, and children are at
greatest risk from exposure to carbon monoxide. Carbon monoxide also affects the central
nervous system by depriving it of oxygen. Therefore, even healthy individuals can experience
adverse effects from carbon monoxide exposure, such as a reduced ability to concentrate.
Carbon monoxide exposure in high altitude environments like the Fort Collins area can present a
greater risk because of the lower levels of oxygen present in the atmosphere.
•
Part I-draft Page 3 -
C. Fort Collins Carbon Monoxide Area Designation History
The Fort Collins area was originally designated as nonattainment for carbon monoxide under
provisions of the 19 Clean Air Act(CAA), as amended. This designation was reaffirmed by the
1990 CAA Amendments when the area was classified as a moderate carbon monoxide
nonattainment area with a design value of less than 12.7 parts per million, effective November
15, 1990 (56FR 56694, Nov. 6, 1991).
D. Fort Collins Metropolitan Attainment/Maintenance Area
The Fort Collins attainment/maintenance area and the Fort Collins urban growth area are one
and the same.
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r* E. Improvement In Air Quality Due To Permanent And Enforceable Emission Reductions
It is reasonable to attribute the improvement in ambient carbon monoxide concentrations in the
Fort Collins area to emission reductions that are permanent and enforceable. The area has met
the national standard for carbon monoxide as a result of effective local, state and federal
emission reduction measures, as opposed to temporary or chance events.
A downturn in the economy is clearly not responsible for the improvement in ambient carbon
monoxide levels in the Fort Collins area. Over the last nine years, the region has experienced
strong growth while at the same time achieving a continuous reduction in carbon monoxide
levels.
The City of Fort Collins Advance Planning staff reports that between 1990 and 2000 the
population of Fort Collins grew from 88,000 to 117,000—up 33% in the 10-year period.
Employment for the area increased 30% for the same period, according to the Colorado
Department of Labor and Employment. Median income rose 33% for the period.
Reductions in ambient carbon monoxide levels occurred in spite of VMT increases. For
example, the City of Fort Collins and the MPO estimate that VMT in the Fort Collins urbanized
area was 1.9 million miles per day in 1990, and had grown to 2.8 million miles per day by 1998—
an increase of 47 percent in VMT for the 8-year period.1
Part I-draft Page 5 -
CHAPTER 2: CONTROL MEASURES THAT BROUGHT THE FORT COLLINS AREA
INTO ATTAINMENT
(NOTE: The following is a description of federally enforceable control measures that brought the
area into attainment. This is not a description of Maintenance Plan control measures.)
A. Federal Tailpipe Standards
One of the more important carbon monoxide control measures for the Fort Collins area and the
nation is the Federal Motor Vehicle Emissions Control Program (FMVECP), established in 1968.
The Clean Air Act of 1970 and its 19 Amendments led to the advent of catalytic converters in
1975 and computerized engine control systems in 1981. The 1990 CAA Amendments required
additional control measures, including stricter emission standards for cars, light duty trucks,
minivans and sport/utility vehicles; cold temperature carbon monoxide standards; and an
extended warranty and recall period. Federal standards will continue to provide emission
reduction benefits as older vehicles are retired and vehicles meeting the newest standards enter
the fleet.
B. Vehicle Inspection &Maintenance Program
Colorado's Automobile Inspection and Readjustment(AIR) Program is described in AQCC
Regulation Number 11 and has been applicable to this carbon monoxide nonattainment area
since 1981. The AIR Program works to reduce carbon monoxide and other pollutants from
gasoline-powered motor vehicles by requiring them to meet emission standards through periodic
tailpipe tests, maintenance, and specific repairs.
The Fort Collins area has been subject to the "Basic"AIR program,which applies to motor
vehicles that operate in the area 90 days or more per year, with the exception of motorcycles,
farm-plated vehicles, collector series vehicles, electric vehicles, two-cycle powered vehicles,
horseless carriages, and diesel vehicles. Since May 20, 1996, the program requires biennial
inspections of vehicles at owner-operated inspection stations in Fort Collins. Testing centers use
EPA's preconditioned two-speed idle test procedures (EPA-AA-TSA-I/M-90-3, March 1990).
Colorado's Basic Automobile Inspection and Readjustment (AIR) Program is applicable to the
Fort Collins NONATTAINMENT area, including certain areas of unincorporated Larimer County. A
first inspection of a new vehicle is due four years after initial registration of a vehicle, and upon
change of ownership, regardless of vehicle age. Fleet vehicles must be inspected annually at
fleet inspection stations.
C. Oxygenated Gasoline Program
The Oxygenated gasoline program is designed to reduce wintertime carbon monoxide emissions
from automobiles by requiring the use of fuel that contains added oxygen. Currently, the
oxygenates typically used along Colorado's Front Range are ethanol and tertiary amyl methyl
ether(TAME).
The oxygenated gasoline program, as defined in Air Quality Control Commission Regulation
Number 13, was first implemented in Fort Collins in 1988, running January 1 through February
28, requiring an oxygen content of 1.5% in gasoline. The program has been revised several
times since then, and now requires that gasoline contain 2.7% oxygenate from November 1
through February 7 each year.
Part I-draft Page 6 -
. D. Industrial Source Controls
The State's comprehensive permit rules, AQCC Regulations Number 3 and 6, control emissions
from industrial facilities and cap carbon monoxide emissions from new or modified major
stationary sources. The State continues to enhance its permit programs,while simultaneously
pursuing a strong inspection and enforcement presence, as authorized by the AQCC's
"Common Provisions" regulation.
E. Wood Stove Requirements in Colorado Air Quality Control Regulation Number 4
The regulation requires that wood stoves must be tested, certified and labeled for emission
performance in accordance with federal criteria and procedures meeting emission standards set
out in 40 CFR Part 60. This regulation went into effect statewide in 1991, and is likely to have
inhibited increases in carbon monoxide emissions in the Fort Collins area in spite of increases in
residential wood burning.
F. CAA Section 110 And Part D Requirements
For the purposes of redesignation, all of the general nonattainment area requirements of CAA
Section 110 and Part D must be met. All of Section 110(a)(2) have been met by the State of
Colorado, including: (1) the establishment and implementation of enforceable emission
limitations; 2) monitoring, compiling, and analyzing of ambient air quality data; (3) pre-
construction reviews and permitting of new and modified major stationary sources; (4)consulting
with and providing for the participation of local governments that are affected by the plan; (5)
• assurance that the State has the adequate funds and authority to enforce the SIP Element and
associated regulations; and (6) permit fees for stationary sources.
Colorado Revised Statute 25-7-111 requires the APCD to administer and enforce the air quality
programs adopted by the AQCC. The APCD is committed to implementing and enforcing the air
quality plans and regulations applicable to the Fort Collins carbon monoxide attainment/
maintenance area.
Part D of the CAA, pertaining to nonattainment plan provisions, requires the following items to be
addressed:
• the implementation of reasonably available control measures, including reasonably
available control technologies (RACT)for existing sources
• reasonable further progress (RFP) towards meeting attainment
• a current emissions inventory and periodic inventories every 3 years until attainment
• the identification and quantification of allowable emissions for new and modified
stationary sources
• a stationary source permitting program
• other measures: enforceable emission limitations, other control measures, schedule for
compliance
• compliance with section CAA Section 110 provisions
• contingency measures
The EPA-approved Colorado SIP already includes the provisions required by Section 110(a)(2)
. and Part D of the CAA. In approving the Fort Collins element of the SIP DECEMBER 12, 1983 (48
Part I-draft Page 7 -
FIR 55284), the EPA determined that the state met the requirements of Section I I0(a)(2) and
Part D of the Clean Air Act.
Other Part D requirements that are applicable in nonattainment and maintenance areas include
the general and transportation conformity provisions of CAA Section 176 (c). These provisions
ensure that federally funded or approved projects and actions conform to the Fort Collins
element of the SIP for carbon monoxide prior to the projects or actions being implemented. The
State has already submitted to EPA a State Implementation Plan revision implementing the
requirements of section 176(c).
G. Provisions Concerning Transportation Conformity
Although the Maintenance Plan (in Part II of this document) does not include the Basic I/M
program after January 1, 2004, the AQCC and APCD commit to implementing an I/M program in
the Fort Collins maintenance area by January 1, 2026 to help assure the Conformity
determination for 2030 and those thereafter. The commitment is more thoroughly discussed in
the federally enforceable portion (Part II)of this document.
Part I-draft Page 8 -
CHAPTER 3: ANALYSES REGARDING POTENTIAL MODIFICATIONS TO
CONTROL STRATEGIES
A. Modeling Considerations
Automotive vehicles are the predominant source—roughly 65%—of carbon monoxide emissions
in the Fort Collins area. Therefore the modeling of mobile source emissions is required to make
projections about future year emissions. The APCD used the MOBILE 6 model, released
January 23, 2002, to project future carbon monoxide emissions from on-road mobile sources.
In addition, roll-forward calculations are made to estimate future CO emissions from stationary
and area sources.
For the simplest modeling demonstration total future CO emissions are compared with those of
the base year—in this case, 1992, the first attainment year. If future CO emissions are predicted
to be lower than those of the base year, the modeled area is thought to be able to maintain
federal standards for the period of the maintenance plan.
B. Preliminary Modeling
Preliminary modeling of future emission inventories was performed using various scenarios,
including:
Oxygenated fuels and Basic I/M programs continuing through 2015
Oxygenated fuels continued for the period without I/M
Basic I/M was continued without oxygenated fuels
Neither I/M nor oxygenated fuels programs in place after 2003 ("No Controls" scenario)
The preliminary modeling indicated that the fourth scenario (no Controls after 2003)
demonstrated maintenance through 2015. Colorado is required, 25-7-105.1, C.R.S., to adopt
programs into the State Implementation Plan that are no more stringent than necessary to
comply with the national standards. Therefore, the no-controls-after-2003 option was selected
for the Maintenance Plan.
Table 2 in Part II of this document indicates emission inventories by sector for 1992 and 1998,
and projections for 2005, 2010 and 2015.
C. Analysis of Strategy Options for Maintenance Plan
Because carbon monoxide levels in the Fort Collins area decreased so dramatically in the past
nine years, the State and the MPO were obliged to consider whether the oxygenated fuels
program and the Basic I/M program could be modified or eliminated in the Fort Collins area
without posing a threat to the National Ambient Air Quality Standards through 2015.
As delineated in Part II of this document, emission projections for the Fort Collins area indicate
that the carbon monoxide standards will be maintained through 2015 without control measures,
i.e.;without either the Basic I/M program or the oxygenated fuels program. Therefore, the
programs are no longer relied upon for compliance with the national standards for carbon
monoxide in the Colorado State Implementation Plan starting on January 1, 2004.
Part I-draft Page 9 -
NOTE: Informal estimates for years beyond the 2015 outdate for this Maintenance Plan project
potential Conformity issues for 2030. Thus, there is a commitment in the Maintenance Plan for
resuming the Basic I/M program in 2026. The federally enforceable Maintenance Plan is
contained in Part II of this document.
D. City of Fort Collins Local Air Quality Plan
The City of Fort Collins' comprehensive plan, known as City Plan, adopted February 1998,
contains a goal "to continually improve Fort Collins air quality as the city grows." Because this
goal is more stringent than Federal requirements, the Commission is precluded by statute from
placing such a commitment in the federally enforceable SIP. (CRS 25-7-105.1) However, statute
also declares that it is "the policy of this state to achieve the maximum practical degree of air
purity in every portion of the state...and to prevent the significant deterioration of air quality in
those portions of the state where the air quality is better than the national ambient air quality
standards (CRS 25-7-102).
Thus, the Colorado Department of Public Health & Environment commits in this narrative section
(Section 1, Background)to work with the City of Fort Collins to support local air quality goals via
continuation of the Basic I/M program in the Fort Collins area until such time as an acceptable
alternative can be found to replace it or it were no longer practical to continue to implement the
program.
Furthermore, the Department commits to work in partnership with the City of Fort Collins and the
MPO to identify feasible mobile source control strategies that could be managed in the future by
the state or local unit of government.
The commitments made above, while not federally enforceable, are made in good faith with the
City of Fort Collins and the North Front Range Transportation &Air Quality Planning Council?
E. Potential Revisions to Inventories and to the Emissions Budget
The City of Fort Collins intends to present updated residential wood burning emissions data and
projections based on a survey to be completed by mid-May of this year(2002). It is anticipated
that the emissions projections for the maintenance period will be substantially lower than those
used in Part II of this document(Tables 2 and 3), and that they will allow for a greater margin of
safety and larger emissions budget—perhaps an additional 8 to 13 tons. At the time of hearing
request the emissions budget is calculated to be 77 tons.
Part I-draft Page 10 -
. PART II - REDESIGNATION REQUEST AND MAINTENANCE PLAN
CHAPTER 1: REQUIREMENTS FOR REDESIGNATION
The State of Colorado, in coordination with the North Front Range Transportation &Air Quality
Planning Council (the Council), requests that the U.S. Environmental Protection Agency (EPA)
redesignate the Fort Collins nonattainment area to maintenance status for the National Ambient
Air Quality Standards for carbon monoxide. The Fort Collins area has been designated as a
carbon monoxide nonattainment area since the 1970's, but has not violated the standard since
1991. Thus, the area is eligible for redesignation.
A. Required Components Of A Redesignation Request
Sections 107(d)(3)(D)and (E)of the CAA define the following five required components of a
redesignation request.
1. Attainment of the Standard
The State must show that the area has attained the national standards for carbon monoxide. This
demonstration must be based on monitoring data representative of the location of the expected
maximum concentrations of carbon monoxide in the area.
• Attainment of the national standard for carbon monoxide is demonstrated when two consecutive
years of 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. Table 1 demonstrates, as required by Section
107(d)(3)(E) of the Clean Air Act, that the Fort Collins area has attained the national standard for
carbon monoxide. This 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.).
2. State Implementation Plan Approval
The State must have a fully approved Carbon Monoxide NoNATrAINMENT AREA State
Implementation Plan element for the Fort Collins metropolitan area under Section 110(k)of the
CAA.
Under the Federal Clean Air Act Amendments of 19, the State of Colorado submitted a Fort
Collins State Implementation Plan element to the EPA in June 1982. This document has served
as the Fort Collins nonattainment area SIP since it was approved by EPA December 12, 1983
(48 FR 55284). Thus, the State has an approved nonattainment area Carbon Monoxide State
Implementation Plan element for the Fort Collins area, as required by Section 110(k) of the
Clean Air Act.
With the 1990 amendments to the Clean Air Act, the EPA designated the Fort Collins area as a
"moderate" nonattainment area with a design value of less than 12.7 ppm carbon monoxide, per
56 FIR 56694, effective November 15, 1990.
• The 1982 SIP element was designed to demonstrate attainment with the carbon monoxide
standard by 1987. This did not occur so soon. Fort Collins experienced violations of the 8-hour
Part II-draft Page 11 -
standard in 1987 and 1988; achieved the standard for the next two years (1989 and 1990); then
experienced a violation in 1991. The year 1991 was the last year any exceedance of the
standard was recorded for Fort Collins. The Fort Collins area has been in attainment of the
carbon monoxide standard from 1992 through the present(2002).
3. Improvement in Air Quality Due to Permanent and Enforceable Emissions
Reductions
The State must demonstrate that the improvement in air quality leading to redesignation is due
to permanent and federally enforceable emissions reductions. The permanent, enforceable
control measures that brought the Fort Collins area into attainment are listed in Part I, Chapter 2
of this document.
4. CAA Section 110 and Part D Requirements
The State must meet all requirements of Section 110 and Part D of the CAA. Section 110 describes
general requirements for SIPs, while Part D pertains to general requirements applicable to all
nonattainment areas. The State of Colorado does meet these CAA requirements, as noted in
Chapter 2 of this Part II.
5. Maintenance Plan
In order to be redesignated to attainment(maintenance status, the State must have a fully approved
carbon monoxide maintenance plan that meets the requirements of CAA Section 175A, including
a demonstration that the area will maintain the standard for a period of at least 10 years following
redesignation by EPA. The plan must also contain contingency measures that could be
implemented if a violation of the standard is monitored at any time during the maintenance period.
Requirements 1 - 4 are addressed below in this chapter. This fifth requirement is addressed in
Chapter 2 of this Part II.
B. Fort Collins Area Carbon Monoxide Monitoring
Ambient air monitoring conducted in Fort Collins indicates that the 8-hour carbon monoxide
standard was exceeded frequently from 1981 through 1991. (The 1-hour standard was never
violated in the Fort Collins area.)With the implementation of emission control programs aimed at
reducing automobile emissions, carbon monoxide concentrations began to decrease
substantially. The last recorded violation of the 8-hour standard occurred in 1991.
The carbon monoxide monitoring site in Fort Collins consists of one National Air Monitoring
Station at 708 S. Mason Street. The Colorado Air Pollution Control Division operates the
monitoring equipment performs precision checks and accuracy audits on the equipment.
The following data verify that the Fort Collins area has been in attainment with the national
standard for carbon monoxide since 1992, including the most recent two-year period (2000-
2001), in accordance with the federal requirements of 40 CFR Part 50.8.
Data recovery rates for the monitors exceed the 75 percent completeness requirements for all
years. All state and federal quality assurance procedures have been complied with, which
Part ii-draft Page 12 -
substantiates their validity as indicators of ambient carbon monoxide levels in the Fort Collins
area. Table 1 presents the long-term record for the Fort Collins carbon monoxide monitor.
Part❑-draft Page 13 -
TABLE 1
1992—2001 CARBON MONOXIDE DATA SUMMARY FOR FORT COLLINS MONITOR
(708 S. MASON ST)
(ppm =parts per million
1-hour Standard 8-hour Standard Data
35 m 9 m Capture
YEAR 16 Max. 2'd Max. 1 Max. 2" Max. % Q/A Audits'
1992 14.2 ppm 13.8 ppm 7.9 ppm 6.9 ppm 99 Y
1993 17.3 ppm 13.8 ppm 7.4 ppm 6.6 ppm 99 Y
1994 13.6 ppm 12.1 ppm 7.3 ppm 6.0 ppm 99 Y
1995 10.6 ppm 9.8 ppm 5.6 ppm 5.2 ppm 99 Y
1996 12.7 ppm 10.9 Ppm 5.5 ppm 5.1 ppm 98 Y
1997 10.M1O.
5.3 m 5.2 m 99 Y
1998 12. 5.3 m 4.1 m 99 Y
1999 8.75.8 m 5.1 m 99 Y
2000 9.64.0 m 3.8 m2001 7.23.3 m 3.0 m 98 Y
NOTE:The 1-hour carbon monoxide standard is 35 parts per million.
The 8-hour carbon monoxide standard—the standard of concern for Fort Collins—is 9 parts per million.
'Accuracy audits were conducted at this station during each year from 1992-2001.All audits passed required quality
assurance measures.
C. Quality Assurance Program
Carbon monoxide data for the Fort Collins area has been collected and quality-assured in
accordance with 40 CFR Part 58, Appendix A, EPA's Quality Assurance Handbook for Air
Pollution Measurement Systems, Vol. 11;Ambient Air Specific Methods, the Division's Standard
Operating Procedures Manual, and Colorado I s Monitoring SIP which EPA approved in 1993.
The data are recorded in EPA's Aerometric Information Retrieval System (AIRS) and are
available for public review at the APCD and through EPA's AIRS database.
In addition, the APCD has verified the integrity of the air quality monitoring network. Precision
and accuracy results for the Fort Collins monitoring network for the years 1999 and 2000 are
contained in the Division's Quality Assurance Reports 3 Results for 2001 are summarized in the
Division's Accuracy Audits from March and September 2001, attached to the Technical Support
Document. The calculated 95 percent probability limits for the precision checks and accuracy
audits demonstrate that the sites were meeting acceptable quality assurance limits for
repeatability and accuracy.
Part H-draft Page 14 -
• CHAPTER 2: MAINTENANCE PLAN
Section 107(d)(3)(E)of the CAA stipulates that for a nonattainment area to be redesignated to
attainment, EPA must fully approve a maintenance plan that meets the requirements of CAA
Section 175A. The maintenance plan is a SIP revision and must provide for maintenance of the
relevant NAAQS in the area for at least ten years after redesignation by EPA.
Because EPA is allowed up to two years to approve redesignation requests after receiving a
complete submittal, and given the time needed to complete the State processes for legislative
approval and AQCC rule-making, the milestone year for this maintenance plan is 2015.
The EPA has established the core elements listed below as necessary for approval of
maintenance plans.
1. Emission inventories for current and future years
2. Maintenance demonstration
3. Description of the control measures for the maintenance period
4. Mobile source emissions budget
5. Approved monitoring network
6. Verification of continued attainment
7. Contingency plan
8. Subsequent maintenance plan revisions
A. Emission Inventories and Maintenance Demonstration
This section presents the emission inventories portion of the maintenance plan. Regional
emission inventories are provided for the 1992 attainment year, 1998, 2004, 2005 and 2010
interim years, and the 2015 maintenance year. (Please see Tables 2 and 3 below.)
•
Part 11-draft Page 15-
Table 2 - 1992-2015 Fort Collins Urban Growth Area Emission
Inventories
Mobile Area/Non-
Urban Fleet Avg. Inventory road
Growth Area CO rate
Year VMT G/mi Tons/day Tons/day Totals Strategies
1992 1,783,560 46.04 90.5 38.4 128.9 Idle I/M
1992 oxy level
1998 2,368,378 29.11 76.0 39.3 115.3 Idle I/M
1998 oxy level
2004 2,740,108 27.67 83.6 42.6 126.2 No controls
2005 2,808,640 25.53 79.1 43.2 122.3 No controls
2010 3,316,072 18.33 67.0 46.1 113.1 No controls
2015 3,919,244 15.48 66.9 50.7 117.6 No controls
Modeled emission inventories for the years 2004, 2005, 2010 and 2015 (interim years and out
year) incorporate no control strategies.
The inventories provide emissions estimates for a weekday during the winter carbon monoxide
season (November through February). The modeling domain consists of the Fort Collins urban
growth area,which encompasses the Fort Collins nonattainment area. The carbon monoxide
attainment/maintenance area is used to establish the mobile source emissions budget.
The inventories were developed using EPA-approved emissions modeling methods and the
latest transportation and demographic data from the North Front Range Transportation &Air
Quality Planning Council. The technical support document for this maintenance plan contains
detailed information on model assumptions and parameters for each source category. The
technical support document for this maintenance plan describes in detail the assumptions and
methodologies used for all modeling work.
Part 9-draft Page 16 -
TABLE 3: EMISSION INVENTORIES FOR THE FORT COLLINS
CARBON MONOXIDE INVENTORY/MODELING DOMAIN
Carbon Monoxide Emissions (tons/day)
ource Category 1992 1998 005 010 015
Residential Heating .3 0.4 .5 .5 .6
ommercial Heating 11 0.1 .2 .2 .2
ommercial Non-road 3.4 4.2 5.7 .9 .8
onstruction Non-road 1.7 1.6 1.4 1.5 1.7
Industrial Non-road 1.6 1.7 1.8 1.8 1.9
Commercial Lawn and Garden5.1 5.2 .3 .0 8.3
Residential Lawn and Garden .9 1.0 1.0
.1 1.0
.3 1.5
Agriculture Non-road .0 .0 .0 .0 .0
Recreation Non-road .2 .2 .2 .2 .2
oodbuming 4.3 4.5 5.6 6.3 7.1
Railroad Non-road .0 .0 .0
Railroad Locomotives 1.0 .0 0.0 .0 0.0
Point Sources .8 .4 PA 0.4 PA
On-Road Mobile 190.5 176.0 179.1 67.0 166.9
TOTAL 1128.9 1115.3 1122.3 1113.1 1117.6
B. Control Measures to be Removed for the Maintenance Period
As of January 1, 2004, the oxygenated fuels program and the Basic I/M program will not be part of
the Federally enforceable SIP for the Fort Collins area. No emission reduction credit has been taken
in the maintenance demonstration for these or any other current State or local control programs.
Specific programs and requirements that will cease to be part of the State Implementation Plan as
of January 1, 2004 are:
1)Oxygenated fuels program
2) Basic I/M program
3) Contingency measures included in the 1982 attainment SIP element.
The federally enforceable Basic UM program included in the SIP for this area through December 31,
2003 does not include on-board diagnostics (OBD) testing because modeling demonstrates that
maintenance of the NAAQS can be achieved without it. For the period prior to January 1, 2004,
maintenance is achieved with Basic I/M without OBD testing. For the period beginning January 1,
2004, maintenance is achieved for the remainder of the maintenance period without an I/M program.
Part 11-draft Page 17 -
C. Enforceable Control Measures for the Maintenance Period
1. 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.
2. Air Quality Control Commission Regulation Number 3
3. Wood stove standards contained in AQCC Regulation Number 4
4. AQCC Regulation Number 6
5. AQCC Common Provisions Rule
The Common Provisions and Regulation Number 6 delineate industrial source control programs.
The Common Provisions, and Parts A and B of Regulation Number 3 are already included in the
approved Colorado SIP. Regulation Number 6 and Part C of Regulation Number 3 implement the
Federal standards of performance for new stationary sources and the federal operating permit
program. The Fort Collins area Maintenance Plan makes no changes to these regulations.
In accordance with State and federal regulations and policies, the State and federal nonattainment
area New Source Review requirements currently in effect for Fort Collins will revert to the State and
federal attainment area Prevention of Significant Deterioration permitting requirements once EPA
approves this redesignation request and maintenance plan.
D. Transportation Conformity and Mobile Source Carbon Monoxide Emissions Budget
The transportation conformity provisions of section 176(c)(2)(A) of the CAA require regional
transportation plans and programs to show that emissions expected from implementation of plans
and programs are consistent with estimates of emissions from motor vehicles and necessary
emissions reductions contained in the applicable state implementation plan.
For the Fort Collins area,total carbon monoxide emissions in future years must be lower than those
of 1992 (the base year). The Fort Collins area mobile source emissions budget is 77 tons per year
for 2015 and beyond.The emissions budget was derived by taking the difference between the base
year (1992) total emissions and out year (2015) total emissions. This difference is the "safety
margin."The calculation is: 129 tons— 118 tons= 11 tons safety margin. This amount, less one ton,
is added to the projected mobile source emissions for 2015,that is, 10 tons+67 tons=77 tons.The
budget allows for flexibility for mobile source growth beyond projected levels for the out year.
(Please see Table 4 below.)
Part 11-draft Page 17 -
Table 4: Mobile Source Emissions Margins of Safety, Emissions Bud et Tons Per Da
Year Mobile Total Math Margin of
Emissions Emissions Safety(tpd)
(tpd) (tpd)
1992 Base 91 129 N/A N/A N/A
2004 84 126 129-126 = 3 N/A
3— 1 = 2 2
2005 79 122 129-122 = 7 N/A
7 - 1 = 6 6
2010 67 113 129-113 = 16 N/A
16 — 1 = 15 15
2015 67 118 129— 118 = 11 77 tpd
11 - 1 = 10
67 + 10 = 77 10
One emissions budget is calculated for the entire period of the maintenance plan.
The Fort Collins area mobile source emissions budget of 77 tons is to take effect upon EPA
approval, or 45 days after submittal of the Plan, unless the budget is determined by the EPA to be
inadequate, per 40 CFR 93.118(e)(1).
Because informal roll forward analyses indicate that the emissions budget may be exceeded by
mobile source emissions in the year 2030, the APCD commits to re-implementing the Basic
Inspection & Maintenance Program in 2026. The I/M program shall include any federally required
on-board diagnostic tests.
• This commitment to implement an I/M program in 2026 is included in the Maintenance Plan for
purposes of 40 CFR Part 93.122(a)(3) (iii),which provides that emissions reduction credit from such
programs may be included in the emissions analysis required by the Federal Transportation
Conformity Rule, if the Maintenance Plan contains such a written commitment. This commitment
is included in the Maintenance Plan solely for the purpose of authorizing such emission reduction
credits for transportation conformity determinations and shall not be construed to extend the
maintenance period beyond the year 2015.
E. Monitoring Network/Verification Of Continued Attainment
Once the Fort Collins area has been redesignated to attainment status by EPA, the 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 carbon monoxide standard. The APCD has committed
to siting a second carbon monoxide monitor in the Fort Collins area in 2002.
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. Annual review of the NAMS/SLAMS air quality
surveillance system will be conducted in accordance with 40 CFR 58.20(d) to determine whether
the system continues to meet the monitoring objectives presented in Appendix D of 40 CFR Part
58.
Part N-draft Page 18 -
F. 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 carbon monoxide standard which
occurs after redesignation to attainment. Attainment areas are not required to have pre-selected
contingency measures,and this plan removes any commitment to contingency measures contained
in the 1982 Fort Collins nonattainment SIP Element.
The contingency plan must ensure that the contingency measures are adopted expeditiously once
the need is triggered. The primary elements of the contingency plan are: 1) the list of potential
contingency measures; 2)the tracking and triggering mechanisms to determine when contingency
measures are needed; and 3)a description of the process for recommending and implementing the
contingency measures.
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 of the 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.
1. List of Potential Contingency Measures
Section 175A(d) of the CAA requires the Maintenance Plan to include as potential contingency
measures all of the carbon monoxide control measures contained in the SIP before redesignation
which were relaxed or modified through the Maintenance Plan. For the Fort Collins area, this
includes the following measures:
a. A Basic vehicle inspection and maintenance program as described in AQCC Regulation
Number I 1 prior to modifications made as of (insert AQCC Public Hearing date),with
the addition of any on-board diagnostics components required by federal law.
b. An oxygenated fuels program as described in Chapter 1, Part I of this document
and set forth in Colorado Air Quality Regulation Number 13, prior to modifications
made as of(insert AQCC Public Hearing date).
In addition to this list of potential contingency measures, the State may evaluate other potential
strategies, including but not limited to, enhanced I/M, transportation control measures and
mandatory wood burning restrictions, in order to address any future violations in the most
appropriate and effective manner possible.
Part H-draft Page 19 -
G. Tracking and Triggering Mechanisms
• Tracking
The primary tracking plan for the Fort Collins area consists of continuous carbon monoxide
monitoring by APCD as described above. The APCD will notify the EPA, the AQCC, the Council
and local governments of any exceedance of the carbon monoxide standard within 30 days of
occurrence.
The ongoing regional transportation planning process carried out by the Council in coordination with
the CDOT,APCD, AQCC, and EPA, will serve as another means of tracking mobile source carbon
monoxide emissions into the future.
• Triggering
An exceedance of the carbon monoxide standard (any value over 9.5 ppm) may trigger a voluntary,
local process by the Council 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 carbon monoxide standard. Specifically, this would be a second
value of 9.5 ppm or higher at the same monitor during any calendar year.
H. Process for Recommending and Implementing Contingency Measures
The State will move forward with mandatory implementation of contingency measures under the SIP
. if a violation (a second exceedance in a calendar year)of the carbon monoxide standard occurs.
No more than 60 days after being notified by the APCD that a violation of the carbon monoxide
standard has occurred, the APCD in conjunction with the MPO and the AQCC, will initiate a
subcommittee process to begin evaluating potential contingency measures. The subcommittee will
present recommendations to the North Front Range MPO and the Division within 120 days of
notification and the North Front Range MPO and the Division will present recommended
contingency measures to implement to the AQCC within 180 days of notification.
The AQCC will then hold a public hearing to consider the contingency measures recommended by
the APCD and Council, along with any other contingency measures the Commission 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.
Part 11-draft Page 20 -
I. Subsequent Maintenance Plan Revisions
It is required that a maintenance plan revision be submitted to the EPA eight years after the original
redesignation requesttmaintenance plan is approved. The purpose of this revision is to provide for
maintenance of the NAAQS for an additional ten years following the first ten-year period.The State
of Colorado commits to submit a revised maintenance plan eight years after redesignation to
attainment, as required by the CAA and EPA.
Fort Collins Land Use,Transportation, &Air Quality Team, Estimation of VMT and VMT Growth Rate,
June 22, 2001.
2 Letter from Doug Benevento to John Fischbach, March 5,2002.
3 Colorado Department of Public Health& Environment,APCD,Technical ServicesProgrami April 9,
2002.
Part 11-draft Page 21 -