2017 - PM2.5 SIP and Regulations: Questions & Answers
Per state statute, DEC is required to respond to questions that it receives at least 10 days before the end of a public comment period. For this regulatory proposal that cutoff was August 28th at 5:00 PM and the comment period has closed. DEC's answers to the written questions it received before August 28th are listed below.
Select a question below to see answer:
The Legislature funds the Department of Environmental Conservation Division of Air Quality effort to develop regulations that manage air quality. For example, the State runs an air quality permitting program for new development and the operating permit program for existing sources of air pollution. The State funds these permit and compliance activities through user fees paid by the permitted sources. The Legislature also appropriates funds to develop and manage an air quality plan to maintain air quality, and for areas that do not meet health or welfare based ambient standards to improve air quality. Services are paid through a mix of general funds and a federal grant that requires the State to match federal funds.
In general, the permit fees pay for permit administration: licensing; reporting; periodic inspection; investigation of non-compliance; and record-keeping for the permitted source universe. Finding funding for programs for real-life solutions is a constant challenge for both the State and Borough. We presently assist the Fairbanks North Star Borough manage air quality through actions such as wood heating device change-out program to replace older devices with new devices that meet EPAs new emission standards. If the questioner is interested in the money collected by the FNSB and its uses, please contact the FNSB Air Quality Division office at 907-459-1234 or find information at the FNSB Air Quality Division webpage
Typically wood fired heating device owner manuals identify the recommended wood moisture content for ideal combustion in the device. If the actual moisture content is not indicated, the manual will state that the wood should be dry. EPA and the State of Alaska currently classify wood with a moisture content of less than 20% as "dry wood".
18 AAC 50.077(e) allows for a manufacturer (any manufacturer, which could be a home owner) of a device to provide proof that the device is in compliance with the standards. This regulation identifies the test method options and standards that need to be met for compliance.
For additional information on test methods, see EPAs webpage.
For additional information on Wood-Fired heating Device standards, including emission standards, see: Burnwise Standards.
Certification of coal stoves will be determined by either the Fairbanks North Star Borough (FNSB) air quality program or EPA. The FNSB ordinances are focused on solid-fuel fired devices, which include both wood and coal. In order to be consistent with the FNSB ordinances, DEC has proposed a coal-fired device section in our proposed regulations but structured the regulations so that the certification and use of these devices will be determined by the FNSB. For questions regarding FNSB solid fuel burning ordinances and requirements, please contact the FNSB Air Quality Division office at 907-459-1234 or find information at the FNSB Air Quality Division webpage. A list of the types of appliances that EPA currently certifies.
Yes. EPA has conducted studies to develop emission factors in its AP-42 guide. This guide is the official repository of how emissions may be calculated. See EPAs webpage for additional information regarding coal combustion emission factors.
Under current regulations, the only limit or restriction regarding blacksmithing and use of coal is that it must meet the 20% opacity requirement for operation during an air quality alert. Under the proposed regulations, the 20% opacity requirement must be met at all times except at initial startup. If the proposed regulations are implemented, the blacksmithing device could be required to be removed or replaced at the time of property sale if it does not meet Fairbanks North Star Borough (FNSB) or EPA requirements, unless a source test has been conducted to demonstrate that it meets emission standards, or a temporary waiver or exception is granted.
For questions regarding FNSB solid fuel burning ordinances and requirements please contact the FNSB Air Quality office at 907-459-1234 or find information at the FNSB Air Quality Division webpage.
Unfortunately, it is unclear as to the exact nature of this question, so two different possible answers are being provided.
- 2.5 PPM could mean PM2.5. PM2.5 is the acronym for particulate matter less than 2.5 micrograms per cubic meter. It references the diameter of the particulates. If there is additional regulation, for example, reducing the standard from 35 micrograms per cubic meter, to something lower, that would be decided by the Environmental Protection Agency (EPA) through their processes.
- 2.5 PPM could mean 2.5 g/hr. In this context, the 2.5 g/hr is the standard that wood-fired heating devices need to meet for new installations. In this context, EPA has developed enough justification that their New Source Performance Standards (NSPS) passed in 2015 reduce the 2.5 g/hr requirement to 2.0 g/hr by 2020. At that point, the federal rules will be more stringent than the current State of Alaska regulations. Fairbanks North Star Borough (FNSB) has already adopted the lower EPA NSPS 2020 standard into the FNSB ordinances.
This question was received during a State public hearing. In past years, the State Legislature appropriated general funding to support a wood stove change-out program in the Fairbanks North Star Borough (FNSB). In fiscal year 2017 and 2018, the Legislature did not appropriate funding to support this local program. More recently, the FNSB allocated its own resources to support the continued operation of the program. Please contact the FNSB Air Quality Office regarding costs related to the operation, maintenance, and funding of the stove change-out program. They can be contacted at 907-459-1234 or find information at the FNSB Air Quality Division webpage.
The development of state regulations regarding particulate matter and the Fairbanks North Star Borough (FNSB) nonattainment area may be found at this link: Previous Proposed Regulations. Included in this link are the responses to comments collected at hearings, open houses, and regulation proposal comment periods. Previously proposed changes are posted in tracked changes starting in 2013. However, these are just the State regulations and not the FNSB ordinances.
The State has not been involved in any buy-back program. Questions regarding a buy-back program should be directed to the FNSB Air Quality office at 907-459-1234 or find information at the FNSB Air Quality Division webpage.
Currently, the Moderate Area State Implementation Plan assumes an approximate 20% of the citizenry had a compliance rate (i.e. that 20% of the public will comply with the requirements). If there was 100% compliance by the citizens of the Fairbanks North Star Borough (FNSB), it is conceivable that the area could come into compliance. However 100% compliance by everyone is unlikely, and noncompliance will likely have to be offset with additional control programs.
In the FNSB PM2.5 Nonattainment Area, the Borough may continue moving toward more stringent regulation of wood burning, if the area continues to experience high levels of air pollution. DEC has been following the FNSBs lead in assisting to address the issues. Although the previous regulations and communal efforts may have improved air quality, the FNSB area still experiences PM2.5 air pollution levels above EPA air quality standards. Until attainment of these standards are achieved, DEC will continue efforts to improve air quality through regulation and education of the population.
These questions were provided during a State public hearing and appear to be focused on the Fairbanks North Star Borough (FNSB). Please contact the FNSB Air Quality Division office at 907-459-1234 or find information at the FNSB Air Quality Division webpage.
There has been modeling conducted for the entire nonattainment area which includes meteorological (weather) data. During the extreme episodes of pollution, the air is very stagnant or still. There is little transport (movement) of particulates into or out of the area. In general, meteorological information shows that when there is wind, the transport of particulates into the North Pole and Fairbanks region is through the Tanana River valley from North Pole into Fairbanks. Vertical mixing of air is also hindered during high concentration PM2.5 pollution events. Based on source contribution studies, the contribution from all the point sources (combined) at the North Pole monitor is approximately 5-10%. In other words, there is very little pollution contribution to the North Pole area from surrounding areas such as Fairbank/Wainwright.