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Regulatory Proposals: Questions & Answers

NOTE: These questions and answers pertain to Fairbanks North Star Borough Fine Particulate Matter (PM2.5) regulatory proposals. The information from previous regulatory proposals were current at the time of posting, but may be outdated after the adoption of regulations and the SIP.

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The air quality seems to be improving, why is there another plan being proposed?
Yes the monitors are showing an improvement in air quality. In fact, the levels appear to show approximately 50% improvement. Unfortunately, there is still quite a ways to go and the Clean Air Act is structured to ensure that improvement happens as rapidly as possible. The intent of the Act is to continue to strengthen requirements the longer it takes to meet the health based standards.
Why are there so many new requirements?
When the Environmental Protection Agency (EPA) reclassified the area as a Serious Nonattainment Area that triggered a number of new more stringent requirements. States developing Serious Air Quality Plans must review controls from all other areas throughout the United States and implement all controls found unless it can be documented that a control measure is technically or economically infeasible. A measure may also be removed if a current regulation is more stringent. The new requirements proposed are those remaining measures that could not be documented technically or economically infeasible.
Why aren’t there more requirements for the Power Plants?
After review of the type of particulates that are on the filters, and confirmation studies, it has been determined that the Power Plants are not the main source of the air quality problem. The Power Plants, under the Serious Area requirements, have undergone a rigorous review called a Best Achievable Control Technology (BACT) analysis. The preliminary draft BACT analysis released in March 2018 illustrated that if all BACT was required the economic burden to the community would be substantial. Please see the Serious SIP for the proposed BACT Determinations that conclude economic infeasibility and other less burdensome requirements are better suited for air quality and the community.
Will the state allow ESPs (Electrostatic Precipitators?)
ESPs can be used, however, they cannot be used as a replacement for curtailment during bad air quality days. The reason is that there has not been enough testing of these devices, in the United States, to provide proof that emissions reductions provided by ESPs are equal to not burning at all, which is the objective of the curtailments included in the current air quality plan. The Borough and others are working on testing studies that will provide additional data on these retrofit devices.
Were the Stakeholder Recommendations Used?
Yes, the Stakeholder recommendations were used in the development of the Serious SIP. There is a detailed description of the process within the Serious SIP, Section III.D.7.7. There is also a summary of the regulations and requirements that show which specific Stakeholder recommendation was incorporated into the proposed regulations. Unfortunately, the recommendations from the Stakeholder group could not bring the area into attainment so additional measures were required and included in the proposed SIP.
When can the area meet the air quality standards?
The Proposed Serious SIP shows that the area can meet attainment by 2029 if all of the proposed control measures are implemented and followed. It may be possible to attain earlier, but this is our best estimate using our current methods and models for projecting emissions into the future.
Why is there a proposed regulation to require switching to Diesel #1, isn’t wood burning the problem?
Yes, wood burning is the main source of fine particulate matter (PM2.5), however, PM2.5 is a complex mixture of small particulates and liquid droplets and is made up of more than just organic carbon (type of particulate from wood burning). PM2.5 is also made up of elements identified as precursor pollutants. Sulfur dioxide (S02) is the second largest component of the PM2.5 problem. SO2 comes from the sulfur in home heating fuel and other diesel and coal combustion. Diesel #2 has 2,566 ppm of sulfur, while Diesel #1 has only 896 ppm. Diesel #1 is a compromise control for the FNSB nonattainment area due to its lower economic impact. Other communities use ultra-low sulfur diesel fuel (ULSD) which has only 15 ppm sulfur. However, ULSD can increase costs $0.30 - $0.40 cents per gallon. Diesel #1 is expected to increase costs $0.02 - $0.07 cents gallon.
What is fine particulate matter (PM2.5) and where does it come from?
Fine particulate matter (PM2.5) is a complex mixture of extremely small particles and liquid droplets less than 2.5 micrometers in diameter. A single human hair is almost 30 times larger in diameter than the largest fine particle, PM2.5. PM2.5 is a product of combustion, primarily caused by burning fuels. Examples of PM2.5 sources include power plants, vehicles, wood burning stoves, and wildland fires. Further information may be found at: Particulate Matter.
Why is fine particulate matter (PM2.5) such a problem for the Fairbanks North Star Borough?
  • The Fairbanks North Star Borough faces a challenging air quality problem due to periodic extreme cold weather and the wood smoke that’s produced when people burn wood to heat their homes.
  • The pollutant is known as fine particulate matter (or “PM2.5”). There are National Ambient Air Quality Standards (NAAQS) set by the Environmental Protection Agency for PM2.5. These include the primary and secondary standards. It is important to remember that primary standard is meant to protect against short-term health effects from these sorts of air pollution spikes. The area where levels periodically exceed the standard is known as a “nonattainment area.”
  • The high levels of air pollution create a public health risk for the residents of Fairbanks North Star Borough, and a strong air quality plan is essential for reducing public exposure to these high levels of air pollution as soon as possible.
Did DEC consider the costs of heating in the development of its State Implementation Plan?
  • The state recognizes that residents of Fairbanks North Star Borough face high energy costs and the need to keep homes and businesses warm in extreme cold, so it is critical that the borough and state develop a plan that works for the specific air quality challenges of the area.
  • The state has applied and received Targeted Air Shed Grants to assist in wood stove change out and conversion programs. The funding has been provided to supplement the Fairbanks North Star Borough’s woodstove change out program in changing out wood and coal-fired home heating devices. The state has also been aggressively working on projects to expand the availability of natural gas in the nonattainment area, including the Interior Energy Project (LNG trucking) and gas pipeline projects.
What is in the PM2.5 State Implementation Plan for the Fairbanks North Star Borough nonattainment area?
There are two air quality plans for the Fairbanks North Star Borough PM2.5 nonattainment area which focus on programs that will help improve the Borough's air quality while recognizing and balancing the need for local residents to economically heat their homes. A mix of programs are needed to bring the area into compliance with the ambient air quality standard. Measures already in place from the Moderate SIP will continue and the Serious SIP incorporates additional measures including:
  • Solid fuel burning curtailments (ie. burn bans) continue but will be called at lower concentrations. Waivers are available and described in the Episode Plan (Section III.D.7.12).
  • Only Diesel fuel #1 will be allowed for use in space heating in the nonattainment area, but not starting until July 2020.
  • Dry wood only may be sold in the nonattainment area, requirement is proposed to start in October 2021.
  • No new outdoor solid fuel hydronic heaters sold or installed unless they are pellet fueled.
  • Stricter emission requirements for new wood fired heating devices.
  • All uncertified solid fuel heating devices must be removed either prior to December 2024 or when homes are sold or leased. They may be replaced with new devices.
  • Solid fuel heating device registration requirements under certain programs.
  • Data submission requirements for used oil burners, charbroilers, and incinerators.
  • Emission control requirements for coffee roasters.
  • Major industrial (point) sources will be controlled as determined through the Best Available Control Technology (BACT) process.
  • EPA certified devices that are older than 25 years to be removed or replaced by December 2024 has been identified as a contingency measure.