Division of Air Quality Air Non-Point and Mobile Sources

Yes the monitors are showing an improvement in air quality. In fact, the levels appear to show approximately 50% improvement. Unfortunately, the State of Alaska failed to attain the 24-hour PM_2.5 National Ambient Air Quality Standard (NAAQS) by the applicable date, December 31, 2019. Consequently, subject to the Clean Air Act (CAA) Section 189(d), the State is required to submit a revised Serious area attainment plan that demonstrates that each year the area will achieve at least a 5 percent reduction in emissions of direct PM_2.5 or a 5 percent reduction in emissions of a PM_2.5 plan precursor based on the most recent emissions inventory for the Fairbanks North Star Borough nonattainment area.

The Proposed 2020 Amendment to the Serious SIP shows that the area can meet or attain the air quality health standard by 2024 if all of the proposed control measures are implemented and followed. Attainment needs to be achieved throughout the area, and this projected date is looking at the forecast for the most impacted monitor in North Pole. Other, less-impacted locations within the area will likely be in attainment sooner.

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.

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.

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 and the Serious SIP will continue. The 2020 Amendment to the Serious SIP only adds an additional contingency measure and is primarily a technical edit to incorporate the latest monitoring information and to demonstrate the SIP can meet the 5% reduction requirements as identified in the Clean Air Act Section 189(d).

In earlier discussions in the community, DEC had discussed an approach that relied on obtaining from the EPA a one-time extension of the attainment deadline of up to five years. That pathway is outlined in EPA’s PM2.5 Implementation Rule and requires the implementation of Most Stringent Measures. However, in December 2018 in further discussion with EPA it was noted that there is another path offered under the Clean Air Act (CAA). If a serious area fails to attain the PM2.5 NAAQS by the applicable attainment date, CAA Section 189(d) requires that the state in which the area is located, after the notice and opportunity for public comment, submit within 12 months after the applicable date, plan revisions that provide for attainment of the standard, and from the date of such submission until attainment, control strategy that demonstrates each year that the area will achieve at least 5 percent reduction in emissions of direct PM2.5 or a 5 percent reduction in emissions of a PM2.5 plan precursor based on the most recent emissions inventory for the area. The department believes the 2020 Amendment/5% plan approach provides more flexibility to the community in meeting Clean Air Act requirements and bringing the area into attainment. Under this planning approach, the Serious SIP was completed in December 2019 and the 2020 Amendment to the Serious SIP would incorporate the new CAA Section 189(d) requirements. We are not aware of any other SIP pathways that are available to the State beyond the two described above.

The 2020 Amendment/5% plan contains some new material but is not a new plan. The requirement for this plan update resulted from the area's failure to attain the standard by the end of 2019 and was an alternative planning pathway to the five year extension path that is outline in EPA’s PM2.5 Implementation Rule. According to CAA Section 189(d), if a serious area fails to attain the PM2.5 NAAQS by the applicable attainment date, the state in which the area is located, after the notice and opportunity for public comment, is required to submit within 12 months after the applicable date, plan revisions that provide for attainment of the standard, and from the date of such submission until attainment, control strategy that demonstrates each year that the area will achieve at least 5 percent reduction in emissions of direct PM2.5 or a 5 percent reduction in emissions of a PM2.5 plan precursor based on the most recent emissions inventory for the area. The department believes the 2020 Amendment/5% plan approach provides more flexibility to the community in meeting Clean Air Act requirements and bringing the area into attainment.

The 2020 Amendment/5% plan builds of the existing Moderate Plan and the adopted Serious Plan. The 2020 Amendment/5% Plan has a new base year, 2019, which means we are working with more recent emission data and monitoring data. The modeling design value for the plan must be based on the last 4-5 full years of monitoring data for North Pole. This is a lower design value than the one used for the Serious SIP.

Failure to meet a 5% reduction target, does not have a straight forward answer. The failure to meet a 5% reduction target would also require a review to see if there was a failure to meet Reasonable Further Progress (RFP) or a Quantitative Milestone (QM). As long as we continue to meet RFP and meet all QMs then failing to meet a single year 5% reduction might not have a direct consequence. However, if RFP and/or a QM is not met, then the implementation of a contingency measures would be required. Continued failure to meet RFP and QMs could result in a finding by EPA for a failure to implement (if it is felt the failure to meet RFP/QM is due to poor implementation of adopted control measures). Or it could result in EPA formally mandating a SIP update under Clean Air Act 110(k). The 2020 Amendment/5% Plan update includes a proposed contingency measure (see Plan Section III.D.7.11) that would be triggered if RFP/QM is not met.

Once the area reaches attainment, then the State will work with the Borough to develop a maintenance plan. During the development of a maintenance plan, it is possible to re-evaluate all measures and commit to those measures that will keep the community in attainment for 20 years. The plan must include contingency measures that would be automatically triggered if the area should exceed the standard.

Once the area reaches attainment, then the State will work with the Borough to develop a maintenance plan. During the development of a maintenance plan, it is possible to re-evaluate all measures and commit to those measures that will keep the community in attainment for 20 years. The plan must include contingency measures that would be automatically triggered if the area should exceed the standard. The area will not be required to continue to reduce emission 5% per year once attainment is reached and a maintenance plan is submitted and approved.

As currently proposed, DEC believes that the 2020 Amendment meets all the completeness criteria to meet the CAA Section 189(d) and other plan requirements.

The regulation of PM_2.5 and other pollutants by the EPA and DEC in the State is to prevent public health issues including stroke, kidney diseases, lung and heart complications, which may arise from the inhalation of PM_2.5 pollutants. The SIP and its 2020 Amendment are meant to reduce air pollution to healthy levels and gain health benefits for individuals in the community.

The proposed contingency measure included in the 2020 Amendment to the SIP would apply to the entire nonattainment area, which includes the North Pole, Fairbanks, and Goldstream zones. Maps of the boundaries of the nonattainment area and the air quality zones can be found in SIP Section III.D.7.3, “Non-Attainment Area Boundary and Design Episode Selection”.

The modeling analyses conducted for the SIP cover a 200 x200 km domain, which is much larger than the boundary of the nonattainment area. Emissions from all sources, including the permitted industrial facilities, throughout this large domain are accounted for in the analyses. The modeling also accounts for boundary conditions, which are emissions coming into the area from outside this broader domain. Information on the modeling can be found in SIP Section III.D.7.8.

No. Using the exceptional event criteria by EPA, a request is made for wildfire emissions to be excluded from the design values used for the SIP. EPA must review all requests and determine on a case by case basis if an exceptional event waiver will be granted. DEC is currently working on the documentation for exceptional events that occurred in 2019 but based on prior concurrence from EPA for wildfire events, DEC is not anticipating an issue for this SIP once EPA has time to review and consider the state’s forthcoming request. Information on the 2019 exceptional events and design values can be found in the proposed 2020 Amendment, Section III.7.4. Ambient Air Quality and Trends. Exceptional event requests submitted to EPA may be found at: Air Monitoring Exceptional Events