2005 Periodic Emissions Inventory
for
PM10

for the
Maricopa County, Arizona, Nonattainment Area

MAY 2007

Foreword
This 2005 PM10 emissions inventory will serve as the basis for the Five Percent Plan projected
2007, 2008, and 2009 PM10 emissions inventories. A draft document was released for public
review by the Maricopa County Air Quality Department (MCAQD) in January 2007. The
present draft incorporates the comments submitted during a 30-day public comment period.
Appendix 1 of this report summarizes comments received along with MCAQD’s responses.
This document is also available electronically on the MCAQD website:
http://www.maricopa.gov/aq/divisions/planning_analysis/emissions_inventory/Default.aspx

Maricopa County Air Quality Department
Emissions Inventory Unit
1001 N. Central Avenue, Suite 595
Phoenix, AZ 85004
e-mail: EmisInv@mail.maricopa.gov

2005 PM10 Periodic Emission Inventory
for the Maricopa County, AZ Nonattainment Area
May 2007

Table of Contents
1. Introduction............................................................................................................................. 1
1.1
1.2
1.3
1.4
1.5
1.6

1.7

Overview.................................................................................................................................1
Agencies responsible for the emissions inventory..................................................................1
Temporal scope.......................................................................................................................2
Geographic scope....................................................................................................................2
Overview of local demographic and land-use data.................................................................3
1.5.1 Demographic profile ....................................................................................................3
1.5.2 Land-use data ...............................................................................................................3
Emissions overview by source category.................................................................................4
1.6.1 Point sources ................................................................................................................4
1.6.2 Area sources.................................................................................................................5
1.6.3 Nonroad mobile sources ..............................................................................................5
1.6.4 Onroad mobile sources ................................................................................................6
1.6.5 Biogenic sources ..........................................................................................................7
1.6.6 All sources ...................................................................................................................7
Response to public review of draft inventory.......................................................................11

2. Point Sources ......................................................................................................................... 13
2.1
2.2
2.3

2.4
2.5
2.6
2.7

2.8

Introduction and scope..........................................................................................................13
Identification of point sources ..............................................................................................14
Procedures for estimating emissions from point sources......................................................18
2.3.1 Calculation of PM2.5 emissions ..................................................................................18
2.3.2 Application of rule effectiveness ...............................................................................19
2.3.3 Example 1: 91st Ave. Wastewater Treatment Plant ..................................................20
2.3.4 Example 2: River Ranch Plant #40 ............................................................................21
Detailed overview of point source emissions .......................................................................22
2.4.1 Point source emissions by geographic location .........................................................22
Emission reduction credits....................................................................................................26
Summary of point source emissions .....................................................................................27
Quality assurance / quality control procedures.....................................................................27
2.7.1 Emission survey preparation and data collection.......................................................27
2.7.2 Submission processing...............................................................................................28
2.7.3 Analysis of annual point source emissions data for this inventory............................29
References.............................................................................................................................29

3. Area Sources.......................................................................................................................... 31
3.1
3.2

Scope and methodology........................................................................................................31
Fuel combustion....................................................................................................................32
3.2.1 Industrial natural gas..................................................................................................33

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3.3

3.4

3.5

3.2.2 Industrial fuel oil........................................................................................................34
3.2.3 Commercial/institutional natural gas .........................................................................36
3.2.4 Commercial/institutional fuel oil ...............................................................................37
3.2.5 Residential natural gas ...............................................................................................39
3.2.6 Residential wood combustion ....................................................................................39
3.2.7 Residential fuel oil .....................................................................................................41
3.2.8 Summary of all area-source fuel combustion ............................................................42
Industrial processes...............................................................................................................42
3.3.1 Chemical manufacturing ............................................................................................42
3.3.2 Food and kindred products.........................................................................................44
3.3.2.1 Commercial cooking ................................................................................... 44
3.3.2.2 Grain handling/processing........................................................................... 45
3.3.2.3 Ammonia cold storage ................................................................................ 46
3.3.3 Secondary metal production ......................................................................................46
3.3.4 Non-metallic mineral processes .................................................................................47
3.3.5 Mining and quarrying ................................................................................................47
3.3.6 Wood product manufacturing ....................................................................................48
3.3.7 Rubber/plastics manufacturing ..................................................................................49
3.3.8 Fabricated metal products manufacturing..................................................................51
3.3.9 Construction ...............................................................................................................52
3.3.10 Electrical equipment manufacturing ..........................................................................55
3.3.11 State-permitted portable sources................................................................................56
3.3.12 Paved/unpaved road travel on industrial sites............................................................57
3.3.13 Industrial processes not elsewhere classified (NEC) .................................................57
3.3.14 Summary of all area-source industrial processes.......................................................58
Waste treatment and disposal ...............................................................................................59
3.4.1 On-site incineration....................................................................................................59
3.4.2 Open burning .............................................................................................................60
3.4.3 Landfills .....................................................................................................................63
3.4.4 Publicly owned treatment works (POTWs) ...............................................................63
3.4.5 Other industrial waste disposal ..................................................................................63
3.4.6 Summary of all area-source waste disposal ...............................................................64
Miscellaneous area sources...................................................................................................64
3.5.1 Other combustion.......................................................................................................64
3.5.1.1 Wildfires...................................................................................................... 64
3.5.1.2 Prescribed fires ............................................................................................ 66
3.5.1.3 Structure fires .............................................................................................. 67
3.5.1.4 Vehicle fires ................................................................................................ 68
3.5.1.5 Engine testing .............................................................................................. 69
3.5.2 Agricultural Activities ..............................................................................................69
3.5.2.1 Tilling .......................................................................................................... 69
3.5.2.2 Harvesting ................................................................................................... 75
3.5.2.3 Travel on unpaved agricultural roads.......................................................... 78
3.5.2.4 Cotton ginning............................................................................................. 79
3.5.2.5 Fertilizer application ................................................................................... 80
3.5.3 Livestock....................................................................................................................80
3.5.4 Health services: crematories ......................................................................................81
3.5.5 Accidental releases.....................................................................................................82
3.5.6 Humans ......................................................................................................................83

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3.6
3.7
3.8
4.1
4.2
4.3
4.4
4.5
4.6
4.7
4.8
4.9
4.10
4.11
4.12
4.13
4.14
4.15

3.5.7 Leaf blower fugitive dust ...........................................................................................83
3.5.8 Offroad recreation vehicles fugitive dust...................................................................84
3.5.9 Unpaved parking lots fugitive dust ............................................................................86
3.5.10 Windblown dust .........................................................................................................87
3.5.11 Summary of all miscellaneous area sources ..............................................................88
Summary of all area sources.................................................................................................89
Quality assurance / quality control procedures.....................................................................91
References.............................................................................................................................93
Introduction...........................................................................................................................97
Agricultural equipment .........................................................................................................98
Airport ground support equipment .......................................................................................99
Commercial equipment.......................................................................................................100
Construction and mining equipment...................................................................................100
Industrial equipment ...........................................................................................................101
Lawn and garden equipment...............................................................................................102
Pleasure craft.......................................................................................................................102
Railway maintenance equipment ........................................................................................103
Recreational equipment ......................................................................................................103
Aircraft................................................................................................................................104
Locomotives........................................................................................................................108
Summary of all nonroad mobile source emissions .............................................................110
Quality assurance procedures .............................................................................................110
References...........................................................................................................................110

5. Onroad Mobile Sources...................................................................................................... 113
5.1
5.2
5.3
5.4

5.5
5.6

5.7

Introduction.........................................................................................................................113
VMT estimation..................................................................................................................114
Vehicle speed......................................................................................................................116
Emission factor estimation procedures ...............................................................................117
5.4.1 MOBILE6.2 emission factor model.........................................................................117
5.4.1.1 MOBILE6.2 inputs.................................................................................... 117
5.4.1.2 MOBILE6.2 outputs.................................................................................. 117
5.4.1.3 Summary of MOBILE6.2 emission factors............................................... 118
5.4.1.4 MOBILE6.2 emission estimates ............................................................... 118
5.4.2 AP-42 emission factors for paved and unpaved roads.............................................122
Summary of particulate emissions from onroad mobile sources........................................124
Quality assurance process...................................................................................................125
5.6.1 VMT estimates.........................................................................................................125
5.6.2 Emission factor estimates ........................................................................................125
5.6.3 Draft particulate matter emissions inventory ...........................................................125
References...........................................................................................................................126

6. Biogenic Sources.................................................................................................................. 127
6.1
6.2
6.3
6.4
6.5

Introduction and scope........................................................................................................127
MEGAN input files.............................................................................................................127
Emission estimation............................................................................................................128
Summary of biogenic source emissions..............................................................................129
References...........................................................................................................................129

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List of Tables
Table 1.2–1.
Table 1.5–1.
Table 1.5–2.
Table 1.6–1.
Table 1.6–2.
Table 1.6–3.
Table 1.6–4.
Table 1.6–5.
Table 1.6–6.
Table 1.6–7.
Table 1.6–8.
Table 1.6–9.
Table 1.6–10.
Table 1.6–11.
Table 2.2–1.
Table 2.4–1.
Table 2.5–1.
Table 2.6–1.
Table 2.6–2.
Table 3.1–1.
Table 3.2–1.
Table 3.2–2.
Table 3.2–3.
Table 3.2–4.
Table 3.2–5.
Table 3.2–6.
Table 3.2–7.
Table 3.2–8.

Chapter authors and QA/QC contacts......................................................................1
Demographic profile of Maricopa County and the PM10 nonattainment area. ........3
Land-use categories used to apportion emissions....................................................3
Summary of annual and typical daily emissions from point sources in
Maricopa County. ....................................................................................................4
Summary of annual and typical daily emissions from point sources in the
PM10 NAA. ..............................................................................................................4
Summary of annual and typical daily emissions from area sources in Maricopa
County......................................................................................................................5
Summary of annual and typical daily emissions from area sources in the PM10
NAA.........................................................................................................................5
Annual and typical daily emissions from nonroad mobile sources in Maricopa
County......................................................................................................................5
Annual and typical daily emissions from all nonroad mobile sources in the
PM10 NAA. ..............................................................................................................6
Annual and typical daily emissions from all onroad mobile sources in
Maricopa County. ....................................................................................................6
Annual and typical daily emissions from all onroad mobile sources in the
PM10 NAA. ..............................................................................................................6
Annual and season-day NOx emissions from biogenic sources...............................7
Annual and typical daily emissions from all sources in Maricopa County. ............8
Annual and typical daily emissions from all sources in the PM10 nonattainment
area.........................................................................................................................10
Name and location of all point sources..................................................................15
Annual and typical daily point source emissions, by facility. ...............................23
Emission reduction credits.....................................................................................26
Maricopa County annual and typical daily point source emissions, by source
category..................................................................................................................27
PM10 nonattainment area annual and typical daily point source emissions, by
source category. .....................................................................................................27
List of area-source categories. ...............................................................................31
Maricopa County natural gas sales data by supply company and end-user
category..................................................................................................................32
Emission factors and annual emissions from area-source industrial natural gas
combustion, by combustion type. ..........................................................................33
Annual and typical daily emissions from area-source industrial natural gas
combustion.............................................................................................................34
Emission factors and annual emissions from area-source industrial fuel oil
combustion, by combustion type. ..........................................................................35
Annual and typical daily emissions from area-source industrial fuel oil
combustion.............................................................................................................35
Emission factors and annual emissions from area-source
commercial/institutional natural gas combustion, by combustion type.................36
Annual and typical daily emissions from area-source commercial/institutional
natural gas combustion. .........................................................................................37
Emission factors and annual emissions from area-source

2005 Periodic PM10 Emission Inventory

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commercial/institutional fuel oil combustion, by combustion type.......................38
Table 3.2–9. Annual and typical daily emissions from area-source commercial/institutional
fuel oil combustion. ...............................................................................................38
Table 3.2–10. Residential natural gas combustion emission factors (in lb/MMCF). ...................39
Table 3.2–11. Annual and typical daily emissions from residential natural gas combustion.......39
Table 3.2–12. Annual wood usage, emission factors, and annual emissions from residential
wood combustion. ..................................................................................................40
Table 3.2–13. Annual and typical daily emissions from residential wood combustion. ..............41
Table 3.2–14. Annual and typical daily emissions from residential fuel oil combustion.............41
Table 3.2–15. Annual and typical daily emissions from all area-source fuel combustion for
Maricopa County. ..................................................................................................42
Table 3.2–16. Annual and typical daily emissions from all area-source fuel combustion for
the PM10 NAA........................................................................................................42
Table 3.3–1. NAICS codes and descriptions for chemical manufacturing.................................43
Table 3.3–2. Annual and typical daily emissions from area-source chemical manufacturing. ..44
Table 3.3–3. Maricopa County restaurants by type. ...................................................................44
Table 3.3–4. Annual emissions from commercial cooking equipment, by equipment type.......44
Table 3.3–5. Typical daily emissions from commercial cooking equipment, by equipment
type.........................................................................................................................45
Table 3.3–6. Annual and typical daily emissions from commercial cooking equipment...........45
Table 3.3–7. Annual and typical daily emissions from area-source grain handling and
processing. .............................................................................................................45
Table 3.3–8. Annual and typical daily NH3 emissions from ammonia cold storage. .................46
Table 3.3–9. Annual and typical daily emissions from secondary metal production. ................47
Table 3.3–10. Annual and typical daily emissions from area-source non-metallic mineral
products..................................................................................................................47
Table 3.3–11. Annual and typical daily emissions from area-source mining and quarrying
operations...............................................................................................................48
Table 3.3–12. NAICS codes and descriptions for wood product manufacturing. ........................48
Table 3.3–13. Annual and typical daily emissions from area-source wood products
manufacturing. .......................................................................................................49
Table 3.3–14. NAICS codes and descriptions for rubber and plastic manufacturing facilities....49
Table 3.3–15. Annual and typical daily emissions from area-source rubber/plastic products
manufacturing. .......................................................................................................50
Table 3.3–16. Annual and typical daily emissions from area-source fabricated metal product
manufacturing. .......................................................................................................52
Table 3.3–17. 2005 Maricopa County dust control permits issued, by type................................52
Table 3.3–18. Average project duration and emission factor, by project type. ............................53
Table 3.3–19. Annual emissions from construction (tons/yr) for Maricopa County....................54
Table 3.3–20. Annual emissions from construction (tons/yr) for the Maricopa County
portion of PM10 NAA.............................................................................................54
Table 3.3–21. Annual emissions from construction (tons/yr) for the Pinal County portion of
the PM10 NAA........................................................................................................55
Table 3.3–22. Annual and typical daily emissions from construction..........................................55
Table 3.3–23. Annual and typical daily emissions from area-source electric equipment
manufacturing. .......................................................................................................55
Table 3.3–24. Emissions from ADEQ-permitted portable sources. .............................................57
Table 3.3–25. Annual and typical daily emissions from paved and unpaved road travel at
industrial facilities..................................................................................................57
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Table 3.3–26. Annual and typical daily emissions from other industrial processes not
elsewhere classified. ..............................................................................................58
Table 3.3–27. Annual and typical daily emissions from all area-source industrial processes in
Maricopa County. ..................................................................................................58
Table 3.3–28. Annual and typical daily emissions from all area-source industrial processes in
the PM10 NAA........................................................................................................59
Table 3.4–1. Annual and typical daily emissions from on-site incineration...............................60
Table 3.4–2. 2005 Maricopa County burn permit activity data. .................................................60
Table 3.4–3. Emission and fuel loading factors for open burning..............................................61
Table 3.4–4. Annual emissions from open burning in Maricopa County...................................62
Table 3.4–5. Surrogate land-use classes, ratios, and annual emissions from open burning in
the PM10 NAA........................................................................................................62
Table 3.4–6. Typical daily emissions from open burning...........................................................62
Table 3.4–7. Annual and typical daily emissions from landfills. ...............................................63
Table 3.4–8. NH3 emissions from publicly-owned treatment works (POTWs)..........................63
Table 3.4–9. Annual and typical daily emissions from other industrial waste disposal. ............63
Table 3.4–10. Annual and typical daily emissions from all area-source waste disposal for
Maricopa County. ..................................................................................................64
Table 3.4–11. Annual and typical daily emissions from all area-source waste disposal for the
PM10 NAA. ............................................................................................................64
Table 3.5–1. Assigned NFDRS Model categories, fuel loading factors, and material burned. ..65
Table 3.5–2. Summary of emission factors for prescribed fire (lb/ton)......................................65
Table 3.5–3. Annual emissions from wildfires (tons/yr). ...........................................................66
Table 3.5–4. Average daily emissions from wildfires (lbs/day). ................................................66
Table 3.5–5. Emission and fuel loading factors for prescribed fires. .........................................66
Table 3.5–6. Annual and typical daily emissions from prescribed fires.....................................67
Table 3.5–7. Estimated material burned, emission and fuel loading factors for structure
fires. .......................................................................................................................67
Table 3.5–8. Annual and typical daily emissions from structure fires. ......................................68
Table 3.5–9. Estimated material burned, fuel loading factors, and emission factors for
vehicle fires............................................................................................................68
Table 3.5–10. Annual and typical daily emissions from vehicle fires..........................................69
Table 3.5–11. Annual and typical daily emissions from engine testing. ......................................69
Table 3.5–12. 2002 Maricopa County agricultural crop acreage, activity, and uncontrolled
annual PM10 emissions...........................................................................................71
Table 3.5–13. Annual controlled PM10 emissions from agricultural tillage in Maricopa
County....................................................................................................................72
Table 3.5–14. Annual controlled PM10 and PM2.5 emissions from agricultural tillage. ...............73
Table 3.5–15. Controlled typical daily emissions from tillage in Maricopa County....................73
Table 3.5–16. Controlled annual and typical daily emissions from tillage within the PM10
NAA.......................................................................................................................74
Table 3.5–17. Maricopa County harvested acres and emission factors. .......................................75
Table 3.5–18. Annual emissions from harvesting (tons/yr)..........................................................77
Table 3.5–19. Typical daily emissions from harvesting (lbs/day)................................................77
Table 3.5–20. Annual and typical daily emissions from travel on unpaved agricultural roads....79
Table 3.5–21. Annual and typical daily emissions from area-source cotton ginning...................79
Table 3.5–22. Annual and typical daily ammonia emissions from fertilizer application. ............80
Table 3.5–23. Maricopa County cattle inventory and PM emission factors.................................81
Table 3.5–24. Annual and typical daily emissions from livestock. ..............................................81
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Table 3.5–25.
Table 3.5–26.
Table 3.5–27.
Table 3.5–28.
Table 3.5–29.
Table 3.5–30.
Table 3.5–31.
Table 3.5–32.
Table 3.5–33.
Table 3.5–34.
Table 3.5–35.
Table 3.6–1.
Table 3.6–2.
Table 4.1–1.
Table 4.1–2.
Table 4.2–1.
Table 4.2–2.
Table 4.2–3.
Table 4.2–4.
Table 4.3–1.
Table 4.3–2.
Table 4.4–1.
Table 4.4–2.
Table 4.5–1.
Table 4.5–2.
Table 4.6–1.
Table 4.6–2.
Table 4.7–1.
Table 4.7–2.
Table 4.8–1.
Table 4.8–2.
Table 4.9–1.
Table 4.9–2.
Table 4.10–1.
Table 4.10–2.
Table 4.11–1.
Table 4.11–2.
Table 4.11–3.
Table 4.12–1.

Annual and typical daily emissions from crematories...........................................82
Annual and typical daily emissions from accidental releases................................83
Annual and typical daily NH3 emissions from human activity..............................83
Leaf blower equipment populations, activity levels and emission factors for
Maricopa County. ..................................................................................................84
Annual and typical daily emissions from leaf blower fugitive dust. .....................84
VMT for offroad recreational vehicles in Maricopa County.................................85
Annual and typical daily emissions from offroad recreational vehicles
traveling on unpaved surfaces................................................................................85
Annual and typical daily emissions from vehicles traveling in unpaved
parking areas. .........................................................................................................87
Annual and typical daily emissions from fugitive windblown dust. .....................87
Annual and typical daily emissions from all miscellaneous area sources for
Maricopa County. ..................................................................................................88
Annual and typical daily emissions from all miscellaneous area sources for the
PM10 NAA. ............................................................................................................88
Summary of annual and typical daily emissions from all area sources in
Maricopa County. ..................................................................................................89
Summary of annual and typical daily emissions from all area sources in the
PM10 NAA. ............................................................................................................90
NONROAD2005 model county temperature and fuel-related inputs....................97
Default weekday and weekend day activity allocation fractions...........................98
Annual emissions (in tons/yr) from agricultural equipment in Maricopa
County....................................................................................................................99
Annual emissions (in tons/yr) from agricultural equipment in the PM10 NAA.....99
Typical daily emissions (lbs/day) from agricultural equipment in Maricopa
County....................................................................................................................99
Typical daily emissions (lbs/day) from agricultural equipment in the PM10
nonattainment area. ................................................................................................99
Annual emissions (in tons/yr) from airport ground support equipment. .............100
Typical daily emissions (in lbs/day) from airport ground support equipment.....100
Annual emissions (in tons/yr) from commercial equipment................................100
Typical daily emissions (in lbs/day) from commercial equipment......................100
Annual emissions (in tons/yr) from construction and mining equipment............101
Typical daily emissions (in lbs/day) from construction and mining equipment..101
Annual emissions (in tons/yr) from industrial equipment. ..................................101
Typical daily emissions (in lbs/day) from industrial equipment. ........................101
Annual emissions (in tons/yr) from lawn and garden equipment. .......................102
Typical daily emissions (in lbs/day) from lawn and garden equipment. .............102
Annual emissions (in tons/yr) from pleasure craft equipment.............................102
Typical daily emissions (in lbs/day) from pleasure craft equipment. ..................102
Annual emissions (in tons/yr) from railway maintenance equipment. ................103
Typical daily emissions (in lbs/day) from railway maintenance equipment. ......103
Annual emissions (in tons/yr) from recreational equipment................................103
Typical daily emissions (in lbs/day) from recreational equipment......................103
NEI default emission factors for PM10 and PM2.5, by aircraft category. ............104
2005 airport activity data and emission factors. ..................................................106
Annual and typical daily emissions, by airport and aircraft type. .......................107
Emission factors for locomotives.........................................................................108

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Table 4.12–2.
Table 4.12–3.
Table 4.12–4.
Table 4.12–5.
Table 4.13–1.
Table 4.13–2.
Table 5.2–1.
Table 5.2–2.
Table 5.2–3.
Table 5.2–4.
Table 5.4–1.
Table 5.4–2.
Table 5.4–3.
Table 5.4–4.
Table 5.4–5.
Table 5.4–6.
Table 5.4–7.
Table 5.4–8.
Table 5.4–9.
Table 5.4–10.
Table 5.4–11.
Table 5.5–1.
Table 5.5–2.
Table 6.3–1.
Table 6.3–2.
Table 6.4–1.

Fuel use and annual emissions from locomotives in Maricopa County. .............109
Annual emissions (in tons/yr) from locomotives in the PM10 NAA....................109
Typical daily emissions (in lbs/day) from locomotives in Maricopa County......109
Typical daily emissions (in lbs/day) from locomotives in the PM10
nonattainment area. ..............................................................................................109
Annual and typical daily emissions from nonroad mobile sources in Maricopa
County..................................................................................................................110
Annual and typical daily emissions from nonroad mobile sources in the PM10
NAA.....................................................................................................................110
2005 daily VMT (vehicle miles of travel) by vehicle class. ................................115
2005 VMT by silt loading category on paved roads in the PM10 modeling area.116
2005 unpaved road mileages and VMT in the PM10 modeling area....................116
VMTs for the PM10 modeling area, PM10 nonattainment area, and Maricopa
County..................................................................................................................116
Emission factors by vehicle class for the PM10 nonattainment area and
Maricopa County. ................................................................................................118
Daily PM10 nonattainment area emissions by vehicle class (metric tons/day). ...119
Daily Maricopa County emissions by vehicle class (metric tons/day). ...............120
Annual PM10 nonattainment area emissions by vehicle class (metric
tons/year)..............................................................................................................121
Annual Maricopa County emissions by vehicle class (metric tons/year). ...........122
2005 paved road fugitive dust emissions in the PM10 modeling area..................123
2005 paved road fugitive dust emissions without Serious Area PM10 Plan
control measures. .................................................................................................123
Estimated emission reductions attributed to measures to reduce paved road
fugitive dust. ........................................................................................................123
2005 fugitive dust emissions from paved roads...................................................123
Unpaved road fugitive dust emissions for the PM10 modeling area. ...................124
2005 fugitive dust emissions from unpaved roads...............................................124
Annual and average daily 2005 emissions from all onroad mobile sources for
the PM10 nonattainment area................................................................................124
Annual and average daily 2005 emissions from all onroad mobile sources for
Maricopa County. ................................................................................................125
Daily NO emissions in the 8-hour ozone modeling area (Maricopa County). ....129
Daily NO emissions in the PM10 nonattainment area. .........................................129
Annual and typical daily NOx biogenic emissions. .............................................129
List of Figures

Figure 1.4–1. Map of Maricopa County and the PM10 nonattainment areas..................................2
Figure 2.7–1. Data flow for annual point source emission inventory reporting. .........................28
Figure 6.3–1. Boundaries of PM10 Nonattainment Area, 8-Hour Ozone Modeling Area and
Maricopa County .................................................................................................128

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Appendices
Appendix 1

Responsiveness Summary to Comments Received on Public Review Draft 2005
Periodic Emissions Inventory for PM10 for the Maricopa County, Arizona,
Nonattainment Area

Appendix 2.1 Instructions for Reporting 2002 Annual Air Pollution Emissions
Appendix 2.2 Rule Effectiveness Study For Maricopa County Rules 310, 310.01, and 316
Appendix 2.3 Calculating Rule Effectiveness for Controlled (Title V and non-Title V)
Point Source Processes
Appendix 3.1 Calculating Rule Effectiveness for Agricultural Activities
Appendix 3.2 Development of a Fugitive Windblown PM10 Dust Emission Inventory for the
Phoenix PM10 Nonattainment Area
Appendix 5

MOBILE6.2 Input and Ouput Files

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

1.

Introduction

1.1

Overview

This 2005 periodic PM10 emissions inventory was developed to meet requirements set forth in
Title I of the Clean Air Act Amendments of 1990 (CAAA). The CAAA require development of
a baseline emission inventory and periodic revisions for areas that fail to meet the National
Ambient Air Quality Standards (NAAQS). A portion of Maricopa County is classified as serious
nonattainment for PM10.
PM10 is defined as particulate matter less than ten micrometers in diameter. This inventory
includes primary emissions of PM10 and PM2.5 as well as three particulate matter precursors:
nitrogen oxides (NOx), sulfur dioxides (SOx) and ammonia (NH3). The inventory provides
emission estimates from point, area, nonroad mobile, onroad mobile and biogenic sources.
Note that totals shown in tables may not equal the sum of individual values due to independent
rounding.

1.2

Agencies responsible for the emissions inventory

Maricopa County Air Quality Department (MCAQD) has primary responsibility for preparing
and submitting the 2005 Periodic PM10 Emissions Inventory for Maricopa County. Point sources
and the majority of area, and nonroad mobile source emission estimates were prepared by
MCAQD. The Maricopa Association of Governments (MAG) prepared the emission estimates
for onroad mobile, biogenic, and some area and nonroad mobile source categories. Table 1.2–1
lists those responsible for inventory preparation and quality assurance/ quality control activities,
which are described in the respective chapters.
Table 1.2–1. Chapter authors and QA/QC contacts.
Chapter
Author(s)
Point Sources
Bob Downing
MCAQD (602) 506-6790
Area Sources

Nonroad Mobile
Sources
Onroad Mobile
Sources
Biogenic Sources

Matt Poppen, Eric Raisanen and
Dena Konopka
MCAQD (602) 506-6790
Cathy Arthur, MAG (602) 254-6300
Matt Poppen and Eric Raisanen
MCAQD (602) 506-6790
Cathy Arthur
MAG (602) 254-6300
Cathy Arthur
MAG (602) 254-6300

2005 Periodic PM10 Emission Inventory

1

QA/QC contact persons
Matt Poppen, Eric Raisanen and Dena Konopka
MCAQD (602) 506-6790
Cathy Arthur, MAG (602) 254-6300
Bob Downing
MCAQD (602) 506-6790
Cathy Arthur, MAG (602) 254-6300
Bob Downing and Dena Konopka
MCAQD (602) 506-6790
Cathy Arthur, MAG (602) 254-6300
Bob Downing and Dena Konopka
MCAQD (602) 506-6790
Bob Downing and Dena Konopka
MCAQD (602) 506-6790

Maricopa County, AZ

1.3

Temporal scope

Annual and typical daily emissions were estimated for the year 2005, for Maricopa County and
the Maricopa County PM10 nonattainment area (NAA).

1.4

Geographic scope

This inventory includes emission estimates for Maricopa County and for the Maricopa County
PM10 nonattainment area. Maricopa County encompasses approximately 9,223 square miles of
land area, while the Maricopa County PM10 nonattainment area is approximately 2,880 square
miles or approximately 31 percent of the Maricopa County land area. A map of Maricopa
County and the PM10 nonattainment area is provided in Figure 1.4–1.
Figure 1.4–1. Map of Maricopa County and the PM10 nonattainment areas.

PM10 Nonattainment Area
Urban Areas
Major Highways

2005 Periodic PM10 Emission Inventory

2

Maricopa County, AZ

1.5

Overview of local demographic and land-use data

Many of the emissions estimates generated in this report were calculated using demographic and
land-use data provided by the Maricopa Association of Governments (MAG). These data were
used to apportion and/or scale Maricopa County emissions estimates to the nonattainment area
and vice versa. (For example, county-level emissions from residential natural gas usage in
Maricopa County were apportioned to the nonattainment area using the ratio of total population
in each area). Detailed explanations of how emission estimates were apportioned or scaled are
presented in each of the following chapters, along with the data sources used.
1.5.1

Demographic profile

The demographic data provided by MAG included population, employment data, and single
family/multi-family splits for calendar year 2004 (2005 data not yet available), for Maricopa
County and the nonattainment area. Table 1.5–1 provides an overview of the demographic data
used in this report.
Table 1.5–1.

Demographic profile of Maricopa County and the PM10 nonattainment area.
Maricopa
Within
Percent within
Demographic variable
County
PM10 NAA
PM10 NAA
Total resident population
3,524,175
3,529,764
100.16%
Total non-resident population
256,205
279,937
109.26%
Total population:
3,780,380
3,809,701
100.78%
Retail employment
Office employment
Industrial employment
Public employment
Other employment
Construction
Work at Home
Total employment:

437,333
359,824
352,827
216,598
151,751
53,774
57,682
1,629,789

435,390
360,309
350,412
209,768
151,618
53,432
57,216
1,618,145

Single Family/Multi-Family Household Split:
Single Family
75%
Multi-Family
25%

1.5.2

99.56%
100.13%
99.32%
96.85%
99.91%
99.36%
99.19%
99.29%
74%
26%

Land-use data

The most recent land-use data available from MAG was for the year 2004. The 2004 land-use
data was assumed to be representative of 2005. Table 1.5–2 presents a summary of the land-use
categories and acreage used to develop emission estimates for this inventory.
Table 1.5–2.

Land-use categories used to apportion emissions.
Acreage in
Acreage
Maricopa
within PM10
Description
County
NAA
General/active open space (e.g., parks)
148,352
141,334
Passive open space (e.g., mountain preserves)
1,748,816
377,814
Golf courses
28,215
28,228
Lakes
12,525
9,510
Agriculture
465,833
223,627
Vacant (e.g., developable land)
2,039,335
404,214

2005 Periodic PM10 Emission Inventory

3

Percent
within PM10
NAA
95.27%
21.60%
100.05%
75.93%
48.01%
19.82%

Maricopa County, AZ

1.6

Emissions overview by source category

1.6.1

Point sources

The point source category includes those stationary sources that emit a significant amount of
pollution into the air such as power plants, industrial processes and large manufacturing
facilities. As Maricopa County has an established annual reporting program for sources with air
quality permits, the thresholds for defining a point source are lower than the minimums required
by the US EPA. For the purposes of this inventory, a point source is a stationary operation
within Maricopa County which in 2005 emitted:
ƒ
ƒ
ƒ

25 English (short) tons or more of carbon monoxide (CO); or
10 tons or more of volatile organic compounds (VOC), oxides of nitrogen (NOx), or sulfur
oxides (SOx); or
5 tons or more of particulate matter less than 10 microns (PM10) or ammonia compounds
(NHx).

Tables 1.6–1 and 1.6–2 summarize annual and typical daily emissions from point sources in
Maricopa County and the PM10 nonattainment area, respectively. A detailed breakdown of
emissions calculations for all point sources is contained in Chapter 2.
Table 1.6–1.

Summary of annual and typical daily emissions from point sources in Maricopa County.
Annual (tons/yr)
Typical day (lbs/day)
Source Category
PM10 PM2.5
NOx
SOx NH3
PM10 PM2.5
NOx
SOx
NH3
Electricity generation
Comm./inst. fuel combustion
Industrial fuel combustion
Food/agriculture
Industrial processes
Manufacturing processes
Industrial road travel
Waste disposal
Emission reduction credits

All Point Sources

313.86
4.90
79.10
64.21
842.61
9.17
729.71
69.62

313.20 1,914.79 51.58 198.06
4.88
58.20
2.82
2.53
78.84
739.13 50.59 55.13
18.08
556.08
116.20 123.40 18.11
8.95
15.00
0.02
0.16
294.90
59.45
27.55 56.53

1.80

9.80

0.16

1,887.5 1,883.5 11,016.1
28.7
28.6
358.1
483.0
481.2 4,760.2
380.1
109.3
5,559.3 3,422.7
797.4
69.2
67.0
82.4
4,945.5 2,035.9
397.6
330.3
151.4
9.9

53.7

318.7 1,107.5
17.1
14.0
352.6
317.0
793.6
0.1

101.2
1.0

310.6
0.9

2,114.97 1,334.38 2,880.67 285.10 273.99 13,760.7 8,358.4 17,219.3 1,793.6 1,540.6

Table 1.6–2.

Summary of annual and typical daily emissions from point sources in the PM10 NAA.
Annual (tons/yr)
Typical day (lbs/day)
Source Category
PM10 PM2.5
NOx
SOx NH3
PM10 PM2.5
NOx
SOx
Electricity generation
Comm./inst. fuel combustion
Industrial fuel combustion
Food/agriculture
Industrial processes
Manufacturing processes
Industrial road travel
Waste disposal
Emission reduction credits

All Point Sources

113.97
4.90
40.67
27.83
670.39
9.17
697.98
69.62

113.72 1,154.60 15.24 132.55
4.88
58.20
2.82
2.53
40.53
614.09 46.35 28.75
7.87
420.49
116.20 123.40 12.41
8.95
15.00
0.02
0.16
283.10
59.45
27.55 56.53

1.80

1,636.33

9.80

0.16

637.8
636.3
28.7
28.6
267.3
266.2
172.3
50.7
4,585.5 2,932.0
69.2
67.0
4,729.2 1,955.7
397.6
330.3
9.9

103.0
17.1
325.4

728.3
14.0
171.8

797.4
82.4

793.6
0.1

69.9
1.0

151.4

310.6

53.7

0.9

938.98 1,995.44 244.52 176.40 10,897.6 6,266.8 11,854.9 1,550.7

2005 Periodic PM10 Emission Inventory

4

NH3

6,402.8
358.1
4,009.2

984.9

Maricopa County, AZ

1.6.2

Area sources

Area sources are facilities or activities whose individual emissions do not qualify them as point
sources. Area sources represent numerous facilities or activities that individually release small
amounts of a given pollutant, but collectively they can release significant amounts of a pollutant.
Stationary sources with annual emissions lower than the point source thresholds described in
Section 1.6.1 were included in the area source inventory. Examples of area source categories
include residential wood burning, commercial cooking, waste incineration and wildfires.
Tables 1.6–3 and 1.6–4 summarize annual and season-day emissions of the chief area source
categories, for Maricopa County and the PM10 nonattainment area, respectively. A detailed
breakdown of emissions calculations for each area source category is contained in Chapter 3.
Table 1.6–3.
Category

Summary of annual and typical daily emissions from area sources in Maricopa County.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx

NH3

Summary of annual and typical daily emissions from area sources in the PM10 NAA.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx

NH3

Fuel combustion
Industrial processes
Waste treatment/disposal
Misc. area sources
All area sources:

Table 1.6–4.
Category

Fuel combustion
Industrial processes
Waste treatment/disposal
Misc. area sources
All area sources:

1.6.3

694.01
36,882.71
142.64
136,892.15
174,611.51

677.85 6,801.33 435.23
27.55
5,968.4
5,754.4 43,000.7 2,805.4
176.6
5,713.02
564.11 147.06 1,699.43
237,157.6 36,770.8
5,432.2 1,469.1 10,896.6
108.81
28.35
6.14 1,310.85
1,198.1
945.1
227.4
34.0
7,182.7
67,831.62 15,659.58 4,291.61 17,026.53
856,409.2 449,431.2 105,201.4 28,831.5 97,343.4
74,331.30 23,053.36 4,880.05 20,064.35 1,100,733.4 492,901.5 153,861.8 33,140.0 115,599.4

691.70
675.51
35,266.82 5,555.90
110.74
76.90
21,021.78 6,133.71
57,091.05 12,442.02

6,760.83
563.60
19.70
1,091.78
8,435.92

432.30
27.36
147.05 1,687.89
6.14 1,321.01
297.30 10,784.63
882.80 13,820.89

5,954.3
226,765.3
890.8
129,190.0
362,800.5

5,739.9
35,741.7
637.8
39,905.6
82,025.0

42,706.4
5,428.5
144.4
7,337.7
55,616.9

2,786.5
1,469.1
34.0
1,998.5
6,288.1

175.1
10,822.7
7,238.4
59,370.9
77,607.1

Nonroad mobile sources

Nonroad mobile sources include off-highway vehicles and engines that move or are moved
within a 12-month period. Tables 1.6–5 and 1.6–6 summarize annual and season-day emissions
from nonroad mobile sources, for Maricopa County and the PM10 nonattainment area,
respectively. A detailed breakdown of emissions calculations for each source category is
contained in Chapter 4.
Table 1.6–5.
Category

Annual and typical daily emissions from nonroad mobile sources in Maricopa County.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3

Agricultural
Airport ground support
Commercial
Construction and
mining
Industrial
Lawn and garden
Pleasure craft
Railway maintenance
Recreational equipment
Aircraft
Locomotives
All nonroad
mobile sources:

39.21
16.50
119.34

38.03
15.70
114.47

386.34
467.82
1,449.72

5.95
14.71
17.32

1,354.26
110.02
178.22
11.33
1.20
42.29
173.48
74.45

1,311.26 16,016.62
107.01 3,316.67
165.18
843.10
10.45
70.58
1.16
9.27
38.95
59.99
125.05 3,029.37
65.28 2,955.24

287.07
26.63
9.53
0.71
0.14
0.68
233.60
173.18

31.22
79.21
21.21
1.49
0.02
1.97

2,120.29

1,992.56 28,604.72

769.51

2005 Periodic PM10 Emission Inventory

5

0.73

251.4
90.4
765.0

243.8
86.0
733.8

2,476.5
2,563.4
9,293.1

38.2
80.6
111.0

8,405.5
686.0
1,135.4
140.7
8.1
332.9
685.2
357.7

102,670.7
21,260.7
5,882.8
950.0
64.2
512.7
16,599.3
16,193.1

1,840.2
170.7
64.1
9.5
1.0
5.8
1,280.0
948.9

200.1
507.7
155.5
20.1
0.1
16.8

4.57

8,681.1
705.2
1,226.0
152.5
8.3
361.4
950.6
407.9

163.58

13,599.9

12,815.2

178,466.6

4,550.0

1,078.7

23.18

4.7

148.6

25.0

Maricopa County, AZ

Table 1.6–6.
Category

Annual and typical daily emissions from all nonroad mobile sources in the PM10 NAA.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3

Agricultural
Airport ground support
Commercial
Construction and
mining
Industrial
Lawn and garden
Pleasure craft
Railway maintenance
Recreational equipment
Aircraft
Locomotives
All nonroad
mobile sources:

1.6.4

18.83
16.50
118.48

18.26
15.70
113.65

185.46
467.82
1,439.36

2.86
14.71
17.20

0.35

1,188.9
2,563.4
9,226.7

18.3
80.6
110.2

1,356.40
109.23
178.50
8.60
1.20
8.89
157.68
38.01

1,313.34 16,042.02
106.25 3,292.98
165.44
844.44
7.94
53.59
1.17
9.29
8.19
12.61
114.15 2,929.27
33.70 1,509.67

287.52
26.44
9.54
0.54
0.14
0.14
225.69
85.72

31.27
78.64
21.24
1.13
0.02
0.41

8,418.8 102,833.5
681.1 21,108.8
1,137.2
5,892.2
106.9
721.4
8.1
64.3
70.0
107.8
625.5 16,050.8
184.7
8,272.2

1,843.1
169.5
64.2
7.2
1.0
1.2
1,236.7
469.7

200.4
504.1
155.8
15.2
0.1
3.5

2.26

8,694.9
700.2
1,227.9
115.8
8.3
76.0
864.0
208.2

2,012.32

1,897.78 26,786.52

670.50

158.33

12,866.0

12,163.8 168,029.9

4,001.8

1,041.4

23.01

120.7
90.4
759.5

117.0
86.0
728.5

2.2

147.5

12.4

Onroad mobile sources

Emissions from onroad mobile sources were calculated for the PM10 nonattainment area located
primarily within Maricopa County, as well as for Maricopa County as a whole. A detailed
breakdown of emissions calculations for each area source category is contained in Chapter 5.
Tables 1.6–7 and 1.6–8 summarize annual and typical daily emissions from onroad mobile
sources in Maricopa County and the PM10 nonattainment area, respectively.
Table 1.6–7.
Category

Annual and typical daily emissions from all onroad mobile sources in Maricopa County.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
PM10 PM2.5
NOx
SOx
NH3
PM10 PM2.5
NOx SOx
NH3

Exhaust
Paved road fugitive dust
Unpaved road fugitive dust
Tire wear
Brake wear

1,092.00 1,007.00 66,187.00 1,611.00 3,011.00
320.00
80.00
413.00 175.00
14,619.00 200.00
8,903.00 890.00

All onroad mobile
sources:

25,347.00 2,352.00 66,187.00 1,611.00 3,011.00 138,886.0 12,892.0 362,669.0 8,827.0 16,496.0

Table 1.6–8.
Category

5,982.0
1,755.0
2,264.0
80,104.0
48,781.0

5,516.0 362,669.0 8,827.0 16,496.0
439.0
960.0
1,098.0
4,879.0

Annual and typical daily emissions from all onroad mobile sources in the PM10 NAA.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
PM10 PM2.5
NOx
SOx
NH3
PM10 PM2.5
NOx SOx
NH3

Exhaust
Paved road fugitive dust
Unpaved road fugitive dust
Tire wear
Brake wear

1,041.00
305.00
394.00
13,783.00
8,490.00

All onroad mobile
sources:

24,013.00 2,241.00 63,093.00 1,536.00 2,870.00 131,575.0 12,277.0 345,713.0 8,415.0 15,725.0

960.00 63,093.00 1,536.00 2,870.00
76.00
167.00
189.00
849.00

2005 Periodic PM10 Emission Inventory

6

5,702.0
1,673.0
2,158.0
75,523.0
46,519.0

5,258.0 345,713.0 8,415.0 15,725.0
418.0
915.0
1,034.0
4,652.0

Maricopa County, AZ

1.6.5

Biogenic sources

The biogenic source category includes emissions from all vegetation (e.g., crops, indigenous
vegetation, landscaping, etc.) in Maricopa County and the PM10 nonattainment area. Emissions
were estimated through MEGAN, a computer model developed by the ENVIRON corporation
through a contract with the Maricopa Association of Governments (MAG). Annual and daily
NOx emissions from biogenic sources are shown in Table 1.6–9 for Maricopa County and the
PM10 nonattainment area.
Table 1.6–9.

Annual and season-day NOx emissions from biogenic sources.
Annual emissions
Typical daily emissions
Geographic area
(tons/yr)
(lbs/day)
3,321.00
18,197.0
Maricopa County
1,048.00
5,745.0
PM10 NAA

1.6.6

All sources

Tables 1.6–10 and 1.6–11 provide summary totals of annual and typical daily emissions from all
emission sources in Maricopa County and the PM10 nonattainment area, respectively.

2005 Periodic PM10 Emission Inventory

7

Maricopa County, AZ

Table 1.6–10. Annual and typical daily emissions from all sources in Maricopa County.
Section
Point Sources
Area Sources:
Fuel combustion
Industrial natural gas
Industrial fuel oil
Comm./ind. natural gas
Comm./ind. fuel oil
Residential natural gas
Residential wood
Residential fuel oil
All combustion
Industrial Processes
Chemical manufacturing
Food products
Commercial cooking
Grain handling
Ammonia storage
Secondary metal prod.
Mineral processes
(concrete batch, etc.)
Mining & quarry (sand &
gravel)
Wood products
Rubber/plastics mfg.
Fabricated metal mfg.
Residential const.
Commercial const.
Road construction
Construction – other
Electric equip. mfg.
ADEQ portables
Unpaved road travel
Industrial proc. NEC
All Ind. Processes
Waste Treatment/Disp.
On-site incineration
Open burning
Landfills
POTWs
Other waste
All Waste Treat/Disp.

PM10
2,114.97

Annual emissions (tons/yr)
PM2.5
NOx
SOx
1,334.38
2,880.67
285.10

Typical daily emissions (lbs/day)
PM2.5
NOx
SOx
8,358.4
17,219.3
1,793.6

NH3
273.99

PM10
13,760.7

NH3
1,540.6

6.81
14.18
3.79
2.76

105.9
1,588.6
385.6
487.6
342.9
2,843.6
0.2
5,754.4

1,977.1
22,074.4
7,348.6
7,120.5
4,241.7
229.8
8.7
43,000.7

8.3
2,110.8
30.3
590.1
27.1
35.3
3.4
2,805.4

176.6

3.0

1.6

2.6

25.0

0.4

10,871.7
10.3

16.51
247.82
60.15
76.06
62.59
230.85
0.01
694.01

16.51
247.82
60.15
76.06
62.59
214.69
0.01
677.85

308.43
3,443.60
1,146.39
1,110.79
774.12
17.35
0.66
6,801.33

1.30
329.29
4.72
92.05
4.94
2.67
0.26
435.23

27.55

105.9
1,588.6
385.6
487.6
342.9
3,057.6
0.2
5,968.4

76.77

38.85

0.39

0.21

0.34

590.5

298.9

1,527.98
12.64

1,416.96
2.68

8,395.5
94.7

7,785.5
20.5

10.95

9.27

79.0

66.3

431.60

222.71

3,030.4

1,517.2

62.97
213.23
365.26
138.96
12,135.60
11,491.21
7,307.35
2,806.46
5.24
101.70
170.49
24.31
36,882.71

17.38
149.95
236.52
119.88
1,213.56
1,149.12
730.73
280.65
3.25
42.18
65.45
13.87
5,713.02

0.01
554.60

4.59
142.20

0.96

35.3
1,431.7

7.4

0.01
147.06

0.80
1,699.43

112.1
1,170.0
1,819.4
1,404.1
7,779.2
7,366.2
4,684.2
1,799.0
25.0
389.8
436.2
97.3
36,770.8

0.1
5,377.5

4.58
564.11

409.1
1,657.9
2,809.7
1,579.3
77,792.3
73,661.6
46,842.0
17,990.2
40.3
844.2
1,138.8
202.0
237,157.6

26.7
5,432.2

0.0
1,469.1

4.6
10,896.6

0.15
56.15
6.79

0.10
56.15
4.05

2.54
15.16
6.50

0.03

1.6
550.9
39.5

1.1
550.9
23.5

19.9
148.4
36.3

0.3
6.3

606.0
1,198.1

369.6
945.1

22.8
227.4

27.5
34.0

7,182.7

475,719.7
120.0
123.8
144.7
1.1
30,241.4
3,489.9
13,087.9
0.6

408,001.6
120.0
123.8
144.7
0.9
4,536.2
523.5
1,308.8
0.2

104,963.1
93.0
16.0
5.8
35.4

28,780.2
25.5

22,008.4
7.5

3,535.7
7.4
5.6

388.9
4.9
5.6

4.53

0.05

1,695.98
1.34

1.11
1,310.85

43.7
90.9
24.3
17.7

7,182.7

79.55
142.64

48.51
108.81

4.15
28.35

5.01
6.14

1,310.85

70,882.24
0.06
22.53
26.41
0.15
2,913.73
145.48
2,041.71
0.08

60,792.24
0.06
22.53
26.41
0.12
437.06
21.82
204.17
0.02

15,639.50
0.05
2.92
1.06
4.61

4,288.25
0.01

3,279.25
0.00

645.27
0.96
1.03

70.98
0.64
1.03

841.66

317.65

4,611.8

1,740.6

Misc. Area Sources
Wildfires
Prescribed fires
Structure fires
Vehicle fires
Aircraft engine testing
Tilling
Harvesting
Unpaved agri. roads
Cotton ginning
Fertilizer application
Livestock
Crematories
Accidental releases
Humans
Leaf blowers fugitive
Offroad rec. vehicles
fugitive dust
Travel on unpaved
parking lots
Windblown dust
All Misc. Area Sources

9,994.00

999.00

54,764.0

5,476.0

4,888.00
44,488.84
136,892.15

489.00
4,448.88
67,831.62

15,659.58

4,291.61

17,026.53

26,781.0
243,774.4
856,409.2

2,678.0
24,377.4
449,431.2

105,201.4

28,831.5

97,343.4

All Area Sources:

174,611.51

74,331.30

23,053.36

4,880.05

20,064.35

1,100,733.4

492,901.5

153,861.8

33,140.0

115,599.4

1.89

2,278.14
10,429.53
11.45

1.46

14.5

12,483.0
57,148.1
88.0

11.3

1,039.60

2005 Periodic PM10 Emission Inventory

8

5,696.5

Maricopa County, AZ

Table 1.6–10 (continued). Annual and typical daily emissions from all sources in Maricopa County.
Section
Nonroad Sources:
Agricultural equipment
Airport GSE
Commercial equipment
Construction and mining
equipment
Industrial equipment
Lawn and garden
equipment
Pleasure craft
Railway maintenance
equipment
Recreational equipment
Aircraft
Locomotives
All Nonroad Sources
Onroad Sources:
Exhaust
Tire wear
Brake wear
Paved road fugitive dust
Unpaved road fugitive
dust
All Mobile Sources:

PM10

Annual emissions (tons/yr)
PM2.5
NOx

NH3

PM10

NH3

0.73

243.8
86.0
733.8

2,476.5
2,563.4
9,293.1

38.2
80.6
111.0

148.6

39.21
16.50
119.34

38.03
15.70
114.47

386.34
467.82
1,449.72

5.95
14.71
17.32

23.18

251.4
90.4
765.0

1,354.26
110.02

1,311.26
107.01

16,016.62
3,316.67

287.07
26.63

31.22
79.21

8,681.1
705.2

8,405.5
686.0

102,670.7
21,260.7

1,840.2
170.7

200.1
507.7

178.22
11.33

165.18
10.45

843.10
70.58

9.53
0.71

21.21
1.49

1,226.0
152.5

1,135.4
140.7

5,882.8
950.0

64.1
9.5

155.5
20.1

1.20
42.29
173.48
74.45
2,120.29

1.16
38.95
125.05
65.28
1,992.56

9.27
59.99
3,029.37
2,955.24
28,604.72

0.14
0.68
233.60
173.18
769.51

0.02
1.97

8.1
332.9
685.2
357.7
12,815.2

64.2
512.7
16,599.3
16,193.1
178,466.6

1.0
5.8
1,280.0
948.9
4,550.0

0.1
16.8

4.57
163.58

8.3
361.4
950.6
407.9
13,599.9

25.0
1,078.7

1,092.00
320.00
413.00
14,619.00

1,007.00
80.00
175.00
200.00

66,187.00

1,611.00

3,011.00

5,982.0
1,755.0
2,264.0
80,104.0

5,516.0
439.0
960.0
1,098.0

362,669.0

8,827.0

16,496.0

8,903.00
25,347.00

890.00
2,352.00

66,187.00

1,611.00

3,011.00

48,781.0
138,886.0

4,879.0
12,892.0

362,669.0

8,827.0

16,496.0

48,310.6

134,714.6

Biogenic Sources:
TOTAL, All Sources:

Typical daily emissions (lbs/day)
PM2.5
NOx
SOx

SOx

3,321.00
204,193.77

80,010.24

2005 Periodic PM10 Emission Inventory

124,046.75

4.7

18,197.0
7,545.67

9

23,512.92

1,266,980.1

526,967.1

730,413.7

Maricopa County, AZ

Table 1.6–11. Annual and typical daily emissions from all sources in the PM10 nonattainment area.
Section
Point Sources
Area Sources:
Fuel combustion
Industrial natural gas
Industrial fuel oil
Comm./ind. natural gas
Comm./ind. fuel oil
Residential natural gas
Residential wood
Residential fuel oil
All combustion
Industrial Processes
Chemical manufacturing
Food products
Commercial cooking
Grain handling
Ammonia storage
Secondary metal prod.
Mineral processes
(concrete batch, etc.)
Mining & quarry (sand &
gravel)
Wood products
Rubber/plastics mfg.
Fabricated metal mfg.
Residential const.
Commercial const.
Road construction
Construction – other
Electric equip. mfg.
ADEQ portables
Unpaved road travel
Industrial proc. NEC
All Ind. Processes
Waste Treatment/Disp.
On-site incineration
Open burning
Landfills
POTWs
Other waste
All Waste Treat/Disp.

PM10
1,636.33

Annual emissions (tons/yr)
PM2.5
NOx
SOx
938.98
1,995.44
244.52

Typical daily emissions (lbs/day)
PM2.5
NOx
SOx
6,266.8
11,854.9
1,550.7

NH3
176.40

PM10
10,897.6

NH3
984.9

6.77
14.08
3.77
2.74

104.7
1,577.8
381.5
484.1
343.5
2,848.2
0.2
5,739.9

1,955.5
21,924.3
7,270.0
7,069.2
4,248.5
230.1
8.7
42,706.4

8.2
2,096.5
30.0
585.8
27.1
35.4
3.4
2,786.5

175.1

3.0

1.6

2.6

25.0

0.4

10,797.8
10.3

16.40
246.14
59.72
75.51
62.69
231.22
0.01
691.70

16.40
246.14
59.72
75.51
62.69
215.04
0.01
675.51

306.33
3,420.18
1,138.13
1,102.80
775.35
17.38
0.66
6,760.83

1.29
327.05
4.69
91.39
4.95
2.67
0.26
432.30

27.36

104.7
1,577.8
381.5
484.1
343.5
3,062.5
0.2
5,954.3

76.25

38.59

0.38

0.21

0.34

586.5

296.8

1,539.90
12.64

1,428.01
2.68

8,461.0
94.7

7,846.2
20.5

10.95

9.27

79.0

66.3

430.89

222.17

3,024.9

1,513.0

54.77
211.78
362.77
138.01
11,331.99
11,085.55
7,236.42
2,475.89
5.24
101.70
167.78
24.29
35,266.82

15.52
148.93
234.91
119.06
1,133.20
1,108.55
723.64
247.59
3.25
42.18
64.48
13.86
5,555.90

0.01
554.60

4.59
142.20

0.96

35.3
1,431.7

7.4

0.01
147.05

0.80
1,687.89

98.2
1,162.0
1,807.0
1,394.5
7,264.1
7,106.1
4,638.7
1,587.1
25.0
389.8
429.0
97.2
35,741.7

0.1
5,377.5

4.08
563.60

347.6
1,646.6
2,790.6
1,568.6
72,641.0
71,061.2
46,387.3
15,871.1
40.3
844.2
1,118.8
201.9
226,765.3

22.9
5,428.5

0.0
1,469.1

4.6
10,822.7

0.15
24.24
6.79

0.10
24.24
4.05

2.54
6.51
6.50

0.03

1.6
243.6
39.5

1.1
243.6
23.5

19.9
65.3
36.3

0.3
6.3

606.0
890.8

369.6
637.8

22.8
144.4

27.5
34.0

7,238.4

32,617.6
0.0
124.0
145.0
1.1
12,797.0
1,420.8
5,837.4
0.7

27,974.5
0.0
124.0
145.0
0.9
1,919.6
213.1
583.7
0.2

7,196.8
0.0
16.1
5.8
35.4

1,973.3
0.0

1,509.0
0.0

2,853.9
7.0
5.6

313.9
4.7
5.6

4.53

0.05

1,684.45
1.34

1.11
1,321.01

43.2
90.3
24.1
17.6

7,238.4

79.55
110.74

48.51
76.90

4.15
19.70

5.01
6.14

1,321.01

4,860.02
0.00
22.56
26.45
0.15
1,228.67
58.99
910.64
0.09

4,168.20
0.00
22.56
26.45
0.12
184.30
8.85
91.06
0.02

1,072.32
0.00
2.92
1.06
4.61

294.02
0.00

224.84
0.00

520.84
0.91
1.03

57.29
0.61
1.03

843.00

318.16

4,619.2

1,743.3

Misc. Area Sources
Wildfires
Prescribed fires
Structure fires
Vehicle fires
Aircraft engine testing
Tilling
Harvesting
Unpaved agri. roads
Cotton ginning
Fertilizer application
Livestock
Crematories
Accidental releases
Humans
Leaf blowers fugitive
Offroad rec. vehicles
fugitive dust
Travel on unpaved
parking lots
Windblown dust
All Misc. Area Sources

2,159.00

216.00

11,830.0

1,184.0

3,009.00
7,380.43
21,021.78

301.00
738.04
6,133.71

1,091.78

297.30

10,784.63

16,490.0
40,440.7
129,190.0

1,649.0
4,044.1
39,905.6

7,337.7

1,998.5

59,370.9

All Area Sources:

57,091.05

12,442.02

8,435.92

882.80

13,820.89

362,800.5

82,025.0

55,616.9

6,288.1

77,607.1

1.89

1,093.74
8,418.39
10.87

1.39

14.5

5,993.1
46,128.1
83.6

10.7

1,047.67

2005 Periodic PM10 Emission Inventory

10

5,740.6

Maricopa County, AZ

Table 1.6–11 (continued). Annual and typical daily emissions from all sources in the PM10 nonattainment
area.
Section
Nonroad Sources:
Agricultural equipment
Airport GSE
Commercial equipment
Construction and mining
equipment
Industrial equipment
Lawn and garden
equipment
Pleasure craft
Railway maintenance
equipment
Recreational equipment
Aircraft
Locomotives
All Nonroad Sources:
Onroad Sources:
Exhaust
Tire wear
Brake wear
Paved road fugitive dust
Unpaved road fugitive
dust
All Mobile Sources:

PM10

Annual emissions (tons/yr)
PM2.5
NOx

1.7

NH3

PM10

NH3

0.35

117.0
86.0
728.5

1,188.9
2,563.4
9,226.7

18.3
80.6
110.2

147.5

18.83
16.50
118.48

18.26
15.70
113.65

185.46
467.82
1,439.36

2.86
14.71
17.20

23.01

120.7
90.4
759.5

1,356.40
109.23

1,313.34
106.25

16,042.02
3,292.98

287.52
26.44

31.27
78.64

8,694.9
700.2

8,418.8
681.1

102,833.5
21,108.8

1,843.1
169.5

200.4
504.1

178.50
8.60

165.44
7.94

844.44
53.59

9.54
0.54

21.24
1.13

1,227.9
115.8

1,137.2
106.9

5,892.2
721.4

64.2
7.2

155.8
15.2

1.20
8.89
157.68
38.01
2,012.32

1.17
8.19
114.15
33.70
1,897.78

9.29
12.61
2,929.27
1,509.67
26,786.52

0.14
0.14
225.69
85.72
670.50

0.02
0.41

8.1
70.0
625.5
184.7
12,163.8

64.3
107.8
16,050.8
8,272.2
168,029.9

1.0
1.2
1,236.7
469.7
4,001.8

0.1
3.5

2.26
158.33

8.3
76.0
864.0
208.2
12,866.0

12.4
1,041.4

1,041.00
305.00
394.00
13,783.00

960.00
76.00
167.00
189.00

63,093.00

1,536.00

2,870.00

5,702.0
1,673.0
2,158.0
75,523.0

5,258.0
418.0
915.0
1,034.0

345,713.0

8,415.0

15,725.0

8,490.00
24,013.00

849.00
2,241.00

63,093.00

1,536.00

2,870.00

46,519.0
131,575.0

4,652.0
12,277.0

345,713.0

8,415.0

15,725.0

20,255.6

95,358.4

Biogenic Sources:
TOTAL, All Sources:

Typical daily emissions (lbs/day)
PM2.5
NOx
SOx

SOx

1,048.00
84,752.70

17,519.78

101,358.87

5,745.0
3,333.82

17,025.62

518,139.1

112,732.6

586,959.7

Response to public review of draft inventory

MCAQD released a draft 2005 PM10 emissions inventory for public review and comment on
January 23, 2007. The public review period for the draft inventory ended on March 1, 2007.
MCAQD evaluated the comments received on the draft PM10 emissions inventory and prepared
written responses to these comments. A full listing of each comment with MCAQD’s and other
responsible agencies’ responses are available in Appendix 1. As a result of these comments, and
along with further QA/QC work by MCAQD and partner agencies, the emission estimates in this
report have been revised.

2005 Periodic PM10 Emission Inventory

2.2

11

Maricopa County, AZ

This page intentionally blank.

2005 Periodic PM10 Emission Inventory

12

Maricopa County, AZ

2.

Point Sources

2.1

Introduction and scope

This inventory of PM10 and related pollutants is one of a number of emission inventories being
prepared to meet US EPA reporting requirements.
In addition to preparing periodic emissions inventories for the PM10 nonattainment area (NAA)
as a commitment under the current PM10 State Implementation Plan (SIP), the federal
Consolidated Emission Reporting Rule (CERR) requires that state and local agencies prepare
emissions estimates on a county basis, and submit data electronically to the US EPA for
inclusion in the National Emission Inventory (NEI) for 2005. This inventory is being developed
concurrently with similar inventories for CO and ozone precursors (VOC, NOx, and CO), as part
of Maricopa County's requirements under the respective SIPs.
In order to provide consistency among all these inventories, it was decided to standardize the
definition of a “point source”. While EPA has defined minimum point source reporting
thresholds for various pollutants, EPA guidance also notes that:
… we encourage organizations to provide facility-specific
emissions data for all point sources, regardless of size, where they
are already included in the S/L/T [state/local/tribal] emission
inventory. (US EPA, 2003)
Since Maricopa County has an established annual reporting program for sources with air quality
permits, the thresholds for defining a point source are lower than the minimums required by
EPA. For the purposes of this inventory, a point source is a stationary operation within Maricopa
County which in 2005 emitted:
• 25 English (short) tons or more of carbon monoxide (CO); or
• 10 tons or more of volatile organic compounds (VOC), oxides of nitrogen (NOx), or
sulfur oxides (SOx); or
• 5 tons or more of particulate matter less than 10 microns (PM10) or ammonia compounds
(NHx).
For the Pinal County portion of the PM10 non-attainment area, the standard point source
definition (70 TPY of PM10) was applied. No additional point sources met this reporting
threshold.
Additionally, EPA guidance requires emission inventories prepared for SIP development
purposes to consider point sources with 25 miles of the non-attainment area boundary. For these
sources, the traditional “major source” threshold definitions for attainment areas were applied.
No additional point sources met this reporting threshold.
While the above approach results in some anomalies (e.g., a facility treated as a point source may
have very low, or no, emissions of a certain pollutant), a uniform definition of “point source”
ensures that all data sets, which are prepared for a variety of purposes, will be comparable.
PM10 is defined as particulate matter less than ten micrometers in diameter. This inventory
includes primary emissions of PM10 and PM2.5 as well as three particulate matter precursors:
2005 Periodic PM10 Emission Inventory

13

Maricopa County, AZ

nitrogen oxides (NOx), sulfur dioxides (SOx) and ammonia (NH3). This point source inventory
includes annual and typical daily emissions of PM10, PM2.5, NOx, SOx, and NH3 for 2005. A
description and map of the PM10 nonattainment area are provided in Chapter 1. Questions
concerning point source emissions may be directed to Bob Downing of MCAQD at (602) 5066790.
Several tables have been constructed to provide the point source emissions and category totals.
Table 2.2–1 provides an alphabetical list of all point sources and their location. Table 2.4–1
shows the 2005 annual and typical day emissions of PM10, PM2.5, NOx, SOx and NH3 for those
point sources which reported emissions of any of these pollutants broken out by facility. Tables
2.6–1 summarize point source emissions by source category for the county and PM
nonattainment area, respectively. Note that totals shown in the tables may not equal the sum of
individual values due to independent rounding.

2.2

Identification of point sources

The Maricopa County Air Quality Department (MCAQD) identified point sources within
Maricopa County through its electronic permit system database, EMS, and the 2005 annual
emissions reports submitted to the department. In addition, the permit system was reviewed to
locate new installations that were not included in the previous emission inventory, and to identify
sources that have ceased operations since the 2002 periodic inventory was compiled.
A total of 173 stationary point sources were identified using the emission thresholds described in
Section 2.1. Of these 173 facilities, 151 sources (listed in Table 2.2–1) reported emissions of
PM10, NOx, SOx, and/or ammonia – 140 within the PM10 nonattainment area, and 11 outside the
PM10 NAA. There are no additional point sources within the 25-mile boundary around the PM10
nonattainment area with permits issued the Pinal County Air Quality Control District
(PCAQCD). While the Arizona Department of Environmental Quality (ADEQ) retains
permitting authority for a limited number of industrial source categories in Maricopa County, no
ADEQ-permitted facilities are considered point sources, and are addressed instead as area
sources.
Table 2.2–1 contains an alphabetical list of all point sources, including a unique business
identification number, NAICS industry classification code, business name, and physical address.

2005 Periodic PM10 Emission Inventory

14

Maricopa County, AZ

Table 2.2–1.
ID #
1074
1075
1387
1952
245
35541
1834
31637
3313
3938
36772
4364
334
74058
43124
458
217
56105
1218
3442
60598
1318
1317
1316
4401
1267
1268
1266
1310
3976
61573
35819
38731
113723
399
1198
4368
1389
130
48771
3305
26
1505
1488
27728
881
1109
44439
73110
508
1418
699

Name and location of all point sources.

NAICS
221320
221320
332312
423110
337122
33121
518210
115111
221112
332812
212321
61131
311211
321918
313230
32191
327123
33711
562212
493190
337211
321991
321991
321991
32732
32732
212321
212321
32311
33711
212322
562212
321991
212321
32739
32311
32191
541380
331512
32739
311812
423810
32191
115111
334413
334413
334413
221112
424910
337122
326299
212321

Business name
23rd Ave Wastewater Treatment Plant
91st Ave Wastewater Treatment Plant
Able Steel Fabricators
Adesa Phoenix LLC
AF Lorts Manufacturing Company
Allied Tube and Conduit
American Express IPC Facility
Anderson Clayton Corp-Valencia Gin
APS West Phx Power Plant
Arizona Galvanizing Inc
Arizona Materials
Arizona State University
Bay State Milling Co
Biltmore Shutters Inc
Bonded Logic Inc
Bryant Industries Inc
Building Products Co
Burdette Cabinet Co Inc
Butterfield Station Facility
Caljet
Case Furniture & Design LLC
Cavco Industries Inc (Litchfield)
Cavco Industries Inc (S. 35th Ave.)
Cavco Industries LLC/Durango Plant
Cemex Construction Materials
Cemex Mesa Plants No #61 & #71
Cemex Usa (107th Ave.)
Cemex Usa (W. Indian School Rd.)
Century Graphics LLC
Cholla Custom Cabinets Inc
Circle H Sand & Rock
City of Chandler Landfill
Clayton Homes-El Mirage
Contractors Landfill & Recycling
Coreslab Structures (Ariz) Inc
Courier Graphics Corp
Craftsmen In Wood Mfg
DaimlerChrysler Arizona Proving Grounds
Dolphin Inc
Eagle Roofing Products
Earthgrains Baking Companies Inc
Empire Machinery Co
Executive Door
Farmer's Gin Inc
Flipchip International LLC
Freescale Semiconductor Inc (Alma School)
Freescale Semiconductor Inc (Elliott Rd.)
Gila River Power Station
Glenn Weinberger Topsoil Inc
Golden Eagle Manufacturing
Goodrich Aircraft Interior Products
Hanson Aggregates of Arizona (S. 51st Ave.)

Address
2470 S 22nd Ave
5615 S 91st Ave
4150 E Quartz Cir
400 N Beck Ave
8120 W Harrison St
2525 N 27th Ave
3151 W Behrend Dr
25500 W Southern Ave
4606 W Hadley St
15775 Elwood St
3636 S 43rd Ave
1551 S Rural Rd
421 S 99th Ave
1138 W Watkins St
411 E Ray Rd
788 W Illini St
4850 W Buckeye Rd
3941 N Higley Rd
40404 S 99th Ave
125 N 53rd Ave
4645 W Polk St
1366 S Litchfield Rd
2602 S 35th Ave
2502 W Durango St
6500 N 115th Ave
1901 N Alma School Rd
24004 N 107th Ave
11701 W Indian School
2960 Grand Ave
1727 E Deer Valley Dr
6400 S El Mirage Rd
3850 S McQueen Rd
12345 W Butler Dr
2425 N Center St
5026 S 43rd Ave
2621 S 37th St
5441 W Hadley St
33040 N 203rd Ave
740 S 59th Ave
4602 W Elwood St
738 W Van Buren St
1725 S Country Club Dr
3939 W Clarendon Ave
8400 S Turner Rd
3701 E University Dr
1300 N Alma School Rd
2100 E Elliot Rd
1250 E Watermelon Rd
39500 S 99th Ave
601 S 65th Ave
3414 S 5th St
4002 S 51st Ave

City
Phoenix
Tolleson
Mesa
Chandler
Tolleson
Phoenix
Phoenix
Buckeye
Phoenix
Goodyear
Phoenix
Tempe
Tolleson
Phoenix
Chandler
Phoenix
Phoenix
Mesa
Mobile
Phoenix
Phoenix
Goodyear
Phoenix
Phoenix
Glendale
Mesa
Sun City
Phoenix
Phoenix
Phoenix
Tolleson
Chandler
El Mirage
Mesa
Phoenix
Phoenix
Phoenix
Wittmann
Phoenix
Phoenix
Phoenix
Mesa
Phoenix
Buckeye
Phoenix
Chandler
Tempe
Gila Bend
Maricopa Co.
Phoenix
Phoenix
Phoenix

* = Facility is outside the PM10 nonattainment area.

2005 Periodic PM10 Emission Inventory

15

Maricopa County, AZ

ZIP
85009
85353
85215
85226
85353
85009
85027
85326
85043
85338
85009
85287
85353
85007
85225
85041
85043
85215
85239
85043
85043
85338
85009
85009
85323
85201
85373
85063
85017
85024
85353
85249
85335
85201
85041
85034
85043
85361
85043
85043
85007
85210
85019
85326 *
85034
85224
85284
85337 *
85239
85043
85040
85043

Table 2.2–1. Name and location of all point sources (continued).
ID #
4498
31565
529
3536
1059
247
355
403
777
3966
725
341
96886
43063
3300
744
1248
31261
44092
40470
353
289
62
3326
1415
1414
44186
1875
226
34197
910
73084
43530
1879
1331
3953
27925
52382
528
98
428
733
1341
1014
562
1154
92072
148
60889
1030
44182
50299

NAICS
212321
32614
32614
311812
336412
336413
336412
331316
32614
334413
212321
325991
337122
221112
92811
331513
325991
21231
32732
32732
326199
115111
33711
325991
212321
212321
221112
334413
32739
327420
334412
337122
221112
562212
337122
33711
337122
221112
322211
221113
115111
811412
33992
327121
51111
33992
212313
331528
811198
32311
332312
713910

Business name
Hanson Aggregates of Arizona (W. Indian School)
Henry Products Inc
Highland Products Inc
Holsum Bakery Inc
Honeywell Engines Sys & Service Phx R&O
Honeywell Engines Systems Accessories
Honeywell-Engines Systems & Services
Hydro Aluminum North America Inc
Insulfoam
Intel Corp-Ocotillo Campus (Fab 12 & 22)
Kilauea Crushers Inc
L & M Laminates & Marble
Legends Furniture
LSP Arlington Valley LLC
Luke AFB - 56Th Fighter Wing
M E Global Inc
Maax Spas Arizona
Madison Granite Supplies
Maricopa Ready Mix (Litchfield)
Maricopa Ready Mix (Sun City)
Marlam Industries Inc
Martori Farms
Mastercraft Cabinets Inc
Mesa Fully Formed Inc
Mesa Materials Inc (Broadway)
Mesa Materials Inc (Higley)
Mesquite Generating Station
Microchip Technology Inc
Monier Lifetile LLC
National Gypsum Co
Neltec Inc
New Directions Incorporated
New Harquahala Generating Co
Northwest Regional Landfill
Oak Canyon Manufacturing Inc
Oakcraft Inc
Oasis Bedroom Co
Ocotillo Power Plant
Packaging Corporation of America Inc
Palo Verde Nuclear Generating Station
Paloma Gin Properties LLC
Pan-Glo Services
Penn Racquet Sports Inc
Phoenix Brick Yard
Phoenix Newspapers Inc
Ping Inc
Pioneer Landscaping Materials
Presto Casting Co
Purcells Western States Tire
Quebecor World-Phoenix Division
Quincy Joist Company
Quintero Area Water System

Address
33500 W Indian School
302 S 23rd Ave
43 N 48th Ave
2322 W Lincoln St
1944 E Sky Harbor Cir
1300 W Warner Rd
111 S 34th St
249 S 51st Ave
3401 W Cocopah St
4500 S Dobson Rd
Hwy 74
813 E University Dr
10300 W Buckeye Rd
39027 W Elliot Rd
14002 W Marauder St
5857 S Kyrene Rd
25605 S Arizona Ave
30600 N 23rd Ave
4405 S Litchfield Rd
10800 W Rose Garden
834 E Hammond Ln
51040 W Valley Rd
305 S Brooks
1111 S Sirrine St
7845 W Broadway Rd
3410 N Higley Rd
37625 W Elliot Rd
1200 S 52nd St
1832 S 51st Ave
1414 E Hadley St
1420 W 12th Pl
402 S 63rd Ave
2530 N 491st Ave
19401 W Deer Valley
3021 N 29th Dr
7733 W Olive Ave
2022 N 22nd Ave
1500 E University Dr
441 S 53rd Ave
5801 S Wintersburg Rd
I-8
2401 W Sherman St
306 S 45th Ave
1814 S 7th Ave
22600 N 19th Ave
2201 W Desert Cove Ave
23044 N 7th St
5440 W Missouri Ave
420 S 35th Ave
1850 E Watkins St
22253 W Southern Ave
16752 W St Rt 74

City
Phoenix
Phoenix
Phoenix
Phoenix
Phoenix
Tempe
Phoenix
Phoenix
Phoenix
Chandler
Wickenburg
Phoenix
Tolleson
Arlington
Glendale
Tempe
Chandler
Phoenix
Phoenix
Sun City
Phoenix
Aguila
Mesa
Mesa
Phoenix
Mesa
Arlington
Tempe
Phoenix
Phoenix
Tempe
Phoenix
Tonopah
Surprise
Phoenix
Peoria
Phoenix
Tempe
Phoenix
Tonopah
Gila Bend
Phoenix
Phoenix
Phoenix
Phoenix
Phoenix
Phoenix
Glendale
Phoenix
Phoenix
Buckeye
Peoria

* = Facility is outside the PM10 nonattainment area.
2005 Periodic PM10 Emission Inventory

16

Maricopa County, AZ

ZIP
85340
85009
85043
85009
85034
85284
85034
85043
85009
85248
85358
85034
85353
85322
85309
85283
85248
85027
85338
85373
85034
85320
85202
85210
85043
85205
85322
85281
85043
85034
85281
85009
85354
85374
85017
85345
85009
85281
85043
85354
85337
85009
85043
85007
85027
85029
85024
85301
85009
85034
85326
85382

*

*
*

*

*

*

*
*

Table 2.2–1. Name and location of all point sources (continued).
ID #
537
42956
303
63
260
64781
213
4318
759
1437
3315
266
246
4175
50422
27933
331
46277
3316
3317
4131
1444
582
4400
378
281
101
31643
249
552
363
56
1211
1210
37546
42915
234
53
2
90
344
174
36676
141
398
20706
1382

NAICS
327999
221112
332431
212321
212321
212313
212321
32732
32613
334412
221112
332312
321991
424710
336413
562212
321999
321999
221112
221112
334413
327123
337122
334413
212321
212321
31161
562212
336411
337122
337122
32739
337122
337122
32739
322299
311514
32739
32412
32732
212321
325998
311119
424910
212321
32614
33711

Business name
Red Mountain Mining Inc
Redhawk Generating Facility
Rexam Beverage Can Company
Rinker Materials (El Mirage)
Rinker Materials (S. 19th Ave.)
Rinker Materials (S. 59th Ave.)
Rinker Materials (W. Glendale)
River Ranch Plant #40
Rogers Corp/Advanced Circuit Materials
Sanmina Phoenix Division
Santan Generating Station
Schuff Steel Co
Schult Homes
SFPP LP Phoenix Terminal
Simula Safety Systems Inc
Skunk Creek Landfill
Smurfit Stone Container Corp
Southwest Forest Products Inc
SRP Agua Fria Generating Station
SRP Kyrene Generating Station
ST Microelectronics
Staco Architectural Roof Tile
Stone Creek Inc
Sumco Southwest Corporation
Sun Land Materials
Sun State Rock & Materials
Sunland Beef Company
SW Reg Municipal Solid Waste Landfill
The Boeing Company
Thornwood Furniture Mfg
Thunderbird Furniture
TPAC A Division of Kiewit Western Co
Trendwood Inc (E. University)
Trendwood Inc (S. 15th Ave.)
Trenwyth Industries
U S Greenfiber-Phoenix
United Dairymen of Arizona
Utility Vault Co
Vulcan Materials Co (115th Ave.)
Vulcan Materials Co (43rd Ave.)
Vulcan Materials Co (W. Indian School Rd.)
W R Meadows of Az Inc
Western Milling
Western Organics Inc
Wickenburg Facility
Wincup Holdings Inc
Woodcase Fine Cabinetry Inc

Address
4520 N Power Rd
11600 S 363rd Ave
211 N 51st Ave
8635 N El Mirage Rd
3640 S 19th Ave
5605 S 59th Ave
11920 W Glendale Ave
5159 N El Mirage Rd
100 S Roosevelt Ave
5020 S 36th St
1005 S Val Vista Rd
420 S 19th Ave
231 N Apache Rd
49 N 53rd Ave
7822 S 46th St
3165 W Happy Valley
6900 W Northern Ave
2828 S 35th Ave
7302 W Northern Ave
7005 S Kyrene Rd
1000 E Bell Rd
3530 E Elwood St
4221 E Raymond St
19801 N Tatum Blvd
6950 W Southern Ave
11500 W Beardsley Rd
651 S 91st Ave
24427 S Hwy 85
5000 E McDowell Rd
5125 E Madison St
7501 E Redfield Rd
3052 S 19th Ave
261 E University Dr
2402 S 15th Ave
4626 N 42nd Ave
601 S 55th Ave
2008 S Hardy Dr
411 E Frye Rd
14521 N 115th Ave
4830 S 43rd Ave
11923 W Indian School
4220 S Sarival Ave
310 S 24th Ave
2807 S 27th Ave
44605 Grand Ave
7980 W Buckeye Rd
3255 W Osborn Rd

City
Mesa
Arlington
Phoenix
El Mirage
Phoenix
Laveen
Glendale
Litchfield Pk
Chandler
Phoenix
Gilbert
Phoenix
Buckeye
Phoenix
Phoenix
Phoenix
Glendale
Phoenix
Glendale
Tempe
Phoenix
Phoenix
Phoenix
Phoenix
Laveen
Sun City
Tolleson
Buckeye
Mesa
Phoenix
Scottsdale
Phoenix
Phoenix
Phoenix
Phoenix
Phoenix
Tempe
Chandler
El Mirage
Phoenix
Avondale
Goodyear
Phoenix
Phoenix
Wickenburg
Phoenix
Phoenix

* = Facility is outside the PM10 nonattainment area.

2005 Periodic PM10 Emission Inventory

17

Maricopa County, AZ

ZIP
85215
85322 *
85043
85335
85009
85339
85307
85340
85226
85040
85296
85009
85326
85043
85044
85027
85303
85009
85303
85283
85022
85040
85040
85050
85339
85373
85353
85326
85215
85034
85260
85009
85004
85007
85019
85043
85282
85225
85335
85041
85039
85338
85009
85009
85390
85043
85017

2.3

Procedures for estimating emissions from point sources

Annual and typical daily emission estimates were determined from annual source emission
reports, MCAQD investigation reports, permit files and logs, or telephone contacts with sources.
For most of the sources, material balance methods were used for determining emissions.
Emissions were estimated using the emission factors from AP–42, source tests, engineering
calculations, or manufacturers' specifications.
MCAQD distributes annual emissions survey forms to nearly all facilities for which MCAQD
has issued an operating permit. Facilities are required to report detailed information on stacks,
control devices, operating schedules, and process-level information concerning their annual
activities. (See Appendix 2.1 for a copy of the instructions to complete the emissions inventory.)
These instructions include examples and explanations on how to complete the annual emissions
reporting forms that facilities must submit to MCAQD.
After a facility has submitted an annual emissions report to MCAQD, emissions inventory staff
checks all reports for missing and questionable data, and check the accuracy and reasonableness
of all emissions calculations with AP–42, the Factor Information and REtrieval (FIRE) software,
and other EPA documentation. Control efficiencies are determined by source tests when
available, or by AP–42 factors, engineering calculations, or manufacturers' specifications.
MCAQD has conducted annual emissions surveys for permitted facilities since 1988, and the
department's database system, EMS, contains numerous automated quality assurance/quality
control checks for data input and processing.
2.3.1

Calculation of PM2.5 emissions

For all county-permitted sources that submitted an annual emission inventory report, all processlevel emissions for PM10, NOx, SOx, and NH3 were calculated for each facility. Actual emissions
for these pollutants were calculated using reported emission factors (from AP–42 or source test
results) and reflecting any control devices installed. PM2.5 was calculated using a variety of
methods, depending on the Source Classification Code (SCC) of the process reported:
1. For those SCC’s and control device combinations included in EPA’s “PM2.5 Calculator”,
this software program was used to calculate PM2.5, using EPA-recommended emission
factors and typical control efficiencies.
2. For processes with no PM10 controls, emission factors for PM2.5 published by the
California Air Resources Board (CARB, 2004) were used where available.
3. For all other processes (where neither of the above resources provided guidance), PM2.5
was assumed equal to PM10 as a conservative estimate.

2005 Periodic PM10 Emission Inventory

18

Maricopa County, AZ

2.3.2

Application of rule effectiveness

Rule effectiveness reflects the actual ability of a regulatory program to achieve the emission
reductions required by regulation. The concept of applying rule effectiveness in a SIP emission
inventory has evolved from the observation that regulatory programs may be less than 100
percent effective for some source categories. Rule effectiveness (RE) is applied to those sources
affected by a regulation and for which emissions are determined by means of emission factors
and control efficiency estimates.
In prior years, EPA guidance (US EPA, 2003b) recommended using a default RE value of 80%.
More recently, a workgroup consisting of emissions inventory staff from state, local and EPA
offices convened to review existing rule effectiveness (RE) guidance, and develop consensus
recommendation for improvements to this guidance. This work resulted in the development of
questionnaires for point and area sources, which identify control program factors most likely to
affect RE.
MCAQD applied this revised approach (US EPA, 2005, Appendix B) to controlled processes
reported by facilities on their annual emission reports. The quantification of RE was performed
for three groups of industrial processes:
• For manually controlled processes that are regulated by Maricopa County Rule 316
(Nonmetallic Mineral Processing), EPA’s non-point source guidance was applied to
determine the rule effectiveness of County Rule 316. Results showed an overall rule
effectiveness of 54.36%; see Appendix 2.2 for details.
• For most other processes that claimed emissions reductions through the use of a control
device, EPA’s point source guidance was applied to determine the effectiveness of the
reported capture and control efficiencies. Calculations were performed separately for
Title V and non-Title V sources. Application of the 2005 EPA guidance resulted in
overall RE values of 90.55% (for Title V processes) and 87.95% (for non-Title V). A
sample questionnaire and documentation of calculations for these processes is included in
Appendix 2.3.
Section 2.3.4 contains a detailed description of the application of RE for a specific process. The
following sections illustrate how emission estimates were obtained for the Maricopa Countypermitted sources listed in Table 2.2–1.

2005 Periodic PM10 Emission Inventory

19

Maricopa County, AZ

2.3.3

Example 1: 91st Ave. Wastewater Treatment Plant

One of the processes at this municipal wastewater treatment plant is a flare that burns off
captured methane (digester gas). The firm provided the following information used to calculate
emissions from the flare:
Calculation of annual PM10 emissions from flare:
Annual PM10 emissions (lbs) = Volume of material processed annually × AP–42 emission factor
= 234.02 MMCF/yr × 24.43 lb PM10 / million cu. ft (MMCF)
= 5,717 lbs PM10/yr

Calculation of annual PM2.5 emissions:
CARB (2004) provides an uncontrolled PM2.5: PM10 ratio of 0.6842 for SCC 50100410, Landfill
Dump: Waste Gas Destruction: Waste Gas Flare. This ratio was used to derive annual PM2.5
emissions from the flare:
Annual PM2.5 emissions (lbs) = Annual PM10 emissions × PM2.5: PM10 ratio
= 5,717 lbs PM10/yr × 0.6842
= 3,912 lbs PM2.5/yr

Calculation of typical daily emissions:
The 91st Ave. Wastewater Treatment Plant provided seasonal operating data for each process.
Typical daily emissions are calculated based on the daily and annual operating schedule, as
follows:
Typical daily emissions
(lbs/day)

= Annual emissions ÷ (days/week × weeks/year)
= 5,717 lbs PM10/yr ÷ (7 days/wk × 52 wks/yr)
= 15.7 lbs PM10/day

2005 Periodic PM10 Emission Inventory

20

Maricopa County, AZ

2.3.4

Example 2: River Ranch Plant #40

The example below demonstrates the steps involved in calculating emissions and the application
of rule effectiveness. The example below shows how PM10 emissions were calculated for a
single process, aggregate delivery to ground storage for River Ranch Plant, a concrete batching
facility:
Uncontrolled emissions (lbs/yr) = Annual throughput × emission factor
= 256,110 tons × 0.0033 lbs PM10/ton
= 845.2 lb PM10/yr

Uncontrolled emissions from many processes can be reduced in a number of ways, including
installation of a control device to capture and control pollutants. This process uses watering
(typically assumed to control 70%) to control PM10 emissions. Thus total controlled emissions
are calculated as follows:
Controlled emissions (lbs/yr) =
=
=
=

Uncontrolled emissions × [1 – (% capture efficiency × % control effectiveness) ]
845.2 lbs × [1 – (100% capture × 70% control )]
845.2 lbs × 0.30
253.5 lb PM10/yr

This total was reported on the facility's annual emissions inventory as actual PM10 emissions
from this process. In developing the SIP inventory, rule effectiveness (RE) is applied to the
reported control device efficiency, following EPA guidelines. As described in Section 2.3.2, a
value of 54.36% RE was applied to this process. Thus the total annual emissions including RE
was calculated as:
Annual emissions
reflecting RE

= Uncontrolled emissions × [1 – (capture efficiency × control efficiency × RE)]
= 845.2 lbs PM10 /yr × [ 1 – (100% × 70% × 54.36%)]
= 845.2 lbs × 0.6195
= 523.6 lbs PM10/yr

Calculation of typical daily emissions:
Typical daily emissions were derived from annual emissions, using operating schedule data as
follows:
Typical daily emissions
(lbs/day)

= Annual emissions (reflecting RE) ÷ (days/week × weeks/year)
= 523.6 lbs/yr ÷ (5 days/wk × 52 wks/yr)
= 2.0 lbs PM10/day

2005 Periodic PM10 Emission Inventory

21

Maricopa County, AZ

2.4

Detailed overview of point source emissions

2.4.1

Point source emissions by geographic location

Table 2.4–1 provides a summary of annual and typical daily emissions from all point sources,
within and outside the PM10 nonattainment area. Sources for which rule effectiveness has been
applied (for PM10 emissions) are noted. Values of “0.00” and “0.0” for annual and daily
emissions denote a value below the level of significance (0.005 tons/yr and 0.05 lbs/day,
respectively).

2005 Periodic PM10 Emission Inventory

22

Maricopa County, AZ

Table 2.4–1.

Annual and typical daily point source emissions, by facility.

Facilities inside the PM10 nonattainment area:
ID #
1074
1075
1387
1952
245
35541
1834
31637
3313
3938
36772
4364
334
74058
43124
458
217
56105
1218
3442
60598
1318
1317
1316
4401
1267
1268
1266
1310
3976
61573
35819
38731
113723
399
1198
4368
1389
130
48771
3305
26
1505
27728
881
1109
73110
508
1418
699
31565
529

Business name
23rd Ave Wastewater Treatment Plant
91st Ave Wastewater Treatment Plant
Able Steel Fabricators
Adesa Phoenix LLC
AF Lorts Manufacturing Company
Allied Tube and Conduit
American Express IPC Facility
Anderson Clayton Corp-Valencia Gin
APS West Phx Power Plant
Arizona Galvanizing Inc
Arizona Materials
Arizona State University
Bay State Milling Co
Biltmore Shutters Inc
Bonded Logic Inc
Bryant Industries Inc
Building Products Co
Burdette Cabinet Co Inc
Butterfield Station Facility
Caljet
Case Furniture & Design LLC
Cavco Industries Inc (Litchfield)
Cavco Industries Inc (S. 35th Ave.)
Cavco Industries LLC/Durango Plant
Cemex Construction Materials
Cemex Mesa Plants No #61 & #71
Cemex USA (107th Ave.)
Cemex USA (W. Indian School Rd.)
Century Graphics LLC
Cholla Custom Cabinets Inc
Circle H Sand & Rock
City of Chandler Landfill
Clayton Homes-El Mirage
Contractors Landfill & Recycling
Coreslab Structures (Ariz) Inc
Courier Graphics Corp
Craftsmen In Wood Mfg
DaimlerChrysler Arizona Proving
Grounds
Dolphin Inc
Eagle Roofing Products
Earthgrains Baking Companies Inc
Empire Machinery Co
Executive Door
Flipchip International LLC
Freescale Semiconductor Inc (Alma
School)
Freescale Semiconductor Inc (Elliott
Rd.)
Glenn Weinberger Topsoil Inc
Golden Eagle Manufacturing
Goodrich Aircraft Interior Products
Hanson Aggregates of Arizona
Henry Products Inc
Highland Products Inc

*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*

PM10
1.28
11.37
0.23
0.01
6.47
0.01
0.77
16.97
54.59
9.44
15.43
1.67
6.46
0.01
9.48
1.24
14.52
0.04
30.45
0.00
3.08
0.84
0.09
0.53
17.45
29.29
33.87
28.57
0.00
0.09
8.33
3.16
0.20
13.47
21.58
0.03
5.17

Annual (tons/yr)
PM2.5
NOx
SOx
0.90
4.18
7.24
7.88
14.75
46.42
0.21
0.01
0.11
0.00
5.17
0.02
0.00
0.01
0.11
0.00
0.77
11.01
0.72
4.39
0.05
0.00
51.06 518.91
5.61
5.75
2.84
0.02
6.33
1.67
11.66
0.17
3.33
0.01
9.48
0.19
0.00
0.99
4.73
5.34
11.42
0.04
21.76
2.08
0.45
0.00
1.38
0.00
2.28
0.67
0.09
0.42
7.50
13.63
61.69
0.65
17.45
12.87
0.00
0.06
0.00
0.07
0.10
0.00
3.40
12.82
0.84
2.22
6.57
1.04
0.18
4.02
2.80
0.18
8.33
0.03
0.37
0.00
4.26
0.07
0.00

NH3
0.08
0.00
0.01
0.00
0.01
0.03
97.63
0.27
1.95
0.02
0.02
0.00
0.04

0.14
0.01
0.03
0.01
0.03
0.01

PM10
7.0
62.5
1.8
0.1
49.8
0.1
4.3
93.2
300.0
51.9
98.9
9.2
49.7
0.1
73.0
9.5
83.7
0.3
233.5
0.0
19.7
6.4
0.7
4.1
95.9
160.9
186.1
157.0
0.0
0.7
62.8
17.4
1.5
103.6
166.0
0.2
39.7

Typical day (lbs/day)
PM2.5
NOx
SOx
5.0
23.0
39.8
43.3
81.0
255.0
1.6
0.1
0.8
0.0
39.8
0.2
0.0
0.1
0.9
0.0
4.2
60.5
4.0
24.1
0.3
0.0
280.6 2,851.1
30.8
31.6
15.6
0.1
40.6
9.2
64.1
0.9
25.6
0.1
73.0
1.5
0.0
7.6
28.2
29.8
62.7
0.3
166.9
13.3
2.6
0.0
7.6
0.0
14.6
5.2
0.7
3.2
41.2
74.9
338.9
3.5
95.9
70.7
0.0
0.4
0.0
0.5
0.7
0.0
25.7
98.6
6.5
12.2
36.1
5.7
1.4
31.0
21.5
1.4
64.1
0.2
2.4
0.0
32.7
0.5
0.0
222.7
76.9
35.3
1.8
5.6
21.0
0.2

1.3
17.4
11.7
13.2
192.7

0.0
0.4
0.1
0.1
2.5

1.6
1.1
1.2
2.7

2.4

0.0

0.6

0.1
0.0
0.1
0.1
536.5
1.5
10.7
0.1
0.2
0.0
0.2

0.8
0.0
0.2
0.0
0.2
0.0

138.77
10.47
5.91
3.61
0.90
3.21
0.03

40.52
9.80
5.50
0.28
0.89
2.73
0.03

0.14
2.27
1.82
2.06
33.25

0.00
0.05
0.01
0.01
0.33

0.20
0.17
0.19
0.50

0.44

0.00

0.11

762.5
82.1
37.9
23.1
5.7
24.7
0.2

*

0.91

0.91

6.92

0.63

1.35

6.8

6.8

95.4

22.1

7.4

*
*
*

0.32
15.20
5.65
0.05
97.66
0.04
0.15

0.32
4.60
4.90
0.04
43.60
0.04
0.15

3.11
0.08
0.03
0.58
5.64
0.55
1.98

0.03
0.01
0.00
0.00
2.30
0.00
0.01

0.65
0.00
0.00
0.03

2.1
104.1
43.4
0.4
735.8
0.3
1.2

2.1
30.6
37.7
0.3
329.7
0.3
1.2

22.1
0.4
0.2
4.4
43.4
4.2
15.2

0.5
0.0
0.0
0.0
17.7
0.0
0.1

3.6
0.0
0.0
0.2

*
*
*
*
*

*

0.05
0.18

* = Source for which rule effectiveness has been applied.

2005 Periodic PM10 Emission Inventory

NH3
0.5
0.0

23

Maricopa County, AZ

0.4
1.4

Table 2.4–1. Annual and typical daily point source emissions, by facility (continued).
ID #
3536
1059
247
355
403
777
3966
341
96886
3300
744
1248
31261
44092
40470
353
62
3326
1415
1414
1875
226
34197
910
73084
1879
1331
3953
27925
52382
528
733
1341
1014
562
1154
92072
148
60889
1030
44182
50299
537
303
63
260
64781
213
4318
759
1437
3315

Business name
Holsum Bakery Inc
Honeywell Engines Sys & Service Phx
R&O
Honeywell Engines Systems
Accessories
Honeywell-Engines Systems &
Services
Hydro Aluminum North America Inc
Insulfoam
Intel Corp-Ocotillo Campus (Fab 12/22)
L & M Laminates & Marble
Legends Furniture
Luke AFB - 56th Fighter Wing
M E Global Inc
Maax Spas Arizona
Madison Granite Supplies
Maricopa Ready Mix (Litchfield)
Maricopa Ready Mix (Sun City)
Marlam Industries Inc
Mastercraft Cabinets Inc
Mesa Fully Formed Inc
Mesa Materials Inc (Broadway)
Mesa Materials Inc (Higley)
Microchip Technology Inc
Monier Lifetile LLC
National Gypsum Co
Neltec Inc
New Directions Incorporated
Northwest Regional Landfill
Oak Canyon Manufacturing Inc
Oakcraft Inc
Oasis Bedroom Co
Ocotillo Power Plant
Packaging Corporation of America Inc
Pan-Glo Services
Penn Racquet Sports Inc
Phoenix Brick Yard
Phoenix Newspapers Inc
Ping Inc
Pioneer Landscaping Materials
Presto Casting Co
Purcells Western States Tire
Quebecor World-Phoenix Division
Quincy Joist Company
Quintero Area Water System
Red Mountain Mining Inc
Rexam Beverage Can Company
Rinker Materials (El Mirage)
Rinker Materials (S. 19th Ave.)
Rinker Materials (S. 59th Ave.)
Rinker Materials (W. Glendale)
River Ranch Plant #40
Rogers Corp/Advanced Circuit Matls.
Sanmina Phoenix Division
Santan Generating Station

PM10
0.21
*

*
*
*

*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*
*

*
*
*
*
*
*

*
*
*
*
*
*

Annual (tons/yr)
PM2.5
NOx
SOx
0.21
2.71
0.02

NH3
0.25

PM10
1.6

Typical day (lbs/day)
PM2.5
NOx
SOx
1.6
20.9
0.1

0.45

1.15

1.52

0.43

0.09

2.8

7.3

8.8

2.8

0.5

0.42

0.42

10.39

0.23

0.15

2.3

2.3

57.1

1.2

0.8

4.21
15.01
0.12
2.21
0.04
0.49
0.82
69.70
0.42
11.28
9.83
11.06
2.56
0.04
1.31
13.77
14.71
1.75
1.56
18.75
0.18
1.88
31.52
0.03
0.11
0.17
9.54
1.05
0.05
20.35
26.36
0.02
0.22
29.94
0.26
9.70
0.20
0.60
0.94
17.48
0.40
10.85
70.27
21.14
52.88
57.50
0.14
0.09
45.32

4.00
14.26
0.12
1.79
0.03
0.43
0.82
67.40
0.30
3.86
4.87
5.08
1.81
0.03
1.04
4.15
4.23
1.23
1.09
11.90
0.18
1.60
22.51
0.02
0.09
0.15
8.98
1.05
0.05
15.15
11.33
0.02
0.20
10.55
0.21
6.88
0.20
0.60
0.93
6.23
0.40
5.43
31.73
8.57
22.32
29.81
0.14
0.09
43.81

64.78
11.95
1.63
24.87

12.82
0.48
0.01
0.37

1.27
0.98
0.15
6.08

7.5
6.3
0.9
33.7

0.23
11.43

0.40
0.50

1.5
87.9

2.2
3.3

31.84

15.05

0.07

115.8

0.6

0.04
0.13

0.00
0.00

0.00
0.01

0.0
0.0

0.0
0.1

9.52
7.02
6.36
0.54
17.96
10.73

10.54
6.59
0.09
0.00
17.40
0.01

0.01
0.01
0.65
0.10
1.58
0.22

81.1
50.7
2.3
0.0
112.1
0.1

0.1
0.1
3.6
0.6
10.2
1.2

8.75

0.92

0.02

6.2

0.1

0.14

0.00

0.01

0.0

0.1

97.46
13.88
0.72
5.17
10.27
0.59
0.17

0.55
0.08
0.00
0.03
26.21
0.00
0.00

9.79
1.26
0.07
0.47

3.0
0.6
0.0
0.2
144.0
0.0
0.0

53.8
9.7
0.5
3.6

1.19
0.16
1.76

0.07
0.00
0.02

0.10
0.01
0.16

0.5
0.0
0.1

0.8
0.1
1.0

13.39
8.46
5.22
0.25
4.90
29.20
7.44

0.88
0.56
0.03
0.09
17.67
1.88
16.46

0.03
0.02
0.48
0.02
0.11
0.07
0.05

4.9
4.3
0.2
0.6
113.3
12.1
105.5

0.2
0.2
2.6
0.1
0.7
0.4
0.3

1.33
1.24
220.66

0.01
0.01
6.19

0.09
1.25
17.71

22.2
355.9
91.4
76.6
0.8
10.4
18.4
259.1
0.2
3.3
5.4
59.5
514.1
304.5
2.3
29.7
244.9
37.4
39.0
14.0
0.3
0.2
1.0
8.0
31.9
73.2
32.5
54.0
8.7
62.8
7.0
3.4
79.0
118.8
1.0
59.0
12.3
173.0
66.0
0.2
0.6
1.1
1.1
49.3
535.5
8.1
106.8
0.4
5.5
116.5
39.7
65.0
56.4
0.1
16.4
1.5
0.9
66.9
1.6
9.1
52.9
1.2
1.3
11.3
4.6
5.2
74.1
45.9
65.0
2.2
28.7
34.8
1.6
203.4
31.4
54.9
187.2
143.1
47.7
229.3
0.8
7.3
0.6
8.0
240.7 1,212.4

70.4
3.1
0.1
10.1

9.37
40.38

23.5
96.2
0.8
20.7
0.3
3.8
5.4
531.3
3.2
86.8
75.4
84.9
19.7
0.3
10.0
105.9
113.1
11.6
10.0
129.1
1.0
14.5
241.8
0.2
0.7
1.3
52.4
8.1
0.4
156.6
149.5
0.1
1.7
189.6
2.0
74.6
1.3
4.6
5.2
127.5
2.2
69.5
450.5
135.5
339.0
442.3
0.8
0.6
249.0

0.1
0.0
34.0

0.5
8.0
97.3

0.02
0.02

* = Source for which rule effectiveness has been applied.

2005 Periodic PM10 Emission Inventory

NH3
1.9

24

Maricopa County, AZ

0.1
0.1

Table 2.4–1. Annual and typical daily point source emissions, by facility (continued).
ID #
266
246
4175
50422
27933
331
46277
3316
3317
4131
1444
582
4400
378
281
101
31643
249
552
363
56
1211
1210
37546
42915
234
53
2
90
344
174
36676
141
398
20706
1382

Annual (tons/yr)
Business name
PM10
PM2.5
NOx
SOx
Schuff Steel Co
*
9.20
7.87
10.46
0.69
Schult Homes
*
9.12
8.13
SFPP LP Phoenix Terminal
0.34
0.33
6.64
0.02
Simula Safety Systems Inc
0.01
0.01
0.08
0.00
Skunk Creek Landfill
*
54.62
50.85
1.83
1.08
Smurfit Stone Container Corp
*
7.28
7.27
10.81
0.71
Southwest Forest Products Inc
1.37
1.36
19.51
1.28
SRP Agua Fria Generating Station
6.65
6.65 352.99
0.56
SRP Kyrene Generating Station
15.52
15.18
47.07
1.92
ST Microelectronics
0.31
0.31
4.02
0.02
Staco Architectural Roof Tile
*
0.32
0.22
0.07
0.00
Stone Creek Inc
*
0.04
0.03
Sumco Southwest Corporation
*
0.79
0.54
11.19
0.02
Sun Land Materials
*
2.87
1.39
10.57
0.69
Sun State Rock & Materials
*
9.65
3.14
32.09
1.56
Sunland Beef Company
*
10.28
5.21
11.19
0.07
SW Reg Municipal Solid Waste Landfill *
30.29
16.04
6.35
0.42
The Boeing Company
0.20
0.20
3.17
0.09
Thornwood Furniture Mfg
*
2.62
2.50
Thunderbird Furniture
*
1.72
1.37
0.03
0.00
TPAC A Division of Kiewit Western Co
*
15.02
5.78
1.77
0.01
Trendwood Inc (E. University)
*
0.01
0.00
Trendwood Inc (S. 15th Ave.)
*
0.05
0.05
Trenwyth Industries
0.01
0.01
0.09
0.00
U S Greenfiber-Phoenix
*
5.85
4.15
United Dairymen of Arizona
*
28.40
9.81
16.60
0.25
Utility Vault Co
*
4.01
1.41
2.36
0.15
Vulcan Materials Co (115th Ave.)
*
45.01
22.74
10.85
7.35
Vulcan Materials Co (43rd Ave.)
*
78.89
39.40
5.88
1.18
Vulcan Materials Co (W. Indian School) *
28.37
15.47
W R Meadows of Az Inc
0.01
0.01
0.14
0.00
Western Milling
5.42
4.46
0.96
0.30
Western Organics Inc
*
24.38
23.59
Wickenburg Facility
*
15.70
6.68
5.65
0.37
Wincup Holdings Inc
1.01
1.01
13.24
0.08
Woodcase Fine Cabinetry Inc
*
0.24
0.19
0.16
Emission reduction credits (See section 2.5)
1.80
9.80
PM10 NAA Total:
1,634.53 938.98 1,985.64 244.36

NH3
0.02
0.01
0.03
0.05
8.05
8.83
0.37
0.01
0.67
0.02
0.07
5.85
0.13
0.00
0.16
0.01
2.87
0.01
0.00
0.01
0.01
1.21
176.40

Typical day (lbs/day)
PM10
PM2.5
NOx
SOx
70.8
60.5
80.5
5.3
70.1
62.6
1.9
1.8
36.5
0.1
0.0
0.0
0.5
0.0
300.1
279.4
10.1
5.9
56.0
55.9
83.1
5.5
10.6
10.5
150.1
9.9
36.6
36.6 1,939.5
3.1
85.3
83.4
258.6
10.5
1.7
1.7
22.1
0.1
2.4
1.7
0.6
0.0
0.3
0.3
4.4
3.0
61.5
0.1
22.1
10.7
81.3
5.3
61.8
20.1
205.7
10.0
66.9
34.4
85.4
0.5
194.2
102.8
40.7
2.7
1.5
1.5
24.2
0.7
20.2
19.2
13.2
10.6
0.3
0.0
115.6
44.4
13.6
0.1
0.0
0.0
0.4
0.4
0.1
0.1
0.8
0.0
32.1
22.8
156.1
53.9
91.2
1.4
30.9
10.8
18.1
1.2
344.5
174.2
69.5
47.1
605.7
302.6
45.2
9.0
217.0
118.4
0.1
0.1
1.7
0.0
41.7
34.3
7.4
2.3
154.9
148.8
118.6
50.6
43.5
2.9
5.5
5.5
72.8
0.4
1.8
1.4
9.9
53.7
0.9
10,897.6 6,266.8 11,854.9 1,550.7

NH3
0.2
0.0
0.2
0.3
44.2
48.5
2.0
0.1
3.7
0.2
0.5
34.3
1.0
0.0
1.2
0.1
15.7
0.0
0.0
0.2
0.1
6.6
984.9

Facilities outside the PM10 nonattainment area:
ID #
1488
44439
4498
725
43063
289
44186
43530
98
428
42956

Business name
Farmer's Gin Inc
Gila River Power Station
Hanson Aggregates of Arizona (W.
Indian School Rd.)
Kilauea Crushers Inc
LSP Arlington Valley LLC
Martori Farms
Mesquite Generating Station
New Harquahala Generating Co
Palo Verde Nuclear Generating Station
Paloma Gin Properties LLC
Redhawk Generating Facility
Total outside PM10 NAA:
Grand total:

2005 Periodic PM10 Emission Inventory

*
*
*
*
*
*
*

PM10
14.81
139.32

Annual (tons/yr)
PM2.5
NOx
SOx
4.42
0.60
0.00
134.01 353.59
10.35

14.12
31.06
16.21
11.09
55.00
34.55
115.36
12.97
34.15
478.64

5.80
11.23
16.15
3.00
48.83
34.48
106.30
3.83
27.35
395.41

NH3
19.44

16.90

1.11

0.04

51.81
0.05
210.54
24.10
82.56
0.08
145.02
885.24

2.99
0.00
14.59
1.83
1.27
0.00
8.44
40.59

0.70
0.00
19.78
26.04
5.96
0.01
25.62
97.59

2,114.97 1,334.38 2,880.67

285.10

25

PM10
81.4
893.9

Typical day (lbs/day)
PM2.5
NOx
SOx
24.3
3.3
0.0
859.9 2277.8
66.5

108.7
44.6
130.0
199.1
72.0
125.2
124.8
406.5
69.7
19.2
0.3
302.6
268.7 1162.6
189.8
189.4
132.4
633.8
317.4
453.6
71.2
21.1
0.4
187.7
150.3
797.4
2,863.2 2,091.7 5,364.4

273.99 13,760.7 8,358.4 17,219.3

NH3
124.7

8.5

0.3

23.9
0.0
80.6
10.0
7.0
0.0
46.4
242.9

5.4
0.0
108.7
143.1
32.7
0.0
140.8
555.7

1,793.6 1,540.6

Maricopa County, AZ

2.5

Emission reduction credits

A major source or major modification planned in a nonattainment area must obtain emissions
reductions as a condition for approval. These emissions reductions, generally obtained from
existing sources located in the vicinity of a proposed source must offset the emissions increase
from the new source or modification. The obvious purpose of acquiring offsetting emissions
decreases is to allow an area to move towards attainment of the national ambient air quality
standards while still allowing some industrial growth.
In order for these emission reductions to be available in the future for offsetting, they must be: 1)
explicitly included and quantified as growth in projection year inventories required in rate of
progress plans or attainment demonstrations that were based on 1990 actual inventories, and 2)
meet the requirements outlined in MCAQD Rule 240 (Permit Requirements for New Major
Sources and Major Modification to Existing Major Sources).
Table 2.5–1 provides a list of emission reduction credits for PM10, NOx, and SOx. Only one
previously operational facility maintains emission reduction credits that are still valid for
inclusion in this report and the rate of progress plan.
Table 2.5–1.

Emission reduction credits.
Emission reduction credits (tons)

ID
1151

Facility
Freescale Semiconductor, Inc. (formerly Motorola Mesa)

2005 Periodic PM10 Emission Inventory

26

PM10

NOx

SOx

1.80

9.80

0.16

Maricopa County, AZ

2.6

Summary of point source emissions

Tables 2.6–1 and 2.6–2 provide an overview of source category contributions to point source
emissions for Maricopa County and the PM10 nonattainment area.
Table 2.6–1.

Maricopa County annual and typical daily point source emissions, by source category.
Annual (tons/yr)
Typical day (lbs/day)
Source Category
PM10 PM2.5
NOx
SOx NH3
PM10 PM2.5
NOx
SOx
NH3
Electricity generation
313.86
313.20 1,914.79 51.58 198.06 1,887.5 1,883.5 11,016.1
318.7 1,107.5
Comm./inst. fuel combustion
4.90
4.88
58.20
2.82
2.53
28.7
28.6
358.1
17.1
14.0
Industrial fuel combustion
79.10
78.84
739.13 50.59 55.13
483.0
481.2 4,760.2
352.6
317.0
Food/agriculture
64.21
18.08
380.1
109.3
Industrial processes
842.61
556.08
116.20 123.40 18.11 5,559.3 3,422.7
797.4
793.6
101.2
Manufacturing processes
9.17
8.95
15.00
0.02
0.16
69.2
67.0
82.4
0.1
1.0
Industrial road travel
729.71
294.90
4,945.5 2,035.9
Waste disposal
69.62
59.45
27.55 56.53
397.6
330.3
151.4
310.6
Emission reduction credits
1.80
9.80
0.16
9.9
53.7
0.9
ALL POINT SOURCES:
2,114.97 1,334.38 2,880.67 285.10 273.99 13,760.7 8,358.4 17,219.3 1,793.6 1,540.6

Table 2.6–2.

PM10 nonattainment area annual and typical daily point source emissions, by source category.
Annual (tons/yr)
Typical day (lbs/day)
Source Category
PM10 PM2.5
NOx
SOx NH3
PM10 PM2.5
NOx
SOx
NH3
Electricity generation
113.97
113.72 1,154.60 15.24 132.55
637.8
636.3 6,402.8
103.0
728.3
Comm./inst. fuel combustion
4.90
4.88
58.20
2.82
2.53
28.7
28.6
358.1
17.1
14.0
Industrial fuel combustion
40.67
40.53
614.09 46.35 28.75
267.3
266.2 4,009.2
325.4
171.8
Food/agriculture
27.83
7.87
172.3
50.7
Industrial processes
670.39
420.49
116.20 123.40 12.41 4,585.5 2,932.0
797.4
793.6
69.9
Manufacturing processes
9.17
8.95
15.00
0.02
0.16
69.2
67.0
82.4
0.1
1.0
Industrial road travel
697.98
283.10
4,729.2 1,955.7
Waste disposal
69.62
59.45
27.55 56.53
397.6
330.3
151.4
310.6
Emission reduction credits
1.80
9.80
0.16
9.9
53.7
0.9
ALL POINT SOURCES:
1,636.33
938.98 1,995.44 244.52 176.40 10,897.6 6,266.8 11,854.9 1,550.7
984.9

2.7

Quality assurance / quality control procedures

2.7.1

Emission survey preparation and data collection

The MCAQD's Emissions Inventory (EI) Unit annually collects point source criteria pollutant
emission data from sources in the county. MCAQD annually reviews EPA guidance, documents
from the Emission Inventory Improvement Program (EIIP), and other source materials to ensure
that the most current emission factors and emission calculation methods are used for each year's
survey. Each January, the EI Unit prepares a pre-populated hard copy of the preceding year’s
submissions and mails reporting forms to permitted sources, along with detailed instructions for
completing the forms. (A copy of these instructions is included as Appendix 2.1). The EI Unit
asks sources to verify and update the data. The EI Unit also holds workshops from January
through April to assist businesses in completing EI forms.
The general data flow for data collection and inventory preparation is shown in Figure 2.7–1.

2005 Periodic PM10 Emission Inventory

27

Maricopa County, AZ

Figure 2.7–1. Data flow for annual point source emission inventory reporting.

EI Reporting
Forms
• Hard Copy Forms/
Instructions
• Instruction on Web

EI Reporting
Forms

Log In EI
reports/ Issue
Receipts

Data Entry

EMS

Issue NOVs for
late submitters

•
•
•

Code/field check
Range checks
Referential value checks

Create
Inventory files

Automated QA checks

Technical QA/
QC

Using completed survey data

Finalized Inventory
Data
Reconciliation

2.7.2

Submission processing

Submitted EI reports are logged in as they are received, and receipts are issued for emissions fees
paid. The data are input “as received” into the department's data base. During data entry,
numerous automated quality control (QC) checks are performed, including:
•
•
•
•
•

pull-down menus to minimize data entry errors (e.g., city, pollutant, emission factor unit,
etc.)
mandatory data field requirement checks (e.g., a warning screen appears if a user tries to
save an emission record with a missing emission factor).
range checks (e.g., were valid SCC, Tier, SIC, and NAICS codes entered?)
referential value checks (e.g., emission factor units, annual throughput units)
automatic formatting of date, time, telephone number fields, etc.

Automated quality assurance (QA) checks on the report that has been entered include the
following:
•
•

Comparing reported emission factors to SCC reference lists
Comparing reported emission factors to material name reference list

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

•
•

Checking the report for calculation errors. This includes annual throughput, emission
factors, unit conversion factors (e.g., BTU to therms), capture efficiency, primary /
secondary control device efficiency, and any offsite recycling credits claimed.
Checking the report for completeness of required data.

When data entry is complete, an electronic version of the original data is preserved separately to
document changes made during the technical review and QA/QC process.
When errors are flagged, the businesses are contacted and correct information is obtained and
input to the EMS. Outstanding reporting issues are documented. Confidential business
information (CBI) is identified by a checkbox on the form, and these data elements are flagged
during data entry and are not transmitted to the EPA. To prepare the inventory for submittal to
the National Emissions Inventory (NEI), the EI Unit runs Microsoft Access queries on the data in
the EMS to pull fields for the NEI Input format (NIF) tables.

2.7.3

Analysis of annual point source emissions data for this inventory

Two environmental planners checked inventory accuracy and reasonableness, and assured that
all point sources had been identified and that the methodology applied to calculate emissions was
appropriate and that the calculations were correct. Other reasonableness checks were conducted
by recalculating emissions using methods other than those used to make the initial emissions
calculations and then comparing results. QA was conducted by checking all emissions reports
submitted to MCAQD for the year 2005 for missing and questionable data and by checking the
accuracy and reasonableness of all emissions calculations made for such reports. Notes
concerning follow-up calls and corrections to calculations were documented on each 2005 annual
emissions report.
The QA point source coordinator reviewed and checked calculations, identified errors, and
performed completeness, reasonableness and accuracy checks.
2.8

References

CARB, 2004. Speciation Profiles and Size Fractions. Available at:
http://www.arb.ca.gov/emisinv/ speciate/speciate.htm
US EPA, 1992. Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State
Implementation Plan Base Year Inventories. USEPA Office of Air Quality Planning and
Standards, Research Triangle Park, NC. Rep. EPA-452/R-92-010, November 1992.
Available at: http://www.epa.gov/ttn/chief/old/eidocs/454r92010_nov1992.pdf.
US EPA, 2003. 2002 National Emission Inventory (NEI) Preparation Plan (draft). USEPA
Office of Air Quality Planning and Standards, Dec. 19, 2003. Available at:
http://www.epa.gov/ttn/ chief/net/2002inventory.html.
US EPA, 2005. Emissions Inventory Guidance for Implementation of Ozone and Particulate
Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.
USEPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. Draft
Rep. Revised Nov. 2005. Available at: http://www.epa.gov/ttn/chief/eidocs/eiguid/

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

This page intentionally blank.

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

3.

Area Sources

3.1

Scope and methodology

This chapter considers all stationary sources which are too small or too numerous to be treated as
point sources. EPA guidance documents, including “Introduction to Area Source Inventory
Development” (US EPA, 2001a) as well as permit and emissions data in the MCAQD’s Environmental Management System (EMS) database, and previous SIP inventories, were evaluated to
develop the list of area-source categories for inclusion. Some source categories were deemed
“insignificant” because there are no large production facilities and/or very few small sources, and
therefore emissions were not quantified. MCAQD prepared the area-source emission estimates
for all area sources and provided quality assurance checks on all data. Table 3.1–1 contains a list
of all area-source categories, with Source Classification Codes (SCCs), addressed in this chapter.
Table 3.1–1.
SCC Code
2102006000
2102004000
2103006000
2103004000
2104006000
2104008000
2104004000

List of area-source categories.
Category Description
Fuel combustion:
Industrial natural gas
Industrial fuel oil
Commercial/institutional natural gas
Commercial/institutional fuel oil
Residential natural gas
Residential wood
Residential fuel oil

Section
3.2.1
3.2.2
3.2.3
3.2.4
3.2.5
3.2.6
3.2.7

2301010000
2302002000
2302040000
2302080000
2304000000
2305000000
2325000000
2307000000
2308000000
2309000000
2311010000
2311020000
2311030000
n/a
2312000000
n/a
n/a
2399000000

Industrial processes:
Chemical manufacturing
Commercial cooking
Grain handling/processing
Ammonia cold storage
Secondary metal production
Non-metallic mineral processes
Mining and quarrying
Wood product manufacturing
Rubber/plastics manufacturing
Fabricated metal products manufacturing
Residential construction
Commercial construction
Road construction
Other construction
Electrical equipment manufacturing
State-permitted portable sources
Paved/unpaved road travel on industrial sites
Industrial processes not elsewhere classified (NEC)

3.3.1
3.3.2.1
3.3.2.2
3.3.2.3
3.3.3
3.3.4
3.3.5
3.3.6
3.3.7
3.3.8
3.3.9
3.3.9
3.3.9
3.3.9
3.3.10
3.3.11
3.3.12
3.3.13

2601000000
2610000000
2620000000
2630000000
2650000000

Waste treatment and disposal:
On-site incineration
Open burning
Landfills
Publicly owned treatment works (POTWs)
Other industrial waste / disposal

3.4.1
3.4.2
3.4.3
3.4.4
3.4.5

2810001000
n/a

Miscellaneous area sources:
Wildfires and brush fires
Prescribed fires

3.5.1.1
3.5.1.2

2005 Periodic PM10 Emission Inventory

31

Maricopa County, AZ

Table 3.1–1.
SCC Code
2810030000
2810050000
2810040000
2801000003
2801000005
n/a
2801000000
2801700000
2805000000
2850000000
2830000000
2810010000
n/a
n/a
n/a
2730100000

List of area-source categories.
Category Description
Miscellaneous area sources: (continued)
Structure fires
Vehicle fires
Engine testing
Tilling
Harvesting
Travel on unpaved agricultural roads
Cotton ginning
Fertilizer application
Livestock
Health services
Accidental releases
Humans
Leaf blower fugitive dust
Offroad recreational vehicle fugitive dust
Unpaved parking lots fugitive dust
Windblown dust

Section
3.5.1.3
3.5.1.4
3.5.1.5
3.5.2.1
3.5.2.2
3.5.2.3
3.5.2.4
3.5.2.5
3.5.3
3.5.4
3.5.5
3.5.6
3.5.7
3.5.8
3.5.9
3.5.10

For nearly all categories, emissions were calculated in one of the following ways:
• emissions estimates for some categories were developed by conducting surveys on local
usage (e.g., natural gas consumption, pesticide usage) or derived from state-wide data
(e.g., fuel oil use).
• for some widespread or diverse categories (e.g., consumer solvent use), emissions were
calculated using published per-capita or per-employee emission factors.
• for source categories with some information available from annual emissions reports
(e.g., bakeries), these data were combined with employment data to “scale up” reported
emissions to reflect the entire source category.
• for those source categories with detailed emissions data available from most or all
significant sources in the category, emissions were calculated based on detailed process
and operational data provided by these sources.
• The specific emissions estimation methodologies used for each source category
(including any application of rule effectiveness) are described in greater detail in the
respective sections.

3.2

Fuel combustion

Area-source emissions for the following seven categories of fuel consumption were calculated:
Industrial natural gas, industrial fuel oil, commercial/institutional natural gas, commercial/
institutional fuel oil, residential natural gas, residential wood, and residential fuel oil. Data for
emissions calculations from natural gas combustion came from a survey of the three natural gas
suppliers in Maricopa County. Table 3.2–1 summarizes the natural gas sales data received from
Maricopa County natural gas suppliers.
Table 3.2–1.

Maricopa County natural gas sales data by supply company and end-user category.
Sales by end user category (in MMCF/yr)
Natural gas
Electric
Commercial/
supplier
Utilities
Industrial
Institutional
Residential
Transport*
Other*
Southwest Gas
n/a
2,459.27
13,968.02
15,364.45
5,151.97
836.01
City of Mesa
n/a
108.99
1,367.49
1,106.08
8.74
114.58
El Paso
148,506.64
185.58
n/a
n/a
n/a
n/a
* For emissions calculations, sales from these two categories were grouped with industrial sales.
2005 Periodic PM10 Emission Inventory

32

Maricopa County, AZ

Area-source emissions for wood and fuel oil combustion were calculated from Arizona statelevel sales and consumption data as described in the following subsections. Area-source
emissions from coal and liquid petroleum gas were not calculated, as emissions from these
categories were determined to be insignificant.

3.2.1

Industrial natural gas

All natural gas suppliers in Maricopa County were surveyed to gather information on the volume
of natural gas distributed, by user category, within the county in 2005. Area-source industrial
natural gas usage for the county is based on the reported total volume of natural gas sold to
industrial sources, minus natural gas used by industrial point sources:
County area-source
industrial natural gas usage

= Total reported industrial
natural gas sales
= 8,865.13 MMCF
= 4,324.16 MMCF

– Industrial point source
natural gas usage
– 4,540.37 MMCF

Natural gas is used for both external combustions (boilers, heaters) and internal combustion
(generators), each of which have different emission factors. Thus the area-source natural gas
usage derived above must be apportioned between these two categories. This apportionment was
based on the percentages of external and internal natural gas combustion reported by all
industrial area sources in 2005.
Annual emissions for the county and the PM10 nonattainment area are calculated by multiplying
natural gas usage by the respective AP-42 emission factors for external and internal combustion,
as in this example for PM10 emissions from external natural gas combustion:
Annual PM10 emissions = External industrial natural × PM10 emission factor for ÷ 2,000 lb/ton
from external natural gas
gas usage (MMCF)
external natural gas comcombustion
bustion (lb/MMCF)
= 4,257.47
× 7.6
÷ 2,000
= 16.18 tons PM10/yr
Table 3.2–2. Emission factors and annual emissions from area-source industrial natural gas combustion, by
combustion type.
Natural gas
Emission factors (lb/MMCF)
Annual emissions (tons/yr)
Combustion % of
usage
type
total
(MMCF)
PM10 PM2.5 NOx SOx NH3 PM10 PM2.5 NOx
SOx NH3
External
98.44
4,257.47
7.6
7.6 100
0.6
3.2 16.18 16.18 212.87 1.28 6.81
Internal
1.56
67.29
10.0 10.0 2840
0.6
n/a 0.34 0.34 95.55 0.02
n/a
Total:
100.00
4,324.16
16.51 16.51 308.43 1.30 6.81

Typical daily emissions for the county are calculated by dividing annual emissions by the
number of days that activity occurs throughout the year:
PM10 typical daily emissions
from industrial natural gas

= Annual PM10
÷ (days/week × wks/yr)
emissions (tons/yr)
= 16.51
÷ (6 × 52)
= 105.9 lbs PM10/day

2005 Periodic PM10 Emission Inventory

33

× 2,000 lbs/ton
× 2,000

Maricopa County, AZ

Annual and typical daily emissions within the PM10 nonattainment area are calculated by
applying the ratio of industrial employment in the nonattainment area to county-level emission
calculations. (See Section 1.5.1 for a discussion of the employment data used).
Emissions from area-source
industrial natural gas combustion
in the PM10 NAA

= Annual county PM10 × NAA:County
emissions (tons/yr)
Industrial employment ratio
= 16.51
= 16.40 tons PM10/yr

× 0.9932

Table 3.2–3.

Annual and typical daily emissions from area-source industrial natural gas combustion.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx SOx
NH3
PM10
PM2.5
NOx SOx NH3
Maricopa County
16.51
16.51 308.43 1.30
6.81
105.9
105.9 1,977.1
8.3 43.7
PM10 NAA
16.40
16.40 306.33 1.29
6.77
104.7
104.7 1,955.5
8.2 43.2

3.2.2

Industrial fuel oil

Area-source emissions from industrial fuel oil combustion are calculated by a multi-step process
which allocates Arizona state-level industrial fuel oil sales as reported by the U.S. Department of
Energy, Energy Information Administration (US DOE, 2006a) to Maricopa County.
To derive industrial fuel oil usage in Maricopa County, reported Arizona state-level sales of
high-sulfur diesel for 2005 are first subtracted from Arizona state-level total industrial fuel oil
sales, as it is presumed that no high-sulfur diesel fuel is used in Maricopa County due to local air
quality regulations and market conditions.
State industrial fuel oil sales
other than high-sulfur diesel
(in thousand gallons, or Mgal)

= Reported state total
– Reported state high-sulfur diesel sales
industrial fuel oil sales
= 84,519 Mgal
– 431 Mgal
= 84,088 Mgal/yr

Arizona state industrial fuel oil sales (less high-sulfur diesel fuel) are then multiplied by the ratio
of industrial employment in Maricopa County to Arizona State (0.70), as determined by data
from the US Census Bureau (2006b) to estimate annual Maricopa County-level industrial fuel oil
sales, as follows:
Maricopa County
= Arizona state industrial fuel
× Maricopa County:State
industrial fuel oil sales
oil sales less high-sulfur diesel
industrial employment ratio
= 84,088 Mgal
× 0.70
= 58,466.39 Mgal/yr

To avoid double-counting, industrial fuel oil use attributable to stationary point sources
(addressed in Chapter 2) and nonroad mobile sources (addressed in Chapter 4) are subtracted
from County industrial fuel oil sales to estimate county fuel oil usage by area sources:
Maricopa County area = Maricopa County
– Fuel oil used by industrial – Fuel oil used by industrial
source fuel oil sales
industrial fuel oil sales
nonroad mobile equipment
stationary point sources
= 58,466.39 Mgal
– 9,928.15 Mgal
– 3,090.77 Mgal
= 45,447.461 Mgal/yr

2005 Periodic PM10 Emission Inventory

34

Maricopa County, AZ

Industrial fuel oil is used for both external combustions (boilers, heaters) and internal combustion (generators), each of which have different emission factors. Thus the area-source
industrial fuel oil sales derived above must be apportioned between these two categories. This
apportionment was based on the percentages of external and internal fuel oil combustion
reported by all industrial area sources surveyed in 2005 (shown in Table 3.2–4 below).
Annual emissions for the county and the PM10 nonattainment area are calculated by multiplying
industrial fuel oil sales by the respective AP-42 emission factors for external and internal
combustion, as in this example for PM10 emissions from external fuel oil combustion:
Annual PM10 emissions = External industrial fuel
from external industrial
oil sales (Mgal)
fuel oil combustion
= 35,453.565
= 35.45 tons PM10/yr

× PM10 emission factor for external ÷
fuel oil combustion (lb/Mgal)

2,000 lb/ton

× 2

2,000

÷

Table 3.2–4. Emission factors and annual emissions from area-source industrial fuel oil combustion, by
combustion type.
Annual
Emission factors (lb/Mgal)
Annual emissions (tons/yr)
Combustion % of
sales
(Mgal)
type
total
PM10 PM2.5 NOx SOx NH3 PM10 PM2.5
NOx
SOx
NH3
External
78.01 35,453.565
2.0
2.0
24 7.39 0.8 35.45 35.45
425.44 130.91 14.18
Internal
21.99 9,993.897 42.5 42.5 604 39.70
– 212.37 212.37 3,018.16 198.38 0.00
Totals:
100.00 45,447.461
247.82 247.82 3,443.60 329.29 14.18

Typical daily emissions for the county are calculated by dividing annual emissions by the
number of days activity that occurs throughout the year, as recommended by EIIP guidance (US
EPA, 2001a):
PM10 typical daily
emissions from
industrial fuel oil

= Annual PM10
÷ (days/week × wks/yr)
emissions (tons/yr)

× 2,000 lbs/ton

= 247.82
÷ (6 × 52)
= 1,588.6 lbs PM10/day

× 2,000

Annual and typical daily emissions in the PM10 nonattainment area are calculated by applying
the ratio of industrial employment in the nonattainment area to county-level emission
calculations. (See Section 1.5.1 for a discussion of the employment data used).
PM10 NAA emissions from area
source industrial fuel oil combustion

= Annual county
× NAA:County industrial employment ratio
PM10 emissions
= 247.82 tons/yr
× 0.9932
= 246.14 tons PM10/yr

Table 3.2–5.

Annual and typical daily emissions from area-source industrial fuel oil combustion.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area PM10 PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
Maricopa County 247.82 247.82 3,443.60 329.29 14.18 1,588.6 1,588.6 22,074.4 2,110.8 90.9
PM10 NAA
246.14 246.14 3,420.18 327.05 14.08 1,577.8 1,577.8 21,924.3 2,096.5 90.3

2005 Periodic PM10 Emission Inventory

35

Maricopa County, AZ

3.2.3

Commercial/institutional natural gas

All natural gas suppliers in Maricopa County were surveyed to gather information on the volume
of natural gas distributed, by user category, within the county in 2005. Area-source commercial
and institutional (C&I) natural gas usage for the county is based on the reported total volume of
natural gas sold to C&I sources, minus natural gas used by C&I point sources:
County area-source C&I = Reported C&I natural gas sales – C&I point source natural gas usage
natural gas usage
= 16,286.09 MMCF
– 538.85 MMCF
= 15,747.24 MMCF

Natural gas is used for both external combustion (boilers, heaters) and internal combustion
(generators), each of which have different emission factors. Thus the area-source natural gas
usage derived above must be apportioned between these two categories. This apportionment was
based on the percentages of external and internal natural gas combustion reported by all C&I
area sources in 2005.
Annual emissions for the county are calculated by multiplying natural gas usage by the
respective AP-42 emission factors for external and internal combustion, as in this example for
PM10 emissions from external natural gas combustion:
Annual PM10 emissions = External C&I natural
from external natural gas
gas usage (MMCF)
combustion
= 15,485.18
= 58.84 tons PM10/yr

× PM10 emission factor for ÷ 2,000 lb/ton
external natural gas combustion (lb/MMCF)
× 7.6
÷ 2,000

Table 3.2–6. Emission factors and annual emissions from area-source commercial/institutional natural gas
combustion, by combustion type.
Annual emissions (tons/yr)
C&I natural Emission factors (lb/MMCF)
Combustion % of
gas usage
type
total
(MMCF) PM10 PM2.5 NOx SOx NH3 PM10 PM2.5
NOx
SOx NH3
External
98.34 15,485.18
7.6
7.6 100
0.6 0.49 58.84 58.84
774.26 4.65 3.79
Internal
1.66
262.06
10.0 10.0 2840
0.6 n/a
1.31 1.31
372.13 0.08 n/a
Total:
100.00
60.15 60.15 1,146.39 4.72 3.79

Typical daily emissions for the county are calculated by dividing annual emissions by the
number of days that activity occurs throughout the year:
PM10 typical daily
emissions from
C&I natural gas

= Annual PM10
÷ (days/week × wks/yr)
emissions (tons/yr)

×

2,000 lbs/ton

= 60.15
= 385.6 lbs/day

×

2,000

÷ (6 × 52)

Annual and typical daily emissions within the PM10 nonattainment area are calculated by
applying the combined ratio of retail, office, public and other employment in the nonattainment
area to county-level emission calculations. (See Section 1.5.1 for a discussion of the
employment data used).

2005 Periodic PM10 Emission Inventory

36

Maricopa County, AZ

Emissions from area-source = Annual county PM10
C&I natural gas combustion
emissions (tons/yr)
in the PM10 NAA
= 60.15
= 59.72 tons PM10/yr
Table 3.2–7.
combustion.

× 0.9928

Annual and typical daily emissions from area-source commercial/institutional natural gas

Geographic area
Maricopa County
PM10 NAA

3.2.4

× NAA:County C&I employment ratio

PM10
60.15
59.72

Annual emissions (tons/yr)
PM2.5
NOx
SOx
60.15 1,146.39 4.72
59.72 1,138.13 4.69

NH3
3.79
3.77

Typical daily emissions (lbs/day)
PM10
PM2.5
NOx
SOx
NH3
385.6
385.6 7,348.6 30.3
24.3
381.5
381.5 7,270.0 30.0
24.1

Commercial/institutional fuel oil

Area-source emissions from commercial and institutional (C&I) fuel oil combustion are calculated by a multi-step process of allocating Arizona state-level C&I fuel oil sales as reported by
the U.S. Department of Energy, Energy Information Administration (US DOE, 2006b) to
Maricopa County.
To derive commercial/institutional fuel oil usage in Maricopa County, reported Arizona statelevel sales of high-sulfur diesel for 2005 are first subtracted from Arizona state-level total C&I
fuel oil sales, as it is presumed that no high-sulfur diesel fuel is used in Maricopa County due to
local clean air act requirements and market conditions.
State C&I fuel oil sales
other than high-sulfur diesel
(in thousand gallons, or Mgal)

= Reported state total
C&I fuel oil sales
= 20,645 Mgal
= 20,645 Mgal/yr

– Reported state high-sulfur diesel sales
– 0 Mgal

Arizona state commercial/institutional fuel oil sales (less high-sulfur diesel fuel) are then
multiplied by the ratio of C&I employment in Maricopa County to Arizona state (0.80), as
determined by data from the US Census Bureau (2006b) to estimate annual Maricopa Countylevel commercial/institutional fuel oil sales, as follows:
Maricopa County
C&I fuel oil sales

= Arizona state C&I fuel
× Maricopa County:state commercial/
oil sales less high-sulfur diesel
institutional employment ratio
= 20,645 Mgal
× 0.80
= 16,532.52 Mgal/yr

To avoid double-counting, C&I fuel oil use attributable to stationary point sources (addressed in
Chapter 2) and nonroad mobile sources (addressed in Chapter 4) are subtracted from County
C&I fuel oil sales to estimate county fuel oil usage used by area sources:
Annual Maricopa County
commercial/institutional
area-source fuel oil sales

= Maricopa County
C&I fuel oil sales

– Fuel oil used by C&I
– Fuel oil used by C&I
nonroad mobile equipment
stationary point sources

= 16,532.52 Mgal
= 10,299.912 Mgal/yr

– 6,092.013 Mgal

– 140.591 Mgal

Fuel oil is used for both external combustions (boilers, heaters) and internal combustion (generators), each of which have different emission factors. Thus the area-source C&I fuel oil sales
derived above must be apportioned between these two categories. This apportionment was based
2005 Periodic PM10 Emission Inventory

37

Maricopa County, AZ

on the percentages of external and internal fuel oil combustion reported by all commercial and
institutional area sources surveyed in 2005 (shown in Table 3.2–8 below).
Annual emissions for the county are calculated by multiplying C&I fuel oil sales by the respective AP-42 emission factors for external and internal combustion, as in this example for PM10
emissions from external fuel oil combustion:
Annual PM10 emissions
from external fuel oil
combustion

= External C&I fuel oil
sales (Mgal)
= 6,895.711
= 3.72 tons PM10/yr

× PM10 emission factor for ÷ 2,000 lb/ton
external fuel oil combustion (lb/Mgal)
× 1.08
÷ 2,000

Table 3.2–8. Emission factors and annual emissions from area-source commercial/institutional fuel oil
combustion, by combustion type.
C&I fuel
Emission factors (lb/Mgal)
Annual emissions (tons/yr)
Combustion % of
oil sales
(Mgal)
type
total
PM10 PM2.5 NOx SOx NH3 PM10 PM2.5
SOx
NH3
NOx
External
66.95 6,895.711 1.08 1.08 24
7.1 0.8
3.72 3.72
82.75 24.48
2.76
Internal
33.05 3,404.121 42.5 42.5 604
39.7
–
72.34 72.34 1,028.04 67.57
0.00
Total:
100.00 10,299.912
76.06 76.06 1,110.79 92.05
2.76

Typical daily emissions for the county are calculated by dividing annual emissions by the
number of days activity occurs throughout the year, as recommended by EIIP guidance (US
EPA, 2001a):
Typical daily PM10 emissions = Annual PM10
÷ (days/week × wks/yr)
from C&I fuel oil combustion
emissions (tons/yr)
= 76.06
÷ (6 × 52)
= 487.6 lbs/day

× 2,000 lbs/ton
× 2,000

Annual and typical daily emissions within the PM10 nonattainment area are calculated by
applying the combined ratio of retail, public, office and other employment in the nonattainment
area to county-level emission calculations. (See Section 1.5.1 for a discussion of the
employment data used).
PM10 NAA emissions from area
source C&I fuel oil combustion

= Annual county PM10 × NAA:County C&I employment ratio
emissions (tons/yr)
= 76.06
= 75.51 tons PM10/yr

Table 3.2–9.
combustion.

× 0.9928

Annual and typical daily emissions from area-source commercial/institutional fuel oil

Geographic area
Maricopa County
PM10 NAA

Annual emissions (tons/yr)
PM10
PM2.5
NOx
SOx
NH3
76.06
76.06 1,110.79 92.05 2.76
75.51
75.51 1,102.80 91.39 2.74

2005 Periodic PM10 Emission Inventory

38

Typical daily emissions (lbs/day)
PM10
PM2.5
NOx
SOx
NH3
487.6
487.6 7,120.5 590.1 17.7
484.1
484.1 7,069.2 585.8 17.6

Maricopa County, AZ

3.2.5

Residential natural gas

All natural gas suppliers in Maricopa County were surveyed to gather information on the volume
of natural gas sold, by user category, within the county. Annual emissions from residential
natural gas combustion emissions were calculated by multiplying residential natural gas sales by
emission factors for residential natural gas combustion summarized in the table below (US EPA,
1998a), as follows:
Table 3.2–10. Residential natural gas combustion emission factors (in lb/MMCF).
PM10
7.6

PM2.5
7.6

NOx
94

SOx
0.6

Annual PM10 emissions = Residential natural
from residential natural
gas annual sales
gas combustion
(MMCF)

× Residential natural gas ÷ 2,000 lbs/ton
emission factor for PM10
(lbs/MMCF)

= 16,470.54
× 7.6
= 62.59 tons PM10/yr

÷ 2,000

Typical daily emissions are calculated by dividing annual emissions by the number of days (365)
that activity occurs for residential natural gas combustion, as follows:
Typical daily PM10 emissions from
residential natural gas combustion

= Annual PM10 emissions × 2,000 lbs/ton

÷ days/yr

= 62.59 tons/yr
= 342.9 lbs PM10/day

÷ 365

× 2, 000

Annual and typical daily residential natural gas emissions in the PM10 nonattainment area are
calculated by multiplying county-level emissions by the percentage of total residential
population in the PM10 nonattainment area as follows:
Annual PM10 emissions
= County annual emissions × Percentage of residential population in the NAA
from residential natural gas
combustion in the NAA
= 62.59
× 100.16%
= 62.69 tons PM10/yr
Table 3.2–11. Annual and typical daily emissions from residential natural gas combustion.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx
SOx
Maricopa County
62.59
62.59 774.12
4.94
342.9
342.9 4,241.7
27.1
PM10 NAA
62.69
62.69 775.35
4.95
343.5
343.5 4,248.5
27.1

3.2.6

Residential wood combustion

Area-source emissions from residential wood combustion are calculated based on the amount of
wood burned in fireplaces and woodstoves in Maricopa County, as recommended by EIIP
guidance (US EPA, 2001d). Residential wood combustion in the county is estimated by multiplying data on statewide residential wood combustion usage from the US Department of Energy
(2006c) by the ratio of county to state households that report use of wood for heating from the
US Census Bureau (2006a). The latest available data on residential wood use for household
2005 Periodic PM10 Emission Inventory

39

Maricopa County, AZ

heating from the US Department of Energy is for the calendar year 2003. Since all fireplaces in
homes constructed since 1999 are required by Arizona statute to be clean-burning, it is assumed
that these new homes have negligible emissions. Thus, year 2003 data is assumed to be
representative of 2005 emissions.
Maricopa County residential = Arizona residential
× Ratio of county:state households
wood usage (cords/yr)
wood usage (cords/yr)
using wood for heat
= 304,000
× 1,449 / 41,213
= 10,701 cords/yr

To calculate emissions, the amount of wood used is converted to tons by multiplying cords by
the number of cubic feet of wood in a cord and by the density of the wood used (US EPA,
2001d). Wood density is determined by weighted average of types of wood used for residential
combustion in Maricopa County, provided by the US Forest Service (USFS, 1993).
County residential
= County wood × avg. ft3 wood/cord × Wood density (lbs/ ft3) ÷ 2,000 lbs/ton
wood usage (tons/yr)
usage (cords)
= 10,701
× 79
× 31.57
÷ 2,000
= 13,344.06 tons

Annual emissions from residential wood combustion are calculated by multiplying the tons of
wood used by the PM10 emission factor for residential woodstoves and fireplaces from US EPA
(2001d), Table 2.4-1:
Annual PM10 emissions from resi- = Residential
× PM10 emission factor (lbs/ton) ÷ 2,000 lbs/ton
dential wood combustion (tons/yr)
wood usage (tons)
= 13,344.06
× 34.6
÷ 2,000
= 230.85 tons PM10/yr
Table 3.2–12. Annual wood usage, emission factors, and annual emissions from residential wood combustion.
Residential wood
Emission factors (lbs/ton)
Annual emissions (tons/yr)
usage (tons/yr)
PM10
PM2.5*
NOx
SOx
PM10
PM2.5*
NOx
SOx
13,344.06
34.6
32.2
2.6
0.4
230.85
214.69
17.35
2.67
*PM2.5 is assumed to be 93% of PM10 (Houck and Tiegs, 1998).

Typical daily emissions are calculated by apportioning wood burning activity based on heating
degree days (i.e., the number of degrees per day that the daily average temperature is below
65°F). Data provided by Arizona Department of Commerce (ADOC, 2006) indicated that there
were seven months (April–October, totaling 214 days) in 2005 where no heating degree days
were recorded. Assuming that no wood burning activity took place during those months, that
leaves 151 days were residential wood burning can be assumed to occur. Thus, typical daily
emissions are calculated by dividing annual emissions by the number of days residential wood
burning occurred, as follows:
Typical daily PM10
= Annual PM10 emissions × 2,000 lbs/ton ÷ number of days wood burning occurred
emissions from residential
wood combustion (lbs/day)
= 230.85
× 2,000
÷ 151
= 3,057.6 lbs PM10/day

Annual and typical daily emissions within the PM10 nonattainment area (NAA) are calculated by
multiplying county totals by the ratio of residential population in the nonattainment area to the
2005 Periodic PM10 Emission Inventory

40

Maricopa County, AZ

residential population in the county. See Section 1.5.1 for a further discussion of the population
used.
NAA annual emissions = County annual emissions
from residential wood
(tons/yr)
combustion (tons/yr)
= 230.85
= 231.22 tons PM10/yr

× NAA:county residential population ratio
× 1.0016

Table 3.2–13. Annual and typical daily emissions from residential wood combustion.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx
SOx
Maricopa County
230.85 214.69
17.35
2.67 3,057.6 2,843.6
229.8
35.3
PM10 NAA
231.22 215.04
17.38
2.67 3,062.5 2,848.2
230.1
35.4

3.2.7

Residential fuel oil

Emissions from residential fuel oil use were calculated using an approach similar to that used for
residential wood combustion described in Section 3.2.6. County-level residential fuel oil use
was derived from statewide totals using the ratio of county to state households that report fuel oil
use from the US Census Bureau (2006a):
Maricopa County residential = Arizona residential × Ratio of county:state households
fuel oil usage (Mgal/yr)
fuel oil use (Mgal/yr)
reporting fuel oil use
= 340
× 490 / 1,813
= 91.89 Mgal/yr

Using AP-42 emission factors, and data on heating degree days and residential housing units
described in Section 3.2.6, annual and daily emissions were calculated as shown in Table 3–2.14.
Table 3.2–14. Annual and typical daily emissions from residential fuel oil combustion.
Emission factors
Annual emissions
Typical daily emissions
(lb/Mgal)
(tons/yr)
(lbs/day)
Geographic area PM10 PM2.5 NOx SOx PM10 PM2.5 NOx SOx PM10 PM2.5 NOx SOx
Maricopa County
0.4
0.4
18
7.1
0.01 0.01 0.66 0.26
0.2
0.2
8.7
3.4
PM10 NAA
0.4
0.4
18
7.1
0.01 0.01 0.66 0.26
0.2
0.2
8.7
3.4

2005 Periodic PM10 Emission Inventory

41

Maricopa County, AZ

3.2.8

Summary of all area-source fuel combustion

Tables 3.2–15 and 3.2–16 provide a summary of annual and typical daily emissions from all fuel
combustion, for Maricopa County and the PM10 nonattainment area, respectively.
Table 3.2–15. Annual and typical daily emissions from all area-source fuel combustion for Maricopa County.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Fuel combustion type
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
Industrial natural gas
16.51
16.51
308.43
1.30
6.81
105.9
105.9 1,977.1
8.3
Industrial fuel oil
247.82
247.82 3,443.60 329.29
14.18 1,588.6 1,588.6 22,074.4 2,110.8
Comm./inst. natural gas
60.15
60.15 1,146.39
4.72
3.79
385.6
385.6 7,348.6
30.3
Comm./inst. fuel oil
76.06
76.06 1,110.79 92.05
2.76
487.6
487.6 7,120.5 590.1
Residential natural gas
62.59
62.59
774.12
4.94
342.9
342.9 4,241.7
27.1
Residential wood
230.85
214.69
17.35
2.67
3,057.6 2,843.6
229.8
35.3
Residential fuel oil
0.01
0.01
0.66
0.26
0.2
0.2
8.7
3.4
Total:
694.01
677.85 6,801.33 435.23
27.55 5,968.4 5,754.4 43,000.7 2,805.4
Table 3.2–16. Annual and typical daily emissions from all area-source fuel combustion for the PM10 NAA.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Fuel combustion type
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
Industrial natural gas
16.40
16.40
306.33
1.29
6.77
104.7
104.7 1,955.5
8.2
Industrial fuel oil
246.14
246.14 3,420.18 327.05
14.08 1,577.8 1,577.8 21,924.3 2,096.5
Comm./inst. natural gas
59.72
59.72 1,138.13
4.69
3.77
381.5
381.5 7,270.0
30.0
Comm./inst. fuel oil
75.51
75.51 1,102.80 91.39
2.74
484.1
484.1 7,069.2 585.8
Residential natural gas
62.69
62.69
775.35
4.95
343.5
343.5 4,248.5
27.1
Residential wood
231.22
215.04
17.38
2.67
3,062.5 2,848.2
230.1
35.4
Residential fuel oil
0.01
0.01
0.66
0.26
0.2
0.2
8.7
3.4
Total:
691.70
675.51 6,760.83 432.30
27.36 5,954.3 5,739.9 42,706.4 2,786.5

3.3

Industrial processes

3.3.1

Chemical manufacturing

Emissions from area-source chemical manufacturing were calculated by the “scaling up” method
as described in EPA emission inventory guidance (US EPA, 2001a). This method combines
detailed emissions data from a subset of sources, and county-level employment data from the US
Census Bureau (2006b) to develop a per-employee emission factor that is then used to estimate
emissions from all sources in an industry category.
The most recent data from the US Census Bureau’s County Business Patterns (CBP) for 2004
employment, were used. Where CBP employment estimates were presented as a range, the
midpoint values was chosen for these calculations. Table 3–3.1 shows the NAICS codes and
employment data used to calculate emissions from chemical manufacturing.

2005 Periodic PM10 Emission Inventory

42

Maricopa County, AZ

NH3
43.7
90.9
24.3
17.7

176.6

NH3
43.2
90.3
24.1
17.6

175.1

Table 3.3–1. NAICS codes and descriptions for chemical manufacturing.
NAICS
US Census
Code
employment data
Description
32532 Pesticide & Other Agricultural Chemical mfg.
0–19
32552 Adhesive mfg.
100–249
32591 Printing Ink mfg.
250–499
324122 Asphalt Shingle & Coating Materials mfg.
20–99
325188 All Other Basic Inorganic Chemical mfg.
100–249
325412 Pharmaceutical Preparation mfg.
500–999
325510 Paint & Coating mfg.
20–99
325611 Soap & Other Detergent mfg.
20–99
325991 Custom Compounding of Purchased Resins
100–249
325998 All Other Miscellaneous Chemical Product & Preparation mfg.
20–99
424690 Other Chemical & Allied Products Merchant Wholesalers
968
Total:

Value
used
10
175
375
60
175
750
60
60
175
60
968
2,868

Since there were no point sources in this category, area-source employment estimate is used to
“scale up” emissions reported from those facilities surveyed in 2005 as follows:
Area-source PM10 = Emissions from surveyed area sources × Total area-source employment
emissions from
Employment at surveyed area sources
chemical mfg.
=
34.26 tons of PM10/yr
× 2,868 employees
1,280 employees
= 76.77 tons PM10/yr

PM10 typical daily emissions are calculated based on the operating schedule data reported by
chemical manufacturing facilities. From annual emission surveys, the modal values were
identified for two items: days/week and annual activity. This data was used to calculate typical
daily emissions as follows:
Typical daily PM10 =
emissions from
chemical mfg.
=
=

Annual emissions (tons/yr)
Days/week × Weeks/year

× 2,000 lbs
ton

76.77
5 × 52

× 2,000

590.5 lbs PM10/day

Annual and typical daily emissions for the PM10 nonattainment area were calculated by
multiplying the Maricopa County emission totals by the percentage industrial employment
within the nonattainment area. (See Section 1.5.1 for a discussion of the employment data used.)
PM10 emissions from
= Annual Maricopa County
area-source chemical mfg.
emissions
in the PM10 NAA (tons/yr)
= 76.77 tons/yr

× NAA:county ratio of
industrial employment
× .9932

= 76.25 tons PM10/yr

Table 3.3–2 summarizes annual and typical daily emissions from chemical manufacturing in
both Maricopa County and the PM10 nonattainment area.

2005 Periodic PM10 Emission Inventory

43

Maricopa County, AZ

Table 3.3–2.

Annual and typical daily emissions from area-source chemical manufacturing.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area PM10
PM2.5
NOx
SOx
NHx
PM10
PM2.5
NOx
SOx
NHx
Maricopa County
76.77
38.85
0.39
0.21
0.34
590.5
298.9
3.0
1.6
2.6
PM10 NAA
76.25
38.59
0.38
0.21
0.34
586.5
296.8
3.0
1.6
2.6

3.3.2

Food and kindred products

3.3.2.1 Commercial cooking
Emissions from commercial cooking were estimated for five source categories based on equipment type. These equipment types include: chain-driven (conveyorized) charbroilers (SCC
2302002100), under-fired charbroilers (2302002200), flat griddles (2302003100), clamshell
griddles (2302003200), and deep-fat fryers (2302003000). Emission inventory methods outlined
in EPA guidance (US EPA, 2006) for these source categories include emissions from all meat
types (hamburger, steak, fish, pork, and chicken) and five restaurant types (ethnic, fast food,
family, seafood, and steak & barbeque).
Data obtained from MCAQD’s eating and drinking establishments permit database indicated that
10,238 restaurants operated in Maricopa County in 2005. The percent of restaurants in Maricopa
County for the five restaurant types was obtained from a commercial business database (Harris
InfoSource, 2003). The percent of restaurants for each restaurant type was multiplied by the total
number of restaurants operated in Maricopa County in 2005 to derive the number of restaurants
for each restaurant type as shown in Table 3.3–3.
Table 3.3–3. Maricopa County restaurants by type.
Restaurant category
Ethnic food
Fast food
Family
Seafood
Steak & barbecue
Unrelated restaurant types e.g., lunchroom, bars,…
All restaurants

Percentage
14.47
15.35
3.64
0.61
1.15
64.79
100.00

# of restaurants
1,481
1,571
372
62
118
6,633
10,238

Using the number of restaurants for each restaurant type, along with the default emission factors
and equations from EPA (2006), emissions for each combination of equipment type, restaurant
type, and meat type were calculated, and the results were summed to estimate annual emissions
for each type of cooking equipment, as shown in Table 3.3–4.
Table 3.3–4.

Annual emissions from commercial cooking equipment, by equipment type.
Annual emissions (tons/yr)
Equipment type
PM10
PM2.5
Chain-driven charbroilers
155.64
150.88
Underfired charbroilers
1,071.56
1,035.86
Deep fat fryers
0.00
0.00
Flat griddles
282.14
214.43
Clamshell griddles
18.64
15.79
Totals:
1,527.98
1,416.96

Commercial cooking is assumed to occur uniformly throughout the year, therefore, it was
assumed that the annual activity was 7 days/week.
2005 Periodic PM10 Emission Inventory

44

Maricopa County, AZ

Table 3.3–5.

Typical daily emissions from commercial cooking equipment, by equipment type.
Typical daily emissions (lbs/day)
Equipment type
PM10
PM2.5
Chain-driven charbroilers
855.2
829.0
Underfired charbroilers
5,887.7
5,691.5
Deep fat fryers
0.0
0.0
Flat griddles
1,550.2
1,178.2
Clamshell griddles
102.4
86.5
Totals:
8,395.5
7,785.5

Annual and typical daily emissions for the PM10 nonattainment area were calculated by multiplying the Maricopa County emission totals by the percentage population within the nonattainment
area of 100.78%. (See Section 1.5.1 for a discussion of the population data used.) Table 3.3–6
summarizes the annual and typical daily emissions from commercial cooking for Maricopa
County and the PM10 NAA.
Table 3.3–6.

Annual and typical daily emissions from commercial cooking equipment.
Maricopa County
PM10 nonattainment area
Typical daily
Typical daily
Annual emissions
emissions
Annual emissions
emissions
(lbs/day)
(lbs/day)
(tons/yr)
(tons/yr)
Equipment type
PM10
PM2.5
PM10
PM2.5
PM10
PM2.5
PM10
PM2.5
Chain-driven charbroilers
155.64 150.88
855.2
829.0 156.86 152.05
861.9
835.5
Underfired charbroilers
1,071.56 1,035.86 5,887.7 5,691.5 1,079.92 1,043.94 5,933.6 5,735.9
Deep fat fryers
0.00
0.00
0.0
0.0
0.00
0.0
0.0
0.0
Flat griddles
282.14 214.43 1,550.2 1,178.2 284.34 216.10 1,562.3 1,187.4
Clamshell griddles
18.64
15.79
102.4
86.8
18.79
15.91
103.2
87.4
Totals:
1,527.98 1,416.96 8,395.5 7,785.5 1,539.90 1,428.01 8,461.0 7,846.2

3.3.2.2 Grain handling/processing
Annual emissions from area-source grain handling and processing operations were derived from
annual emission reports submitted by permitted sources. It was assumed that there were no
significant unpermitted sources within Maricopa County. Note that larger operations are treated
as point sources, and addressed in Chapter 2.
Typical daily emissions were calculated based on reported activity data (days per week) for each
individual process, and then summed. Nearly all processes reported operating on either a 5- or 6day week. As all facilities addressed in this source category are located within the PM10
nonattainment area, emission totals for both areas are equal. Annual and typical daily emissions
are shown in Table 3.3–7.
Table 3.3–7.

Annual and typical daily emissions from area-source grain handling and processing.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Area
PM10
PM2.5
PM10
PM2.5
Maricopa County
12.64
2.68
94.7
20.5
PM10 NAA
12.64
2.68
94.7
20.5

2005 Periodic PM10 Emission Inventory

45

Maricopa County, AZ

3.3.2.3 Ammonia cold storage
Area-source emissions from ammonia cold storage are estimates of ammonia emissions from
food and kindred products industrial sources that use ammonia for refrigeration of food products.
Emission calculations are based on the number of employees in the food and kindred products
industry classification (NAICS codes 311, 312) as reported by the 2004 County Business
Patterns (US Census Bureau, 2006b). Annual emissions are calculated by multiplying
employment numbers by the emission factor for ammonia cold storage as listed in Table 6-5 of
“Development and Selection of Ammonia Emission Factors” (Battye et al., 1994) as follows:
Annual NH3 emissions = Number of employees
from ammonia cold
in relevant industries
storage (tons/yr)
(from CBP)
= 8,213
= 1,695.98 tons NH3/yr

× NH3 emission
÷ 2,000 lbs/ton
factor (lb/employee-yr)
× 413

÷ 2,000

Typical daily emissions are calculated by dividing annual emissions by the number of days per
year that activity occurred, as follows:
Typical daily = Annual emissions (tons/yr) × 2,000 lbs/ton
NH3 emissions
(lbs/day)
= 1,695.98
× 2,000
= 10.871.7 lbs NH3/day

÷ (weeks/year × days/week)
÷ (52 × 6)

Annual and typical daily emissions for the PM10 nonattainment area are calculated by
multiplying Maricopa County emissions by the ratio of County industrial employment that
occurs in the PM10 nonattainment area. (See Section 1.5.1 for a discussion of employment data).
Annual NH3 emissions from
ammonia cold storage in the
PM10 NAA (tons/yr)

= Annual county emissions (tons/yr)

× NAA:County Industrial employment ratio

= 1,695.98
= 1,684.45 tons NH3/yr

× 0.9932

Annual and typical daily NH3 emissions from ammonia cold storage.
Annual emissions
Typical daily
Geographic area
(tons/yr)
emissions (lbs/day)
Maricopa County
1,695.98
10,871.7
PM10 NAA
1,684.45
10,797.8

Table 3.3–8.

3.3.3

Secondary metal production

Annual emissions from secondary metal production facilities were derived from annual emission
reports from permitted sources. As this category consists primarily of foundries, it was assumed
that there were no significant unpermitted sources within Maricopa County. Since all facilities
considered in this section are located within the PM10 nonattainment area, total emission values
for the county and the PM10 NAA from area-source secondary metal production are equal.

2005 Periodic PM10 Emission Inventory

46

Maricopa County, AZ

Table 3.3–9.

Annual and typical daily emissions from secondary metal production.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
Maricopa County
10.95
9.27
4.53
0.05
1.34
79.0
66.3
25.0
0.4
10.3
PM10 NAA
10.95
9.27
4.53
0.05
1.34
79.0
66.3
25.0
0.4
10.3

3.3.4

Non-metallic mineral processes

The primary contributors to this source category include concrete batch plants, ceramic clay and
tile manufacturing, brick manufacturing, and gypsum mining. Emissions from this source were
derived from annual emission reports from permitted facilities. Since all permitted facilities in
this category were surveyed in 2005, it was assumed that there were no significant unpermitted
sources within Maricopa County. Note that larger operations are treated as point sources, and
addressed in Chapter 2. Some portable concrete batch operations which operate within Maricopa
County for only part of the year are issued air quality permits by the Arizona Department of
Environmental Quality (ADEQ). All state-permitted portable sources are addressed in Section
3.3.11.
Typical daily emissions are calculated based on the operating schedule data reported by surveyed
facilities. Annual and typical daily emissions for the PM10 nonattainment area were derived
based on the location data of the individual facilities. County permitted portable sources with no
location data were assumed to operate within the PM10 nonattainment area as a conservative
estimate.
Table 3.3–10 summarizes annual and typical daily emissions from non-metallic mineral
processing in both Maricopa County and the PM10 nonattainment area.
Table 3.3–10. Annual and typical daily emissions from area-source non-metallic mineral products.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
PM10
PM2.5
Maricopa County
431.60
222.71
3,030.4
1,517.2
PM10 NAA
430.89
222.17
3,024.9
1,513.0

3.3.5

Mining and quarrying

Annual emissions from area-source mining and quarrying (sand and gravel) operations were
derived from annual emission reports submitted by permitted sources. It was assumed that there
were no significant unpermitted sources within Maricopa County. Note that larger mining and
quarrying operations are treated as point sources, and addressed in Chapter 2. Some portable
mining and quarrying operations which operate within Maricopa County for only part of the year
are issued air quality permits by the Arizona Department of Environmental Quality (ADEQ). All
state-permitted portable sources are addressed in Section 3.3.11.
Typical daily emissions were calculated based on reported activity data (days per week) for each
individual process, and then summed. Nearly all processes reported operating on either a 5- or 6day week. Emissions within the PM10 nonattainment area were identified using information on
the location of each permitted facility. County permitted portable sources with no location data
were assumed to operate within the PM10 nonattainment area as a conservative estimate. Annual
and daily emissions are shown in Table 3.3–11.
2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

Table 3.3–11. Annual and typical daily emissions from area-source mining and quarrying operations.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic Area
PM10
PM2.5
PM10
PM2.5
Maricopa County
62.97
17.38
409.1
112.1
PM10 NAA
54.77
15.52
347.6
98.2

3.3.6

Wood product manufacturing

Emissions from wood product manufacturing were calculated by the “scaling up” method as
described in EPA emission inventory guidance (US EPA, 2001a). This method combines
detailed emissions data from a subset of sources, and county-level employment data from the US
Census Bureau (2006b) to develop a per-employee emission factor that is then used to estimate
emissions from all sources in an industry category.
The most recent data from the US Census Bureau’s County Business Patterns (CBP) for 2004
employment were used. Where CBP employment estimates were presented as a range, the
midpoint values was chosen for these calculations. Table 3.3–12 shows the NAICS codes and
employment data used to calculate emissions from wood product manufacturing.
Table 3.3–12. NAICS codes and descriptions for wood product manufacturing.
NAICS
US Census
Code
Description
employment data
321--Wood products manufacturing
7430
337--Furniture and related products manufacturing
7342
Total:

Value
used
7430
7342
14,772

Some facilities in this category are considered point sources, and have been addressed in Chapter
2. To avoid double-counting, employment at point sources is subtracted from total employment
as follows:
Total area-source
employment in
wood products

= Total employment (from US
– Employment at point sources
Census’ County Business Patterns)
(from annual emission reports)
= 14,772

– 4,216

= 10,556 employees

Annual emissions are calculated by “scaling up” area-source emissions reported from those
facilities surveyed in 2005 as follows:
Total area-source = Emissions from surveyed area sources × Total area-source employment
emissions
Employment at surveyed area sources
Area-source PM10 =
51.792 tons of PM10/yr
emissions from
2,564 employees
wood products
= 213.23 tons PM10/yr

× 10,556 employees

Typical daily emissions are calculated in the same method as annual emissions, only using
surveyed daily emissions instead of annual totals. Annual and typical daily emissions for the
PM10 nonattainment area were calculated by multiplying the Maricopa County emission totals by
2005 Periodic PM10 Emission Inventory

48

Maricopa County, AZ

the percentage of industrial employment within the nonattainment area. (See Section 1.5.1 for a
discussion of the employment data used.)
PM10 emissions from
= Annual Maricopa County
area-source wood products
emissions
in the PM10 NAA (tons/yr)
= 213.23 tons/yr

× NAA:county ratio of
industrial employment
× .9932

= 211.78 tons PM10/yr

Table 3.3–13 summarizes annual and typical daily emissions from wood products manufacturing
in both Maricopa County and the PM10 nonattainment area.
Table 3.3–13. Annual and typical daily emissions from area-source wood products manufacturing.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic Area
PM10
PM2.5
PM10
PM2.5
Maricopa County
213.23
149.95
1,657.9
1,170.0
PM10 NAA
211.78
148.93
1,646.6
1,162.0

3.3.7

Rubber/plastics manufacturing

Emissions from area-source rubber and plastic manufacturing facilities were calculated by the
“scaling up” method as described in EPA emission inventory guidance (US EPA, 2001a). This
method combines detailed emissions data from a subset of sources, and county-level
employment data from the US Census Bureau (2006b) to develop a per-employee emission
factor that is then used to estimate emissions from all sources in an industry category. The most
recent data from the US Census Bureau’s County Business Patterns (CBP) for 2004 employment,
were used. Where CBP employment estimates were presented as a range, the midpoint values
were chosen for these calculations. Table 3.3–14 shows the NAICS codes and employment data
used to calculate emissions from rubber and plastic manufacturing facilities.
Table 3.3–14. NAICS codes and descriptions for rubber and plastic manufacturing facilities.
NAICS
US Census
Code
employment data
Description
322130 Paperboard Mills
0 – 19
323116 Manifold Business Forms Printing
325991 Custom Compounding of Purchased Resins
100 – 249
326122 Plastics Pipe & Pipe Fitting Mfg.
250 – 499
32613 Laminated Plastics Plate, Sheet (except Packaging), & Shape Mfg.
0 – 19
32614 Polystyrene Foam Product Mfg.
326160 Plastics Bottle Mfg.
32619 Other Plastics Product Mfg.
326212 Tire Retreading
20 – 99
32622 Rubber & Plastics Hoses & Belting Mfg.
20 – 99
326299 All Other Rubber Product Mfg.
100 – 249
327991 Cut Stone & Stone Product Mfg.
333415 HVAC Equipment Mfg.
500 – 999
336612 Boat Building
0 – 19
33992 Sporting & Athletic Goods Mfg.
423930 Recyclable Material Merchant Wholesalers
Total:

2005 Periodic PM10 Emission Inventory

49

Value
used
10
375
175
375
10
316
161
4,117
60
60
175
411
750
10
1,212
503
8,720

Maricopa County, AZ

Some facilities in this category are considered point sources, and have been addressed in Chapter
2. To avoid double-counting, employment at point sources is subtracted from total employment
as follows:
Total area-source employment = Total employment (from US
in rubber & plastic product
Census’ County Business Patterns)
manufacturing
= 8,720

– Employment at point sources
(from annual emission reports)
– 2,536

= 6,184 employees

This area-source employment estimate is used to “scale up” emissions reported from those
facilities surveyed in 2005 as follows:
Total area-source PM10
emissions from rubber/
plastic product mfg.

= Emissions from surveyed area sources × Total area-source employment
Employment at surveyed area sources
=

66.09 tons of PM10/yr
1,119 employees
= 365.26 tons PM10/yr

× 6,184 employees

Typical daily emissions are calculated based on the operating schedule data reported by
rubber/plastics products manufacturing facilities. From annual emission surveys, the modal
values were identified for two items: days/week and annual activity. This data was used to
calculate typical daily emissions as follows:
Typical daily PM10 =
emissions from
rubber & plastic
manufacturing
=
=

Annual emissions (tons/yr)
Days/week × Weeks/year

× 2,000 lbs
ton

365.26
5 × 52
2,809.7 lbs PM10/day

× 2,000

Annual and typical daily emissions for the PM10 nonattainment area were calculated by multiplying the Maricopa County emission totals by the percentage industrial employment within the
nonattainment area. (See Section 1.5.1 for a discussion of the employment data used.)
PM10 emissions from
= Annual Maricopa County
area-source plastic/rubber
emissions
in the PM10 NAA (tons/yr)
= 365.26 tons PM10/yr
= 362.77 tons PM10/yr

× NAA:county ratio of
industrial employment
× 0.9932

Table 3.3–15 summarizes annual and typical daily emissions from rubber/plastic products
manufacturing in both Maricopa County and the PM10 nonattainment area.
Table 3.3–15. Annual and typical daily emissions from area-source rubber/plastic products manufacturing.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic Area
PM10
PM2.5
PM10
PM2.5
Maricopa County
365.26
236.52
2,809.7
1,819.4
PM10 NAA
362.77
234.91
2,790.6
1,807.0

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

3.3.8

Fabricated metal products manufacturing

Emissions from fabricated metal products manufacturing were calculated by the “scaling up”
method as described in EPA emission inventory guidance (US EPA, 2001a). This method
combines detailed emissions data from a subset of sources, and county-level employment data
from the US Census Bureau (2006b) to develop a per-employee emission factor that is then used
to estimate emissions from all sources in an industry category.
The most recent data from the US Census Bureau’s County Business Patterns (CBP) for 2004
employment were used. CBP employment data for NAICS code 332* (fabricated metal products
manufacturing) indicated that there were 13,400 employees in this industry in Maricopa County.
Some facilities in this category are considered point sources, and have been addressed in Chapter
2. To avoid double-counting, employment at point sources is subtracted from total employment
as follows:
Total area-source
employment in
fab. metal products

= Total employment (from US
– Employment at point sources
Census’ County Business Patterns)
(from annual emission reports)
= 13,400
= 12,709 employees

– 691

Annual emissions are calculated by “scaling up” area-source emissions reported from those
facilities surveyed in 2005 as follows:
Total area-source = Emissions from surveyed area sources × Total area-source employment
emissions
Employment at surveyed area sources
Area-source PM10 =
12.519 tons of PM10/yr
emissions from
1,145 employees
fab. metal products
= 138.96 tons PM10/yr

× 12,709 employees

Typical daily emissions are calculated in the same method as annual emissions, only using
surveyed daily emissions instead of annual totals. Annual and typical daily emissions for the
PM10 nonattainment area were calculated by multiplying the Maricopa County emission totals by
the percentage of industrial employment within the nonattainment area. (See Section 1.5.1 for a
discussion of the employment data used.)
PM10 emissions from
= Annual Maricopa County
area-source fab. metal prod. emissions
in the PM10 NAA (tons/yr)
= 138.96 tons/yr
= 138.01 tons PM10/yr

× NAA:County ratio of
industrial employment
× 0.9932

Table 3.3–16 summarizes annual and typical daily emissions from fabricated metal products
manufacturing in both Maricopa County and the PM10 nonattainment area.

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

Table 3.3–16. Annual and typical daily emissions from area-source fabricated metal product manufacturing.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic Area
PM10
PM2.5
PM10
PM2.5
Maricopa County
138.96
119.88
1,579.3
1,404.1
PM10 NAA
138.01
119.06
1,568.6
1,394.5

3.3.9

Construction

Maricopa County’s air quality permits database was used to identify all dust control permits
issued during 2005. A total of 5,257 permits were issued, comprising a total of 68,664 acres
(Table 3.3–17). Data requested on each dust control permit application includes the project type
and acreage. It was assumed there is no unpermitted earthmoving activity.
Table 3.3–17. 2005 Maricopa County dust control permits issued, by type.
Dust Control Permit
Reported
Project Type
Acres
Residential
47,324.4
Commercial
10,163.0
Road construction
4,247.5
Trenching
470.3
Demolition
584.3
Weed control
177.7
Site prep / land development
5,607.0
Temp. storage yard
89.3
Totals:
68,663.5

The Western Regional Air Partnership (WRAP) Fugitive Dust Handbook (WRAP, 2006a)
provides different emission factors for residential (single-family houses and apartment
buildings), nonresidential, road, and general construction. MCAQD used the WRAP suggested
emission factors except for the following activities:
•

The WRAP Fugitive Dust Handbook recommended using 0.42 ton PM10/acre-month for road
construction to account for the large amount of dirt moved during the construction of
roadways. However, the South Coast Air Quality Management District (SCAQMD) and the
Clark County Department of Air Quality and Environmental Management estimated a
percentage of their road construction projects did not involved large-scale earthmoving
activities and therefore they used an average emission factor for road construction (.1895 ton
PM10/acre-month and 0.265 ton PM10/acre-month, respectively). Because Maricopa County
and Clark County have similar population growth, climatic, and PM10 sources, MCAQD used
the Clark County road construction emission factor of 0.265 tons/acre-month to estimate
emissions from road construction projects (Clark County, 2001).

•

Specific emission factors were not available in the WRAP Fugitive Dust Handbook for
trenching, demolition, weed control, and temporary storage yard activities; thus, the general
construction emission factor of 0.11 tons PM10/acre-month was used to estimate emissions
from these activities.

Information was not readily available regarding the breakout of residential construction activity
between single-family and multi-family residential construction; thus, acreage for residential

2005 Periodic PM10 Emission Inventory

52

Maricopa County, AZ

construction was allocated based on single-family and multi-family household percentages (See
Section 1.5.1 for single-family and multi-family household percentages used).
Estimates for the duration of house and apartment construction were obtained from EIIP
guidance (US EPA, 2002). Estimates for the duration of nonresidential construction and road
construction were obtained from the WRAP Fugitive Dust Handbook (WRAP, 2006a). No
estimates for the duration of trenching, demolition, weed control, site prep/land development,
and temporary storage yard activities were available; thus, MCAQD assumed the following:
ƒ
ƒ
ƒ

1-month duration for trenching, demolition, and weed control.
8-month duration for site prep/land development activities (weighted average of residential
and commercial duration) because the duration depends on the project type and size.
12-month duration for temporary storage yard activities because these activities are
frequently associated with road construction.

The average duration of construction activity and emission factors for each project type are
shown below in Table 3.3–18.
Table 3.3–18. Average project duration and emission factor, by project type.
Average
Emission factor
Duration
(tons PM10/
Project Type
(months)
acre-month)
6
Residential: single-family
0.032
12
Residential: multi-family
0.11
11
Commercial
0.19
12
Road construction
0.265
1
Trenching
0.11
1
Demolition
0.11
1
Weed control
0.11
8
Site prep / land development
0.11
12
Temp. storage yard
0.11

County-wide annual uncontrolled PM10 emissions for each construction category were then
calculated as follows:
Annual uncontrolled
PM10 emissions
Example:
Annual uncontrolled PM10
emissions from single-family
residential construction

= total acres/yr

× no. months

× emission factor
(tons of PM10/acre-month)

= 35,493.3 acres/yr

× 6 months

× 0.032 tons PM10/acre-month

= 6,814.72 tons PM10/yr

A control efficiency of 90% was applied to the uncontrolled emissions calculations. A recent
rule effectiveness study by Maricopa County (contained in Appendix 2.2) indicates a 51%
compliance rate with Maricopa County Rule 310 on dust control at construction sites. Thus, an
overall control effectiveness of 44.1% (= 90% × 49%) was applied. Controlled PM10 emissions
were calculated as follows:
Annual controlled
PM10 emissions

= Uncontrolled PM10 emissions (tons/yr) × [1 – (control efficiency × rule effectiveness)]

2005 Periodic PM10 Emission Inventory

53

Maricopa County, AZ

Example:
Annual controlled PM10 emissions from
single-family residential construction

= 6,814.72 tons × [1 – (90% control × 51% rule effectiveness)]
=3,686.76 tons PM10/yr

PM2.5 emissions were calculated as 10% of PM10 emissions (WRAP, 2006a). Table 3.3–19
summarizes the calculations for each construction category.
Table 3.3–19. Annual emissions from construction (tons/yr) for Maricopa County.
Total acreEmission factor
Uncontrolled
Controlled
months
(tons/acre-month)
PM10
PM10
Project Type
Residential: single-family
212,960.0
0.032
6,814.72
3,686.76
Residential: multi-unit
141,973.3
0.11
15,617.07
8,448.83
Commercial
111,793.1
0.19
21,240.69
11,491.21
Road construction
50,970.2
0.265
13,507.11
7,307.35
Trenching
470.3
0.11
51.73
27.99
Demolition
584.3
0.11
64.27
34.77
Weed control
177.7
0.11
19.55
10.58
Site prep/land development
44,855.8
0.11
4,934.13
2,669.37
Temporary storage yard
1,071.5
0.11
117.86
63.76
Totals:
62,367.14
33,740.62

Controlled
PM2.5
368.68
844.88
1,149.12
730.73
2.80
3.48
1.06
266.94
6.38
3,374.06

Dust control permit site location data was used to determine construction activity that occurred in
the Maricopa County PM10 nonattainment area. The same average duration of construction
activity and emission factors used to estimate Maricopa County emissions (see Table 3.3–18)
were applied to construction activity in the Maricopa County PM10 nonattainment area. Table
3.3–20 summarizes Maricopa County PM10 nonattainment area construction activity and
calculations for each project type.
Table 3.3–20. Annual emissions from construction (tons/yr) for the Maricopa County portion of PM10 NAA.
Total
Total acreEF (tons/
Uncontrolled Controlled Controlled
Project Type
Acres
months
acre-month)
PM10
PM10
PM2.5
Residential: single-family
32,631.6
195,789.5
0.032
6,265.26
3,389.51
338.95
Residential: multi-unit
10,877.2
130,526.3
0.11
14,357.90
7,767.62
776.76
Commercial
9,740.3
107,143.0
0.19
20,357.16
11,013.23
1,101.32
Road construction
4,199.2
50,390.8
0.265
13,353.55
7,224.27
722.43
Trenching
450.5
450.5
0.11
49.56
26.81
2.68
Demolition
580.6
580.6
0.11
63.86
34.55
3.46
Weed control
177.7
177.7
0.11
19.55
10.58
1.06
Site prep/land development
4,905.6
39,244.6
0.11
4,316.90
2,335.44
233.54
Temporary storage yard
89.3
1,071.48
0.11
117.86
63.76
6.38
Totals:
63,652.0
58,901.61
31,865.77
3,186.58

The Pinal County Air Quality Department (PCAQD) provided construction emission estimates
for the Pinal County portion of the PM10 nonattainment. PCAQD estimated that 1.3 percent of
the Pinal County construction activity occurred in the Pinal County portion of the PM10
nonattainment area, thus, annual and typical daily emission for the Pinal County portion of the
PM10 nonattainment area was calculated by multiplying the Pinal County emission totals by 1.3
percent. PCAQD estimates incorporated the same average duration of construction activity,
emission factors, control efficiency, and rule effectiveness as Maricopa County's estimates.

2005 Periodic PM10 Emission Inventory

54

Maricopa County, AZ

Table 3.3–21. Annual emissions from construction (tons/yr) for the Pinal County portion of the PM10 NAA.
PM2.5
Project Type
PM10
Residential: single-family
22.29
2.23
Residential: multi-family
152.56
15.26
Commercial
72.32
7.23
Road construction
12.15
1.21
Trenching
0.02
0.00
Demolition
0.00
0.00
Weed control
0.00
0.00
Site prep/land development
0.00
0.00
Temporary storage yard
4.72
0.47
Totals:
264.08
26.41

It was assumed that construction activity occurs 6 days per week and evenly throughout the year.
Thus, typical daily emissions were calculated by dividing annual emissions by 312 (6 days/wk ×
52 wks/yr).
Table 3.3–22. Annual and typical daily emissions from construction.
PM10 NAA

Maricopa County
Annual emissions
(tons/yr)

Typical daily emissions
(lbs/day)

Annual emissions
(tons/yr)

Typical daily emissions
(lbs/day)

Construction Type
PM10
PM2.5
PM10
PM2.5
PM10
PM2.5
Residential
12,135.60
1,213.56
77,792.3
7,779.2
11,331.99
1,133.20
Commercial
11,491.21
1,149.12
73,661.6
7,366.2
11,085.55
1,108.55
Road construction
7,307.35
730.73
46,842.0
4,684.2
7,236.42
723.64
Construction other*
2,806.46
280.65
17,990.2
1,799.0
2,475.89
247.59
Total
33,740.62
3,374.06
216,286.0
21,628.6
32,129.85
3,212.98
*Includes: trenching, demolition, weed control, site prep/land development, and temp. storage yd.

PM10
72,641.0
71,061.2
46,387.3

PM2.5
7,264.1
7,106.1
4,638.7

15,871.1
205,960.6

1,587.1
20,596.1

3.3.10 Electrical equipment manufacturing
Emissions from electric equipment manufacturing were derived from annual emission reports
submitted by permitted sources. It was assumed that there were no significant unpermitted
sources within Maricopa County. Note that larger operations are treated as point sources, and
addressed in Chapter 2.
Typical daily emissions were calculated based on reported activity data (days per week) for each
individual process, and then summed. Nearly all processes reported operating on either a 5- or 6day week. As all facilities addressed in this source category are located within the PM10
nonattainment area, emission totals for both areas are equal. Annual and typical daily emissions
are shown in Table 3.3–23.
Table 3.3–23. Annual and typical daily emissions from area-source electric equipment manufacturing.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
Maricopa County
5.24
3.25
0.01
4.59
0.96
40.3
25.0
0.1
35.3
7.4
PM10 NAA
5.24
3.25
0.01
4.59
0.96
40.3
25.0
0.1
35.3
7.4

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Maricopa County, AZ

3.3.11 State-permitted portable sources
The Arizona Department of Environmental Quality (ADEQ) retains the authority to permit
certain categories of sources within Maricopa County, including portable sources. MCAQD
requested information from ADEQ for all ADEQ-permitted sources that reported any activity in
Maricopa County during 2002. Annual total emissions for most pollutants were provided, along
with information on the facility type, and information on the location of the site(s) during the
year. Permits were classified into four major types: asphalt batch, concrete batch, crushing/
screening, and other (including soil remediation, generators, etc.). From this information,
emissions that occurred within Maricopa County were estimated as in the following example.
Data provided:
Source information:
Permit type:
Operating schedule:

D.G.Huskin Construction 1000677
Portable crushing/screening plant
Operated from 5/31-6/29 Gila Bend SR 85 (Maricopa Co.); 6/30-8/30 Buckeye SR 85
(Maricopa Co.) 9/1-10/24 Cordes Jct I-17 (Yavapai Co.), 10/25-11/09 Williams SR 64
(Coconino Co.) and 11/10-12/31 Parker SR 95 (La Paz Co.)
Total annual emissions:
PM10
PM2.5 1
NOx
SOx
(tons/yr)
1.415
0.708
10.067
4.062
1. PM2.5 was assumed to be 50% of reported PM10 for crushing/screening operations.

Using this information, calculations were made to determine:
Total operating days in 2005:
216 = 1 (May) + 30 (June) + … + 31 (Dec.)
Total operating days in Maricopa County: 92 = 1 (May ) + 30 (June) + … + 30 (Aug.)

All emissions were assumed to be equally distributed among all reported days of operation.
First, the total emissions attributable to activity in Maricopa County was calculated as follows:
Annual PM10 emissions = Total annual emissions × operating days in Maricopa County
in Maricopa County
(tons/yr)
total operating days in 2002
= 1.415

×

92
216

= 0.61 tons PM10/yr

Typical daily emissions were then calculated as follows:
Typical daily =total emissions attributable to activity in Maricopa County × 2,000 lbs
emissions
number of operating days in Maricopa County
ton
(lbs/day)
= 0.61 tons × 2,000 lbs
92 days
ton
= 13.2 lbs PM10/day

2005 Periodic PM10 Emission Inventory

56

Maricopa County, AZ

Table 3.3–24 summarizes the annual and typical daily emissions for all ADEQ-permitted
portable sources that operated within Maricopa County at some point during 2005. Since no
precise location data was not available for all permits, all emissions are conservatively assumed
to have originated within the PM10 nonattainment area, therefore emissions in Maricopa County
and the PM10 nonattainment area are equal.
Table 3.3–24. Emissions from ADEQ-permitted portable sources.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx
SOx
101.70 42.18
554.60 142.20
844.2
389.8
5,377.5 1,431.7
Total:

3.3.12 Paved/unpaved road travel on industrial sites
This section addresses emissions from travel on paved and unpaved roads within the boundaries
of a permitted facility. Emissions from motor vehicle travel on public and private roads is
addressed in Chapter 5, Mobile Sources, and road travel emissions from facilities considered
point sources are addressed in Chapter 2, Point Sources. PM10 emissions from this source
category were derived from annual emission reports from permitted sources, using AP-42
equations based on vehicle size and average speed (US EPA, 1997; 1998b). It is assumed that
there are no unpermitted sources with significant emissions from on-site road travel.
PM2.5 emissions were calculated from PM10 using a ratio derived from California Air Resources
Board’s (CARB) PM2.5 Fraction Table (CARB, 2006).
Typical daily emissions were calculated using operating schedule information for each reported
process (normally a 5- or 6-day week), which were then summed to provide total daily emissions
for the county. Emissions totals for the PM10 nonattainment area were determined from the site
locations of each facility.
Table 3.3–25. Annual and typical daily emissions from paved and unpaved road travel at industrial facilities.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
PM10
PM2.5
Maricopa County
170.49
65.45
1,138.8
436.2
PM10 NAA
167.78
64.48
1,118.8
429.0

3.3.13 Industrial processes not elsewhere classified (NEC)
Annual area-source emissions from other industrial processes NEC were derived from annual
emissions reports from permitted facilities. Other industrial processes include a wide array of
industrial activities that are often specific to the permitted facility that reported the process. For
this reason, it is assumed there are no significant emissions from other industrial processes, other
than those reported by permitted facilities on their annual emissions reports. Typical daily
emissions are calculated based on operating schedule information provided by the facilities in
their annual emissions report. Emissions for the PM10 nonattainment area are based on the
location of the facilities that report other industrial processes.

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

Table 3.3–26. Annual and typical daily emissions from other industrial processes not elsewhere classified.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
Maricopa County
24.31
13.87
4.58
0.01
0.80
202.0
97.3
26.7
<0.1
4.6
PM10 NAA
24.29
13.86
4.08
0.01
0.80
201.9
97.2
22.9
<0.1
4.6

3.3.14 Summary of all area-source industrial processes
Tables 3.3–27 and 3.3–28 provide a summary of annual and typical daily emissions from all
industrial sources, for Maricopa County and the PM10 nonattainment area, respectively.
Table 3.3–27. Annual and typical daily emissions from all area-source industrial processes in Maricopa
County.
Annual emissions (tons/yr)
Source category
PM10
PM2.5
NOx
SOx
NH3
Chemical manufacturing
76.77
38.85
0.39
0.21
0.34
Commercial cooking
1,527.98
1,416.96
Grain handling/processing
12.64
2.68
Ammonia cold storage
1,695.98
Secondary metal production
10.95
9.27
4.53
0.05
1.34
Non-metallic mineral processes
431.60
222.71
Mining and quarrying
62.97
17.38
Wood product manufacturing.
213.23
149.95
Rubber/plastic product manufacturing
365.26
236.52
Fabricated metal product manufacturing
138.96
119.88
Residential construction
12,135.60
1,213.56
Commercial construction
11,491.21
1,149.12
Road construction
7,307.35
730.73
Other construction
2,806.46
280.65
Electrical equipment manufacturing
5.24
3.25
0.01
4.59
0.96
ADEQ-permitted portable sources
101.70
42.18
554.60
142.20
Road travel at industrial sites
170.49
65.45
Industrial processes NEC
24.31
13.87
4.58
0.01
0.80
All industrial processes:
36,882.71
5,713.02
564.11
147.06
1,699.43

Source category
Chemical manufacturing
Commercial cooking
Grain handling/processing
Ammonia cold storage
Secondary metal production
Non-metallic mineral processes
Mining and quarrying
Wood product manufacturing.
Rubber/plastic product manufacturing
Fabricated metal product manufacturing
Residential construction
Commercial construction
Road construction
Other construction
Electrical equipment manufacturing
ADEQ-permitted portable sources
Road travel at industrial sites
Industrial processes NEC
All industrial processes:
2005 Periodic PM10 Emission Inventory

PM10
590.5
8,395.5
94.7
79.0
3,030.4
409.1
1,657.9
2,809.7
1,579.3
77,792.3
73,661.6
46,842.0
17,990.2
40.3
844.2
1,138.8
202.0
237,157.6
58

Typical daily emissions (lbs/day)
PM2.5
NOx
SOx
298.9
3.0
1.6
7,785.5
20.5
66.3
1,517.2
112.1
1,170.0
1,819.4
1,404.1
7,779.2
7,366.2
4,684.2
1,799.0
25.0
389.8
436.2
97.3
36,770.8

NH3
2.6
10,871.7
10.3

25.0

0.4

0.1
5,377.5

35.3
1,431.7

7.4

26.7
5,432.2

<0.1
1,469.1

4.6
10,896.2

Maricopa County, AZ

Table 3.3–28. Annual and typical daily emissions from all area-source industrial processes in the PM10 NAA.
Annual emissions (tons/yr)
Source category
PM10
PM2.5
NOx
SOx
NH3
Chemical manufacturing
76.25
38.59
0.38
0.21
0.34
Commercial cooking
1,539.90
1,428.01
Grain handling/processing
12.64
2.68
Ammonia cold storage
1,684.45
Secondary metal production
10.95
9.27
4.53
0.05
1.34
Non-metallic mineral processes
430.89
222.17
Mining and quarrying
54.77
15.52
Wood product manufacturing.
211.78
148.93
Rubber/plastic product manufacturing
362.77
234.91
Fabricated metal product manufacturing
138.01
119.06
Residential construction
11,331.99
1,133.20
Commercial construction
11,085.55
1,108.55
Road construction
7,236.42
723.64
Other construction
2,475.89
247.59
Electrical equipment manufacturing
5.24
3.25
0.01
4.59
0.96
ADEQ-permitted portable sources
101.70
42.18
554.60
142.20
Road travel at industrial sites
167.78
64.48
Industrial processes NEC
24.29
13.86
4.08
0.01
0.80
All industrial processes:
35,266.82
5,555.90
563.60
147.05
1,687.89

Source category
Chemical manufacturing
Commercial cooking
Grain handling/processing
Ammonia cold storage
Secondary metal production
Non-metallic mineral processes
Mining and quarrying
Wood product manufacturing.
Rubber/plastic product manufacturing
Fabricated metal product manufacturing
Residential construction
Commercial construction
Road construction
Other construction
Electrical equipment manufacturing
ADEQ-permitted portable sources
Road travel at industrial sites
Industrial processes NEC
All industrial processes:

3.4

Waste treatment and disposal

3.4.1

On-site incineration

PM10
586.5
8,461.0
94.7
79.0
3,024.9
347.6
1,646.6
2,790.6
1,568.6
72,641.0
71,061.2
46,387.3
15,871.1
40.3
844.2
1,118.8
201.9
226,765.3

Typical daily emissions (lbs/day)
PM2.5
NOx
SOx
296.8
3.0
1.6
7,846.2
20.5
66.3
1,513.0
98.2
1,162.0
1,807.0
1,394.5
7,264.1
7,106.1
4,638.7
1,587.1
25.0
389.8
429.0
97.2
35,741.7

NH3
2.6
10,797.8
10.3

25.0

0.4

0.1
5,377.5

35.3
1,431.7

7.4

22.9
5,428.5

<0.1
1,469.1

4.6
10,822.7

This section includes emissions from on-site industrial incinerators, primarily burn-off ovens
used to reclaim electric wire or other materials. Emissions from human and animal crematories
are addressed in Section 3.5.4. There were no incinerators at residential (e.g., apartment
complexes) or commercial/institutional facilities (e.g., hospitals, service establishments) in
operation during 2005.
2005 Periodic PM10 Emission Inventory

59

Maricopa County, AZ

Emissions from on-site incineration were determined from annual emission inventory reports. It
is assumed that all incinerator emissions are accounted for, since all permitted incinerators
received surveys in 2005. All surveyed facilities are located within the PM10 nonattainment area,
thus total emissions for the county and NAA are equal.
Table 3.4–1.

Annual and typical daily emissions from on-site incineration.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx
SOx
Maricopa County
0.15
0.10
2.54
0.03
1.6
1.1
19.9
0.3
PM10 NAA
0.15
0.10
2.54
0.03
1.6
1.1
19.9
0.3

3.4.2

Open burning

Emissions from controlled open burning are regulated by Maricopa County Air Pollution Control
Regulations Rule 314 (Open Outdoor Fires), which requires a burn permit for open burning in
Maricopa County. Burn permits are issued primarily for purposes of agricultural ditch bank and
fence row burning, tumbleweed burning, land clearance, air curtain destructor burning of trees,
and fire fighting training. Maricopa County’s burn permit data base was used to identify all burn
permits issued during 2005. A total of 73 permits were issued during the year; however, not all
permit applications contained the information needed to calculate emissions. Where data were
missing, activity data for each permit category was grown from those permits that contained
information, as follows:
Total activity = ∑ activity reported ×

total number of permits issued
number of permits with activity data

Example:

Total ditch 50 burn permits issued
= 2,594,572 linear ft
bank/fencerows = 1,504,852 linear ft (reported) ×
29 permits with data
Reported and estimated activity data for each open burning category are summarized in Table
3.4–2. Permits issued for fire fighting training are addressed Section 3.5.1.2.
Table 3.4–2.

2005 Maricopa County burn permit activity data.
Number of
Total reported
permits with
activity data
Category
Unit of measure
activity
Ditchbank/fencerow Linear ft
1,504,852
29
Land clearance
Acres
5
1
Land clearance
Piles
37
2
Air curtain
Material Burned
70
7
Tumbleweeds
Piles
20
3

Total
permits
issued
50
7
7
7
4

Activity grown to
total number of
permits issued
2,594,572
35
130
70
27

The above activity data were converted to tons material burned using fuel loading factors from
AP-42, Table 2.5-5 (US EPA, 1992). The emission and loading factors used are shown in Table
3.4–3. As a conservative estimate, all particulate matter is presumed to be PM10 (and PM2.5).

2005 Periodic PM10 Emission Inventory

60

Maricopa County, AZ

Table 3.4–3.

Emission and fuel loading factors for open burning.
Emission factors (lb/ton burned)
Category
PM10
PM2.5
NOx
SOx
NH3
Weeds, unspecified
15
15
4
n/a
n/a
Russian Thistle (tumbleweeds)
22
22
4
n/a
n/a
Orchard Crops: Citrus
6
6
4
n/a
n/a

Fuel loading factor
3.2 tons/acre
0.1 tons/acre
1.0 tons/acre

The following assumptions were made based on previous Maricopa County emission inventory
and information from MCAQD's open burn program staff:
• Ditch banks and fence rows in Maricopa County average 7 feet in width and are burned
twice per year (MCESD, 1999).
• A pile of tumbleweeds 15 feet in diameter and 5 feet high weighs 200 lbs (MCESD,
1993). This is equivalent to the AP-42 fuel loading factor for tumbleweeds – 0.1
tons/acre.
• Air curtain destructors burn between 7–10 tons of material per day. (MCAQD, 2006).
To calculate the annual amount of material burned on ditch banks and fence rows in Maricopa
County, MCAQD estimated the area burned and then applied AP-42 fuel loading factor. The
tons of material burned in ditch banks and fence rows in Maricopa County were estimated as
follows:
Material burned from
ditchbanks and fence rows

= 2,594,572 ft length × 7 ft width × 3.2 tons/acre × 2 times/yr
43,560 ft2 / acre
= 2,668 tons material burned/yr

Activity data for the other categories were similarly converted to material burned using AP-42
fuel loading factors.
Annual emissions were then calculated by multiplying the amount of material burned by AP-42
emission factors (listed in Table 3.4–3) for each open burning category. To account for
unpermitted illegal outdoor burning, all calculated emissions estimates were increased 2.31 times
based on complaints received in 2006 for open or illegal outside burning (169 complaints
received; 169 complaints/73 open burn permits = 2.31).
Annual PM10 emissions from
= Total material burned
ditchbank and fence row burning
= 2,668 tons
= 20.01 tons/yr
Total annual PM10 emissions
including unpermitted burning

× emission factor

× unit conversion factor

× 15 lbs/ton

× 1 ton / 2,000 lbs

= Calculated emissions from permit data + unpermitted burning adjustment factor
= 20.02 tons/yr × 2.32
= 46.44 tons PM10/yr

Table 3.4–4 summarizes the annual emissions for Maricopa County from each open burning
category.

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Maricopa County, AZ

Table 3.4–4.

Annual emissions from open burning in Maricopa County.
Annual emissions (tons/yr)
NOx
Category
Ton-equivalents
PM10
PM2.5
Ditchbank/fencerow
2,668.4
46.43
46.43
12.38
Land clearance
526.4
9.61
9.61
2.44
Air curtain
70.0
0.49
0.49
0.32
Tumbleweeds
2.67
0.07
0.07
0.01
Totals:
56.15
56.15
15.16

Annual emissions for the nonattainment area are calculated by multiplying the percentage of
agricultural and/or vacant land use located in the PM10 nonattainment area by the Maricopa
County emission totals. (See Section 1.5.1 for a discussion of the land-use data used.) Table
3.4–5 summarizes the annual emissions for the PM10 nonattainment area.
Table 3.4–5.

Surrogate land-use classes, ratios, and annual emissions from open burning in the PM10 NAA.
Emissions (tons/yr)
Surrogate land
2004 NAA:county
Category
use categories
land-use ratio
NOx
PM10
PM2.5
Ditchbank/fencerow Agriculture
48.01 %
22.29
22.29
5.94
Land clearance
Vacant
19.82 %
1.82
1.82
048
Air curtain
Agriculture and vacant
25.06 %
0.12
0.12
0.08
Tumbleweeds
Agriculture and vacant
25.06 %
0.02
0.02
0.00
Totals:
24.24
24.24
6.51

It was assumed that open burning occurs 5 days per week (most burn permits are issued for
weekdays but permits may be issued on weekends depending on circumstances). Open burning
occurs year-round with the exception of ditch bank and fence row burning, which is not allowed
during the CO season (November through January).
PM10 typical daily emissions for Maricopa County are derived as follows:
Typical daily PM10 emissions

=annual PM10 emissions (tons/yr) × 2000 lbs/ton
(burn days/week) × (burn weeks/year)

Typical daily PM10 emissions from = 46.43 tons/yr × 2000 lbs/ton
ditchbank/ fence row burning
5 days/wk × 39 wks/yr
= 476.2 lbs PM10/day

Typical daily emissions for the PM10 nonattainment area are calculated by multiplying the
percentage of agricultural and/or vacant land use located in the nonattainment area by the
Maricopa County typical daily emissions. (See Section 1.5.2 for a discussion of the land-use
data used.) Table 3.4–6 summarizes the typical daily emissions from open burning for both
Maricopa County and the PM10 nonattainment area.
Table 3.4–6.

Typical daily emissions from open burning.
Maricopa County (lbs/day) PM10 nonattainment area (lbs/day)
Category
PM10
PM2.5
NOx
PM10
PM2.5
NOx
Ditchbank/fencerow
476.2
476.2
127.0
228.6
228.6
61.0
Land clearance
70.5
70.5
28.8
14.0
14.0
3.7
Air curtain
3.7
3.7
2.5
0.9
0.9
0.6
Tumbleweeds
0.5
0.5
0.1
0.1
0.1
0.0
Totals:
550.9
550.9
148.4
243.6
243.6
65.3

2005 Periodic PM10 Emission Inventory

62

Maricopa County, AZ

3.4.3

Landfills

Emissions from municipal solid waste (MSW) landfills come from uncontrolled landfill gas
emissions as well as from cover operations and combustion from control measures, such as a
flare. Total emissions were calculated from annual emissions inventory reports from all landfills
located within the county. Five MSW landfills (Butterfield Station, City Of Chandler Landfill,
Northwest Regional Landfill, Skunk Creek Landfill and Southwest Regional Municipal Solid
Waste Landfill) are considered point sources and are reported in Chapter 2. All other MSW
landfills are reported here as area-source landfills.
Table 3.4–7.

Annual and typical daily emissions from landfills.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx
SOx
Maricopa County
6.79
4.05
6.50
1.11
39.5
23.5
36.3
6.3
PM10 NAA
6.79
4.05
6.50
1.11
39.5
23.5
36.3
6.3

3.4.4

Publicly owned treatment works (POTWs)

Emissions from publicly owned treatment works (POTWs) were calculated by multiplying percapita emission factors (Battye et al., 1994) by population estimates and per-capita wastewater
usage estimates of 100 gallons per day per person (Tchobanoglous, 1979), as shown in Table
3.4–8. Typical daily emissions were calculated dividing annual emission by 365 day as activity
is assumed to occur uniformly throughout the year.
Table 3.4–8.

NH3 emissions from publicly-owned treatment works (POTWs).
Typical daily NH3
Annual NH3
2005
NH3 emission factor
emissions
emissions
Geographic area Population (lbs/106 gals treated)
(tons/yr)
(lbs/day)
Maricopa County
3,780,380
19.0
1,310.85
7,182.72
PM10 NAA
3,809,701
19.0
1,321.01
7,238.4

3.4.5

Other industrial waste disposal

Annual area-source emissions from other industrial waste disposal were derived from annual
emissions reports from permitted facilities. Other industrial waste disposal processes include a
wide array of industrial activities that are often specific to the permitted facility that reported the
process. For this reason, it is assumed there are no significant emissions from this category,
other than those reported by permitted facilities on their annual emissions reports. Typical daily
emissions are calculated based on operating schedule information provided by the facilities in
their annual emissions report.
All facilities that reported area-source emissions from other industrial waste disposal are located
inside the PM10 nonattainment area, therefore emissions for Maricopa County and the PM10
NAA are equal.
Table 3.4–9.

Annual and typical daily emissions from other industrial waste disposal.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx SOx
Maricopa County
79.55
48.51
4.15
5.01
606.0
369.6
22.8 27.5
PM10 NAA
79.55
48.51
4.15
5.01
606.0
369.6
22.8 27.5

2005 Periodic PM10 Emission Inventory

63

Maricopa County, AZ

3.4.6

Summary of all area-source waste disposal

Tables 3.4–10 and 3.4–11 provide a summary of annual and typical daily emissions from all
waste disposal, for Maricopa County and the PM10 nonattainment area, respectively.
Table 3.4–10. Annual and typical daily emissions from all area-source waste disposal for Maricopa County.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Category
PM10 PM2.5 NOx
SOx
NH3
PM10 PM2.5 NOx
SOx
NH3
On-site incineration
0.15
0.10
2.54
0.03
1.6
1.1
19.9
0.3
Open burning
56.15 56.15 15.16
550.9 550.9 148.4
Landfills
6.79
4.05
6.50
1.11
39.5
23.5
36.3
6.3
POTWs
1,310.85
7,182.7
Other
79.55 48.51
4.15
5.01
606.0 369.6
22.8
27.5
Total:
142.64 108.81 28.35
6.14 1,310.85 1,198.1 945.1 227.4
34.0 7,182.7
Table 3.4–11. Annual and typical daily emissions from all area-source waste disposal for the PM10 NAA.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Category
PM10 PM2.5 NOx
SOx
NH3
PM10 PM2.5 NOx
SOx
NH3
On-site incineration
0.15
0.10
2.54
0.03
1.6
1.1
19.9
0.3
Open burning
24.24 24.24
6.51
243.6 243.6
65.3
Landfills
6.79
4.05
6.50
1.11
39.5
23.5
36.3
6.3
POTWs
1,321.01
7,238.4
Other
79.55 48.51
4.15
5.01
606.0 369.6
22.8
27.5
Total:
110.74 76.90 19.70
6.14 1,321.01 890.8 637.8 144.4
34.0 7,238.4

3.5

Miscellaneous area sources

3.5.1

Other combustion

3.5.1.1 Wildfires
Federal and state records of individual vegetation fire events were collected from the Arizona
State Land Department WildCAD database (ASLD, 2006a), and the United States Geological
Survey GeoMAC Wildland Fire Support database (USGS, 2006). Only vegetation fires with
reported acreage were used to estimate emissions from wildfires. Thirty-eight fires occurred
within the PM10 nonattainment area, resulting in nearly 22,000 acres burned. The largest fire
within the PM10 nonattainment area was the Bart fire which occurred in May 2006 and resulted
in over 14,000 acres burned.
Fire activity records in the two databases were culled for duplicates by comparing incident
names and incident dates. The acreage for fires located near the Maricopa County border where
reviewed by Arizona State Land Department (ASLD) staff to ensure that only acres burned
within Maricopa County were included in emission estimates. ASLD staff also reviewed acreage
estimates for all fires with a discrepancy greater than 500 acres between data reported by ASLD
and USGS. When fuel type data was missing from state and federal records, fuel type was
obtained from Incident Status Summary, Form ICS-209 (USFSa, 2006). In the event that fire
event-specific fuel type were not contained in federal or state data nor in the ICS-209 forms, then
National Fire Danger Rating System (NFDRS) model descriptions of “sagebrush grass” or
“California chaparral” were assigned based on guidance from Arizona State Land Department
(ASLD, 2006b).
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Maricopa County, AZ

NFDRS model descriptions were assigned to each fire event based on the fuel type and then
corresponding fuel loadings were assigned (WGA/WRAP, 2005). Estimates of the material
burned were derived by multiplying the number of acres burned by the assigned fuel loading
factor.
Table 3.5–1.

Assigned NFDRS Model categories, fuel loading factors, and material burned.

NFDRS Model Description
California Chaparral

Fuel Load
(tons/acre)
19.5

Intermediate Brush

15

Sagebrush Grass

4.5

Western Grasses (annual)

0.5

Data
acres burned
material burned (tons)
acres burned
material burned (tons)
acres burned
material burned (tons)
acres burned
material burned (tons)

Total acres burned
Total material burned (tons)

PM10 NAA
14,634
285,365
2,788
41,820
4,137
18,618
213
106
21,772
345,909

Maricopa
County
187,864
3,663,350
81,446
1,221,690
34,163
153,736
12,447
6,224
315,921
5,044,999

Emission factors were obtained from the Western Regional Air Partnership's (WRAP) 2002 Fire
Emission Inventory (WGA/WRAP, 2005). Emission factors are listed below in Table 3.5–2.
Table 3.5–2. Summary of emission factors for prescribed fire (lb/ton).
Wildfire Emission Factors
PM2.5
NOx
PM10
Prescribed fire (Non-Piled)
28.1
24.1
6.2

SOx
1.7

NH3
1.3

Annual emissions from wildfires in Maricopa County were calculated as follows.
Annual PM10 emissions = material burned × emission factor (lbs/ton)
from wildfires in
2,000 lbs/ton
Maricopa County
= 5,044,999 tons of material burned × 28.1 lbs PM10/ton
2,000 lbs/ton
= 70,882.24 tons PM10/yr

Fire activity records included fire locations in latitude and longitude. This data was used to
determine the number of acres burned inside of the nonattainment area. Estimates of the material
burned were derived by multiplying the number of acres burned within the nonattainment area by
the assigned fuel loading factor. Annual emissions from wildfires within the nonattainment area
were then calculated by multiplying the material burned by the appropriate emission factor.
Annual PM10 emissions = material burned within the PM10 NAA × emission factor (lbs/ton)
from wildfires within
2,000 lbs/ton
the PM10 NAA
= 345,909 tons of material burned × 28.1 lbs PM10/ton
2,000 lbs/ton
= 4,860.0 tons PM10/yr

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Maricopa County, AZ

Table 3.5–3.

Annual emissions from wildfires (tons/yr).
Annual emissions (tons/yr)
Material
Burned
(tons)
Geographic Area
PM10
PM2.5
NOx
SOx
Maricopa County
5,044,999 70,882.24 60,792.24 15,639.50 4,288.25
PM10 NAA
345,909
4,860.02
4,168.20
1,072.32
294.02

NH3
3,279.25
224.84

Average daily emissions were estimated by dividing annual emissions by the number of burn
days in 2005.
Average daily PM10 emissions =
from wildfires in
Maricopa County
=

70,882.24 tons PM10/yr × 2,000 lbs/ton
298 days/yr
475,719.7 lbs PM10/day

Table 3.5–4.

Average daily emissions from wildfires (lbs/day).
Avg daily emissions (lbs/day)
Number of
Burn Days
PM2.5
NOx
SOx
PM10
Geographic Area
Maricopa County
475,719.7 408,001.6 104,963.1 28,780.2
298
PM10 NAA
32,617.6
27,974.5
7,196.8
1,973.3

NH3
22,008.4
1,509.0

3.5.1.2 Prescribed fires
Prescribed fires data were obtained from the United States Forest Service (USFS, 2006b). The
United States Forest Service reported that one prescribed fire occurred in Maricopa County in
2005. Three acres of piled fuels were burned in the Tonto National Forest on October 21, 2005.
The burn occurred outside of the PM10 nonattainment area.
Prescribed fire emission factors were obtained from the Western Regional Air Partnership’s
(WRAP) 2002 Fire Emission Inventory (WGA/WRAP, 2005). The United States Forest Service
estimated the fuel loading. Both are listed in Table 3.5–5. Estimates of the material burned in
are derived by multiplying the number of acres burned by the appropriate fuel loading factor.
Table 3.5–5.

Emission and fuel loading factors for prescribed fires.
Emission factors (lbs/ton burned)
Fuel loading
Number of
factor
Type of fire
acres burned
(tons/acre)
PM10 PM2.5 NOx SOx NH3
Prescribed fire (piled Fuels)
3
5.0
8.0
8.0 6.2 1.7 .05

Annual emissions from prescribed fires in Maricopa County were calculated as follows.
Annual PM10 emissions = acres burned × fuel loading factor × emission factor (lbs/ton)
from prescribed fires
2,000 lbs/ton
in Maricopa County
= 3 acres burned × 5.0 tons/acre × 8.0 lbs/ton
2,000 lbs/ton
= 0.06 tons PM10/yr

Because the prescribed fire occurred in the Tonto National Forest, which is located outside of the
nonattainment area, emissions from prescribed fires within the nonattainment area were
determined to be zero. It was assumed that the prescribed fire lasted one day. Thus, daily

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

emissions from prescribed fires (lbs./day) are equal to annual emissions (tons/day) divided by
2000 lbs/ton.
Table 3.5–6.

Annual and typical daily emissions from prescribed fires.
Annual emissions (tons/yr)
Geographic Area
PM10 PM2.5 NOx
SOx NH3
Maricopa County
0.06
0.06
0.05
0.01 0.00
PM10 NAA
0.00
0.00
0.00
0.00 0.00

Typical daily emission (lbs/day)
PM10
PM2.5 NOx
SOx NH3
120.0
120.0
93.0
25.5
7.5
0.0
0.0
0.0
0.0
0.0

3.5.1.3 Structure fires
2005 structure fire data were obtained by surveying fire departments in Maricopa County and by
querying Maricopa County’s burn permit data base. Approximately 50 percent of the fire
departments surveyed responded to the survey. Because actual fire data was only collected for a
portion of the fire departments in Maricopa County, the number of structure fires reported were
scaled up to the entire inventory area based on population. The most recent population estimates
for Maricopa County were used to scale up the number of structure fires (DES, 2006). Five open
burn permits were issued in 2005 for fire training; these were included in the total number of
estimated structure fires for 2005. It was estimated that 3,628 structure fires occurred in
Maricopa County in 2005.
Estimates of the material burned in a structure fire were determined by multiplying the number
of structure fires by a fuel loading factor of 1.15 tons of material per fire, which factors in
percent structural loss and content loss (US EPA, 2001e). Tons of material burned were
estimated as follows:
Material burned in
structure fires (tons/yr)

= 3,628 fires

× 1.15 tons/fire

= 4,171.77 tons material burned/yr
Table 3.5–7. Estimated material burned, emission and fuel loading factors for structure fires.
Emission factors (lbs/ton)
Structure
Fuel loading
Material
fires reported
factor (tons/fire)
burned (tons)
PM10
PM2.5*
NOx
SOx
3,628
1.15
4,171.77
10.8
10.8
1.4
n/a
* All PM10 is assumed to be PM2.5.

NH3
n/a

Annual emissions were then calculated by multiplying the amount of material burned by the
emission factors listed in Table 3.5–7 (from US EPA, 2001e), as follows:
Annual PM10 emissions = Quantity of material burned × emission factor × unit conversion factor
from structure fires
Maricopa County
= 4,171.77 tons × 10.8 lbs/ton × (1 ton/2,000 lbs.)
= 22.53 tons PM10/yr

Annual emissions for the PM10 nonattainment area were derived by multiplying Maricopa
County annual emissions by the percentage of total residential population within the PM10
nonattainment area (100.16%), as shown in the example below. See Section 1.5.2 for a
discussion of the population data used.

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Maricopa County, AZ

Annual PM10 emissions = annual PM10 emissions
within the PM10 NAA
for Maricopa County
= 22.53 tons/yr

× percentage residential
population within the NAA
× 100.16%

= 22.56 tons PM10/yr

Typical daily emissions for both Maricopa County and the PM10 nonattainment area are
calculated by dividing annual emissions by 364, as activity is assumed to take place 7 days a
week. Typical daily emissions for Maricopa County were derived using the following formula:
Typical daily PM10 emissions
from structure fires

= annual PM10 emissions (lbs)
7 days/wk × 52 weeks/yr
=

45,060 lbs
364

= 123.8 lbs/day
Table 3.5–8.

Annual and typical daily emissions from structure fires.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
PM10
PM2.5
NOx
Maricopa County
22.53
22.53
2.92
123.8
123.8
16.0
PM10 NAA
22.56
22.56
2.92
124.0
124.0
16.1

3.5.1.4 Vehicle fires
2005 vehicle fire data were obtained by surveying fire departments in Maricopa County.
Approximately 50 percent of the fire departments surveyed responded to the survey. Because
actual fire data was only collected for a portion of the fire departments in Maricopa County, the
number of vehicle fires reported were scaled up to the entire inventory area based on population.
The most recent population estimates for Maricopa County were used to scale up the number of
vehicle fires (DES, 2006). It was estimated that 2,113 vehicle fires occurred in Maricopa County
in 2005.
Annual emissions from vehicle fires are calculated by first multiplying the number of vehicle
fires by a fuel loading factor of per vehicle fire to estimate the annual amount of material burned
in vehicle fires (US EPA, 2000). The amount of annual material burned in vehicle fires is then
multiplied by emission factors for open burning of automobile components from AP-42 as listed
in table 3.5–9 (US EPA, 1992).
Annual PM10 emissions = annual number × fuel loading factor × emission factor × unit conversion factor
from vehicle fires
of vehicle fires
= 2,113

× 0.25 tons/vehicle

× 100 lbs/ton

× (1 ton / 2,000 lbs)

= 26.41 tons PM10/yr
Table 3.5–9. Estimated material burned, fuel loading factors, and emission factors for vehicle fires.
Emission factors (lbs/ton)
Vehicle fires
Fuel loading
Material
reported
factor (tons/fire)
burned (tons)
PM10
PM2.5*
NOx
SOx
NH3
2,113
0.25
528.25
100
100
4
n/a
n/a
* All PM10 is assumed to be PM2.5.
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Maricopa County, AZ

Annual emissions for the PM10 nonattainment area were derived by multiplying Maricopa
County annual emissions by the percentage of total residential population within the PM10
nonattainment area (100.16%). See Section 1.5.1 for a discussion of the population data used.
Annual PM10 emissions
from vehicle fires in the
PM10 NAA

= annual PM10 emissions
for Maricopa County

× percentage of total residential population
within the PM10 NAA

= 26.41 tons/yr
= 26.45 tons/yr

× 100.16%

It is assumed that vehicle fires occur evenly throughout the year. Thus, typical daily emissions
were derived by dividing the Maricopa County and nonattainment area annual emissions by 365
days/year. The results are shown in Table 3.5–10 below.
Table 3.5–10. Annual and typical daily emissions from vehicle fires.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
PM10
PM2.5
NOx
Maricopa County
26.41
26.41
1.06
144.7
144.7
5.8
PM10 NAA
26.45
26.45
1.06
145.0
145.0
5.8

3.5.1.5 Engine testing
Annual emissions from engine testing facilities were derived from annual emission reports from
permitted sources that were not considered point sources in this inventory. It was assumed that
there were no significant unpermitted sources within Maricopa County. Typical daily emissions
were calculated based on operating schedule information provided in the facilities’ annual
emission reports.
Since all facilities considered in this section are located within the PM10 nonattainment area, total
emission values for the county and the PM10 NAA are equal. Results are shown in Table 3.5–11.
Table 3.5–11. Annual and typical daily emissions from engine testing.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx
SOx
Maricopa County
0.15
0.12
4.61
1.89
1.1
0.9
35.4
14.5
PM10 NAA
0.15
0.12
4.61
1.89
1.1
0.9
35.4
14.5

3.5.2

Agricultural Activities

3.5.2.1 Tilling
Tillage emissions were estimated using the tillage emission factor equation and Maricopa County
specific soil silt content for agricultural land (URS and ERG, 2001). The number of planted or
harvested acres by crop were obtained from the Arizona Agricultural Statistics Service (AASS,
2006). Crop specific annual land preparation operations data were obtained from the Technical
Support Document for Quantification of Agricultural Best Management Practices (URS and
ERG, 2001). The agricultural tillage emission factor was calculated as follows:

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69

Maricopa County, AZ

EF = k (4.8) s0.6
where:
EF = Agricultural emission tillage factor (lbs PM10 / acre-pass)
k = Particle size multiplier (value of 0.15 for PM10)
s = Silt content of soil (percent) = 35.2% (URS and ERG, 2001)
Thus:

EF = 0.15 × 4.8 × (35.2)0.6

= 6.10 lbs PM10 / acre-pass

Annual PM10 emissions from agricultural tillage were calculated for each crop category using the
following equation (URS and ERG, 2001; Pollack et al., 2003):
TillageCrop = EF × APCrop × ACrop × ton / 2,000 lb
where:
TillageCrop
EF
APCrop
ACrop

=
=
=
=

Tillage emissions for each crop type (lbs PM10),
Tillage emission factor (lbs PM10/acre-pass),
Number of tillage passes per crop (passes), and
Total number of tilled acres for each crop type (acres)

Example:
EF
= 6.10 lbs PM10/acre-pass
APCpttpm 8.9 tillage passes for a cotton crop
ACotton
42,000 acres of cotton
TillageCotton

= 6.10 lbs PM10 / acre-pass × 8.9 passes × 42,000 acres × ton/ 2,000 lb
= 1,140.09 tons PM10 / year

Table 3.5–12 lists crop types and acreage; typical number of land preparation operations and
acre-passes; and annual uncontrolled PM10 emissions from agricultural tillage for Maricopa
County.

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Maricopa County, AZ

Table 3.5–12. 2002 Maricopa County agricultural crop acreage, activity, and uncontrolled annual PM10
emissions.
Annual land
Annual uncontrolled
Reported
preparation
PM10 emissions
Crop
Acres
operations
Acre-passes
(tons/yr)
Cotton
42,000
8.9
373,800
1,140.09
Corn
15,100
7.3
109,475
333.90
Wheat
18,200
3.1
55,510
169.31
Barley
12,500
2.1
25,625
78.16
Alfalfa (stand establishment)
21,750 (1)
5.1
109,838
335.00
Cantaloupe (fall)
6,400
16.1
102,880
313.78
Cantaloupe (spring)
8,900
15.0
133,634
407.58
Watermelon
3,400
13.7
46,410
141.55
Honeydew (fall)
700
16.1
11,253
34.32
Honeydew (summer)
1,500
12.5
18,750
57.19
Dry onion
700
11.1
7,757
23.66
Carrots
2,000
12.1
24,241
73.93
Broccoli
2,600
13.2
34,190
104.28
Grapefruit
220 (2)
5.0
1,100
3.36
Navel Oranges and miscellaneous
540 (2)
5.0
2,700
8.24
Valencia Oranges
360 (2)
5.0
1,800
5.49
Lemon
300 (2)
5.0
1,500
4.58
Tangerine
440 (2)
5.0
2,200
6.71
Total acreage:
137,610
3,241.12
1. Alfalfa is a multi-year crop and alfalfa stand establishment is assumed to occur once every 4 years to
approximately 25% of the total alfalfa acreage (URS and ERG, 2001).
2. 15 to 20% of citrus orchard acreage is non-bearing in a given year (URS and ERG, 2001); therefore, tillage is
assumed to occur in 20% of the reported harvested acreage.

In the Maricopa County PM10 nonattainment area, the agricultural PM10 general permit (Arizona
Administrative Code [AAC], R18-2-610 and 611) requires that commercial farmers implement at
least three agricultural best management practice (BMP) to control PM10 emissions generated
from tillage and harvest, non-cropland, and cropland.
Net control efficiencies from implementation of agricultural BMPs were developed by URS and
ERG (2001) in the Technical Support Document for Quantification of Agricultural BMPs. Three
BMPs were quantified for tillage: 1) combining tractor operations, 2) limited activity during
high-wind events, and 3) multi-year crops. URS/ERG derived net control efficiencies by multiplying a mid-point BMP control efficiency by a compliance factor and a relevancy factor for
applicable crops. MCAQD has used the same mid-point BMP control efficiency and relevancy
factor with a revised compliance factor of 59%, which was derived using latest EPA rule
effectiveness guidance (US EPA, 2005) that supercedes the 80% “default” rule effectiveness
(RE) value. (RE calculations for agricultural activities are included as Appendix 3.1). To
estimate controlled tillage emissions from agricultural operations within the PM10 NAA, the midpoint net control efficiency for each BMP were applied to 48.01% (the percent of agricultural
land in the PM10 NAA) of the uncontrolled annual PM10 emissions as follows:
Controlled annual
= Annual uncontrolled
PM10 emissions
tillageCrop emissions

× (100% – mid-point net
control efficiencycrop)

Controlled annual
= 1,140.09 tons PM10/yr × (100% – 24.3%)
tillageCotton emissions
= 413.94 tons PM10/yr
2005 Periodic PM10 Emission Inventory

71

× % agricultural land
in the PM10 NAA
× 48.01%

Maricopa County, AZ

The uncontrolled portion of tillage emissions from agricultural operations taking place outside
the PM10 NAA but within Maricopa County were estimated by multiplying the uncontrolled
annual PM10 emissions by the percent of agricultural land located within Maricopa County by
outside of the PM10 NAA (100% – 48.01%) as follows:
Uncontrolled annual = Uncontrolled annual
tillageCrop emissions
PM10 emissions
= 1,140.09 tons PM10/yr
= 592.73 tons PM10/yr

× 51.99%
× 51.99%

Controlled and uncontrolled emissions were then summed to estimate total annual PM10
emissions from agricultural tillage in Maricopa County. Results are shown in Table 3.5–13.
Table 3.5–13. Annual controlled PM10 emissions from agricultural tillage in Maricopa County.
Annual PM10 emissions (tons/yr)
Controlled PM10 Uncontrolled PM10
Total PM10
Net control Emissions (within emissions (outside
(controlled +
Crop
efficiency
the PM10 NAA)
the PM10 NAA)
uncontrolled)
Cotton
0.244
413.94
592.73
1006.67
Corn
0.244
121.23
173.59
294.82
Wheat
0.244
61.47
88.02
149.49
Barley
0.244
28.38
40.63
69.01
Alfalfa (stand establishment)
0.147
137.15
174.17
311.32
Cantaloupe (fall)
0.18
123.56
163.14
286.70
Cantaloupe (spring)
0.18
160.50
211.90
372.40
Watermelon
0.18
55.74
73.59
129.33
Honeydew (fall)
0.18
13.51
17.84
31.36
Honeydew (summer)
0.18
22.52
29.73
52.25
Dry onion
0.18
9.32
12.30
21.62
Carrots
0.18
29.11
38.44
67.55
Broccoli
0.18
41.06
54.21
95.28
Grapefruit
0.18
1.32
1.74
3.07
Navel oranges and miscellaneous
0.18
3.24
4.28
7.52
Valencia oranges
0.18
2.16
2.85
5.02
Lemon
0.18
1.80
2.38
4.18
Tangerine
0.18
2.64
3.49
6.13
Total
1,228.67
1,685.06
2,913.73

Annual PM2.5 emissions from agricultural tillage were calculated by multiplying the total annual
PM10 emissions by a conversion factor of 0.15 (WRAP, 2006b). Table 3.5–14 summarizes the
2005 PM10 and PM2.5 emissions for Maricopa County and the PM10 NAA from agricultural
tillage after the implementation of agricultural BMPs.

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Table 3.5–14. Annual controlled PM10 and PM2.5 emissions from agricultural tillage.
Maricopa County (tons/yr)
PM10 NAA (tons/yr)
Crop
PM10
PM2.5
PM10
PM2.5
Cotton
1,006.67
151.00
413.94
62.09
Corn
294.82
44.22
121.23
18.18
Wheat
149.49
22.42
61.47
9.22
Barley
69.01
10.35
28.38
4.26
Alfalfa (stand establishment)
311.32
46.70
137.15
20.57
Cantaloupe (fall)
286.70
43.00
123.56
18.53
Cantaloupe (spring)
372.40
55.86
160.50
24.07
Watermelon
129.33
19.40
55.74
8.36
Honeydew (fall)
31.36
4.70
13.51
2.03
Honeydew (summer)
52.25
7.84
22.52
3.38
Dry onion
21.62
3.24
9.32
1.40
Carrots
67.55
10.13
29.11
4.37
Broccoli
95.28
14.29
41.06
6.16
Grapefruit
3.07
0.46
1.32
0.20
Navel oranges and miscellaneous
7.52
1.13
3.24
0.49
Valencia oranges
5.02
0.75
2.16
0.32
Lemon
4.18
0.63
1.80
0.27
Tangerine
6.13
0.92
2.64
0.40
Total
2,913.73
437.06
1,228.67
184.30

Typical daily emissions for Maricopa County and the PM10 NAA were calculated by dividing the
annual PM10 emissions by estimated days per year of tillage operation by crop. The number of
days of tillage operations was estimated using the calendar of tillage operations by crop in the
Technical Support Document for Quantification of Agricultural BMPs (URS and ERG, 2001)
and assuming tillage activities occur 7 days per week during the months of tillage operations.
Results are shown in Table 3.5–15. The calendar of tillage operations did not include months of
tillage operations for citrus, thus, a conservative estimate of three (3) months per year was
assumed.
Table 3.5–15. Controlled typical daily emissions from tillage in Maricopa County.
Tillage operations (1) Tillage operations
Daily emissions (lbs/day)
(months/yr)
(days/yr)
Crop
PM10
PM2.5
Cotton
12
364
5,531.2
829.7
Corn
5
152
3,887.8
583.2
Wheat
8
243
1,232.1
184.8
Barley
8
243
568.8
85.3
Alfalfa (stand establishment)
3
91
6,842.2
1,026.3
Cantaloupe (fall)
6
182
3,150.5
472.6
Cantaloupe (spring)
6
182
4,092.3
613.8
Watermelon
6
182
1,421.2
213.2
Honeydew (fall)
6
182
344.6
51.7
Honeydew (summer)
6
182
574.2
86.1
Dry onion
6
182
237.5
35.6
Carrots
7
243
742.3
111.4
Broccoli
6
182
1,047.0
157.1
Grapefruit
3
91
67.4
10.1
Navel Oranges and misc.
3
91
165.4
24.8
Valencia Oranges
3
91
110.2
16.5
Lemon
3
91
91.9
13.8
Tangerine
3
91
134.7
20.2
Total
30,241.4
4,536.2
(1) Source: URS and ERG, 2001, Table 3-2, p. 3-5.

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

Typical daily emissions for the PM10 nonattainment area were calculated by dividing the annual
PM10 emissions for the PM10 NAA by an estimated day per year of tillage operation by crop.
Results are shown in Table 3.5–16.
Table 3.5–16. Controlled annual and typical daily emissions from tillage within the PM10 NAA.
Typical daily emissions (lbs/day)
Crop
PM2.5
PM10
Cotton
2,274.4
341.2
Corn
1,598.6
239.8
Wheat
506.6
76.0
Barley
233.9
35.1
Alfalfa (stand establishment)
3,014.3
452.2
Cantaloupe (fall)
1,357.8
203.7
Cantaloupe (spring)
1,763.7
264.6
Watermelon
612.5
91.9
Honeydew (fall)
148.5
22.3
Honeydew (summer)
247.5
37.1
Dry onion
102.4
15.4
Carrots
240.0
36.0
Broccoli
451.2
67.7
Grapefruit
29.0
4.4
Navel Oranges and miscellaneous
71.3
10.7
Valencia Oranges
47.5
7.1
Lemon
39.6
5.9
Tangerine
58.1
8.7
Total
12,797.0
1,919.6

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

3.5.2.2 Harvesting
Harvest emissions were estimated using crop-specific emission factors (CARB, 2003). The
number of harvested acres by crop was obtained from the 2005 Arizona Agricultural Statistics
Bulletin (AASS, 2006). Table 3.5–17 lists the crop types and associated PM10 emission factors
used to calculate emissions from agricultural harvesting.
Annual PM10 emissions from agricultural harvesting were calculated using the following
equation:
Uncontrolled annual
harvestCrop emissions

= EF × ACrop × ton / 2,000 lb

where:
harvestCrop
EFCrop
ACrop

= harvest emissions for each crop type (tons PM10/yr)
= harvest emission factor (lbs PM10/acre)
= total number of reported acres for each crop type per year

Example:
EFCotton
ACotton

= 3.4 lbs PM10/acre for cotton
= 41,900 acres of cotton

Uncontrolled annual
HarvestCotton Emissions

= 3.4 lbs PM10/acre × 41,900 acres × 1 ton/2,000 lbs
= 71.23 tons PM10/yr

Table 3.5–17. Maricopa County harvested acres and emission factors.

Crop
Cotton
Wheat
Barley
Alfalfa Hay
Other Hay
Corn
Broccoli
Dry Onions
Carrots
Summer Honeydews
Fall Honeydews
Spring Cantaloupe
Fall Cantaloupe
Watermelon
Grapefruit
Lemons
Valencia oranges
Navel, sweet, and miscellaneous
Tangerines
Total

PM10 emission
factor (lb/acre-yr)
3.4
5.8
5.8
0.0
1.68
1.68
0.08
1.68
0.17
0.08
0.08
0.08
0.08
0.08
0.08
0.08
0.08
0.08
0.08

2005
Acreage
41,900
17,500
12,300
80,000
7,000
900
2,600
700
2,000
1,500
700
8,900
6,400
3,400
1,100
1,500
1,800
2,700
2,200
195,100

Uncontrolled Annual
PM10 Emissions
(tons/yr)
71.23
50.75
35.67
0.00
5.88
0.76
0.10
0.59
0.17
0.06
0.03
0.36
0.26
0.14
0.04
0.06
0.07
0.11
0.09
166.36

In the Maricopa County PM10 nonattainment area, the agricultural PM10 general permit (Arizona
Administrative Code [AAC], R18-2-610 and 611) requires that commercial farmers implement at
least three agricultural best management practice (BMP) to control PM10 emissions generated
from tillage and harvest, non-cropland, and cropland. Net control efficiencies from the

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

implementation of agricultural BMPs were developed by URS and ERG (2001) in the Technical
Support Document for Quantification of Agricultural BMPs. Two BMPs were quantified for
harvesting: 1) combining tractor operations, and 2) reduced harvest activity. URS and ERG
(2001) derived net control efficiencies by multiplying a mid-point BMP control efficiency by a
compliance factor and a relevancy factor for applicable crops. MCAQD has used the same midpoint BMP control efficiency and relevancy factor with a revised compiance factor of 59% (from
80%). The revised compliance factor was derived using latest EPA rule effectiveness guidance
(US EPA, 2005) which eliminates use of the 80% default rule effectiveness value (rule
effectiveness calculations for agricultural activities are included as Appendix 3.1). To estimate
controlled harvest emissions from agricultural operations taking place within the PM10 NAA, the
mid-point net control efficiency for each BMP were applied to 48.01% of the uncontrolled
annual emissions (the percent of agricultural land in the PM10 NAA) as follows:
Controlled annual
harvestCrop emissions

= annual uncontrolled
PM10 emissions

Controlled annual
harvestCotton emissions
from within the PM10 NAA = 71.23 tons PM10/yr
= 24.88 tons PM10/yr

× (100% – mid-point net × % agricultural land
control efficiencycrop)
in PM10 NAA

× (100% – 27.2%)

× 48.01%

The uncontrolled portion of harvest emissions from agricultural operations outside the PM10
NAA but within Maricopa County were estimated by multiplying the uncontrolled annual PM10
emissions by the percent of agricultural land located within Maricopa County but outside of the
PM10 NAA (100% – 48.01%) as follows:
Uncontrolled annual
= Uncontrolled PM10
HarvestCotton emission
emissions
from outside the PM10 NAA
= 71.23 tons PM10/yr
= 37.03 tons PM10/yr

× 51.99%
× 51.99%

The total controlled and uncontrolled annual emissions were then summed to estimate total
annual PM10 emissions from agricultural harvesting in Maricopa County as follows:
Total annual harvestCotton = Uncontrolled annual
+ Controlled annual
emissions for Maricopa
harvestCotton emissions
harvestCotton emissions
County
from outside the PM10 NAA
from within the PM10NAA
= 37.03
+ 24.88
= 61.91 tons PM10/yr

Annual PM2.5 emissions from agricultural harvesting were calculated by multiplying the annual
PM10 emissions by a conversion factor of 0.15 (WRAP, 2006c).
Typical daily emissions for Maricopa County and the PM10 NAA were calculated by dividing the
controlled annual emissions by the number of harvest days per year (URS and ERG, 2001), as
shown in Table 3.5–19.

2005 Periodic PM10 Emission Inventory

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Table 3.5–18. Annual emissions from harvesting (tons/yr).
Net
PM10 NAA Outside NAA
Uncontrolled control
efficiency (controlled) (uncontrolled)
PM10
(tons/yr)
(%)
Crop
PM10
PM10
Cotton
71.23
27.2%
24.88
37.04
Wheat
50.75
25.0%
18.26
26.39
Barley
35.67
25.0%
12.84
18.55
Alfalfa Hay
0.00
29.5%
0.00
0.00
Other Hay
5.88
29.5%
1.99
3.06
Corn
0.76
25.0%
0.27
0.39
Broccoli
0.10
25.0%
0.04
0.05
Dry Onions
0.59
25.0%
0.21
0.31
Carrots
0.17
25.0%
0.06
0.09
Summer
0.06
25.0%
0.02
0.03
Honeydews
Fall Honeydews
0.03
25.0%
0.01
0.01
Spring
0.36
25.0%
0.13
0.19
Cantaloupe
Fall Cantaloupe
0.26
25.0%
0.09
0.13
Watermelon
0.14
25.0%
0.05
0.07
Grapefruit
0.04
25.0%
0.02
0.02
Lemons
0.06
25.0%
0.02
0.03
Valencia oranges
0.07
25.0%
0.03
0.04
Navel, sweet,
0.11
25.0%
0.04
0.06
and misc.
Tangerines
0.09
25.0%
0.03
0.05
Total
166.36
58.99
86.50

Table 3.5–19. Typical daily emissions from harvesting (lbs/day).
Maricopa County
Harvest
Crop
days/yr
PM10
PM2.5
Cotton
143
865.9
129.9
Wheat
60
1488.4
223.3
Barley
60
1046.1
156.9
Alfalfa Hay
294
0.0
0.0
Other Hay
294
34.3
5.2
Corn
91
14.6
2.2
Broccoli
161
1.1
0.2
Dry Onions
70
14.8
2.2
Carrots
273
1.1
0.2
Summer Honeydews
61
1.7
0.3
Fall Honeydews
71
0.7
0.1
Spring Cantaloupe
72
8.7
1.3
Fall Cantaloupe
71
6.3
1.0
Watermelon
152
1.6
0.2
Grapefruit
304
0.3
0.0
Lemons
232
0.5
0.1
Valencia oranges
151
0.8
0.1
Navel, sweet, and misc.
102
1.9
0.3
Tangerines
151
1.0
0.2
Total
3,489.9
523.5

2005 Periodic PM10 Emission Inventory

77

Maricopa County
(controlled +
uncontrolled)
PM10
PM2.5
61.91
9.29
44.65
6.70
31.38
4.71
0.00
0.00
5.05
0.76
0.67
0.10
0.09
0.01
0.52
0.08
0.15
0.02
0.05
0.01

PM10 NAA
(controlled)
PM2.5
3.73
2.74
1.93
0.00
0.30
0.04
0.01
0.03
0.01
0.00

0.02
0.31

0.00
0.05

0.00
0.02

0.23
0.12
0.04
0.05
0.06
0.10

0.03
0.02
0.01
0.01
0.01
0.01

0.01
0.01
0.00
0.00
0.00
0.01

0.08
145.48

0.01
21.82

0.00
8.85

PM10 nonattainment area
PM10
PM2.5
348.0
52.19
608.8
91.32
427.9
64.19
0.0
0.00
13.5
2.03
6.0
0.90
0.5
0.07
6.0
0.91
0.4
0.07
0.7
0.11
0.3
0.04
3.6
0.53
2.6
0.39
0.6
0.10
0.1
0.02
0.2
0.03
0.3
0.05
0.8
0.11
0.4
0.06
1,420.8
213.1

Maricopa County, AZ

3.5.2.3 Travel on unpaved agricultural roads
Resuspended PM10 emissions from travel on unpaved agricultural roads were estimated using an
unpaved road emission factor derived from AP-42 13.2.2 (US EPA, 2006b). The unpaved road
emission factor equation is shown below:
Unpaved road emission factor (EF) (lb/VMT) = k (s/12)a(W/3)b

where:
s
W
k
a
b

=
=
=
=
=

surface material silt content
=
mean vehicle weight (tons)
=
1.5 (PM10 constant) (US EPA, 2006b)
0.9 (PM10 constant) (US EPA, 2006b)
0.45 (PM10 constant) (US EPA, 2006b)

Unpaved road emission factor (lb/VMT)

11.90% (MAG, 2000)
2.80 (URS and ERG, 2001)

= 1.5 (11.9/12)0.9(2.8/3)0.45
= 1.444 lb/VMT

Emissions were estimated using farm vehicle activity data obtained from the Technical Support
Document for Quantification of Agricultural Best Management Practices (URS and ERG, 2001).
URS and ERG (2001) estimated average daily vehicle miles traveled per 1,000 acres to be 49.5
VMT.
Daily emissions from travel on unpaved agricultural roads were then estimated as follows:
Daily uncontrolled PM10
emissions from ag roads

= unpaved road EF × VMT/1000 acres × 2005 harvested acres
= 1.444 lbs/VMT × 49.5 VMT/1000 acres × 195,100 acres
= 13,944.8 lbs/day

Net control efficiencies from implementation of agricultural BMPs were developed by URS and
ERG (2001) in the Technical Support Document for Quantification of Agricultural BMPs. Two
BMPs were quantified for unpaved road travel: 1) access restriction and 2) reduced vehicle
speed. URS and ERG (2001) derived net control efficiencies by multiplying a mid-point BMP
control efficieincy by a compliance factor and a relevancy factor for applicable crops. MCAQD
has used the same mid-point BMP control efficiency and relevancy factor with a revised
compliance factor of 59% (from 80%). The revised compliance factor was derived using latest
EPA rule effectiveness guidance (US EPA, 2005) which eliminates use of the 80% default rule
effectiveness value (rule effectiveness calculations for agricultural activities are included as
Appendix 3.1). To estimated controlled emissions from travel on unpaved agricultural roads
within the PM10 NAA, the mid-point net control efficiency for each BMP (12.4 % and 0.4%,
respectively) were applied to 48.01 % (the percent of agricultural land in the PM10 NAA) of the
uncontrolled daily PM10 emissions as follows:
Controlled daily
unpaved ag road
emissions within
the NAA

= Daily uncontrolled
PM10 emissions

× (100%-mid-point net
control efficiency)

× % agricultural land
in the PM10 NAA

= 13,944.8 lbs/day

× (100% – 12.8%)

× 48.01%

= 5,838.0 lbs/day

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78

Maricopa County, AZ

The uncontrolled portion of unpaved agricultural road emissions outside the PM10 NAA but
within Maricopa County were estimated by multiplying uncontrolled daily PM10 emissions by
the percent of agricultural land located within Maricopa County but outside of the PM10 NAA
(100% – 48.01%) as follows:
Uncontrolled daily unpaved ag.
road emissions from outside
of the PM10 NAA

= Uncontrolled PM10 emissions × 51.99%
= 13,944.8 lbs/day × 51.99%
= 7,249.90 lbs/day

Total controlled and uncontrolled daily emissions were then summed to estimate total daily PM10
emissions from travel on unpaved agricultural roads in Maricopa County as follows:
Total daily unpaved
ag road emissions for
Maricopa County

= Uncontrolled daily
unpaved ag road emissions
from outside the PM10 NAA

+

Controlled daily
unpaved ag road emissions
from within the PM10 NAA

= 7,249.90

+

5,838.0

= 13,087.9 lbs PM10/day

Daily PM2.5 emission from travel on unpaved agricultural unpaved roads were calculated by
multiplying the daily PM10 emissions by a conversion factor of 0.10 (WRAP, 2006d).
Annual emissions for Maricopa County and the PM10 NAA were calculated by multiplying the
daily emissions by the 312 (6 days per week × 52 weeks per year).
Table 3.5–20. Annual and typical daily emissions from travel on unpaved agricultural roads.
Annual emissions
Typical daily emissions
(tons/yr)
(lbs/day)
PM10
PM2.5
PM10
PM2.5
Geographic area
Maricopa County (controlled + uncontrolled)
2,041.71
204.17
13,087.9
1,308.8
PM10 NAA (controlled)
910.64
91.06
5,837.4
583.7

3.5.2.4 Cotton ginning
Annual emissions from cotton ginning were derived from annual emission reports from permitted sources. There is only one small cotton gin operating in the County that is not addressed
as a point source in Chapter 2.
Data from CARB’s PM2.5 Fraction Table (CARB, 2006) were used to calculate PM2.5 emissions,
assumed to be 28.6% of PM10 emissions. Since all cotton gins considered in this section are
located within the PM10 nonattainment area, total emission values for the county and the PM10
NAA from cotton ginning are equal. Results are shown in Table 3.5–21.
Table 3.5–21. Annual and typical daily emissions from area-source cotton ginning.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
PM10
PM2.5
Maricopa County
0.09
0.02
0.7
0.2
PM10 NAA
0.09
0.02
0.7
0.2

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Maricopa County, AZ

3.5.2.5 Fertilizer application
Annual NH3 emissions from synthetic nitrogen fertilizers were calculated using the CMU
Ammonia Model (CMU, 2004). The CMU Ammonia Model uses semiannual sales data for
2002 from the Association of American Plant Food Control Officials, which are available at the
county-level. This information was combined with information from National Agricultural
Statistics Service (NASS) crop calendars to estimate monthly fertilizer application rates for each
county. County-wide results are shown in Table 3.5–22. Typical daily NH3 emissions were
derived by dividing annual emissions by 365 days/year.
Annual and typical daily emissions for the PM10 nonattainment area were derived by multiplying
the county annual and typical daily emissions by the percentage of agricultural land located in
the PM10 NAA (48.01%). See Section 1.5.2 for a discussion of the land-use data used.
Table 3.5–22. Annual and typical daily ammonia emissions from fertilizer application.
Maricopa County
PM10 NAA

Fertilizer Category
Anhydrous ammonia
Aqueous ammonia
Ammonium nitrate
Ammonium sulfate
Ammonium thiosulfate
Calcium ammonium nitrate
Nitrogen solutions
Urea
Diammonium phosphate
Monoammonium phosphate
Liquid ammonium polyphosphate
Potassium nitrate
Miscellaneous
Total

3.5.3

Annual NH3
Emissions
(tons/year)
70.66
3.75
0.00
74.41
0.00
0.00
1,399.94
496.04
2.67
71.76
38.91
0.95
119.05
2,278.14

Daily NH3
Emissions
(lbs/day)
387.2
20.5
0.0
407.7
0.0
0.0
7670.9
2718.0
14.6
393.2
213.2
5.2
652.3
12,483.0

Annual NH3
Emissions
(tons/year)
33.92
1.80
0.00
35.72
0.00
0.00
672.11
238.15
1.28
34.45
18.68
0.46
57.16
1,093.74

Daily NH3
Emissions
(lbs/day)
185.9
9.9
0.0
195.7
0.0
0.0
3682.8
1304.9
7.0
188.8
102.4
2.5
313.2
5,993.1

Livestock

Annual NH3 emissions from livestock in Maricopa County were calculated using the CMU
Ammonia Model (CMU, 2004). The CMU Ammonia Model developed by Carnegie Mellon
University is a software application that generates ammonia emissions from many different
sources for the continental United States. County-wide results are shown in Table 3.5–24. It
was assumed that livestock emissions occur evenly throughout the year. Typical daily NH3
emissions were derived by dividing annual emissions for Maricopa County by 365 days/year.
PM10 and PM2.5 emissions estimates were derived using Maricopa County cattle inventory
estimates for 2005 from Arizona Agricultural Statistics Bulletin (AASS, 2006) and emission
factor for PM10 for dairy cattle, and feedlot cattle from the California Air Resources Board
(CARB, 2004). PM2.5 was presumed to be 11% of PM10 per WRAP Fugitive Dust Handbook
(WRAP, 2006d).
The number of “cattle on feed” was not available from the Arizona Agricultural Statistics
Bulletin (AASS, 2006) for 2005; therefore, 2004 numbers were used. Beef cows were excluded
2005 Periodic PM10 Emission Inventory

80

Maricopa County, AZ

from the inventory as information provided by Arizona Agricultural Statistics staff (Coon, 2004)
indicated that the majority of beef cows that are not on feed are grazed on range and pastures.
Cattle on feed, milk cows, and other cattle (heifers, steers, bulls, and calves) were included in the
PM10 emission estimates for livestock. The 2005 Maricopa County cattle inventory and
applicable PM emission factors are contained in Table 3.5–23.
Table 3.5–23. Maricopa County cattle inventory and PM emission factors.
Emission factors
Animal type
Cattle on feed
Milk cows
Other cattle
Total

Head
5,000
105,000
93,000
203,000

PM10
(lb/1000 head/day )
28.9
6.7
28.9

PM2.5/PM10 Ratio
0.11
0.11
0.11

Typical daily PM10 emissions from livestock in Maricopa County were calculated using the
following formula:
Typical daily emissions
(lbs/day) from dairy cattle

= milk cow inventory (1,000 head) × emission factor (lbs PM10/1,000 head/day)
= 105 × 6.7
= 703.5 lbs PM10/day

It was assumed that livestock emissions occur evenly throughout the year. Annual PM10 and
PM2.5 emissions were derived by multiplying typical daily emissions for Maricopa County and
the nonattainment area by 365 days/year.
MCAQD determined through GIS analysis of confined animal feeding operation (CAFO)
locations and animal numbers in Maricopa County that 80.7% of CAFO animals are located
within the nonattainment area. Therefore, annual and typical daily emissions for the
nonattainment area were calculated by multiplying the Maricopa County emission totals by
80.7%.
Table 3.5–24 summarizes the annual and typical daily emissions from livestock for Maricopa
County and the PM10 nonattainment area.
Table 3.5–24. Annual and typical daily emissions from livestock.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NH3
PM10
PM2.5
NH3
Maricopa County
645.27
70.98 10,429.53
3,535.7
388.9
57,148.1
PM10 NAA
520.84
57.29
8,418.39
2,853.9
313.9
46,128.1

3.5.4

Health services: crematories

Emissions from human and animal crematories were calculated from annual emissions inventory
reports from all landfills located within the county. Typical daily emissions are calculated based
on the operating schedule data reported by surveyed facilities. From annual emission surveys, it
was determined that crematories operate on a 5-day week throughout the year. This data was
used to calculate typical daily emissions as follows:

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81

Maricopa County, AZ

Typical daily PM10 =
emissions from
crematories
=

Annual emissions (tons/yr)
Days/week × Weeks/yr

× 2,000 lbs
ton

0.96
5 × 52

× 2,000

= 7.4 lbs PM10/day

Annual and typical daily emissions for the PM10 nonattainment area were calculated by
multiplying the Maricopa County emission totals by the percentage county permitted sources that
are within the nonattainment area.
PM10 emissions from
= Annual Maricopa County
area-source crematories
emissions
in the PM10 NAA (tons/yr)
= 0.96 tons/yr

× Percentage of crematories within the NAA
× .95

= 0.91 tons PM10/yr

Table 3.5–25 summarizes annual and typical daily emissions from crematories in both Maricopa
County and the PM10 nonattainment area.
Table 3.5–25. Annual and typical daily emissions from crematories.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
NOx
SOx
PM10
PM2.5
NOx
SOx
Maricopa County
0.96
0.64
11.45
1.46
7.4
4.9
88.0
11.3
PM10 NAA
0.91
0.61
10.87
1.39
7.0
4.7
83.6
10.7

3.5.5

Accidental releases

As part of its air quality permit compliance program, MCAQD keeps an “upset log”, for each
calendar year that records excess emissions and accidental releases at permitted facilities.
Annual emissions inventory reports also provide for recording of accidental releases. Data from
these two sources documented the release of 1.03 tons of PM10 for the year 2005. (No accidental
releases of NOx, SOx or NH3 were reported). Accidental releases from point source facilities are
included as part of their annual emissions totals (see chapter 2).
Typical daily emissions are calculated by summing reported releases and dividing the total by
365 days. Emissions in the PM10 nonattainment area are calculated based on locations of
facilities that reported releases.

2005 Periodic PM10 Emission Inventory

82

Maricopa County, AZ

Table 3.5–26. Annual and typical daily emissions from accidental releases.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5*
PM10
PM2.5*
Maricopa County
1.03
1.03
5.6
5.6
PM10 NAA
1.03
1.03
5.6
5.6
* As a conservative estimate, all PM10 emissions are assumed to be PM2.5.

3.5.6

Humans

A literature review by Battye et al. (1994) recommended using a per-capita emission factor
developed for the National Acid Precipitation Assessment Program (NAPAP) inventory in 1985.
This factor was applied to MAG population estimates for the county and PM10 nonattainment
areas (see section 1.5 for population information). Daily emissions were calculated by dividing
annual values by 365.
Table 3.5–27. Annual and typical daily NH3 emissions from human activity.
Emission factor
Annual NH3
Typical daily NH3
(lbs/ person-yr) emissions (tons/yr) emissions (lbs/day)
Geographic Area
Population
Maricopa County
3,780,380
0.55
1,039.60
5,696.5
PM10 NAA
3,809,701
0.55
1,047.67
5,740.6

3.5.7

Leaf blower fugitive dust

Fugitive dust emissions from leaf blowers are the result of blowing loose material from the area
being cleared by the leaf blowers. Exhaust emissions from gasoline powered leaf blowers are
covered under the Nonroad mobile sources chapter of this report (see chapter 4). Fugitive dust
emission estimates are developed with the use of three main sources: EPA’s NONROAD model,
California Air Resources Board report to legislature on leaf blowers (CARB, 2000), and a very
recent research effort done by the University of Riverside (Fitz et al., 2005).
EPA’s NONROAD model was used to develop estimates of the number of gasoline powered leaf
blowers in Maricopa County, along with the average activity figures for those leaf blowers.
Electric leaf blower population numbers were derived from the CARB report (2000) which
indicates 60% of all leaf blowers sold are electric, as in the following equation:
Population of electric =
Leaf blowers
=
=

(gas-powered leaf blowers ÷ 40% [= all leaf blowers]) – gas-powered leaf blowers
(103,668
155,502 units

÷ 0.4

[=259,170])

– 103,668

Fitz et al. (2005) developed emission factors for PM10 and PM2.5 fugitive dust emissions from
leaf blowers. For this report, the most conservative (highest) emission factors were chosen to
estimate emissions. Given these two data sources, Table 3.5–28 lists the equipment population
numbers, activity estimates and emission factors for leaf blowers in Maricopa County.

2005 Periodic PM10 Emission Inventory

83

Maricopa County, AZ

Table 3.5–28. Leaf blower equipment populations, activity levels and emission factors for Maricopa County.
Activity
PM10 Emission
PM2.5 Emission
(hrs/yr)
factors (mg/m2)
factors (mg/m2)
Leaf blower description
Population
Commercial 2-stroke gasoline
3,158
626
70
30
Commercial 4-stroke gasoline
1,548
626
70
30
Residential 2-stroke gasoline
94,072
10
70
30
Residential 4-stroke gasoline
4,890
10
70
30
Electric
155,502
10
130
40
Total
259,170
n/a
n/a
n/a

The CARB report (2000) estimates that approximately 1600m2 of surface can be cleared in one
hour of leaf blower operation. Therefore, annual emission estimates are calculated by using the
following formula, as in this example for electric leaf blowers:
Annual PM10 = Population × Activity × Emission Factor × area covered ÷ 1000g/mg ÷ 454g/lb ÷ 2000lb/ton
emissions
(hrs/yr)
(mg/m2)
(1600m2)
from electric
leaf blowers
= 155,502 × 10 hrs/yr × 130mg/m2
× 1600m2 /hr ÷ 1000g/mg ÷ 454g/lb ÷ 2000lb/ton
= 356.22 tons PM10/yr

Leaf blowers are assumed to operate seven days a week all year long. Typical daily emissions
are estimated by dividing annual totals by 365 days per year. Emissions for the PM10
nonattainment area are allocated based on the ratio of resident population in the County to the
nonattainment area (see Section 1.5 for information on population). Table 3.5–29 lists annual
and daily fugitive emission from leaf blowers for Maricopa County and the PM10 nonattainment
area.
Table 3.5–29. Annual and typical daily emissions from leaf blower fugitive dust.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
PM10
PM2.5
Maricopa County
841.66
317.65
4,611.8
1,740.6
PM10 NAA
843.00
318.16
4,619.2
1,743.3

3.5.8

Offroad recreation vehicles fugitive dust

The EPA NONROAD model estimates exhaust emissions for offroad recreational vehicles.
These emissions are included in the Nonroad Emissions category of the 2005 particulate
inventory. Particulate emissions are also generated by recreational vehicles traveling on unpaved
surfaces. For the 2005 periodic inventory, these emissions were estimated by MAG using
mileage and activity data for offroad recreational vehicles in Maricopa County, from the EPA
NONROAD model. The specific methodology, calculations, and assumptions for the calculation
of fugitive dust emissions from offroad recreational vehicles traveling on unpaved surfaces are
described below.
The EPA NONROAD model provides annual mileage and activity data for all terrain vehicles
(ATV), all terrain cycles (ATC), and specialty vehicles/carts (SVC). The NONROAD activity
and mileage estimates for Maricopa County in 2005 are shown in Table 3.5–30. The product of
the mileage and the number of vehicles equals the annual VMT.

2005 Periodic PM10 Emission Inventory

84

Maricopa County, AZ

It was further assumed that 75% of the annual VMT is traveled on unpaved surfaces inside
Maricopa County. The remaining 25% of the miles are assumed to be on paved surfaces and
unpaved surfaces outside of Maricopa County. Multiplying the annual VMT by 75 percent and
dividing by 365 produces the Daily VMTs on unpaved surfaces in Maricopa County as shown in
Table 3.5–30.
Table 3.5–30. VMT for offroad recreational vehicles in Maricopa County.
Daily VMT inside
Annual
Number of
Annual VMT
Vehicle Type
Maricopa County
Mileage
Vehicles
ATV
1,600
24,511
39,413,688
80,987
ATC
1,600
6,158
9,852,800
20,246
SVC
65
1,664
108,160
222

The daily VMTs were multiplied by the AP-42 emission factor for unpaved industrial roads,
assuming silt content of 11.9% and a vehicle weight of one-half of a ton. The AP-42 emission
factor for ATVs and ATCs is 272 grams per mile. This emission rate was reduced by 50%, to
136 grams per mile, for ATCs, to account for two wheels generating dust instead of four.
According to the November 2006 revision of AP-42, PM2.5 emissions are 10 percent of PM10
emissions from unpaved roads. Therefore, the PM2.5 emission rate for ATVs and ATCs is 27
grams per mile; and for SVCs, 14 grams per mile.
The PM10 and PM2.5 emission rates were multiplied by the daily VMT by vehicle type to obtain
total emissions attributable to offroad recreational vehicles traveling on unpaved surfaces in
Maricopa County, as shown in Table 3.5–31.
Emissions for the PM10 nonattainment area were derived by applying GIS to MAG 2004 land use
data to obtain the acreage of passive open space in the PM10 nonattainment area and in Maricopa
County. Passive open space includes mountains and washes. The detailed calculations to derive
the PM10 nonattainment area emissions are shown below:
Passive Open Space in the PM NAA: 377,814 acres
Passive Open Space in Maricopa County: 1,748,816 acres
Ratio of Passive Open Space in PM NAA vs. Maricopa County: 377,814/1,748,816 = 21.6%
PM NAA Emissions: 0.216 × Maricopa County Emissions
The application of the above methodology resulted in total emissions for offroad recreational
vehicles traveling on unpaved surfaces in the PM10 nonattainment area, as shown in Table 3.5–
31.
Table 3.5–31. Annual and typical daily emissions from offroad recreational vehicles traveling on unpaved
surfaces.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
PM10
PM2.5
Maricopa County
9,994.00
999.00
54,764.0
5,476.0
PM10 NAA
2,159.00
216.00
11,830.0
1,184.0

2005 Periodic PM10 Emission Inventory

85

Maricopa County, AZ

3.5.9

Unpaved parking lots fugitive dust

Fugitive dust particulate emissions from vehicles traveling in unpaved parking areas were
estimated by MAG based on the acres of disturbed land devoted to unpaved parking areas,
estimated vehicle activity on unpaved parking areas, and emission rates from AP-42. The
specific methodology, calculations, and assumptions for each component of the calculation are
described below.
Acres of disturbed vacant land were estimated as follows: In the Phase I Windblown Dust
Modeling for the Western Regional Air Partnership (ENVIRON, 2004), it was estimated that
eight percent of the vacant land in core urban areas is disturbed and thirty percent of the land
under development is disturbed. MAG used geographic information systems (GIS) and the 2004
MAG land use data, to estimate that there were 93,429 acres of vacant land in the core urbanized
area and 60,357 acres of land under development in the PM10 nonattainment area. Multiplying
the percentages above by these acreage estimates produces:
93,429 × 0.08 = 7,474 acres of vacant disturbed land in the urbanized core
60,357 × 0.30 = 18,107 acres of vacant disturbed land under development
Summing the urbanized core and developing acreages results in a total of 25,581 acres of vacant
disturbed land in the PM10 nonattainment area. The 1995 microscale particulate emissions study
(MAG, 1995) estimated that 24 percent of the disturbed vacant land is devoted to unpaved
parking areas. Applying this assumption to the total acreage of vacant disturbed land results in a
total of 6,139 acres of unpaved parking areas in the PM10 nonattainment area..
Vehicle activity on unpaved parking areas was estimated by assuming that each day, an average
of 100 vehicles drive on each acre of unpaved parking area. One acre, if perfectly square, would
have dimensions of about 212 × 212 feet. If the average vehicle travels one-half the distance
from the center of the acre, each vehicle would travel an average of 106 feet or 0.02 miles per
acre. Multiplying 100 vehicles per day times 0.02 miles produces 2 vehicle miles traveled
(VMT) per acre per day. Multiplying 6,139 acres times 2 VMT per acre per day yields 12,278
VMT per day on unpaved parking areas in the PM10 nonattainment area.
Emission rates for unpaved parking areas were derived from the AP-42 equation for unpaved
industrial roads, assuming 11.9 percent silt content and an average vehicle weight of three tons.
The resultant PM10 emission rate is 609.23 grams per mile. The November 2006 revision to AP42 indicates that the PM2.5 emission rate is 10 percent of the PM10 emission rate or 60.92 grams
per mile. Applying the emission rate to the VMT produces the total emissions from vehicles
traveling on unpaved parking areas in the PM10 nonattainment area of 7,480 kg/day.
To estimate emissions for Maricopa County, GIS was applied to the 2004 MAG land use data to
derive the total acres of vacant land in Maricopa County. The vacant land in Maricopa was
estimated to be 1,642,255 acres. Removing the acres of vacant land in the Maricopa County
portion of the PM10 nonattainment area (i.e., 397,080 acres) results in 1,642,255 vacant acres
inside Maricopa County but outside the PM10 nonattainment area.

2005 Periodic PM10 Emission Inventory

86

Maricopa County, AZ

Assuming that one percent of the vacant acres outside the PM10 nonattainment area is disturbed
(Clark County, 2006), and 24 percent of the disturbed vacant land is unpaved parking areas
(MAG, 1995) results in 3,942 acres of unpaved parking areas outside the PM10 nonattainment
area. Multiplying this by 2 VMT per acre, per day results in 7,884 VMT/day. Applying the
same emission rate from AP-42 produces 4,803 kg/day of PM10 emissions due to unpaved
parking areas located outside the PM10 nonattainment area.
To estimate Maricopa County emissions, the Pinal County portion needs to be removed from the
PM10 nonattainment area emissions. The emissions in the Pinal County portion of the PM10
nonattainment area are assumed to be proportional to the acres of vacant land, derived using GIS
and the 2004 MAG land use, as calculated below.
Vacant land in the Pinal County portion of the PM10 nonattainment area: 7,134 acres
Vacant land in the PM10 nonattainment area: 404,214
Ratio: 7,134/404,214 = 1.8%
Emissions attributable to the Pinal County portion: 7,480 kg/day × 0.018 = 135 kg/day
Adding the emissions inside and outside the PM10 nonattainment area (7,480 kg/day and 4,803
kg/day) and subtracting the emissions for the Pinal County portion (135 kg/day) produces total
Maricopa County emissions attributable to vehicles traveling in unpaved parking areas of 12,148
kg/day. The results for the PM10 nonattainment area and Maricopa County are summarized in
tons per year and lbs per day in Table 3.5–32.
Table 3.5–32. Annual and typical daily emissions from vehicles traveling in unpaved parking areas.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
PM10
PM2.5
Maricopa County
4,888.00
489.00
26,781.0
2,678.0
PM10 NAA
3,009.00
301.00
16,490.0
1,649.0

3.5.10 Windblown dust
ENVIRON International corporation estimated windblown dust based on the computer model
developed by Western Regional Air Partnership Regional Modeling Center (WRAP RMC). A
full description of this modeling process is included as Appendix 3.2. Table 3.5–33 summarizes
annual and typical daily emissions from windblown dust.
Table 3.5–33. Annual and typical daily emissions from fugitive windblown dust.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Geographic area
PM10
PM2.5
PM10
PM2.5
Maricopa County
44,488.84
4,448.88
243,774.4
24,377.4
PM10 NAA
7,380.43
738.04
40,440.7
4,044.1

2005 Periodic PM10 Emission Inventory

87

Maricopa County, AZ

3.5.11 Summary of all miscellaneous area sources
Tables 3.5–34 and 3.5–35 provide a summary of annual and typical daily emissions from all
miscellaneous area sources, for Maricopa County and the PM10 nonattainment area, respectively.
Table 3.5–34. Annual and typical daily emissions from all miscellaneous area sources for Maricopa County.

Category
Wildfires
Prescribed fires
Structure fires
Vehicle fires
Engine testing
Tilling
Harvesting
Unpaved ag roads
Cotton ginning
Fertilizer
Livestock
Crematories
Accidental releases
Humans
Leaf blowers dust
Offroad rec dust
Unpaved parking lots
Windblown dust
Total:

Annual emissions (tons/yr)
PM10
PM2.5
NOx
SOx NH3
70,882.24
0.06
22.53
26.41
0.15
2,913.73
145.48
2,041.71
0.09
645.27
0.96
1.03
841.66
9,994.00
4,888.00
44,488.84
136,892.15

60,792.24 15,639.50 4,288.25
0.06
0.05
0.01
22.53
2.92
26.41
1.06
0.12
4.61
1.89
437.06
21.82
204.17
0.02
70.98
0.64
1.03

3,279.25
0.00

2,278.14
10,429.53
11.45

1.46

1,039.60
317.65
999.00
489.00
4,448.88
67,831.62 15,659.58 4,291.61 17,026.53

Typical daily emissions (lbs/day)
PM10 PM2.5 NOx SOx NH3

475,719.7 408,001.6 104,963.1 28,780.2 22,008.4
120.0
120.0
93.0
25.5
7.5
123.8
123.8
16.0
144.7
144.7
5.8
1.1
0.9
35.4
14.5
30,241.4
4,536.2
3,489.9
523.5
13,087.9
1,308.8
0.7
0.2
12,483.0
3,535.7
388.9
57,148.1
7.4
4.9
88.0
11.3
5.6
5.6
5,696.5
4,611.8
1,740.6
54,764.0
5,476.0
26,781.0
2,678.0
243,774.4 24,377.4
856,409.2 449,431.2 105,201.4 28,831.5 97,343.4

Table 3.5–35. Annual and typical daily emissions from all miscellaneous area sources for the PM10 NAA.

Category
Wildfires
Prescribed fires
Structure fires
Vehicle fires
Engine testing
Tilling
Harvesting
Unpaved ag roads
Cotton ginning
Fertilizer
Livestock
Crematories
Accidental releases
Humans
Leaf blowers dust
Offroad rec dust
Unpaved parking lots
Windblown dust
Total:

PM10

Annual emissions (tons/yr)
PM2.5
NOx
SOx NH3

4,860.02
0.00
22.56
26.45
0.15
1,228.67
58.99
910.64
0.09

4,168.2
0.00
22.56
26.45
0.12
184.30
8.85
91.06
0.02

520.84
0.91
1.03

57.29
0.61
1.03

843.00
2,159.00
3,009.00
7,380.43
21,021.78

318.16
216.00
301.00
738.04
6,133.71

1,072.32
0.00
2.92
1.06
4.61

294.02
0.00

224.84
0.00

1.89

1,093.74
8,418.39
10.87

1.39

Typical daily emissions (lbs/day)
PM10 PM2.5 NOx
SOx NH3
32,617.6
0.0
124.0
145.0
1.1
12,797.0
1,420.8
5,837.4
0.7

27,974.5
0.0
124.0
145.0
0.9
1,919.6
213.1
583.7
0.2

2,853.9
7.0
5.6

313.93
4.7
5.6

4619.2
11,830.0
16,490.0
40,440.7
129,190.0

1743.3
1,184.0
1,649.0
4,044.1
39,905.6

7,196.8
0.0
16.1
5.8
35.4

1,973.3
0.0
14.5

5,993.1
46,128.1
83.6

10.7

1,047.67

2005 Periodic PM10 Emission Inventory

1,091.78

297.30 10,784.63

88

1,509.0
0.0

5,740.6

7,337.7

1,998.5 59,370.9

Maricopa County, AZ

3.6

Summary of all area sources

Tables 3.6–1 and 3.6–2 summarize the total annual and typical daily emissions from all area
sources addressed in this chapter, for both Maricopa County and the PM10 nonattainment area,
respectively.
Table 3.6–1.

Summary of annual and typical daily emissions from all area sources in Maricopa County.

Category
Fuel Combustion
Industrial natural gas
Industrial fuel oil
Comm./inst. natural gas
Comm./inst. fuel oil
Residential natural gas
Residential wood
Residential fuel oil
All fuel combustion
Industrial Processes
Chemical manufacturing
Commercial cooking
Grain processing
Cold storage
Secondary metal prod.
Mineral processes
Mining & quarrying
Wood product mfg.
Rubber/plastic mfg.
Fabricated metal mfg.
Residential construction
Commercial construction
Road construction
Other construction
Electrical equip mfg.
ADEQ-permitted
portable sources
Road travel at
industrial sites
Industrial processes NEC
All Industrial Processes
Waste Treatment/disposal
On-site incineration
Open burning
Landfills
POTWs
Other waste
All Waste Treatment/
Disposal

PM10

Annual emissions (tons/yr)
PM2.5
NOx
SOx NH3

16.51
247.82
60.15
76.06
62.59
230.85
0.01
694.01

16.51
247.82
60.15
76.06
62.59
214.69
0.01
677.85

308.43
3,443.60
1,146.39
1,110.79
774.12
17.35
0.66
6,801.33

1.30
329.29
4.72
92.05
4.94
2.67
0.26
435.23

6.81
14.18
3.79
2.76

27.55

76.77
1,527.98
12.64

38.85
1,416.96
2.68

0.39

0.21

0.34

10.95
431.60
62.97
213.23
365.26
138.96
12,135.60
11,491.21
7,307.35
2,806.46
5.24

9.27
222.71
17.38
149.95
236.52
119.88
1,213.56
1,149.12
730.73
280.65
3.25

4.53

0.05

1,695.98
1.34

0.01

4.59

0.96

101.70

42.18

554.60

142.20

170.49
24.31
36,882.71

65.45
13.87
5,713.02

4.58
564.11

0.01
147.06

0.15
56.15
6.79

0.10
56.15
4.05

2.54
15.16
6.50

0.03

0.80
1,699.43

1.11

Typical daily emissions (lbs/day)
PM10 PM2.5 NOx SOx NH3
105.9
1,588.6
385.6
487.6
342.9
3,057.6
0.2
5,968.4

105.9
1,588.6
385.6
487.6
342.9
2,843.6
0.2
5,754.4

1,977.1
22,074.4
7,348.6
7,120.5
4,241.7
229.8
8.7
43,000.7

8.3
2,110.8
30.3
590.1
27.1
35.3
3.4
2,805.4

176.6

590.5
8,395.5
94.7

298.9
7,785.5
20.5

3.0

1.6

2.6

79.0
3,030.4
409.1
1,657.9
2,809.7
1,579.3
77,792.3
73,661.6
46,842.0
17,990.2
40.3

66.3
1,517.2
112.1
1,170.0
1,819.4
1,404.1
7,779.2
7,366.2
4,684.2
1,799.0
25.0

25.0

0.4

10,871.7
10.3

0.1

35.3

7.4

844.2

389.8

5,377.5

1,431.7

1,138.8
202.0
237,157.6

436.2
97.3
36,770.8

26.7
5,432.2

<0.1
1,469.1

1.6
550.9
39.5

1.1
550.9
23.5

19.9
148.4
36.3

0.3
6.3

606.0

369.6

22.8

27.5

1,198.1

945.1

227.4

34.0

1,310.85
79.55

48.51

4.15

5.01

142.64

108.81

28.35

6.14

2005 Periodic PM10 Emission Inventory

89

1,310.85

43.7
90.9
24.3
17.7

4.6
10,896.6

7,182.7

Maricopa County, AZ

7,182.7

Table 3.6–1. Summary of annual and typical daily emissions from all area sources in Maricopa County.

Category

PM10

Misc. Area Sources
Wildfires fires
Prescribed fires
Structure fires
Vehicle fires
Engine testing
Tilling
Harvesting
Unpaved ag roads
Cotton ginning
Fertilizer application
Livestock
Crematories
Accidental releases
Humans
Leaf blowers dust
Offroad rec dust
Unpaved park. lots
Windblown dust
All Misc. Sources
TOTAL, ALL AREA
SOURCES

Table 3.6–2.

Annual emissions (tons/yr)
PM2.5
NOx
SOx NH3

70,882.24
0.06
22.53
26.41
0.15
2,913.73
145.48
2,041.71
0.09
645.27
0.96
1.03

60,792.24 15,639.50 4,288.25
0.06
0.05
0.01
22.53
2.92
26.41
1.06
0.12
4.61
1.89
437.06
21.82
204.17
0.02
70.98
0.64
1.03

3,279.25
0.00

2,278.14
10,429.53
11.45

1.46

Typical daily emissions (lbs/day)
PM10 PM2.5 NOx SOx NH3
475,719.7 408,001.6 104,963.1 28,780.2
120.0
120.0
93.0
25.5
123.8
123.8
16.0
144.7
144.7
5.8
1.1
0.9
35.4
14.5
30,241.4
4,536.2
3,489.9
523.5
13,087.9
1,308.8
0.7
0.2
3,535.7
7.4
5.6

388.93
4.9
5.6

22,008.4
7.5

12,483.0
57,148.1
88.0

11.3

1,039.60

5,696.5

841.66
9,994.00
4,888.00
44,488.84
136,892.15

317.65
999.00
489.00
4,448.88
67,831.62 15,659.58 4,291.61

4611.8
1740.6
54,764.0
5,476.0
26,781.0
2,678.0
243,774.4 24,377.4
856,409.2 449,431.2 105,201.4 28,831.5

17,026.53

174,611.51

74,331.30 23,053.36 4,880.05

20,064.35 1,100,733.4 492,901.5 153,861.8 33,140.0 115,599.4

97,343.4

Summary of annual and typical daily emissions from all area sources in the PM10 NAA.

Category
Fuel Combustion
Industrial natural gas
Industrial fuel oil
Comm./inst. natural gas
Comm./inst. fuel oil
Residential natural gas
Residential wood
Residential fuel oil
All fuel combustion
Industrial Processes
Chemical manufacturing
Commercial cooking
Grain processing
Cold storage
Secondary metal prod.
Mineral processes
Mining & quarrying
Wood product mfg.
Rubber/plastic mfg.
Fabricated metal mfg.
Residential construction
Commercial construction
Road construction
Other construction
Electrical equip mfg
ADEQ-permitted
portable sources
Road travel at
industrial sites
Industrial processes NEC
All Industrial Processes

PM10

Annual emissions (tons/yr)
PM2.5
NOx
SOx NH3

16.40
246.14
59.72
75.51
62.69
231.22
0.01
691.70

16.40
246.14
59.72
75.51
62.69
215.04
0.01
675.51

306.33
3,420.18
1,138.13
1,102.80
775.35
17.38
0.66
6,760.83

1.29
327.05
4.69
91.39
4.95
2.67
0.26
432.30

27.36

76.25
1,539.90
12.64

38.59
1,428.01
2.68

0.38

0.21

0.34

10.95
430.89
54.77
211.78
362.77
138.01

9.27
222.17
15.52
148.93
234.91
119.06

4.53

0.05

1,684.45
1.34

11,331.99
11,085.55
7,236.42
2,475.89

1,133.20
1,108.55
723.64
247.59

5.24

3.25

0.01

4.59

101.70

42.18

554.60

142.20

167.78
24.29

64.48
13.86

4.08

0.01

35,266.82

5,555.90

563.60

147.05

2005 Periodic PM10 Emission Inventory

90

6.77
14.08
3.77
2.74

Typical daily emissions (lbs/day)
PM10 PM2.5 NOx SOx NH3
104.7
1,577.8
381.5
484.1
343.5
3,062.5
0.2
5,954.3

104.7
1,577.8
381.5
484.1
343.5
2,848.2
0.2
5,739.9

586.5
8,461.0
94.7

296.8
7,846.2
20.5

3.0

1.6

2.6

79.0
3,024.9
347.6
1,646.6
2,790.6
1,568.6

66.3
1,513.0
98.2
1,162.0
1,807.0
1,394.5

25.0

0.4

10,797.8
10.3

72,641.0
71,061.2
46,387.3
15,871.1

7,264.1
7,106.1
4,638.7
1,587.1

40.3

25.0

0.1

35.3

7.4

844.2

389.8

0.80

1,118.8
201.9

429.0
97.2

1,687.89

226,765.3

35,741.7

0.96

1,955.5
8.2
21,924.3 2,096.5
7,270.0
30.0
7,069.2 585.8
4,248.5
27.1
230.1
35.4
8.7
3.4
42,706.4 2,786.5

43.2
90.3
24.1
17.6

175.1

5,377.5 1,431.7
<0.1

4.6

5,428.5 1,469.1

22.9

10,822.7

Maricopa County, AZ

Table 3.6–2. Summary of annual and typical daily emissions from all area sources in the PM10 NAA.

Category
Fuel Combustion
Waste Treatment/disposal
On-site incineration
Open burning
Landfills
POTWs
Other waste
All Waste Treatment/
Disposal
Misc. Area Sources
Wildfires
Prescribed fires
Structure fires
Vehicle fires
Engine testing
Tilling
Harvesting
Unpaved ag roads
Cotton ginning
Fertilizer application
Livestock
Crematories
Accidental releases
Humans
Leaf blowers dust
Offroad rec dust
Unpaved park. lots
Windblown dust
All Misc. Sources
TOTAL, ALL AREA
SOURCES:

3.7

PM10

Annual emissions (tons/yr)
PM2.5
NOx
SOx NH3

0.15
24.24
6.79

0.10
24.24
4.05

2.54
6.51
6.50

0.03
1.11

Typical daily emissions (lbs/day)
PM10 PM2.5 NOx SOx NH3
1.6
243.6
39.5

1.1
243.6
23.5

19.9
65.3
36.3

0.3
6.3

606.0

369.6

22.8

27.5

144.4

34.0

7,238.4

7,196.8 1,973.3
0.0
0.0
16.1
5.8
35.4
14.5

1,509.0
0.0

1,321.01

7,238.4

79.55

48.51

4.15

5.01

110.74

76.90

19.70

6.14

1,321.01

890.8

637.8

4,860.02
0.00
22.56
26.45
0.15
1,228.67
58.99
910.64
0.09

4,168.2
0.00
22.56
26.45
0.12
184.30
8.85
91.06
0.02

1,072.32
0.00
2.92
1.06
4.61

294.02
0.00

224.84
0.00

32,617.6
0.0
124.0
145.0
1.1
12,797.0
1,420.8
5,837.4
0.7

27,974.5
0.0
124.0
145.0
0.9
1,919.6
213.1
583.7
0.2

520.84
0.91
1.03

57.29
0.61
1.03

2,853.9
7.0
5.6

313.9
4.7
5.6

843.00
2,159.00
3,009.00
7,380.43
21,021.78

318.16
216.00
301.00
738.04
6,133.71

1,091.78

297.30

10,784.63

4,619.2
11,830.0
16,490.0
40,440.7
129,190.0

1,743.3
1,184.0
1,649.0
4,044.1
39,905.6

7,337.7 1,998.5

59,370.9

57,091.05

12,442.02

8,435.92

882.80

13,820.89

362,800.5

82,025.0

55,616.9 6,288.1

77,607.1

1.89

1,093.74
8,418.39
10.87

1.39

5,993.1
46,128.1
83.6

10.7

1,047.67

5,740.6

Quality assurance / quality control procedures

Quality assurance and quality control (QA/QC) activities for the area source emissions inventory
were driven by the goal of creating a comprehensive, accurate, representative and comparable
inventory of area source emissions for Maricopa County and the nonattainment area. During
each step of creating, building and reviewing the area source emissions inventory, quality checks
and assurances were performed to establish confidence in the inventory structure and data.
Area source categories were selected for inclusion in the inventory based on the latest Emission
Inventory Improvement Program (EIIP) guidance available. EPA’s guidance for area source
categories included in the draft 2002 National Emission Inventory (NEI) was also evaluated, as
area source emissions from this inventory will be submitted to EPA for the 2005 NEI. The list of
area source categories developed based on these guidance documents was modified to fit the
characteristics of Maricopa County, with some area source categories determined to be insignificant (such as industrial coal combustion and oil and gas production). The 1999 Maricopa
County Periodic Ozone and Carbon Monoxide Emission Inventories and other regional emission
inventories were also consulted to confirm the completeness of the area source categories chosen
for inclusion.
Data for area source emission calculations were gathered from a wide universe of resources.
Whenever applicable, local surveyed data (such as annual emissions report) was used as this data
2005 Periodic PM10 Emission Inventory

91

Maricopa County, AZ

best reflects activity in the county and the nonattainment area. When local data was not
available, state data from Arizona State agencies (such as the Arizona Department of Transportation) and regional bodies (such as the Western Regional Air Partnership, WRAP) were
used. National level data (such as the US Census Bureau) was used when no local, state or
regional data was available. In addition, the most recent EIIP guidance for area sources was
consulted for direction in determining the most relevant data source for use in emissions
calculations.
Emissions calculations for area sources were performed by three air quality planners and one unit
manager. All area source emission estimates were calculated in spreadsheets to ensure the
calculations could be verified and reproduced. Whenever possible or available, the “preferred
method” described in the most recent EIIP guidance documents for area sources was used to
calculate emissions. Emissions were estimated using emission factors from EIIP guidance, AP42, and local source testing. Local seasonal and activity data were used when available, with
EPA and EIIP guidance used when no local seasonal or activity data existed. All calculations
were evaluated to ensure that emissions from point sources were not being double-counted and to
determine if rule effectiveness applied.
Once area source emission estimates had been produced, several quality control checks were
performed to substantiate the calculations. Most area source calculations were peer-reviewed by
two other planners, with all area sources being reviewed by at least one other planner. Peer
review ensured that all emission calculations were reasonable and could be reproduced.
Sensitivity analyses and computational method checks were performed on area sources when
emissions seemed to be outside the expected ranges. When errors were found, the appropriate
changes were made by the author of the calculations to ensure consistency of the emissions
calculations. The peer-reviewed emissions estimates were combined into a draft area source
chapter. This draft chapter was read through in its entirety by the unit manager and the three air
quality planners for final review, with any identified errors corrected by the author of the section.
The draft version of the area source chapter was sent to the Arizona Department of Environmental Quality, the Arizona Department of Transportation, and the Maricopa Association of
Governments for a quality assurance review. These agencies provided comments which were
addressed and incorporated into the final area source chapter. Further quality analysis was
performed by inputting the emission estimates into EPA’s “QA/QC basic format and content
checker”, prior to submitting the data to the 2005 NEI.
The QA/QC activities described here have produced high levels of confidence in the area source
emissions estimates detailed in this chapter, and represent the best efforts of the inventory
preparers.

2005 Periodic PM10 Emission Inventory

92

Maricopa County, AZ

3.8

References

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Service, September 2005.
AASS, 2006. 2005 Arizona Agricultural Statistics Bulletin, Arizona Agricultural Statistics
Service, September 2006.
ADOA, 2004. Fertilizer Annual Tonnage Reported, Calendar Year 2003. Arizona Department
of Agriculture, Gary Christian, pers. comm., April 12, 2004.
ADOC, 2006. Heating Degree Days: Phoenix. Internet address:
http://www.azcommerce.com/doclib/ENERGY/ Degreedays.pdf.
ASLDa, 2006. June 28, 2006, email containing fire data for Maricopa County for 2005 from
WildCAD, from Jeff Herweg, Office of State Forester, Forestry Division, Arizona State Land
Department, 1110 West Washington Street, Suite 100, Phoenix, AZ.
ASLDb, 2006. December 19, 2006, telephone conversation with Jeff Herweg, Office of State
Forester, Forestry Division, Arizona State Land Department, 1110 West Washington Street,
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Battye, R., W. Battye, C. Overcash and S. Fudge, 1994. Development and Selection of
Ammonia Emission Factors. Prepared for U.S. Environmental Protection Agency,
Atmospheric Research and Exposure Assessment Laboratory by EC/R Inc., Durham, NC,
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CARB, 1999. Area Source Methodologies – Section 7.6 (Cattle Feedlot Dust). California Air
Resources Board, Sacramento, CA. December 20, 1999. Internet address:
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CARB, 2003. Area-wide Source Methodologies, Section 7.5 Agricultural Harvest Operations,
revised January 2003. Internet address: http://www.arb.ca.gov/ei/areasrc/index7.htm.
CARB, 2004. Area Source Methodologies – Section 7.6 (Cattle Feedlot Dust). California Air
Resources Board, Sacramento, CA. Revised May 2004. Internet address:
http://www.arb.ca.gov/ei/areasrc/fullpdf/FULL7-6.PDF
CARB, 2006 Speciation Profiles and Size Fractions. California Air Resources Board,
Sacramento, CA. Internet address: http://www.arb.ca.gov/emisinv/speciate/speciate.htm.
Clark County, 2001. PM10 State Implementation Plan Plan for Clark County (Nevada),
Appendix B: Emissions Inventory Methodology, Emission Factors, and Emission Estimates,
June 2001, p. B-59. Internet address: http://www.co.clark.nv.us/daqem/ aq/plans/
pm10sip2001.html.
Coon, 2004. Personal communication between Dennis coon, Arizona Agricultural Statistical
Service and Dena Konopka, MCESD, on February 3, 2004.
CMU, 2004. Carnegie Mellon University Ammonia Model Version 3. Internet address:
http://www.cmu.edu/ammonia/
DES, 2006. July 1, 2005 Population Estimates for Arizona's Counties, Incorporated Places and
Balance of County, Population Statistics Unit, Research Administration, Department of
Economic Security, February 23, 2006.
Fitz et. al., 2005. Determination of Particulate Emission Rates from Leaf Blowers. University
of California Riverside. Internet address:
http://www.epa.gov/ttn/chief/conference/ei15/session5/fitz.pdf
Harris InfoSource, 2003. Selectory CD-ROM Database of Arizona Businesses. March 2003.
Houck, James E. and Tiegs, Paul E., 1998. Residential Wood Combustion– PM2.5 Emissions.
Rep. prepared for WESTAR PM2.5 Emission Inventory Workshop, July 22-23, 1998. OMNI
Environmental Services, Inc., Beaverton, OR. Internet address: http://www.omnitest.com/Publications/westar.pdf.
2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

MAG, 2000. Draft Final Report 1994 Regional PM10 Emission Invnetory for the Maricopa
County Nonattainment Area, Revised MAG 1999 Serious Area Particulate Plan for PM10 for
the Maricopa County Nonattainment Area, Appendices Volume One. Maricopa Association
of Governments, Phoenix, AZ, Feb. 2000.
MCESD, 1993. 1990 Base Year Ozone Emission Inventory for Maricopa County, Arizona,
Nonattainment Area, Draft Submittal, Maricopa County Environmental Quality &
Community Services Agency, Phoenix, AZ, March 1993.
MCESD, 1999. 1999 Periodic Ozone Emissions Inventory for the Maricopa County, Arizona
Nonattainment Area, Maricopa County Environmental Services Department, Phoenix AZ,
Rev. Aug. 2002.
MCESD, 2006. 2002 Periodic Emissions Inventory for PM10 for the Maricopa County, Arizona,
Nonattainment Area, Maricopa County Environmental Services Department, June 2004
(Revised March 2006).
MCAQD, 2006. Personal communications with George Mills, Dust Compliance Division,
MCAQD, and Dena Konopka, MCAQD, November 2006.
MCAQD, 2007. Draft Rule Effectiveness Study for Maricopa County. Maricopa County Air
Quality Department, Phoenix, AZ, Jan. 2007.
Pollack, A.K., C. Lindhjem, C. Tran, T. Stoeckenius, R. Downing, R. Schindler, E. Raisanen, D.
Konopka and R. Sedlacek, 2003. Maricopa County 2002 Comprehensive Emission
Inventory for the Cap and Trade Oversight Committee, Final Report, Prepared for AZ Dept.
of Environmental Quality, October 9, 2003.
Tchobanoglous, G., 1979. Wastewater Engineering: Treatment, Disposal, and Reuse. McGrawHill Science/Engineering/Math, New York.
URS and ERG, 2001. Technical Support Document of Quantification of Agricultural Best
Management Practices, Final, URS Corporation and Eastern Research Group, Inc., June 8,
2001
US Census Bureau, 2006a. 2005 American Community Survey, Table B25117: Tenure by
House Heating Fuel for Maricopa County and Arizona State. Internet address:
http://factfinder.census.gov
US Census Bureau, 2006b. 2004 County Business Patterns (NAICS). Internet address:
http://censtats.census.gov/cgi-bin/cbpnaic/cbpsel.pl
US DOE, 2006a. US Department of Energy, Energy Information Administration. Adjusted
Sales for Industrial Use:Distillate Fuel Oil, Residual Fuel Oil, and Kerosene, 2005 (Table 21)
US DOE, 2006b. US Department of Energy, Energy Information Administration. Adjusted
Sales for Commercial Use:Distillate Fuel Oil, Residual Fuel Oil, and Kerosene, 2005 (Table
20)
US DOE, 2006c. US Department of Energy, Energy Information Administration. State Energy
Data 2000 Consumption Tables, Table 8–Residential Energy Consumption Estimates, 1960–
2003, Arizona. Internet address: http://www.eia.doe.gov/emeu/states/sep_use/
res/use_res_az.html
US EPA, 1980. Compilation of Air Pollution Emission Factors (AP-42), Fifth Ed. Vol. I:
Stationary Point and Area Sources. Section 9.3.2: Grain Harvesting. US Environmental
Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park,
NC. Internet address: http://www.epa.gov/ttn/chief/ap42/ch09/
US EPA, 1988. Control of Open Fugitive Sources. US Environmental Protection Agency,
Office of Air Quality Planning and Standards, Research Triangle Park, NC. EPA Rep.
450/3-88-008, Sept. 1988.
US EPA, 1992. Compilation of Air Pollution Emission Factors (AP-42). Fifth Ed. Vol. I:
Stationary Point and Area Sources. Section 2.5: Open Burning. US Environmental
2005 Periodic PM10 Emission Inventory

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Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park,
NC.
US EPA, 1997. Compilation of Air Pollution Emission Factors (AP-42). Fifth Ed. Vol. I:
Stationary Point and Area Sources. Section 13.2.1: Paved Roads. US Environmental
Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park,
NC.
US EPA, 1998a. Compilation of Air Pollution Emission Factors (AP-42). Fifth Ed. Vol. I:
Stationary Point and Area Sources. Section 1.4: Natural Gas Combustion. US
Environmental Protection Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, NC. Internet address: http://www.epa.gov/ttn/chief/ap42/ch01/final/
c01s04.pdf
US EPA, 1998b. Compilation of Air Pollution Emission Factors (AP-42). Fifth Ed. Vol. I:
Stationary Point and Area Sources. Section 13.2.2: Unpaved Roads. US Environmental
Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park,
NC.
US EPA, 2000. Area Source Category Method Abstract: Vehicle Fires. Emission Inventory
Improvement Program (EIIP), May 2000. Internet address:
http://www.epa.gov/ttn/chief/eiip/techreport/volume03/vehclf13.pdf
US EPA, 2001a. Introduction To Area Source Emission Inventory Development. Emission
Inventory Improvement Program (EIIP) Vol. III, Chap. 1. Prepared by Eastern Research
Group, Revised Final, Jan. 2001. Internet address: http://www.epa.gov/ttn/chief/eiip/
techreport/volume03/iii01_apr2001.pdf
US EPA, 2001b. Open Burning. Emission Inventory Improvement Program (EIIP) Vol. III,
Chap. 16. Revised Final, Jan. 2001. Prepared by Eastern Research Group, Inc. for the Area
Source Committee, EIIP. Internet address: http://www.epa.gov/ttn/chief/eiip/techreport/
volume03/iii16_apr2001.pdf.
US EPA, 2001c. PM Calculator software, ver. 2.0.2. Jan. 2001. US Environmental Protection
Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC. Internet
address: http://www.epa.gov/ttnchie1/software/pmcalc/index.html
US EPA, 2001d. Residential Wood Combustion. Emission Inventory Improvement Program
(EIIP) Vol. III, Chap. 2. Revised Final, Jan. 2001. Prepared by Eastern Research Group, Inc.
for the Area Source Committee, EIIP. Internet address: http://www.epa.gov/ttn/chief/eiip/
techreport/volume03/iii02_apr2001.pdf.
US EPA, 2001e. Structure Fires. Emission Inventory Improvement Program (EIIP) Vol. III,
Chap. 18. Revised Final, Jan. 2001. Prepared by Eastern Research Group, Inc. for the Area
Source Committee, EIIP. Internet address: http://www.epa.gov/ttn/chief/eiip/techreport/
volume03/iii18_apr2001.pdf.
US EPA, 2002. Residential Construction – Fugitive Dust. Emission Inventory Improvement
Program (EIIP) Vol. IX: Particulate Emissions. Internet address: http://www.epa.gov/ttn/
chief/eiip/techreport/volume09/residn3.pdf
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Environmental Protection Agency, Office of Air Quality Planning and Standards, Research
Triangle Park, NC. Dec. 19, 2003. Internet address: http://www.epa.gov/ttn/
chief/net/2002inventory.html.
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Program (EIIP) Vol. IX: Particulate Emissions. US Environmental Protection Agency, Feb.
2003. Internet address: http://www.epa.gov/ttn/chief/eiip/techreport/volume09/agtilling.pdf

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Maricopa County, AZ

US EPA, 2003c. Fugitive Dust from Beef Cattle Feedlots. Emission Inventory Improvement
Program (EIIP) Vol. IX: Particulate Emissions. US Environmental Protection Agency, Feb.
2003. Internet address: http://www.epa.gov/ttn/chief/eiip/techreport/volume09/feedlots.pdf
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Matter National Ambient Air Quality Standards (NAAQS) and Regional Haze Regulations.
USEPA Office of Air Quality Planning and Standards, Research Triangle Park, NC. August
2005, updated Nov. 2005. Available at: http://www.epa.gov/ttn/chief/eidocs/eiguid/
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Inventory for Criteria and Hazardous Air Pollutants (Feb. 2006 Version). Prepared by E.H.
Pechan & Associates, Inc. for Emission Factor and Inventory Group. Internet address:
ftp://ftp.epa.gov/EmisInventory/2002finalnei/documentation/nonpoint/2002nei_final_nonpoi
nt_documentation0206version.pdf.
US EPA, 2006b. Compilation of Air Pollution Emission Factors (AP-42). Fifth Ed. Vol. I:
Stationary Point and Area Sources. Section 13.2.2: Unpaved Roads. November 2006.
Internet address: http://www.epa.gov/ttn/chief/ap42/ch13/final/c13s0202.pdf
USGS, 2006. United States Geological Survey GeoMAC Wildland Fire Support database.
Internet address: http://geomac.usgs.gov/
USFS, 2006a. National Fire and Aviation Management Web Applications, Historical Incident
ICS-209 Reports. Internet address: http://famweb.nwcg.gov/?display=text
USFS, 2006b. July 24, 2006, e-mail from Mark Fitch, US Forest Service,
Fitch.Mark@azdeq.gov.
WGA/WRAP 2005. 2002 Fire Emission Inventory for the WRAP Region - Phase II. Western
Governors Association/Western Regional Air Partnership, prepared by Air Science, Inc.
Project 178-6, July 22, 2005. pp. 48–51. Internet address: http://www.wrapair.org/forums/
fejf/tasks/FEJFtask7PhaseII.html.
WRAP 2006a. Fugitive Dust Handbook. Chapter 3.0 Construction and Demolition, September
2006. Internet address: http://wrapair.org/forums/dejf/fdh/index.html.
WRAP 2006b. Fugitive Dust Handbook. Chapter 2.0 Agricultural Tilling, September 2006.
Internet address: http://wrapair.org/forums/dejf/fdh/index.html.
WRAP 2006c. Fugitive Dust Handbook. Chapter 10.0 Agricultural Harvesting, September 2006.
Internet address: http://wrapair.org/forums/dejf/fdh/index.html.
WRAP 2006c. Fugitive Dust Handbook. Chapter 6.0 Unpaved Roads, September 2006. Internet
address: http://wrapair.org/forums/dejf/fdh/index.html.
WRAP 2006d. Fugitive Dust Handbook. Chapter 13.0 Livestock Husbandry, September 2006.
Internet address: http://wrapair.org/forums/dejf/fdh/index.html.

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4.

Nonroad Mobile Sources

4.1

Introduction

Nonroad mobile sources are defined as those that move or are moved within a 12-month period
and are not licensed or certified as highway vehicles. Nonroad mobile sources are vehicles and
engines that fall under the following categories:
•
•
•
•
•
•
•
•
•
•
•
•
•

Agricultural equipment, such as tractors, combines and balers;
Airport ground support equipment, such as baggage tugs and terminal tractors;
Commercial equipment, such as generators and pumps;
Industrial equipment, such as forklifts and sweepers;
Construction and mining equipment, such as graders, back hoes and trenchers;
Lawn and garden equipment, such as leaf blowers and lawn mowers;
Logging equipment (not present in Maricopa County);
Pleasure craft, such as power boats and personal watercraft;
Railway maintenance equipment, such as rail straighteners;
Recreational equipment, such as all-terrain vehicles and off-road motorcycles;
Underground mining and oil field equipment (not present in Maricopa County);
Aircraft, such as jet and piston engines; and
Locomotives, such as switching and line haul trains.

Emission calculations for all nonroad mobile sources except aircraft, airport ground support
equipment and locomotives are derived from EPA’s NONROAD2005 model (Core version
2005a, Feb. 2006). Aircraft and airport ground support equipment emission calculations were
derived from individual surveys of county airports. Locomotive emission calculations were
derived from surveys of the 3 railroad companies that have operations in the county (Burlington
Northern Santa Fe, Union Pacific and Amtrak).
County specific temperature and fuel-related inputs are required for the operation of the
NONROAD2005 model. Monthly temperature and fuel data were provided by the Arizona State
Weights and Measures Department. The following table lists the local county inputs used:
Table 4.1–1.

NONROAD2005 model county temperature and fuel-related inputs.
Max
Min
Average
Fuel RVP
Diesel Sulfur
Gasoline Sulfur
Month
(°F)
(°F)
(°F)
(psi)
(ppm)
(ppm)
January
81
41
57.8
9
354
39
February
72
46
59.2
9
318
43
March
88
46
63.9
9
303
29
April
96
53
72.3
8
301
39
May
109
60
82.7
7
299
43
June
114
71
90.4
7
286
84
July
116
79
97.3
6
260
45
August
113
72
92.2
7
287
40
September
108
70
89.6
7
314
37
October
101
58
78.3
8
339
30
November
90
40
66.3
9
364
34
December
78
35
56.8
9
389
30
Note: All other required temperature and fuel-related inputs not listed assumed NONROAD2005 default values

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EPA recommends adjusting default NONROAD2005 model values (such as equipment
population, activity levels of equipment, growth factors, etc.) where local data is available, as the
default values in the model are derived from national averages. The NONROAD2005 model
defaults were adjusted in the following manner:
•

Equipment population numbers and activity levels for commercial lawn and garden
equipment were adjusted based on 2003 survey results of the commercial lawn and
garden industry performed by ENVIRON as part of an inventory developed to study the
impact of visibility impairing pollutants (ENVIRON et al., 2003). Survey results show
that for most categories of lawn and garden equipment, the equipment populations for
Maricopa County are significantly lower than EPA default values, while the average
annual hours of operation for most equipment types are slightly higher than EPA's values.
Using these new local data results is a considerable decrease in emissions from this
category, compared with earlier results using EPA default data.

The NONROAD2005 model does not calculate emission values for NH3. Ammonia emission
calculations for NONROAD2005 model were derived by using a ratio of NOx emissions
developed by ENVIRON (2003).
Spatial allocation factors were developed (based on EPA guidance documents) to apportion
nonroad emissions to the PM10 nonattainment area. The approaches used are described in each
section of this chapter.
Temporal allocations (used to calculate PM10 average-day emissions) for nonroad equipment
categories modeled in the NONROAD2005 model come from EPA recommendations on weekday and weekend day activity levels for each nonroad equipment category (US EPA, 1999).
Table 4.1–2 below lists the weighted activity level allocation fractions for each equipment class
for weekdays and weekend days. For this report, the most conservative (highest) allocation
fraction in each nonroad equipment class was used to calculate average-day emissions.
Table 4.1–2. Default weekday and weekend day activity allocation fractions.
Equipment category
Weekday
Weekend day
Agricultural
0.1666667
0.0833334
Airport ground support
0.1428571
0.1428571
Commercial
0.1666667
0.0833334
Construction and mining
0.1666667
0.0833334
Industrial
0.1666667
0.0833334
Lawn and garden (residential)
0.1111111
0.2222222
Lawn and garden (commercial)
0.1600000
0.1000000
Logging
0.1666667
0.0833334
Pleasure craft
0.0600000
0.3500000
Railway maintenance
0.1800000
0.0500000
Recreational
0.1111111
0.2222222

4.2

Agricultural equipment

Annual emissions from agricultural equipment in Maricopa County were calculated using EPA’s
NONROAD2005 model, as discussed above. County-wide results are shown in Table 4.2–1.

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Table 4.2–1. Annual emissions (in tons/yr) from agricultural equipment in Maricopa County.
PM10
PM2.5
NOx
SOx
NH3
39.21
38.03
386.34
5.95
0.73

PM10 nonattainment area annual emissions were calculated based on EIIP guidance (US EPA,
2002) which recommends using the ratio of agricultural land inside the nonattainment area
(223,627 acres) to agricultural land inside the county (465,833 acres). See Section 1.5.2 for a
discussion of land-use data used.
PM10 nonattainment area emissions
from agricultural equipment

= County PM10 emissions

× Agricultural land-use allocation factor

= 39.21 tons
× 48.01%
= 18.83 tons PM10 /yr
Table 4.2–2. Annual emissions (in tons/yr) from agricultural equipment in the PM10 NAA.
PM10
PM2.5
NOx
SOx
NH3
18.83
18.26
185.46
2.86
0.35

County average-day emissions were calculated by multiplying annual emissions (generated by
the NONROAD2005 model) by the most conservative weekday/weekend day activity allocation
factor for agricultural equipment listed in Table 4.1–2, and dividing the product by the number of
weeks (52) in the year (US EPA, 1999), as follows:
Maricopa County PM10 = Annual PM10
average-day emissions
emissions
(lbs/day)
(tons/year)
= 39.21
= 251.4 lbs/day

× 2000
(lb/ton)

× daily activity allocation factor
for agricultural equipment
expressed as (week/day)
× 0.166667

× 2000

÷ 52
(weeks per year)
÷ 52

Table 4.2–3. Typical daily emissions (lbs/day) from agricultural equipment in Maricopa County.
PM10
PM2.5
NOx
SOx
NH3
251.4
243.8
2,476.5
38.2
4.7

PM10 nonattainment area average-day emissions were calculated by multiplying County averageday emissions by the agricultural land-use allocation factor:
PM10 nonattainment area
average-day emissions

= Maricopa County PM10 ×
average-day emissions

Agricultural land-use allocation factor

= 251.4 lbs/day
= 120.7 lbs/day

48.01%

×

Table 4.2–4. Typical daily emissions (lbs/day) from agricultural equipment in the PM10 nonattainment area.
PM10
PM2.5
NOx
SOx
NH3
120.7
117.0
1,188.9
18.3
2.2

4.3

Airport ground support equipment

Annual emissions from airport ground support equipment (GSE) were calculated based on the
MAG Airport Emission Model. Activity data on aircraft operations was obtained through the
Federal Aviation Administration website for 8 towered airports in Maricopa County. Since all 8
towered airports are in the PM10 nonattainment area, the calculated emissions are equal to
Maricopa County totals.
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Table 4.3–1.
PM10
16.50

Annual emissions (in tons/yr) from airport ground support equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
15.70 467.82 14.71
16.50
15.70 467.82 14.71

Table 4.3–2.
PM10
90.4

4.4

Typical daily emissions (in lbs/day) from airport ground support equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
86.0 2,563.4
80.6
90.4
86.0 2,563.4
80.6

Commercial equipment

Annual emissions from commercial equipment in Maricopa County were calculated using EPA’s
NONROAD2005 model, as described in Section 4.1. Annual emissions for the PM10 nonattainment area for this category were derived by applying the ratio of industrial employment in the
nonattainment area to Maricopa County-level totals, as data on the number of wholesale
establishments recommended by EIIP guidance (US EPA, 2002) was not available. See Section
1.5.1 for a discussion of the industrial employment data used.
Table 4.4–1.

Annual emissions (in tons/yr) from commercial equipment.
Maricopa County
PM10 nonattainment area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
119.34 114.47 1,449.72
17.32
23.18 118.48 113.65 1,439.36
17.20

NH3
23.01

County average-day emissions were calculated by multiplying Maricopa County annual emissions (generated by the NONROAD2005 model) by the most conservative weekday/weekend
day activity allocation factor for commercial equipment (0.1666667) listed in Table 4.1–2, and
dividing the product by the number of weeks (52) in the year (US EPA, 1999). PM10 nonattainment area average-day emissions were calculated based on industrial employment ratios as
described above.
Table 4.4–2.
PM10
765.0

4.5

Typical daily emissions (in lbs/day) from commercial equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
733.8 9,293.1 111.0
148.6
759.5
728.5 9,226.7 110.2

NH3
147.5

Construction and mining equipment

Annual emissions from construction and mining equipment in Maricopa County were calculated
using EPA’s NONROAD2005 model as described in Section 4.1. Annual emissions for the
PM10 nonattainment area for this category were derived by applying the ratio of population in the
nonattainment area to Maricopa County-level totals as a conservative estimate, as the EIIPrecommended allocation factor of total dollar value of construction was unavailable (US EPA,
2002). See Section 1.5.1 for a discussion of the population data used.

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Table 4.5–1.

Annual emissions (in tons/yr) from construction and mining equipment.
Maricopa County
PM10 nonattainment area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
1,354.26 1,311.26 16,016.62 287.07
31.22
1,356.40
1,313.34 16,042.02 287.52

NH3
31.27

County average-day emissions were calculated by multiplying Maricopa County annual
emissions (generated by the NONROAD2005 model) by the most conservative
weekday/weekend day activity allocation factor for construction/mining equipment (0.1666667)
listed in Table 4.1–2, and dividing the product by the number of weeks (52) in the year (US
EPA, 1999). PM10 nonattainment area average-day emissions were calculated based on
population ratios as described above.
Table 4.5–2.

Typical daily emissions (in lbs/day) from construction and mining equipment.
Maricopa County
PM10 nonattainment area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
8,681.1 8,405.5 102,670.7 1,840.2 200.1 8,694.9 8,418.8 102,833.5 1,843.1 200.4

4.6

Industrial equipment

Annual emissions from industrial equipment in Maricopa County were calculated using EPA’s
NONROAD2005 model, as described in Section 4.1. Annual emissions for the PM10 nonattainment area for this category were derived by applying the ratio of industrial employment in the
nonattainment area to Maricopa County-level totals as a conservative estimate, as the number of
employees in manufacturing recommended by EIIP guidance (US EPA, 2002) was not available.
See Section 1.5.1 for a discussion of the industrial employment data used.
Table 4.6–1.
PM10
110.02

Annual emissions (in tons/yr) from industrial equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10 PM2.5
NOx
SOx
107.01 3,316.67 26.63
79.21 109.23 106.25 3,292.98 26.44

NH3
78.64

County average-day emissions were calculated by multiplying Maricopa County annual emissions (generated by the NONROAD2005 model) by the most conservative weekday/weekend
day activity allocation factor for industrial equipment (0.1666667) listed in Table 4.1–2, and
dividing the product by the number of weeks (52) in the year (US EPA, 1999). PM10 nonattainment area average-day emissions were calculated based on industrial employment ratios as
described above.
Table 4.6–2.
PM10
705.2

Typical daily emissions (in lbs/day) from industrial equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10 PM2.5
NOx
SOx
686.0 21,260.7 170.7
507.7
700.2 681.1 21,108.8 169.5

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NH3
504.1

Maricopa County, AZ

4.7

Lawn and garden equipment

Annual emissions from lawn and garden equipment in Maricopa County were calculated using
EPA’s NONROAD2005 model, as described in Section 4.1. These results reflect new equipment
population and usage estimates from survey work done in early 2003 for the Arizona Department
of Environmental Quality (discussed further in Section 4.1). Annual emissions for the PM10
nonattainment area for this category were derived by applying the ratio of population in the
nonattainment area to Maricopa County-level totals, since housing units was not available, as
recommended by EIIP guidance (US EPA, 2002). See Section 1.5.1 for a discussion of the
population data used.
Table 4.7–1.
PM10
178.22

Annual emissions (in tons/yr) from lawn and garden equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
165.18 843.10
9.53
21.21 178.50 165.45 844.43
9.54

NH3
21.24

County average-day emissions were calculated by multiplying Maricopa County annual emissions (generated by the NONROAD2005 model) by the most conservative weekday/weekend
day activity allocation factor for lawn and garden equipment (0.1600000 for the commercial
segment, 0.2222222 for residential) listed in Table 4.1–2, and dividing the product by the
number of weeks (52) in the year (US EPA, 1999). PM10 nonattainment area average-day
emissions were calculated based on population as described above.
Table 4.7–2.

Typical daily emissions (in lbs/day) from lawn and garden equipment.
Maricopa County
PM10 nonattainment area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
1,226.0 1,135.5 5,882.8
64.2
155.6 1,228.0 1,137.3 5,892.2
64.3
155.8

4.8

Pleasure craft

Annual emissions from pleasure craft equipment in Maricopa County were calculated using
EPA’s NONROAD2005 model, as described in Section 4.1. Annual emissions for the PM10
nonattainment area for this category were derived by applying the ratio of water surface area in
the nonattainment area to Maricopa County-level totals, as recommended by EIIP guidance (US
EPA, 2002). See Section 1.5.2 for a discussion of the land-use data used.
Table 4.8–1.
PM10
11.33

Annual emissions (in tons/yr) from pleasure craft equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
10.45
70.58
0.71
1.49
8.60
7.94
53.59
0.54

NH3
1.13

County average-day emissions were calculated by multiplying Maricopa County annual emissions (generated by the NONROAD2005 model) by the most conservative weekday/weekend
day activity allocation factor for pleasure craft (0.3500000) listed in Table 4.1–2, and dividing
the product by the number of weeks (52) in the year (US EPA, 1999). PM10 nonattainment area
average-day emissions were calculated based on water surface area as described above.
Table 4.8–2.
PM10
152.5

Typical daily emissions (in lbs/day) from pleasure craft equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
140.7
950.0
9.5
20.1
115.8
106.9
721.4
7.2

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NH3
15.2

Maricopa County, AZ

4.9

Railway maintenance equipment

Annual emissions from railway maintenance equipment in Maricopa County were calculated
using EPA’s NONROAD2005 model, as described in Section 4.1. Annual emissions for the
PM10 nonattainment area for this category were derived by applying the ratio of population in the
nonattainment area to Maricopa County-level totals, as recommended by EIIP guidance (US
EPA, 2002). See Section 1.5.1 for a discussion of the population data used.
Table 4.9–1.
PM10
1.20

Annual emissions (in tons/yr) from railway maintenance equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
1.16
9.27
0.14
0.02
1.20
1.17
9.29
0.14
0.02

County average-day emissions were calculated by multiplying Maricopa County annual emissions (generated by the NONROAD2005 model) by the most conservative weekday/weekend
day activity allocation factor for railway maintenance equipment (0.1800000) listed in Table
4.1–2, and dividing the product by the number of weeks (52) in the year (US EPA, 1999). PM10
nonattainment area average-day emissions were calculated based on the population ratio as
described above.
Table 4.9–2.
PM10
8.3

4.10

Typical daily emissions (in lbs/day) from railway maintenance equipment.
Maricopa County
PM10 nonattainment area
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
8.1
64.2
1.0
0.1
8.3
8.1
64.3
1.0
0.1

Recreational equipment

Annual emissions from recreational equipment in Maricopa County were calculated using EPA’s
NONROAD2005 model, as described in Section 4.1. Annual emissions for the PM10 nonattainment area for this category were derived by applying the ratio of passive open space, golf
courses and vacant land use in the nonattainment area to Maricopa County-level totals as
recommended by EIIP guidance (US EPA, 2002). See Section 1.5.2 for a discussion of the landuse data used.
Table 4.10–1. Annual emissions (in tons/yr) from recreational equipment.
Maricopa County
PM10 nonattainment area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
42.29
38.95
59.99
0.68
1.97
8.89
8.19
12.61
0.14

NH3
0.41

County average-day emissions were calculated by multiplying Maricopa County annual emissions (generated by the NONROAD2005 model) by the most conservative weekday/weekend
day activity allocation factor for recreational equipment (0.2222222) listed in Table 4.1–2, and
dividing the product by the number of weeks (52) in the year (US EPA, 1999). PM10 nonattainment area average-day emissions were calculated based on land use as described above.
Table 4.10–2. Typical daily emissions (in lbs/day) from recreational equipment.
Maricopa County
PM10 nonattainment area
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
361.4
332.9
512.7
5.8
16.8
76.0
70.0
107.8
1.2

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3.5

Maricopa County, AZ

4.11

Aircraft

A survey of 17 airports in Maricopa County was conducted to collect data on the total number of
landing and take-off operations (LTO’s) as well as fleet mix to determine the types of aircraft
used and idle times to calculate annual emissions. Of these airports, four locations (Buckeye
Municipal Airport, Gila Bend Municipal Airport, Gila Bend Air Force Auxiliary Field and
Wickenburg Municipal Airport) are outside of the nonattainment area.
Emissions were derived from both computer modeling results and National Emissions Inventory
(NEI) default emission factors. For airports that provided complete survey data, the FAA’s latest
airport Emissions and Dispersion Modeling Software (EDMS 4.5) was used to calculate
emissions. Parameters required to apply this model include annual LTO figures, fleet mix of
types of aircraft in each activity category, and average taxi-in and taxi-out times.
For those airports that provided only partial data, the EDMS model could not be used to calculate
emissions for that specific airport. Instead, emission factors from similar airports that provided
complete information was used. Examples of missing data were detailed fleet mix data or
unknown idle times. For airports that did not respond to the survey, LTO figures, taxi-in/taxi-out
times and aircraft types were derived from online databases that provide detailed aeronautical
information on airports at http://www.transtats.bts.gov, http://www.apo.data.faa.gov and
http://www.airnav.com.
The EDMS model was used to estimate emissions for all pollutants for the air carrier category
and only for NOx and SOx for air taxi, general aviation and military. This is due to the fact that
the EDMS model version 4.5 does not estimate emissions for PM10 or PM2.5 for air taxi, general
aviation and military. For these aircraft categories, 2002 NEI default emission factors for PM10
and PM2.5 were used (ERG, 2001). The PM10 and PM2.5 emission factors are shown in Table
4.11–1.
Table 4.11–1. NEI default emission factors for PM10 and PM2.5, by aircraft category.
PM10 Emission
PM2.5 Emission
Aircraft category Abbreviation
SCC
Factor (lbs/LTO) Factor (lbs/LTO)
Air Taxi
AT
2275060000
0.60333
0.42
General Aviation
GA
2275050000
0.2367
0.163
Military
ML
2275001000
0.60333
0.42

The following provides an example of how aircraft emissions were calculated using the FAA’s
EDMS modeling software for Skyranch at Carefree, a small, general-aviation only airport that
has an ordinance mandate that the airport can only accept aircraft that weigh 12,500 lbs or less.
Since the EDMS model requires an exact LTO value for each airframe considered in the model,
and since the survey did not require respondents to supply exact LTO counts for each individual
airframe, an averaging method was used. EDMS was run to produce a composite emission
factor for an airport based on the most common type of aircraft using that facility. The
composite emission factor was then applied to the actual reported activity for the airport. For
Skyranch, a composite profile was created by selecting within the EDMS model, 12 aircraft
likely to utilize the airport, based on data provided by the airport survey and follow-up
correspondence. These 12 aircraft types are: Cessna 150, Comanche, Robin R 2160, Socata
Tampico, Cessna 172 Skyhawk, Piper PA-28, Robin R 3000, Socata Tobago, Cherokee six,
Robin DR 400, Rockwell Commander, and Spencer S-12 Air Car.
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Maricopa County, AZ

The model run with the 12 aircraft types resulted in total NOx emissions of 0.277 tons (assuming
each of the 12 aircraft types had 1000 LTOs each during the period).
Composite NOx emission = Σ modeled NOx emissions (tons/yr) × 1 yr / 12,000 LTOs × 2000 lb/ton
factor (lb/LTO)
= 0.046 lb NOx /LTO

This composite emission factor was then multiplied by the actual number of LTOs at the airport
to derive an annual NOx emissions total:
NOx emissions (lb/ yr)

= 2,248 LTO/yr × 0.046 lb NOx /LTO
= 103.6 lb NOx /yr

The above approach was used to calculate annual NOx and SOx directly from the EDMS model.
Annual PM10 and PM2.5 emissions were calculated by multiplying the default emission factor
shown in Table 4.11–1 by the activity level (LTO/year) for the airport and its appropriate aircraft
category.

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Table 4.11–2 summarizes the activity level for each aircraft category for each airport surveyed as
well as the emission factor for each pollutant.
Table 4.11–2. 2005 airport activity data and emission factors.
Lbs/LTO
Airport name
Activity
2005
category LTOs
PM10
PM2.5
NOx
SOx
Arizona Army National Guard 2
ML
1,080
0.603
0.420
2.251
0.136
Buckeye Municipal Airport 1,2
GA
21,457
0.237
0.163
1.412
0.112
Chandler Municipal Airport 4
AT
1,370
0.603
0.420
2.036
0.333
GA
116,158
0.237
0.163
1.412
0.112
ML
28
0.603
0.420
4.243
0.371
Falcon Field 2
AC
24
0.175
0.175
26.34
1.425
AT
4,098
0.603
0.420
2.036
0.333
GA
128,835
0.237
0.163
1.214
0.076
ML
2,136
0.603
0.420
4.243
0.371
Gila Bend Air Force Auxiliary Field 1,2
ML
31,003
0.603
0.420
4.174
0.345
Gila Bend Municipal Airport 1,3
GA
6,935
0.237
0.163
1.214
0.076
Glendale Municipal Airport 4
AT
935
0.603
0.420
2.036
0.333
GA
65,438
0.237
0.163
1.214
0.076
ML
62
0.603
0.420
4.243
0.371
Luke Air Force Base 2
ML
59,500
0.603
0.420
14.327
0.809
Phoenix Deer Valley Airport 4
AT
2,293
0.603
0.420
2.036
0.333
GA
186,231
0.237
0.163
1.214
0.076
ML
30
0.603
0.420
4.243
0.371
Phoenix Goodyear Airport 4
AC
172
0.175
0.180
26.34
1.425
AT
1,893
0.603
0.420
2.036
0.333
GA
46,440
0.237
0.163
1.214
0.076
ML
2,005
0.603
0.420
4.243
0.371
Phoenix Sky Harbor International 4
AC
204,856
0.168
0.168
16.889
1.373
AT
48,118
0.603
0.420
5.494
0.636
GA
20,670
0.237
0.163
1.412
0.112
ML
1,447
0.603
0.420
35.936
1.814
Pleasant Valley Airport 2
GA
14,096
0.237
0.163
0.354
0.064
Scottsdale Airport 2
AT
5,903
0.603
0.420
2.036
0.333
GA
100,164
0.237
0.163
1.412
0.112
ML
155
0.603
0.420
4.243
0.371
Skyranch at Carefree 2
GA
2,248
0.237
0.163
0.046
0.002
Stellar Airpark 2
GA
19,528
4.421
0.163
1.214
0.076
Wickenburg Municipal Airport1
AT
485
0.603
0.420
2.036
0.333
GA
23,059
0.237
0.163
1.214
0.076
ML
728
0.603
0.420
4.243
0.371
Williams Gateway Airport 4
AC
450
0.175
0.180
26.34
1.425
AT
3,874
0.603
0.420
2.036
0.333
GA
128,310
0.237
0.163
1.214
0.076
ML
5,689
0.603
0.420
19.82
1.429
1. Airport is outside the nonattainment area.
2. Activity data reported from source.
3. No data reported from source. Data derived from http://www.airnav.com
4. No data reported from source. Data derived from http://www.apo.data.faa.gov/main/atads.asp

For all airports, activity is presumed to occur evenly over a 7-day week and average daily emissions were calculated by dividing annual totals by 365 days per year. Table 4.11–3 lists the total
annual emissions and average daily emissions, for each airport and aircraft type.

2005 Periodic PM10 Emission Inventory

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Table 4.11–3. Annual and typical daily emissions, by airport and aircraft type.

Facility
Arizona Army National
Guard
Chandler Municipal
Airport
Falcon Field

Glendale Municipal
Airport
Luke Air Force Base
Phoenix Deer Valley
Airport.
Phoenix Goodyear
Airport
Phoenix Sky Harbor
International
Pleasant Valley Airport
Scottsdale Airport
Skyranch at Carefree
Stellar Airpark
Williams Gateway
Airport

Category1
ML

PM10
0.33

Tons/yr
PM2.5
0.22

AT
GA
ML
AC
AT
GA
ML
AT
GA
ML
ML
AT
GA
ML
AC
AT
GA
ML
AC
AT
GA
ML
GA
AT
GA
ML
GA
GA
AC
AT
GA
ML

0.41
13.75
0.01
0.00
1.24
15.25
0.64
0.28
7.74
0.02
17.94
0.69
22.04
0.01
0.02
0.57
5.50
0.60
17.21
14.52
2.45
0.44
1.67
1.78
11.85
0.05
0.27
2.31
0.04
1.17
15.19
1.72
157.68

PM10 nonattainment
area totals:

NOx
1.22

SOx
0.07

PM10
1.8

0.29
9.49
0.01
0.00
0.85
10.52
0.44
0.19
5.34
0.01
12.38
0.48
15.21
0.01
0.02
0.39
3.79
0.42
17.21
10.02
1.69
0.30
1.15
1.23
8.18
0.03
0.18
1.59
0.04
0.81
10.48
1.18

1.39
0.23
82.01
6.50
0.06
0.01
0.32
0.02
4.17
0.68
78.20
4.90
4.53
0.40
0.95
0.16
39.72
2.49
0.13
0.01
426.23 24.07
2.33
0.38
113.04
7.08
0.06
0.01
2.27
0.12
1.93
0.32
28.19
1.76
4.25
0.37
1,729.91 140.63
132.18 15.30
14.59
1.16
26.00
1.31
2.49
0.45
6.01
0.98
70.72
5.61
0.33
0.03
0.05
0.00
11.85
0.74
5.93
0.32
3.94
0.65
77.88
4.88
56.38
4.06

2.3
75.3
0.0
0.0
6.8
83.5
3.5
1.5
42.4
0.1
98.3
3.8
120.8
0.0
0.1
3.1
30.1
3.3
94.3
79.5
13.4
2.4
9.1
9.8
65.0
0.3
1.5
12.7
0.2
6.4
83.2
9.4

114.15

2,929.27 225.69

864.0

Lbs/day
PM2.5
NOx
1.2
6.7
1.6
52.0
0.0
0.0
4.7
57.6
2.4
1.1
29.3
0.1
67.8
2.6
83.3
0.0
0.1
2.2
20.8
2.3
94.3
54.9
9.2
1.6
6.3
6.7
44.8
0.2
1.0
8.7
0.2
4.4
57.4
6.5

SOx
0.4

7.6
449.4
0.3
1.7
22.9
428.5
24.8
5.2
217.6
0.7
2,335.5
12.8
619.4
0.3
12.4
10.6
154.5
23.3
9,478.9
724.3
80.0
142.5
13.7
32.9
387.5
1.8
0.3
65.0
32.5
21.6
426.8
308.9

1.2
35.6
0.0
0.1
3.7
26.8
2.2
0.9
13.6
0.1
131.9
2.1
38.8
0.0
0.7
1.7
9.7
2.0
770.6
83.8
6.3
7.2
2.5
5.4
30.7
0.2
0.0
4.1
1.8
3.5
26.7
22.3

625.5 16,050.8

1,236.7

Airports outside the nonattainment area:
Buckeye Mun. Airport
Gila Bend AF Aux Field
Gila Bend Mun. Airport
Wickenburg Municipal
Airport
Maricopa County
totals:

GA
ML
GA
AT
GA
ML

2.54
9.35
0.82
0.15
2.73
0.22

1.75
6.45
0.57
0.10
1.88
0.15

173.48

125.05

15.15
64.70
4.21
0.49
14.00
1.54

1.20
5.35
0.26
0.08
0.88
0.14

13.9
51.2
4.5
0.8
15.0
1.2

3,029.37 233.60

950.6

9.6
35.3
3.1
0.6
10.3
0.8

83.0
354.5
23.1
2.7
76.7
8.5

6.6
29.3
1.4
0.4
4.8
0.7

685.2 16,599.3

1,280.0

1. AC = air carrier, GA = general aviation, AT = air taxi, ML = military.

2005 Periodic PM10 Emission Inventory

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4.12

Locomotives

Annual emissions from locomotives were calculated based on diesel fuel usage provided by
Burlington Northern/Santa Fe Railway (BNSF), Union Pacific Railway (UP) and Amtrak.
Railway operations from these companies fall into two categories: Class I haul lines and
yard/switching operations. Annual emissions from Class I haul operations and yard/switching
operations were calculated by multiplying diesel fuel usage by the emission factors listed in
Table 4.12–1.
Table 4.12–1. Emission factors for locomotives.
Emission factors (lbs/gal diesel)
Activity type
PM10 (1) PM2.5 (1)
NOx (1)
SOx (2)
NH3 (3)
Class I haul line
0.015
0.013
0.595
0.036
0.00095
Yard/switch operations
0.020
0.019
0.798
0.036
0.00095
Sources: (1) EPA, 1997. (2) EPA, 1992. (3) EPA, 1998.

The example below illustrates how emissions were calculated for each locomotive activity type.
Fuel use reported by railroads, and emission totals are summarized in Table 4.12–2.
PM10 emissions from = Diesel fuel used (gals) × EPA emission factor (lbs/gal) ÷ 2000 lbs/ton
UP Class I haul lines
for PM10
= 7,598,448 gallons
× 0.015 lbs/gal
÷ 2000 lbs/ton
= 56.99 tons PM10/yr

2005 Periodic PM10 Emission Inventory

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Table 4.12–2. Fuel use and annual emissions from locomotives in Maricopa County.
Annual emissions (tons/yr)
Diesel fuel
Locomotive type
used (gals)
PM10
PM2.5
NOx
SOx
BNSF Class I haul line
1,089,969
8.17
7.08
324.27
19.62
UP Class I haul line
7,598,448
56.99
49.39 2,260.54
136.77
BNSF yard/switch operations
500,000
5.00
4.75
199.50
9.00
UP yard/switch operations
415,740
4.16
3.95
165.88
7.48
Amtrak
17,000
0.13
0.11
5.06
0.31
Totals:
9,621,157
74.45
65.28 2,955.24
173.18

NH3
0.52
3.61
0.24
0.20
0.01
4.57

PM10 nonattainment area emissions were calculated by multiplying Maricopa County emissions
by the percentage of track miles inside the PM10 nonattainment area, determined by GIS
mapping:
PM10 nonattainment area emissions = County PM10 emissions
from UP Class I haul lines
= 56.99 tons PM10/yr
= 30.56 tons PM10/yr

×

Percentage of track in
the nonattainment area

×

44.27%

Table 4.12–3. Annual emissions (in tons/yr) from locomotives in the PM10 NAA.
Annual emissions (tons/yr)
Track in
nonattainment
Locomotive type
area (%)
PM10
PM2.5
NOx
SOx
BNSF Class I haul line
44.27
3.62
3.14
143.55
8.69
UP Class I haul line
44.27
25.23
21.86 1,000.74
60.55
BNSF yard/switch operations
100.00
5.00
4.75
199.50
9.00
UP yard/switch operations
100.00
4.16
3.95
165.88
7.48
Amtrak
0.00
0.00
0.00
0.00
0.00
Totals:
38.01
33.70 1,509.67
85.72

NH3
0.23
1.60
0.24
0.20
0.00
2.26

PM10 typical daily emissions for both the county (shown in Table 4.12–4) and the PM10
nonattainment area (Table 4.12–5) were calculated by dividing annual totals by 365 days per
year, as locomotive activity is assumed to be uniform throughout the year.
PM10 typical daily
= Annual PM10 emissions (tons) × 2000 lbs/ton
emissions from haul lines
= 56.99 tons PM10/yr
× 2000 lbs/ton
= 312.3 lbs PM10/day

÷ 365 days
÷ 365 days

Table 4.12–4. Typical daily emissions (in lbs/day) from locomotives in Maricopa County.
Locomotive type
PM10
PM2.5
NOx
SOx
NH3
BNSF Class I haul line
44.8
38.8
1,776.8
107.5
2.8
UP Class I haul line
312.3
270.6
12,386.5
749.4
19.8
BNSF yard/switch operations
27.4
26.0
1,093.2
49.3
1.3
UP yard/switch operations
22.8
21.6
908.9
41.0
1.1
Amtrak
0.7
0.6
27.7
1.7
0.0
Totals:
407.9
357.7
16,193.1
948.9
25.0
Table 4.12–5. Typical daily emissions (in lbs/day) from locomotives in the PM10 nonattainment area.
Locomotive type
PM10
PM2.5
NOx
SOx
NH3
BNSF Class I haul line
19.8
17.2
786.6
47.6
1.3
UP Class I haul line
138.2
119.8
5,483.5
331.8
8.8
BNSF yard/switch operations
27.4
26.0
1,093.2
49.3
1.3
UP yard/switch operations
22.8
21.6
908.9
41.0
1.1
Amtrak
0.0
0.0
0.0
0.0
0.0
Totals:
208.2
184.7
8,272.2
469.7
12.4

2005 Periodic PM10 Emission Inventory

109

Maricopa County, AZ

4.13

Summary of all nonroad mobile source emissions

Table 4.13–1 summarizes annual and daily emissions of PM10, PM2.5, NOx, SOx and NH3 from
nonroad mobile sources in Maricopa County respectively. Table 4.13–2 shows annual and
typical daily emissions for these pollutants for the PM10 nonattainment area.
Table 4.13–1. Annual and typical daily emissions from nonroad mobile sources in Maricopa County.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Category
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
Agricultural
Airport ground support
Commercial
Construction & mining
Industrial
Lawn & garden
Pleasure craft
Railway maintenance
Recreational
Aircraft
Locomotives
Totals:

39.21
16.50
119.34
1,354.26
110.02
178.22
11.33
1.20
42.29
173.48
74.45
2,120.29

38.03
386.34
15.70
467.82
114.47 1,449.72
1,311.26 16,016.62
107.01 3,316.67
165.18
843.10
10.45
70.58
1.16
9.27
38.95
59.99
125.05 3,029.37
65.28 2,955.24
1,992.56 28,604.72

5.95
14.71
17.32
287.07
26.63
9.53
0.71
0.14
0.68
233.60
173.18
769.51

0.73

23.18
31.22
79.21
21.21
1.49
0.02
1.97
4.57
163.58

251.4
90.4
765.0
8,681.1
705.2
1,226.0
152.5
8.3
361.4
950.6
407.9
13,599.9

243.8
86.0
733.8
8,405.5
686.0
1,135.4
140.7
8.1
332.9
685.2
357.7
12,815.2

2,476.5
2,563.4
9,293.1
102,670.7
21,260.7
5,882.8
950.0
64.2
512.7
16,599.3
16,193.1
178,466.6

38.2
80.6
111.0
1,840.2
170.7
64.1
9.5
1.0
5.8
1,280.0
948.9
4,550.0

4.7

148.6
200.1
507.7
155.5
20.1
0.1
16.8
25.0
1,078.7

Table 4.13–2. Annual and typical daily emissions from nonroad mobile sources in the PM10 NAA.
Annual emissions (tons/yr)
Typical daily emissions (lbs/day)
Category
PM10
PM2.5
NOx
SOx
NH3
PM10
PM2.5
NOx
SOx
NH3
Agricultural
Airport ground support
Commercial
Construction & mining
Industrial
Lawn & garden
Pleasure craft
Railway maintenance
Recreational
Aircraft
Locomotives
Totals:

4.14

18.83
16.50
118.48
1,356.40
109.23
178.50
8.60
1.20
8.89
157.68
38.01
2,012.32

18.26
185.46
15.70
467.82
113.65 1,439.36
1,313.34 16,042.02
106.25 3,292.98
165.44
844.44
7.94
53.59
1.17
9.29
8.19
12.61
114.15 2,929.27
33.70 1,509.67
1,897.78 26,786.52

2.86
14.71
17.20
287.52
26.44
9.54
0.54
0.14
0.14
225.69
85.72
670.50

0.35

23.01
31.27
78.64
21.24
1.13
0.02
0.41
2.26
158.33

120.7
90.4
759.5
8,694.9
700.2
1,227.9
115.8
8.3
76.0
864.0
208.2
12,866.0

117.0
86.0
728.5
8,418.8
681.1
1,137.2
106.9
8.1
70.0
625.5
184.7
12,163.8

1,188.9
2,563.4
9,226.7
102,833.5
21,108.8
5,892.2
721.4
64.3
107.8
16,050.8
8,272.2
168,029.9

18.3
80.6
110.2
1,843.1
169.5
64.2
7.2
1.0
1.2
1,236.7
469.7
4,001.8

2.2

147.5
200.4
504.1
155.8
15.2
0.1
3.5
12.4
1,041.4

Quality assurance procedures

Established procedures were used to check, and correct when necessary, the nonroad mobile
sources emissions estimates. All NONROAD model input and output files, and Excel spreadsheets used to calculate the emissions, were checked by personnel who were not involved in the
development of the modeling inputs/outputs and spreadsheets. In addition, the emissions
estimates were reviewed for reasonableness by external agency staff.

4.15

References

ENVIRON et al., 2003. Maricopa County 2002 Comprehensive Emission Inventory for the Cap
and Trade Oversight Committee, Final Rep. prepared for Arizona Dept. of Environmental
Quality, Oct. 9, 2003.
ERG, 2001. Documentation for the Draft 1999 Base Year Aircraft, Commercial Marine Vessels,
and Locomotive National Emissions Inventory for Criteria and Hazardous Air Pollutants.
Prepared by Eastern Research Group, Morrisville, NC for the US Environmental Protection
Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, Oct. 29,
2001. Internet address: http://www.epa.gov/ttn/chief/eidocs/partllsec4.pdf
2005 Periodic PM10 Emission Inventory

110

Maricopa County, AZ

EPA, 2002. Geographic Allocation of State Level Nonroad Engine Population Data to the
County Level. EPA Office of Transportation and Air Quality, Rep. EPA420-P-02-009, July.
Internet address: http://www.epa.gov/otaq/models/nonrdmdl/p02009.pdf
EPA, 1999. Weekday and Weekend Day Temporal Allocation of Activity in the NONROAD
Model. EPA Office of Transportation and Air Quality, Rep. EPA420-P-99-033, March.
Internet address: http://www.epa.gov/otaq/models/nonrdmdl/p99033.pdf
EPA, 1998. National Air Pollutant Emission Trends Procedures Document, 1900-1996. Office
of Air Quality Planning and Standards, Rep. EPA-454/R-98-008, Research Triangle Park,
NC. May.
EPA, 1997. Emission Factors for Locomotives. Office of Mobile Sources. Techn. Highlights,
(Table 9) Rep. EPA420-F-97-051, Dec. 1997. Internet address: http://www.epa.gov/otaq/
regs/nonroad/locomotv/frm/ 42097051.pdf
EPA, 1992. Procedures for Emission Inventory Preparation – Vol. IV: Mobile Sources. Office
of Air and Radiation, EPA Rep. EPA420-R-92-009, December.

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5.

Onroad Mobile Sources

5.1

Introduction

Onroad mobile source emission estimates have been calculated for particulate matter for the
2005 Periodic Particulate Matter Emissions Inventory. For the purposes of this particulate matter
inventory, the following pollutants were included: PM10, PM2.5, nitrogen oxides (NOx), sulfur
oxides (SOx), and ammonia (NH3). PM10 refers to all particles less than or equal to 10
micrometers in diameter, about one-seventh the diameter of a human hair. PM2.5 refers to
particles less than or equal to 2.5 micrometers in diameter.
Onroad mobile source emissions are estimated for the PM10 nonattainment area (approximately
3,000 square miles), as well as for Maricopa County (approximately 9,000 square miles).
Emission factors were calculated using MOBILE6.2 and AP-42. MOBILE6.2 is the latest
version in a series of models developed by the US Environmental Protection Agency (EPA) for
the purpose of estimating motor vehicle emission factors. AP-42 is the EPA Compilation of Air
Pollutant Emission Factors. AP-42 emission factors were used to calculate fugitive dust
emission factors, while the MOBILE6.2 model was used to estimate all other emission factors.
The resulting emission factors were multiplied by the estimates of vehicle miles of travel (VMT)
to generate emission estimates.
The 2005 motor vehicle exhaust, tire wear, and brake wear emissions were estimated using the
MOBILE6.2 model. The modeling accounted for the oxygenated fuel and vehicle inspection/
maintenance (I/M) programs in existence in Maricopa County in 2005. Fuel use assumptions for
2005, including oxygen content and Reid Vapor Pressure (RVP), were based on actual July 2005
testing results provided by the Arizona Department of Weight and Measures. MOBILE6.2
calculations reflected a 91.6 percent participation in the I/M program.
The 2005 vehicle miles of travel (VMT) used in developing the onroad mobile source emissions
were derived from the latest 2005 traffic assignment produced by the MAG travel demand model
(i.e., EMME2). The 2005 VMT was split into 28 vehicle classes. The VMT by vehicle class
was derived using the VMT mix produced by MOBILE6.2. The MOBILE6.2 VMT mix is based
on July 2003 vehicle registration data for Maricopa County obtained from the Arizona
Department of Transportation. The VMT by vehicle class was multiplied by the appropriate
MOBILE6.2 emission factors to produce 2005 onroad exhaust, tire wear, and brake wear
emissions.
Paved road fugitive dust emissions were estimated using emission factors from AP-42 applied to
VMT from the 2005 traffic assignment produced by the MAG EMME2 travel demand model.
The 2005 VMT for freeways, high traffic arterials, and low traffic arterials were derived from the
traffic assignment. Low traffic arterials are assumed to carry 5,000 or fewer vehicles on an
average weekday, while high traffic arterials carry more than 5,000 vehicles per weekday. These
VMTs were multiplied by the appropriate paved road particulate emission factors from AP-42.
The paved road fugitive dust particulate emission factors were derived from the AP-42 equation
for paved roads, assuming silt loadings from the Serious Area PM10 Plan and a mean vehicle
weight of three tons. GIS was applied to obtain VMT estimates for the PM10 nonattainment area
and Maricopa County.

2005 Periodic PM10 Emission Inventory

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Unpaved road VMT was developed using the mileage for low and high traffic unpaved roads
derived from the unpaved road inventory in the Serious Area PM10 Plan. Low traffic unpaved
roads are assumed to carry an average of four vehicles per day, while high traffic unpaved roads
carry an average of 120 vehicles per day. The unpaved road mileage used in developing the
2005 particulate emission inventory assumes that all commitments to pave unpaved roads in the
Serious Area PM10 Plan have been implemented. Low and high traffic unpaved road VMTs
were multiplied by the appropriate AP-42 emission factor to produce unpaved road particulate
emissions. The unpaved road particulate emission factors were derived from the AP-42 equation
for publicly accessible unpaved roads, assuming a silt content of 11.9%, soil moisture content of
0.5%, a mean vehicle weight of three tons, and an average speed of 25 mph.
The main references for preparing the onroad mobile source portion of the 2005 emissions
inventory were:
ƒ
Emission Inventory Requirements for Ozone State Implementation Plans, EPA-450/4-91010, March 1991,
ƒ
Technical Guidance on the Use of MOBILE6 for Emission Inventory Preparation, US
EPA, January 2002,
ƒ
User's Guide to MOBILE6.1 and MOBILE6.2 (Mobile Source Emission Factor Model),
EPA420-R-03-010, August 2003, and
ƒ
Procedures for Emission Inventory Preparation Volume IV: Mobile Sources, EPA-450/481/026d (Revised), 1992.
5.2

VMT estimation

MAG prepared the 2005 vehicle miles of travel (VMT) estimates for the PM10 nonattainment
area and Maricopa County. The source of data for these estimates is the 2005 traffic assignment
prepared by MAG using the EMME2 travel demand model. Highway Performance Monitoring
System (HPMS) data for 2005 prepared by the Arizona Department of Transportation was not
available in time to be used for the 2005 periodic particulate matter emissions inventory.
The distribution of VMT by vehicle class for the PM10 nonattainment area was derived from the
MAG EMME2 traffic assignment and MOBILE6.2 runs for 2005. The output of the traffic
assignment was evaluated using GIS to obtain VMT for the PM10 nonattainment area and
Maricopa County. Since information provided by the 2005 traffic assignment does not cover the
far western and far northeastern areas of Maricopa County, 2005 VMT for Maricopa County was
obtained by multiplying the 2005 traffic assignment VMT by the ratio of the 2002 HPMS VMT
for Maricopa County to the 2002 traffic assignment VMT for Maricopa County. The traffic
assignment VMTs shown below represent annual average daily traffic volumes. The ratio
applied to obtain Maricopa County VMT was calculated as follows:
Maricopa County 2002 HPMS VMT = 73,579,000 miles per day
Maricopa County 2002 traffic assignment VMT = 71,988,181 miles per day
Maricopa County 2005 traffic assignment VMT = 80,374,602 miles per day
Ratio = 73,579,000 / 71,988,181 = 1.02
2005 VMT for Maricopa County = 1.02 × 80,374,602 = 82,150,747 miles per day

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VMTs for the PM10 nonattainment area and Maricopa County were split by vehicle class using
VMT mix data obtained from the MOBILE6.2 run. The VMT estimates by 28 vehicle class
categories for the PM10 nonattainment area and Maricopa County are shown in Table 5.2–1.
Table 5.2–1.

2005 daily VMT (vehicle miles of travel) by vehicle class.
PM10
Maricopa
NAA
County
Vehicle Type
LDGV
32,364,131
33,951,479
LDGT1
5,937,079
6,228,272
LDGT2
19,761,545
20,730,780
LDGT3
6,579,349
6,902,043
LDGT4
3,023,368
3,171,653
HDGV2B
2,294,940
2,407,498
HDGV3
78,326
82,167
HDGV4
31,330
32,867
HDGV5
93,991
98,601
HDGV6
195,814
205,418
HDGV7
78,326
82,167
HDGV8A
0
0
HDGV8B
0
0
MC
375,963
394,402
LDDV
62,660
65,734
LDDT12
23,498
24,650
LDDT34
140,986
147,901
HDDV2B
720,595
755,938
HDDV3
219,312
230,068
HDDV4
234,977
246,502
HDDV5
109,656
115,034
HDDV6
556,112
583,387
HDDV7
806,754
846,322
HDDV8A
971,237
1,018,873
HDDV8B
3,430,661
3,598,922
HDGB
15,665
16,433
HDDBT
70,493
73,950
HDDBS
133,153
139,684
Total
78,309,918
82,150,747

VMT for estimating fugitive dust emissions from paved roads was also estimated using data
from the 2005 EMME2 traffic assignment. Roadway silt loading measurements used in the
Serious Area PM10 Plan reflect three silt loading classifications: freeways, high traffic arterials
(greater than or equal to 5,000 vehicles per average weekday), and low traffic arterials (less than
5,000 vehicles per average weekday). GIS was applied to extract VMT for the PM10 modeling
area from the MAG 2005 traffic assignment. The PM10 modeling area for the Serious Area PM10
Plan is a rectangle that encompasses the portion of the PM10 nonattainment area in Maricopa
County. The VMT for freeways and high and low traffic arterials in the PM10 modeling area is
shown in Table 5.2–2. These VMTs represent annual average daily traffic volumes. All travel
on local streets is included in the low traffic arterial category below.

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

Table 5.2–2.

2005 VMT by silt loading category on paved roads in the PM10 modeling area.
VMT
High Traffic
Low Traffic
Arterials
Arterials
Freeways
Total
PM10 Modeling Area
27,929,802
40,164,352
9,688,202
77,782,356

The miles of unpaved roads used to estimate VMT for unpaved roads was derived from the
Serious Area PM10 Plan (MAG, 2000). The unpaved road mileages shown in Table 5.2–3 have
been reduced to account for control measures to Reduce Particulate Emissions from Unpaved
Roads and Alleys in the Plan. The Plan classifies the miles of unpaved roads as low traffic and
high traffic. Low traffic unpaved roads have an annual average traffic level of 4 vehicles per
day; high traffic unpaved roads have an annual average traffic level of 120 vehicles per day.
Applying these traffic volumes to the unpaved road mileages, after implementation of committed
measures in the Plan, results in the daily VMTs for the PM10 modeling area shown in Table 5.2–
3. The PM10 modeling area is a rectangle that includes the portion of the PM10 nonattainment
area located in Maricopa County.
Table 5.2–3.

2005 unpaved road mileages and VMT in the PM10 modeling area.
2005
Unpaved Road Type
Miles
Daily VMT
High Traffic
224.3
26,916
Low Traffic
1,129.2
4,517
Total
1,353.5
31,433

To estimate paved and unpaved road emissions for Maricopa County and the entire PM10
nonattainment area, including Apache Junction in Pinal County, the emissions for the PM10
modeling area were multiplied by the ratio of the total daily VMT in Maricopa County (or the
PM10 nonattainment area) to the total daily VMT in the PM10 modeling area. GIS was applied to
extract the total VMTs for Maricopa County and the PM10 nonattainment area from the 2005
MAG traffic assignment. These VMTs represent annual average daily traffic volumes. The
resultant VMTs and ratios are shown in Table 5.2–4.
Table 5.2–4. VMTs for the PM10 modeling area, PM10 nonattainment area, and Maricopa County.
Area
Total Daily VMT
PM10 Modeling Area (MA)
77,782,356
PM10 Nonattainment Area (NA)
78,309,918
Maricopa County (MC)
82,150,747
Ratio (NA/MA)
1.007
Ratio (MC/MA)
1.056

5.3

Vehicle speed

Vehicle speeds have no effect on the emission factors for exhaust particulate matter, re-entrained
dust from paved roads, brake wear, tire wear, or exhaust ammonia (NH3) and have only a very
slight effect on the pollutants, SO4 and SO2. However, speeds can have a significant effect on
NOx exhaust emissions and re-entrained dust from unpaved roads. The MOBILE6.2 default
speeds were assumed for the NOx emission calculations and 25 miles per hour was assumed on
all unpaved roads.

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

5.4

Emission factor estimation procedures

PM10, PM2.5, SO2, NH3, and oxides of nitrogen (NOx) vehicle exhaust emission factors were
calculated using MOBILE6.2. The PM10 and PM2.5 non-exhaust components of tire wear and
brake wear were also estimated using MOBILE6.2. The PM10 and PM2.5 estimates include the
components lead, elemental carbon from diesel exhaust, organic carbon from diesel exhaust,
sulfate portion, and carbon portion of gasoline exhaust. MOBILE6.2 is the latest version in a
series of models developed by the U.S. EPA for the purpose of estimating motor vehicle
emission factors. The MOBILE6.2 runs were executed by MAG. The contact person for the
MOBILE6.2 emission estimates is Taejoo Shin (602-254-6300).
Fugitive dust emission factors were derived from AP-42. The contact person for the fugitive
dust emission estimates is Cathy Arthur (602-254-6300).
5.4.1

MOBILE6.2 emission factor model

The emission factors not related to fugitive dust were calculated using MOBILE6.2. Two
MOBILE6.2 runs were executed for an annual average day (24-hour period) reflecting vehicles
registered locally (subject to the I/M program) and those not registered locally (not participating
in the I/M program). Of the pollutants modeled for this study, the presence or lack of an I/M
program only affects the modeled emission factors for NOx. Refer to Appendix 5 for portions of
the actual input and output files.
The emission factors estimated with these runs were combined to reflect the actual proportions of
vehicles subject to the specified levels of inspection. The term “I/M vehicles” denotes vehicles
which are required to undergo an emission test and/or inspection under the Arizona Vehicle
Inspection/Maintenance Program. It is important to note that participation in the I/M program is
required for all vehicles registered in the nonattainment area, with the exception of certain model
year and vehicle types. However, it is assumed that of the vehicles which are of an age and type
subject to an I/M program, only 91.6 percent of the vehicles operating within the nonattainment
area participate in the I/M program. The remaining 8.4 percent do not participate in the program.
These percentages reflect the implementation of the control measures “Tougher Registration
Enforcement” and “Expansion of Area A Boundaries”, described in the Revised MAG 1999
Serious Area Carbon Monoxide Plan for the Maricopa County Nonattainment Area, MAG,
March 2001. In the absence of any additional data, this percentage split is assumed to apply
directly to VMT as well.
5.4.1.1 MOBILE6.2 inputs
In order to accurately reflect the state of the I/M program in the modeling area, several
MOBILE6.2 runs were performed and the emission factors from those runs were weighted
together. The specific model run inputs to the MOBILE6.2 model are described in Appendix 5.
5.4.1.2 MOBILE6.2 outputs
MOBILE6.2 was executed to obtain composite emission factors in grams per mile (g/mi) for
exhaust PM10, PM2.5, NOx, SO2, and NH3. These values were obtained for 28 vehicle classes.
The emission factors generated for 2005 are presented in the following section. Representative
output runs are contained in Appendix 5. These values were then used in developing emission
estimates.
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Maricopa County, AZ

5.4.1.3 Summary of MOBILE6.2 emission factors
MOBILE6.2 was used to generate emission factors by vehicle class in terms of gram per mile.
Table 5.4–1 provides the emission factors for each vehicle class for the PM10 nonattainment area
and Maricopa County.
Table 5.4–1. Emission factors by vehicle class for the PM10 nonattainment area and Maricopa County.
Vehicle
PM10
PM10
PM10
PM2.5
PM2.5
PM2.5
Type
Ext
Tire
Brake
Ext
Tire
Brake
NOx
SOx
LDGV
0.0052 0.0080
0.0125
0.0048
0.0020
0.0053
0.766
0.020
LDGT1
0.0061 0.0080
0.0125
0.0057
0.0020
0.0053
0.788
0.026
LDGT2
0.0061 0.0080
0.0125
0.0057
0.0020
0.0053
1.043
0.026
LDGT3
0.0066 0.0080
0.0125
0.0061
0.0020
0.0053
1.200
0.034
LDGT4
0.0066 0.0080
0.0125
0.0061
0.0020
0.0053
1.590
0.034
HDGV2B 0.0616 0.0080
0.0125
0.0547
0.0020
0.0053
4.024
0.049
HDGV3
0.0671 0.0120
0.0125
0.0583
0.0030
0.0053
4.442
0.053
HDGV4
0.0731 0.0120
0.0125
0.0586
0.0030
0.0053
4.769
0.054
HDGV5
0.0602 0.0120
0.0125
0.0505
0.0030
0.0053
4.844
0.062
HDGV6
0.0593 0.0120
0.0125
0.0500
0.0030
0.0053
4.788
0.061
HDGV7
0.0605 0.0120
0.0125
0.0507
0.0030
0.0053
5.375
0.067
HDGV8A 0.0620 0.0360
0.0125
0.0513
0.0090
0.0053
5.961
0.071
HDGV8B 0.0000 0.0000
0.0000
0.0000
0.0000
0.0000
0.000
0.000
MC
0.0208 0.0040
0.0125
0.0145
0.0010
0.0053
1.240
0.010
LDDV
0.1857 0.0080
0.0125
0.1711
0.0020
0.0053
1.563
0.070
LDDT12
0.3148 0.0080
0.0125
0.2899
0.0020
0.0053
2.736
0.069
LDDT34
0.1079 0.0080
0.0125
0.0998
0.0020
0.0053
1.147
0.115
HDDV2B 0.1405 0.0080
0.0125
0.1301
0.0020
0.0053
3.996
0.152
HDDV3
0.1252 0.0120
0.0125
0.1162
0.0030
0.0053
4.443
0.169
HDDV4
0.1286 0.0120
0.0125
0.1194
0.0030
0.0053
5.286
0.192
HDDV5
0.1210 0.0120
0.0125
0.1124
0.0030
0.0053
5.642
0.199
HDDV6
0.2371 0.0120
0.0125
0.2194
0.0030
0.0053
7.711
0.225
HDDV7
0.2427 0.0120
0.0125
0.2247
0.0030
0.0053
9.578
0.260
HDDV8A 0.2961 0.0360
0.0125
0.2741
0.0090
0.0053
12.217 0.298
HDDV8B 0.3127 0.0360
0.0125
0.2895
0.0090
0.0053
14.339 0.313
HDGB
0.1377 0.0120
0.0125
0.0995
0.0030
0.0053
7.831
0.079
HDDBT
0.5888 0.0120
0.0125
0.5442
0.0030
0.0053
17.002 0.455
HDDBS
0.6102 0.0120
0.0125
0.5631
0.0030
0.0053
11.940 0.315

5.4.1.4 MOBILE6.2 emission estimates
The annual average daily VMT shown in Table 5.2–1 was multiplied by the appropriate emission
factor shown in Table 5.2–1 for each vehicle class to calculate exhaust emissions. Calculations
for brake wear and tire wear involved the multiplication of the VMT by appropriate emission
factors from MOBILE6.2 also shown in the table above.
Tables 5.4–2 through 5.4–3 show the resultant PM10, PM2.5, NOx, SO2, and NH3 emissions for
each vehicle class in the PM10 nonattainment area and Maricopa County, respectively. The
emissions are shown in terms of metric tons per day.
Tables 5.4–4 and 5.4–5 show the same emissions on an annual basis in metric tons per year. In
Tables 5.4–1 through 5.4–5, the abbreviation “Ext” refers to exhaust particulate
emissions, “Tire” refers to tire wear particulate emissions, and “Brake” refers to brake wear
particulate emissions. NOx and SOx refer to exhaust emissions.
2005 Periodic PM10 Emission Inventory

118

Maricopa County, AZ

Table 5.4–2.
Vehicle
type
LDGV
LDGT1
LDGT2
LDGT3
LDGT4
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
MC
LDDV
LDDT12
LDDT34
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
HDGB
HDDBT
HDDBS
Total

Daily PM10 nonattainment area emissions by vehicle class (metric tons/day).
PM10
PM2.5
PM2.5
PM2.5
PM10 PM2.5
PM10 PM10
Ext
Tire
Brake
Ext
Tire
Brake Total Total
NOx
0.168 0.259 0.405
0.155
0.065
0.172
0.832
0.392
24.788
0.036 0.047 0.074
0.034
0.012
0.031
0.158
0.077
4.679
0.121 0.158 0.247
0.113
0.040
0.105
0.526
0.257
20.611
0.043 0.053 0.082
0.040
0.013
0.035
0.178
0.088
7.895
0.020 0.024 0.038
0.018
0.006
0.016
0.082
0.041
4.807
0.141 0.018 0.029
0.126
0.005
0.012
0.188
0.142
9.234
0.005 0.001 0.001
0.005
0.000
0.000
0.007
0.005
0.348
0.002 0.000 0.000
0.002
0.000
0.000
0.003
0.002
0.149
0.006 0.001 0.001
0.005
0.000
0.000
0.008
0.006
0.455
0.012 0.002 0.002
0.010
0.001
0.001
0.016
0.011
0.938
0.005 0.001 0.001
0.004
0.000
0.000
0.007
0.005
0.421
0.000 0.000 0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.000 0.000 0.000
0.000
0.000
0.000
0.000
0.000
0.000
0.008 0.002 0.005
0.005
0.000
0.002
0.014
0.008
0.466
0.012 0.001 0.001
0.011
0.000
0.000
0.013
0.011
0.098
0.007 0.000 0.000
0.007
0.000
0.000
0.008
0.007
0.064
0.015 0.001 0.002
0.014
0.000
0.001
0.018
0.015
0.162
0.101 0.006 0.009
0.094
0.001
0.004
0.116
0.099
2.879
0.027 0.003 0.003
0.025
0.001
0.001
0.033
0.027
0.974
0.030 0.003 0.003
0.028
0.001
0.001
0.036
0.030
1.242
0.013 0.001 0.001
0.012
0.000
0.001
0.016
0.013
0.619
0.132 0.007 0.007
0.122
0.002
0.003
0.145
0.127
4.288
0.196 0.010 0.010
0.181
0.002
0.004
0.216
0.188
7.727
0.288 0.035 0.012
0.266
0.009
0.005
0.335
0.280
11.866
1.073 0.124 0.043
0.993
0.031
0.018
1.239
1.042
49.192
0.002 0.000 0.000
0.002
0.000
0.000
0.003
0.002
0.123
0.042 0.001 0.001
0.038
0.000
0.000
0.043
0.039
1.199
0.081 0.002 0.002
0.075
0.000
0.001
0.085
0.076
1.590
2.587 0.759 0.979
2.385
0.190
0.415
4.324
2.990 156.814

2005 Periodic PM10 Emission Inventory

119

SOx
0.660
0.156
0.518
0.225
0.103
0.112
0.004
0.002
0.006
0.012
0.005
0.000
0.000
0.004
0.004
0.002
0.016
0.110
0.037
0.045
0.022
0.125
0.210
0.290
1.075
0.001
0.032
0.042
3.817

NH3
3.285
0.594
1.976
0.651
0.299
0.104
0.004
0.001
0.004
0.009
0.004
0.000
0.000
0.004
0.000
0.000
0.001
0.019
0.006
0.006
0.003
0.015
0.022
0.026
0.093
0.001
0.002
0.004
7.133

Maricopa County, AZ

Table 5.4–3.
Vehicle
type
LDGV
LDGT1
LDGT2
LDGT3
LDGT4
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
MC
LDDV
LDDT12
LDDT34
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
HDGB
HDDBT
HDDBS
Total

Daily Maricopa County emissions by vehicle class (metric tons/day).
PM10
PM2.5
PM2.5
PM2.5 PM10 PM2.5
PM10 PM10
Ext
Tire
Brake
Ext
Tire
Brake Total Total
0.177 0.272 0.424
0.163
0.068
0.180
0.873
0.411
0.038 0.050 0.078
0.036
0.012
0.033
0.166
0.081
0.126 0.166 0.259
0.118
0.041
0.110
0.551
0.270
0.046 0.055 0.086
0.042
0.014
0.037
0.187
0.092
0.021 0.025 0.040
0.019
0.006
0.017
0.086
0.043
0.148 0.019 0.030
0.132
0.005
0.013
0.198
0.149
0.006 0.001 0.001
0.005
0.000
0.000
0.008
0.005
0.002 0.000 0.000
0.002
0.000
0.000
0.003
0.002
0.006 0.001 0.001
0.005
0.000
0.001
0.008
0.006
0.012 0.002 0.003
0.010
0.001
0.001
0.017
0.012
0.005 0.001 0.001
0.004
0.000
0.000
0.007
0.005
0.000 0.000 0.000
0.000
0.000
0.000
0.000
0.000
0.000 0.000 0.000
0.000
0.000
0.000
0.000
0.000
0.008 0.002 0.005
0.006
0.000
0.002
0.015
0.008
0.012 0.001 0.001
0.011
0.000
0.000
0.014
0.012
0.008 0.000 0.000
0.007
0.000
0.000
0.008
0.007
0.016 0.001 0.002
0.015
0.000
0.001
0.019
0.016
0.106 0.006 0.009
0.098
0.002
0.004
0.122
0.104
0.029 0.003 0.003
0.027
0.001
0.001
0.034
0.029
0.032 0.003 0.003
0.029
0.001
0.001
0.038
0.031
0.014 0.001 0.001
0.013
0.000
0.001
0.017
0.014
0.138 0.007 0.007
0.128
0.002
0.003
0.153
0.133
0.205 0.010 0.011
0.190
0.003
0.004
0.226
0.197
0.302 0.037 0.013
0.279
0.009
0.005
0.351
0.294
1.125 0.130 0.045
1.042
0.032
0.019
1.300
1.093
0.002 0.000 0.000
0.002
0.000
0.000
0.003
0.002
0.044 0.001 0.001
0.040
0.000
0.000
0.045
0.041
0.085 0.002 0.002
0.079
0.000
0.001
0.089
0.080
2.713 0.796 1.027
2.502
0.199
0.435
4.536
3.136

2005 Periodic PM10 Emission Inventory

120

NOx
26.004
4.909
21.622
8.282
5.043
9.687
0.365
0.157
0.478
0.984
0.442
0.000
0.000
0.489
0.103
0.067
0.170
3.021
1.022
1.303
0.649
4.498
8.106
12.448
51.605
0.129
1.257
1.668
164.506

SOx
0.693
0.163
0.543
0.236
0.108
0.117
0.004
0.002
0.006
0.013
0.005
0.000
0.000
0.004
0.005
0.002
0.017
0.115
0.039
0.047
0.023
0.131
0.220
0.304
1.128
0.001
0.034
0.044
4.004

NH3
3.446
0.623
2.073
0.683
0.314
0.109
0.004
0.001
0.004
0.009
0.004
0.000
0.000
0.004
0.000
0.000
0.001
0.020
0.006
0.007
0.003
0.016
0.023
0.028
0.097
0.001
0.002
0.004
7.483

Maricopa County, AZ

Table 5.4–4. Annual PM10 nonattainment area emissions by vehicle class (metric tons/year).
PM2.5
PM10 PM2.5
Vehicle
PM10 PM10 PM10 PM2.5 PM2.5
Ext
Tire
Brake Ext
Tire
Brake Total Total
type
NOx
SOx
LDGV
61.4
94.5
147.7
56.7
23.6
62.6
303.6 142.9
9,047.6
241.0
LDGT1
13.2
17.3
27.1
12.4
4.3
11.5
57.6
28.2
1,708.0
56.8
LDGT2
44.0
57.7
90.2
41.1
14.4
38.2
191.9
93.8
7,523.0
189.0
LDGT3
15.8
19.2
30.0
14.6
4.8
12.7
65.1
32.2
2,881.7
82.1
LDGT4
7.3
8.8
13.8
6.7
2.2
5.8
29.9
14.8
1,754.6
37.7
HDGV2B
51.6
6.7
10.5
45.8
1.7
4.4
68.8
51.9
3,370.4
40.7
HDGV3
1.9
0.3
0.4
1.7
0.1
0.2
2.6
1.9
127.0
1.5
HDGV4
0.8
0.1
0.1
0.7
0.0
0.1
1.1
0.8
54.5
0.6
HDGV5
2.1
0.4
0.4
1.7
0.1
0.2
2.9
2.0
166.2
2.1
HDGV6
4.2
0.9
0.9
3.6
0.2
0.4
6.0
4.2
342.2
4.4
HDGV7
1.7
0.3
0.4
1.4
0.1
0.2
2.4
1.7
153.7
1.9
HDGV8A
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
HDGV8B
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
MC
2.9
0.5
1.7
2.0
0.1
0.7
5.1
2.9
170.2
1.3
LDDV
4.2
0.2
0.3
3.9
0.0
0.1
4.7
4.1
35.7
1.6
LDDT12
2.7
0.1
0.1
2.5
0.0
0.0
2.9
2.5
23.5
0.6
LDDT34
5.6
0.4
0.6
5.1
0.1
0.3
6.6
5.5
59.0
5.9
HDDV2B
37.0
2.1
3.3
34.2
0.5
1.4
42.3
36.1
1,051.0
40.0
HDDV3
10.0
1.0
1.0
9.3
0.2
0.4
12.0
10.0
355.7
13.5
HDDV4
11.0
1.0
1.1
10.2
0.3
0.5
13.1
11.0
453.4
16.5
HDDV5
4.8
0.5
0.5
4.5
0.1
0.2
5.8
4.8
225.8
7.9
HDDV6
48.1
2.4
2.5
44.5
0.6
1.1
53.1
46.2
1,565.2
45.7
HDDV7
71.5
3.5
3.7
66.2
0.9
1.6
78.7
68.6
2,820.4
76.5
HDDV8A 105.0
12.8
4.4
97.2
3.2
1.9
122.2 102.2
4,330.9
105.7
HDDV8B 391.6
45.1
15.7 362.5
11.3
6.6
452.3 380.4
17,955.2
392.4
HDGB
0.8
0.1
0.1
0.6
0.0
0.0
0.9
0.6
44.8
0.5
HDDBT
15.1
0.3
0.3
14.0
0.1
0.1
15.8
14.2
437.5
11.7
HDDBS
29.7
0.6
0.6
27.4
0.1
0.3
30.8
27.8
580.3
15.3
Total
944
277
357
871
69
151
1,578 1,091
57,237
1,393

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121

NH3
1,199.0
216.7
721.3
237.7
109.2
37.8
1.3
0.5
1.5
3.2
1.3
0.0
0.0
1.6
0.2
0.1
0.3
7.1
2.2
2.3
1.1
5.5
8.0
9.6
33.8
0.3
0.7
1.3
2,603

Maricopa County, AZ

Table 5.4–5. Annual Maricopa County emissions by vehicle class (metric tons/year).
Vehicle
PM10 PM10 PM10
PM2.5
PM2.5
PM2.5 PM10 PM2.5
type
Ext
Tire
Brake Ext
Tire
Brake Total Total
NOx
LDGV
64.4
99.1
154.9
59.5
24.8
65.7 318.5 149.9
9,491.3
LDGT1
13.9
18.2
28.4
13.0
4.5
12.0
60.5
29.6
1,791.7
LDGT2
46.2
60.5
94.6
43.1
15.1
40.1 201.3
98.4
7,892.0
LDGT3
16.6
20.2
31.5
15.4
5.0
13.4
68.3
33.8
3,023.1
LDGT4
7.6
9.3
14.5
7.1
2.3
6.1
31.4
15.5
1,840.7
HDGV2B
54.1
7.0
11.0
48.1
1.8
4.7
72.1
54.5
3,535.7
HDGV3
2.0
0.4
0.4
1.7
0.1
0.2
2.7
2.0
133.2
HDGV4
0.9
0.1
0.1
0.7
0.0
0.1
1.2
0.8
57.2
HDGV5
2.2
0.4
0.4
1.8
0.1
0.2
3.0
2.1
174.3
HDGV6
4.4
0.9
0.9
3.7
0.2
0.4
6.3
4.4
359.0
HDGV7
1.8
0.4
0.4
1.5
0.1
0.2
2.5
1.8
161.2
HDGV8A
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
HDGV8B
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
MC
3.0
0.6
1.8
2.1
0.1
0.8
5.4
3.0
178.5
LDDV
4.5
0.2
0.3
4.1
0.0
0.1
4.9
4.3
37.5
LDDT12
2.8
0.1
0.1
2.6
0.0
0.0
3.0
2.7
24.6
LDDT34
5.8
0.4
0.7
5.4
0.1
0.3
6.9
5.8
61.9
HDDV2B
38.8
2.2
3.4
35.9
0.6
1.5
44.4
37.9
1,102.6
HDDV3
10.5
1.0
1.0
9.8
0.3
0.4
12.6
10.5
373.1
HDDV4
11.6
1.1
1.1
10.7
0.3
0.5
13.8
11.5
475.6
HDDV5
5.1
0.5
0.5
4.7
0.1
0.2
6.1
5.1
236.9
HDDV6
50.5
2.6
2.7
46.7
0.6
1.1
55.7
48.5
1,642.0
HDDV7
75.0
3.7
3.9
69.4
0.9
1.6
82.5
72.0
2,958.7
HDDV8A 110.1
13.4
4.6
101.9
3.3
2.0 128.2 107.3
4,543.4
HDDV8B 410.8
47.3
16.4
380.3
11.8
7.0 474.5 399.1 18,835.8
HDGB
0.8
0.1
0.1
0.6
0.0
0.0
1.0
0.6
47.0
HDDBT
15.9
0.3
0.3
14.7
0.1
0.1
16.6
14.9
458.9
HDDBS
31.1
0.6
0.6
28.7
0.2
0.3
32.4
29.1
608.8
Total
990
291
375
913
73
159
1,656 1,145
60,045

5.4.2

SOx
252.8
59.6
198.2
86.2
39.6
42.7
1.6
0.7
2.2
4.6
2.0
0.0
0.0
1.4
1.7
0.6
6.2
42.0
14.2
17.3
8.3
48.0
80.2
110.9
411.7
0.5
12.3
16.1
1,461

NH3
1,257.8
227.3
756.7
249.4
114.6
39.6
1.4
0.5
1.6
3.4
1.4
0.0
0.0
1.6
0.2
0.1
0.4
7.4
2.3
2.4
1.1
5.7
8.3
10.0
35.5
0.3
0.7
1.4
2,731

AP-42 emission factors for paved and unpaved roads

While the exhaust, tire wear, and brake wear emissions were calculated using the EPA
MOBILE6.2 model, fugitive dust from paved and unpaved roads were calculated using equations
found in AP-42, Fifth Edition, November 2006. AP-42 is the common name for the EPA
Compilation of Air Pollutant Emission Factors. Specifically, sections 13.2.1 and 13.2.2 of AP42 describe calculations for fugitive dust from paved and unpaved roads, respectively.
The calculations for paved road fugitive dust emissions are related to silt loading values on road
surfaces. As described previously, paved roads were split into three silt loading levels; freeways
with a silt loading of 0.02 grams per square meter, high traffic arterials, 0.067 grams per square
meter, and low traffic arterials, 0.23 grams per square meter. All local roadways were assumed to
fall into the low traffic arterial category. These silt loading estimates are consistent with the
Serious Area PM10 Plan. When input to the AP-42 equation, these silt loadings result in the
following PM10 emission factors: for freeways 0.15 grams per VMT, for high ADT nonfreeways, 0.58 grams per VMT, and for low ADT non-freeways, 1.54 grams per VMT.

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Applying the same AP-42 equation produces PM2.5 emission rates of 0.00 grams per VMT for
freeways and high ADT non-freeways and 0.06 grams per VMT for low ADT non-freeways.
The VMT in each silt loading category may be found in Table 5.2–2. Multiplying the paved
road fugitive dust emission factors by the VMT estimates in Table 5.2–2 results in the emission
totals for the PM10 modeling area shown in Table 5.4–6.
Table 5.4–6.

2005 paved road fugitive dust emissions in the PM10 modeling area.
Emissions (kg/day)
Silt Loading Category
PM10
PM2.5
Freeway
4,189
0
High Traffic Arterial
23,295
0
Low Traffic Arterial
14,920
581
Total
42,404
581

Applying the VMT ratios in Table 5.2–4 to the modeling area emissions in Table 5.4–6 produces
the total 2005 paved road fugitive dust emissions in the PM10 nonattainment area and Maricopa
County without reductions due to control measures in the Serious Area PM10 Plan. These results
are shown in Table 5.4–7.
Table 5.4–7. 2005 paved road fugitive dust emissions without Serious Area PM10 Plan control measures.
Total emissions (kg/day)
PM10 PM2.5
Nonattainment area
42,701
585
Maricopa County
44,779
614

The Serious Area PM10 Plan contained a number of measures to reduce paved road fugitive dust
emissions (MAG, 2000). The estimated emission reductions attributable to these measures in
2005 are summarized below in Table 5.4–8:
Table 5.4–8.

Estimated emission reductions attributed to measures to reduce paved road fugitive dust.
2005 PM10 Emission
Paved Road Control Measures
Reductions (kg/day)
1. PM10 Efficient Street Sweepers
6,441
2. Curbing, Paving or Stabilizing Shoulders on Paved Roads
1,412
3. Paving, Vegetating or Chemically Stabilizing Unpaved Access
590
Points onto Paved Roads
8,443
Total 2005 PM10 Emission Reductions

Applying these control measures to the PM10 emissions in Table 5.4–7, results in the PM10
emissions shown in Table 5.4–9. The PM2.5 emissions in Table 5.4–9 were obtained by applying
the percentage reductions in PM10 (i.e., 19.8% for the NAA and 18.9% for Maricopa County) to
the PM2.5 emissions in Table 5.4–7.
Table 5.4–9.

2005 fugitive dust emissions from paved roads.
PM10 Emissions
PM2.5 Emissions
Area
kg/day
lbs/day
tons/yr
kg/day
lbs/day
tons/yr
PM10 NAA
34,258
75,525
13,783
469
1,034
189
Maricopa County
36,336
80,106
14,619
498
1,098
200

For unpaved roads, emission factors from AP-42 were applied to the VMT estimates from the
Serious Area PM10 Plan shown in Table 5.2–3. The unpaved road particulate emission factors
were derived from the AP-42 equation for publicly accessible unpaved roads, assuming a silt
content of 11.9%, soil moisture content of 0.5%, a mean vehicle weight of three tons, and an
2005 Periodic PM10 Emission Inventory

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average speed of 25 mph. The resultant emission factor for PM10 is 666.62 grams per vehicle
mile of travel. The comparable PM2.5 emission factor based on AP-42 is 10 percent of the PM10
factor or 66.66 grams per vehicle mile. The unpaved road mileage estimates in Table 5.2–3
assume that all commitments to pave unpaved roads in the Serious Area PM10 Plan have been
implemented by 2005. Multiplying the unpaved road emission factors by the VMT estimates in
Table 5.2–3 results in the emissions for the PM10 modeling area shown in Table 5.4–10.
Table 5.4–10. Unpaved road fugitive dust emissions for the PM10 modeling area.
Emissions (kg/day)
Unpaved road type
PM10
PM2.5
High traffic
17,943
1,794
Low traffic
3,011
301
Total
20,954
2,095

Applying the VMT ratios in Table 5.2–4 to the PM10 modeling area emissions in Table 5.4–10
produces the total 2005 unpaved road fugitive dust emissions in the PM10 nonattainment area and
Maricopa County. These results are shown in Table 5.4–11.
Table 5.4–11. 2005 fugitive dust emissions from unpaved roads.
PM10 Emissions
PM2.5 Emissions
Area
kg/day
lbs/day
tons/yr
kg/day
lbs/day
tons/yr
PM10 NAA
21,101
46,519
8,490
2,110
4,652
849
Maricopa County
22,127
48,781
8,903
2,213
4,879
890

5.5

Summary of particulate emissions from onroad mobile sources

Table 5.5–1 summarizes the annual emissions (in English tons per year) and the average daily
emissions (in pounds per day) for the pollutants PM10, PM2.5, NOx, SO2, and NH3 from all onroad
mobile sources in the PM10 nonattainment area in 2005. Similar data for all of Maricopa County
is presented in Table 5.5–2.
Table 5.5–1. Annual and average daily 2005 emissions from all onroad mobile sources for the PM10
nonattainment area.
Annual emissions (tons/yr)
Average daily emissions (lbs/day)
PM10 PM2.5
NOx SOx NH3
PM10 PM2.5
NOx SOx
NH3
Exhaust
1,041
960 63,093 1,536 2,870
5,702 5,258 345,713 8,415 15,725
Paved road fugitive dust
13,783
189
75,523 1,034
Unpaved road fugitive dust
8,490
849
46,519 4,652
Tire wear
305
76
1,673
418
Brake wear
394
167
2,158
915
Total:
24,013 2,241 63,093 1,536 2,870 131,575 12,277 345,713 8,415 15,725

2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

Table 5.5–2.
County.

Annual and average daily 2005 emissions from all onroad mobile sources for Maricopa

Annual emissions (tons/yr)
Average daily emissions (lbs/day)
PM10 PM2.5
NOx SOx NH3
PM10 PM2.5
NOx SOx
NH3
Exhaust
1,092 1,007 66,187 1,611 3011
5,982 5,516 362,669 8,827 16,496
Paved road fugitive dust
14,619
200
80,104 1,098
Unpaved road fugitive dust 8,903
890
48,781 4,879
Tire wear
320
80
1,755
439
Brake wear
413
175
2,264
960
Total:
25,347 2,352 66,187 1,611 3,011 138,886 12,892 362,669 8,827 16,496

5.6

Quality assurance process

5.6.1

VMT estimates

Normal quality assurance procedures, including automated and manual consistency checks, were
conducted by MAG in developing the 2005 EMME2 traffic assignment used to generate the
VMT data. The MAG travel demand model VMT estimates have been validated against more
than 3,000 traffic counts collected in 2002–2003, as well as Highway Performance Monitoring
System data submitted annually by ADOT to the Federal Highway Administration.
5.6.2

Emission factor estimates

The quality assurance process performed on the MOBILE6.2 analyses included accuracy,
completeness, and reasonableness checks. For accuracy and completeness, a system was used
that included an independent reviewer. All calculations were checked independently for
accuracy and completeness by the reviewer. Any errors found were corrected and the changes
were then rechecked by the reviewer.
5.6.3

Draft particulate matter emissions inventory

The draft onroad mobile source portion of the 2005 periodic particulate matter emissions
inventory was reviewed using published EPA quality review guidelines for base year emission
inventories (EPA Document 450/4-91-022, September 1991). The procedural review (Levels I,
II, and III) included checks for completeness, consistency, and the correct use of appropriate
procedures.

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Maricopa County, AZ

5.7

References

Arizona Department of Environmental Quality, 2001. Memorandum on Cutpoints for IM147 for
MOBILE6, May 2001.
MAG, 1986. 1986 Phoenix Urbanized Area Travel Speed Study, Parsons Brinkerhoff Quade &
Douglas, Inc., for MAG, October 1986.
MAG, 1995. Maricopa Association of Governments Highway Performance Monitoring System
Update, Lee Engineering, Inc., for MAG, January 1995.
MAG, 1995. 1993 Study of Travel Speed and Delay in the MAG Region, Lee Engineering, Inc.,
for MAG, January 1995.
MAG, 1999. MAG 1999 Serious Area Carbon Monoxide Plan for the Maricopa County
Nonattainment Area, MAG, June 1999.
MAG, 2000. 1998 MAG Regional Congestion Study, Traffic Research & Analysis, Inc. et. all
for MAG, September 2000.
US EPA, 1991. Emission Inventory Requirements for Ozone State Implementation Plans, EPA450/4-91-010, March 1991.
US EPA, 1992a. Procedures for Emission Inventory Preparation Volume IV: Mobile Sources,
EPA-450/4-81-026d (Revised), 1992.
US EPA, 1992b. Quality Review Guidelines for 1990 Base Year Emission Inventories. U.S.
Environmental Protection Agency Rep. EPA-450/4-92-007, Research Triangle Park, NC,
August 1992.
US EPA, 2003a. Compilation of Air Pollutant Emission Factors, AP-42, Fifth Edition, Volume
I: Stationary Point and Area Sources, EPA, December 2003 (referenced sections). See
http://www.epa.gov/ttn/chief/ ap42/ch13/final/c13s0201.pdf and http://www.epa.gov/ttn/
chief/ap42/ch13/final/c13s0202.pdf.
US EPA, 2003b. User's Guide to MOBILE6.1 and MOBILE6.2 (Mobile Source Emission Factor
Model), EPA420-R-03-010, August 2003.
US EPA, 2004. Technical Guidance on the Use of MOBILE6 for Emission Inventory
Preparaton, EPA420-R-04-013.

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6.

Biogenic Sources

6.1

Introduction and scope

Biogenic source emission estimates have been calculated for particulate matter precursors for use
in the 2005 Periodic PM10 Inventory. These biogenic source emission estimates are for
Maricopa County and the approximately 3,000 square-mile portion of the PM10 nonattainment
area within Maricopa County and a small portion of Pinal County. The biogenic emissions were
estimated using the Model of Emissions of Gases and Aerosols from Nature (MEGAN).
MEGAN is a state-of-the-art model, developed by Dr. Alex Guenther and ENVIRON
International Corporation (Guenther, 2006a and b). MAG contracted with ENVIRON and Dr.
Guenther in 2005 to develop a more reliable and accurate biogenic emissions model. Dr.
Guenther performed field studies in June 2006 to measure vegetation emission rates within
Maricopa County. During 2006, Dr. Guenther also collected data on desert plant emission rates
in Clark County, Nevada. Due to the incorporation of emission rates that are more characteristic
of plants located in the desert southwest, the MEGAN estimates represent a substantial
improvement over previous biogenic emission estimates for Maricopa County. Among the
chemical species included in MEGAN, only nitric oxide (NO) is attributable to PM formation.
Therefore, only NOx emissions are included in the inventory.

6.2

MEGAN input files

To calculate biogenic emissions using MEGAN, seven gridded input files were prepared:
•
•
•
•
•
•
•

User domain file: this file describes the user’s domain such as the number of grid cells,
grid cell size, and latitude and longitude coordinates of grid cells
Solar radiation and temperature file
Monthly Leaf Area Index (LAI) file
Plant Functional Type (PFT) file
Emission Factor (EF) file
Wind speed and humidity
Soil moisture

Since MEGAN requires that all input data files be provided for grid cells defined in the user
domain file, gridded meteorological data (e.g., temperature, solar radiation, wind speed and
humidity, and soil moisture) generated by the Penn State/NCAR Mesoscale Meteorological
Model 5 (MM5) for MAG 8-hour ozone modeling were provided to MAG by ENVIRON. The
MM5 meteorological data files were reformatted for MEGAN input. LAI, PFT and EF files for
Maricopa County developed by Dr. Guenther were extracted from the MEGAN database using
the MEGAN driving variables processor.

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Maricopa County, AZ

6.3
Emission estimation
Since MM5-generated meteorological data for all days in 2005 were not available, NO emission
estimates from MEGAN for May 31 to June 7, 2002 for the MAG 8-hour ozone modeling area
were employed to derive 2005 daily average NO emissions for the PM10 nonattainment area and
Maricopa County. The PM10 nonattainment area, Maricopa County, and 8-hour ozone modeling
area are delineated in Figure 6.3–1.

Figure 6.3–1. Boundaries of PM10 Nonattainment Area, 8-Hour Ozone Modeling Area and Maricopa County

The daily average NO emissions for the 8-hour ozone modeling area within Maricopa County
and PM10 nonattainment area were extracted from NO emissions for the 8-hour ozone modeling
area using GIS. The extracted daily NO emissions for May 31 to June 7, 2002 for the Maricopa
County portion of the 8-hour ozone modeling area and PM10 nonattainment area are provided in
Tables 6.3-1 and Table 6.3-2, respectively.
However, the emissions developed for the 8-hour ozone modeling area do not cover 7,295 square
kilometers of the western and southern areas of Maricopa County. To obtain NO emissions for
all of Maricopa County, emissions per square kilometer were calculated using MEGAN NO
emission estimates for a 1,600 square kilometer area in the southwest corner of the 8-hour ozone
modeling area. This relatively remote and largely unpopulated area was assumed to be
representative of vegetation in the portion of Maricopa County that was not modeled for 8-hour
ozone. The average NO emissions per square kilometer for the 1,600 square kilometer area,
0.3505 kg/km2-day, was multiplied by 7,295 square kilometers. The result, 2,557 kg/day, was
2005 Periodic PM10 Emission Inventory

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Maricopa County, AZ

added to NO emissions estimated for the 8-hour ozone modeling area within Maricopa County to
obtain total biogenic NO emissions for all of Maricopa County.
Table 6.3–1.
Date
5/31/2002
6/1/2002
6/2/2002
6/3/2002
6/4/2002
6/5/2002
6/6/2002
6/7/2002
Average

Daily NO emissions in the 8-hour ozone modeling area (Maricopa County).
NO (kg/day)
6,414
5,921
5,197
4,742
4,926
5,655
6,536
6,182
5,697

Table 6.3–2.
Date
5/31/2002
6/1/2002
6/2/2002
6/3/2002
6/4/2002
6/5/2002
6/6/2002
6/7/2002
Average

Daily NO emissions in the PM10 nonattainment area.
NO (kg/day)
2,920
2,707
2,371
2,169
2,262
2,598
2,993
2,829
2,606

6.4

Summary of biogenic source emissions

Annual and typical daily NOx biogenic emissions for Maricopa County and the PM10
nonattainment area are summarized in Tables 6.4–1.
Table 6.4–1.

Annual and typical daily NOx biogenic emissions.
Annual emissions
Annual emissions
Season-day emissions
(metric tons/yr)
(tons/yr)
(kg/day)
Geographic area
Maricopa County
3,013
3,321
8,254
PM10 NAA
951
1,048
2,606

6.5

Average daily
emissions (lbs/day)
18,197
5,745

References

Guenther, A., 2006a. User’s Guide to Processing Driving Variables for Model of Emissions of
Gases and Aerosols from Nature (MEGAN), August 14, 2006.
Guenther, A., 2006b. User’s Guide to the Model of Emissions of Gases and Aerosols from
Nature (MEGAN) Version MEGAN-VBA-2.0, August 28, 2006.
ENVIRON International Corp., Final Report, Maricopa Association of Governments 2006
Biogenics Study, September 11, 2006.

2005 Periodic PM10 Emission Inventory

129

Maricopa County, AZ

Appendix 1
Responsiveness Summary to Comments Received on Public Review Draft 2005
Periodic Emissions Inventory for PM10 for the Maricopa County, Arizona,
Nonattainment Area

Responsiveness Summary to Comments Received on
Public Review Draft 2005 Periodic Emissions Inventory for PM10 for the Maricopa
County, Arizona, Nonattainment Area
The purpose of this document is to present public comments and responses to comments received on
the public review draft of the 2005 Periodic Emissions Inventory. The Maricopa County Air Quality
Department (MCAQD) released the 2005 PM10 emissions inventory for public review and comment on
January 23, 2007. The public review period ended on March 1, 2007. MCAQD and the Maricopa
Association of Governments (MAG) have evaluated the comments received on the PM10 emissions
inventory and prepared written responses to these comments. Table 1 contains a list of all individuals
who submitted comments. Comments are taken verbatim from written comments received with a few
minor exceptions (some ancillary tables and general introductory/closing statements not directly
germane to the emission inventory calculations are not reproduced here). Comments about ambient air
monitoring, control measures, dispersion modeling, zoning, source clustering, compliance, and
complaint response are outside the scope of the emissions inventory report.
Table 1. Written Comments Received.
Comment
Number
1
2
3
4 A–H
5 A–F
6 A–G
7
8 A–L

9 A–L

10

Commenter
Charlie Carrier
John Enkoji
Oddvar Tveit
Stephen M. Brittle
Tom Merrifield
Shirley McDonald
Shirley McDonald
Amanda McGennis
and
Albert H. Acken,
Lewis and Roca, LLP
On behalf of Spencer Kamps
Attachment to Comment #8 Memorandum from Jim
Wilson, et al., E.H. Pechan &
Associations
Larry Biland

Affiliation
n/a
n/a
City of Tempe
Don't Waste Arizona, Inc.
n/a
Joint Environmental Task Force
Joint Environmental Task Force
–Arizona Chapter of Associated General
Contractors
–Home Builders Association of Central
Arizona

Date Received
Jan. 25, 2007
Feb. 1, 2007
Feb. 12, 2007
Feb. 12, 2007
Feb. 22, 2007
Feb. 22, 2007
Feb. 22, 2007
Feb. 22, 2007

–Arizona Chapter of Associated General
Contractors
–Home Builders Association of Central
Arizona
U.S. Environmental Protection Agency

Feb. 22, 2007

Feb. 22, 2007

Comment #1:
Living near the intersection of Lindsay and Riggs Roads, I have had plenty of opportunity to
observe poor air quality. While there has been an abundance of new home building in this area
the past 5 years, most of the builders have been pretty good in trying to comply with the “no
dust” rules imposed by the county. The major problem that we have down here stems from 3
sources: 1. The existing farms that continue to pulverize the soil prior to planting cotton, etc. 2.
The dairy farms where the powdered manure gets carried aloft with each passing breeze. 3. The
Gila River reservation which plows and discs the soil for weed control, but is yet to plant
anything to retain the soil. Since all three of these sources are “Grandfathered” in, they really
have no incentive to lessen their dust-causing activities. Until the state or federal government
gets serious about dust abatement it won't matter how much bluster is raised on this issue. Our
legislature probably needs to give some sort of incentive such as a tax credit or something along

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Appendix 1: Responsiveness Summary

that line to bring the farmers on board. What we can do about the problems arising on the
reservation is probably beyond our reach. I wish you good luck in your quest.

Response #1:
Dust compliance issues from agriculture, dairies, and tribal lands are outside the scope of the emissions
inventory report. However, for your information within the Maricopa County PM10 nonattainment
area, agriculture is required to implement best management practices to reduce PM10 emissions under
Arizona Department of Environmental Quality's (ADEQ's) Agricultural PM10 General Permit (Arizona
Administrative Code R18-2-611). Agricultural dust complaints can be filed on ADEQ's online
complaint form at: http://www.azdeq.gov/function/ compliance/complaint.html or by calling (602)
771-2324.
Fugitive dust from dairies is regulated under Maricopa County Rule 310.01. The Maricopa County Air
Quality Department's Dust Compliance Division investigates dust complaints concerning commercial
livestock areas. Rule 310.01 imposes a 20% dust opacity limit and requires the prevention of
excessive emissions of fugitive dust and implementation of one of the following control measures: dust
suppressants (water or dust palliative), surface gravel, or shrubs and/or trees within 50 feet of animal
pens. Dust complaints can be filed on line with Maricopa County Air Quality Department at:
http://www.maricopa.gov/aq/contact_us/forms/dust_form.asp or by calling (602) 372-2703.
According to staff at the Gila River Indian Community's Department of Environmental Quality, the
agricultural fields mentioned by the commenter have been out of production due to lack of water;
however, these fields are expected to go back into production in early summer 2007, once water is
received under a water rights settlement. Air quality concerns on the Gila River Indian Community
can be referred to the Gila River Indian Community's Department of Environmental Quality by calling
(520) 562-2234.
Comment #2:
One way to reduce emissions would be to ban drive up windows throughout Maricopa County. This
would include fast food restaurants, banks, dry cleaners, pharmacies, etc. While convenient, they serve
no essential or critical purpose and are only luxuries that should be banned in the interests of helping to
clean our air. If the ban were universal and county wide, no specific business or establishment would
suffer a disadvantage or gain an advantage. The numbers of cars that are idling at drive up windows on a
daily basis in the county must number in the hundreds of thousands.

Response #2:
Development of potential control measures to reduce emissions is outside the scope of the emissions
inventory. However, the Maricopa Association of Governments (MAG) is in the process of
developing a preliminary draft comprehensive list of control measures to reduce PM10 for a new PM10
SIP. Your suggestion has been forwarded to MAG for consideration.
Comment #3:
The non-road mobile sources inventory for airport ground support equipment calculates emissions for 8
towered airports using the MAG Airport Emission Model that is limited to ground support equipment
(Auxiliary Power Units). Below I have compared the numbers with calculations the URS Corporation did
for the FAA for proposed projects at the PHX Sky Harbor International Airport in the 2006 EIS using a
different model, FAA's Emission and Dispersion Modeling System. The numbers below are taken from
table 3.5.9.1 in the FEIS that also include airport non-road on-site vehicle traffic. It appears that the draft
2005 inventory only accounts for Sky Harbor emissions, or is the use of different models/input the reason
for this discrepancy in tpy inventories?

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Appendix 1: Responsiveness Summary

Inventory
PHX Final EIS
(2001)
MAG 2005 Draft
Emission Inventory

Sources
On-site Vehicles
GSE
GSE

PM10
7
11
16.5

PM2.5
5
10
15.7

NOx
233
424
467.82

SOx
n/a
n/a
14.71

NH3
n/a
n/a
n/a

Response #3:
The MAG Airport Emissions Model was used to generate 2005 ground support equipment emissions
for all the towered airports in Maricopa County. The airport emissions model was developed under
Phase II of the MAG Aviation Air Quality Study, November 1996.
The table below lists the contribution from each of the towered airports in Maricopa County. It is clear
from the table that Sky Harbor alone contributes more than 85% of the total emissions from GSE.
MAG staff had not had an opportunity to review the methodology used by FAA in developing the
FEIS for Sky Harbor. However, the differences between the Phoenix FEIS and the MAG 2005 GSE
estimates are most likely explained by the used of different models and input assumptions.
Pollutant Contribution from GSEs at Towered Airports in Maricopa County
Airport
Chandler
Glendale
Mesa Falcon
Dear Valley
Goodyear
Sky Harbor
Scottsdale
Williams Gateway

CO
1%
1%
3%
0%
4%
86%
1%
3%

NOX
1%
0%
1%
0%
2%
89%
1%
6%

SO2
1%
1%
1%
0%
2%
89%
1%
5%

PM10
0%
0%
0%
0%
1%
92%
1%
5%

PM2.5
0%
0%
0%
0%
1%
92%
1%
5%

Comment #4 A & B:
The draft emissions report draft (2005 Periodic Emissions Inventory for PM10 for the Maricopa County
PM10 Nonattainment Area) is fatally flawed. For one thing, the emissions from sand and gravel operations
and asphalt batch plants are exponentially under-stated.
The MCAQD has systemically and programmatically failed to accurately account for the PM10 and PM2.5
emissions from sand and gravel outfits operating in Maricopa County. Don't Waste Arizona, Inc.
(DWAZ) has reviewed the annual emissions reports of several sand and gravel operations in Maricopa
County, covering several years, and the reported PM emissions have no basis in reality. Some sand and
gravel operations have reported no (zero) emissions of PM, year after year, while others have filed
amounts that are vastly understated. This could indicate several things: 1) the agency itself has no quality
control over the emissions reports being filed; and/or 2) there is someone at the agency who has
deliberately allowed this to occur, i.e. corruption. In any event, the problem is systemic, and indicates that
the entire county air program is fatally flawed.

Response #4 A & B:
All annual emission reports undergo a number of quality control checks; these are described in detail in
Section 2.7 of the report. While the County does not currently regulate emissions of PM2.5, EPA’s
Consolidated Emissions Reporting Rule (CERR) requires that PM2.5 be estimated and reported in
periodic emissions inventories. Thus PM2.5 emissions are estimated based on calculated PM10
emission rates, using standard procedures outlined by EPA or other regulatory agencies (e.g., the
California Air Resources Board).
Comment #4 C & D:
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Further investigation into the agency’s oversight of these sand and gravel outfits shows that their required
dust control plans are frankly a joke. Several of these sand and gravel outfits claim that the enormous
piles of dirt they create have a “natural moisture content” that prevents blowing dust. DWAZ has seen no
evidence that MCAQD has ever tested the soil moisture content of any of these. Other ridiculous
assertions include statements that driving trucks over miles of unpaved roads are controlled and produce
little dust.
Some facilities state that their water trucks are responsible for keeping piles of dirt and dirt roads watered,
yet when the agency actually showed up due to complaints, the inspector found that the water truck was
not working.

Response #4 C & D:
The issue of enforcement in the sand and gravel industry is beyond the scope of the emissions report.
The Department is currently in the process of conducting full inspections at all Maricopa County
permitted sand and gravel facilities. All submitted dust control plans will be reviewed over the next
several months for revision, where necessary, and approval.
Stockpiled materials will retain moisture from process controls with the surface subject to drying.
Stabilization of the stockpile surface, in compliance with Maricopa County Rule 316, by crusting with
water, application of dust suppressants, covers, or other methods are intended to control wind
generated fugitive emissions. The soil moisture does not need to be tested unless there is a question of
compliance with Rule 316 subsection 306.1 or 306.5.
Rule 316 is not a zero emissions regulation, however through the use of water, palliatives, or other dust
suppressants unpaved roads fugitive dust generation and stabilization standards may be in compliance
with the regulation. Comments made on an inspection report are intended to convey issues as
observed at time of inspection. A non-operational water truck does not always indicate that a facility is
in violation of a permit condition or rule standard. Violations are only issued based on inspector
observations which unfortunately do not always occur contemporaneously with complainant
observations.
Comment #4 E & F:
There is a faulty response to citizens’ complaints, or not even a response. Citizens complain, then no one
ever investigates or responds. In some cases, the inspector has called days or weeks after the complaint
was filed, and if the inspector does not reach the complainant, there is no on-site investigation. When the
head of the agency is notified that there has been no follow up to the complaint, nothing changes.
There are no night-time or weekend inspectors, and sand and gravel operations stop using spray bars and
emit enormous amounts of dust without ever reporting these emissions on emissions reports. Even when
these are reported to the director of the agency, no enforcement action or investigation ensues. (See a
short video of what goes on at night at http://www.dontwastearizona.org/gravel.html) This URL was
supplied to the agency director, and there was no action taken. The problem persists.
There is a lack of inspections while these sand and gravel outfits are actually operating. Time after time,
the agency inspector shows up to conduct an annual inspection, and the facility is not in operation at that
time, and the inspector does not return that year.

Response #4 E & F:
Response to citizen complaints and other enforcement issues are beyond the scope of the emissions
report. Starting December 2006, inspection of the sand and gravel facilities became a shared
responsibility between Dust Compliance and Stationary Source Compliance. This effectively
increased the number of responding inspectors by 30. The Department is committed to responding to
all complaints within 24 hours and is working on plans to institute a second and weekend shift pending

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Appendix 1: Responsiveness Summary

approval of staffing. By Department policy all fugitive dust complaints result in an inspection and
contact with the complainant where possible.
Comment #4G:
There are portable facilities operating in Maricopa County using ADEQ-issued permits. There are no
records of their emissions or of any inspections of these outfits while they are operating by ADEQ. None
of these emissions are accounted for in the draft report.

Response #4G:
On the contrary, portable sources with permits issued by ADEQ are addressed in section 3.3.11 of the
report, “State-permitted portable sources”. Emissions attributable to activity within Maricopa County
were estimated based on information provided by the Arizona Dept. of Environmental Quality.
Comment #4H:
The worst air quality is in the areas where sand and gravel outfits are operating, along the Salt River Bed
and along the Agua Fria riverbed. There are several of these sand and gravel outfits along the Salt River
Bed, which has the highest PM levels, and where the exceedances of the federal standard have occurred.
Rusty Bowers, while a state senator, demanded that the MCAQD’s air monitors at the 22nd Avenue and
Lower Buckeye Road location be moved. He is now officially the lobbyist for the sand and gravel outfits.
The City of Phoenix was complicit in the moving of the 22nd Avenue and Lower Buckeye Road monitor
to 43rd Avenue and Broadway because of its vast earthmoving project, the Rio Salado Project, and the
certainty that this would trigger even more exceedances at that monitor.
The second worst place for PM concentrations in the ambient air in Maricopa County is in the Sun City
area, where there are 26 sand and gravel outfits and asphalt plants in a five-mile radius operating along
the Agua Fria riverbed. The MCAQD’s own money was spent to conduct this monitoring. There is no
industry in Sun City other than the 26 sand and gravel outfits and asphalt plants. Folks there don’t
commute to work. Clearly, the 26 sand and gravel outfits and asphalt plants are the source of the
particulate matter.

Response #4H:
Annual emissions from mining and quarrying sand and gravel operations are included in the 2005
PM10 emissions inventory in Chapter 2 (Point Sources) and Chapter 3 (Area Sources). Ambient
monitor siting and ambient concentrations are outside the scope of this report; however, MCAQD
would like to clarify the facts pertaining to comments made regarding relocation of the Salt River
monitor and PM10 concentrations in Sun City.
The Salt River monitor was established at a City of Phoenix vehicle maintenance yard (near 19th
Avenue and Lower Buckeye Road) in 1994. In January 2002, the monitor site was relocated from its
original location in the southeast corner of the property to the roof of the City office building on the
property. Removal of the monitor site was requested by the City of Phoenix because of scheduled
construction on and near the vehicle maintenance yard property (unrelated to the Rio Salado project
construction which actually began in 2000).
Efforts to find a suitable replacement site with comparable PM10 concentrations and industrial
emissions were conducted by Maricopa County and Arizona Department of Environmental Quality in
2002. The West 43rd Avenue site was determined to be a suitable replacement site. This site is
located at a Maricopa County Department of Transportation storage lot and is surrounded by a
combination of heavy industry and residential homes. The main purpose of the monitor is to measure
maximum concentration PM10 and to determine the impact on ambient pollution levels of significant
sources or source categories. The sources around the site include sand and gravel operations, auto and
metal recycling, landfills, paved and unpaved haul roads, and cement casting.

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In 2002, ADEQ analyzed the PM10 concentrations and source attributions for the West 43rd Avenue
site and the Salt River site. The results of ADEQ's analysis are documented in the Salt River PM10
State Implementation Plan Revision.1 ADEQ concluded that despite the contrast between the two
sites in their nearby emission sources, the PM10 concentrations were nearly equivalent. Their analysis
showed that diurnal patterns are similar and late evening and early morning concentrations were nearly
identical. ADEQ concluded that since PM10 concentrations at the West 43rd Avenue site are higher
than the Salt River site, the former is an adequate replacement for the latter. This equivalence was also
born out by a cursory look at the regulatory important extreme values. In 2002, the Salt River PM10
maximum concentrations were 249, 184, and 174 µg/m3, with the first two under high wind conditions.
At West 43rd Avenue, the highest PM10 concentrations were about the same: 243, 174, and 181
µg/m3, with the first two under high wind conditions. Under low-wind and high-wind conditions, the
two sites recorded equivalent maximum 24-hour average PM10 concentrations.
In response to concerns from Sun City residents in the vicinity of several sand and gravel operations, in
2004 MCAQD contracted with Weston Solutions, Inc. to conduct a 4-month ambient air quality study
along the Agua Fria River basin in the Sun City area. The study focused on particulate matter and
polynuclear aromatic hydrocarbons (PAHs). Only a single day at one monitoring location had a 24hour PM10 concentration above NAAQS of 150 µg/m3. This concentration was caused by a natural
occurrence which was recorded on a county-wide basis and was not the result of a particular source or
industry. The event resulted in elevated PM10 concentrations at all the study monitors. Furthermore,
since this was a single occurrence in a short-term monitoring program (less than 1 year), this elevated
concentration does not constitute a violation of the NAAQS.
Lastly, in response to Sun City residents concerns, in spring 2007, MCAQD installed a special purpose
PM10 monitor in the Coyote Lakes subdivision of Sun City near 111th Avenue and Beardsley on April
1, 2007. The real-time data is available on the county website at http://www.maricopa.gov/aq/
divisions/monitoring/Default.aspx.
Comment #5A:
The fundamental question I have when reviewing this document is “where the beef;” by that I mean
“where is the data.” Because the “data” for this study is primarily a calculation for each facility or
activity, I feel that appendices should be available to review that shows calculations for each permitted
facility mentioned or activity. I think there is too much latitude for error and misrepresentation of the
calculations. Furthermore, for each permitted facility or activity, there needs to be more detail on any
adjustments made, for instance, how were contributions made when NOVs were issued, when operating
in a manner inconsistent with the permit. In the report oral conversations with a facility were noted as
part of the data base; notes from those conversations should be included in the appendix.

Response #5A:
The emissions inventory report follows EPA guidelines for required documentation. Individual facility
reports are available at the Department offices and are available for inspection and review upon
request; reproducing this level of detail in the inventory report itself would be inefficient (and costprohibitive). In developing emission inventories for SIP planning purposes, the US EPA requires the
application of rule effectiveness which is designed to reflect the fact that regulatory programs typically
achieve less than full compliance. Section 2.3.2 of the report describes the application of rule
1

Final Salt River PM10 State Implementation Plan Revision, Technical Support Document Chapter 3, Arizona Dept. of
Environmental Quality, Air Quality Division, January 2004.

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effectiveness, and all facilities that that have had rule effectiveness applied to their emission
calculations according to current EPA guidance, are clearly indicated in the report.
Comment #5B:
I feel that any monitoring data gathered needs to be included. This data needs to be utilized to calibrate
and adjust the calculations. Perhaps this was done in this report; if so, this needs to be made very clear,
perhaps in a separate chapter.

Response #5B:
MCAQD assumes that the commenter is referring to monitoring data from stationary source
continuous emissions monitors (CEMs) rather than ambient air monitoring data. Data from CEMs are
preferred for estimating a source’s emissions; however, CEMs data from individual sources are not
always available. The EPA only requires certain large stationary source categories to install and
operate CEMs. Electric utilities are the only source category operating within Maricopa County,
required to operate CEMs. Thus, source performance tests and emission factors are frequently the best
or only method available for estimating emissions.
Maricopa County has an established annual reporting program for sources with air quality permits.
Businesses submitting annual emission reports must use the most accurate method for calculating
actual emissions. Whenever available, emissions are calculated based on CEMs data. When CEMs
data are not available, emissions are calculated based on source performance tests, material balance,
emissions factors from EPA's AP-42, or by equivalent methods supported by back-up documentation
that will substantiate the chosen method.
Comment #5C:
I feel there needs to be a chapter entitled “Analysis or Interpretation” of the data and a chapter entitled
“Summary or Conclusion/Recommendations.” I understand this is an inventory, but the EPA is asking
this inventory to be done for a reason. It is unclear to me what this inventory is going to do for the public
in order to address the overall problem of non-attainment of PM10.

Response #5C:
The Clean Air Act requires states with areas failing to meet National Ambient Air Quality Standards
(NAAQS) to produce a state implementation plan (SIP). A SIP is an enforceable plan developed at the
state and local level that explains how the area will comply with air quality standards according to the
Federal Clean Air Act and its amendments.
The PM10 emissions inventory is one component of the SIP currently being developed to address the
PM10 problem in Maricopa County (referred to as the “Five Percent Plan”). The Five Percent Plan will
include historical background information, a description of the nonattainment area, an assessment of
air quality conditions and ambient air quality data for the area, an emissions inventory of sources of
pollutants, control strategies, an attainment demonstration, and contingency provisions. Before the
Five Percent Plan is submitted to EPA in December 2007, it will be available for public review. The
public review phase is slated for fall 2007.
Comment #5D:
In order to address the EPA compliance issue of non-attainment for Maricopa County, this inventory of
data needs to be mapped and an analysis of the density of tonnage of pollutants can be better estimated.
This really needs to be completed in order to address Item #2 above (see comment #5B in this document).
The results of this density analysis should be used to address where more monitoring stations need to be
set up to calibrate the inventory data throughout Maricopa County.

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Response #5D:
Ambient air monitoring stations are set up to measure ambient air not to calibrate the emissions
inventories. MCAQD’s Air Monitoring Division maintains ambient air monitoring networks within
the borders of Maricopa County. The purpose of the ambient air monitoring network is to sample air
pollution in a variety of settings, assess the health and welfare effects, and assist in determining
sources of air pollution.
Conversely, emissions inventories are developed to meet Federal Clean Air Act requirements and they
provide a baseline understanding of local and regional sources of emissions. The Maricopa
Association of Governments is developing a PM10 state implementation plan (referred to as the Five
Percent Plan). The Five Percent Plan must show reductions in PM10 emissions of five percent per year
until attainment is achieved at all monitors. The 2005 PM10 emissions inventory will be the starting
point for the five percent per year reductions.
The Five Percent Plan will also include an assessment of air quality conditions and ambient air quality
data for the area and must demonstrate through modeling that the PM10 standard will be met at all
monitors. Before the Five Percent Plan is submitted to EPA in December 2007, it will be available for
public review. The public review phase is slated for fall 2007.
Comment #5E:
Where the density of pollutant emissions are high, care needs to be taken to ensure that ARS 49-401-B is
not violated. This statute states that a new facility shall not begin operation if existing air quality is
already degraded beyond the EPA standards.
In my mind the EPA standards are what protect my health and my property through the vehicle of ARS
49-401A, and as a person living 180 feet down gradient from a future emitting facility, I question the
applicability of the calculations presented herein in order to ensure compliance with the statute. The
calculations in this report tell me nothing about how this inventory affects me personally. In my mind
this report so far has been a waste of my tax dollars.

Response #5E:
The comment is outside the scope of this emissions inventory report. An emissions inventory is not
meant to provide a measurement of impacts on a particular individual. An emissions inventory is a
comprehensive listing by source category of air pollutant emissions. Emissions inventories are
developed to meet Federal Clean Air Act mandates and to identify sources and general emission levels,
patterns, and trends to develop control strategies and new regulations.
Conversely, ARS 49-401-B requires industries to operate within the emission standards set by the
director of the Arizona Department of Environmental Quality. The Maricopa County Air Quality
Department has the legal authority to enforce all Air Quality Rules and Ordinances within County
borders. The rules are adopted under the authority granted by Arizona Revised Statures §49-479 to
fulfill the State’s responsibilities under the Federal Clean Air Act and its amendments to provide a
legally enforceable State Implementation Plan for the attainment and maintenance of the National
Ambient Air Quality Standards.
The Maricopa County Air Pollution Control Regulations were put in place with the goal of assisting
Maricopa County in complying with the Federal health-based National Ambient Air Quality Standards.
Air permit conditions are based on an engineering review, which included the calculation of potential
emissions, and an analysis of applicable County, State, and Federal regulations. Each facility is
required to comply with all applicable Maricopa County Air Quality Department regulations and

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Appendix 1: Responsiveness Summary

standards related to their operations. Failure to meet the requirements of all applicable rules can result
in an enforcement action to be brought against the facility.
Comment #5F:
Personally I am involved in negotiating with a future emitting facility 180 feet from my house because in
my opinion the Maricopa County zoning laws for county islands are so relaxed and do not support ARS
49-401-A. I feel the negotiations with the future emitting facility next to my house are going very well,
but I still question the legality of the county zoning laws given the statements made in ARS 49-401-A,
which should apply to the entire state. I am not a lawyer, but in my opinion the County is using an
archaic federal mining law to be used as a basis for granting an exemption to normal zoning regulations
that would protect me, my family and my property under ARS 49-401-A. It appears to me to be a local
vs. federal rights legal issue. The irony is that the local government is using federal law to govern
locally, which to me is absurd, and I question its legality, especially in view of the state statute.

Response #5F:
Zoning issues are outside the scope of this emissions inventory report.
Comment #6A:
The para. 2.3.4 example calculation on page 20 uses a rule effectiveness factor of 93.88% for a “point
source” process. Since this plant (River Ranch Plant #40) was listed in Table 2.4-1 as a “point source”, it
appears that this would be the correct RE factor. However, when applying the “non-point” source RE
factor (54.36%) from paragraph 2.3.4, to the annual emission report PM10 annual totals for each of four
Rinker plants, it appears that the numbers in Table 2.4-1 were derived using this factor rather that the
point source factor. Why?

Response #6A:
In the example equation on page 20, of section 2.3.4, which describes how annual emissions are
calculated to incorporate rule effectiveness, MCAQD incorrectly applied the point source RE
percentage (93.88%) to a process that should have used the Rule 316 effectiveness study percentage
(54.36%). As stated in Appendix 2.2, all processes that are subject to Rule 316 and use a manual
control such as watering are subject to the Rule 316 effectiveness percentage (54.36%), regardless if
the process is categorized as a point or non-point process. Table 2.4-1 correctly summarizes the
emissions from each facility and includes processes that are subject to the Rule 316 effectiveness
percentage (54.36%). MCAQD will correct the example equation in section 2.3.4.

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Comment #6B:
Are all of the sand and gravel mining plant data derived from the nonpoint source factor? Are you going
to collect fees for the extra emissions?

Response #6B:
Data used to calculate emissions from sand and gravel facilities are based on annual surveys completed
by individual sand and gravel facilities from within Maricopa County. MCAQD reviews the annual
surveys for completeness and accuracy of data submitted. For this report, MCAQD also applies rule
effectiveness percentages to each reported process where appropriate. For sand and gravel facilities,
all processes that are manually controlled by water and are subject to Rule 316, a rule effectiveness
percentage of 54.36% is applied to those processes (see Appendix 2.2). Processes that are not
controlled manually with water (such as a baghouse) apply the point source rule effectiveness
percentage of 93.88% (see Appendix 2.3). For processes where no controls are used, neither the point
source nor the Rule 316 rule effectiveness percentages apply.
Emission fees are outside the scope of the emissions inventory report. See Response #6C for an
explanation of increased individual facility emissions due to the application of rule effectiveness
percentages.
Comment #6C:
When the PM10 permit limits for seven plants are compared with the annual emissions shown in Table
2.4-1, six of the seven are out of limits. Are you going to compare all of the plant permit limits with the
annual emissions shown in Table 2.4-1? Are you going to issue violations? Why not?

Response #6C:
The application of rule effectiveness percentage can substantially increase an individual facility’s base
reported emissions. Rule effectiveness percentages are a useful tool in the development of regional
inventory to help predict the effects of assumed operator error and faulty control equipment. It is
possible that the process of applying rule effectiveness to individual facilities will increase their annual
emissions beyond their permit limits. However, annual emission estimates that include adjustments for
rule effectiveness cannot be used for compliance purposes, as compliance with permit limits is based
on actual reported emissions.
Comment #6D & E:
Of the 30 permits that we have, 23 would be considered point sources according to the 5 tpy criterion. Six
of these are 2006 permits. In the July 7, 2005 response to comments for the 3/15/05 Vulcan permit
#970105 Hearing, it is stated that there are 87 sand and gravel operations in the valley. Add the six 2006
permits, and it becomes 93 plants. If 23/30 permits are point sources, then the number of point sources
listed in Table 2.4-1 should be about 70 rather than the 20+ shown there. The criterion is the 5tpy not
whether a plant is portable or not.
With numbers like these that are questionable, how are you going to convince the public and the EPA that
you have caused a 5% reduction this year and for the next 3 years?

Response #6D & E:
MCAQD determined which facilities are categorized as point sources through a review of all 2005
annual emissions reports that were submitted to MCAQD. In order to be categorized as a point source,
a facility needed to have actual reported emissions that meet or exceed 25 tons of carbon monoxide
(CO); or 10 tons of either volatile organic compounds (VOC), oxides of nitrogen (NOx), or sulfur
oxides (SOx); or 5 tons of either particulate matter less than 10 microns (PM10) or ammonia
compounds (NHx). In addition to meeting or exceeding one of the pollutant thresholds noted above,
MCAQD chose to list only the permanent stationary sources (non-portable) as part of Chapter 2 (Point

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Sources). MCAQD-permitted portable concrete batch and sand and gravel facility emissions are
included in Chapter 3 (Area Sources) Sections 3.3.4 and 3.3.5, respectively. All MCAQD-permitted
portable were assumed to operate in the nonattainment area in order to conservatively estimate
emissions. ADEQ-permitted portable facility emissions are included in Section 3.3.11. MCAQD
listed 36 MCAQD-permitted facilities in the point source chapter that engage in sand and gravel
activity. 71 MCAQD-permitted facilities comprise the area source section for sand and gravel
activities (mining and quarrying, 3.3.5); and of those 71, 23 are listed as portable sand and gravel
permits. ADEQ reported 69 ADEQ-permitted portable sources that comprise the emissions in Section
3.3.11.
Comment #6F:
The nonroad internal combustion engines that are exempt still contribute to the nonattainment here. Add
their pollution to the totals. Some are 1000hp.

Response #6F:
All emissions from nonroad engines are included in Chapter 4. Nonroad engines associated with sand
and gravel or concrete batch facilities are included in Section 4.5 (Construction and mining equipment)
and 4.6 (Industrial equipment).
Comment #6G:
There are plenty of witnesses in the Northwest Valley who see dust at night from mining operations
because water sprays are not used. When water is not used, pollution is not 30%, its 100%!

Response #6G:
Part of the Rule 316 rule effectiveness study takes into account the compliance rate of facilities that are
controlling process emissions through the use of water. Failure to use water to control emissions is
included in the quantification of the effectiveness percentage of the Rule 316 study (contained in
Appendix 2.2 of this report). Using this rule effectiveness percentage, MCAQD has on average
increased emissions from these types of processes to account for possible non-compliance with dust
control or watering requirements.
Comment #6H:
The out of compliance condition here is evidence that guessing what the total pollution is … is not
working. You need more monitors. You also need to take into account what the excess pollution is doing
to the public health, even your own families. It is especially hazardous to those who live near clusters of
plants.

Response #6H:
Ambient air monitoring is outside the scope of the emissions inventory report. MCAQD develops an
annual network review which is posted on MCAQD's website at: http://www.maricopa.gov/aq/
divisions/monitoring/network.aspx. A fundamental purpose of this review is to provide the citizens of
Maricopa County with relevant information, so that they may make better decisions about their lives.
This information is used in a variety of ways. Most importantly it is used to determine the attainment
status for parts of Maricopa County. Mathematical models are using the data to determine the
effectiveness of control programs on pollution levels.
It is physically and fiscally impossible to monitor air quality in every location, representative samples
must be obtained. The optimal locations for obtaining these samples are determined by using the
monitoring objectives and the spatial measurement scales established by EPA. For example, there
might be numerous locations where the highest concentration of particulate matter may occur. Using

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EPA monitoring objectives and spatial measurement scales, only one or two sites will be established to
represent all of the high-concentration areas.
Comment #7:
The Joint Environmental Task Force also supports the comments from Tom Merrifield. The idea of a
three dimensional plot of the data would be very enlightening. Looking at averages for the valley as a
whole versus finding out where the “clustered” pollution is occurring and causing the noncompliance is a
reasonable as well as a scientific approach.

Response #7:
Ambient air monitoring stations are set up to measure ambient air not to calibrate the emissions
inventories. MCAQD’s Air Monitoring Division maintains ambient air monitoring networks within
the borders of Maricopa County. The purpose of the ambient air monitoring network is to sample air
pollution in a variety of settings, assess the health and welfare effects, and assist in determining
sources of air pollution.
Conversely, emissions inventories are developed to meet Federal Clean Air Act requirements and they
provide a baseline understanding of local and regional sources of emissions. The Maricopa
Association of Governments is developing a PM10 state implementation plan (referred to as the Five
Percent Plan). The Five Percent Plan must show reductions in PM10 emissions of five percent per year
until attainment is achieved at all monitors. The 2005 PM10 emissions inventory will be the starting
point for the five percent per year reductions.
The Five Percent Plan will also include an assessment of air quality conditions and ambient air quality
data for the area and must demonstrate through modeling that the PM10 standard will be met at all
monitors. Before the Five Percent Plan is submitted to EPA in December 2007, it will be available for
public review. The public review phase is slated for fall 2007.
Comment #8A:
Home Builders and AGC were extremely disappointed that the Draft Emissions Inventory and supporting
studies were developed without stakeholder input and involvement. Home Builders and AGC have a great
deal of technical expertise and unique understandings about their industries. This knowledge is an
invaluable resource that MCAQD should use when developing the best emissions inventory possible.
For example, Home Builders and AGC expressed a willingness and desire to work with MCAQD to
develop a technically sound and rigorous Rule Effectiveness Study methodology in the summer of 2006.
Unfortunately, MCAQD developed its initial study behind closed doors. Additionally, MCAQD did not
provide an opportunity to review the Draft Emissions Inventory when it was first developed.
Notwithstanding these earlier disappointments, Home Builders and AGC welcome the opportunities
provided by MCAQD to provide input to the Draft Emissions Inventory during the public comment
period and appreciate MCAQD's willingness to consider additional information provided.
We recognize that some of the comments and ideas suggested by Home Builders and AGC will require
some effort to address. We hope that MCAQD does not simply take the position that there is now too
little time left to resolve outstanding issues and incorporate Home Builders' and AGC's suggestions. To
ensure that timing and resource issues are not a concern when developing the final emissions inventory,
Home Builders and AGC hereby volunteer their expertise and assistance and stand willing to assist
MCAQD in its efforts.

Response #8A:
MCAQD concurs that an open process is important to developing an emission inventory that will
become part of a state implementation plan such as the Five Percent Plan. This is the reason MCAQD

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released on January 23, 2007, a draft of the PM10 emissions inventory with supporting documentation
via the department's website. MCAQD made the document available to the public for a 30-day review
and comment period. In addition, MCAQD held a public workshop on January 30, 2007, to provide an
overview of the emissions inventory and to answer questions. MCAQD is evaluating and responding
to all comments received during the public review period.
EPA emissions inventory guidance requires EPA approval and thus a public review process for
emission inventories that are deemed to be of “regulatory significance”. In general, this means that the
approval process for an emissions inventory of “regulatory significance” will be as a component of a
SIP submittal. Clearly, the draft 2005 PM10 emissions inventory is of “regulatory significance” and
thus requires public review and EPA approval as a component of the Five Percent Plan submittal.
Because the public review process for the Five Percent Plan is not scheduled until September 2007,
after all the technical work and attainment demonstrations are completed, MCAQD made the draft
PM10 emissions inventory available for public review well in advance of when the document was
technically required to be made available. Further, MCAQD provided the public an opportunity to
review the document less than one week after it went through internal peer review at Maricopa
Association of Governments and Arizona Department of Environmental Quality.
Comment #8B:
It is critical that all PM10 sources be identified and explained. This includes secondary and condensable
particulate formation.
For all emission sources, please also identify, and explain the reasons for using, the data sources,
assumptions, emission factors, methodologies and categories used to develop emission estimates. For
example, we recommend that summary tables 1.6-10, 1.6-1 1, 3.1-1, 3.6-1, and 3.6-2 be revised to
identify construction sources by subcategories, as has been done for other sources such as agriculture,
which is subdivided into various agricultural activities.
Additionally, with respect to construction emission estimates, it would be helpful to have definitions of
the various subcategories of construction sources that are identified in tables 3.3-17 through 3.3-21. We
are concerned that MCAQD's methodology for identifying construction subcategories, which was based
on dust control permit forms, does not necessarily correlate to emission factors developed by WRAP,
EPA, and others. Roughly two-thirds of the road construction projects in Maricopa County over the past
two years involved reconstruction above sub-grade and sub-base or milling and overlaying. These
activities generate relatively few emissions.

Response #8B:
MCAQD is willing to address specific instances where data sources, emission factors, and
methodology may be unclear; however, it is difficult to respond to sweeping generalizations. MCAQD
has used the most current published emission factors and data available and thoroughly documented all
data sources, assumptions, and emission factors. The 2005 PM10 emissions inventory report, including
appendices, encompasses more than 200 pages of documentation.
Summary tables 1.6-10, 1.6-11, 3.1-1, 3.6-1, and 3.6-2 have been revised to identify separately the
following construction subcategories: residential, commercial, road, and “other” construction
activities (“other” includes trenching, demolition, weed control, site prep/land development, and
temporary storage yard projects).
MCAQD categorizes the project type from information provided by the permit applicant on the
Application for Dust Control Permit. Prior to July 2005, the applicant indicated the project type by
selecting “Type of Project” from a discrete series of check boxes. The dust control permit application

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form was revised effective July 2005 in response to EPA concerns requiring more documentation
regarding the control measure to be used at each project. Since that time, information on the project
has been provided by the applicant in a number of ways: data provided on the application forms
include “Name of Project” (Item 7), “Description of Project” (Item No. 8), and “Project Site Drawing”
(Item 12). From this information, MCAQD permit intake staff assign a “project type” code (consulting
with the permit applicant in-person or by phone if additional details are needed).
While a single permit may encompass more than one project category (e.g., a dust control permit for a
new “residential” development often entails substantial road construction activity), the assignment of a
category for emission calculation purposes is directed at the primary activity at the site. MCAQD
acknowledges that the emission factor used for all “road construction” projects in its January 2007
emissions inventory report reflects “worst-case” conditions2, and thus has adjusted its assumptions
(described in detail in Response 9B, below) for the May 2007 report.
Lastly, a dust control permit is only required for reconstruction above sub-grade and sub-base or
milling and overlaying should the contractor remove sufficient surface road layers to reach the dirt or
rock surfaces. However sources that do not reach the dirt or rock surface, may still require a dust
control permit for a storage yard. For example, one company that does repaving that does not involve
sub-grade and sub-base does not obtain their dust control permit for the repaving work, they obtain the
permit for the other disturbed areas, such as storage piles. Should this type of reconstruction activity
be included in the “road construction” projects it will be relatively small acreage in comparison to the
total “road construction” acreage.
Comment #8C:
Home Builders and AGC believe that the best way to ensure the emissions inventory represents actual
conditions is to use the best information available. We believe local, current, and measured observations
are superior to emission factors extrapolated from national or regional sources. For example, we
understand that unpaved road emissions are based on data from the 1990s. See page 108, estimates for
miles of improved roads and traffic levels. This information is simply too stale to be used for this
important project, which must be comprehensive, accurate, and current.

Response #8C:
MAG used the best available data on unpaved roads to prepare the PM10 emissions estimates in the
Draft 2005 Periodic Emissions Inventory for PM10. The unpaved road mileage by traffic volume
category (i.e., low – average of 4 average daily trips (ADT) and high – average of 120 ADT) was
derived from a database developed for the MAG Serious Area PM10 Plan. The Serious Area PM10
Plan, that was approved by EPA on July 25, 2002, reduced the miles of unpaved roads to reflect
legally-binding commitments made by local jurisdictions to pave and stabilize unpaved roads by 2006.
To ensure that these unpaved road assumptions continue to be representative of the PM10
nonattainment area, MAG will work diligently to update the traffic counts on a sample of unpaved
roads. MAG will also apply geographic information systems (GIS) and recent aerial photography to
estimate the current unpaved road mileage. Since it will take several months to collect this data, it will
not be available to recalculate unpaved road emissions for the final 2005 periodic emissions inventory;
however, it will be available for use in estimating the 2007 unpaved road emissions for the Five
Percent Plan for PM10.
Comment #8D:

2

MRI, 1996. Improvement of Specific Emission Factors (BACM Report No. 1), Final Report, March 29, 1996, Table 7.

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E.H. Pechan & Associates, Inc. (Pechan) has reviewed the assumptions, emission factors, methodologies,
and calculations for some of the major source categories identified in the Draft Emissions Inventory.
Pechan's analysis is attached and incorporated by reference. As detailed in the attached analysis, Pechan
discovered specific concerns with the following categories: (1) construction; (2) windblown dust; (3)
paved roads; and (4) unpaved roads.
Pechan's technical concerns include, but are not limited to, the following: (1) computational errors; (2) the
use of different assumptions, emission factors, and data in the Draft Emissions Inventory when compared
to other inventories; (3) the lack of supporting documentation for some assumptions; and (4) the use of a
rule effectiveness methodology that does not adequately represent actual conditions at complex sources
such as construction sites.
The following table, solely based on Pechan's analysis of construction emissions, shows the relative
contributions of major sources and total emissions in the PM10 nonattainment area:
Source Category
Residential: Single-Family
Residential: Multi-Unit
Commercial
Road Construction
Site Prep/Land Development
Other Construction
Total Agriculture
Offroad Rec. Vehicles
Unpaved Parking Lots
Windblown dust
Wildfires
Aircraft
Paved road Fugitive Dust
Unpaved Roads
Other Emission Sources
Total Emissions

Total PM10 Emissions
895
2051
2908
1754
216
58
2719
2159
3009
1087
4860
6364
13783
8490
11154
61507

% of Total Emissions
1.46%
3.33%
4.73%
2.85%
0.35%
0.09%
4.42%
3.51%
4.89%
1.77%
7.90%
10.35%
22.41%
13.80%
18.13%
100.00%

Pechan has proposed alternative rule compliance methodologies that they believe are appropriately
rigorous and detailed for the important purpose of estimating Rule 310 compliance. We requested that
MCAQD revise the Draft Emissions Inventory to be consistent with Pechan's suggestions.

Response #8D:
MCAQD and MAG responded to each of Pechan's comments separately in responses 9A–9L.
Comment #8E:
It is a common practice in the construction industry for one entity to obtain a permit for a large site, and
then shortly thereafter subdivide the site to builders, who then obtain another permit for a position of the
same site originally covered under the first permit. Accordingly, using the permit database to determine
the amount of acreage actually under construction can be only a starting point for any assessment of
acreage under construction.
We are glad to learn that MCAQD recognizes this, and has attempted some creative solutions to address
this problem in past. We appreciate MCAQD's expressed interest in obtaining additional information that
will further help it identify instances of double counting.
A good first place to look is at all permits where the site activity listed is site preparation/land
development. The entities that obtain these permits are typically large developers who then pass along
portions of the large site to individual builders. In fact, MCAQD should review all permits obtained by
these entities as well as the permits pulled by others in the same area to identify instances of doublecounting.

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Additionally, this is a common practice in growing areas near the boundaries of the metropolitan area.
We recommend reviewing permits in those areas to determine whether double-counting has occurred. We
offer our assistance in that effort. Implementing the recommendations will allow MCAQD to revise table
3.3-17 to best reflect actual conditions.

Response #8E:
MCAQD looked at a sample of the largest acreage permits where the project type was identified as site
preparation/land development and saw no indication that the initial site preparation/land development
company ownership had been transferred to another entity. MCAQD believes if this does occur it is
relatively small in comparison to the overall acreage being disturbed.
Comment #8F:
In addition to the limitations of the County's methodology highlighted in Pechan's comments, there are a
number of other problems with the Rule Effectiveness Study.
We are greatly concerned that MCAQD's proposal is overly simplistic and insufficiently rigorous for its
purpose.
Dust control operations are complex, with several activities ongoing at any one time. Rule 310 is also
extremely complex, with dozens of subsections and requirements. However, under the County's approach,
limited noncompliance with one requirement, or limited noncompliance at one small area of a dust
generating operation, deems the entire site uncontrolled. For example, under MCAQD's methodology, a
1000 acre site with 10 exits that has 51 feet of trackout from those ten exits, is assumed to be completely
uncontrolled.
The County's methodology is obviously flawed. As the illustration above suggests, it does not reasonably
represent actual conditions. It also conflicts with EPA guidance. In addition, even the underlying
inspection data does not support MCAQD's approach. For example, for one site deemed to be
noncompliant, the inspector acknowledges that trackout is less than 50 feet, and that the site has “overall
good stabilization.” See inspection # 609003.
MCAQD has attempted to justify its approach by expressing the concern that even limited noncompliance
at a construction site can have an impact on monitored readings of particulate matter. This anecdotal
belief, however, in no way justifies creating an emissions inventory that does not represent actual
conditions. After all, an inventory that represents actual conditions is what the Clean Air Act requires.
The only way to develop a plan that will achieve attainment is to start with an emissions inventory that
represents real world conditions. MCAQD's Rule Effectiveness Study does not do that.
MCAQD has also attempted to justify this approach by stating that EPA has remarked in the past that rule
compliance was relatively low. We are unaware of any EPA study conducted of' Rule 310 compliance. If
one has been conducted, it should be made available for public review. To the extent that EPA's belief
was based on anecdotal observations made while driving around the Phoenix metropolitan area several
years ago, we submit that these observations are stale and pale in comparison to the scientifically rigorous
methodology proposed by Pechan. Accordingly, these anecdotes do not justify an abnormally low
compliance rate that does not represent actual conditions.

Response #8F:
Rule effectiveness is a term that describes a method to account for the reality that not all facilities
covered by a rule are in compliance with the rule 100% of the time. A rule effectiveness study is an
examination of a rule and its implementation. Rule effectiveness studies are field evaluation studies
designed to determine the percentage of non-compliance among sources for the selected rule. A
representative number of sources within the study group are chosen at random and inspected. The
effectiveness of a rule is reflected in the non-compliance rates determined by dividing the number of
non-complying facilities by the number inspected.

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An inspection is a snapshot in time and reflects conditions which may be present most of the time. In
the rule effectiveness study, a site with an observed violation during the inspection was deemed
noncompliant (not completely uncontrolled). Similarly, other sites in the rule effectiveness study with
no observed violations were deemed to be 100% compliant, although violations may have occurred
before or after the inspection.
The rule effectiveness study was conducted in accordance with EPA rule effectiveness guidance.
Inspection report # 609003 noted an observed violation for a trackout control device that was not
suitable. This is a violation of Rule 310. This inspection report supports MCAQD's approach; the site
had an observed violation and was deemed to be noncompliant.
MCAQD made no mention in the rule effectiveness study that “limited noncompliance at a
construction site can have an impact on monitored readings” nor were past EPA remarks regarding low
rule compliance mentioned in the study. Neither of these issues was factored into the study results.
The study results were based on compliance status established during inspections and determined by
dividing the number of noncomplying facilities by the number inspected.
Comment #8G:
MCAQD relied on a sample of 63 inspections for its Rule Effectiveness Study. Yet, thousands and
thousands of inspections are conducted every year. MCAQD has acknowledged that it has the ability to
identify the number of inspections that occurred during a given time period, and determine the number of
inspections that resulted in an allegation of noncompliance. This data must be reviewed to determine
whether the Rule Effectiveness Study sample is truly representative.3
MCAQD previously made available similar inspection data from the June 2006 - August 2006 time frame
during an October 10, 2006 meeting.4 This data from 2,811 inspections showed that the simplistic
compliance rate for both administrative and emissions-related requirements was 68%, far higher than the
33% compliance rate determined by MCAQD in the 63 set sample. These more representative numbers
should be considered when determining rule compliance.
Additionally, we believe it is also possible to determine which of those violations were administrative and
which were emissions-related. We understand that the process of identifying administrative vs.
emissions-related allegations of noncompliance is more labor intensive than the process of identifying the
total number of inspections, and the total number of sites with violations. Accordingly, Home Builders
and AGC would be willing to provide their assistance in any manner that would be helpful to MCAQD to
accomplish this goal.

Response #8G:
MCAQD followed EPA guidance to determine a statistically adequate sample size for the Rule 310
rule effectiveness study.5 The number of inspection sites in the sample size was determined by
calculating the standard deviation of the initial ten random inspections. Then using EPA's
recommended confidence interval (90 percent) and sample error (5 percent), MCAQD determined that
sixty-three Rule 310 inspections were needed.

3

Even this data must be reviewed, of course, with the caveat that drive-by compliant inspections may not show up in MCAQD's
database, and therefore the compliance rate shown in the data is less than the true compliance rate.

4

This 60% figure must also be viewed in context. The 32% of sites with documented violations were not completely
uncontrolled.
5
Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State Implementation Plan Base Year
Inventories, Appendix D, U.S. EPA, EPA-452/R-92-010, November 1992.

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Using the compliance data from MCAQD's Environmental Management System (EMS) would not be
the same as inspections done under a rule effectiveness study. All inspections done for the rule
effectiveness study were full scale level 2 inspections where every applicable rule subsection was
inspected for compliance. Inspections entered into EMS include level 1 (onsite or offsite) and level 2
(onsite). The level 1 inspections are commonly done as spot inspections for violation follow-up,
complaint inspections, or the next multiple inspection of a site. The follow-up inspections in particular
tend to have a higher compliance rate because it is possible that only those issues found in violation
previously will be checked during a follow-up inspection.
It is unclear what 33 percent compliance rate the commenter is referring to as the Rule 310 rule
effectiveness study results showed a 49 percent compliance rate (revised to 51% in the April 2007 rule
effectiveness study). The discrepancy between the 68 percent compliance rate cited by the commenter
and the 49 percent compliance rate found in the rule effectiveness study is due to the reasons discussed
above. Specifically, follow-up inspections have a higher compliance rate and including these in the
data set will result in a higher overall compliance rate. The example below illustrates this point:
63 level 1 inspections with 49% non-compliance rate = 31 sites out of compliance
31 sites are re-inspected and found to be in compliance
94 total inspections (63 Level 1 + 31 follow-up inspections) with 31 site out of compliance = 32.98%
non-compliance rate or 67.02% compliance rate.
The higher compliance rate found in follow-up inspections will increase the overall compliance rate.
Comment #8H:
The inspection reports on which the Rule Effectiveness Study is based contain numerous errors and
unsupported allegations. For example, none of the allegations concerning Rule 310, Sections 301 and
302, provides supporting documentation that demonstrate test methods were used to determine
compliance. As a result, these unsupported statements cannot be used to allege noncompliance.
Similarly, some of the allegations are not violations of Rule 310 at all. For example, one inspector noted
that the stockpile on a particular site was wet, but wrote an NTC because the material “needs visible
crust.” See inspection # 609030. This allegation is unfounded. Under Rule 310, Section 308.6, a
permittee has the option to keep an inactive stockpile moist or maintain a visible crust. For active
stockpiles, maintaining a visible crust is not even a listed alternative, because it is not feasible.
Some of the inspection reports allege violations for activities that are not regulated under Rule 310. One
inspection report documents an NTC for opacity greater than 20% during sandblasting. See inspection #
609023. Sandblasting is not subject to Rule 310. Another alleges a violation resulting from tile cutting.
See inspection # 609024. Tile cutting is not regulated under Rule 310; it is regulated by OSHA.
Finally, Horne Builders and AGC concur with Maricopa County's decision to exclude administrative
allegations in its emissions compliance methodology. However, the fact that these allegations are
mentioned at all in the Rule Effectiveness Study implies rampant noncompliance.
Again the facts do not bear this out. At least half of the administrative allegations concern dust control
complaint phone numbers. During calendar 2006, MCAQD created a new phone number for dust
complaints. The previous number continued to work, and continues to work to this day. The applicable
rule requirement does not state that there can be only one current/accurate phone number. Therefore,
these are not violations under any reasonable interpretation of the rule.

Response #8H:
Nineteen inspection reports showed Rule 310 Section 301 or 302 violations; fourteen of these
inspection reports showed other emission violations. If a NOV was issued for a Rule 310 Section 301

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opacity violation, a visible emissions evaluation was conducted and documented. The evaluation is
documented on separate forms which are forwarded in the referral report to MCAQD's Enforcement
Division; these were not included with the inspection reports provided to the commenter. Inspectors
evaluate the surface under inspection for compliance with Rule 310 Section 302. The inspectors are
able to determine through visual examination and depth analysis the severity of the unstabilized soil.
When larger elements are not present in the first 3/8 inch, the surface will not pass the threshold
friction velocity test. Furthermore, Rule 310 Section 302.3 requires that the owner/operator conduct
the stabilization tests.
In regards to inspection report # 609030, MCAQD reviewed this inspection report and determined that
a NTC was issued for an administrative violation for not posting the dust control plan. Because no
emission violation was observed, this inspection was excluded from the violations used in calculating
rule effectiveness. In reviewing the inspection report, MCAQD determined that an error was made in
Table 3.4.1 in the Rule Effectiveness Study pertaining to inspection report #609030 (Permit Id
E054400). MCAQD incorrectly noted in Table 3.4.1 the violation as Rule 310 Section as 308; the
violation was actually a Section 401 violation. This error has been corrected in the April 2007 Rule
Effectiveness Study.
In regards to inspection report # 609023, MCAQD reviewed this report and determined that the
violation for exceeding opacity while sandblasting should have been a violation of Rule 312 not Rule
310. MCAQD has corrected the rule effectiveness study results accordingly. The correction results in
an increase to rule effectiveness (or compliance rate) from 49% to 51%. This change will be been
reflected in the April 2007 Rule Effectiveness Study report and in the calculated emissions for
construction in the May 2007 emissions inventory report.
In regards to inspection report # 609024, the NTC was for block cutting not tile cutting and this was
one of several NTCs and an NOV observed at this site. Block cutting is regulated under Rule 310 as a
dust generating operation. The Rule 310 definition of dust generating operations is:
Any activity capable of generating fugitive dust, including but not limited to, land clearing, earthmoving,
weed abatement by discing or blading, excavating, construction, demolition, bulk material handling,
storage and/or transporting operations, vehicle use and movement, the operation of any outdoor
equipment, or unpaved parking lots. For the purpose of this rule, landscape maintenance and playing on
or maintaining a field used for non-motorized sports shall not be considered a dust generating operation.
However, landscape maintenance shall not include grading, trenching, or any other mechanized surface
disturbing activities performed to establish initial landscapes or to redesign existing landscapes.

Finally, administrative violations with no observed emissions violation were excluded from the rule
effectiveness calculation; thus, a discussion of administrative violations that were excluded, such as the
dust control complaint phone number is outside of the scope of this report.
Comment #8I:
Under Section 172(c) (3) of the Clean Air Act, the emissions inventory must be a “comprehensive,
accurate, current inventory of actual emissions from all sources of the relevant pollutant or pollutants in
such area...” Given the serious scientific flaws in MCAQD's Rule Effectiveness Study, the Draft
Emissions Inventory cannot be a comprehensive, accurate, or current inventory of actual emissions from
all sources.

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Response #8I:
The rule effectiveness study was conducted in accordance with EPA guidance. MCAQD followed
EPA guidance to determine a statistically adequate sample size for the Rule 310 rule effectiveness
study and used a quality assurance supervisor and an observer for the study to assure consistency
during the inspections. MCAQD reviewed all comments made pertaining to the rule effectiveness
study and made adjustments where appropriate.
Comment #8J:
Unpaved road emissions are a significant portion of the inventory. Unpaved road emissions, based on
stale data and unsupported assumptions, are greatly underestimated. By MCAQD's own estimate, they
constitute 9% of the PM10 inventory. Revising the Draft Emissions Inventory to accurately reflect
construction emissions increases the unpaved road contribution to nearly 14%. Accordingly, it is critical
that unpaved road emission estimates be based on comprehensive, accurate, and current information.
Pechan's analysis identified a number of areas where the data sources for unpaved road estimates do not
meet these criteria.
For example, MCAQD does not explain the average speed estimate of 25 miles per hour. On rural
unpaved roads, speeds are certainly higher. Pechan's analysis showed that changing the speed to 40 mph
would increase unpaved road emissions to 10,697 tons per year. Because vehicle speeds greatly influence
emission estimates, it is critical that MCAQD base its estimate for vehicle speeds on the best information
available.
Second, MCAQD uses average daily traffic volumes that were carried forward from a 1994 study (we
understand this is the basis for the assumption on page 108 that the average annual traffic level is 4
vehicles per day). Data from 1994 are not current under any definition of the term, and cannot be used in
a 2005 emissions inventory.
In addition, the Draft Emissions Inventory assumes that the mileage of unpaved roads actually decreased
slightly over the last several years. See page 108. As noted by Pechan, the Draft Emissions Inventory
does not account for new unpaved roads added over the past several years.
Finally, Pechan noted the rigorous methodology undertaken in Clark County to determine unpaved road
emissions. Similar methodologies must be used here to create a comprehensive, accurate, and current
estimate of unpaved road emissions. Revising the ADT numbers to be consistent with Clark County's
would increase the unpaved road fugitive dust PM10 emissions reported in Table 5.4-10 from 20,954
kg/day to 36,762kg/day.

Response #8J:
As indicated in Response #8C, MAG used the best available data on unpaved roads to prepare the
PM10 emissions estimates in the Draft 2005 Periodic Emissions Inventory for PM10. The unpaved road
mileage by traffic volume category (i.e., low – average of 4 average daily trips (ADT) and high –
average of 120 ADT) was derived from a database developed for the MAG Serious Area PM10 Plan.
The Serious Area PM10 Plan, that was approved by EPA on July 25, 2002, reduced the miles of
unpaved roads to reflect legally-binding commitments made by local jurisdictions to pave and stabilize
unpaved roads by 2006. To ensure that these unpaved road assumptions continue to be representative
of the PM10 nonattainment area, MAG will work diligently to update the traffic counts on a sample of
unpaved roads. MAG will also apply geographic information systems (GIS) and recent aerial
photography to estimate the current unpaved road mileage. Since it will take several months to collect
this data, it will not be available to recalculate unpaved road emissions for the final 2005 periodic
emissions inventory; however, it will be available for use in estimating the 2007 unpaved road
emissions for the Five Percent Plan for PM10.

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With respect to the speed used in estimating unpaved road emissions, 25 mph was assumed, because it
is the speed limit that the Arizona Department of Transportation Motor Vehicle Division has officially
established for roads that are not posted with a speed limit sign. While collecting traffic counts on a
sample of unpaved roads, MAG will try to obtain typical vehicle operating speeds on the same roads.
Although these speeds will not be scientifically-derived (i.e., through a formal travel time survey or
speed study), the observations should provide a basis to determine whether the current assumption of
25 mph is reasonable.
Comment #8K:
Every stakeholder involved in this process understands that it is critical that the emissions inventory
represents actual and current conditions in the nonattainment area. We urge MCAQD to look at the
available data objectively and without preconceptions. Only one reasonable conclusion can be drawn if
that is done. Rule 310 effectiveness is much higher and construction emissions are much lower than
reported in the Draft Emissions Inventory. Pechan has provided its best estimate, which was based on the
available information, and took many of MCAQD's assumptions at face value. We ask that MCAQD use
Pechan's methodology and results, incorporate modifications as necessary to reflect our additional
comments, and revise the emissions inventory to be a “comprehensive, accurate, current inventory of
actual emissions from all sources....”

Response #8K:
MCAQD carefully reviewed all comments received and modified the emissions inventory report where
warranted. Each of Pechan's comments was addressed separately and responses are provided below in
responses 9A-9L.
Comment #9A:
The basic approach used by MCAQD to estimate 2005 construction activity PM10 emissions is to
develop estimates of affected acreage by type of activity, and then to apply standard emission factors and
average project durations by project type along with estimates of the effectiveness of existing fugitive
dust control rules to estimate controlled 2005 emissions. This approach is a standard one for this source
category, with some similarities to the methods used by EPA for its National Emissions Inventory.
MCAQD uses estimates of acres permitted for construction during 2005, which is an improvement over
some approaches which are based on the dollars spent on construction projects. Overall, Pechan has three
concerns [Note: included as comments 9A–C] about the construction activity PM10 emission estimates in
the 2005 MCAQD Inventory:
1. There is a computational error in the site preparation/land development emission estimate that
results in the emissions for the Maricopa County portion of the PM10 nonattainment area for this
project type being overestimated by 2,110 tons per year. The total acre-months in Table 3.3-20
for site prep/land development should be 4,905.6, not 39,244.6. The controlled PM10 estimate
should be 301.6. Table 1 [Note: not reproduced in this responsiveness summary] provides a
revised version of Table 3.3-20 with corrected values for site prep/land development.

Response #9A:
The one-month average duration for “site prep/land development” shown in Table 3.3-18 is a
typographical error. The average duration used to estimate emissions from “site prep/land
development” projects was eight (8) months and not the one (1) month shown in Table 3.3-18. A
correction has been made in Table 3.3-18 to show the correct average duration for “site prep/land
development” of eight (8) months. The typographical error did not affect the emission calculations as
the emissions were estimated using the correct average duration.
Comment #9B:
2. The 2005 MCAQD Inventory applies an emission factor of 0.42 tons/acre-month to estimate road
construction emissions. This value was selected based on information from the WRAP Fugitive Dust
Handbook, which advises that a 0.42 tons/acre-month emission factor be used for worst case conditions.
It is not clear from the information presented by MCAQD in its report why a worst case conditions

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emission factor was deemed appropriate for road construction in this geographic area. For its 2002 PM10
emission inventory, a 0.11 tons/acre-month emission factor was applied to estimate uncontrolled road
construction emissions. This emission factor change alone produces a 281 percent higher PM10 emission
estimate for road construction than was estimated for the 2002 calendar year. This emission factor
selection seems unjustified without evidence being presented by MCAQD for its selection.
Pechan reviewed recent PM10 emission calculations performed by the South Coast Air Quality
Management District, where it is estimated that 25 percent of road construction is at the 0.42 tons/acremonth emission rate and 75 percent is at the 0.11 tons/acre-month rate, which is a net emission factor of
0.1875 tons/acre-month. It is suggested that MCAQD consider using the SCAQMD assumptions in its
road construction emission estimates to estimate uncontrolled PM10 emissions. Making this revision
would change the road construction controlled PM10 emission estimate in Table 3.3-20 to 5,281 from
11,831 tons per year, a reduction of 6,550 tons. This would change the Table 1 corrected PM10 controlled
emission estimate to 28,631 tons per year (from 35,181 tons per year).

Response #9B:
MCAQD requested a citation or documentation from the commenter on the PM10 emission calculations
performed by the South Coast Air Quality Management District (SCAQMD). The commenter was not
able to provide specific documentation on the methodology but rather sent information from the
California Air Resources Board which only describes the method in general terms and does not include
the specific percentages used to apply the 0.42 tons versus the 0.11 tons emissions factor for road
construction. It is also important to note that the SCAQMD work cited assumed the construction
emission factors included the effects of typical control measures such as routine watering.6 Whereas,
MCAQD assumed the emission factor values were uncontrolled and applied a 90% control efficiency.
If MCAQD had adopted the entire SCAQMD methodology as the commenter requested, overall
emissions from this source category would have increased significantly.
MCAQD rational for selecting the 0.42 tons/acre-month emission factor for road construction was
based on the following excerpts in the WRAP Fugitive Dust Handbook:
1. The WRAP Fugitive Dust Handbook (Section 3.2.4 Road Construction) states on page 3-6:
Almost all roadway construction involves extensive earthmoving and heavy construction vehicle travel, causing emissions to be higher than found for other construction
projects. The PM10 emissions produced by road construction are calculated using the
BACM recommended emission factor for heavy construction7 and the miles of new
roadway constructed.
2. On page 3-7, the WRAP Fugitive Dust Handbook further states:
The BACM worst case scenario emission factor of 0.42 tons/acre-month is used to
account for the large amount of dirt moved during the construction of roadways. Since
most road construction consists of grading and leveling the land, the higher emission
factor more accurately reflects the high level of cut and fill activity that occurs at road
construction sites.
In its 2002 PM10 emission inventory, MCAQD used an emission factor of 0.11 tons/acre-month to
estimate uncontrolled road construction. MCAQD strives to use improved estimation methods where
available and practical in order to update and improve emission estimates. Because the WRAP
6

California Air Resources Board, Emissions Estimation Methodology, Section 7.7 (Building Construction Dust) and
Section 7.8 (Road Construction Dust), Sept. 2002 and August 1997, respectively.
7
Midwest Research Institute, 1999. Estimating Particulate Matter Emissions From Construction Operations,
Kansas City, Missouri, September.

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Fugitive Dust Handbook was published in September 2006, after the 2002 PM10 emissions inventory
but prior to finalizing the 2005 PM10 emissions inventory, MCAQD chose to use the road construction
emission factor (0.42 tons/acre-month) recommended by WRAP in the Fugitive Dust Handbook to
estimate road construction emissions.
MCAQD researched PM10 emission calculations performed by the SCAQMD and was unable to locate
emissions estimation methodology specifically from SCAQMD for road construction emissions. The
only reference to this methodology is in the WRAP Fugitive Dust handbook and in the California Air
Resources Board (CARB) building and road construction dust estimation methodology. Both indicate
that the SCAQMD applied 0.42 tons/acre-month emission rate and 0.11 tons/acre-month rate to both
road and building construction. Neither WRAP nor CARB showed the specific percentages used to
apply the 0.42 tons versus the 0.11 tons emissions factor for road construction. Further, the SCAQMD
and CARB work both assumed the construction emission factors included the effects of typical control
measures such as routine watering.8 Adopting the entire SCAQMD methodology would have
significantly increased the overall emissions from this source category.
EPA used the 0.42 tons/acre-month emission factor to estimate emissions from road
construction for the 1999 and 2002 National Emissions Inventory (NEI).
EPA's Procedures Document for National Emissions Inventory, Criteria Air Pollutants 19851999 states:
An emission factor of 0.42 tons/acre/month is used to account for the large amount of
dirt moved during the construction of roadways. Since most road construction consists
of grading and leveling the land, the higher emission factors more accurately reflects the
high level of cut and fill activity that occurs at road construction sites.9
In 2004, E.H. Pechan & Associates used the 0.42 tons/acre-month PM10 emission factor (adjusted to
account for conditions in Yuma including correction parameters for silt moisture level and silt content)
to calculated road construction emissions in the 1999 and 2016 Emission Estimates for the Yuma,
Arizona PM10 Nonattainment Area Maintenance Plan, prepared for Arizona Department of
Environmental Quality10
Because MCAQD was unable to locate detailed documentation of the SCAQMD approach and
because the 1999 and 2002 NEIs, the WRAP Fugitive Dust Handbook, and E.H. Pechan & Associates
all used the 0.42 tons/acre-month for road construction, MCAQD believes that the 0.42 tons/acremonth is an appropriate emission factor. However, since Clark County Department of Air Quality and
Environmental Management used an average emission factor of 0.265 tons/acre/month ([0.11 + 0.42] /
2) for construction projects that sometimes include cut and fill areas, large-scale earthmoving
activities, and/or heavy traffic volumes and other times do not, MCAQD will use the Clark Co.
approach for road construction activities and revise road construction emissions accordingly. 11
8

California Air Resources Board, Emissions Estimation Methodology, Section 7.7 (Building Construction Dust) and
Section 7.8 (Road Construction Dust), Sept. 2002 and August 1997, respectively.
9
U.S. EPA, Procedures Document for National Emission Inventory, Criteria Air Pollutants 1985-1999, EPA-454/R-01-006,
March 2001, p. 4-291.
10
Appendix: Technical Support Document: Yuma Natural Events Action Plan, January 2004. 1999 and 2016 Emission
Estimates for the Yuma, Arizona, PM10 Nonattainment Area Maintenance Plan, Final Report, Prepared for: Arizona
Department of Environmental Quality, Prepared by E.H. Pechan & Associates, Inc., June 2003, Contract No. 98-0159,
Pechan Rpt. No. 03.06.004/9412.001 (Rev.), p. 22.
11
PM10 SIP Plan for Clark Co., Appendix B: Methodology, Emission Factors, and Emission Estimates, June 2001, p. B-59.

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Comment #9C:
3. One of the key variables in the controlled PM10 emission estimate for road construction is the
estimated rule effectiveness. Rule effectiveness in this case is a measure of the Rule 310-Fugitive Dust
compliance rate in the area. The rule effectiveness guidance available from EPA during the 1990s
suggested that a default rule effectiveness assumption of 80 percent be used in most cases to estimate
compliance rates in cases where data were not available to estimate this value quantitatively. More recent
guidance from EPA removes the previous recommendation for use of an across the board 80 percent
default value. EPA's revised rule effectiveness guidance provides inventory preparers with lists of factors
that are most likely to affect RE and ranks these factors in a priority order. For nonpoint sources like
construction activity, EPA provides three ranges: 86 to 100 percent, 70 to 85 percent and below 70
percent with associated importance factors to use in determining the appropriate RE to apply.
As part of its 2005 inventory development, MCAQD performed its own RE study to quantify compliance
with the fugitive dust rules in the Maricopa County air quality regulatory program. One portion of this
RE study examined earthmoving sources. For the earthmoving site RE study, site inspections were
performed for 63 sites. MCAQD used the information from these special site visits to assign each site as
either being fully compliant (100% RE) or non-compliant (0% RE or uncontrolled). The MCAQD RE
study for earthmoving sites found that 31 of 63 inspected sites with no emission violation, and 32 of 63
with observed violations. This information was used to compute an overall RE value of 49 percent, which
was used in the PM10 emission calculations for this source category.
Pechan staff reviewed the inspection results for all of sites that either received a Notice to Correct (NTC)
or a Notice of Violation (NOV) and matched that information with the applicable project types, which
were described in the inspection reports as not being fully compliant with Rule 310. We then made
judgments about which emission sources within the site were uncontrolled and adjusted only those
sources. This resulted in a scoring system that assigned values in between zero and 1 when warranted by
the information provided by the site inspectors. Table 2 shows how the site inspection reports were
evaluated. The columns in this table are the site inspection report numbers. For each site inspection, the
letters V and C are used in Table 2 to indicate the source type (project type) associated with any violation
(V) or notice to correct (C). There were three sites with notices of violation that indicated widespread
violations to the extent that the site was deemed fully uncontrolled (site numbers 609071, 609005, and
609007). For all other sites, the PM10 emission rates were estimated to be uncontrolled at the sites where
either a V or a C is indicated in that row. As an example, if 10 sites had a V or C for site prep/land
development, then the RE was estimated to be 10/63 times zero plus 53/63 times 100 percent, or 84
percent. The denominator of 63 is the total number of earthmoving sites inspected during the MCAQD
RE study. In this way, a rule effectiveness value is computed for each project type. Then, that project
type-specific RE value is used to estimate 2005 emissions consistent with the methods employed by
MCAQD in section 3.3.9 Construction of the 2005 Periodic PM10 Emission Inventory.
Pechan's revised .PM10 emission estimates for the construction category using the above methods are
provided in Table 3 (not included in this responsiveness summary). Pechan's revised PM10 emission
estimate for construction activity in Table 3 is 10,059 tons per year, significantly lower than the MCAQD
reported value. (This table uses the higher 0.42 tons/acre-month emission factor for road construction.)
If the lower SCAQMD composite emission factor of 0.1875 were used, this would change the resulting
construction activity PM10 estimate to 7,882 tons per year.

Response #9C:
The project type relates to the type of construction (residential, commercial, road construction, etc.)
and should not be confused with the dust generating activities (bulk material hauling, trackout,
unpaved haul roads, open storage piles, disturbed surfaces etc.) that occur on a construction site or the
types of violations (trackout > 50 feet, opacity > 20%, ineffective trackout control device, etc.)
observed at a given construction site or identified in an inspection report. MCAQD determines the
project type from “Description of Project” information submitted on the Application for Dust Control
Permit.

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Pechan interpreted violations identified on inspection reports as emission sources and then incorrectly
allocated these violations to project types. For example, inspection report #609073 identified the
following two NOVs:
• Trackout on Central from site west exit point extends southerly for > 250 feet.
• Ineffective trackout control device at time of inspection earthmoving activities disturbed more
(than) 2 acres.
Pechan incorrectly interpreted these NOVs as “site prep/land development” and “temporary storage
yard” (see Table 2 on page 6 of Pechan comment letter). This was actually a commercial construction
project and not “site prep/land development” or “temporary storage yard”.
Further, Pechan also created two project types that are not identified separately in the emissions
inventory: trackout and opacity. These are actually types of violations observed during inspections.
Pechan identified in Table 2, 17 Notices of Violation/Notices to Correct for “trackout” and 6 Notices
of Violation/Notices to Correct for “opacity”, yet Pechan failed to include these in their revised
NOV/NTC count or revised emission estimates in Table 3.
Comment #9D:
Because the information in the rule effectiveness study inspection reports is organized by Rule 310
section rather than by emissions generating subcategory, an alternate analysis was performed where the
NOVs and NTCs were organized by the Rule 310 sections. This analysis is shown in Table 4 (not
included in this responsiveness summary). This table was constructed by taking the information in the
rule effectiveness study inspection reports and noting wherever the report said that a specific rule NOV or
NTC occurred. The level-of-detail provided in Table 4 for the Rule 310 requirements is designed to
match the level-of-detail provided in the inspection reports.
Table 5 (not included in this responsiveness summary) summarizes the results of this alternate analysis.
Table 5 summarizes the total NOV plus NTCs by rule number as well as the occurrences of NOVs and
NTCs separately. Then, in the right-most columns of this table, the number of occurrences is used to
compute a non-compliance rate for each rule number that had an NOV or an NTC. For example, Table 5
shows that about 8 percent of inspected sites had either an NOV or an NTC for the opacity limits for dust
generating operations (Section 301 of Rule 310). Therefore, for this specific section of Rule 310, the rule
effectiveness survey showed a 92 percent compliance rate, and an 8 percent non-compliance rate.
For the eight rule sections in Table 5 where there were one or more NOVs/NTCs, the noncompliance
rates were averaged to estimate an overall non-compliance rate of 13 percent. The non-compliance rates
by rule section range from a low of 1.5 percent for unpaved haul/access piles to a high of 27 percent for
stabilization. This average rule effectiveness value of 87 percent (13 percent non-compliance) computed
using this alternate methodology is very close to the 84 percent estimate provided above, and serves as
confirmation of the revised PM10 emission estimates provided in the right-most column in Table 3.

Response #9D:
Pechan reviewed the 63 inspection reports from the Rule Effectiveness Study and totaled the multiple
violations observed at each construction site according to the specific sections of Rule 310. Pechan
listed ten different sections of Rule 310 in Table 5 (see page 9 of Pechan's comment letter). Pechan
then calculated a noncompliance rate for each section of the rule and suggests that averaging the
noncompliance rate for each section estimates an overall noncompliance rate. However, this approach
represents the average noncompliance rate for each section of the rule rather than an overall
noncompliance rate. In other words, the rate that any one section of the rule had been violated.

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Based on Pechan's count of the different rule sections in Table 4, 32 of 63 inspections (51%) resulted
in a notice of violation or notice to correct. The 32 inspections which resulted in notices of violations
or notices to correct had 66 separate Rule 310 section violations.
Rule effectiveness is reflected in the non-compliance rates determined by dividing the number of noncomplying facilities by the number inspected.
MCAQD estimated rule effectiveness by conducting a statistically significant number of randomly
selected inspections (63) and determining the number of inspected sites with no observed violation (32
inspections (of 63 total) had no observed violation = 51%). Conversely, Pechan's approach estimates
the number of times each section of the rule was violated. Their approach measures the noncompliance rate of individual sections of Rule 310 rather than the non-compliance rate of Rule 310.
Their approach simple does not represent an overall rate of compliance; it represents an average rate of
non-compliance with individual section of Rule 310.
Further, Pechan miscounted the number of violations identified on the inspection reports. The total of
all NOV and NTC is short by 13 violations; thus, 79 violations were identified in the 32 inspections
with observed violations. The violations miscounted by Pechan are identified in the table below:
Inspection
Number
609071
609005
609007
607450
607448
605737
Total

Number of
Violations Identified
in Inspection Report
4
6
5
6
5
2
28

Number of
Violations Listed in
Pechan's Table 4
2
1
4
4
3
1
15

Number of
Violations Not
Counted by Pechan
2
5
1
2
2
1
13

Comment #9E:
Any calculation of 5 percent per year emission reductions for the PM10 nonattainment area should use an
average, or typical year emission estimate for windblown dust emissions, so more information is needed
in the ENVIRON analysis, or the body of the report, about the representativeness of the PM10 emission
estimate computed using 2005 meteorological data. One of the weaknesses of the windblown dust
inventory model application is the lack of accounting for rainfall (page 2-8 of Appendix 3-3). In addition,
it is suggested that daily PM10 emissions be presented in the appendix for the specific days when wind
speeds exceeded 20 miles per hour and there were positive emissions for this source type. The 2005
windblown dust emissions estimate for the PM10 nonattainment area is 1,086 tons per year.

Response #9E:
Since the January 2007 draft report was published, the model has been revised to incorporate the
effects of rainfall. Five years (2001–2005) of hourly precipitation data from approximately 200
monitoring stations (throughout Maricopa and Pinal Counties) was provided by Maricopa County
Flood Control district, and has been incorporated into the model input data sets.
The comment re: a 20-mph threshold is unclear. As discussed in the January 2007 draft report, the
windblown dust inventory has been developed using a grid-based modeling system. Dust emissions
from wind erosion are determined from the gridded wind speeds and surface characteristics.
Windblown emission are only possible when wind speeds exceed a threshold wind speed determined
by the aerodynamic surface roughness lengths of the underlying surface. These vary by landcover
type, and so the threshold also vary. However, the draft report does summarize a previous version of
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the modeling system developed for WRAP during Phase I of the WRAP project. That version of the
model did use a constant threshold corresponding to a 20-mph wind speed (at a height of 10 m).
Comment #9F:
Another concern with the approach used by ENVIRON is its suitability for estimating windblown dust
PM10 emissions for an analysis of this geographic scale. The RMC windblown dust model “is designed to
estimate fugitive windblown dust emissions for regional air quality modeling.” Is the model valid for
smaller scale applications like this one where the relative accuracy of the estimate is more important? Has
the model been validated for PM10? It seems likely that this model has been designed primarily to
estimate fine particulate windblown dust emissions over large geographic regions and may not be a good
predictor of PM10 emissions for a State Implementation Plan/regulatory analysis.

Response #9F:
The ENVIRON windblown dust model was indeed developed for application to regional air quality
modeling studies. However, this limitation is actually due to the various databases used as inputs. For
the modeling work conducted for the Western Regional Air Partnership (WRAP), the inventory was
required to cover the entire conterminous United States. Because of this, the underlying GIS databases
(i.e. soil characteristics and land use/land cover [LULC]) were somewhat lacking in detail and
resolution, primarily due to limited time and resources available for their development. The emission
estimation methodology is valid regardless of the scale of the final inventory as has been validated
through field studies using wind tunnels. It should be noted that the model has been successfully
applied to other nonattainment-area scale studies.12 In fact, the current inventory developed for
Maricopa County is considered by the model developers to be better and more applicable than that of
the WRAP due to the use of local high resolution and detailed LULC data. Additionally, the
methodology is designed to estimate PM10 directly; PM2.5 is apportioned from the estimated PM10 dust
emissions.
Comment #9G:
The ENVIRON report also lacks clarity in describing how the emission calculations were performed for
each land use type, which makes it difficult to determine whether the emission estimates are correct. For
example, page 2-9 of the ENVIRON report discusses surface disturbance assumptions used in the
windblown dust model that conflict with what is said later in the report on page 4-3. Some of the key
assumptions mentioned on page 4-3, like those about the fraction of barren lands that are disturbed (30
percent) and the fraction of shrublands that are disturbed (8 percent) are provided with no back-up
information. These assumptions and the assumptions about threshold friction velocities have a
substantial effect on resulting emission estimates by land use type and should be justified and referenced.

Response #9G:
A concise summary of the computational steps required has been included in the revised version of the
report summarizing the modeling results, along with further details concerning the original and/or
derivation of threshold friction velocities for individual land use types. To summarize:
1) The model calculates the threshold surface friction velocity as a function of the surface
roughness lengths for each landuse type in each grid cell using the relationship displayed in
Figure 2-1, and the assumed roughness lengths by landuse type (listed in Table 3-2).
2) The surface friction velocity is calculated from the relationship displayed in page 2-2, the
assumed roughness lengths by landuse type (Table 3-2) and the gridded 10-meter wind speeds.
When the surface friction velocity exceeds the estimated threshold from step 1) the model
12

See (e.g.) “Development of a Wind Blown Fugitive Dust Model and Inventory For Imperial County, California”,
ENVIRON International Corp., May 2004.

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calculates PM10 dust emissions using the relationships shown in Figure 2-2 as a function of the
wind speed and soil texture.
3) Any adjustments for agricultural lands are then computed.
4) The final step involves summing all the PM10 dust emissions in each grid cell for each hour.
(Note that in any given grid cell, the percentages of the various landuse and soils are available
for use in estimating the dust emissions).
Comment #9H:
In the end analysis, ENVIRON estimates PM10 emissions for just four land use types: (1) agricultural
lands, (2) grassland, (3) shrubland, and (4) barren lands. Urban lands are estimated to have no windblown
dust emissions. When the relationship between land area, land use type and PM10 emissions is compared
(Table 3.3 and Table 5-3), the relative PM10 emission strengths (in tons per square kilometer) are: barren
land (1.14 tons per square km), shrubland (0.25 tons per square km), and agricultural land (0.0078 tons
per square km).

Response #9H:
The windblown dust emission estimation methodology relies on the relationship between threshold
surface friction velocity and aerodynamic surface roughness lengths. Further, the surface roughness
lengths are a function of the landuse. Clearly, these roughness lengths exhibit a range of values even
for the same nominal landuse type. Unfortunately, a database of specific surface roughness lengths for
the study are was not available, so assumed values were used for each of the general landuse types in
the GIS data used. The assumed roughness lengths were chosen from a range of values reported in the
literature. Based on these values, only those landuse types that are considered in the model would
result in threshold surface friction velocities that would typically be observed in nature. Note however,
that although urban lands are not considered, the LULC data used for the current project included such
detail within the Phoenix metro area as residential and commercial buildings under construction.
Therefore, although urban land, per se, is not considered, dust emission are generated with in the
metro, or urban, area of Phoenix.
Comment #9I:
The 2002 windblown dust PM10 emission estimate for the nonattainment area was 10,505 tons per year.
However, the 2002 PM10 emission estimate used a threshold wind speed of 15 miles per hour and the
2005 analysis assumed a threshold wind speed of 20 miles per hour. The 2005 emission inventory report
should explain why a higher threshold wind speed was used in 2005 than previously. Is this based on
research within the Phoenix area on the wind speed versus emissions relationship?

Response #9I:
The 2002 windblown dust emission estimates cited by Pechan (10,505 tons per year) were developed
prior to the development of the model used in the current application. The previous emission estimates
were based on a very simplistic modeling approach which indeed used a constant threshold surface
friction velocity. Contrary to Pechan's implication, the current model does not use a fixed threshold
(see response above). In addition, the previous estimate of 10,505 tpy of windblown PM10 dust
included numerous assumptions and flawed wind tunnel study data and should be disregarded.

Maricopa Co. 2005 PM10 Emissions Inventory

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Appendix 1: Responsiveness Summary

Comment #9J:
Paved road emissions were estimated using EPA's AP-42 equations. Area-specific inputs to this equation
are the paved road silt loadings and average weight of the vehicle fleet traveling on the roads. The values
used for silt loadings varied by freeways, high-traffic roads, and local and low traffic roads. The values
for these silt loading values are documented in the MCAQD 1999 Serious Area Particulate Plan and
appear to be reasonable values, and are also relatively close to the AP-42 default. The average vehicle
weight assumption of 3 tons per vehicle is a default value that essentially eliminates vehicle weight from
factoring into the emission factor calculation. This is generally acceptable practice. However, a more
locally-specific value could be derived based on the VMT mix used in calculating the onroad exhaust
emissions, by assigning an average vehicle weight to each vehicle type and weighting these values
according to the VMT mix. The one significant area of concern in the paved road emissions calculations,
though, is the improper calculation of PM2.5 emissions from the PM10 emissions. In the MCAQD 2005
inventory, the PM2.5 paved road emissions are calculated by multiplying the PM10 emissions by 0.15.
Instead, the PM2.5 emissions should be calculated by using the same AP-42 equation used to calculate the
PM10 emissions, but using the PM2.5-based particle size multiplier and the PM2.5-based correction factor
that accounts for exhaust, brake wear, and tire wear. Using the appropriate equation and factors results in
PM2.5 emissions for the PM10 modeling area of approximately 1,000 kg/day, yields a reduction of about
5,000 kg/day from the 6,360 kg/day value reported in Table 5.4-6.
The AP-42 equation for paved roads also includes an adjustment to account for the effects of precipitation
on paved road emissions. MCAQD does not include this adjustment. Based on 18 days in 2002 with
greater than 0.0 1 inches of precipitation, the PM emissions from paved roads would be reduced by
approximately 1.4 percent. This would change the Table 5.5-1 PM10 annual emissions from paved road
fugitive dust for the PM10 nonattainment area from 13,783 tons per year to 13,590 tons per year. Unless
the Phoenix area experienced significantly more precipitation than this in 2005, it is not expected that
applying the precipitation correction would significantly change the calculated paved road emissions.

Response #9J:
MAG has recalculated PM2.5 emissions using the same equation (i.e., AP-42, Section 12.2.1, Equation
(2)) used to estimate PM10 paved road dust emission factors, but substituting the new PM2.5 particle
size multiplier shown in AP-42, Table 13.2-1.1. This reduces PM2.5 emissions to 581 kilograms per
day for the PM10 modeling area, compared with the 6,360 kg/day reported in Table 5.4-6 of the draft
inventory. All PM2.5 paved road dust emissions in the 2005 inventory will be revised to be consistent
with this reduced estimate for the PM10 modeling area. It is important to note that PM2.5 emissions are
included in the inventory to meet EPA periodic reporting requirements. This change has no impact on
the PM10 emissions for paved roads that will be used in the Five Percent Plan for PM10.
As previously stated, MAG used AP-42, Section 12.2.1, Equation (2), to estimate PM10 emission
factors for paved road dust. In that equation, MAG applied 36 days as the precipitation correction
term, P, for the 365 days in 2005. P, which represents the number of days with at least 0.01 inches of
precipitation, was derived from an analysis of 2005 measurements at meteorological stations located
throughout Maricopa County. A precipitation correction term based on this actual 2005 data is
considered to be more accurate in estimating 2005 paved road dust emissions than the 2002 P value of
18 days, proposed by the commenter.
Comment #9K:
Unpaved road emissions were also calculated using the AP-42 emission factor equation. This equation for
unpaved road emissions includes terms for surface material silt content, average vehicle speed, and
surface material moisture content. The values used by MCAQD are all reasonable, however, no
explanation for the use of these values is provided. The average speed value modeled of 25 miles per hour
should be based on actual data, as this can have a significant impact on the emissions. For example,
changing the speed to 40 mph would cause the unpaved road PM10 emissions to increase by about 26
percent. This would change the Table 5.5-1 PM10 annual emissions from unpaved road fugitive dust for
the PM10 nonattainment area from 8,490 tons per year to 10,697 tons per year. In contrast, modeling these

Maricopa Co. 2005 PM10 Emissions Inventory

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Appendix 1: Responsiveness Summary

emissions at a speed of 15 mph would result in a decrease in PM10 annual emissions to 6,537 tons per
year. Another general concern is that the emission totals for the PM10 modeling area reported in Table
5.4-10 cannot be duplicated using the AP-42 equation and the stated inputs. Applying the information
provided by MCAQD to the AP-42 unpaved road equation results in PM10 emissions that are about 11
percent greater than those reported in Table 5.4-10, or 23,226 kg/day.
Activity for unpaved roads is calculated by multiplying an average daily traffic (ADT) volume by
unpaved road mileage. MCAQD uses an ADT of 4 vehicles per day on low traffic roads and 120 vehicles
per day on high traffic roads. This is an assumption that appears to be carried forward from the 1994 PM
inventory for Maricopa County. This value is an assumption that does not appear to have been based on
any actual data. The unpaved road emissions are directly proportional to the ADT values. Thus, if the low
traffic ADT is actually 40 rather than 4, then the emissions from the low traffic roads would be increased
by a factor of 10. This would result in a change to the Table 5.4- 10 total unpaved road PM10 fugitive dust
emissions in the modeling area from 20,954 kg/day to 48,053 kg/day. Thus, it is important that this ADT
value have some basis in actuality.
The unpaved road mileage used in these calculations is also of concern. The 2005 unpaved road mileage
for low traffic roads of 1,129.2 miles is essentially the same as the values used for 2001 through 2006 in
the 1999 Serious Area PM10 Plan. The mileage modeled for the 2005 inventory on high traffic unpaved
roads of 224.3 represents a decrease of 54 miles from the 2006 projections in the 1999 Plan. The 2005
inventory indicates that this represents the reduction in unpaved road mileage due to the control measures
in the 1999 Plan to Reduce-Particulate Emissions from Unpaved Roads and Alleys. However, the
documentation does not state how many miles of roads have assumed to have been paved. One of the
appendices to the Revised MCAQD 1999 Serious Area Particulate Plan for PM10 for the Maricopa
County Nonattainment Area lists commitments by several jurisdictions in the MCAQD area to pave,
gravel, or stabilize emissions from unpaved roads. This list does not provide sufficient information to
calculate the mileage reduced from unpaved roads. Additionally, there is no indication that growth in
unpaved roads since the time of the 1999 plan has been factored into this analysis. With the growth in
population and VMT in the MCAQD area, it is unrealistic to expect that the mileage of unpaved roads in
the area has not increased since 1999.
As with the paved roads, the AP-42 documentation includes a precipitation adjustment. No adjustment for
precipitation was applied to the unpaved roads, but, again, this is not expected to have a significant
impact.

Response #9K:
As indicated in Responses #8C and #8J, MAG used the best available data on unpaved roads to prepare
the PM10 emissions estimates in the Draft 2005 Periodic Emissions Inventory for PM10. The unpaved
road mileage by traffic volume category (i.e., low – average of 4 average daily trips (ADT) and high –
average of 120 ADT) was derived from a database developed for the MAG Serious Area PM10 Plan.
The Serious Area PM10 Plan, that was approved by EPA on July 25, 2002, reduced the miles of
unpaved roads to reflect legally-binding commitments made by local jurisdictions to pave and stabilize
unpaved roads by 2006. To ensure that these unpaved road assumptions continue to be representative
of the PM10 nonattainment area, MAG will work diligently to update the traffic counts on a sample of
unpaved roads. MAG will also apply geographic information systems (GIS) and recent aerial
photography to estimate the current unpaved road mileage. Since it will take several months to collect
this data, it will not be available to recalculate unpaved road emissions for the final 2005 periodic
emissions inventory; however, it will be available for use in estimating the 2007 unpaved road
emissions for the Five Percent Plan for PM10.
As indicated in Response #8J, the 25 mph speed on unpaved roads was assumed, because it is the
speed limit that the Arizona Department of Transportation Motor Vehicle Division has officially
established for roads that are not posted with a speed limit sign. While collecting traffic counts on a
sample of unpaved roads, MAG will try to obtain typical vehicle operating speeds on the same roads.

Maricopa Co. 2005 PM10 Emissions Inventory

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Appendix 1: Responsiveness Summary

Although these speeds will not be scientifically-derived (i.e., through a formal travel time survey or
speed study), the observations should provide a basis to determine whether the current assumption of
25 mph is reasonable.
MAG used AP-42, Section 12.2.2, Equation (1b), to estimate PM10 emission factors for unpaved road
dust. As documented on Page 116 of the inventory, the inputs to this equation were mean vehicle
weight (3 tons), surface material silt content (11.9%), average vehicle speed (25 mph), and surface
material moisture content (0.5%). The mean vehicle weight and surface moisture content represent
EPA default values. The source for the speed assumption is discussed above. The average silt content
was derived from analysis of soils in Maricopa County for the 1994 Regional PM10 Emission
Inventory. In calculating unpaved road dust emissions, MAG also applied Equation (2) which corrects
the particulate emission factor for precipitation. MAG applied 36 days as the precipitation correction
term, P, for 2005. P, which represents the number of days with at least 0.01 inches of precipitation, was
derived from an analysis of 2005 measurements at meteorological stations located throughout
Maricopa County. The commenter should be able to replicate the unpaved road emissions if the
correct 2005 precipitation correction factor is applied.
Comment #9L:
Due to the sensitivity of the unpaved road fugitive dust emissions to the average daily traffic volume
used, information on how this value was derived in other comparable areas in the Southwest was
investigated. The Clark County, Nevada, PM10 SIP was prepared in June 2001 and estimates the ADT for
unpaved roads based on traffic count data. The Clark County SIP indicates that traffic counts were taken
on a representative sample of the unpaved roads in the area and these samples were then used to predict
daily traffic volumes on the remaining unpaved roads. The roads were divided into four volume
categories. For the first three categories, the average of the daily traffic volume range was modeled as the
ADT for the roads in each category, resulting in ADTs of 25, 75, and 125 for these three categories. The
fourth category included unpaved roads with ADTs estimated to be greater than 150. Because the upper
end of this range was unknown, the ADT for this category was set to 15 1. This method of estimating
ADT based on actual traffic counts is more robust than the Maricopa County method which relies on
model assumptions of 4, 120, and 120 vehicles per day on low, medium, and high ADT roads,
respectively. Although the MCAQD documentation does not indicate the ADT volume range for the low,
medium, and high ADT unpaved road categories, a conservative assumption could be made that these
roads fall in a less than 50 ADT volume category. Making the argument that the lowest ADT category of
unpaved roads in Maricopa County should be comparable to those in Clark County, based on proximity
and comparable geographic conditions, then it would be reasonable to assume that the ADT for the low
ADT category should be increased to 25 vehicles per day. Such an assumption would increase the
unpaved road fugitive dust PM10 emissions reported in Table 5.4-10 from 20,954 kg/day to 36,762 kg/day
in the PM10 modeling area.

Response #9L:
As indicated in Responses #8C, #8J and #9K, MAG used the best available data on unpaved roads to
prepare the PM10 emissions estimates in the Draft 2005 Periodic Emissions Inventory for PM10. The
unpaved road mileage by traffic volume category (i.e., low – average of 4 average daily trips (ADT)
and high – average of 120 ADT) was derived from a database developed for the MAG Serious Area
PM10 Plan. To ensure that the traffic volumes on unpaved roads continue to be representative of the
PM10 nonattainment area, MAG will work diligently to update the traffic counts on a sample of
unpaved roads. Since it will take several months to collect this data, it will not be available to
recalculate unpaved road emissions for the final 2005 periodic emissions inventory; however, it will be
available for use in estimating the 2007 unpaved road emissions for the Five Percent Plan for PM10.

Maricopa Co. 2005 PM10 Emissions Inventory

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Appendix 1: Responsiveness Summary

Comment #10:
We have given a preliminary review of the 2005 Periodic Emissions Inventory for PM10 for the Maricopa
County, Arizona, Nonattainment Area; and have the following questions concerning the assumption of
construction activities occurring only 5 days per week.
EPA has found in Las Vegas, Nevada that activities for residential construction occur 6 days per week on
non union sites (70%) and 5 days for union sites (30%). Commercial construction occurs 6 to 7 days per
week. Road construction activities occur 7 days per week with most of the road construction activities
occurring at night in the summer months. EPA finds that the activities in Las Vegas are similar to the
activities in Maricopa County. Although the emissions calculated for these activities will probably not
change, since the emission factors are based upon acres disturbed, number of homes built, number of
miles of roads constructed, etc; EPA concern is that Construction and Mining Equipment may have been
underestimated with the assumption of only 5 days of construction activities. If there are laws,
ordinances, or rules that prohibit construction to just 5 days, then the assumptions in the inventory are
correct. EPA asks that the number of days of construction activities be reviewed and if found to occur
above 5 days, to adjust the emissions in the Construction and Mining Equipment category.
EPA has found that there are some emissions that were not included in the draft inventory but are stated
to be included in the final inventory. They were: ammonia emissions for fertilizer applications, cattle
feedlots and dairies, and PM2.5 emissions from windblown dust.

Response #10:
MCAQD Dust Compliance Division staff acknowledge that residential and commercial construction
may occur 6 or 7 days/week and roadway construction may occur 7 days/week. However MCAQD
does not track this information and the activity can vary depending on the project. MCAQD chose to
modify it's assumption regarding the number of days per week that construction activities occurs from
5 days per week to 6 days per week. The effect of this modification has no effect on annual emission
calculations, but results in lower daily PM10 emissions from construction. This change is reflected in
the May 2007 emissions inventory report.

Maricopa Co. 2005 PM10 Emissions Inventory

A1–32

Appendix 1: Responsiveness Summary

Appendix 2.1
Instructions for Reporting 2002 Annual Air Pollution Emissions

MARICOPA COUNTY
AIR QUALITY DEPARTMENT

INSTRUCTIONS
FOR REPORTING 2005
ANNUAL AIR POLLUTION EMISSIONS

February 2006

Emissions Inventory Unit
1001 North Central Avenue, Suite 400
Phoenix, Arizona 85004
(602) 506-6790
(602) 506-6985 (Fax)

Copies of this document, related forms
and other reference materials are available online at our web site:
www.maricopa.gov/aq/ei.aspx

TABLE OF CONTENTS
WHAT’S NEW FOR 2005?.............................................................................................................. 1
I.

INTRODUCTION............................................................................................................................. 2
Steps to Complete Your 2005 Maricopa County Emissions Inventory

II. REPORTING REQUIREMENTS................................................................................................... 3
- Pollutants to be Reported
- Emission Calculation Method Hierarchy
III. CONFIDENTIALITY OF DATA SUBMITTED............................................................................ 5
- Arizona State Statue and Maricopa County Rule
IV. HELPFUL HINTS AND INFORMATION..................................................................................... 6
- What is a Process?
- Processes and Materials That Do Not Have to be Reported
- Grouping Materials and/or Equipment Under One Process ID
- Assigning Identification Numbers (IDs)
- Industry-Specific Instructions
- Commonly Used Conversion Factors
- Additional Resources and Assistance
V.

INSTRUCTIONS AND EXAMPLES FOR EMISSIONS REPORTING FORMS
Business Form..................................................................................................................................... 8
Stack Form ......................................................................................................................................... 9
Control Device Form ....................................................................................................................... 10
General Process Form ....................................................................................................................... 11
Evaporative Process Form ................................................................................................................ 15
Off-Site Recycling/Disposal Form.................................................................................................... 19
Documentation of Emission Factor Calculations ............................................................................. 20
Data Certification Form (for NON-Title V sources) ........................................................................ 21
How to Calculate an Emission Fee (for Title V sources ONLY)...................................................... 22
Data Certification/Fee Calculation Form (for Title V sources ONLY) ............................................ 23

Maricopa County Emissions Inventory Unit

ii

Instructions for Reporting 2005 Emissions

WHAT'S NEW FOR 2005?
Emissions reporting requirements:
•

The US EPA has recently designated the chemical t-butyl acetate (CAS number 540-88-5) as a VOC
for record-keeping and emissions reporting requirements, but not for emission limitations or content
requirements. If you use this chemical at your facility, see the box on page 3 for specific reporting
instructions.

•

It is critical to the accuracy of your report to use the emission calculation method that best represents
actual emissions from your facility. Page 4 of these instructions now includes details on the preferred
emission calculation methods. Please double check your emissions calculations to make sure the best
method is employed.

Reporting forms:
•

Some pre-printed information on your report may be different from last year’s version. Please
review the enclosed forms carefully, and verify all pre-printed information.

•

Many of our reporting forms have changed recently. If you use your own forms, or a computerized
reproduction of our forms, the forms used MUST conform to the current information requirements
and FORMAT as supplied on our preprinted forms. “Homemade” reporting forms that vary
significantly from the preprinted forms sent to you will not be accepted.

Miscellaneous:
•

EPA emission factors for certain activities at sand and gravel facilities have been revised. The new
emission factors appear on applicable pre-printed general process forms and are also listed on our
revised Sand & Gravel Helpsheet available at: www.maricopa.gov/aq/ei.aspx

•

In accordance with Maricopa County Air Pollution Control Rule 280 (Fees), the 2005 annual emission
fee (for Title V sources only) is $13.65/ton.

Maricopa County Emissions Inventory Unit

1

Instructions for Reporting 2005 Emissions

I. INTRODUCTION
An annual emissions inventory is a document submitted by a business that: (1) lists all processes emitting
reportable air pollutants and (2) provides details about each of those processes. Submitting the emissions
inventory report is required as a condition of your Maricopa County Air Quality Permit. A separate
emissions report is required for each business location with its own air quality permit.
Follow these steps to complete your 2005 Maricopa County emissions inventory:
STEP 1: Determine which forms are needed for your business. There are eight different forms available,
but not all are required for every type of business. For most permitted sources, the packet you received from
us contains the necessary pre-printed forms based on your site’s most recent emissions inventory.
1.
2.

3.
4.
5.
6.
7.
8.

Business Form: Contains general contact information about the permitted site. This form is required
for all businesses.
Stack Form: Only required if your business location annually emits over 10 tons of a single pollutant
(CO, VOC, NOx, PM10, or SOx). A “stack” is defined as a stack, pipe, vent or opening through which a
significant percentage of emissions (from one or more processes) are released into the atmosphere. See
the “Stack Form Instructions” on page 9 for specific requirements.
Control Device Form: Required only if there is one or more emission control devices used at the
business location.
General Process Form and
Either or both will be required for all businesses.
Evaporative Process Form:
Off-Site Recycling/Disposal Form: Required if you want to claim off-site recycling or disposal.
Emission Factor Calculations: Required as attachment for each process for which you calculated
your own emission factors.
Data Certification Form or Data Certification/Fee Calculation Form: Only sources with a Title V
permit are required to pay a fee for their emissions and need to use the Data Certification/Fee
Calculation Form. All other sources use the Data Certification Form.

}

STEP 2: Complete the applicable forms. Verify all preprinted information, and make corrections where
necessary. When making corrections, strike out the preprinted data and write in corrections beside it. Please
make all changes readily noticeable. Detailed information on how to complete the most common forms is
included in this document. The packet you received also contains information about other resources
(workshops, one-on-one assistance, etc.) available to help you in completing the necessary forms.
STEP 3: Make a copy of your completed emissions inventory report. Make sure to KEEP COPIES of all
forms submitted and copies of all records and calculations used in completing the forms. Air pollution
control regulations require that you keep all documentation for at least FIVE YEARS at the location where
pollution is being emitted.
STEP 4: Make sure the Data Certification Form (or Data Certification/Fee Calculation Form for Title V
sources) is signed by a company representative. Include your air quality permit number on all
correspondence and applicable checks submitted with your report. Return the original, signed copy of your
annual emission report, with payment for any applicable emission fees to:
Maricopa County Air Quality Department
Emissions Inventory Unit
1001 North Central Avenue, Suite 100
Phoenix, AZ 85004
Maricopa County Emissions Inventory Unit

2

Instructions for Reporting 2005 Emissions

II. REPORTING REQUIREMENTS
POLLUTANTS TO BE REPORTED:
Your emissions inventory must include your business’s emissions of the following air pollutants:
CO
NOx
PM10
SOx
VOC
HAP&NON
NHx
Pb

=
=
=
=
=
=
=
=

Carbon monoxide
Nitrogen oxides
Particulate matter less than 10 microns
Sulfur oxides
Volatile organic compounds *
Hazardous Air Pollutant (HAP) that is also NOT a volatile organic compound (VOC)**
Ammonia and ammonium compounds
Lead

* A volatile organic compound (VOC) is defined as any compound of carbon that participates in atmospheric photochemical reactions. This definition excludes: carbon monoxide, carbon dioxide, acetone,
carbonic acid, metallic carbides or carbonates, and ammonium carbonate, as well as certain other organic
compounds. (See Maricopa County Air Pollution Control Rule 100, Sections 200.69 and 200.110 for a full
definition.)
NEW FOR 2005: EPA has redesignated the chemical t-butyl acetate (CAS Number 540-88-5) as a VOC
for record-keeping requirements and emissions reporting, but not for emission limitations or content
requirements. An anticipated revision to County Rule 100, Section 200.69 (tentatively scheduled for
adoption in March 2006) will incorporate this change as follows:
“The following compound(s) are VOC for purposes of all recordkeeping, emissions reporting, photochemical
dispersion modeling and inventory requirements which apply to VOC and shall be uniquely identified in
emission reports, but are not VOC for purposes of VOC emissions limitations or VOC content requirements:
t-butyl acetate (540-88-5).”
Therefore, if your facility uses t-butyl acetate, it is necessary to report t-butyl acetate as a separate material
on the evaporative process form, not as part of a grouped material (e.g., solvents, thinners, activators, etc.).
T-butyl acetate will continue to be identified as a VOC on your emission report and count towards any
applicable emission fees.
** HAP&NON: Usage of certain materials that are: (1) a Hazardous Air Pollutant (HAP) and (2) not also a
VOC (that is, not also an ozone precursor) should also be reported if:
(a) your site is subject to a Federal MACT (Maximum Achievable Control Technology) standard or
(b) your air quality permit contains specific quantitative limits for HAP emissions.
The most common materials categorized as “HAP&NON” include:
• methylene chloride (dichloromethane)
• perchloroethylene
• 111-trichloroethane (111-TCA or methyl chloroform)
• hydrochloric acid
• hydrofluoric acid
NOTE: HAPs that are also considered volatile organic compounds are reported as VOC.
Maricopa County Emissions Inventory Unit

3

Instructions for Reporting 2005 Emissions

EMISSION CALCULATION METHOD HIERARCHY:
When preparing emission information for your report, the most accurate method for calculating actual
emissions must be used. The hierarchy listed below outlines the preferred methods for calculating emission
estimates. (The hierarchy listed below will be incorporated into an anticipated July 2006 revision of Rule
280 of Maricopa County’s Air Pollution Control Rules and Regulations).
(1)

Whenever available, emissions estimates should be calculated from continuous emissions
monitors certified under 40 CFR Part 75, Subpart C, or data quality assured pursuant to Appendix
F of 40 CFR, Part 60.

(2)

When sufficient data obtained using the methods described in paragraph 1 is not available,
emissions estimates should be calculated from source performance tests conducted pursuant to
Rule 270 in Maricopa County’s Air Pollution Control Rules and Regulations.

(3)

When sufficient data obtained using the methods described in paragraphs 1 or 2 is not available,
emissions estimates should be calculated from material balance using engineering knowledge of
the process.

(4)

When sufficient data obtained using the methods described in paragraphs 1 through 3 is not
available, emissions estimates shall be calculated using emissions factors from EPA Publication
No. AP-42 "Compilation of Air Pollutant Emission Factors," Volume I: Stationary Point and Area
Sources.

(5)

When sufficient data obtained using the methods described in paragraphs 1 through 4 is not
available, emissions estimates should be calculated by equivalent methods supported by back-up
documentation that will substantiate the chosen method.

Maricopa County Emissions Inventory Unit

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Instructions for Reporting 2005 Emissions

III. CONFIDENTIALITY OF DATA SUBMITTED
Information submitted in your annual emissions reports must be made available to the public unless it meets
certain criteria of Arizona State Statutes and Maricopa County Rules. Applicable excerpts concerning
confidentiality of data are reproduced below.
ARS § 49-487 D. ...the following information shall be available to the public:…
2. The chemical constituents, concentrations and amounts of any emission of any air contaminant. ...
MARICOPA COUNTY AIR POLLUTION CONTROL RULES AND REGULATIONS, Rule 100:
§ 200.107 TRADE SECRETS - Information to which all of the following apply:
a.
A person has taken reasonable measures to protect from disclosure and the person intends to continue to
take such measures.
b.
The information is not, and has not been, reasonably obtainable without the person’s consent by other
persons, other than governmental bodies, by use of legitimate means, other than discovery based on a
showing of special need in a judicial or quasi-judicial proceeding.
c.
No statute, including ARS §49-487, specifically requires disclosure of the information to the public.
d.
The person has satisfactorily shown that disclosure of the information is likely to cause substantial harm to
the business’s competitive position.
§ 402
CONFIDENTIALITY OF INFORMATION:
402.2
Any records, reports or information obtained from any person under these rules shall be available to the
public ... unless a person:
a.
Precisely identifies the information in the permit(s), records, or reports which is considered confidential.
b.
Provides sufficient supporting information to allow the Control Officer to evaluate whether such information
satisfies the requirements related to trade secrets as defined in Section 200.107 of this rule.

For emissions inventory information to be deemed confidential, the following steps must be followed:
• Specific data which you request be held confidential must be identified by marking an “X” in the
corresponding gray confidentiality box(es) on the relevant report forms.
• Provide a written explanation which gives factual information satisfactorily describing why releasing this
information could cause substantial harm to the business’s competitive position.
• Use the gray-shaded boxes on the reporting forms to indicate which data are to be held confidential. Do
NOT stamp “Confidential”, highlight data, or otherwise mark the page.
No data can be held confidential without proper justification.

Maricopa County Emissions Inventory Unit

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Instructions for Reporting 2005 Emissions

IV. HELPFUL HINTS AND INFORMATION
Be sure to verify all preprinted information on forms. If any information is incorrect or blank, please
provide correct information. Making a change on the Business Form will NOT transfer the permit
ownership or location. You must contact the Department's Permit Engineering Division at (602) 506-6464 to
accomplish this.
WHAT IS A PROCESS? A process is a business activity at your location that emits one or more of the
pollutants listed on page 3, and has only one material type as input and one operating schedule. For each
applicable process at your business, you must assign a unique Process ID number to differentiate each
process.
PROCESSES AND MATERIALS THAT DO NOT HAVE TO BE REPORTED:
• Welding.
• Acetone usage.
• Fuel use for forklifts or other vehicles. (NOTE: Fuel use in non-vehicle engines is reportable.)
• Soil remediation activities. (Note: Other periodic reporting requirements may exist; consult your permit.)
• Storage emissions from fuels or organic chemicals in any tank with a capacity of 250 gallons or less.
• Storage emissions of diesel and Jet A fuel in underground tanks of any size.
• Storage emissions of diesel and Jet A fuel in aboveground tanks, with throughput < 4,000,000 gal/yr.
• Routine pesticide usage, housekeeping cleaners, and routine maintenance painting at your facility.
Please group all similar equipment and materials together before applying the following limitations:
• Internal combustion engines (e.g., emergency generators) or external combustion equipment (e.g., boilers
and heaters) that operated less than 100 hrs. and burned less than 200 gals. diesel or gas, or less than
100,000 cubic feet of natural gas.
• Materials with usage of less than 15 gallons or 100 pounds per year.
GROUPING MATERIALS AND/OR EQUIPMENT UNDER ONE PROCESS ID:
You can group together under one process ID:
• All internal combustion engines less than 600 hp if they burn the same fuel and have similar operating
schedules.
• All external combustion equipment (boilers, heaters) with a capacity of less than 10,000,000 Btu per
hour if they burn the same fuel and have similar operating schedules.
• All similar evaporative materials with similar emission factors that have similar operating schedules and
process descriptions. For example, group low-VOC red paint, green paint and white paint together as
one material: “Paint: Low-VOC.” Do not group dissimilar materials together, such as thinners and
paints. Attach documentation (see example, p. 20) showing how the grouped emission factor was
determined.
• All underground tanks with the same fuel and same type of vapor recovery system.
ASSIGNING IDENTIFICATION NUMBERS (IDs):
Unique IDs are required for the following report elements: Stacks, Control Devices and Processes. For
processes, that means a process ID number may be used only once on each General Process form and for
each material reported on the Evaporative Process Forms.
These numbers are usually assigned by the person who prepares the original report. If you are adding a new
item to a preprinted report, assign a number not already in use. Once an ID number is assigned, continue
Maricopa County Emissions Inventory Unit

6

Instructions for Reporting 2005 Emissions

using the same number for that item each year. If that item is no longer reportable, return the preprinted
form with a brief explanation. Do not use that ID number again.

INDUSTRY-SPECIFIC INSTRUCTIONS: Additional help sheets, detailed examples, and special instructions are available for a number of specific processes or industries listed below. To get copies of any of these
documents, please visit our web site at www.maricopa.gov/aq/ei.aspx or call (602) 506-6790.
• Bakeries
• Concrete Batch Plants
• Fuel Storage and Handling
• Incinerators and Crematories
• Lg. Aboveground Storage Tanks

•
•
•
•
•

Natural Gas Boilers/Heaters
Polyester Resin
Printing Plants
Roofing Asphalt
Sand and Gravel Plants

•
•
•
•

Using EPA's TANKS 4.09d Program
Vehicle Refinishing
Vehicle Travel on Unpaved Roads
Woodworking

COMMONLY USED CONVERSION FACTORS:
1 gram/liter = 0.00834 lbs/gal
1 foot
= 0.0001894 mile
1 liter
= 0.2642 gallon (US)
1 square foot
= 0.000022957 acre
1 therm
= 0.0000952 MMCF
1 pound
= 0.0005 ton
NOTE:
MM = 1,000,000
Example: MMCF = 1,000,000 cubic feet
M = 1,000
Example: MGAL = 1,000 gallons
ADDITIONAL RESOURCES AND ASSISTANCE:
The Maricopa County Emissions Inventory web site at www.maricopa.gov/aq/ei.aspx contains additional
reference materials, such as:
• blank copies of most emissions reporting forms.
• an updated list of emission factors for a large number of industrial processes, including SCC codes.
• a list of Tier Codes for industrial processes.
• detailed help sheets for a number of specific industries or processes.
To receive any of the above materials by fax or mail, or for additional information or assistance in how to
calculate and report your emissions, please call us at (602) 506-6790.

Maricopa County Emissions Inventory Unit

7

Instructions for Reporting 2005 Emissions

V. INSTRUCTIONS AND EXAMPLES FOR COMPLETING EMISSIONS REPORTING FORMS

Business Form

Instructionss

Verify all preprinted information, and make corrections where necessary. When making corrections, strike
out the preprinted data and write in corrections beside it. Please make all changes readily noticeable.

NOTE:

Indicating a change in ownership or business location on the Business Form will not serve to
transfer the permit ownership or location. You must contact the Department's Permit Engineering Division at
(602) 506-6464 to accomplish this.

Data fields:
6 Number of employees: This should be the annual average number of full-time equivalent (FTE)
employee positions at this business location.
9

NAICS Code: This 5- or 6-digit North American Industrial Classification System (NAICS) code has
been introduced to replace the 4-digit Standard Industrial Classification (SIC) codes. Please list the
primary and secondary NAICS codes for your business, if known. (Consult our website, at
www.maricopa.gov/aq/ei.aspx, for a link to a full list of NAICS codes.)

10 Preparer of the Inventory (primary contact for technical questions concerning this report): This should
be the person who knows the most about the data in the report. If this person has an e-mail address used
for business purposes, please provide it.

Maricopa County Emissions Inventory Unit

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Instructions for Reporting 2005 Emissions

Stack Form

Instructions

A “stack” is defined as a stationary stack, pipe, vent or opening through which a significant percentage of
emissions (from one or more processes) are released into the atmosphere (with or without a control device).

NOTE:

Stack information is required only if your business location annually emits over 10 tons of any
one individual pollutant. If so, you must complete a Stack Form for:
• each stack connected to a control device.
• any stack that discharges annually more than 5 tons of combined pollutant emissions (such as a paint
booth exhaust).
EXAMPLE Stack Form Information:
1

2

Stack
ID

Stack
Type
Code*

3

1

W

30 ft

2

V

14 ft

4

5a OR

5b

6a

OR

6b & 6c

7

Stack
Exit Gas
Velocity Flow Rate Diameter Length / Width
Height** Temperature feet/sec
acfm
inside inch
inside inch

* Stack Type Codes:

90
200

o

F

o

F

Stack Name/Description. Include lat/long
coordinates of stack (in decimal degrees)

20,000

36

paint booth Lat: N33.531873

19,186

40

thermal oxidizer, Bldg. 2

Long: W112.261331

Lat: N33.5325 Long:
W112.26136

V = Vertical unobstructed
D = Downward unobstructed
W = Obstructed vertical (e.g. weather cap)

H = Horizontal unobstructed
G = Gooseneck

** Stack height is calculated relative to the surrounding terrain. For instance, the stack height of a 10-foot
stack on top of a 20-foot tall building is 30 feet.
Data fields:
1

Stack ID: (See “Assigning Identification Numbers” on page 6.) A number (up to three digits, numeric
only) which identifies a specific stack. It is suggested you start with 1, then 2, etc.

4

Exit Gas Temperature: Should represent average operating conditions, in degrees Fahrenheit.
DO NOT report “ambient”.

5a Exit Gas Velocity: OR 5b Gas Flow Rate:
Provide EITHER the exit velocity (in feet per second) OR the flow rate of gas (in actual cubic feet per
minute) exiting the stack during normal operations. Preprinted information provides both.
6a Inside Stack Diameter: For round stacks, provide Inside Stack Diameter in inches.
OR
6b & 6c Inside Stack Length and Width: For square or rectangular stacks, provide inside Length and inside
Width in inches.
7

Stack Name/Description and Lat/Long Coordinates: Provide a brief text description of the stack along
with the latitude and longitude coordinates of the stack (in decimal degrees).

Maricopa County Emissions Inventory Unit

9

Instructions for Reporting 2005 Emissions

Control Device Form

Instructionss

EXAMPLE Control Device Form Information
1

2

3

4

Control
ID

Installation/
Reconstruction*
Date

5

Size or Rated Capacity**

Control
Type Code

Control Device
Name/Description

1

05/09/98

25,000.0 cfm

021

Thermal oxidizer

4

03/10/97

cfm

153

Watering with water trucks

6
Stack ID

2

Data fields:
1

Control ID: (See “Assigning Identification Numbers” on page 6.) A unique number (up to three digits)
that you assign to identify a specific control device.

2

Installation/Reconstruction Date: The completion date (given in mm/dd/yy format) of installation or the
most recent reconstruction of the identified control device. This is not a date on which routine repair or
maintenance was done. Reconstruction means any component of the control device was replaced and the
cost (fixed capital) of the new component(s) was more than half of what it would have cost to purchase
or construct a new control device.

3

Size or Rated Capacity: Report the air or water flow rate in cubic feet per minute. Some devices (e.g.,
water trucks for dust control) will not include a value in this field.

4

Control Type Code: A 3-digit code designating the type of control device. A complete list of all EPA
control device codes can be found on the Web at www.maricopa.gov/aq/ei.aspx or call (602) 506-6790
for assistance.

6

Stack ID: Not all businesses require a Stack ID. This is required if the Stack Form is used for your site
(see page 9) and the control device is vented through that identified stack. This is the ID number shown
in column 1 of the Stack Form. The Stack ID can be entered on this form after the Stack Form has been
filled out.

Maricopa County Emissions Inventory Unit

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Instructions for Reporting 2005 Emissions

General Process Form

Instructionss

The General Process Form is used to record data on all emissions-producing processes except evaporative
processes. A “general process” is normally characterized by the burning or handling of a material. One
form reports all the pollutants for one process. For example, several pollutants are produced by burning fuel,
and PM10 is emitted by processing rock products, processing materials such as wood or cotton, and driving
on unpaved areas.
Data fields: (See sample forms on pages 13 and 14.)
1 Process ID: A number (up to three digits) that is preprinted or you assign. (See “Assigning
Identification Numbers” on page 6.) This Process ID number can not be used for any other process at
this location.
2

Process Type/Description: Brief details on the type of activity that is occurring.

3

Stack ID(s): The stack ID number(s) shown in column 1 of the Stack Form that identify the stack(s)
which vent pollution created by this process. Not all businesses are required to report stacks. This is only
required if the Stack Form is required for your site (see page 9) and the process has a stack.

4
5

Process Tier Code and
SCC Code:

6

Seasonal Throughput Percent: Enter the percent of total annual operating time that occurred per season,
rounded to the nearest percent. For example, “Dec-Feb 30% ” means 30% of total annual activity
occurred in January, February and December 2005. The total for all four seasons must equal 100%.

7
8

Normal Operating Schedule and
Typical Hours of Operation:

9

Emissions Based on: Provide the name of the material used, fuel used, product produced, or whatever
was measured for the purpose of calculating emissions, such as “natural gas”, “hours of operation,”
“vehicle miles traveled,” or “acres.”

If these codes are not preprinted on your form, please consult the
section “Other Resources” on our web site, or call (602) 506-6790.

These reflect the normal daily, weekly, and annual operating
parameters of this process during 2005.

10 Used, Produced or Existing: Indicate whether calculated emissions are based on a material type or fuel
used (an input, such as “paint” or “natural gas”), or an output (such as “sawdust produced” or “finished
product”). Use “Existing” if the parameter reported on line 9 is not directly used or produced in the
process (such as “vehicle miles traveled” or “acres”).
11 Annual Amount: The annual amount (a number) of material that was used, fuel combusted, product
produced, hours of operation, vehicle miles traveled, or acres.
12 Fuel Sulfur Content (in percent): For processes that involve the combustion of oil or diesel fuels, report
the sulfur content of the fuel as a decimal value. Example: 0.05 % (= 500 ppm)
13 Unit of Measure: Units of the material used, fuel used or product produced shown on line 9.
For example: gallons, pounds, tons, therms, acres, vehicle miles traveled, units produced.
14 Unit Conversion Factor: You must provide this if you use an emission factor with an emission factor unit
(see item 17 below) that is not the same as the unit of measure (from line 13). This is the standard
number you would multiply your amount (line 11) by to convert it to the units of the emission factor. See
page 7 for a list of commonly used conversion factors.
Maricopa County Emissions Inventory Unit

11

Instructions for Reporting 2005 Emissions

General Process Form Instructions (continued)
15 Pollutant: See page 3 for a list of pollutants that need to be reported.
16 Emission Factor (EF): The number to be multiplied by the annual amount (line 11) to determine how
much of the pollutant was emitted. If you calculate your own emission factor or change the preprinted
emission factor, you must provide details of your calculations in an attachment.
17 Emission Factor (EF) Units: Enter the appropriate Emission Factor Units in pounds (lb) per unit; e.g.,
lb/ton, lb/MMCF, lb/gal.
18 Controlled Emission Factor (EF)? YES or NO: Indicate “YES” if: 1) you have your own emission factor
from testing and included the control device efficiency within the factor, or 2) the emission factor used is
clearly identified as a controlled emission factor. A “YES” response requires the use of Formula A (see
#25 below). Indicate “NO” if: 1) there is no emission control device, or 2) the emission factor represents
emission rates before controls. A “NO” response requires the use of Formula B (see #25 below).
19 Calculation Method: Enter the number code (listed at the bottom of the General Process Form) which
best describes the method you used to obtain this emission factor. Code 5, “AP-42/FIRE Method or
Emission Factor” means that the factor comes from EPA documents or software. NOTE: If you have
continuous emissions monitors (CEM) data or conducted a source test that was required and approved by
the County for a specific process or piece of equipment, you must use the emission data from the CEM
or the test results. Report “1” in this column for CEM data or “4” for performance test data.
20 through 24: Leave blank if there is no control device.
20 Capture % Efficiency: The percent of the pollutant that is captured and sent to the primary control
device in this process. Be sure to list capture efficiency separately for each pollutant affected.
21 Primary Control Device ID: If this pollutant is being controlled in this process, enter the Control
Device ID number which represents the first control device affecting the pollutant.
22 Secondary Control Device ID: If this pollutant is being controlled sequentially by 2 devices, enter
the Control Device ID number which represents the second control device; otherwise leave this field
blank.
23 Control Device(s) % Efficiency: Enter the total control efficiency of the control device(s). Be sure
to list control device efficiency separately for each pollutant affected. If you report control device
efficiency, you must also show capture efficiency in column 20.
24 Efficiency Reference Code: Enter the code (1 through 6) that best describes how you determined the
control device efficiency. A list of possible codes is included at the bottom of the form.
25 Estimated Actual Emissions (in pounds/year): You may round the calculated emissions values to the
nearest pound. Calculate as follows:
A. Emissions with no controls or controls are reflected in the emission factor:
Column 25 = line 11 × line 14 × column 16
B. Emissions after control:
Column 25 = line 11 × line 14 × column 16 × (1 – [column 20 × column 23])
Use the decimal equivalent for columns 20 and 23. Example: 96.123% = 0.96123
Maricopa County Emissions Inventory Unit

12

Instructions for Reporting 2005 Emissions

General Process Form 2005

Permit number(s)

EXAMPLE: Internal Combustion

V99999

Place an X in any gray cell to mark data requested to be held confidential. See page 5 for requirements for information to be deemed confidential.
1- Process ID
80
2- Process Type/Description:

3 ENGINES FOR CRUSHING (EACH LESS THAN 600 HP)

3- Stack ID(s) (only if required on Stack Form)

________

020599

4- Process TIER Code:
5- SCC Code

_______

20200102

________

IND:DIESEL-RECIPROCATING

(8 digit number)

25

Dec-Feb

7- Normal Operating Schedule:

Hours/Day
(military time)

%

8

Days/Week

0700

Start

25

Mar-May

%

5

Jun-Aug
Hours/Year

⌧ Used (input)

11- Annual Amount:

or

Produced (output)

or

CO

NOx
PM-10
SOx
VOC

Emission Factor (EF) Information
16
17
18
Emission
Factor (EF)
(number)

130
604
42.5
39.7
49.3

Emission
Factor
Unit (lb per)

M
M
M
M
M

19

20

Controlled
EF?
Yes or No

Calculation
Method
Code*

Capture %
Efficiency

N
N
N
N
N

5
5
5
5
5

GALS
GALS
GALS
GALS
GALS

* Calculation Method Codes:
1 = Continuous Emissions Monitoring Measurements
2 = Best Guess / Engineering Judgment
3 = Material Balance
4 = Source Test Measurements (Stack Test)
5 = AP-42 / FIRE Method or Emission Factor

Maricopa County Emissions Inventory Unit

25

Sep-Nov
Weeks/Year

%

52 x

DIESEL

__0.05_______%

GALLONS

14- Unit Conversion Factor (if needed to convert Unit of Measure to correlate with emission factor units)

15

2080

12- Fuel Sulfur Content (in percent)

13- Unit of Measure: (for example: tons, gallons, million cu ft, acres, units produced, etc.)

Pollutant

%

Existing (e.g. VMT, acres)

16,250

(a number)

25

1530

End

9- Emissions based on (name of material or other parameter, e.g. “rock”, “diesel”, “vehicle miles traveled”)
10-

________

FUEL COMB. INDUSTRIAL: INTERNAL COMBUSTION

6- Seasonal Throughput Percent:

8- Typical Hours of Operation:

________

0.001

Control Device Information
21
22
23
Primary
Control
Device ID

Secondary
Control
Device ID

Control
Device(s) %
Efficiency

24

25

Efficiency
Reference
Code**

Estimated Actual
Emissions

2,113
9,815
691
645
801

6 = State or Local Agency Emission Factor
7 = Manufacturer Specifications
8 = Site-Specific Emission Factor
9 = Vendor Emission Factor
10 = Trade Group Emission Factor

13

lbs
lbs
lbs
lbs
lbs

** Control Efficiency Reference Codes:
1 = Tested efficiency / EPA reference method
2 = Tested efficiency / other source test method
3 = Design value from manufacturer
4 = Best guess / engineering estimate
5 = Calculated based on material balance
6 = Estimated, based on a published value

Instructions for Reporting 2005 Emissions

General Process Form 2005

Permit number(s)

EXAMPLE: Unpaved Road Travel

V99999

Place an X in any gray cell to mark data requested to be held confidential. See page 5 for requirements for information to be deemed confidential.
1- Process ID
28
2- Process Type/Description: UNPAVED ROAD TRAVEL: HEAVY-DUTY TRUCKS @ 15 MPH
_______

3- Stack ID(s) (only if required on Stack Form)
4- Process TIER Code:
5- SCC Code

________

140799

30502504

6- Seasonal Throughput Percent:

8- Typical Hours of Operation:

________

SAND/GRAVEL: HAULING
25

Dec-Feb

8

Hours/Day
(military time)

%

%

Used (input)

11- Annual Amount:

or

Produced (output)

Hours/Year

Sep-Nov
Weeks/Year

25

%

52 x

VEHICLE MILES TRAVELED (VMT)

⌧ Existing (e.g. VMT, acres)

7,500

(a number)

2080

%

1530

End

or

25

Jun-Aug

5

Days/Week

0700

Start

25

Mar-May

9- Emissions based on (name of material or other parameter, e.g. “rock”, “diesel”, “vehicle miles traveled”)
10-

________

MISCELLANEOUS: FUGITIVE DUST
(8 digit number)

7- Normal Operating Schedule:

________

12- Fuel Sulfur Content (in percent)

__

_______%

VMT

13- Unit of Measure: (for example: tons, gallons, million cu ft, acres, units produced, etc.)

14- Unit Conversion Factor (if needed to convert Unit of Measure to correlate with emission factor units)

15
Pollutant

PM-10

Emission Factor (EF) Information
16
17
18
Emission
Factor (EF)
(number)

3.2

Emission
Factor
Unit (lb per)

Control Device Information
21
22
23

19

20

Controlled
EF?
Yes or No

Calculation
Method
Code*

Capture %
Efficiency

Primary
Control
Device ID

N

6

100

4

VMT

Secondary
Control
Device ID

24

25

Control
Device(s) %
Efficiency

Efficiency
Reference
Code**

Estimated Actual
Emissions

70

6

7200

lbs
lbs
lbs
lbs
lbs
lbs

NOTE: Emissions in col. 25 are calculated as follows:
* Calculation Method Codes:
1 = Continuous Emissions Monitoring Measurements
2 = Best Guess / Engineering Judgment
3 = Material Balance
4 = Source Test Measurements (Stack Test)
5 = AP-42 / FIRE Method or Emission Factor

Maricopa County Emissions Inventory Unit

(line 11 × col. 16) × (1 – [col. 20 × col. 23])

6 = State or Local Agency Emission Factor
7 = Manufacturer Specifications
8 = Site-Specific Emission Factor
9 = Vendor Emission Factor
10 = Trade Group Emission Factor

14

** Control Efficiency Reference Codes
1 = Tested efficiency / EPA reference method
2 = Tested efficiency / other source test method
3 = Design value from manufacturer
4 = Best guess / engineering estimate
5 = Calculated based on material balance
6 = Estimated, based on a published value

Instructions for Reporting 2005 Emissions

Evaporative Process Form

Instructionss

The Evaporative Process Form is used to report all emissions produced by evaporation. Examples include:
cleaning with solvents, painting and other coatings, printing, using resin, evaporation of fuels from storage
tanks, ammonia use, etc. All other processes should be shown on the General Process Form.
One Evaporative Process Form may be used to report numerous materials, with each material given a
separate process ID number, as long as the information on lines 1–5 apply to all items on that form. Use a
separate form for each group of materials that has a different Process Type/Description (shown on line 1),
different Tier Code (line 2) or different operating schedule (lines 3, 4, or 5).
Data fields: (See sample forms on pages 17 and 18.)
1 Process Type/Description: Brief details of the activity in which the listed materials were used.
2

Process Tier Code: If this 6-digit code is not preprinted on your form, please refer to the Tier Code list at
www.maricopa.gov/aq/ei.aspx or call (602) 506-6790.

3

Seasonal Throughput Percent: Enter the percent of total annual operating time that occurred per season
(rounded to the nearest percent). For example, “Dec-Feb 30% ” means 30% of the total annual activity
occurred during January, February and December 2005. The total for all four seasons must equal 100%.

4
5

Normal Operating Schedule and
Typical Hours of Operation:

6

Process ID: A number (up to three digits) that represents this specific material (process). Each process
on one form must have the same tier code and operating schedule as that shown in the top portion of the
form. This Process ID number can not be used for any other process at this business location. See page
6 of these instructions for more explanation of ID numbers and for exclusions and guidance on grouping
materials.

7

Stack ID(s): The stack ID number(s) shown in column 1 of the Stack Form that identify the stack(s)
which vent pollution created by this process. Not all businesses are required to report stacks. This is only
required if the Stack Form is required for your site (see page 9) and the process has a stack.

8

Material Type: Provide the name of the material used in this process. Give the chemical name for pure
chemicals or a name that reflects its use (paint, ink, etc.), rather than just a brand name or code number.
Examples of materials include: paint, thinner, degreasing solvent (plus its common name), ink, fountain
solution, ammonia, alcohol, ETO (ethylene oxide), gasoline (in a storage tank).

9

Annual Material Usage/Input: Amount of this material used during the year. In most cases, the amount
purchased is suitable. Write in “lbs” or “gal” (pounds or gallons).

These represent the usual number of hours, time of day and weeks
per year when this process occurred during the calendar year.

10 Pollutant: The only pollutants reported on this form are VOC, HAP&NON and NHX (see definitions on
page 3). When one process (or material) has more than one of these pollutants, list each pollutant on a
separate line, using the same process ID number.

Maricopa County Emissions Inventory Unit

15

Instructions for Reporting 2005 Emissions

Evaporative Process Form (continued)
11 Emission Factor (EF): An emission factor is a number used to calculate the pounds of pollutant emitted
based on the quantity of material used in a process. Emission factors can be obtained from your supplier
(usually provided on a Material Safety Data Sheet or environmental data sheet), and must correspond
with the material units reported in column 9. If the material unit is “gal,” then the emission factor must
be in pounds of pollutant per gallon. If the material unit is “lb,” then the emission factor must be in
pounds of pollutant per pound of material.
Verify (and correct, where necessary) all pre-printed emission factors, as the composition of materials
used may have changed since your last report. A “lb/gal” emission factor is almost always less than 8 and
never greater than 14. A “lb/lb” emission factor is never larger than 1.0.
12 Pounds of pollutant sent off-site: Required only if you wish to take credit for reduced emissions because
waste of this material is sent off-site for recycling or disposal. Only waste generated during the report
year may be claimed. The Off-Site Recycling/Disposal Form must be completed if you wish to claim a
credit. The number of pounds reported in column 12 must equal the number of pounds reported on the
Off-Site Recycling/Disposal Form(s) for the same Process ID number.
13 and 14: Leave these fields blank if there is no control device present.
13 Capture % Efficiency: The percent of the pollutant from this process that is captured and sent to the
control device.
14 Control ID: If this pollutant is being controlled in this process, enter the Control Device ID number
from column 1 of the Control Device Form.
Control % Efficiency: Enter the percent of this pollutant that is controlled by this control device.
Code: Select the Control Efficiency Reference Code from the list at the bottom of the form.
15 Estimated Emissions (lbs/yr): Estimated pounds of the pollutant emitted during the year, after off-site
recycling/disposal and controls if applicable. Credit will not be given for off-site recycling/disposal
unless it is shown on the Off-Site Recycling/Disposal Form. Round to the nearest pound. If the
answer is 0, give a decimal answer to the first significant digit. Column 15 is calculated as follows:
Emissions without off-site recycling/disposal or controls:
Column 15 = column 9 × column 11
Emissions with off-site recycling/disposal:
Column 15 = (column 9 × column 11) – column 12
Emissions with off-site recycling/disposal and controls:
Column 15 = ([column 9 × column 11] – column 12) × (1 – [column 13 × column 14])
Use the decimal equivalent for columns 13 and 14. Example: 96.123% = 0.96123

Maricopa County Emissions Inventory Unit

16

Instructions for Reporting 2005 Emissions

EXAMPLE: Coating and Painting
Evaporative Process Form 2005

Permit number(s)

V99999

Place an X in any gray cell to mark data requested to be held confidential. See page 5 for requirements for information to be deemed confidential.
1- Process Type/Description:
2- Process TIER Code:

Coating metal widgets

080415

3- Seasonal Throughput Percent:
4- Normal Operating Schedule:
5- Typical Hours of Operation

SOLVENT USE: SURFACE COATING - MISC METAL PARTS
Dec-Feb

Hours/Day

25

%

8

Days/Week

(military time)

6

7

8

Process
ID

Stack
ID(s)

Material Type

800

1

801

1

802

1

803

1

804

1

Start

9

%

25

5

Hours/Year
End

0800

Jun-Aug
2080

25

%

Sep-Nov

25

%

Weeks/Year 52__

1700

10

11
Emission
Factor

EF
Units
(lbs per)

12

13

Pounds of
pollutant*
sent
off site

Capture
Efficiency
%

14
Control
ID

15

Control
Efficiency
%

Control
Efficiency
Code**

Estimated
Emissions
(lbs/yr)

lb
or
gal

VOC,
HAP&NON
or
NHx

95

gl

VOC

4.7

gal

%

%

447

120

gl

VOC

7.1

gal

%

%

852

940

gl

VOC

4.2

gal

%

%

3,948

707

gl

VOC

7.0

gal

%

%

4,949

20,200

lb

VOC

0.001

lb

Annual
Usage
Input

Lacquer
6455-06
lacq thinner
Paint red
4039-03
paint thinner
powder paint
8730-11

Mar-May

%
%

%
%

Note: Do NOT change pre-printed Process ID numbers. See page 6 of these instructions for information on how to delete materials that are no longer used, or to assign
Process ID numbers for new materials.

* If you have off-site recycling/disposal of any of the materials listed above, you must complete an Off-site Recycling/Disposal Form to receive
credit for reduced emissions.
NOTE: Emissions in col. 15 are calculated as follows:
** Control Efficiency Reference Codes
1 = Tested efficiency / EPA reference method
4 = Best guess / engineering estimate

Maricopa County Emissions Inventory Unit

([col. 9 × col. 11] – col. 12) × (1 – [col. 13 × col. 14])

2 = Tested efficiency / other source test method
5 = Calculated based on material balance

17

3 = Design value from manufacturer
6 = Estimated, based on a published value.

Instructions for Reporting 2005 Emissions

20

EXAMPLE: Cleaning solvent (with recycling)
Evaporative Process Form 2005

Permit number(s)

V99999

Place an X in any gray cell to mark data requested to be held confidential. See page 5 for requirements for information to be deemed confidential.
1- Process Type/Description:
2- Process TIER Code:

Cleaning metal parts

080103

3- Seasonal Throughput Percent:

Dec-Feb

4- Normal Operating Schedule:
5- Typical Hours of Operation

SOLVENT USE: DEGREASING - COLD CLEANING

Hours/Day

25

%

8

Days/Week

(military time)

6

7

8

Process
ID

Stack
ID(s)

Material Type

3

2

Mar-May

Start

9

%

25

Hours/Year

5

End

1300

Jun-Aug

25

%

2080

Sep-Nov

%

25

Weeks/Year 52__

1700

10

11
Emission
Factor

EF
Units
(lbs per)

12

13

Pounds of
pollutant*
sent
off site

Capture
Efficiency
%

14
Control
ID

15

Control
Efficienc
y
%

Control
Efficiency
Code**

Estimated
Emissions
(lbs/yr)

Annual Usage
Input

lb
or
gal

VOC,
HAP&NON
or
NHx

sanitizer

716

lb

VOC

1.0

lb

6

gun cleaner

180

gl

VOC

7.2

gl

569

%

%

727

7

xyz stripper

1300

gl

VOC

3.3

gl

1,884

%

%

2,406

8

cleaning
solvents
generoclean

358

gl

VOC

6.4

gl

1,006

%

%

1,285

2258

gl

VOC

6.8

gl

6,741

%

%

8,613

%

%

9

95 %

1

80 %

3

172

Note: Do NOT change pre-printed Process ID numbers. See page 6 of these instructions for information on how to delete materials that are no longer used, or to assign
Process ID numbers for new materials.

* If you have off-site recycling/disposal of any of the materials listed above, you must complete an Off-site Recycling/Disposal Form to receive
credit for reduced emissions.
NOTE:

This example shows the case where 2,400 of the original 4,096 gallons of materials #6 through 9 were captured
for off-site recycling, and the pollutant content of the waste material was estimated to be 75% of the
original. The pounds of pollutant sent off-site shown in column 12 is calculated on the example Off-Site
Recycling/Disposal Form on the next page.

Maricopa County Emissions Inventory Unit

18

Instructions for Reporting 2005 Emissions

EXAMPLE
Off-Site Recycling/Disposal Form 2005

Permit number(s)

V99999

NOTE: If you need blank copies of this form, call the Emissions Inventory Unit at
(602) 506-6790 or consult our web page at www.maricopa.gov/aq/ei.aspx.
Provide one off-site recycling/disposal form for each waste stream at your business location. A waste stream is the waste from
one or more processes mixed together to make one waste product before it is taken off site for recycling, disposal or combustion.
01
1) Assign a unique two-digit ID number to identify the waste stream that will be described below.
(Start with ID# 01 for first waste stream. Make copies of a blank Off-Site Recycling/Disposal form and use 02 for second,
etc.)
Check one:

pounds
gallons

2,400
2) What was the quantity of this waste stream in 2005?
Indicate whether this quantity is reported in pounds or gallons. Keep waste disposal company manifests as proof that this
amount of waste was taken off-site.
3) What was the average pollutant content of the waste stream? NOTE: Report in the same units (pounds or gallons) as used
in line 2.
VOC

4.25

lbs/unit

HAP&NON

lbs/ unit NHx

lbs/ unit

NOTE: Waste normally has less pollutant content than the new product. Some of the
pollutant evaporates during the use of the product, and there is usually dirt, water or
other contaminants in the waste stream. The estimated pollutant content of the waste is
usually between 50% and 95% of the new product. This example estimates an average VOC
content (on line 3) to be 75% of the original VOC content of 5.67 lbs/gal., to account
for evaporation and contaminants. See page 20 to calculate a weighted average.
4) Calculate the total annual pollutant content of the waste in this waste stream.
(volume of waste, from Line 2) × (pollutant content, from Line 3) = Total pollutants in waste stream, in lbs/yr.
VOC

10,200

lbs/yr HAP&NON

lbs/yr

NHx

lbs/yr

5) List the process ID numbers of the processes contributing to this waste stream. Also estimate the pounds of pollutant
that each process contributed to this waste stream.
NOTE: In this example, the amount each process material contributed to total pollutants
in the waste stream (Line 4) is based on the percentage, by weight, of each material
that contributed to the waste stream. (e.g. Process ID #6 contributed 5.6%, therefore
5.6% × 10,200 lbs/yr = 569 lbs. See example on page 20.)
NOTE: Column totals in the table below must equal the total for each pollutant type reported on line 4. The quantities
you report below for each pollutant and process must also be reported in column 12 on the Evaporative Process Form.
Process ID
6 Contributed about
7 Contributed about
8 Contributed about
9 Contributed about

Annual VOC (lbs)
569
1,884
1,006
6,741

Maricopa County Emissions Inventory Unit

Annual
HAP&NON (lbs)
lbs
lbs
lbs
lbs

19

Annual NHx (lbs)
lbs
lbs
lbs
lbs

lbs
lbs
lbs
lbs

Instructions for Reporting 2005 Emissions

EXAMPLE: Documentation of Emission Factor Calculations
Identify the process ID number(s) and pollutant(s). Show calculations made to obtain the emission factors used
for the process(es). Include references to data sources used, including the document name, date published, page
numbers, etc.

Emission Factor Calculation
Process ID

Permit number

201

V99999

Emission factors derived from source test performed 12/2/00 by XYZ Engineering
Company (copy of summary tables also attached).
Outlet (after controls):
CO
= 0.43 lb/hr × 1 hr/60 min × 1 min/77.9 cu. ft × 1,000,000 cu. ft/MMCF
= 92.0 lb/MMCF
= 0.09 lb/hr × 1 hr/60 min × 1 min/77.9 cu. ft × 1,000,000 cu. ft/MMCF
= 19.3 lb/MMCF

NOx

Weighted average sample calculation
NOTE: The example below shows how the weighted average of the materials going into the
waste stream is calculated. A weighted-average emission factor has been calculated
by listing usage amounts and emission factors for each material, summing each
column, and then dividing the total emissions by the total gallons used.
In this example: 23,231 lbs ÷ 4,096 gal = 5.67 lb/gal average VOC content. This
emission factor is then used to calculate the average pollutant content in the Offsite Recycling / Disposal Form example.
This process can also be used to find the weighted average emission factor for
similar materials if you are reporting them together as a single line item on the
Evaporative Process form. Refer to the explanation of “grouping” on page 6.

Process
ID #
6
7
8
9

Material Type
gun cleaner
xyz stripper
cleaning solvent
generoclean solvent
Totals:
Average
VOC content:

Maricopa County Emissions Inventory Unit

2005
Usage

Units

180
1,300
358
2,258
4,096

gal
gal
gal
gal
gal

VOC
(lbs/unit)
7.2
3.3
6.4
6.8

23,231 lbs.
4,096 gals

20

VOC Emissions
(= Usage × VOC
content)
1,296 lbs.
4,290 lbs.
2,291 lbs.
15,354 lbs.
23,231 lbs.
=

Percent contributed
to waste stream

5.6 %
18.5
9.9
66.1
100.0

%
%
%
%

5.67
lb/gal

Instructions for Reporting 2005 Emissions

EXAMPLE (for all sources except Title V sources)
Data Certification Form 2005

Permit number

999999

For EACH pollutant listed, total up all emissions recorded on your General Process and Evaporative Process Forms. Enter these
numbers in column 1, “Totals from Process Forms.” Report any emissions from accidental releases in column 2.
Add the figures in each row across, and enter the result in column 3, “Total Emissions”.
NOTE: “Accidental Releases” reported in column 2 should include all excess emissions
reported to the Department under Rule 140, Section 500.
(1)
Totals from
Process Forms

Summary of 2005 Annual Emissions:

2,113
0
0
0
24,220
9,815
645
7,891

CO
NHx
Lead
HAP&NON
VOC
NOx
SOx
PM10

(2)
+ Accidental
Releases

0
0
0
0
0
0
0
0

(3)
= TOTAL
2005 Emissions

2,113
0
0
0
24,220
9,815
645
7,891

NOTE: Review specific requirements for data confidentiality on page 5. We cannot hold
any data confidential without the required documentation.

TO COMPLETE YOUR EMISSIONS INVENTORY REPORT:
-

Complete the Confidentiality Statement below.
Sign and date this form below where indicated.
Send the original copy of your completed forms: Maricopa County Air Quality Department, Emissions Inventory Unit,
1001 N. Central Ave., Suite 100, Phoenix, AZ 85004. Keep a copy of all forms for your records.

CONFIDENTIALITY STATEMENT:
This annual emissions report contains requests to keep some data confidential.
YES
NO
If you check “YES”, you must submit documentation and meet certain requirements before your data can be deemed confidential.
See enclosed instructions for further details.
NOTE: The Data Certification form must be signed by a responsible company official.
CERTIFICATION STATEMENT:
I declare under penalty of perjury that the data (e.g. inputs, emission factors, controls, and annual emissions) presented herein
represents the best available information and is true, accurate and complete to the best of my knowledge.

___________________________________________________________________________________________________________
Signature of owner/business officer
Date of signature
Telephone number
___________________________________________________________________________________________________________
Type or print full name of owner/business officer
Type or print full title

Maricopa County Emissions Inventory Unit

21

Instructions for Reporting 2005 Emissions

How to calculate an emission fee (for Title V sources only):
1. For each pollutant listed on the “Data Certification/Fee Calculation” form, total up all emissions
recorded on your General Process and Evaporative Process Forms. Enter these numbers in column 1,
“Totals from Process Forms.”
NOTE: While most processes that generate PM10 should be reported on line 5 of the Data Certification/Fee
Calculation form, “[f]ugitive emissions of PM10 from activities other than crushing, belt transfers,
screening, or stacking” (County Rule 280, § 305.2d) are NOT subject to annual emission fees. The most
common occurrences of these PM10-producing activities that are NON-billable are listed below:
SCC codes and description of PM10-producing processes that are NOT subject to emission fees
SCC
30200814
30400737
30500120
30500121
30500134
30500135
30500141
30500143
30500203
30500212
30500213
30500290
30500303
30500608
30500708
30501710
30502007
30502011
30502504
30502507
30502760
30531090
30532007
30704002
31100199
31100299
50100401
50100402
50100403
50100404
50100405

Major Category Subcategory

Facility / Process Type

Process Description

Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Industrial Processes
Waste Disposal
Waste Disposal
Waste Disposal
Waste Disposal
Waste Disposal

Feed Manufacture
Steel Foundries
Asphalt Roofing Manufacture
Asphalt Roofing Manufacture
Asphalt Roofing Manufacture
Asphalt Roofing Manufacture
Asphalt Roofing Manufacture
Asphalt Roofing Manufacture
Asphalt Concrete
Asphalt Concrete
Asphalt Concrete
Asphalt Concrete
Brick Manufacture
Cement Manufacturing (Dry Process)
Cement Manufacturing (Wet Process)
Mineral Wool
Stone Quarrying - Processing
Stone Quarrying - Processing
Construction Sand and Gravel
Construction Sand and Gravel
Industrial Sand and Gravel
Coal Mining, Cleaning, Material Handling
Stone Quarrying - Processing
Bulk Handling and Storage - Wood/Bark
Construction: Building Contractors
Demolitions/Special Trade Contracts
Landfill Dump
Landfill Dump
Landfill Dump
Landfill Dump
Landfill Dump

Storage
Raw Material Silo
Storage Bins: Ferric Chloride
Storage Bins: Mineral Stabilizer
Blown Saturant Storage
Blown Coating Storage
Granules Storage
Mineral Dust Storage
Storage Piles
Heated Asphalt Storage Tanks
Storage Silo
Haul Roads: General
Storage of Raw Materials
Raw Material Piles
Raw Material Piles
Storage of Oils and Binders
Open Storage
Hauling
Hauling
Storage Piles
Sand Handling, Transfer, & Storage
Haul Roads: General
Open Storage
Stockpiles
Other Not Classified
Other Construction/Demolition
Unpaved Road Traffic
Fugitive Emissions
Area Method
Trench Method
Ramp Method

Food and Agriculture
Secondary Metal Production
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Mineral Products
Pulp and Paper & Wood Pdts.
Building Construction
Building Construction
Solid Waste Disposal
Solid Waste Disposal
Solid Waste Disposal
Solid Waste Disposal
Solid Waste Disposal

2. Report any accidental releases in column 2. Add columns 1 and 2 together for each pollutant, and enter
the sum in column 3. Sum lines 1 through 5 together, and enter the total on line 6.
3. Divide your facility's total billable emissions (on line 6) by 2000 to convert pounds into tons. Round to
the nearest ton. Enter this value on line 7. Multiply this number by $13.65, and enter the result on line
8. This is your 2005 emission fee.

Maricopa County Emissions Inventory Unit

22

Instructions for Reporting 2005 Emissions

EXAMPLE (for Title V sources only)
Data Certification/Fee Calculation Form 2005

Permit number

V99999

For EACH pollutant listed, total up all emissions recorded on your General Process and Evaporative Process Forms. Enter these
numbers in column 1, “Totals from Process Forms.” Report any emissions from accidental releases in column 2.
Add the figures in each row across, and enter the result in column 3, “Total Emissions”.
Carefully follow the instructions on lines 6 through 8 to calculate any emission fee owed.
NOTE: “Accidental Releases” reported in column 2 should include all excess emissions
reported to the Department under Rule 140, Section 500.
(1)
Totals from
Process Forms

Summary of 2005 Annual Emissions:

2,113
0
0
7,200

CO
NHx
Lead
PM10 (non-billable; see page 22)

(2)
+ Accidental
Releases

(3)
= TOTAL
2005 Emissions

0
0
0
0

2,113
0
0
7,200

Emissions fees are based on your emissions of the following pollutants ONLY:
1
2
3
4
5
6
7

8

0
24,220
9,815
645
691

HAP&NON
VOC
NOx
SOx
PM10 (billable; see page 22)

0
0
0
0
0

0
24,220
9,815
645
691
35,371

Add “TOTAL” column from lines 1 through 5 ONLY:
Divide the total on line 6 by 2000 (pounds per ton) to get tons, and round the number to the
nearest ton. (Drop any decimal of .499 or less. Increase to the next whole number any
decimal of .500 or more.) Enter the resulting WHOLE NUMBER here.
Multiply line 7 (a WHOLE number) by $ 13.65.
This is your 2005 ANNUAL EMISSION FEE.

18

$

lbs.

TONS

245.70

NOTE: Review specific requirements for data confidentiality on page 5. We cannot hold
any data confidential without the required documentation.

TO COMPLETE YOUR EMISSIONS INVENTORY REPORT:
-

Include a check (made payable to Maricopa County Air Quality Department) for the amount calculated on line 8 above.
Complete the Confidentiality Statement below.
Sign and date this form below where indicated.
Send the original copy of your completed forms, along with any emission fee due to: Maricopa County Air Quality Department,
Emissions Inventory Unit, 1001 N. Central Ave., Suite 100, Phoenix, AZ 85004. Keep a copy of all forms for your records.

CONFIDENTIALITY STATEMENT:
This annual emissions report contains requests to keep some data confidential.
YES
NO
If you check “YES”, you must submit documentation and meet certain requirements before your data can be deemed confidential.
See enclosed instructions for further details.
NOTE: The Data Certification form must be signed by a responsible company official.
CERTIFICATION STATEMENT:
I declare under penalty of perjury that the data (e.g. inputs, emission factors, controls, and annual emissions) presented herein
represents the best available information and is true, accurate and complete to the best of my knowledge.
___________________________________________________________________________________________________________
Signature of owner/business officer
Date of signature
Telephone number
___________________________________________________________________________________________________________
Type or print full name of owner/business officer
Type or print full title

Maricopa County Emissions Inventory Unit

23

Instructions for Reporting 2005 Emissions

Appendix 2.2
Rule Effectiveness Study For Maricopa County Rules 310, 310.01, and 316

RULE EFFECTIVENESS STUDY FOR
MARICOPA COUNTY RULES 310, 310.01, AND 316

Table of Contents
1. Overview......................................................................................................................................... 1
2. Background ..................................................................................................................................... 1
2.1 Study Purpose and Goals ...................................................................................................... 2
2.1.1 Office Inspection Phase ............................................................................................ 2
2.1.2 Field Inspection Phase .............................................................................................. 2
2.2 Sample Size and Rule Effectiveness Calculation ................................................................. 3
3. Study Team ..................................................................................................................................... 4
3.1 Rule Summaries .................................................................................................................... 4
3.1.1 Rule 310 .................................................................................................................... 4
3.1.2 Rule 310.01 ............................................................................................................... 4
3.1.3 Rule 316 .................................................................................................................... 5
4. Field Inspection Phase .................................................................................................................... 5
4.1 Inspection Scoring Protocol.................................................................................................. 5
4.2 Inspection Priority for Rule 310.01 sources ......................................................................... 7
4.3 Rule Effectiveness Calculation ............................................................................................. 8
4.4 Inspection Results ................................................................................................................. 8
4.4.1 Earthmoving Sites..................................................................................................... 8
4.4.2 Vacant Lots/Open Areas ......................................................................................... 10
4.4.3 Nonmetallic Mineral Processing Plants .................................................................. 15
4.5 Summary of Rule Effectiveness Study ............................................................................... 16
4.6 Quality Assurance............................................................................................................... 16
5. Recommendations......................................................................................................................... 16
6. Policy/Procedure Improvements................................................................................................... 17
APPENDIX A..................................................................................................................................... 18
APPENDIX B ..................................................................................................................................... 19
APPENDIX C ..................................................................................................................................... 21

1.

Overview

This rule effectiveness study objective is to quantify compliance with the fugitive dust rules in the
Maricopa County air quality regulatory program and determine how well the rules are achieving the
intended results. Rule Effectiveness is applied to emissions inventory estimates used in State
Implementation Plans (SIP). This evolved from the observation that regulatory programs may be less
than 100 percent effective due to lack of rule compliance or control equipment inefficiency. EPA’s
initial rule effectiveness policy1 was limited to the ozone related pollutants and recommended an 80
percent default rule effectiveness factor. EPA has revised their initial rule effectiveness policy and
replaced it; specifically, the 80 percent default no longer applies and particulate matter related
pollutants are now included.2
EPA has encouraged local agencies and regional planning organizations to include in rule effectiveness
evaluations consideration of inspection frequency, experience with equipment processes as well as
previous rule effectiveness studies that have been conducted to determine current rule effectiveness
factors. In this study the application of these various factors and data from actual compliance
inspections are used to measure how well a rule is achieving its intended results.
This study of the effectiveness of the Maricopa County fugitive dust rules consists of two parts: field
and office inspections. The study team consists of representatives from Maricopa County’s Air Quality
Department (MCAQD) and the Arizona Department of Environmental Quality’s Air Quality Division.

2.

Background

In May 1997, ADEQ submitted the Plan for Attainment of the 24-hour PM-10 Standard – Maricopa
County PM-10 Nonattainment Area, as a SIP revision. This plan demonstrated attainment and
reasonable further progress (RFP) for the 24-hour PM-10 standard at the Salt River air quality
monitoring site by May 1998.
On July 9, 1999, the Maricopa Association of Governments (MAG) submitted to EPA the MAG 1999
Serious Area Particulate Plan for PM-10, demonstrating attainment for both the 24-hour and annual
PM-10 standards for the Metropolitan Phoenix area (Maricopa County), Arizona. A revised plan was
submitted in February 2000. The Revised Plan included an extension request for PM-10 attainment, no
later than Dec. 31, 2006.
The Salt River air quality monitoring site continued to violate the standard and on July 2, 2002
(67 FR 44369), EPA found the SIP for the Metropolitan, Phoenix serious PM-10 area to be inadequate
to attain the 24-hour PM-10 standard at the Salt River monitoring site. Under authority from the Clean
Air Act, EPA required a SIP revision be submitted to correct the inadequacy. A component of this SIP
revision demonstrates attainment at the Salt River monitoring site as a result of the additional controls
adopted by the Maricopa County Air Quality Department to strengthen its dust rule inspection
program.
As of 2006, the Metropolitan Phoenix serious nonattainment area continues to violate the PM-10 24
hour standard. There were 19 exceedances in 2005 and 27 exceedances in 2006.3 Three years without
1

U.S. EPA, Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State Implementation Plan Base
Year Inventories, EPA-452/R-92-010, November 1992.
2
Emissions Inventory Guidance for Implementation of Ozone and Particulate Matter NAAQS and Regional Haze
Regulations. EPA-454/R-05-001, August 2005.
3
a. The 2006 data has been validated by the Maricopa County Air Quality Department
b. Monitoring data for 2006 is Calendar year January through December, 2006.

violations (3-year average) is required at all PM-10 monitors to attain the standard. Because this area
did not attain the PM-10 standards by December 31, 2006, the Clean Air Act requires a demonstration
plan be submitted providing for attainment of the PM-10 air quality standard and five percent annual
reductions of PM10 or PM10 precursor emissions until attainment. The five percent plan is due to
EPA by December 31, 2007.
To prepare the Five Percent Plan, Maricopa Association of Governments (MAG) will use the 2005
PM-10 2007, 2008, and 2009 period emissions inventory prepared, by MCAQD to project the
emissions inventories. The results of the Rule Effectiveness Study will be incorporated into this 2005
PM-10 periodic emissions inventory.
Maricopa County has implemented dust control regulations to help achieve timely attainment of the
ambient standard for PM-10. The following are Maricopa County Regulations that apply to PM-10
control:
Maricopa County
Rule 310
Fugitive Dust Sources
Maricopa County

Rule 310.01

Fugitive Dust From Open Areas, Vacant Lots,
Unpaved Parking Lots and Unpaved Roadways

Maricopa County

Rule 316

Nonmetallic Mineral Mining and Processing

For state permitted portable sources, that operate within Maricopa County, the Maricopa County
Air Pollution Control Regulations are applied in lieu of the state of Arizona’s Administrative
Code Article 6 rules (R18-2-604, 605, 606, and 607). The state of Arizona Air Quality Control
General Permit for Crushing and Screening plants incorporates the requirements of Maricopa
County Air Pollution Control Rule 310 for the dust control plan requirements and Rule 316
for the visible emission limitations for facilities that operate in Maricopa County.
2.1

Study Purpose and Goals

The purpose of this rule effectiveness study is to quantify the control strategy efficiency as
described in the rules of MCAQD and determine if these rules are adequate. This study was
conducted according to EPA guidance provided for states and local agencies on how to review
and measure the efficiency of a control strategy intended to progress towards reaching air
quality goals. To accomplish this goal, a two part study was conducted comprised of field and
office inspections and focusing on the compliance and enforcement of Maricopa County
Rules 310, 310.01, 316.
2.1.1

Office Inspection Phase

The office investigation phase focused on rule content and the internal policies and procedures
that affect how rules are implemented and enforced, such as regulatory enforceability, inspection
procedures, training, and agency resource management.
2.1.2

Field Inspection Phase

In the field inspections conducted as part of this rule effectiveness study,
the study team visited sites subject to Maricopa County Rules 310, 310.01, and 316. The study
group identified which rules apply, which specific parts of the rule apply to the site, the type of site
(earthmoving, vacant lots, nonmetallic mineral processing), the compliance status of the site and if any
compliance notifications would be issued. Inspections occurred consistent with current department
c. Exceedances are defined as number of days in 2006 where at least one monitor exceeded the 24hr PM-10 Standard

schedules. If a level 1 inspection was planned, then that was carried out. If a level 2 inspection was
planned, then that type of inspection occurred. The goals of this phase were to determine whether
MCAQD and ADEQ programs are adequate to:
1) Determine compliance and
2) Deter, detect and correct any instances of noncompliance.
2.2

Sample Size and Rule Effectiveness Calculation

The number of inspections determines sample size of the study. There is a very large number of Rule
310, 310.01, 316 inspections sites in Maricopa County so it is not practical to visit each site for this
study. Since we can not visit all the inspection sites in the county, we can randomly select according
to statistically sound procedures, a small number of sites that provides inference from the sample
drawn, to the entire population of inspections. This process used in this study is detailed in EPA’s
‘Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State Implementation Plan
Base Year Inventories’, Appendix D 4.
There are three distinct categories of inspection sites:
- Maricopa County Rule 310

Fugitive Dust Sources

- Maricopa County Rule 310.01

Fugitive Dust From Open Areas, Vacant Lots, Unpaved
Parking Lots and Unpaved Roadways
Nonmetallic Mineral Processing.

- Maricopa County Rule 316

EPA guidance recommends for each category, a 90 percent confidence interval and a sample error of 5
percent, that should not exceed 10 percent. These parameters are listed in Table D-1 of EPA’s
guidelines (Appendix C of this report). Referring to this table, assuming the above parameters, we can
determine what sample size is needed for each population category after we calculate the standard
deviation of each sample group.
In summary:
The variance or variation of a sample is reflected in the standard deviation.
Since we do not have an estimate of the standard deviation from past surveys of Rule 310, Rule 310.01
inspection sites, we are required to calculate one. According to the EPA rule effectiveness guidance,
the standard deviation is calculated from ten randomly chosen inspection sites from each category.
From these initial inspections, the calculated standard deviation for each category is used to determine
adequate study sample size. The standard deviation reflects the amount of variation of the inspection
site compliance with existing rules. In this study, the variation ranged from total compliance to noncompliance. After adequate study sample size was determined, additional inspections were scheduled
to comprise a statistically sound study sample size.
The rule effectiveness for Rule 316 sources was estimated following the recently updated EPA
guidance5, with factors that are most likely to affect rule effectiveness. These factors are listed in
Appendix A. EPA grouped likely responses to these factors into rule effectiveness ranges, such that

4

U.S. EPA, Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State Implementation Plan Base
Year Inventories, EPA-452/R-92-010, November 1992.
5

US EPA, Emissions Inventory guidance for Implementation of Ozone and Particulate Matter National Ambient Air
Quality Standards (NAAQS) and Regional Haze Regulations, EPA, August 2005.

more positive responses to a number of the factors will lead towards selection of a higher RE value,
whereas more negative responses will direct one to select an RE value from a lower range.
Rule Effectiveness factors are only applied to those emissions estimates where a control device or
control technique is used The Maricopa County fugitive dust rules define a pollution control
technique; therefore emission estimates of sources regulated by these rules would need to be adjusted
for rule effectiveness.

3.

Study Team

The study team is composed of personnel from the MCAQD and the Arizona Department of
Environmental Quality (ADEQ). Both the Compliance and Planning-Analysis sections from the
Maricopa County Air Quality will participate.
The study team inspected three types of facilities: Nonmetallic mineral processing, earthmoving
sources, and vacant lots. The Quality Assurance/ Supervisor insured consistency of the data collection.
The Study Team consists of three members:
- Maricopa County Quality Assurance/ Supervisor
- Maricopa County earthmoving, dust or small source inspector or
ADEQ Compliance Inspector
- Maricopa County Planning & Analysis Observer
3.1

Rule Summaries

The following includes a summary of the Maricopa County fugitive dust rules included in this study.
3.1.1

Rule 310

Rule 310 applies to all dust generating operations including open areas, vacant lots, unpaved parking
lots, and unpaved roadways which are located at sources that require a permit under Maricopa County
Rules. Normal farm cultural practices as defined under Arizona Revised Statutes (ARS) §49-457 and
ARS §49-504.4 and are exempt from this rule. These sources are subject to the ADEQ’s PM-10
General Permit (AAC R18-2-611) established under Arizona Revised Statutes Section 49-457 and
were not be subject to this study. Fugitive dust sources are required to keep
dust stabilized and control measures implemented at all times and visible fugitive dust emissions shall
not exceed a 20% opacity. Measures include stabilization requirements, installing signs restricting
trespassing, applying gravel or paving unpaved parking lots, applying water, gravel, or dust
suppressant to haul roads, pre-watering work sites, constructing wind barriers and establishing
vegetative cover. Earthmoving operations must submit a dust control plan if the project is equal
to or greater than 0.1 acres. Specific work practices for different types of activities are described
in the rule. Compliance shall be determined by conducting opacity observations, stabilization
determinations, observing implementation of controls and recordkeeping.
3.1.2

Rule 310.01

Rule 310.01 applies to open areas, vacant lots, unpaved parking lots and unpaved roadways which are
not regulated by Rule 310. Any open area or vacant lot that is not defined as agricultural land and is
not used for agricultural purposes according to ARS § 42-1251 and ARS § 42-1252, and normal farm
cultural practices as defined under Arizona Revised Statutes (ARS) §49-457 and ARS §49-504.4, is

subject to this rule. The rule outlines control measures and stabilization limitations required for
different dust source activities such as preventing vehicular access to open areas and vacant lots,
establishing vegetative cover, uniformly applying and maintaining surface gravel, and application of
dust suppressant. Stabilization and recordkeeping are required to be maintained.
3.1.3

Rule 316

Rule 316 regulates particulate matter emissions from nonmetallic mineral processing and rock product
processing plants. Opacity and emission limits, stabilization, equipment design, and control measures
are outlined for the different type of operations and stack and fugitive dust emissions. For those
sources with air pollution control equipment and/or monitoring equipment, an Operation and
Maintenance Plan is required. This rule requires recordkeeping of daily operations and control device
data. Additionally a facility with a permitted capacity of 25 tons or more of material per hour shall
have in place a Fugitive Dust Control Technician or designee. The owner and/or operator of a
nonmetallic mineral processing plant and/or a rock product processing plant shall implement the
fugitive dust control measures described in rule 316, section 306.

4.

Field Inspection Phase

There are three types of field inspections in this study. The first two require the study team members
to conduct inspections at earthmoving sites and vacant lots. The third requires the study team to
inspect stationary permitted sources.
4.1

Inspection Scoring Protocol

Study scoring for the rules 316 and Rule 310, 310.01 are prioritized according to significance of
creating emissions. For example, an opacity limit has a direct correlation to pollution being emitted,
where recordkeeping requirements are administrative in nature and may have less direct affect on
emissions. This is similar to the approach taken in EPA’s Rule Effectiveness Guidance: Integration of
Inventory, Compliance and Assessment Applications.6
The scoring system observes:

No violations observed on site;
Notice to Correct; and
Notice of Violations.

Points are assigned as follows:
No violations observed on site - Maximum 1.0 point;
All violations: Notice of Violation or
Notice to Correct - zero (0) points;
Administrative compliance is only scored if there are no emissions violations. A complete
administrative failure, such as failure to obtain a dust permit is considered a violation and is a zero
score. A partial administrative failure is not included in the scoring if there were no emissions
violations observed at the site. Both MCAQD Quality Assurance/ Supervisor and inspector reports
were summarized but final study results were compiled from the Supervisor reports only.

6

U.S. EPA, Office of Air quality Planning and Standards, Rule Effectiveness Guidance: Integration of Inventory,
Compliance and Assessment Applications, EPA-452/4-94-001, January 1994.

Table 4.1.1: Rule 310 Rule Effectiveness Violations
Emission Violations
Condition of Areas not being worked
Stabilize storage piles
Water:
ƒ Available
ƒ Use
Track out / Track out device
Haul Roads
Not follow dust plan
Work Practices:
ƒ dumping
ƒ tarping
ƒ >50 ft.track out/ clean up end day
ƒ bulk materials
Administrative Violations
Lack of records
Permit not current / on Site
Records not on site
No dust plan posted
Lack of Dust Plan

Table 4.1.2: Rule 310 Rule Effectiveness Score System
Compliance Status
Notice of Violation (NOV)
Notice to Correct (NTC)
Administrative Violation - NOV or NTC
No violations Observed

Points
0
0
1.0 - If no observed emissions
violations
1.0

A similar point system is used for Rule 310.01 scoring. When non-compliance is observed at a lot or
open area, a letter is sent to the parcel owner requesting correction. After receipt of this letter, the
parcel owner has 60 days to institute control measures, establish stabilization, or contact MCAQD. The
owner has 14 more days to comply and/or contact the MCAQD offices before a Notice of Violation
(NOV) is issued.
The study scoring for Rule 310.01 is the same as described above where either No Violations are
observed (1.0) or Violations exist (0). Stabilization test methods are completed to determine
violations in accordance with rule requirements. If the inspection site passes one of the five
stabilization test, then the site is scored as "no violations are observed".
Table 4.1.3 Rule 310.01 Rule Effectiveness Score System
Results of Stabilization Tests
Passed
Failed

Points
1.0
0

TABLE 4.1.4 Rule 316 Violation
Emissions Violations
Standards
Stack Emissions
Operations or Process
Trucks Dumping
O&M Requirements
Submit Permit
Permit maintained and Onsite
Comply with Permit actions & Schedules
Schedules
Recordkeeping Requirements
General Data/Hours of Operations

4.2

Inspection Priority for Rule 310.01 sources

The MCAQD inspects vacant lots, open areas and unpaved parking lots based on following criteria:
1. Citizen complaints.
2. Located within Salt River Study Area.
3. Open areas with soil textures that may consist of high silt content and increased wind
erosion potential.
4. Areas that are in excess of ten acres.
5. Areas outside the Salt River Study area but within the border of the Maricopa County
PM10 nonattainment area.
6. Areas located in close proximity to schools, health care facilities, assisted care facilities,
residential neighborhoods, parks, etc.
7.
The goal of the inspection program is to proactively inspect vacant lots/ open areas and unpaved
parking lots based on these inspection priorities. Before May 2006, the inspection program was
exclusively based on citizen complaints. Over 100,000 vacant lots/open areas and an unknown number
of unpaved parking lots exist within Maricopa County and will require at least one compliance
inspection. Utilizing data loaded into Permits Plus from the County Assessor records, the vacant
lots/open areas are identified and then inspection schedules and routes are determined. Further,
utilizing GPS readings provides map locations of these areas for planning and monitoring. MCAQD
vacant lot/open area program goal is to complete 5,200 vacant lot inspections per year (approximately
3,100 inspections of vacant parcels > 10 acres; and 2,100 inspections of vacant parcels < 10 acres).
Initial focus is on vacant parcels > 10 acres. The program also provides for complaint processing from
telephone as well as internet based submittals.

4.3

Rule Effectiveness Calculation

As referenced earlier in the report, the number of inspection sites in the sample size was determined by
calculating the standard deviation of the initial ten random inspections, based on EPA guidance.7
Table D-1 referenced in EPA guidance correlates confidence level, sample error, standard deviation,
and sample size and is listed in Appendix C of this report.
The standard deviation for both Rule 310 and 310.01 from the first 10 sites inspected was 24%.
The standard deviation calculated from 10 initial Rule 310 and Rule 310.01 inspection sites with a 90
percent confidence level and a sample error of 5%, determined that a sample size of at least 63 sites
was required. Sixty-three Rule 310 sites and 124 Rule 310.01 sites (many sites have multiple parcels)
were inspected. The first 47 Rule 310.01 inspections were conducted over a three week period. The
remaining seventy-seven inspections were conducted during the last six months of 2006. Inspections
conducted over a six month time period were required so as to obtain a sample of inspections that
represents the average Maricopa County ambient weather conditions.
4.4

Inspection Results

4.4.1

Earthmoving Sites

Ten earthmoving sites were randomly chosen for inspection during the months of July - August, 2006.
Fifty-three additional earthmoving sites were inspected during September through November 2006.
The following table summarizes what was observed at each site and if any corrective action was taken.
Two types of corrective actions were taken: Notice to Correct (NTC) and Notice of Violation (NOV).
The NOV is the most serious corrective action.
Table 4.4.1 List of Inspected Earthmoving Sites

7

Date

Permit ID

Site

Address

7/19/2006
9/27/06
7/17/2006
7/17/2006
7/17/2006
7/17/2006
7/17/2006
7/17/2006
7/17/2006
7/18/2006
7/18/2006
9/21/2006
9/21/2006
9/21/2006
9/26/2006
9/26/2006

E062984
EO54480
E061115
E053622
E060901
E054144
E054289
E062849
E062311
E054191
E060726
E062535
E063893
E063372
E063550
E054400

Ardavin Builders
Aston Woods
Gierczyk
Quailwood Const.
Canterra Contract
Concord Companies
Catalina Custom Hms
Markham Contract.
Zacher Homes
Veneto Inc.
Layton
Lehi Meadow
Larry Boblitz
TRC Bellatrix
Pulte Homes
SouthwestGas

16705 E. Ave. of Fountains
Westar/184 Ave Goodyear
17275 N. Litchfield Rd.
13370 West Van Buren
SWC Maricopa Rd & Miller Rd
708 W. Baseline Rd
5009 E. Road Runner Rd
2565 E. Southern Ave
119 W. Maryland
19th Ave & Vineyard
Happy Valley & Lake Pleasant
2354 E. Meadow Mesa
4728 E. Virginia Mesa
Val Vista & Thomas Mesa
200 N. 95th Ave Buckeye
Jackrabbit Buckeye

Violation
Observed
No
No
No
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes

Rule310
Section
NTC/ NOV
Issued
*
*
308
306, 308
306, 308
*
308
*
306, 308
306, 308
301,302,308
302
*
308
401

Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State Implementation Plan Base Year
Inventories, U.S. EPA, EPA-452/R-92-010, November 1992.

Date
7/26/2006
9/28/2006
9/28/2006
9/28/2006
9/20/2006
9/20/2006
9/19/2006
9/19/2006
9/20/2006
9/19/2006
9/19/2006
9/19/2006
9/19/2006
9/19/2006
9/21/2006
9/21/2006
9/19/2006
9/19/2006
9/19/2006
9/19/2006
9/19/2006
9/20/2006
9/20/2006
9/20/2006
9/20/2006
9/20/2006
9/21/2006
9/21/2006
9/21/2006
9/21/2006
9/21/2006
9/26/2006
9/26/2006
9/26/2006

Permit ID
E063293
E061166
E060852
E054565
E061304
E061294
E060380
E060641
E060974
E054279
E060071
E060073
E060026
E061280
E062154
E055258
E063901
E063039
E063922
EO54234
E061531
E062768
E061984
E063069
E060500
E060025
E063747
E063029
E061488
E061056
E054436
E060334
E061805
E063979

Site
Ames Const.
Trend Homes
HBT Const.
KB Homes
Colorado Stru
Colorado Stru
Buzz Oats
Hallcraft Homes
Summit Bldrs
MT Buildiers
Morrison Hms
Morrison H
Sundt.
Randall Martin
Bill Dennis
Willow Park
Design Bldg
Beazer Hms
Meritage Homes
Meritage Homes
Morison Homes
Maracay Homes
Nickle Contr
Double AA
Laguna Homes
Meritage Homes
Austin Bridge
Starpointe
Sunstate Building
Scott Homes
Carlson Mas
Eagle Homes
Engle Homes
Stnd Pacific Homes

9/26/2006

E063559

Stnd Pacific Homes

9/26/2006
9/28/2006
9/28/2006
9/28/2006
11/1/2006
11/1/2006
11/1/2006
11/1/2006
11/6/2006
11/6/2006
11/6/2006
11/6/2006
Total

E060896
E063571
E062060
E063832
E062927
E055477
E061981
E061791
E063905
EO63799
EO64332
EO63826

B & D Ericks
Northld Res
Heartland Exp
Renaissance
Sundt.
Russell Granors
LGE Corporation
Forte Homes
Gemcor Homes
SGL Custom Homes
CGS109 - Magee
Monza Const.

Address
Perryville/Northern Waddell
Citrus/Bell Surprise
Bell/Citrus Surprise
Bell/Citrus Surprise
1825 W. Bell Rd. Phoenix
1525 W. Bell Rd. Phoenix
4707 W. Camelback Phoenix
75th Ave/ Glendale Glendale
8220 N. 23rd Ave Phoenix
11120 W. Van Buren Avondale
107th Ave/Becker Avondale
103 S. 110th Ave Avondale
115 Ave/Van Buren Avondale
Roosevelt Park Avondale
3435 N. 91st Pl. Mesa
1928 E. Riverdale St. Mesa
326 S. 353 Rd Tonopah
SR 85/ I -10 Buckeye
Rainbow/Yuma Rd Buckeye
228 Ave/ Moonlight Path Buck
Yuma/ Watson Buckeye
Dobson/ German Chandler
Ryan/ Hartford Chandler
German/ Gilbert Changler
24410 S. 120 Way Chandler
Hunt HWY/AZ Ave Chandler
I - 10 / Ray Rd Phx-Chandler
16160 S. 50 st. Phoenix
685 W. Elliott Tempe
Rural / Elliot Tempe
1901 E. 5th St Tempe
395 E. Baseline Phoenix
2901 E. Baseline Rd Phoenix
67th/Baseline Laveen
Meadow Loop W/ Beverly
Laveen
S. Mountain Rd/ 7th Ave
Phoenix
4000 W. Mohave St. Phoenix
4555 W. Mohave St Phoenix
4747 W. Buckeye Rd Phoenix
1636 W Alameda Tempe
1845 E University Tempe
4040 W EarHart Chandler
4452 W Kitty Hawk Chandler
1121 E. Birdwood Chandler
3660 S Nash Way, Chandler
SWC Pecos& Hamilton Gilbert
2920 E. Germann Rd Gilbert

* Indicates there is no violation observed during this inspection.

Violation
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
No
No
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
No
Yes
Yes
No
No
Yes
Yes
Yes

Rule310
Section
NTC/ NOV
301, 306,308
*
307
*
302
*
307
302, 306
401
307
307, 503
307, 503
*
302, 308
*
*
302
306, 308
306, 401, 503
308
*
307
*
302, 306
401
306
*
302, 306, 308
306, 308
*
*
302, 308
302
302

Yes

401

No
No
Yes
Yes
No
No
Yes
No
Yes
Yes
Yes
Yes

*
*
306, 308
301, 308
*
*
302. 308
*
302,306,308
302, 306
302, 306, 308
306
63 Inspected Sites

The scoring system described in section 3.1 was applied to each inspection site. Each site has 1.0
possible point. If a corrective action is required, then the score is zero. The status of the site is either
‘yes’ a violation was observed or ‘no violations were observed’ for the site.
Table 3.4.1 above summarizes 63 Rule 310 inspection sites. There were violations observed at fortyone (41) of these sites. Ten (10) of these violating sites were administrative violations only and
emissions violations were not observed. The ten (10) administrative only violations were excluded in
the final count of violating sites because of the absence of an emission violation resulting in the final
count of violating sites totaling thirty-one (31).
The resulting rule effectiveness for all Rule 310 sites inspected is 51% (32/63 = 51%), where
conversely 49% of the sites had an observed a violation (31/63=49%).
4.4.2

Vacant Lots/Open Areas

Ten vacant lots were randomly chosen for inspection subject to Rule 310.01 during the months of
August - September 2006. Applying the standard deviation calculated from these 10 initial Rule 310.01
inspection sites, to the matrix of 90 percent confidence level and sample error of 5%, the sample size
should be at least 63 sources. The following table lists the compliance status of each Rule 310.01 site
as determined by the test methods required in Rule 310.01.

Table 4.4.2 List of Inspected Vacant Lot Sites
Site
AO10318
"

Date
9/22/2006
9/22/2006

"
"
A010318
"
"
A010318
"
AO10203
A010203
A0102
A010203
BO20115
BO20115
BO20114
BO20122
B020122
A0102
A0102
A0102
A0102
A0102
DO20730
"
DO20732
DO20731
A06033100
21151003L
21151033L
21153049
21181001
D01061200
D01061200
AOBO409
3N403Sec 7
3N403Sec 7
T03R04506
T03R04506
A031406
A205040900
A03040700
A2030407
A010535
A010522
A010523
A010523
A010523

9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/29/2006
9/29/2006
9/29/2006
9/29/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
10/3/2006
10/3/2006
10/3/2006
10/3/2006
10/3/2006
9/27/2006
9/27/2006
9/27/2006
9/27/2006
9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/29/2006
9/29/2006
10/2/2006
10/2/2006
10/2/2006
10/2/2006
10/2/2006
10/2/2006
10/2/2006
10/2/2006
10/2/2006
9/27/2006
9/27/2006
9/27/2006
9/27/2006
9/27/2006

Parcel #
105-03-078A
105-03-078H
105-02-123
105-02-124
105-02-122
105-02-121
105-02-125
105-03-078F
105-03-078B
105-03-078G
105-03-0780
105-03-078C
106-10-066
106-10-068
111-34-102
106-10-067
502-62-011F
501-62-008C
501-63-013D
501-68-414B
501-68-012S
106-10-065
106-10-047
106-10-048
106-10-046
106-10-045
304-90-375J
304-90-375F
304-90-017G
304-89-013-U
21151003D
A06033100
A06033100
A05030500
A05030200
30416004G
30405985
21561004A
21570356
21570355
21531007-8
21531007-7
21524001
21564005J
21570354
21570357
13913244A
13861080
13822098
13827096
13827095-A

Address
1527 W. Buckeye
"
1235 S. 15 Ave. Phoenix
"
"
1233 S. 15th Ave. Phoenix
1241 S. 15th Ave Phoenix
1227 S. 15th Drive Phoenix
1231 S. 15th Drive Phoenix
15th Dr/Buckeye Phoenix
1225 S. 15th Dr. Buckeye
1229 S. 16Ave Phoenix
623 N. 37th Dr. Phoenix
611 N. 37th Dr. Phoenix
City of Ph - 3rd Ave Portland
617 N. 37th Dr. Phoenix
Litchfield/Camelback Litchfield
Litchfield/Camelback Litchfield
Dysart/Camelback Maricopa
Litchfield/Wigwam Litchfield Park
Litchfield/Wigwam Litchfield Park
629 N. 37 Dr, Phoenix
3734 W Fillmore Phoenix
3740 W Fillmore Phoenix
3728 W Fillmore Phoenix
3722 W Fillmore Phoenix
Power/Riggs Queen Creek
"
25518 S 192 Pl Maricopa Co
Power/San Tan Maricopa Co
36822 N 17th Ave Phoenix
36824 N.17th Ave Phoenix
11th & Maddock Phoenix
7th Ave &Cloud Rd. Phoenix
32nd St & Cloud Phoenix
SW Power/Guadalupe Gilbert
NE Power/Guadalupe Gilbert
62 st / Thunderbird Phoenix
NWC Tatum/Nesbet Phoenix
NWC Tatum/Nesbet Phoenix
NEC Steuer T/Jerry Florence
NEC Steuer T/Jerry Florence
SEC Paradise.40th St Phoenix
5880 E Thunderbird Phoenix
15002 N. Tatum Phoenix
15030 N. Tatum Phoenix
1511 S. Mesa Dr Mesa
NE Pasadena Mesa
139 S. Mesa Dr. Mesa
2nd Ave/ Mesa Dr Mesa
2nd Ave/ Mesa Dr Mesa

Violation
Observed
No
No
No
No
No
Non-Reg
Non-Reg
Non-Reg
Non-Reg
Non-Reg
Non-Reg
Non-Reg
No
No
Yes
No
No
No
No
No
No
No
No
Non-Reg
No
No
No
No
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No

Site
A010523
A010523
A010523
A010523
A01073500
A01073500
A01073500
A01072600
A01073400
A01073400
A01073400
A01073400
A01073400
A01073500
1073500
A010786
A01073400
A1073400
A01073400
D010304
D010304
D010304
D010304
D010304
A01070600
A010706
D01061200
D01030400
A06033100
A06033100
A06033100
A050305
A05030200
A010523
A01053500
A01052300
A010522
A01052300

Date
9/27/2006
9/27/2006
9/27/2006
9/27/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
9/18/2006
10/3/2006
10/3/2006
10/3/2006
10/3/2006
10/3/2006
9/29/2006
9/29/2006
9/29/2006
10/3/2006
9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/22/2006
9/27/2006
9/27/2006
9/27/2006
9/27/2006
9/27/2006

A01052300
B0204Sec28
B0204Sec28
B02032800
A29040200
"
"
"
"
"
"
"
"

9/27/2006
10/3/2006
10/3/2006
10/3/2006
9/27/2006
"
"
"
"
"
"
"
"

Parcel #
13827097
13827064A
13827065A
13827066A
22081002D
220-81-002D
22081004B
22071001Q
22080007Q
22080001M
22080001P
2208007-Q
22080007P
77081004B
22081002D
22071001Q
22680001P
22080001M
22080007N
33019023D
30019023E
30043019M
30043007A
30062066A
30405977B
30405977A
30416004G
30019023D
21151003D
21151003C
21151933C
21153049
21181001
13827096
13913244A
13827098
13861080
13827095A
13827064A
13827065A
13827066A
11932002A
11930076
16328048A
20027005P
20027010
200005W
20027005P
20027005Q
20027005T
20027005G
20027005K
20027005L

Address
2nd Ave/ Mesa Dr Mesa
2nd Ave/ Mesa Dr Mesa
2nd Ave/ Mesa Dr Mesa
2nd Ave/ Mesa Drive Mesa
SWC Signal Butte/Southeast Mesa
SW Signal Butte/Southeast Mesa
SW Signal Butte/Southeast Mesa
NW Signal Butte/Southeast Mesa
SW Crimson/SO Mesa
SW Ellsworth/Southeast Mesa
SW Ellsworth/Southeast Mesa
1330 S. Crismon Mesa
S Signal Butte/South Mesa
SW Signal Butte/SE Mesa
SW Signal Butte/Southeast Mesa
NW Signal Butte/Southeast Mesa
SE Ellsworth/Southern Mesa
SE Ellsworth/Southern Mesa
SW Crimson/Southern Mesa
SW 7th St/Baseline Phoenix
SE 7th St/Baseline Phoenix
SW 7th St/Baseline Phoenix
SW 7th St/Baseline Phoenix
Central/Dobbins Phoenix
NE Power/ Guadalupe Mesa
2650 S. Power Mesa
SW Power/Guadalupe Mesa
SW 7th St/Baseline Phoenix
36822 N 17th Avenue Phoenix
36824 N. 17th Avenue Phoenix
SE 11th Ave/ Maddock Phoenix
SE 7th Ave/Cloud Phoenix
SW 2411 E Cloud Phoenix
NE Mesa dr/2nd Avenue Mesa
SE Mesa Dr/Holmes Mesa
NE Mesa dr/2nd Avenue Mesa
NE Pasadena/2nd Street Mesa
NE Mesa Dr/2nd Avenue Mesa
Adjoining parcels
"
"
3109 N 16th Street Phoenix
3435 N 16th Street Phoenix
4249 N. 16th Street Phoenix
20000 N 57th Drive Glendale
"
"
"
"
"
"'
"
"

Violation
Observed
No
No
No
No
No
No
No
No
Yes
No
No
Yes
No
No
No
No
Yes
Yes
No
No
No
No
Yes
No
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
No
Yes
No
No
No
No
No
No
No
No
No

Date
"
"
"
9/27/2006
9/22/2006
9/22/2006
"
9/22/2006
9/18/2006

Parcel #
20027005U
20027005V
20027005N
20027005M
21526031
21531001M
21531007
21531008
50526005A

Address
"
"
"
"
4102 E. Greenway Phoenix
"
"
"
US 60 & El Recreo Phoenix

Violation
Observed
No
No
No
No
No
No
No
No
No

A010624
"
A010624
A010601

9/18/2006
9/18/2006
9/18/2006
10/2/2006
10/2/2006
10/2/2006
10/02/2006
9/29/2006
9/29/2006
9/29/2006
9/29/2006

"
"
NW US60/Mariposa Dr. Phoenix
Hayden/101 Freeway Phoenix
NE 92st/Pinacle Peak Scottsdale
NE 92st/Pinacle Peak Scottsdale
9456 E. Pinnacle Peak Scottsdale
6762 E. Albany St. Mesa
206 N Power Rd Mesa
214 N. Power Rd Mesa
Power/Heather Dr Mesa

No
No
No
No
No
No
No
Yes
Yes
No
No

3/2S/6E
4/1S/GE
17/15/GE
DO10509
TINR2E Sec 22
TIN2E14
67th Ave &Chester
A03032400
A010211
A010212
A010309
A010214
A040427
A040428
A10040300
A04040200
1 IN 1E
9 1N 1E
13-2S-Se
D010526
18 1N 1E
A02010700
A03031500
D0206500
A050406
A03033300
A050406
14 IN 1E
30-2S-5E
A030319
A02023400

5/23/2006
6/7/2006
6/30/2006
7/17/2006
8/15/2006
8/17/2006
8/22/2006
8/24/2006
8/29/2006
8/29/2006
8/31/2006
8/31/2006
9/21/2006
9/21/2006
9/28/2006
10/4/2006
10/12/2006
10/12/2006
10/12/2006
10/16/2006
10/16/2006
10/17/2006
10/19/2006
10/20/2006
10/23/2006
10/23/2006
10/23/2006
10/23/2006
10/31/2006
11/1/2006
11/2/2006

50526011
50526003C
50534049
21231966
21705017
21705018
21705013B
14159017
14159018
14159019
14171158J
14171158K
304-52-041
30409- 956
304-22-170
302-04-006-Q
104-61-002-D
10512015
201-12-816-A
166-36-004-Q
10958108
109-49-071A
116-48-001A
10510011A
215-04-037
212-32-953
212-15-438
205-07-076
102-41-297-A
101-08-012-L
303-43-4-529
302-84-001M
101-17-169
102-59-001-T
166-40-298-J
304-78-014 V
211-48-083
160-11-012
211-48-066
104-32-013-C
303-50-001-4
159-15-047-F
108-11-058

16202 E. Claxton Gilbert
Val Vista-Baseline Gilbert
1240 E Sagebrush Gilbert
SE Vineyard/Baseline Mesa
43rd/ Lower Buckeye Phoenix
1817 S 35th Avenue Phoenix
64th Ave Peay Dr Phoenix
10801 N. 32 St. Phoenix
3402 W. Buckeye Phoenix
19th Ave/Madison Phoenix
1451 E. Washington Phoenix
2916 W. Yuma Phoenix
Scottsdale/Mayo Phoenix
56th St/ Mayo Phoenix
N 23 St/E Avenida Del Sol Phoenix
4500 Block W. Saddlehorn Phoenix
7309 W. Lynwood Phoenix
91Ave/Adams Tollison
Cooper/Queen Creek Chandler
215 N. McQueen Chandler
111Ave/4 St. Avondale
Glen Harbor Blvd Glendale
1802 E Larkspur Phoenix
24620 S. 182 Pl Gilbert AZ
Lt 1 La Ventanas Cave Creek
1247 E. Griswold Phoenix AZ
48 St. Carefree HWY Phoenix AZ
83Ave Buckeye Maricopa AZ
Sun Lakes Blvd/Riggs Sun Lakes
1326 W. Becker Lane Phoenix AZ
3630 W Roanoke Ave Phoenix AZ

No
No
No
No
No
No
No
No
Yes
Non-reg
No
No
No
No
Yes
No
No
Non-reg
No
No
Non-reg
Yes
Yes
Yes
No
No
No
Yes
No
No
No

Site
"
"
"
A29040200
A030406
A030406
"
"
US 60 & El Recreo
US 60 & El
Recreo
US 60 & El Recreo
Mariposa & US 60

Site
D01060900
A010309
A0290403
A02022700
D010509
A02022600
D010509
D02073100
D010529
D02073200
01 01 19
A040424
A02020300
D020533
D010521
A040424

Date
11/2/2006
11/3/2006
11/6/2006
11/9/2006
11/9/2006
11/13/2006
11/14/2006
11/15/2006
11/15/2006
11/15/2006
11/15/2006
11/16/2006
11/16/2006
11/16/2006
11/16/2006
11/16/2006

Parcel #
304-09-014
116-47-084
200-24-013A
107-33-054
302-88-989
108-04-202
302-88-989
304-89-066-U
302-48-830-B
304-90-417
101-23-004-A
212-31-976
151-04-080
303-59-972-C
302-23-095
212-31-977

Address
159 E. Elliot Rd Gilbert AZ
1302 E. Jefferson Phoenix AZ
19812 N. 53 Ave Glendale AZ
35 Ave/Indian School Phoenix AZ
Arizona Ave/Chilton Chandler
3010 Grand Ave Phoenix AZ
3300 Arizona Ave Chandler AZ
Chandler Heights Citrus Unit 3127
Alma School/Ivanhoe Chandler
NEC Sossaman/Happy Rd City
Avondale Blvd/ Broadway Avondale
Pima/ Deer Valley Rd Scottsdale
7750 N 35 Ave Phoenix
25558 S Arizona Ave Chandler
Arizona/Orchid Chandler
Pima/Deer Valley Scottsdale

Violation
Observed
No
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
Yes
No
No
No
Yes
No

D020503
A010206
D020522
D01071100
A0303225
A040109
A040123
A0404109
A03020300
A03020700
A02023100
D01070400

11/21/2006
11/21/2006
11/21/2006
11/21/2006
11/22/2006
11/27/2006
12/27/2006
11/27/2006
11/27/2006
11/27/2006
11/28/2006
11/28/2006

303-28-022A
103-23-003-P
303-46-011-C
304-01-006-E
165-15-003-A
210-16-288
200-20-006-G
201-16-299
207-14-045
200-70-004-T
103-13-695304-03-009N

800 E. Germann Rd Chandler
67Ave/Roosevelt Phoenix
McQueen/Chandler Heights Chandler
NW Signal Butte/Elliot Mesa
3937 E. Ocotillo Phoenix
23416 N Cunino Rancho Peoria
21000 N 75 Ave Glendale
MCR 58440 Peoria
4101 W Waltann Lane Phoenix
76 Ave/ Thunderbird Glendale
59 Ave McDowell Phoenix
Joslyn/Guadalupe Mesa

No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
No
No

D020522
A02023500
A02023300
B030113
A030206
D010622
A01 02 22
A040207
A060215
D020525
A060215
A03021000
D020525
D02070400
A02022700
A010219
A060328
A02031800
A010211
D010626

11/28/2006
11/29/2006
11/29/2006
12/1/2006
12/1/2006
12/1/2006
12/4/2006
12/5/2006
12/6/2006
12/6/2006
12/6/2006
12/11/2006
12/11/2006
12/12/2006
12/12/2006
12/15/2006
12/13/2006
12/15/2006
12/21/2006
12/4/2006

303-46-002-A
108-26-115
103-51-143
200-85-972-A
20051007E
304-27-016-K
102-19-007-V
20112004Q
203-03-003
303-55-161
203-03-034
207-13-003-B
303-55-165
304-62-011-C
107-33-026-F
104-57-001-K
2111-49-027
156-38-029
109-40-001M
304-39-016W

450 E Chandler Heights Chandler,
32 Ave/McDowell Phoenix
4733 W. Thomas Phoenix
115 Ave/El Mirage
59 Ave/Paradise Lane Phoenix
Higley/Ray Gilbert
4115 N. 91 Ave Phoenix
67 Ave Pinnacle Peak Phoenix
Anthem Common Park Lot 2 Phoenix
2331 E Cedar Pl Chandler
4124 W Fortune Dr Phoenix
15024 N 37 Phoenix
2452 E Elmwood Chandler
88 st/ Woodland Ave Mesa
3515 W. Clarendon Phoenix
63 Ave/Broadway Phoenix
1- St/ Joy Ranch Rd Phoenix
1604 W. Pasadena Phoenix
3101 W. Washington St Phoenix
Higley/Ray Rd Gilbert

Yes
No
No
Yes
Yes
No
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No

Yes = Violations were observed
No = No Violations were observed during this inspection
Non-Regulated = Parcel greater than .5 acre and no vehicle use.

Table 3.4.2 above summarizes 124 Inspected Rule 310.01 sites. Often one inspection site will have
multiple owners, creating more than one parcel at a specific site. These multiple parcels were counted
as one site. There were violations observed at forty (40) of the 124 sites; thus 32% of sites had an
observed violation. From this we observe a 68% Rule Effectiveness. 68% of the sites inspected had no
observable violations. Rule 310.01 Supervisor/ Inspector inspection reports were identical. There were
no differences between supervisor and inspector observations of Rule 310.01 violations.
Forty-seven of the inspections were conducted during a three week period: September 18, 2006
through October 3, 2006. Two weeks before, September 2 – September 14, Maricopa County
experienced a high precipitation rate. Many of these days were categorized by the U.S. National
Weather service as Thunderstorm activity days. Stabilization observed at these sites was due to this
unusual but naturally occurring wet weather and not to actions initiated by property owners. Within
two weeks, activity or trespass on these vacant lots destabilized some of the later test sites. To better
reflect the range of weather conditions more representative of Maricopa County, the Department
randomly selected 77 more inspection sites from the last six-months of 2006 to include with the
original 47 sites. This larger set of inspection sites more closely approximates the average Maricopa
County weather conditions.

4.4.3

Nonmetallic Mineral Processing Plants

Ten Rule 316 sources were randomly chosen for inspection during the months of August - November
2006. The following table lists the compliance status of each site as determined by QA/Supervisor –
Inspector.
Table 4.4.3: List of Inspected Non-Metallic Mineral Processing
Site Address
Paradise Valley Desert Rock Inc.
17238 N. Cave Creek Rd
Phoenix Arizona
Kilauea Crushers, Inc
7516 W. Deer Valley
Phoenix Arizona
Master Block
12620 W. Butler Drive
Phoenix Arizona
Maricopa Ready Mix
1800 N. Alma School Rd
Mesa Arizona
Southwest Asphalt Paving
Fisher Sand & Gravel dba
Tempe Arizona
Vulcan Materials/ Calmat Div.
5301 S. Dysart Rd.
Avondale, Arizona
Vulcan Materials Co. Plant #138
2205 W. Adobe Dr.
Phoenix, Arizona
Rinker
11920 W. Glendale
Glendale Arizona
Superstition Crushing
3914 East Presidio Street
Mesa Arizona 85215
(double inspection State/ County)
Kilauea Crushers

Permit Issued By

Compliance Status

MCAQD

CSN

MCAQD

No Observed Violation

MCAQD

NOVs

MCAQD

NOVs

ADEQ & MCAQD

NOVs

ADEQ

No Observed Violation

MCAQD

CLOSED PLANT

MCAQD

NOV

ADEQ & MCAQD
MCAQD

NOVs
NOV

Site Address
16402 S. Tuthill
Buckeye Arizona
Imix Group LLC
7505 S. 143 Ave
Goodyear Arizona
Sunshine Redi-Mix, Inc.
5725 N. 55th Ave
Glendale Arizona 85301

Permit Issued By

Compliance Status

MCAQD

NOVs

MCAQD

NOV

Of the eleven randomly chosen inspection sites, two of the sites had no observable violations.
Consequently, 18% of these sites had not observable violations.
Using EPA guidance (EPA, 1992), MCAQD determined that eleven inspections were not adequate to
meet the required 90 percent confidence level and 5 percent sample error. Therefore, MCAQD applied
recently revised EPA Rule Effectiveness Guidance (August 2005) to the Nonmetallic Mineral
Processing source category and derived a rule effectiveness of 54% for Rule 316 (Appendix B).
Appendix B describes the revised rule effectiveness methodology used. In this methodology, the value
assigned to the "compliance history" was derived from the inspection results of the eleven randomly
selected Rule 316 inspections.
4.5

Summary of Rule Effectiveness Study
Rule Effectiveness Study Results

Guidance
Rule 310
Rule 310.01
Rule 316

4.6

Earth Moving Sources
Vacant Lots/Open Areas
Nonmetallic Mineral

51%
68%
-

Revised EPA Rule Effectiveness
54%

Quality Assurance

As mentioned above, a quality assurance (QA) supervisor assigned to follow inspectors on the Rule
310 and Rule 310.01 inspections. The Earthmoving inspector data reported a lower rule effectiveness
or 46% Rule Effectiveness while the QA/ Supervisor data resulted in a 49% rule effectiveness. As the
difference between scoring was relatively small, the Department chose to rely upon the more
experienced, QA/ Supervisor observations to score the Rule 310 rule effectiveness. The Rule 310.01
QA/Supervisor and the inspector reports were identical. The consistent observations result from the
application of the Fugitive Dust Test Methods required by Rule 310.01
5.

Recommendations

Maricopa County’s significant growth rate over the last 5 years significantly affected the Department’s
workload. The Department was unable to add staff as rapidly as the growth took place. As a result,
for a period of time the Department responded to complaints but was unable to complete many
proactive inspections. To train the significant number of new staff necessary, the Department updated
its new employee training program and developed an ongoing training program. These updates were
put in place since the last rule effectiveness study.8 The small (3%) difference in Supervisor/inspector
observations reflects the success of this training and ongoing inspector quality control program.

8

MCESD, 2003 Rule Effectiveness Study for Salt River PM10 Study. Maricopa County Environmental Services
Department. Revised December 2003.

6.

Policy/Procedure Improvements

The Department programs for non-permitted sources are at the point where it is now conducting
proactive and well as reactive inspections. Based on the experience gained from inspections, the
Department will be recommending clarifications as to rule text to make the rule clearer to both the
regulated community and the regulators.

APPENDIX A
EPA Revised Rule Effective Guidance Factors for Non-point Sources
NON-POINT SOURCE RULE EFFECTIVENESS FACTORS:
Most important factor:

• Compliance History

Other important factors:
• Compliance Certification
• Type of Inspection
• Unannounced inspections
• Inspection Frequency
• Enforcement
• Compliance assistance
• Monitoring requirements
• Follow-up inspections
• Media publicity

APPENDIX B
Rule 316- EPA Revised Rule Effectiveness Guidance-Nonmetallic Mineral Processing
A. Most important factor (1 criteria, assigned weighting of 40% total)
Range
Compliance
History

Midpt.
Value

Description

86%

100%

93%

Over 90% of facilities Inspected in the
source Category are in compliance

70%

85%

78%

<70%

35%

Over 75% of facilities inspected in the
source category are in compliance
Over 60% of facilities inspected in the
source category are in compliance

Weight

Value
Assigned by
MCAQD

Score
(=weight x
value)

40%

18%

7.2%

8%

50%

4.00%

8%

80%

6.4%

8%

80%

6.40%

8%

93%

7.44%

8%

80%

6.40%

8%

80%

6.40%

B. Other Important factors ( 6 criteria, each assigned weighting of 8% of total)
Compliance
Certifications

Type of
Inspection

Inspection
Frequency/
Percentage

Unannounced
Inspections

Enforcement
Penalties

Compliance
Assistance

86%

100%

93%

70%

85%
<70%

78%
35%

86%

100%

93%

70%

85%

78%

<70%

35%

86%

100%

93%

70%

85%

78%

<70%

35%

100%

93%

86%

70%

85%
<70%

78%
35%

86%

100%

93%

70%

85%

78%

<70%

35%

86%

100%

93%

70%

85%
<70%

78%
35%

Source is subject to some type of
compliance certification
Source is subject to some type of
compliance certification
Source is not subject to any type of
compliance certification;
Inspections are thorough and detailed,
and include close examination of control
equipment, and a detailed records review
Inspections consist of a records review,
and sometimes inspections of control
equipment
Inspections generally consist of a records
review only;
Percent of facilities inspected in the
sector in a given year is 25% or greater.
Percent of facilities inspected in the
sector in a given year is 15% or greater
Percent of facilities inspected in the
sector in a given year is less than 15%
Unannounced inspections are sometimes
done
Unannounced inspections are sometimes
done, but infrequently
Unannounced inspections are never done
Agency takes prompt enforcement action,
including monetary fines, against
violators
Agency usually takes enforcement action,
including monetary fines against
violators;
Agency usually does not take
enforcement action against violators;
A compliance assistance program exists
and is adequately staffed, and includes
such things as workshops,
Mailings, web-based tutorials, etc.
Workshops, mailings, web-based
tutorials, etc available

C. Other factors ( 3 criteria, each assigned weighting of 4% total):
Monitoring
Requirements

Follow Up
Instructions

Media
Publicity

86%

100%

93%

70%

85%

78%

<70

35%

86%

100%

93%

70%

85%

78%

<70%

35%

86%

100%

93%

70%

85%
<70%

78%
35%

Monitoring requirements exist and must
be reported to regulatory agency at least
once a year;
Monitoring requirements exist but records
don’t have to be filed with regulatory
agency
Monitoring requirements do not exist;
Follow-up inspections are done when
violations are noted most (>75%) of the
time
Follow-up inspections are done when
violations are noted most (>75%) of the
time
Follow-up inspections are routinely done;
Media publicity of enforcement actions is
routinely conducted
Media publicity of enforcement actions is
sometimes done
Media publicity of enforcement actions is
rarely if ever done

4%

80%

3.2%

4%

80%

3.2%

4%

93%

3.72%

54.35%

APPENDIX C
SAMPLE SIZE with a 90% CONFIDENCE LEVEL
As a function of Standard deviation & Sample error 9

TABLE D-1

ANALYSIS OF SAMPLE SIZE; CONFIDENCE LEVEL = 90%
STANDARD DEVIATION

9

SAMPLE
ERROR

2%

4%

6%

8%

10%

12%

14%

16%

18%

20%

22%

24%

2.5%

2

7

16

28

44

63

85

112

141

174

211

251

3.0%

1

5

11

19

30

44

59

77

98

121

146

174

3.5%

1

4

8

14

22

32

44

57

72

89

108

128

4.0%

1

3

6

11

17

25

33

44

55

68

82

98

4.5%

1

2

5

9

13

19

26

34

44

54

65

77

5.0%

0

2

4

7

11

16

21

28

35

44

53

63

5.5%

0

1

3

6

9

13

18

23

29

36

44

52

6.0%

0

1

3

5

8

11

15

19

25

30

37

44

6.5%

0

1

2

4

6

9

13

16

21

26

31

37

7.0%

0

1

2

4

6

8

11

14

18

22

27

32

7.5%

0

1

2

3

5

7

9

12

16

19

23

28

8.0%

0

1

2

3

4

6

8

11

14

17

21

25

8.5%

0

1

1

2

4

5

7

10

12

15

18

22

9.0%

0

1

1

2

3

5

7

9

11

13

16

19

Guidelines for Estimating and Applying Rule Effectiveness for Ozone/CO State Implementation Plan Base Year
Inventories, U.S. EPA, EPA-452/R-92-010, November 1992.

Appendix 2.3
Calculating Rule Effectiveness for Controlled (Title V and non-Title V)
Point Source Processes

Title V

A. Most important factors (2 criteria, each assigned weighting of 20% of total):

Range

Monitoring

Compliance
History

94%

100%

87%

93%

81%

86%

70%

80%
< 70%

94%

100%

87%

93%

81%

86%

70%

80%
< 70%

Midpt.
value

Description
Source specific monitoring used for compliance purposes, and
monitoring records filed with regulatory agency at least every 4
97% months.
Source specific monitoring used as an indicator of compliance,
and monitoring records filed with regulatory agency every 6 to 9
90% months.

Value
Score
assigned to (= weight ×
Weight MCAQD
value)

20%

90%

18.0%

18 of 39
facilities

9.0%

5 of 39
facilities

2.3%

Source specific monitoring used as an indicator of compliance,
84% and monitoring records filed with regulatory agency each year.
General guidance exists for source specific enhanced monitoring,
and monitoring records required but aren’t submitted to
75% regulatory agency.
35% No requirements for any type of monitoring.

97% The facility has been in compliance for the past eight quarters.
The facility is believed to have been in compliance for the past
eight quarters, although inspection frequency is such that this
90% can’t be positively confirmed.
84% On schedule; the facility is meeting its compliance schedule.
In Violation; facility is in violation of emissions and/or
75% procedural requirements.
High Priority Violator (HPV): the facility is in significant
35% violation of one or more applicable requirement of the CAA.
20%

7 of 39
facilities
9 of 39
facilities
Sum:

2.7%
1.6%
15.6%

B. Other important factors (4 criteria, each assigned weighting of 6% of total):
Type of
Inspection

Operation &
Maintenance

94%

100%

97%

87%

93%

90%

81%
70%

86%
80%

84%
75%

< 70%

35%

94%

100%

87%

93%

81%
70%

86%
80%
< 70%

Inspections involve compliance test methods with a high degree
of accuracy, such as stack testing or other types of precise
emissions measurement.
Inspections involve detailed review of process parameters &
inspection of control equipment.
Inspections involve review of process and inspection of control
equipment.
Inspections generally consist of only a records review.
Inspections most likely consist of visual inspection (e.g., opacity),
or drive by.

6%

97%

5.8%

6%

90%

5.4%

Control equipment operators follow and sign daily O&M
97% instructions.
90% Control equipment operators follow daily O&M instructions.
Control equipment operators follow daily or weekly O&M
84% instructions.
75% O&M requirements exist, but on no specific schedule.
35% No specific O&M requirements.

1 of 4

Title V

Range
Unannounced
Inspections

Enforcement
Penalties

94%
87%
81%
70%

100%
93%
86%
80%
< 70%

Midpt.
value
97%
90%
84%
75%
35%

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

35%

Description
Routinely conducted.
Sometimes done.
Done, but infrequently.
Rarely done.
Never done.

Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency does not have sufficient authority to impose punitive
measures towards violators.

Value
Score
assigned to (= weight ×
Weight MCAQD
value)
6%

97%

5.8%

6%

97%

5.82%

4%

97%

3.88%

4%

97%

3.88%

4%

97%

3.88%

C. Other factors (9 criteria, each assigned weighting of 4% of total):
Compliance
Certifications

94%

100%

87%

93%

Source subject to Title V or other type of compliance
97% certification.
Source subject to Title V or other type of compliance
90% certification.

81%

86%

84% Source not subject to any type of compliance certification.

70%

Inspection
Frequency

EPA HPV
Enforcement

80%

75% Source not subject to any type of compliance certification.

< 70%

35% Source not subject to any type of compliance certification.

94%
87%
81%
70%

100%
93%
86%
80%
< 70%

97%
90%
84%
75%
35%

94%

100%

87%

93%

81%

86%

70%

80%
< 70%

Source(s) are inspected once every 2 years or more frequently.
Source(s) inspected every 3 years or more frequently.
Source(s) inspected every 5 years or more frequently.
Inspection of source(s) infrequent. > every 5 years.
Inspections rarely, if ever, performed.

Agency has sufficient resources to implement EPA’s 12/22/98
97% HPV policy.
Agency’s resources allow it to implement EPA’s 12/22/98 HPV
90% policy in most instances.
Agency’s resources allow it to implement EPA’s 12/22/98 HPV
84% policy in most instances.
Agency’s resources allow it to implement EPA’s 12/22/98 HPV
75% policy more often than not.
Resource constraints prohibit agency from implementing EPA’s
35% 12/22/98 HPV policy in most instances.

2 of 4

Title V

94%

100%

97%

87%

93%

90%

81%
70%

86%
0.8
< 70%

84%
75%
35%

Description
Control equipment operators complete a formal training program
on use of the equipment, and such program is kept up to date and
has been reviewed by the regulatory agency.
Control equipment operators complete formal training program,
and such program is kept up to date and available for review by
the regulatory agency upon request.
Control equipment operators complete some amount of formal
training.
Control equipment operators receive only on the job training .
Control equipment operators receive no specific training.

94%
87%
81%
70%

100%
93%
86%
80%
< 70%

97%
90%
84%
75%
35%

Media publicity of enforcement actions.
Media publicity of enforcement actions.
Media publicity of enforcement actions.
Media publicity of enforcement actions.
No media publicity of enforcement actions.

Range
Operator
Training

Media
Publicity

Midpt.
value

Regulatory
Workshops
94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

35%

Inspector
Training
94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

Regulatory workshops are available annually, and/or the
implementing agency mails regulatory information packages each
year.
Regulatory workshop are available every 1-2 years, and/or the
implementing agency mails regulatory information packages
every 1-2 years.
Regulatory workshop are available every 2-3 years, and/or the
implementing agency mails regulatory information packages once
every 2-3 years.
Regulatory workshop not routinely available, but implementing
agency mails regulatory information packages out about once
every 2-3 years.
Regulatory workshops not routinely available. implementing
agency mails regulatory information packages infrequently, if
ever.

Inspectors must undergo 2 weeks of comprehensive basic
training, and 1 to 2 weeks of source specific training, and such
training is updated each year.
Inspectors must undergo 1 to 2 weeks of basic training and 1
week of source specific training, and such training is updated
every 1-2 years.
Inspectors must undergo 1 to 2 weeks of basic training and 3 to 5
days of source specific training, and such training is updated
every 1-2 years.
Inspectors must undergo 1 to 2 weeks of basic training and 1 to 3
days of source specific training, and such training is updated
every 1-2 years.

Inspectors must undergo less than 5 days of basic training less
than 3 days of source specific training, and such training is
35% updated only every 2 years or less frequently.

3 of 4

Value
Score
assigned to (= weight ×
Weight MCAQD
value)

4%

84%

3.36%

4%

97%

3.88%

4%

97%

3.88%

4%

90%

3.60%

Title V

Range
Testing
Guidelines

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

Follow-up
Inspections

Midpt.
value

94%

100%

87%

93%

81%

86%

70%

80%
< 70%

35%

Description
Specific guidelines and schedule for testing and test methods
exist.
Specific guidelines on testing and test methods exist, but no
schedule for testing.
Specific guidelines on testing and test methods exist, but no
schedule for testing.
Specific guidelines on testing and test methods, but no schedule
for testing.
Only general guidance on testing, or no mention of testing
requirements.

Follow-up inspections always or almost always done (90 % of the
97% time or more).
Follow-up inspections usually done (approximately 75% of the
90% time).
Follow-up inspections sometimes done (approximately 50% of
84% the time).
Follow-up inspections infrequently done (approximately 25% of
75% the time).
Follow-up inspections rarely or never done (10% of the time or
35% less)

Value
Score
assigned to (= weight ×
Weight MCAQD
value)
4%

97%

3.88%

4%

97%

3.88%

90.55%

4 of 4

Non-Title V

A. Most important factors (2 criteria, each assigned weighting of 20% of total):

Range

Monitoring

Compliance
History

Midpt.
value

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%
< 70%

75%
35%

94%

100%

97%

87%
81%

93%
86%

90%
84%

70%

80%

75%

< 70%

35%

Description
Source specific monitoring used for compliance purposes, and
monitoring records filed with regulatory agency at least every 4
months.
Source specific monitoring used as an indicator of compliance,
and monitoring records filed with regulatory agency every 6 to 9
months.
Source specific monitoring used as an indicator of compliance,
and monitoring records filed with regulatory agency each year.
General guidance exists for source specific enhanced monitoring,
and monitoring records required but aren’t submitted to
regulatory agency.
No requirements for any type of monitoring.

Value
Score
assigned to (= weight ×
Weight MCAQD
value)

20%

The facility has been in compliance for the past eight quarters.
The facility is believed to have been in compliance for the past
eight quarters, although inspection frequency is such that this
can’t be positively confirmed.
On schedule; the facility is meeting its compliance schedule.
In Violation; facility is in violation of emissions and/or
procedural requirements.
High Priority Violator (HPV): the facility is in significant
violation of one or more applicable requirement of the CAA.

75%

15.0%

182 of 748
facilities

4.7%

404 of 748
facilities

9.7%

156 of 748
facilities
6 of 748
facilities
Sum:

0.1%
17.6%

6%

90%

5.4%

6%

90%

5.4%

3.1%

B Other important factors (4 criteria, each assigned weighting of 6% of total):
Type of
Inspection

Operation &
Maintenance

94%

100%

97%

87%

93%

90%

81%
70%

86%
80%

84%
75%

< 70%

35%

94%
87%
81%
70%

100%
93%
86%
80%
< 70%

97%
90%
84%
75%
35%

Inspections involve compliance test methods with a high degree
of accuracy, such as stack testing or other types of precise
emissions measurement.
Inspections involve detailed review of process parameters &
inspection of control equipment.
Inspections involve review of process and inspection of control
equipment.
Inspections generally consist of only a records review.
Inspections most likely consist of visual inspection (e.g.,
opacity), or drive by.

Control equipment operators follow and sign daily O&M
instructions.
Control equipment operators follow daily O&M instructions.
Control equipment operators follow daily or weekly O&M
instructions.
O&M requirements exist, but on no specific schedule.
No specific O&M requirements.

Page 1 of 4

Non-Title V

Range
Unannounced
Inspections
94% 100%
87% 93%
81% 86%
70% 80%
< 70%

Enforcement
Penalties

Midpt.
value
97%
90%
84%
75%
35%

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

35%

Description
Routinely conducted.
Sometimes done.
Done, but infrequently.
Rarely done.
Never done.

Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency has the authority to impose punitive measures, including
monetary fines, towards violators such as in delegated Title V
Operating Permit programs.
Agency does not have sufficient authority to impose punitive
measures towards violators.

Value
Score
assigned to (= weight ×
Weight MCAQD
value)
6%

97%

5.8%

6%

97%

5.82%

4%

75%

3.00%

4%

97%

3.88%

4%

97%

3.88%

C. Other factors (9 criteria, each assigned weighting of 4% of total):
Compliance
Certifications 94%

Inspection
Frequency

EPA HPV
Enforcement

100%

97%

87%
81%
70%

93%
86%
80%
< 70%

90%
84%
75%
35%

Source subject to Title V or other type of compliance
certification.
Source subject to Title V or other type of compliance
certification.
Source not subject to any type of compliance certification.
Source not subject to any type of compliance certification.
Source not subject to any type of compliance certification.

94%
87%
81%
70%

100%
93%
86%
80%
< 70%

97%
90%
84%
75%
35%

Source(s) are inspected once every 2 years or more frequently.
Source(s) inspected every 3 years or more frequently.
Source(s) inspected every 5 years or more frequently.
Inspection of source(s) infrequent. > every 5 years.
Inspections rarely, if ever, performed.

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

35%

Agency has sufficient resources to implement EPA’s 12/22/98
HPV policy.
Agency’s resources allow it to implement EPA’s 12/22/98 HPV
policy in most instances.
Agency’s resources allow it to implement EPA’s 12/22/98 HPV
policy in most instances.
Agency’s resources allow it to implement EPA’s 12/22/98 HPV
policy more often than not.
Resource constraints prohibit agency from implementing EPA’s
12/22/98 HPV policy in most instances.

Page 2 of 4

Non-Title V

94%

100%

97%

87%

93%

90%

81%
70%

86%
80%
< 70%

84%
75%
35%

Description
Control equipment operators complete a formal training program
on use of the equipment, and such program is kept up to date and
has been reviewed by the regulatory agency.
Control equipment operators complete formal training program,
and such program is kept up to date and available for review by
the regulatory agency upon request.
Control equipment operators complete some amount of formal
training.
Control equipment operators receive only on the job training .
Control equipment operators receive no specific training.

94%
87%
81%
70%

100%
93%
86%
80%
< 70%

97%
90%
84%
75%
35%

Media publicity of enforcement actions.
Media publicity of enforcement actions.
Media publicity of enforcement actions.
Media publicity of enforcement actions.
No media publicity of enforcement actions.

Range
Operator
Training

Media
Publicity

Regulatory
Workshops

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

Inspector
Training

Midpt.
value

35%

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

35%

Regulatory workshops are available annually, and/or the
implementing agency mails regulatory information packages each
year.
Regulatory workshop are available every 1-2 years, and/or the
implementing agency mails regulatory information packages
every 1-2 years.
Regulatory workshop are available every 2-3 years, and/or the
implementing agency mails regulatory information packages once
every 2-3 years.
Regulatory workshop not routinely available, but implementing
agency mails regulatory information packages out about once
every 2-3 years.
Regulatory workshops not routinely available. implementing
agency mails regulatory information packages infrequently, if
ever.

Inspectors must undergo 2 weeks of comprehensive basic
training, and 1 to 2 weeks of source specific training, and such
training is updated each year.
Inspectors must undergo 1 to 2 weeks of basic training and 1
week of source specific training, and such training is updated
every 1-2 years.
Inspectors must undergo 1 to 2 weeks of basic training and 3 to 5
days of source specific training, and such training is updated
every 1-2 years.
Inspectors must undergo 1 to 2 weeks of basic training and 1 to 3
days of source specific training, and such training is updated
every 1-2 years.
Inspectors must undergo less than 5 days of basic training less
than 3 days of source specific training, and such training is
updated only every 2 years or less frequently.

Page 3 of 4

Value
Score
assigned to (= weight ×
Weight MCAQD
value)

4%

75%

3.00%

4%

97%

3.88%

4%

97%

3.88%

4%

90%

3.60%

Non-Title V

Range
Testing
Guidelines

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

Follow-up
Inspections

Midpt.
value

35%

94%

100%

97%

87%

93%

90%

81%

86%

84%

70%

80%

75%

< 70%

35%

Description
Specific guidelines and schedule for testing and test methods
exist.
Specific guidelines on testing and test methods exist, but no
schedule for testing.
Specific guidelines on testing and test methods exist, but no
schedule for testing.
Specific guidelines on testing and test methods, but no schedule
for testing.
Only general guidance on testing, or no mention of testing
requirements.

Follow-up inspections always or almost always done (90 % of the
time or more).
Follow-up inspections usually done (approximately 75% of the
time).
Follow-up inspections sometimes done (approximately 50% of
the time).
Follow-up inspections infrequently done (approximately 25% of
the time).
Follow-up inspections rarely or never done (10% of the time or
less)

Value
Score
assigned to (= weight ×
Weight MCAQD
value)
4%

97%

3.88%

4%

97%

3.88%

87.95%

Page 4 of 4

Appendix 3.1
Calculating Rule Effectiveness for Agricultural Activities

Rule Effectiveness for Agricultural Activities for 2005 Periodic Inventory

A. Most important factors (1 criteria with an assigned weight of 25% of total):

Range
Compliance
History

86% 100%
70%

85%
< 70%

Midpt.
value

Description
Over 90% of facilities inspected in the source category
93% are in compliance.
Over 75% of facilities inspected in the source category
80% are in compliance.
Over 60% of facilities inspected in the source category
35% are in compliance.

Value
Score
assigned to
(= weight
MCAQD Weight × value)
93%

25%

23%

35%

10%

4%

35%

10%

4%

0.7

10%

7%

35%

10%

4%

B. Other important factors (6 criteria, each assigned weighting of 10% of total):
Compliance
Certification

86% 100%
70%

85%
< 70%

Level of
Inspection

Unannounced
Inspections

Inspections
Frequency

85%

Inspections are thorough and detailed, and include
close examination of control equipment, and a detailed
93% records review.
Inspections consist of a records review, and sometimes
80% inspection of control equipment.

< 70%

35% Inspections generally consist of a records review only.

86% 100%
70%

Source is subject to some type of compliance
93% certification.
Source is subject to some type of compliance
80% certification.
Source is not subject to any type of compliance
35% certification.

86% 100%

93% Unannounced inspections are sometimes done.

70%

80% Unannounced inspections are done, but infrequently.
35% Unannounced inspections are never done.

85%
< 70%

86% 100%
70%

85%
< 70%

Percent of facilities inspected in the sector in a given
93% year is 25% or greater.
Percent of facilities inspected in the sector in a given
80% year is 15% or greater.
Percent of facilities inspected in the sector in a given
35% year is less than 15%.

1 of 2

Rule Effectiveness for Agricultural Activities for 2005 Periodic Inventory

Range
Enforcement

86% 100%
70%

85%
< 70%

Compliance
Assistance
Programs

86% 100%

70%

85%
< 70%

Midpt.
value

Description
Agency takes prompt enforcement action, including
93% monetary fines, against violators.
Agency usually takes enforcement action, including
80% monetary fines, against violators.
Agency usually does not take enforcement action
35% against violators.

Value
Score
assigned to
(= weight
MCAQD Weight × value)

35%

10%

4%

0.93

10%

9%

Monitoring requirements exist and must be reported to
93% regulatory agency at least once a year.
Monitoring requirements exist but records don’t have
80% to be filed with regulatory agency.
35% Monitoring requirements do not exist.

35%

5%

2%

Follow-up inspections are done when violations are
93% noted most (>75%) of the time.
Follow-up inspections are done when violations are
80% noted most (>75%) of the time.
35% Follow-up inspections are not routinely done.

35%

5%

2%

Media publicity of enforcement actions is routinely
93% conducted.
Media publicity of enforcement actions is sometimes
80% done.
Media publicity of enforcement actions is rarely if ever
35% done.

35%

5%

2%
59%

A compliance assistance program exists and is
adequately staffed, and includes such things as
93% workshops, mailings, web-based tutorials, etc.
A compliance assistance program exists, but is
minimally staffed. The program occasionally makes
workshops, mailings, web-based tutorials,
80% etc.;available.
35% A compliance assistance program does not exist.

C. Other factors (3 criteria, each assigned weighting of 5% of total):
Monitoring
Requirements

86% 100%
70%

Follow-up
Inspections

86% 100%
70%

Media
Publicity

85%
< 70%

85%
< 70%

86% 100%
70%

85%
< 70%

2 of 2

Appendix 3.2
Development of a Fugitive Windblown PM10 Dust Emission Inventory
for the Phoenix PM10 Nonattainment Area

Air Sciences

International Corporation

Final Report
Development of a Fugitive Windblown
PM10 Dust Emission Inventory
for the Phoenix PM10 Nonattainment Area

Prepared for
Maricopa County Air Quality Department
1001 N. Central Ave., Suite 400
Phoenix, AZ 85004

Prepared by
Gerard E. Mansell
Abigail Hoats
ENVIRON International Corporation
101 Rowland Way
Novato, CA 94945

Revised
16 May 2007

101 Rowland Way, Suite 220, Novato, CA 94945

415.899.0700

May 2007

TABLE OF CONTENTS
Page

1. INTRODUCTION................................................................................................................ 1-1

2. WINDBLOWN PM10 DUST EMISSION ESTIMATION METHODOLOGY............ 2-1

3. INPUT DATA....................................................................................................................... 3-1

4. MODEL APPLICATION ................................................................................................... 4-1

5. MODELING RESULTS...................................................................................................... 5-1

6. SUMMARY .......................................................................................................................... 6-1

7. REFERENCES .................................................................................................................... 7-1

TABLES
Table 2-1.
Table 2-2.
Table 2-3.
Table 2-4.
Table 3-1.
Table 3-2.
Table 3-3.
Table 3-4.
Table 3-5.
Table 3-6.
Table 3-7.
Table 4-1.
Table 4-2
Table 4-3

Threshold friction velocities for typical surface types
calculated from available data and as reported in the literature........................... 2-4
Typical surface aerodynamic roughness lengths
calculated from available data and as reported in the literature........................... 2-5
Number of days after precipitation event to re-initiate
wind erosion for rainfall amounts (constant) exceeding 2 inches........................ 2-8
Number of days after precipitation event to re-initiate
wind erosion for rainfall amounts (constant) less than or equal to 2 inches........ 2-8
Merged land Use/Land Cover classifications (codes < 1000
correspond to MAG LU database)....................................................................... 3-2
Surface roughness lengths by LULC and dust code ............................................ 3-8
Soil texture and soil group codes ......................................................................... 3-9
Meteorological data provided by MAG............................................................. 3-11
AZMET observation stations............................................................................. 3-12
Agricultural crops in Maricopa and Pinal Counties........................................... 3-18
Default agricultural crop calendar for Maricopa and Pinal Counties. ............... 3-19
Transport fractions as a function of landuse ........................................................ 4-2
Revised disturbance assumptions for MAG
Landuse/Landcover classifications ...................................................................... 4-3
Monthly, crop-specific soil disturbance percentages........................................... 4-6
i

May 2007

Table 5-1.
Table 5-2.
Table 5-3.
Table 5-4.
Table 5-5.
Table 5-6.
Table 5-7.
Table 5-8.

Preliminary 2005 Monthly PM10 windblown dust emissions for the
Phoenix Nonattainment area ................................................................................ 5-2
Preliminary 2005 Monthly PM10 windblown dust emissions for Maricopa
and Pinal Counties ............................................................................................... 5-2
2005 Annual PM10 windblown dust emissions for the
Phoenix NNA ...................................................................................................... 5-6
2005 Annual PM10 windblown PM10 dust emissions for Maricopa
and Pinal Counties ............................................................................................... 5-6
2005 Annual PM10 windblown dust emissions for the Phoenix NAA ............... 5-7
2005 Monthly PM10 windblown dust emissions for
Maricopa and Pinal Counties ............................................................................... 5-7
2005 Annual PM10 windblown dust emissions for the
Phoenix NAA using 5-year average (2001-2005) wind speed data................... 5-12
2005 Annual PM10 windblown dust emissions for
Maricopa and Pinal Counties using 5-year average
(2001-2005) wind speed data............................................................................. 5-12

FIGURES
Figure 1-1.
Figure 2-1.

Figure 2-2.

Figure 2-3.

Figure 3-1.
Figure 3-2.
Figure 3-3.
Figure 3-4.
Figure 3-5.
Figure 3-6.
Figure 3-7.
Figure 5-1.
Figure 5-2.
Figure 5-3.
Figure 5-4.

MCAQD 12-km windblown dust emissions modeling domain .......................... 1-2
Comparison between the Marticorena et al. (1997) modeled
relationship of threshold friction velocity and aerodynamic
roughness length and wind tunnel data from Gillette et al.
(1980, 1982), Gillette (1988) and Nickling and Gillies (1989). .......................... 2-3
The emission flux as a function of friction velocity predicted
by the Alfaro and Gomes (2001) model constrained by the four
soil geometric mean diameter classes of Alfaro et al. (2003).............................. 2-6
Comparison between the Alfaro et al. (2003) model relationship
for FS and CS sizes and the wind tunnel flux data of Nickling
and Gillies (1989). Ten (out of 13) sites have a dust production
potential similar to the FS model and one site (Mesa agricultural)
is closely aligned with the CS model (after Alfaro et al., 2003).......................... 2-7
Merged LULC data for windblown dust model application................................ 3-8
Merged soil texture data for windblown dust model application. ..................... 3-10
Merged soil group data for windblown dust model application. ....................... 3-10
Example interpolated wind speeds for 12 Noon, January 28, 2006................... 3-12
Monthly average wind speeds on the 12-km windblown
dust modeling domain........................................................................................ 3-13
Flood Control Precipitation Sites....................................................................... 3-15
Monthly total rainfall in inches (2001-2005 data) ............................................. 3-16
Monthly windblown PM10 dust emissions for the
Phoenix Nonattainment area ................................................................................ 5-3
Monthly windblown PM10 dust emissions for Maricopa
and Pinal Counties ............................................................................................... 5-3
Spatial distribution of estimated PMC windblown dust emissions ..................... 5-4
Final monthly windblown PM10 dust emissions for the
Phoenix Nonattainment area ................................................................................ 5-8
ii

May 2007

Figure 5-5.
Figure 5-6.
Figure 5-7.

Final monthly windblown PM10 dust emissions for Maricopa
and Pinal Counties ............................................................................................... 5-8
Location of meteorological monitoring stations for 5-year
average wind speed data ...................................................................................... 5-9
Monthly average wind speeds on the 12-km modeling
domain. (2001-2005 data).................................................................................. 5-10

iii

May 2007

1. INTRODUCTION

The Maricopa County Air Quality Department (MCAQD) has contracted with ENVIRON to
develop a windblown dust PM10 emissions inventory for the metro Phoenix PM10 nonattainment area (NAA). The draft inventory was developed for calendar year 2005 and the first
quarter of calendar year 2006 for inclusion in a complete 2005 PM10 emissions inventory. As
part of this development effort, the Windblown Dust emissions model, developed by the Western
Regional Air Partnership Regional Modeling Center (WRAP RMC), was used in combination
with local and regional data sets describing the land characteristics within the study area. The
development of the windblown PM10 dust emission inventory is described in this report.
ENVIRON applied the WRAP RMC Windblown Dust Model to develop the necessary PM10 and
PM2.5 emissions inventory. The dust model was developed to generate hourly gridded estimates
of PM dust emissions based on landuse, soils characteristics, hourly meteorological data and
additional information related to agricultural practices. The accuracy and quality of the dust
estimates is limited by the detail and resolution of available input data, particularly the
characterization of land use and landcover. The existing databases used previously for the
WRAP Regional Haze modeling efforts were augmented with additional local data for Maricopa
County and surrounding areas. In addition to surface characteristics data, the model requires
gridded, hourly wind speeds to estimate PM10 dust emissions from wind erosion. The Maricopa
Association of Governments (MAG) has provided ENVIRON with observed wind data from
meteorological monitoring sites within the Phoenix PM10 non-attainment area (NAA).
The emission inventory pollutants include both PM10 and PM2.5 in order to facilitate the
assessment of potential control measures. Emission estimates were apportioned to specific land
use categories based upon GIS analysis and existing land use data bases. Emissions estimates
were developed at a spatial resolution of 12-km on a modeling domain encompassing Maricopa
County, the Phoenix PM10 Non-Attainment Area, and Pinal County. Figure 1-1 displays the 12km windblown dust modeling domain used in the present study. The emission estimates were
aggregated and provided separately for each of the regions from the gridded modeling results.
The draft dust emission inventory and project report (Mansell and Hoats, 2007) presented and
discussed results for both calendar year 2005 and the first quarter of 2006. This report and the
final windblown dust emissions inventory focuses only on the calendar year 2005 estimates.

1-1

May 2007

-504

-540

-576

-612

-648

-684

-720

-756
-1548

-1512

-1476

-1440

-1404

-1368

-1332

-1296

-1260

-1224

Maricopa/Pinal Co. WB Dust Modeling Domain

Figure 1-1. MCAQD 12-km windblown dust emissions modeling domain.

This report is organized as follows:
•
•
•
•
•
•

Section 2 provides a summary of the WRAP RMC windblown dust emission estimation
methodology used for the project.
Section 3 presents and discusses the various data sources used for the emissions
inventory development.
The implementation of the dust model for Maricopa and Pinal Counties is described in
Section 4.
Section 5 documents the results of the windblown dust emissions modeling for calendar
year 2005. Various sensitivity simulations performed during the course of the project are
also discussed in this section.
Section 6 provides an overall summary of the work performed as part of the project.
Limitations of the model and results, as well as recommendations for future modeling
efforts are also provided.
Section 7 includes references for this report.

1-2

May2007

2. WINDBLOWN PM10 DUST EMISSION ESTIMATION METHODOLOGY

The WRAP Windblown Dust model was developed by the WRAP Regional Modeling Center
(RMC) in two phases. The current application for Maricopa and Pinal Counties uses the most
recent version developed during Phase II of the RMC’s model development efforts. A brief
description of the Phase I methodology is provided below, including a discussion of the various
assumptions and associated limitations. A discussion of the Phase II estimation methodology
used for this project is then presented.

Summary of Phase I Methodology
The development of the Phase I Wind Blown Dust model and implementation, including various
assumptions incorporated in the estimation methodology, has been documented previously
(ENVIRON, 2004; 2003a; 2003b; Mansell, 2003a; 2003b). In summary, the method relies on
the characterization of vacant land types and soil conditions, and numerous assumptions
regarding dust reservoir characteristics. Wind erosion is initiated in the model based on an
arbitrary wind speed assignment, independent of surface conditions. Emission factors, or dust
fluxes, were derived from very limited wind tunnel study results as a function of wind speed and
soil texture. Adjustments were applied to the resulting emission rates based on vegetation
density of vacant land parcels. Surface disturbance levels were based on land use types. In
addition, adjustments were applied for agricultural lands based on non-climatic factors. Land
use characterization was based on the Biogenic Emission Landuse Database (BELD3); soil
texture was derived from the State Soil Geographic Database (STATSGO).
The relative lack of detail in the data sets used for characterizing the physical conditions of land
parcels and soils required a number of assumptions to be employed in the methodology. These
assumptions were presented and discussed in detail by Mansell, 2003b and Mansell et al., 2004.
The primary assumptions affecting the model results can be summarized as follows:
•

Threshold wind velocities: The threshold wind velocity is assumed to be 20 mph,
independent of land use and soil texture.

•

Vacant land stability: The methodology developed relies on the specification of stability
of vacant land parcels. The stability characteristics of land parcels are based solely on the
land use type.

•

Dust Reservoirs: Reservoir properties are based on the stability characteristics of vacant
land parcels and determine the duration of dust events. Limited reservoirs emit dust for a
shorter duration of time than unlimited reservoirs. Assumptions are made concerning the
amount of time a reservoir will emit wind blown dust. Also assumed are the reservoir
recharge intervals.

•

Rain, Snow and Freeze Events: Assumptions are included which determine time
intervals after which land parcels will emit dust following precipitation, snow and freeze
events. These assumptions greatly impact the number of wind events treated in the
methodology as well as the total dust emissions generated.
2-1

May2007

•

Vegetation Density: The percentage of vegetative, or canopy, cover is determined by the
general land use category of vacant land parcels. These percentages are constant for a
given land type. Estimated emission factors, or emission rates, are attenuated based on
the assumed canopy cover percentage.

These various assumptions have a number of implications with respect to the estimation of
fugitive dust from wind erosion. However, in many cases, the data necessary to address these
issues on a regional scale domain are lacking. These issues and their implications were
discussed in Mansell et al., 2004. The Phase II Windblown Dust methodology, described in the
following section, seeks to address these assumptions and limitations and provide improvements
to the overall estimation methodology and dust model implementation. It should be noted that
previous windblown PM10 dust emission inventories for the State of Arizona have been
developed using the Phase I estimation methodology (Pollack, et al., 2004)
WRAP RMC Phase II Methodology
The WRAP RMC developed the Phase II estimation methodology based a review of recent
literature and windblown dust studies. A summary of the literature review can be found in
Mansell, et al., 2004. Based on a review of wind tunnel studies it was noted that the two
important components to characterize the dust emission process from an erodible surface are the
threshold friction velocity that defines the inception of the emission process as a function of the
wind speed and as influenced by the surface characteristics, and the strength of the emissions that
follow the commencement of particle movement. The two critical factors affecting emission
strength are the wind speed (wind friction velocity) that drives the saltation system, and the soil
characteristics.
Friction Velocities
Surface friction velocities are determined from the aerodynamic surface roughness lengths and
the 10-meter wind speeds. Friction velocity u*, is related to the slope of the velocity versus the
natural logarithm of height through the relationship:
uz 1
z
= ln
u* κ zo
where uz = wind velocity at height z (m s-1)
u* = friction velocity (m s-1)
κ = von Karman's constant (0.4)
zo = aerodynamic roughness height (m)
Threshold Friction Velocities
The methodology relies on the determination of threshold surface friction velocities, u*t, as a
function of aerodynamic surface roughness length, z0. In addition to aerodynamic roughness, the
degree of disturbance of the surface also plays a key role in the estimation of threshold friction
velocities. Based on the work of Marticorena et al. (1997), relationships between u*t and z0

2-2

May2007

where identified and compared with wind tunnel data from Gillette et al. (1980, 1982), Gillette
(1988) and Nickling and Gillies (1989). This comparison is presented in Figure 2-1.

3

2.5
u*t = 0.31e7.44x(Zo)
R2 = 0.60

u*t (m s-1)

2

u*t = 0.30e7.22x(Zo)

1.5

1

0.5

0
0.00001

0.0001

wind tunnel data
Expon. (wind tunnel data)

0.001

0.01

0.1

1

zo (cm)
Marticorena et al. 1997
Expon. (Marticorena et al. 1997)

Figure 2-1. Comparison between the Marticorena et al. (1997) modeled relationship of
threshold friction velocity and aerodynamic roughness length and wind tunnel data from Gillette
et al. (1980, 1982), Gillette (1988) and Nickling and Gillies (1989).

Several general relationships can be described for threshold friction velocity data. Two major
factors have the greatest influence on the threshold of wind erodible soils: the degree of
disturbance and the aerodynamic roughness. For loose or disturbed soils the most important
factor that controls the threshold friction velocity is aerodynamic roughness. The effect of
surface disturbance on threshold friction velocity can be seen in Table 2-1 for data from Gillette
et al. (1980, 1982), Gillette (1988), and Nickling and Gillies (1989) where surfaces are grouped
by land type. For a given surface type, the effect of disturbance is to lower the threshold
between ~90% to ~20% of the undisturbed value.

2-3

May2007

Table 2-1. Threshold friction velocities for typical surface types calculated from available data
and as reported in the literature1.
Average
Std. D.
No. of Average Std. D.
No. of
u*t(m s-1)
u*t (m s-1)
Data u*t (m s-1) u*t (m s-1) Data
% change
Site Type Undisturbed Undisturbed Points Disturbed Disturbed Points [1-(dist./undist.)]
agricultural
fields
1.29
0.74
41
0.55
0.25
37
0.57
alluvial fan

0.72

0.09

2

0.60

0.18

2

0.17

desert flat
desert
pavement

0.75

0.06

4

0.51

0.19

4

0.32

2.17

0.67

4

0.59

0.10

5

0.73

fan surface

1.43

0.59

5

0.47

0.25

5

0.67

play, crusted

2.13

0.67

4

0.63

0.50

15

0.70

playa

1.46

0.98

12

0.58

0.56

25

0.60

prairie

2.90

n/a

1

0.24

0.03

3

0.92

sand dune

0.44

0.10

4

0.32

0.05

4

0.27

1

Sources include: Gillette et al. (1980, 1982), Gillette (1988), and Nickling and Gillies (1989).

Surface Roughness Lengths
Surface friction velocities, including the threshold friction velocity, are a function of the
aerodynamic surface roughness lengths. The surface roughness lengths are in turn dependent on
surface characteristics, particularly land use/land cover. While these values can vary
considerable for a given land type, published data are available which provide a range of surface
roughness lengths for various land use types and vegetation cover. These data were presented in
Table 2-1.
Application of the relationship shown in Figure 2-1 to assign a threshold friction velocity to a
surface requires information on a surface’s aerodynamic roughness length. This type of
information is not generally available in land use databases, because they were not specifically
developed to quantify aerodynamic properties of surfaces. Based on the designation of land use
type, the aerodynamic roughness can be assigned based on previously reported values for similar
surfaces. A list of surface types and reported aerodynamic roughness lengths is presented in
Table 2-2. In the RMC Phase II model, as implemented in the current project, surface roughness
lengths were assigned based on the land cover type, and are documented in Section 3.
A degree of uncertainty exists upon assigning an aerodynamic roughness length to a surface, as it
will be complicated by the individual condition of the surface, which can change through time on
several scales. For agricultural fields, aerodynamic roughness will change as a function of plant
height and cover through a growing season and the tillage practices. These affects are considered
for agricultural lands within the model, as described below. For natural surfaces, the
aerodynamics can change through the season as well as annually through several years affecting
dust production cycles. This is linked to plant growth in response to annual and long term
climate variability, which will affect plant cover.

2-4

May2007

Table 2-2. Typical surface aerodynamic roughness lengths calculated from available data and
as reported in the literature.
Average
zo (cm)

Std. D. zo
(cm)

agricultural fields (bare)

0.031

0.039

9

0.38

desert flat/pavement

0.133

0.180

8

0.79

fan surface

0.088

0.148

5

0.57

play, crusted

0.059

0.099

15

0.46

playa

0.057

0.083

33

0.46

prairie

0.049

0.088

4

0.43

0.007
0.045
0.370
6.800
7.200
8.300
5.400
2.3
5
0.12
2-4
50-100
100-600
100-601
15
100

0.006
0.040

4
2

0.32
0.42

Site Type

sand dune
scrub desert
sparse veg. (0.04% cover)
sparse veg. (10.3% cover)
sparse veg. (13.5% cover)
sparse veg. (26% cover)
sparse veg. (8% cover)
thick grass
thin grass
sparse grass
agricultural crops
orchards
Decid. Forests
Conf. Forests
agricultural crops
urban
Decid. Forests (closed
canopy)
Conif. Forests (closed
canopy)

Number of Estimated
Data Points u*t (m s-1) Source
Gillette et al. (1980, 1982), Gillette
(1988) Nickling and Gillies (1989)
Gillette et al. (1980, 1982), Gillette
(1988) Nickling and Gillies (1989)
Gillette et al. (1980, 1982), Gillette
(1988) Nickling and Gillies (1989)
Gillette et al. (1980, 1982), Gillette
(1988) Nickling and Gillies (1989)
Gillette et al. (1980, 1982), Gillette
(1988) Nickling and Gillies (1989)
Gillette et al. (1980, 1982), Gillette
(1988) Nickling and Gillies (1989)
Gillette et al. (1980, 1982), Gillette
(1988) Nickling and Gillies (1989)
Nickling and Gillies (1989)
Wolfe (1993)
Wolfe (1993)
Wolfe (1993)
Wolfe (1993)
Wolfe (1993)
Sutton (1953)
Sutton (1953)
Oke (1978)
Oke (1978)
Oke (1978)
Oke (1978)
Oke (1978)
Deursen et al. (1993)
Deursen et al. (1993)

121

Deursen et al. (1993)

134

Deursen et al. (1993)

Emission Fluxes
Field and wind tunnel experiments suggest that dust emissions are proportional to wind friction speed
and approximate theoretical model predictions, but the considerable scatter in the available data
make it impossible to clearly define this dependence (Nickling and Gillies, 1993). Different surfaces
appear to have different constants of proportionality for the flux versus wind friction velocity
relationship, implying that the flux is predictable, but surface and soil properties affect the magnitude
of the flux. A detailed discussion of wind tunnel studies, including various limitations and measured
data, was provided in ENVIRON, 2003a; 2003b. The findings of the various wind tunnel studies are
briefly summarized here.
Recently Alfaro, et al. (2003) re-analyzed the Nickling and Gillies (1989) data and found that the
tendency of a surface to emit dust depends not primarily on its textural qualities, but on the size
distribution of the loose soil aggregates available for saltation, and the aerodynamic roughness length
that conditions the emission threshold. The re-analysis was based in part on the work of Chatenet, et
al. (1996) in which they found that desert soils could be broadly divided into four populations based
upon their soil aggregate populations. The differences between the four groups are based upon the

2-5

May2007

estimated geometric mean diameter of the soil particles. The four size classes are 125 mm, 210 mm,
520 mm, and 690 mm, which are labeled FFS, FS, MS, and CS by Chatenet, et al. (1996).
0.00001

Emission Flux (F, g cm-2 s-1)

0.000001

FFS
F = 2.45x10-6 (u*)3.97
FSS
FS
MS
CS
Power (FSS)
Power (FS)
Power (MS)
Power (CS)

FS
F = 9.33x10-7 (u*)2.44
0.0000001

0.00000001

MS
F = 1.243x10-7(u*)2.64
CS
F = 1.24x10-7 (u*)3.44

0.000000001
0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

0.9

1

-1

Friction Velocity (m s )

FIgure 2-2. The emission flux as a function of friction velocity predicted by the Alfaro and
Gomes (2001) model constrained by the four soil geometric mean diameter classes of Alfaro et
al. (2003).

Alfaro et al., (2003) grouped the Nickling and Gillies (1989) emission data based on these
classes then tested how well the grouped data matched predicted output of a dust production
model developed by Alfaro and Gomes (2001) that was constrained to use the four different
geometric mean diameters. The modeled dust emission relationships for the four size classes are
shown in Figure 2-2. As presented in Alfaro, et al. (2003) the emission data from Nickling and
Gillies (1989), which fall into the FS class (10 out of 13) are well explained by the model (Figure
2-3).

2-6

May2007

1E-06
FS
Casa Grande
Mesa (Salt River )

1E-07

Hayden

Fv (g/cm2/s)

A jo
Y uma ( ag)
Glendale

1E-08

Tucson (Sta Cr uz)
Tucson (co nst.
site)
Mesa (ag)
CS
Y uma ( scrub
deser t)
Y uma ( dist
deser t)

1E-09

1E-10

10

u* (cm/s)

100

Figure 2-3. Comparison between the Alfaro et al. (2003) model relationship for FS and CS
sizes and the wind tunnel flux data of Nickling and Gillies (1989). Ten (out of 13) sites have a
dust production potential similar to the FS model and one site (Mesa agricultural) is closely
aligned with the CS model (after Alfaro et al., 2003).

Using the Alfaro, et al. (2003) approach, emissions of dust for soils can be confined to four
different emission factors, depending on the geometric mean grain size, as determined by the
methods of Chatenet, et al. (1996). The model predictions were tested against the wind tunnel
data set of Nickling and Gillies (1989) and found to fit the measured data satisfactorily. Of key
importance is that Chatenet, et al. (1996) established relationships between the 12 soil types that
are defined in the classical soil texture triangle and their four dry soil types (silt [FSS], sandy silt
[FS], silty sand [MS], and sand [CS]). The soil texture categorization and the relationships
among texture assignments and soil groupings are discussed below.

Reservoir Characteristics
Dust emissions from vacant lands are limited by the amount of erodible soil available for
suspension into the atmosphere. In addition to the amount of soil present, the condition of the
soils, including textural and stability, as well as climatological factors influence the total wind
blown dust emission potential of a given parcel of vacant land. The amount of soil available for
a given land parcel is referred to as the reservoir and can be classified as limited or unlimited.
Classification of reservoirs as limited or unlimited has implications with respect to the duration
of time over which the dust emissions are generated. In general, the reservoirs should be
classified in terms of the type of soils, the depth of the soil layer, soil moisture content and
meteorological parameters. Finally, the time required for a reservoir to recharge following a
wind event is influenced by a number of factors including precipitation and snow events and
freezing conditions of the soils.
Given that the soils database for use in the project does not provide information concerning the
moisture content or the depth of the soil layer, certain assumption are made regarding the
2-7

May2007

determination and classification of soil reservoirs. These assumptions are based primarily on the
land use type and stability of the vacant land parcel. Reservoirs are classified as limited for
stable land parcels and unlimited for unstable land parcels.
The duration and amount of precipitation and snow and freeze events will also affect the dust
emissions from wind erosion. Barnard (2003) has compiled a set of conditions for treating these
events based on seasons, soil characteristics and the amounts of rainfall and snow cover. These
conditions were based on limited information found in the literature and additional assumptions.
The results of the analysis of Barnard are summarized in Tables 2-3 and 2-4. .
Table 2-3. Number of days after precipitation event to re-initiate wind erosion for rainfall
amounts (constant) exceeding 2 inches.
Soil type
Spring/Fall Summer Winter
Sand
Sandy Loam
Fine Sand Loam
Loam
Silt Loam
Sandy Clay Loam
Clay Loam
Silty Clay Loam
Clay

3
3
3
4
4
4
5
6
7

2.1
2.1
2.1
2.9
2.9
2.9
3.6
4.3
5

4.2
4.2
4.2
3.8
3.8
3.8
7.2
8.6
10

Table 2-4. Number of days after precipitation event to re-initiate wind erosion for rainfall
amounts (constant) less than or equal to 2 inches.
Soil type
Spring/Fall Summer Winter
Sand
Sandy Loam
Fine Sand Loam
Loam
Silt Loam
Sandy Clay Loam
Clay Loam
Silty Clay Loam
Clay

1
1
1
2
2
2
3
4
5

0.7
0.7
0.7
1.4
1.4
1.4
2
2.8
3.6

1.4
1.4
1.4
2.8
2.8
2.8
4
5.6
7.2

Soil Disturbance
It has been noted that the level of disturbance of an erodible surface is an important parameter in
the estimation of wind blown dust emissions. Disturbed surfaces tend to generate more dust than
un-disturbed surfaces. In the application of the Phase I model, different emissions rates were
applied for disturbed versus un-disturbed surfaces. The assumed disturbance level of the surface
was to be determined by the land type and invariant in time and across the modeling domain.
Thus, assumptions were required to assign surface disturbance based on land cover type. As
noted previously, the disturbance level of a surface more appropriately has the effect of altering
the threshold surface friction velocity; disturbed surfaces have lower thresholds while
undisturbed surfaces exhibit higher threshold friction velocities.

2-8

May2007

The disturbance level of various surfaces across a regional scale modeling is difficult to
determine given the lack of detail in both the LULC and soils data available for use in the model.
Except for agricultural lands, which are treated separately in the model as described below,
vacant land parcels are typically un-disturbed unless some activity is present such as to cause a
disturbance, for example, off-road vehicle activity in desert lands, or animal grazing on
rangelands.
For the RMC Phase II model implementation, all non-agricultural land types are considered undisturbed, since there is no a priori information to indicate otherwise for the regional scale
modeling domain to be considered. Additional information concerning disturbance levels for
certain land types should be was investigated to determine whether an assumed percentage of
specific land types can be considered disturbed versus un-disturbed. The windblown dust
emission model application for the draft Phoenix NAA emission inventory considered various
assumptions regarding the disturbance levels of barren lands and shrublands only, as documented
in Mansell and Hoats, 2007. Revised assumptions regarding disturbance levels of various land
types for the final inventory are presented and discussed in Section 4 of this report.

Agricultural Land Adjustments
Unlike other types of vacant land, windblown dust emissions from agricultural land are subject
to a number of non-climatic influences, including irrigation and seasonal crop growth. As a
result, several non-climatic correction or adjustment factors were developed for applicability to
the agricultural wind erosion emissions. These factors included:
•
•
•
•
•

Long-term effects of irrigation (i.e., soil “clodiness”);
Crop canopy cover;
Post-harvest vegetative cover (i.e., residue);
Bare soil (i.e., barren areas within an agriculture field that do not develop crop
canopy for various reasons, etc.); and
Field borders (i.e., bare areas surrounding and adjacent to agricultural fields).

The methodology used to develop individual non-climatic correction factors for the Phase I study
was described in detail in ENVIRON, 2004. Most of these methods were based upon previous
similar work performed by the California Air Resources Board (CARB) in their development of
California-specific adjustment factors for USDA’s Wind Erosion Equation (WEQ) (CARB,
1997). These correction factors were developed for specific soil textures, crop types, and
geographic locations and then applied to the wind erosion estimates developed from the wind
tunnel studies. Correction factors are developed only for the 17 field crops specifically identified
in the BELD3.1 data set (i.e., alfalfa, barley, corn, cotton, grass, hay, oats, pasture, peanuts,
potatoes, rice, rye, sorghum, soybeans, tobacco, wheat, and miscellaneous crops). Due to the
insufficient characterization of the wind erosion emission processes for orchards and vineyards,
correction factors for this type of agricultural land were not developed.
For the current windblown dust emission model application, these same non-climatic
adjustments are applied. However, because the BELD3 database will not be used, these factors
are related to the agricultural land types available in the LULC data used for the project. The
existing county-level crop percentages from the BELD3 database are linked to the aggregated
2-9

May2007

agricultural land parcels from the LULC data used. Specific updates to the agricultural
information for Maricopa County are considered, as discussed in Section 5 of this report.
The agricultural correction factors are applied to the wind erosion emission rates for agricultural
lands developed from wind tunnel studies. The data and methodology used for developing the
correction factors is documented in ENVIRON, 2003b, and summarized below.

Long-Term Irrigation Effect Correction Factor
The correction factor for the long-term effects of irrigation is as follows:
Cil = Ii/In
Where:

Cil =
II =
In =

correction factor for long-term effects of irrigation;
irrigated soil erodibility (tons/acre/year); and
non-irrigated soil erodibility (tons/acre/year).

This correction factor is the ratio of irrigated and non-irrigated soil erodibilities (“I”). Nonirrigated soil erodibility values (In) can be assigned to each soil texture (U.S. EPA, 1974; U.S.
EPA, 1977). Irrigated soil erodibilities (Ii) were assigned by staff of the USDA Agricultural
Research Service (ARS) to corresponding non-irrigated soil erodibilities (In) as shown in Table 3
on Page 7.11-23 of the ARB windblown dust document (ARB, 1997). The long-term irrigation
effect correction factors are developed for each soil texture and applied to all irrigated croplands,
regardless of crop type. This correction factor has a value of 1.0 for all non-irrigated croplands.
The correction factor is applied throughout the year with no seasonal variation.

Crop Canopy Correction Factor
The correction factor for crop canopy cover is as follows:
Ccc = exp (-0.201CC0.7366)
Where: Ccc = correction factor for canopy cover;
exp = exponential function; and
CC = canopy cover (percent).
This correction factor is shown as Equation 7 on Page 7.11-26 of the ARB windblown dust
document (ARB, 1997). Because the crop canopy cover correction factor equation contains an
exponential function, the correction factor can change significantly with relatively small changes
in percent crop cover. In the absence of canopy cover (i.e., CC = 0 percent), the correction factor
is 1.000. With total canopy cover (i.e., CC = 100 percent), the correction factor is 0.0025 (i.e.,
effectively zero). More realistic canopy cover values of 10 and 20 percent give correction factors
of 0.334 and 0.161, respectively. As a result, windblown emissions can vary significantly for a
given crop depending upon the stage of canopy growth. For this reason, crop-specific canopy
profiles should be developed; however, the ability to develop these profiles (i.e., growth curves)
is dependent on the availability of data, and the resources and time to collect these data.

2-10

May2007

Post-Harvest Soil Cover Correction Factor
The correction factor for post-harvest soil cover is as follows:
Csc = exp (-0.0438SC)
Where: Csc = correction factor for post-harvest soil cover;
exp = exponential function; and
SC = post-harvest soil cover (percent).
This correction factor is shown as Equation 8 on Page 7.11-28 of the ARB windblown dust
document (ARB, 1997). The post-harvest soil cover correction factor applies to the period of
time between harvest and the next year’s planting. Because the post-harvest soil cover
correction factor equation contains an exponential function, the correction factor can change
significantly with relatively small changes in percent post-harvest soil cover. Without any postharvest soil cover (i.e., SC = 0 percent), the correction factor is 1.000. With total post-harvest
soil cover (i.e., SC = 100 percent), the correction factor is 0.013 (i.e., effectively zero). More
realistic post-harvest soil cover values of 10 and 20 percent give correction factors of 0.645 and
0.416, respectively.
Unlike canopy cover that varies throughout the growing season, the level of post-harvest soil
cover is assumed constant during the post-harvest to pre-planting period. If disk-under
operations are conducted for particular crops, then two levels of post-harvest soil cover will be
used.
As with the crop canopy during the growing season, crop-specific post-harvest soil cover profiles
will need to be developed for the non-growing season. All of the issues discussed regarding crop
canopy (e.g., weekly average versus aggregated monthly, non-field crops, sub-state variability,
etc.) are also applicable to developing correction factors for post-harvest soil cover.
As described above for the crop canopy correction factor, the planting and harvesting data for
RUSLE2 is used to develop the post-harvest soil cover correction factor (ARS, 2003; Lightle,
2003). RUSLE2 provides crop-specific residue profiles for individual CMZs. However, residue
levels are extremely dependent upon the equipment treatments conducted between harvest and
planting.
Also, the Conservation Technology Information Center (CTIC) maintained by Purdue University
provides information regarding the amount of residue left on a field after harvest (e.g., 0-15
percent, 15-30 percent, >30 percent), by crop and by county for the U.S. These data are collected
from surveys and stored in CTIC’s Crop Residue Management Program (CRM) database
(Towery, 2003). State- and county-level data are available on-line for years 1989–1998, 2000,
and 2002. Years 1989–1998 are for a suite of 8 crops; years 2000 and 2002 are for 8-crop and
22-crop suites.

2-11

May2007

Bare Soil Adjustment Correction Factor
The correction factor for bare soil accounts for the fraction of cultivated area that remains barren
during the growing cycle. There are many possible reasons for this including uneven ground,
uneven irrigation, soil salinity, pest damage, etc.
The bare soil adjustment correction factor is simply a small fraction applied to the total
cultivated acreage. The ARB windblown dust document uses bare soil fractions of 0.5 percent
for crop acreage and 0.05 percent for pasture (ARB, 1997). These fractions were estimated from
limited visual observations by ARB staff. Although statistics quantifying bare soil fractions have
not been identified, the USDA has indicated that 2-3 percent of planted cropland experiences
“crop failure” (USDA, 1997b). The term “crop failure” appears to indicate that planting
occurred, but that harvest did not. However, it may not be appropriate to assume that crop
failure acreage is equivalent to bare soil acreage (i.e., some vegetation growth may have
occurred, but for some reason the harvest did not). Therefore, ARB’s assumed bare soil fractions
seem to be reasonable.
Although the bare soil adjustment correction factor is relatively small compared to overall
agricultural acreage, the contribution from the bare soil area may be significant because many of
the other non-climatic correction factors are not applicable (i.e., crop canopy cover, post-harvest
vegetative cover, post-harvest planting, etc.).
The assumed ARB bare soil adjustment correction factors is applied throughout the year and
does not vary by month or season.

Border Adjustment Correction Factor
The correction factor for border adjustment accounts for the fact the surrounding borders of most
agricultural fields (excluding pastures) that are not covered in vegetation.
The border adjustment correction factor is simply a small fraction applied to the total cultivated
acreage. The ARB windblown dust document uses fractions of 0.5 percent for crop acreage;
pastures are assumed to have no borders (ARB, 1997). These fractions were estimated from
limited visual observations by ARB staff.
Like the bare soil adjustment correction factor, the border adjustment correction factor is
relatively small compared to overall agricultural acreage. However, the contribution from
agricultural field borders may be significant. In fact, it may be more significant than the bare
soil areas because the field borders are typically non-irrigated (i.e., long- and short-term
irrigation adjustments are not applicable.
The assumed ARB border adjustment correction factor is applied throughout the year and does
not vary by month or season.

2-12

May2007

3. INPUT DATA

The various data sets required for implementation of the windblown dust emission model are
summarized in this section. These include:
•
•
•
•

Landuse/landcover data;
Soil characteristics data;
Meteorological data, and;
Agricultural data

Landuse/Landcover
Landuse and landcover data are required by the model to determine the susceptibility of the
surfaces to wind erosion. As discussed previously, wind erosion is initiated when wind speeds
exceed the threshold wind speed as determined by surface friction velocities. Surface friction
velocities are dependent on the surface roughness lengths, which are assigned based on the
landuse/landcover characteristics.
The current application of the model utilizes landuse data for Maricopa County obtained from
the Maricopa Association of Governments (MAG). These data provide varying degrees of detail
with respect to urban lands and natural landscapes within the modeling domain. Because these
data cover only Maricopa County and the Phoenix NAA region of Pinal county, other landuse
data were required. The Southwest GAP database was used for this purpose.
The purpose of the Gap Analysis Program (GAP) is to provide regional assessments of the
conservation status of native vertebrate species and natural land cover types and to facilitate the
application of this information to land management activities. The National GAP URL is
http://www.gap.uidaho.edu/. The GAP is conducted as state-level projects and is coordinated by
the USGS Biological Resources Division. Currently the program is developing land cover
mappings for all U.S. States. The entire GAP process for a state requires four to six years.
Although each state is being developed separately, detailed vegetation species covers are being
developed based on predetermined classifications.
The National GAP data is available in an Albers Conical Equal Area projection coordinate
system at a nominal spatial resolution of approximately 50 meters. Depending on the state, a
minimum mapping unit of 2, 5, 40 or even 100 hectares (1 km2) is used, although 0.09 hectares
(30 m2) is most common. The land cover classifications are based on the National Vegetation
Classification System and are derived primarily from Landsat Thematic Mapper (TM) imagery.
The base year for the TM scenes used by each state is supposed to be less than three years old at
the start of the project. Ancillary input data from aerial photography and other maps is also used.
The classification system provides for several hundred species designations, but includes broad
categories stratified according to primary, secondary and tertiary coverages based on percent of
land cover in each of several broad regions.
For model application of Maricopa and Pinal Counties, the MAG and SW GAP landuse data
bases were merged to obtain a single coverage for the entire modeling domain. Table 3-1
presents the landuse classifications available within the final merged dataset. Also included in
3-1

May2007

Table 3-1 are the assignments of each LULC class to the corresponding dust code used in the
model. Note that the assignments for each LULC category presented in Table 3-1 differ from
those used in the development of the draft inventory. These revised assignments were based a
review and assessment of the landuse categories specific to the Phoenix area conducted by staff
at the MCAQD and MAG. The dust code is used to determine the surface roughness lengths as a
function of landuse/landcover. These roughness lengths, in turn determine the threshold surface
friction velocities, as discussed previously in Section 2. Table 3-2 presents the assigned surface
roughness lengths as a function of landuse/landcover and dust codes. Note that for dust codes 1
(urban lands), 2 (forest) and 5 (orchards and vineyards), the assumed surface roughness lengths
result in threshold surface friction velocities with magnitudes too high to be considered
susceptible to wind erosion, and are therefore not included in the model. Figure 3-1 displays the
complete, merged LULC data used for the project.
Table 3-1. Merged land Use/Land Cover classifications (codes < 1000 correspond to MAG LU
database).
LU_MRG
_Code
0
100
110
120
130
140
150

LU_Code
0
100
110
120
130
140
150

Description
N/A
General Residential - Residential where no detail available
Rural Residential - <= 1/5 du per acre
Estate Residential - 1/5 du per acre to 1 du per acre
Large Lot Residential (SF) - 1 du per acre to 2 du per acre
Medium Lot Residential (SF) - 2-4 du per acre
Small Lot Residential (SF) - 4-6 du per acre

160

160

Very Small Lot Residential (SF) - >6 du per acre (includes
mobile home parks)

1

161
170
180
190

161
170
180
190

Very Small Lot Res (SF-Mobile Homes) - Mobile home
parks/RV Parks (>6 du per acre)
Medium Density Residential (MF) - 5-10 du per acre
High Density Residential (MF) - 10-15 du per acre
Very High Density Residential (MF) - > 15 du per acre

1
1
1
1

198

198

199
200
201
202
203
210
220
230
240
250

199
200
201
202
203
210
220
230
240
250

Parking structures serving Residential - Parking structures
serving Residential
Parking lots serving Residential - Parking lots serving
Residential
General Commercial - Commercial where no detail available
Very Low Density Commercial - Amusement facilities
Low Density Commercial - Movie Theatres, Skating Rinks
Greenhouse Commercial - Nurseries, Greenhouses
Specialty Commercial - <=50,000 square feet
Neighborhood Commercial - 50,000 to 100,000 square feet
Community Commercial - 100,000 to 500,000 square feet
Regional Commercial - 500,000 to 1,000,000 square feet
Super-Regional Commercial - >= 1,000,000 square feet

298

298

Parking structures serving Commercial - Parking structures
serving Commercial

1

299
300
310
320

Parking lots serving Commercial - Parking lots serving
Commercial
General Industrial - Industrial where no detail available
Warehouse/Distribution Centers Industrial -

1
1
1
1

299
300
310
320

Dust_Code
0

1
1
1
1
1
1

1
1
1
1
1
1
1
1
1
1
1

3-2

May2007

LU_MRG
_Code

LU_Code

398
399
400
410
420
430

398
399
400
410
420
430

498
499
500

498
499
500

510
511
512
513
520
521

510
511
512
513
520
521

522

522

523

523

524
525
530
531
532
533
534
540

524
525
530
531
532
533
534
540

Description
Parking structures serving Industrial - Parking structures
serving Industrial
Parking lots serving Industrial - Parking lots serving Industrial
Office General - Office where no detail available
Office Low Rise - 1-4 stories
Office Mid Rise - 5-12 stories
Office High Rise - 13 stories or more
Parking structures serving Office - Parking structures serving
Office
Parking lots serving Office - Parking lots serving Office
General Employment - Employment where no detail available
Tourist and Visitor Accommodations - Hotels, motels and
resorts
Motels - Motels
Hotels - Hotels
Resorts - Resorts
Educational - Public schools, private schools, universities
Schools (K-12 grade) - Schools
Post High School Institutions - Including public and private
colleges and technical training institutions
Arizona State University - ASU Main and Extended
Campuses
Dormitories - Dormitories associated with educational
institutions
Preschool/Daycare facilities - Preschool/Daycare facilities
Institutional - Includes hospitals, churches
Medical Institutions - Hospitals/Medical Centers
Religious Institutions - Churches/Religious Institutions
Nursing Homes - Nursing Homes (Group Quarter)
Assisted Care Facilities - Assisted Care Facilities
Cemeteries -

Dust_Code

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1

550
551

550
551

552

552

Public Facilities - Includes community centers, power substations, libraries, city halls, police and fire stations and other
government facilities
Public Offices - Includes city halls
Public Services - Includes community centers, libraries, police
and fire stations, courts, prisons and other government
services

553
554

553
554

Large Public Facilities - Includes power sub-stations, Work
yards, Sewer and Water treatment plants
Military - Military Use

1
1

555

555

Limited Use Public Facilities - Very small difficult to access
parcels

1

560
570
571
572
573
574
580

560
570
571
572
573
574
580

Special Events - Includes stadiums, sports complexes, and
fairgrounds
Other Employment (low) - Proving grounds, land fills
Landfill - Landfill
Sand and Gravel - Sand and Gravel
Proving Grounds - Proving Grounds
Mining - Mining
Other Employment (medium) -

1
1
7
7
7
7
1

1
1
1

3-3

May2007

LU_MRG
_Code
590

LU_Code
590

598

598

599

599

600

600

610
611
612
613
614
620
621
699
700
710
720

610
611
612
613
614
620
621
699
700
710
720

730

730

Transportation - Includes railroads, railyards, transit centers
and freeways
Parking Lots - Parking Lots
Parking Structures - Parking Structures
Park and Ride lots - Park and Ride lots
Transit Center - Transit Center
Airports - Includes public use airports
Sky Harbor Airport - Sky Harbor Airport
Unassigned
General Open Space - Open Space where no detail available
Active Open Space - Includes parks
Golf courses Passive Open Space - Includes mountain preserves and
washes

731
740
750
800

731
740
750
800

Restricted Open Space - Restricted Open Space (Including
Firing Range)
Water Agriculture Multiple Use General - Multiple Use where no detail available

7
7
3
1

798

798

Parking structures serving Open Space - Parking structures
serving Open Space

1

799

799

Parking lots serving Open Space - Parking lots serving Open
Space

7

810
820
821
830

810
820
821
830

Business Park - Includes enclosed industrial, office or retail in
a planned environment
Mixed Use - Jurisdiction defined
Mixed Use/Indian Community - Mixed Use/Indian Community
Planned Developments -

1
1
1
1

898

898

Parking structures serving Multiple Use - Parking structures
serving Multiple Use

1

899
900
910
920
930
940

899
900
910
920
930
940

Parking lots serving Multiple Use - Parking lots serving
Multiple Use
Vacant (existing land use database only) - Vacant
Developing Residential - Residential Under Construction
Developing Commercial - Commercial Under Construction
Developing Industrial - Industrial Under Construction
Developing Office - Office Under Construction

1
7
7
7
7
7

950

950

960
970
980
999

960
970
980
999

Description
Other Employment (high) Parking structures serving Facilities/Emp - Parking structures
serving Facilities/Employment
Parking lots serving Facilities/Employment - Parking lots
serving Facilities/Employment
General Transportation - Transportation where no detail
available

Developing Public/Other Employment - Employment Under
Construction
Developing Transportation - Transportation Under
Construction
Developing Open Space - Developing Open Space
Developing Multiple Use - Multiple Use Under Construction
Salvage/Unknown - Evaluate on an individual basis

Dust_Code

1
1
1
1
1
1
1
1
1
1
1
1
7
7
4
7

7
7
7
7
1

3-4

May2007

LU_MRG
_Code
1000
1001
1002
1003
1004
1005
1006
1007
1008
1009
1010
1011
1012
1013
1014
1015
1016
1017
1018
1019
1020
1021
1022
1023

LU_Code
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23

1024

24

Rocky Mountain Subalpine-Montane Limber-Bristlecone Pine
Woodland

2

1025

25

Inter-Mountain Basins Subalpine Limber-Bristlecone Pine
Woodland

2

1026
1027

26
27

1028
1029

28
29

Rocky Mountain Subalpine Dry-Mesic Spruce-Fir Forest and
Woodland
Northern Pacific Mesic Subalpine Woodland
Rocky Mountain Subalpine Mesic Spruce-Fir Forest and
Woodland
Rocky Mountain Lodgepole Pine Forest

1030

30

Rocky Mountain Montane Dry-Mesic Mixed Conifer Forest and
Woodland

2

1031

31

Mediterranean California Dry-Mesic Mixed Conifer Forest and
Woodland

2

1032
1033
1034
1035
1036
1037

32
33
34
35
36
37

Rocky Mountain Montane Mesic Mixed Conifer Forest and
Woodland
Madrean Pine-Oak Forest and Woodland
Rocky Mountain Ponderosa Pine Woodland
Southern Rocky Mountain Pinyon-Juniper Woodland
Colorado Plateau Pinyon-Juniper Woodland
Great Basin Pinyon-Juniper Woodland

2
2
2
2
2
2

1038
1039
1040
1041

38
39
40
41

Inter-Mountain West Aspen-Mixed Conifer Forest and
Woodland Complex
Rocky Mountain Alpine Dwarf-Shrubland
Inter-Mountain Basins Mat Saltbush Shrubland
Rocky Mountain Gambel Oak-Mixed Montane Shrubland

2
6
6
6

Description
N/A
North American Alpine Ice Field
Rocky Mountain Alpine Bedrock and Scree
Mediterranean California Alpine Bedrock and Scree
Rocky Mountain Alpine Fell-Field
Rocky Mountain Cliff and Canyon
Sierra Nevada Cliff and Canyon
Western Great Plains Cliff and Outcrop
Inter-Mountain Basins Cliff and Canyon
Colorado Plateau Mixed Bedrock Canyon and Tableland
Inter-Mountain Basins Shale Badland
Inter-Mountain Basins Active and Stabilized Dune
Inter-Mountain Basins Volcanic Rock and Cinder Land
Inter-Mountain Basins Wash
Inter-Mountain Basins Playa
North American Warm Desert Bedrock Cliff and Outcrop
North American Warm Desert Badland
North American Warm Desert Active and Stabilized Dune
North American Warm Desert Volcanic Rockland
North American Warm Desert Wash
North American Warm Desert Pavement
North American Warm Desert Playa
Rocky Mountain Aspen Forest and Woodland
Rocky Mountain Bigtooth Maple Ravine Woodland

Dust_Code

1
1
1
1
1
1
1
1
1
1
1
7
1
7
7
1
1
7
1
7
1
7
2
2

2
2
2
2

3-5

May2007

LU_MRG
_Code
1042
1043

LU_Code
42
43

1044
1045
1046
1047
1048
1049
1050
1051
1052
1053
1054
1055
1056
1057
1058
1059
1060
1061
1062
1063
1064

44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64

1065
1066
1067
1068
1069
1070
1071
1072
1073
1074
1075
1076
1077
1078

65
66
67
68
69
70
71
72
73
74
75
76
77
78

1079

79

1080
1081
1082

80
81
82

1083
1084
1085
1086

83
84
85
86

Description
Rocky Mountain Lower Montane-Foothill Shrubland
Western Great Plains Sandhill Shrubland
Inter-Mountain Basins Mountain Mahogany Woodland and
Shrubland
Madrean Encinal
Colorado Plateau Pinyon-Juniper Shrubland
Great Basin Semi-Desert Chaparral
Inter-Mountain Basins Big Sagebrush Shrubland
Great Basin Xeric Mixed Sagebrush Shrubland
Colorado Plateau Mixed Low Sagebrush Shrubland
Mogollon Chaparral
Apacherian-Chihuahuan Mesquite Upland Scrub
Colorado Plateau Blackbrush-Mormon-tea Shrubland
Mojave Mid-Elevation Mixed Desert Scrub
Chihuahuan Succulent Desert Scrub
Chihuahuan Creosotebush Mixed Desert and Thorn Scrub
Sonoran Paloverde-Mixed Cacti Desert Scrub
Inter-Mountain Basins Mixed Salt Desert Scrub
Chihuahuan Stabilized Coppice Dune and Sand Flat Scrub
Sonora-Mojave Creosotebush-White Bursage Desert Scrub
Sonora-Mojave Mixed Salt Desert Scrub
Inter-Mountain Basins Montane Sagebrush Steppe
Southern Rocky Mountain Juniper Woodland and Savanna
Inter-Mountain Basins Juniper Savanna
Apacherian-Chihuahuan Piedmont Semi-Desert Grassland and
Steppe
Inter-Mountain Basins Big Sagebrush Steppe
Inter-Mountain Basins Semi-Desert Shrub Steppe
Chihuahuan Gypsophilous Grassland and Steppe
Rocky Mountain Dry Tundra
Rocky Mountain Subalpine Mesic Meadow
Southern Rocky Mountain Montane-Subalpine Grassland
Western Great Plains Foothill and Piedmont Grassland
Central Mixedgrass Prairie
Western Great Plains Shortgrass Prairie
Western Great Plains Sandhill Prairie
Inter-Mountain Basins Semi-Desert Grassland
Rocky Mountain Subalpine-Montane Riparian Shrubland
Rocky Mountain Subalpine-Montane Riparian Woodland
Rocky Mountain Lower Montane Riparian Woodland and
Shrubland
North American Warm Desert Lower Montane Riparian
Woodland and Shrubland
Western Great Plains Riparian Woodland and Shrubland
Inter-Mountain Basins Greasewood Flat
North American Warm Desert Riparian Woodland and
Shrubland
North American Warm Desert Riparian Mesquite Bosque
North American Arid West Emergent Marsh
Rocky Mountain Alpine-Montane Wet Meadow

Dust_Code

6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
6
4
4
4
4
6
6
4
1
4
4
4
4
4
4
4
6
2
6
6
6
2
6
2
1
1

3-6

May2007

LU_MRG
_Code
1087
1088

LU_Code
87
88

1089
1090
1091
1092
1093
1094
1095
1096
1097

89
90
91
92
93
94
95
96
97

1098
1099
1100

98
99
100

1101

101

Great Basin Foothill and Lower Montane Riparian Woodland
and Shrubland
Western Great Plains Floodplain Herbaceous Wetland
Mediterranean California Red Fir Forest and Woodland
Sierra Nevada Subalpine Lodgepole Pine Forest and
Woodland

1102
1103
1104
1105
1106
1107
1108
1109
1110
1111
1112
1113
1114
1115
1116
1117
1118
1119
1120
1121
1122
1123
1124
1125
2200
2300
2400
2500
2600
2700
2800
2900

102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
22
23
24
25
26
27
28
29

Mediterranean California Ponderosa-Jeffrey Pine Forest and
Woodland
Rocky Mountain Foothill Limber Pine-Juniper Woodland
Wyoming Basins Low Sagebrush Shrubland
Sonoran Mid-Elevation Desert Scrub
Western Great Plains Tallgrass Prairie
North Pacific Montane Grassland
Southern Colorado Plateau Sand Shrubland
Western Great Plains Mesquite Woodland and Shrubland
Open Water
Developed Mixed Desert and Thorn Scrub
Developed Medium - High Intensity
Barren Lands Non-specific
Agriculture
Disturbed Non-specific
Recently Burned
Recently Mined or Quarried
Invasive Southwest Riparian Woodland and Shrubland
Invasive Perennial Grassland
Invasive Perennial Forbland
Invasive Annual Grassland
Invasive Annual and Biennial Forbland
Recently Logged Areas
Recently Chained Pinyon-Juniper Areas
Disturbed Oil Well
Alfalfa
Barley
Corn
Cotteon
Grass
Hay
Misc. crops
Oats

Description
Temperate Pacific Montane Wet Meadow
Mediterranean California Subalpine-Montane Fen
Western Great Plains Saline Depression Wetland
Chihuahuan-Sonoran Desert Bottomland and Swale Grassland
Madrean Upper Montane Conifer-Oak Forest and Woodland
Madrean Pinyon-Juniper Woodland
Chihuahuan Sandy Plains Semi-Desert Grassland
Sonora-Mojave-Baja Semi-Desert Chaparral
Madrean Juniper Savanna
Chihuahuan Mixed Salt Desert Scrub
Coahuilan Chaparral

Dust_Code

1
1
1
4
2
2
4
6
4
6
6
6
1
2
2
2
2
6
6
4
4
6
7
1
6
1
7
3
6
7
7
6
4
4
4
4
7
2
7
3
3
3
3
3
3
3
3

3-7

May2007

LU_MRG
_Code
3000
3100
3200
3300
3400
3500
3600
3700
3800
3900

LU_Code
30
31
32
33
34
35
36
37
38
39

Description
Pasture
Peanuts
Potatoes
Rice
Rye
Sorghum
Soybeans
Tobacco
Wheat
Forest (from FIA data)

Dust_Code

3
3
3
3
3
3
3
3
3
2

Table 3-2. Surface roughness lengths by LULC and dust code.
Landuse
Dust
Surface Roughness
Category
Code
Length (cm)
Agricultural
3
0.015
(bare field)
Grasslands
4
0.1
Shrublands
6
0.05
Barren Lands
7
0.002

Figure 3-1. Merged LULC data for windblown dust model application.

3-8

May2007

Soil Characteristics
Soils characteristics data (soil texture) are used in the model to determine dust emissions rates as
a function of wind speeds. Application of the emission factor relations described above requires
the characterization of soil texture in terms of the 4 soil groups considered by the model. The
characteristics, or type, of soil is one of the parameters of primary importance for the application
of the emission estimation relations derived from wind tunnel study results.
The SSURGO1 soils geographic database developed by USDA Natural Resource Conservation
Service was used as the primary soils database for this study. Because some of the survey areas
within the modeling domain were missing from the SSURGO1 database, the State Soil
Geographic Database (STATSGO) was used to fill in these regions. The SSURGO1 database
was obtained from http://soildatamart.nrcs.usda.gov while the STATSGO databases were
obtained from the Earth System Science Center (ESSC) at Penn State University
(http://www.essc.psu.edu/soil_info/).
The classification of soil textures and soil group codes is based on the standard soil triangle that
classifies soil texture in terms of percent sand, silt and clay. Combining the soil groups defined
by the work of Alfaro, et al. (2003) and Chatenet, et al. (1996) and the standard soil triangle
provides the mapping of the 12 soil textures to the 4 soil groups considered in their study.
Combining the data from these two soil texture/soil group mappings results in the unique
mapping of soil textures to the soil groups for which emission factor data can be applied. The
results of combining these soil texture definitions allows the assignment of the loam soil group in
terms of standard soil texture. The soil texture mappings are summarized in Table 3-3. Figures
3-2 and 3-3 display the merged soils data used for the project.
Table 3-3. Soil texture and soil group codes.
Soil Texture
Soil Texture
Code
Soil Group
0
N/A
No Data
Sand
1
CS
2
CS
Loamy Sand
Sandy Loam
3
MS
4
FS
Silt Loam
Silt
5
FSS
6
MS
Loam
7
MS
Sandy Clay Loam
8
FSS
Silty Clay Loam
Clay Loam
9
MS
10
MS
Sandy Clay
Silty Clay
11
FSS
12
FS
Clay

Soil Group
Code
0
4
4
3
1
2
3
3
1
3
3
1
2

3-9

May2007

Figure 3-2. Merged soil texture data for windblown dust model application.

Figure 3-3. Merged soil group data for windblown dust model application.

3-10

May2007

Meteorology
The RMC windblown dust model, as used in the present application, was developed to generate
hourly gridded estimates of PM dust emissions based on landuse, soils characteristics, hourly
meteorological data and additional information related to agricultural practices. In previous
regional applications, the necessary meteorological data have been derived from the results
regional MM5 model simulations. Additionally, for local-scale applications, meteorological data
has been developed from CALMET simulations using the regional MM5 simulation results as
inputs to the CALMET model. For the current application to the Phoenix PM10 non-attainment
area, hourly observational data was provided by MAG. These observational data were as the
basis for interpolation to gridded, hourly-resolved wind speed fields. The data provided by
MAG consists of comma-delimited ASCII files containing the meteorological fields shown in
Table 3-4.
Table 3-4. Meteorological data provided by MAG.
Column

Description

Type

1

Julian date in dddhh.ff (ff: a fraction of minute to hour)

Real

2

Y-location (I dot-point location on coarse mesh)

Real

3

X-location (J dot-point location on coarse mesh)

Real

4

Vertical height from the ground (in meter)

Real

5

U wind (in m/sec)

Real

6

V wind (in m/sec)

Real

7

Temperature (in Kelvin)

Real

8

Water vapor mixing ratio (in kg/kg)

Real

9

Pstar (in cb) (99999. for the model in nonhydrostatic
mode)

Real

10

Site ID

Char

11

Network Name

Char

12

Latitude

Real

13

Longitude

Real

14

Pressure

Real

The meteorological data tabulated above were provided for calendar year 2005 from the AZMET
weather stations listed in Table 3-5. All measurements are taken at a height of 3 meters AGL.

3-11

May2007

Table 3-5. AZMET observation stations.
Site

Abbr.

Lat

Lon

UTM (Zone 12)

Elev.
(m)

County

Buckeye

BCK1

33.400000

-112.683333

3696899

343454

304

Maricopa

Harquahala

HARQ

33.483333

-113.116667

3706876

303337

350

Maricopa

Paloma

PALO

32.926667

-112.895556

3644751

322765

219

Maricopa

Phx. Encanto
Phx.
Greenway

ENCA

33.479167

-112.096389

3704947

398135

335

Maricopa

PGRN

33.621389

-112.108333

3720728

397193

401

Queen Creek

QUEE

33.258333

-111.641667

3680110

440233

430

Maricopa

Waddell

WADD

33.618056

-112.459722

3720763

364592

407

Maricopa

Coolidge

COOL

32.980000

-111.604722

3649232

443496

422

Pinal

Maricopa

MARI

33.068611

-111.971667

3659313

409299

361

Pinal

Aguila

AGUI

33.946667

-113.188889

3758401

297716

655

Maricopa

Maricopa

For the current windblown dust model application, these observational wind data were
interpolated to the modeling grid (Figure 1-1) using a kriging algorithm. Figure 3-4 displays an
example of the results of this approach for the windspeed observational data of noon on January
28, 2006. Also shown are the locations of the AZMET observational stations.
Monthly average wind speeds obtained through interpolation of the observational data are
displayed in Figure 3-5 for the 12-km modeling domain used in the project.
Interpolated Windspeed (m/s)
12 Noon, January 28, 2006
AGUI

2

33.8

1.8
1.6

Latitude

33.6

WADD

PGRN

1.4
1.2

ENCA

HARQ
33.4

1
BCK1

0.8

33.2

QUEE

0.6
0.4

MARI

33

0.2
COOL

-113

-112.8
PALO

-112.6

-112.4

-112.2

-112

-111.8

Longitude

0

m/s

Figure 3-4. Example interpolated wind speeds for 12 Noon, January 28, 2006.

3-12

May2007

Figure 3-5. Monthly average wind speeds on the 12-km windblown dust modeling domain.

3-13

May2007

Figure 3-5. (concluded). Monthly average wind speeds on the 12-km windblown dust modeling domain

3-14

May2007

Hourly precipitation data used in the current application were based on data provided by the
Maricopa County Flood Control District and consisted of a five average (2001-2005) of
measured hourly rainfall rates. The locations of these monitoring stations are displayed in Figure
3-6. To generate gridded hourly rainfall for model application, a nearest neighbor interpolation
scheme was utilized. Figure 3-7 displays the result of the interpolation in terms of monthly total
rainfall, in inches, across the domain.

Figure 3-6. Flood Control Precipitation Sites.

3-15

May2007

3-16

May2007

Figure 3-7. Monthly total rainfall in inches (2001-2005 data)

Figure 3-7. (concluded). Monthly total rainfall in inches (2001-2005 data)

3-17

May2007

Agricultural Data
Agricultural information is used in the model to adjust the estimated windblown dust emissions
based on crop growth and agricultural management practices. The adjustments applied were
described previously in Section 2. The primary adjustments for agricultural lands are based on
the growth of crop canopy from planting to harvest. The RMC model is populated with default
crop calendars derived from a variety of sources, as discussed in Section 2. The crops
considered are those included in the BELD landuse database, which is based on USDA crop
acreages by county.
For the current application, the crop acreages included in the BELD database were compared
with the most recent USDA statistics for Maricopa and Pinal counties. This comparison is
summarized in Table 3-6. Due to inconsistencies between the BELD data (based on 1997 USDA
statistics) and the most recent data from the USDA, the default data sets for the windblown dust
model were updated to reflect the more recent information using a combination of the 2004 and
2005 USDA data for Maricopa and Pinal counties.
Table 3-6. Agricultural crops in Maricopa and Pinal Counties.
BELD Code
28
25
27
38
23
24
32
35
29
26

Crop
Misc
Cotton
Hay
Wheat
Barley
Corn
Potatoes
Sorghum
Oats
Grass

BELD
39%
38%
13%
5%
3%
1%
1%
1%
0%
0%

Maricopa
USDA 05
27%
55%
9%
8%
1%

USDA 04
13%
26%
43%
9%
8%
0%

BELD
34%
52%
5%
4%
2%
0%
0%
1%
0%
0%

Pinal
USDA 05
57%
28%
8%
5%
3%

USDA 04
3%
53%
24%
12%
7%
1%

The current version of the RMC dust model includes default crop calendars based on crops
defined in the BELD database. These data were reviewed for the study area and determined to
be acceptable as is. Table 3-7 presents these data, as currently implemented in the model.

3-18

May2007

Table 3-7. Default agricultural crop calendar for Maricopa and Pinal Counties.
Plant/Harvest Dates by CMZ and BELD category (current data in WBD model "crop_plt_dates_US.txt")
CMZ
BELD3 Crop
Plant_Spr Harv_Spr Plant_Fall Harv_Fall Cano_Spr Cano_Fall
30
22 Alfalfa
Apr
Mar
ALF01
0
30
23 Barley
May
Aug
BAR01
0
30
24 Corn
May
Oct
COR01
0
30
25 Cotton
May
Nov
COT02
0
30
26 Grass
Apr
Apr
GRA01
0
30
27 Hay
Apr
Mar
HAY01
0
30
28 Misc
0
0
30
29 Oats
May
Aug
OAT01
0
30
32 Potatoes
May
Oct
POT01
0
30
35 Sorghum
May
Oct
SOR01
0
30
38 Wheat
Oct
Sep
0
WHE03
33
22 Alfalfa
Apr
Mar
ALF01
0
33
23 Barley
Dec
Jun
0
BAR03
33
24 Corn
Apr
Oct
COR01
0
33
25 Cotton
Apr
Oct
COT02
0
33
26 Grass
Apr
Apr
GRA01
0
33
27 Hay
Apr
Mar
HAY01
0
33
28 Misc
0
0
33
29 Oats
Mar
Sep
Dec
Aug
OAT01
OAT03
33
32 Potatoes
Jan
Jun
POT01
0
33
35 Sorghum
May
Nov
SOR01
0
33
38 Wheat
Dec
Jun
0
WHE03
Most of Maricopa and Pinal counties in CMZ 33; Only NE corner of each in CMZ 30

3-19

May2007

This page intentionally blank.

3-20

May 2007

4. MODEL APPLICATION

The application of the WRAP RMC windblown fugitive dust emission model for the Phoenix PM10 nonattainment area and surrounding areas is described in this section.
Spatial Resolution and Modeling Domain
As noted previously, the RMC windblown dust model is designed to estimate fugitive windblown dust
emissions for regional air quality modeling. The outputs of the model are gridded, hourly estimates of
PM10 and PM2.5 dust emissions. For the current application to Marciopa and Pinal counties, the
modeling domain was defined based on a 12-km grid encompassing the entirety of Maricopa and Pinal
counties in Arizona. The modeling domain was displayed ion Figure 1-1 of this report.
Input datasets include soil characteristics, landuse/landcover data and gridded wind speed fields.
Meteorological data were developed at a spatial resolution of 12-km, as described in the previous section.
Although the winds are modeled at 12-km resolution, the modeling system is designed to allow higher
resolution surface characteristics data. Soil characteristics, soil texture and soil groups, were processed at
4-km using the ArcINFO GIS software. In addition, LULC data were gridded at 4-km spatial resolution.
However, higher spatial resolution of the LULC data is possible through the inclusion of the percentages
of land, by LULC category, within each 4-klm model grid cell.
Temporal Period and Resolution
Windblown dust modeling for the Phoenix PM10 NAA, and all of Maricopa and Pinal counties was
conducted for the entire calendar year 2005. The temporal duration of the modeling was determined by
the availability of the meteorological data provided by project sponsors.
The model is run on an hourly temporal resolution and provides hourly outputs of coarse (PM10 –
PM2.5) and fine (PM2.5) particulate matter dust emissions. The results are subsequently aggregated to
annual emissions estimates for reporting purposes.
Model Outputs
As previously noted, the model provides hourly gridded estimates of windblown fugitive PM dust
emissions. The output data files are formatted for input to regional air quality models, in particular, the
CMAQ model. Using GIS tools, these gridded emission estimates are summarized on the county-level as
well as at the non-attainment area level, for reporting. Model outputs were obtained with and without the
application of fugitive dust transport fractions, described below.

4-1

May 2007

Fugitive Dust Transport Fractions
The concept of fugitive dust transport fractions has been considered and refined in recent years. It has
been recognized that, due to various mechanisms, dust particles are subject to near source removal.
These mechanisms include gravitational settling, particle deposition to the ground and impaction and
removal due to particle capture by the surrounding vegetation canopy and other physical structures. The
EPA for many years had promoted the “divide by four” approach for reducing the emission from fugitive
dust sources to account for these processes. The idea is that only a limited amount of the dust emitted by
a particular source is transported significantly to affect the total available emissions in the atmosphere for
air quality grid modeling.
Recent research has shown that the amount of fugitive dust captured in the surrounding canopy or on
physical structures can be related to the physical characteristics of the land surface, i.e., land use/land
cover. The EPA recently developed county-level transport fractions for use in emissions inventory
development for air quality modeling (Pace, 2003; 2005). The county-level transport fractions were
based on the percentage of land use in each county derived from the BELD3 LULC database. The
transport fractions were calculated as a weighted sum of landuse-specific fractions for each landuse type.
Within the wind blown dust model, rather than applying county-level fractions, landuse-dependent
transport fractions were calculated based on the gridded landuse data used in the estimation methodology.
The fractions used for each of the relevant land use types are presented in Table 4-1. Note that the
inclusion of the transport fractions should only be considered in situations where the results of the model
are to be used in grid-based air quality modeling studies. For inventory reporting requirements and SIP
development, the emissions should be developed and reported without the application of the transport
fractions. For the current project, model outputs were developed without the application of transport
fractions.
Table 4-1. Transport fractions as a function of landuse.
Original Transport Revised Transport
Fractions
Fractions
LULC
Barren & Water
0.97
1.00
Agricultural
0.85
0.75
Grasses
0.70
0.75
Scrubland & Sparsely Wooded
0.60
0.75
(Shrublands)
Urban
0.30
0.00
0.30
Forested
0.00

Specific Revisions for Maricopa and Pinal Counties
As noted previously, the amount disturbance of the vacant lands for which emissions from wind erosion
are to be estimated will have a direct impact on the magnitude of those emissions. In the default
configuration of the model, all lands are assumed to be undisturbed and have stable soil characteristics.
The primary reason for this assumption was directly related to the lack of detailed information available
in the regional-scale data sets used in previous applications. However, for small-scale applications and/or
where more detailed data is available, this assumption can be relaxed.

4-2

May 2007

In the case of Maricopa and Pinal counties, the disturbance levels of the vacant land parcels were revised
to reflect a better understanding of the local landscapes, as well as to reflect various control measures (in
the case of vacant lots and construction sites) and seasonal variations in disposition of agricultural lands
(i.e., increased disturbance levels of agricultural lands prior to planting and post-harvest).
Based on consultation with the project sponsors, the percentage of disturbed acreage for each of the
individual landuse types within the MAG database were revised. The percent of disturbed acreage for
each LU type is presented in Table 4-2, which lists only those landuse categories available in the MAG
database. Outside of the Phoenix PM10 nonattainment area where the Southwest GAP database is used,
it was assumed that 30% of all barren lands were disturbed, while 8% of all shrublands were assumed
disturbed. Table 4-2 also presents the assignment of each landuse category to the 8 general land
categories for aggregation and reporting of modeling results. Note that the water landuse category has
been re-assigned to dust code 7 (barren land) to reflect the fact that, within the MAG database, these
regions are essentially alluvial fans along and dry riverbeds and washes.
The treatment of agricultural lands was further refined to reflect varying disturbance levels of the lands
based on crop-specific tilling and harvesting schedules. The primary crops considered for this treatment
include barley, corn, cotton and wheat. Based on the crop calendars for these crops, soil disturbance
levels where assigned for each month. In general, during tilling activities, 100% of the crop-specific
agricultural lands were assumed disturbed. The disturbance levels during harvesting varied by crop and
month. During the growing season, the default undisturbed soil assumption is applied. Note that during
the growing season, reductions to the estimated windblown dust emissions for agricultural lands are
applied based on the growth of crop canopy. Table 4-3 presents the assumed soil disturbance percentages
by crop and month.
Disturbed land surfaces have the effect of reducing the threshold surface friction velocities required to
initiate wind erosion. Based on a review of studies found in the literature (see Tables 2-1 and 2-2) and
from various sensitivity scenarios performed for the WRAP during model development, assumed
percentage reductions in the threshold friction velocities were applied for disturbed vacant lands. In the
present application, for disturbed shrublands, the threshold friction velocities were assumed to be 50% of
the undisturbed values, while for disturbed barren lands the threshold friction velocities were assumed to
be 27% of the undisturbed value.
Table 4-2. Revised disturbance assumptions for MAG Landuse/Landcover classifications.

LU_CODE
100
110
120
130
140
150
160
161
170
180
190
198
199

Model Output
category
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED

Description
General Residential - Residential where no
Rural Residential - <= 1/5 du per acre
Estate Residential - 1/5 du per acre to 1
Large Lot Residential (SF) - 1 du per acre
Medium Lot Residential (SF) - 2-4 du per a
Small Lot Residential (SF) - 4-6 du per ac
Very Small Lot Residential (SF) - >6 du p
Very Small Lot Res (SF-Mobile Homes) - Mob
Medium Density Residential (MF) - 5-10 du
High Density Residential (MF) - 10-15 du p
Very High Density Residential (MF) - > 15
Parking structures serving Residential - P
Parking lots serving Residential - Parking

Dust
Code
1
1
1
1
1
1
1
1
1
1
1
1
1

Areal %
Disturbance
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%

4-3

Z0 (cm)
100
100
100
100
100
100
100
100
100
100
100
100
100

May 2007

LU_CODE
200
201
202
203
210
220
230
240
250
298
299
300
310
320
398
399
400
410
420
430
498
499
500
510
511
512
513
520
521
522
523
524
525
530
531
532
533
534
540
550
551
552
553
554
555
560
570
571

Model Output
category
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
OTHER

Description
General Commercial - Commercial where no d
Very Low Density Commercial - Amusement fa
Low Density Commercial - Movie Theatres
Greenhouse Commercial - Nurseries
Specialty Commercial - <=50
Neighborhood Commercial - 50
Community Commercial - 100
Regional Commercial - 500
Super-Regional Commercial - >= 1
Parking structures serving Commercial - Pa
Parking lots serving Commercial - Parking
General Industrial - Industrial where no d
Warehouse/Distribution Centers Industrial Parking structures serving Industrial - Pa
Parking lots serving Industrial - Parking
Office General - Office where no detail av
Office Low Rise - 1-4 stories
Office Mid Rise - 5-12 stories
Office High Rise - 13 stories or more
Parking structures serving Office - Parkin
Parking lots serving Office - Parking lots
General Employment - Employment where no d
Tourist and Visitor Accommodations - Hote
Motels - Motels
Hotels - Hotels
Resorts - Resorts
Educational - Public schools
Schools (K-12 grade) - Schools
Post High School Institutions - Including
Arizona State University - ASU Main and Ex
Dormitories - Dormitories associated with
Preschool/Daycare facilities - Preschool/D
Institutional - Includes hospitals
Medical Institutions - Hospitals/Medical C
Religious Institutions - Churches/Religiou
Nursing Homes - Nursing Homes (Group Quart
Assisted Care Facilities - Assisted Care F
Cemeteries Public Facilities - Includes community ce
Public Offices - Includes city halls
Public Services - Includes community cent
Large Public Facilities - Includes power
Military - Military Use
Limited Use Public Facilities - Very small
Special Events - Includes stadiums
Other Employment (low) - Proving grounds
Landfill - Landfill

Dust
Code
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
7

Areal %
Disturbance
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30.00%

4-4

Z0 (cm)
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
100
0.002

May 2007

LU_CODE
572
573
574
580
590
598
599
600
610
611
612
613
614
620
621
700
710
720
730
731
740
750
800
798
799
810
820
821
830
898
899
900
910
920
930
940
950
960
970
980
999

Model Output
category
OTHER
OTHER
OTHER
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
VACANT
VACANT
VACANT
VACANT
VACANT
WATER
AGRICULTURE
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
DEVELOPED
VACANT
RESIDENTIAL
CONSTRUCTION
COMMERCIAL
CONSTRUCTION
COMMERCIAL
CONSTRUCTION
COMMERCIAL
CONSTRUCTION
COMMERCIAL
CONSTRUCTION
TRANSPORTATION
CONSTRUCTION
VACANT
COMMERCIAL
CONSTRUCTION
DEVELOPED

Dust
Code
7
7
7
1
1
1
1
1
1
1
1
1
1
1
1
7
7
4
7
7
7
3
1
1
7
1
1
1
1
1
1
7

Areal %
Disturbance
30.00%
30.00%
30.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30.00%
30.00%
0.00%
30.00%
30.00%
0.00%
70.00%
0.00%
0.00%
30.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
30.00%

Z0 (cm)
0.002
0.002
0.002
100
100
100
100
100
100
100
100
100
100
100
100
0.002
0.002
0.1
0.002
0.002
0.002
0.015
100
100
0.002
100
100
100
100
100
100
0.002

Developing Residential - Residential Under

7

75.00%

0.002

Developing Commercial - Commercial Under C

7

75.00%

0.002

Developing Industrial - Industrial Under C

7

75.00%

0.002

Developing Office - Office Under Construct

7

75.00%

0.002

Developing Public/Other Employment - Emplo

7

75.00%

0.002

Developing Transportation - Transportation
Developing Open Space - Developing Open Sp

7
7

75.00%
30.00%

0.002
0.002

Developing Multiple Use - Multiple Use Und
Salvage/Unknown - Evaluate on an individua

7
1

30.00%
0.00%

0.002
100

Description
Sand and Gravel - Sand and Gravel
Proving Grounds - Proving Grounds
Mining - Mining
Other Employment (medium) Other Employment (high) Parking structures serving Facilities/Emp Parking lots serving Facilities/Employment General Transportation - Transportation wh
Transportation - Includes railroads
Parking Lots - Parking Lots
Parking Structures - Parking Structures
Park and Ride lots - Park and Ride lots
Transit Center - Transit Center
Airports - Includes public use airports
Sky Harbor Airport - Sky Harbor Airport
General Open Space - Open Space where no d
Active Open Space - Includes parks
Golf courses Passive Open Space - Includes mountain pre
Restricted Open Space - Restricted Open Sp
Water Agriculture Multiple Use General - Multiple Use where
Parking structures serving Open Space - Pa
Parking lots serving Open Space - Parking
Business Park - Includes enclosed industr
Mixed Use - Jurisdiction defined
Mixed Use/Indian Community - Mixed Use/Ind
Planned Developments Parking structures serving Multiple Use Parking lots serving Multiple Use - Parkin
Vacant (existing land use database only) -

4-5

May 2007

Table 4-3. Monthly, crop-specific soil disturbance percentages.
Month
Corn
Cotton
Barley
January
100
100
-1
February
100
100
March
100
100
April
100
100
May
100
June
July
30
August
10
September
October
80
November
December
1

Wheat
10
100
100

(–) denotes no revisions to default disturbance levels

4-6

May 2007

5. MODELING RESULTS

The results of the windblown PM10 dust emission modeling is presented in this section. The
emission estimation methodology and required input data were described in Section 2 and
Section 3 of this report. Specific revisions to the data and/or model implementation for the
Phoenix PM10 Non-Attainment Area, as well as the entirety of Maricopa and Pinal counties,
were discussed in Section 4.
Preliminary Model Simulations
A number of preliminary simulations were performed prior to finalizing the various inputs and
assumptions associated with the development of emission estimates for windblown fugitive PM
dust. These initial model simulations were performed with the assumed landuse specific soil
disturbance percentages presented in Table 4-2. These results provide the base default estimates
upon which the specific agricultural adjustments and revisions were built.
Preliminary default results of the windblown model for 2005 are presented in Tables 5-1 and 5-2.
Table 5-1 presents the modeled monthly 2005 windblown PM10 dust emissions for the Phoenix
PM10 Non-Attainment Area for each of the 8 aggregated landuse types defined in Table 4-2.
Note that while nearly one third of Maricopa County is within the Phoenix PM10 NAA, only a
very small portion of Pinal County is included in the NAA. Note also that the emission estimates
presented in these tables do not include the application of the fugitive dust transport fraction,
discussed in the previous section of this report. Thus, these estimates are appropriate for
emission inventory reporting purposes and for SIP development efforts.
Monthly 2005 county-level PM10 emission estimates for Maricopa and Pinal Counties are
presented in Table 5-2 for each landuse category defined in Table 4-2. As seen, the majority of
the windblown dust emissions are from the vacant land and “other” category. Shrublands and
grasslands are included within the “other” category, which comprises a significant portion of
both Maricopa and Pinal Counties. A relatively small amount of windblown dust is estimated
from the agricultural lands in each county. Based on the distribution of the landcover across the
domain, and the reductions applied to agricultural lands due to crop canopy and agricultural
management practices, these results appear reasonable in light of the various assumptions
incorporated in the model.
Figure 5-1 provides a graphical representation of these results. As seen, the estimated dust
emissions peak during the spring and summer months reflecting the impact of higher wind
speeds and agricultural activity during these time periods. The corresponding results for the
entire counties of Maricopa and Pinal are presented in Figure 5-2.

5-1

May 2007

Table 5-1. Preliminary 2005 Monthly PM10 windblown dust emissions for the Phoenix NAA.
Preliminary 2005 PM10 Windblown Dust Emission (tons) -- Phoenix NAA
Month
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Annual

Other
Comm. Res.
Trans.
Water
Total
Agricultural Constr. Constr. Constr. Developed Vacant (Alluvial) Other Barley
1.5
4.3
27.0
0.3
0.0 176.6
17.8 23.1
0.00
250.6
1.4
7.4
45.4
0.5
0.0 310.5
41.7 26.5
0.00
433.4
3.4
11.6
69.5
0.7
0.0 503.2
65.5 55.4
0.00
709.2
6.5
13.9
84.4
0.8
0.0 642.3
84.5 67.5
0.00
900.1
5.8
13.6
83.8
0.8
0.0 638.4
91.0 64.0
0.00
897.3
2.5
14.3
87.8
0.8
0.0 659.8
101.6 41.4
0.00
908.3
4.9
17.0 100.5
1.1
0.0 786.3
114.1 77.7
0.00
1,101.7
4.4
12.9
75.2
0.9
0.0 586.2
80.0 61.4
0.00
821.0
2.2
7.8
49.0
0.5
0.0 363.5
51.2 33.1
0.00
507.4
2.4
6.6
42.7
0.4
0.0 309.9
44.1 25.1
0.00
431.2
1.3
4.3
30.4
0.3
0.0 201.3
22.3 16.1
0.00
276.0
0.0
2.3
18.3
0.1
0.0 110.0
6.8
3.7
0.00
141.2
7,377.5
36.2
116.0 713.9
7.3
0.0 5,288.1
720.6 495.2
0.00

Corn Cotton Wheat
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.01
0.00
0.00
0.02
0.00
0.00
0.01
0.00
0.00
0.00
0.00
0.00
0.02
0.00
0.00
0.02
0.00
0.00
0.01
0.00
0.00
0.01
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.01
0.10
0.01

Table 5-2. Preliminary 2005 Monthly PM10 windblown dust emissions for Maricopa and Pinal
Counties.
Preliminary 2005 PM10 Windblown Dust Emission (tons) -- County Totals
Other
Comm. Res.
Trans.
Water
Month Total
Agricultural Constr. Constr. Constr. Developed Vacant (Alluvial) Other
Barley
7.7
4.6
31.1
0.3
0.0 2,003.8
41.4
828.2
0.01
Jan
2,917.2
9.6
7.8
51.2
0.5
0.0 2,608.5
71.0
914.9
0.00
Feb
3,663.6
22.1
12.0
76.7
0.7
0.0 3,445.6
102.6 1,444.1
0.01
Mar
5,104.0
31.5
14.5
93.1
0.8
0.0 4,454.9
131.1 1,634.2
0.03
Apr
6,360.6
26.6
14.2
92.7
0.8
0.0 4,542.7
142.1 1,394.6
0.02
May
6,214.0
25.1
14.9
96.8
0.8
0.0 4,686.8
154.1 1,761.1
0.01
Jun
6,739.9
28.2
17.7
110.2
1.1
0.0 5,203.2
171.3 2,406.7
0.02
Jul
7,938.7
22.4
13.3
82.3
0.9
0.0 3,975.7
121.4 1,643.4
0.02
Aug
5,859.8
9.7
8.3
55.2
0.5
0.0 3,073.9
88.3
911.2
0.01
Sep
4,147.2
13.3
7.0
48.5
0.4
0.0 2,810.2
76.0
803.0
0.01
Oct
3,758.5
7.4
4.6
35.1
0.3
0.0 1,993.2
46.6
538.2
0.00
Nov
2,625.4
0.9
2.6
22.3
0.1
0.0 1,711.7
29.2
128.7
0.00
Dec
1,895.4
Annual 57,224.3
204.5
121.3
795.0
7.3
0.0 40,510.1
1,175.1 14,408.4
0.13

Corn Cotton Wheat
0.00
0.16
0.02
0.00
0.06
0.00
0.01
0.14
0.02
0.01
0.33
0.05
0.01
0.26
0.03
0.00
0.18
0.02
0.01
0.42
0.04
0.01
0.33
0.03
0.00
0.13
0.01
0.00
0.14
0.02
0.00
0.03
0.00
0.00
0.00
0.00
0.05
2.18
0.26

5-2

May 2007

Monthly PM10 Dust Emissions (tons) -- Phoenix NAA

1,200

1,000

tons

800

600

400

200

0
Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sep

Oct

Nov

Dec

Month
Agricultural

Commercial Construction

Residential Construction

Transportation Construction

Developed

Vacant

Water (Alluvial)

Other

Figure 5-1. Monthly windblown PM10 dust emissions for the Phoenix Nonattainment area.

Monthly PM10 Dust Emissions (tons) - County Total
9,000
8,000
7,000

tons

6,000
5,000
4,000
3,000
2,000
1,000
0
Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sep

Oct

Nov

Dec

Month
Agricultural
Developed

Commercial Construction
Vacant

Residential Construction
Water (Alluvial)

Transportation Construction
Other

Figure 5-2. Monthly windblown PM10 dust emissions for Maricopa and Pinal Counties.

The spatial distribution of the estimated windblown dust PM emissions are presented in Figure 53. Figure 5-3 presents the monthly total PMC (=0.9*PM10) windblown dust emissions for
calendar year 2005. Note that these displays do not reflect the monthly, crop-specific revisions
to soil disturbance percentages incorporated into the final model simulations, presented below.
The dependence on landuse can be seen as the spatial distribution of the estimated emissions
corresponds to the distribution of the various landuse types across the domain.
5-3

May 2007

Figure 5-3. Spatial distribution of estimated PMC windblown dust emissions.

5-4

May 2007

Figure 5-3 (concluded). Spatial distribution of estimated PMC windblown dust emissions.

5-5

May 2007

Final Model Simulation Results
As discussed in Section 4, the final model simulations considered the monthly variation in soil
disturbance levels due to agricultural activities through out the year. Table 4-3 presented the
assumed monthly disturbance percentages of agricultural lands throughout the Phoenix NonAttainment Area. These monthly variations were based on the crop calendars for 2005 for
Maricopa County. The final windblown dust emission model runs incorporated these disturbance
levels within the estimation methodology by reducing the threshold surface friction velocities.
For those months were no assumed disturbances are listed in Table 4-3, the results of the
preliminary model simulation were substituted. These results reflect the default assumptions of
the estimation methodology, i.e., loose undisturbed soils. The results of the final windblown dust
model simulation are presented below.
Table 5-3 presents the 2005 annual windblown PM10 dust emissions for the Phoenix NonAttainment Area by county and landuse category. Table 5-4 presents the corresponding results
for the entirety of Maricopa and Pinal Counties. As can be seen, the implementation of the
monthly variation of disturbance for agricultural lands has only minor impacts on the estimated
emissions. In the final model simulation only the four main crops were considered for variations
in disturbance levels. The remaining croplands, approximately 10% ogf the total agricultural
lands in the region, were treat4d as miscellaneous crops with the default disturbance treatment of
the model. Additionally, only a very small portion of the total land area within the Phoenix
NAA is categorized as cropland, thus the effects of these model revisions are minimal.
The corresponding monthly windblown PM10 dust emissions are summarized for the Phoenix
NAA and Maricopa/Pinal Counties, by landuse category, in Tables 5-5 and 5-6, respectively.
Figures 5-4 and 5-5 present these results graphically.

Table 5-3. 2005 Annual PM10 windblown dust emissions for the Phoenix NAA.
2005 Annual Windblown PM10 Dust Emission in Phoenix NAA (tons)
Other
Comm. Res.
Trans.
Water
County
Total Agricultural Constr. Constr. Constr. Developed Vacant (Alluvial) Other Barley Corn Cotton Wheat
36.1
116.0 712.8
7.3
0.0 5,287.1
720.6 401.3
0.4 0.2
2.3
0.2
Maricopa 7,284.3
96.2
0.1
0.0
1.1
0.0
0.0
1.0
0.0 93.8
0.0 0.0
0.0
0.0
Pinal
Total
7,380.4
36.2
116.0 713.9
7.3
0.0 5,288.1
720.6 495.2
0.4 0.2
2.3
0.2

Table 5-4. 2005 Annual PM10 windblown dust emissions for Maricopa and Pinal Counties.
2005 Annual Windblown PM10 Dust Emisisons (tons) - County-wide

County
Maricopa
Pinal
Total

Other
Comm. Res.
Trans.
Water
Total
Agricultural Constr. Constr. Constr. Developed Vacant (Alluvial) Other
Barley Corn Cotton Wheat
44,488.8
149.7
121.2
790.7
7.3
0.0 40,468.2
1,175.1 1,766.9
1.1 0.6
7.1
0.9
12,769.5
54.7
0.1
4.4
0.0
0.0
41.9
0.0 12,641.4
1.1 0.7
23.9
1.2
57,258.3
204.5
121.3
795.0
7.3
0.0 40,510.1
1,175.1 14,408.4
2.2 1.3
31.0
2.1

5-6

May 2007

Table 5-5. 2005 Monthly PM10 windblown dust emissions for the Phoenix NAA.
2005 PM10 Windblown Dust Emission (tons) -- Phoenix NAA
Month
Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Annual

Other
Comm. Res.
Trans.
Water
Total
Agricultural Constr. Constr. Constr. Developed Vacant (Alluvial) Other Barley
1.5
4.3
27.0
0.3
0.0 176.6
17.8 23.1
0.00
250.8
1.4
7.4
45.4
0.5
0.0 310.5
41.7 26.5
0.00
433.9
3.4
11.6
69.5
0.7
0.0 503.2
65.5 55.4
0.00
709.8
6.5
13.9
84.4
0.8
0.0 642.3
84.5 67.5
0.19
900.9
5.8
13.6
83.8
0.8
0.0 638.4
91.0 64.0
0.19
897.5
2.5
14.3
87.8
0.8
0.0 659.8
101.6 41.4
0.00
908.3
4.9
17.0 100.5
1.1
0.0 786.3
114.1 77.7
0.00
1,101.7
4.4
12.9
75.2
0.9
0.0 586.2
80.0 61.4
0.02
821.0
2.2
7.8
49.0
0.5
0.0 363.5
51.2 33.1
0.00
507.4
2.4
6.6
42.7
0.4
0.0 309.9
44.1 25.1
0.00
431.5
1.3
4.3
30.4
0.3
0.0 201.3
22.3 16.1
0.00
276.3
0.0
2.3
18.3
0.1
0.0 110.0
6.8
3.7
0.00
141.3
7,380.4
36.2
116.0 713.9
7.3
0.0 5,288.1
720.6 495.2
0.40

Corn Cotton Wheat
0.03
0.21
0.00
0.06
0.36
0.00
0.08
0.53
0.00
0.00
0.66
0.00
0.00
0.01
0.00
0.00
0.00
0.03
0.01
0.02
0.00
0.00
0.02
0.00
0.00
0.01
0.00
0.00
0.28
0.00
0.00
0.19
0.09
0.00
0.00
0.06
0.18
2.29
0.19

Table 5-6. 2005 Monthly PM10 windblown dust emissions for Maricopa and Pinal Counties.
2005 PM10 Windblown Dust Emission (tons) -- County Totals
Other
Comm. Res.
Trans.
Water
Month Total
Agricultural Constr. Constr. Constr. Developed Vacant (Alluvial) Other
Barley
7.7
4.6
31.1
0.3
0.0 2,003.8
41.4
828.2
0.01
Jan
2,921.1
9.6
7.8
51.2
0.5
0.0 2,608.5
71.0
914.9
0.00
Feb
3,668.7
22.1
12.0
76.7
0.7
0.0 3,445.6
102.6 1,444.1
0.01
Mar
5,110.7
31.5
14.5
93.1
0.8
0.0 4,454.9
131.1 1,634.2
0.98
Apr
6,368.5
26.6
14.2
92.7
0.8
0.0 4,542.7
142.1 1,394.6
1.02
May
6,215.0
25.1
14.9
96.8
0.8
0.0 4,686.8
154.1 1,761.1
0.01
Jun
6,740.1
28.2
17.7
110.2
1.1
0.0 5,203.2
171.3 2,406.7
0.02
Jul
7,938.9
22.4
13.3
82.3
0.9
0.0 3,975.7
121.4 1,643.4
0.13
Aug
5,859.9
9.7
8.3
55.2
0.5
0.0 3,073.9
88.3
911.2
0.01
Sep
4,147.2
13.3
7.0
48.5
0.4
0.0 2,810.2
76.0
803.0
0.01
Oct
3,762.3
7.4
4.6
35.1
0.3
0.0 1,993.2
46.6
538.2
0.00
Nov
2,629.8
0.9
2.6
22.3
0.1
0.0 1,711.7
29.2
128.7
0.00
Dec
1,896.2
Annual 57,258.3
204.5
121.3
795.0
7.3
0.0 40,510.1
1,175.1 14,408.4
2.21

Corn Cotton Wheat
0.28
3.77
0.02
0.36
4.81
0.00
0.47
6.40
0.02
0.01
7.19
0.05
0.01
0.26
0.03
0.00
0.18
0.21
0.14
0.42
0.04
0.01
0.33
0.03
0.00
0.13
0.01
0.00
3.98
0.02
0.00
3.56
0.88
0.00
0.00
0.79
1.29 31.03
2.11

5-7

May 2007

Monthly PM10 Dust Emissions (tons) -- Phoenix NAA
w/ Temporal Agricultural Adjustments
1,200

1,000

tons

800

600

400

200

0
Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sep

Oct

Nov

Dec

Month
Agricultural

Commercial Construction

Residential Construction

Transportation Construction

Developed

Vacant

Water (Alluvial)

Other

Figure 5-4. Final monthly windblown PM10 dust emissions for the Phoenix NNA.

Monthly PM10 Dust Emissions (tons) - County Total
w/ Temporal Agricultural Adjustment
9,000
8,000
7,000

tons

6,000
5,000
4,000
3,000
2,000
1,000
0
Jan

Feb

Mar

Apr

May

Jun

Jul

Aug

Sep

Oct

Nov

Dec

Month
Agricultural
Developed

Commercial Construction
Vacant

Residential Construction
Water (Alluvial)

Transportation Construction
Other

Figure 5-5. Final monthly windblown PM10 dust emissions for Maricopa and Pinal Counties.

5-8

May 2007

Model Sensitivity Simulations
The sensitivity of the model results to variations in meteorology was also investigated as part of
the project. For air quality planning and SIP development efforts, databases representative of
typical, or average, conditions are often developed based on data from several years. Emission
inventories and air quality modeling results obtained using representative conditions allow for a
more consistent comparison between baseline future year modeling scenarios.
For the current application, wind speed data from the AZMET database were augmented with
observed data archived by the Maricopa County Flood Control District. The hourly wind speed
data from each of the monitoring stations were averaged over the 5-year period 2001-2005.
Only those monitoring site with a complete five year record were considered. The monitoring
station locations are displayed in Figure 5-6. All other input data and modeling assumptions
remained unchanged.
The AZMET and Flood Control District monitoring networks provide observed data from
different heights above ground level. AZMET station data are obtained at a height of 3 meters,
while the Flood Control District monitoring network provides data at a height of 10 meters.
Prior to applying the kriging algorithms to these data, the AZMET station data were re-cast to a
10 meter height using a simple power law relation assuming neutral atmospheric conditions. The
resulting hourly gridded wind speeds are presented in Figure 5-7 in terms of monthly average
wind speeds across the modeling domain.

Figure 5-6. Location of meteorological monitoring stations for 5-year average wind speed data.

5-9

May 2007

Figure 5-7. Monthly average wind speeds on the 12-km modeling domain. (2001-2005 data)

5-10

May 2007

Figure 5-7. (concluded). Monthly average wind speeds on the 12-km modeling domain (2001-2005 data)

5-11

May 2007

The results of the windblown dust model simulation using the 5-year average wind speed data
are presented in Tables 5-7 and 5-8. Table 5-7 presents the annual 2005 windblown PM10 dust
emissions for the Phoenix Nonattainment area disaggregated into the 8 generalized landuse types
defined in Table 4-2. The corresponding results for the entire Maricopa and Pinal Counties are
presented in Table 5-8. As seen, the resulting PM10 dust emissions are significantly decreased
from those obtained using the 2005 data alone. The large reduction in estimated windblown
PM10 dust emissions is directly related to the reduced wind speeds across the modeling domain
resulting from the use of 5-year average meteorology.
Table 5-7. 2005 Annual PM10 windblown dust emissions for the Phoenix NAA using 5-year
average (2001-2005) wind speed data.
2005 PM10 Dust Emissions (tons)
Phoenix Non-Attainment Area
Commercial Residential Transportation
Water
County
Total
Agricultural Construction Construction Construction
Developed Vacant
(Aluvial) Other
2,816
29.5
34.1
218.1
2.2
0.0
2,408.6
91.9
31.8
Maricopa
5
0.2
0.0
0.4
0.0
0.0
0.3
0.0
3.7
Pinal
Total
2,821
30
34
218
2
0
2,409
92
36

Table 5-8. 2005 Annual PM10 windblown dust emissions for Maricopa and Pinal Counties
using 5-year average (2001-2005) wind speed data.
2005 PM10 Dust Emissions (tons)
County Totals
Commercial Residential Transportation
Water
County
Total
Agricultural Construction Construction Construction
Developed Vacant
(Aluvial) Other
87.0
37.4
253.2
2.2
0.0 17,288.3
163.8
573.4
Maricopa 18,405.3
1,977.4
100.1
0.0
1.4
0.0
0.0
11.5
0.0
1,864.3
Pinal
Total
20,383
187
37
255
2
0
17,300
164
2,438

5-12

May 2007

6. SUMMARY

The WRAP RMC windblown fugitive dust emission model was applied to the Phoenix PM10
Non-Attainment Area to estimate PM10 dust emissions for calendar year 2005. Various
improvements to the model input data and assumptions associated with the emission estimation
methodology were considered. Summary results of the simulations for Maricopa and Pinal
Counties and for the Phoenix PM10 NAA were presented in Section 5.
The modeling domain was defined on a 12-km resolution grid to encompass all of Maricopa and
Pinal Counties of Arizona. Model input data were developed from local data as well as regional
data sets. Local landuse/landcover data were provided by the Maricopa Association of
Governments for use in the project. Landuse data from the Southwest GAP database were used
to augment the local landuse data to cover the entire modeling domain. Soils data were
developed from a combination of SSURGO and STATSGO databases. The necessary hourly
gridded wind fields were derived from AZMET observational datasets using a kriging algorithm.
Minor updates to the default agricultural crop information of the model were incorporated for
Maricopa County. Assumed disturbance levels of the vacant lands within the modeling domain
were also modified for the current application based on knowledge of the local landscapes.
A number of limitations are worth noting with respect to the input data and estimation
methodology:
•

Threshold surface friction velocities are determined as a function of the aerodynamic
surface roughness lengths. In the current implementation, surface roughness lengths are
assigned as a function of land types. However, only a limited number of land types are
available to characterize vacant lands across the entire domain. A large degree of
variation can be found within a given land type which is not being captured by the model
due to a lack of detail in the land use data used for the model.

•

Although some revisions were incorporated with respect to the soil disturbance of vacant
lands, the default implementation of the current model assumes that all soils are loose and
undisturbed with no temporal variation of disturbance levels. In addition, the effect that
disturbance of soils and vacant lands has on the emission rates of dust due to wind
erosion is not well characterized or fully understood.

•

The treatment of dust reservoirs is too simplistic in the model. The reservoir
characteristics determine the duration of wind blown dust events as well as the effects of
precipitation on the erosion potential of exposed surfaces. It has been documented in the
literature that depending on the type of soils, a small amount of precipitation can cause a
crust to form on the surface effectively preventing dust emissions due to wind erosion.
Only after these crusts have been broken does the surface again have the potential to emit
dust emissions. These affects can also vary to some degree even for the same types of
soils depending on soil moisture content among other factors. The amount of soil
available for erosion is also important with respect to determining the duration of
emissions during wind events.

6-1

May 2007

This page intentionally blank.

6-2

May2007

7. REFERENCES

Alfaro, S.C., Rajot, J.L., and Nickling, W.G. Estimation of PM20 emissions by wind erosion:
main sources of uncertainties. Geomorphology (in press). 2003.
Alfaro, S.C. and Gomes, L. Modeling mineral aerosol production by wind erosion: emission
intensities and aerosol size distributions in source areas. J. Geophys. Res. 106 (16):
18075-18084. 2001.
ARB. 1997 “Section 7.11 – Supplemental Documentation for Windblown Dust – Agricultural
Lands.” California Air Resources Board, Emission Inventory Analysis Section,
Sacramento, California. April.
ARS. Revised Universal Soil Loss Equation, Version 2 (RUSLE2). U.S. Department of
Agriculture, Agricultural Research Service. Internet address:
http://fargo.nserl.purdue.edu/rusle2_dataweb/RUSLE2_Index.htm, 2003.
Barnard, W. 2003. Personal communication with W. Barnard, MACTEC Engineering &
Consulting, Gainesville, FL. April.
Chatenet, B., Marticorena, B., Gomes, L., and Bergametti, G. 1996. Assessing the microped
size distributions of desert soils erodible by wind. Sedimentology 43: 901-911..
ENVIRON. 2003a. “Determining Fugitive Dust Emissions from Wind Erosion – Task 2:
Development of Emission Inventory Specific Emission Factors.” Draft Technical
memorandum. Prepared for Western Governors’ Association by ENVIRON International
Corporation, Novato, California; ERG, Inc., Sacramento, California; and Desert Research
Institute, Reno, Nevada. March 17.
ENVIRON. 2003b. “Determining Fugitive Dust Emissions from Wind Erosion – Task 1:
Analysis of Wind Tunnel Study Results, Meteorological and Land Use Data." Technical
memorandum. Prepared for Western Governors’ Association by ENVIRON International
Corporation, Novato, California; ERG, Inc., Sacramento, California; Desert Research
Institute, Reno, Nevada, MACTEC Engineering & Consulting, Gainsville, Florida and
University of California Riverside, Riverside, California. January 15.
ENVIRON. 2004. “Determining Fugitive Dust Emissions from Wind Erosion.” Final Report.
Prepared for Western Governors’ Association by ENVIRON International Corporation,
Novato, California; ERG, Inc., Sacramento, California; Desert Research Institute, Reno,
Nevada, MACTEC Engineering & Consulting, Gainsville, Florida and University of
California Riverside, Riverside, California. March 12.
Gillette, D.A., 1988. Threshold friction velocities for dust production for agricultural soils.
Journal of Geophysical Research, 93(D10): 12645-12662.
Gillette, D.A., Adams, J., Endo, E. and Smith, D., 1980. Threshold velocities for input of soil
particles into the air by desert soils. Journal of Geophysical Research, 85(C10): 56215630.
7-1

May2007

Gillette, D.A., Adams, J., Muhs, D. and Kihl, R., 1982. Threshold friction velocities and rupture
moduli for crusted desert soils for the input of soil particles into the air. Journal of
Geophysical Research, 87(C10): 9003-9015
Gillette, D.A., Fryrear, W. D., Gill, T. E., Ley, T., Cahill, T. A., and Gearhart, E. A. 1997.
Relation of vertical flux of PM10 to total Aeolian horizontal mass flux at Owens Lake. J.
Geophysical. Research. 102:26009-26015.
Lightle. Personal communication with Dave Lightle, U.S. Department of Agriculture, Natural
Resources Conservation Service, Lincoln, Nebraska. February 25, 2003.
Mansell, G.E. and A. Hoats, 2007. Development of a Fugitive Windblown PM10 Dust Emission
Inventory for the Phoenix PM10 Nonattainment Area. Draft Final Report. Prepared for
Maricopa County Air Quality Department, Phoenix AZ. January 22.
Mansell, G.E., 2003a. Revised windblown fugitive dust emission estimation methodology
Technical Memorandum prepared for Michael Uhl, Department of Air Quality
Management, Clark County, NV. October 6.
Mansell, G.E., 2003b. Summary of WRAP fugitive dust methodology assumptions model
sensitivity. Technical Memorandum prepared for Michael Uhl, Department of Air
Quality Management, Clark County, NV. November 14.
Mansell, G.E., R. Morris and M. Omary. 2004. Recommendations and model performance
evaluation for the Phase II Windblown Fugitive Dust Emission Project. Technical
Memorandum prepared for the WRAP Dust Emission Joint Forum. July,
Marticorena, B., and Bergametti, G., 1995. Modeling the atmospheric dust cycle,1. Design of an
a soil-derived dust emissions scheme. J. Geophysics. Research. 100: 16415-16430.
Marticorena, B., Bergametti, G., Gillette, D., and Belnap, J. 1997. Factors controlling threshold
friction velocity in semiarid and arid areas of the United States. J. Geophysics Research
102 (D19): 23277-23287.
Nickling, W.G. and Gillies, J.A. 1989. Emission of fine-grained particulate from desert soils. In:
M. Leinen and M. Sarnthein (Editors), Paleoclimatology and Paleometeorology: Modern
and Past Patterns of Global Atmospheric Transport. Kluwer Academic Publishers, pp.
133-165.
Nickling, W.G. and Gillies, J.A. 1993. Dust emission and transport in Mali, West Africa.
Sedimentology 40: 859-868.
Oke, T.R. 1978. Boundary Layer Climates. London, Methuen Co., 371 p.
Pace, T.G., 2003. A Conceptual Model to Adjust Fugitive Dust Emissions to Account for Near
Source Particle Removal in Grid Model Applications. U.S. EPA. August 22.

7-2

May2007

Pace, T.G., 2005. Methodology to Estimate the Transportable Fraction (TF) of Fugitive Dust
Emissions for Regional and Urban Scale Air Quality Analyses. U.S. EPA. June 2.
Pollack, et al., 2004. Arizona 2002 Emission Inventory. Final Report. Prepared for Arizona
Department of Environmental Quality. June 30.
Towery. Personal communication with Dan Towery, Conservation Technology Information
Center, Purdue University, West Lafayette, Indiana. August 20, 2003.
Towery, 2003. Personal communication with Dan Towery, CTIC/ERM, Purdue University, West
Bend, IN. January 7.
USDA, 1994. State Soil Geographic (STATSGO) Data Base, Data use information. U.S.
Department of Agriculture, Natural Resources Conservation Service, National Soil
Service Center, Miscellaneous Publication Number 1492. December.
U.S. EPA, 2001. The Biogenic Emissions Landcover Database, Version 3.1. Via anonymous ftp
at ftp.epa.gov/and/asmd/beld3.
U.S. EPA, 2001. The Biogenic Emissions Landcover Database, Version 3.1. Via anonymous ftp
at ftp.epa.gov/and/asmd/beld3.
U.S. EPA. Development of Emission Factors for Fugitive Dust Sources, EPA-450/3-74-037.
U.S. Environmental Protection Agency, Research Triangle Park, North Carolina. June.
1974.
U.S. EPA. Guideline for Development of Control Strategies in Areas with Fugitive Dust
Problems, EPA-450/2-77-029. U.S. Environmental Protection Agency, Research
Triangle Park, North Carolina. 1977.
Wolfe, S.A. 1993. Sparse Vegetation as a Control on Wind Erosion. Ph.D. thesis, University of
Guelph, Guelph, Ontario.

7-3

Appendix 5
MOBILE6.2 Input and Ouput Files

MOBILE6 input files
Two scenarios of Inspection/Maintenance (I/M) were developed for MOBILE6.2 inputs: with
I/M program in place and no I/M program in place. I/M program affected only NOx emission
factor. I/M programs were simply removed to develop MOBILE6.2 input files for No I/M
program scenario. No I/M input is followed by I/M input.
The inputs to MOBILE6.2 are grouped into three categories: Header inputs, run inputs, and
scenario inputs. The input values used in the MOBILE6.2 runs are specified and explained
below.
Header Section
1.

MOBILE6 INPUT FILE: indicates that the MOBILE6.2 input file is a regular command
file rather than a batch file.

Run Data Section
1.

EXPAND LDT EFS: directs MOBILE6.2 to display EFs by 6 LDT classes.
EXPAND HDDV EFS: directs MOBILE6.2 to display EFs by 8 HDDV classes.
EXPAND HDGV EFS: directs MOBILE6.2 to display EFs by 8 HDGV classes.
EXPAND BUS EFS: directs MOBILE6.2 to report EFs for gas, urban, and school bus
categories separately.

2.

I/M PROGRAM: 1 1977 2050 1 T/O LOADED IDLE indicates the program start and end
dates, frequency of testing, and test type. There are five components of the I/M program
modeled; a loaded idle test for heavy duty gasoline vehicles (shown in the example in
Appendix 5.9.2), a transient idle test (I/M240 modeled as a surrogate for the I/M147 test)
for light duty cars and trucks through model year 1995, a loaded idle test for light duty
cars and trucks of model years 1967 to 1980, an on-board diagnostic (OBD) exhaust test
for model year 1996 and newer vehicles, and an OBD evaporative test for the same
vehicles. The remaining four occurrences of this command are as follows:
I/M PROGRAM: 2 1977 2050 2 T/O IM240 - relating to the transient idle I/M240
program modeled as a surrogate for the I/M147 program.
I/M PROGRAM: 3 1977 2050 1 T/O LOADED IDLE - relating to the loaded idle
program for model year 1967-1980 light duty cars and trucks.
I/M PROGRAM: 4 2001 2050 2 T/O OBD I/M - relating to the exhaust portion of the
OBD test.
I/M PROGRAM: 5 2001 2050 2 T/O EVAP OBD & GC - relating to the evaporative and
gas cap portion of the OBD test.

3.

I/M MODEL YEARS: 1 1967 2050 indicates the first and last model years affected by
the given component of the I/M program. The inputs shown above indicate that model
years 1967 and newer are tested by component 1 of the I/M program. The remaining four
occurrences of this command are as follows:
I/M MODEL YEARS: 2 1981 1995 - relating to the transient idle I/M240 program
modeled as a surrogate for the I/M147 program.
I/M MODEL YEARS: 3 1967 1980 - relating to the loaded idle program for model year
1967-1980 light duty cars and trucks.
I/M MODEL YEARS: 4 1996 2050 - relating to the exhaust portion of the OBD test.
I/M MODEL YEARS: 5 1996 2050 - relating to the evaporative and gas cap portion of
the OBD test.

4.

I/M VEHICLES: 1 11111 22222222 2 indicates that for the first component of the I/M
program (1), the five vehicle categories LDGV, LDGT1, LDGT2, LDGT3, and LDGT4
are not subject to this portion of the I/M program (indicated by “1") while HDGV2B,
HDGV3, HDGV4, HDGV5, HDGV6, HDGV7, HDGV8A, HDGV8B, and gasoline
buses are covered (indicated by “2"). The remaining four occurrences of this command
are as follows:
I/M VEHICLES: 2 22222 11111111 1 indicates that the opposite vehicle classes are
subject to the transient idle I/M240 program modeled as a surrogate for the I/M147
program. This selection of vehicle classes is also applied to the remaining three portions
of the I/M program.

5.

I/M STRINGENCY: 1 28.0 indicates that the initial test failure rate for pre-1981 LDGVs
and pre-1984 LDGTs is 28.0 percent. This stringency rate is also applied to the
remaining portions of the I/M program.

6.

I/M COMPLIANCE: 1 97.0 indicates that the fraction of the total vehicle fleet subject to
the I/M program that passes the I/M test or receives a waiver is 97.0 percent. This
compliance rate is also applied to the remaining portion of the I/M program.

7.

I/M WAIVER RATES: 1 1.3 1.0 indicates that the fraction of vehicles that fail the I/M
program is 1.3 for pre-1981 model years and 1.0 percent for 1981 and later model years.
These waiver rates are also applied to the remaining portion of the I/M program.

8.

I/M GRACE PERIOD: 1 5 indicates that vehicles less than 5 years old are exempted
from the I/M program. This exemption is identical for all portions of the I/M program.

9.

I/M CUTPOINTS: 2 CUTPNT05.d indicates that MOBILE6.2 reads the external data file
“CUTPNT05.d” for the I/M cutpoint values for HC, CO, and NOx. There are 25 values
for each vehicle class and pollutant, for the most recent 25 model years, starting with the
youngest vehicle. This data is only input for the I/M240 program.

10.

ANTI-TAMP PROGRAM :
87 75 80 22222 22222222 2 11 097. 22111222
indicates the nature of the anti-tampering program. Specifically, this portion of the antitampering program began in 1987 and covers model year vehicles 1975 to 1980. Vehicle
classes subject to the inspection (indicated by a “2") include LDGV, LDGT1, LDGT2,
LDGT3, LDGT4, HDGV2B, HDGV3, HDGV4, HDGV5, HDGV6, HDGV7, HDGV8A,
HDGV8B, and gasoline powered buses. The test is performed annually. The test has a
97 percent compliance rate. The parameters tested include air pump disablement, catalyst
removal, evaporative system disablement, PCV system disablement, and missing gas cap.
The parameters not tested are fuel inlet restrictor disablement, tailpipe lead deposit test,
and EGR disablement. A second data line indicates that the same test is also performed
on model year 1981 to 1995 vehicles, but with the LDGV, LDGT1, LDGT2, LDGT3,
and LDGT4 classes omitted because those vehicles are subject to the transient I/M or
OBD test.

11.

REG DIST: 02reg05.d indicates that vehicle registration distributions by age for the 16
composite vehicle types are read by MOBILE6.2 from an external data file, called
02reg05.d.

12.

DIESEL FRACTIONS: indicates the user-supplied diesel sales fractions. This input is
followed by 350 fractional values representing the fraction of the 14 vehicle classes
internally examined by MOBILE6.2 and 25 most recent model years that are diesel
vehicles. As an example, the first value, 0.0009, indicates that for the most recent model
year of light duty vehicles, 0.09 percent of the vehicles sold are diesel.

Scenario Section
1.

SCENARIO RECORD: Allows the user to enter a name to identify the scenario being
run.

2.

PARTICULATE EF: PMGZML.CSV PMGDR1.CSV PMGDR2.CSV PMDZML.CSV
PMDDR1.CSV PMDDR2.CSV specifies six external data files that contain the
particulate emission factors. MOBILE6.2 reads PMGZML.CSV for gasoline vehicle zero
mile particulate emission factors, PMGDR1.CSV for gasoline vehicle deterioration rate
particulate emission factors for all vehicle ages from 1 to the age specified variable X,
PMGDR2.CSV for gasoline vehicle deterioration rate particulate emission factors for all
vehicle ages from X+1 to age 25, PMDZML,CSV for diesel zero mile particulate
emission factors, PMDDR1.CSV for diesel vehicle deterioration rate particulate emission
factors for all vehicle ages from 1 to the age specified variable X, PMDDR2.CSV for
diesel vehicle deterioration rate particulate emission factors for all vehicle ages from X+1
to age 25, The values of X for gasoline and diesel vehicles are specified in gasoline and
diesel vehicle zero mile particulate emission factor files, respectively.

3.

PARTICLE SIZE: 10.0 indicates that particulate matter emission factors are reported in
term of PM10. PARTICLE SIZE: 2.5 indicates that particulate emission factors are
reported in term of PM2.5.

4.

DIESEL SULFUR: 309.0 specifies average diesel fuel sulfur level 309 ppm.

5.

CALENDAR YEAR: 2005 specifies the calendar year 2005 for which emission factors
are to be calculated.

6.

EVALUATION MONTH: 7 indicates that the month to be modeled is July.

7.

ALTITUDE:1 indicates the geographic area modeled was low altitude.

8.

MIN/MAX TEMPERATURE: 56. 97. provides the model with the daily minimum and
maximum temperatures.

9.

FUEL RVP: 8.0 Indicates that the average Reid Vapor Pressure of the gasoline sold during
this time period is 8.0 pounds per square inch. This estimate is based upon raw gasoline
data provided by the Arizona Department of Weights and Measures.

10.

FUEL PROGRAM: 2 S instructs MOBILE6.2 that the gasoline in use will be
reformulated gasoline for the southern region.

MOBILE6.2 Input File for I/M scenario: PM10, NOx, SOx, and NH3
MOBILE6 INPUT FILE :
PARTICULATES
:
RUN DATA
EXPAND LDT EFS
EXPAND HDDV EFS
EXPAND HDGV EFS
EXPAND BUS EFS
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD
I/M CUTPOINTS
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD

:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:

1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
3
3
3
3
3
3
4
4
4
4
4
4
4
5
5
5
5
5
5
5

1977 2050 1 T/O LOADED/IDLE
1967 2050
11111 22222222 2
28.0
97.0
1.3 1.0
5
1977 2050 2 T/O IM240
1981 1995
22222 11111111 1
28.0
97.0
1.3 1.0
5
CUTPNT05.d
1977 2050 1 T/O LOADED/IDLE
1967 1980
22222 11111111 1
28.0
97.0
1.3 1.0
2001 2050 2 T/O OBD I/M
1996 2050
22222 11111111 1
28.0
97.0
1.3 1.0
5
2001 2050 2 T/O EVAP OBD & GC
1996 2050
22222 11111111 1
28.0
97.0
1.3 1.0
5

ANTI-TAMP PROG
:
87 75 80 22222 22222222 2 11 097. 22111222
ANTI-TAMP PROG
:
87 81 95 11111 22222222 2 11 097. 22111222
*the tech12.d file must be located with Mobile6 execution file
*the user tech file tech12.1me should be renamed as tech12.d
*Two more I/M programs should not have overlapped motor vehicles.
REG DIST
:
DIESEL FRACTIONS
:
0.0009 0.0009 0.0009
0.0006 0.0001 0.0003
0.0097 0.0162 0.0241
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145
0.0135 0.0169 0.0209
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145
0.0135 0.0169 0.0209

02reg05.d
0.0009
0.0006
0.0510
0.0000
0.0000
0.0656
0.0000
0.0000
0.0656
0.0126
0.0115
0.0256
0.0126
0.0115
0.0256

0.0009
0.0013
0.0706
0.0000
0.0000
0.0616
0.0000
0.0000
0.0616
0.0126
0.0129
0.0013
0.0126
0.0129
0.0013

0.0009 0.0009 0.0009 0.0009 0.0009
0.0004 0.0004 0.0001 0.0027 0.0032
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124

0.1998
0.2578
0.2743
0.6774
0.7715
0.6145
0.8606
0.8473
0.1968
0.4647
0.4384
0.0333
0.6300
0.6078
0.4525
0.8563
0.8443
0.7431
0.9992
0.9989
0.9979
1.0000
1.0000
1.0000
0.9585
0.8857
0.5155

0.1998
0.2515
0.3004
0.6774
0.7910
0.5139
0.8606
0.8048
0.1570
0.4647
0.3670
0.0255
0.6300
0.5246
0.4310
0.8563
0.7943
0.7261
0.9992
0.9987
0.9976
1.0000
1.0000
1.0000
0.9585
0.8525
0.3845

0.1998
0.3263
0.2918
0.6774
0.8105
0.5032
0.8606
0.8331
0.0738
0.4647
0.4125
0.0111
0.6300
0.5767
0.3569
0.8563
0.8266
0.6602
0.9992
0.9989
0.9969
1.0000
1.0000
1.0000
0.9585
0.8795
0.3238

SCENARIO RECORD
:
PARTICULATE EF
:
PARTICLE SIZE
:
DIESEL SULFUR
:
CALENDAR YEAR
:
EVALUATION MONTH
:
ALTITUDE
:
MIN/MAX TEMPERATURE:
FUEL RVP
:
FUEL PROGRAM
:
END OF RUN

0.1998
0.2784
0.2859
0.6774
0.8068
0.4277
0.8606
0.7901
0.0341
0.4647
0.3462
0.0049
0.6300
0.5289
0.3690
0.8563
0.7972
0.6717
0.9992
0.9977
0.9978
1.0000
1.0000
1.0000
0.9585
0.9900
0.3260

0.1998
0.2963
0.0138
0.6774
0.8280
0.0079
0.8606
0.7316
0.0414
0.4647
0.2771
0.0060
0.6300
0.5788
0.4413
0.8563
0.8279
0.7344
0.9992
0.9984
0.9982
1.0000
1.0000
1.0000
0.9585
0.9105
0.2639

0.1998 0.1998 0.1998 0.1998 0.1998
0.2384 0.2058 0.1756 0.1958 0.2726
0.6774 0.6774 0.6774 0.6774 0.6774
0.8477 0.7940 0.7488 0.7789 0.7842
0.8606 0.8606 0.8606 0.8606 0.8606
0.7275 0.7158 0.5647 0.3178 0.2207
0.4647 0.4647 0.4647 0.4647 0.4647
0.2730 0.2616 0.1543 0.0615 0.0383
0.6300 0.6300 0.6300 0.6300 0.6300
0.5617 0.4537 0.4216 0.4734 0.4705
0.8563 0.8563 0.8563 0.8563 0.8563
0.8177 0.7440 0.7184 0.7588 0.7567
0.9992 0.9992 0.9992 0.9992 0.9992
0.9982 0.9979 0.9969 0.9978 0.9980
1.0000 1.0000 1.0000 1.0000 1.0000
1.0000 1.0000 1.0000 1.0000 1.0000
0.9585 0.9585 0.9585 0.9585 0.9585
0.8760 0.7710 0.7502 0.7345 0.6733

I/M Scenario
PMGZML.CSV PMGDR1.CSV PMGDR2.CSV PMDZML.CSV PMDDR1.CSV PMDDR2.CSV
10.0
309.0
2005
7
1
56. 97.
8.0
2 S

MOBILE6.2 Input File for I/M scenario: PM2.5
MOBILE6 INPUT FILE :
PARTICULATES
:

RUN DATA
EXPAND LDT EFS
EXPAND HDDV EFS
EXPAND HDGV EFS
EXPAND BUS EFS
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD
I/M CUTPOINTS
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD
I/M PROGRAM
I/M MODEL YEARS
I/M VEHICLES
I/M STRINGENCY
I/M COMPLIANCE
I/M WAIVER RATES
I/M GRACE PERIOD

:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:
:

1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
3
3
3
3
3
3
4
4
4
4
4
4
4
5
5
5
5
5
5
5

1977 2050 1 T/O LOADED/IDLE
1967 2050
11111 22222222 2
28.0
97.0
1.3 1.0
5
1977 2050 2 T/O IM240
1981 1995
22222 11111111 1
28.0
97.0
1.3 1.0
5
CUTPNT05.d
1977 2050 1 T/O LOADED/IDLE
1967 1980
22222 11111111 1
28.0
97.0
1.3 1.0
2001 2050 2 T/O OBD I/M
1996 2050
22222 11111111 1
28.0
97.0
1.3 1.0
5
2001 2050 2 T/O EVAP OBD & GC
1996 2050
22222 11111111 1
28.0
97.0
1.3 1.0
5

ANTI-TAMP PROG
:
87 75 80 22222 22222222 2 11 097. 22111222
ANTI-TAMP PROG
:
87 81 95 11111 22222222 2 11 097. 22111222
*the tech12.d file must be located with Mobile6 execution file
*the user tech file tech12.1me should be renamed as tech12.d
*Two more I/M programs should not have overlapped motor vehicles.
REG DIST
:
DIESEL FRACTIONS
:
0.0009 0.0009 0.0009
0.0006 0.0001 0.0003
0.0097 0.0162 0.0241
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145
0.0135 0.0169 0.0209
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145

02reg05.d
0.0009
0.0006
0.0510
0.0000
0.0000
0.0656
0.0000
0.0000
0.0656
0.0126
0.0115
0.0256
0.0126
0.0115

0.0009
0.0013
0.0706
0.0000
0.0000
0.0616
0.0000
0.0000
0.0616
0.0126
0.0129
0.0013
0.0126
0.0129

0.0009 0.0009 0.0009 0.0009 0.0009
0.0004 0.0004 0.0001 0.0027 0.0032
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124

0.0135
0.1998
0.2578
0.2743
0.6774
0.7715
0.6145
0.8606
0.8473
0.1968
0.4647
0.4384
0.0333
0.6300
0.6078
0.4525
0.8563
0.8443
0.7431
0.9992
0.9989
0.9979
1.0000
1.0000
1.0000
0.9585
0.8857
0.5155

0.0169
0.1998
0.2515
0.3004
0.6774
0.7910
0.5139
0.8606
0.8048
0.1570
0.4647
0.3670
0.0255
0.6300
0.5246
0.4310
0.8563
0.7943
0.7261
0.9992
0.9987
0.9976
1.0000
1.0000
1.0000
0.9585
0.8525
0.3845

0.0209
0.1998
0.3263
0.2918
0.6774
0.8105
0.5032
0.8606
0.8331
0.0738
0.4647
0.4125
0.0111
0.6300
0.5767
0.3569
0.8563
0.8266
0.6602
0.9992
0.9989
0.9969
1.0000
1.0000
1.0000
0.9585
0.8795
0.3238

SCENARIO RECORD
:
PARTICULATE EF
:
PARTICLE SIZE
:
DIESEL SULFUR
:
CALENDAR YEAR
:
EVALUATION MONTH
:
ALTITUDE
:
MIN/MAX TEMPERATURE:
FUEL RVP
:
FUEL PROGRAM
:
END OF RUN

0.0256
0.1998
0.2784
0.2859
0.6774
0.8068
0.4277
0.8606
0.7901
0.0341
0.4647
0.3462
0.0049
0.6300
0.5289
0.3690
0.8563
0.7972
0.6717
0.9992
0.9977
0.9978
1.0000
1.0000
1.0000
0.9585
0.9900
0.3260

0.0013
0.1998
0.2963
0.0138
0.6774
0.8280
0.0079
0.8606
0.7316
0.0414
0.4647
0.2771
0.0060
0.6300
0.5788
0.4413
0.8563
0.8279
0.7344
0.9992
0.9984
0.9982
1.0000
1.0000
1.0000
0.9585
0.9105
0.2639

0.1998 0.1998 0.1998 0.1998 0.1998
0.2384 0.2058 0.1756 0.1958 0.2726
0.6774 0.6774 0.6774 0.6774 0.6774
0.8477 0.7940 0.7488 0.7789 0.7842
0.8606 0.8606 0.8606 0.8606 0.8606
0.7275 0.7158 0.5647 0.3178 0.2207
0.4647 0.4647 0.4647 0.4647 0.4647
0.2730 0.2616 0.1543 0.0615 0.0383
0.6300 0.6300 0.6300 0.6300 0.6300
0.5617 0.4537 0.4216 0.4734 0.4705
0.8563 0.8563 0.8563 0.8563 0.8563
0.8177 0.7440 0.7184 0.7588 0.7567
0.9992 0.9992 0.9992 0.9992 0.9992
0.9982 0.9979 0.9969 0.9978 0.9980
1.0000 1.0000 1.0000 1.0000 1.0000
1.0000 1.0000 1.0000 1.0000 1.0000
0.9585 0.9585 0.9585 0.9585 0.9585
0.8760 0.7710 0.7502 0.7345 0.6733

I/M Scenario
PMGZML.CSV PMGDR1.CSV PMGDR2.CSV PMDZML.CSV PMDDR1.CSV PMDDR2.CSV
2.5
309.0
2005
7
1
56. 97.
8.0
2 S

MOBILE6.2 Input File for no I/M scenario: PM10, NOx, SOx, and NH3
MOBILE6 INPUT FILE :
PARTICULATES
:
RUN DATA
EXPAND LDT EFS
:
EXPAND HDDV EFS
:
EXPAND HDGV EFS
:
EXPAND BUS EFS
:
REG DIST
:
DIESEL FRACTIONS
:
0.0009 0.0009 0.0009
0.0006 0.0001 0.0003
0.0097 0.0162 0.0241
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145
0.0135 0.0169 0.0209
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145
0.0135 0.0169 0.0209
0.1998 0.1998 0.1998
0.2578 0.2515 0.3263
0.2743 0.3004 0.2918
0.6774 0.6774 0.6774
0.7715 0.7910 0.8105
0.6145 0.5139 0.5032
0.8606 0.8606 0.8606
0.8473 0.8048 0.8331
0.1968 0.1570 0.0738
0.4647 0.4647 0.4647
0.4384 0.3670 0.4125
0.0333 0.0255 0.0111
0.6300 0.6300 0.6300
0.6078 0.5246 0.5767
0.4525 0.4310 0.3569
0.8563 0.8563 0.8563
0.8443 0.7943 0.8266
0.7431 0.7261 0.6602
0.9992 0.9992 0.9992
0.9989 0.9987 0.9989
0.9979 0.9976 0.9969
1.0000 1.0000 1.0000
1.0000 1.0000 1.0000
1.0000 1.0000 1.0000
0.9585 0.9585 0.9585
0.8857 0.8525 0.8795
0.5155 0.3845 0.3238
SCENARIO RECORD
:
PARTICULATE EF
:
PARTICLE SIZE
:
DIESEL SULFUR
:
CALENDAR YEAR
:
EVALUATION MONTH
:
ALTITUDE
:
MIN/MAX TEMPERATURE:
FUEL RVP
:
FUEL PROGRAM
:
END OF RUN

02reg05.d
0.0009
0.0006
0.0510
0.0000
0.0000
0.0656
0.0000
0.0000
0.0656
0.0126
0.0115
0.0256
0.0126
0.0115
0.0256
0.1998
0.2784
0.2859
0.6774
0.8068
0.4277
0.8606
0.7901
0.0341
0.4647
0.3462
0.0049
0.6300
0.5289
0.3690
0.8563
0.7972
0.6717
0.9992
0.9977
0.9978
1.0000
1.0000
1.0000
0.9585
0.9900
0.3260

0.0009
0.0013
0.0706
0.0000
0.0000
0.0616
0.0000
0.0000
0.0616
0.0126
0.0129
0.0013
0.0126
0.0129
0.0013
0.1998
0.2963
0.0138
0.6774
0.8280
0.0079
0.8606
0.7316
0.0414
0.4647
0.2771
0.0060
0.6300
0.5788
0.4413
0.8563
0.8279
0.7344
0.9992
0.9984
0.9982
1.0000
1.0000
1.0000
0.9585
0.9105
0.2639

0.0009 0.0009 0.0009 0.0009 0.0009
0.0004 0.0004 0.0001 0.0027 0.0032
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124
0.1998 0.1998 0.1998 0.1998 0.1998
0.2384 0.2058 0.1756 0.1958 0.2726
0.6774 0.6774 0.6774 0.6774 0.6774
0.8477 0.7940 0.7488 0.7789 0.7842
0.8606 0.8606 0.8606 0.8606 0.8606
0.7275 0.7158 0.5647 0.3178 0.2207
0.4647 0.4647 0.4647 0.4647 0.4647
0.2730 0.2616 0.1543 0.0615 0.0383
0.6300 0.6300 0.6300 0.6300 0.6300
0.5617 0.4537 0.4216 0.4734 0.4705
0.8563 0.8563 0.8563 0.8563 0.8563
0.8177 0.7440 0.7184 0.7588 0.7567
0.9992 0.9992 0.9992 0.9992 0.9992
0.9982 0.9979 0.9969 0.9978 0.9980
1.0000 1.0000 1.0000 1.0000 1.0000
1.0000 1.0000 1.0000 1.0000 1.0000
0.9585 0.9585 0.9585 0.9585 0.9585
0.8760 0.7710 0.7502 0.7345 0.6733

I/M Scenario
PMGZML.CSV PMGDR1.CSV PMGDR2.CSV PMDZML.CSV PMDDR1.CSV PMDDR2.CSV
10.0
309.0
2005
7
1
56. 97.
8.0
2 S

MOBILE6.2 Input File for no I/M scenario: PM2.5
MOBILE6 INPUT FILE :
PARTICULATES
:

RUN DATA
EXPAND LDT EFS
:
EXPAND HDDV EFS
:
EXPAND HDGV EFS
:
EXPAND BUS EFS
:
REG DIST
:
DIESEL FRACTIONS
:
0.0009 0.0009 0.0009
0.0006 0.0001 0.0003
0.0097 0.0162 0.0241
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0000 0.0000 0.0000
0.0000 0.0000 0.0000
0.0048 0.0120 0.0223
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145
0.0135 0.0169 0.0209
0.0126 0.0126 0.0126
0.0115 0.0111 0.0145
0.0135 0.0169 0.0209
0.1998 0.1998 0.1998
0.2578 0.2515 0.3263
0.2743 0.3004 0.2918
0.6774 0.6774 0.6774
0.7715 0.7910 0.8105
0.6145 0.5139 0.5032
0.8606 0.8606 0.8606
0.8473 0.8048 0.8331
0.1968 0.1570 0.0738
0.4647 0.4647 0.4647
0.4384 0.3670 0.4125
0.0333 0.0255 0.0111
0.6300 0.6300 0.6300
0.6078 0.5246 0.5767
0.4525 0.4310 0.3569
0.8563 0.8563 0.8563
0.8443 0.7943 0.8266
0.7431 0.7261 0.6602
0.9992 0.9992 0.9992
0.9989 0.9987 0.9989
0.9979 0.9976 0.9969
1.0000 1.0000 1.0000
1.0000 1.0000 1.0000
1.0000 1.0000 1.0000
0.9585 0.9585 0.9585
0.8857 0.8525 0.8795
0.5155 0.3845 0.3238
SCENARIO RECORD
:
PARTICULATE EF
:
PARTICLE SIZE
:
DIESEL SULFUR
:
CALENDAR YEAR
:
EVALUATION MONTH
:
ALTITUDE
:
MIN/MAX TEMPERATURE:
FUEL RVP
:
FUEL PROGRAM
:
END OF RUN

02reg05.d
0.0009
0.0006
0.0510
0.0000
0.0000
0.0656
0.0000
0.0000
0.0656
0.0126
0.0115
0.0256
0.0126
0.0115
0.0256
0.1998
0.2784
0.2859
0.6774
0.8068
0.4277
0.8606
0.7901
0.0341
0.4647
0.3462
0.0049
0.6300
0.5289
0.3690
0.8563
0.7972
0.6717
0.9992
0.9977
0.9978
1.0000
1.0000
1.0000
0.9585
0.9900
0.3260

0.0009
0.0013
0.0706
0.0000
0.0000
0.0616
0.0000
0.0000
0.0616
0.0126
0.0129
0.0013
0.0126
0.0129
0.0013
0.1998
0.2963
0.0138
0.6774
0.8280
0.0079
0.8606
0.7316
0.0414
0.4647
0.2771
0.0060
0.6300
0.5788
0.4413
0.8563
0.8279
0.7344
0.9992
0.9984
0.9982
1.0000
1.0000
1.0000
0.9585
0.9105
0.2639

0.0009 0.0009 0.0009 0.0009 0.0009
0.0004 0.0004 0.0001 0.0027 0.0032
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0000 0.0000 0.0000 0.0000 0.0000
0.0000 0.0000 0.0000 0.0007 0.0033
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124
0.0126 0.0126 0.0126 0.0126 0.0126
0.0096 0.0083 0.0072 0.0082 0.0124
0.1998 0.1998 0.1998 0.1998 0.1998
0.2384 0.2058 0.1756 0.1958 0.2726
0.6774 0.6774 0.6774 0.6774 0.6774
0.8477 0.7940 0.7488 0.7789 0.7842
0.8606 0.8606 0.8606 0.8606 0.8606
0.7275 0.7158 0.5647 0.3178 0.2207
0.4647 0.4647 0.4647 0.4647 0.4647
0.2730 0.2616 0.1543 0.0615 0.0383
0.6300 0.6300 0.6300 0.6300 0.6300
0.5617 0.4537 0.4216 0.4734 0.4705
0.8563 0.8563 0.8563 0.8563 0.8563
0.8177 0.7440 0.7184 0.7588 0.7567
0.9992 0.9992 0.9992 0.9992 0.9992
0.9982 0.9979 0.9969 0.9978 0.9980
1.0000 1.0000 1.0000 1.0000 1.0000
1.0000 1.0000 1.0000 1.0000 1.0000
0.9585 0.9585 0.9585 0.9585 0.9585
0.8760 0.7710 0.7502 0.7345 0.6733

I/M Scenario
PMGZML.CSV PMGDR1.CSV PMGDR2.CSV PMDZML.CSV PMDDR1.CSV PMDDR2.CSV
2.5
309.0
2005
7
1
56. 97.
8.0
2 S

Model Outputs
MOBILE6.2 was executed with the inputs described above to obtain composite emission factors
in grams per mile (g/mi) for PM10, PM2.5, NOx, SOx, and NH3. These values were obtained for
the twenty-eight vehicle classes described in the onroad section 5.2 (Table 5.2-1).

MOBILE6.2 Output File for I/M scenario: PM10, SOx, and NH3
***************************************************************************
* MOBILE6.2.03 (24-Sep-2003)
*
* Input file: PM05INV\TEST\PM10.IN (file 1, run 1).
*
***************************************************************************
*
*
*
*

# # # # # # # # # # # # # # # # # # # # # # # # #
I/M Scenario
File 1, Run 1, Scenario 1.
# # # # # # # # # # # # # # # # # # # # # # # # #
Calendar Year: 2005
Month: July
Gasoline Fuel Sulfur Content:
90. ppm
Diesel Fuel Sulfur Content: 309. ppm
Particle Size Cutoff: 10.00 Microns
Reformulated Gas: Yes
Vehicle Type:
GVWR:

LDGV

LDGT12
LDGT34
LDGT
HDGV
LDDV
LDDT
HDDV
MC
All Veh
<6000
>6000
(All)
--------------------------------------------------VMT Distribution:
0.4132
0.3281
0.1227
0.0357
0.0008
0.0021
0.0926
0.0048
1.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
---------------0.0000
0.0000
GASPM:
0.0042
0.0046
0.0050
0.0047
0.0587
---------------0.0205
0.0060
ECARBON:
-------------------------0.1420
0.0536
0.1685
-----0.0158
OCARBON:
-------------------------0.0401
0.0771
0.0859
-----0.0081
SO4:
0.0010
0.0015
0.0016
0.0016
0.0034
0.0037
0.0057
0.0192
0.0003
0.0030
Total Exhaust PM:
0.0052
0.0061
0.0066
0.0063
0.0621
0.1857
0.1363
0.2736
0.0208
0.0331
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
Tire:
0.0080
0.0080
0.0080
0.0080
0.0087
0.0080
0.0080
0.0262
0.0040
0.0097
Total PM:
0.0257
0.0267
0.0272
0.0268
0.0833
0.2063
0.1569
0.3123
0.0374
0.0553
SO2:
0.0204
0.0262
0.0342
0.0284
0.0508
0.0700
0.1090
0.2741
0.0098
0.0488
NH3:
0.1015
0.1000
0.0990
0.0998
0.0451
0.0068
0.0068
0.0270
0.0113
0.0911
----------------------------------------------------------------------------------------------------------------------Veh. Type:
LDGT1
LDGT2
LDGT3
LDGT4
LDDT12
LDDT34
------------------------------VMT Mix:
0.0758
0.2523
0.0840
0.0386
0.0003
0.0018
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
----------GASPM:
0.0046
0.0046
0.0050
0.0050
----------ECARBON:
--------------------0.1276
0.0418
OCARBON:
--------------------0.1836
0.0601
SO4:
0.0015
0.0015
0.0016
0.0016
0.0036
0.0060
Total Exhaust PM:
0.0061
0.0061
0.0066
0.0066
0.3148
0.1079
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
Tire:
0.0080
0.0080
0.0080
0.0080
0.0080
0.0080

Total PM:
0.0267
0.0267
0.0272
0.0272
0.3353
0.1285
SO2:
0.0262
0.0262
0.0342
0.0342
0.0694
0.1153
NH3:
0.1000
0.1000
0.0990
0.0990
0.0068
0.0068
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
----------------------------------------VMT Mix:
0.0293
0.0010
0.0004
0.0012
0.0025
0.0010
0.0000
0.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
GASPM:
0.0580
0.0636
0.0709
0.0577
0.0568
0.0581
0.0598
0.0000
ECARBON:
----------------------------------------OCARBON:
----------------------------------------SO4:
0.0036
0.0035
0.0022
0.0024
0.0024
0.0024
0.0022
0.0000
Total Exhaust PM:
0.0616
0.0671
0.0731
0.0602
0.0593
0.0605
0.0620
0.0000
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0000
Tire:
0.0080
0.0120
0.0120
0.0120
0.0120
0.0120
0.0360
0.0000
Total PM:
0.0822
0.0917
0.0976
0.0847
0.0838
0.0851
0.1106
0.0000
SO2:
0.0486
0.0526
0.0542
0.0619
0.0613
0.0669
0.0710
0.0000
NH3:
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0000
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
----------------------------------------VMT Mix:
0.0092
0.0028
0.0030
0.0014
0.0071
0.0103
0.0124
0.0438
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
----------------------------------------GASPM:
----------------------------------------ECARBON:
0.0636
0.0556
0.0564
0.0525
0.1240
0.1257
0.1541
0.2210
OCARBON:
0.0662
0.0579
0.0587
0.0546
0.0974
0.0988
0.1211
0.0698
SO4:
0.0107
0.0118
0.0135
0.0139
0.0158
0.0182
0.0209
0.0219
Total Exhaust PM:
0.1405
0.1252
0.1286
0.1210
0.2371
0.2427
0.2961
0.3127
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
Tire:
0.0080
0.0120
0.0120
0.0120
0.0120
0.0120
0.0360
0.0360
Total PM:
0.1610
0.1498
0.1531
0.1455
0.2616
0.2672
0.3446
0.3613
SO2:
0.1522
0.1686
0.1924
0.1985
0.2252
0.2597
0.2983
0.3134
NH3:
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
----------------------------------------------------------------------------------------------------------------------Veh. Type:
GasBUS
URBAN
SCHOOL
---------------VMT Mix:
0.0002
0.0009
0.0017
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
----------GASPM:
0.1366
----------ECARBON:
-----0.3119
0.3293
OCARBON:
-----0.2451
0.2588
SO4:
0.0011
0.0318
0.0221
Total Exhaust PM:
0.1377
0.5888
0.6102
Brake:
0.0125
0.0125
0.0125
Tire:
0.0120
0.0120
0.0120

Total PM:
0.1622
0.6133
0.6347
SO2:
0.0788
0.4545
0.3153
NH3:
0.0451
0.0270
0.0270
-----------------------------------------------------------------------------------------------------------------------

MOBILE6.2 Output File for I/M scenario: PM2.5
***************************************************************************
* MOBILE6.2.03 (24-Sep-2003)
*
* Input file: PM05INV\TEST\PM25.IN (file 1, run 1).
*
***************************************************************************
*
*
*
*

# # # # # # # # # # # # # # # # # # # # # # # # #
I/M Scenario
File 1, Run 1, Scenario 1.
# # # # # # # # # # # # # # # # # # # # # # # # #
Calendar Year:
Month:
Gasoline Fuel Sulfur Content:
Diesel Fuel Sulfur Content:
Particle Size Cutoff:
Reformulated Gas:
Vehicle Type:
GVWR:

LDGV

2005
July
90. ppm
309. ppm
2.50 Microns
Yes

LDGT12
LDGT34
LDGT
HDGV
LDDV
LDDT
HDDV
MC
All Veh
<6000
>6000
(All)
--------------------------------------------------VMT Distribution:
0.4132
0.3281
0.1227
0.0357
0.0008
0.0021
0.0926
0.0048
1.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
---------------0.0000
0.0000
GASPM:
0.0038
0.0042
0.0045
0.0043
0.0511
---------------0.0142
0.0054
ECARBON:
-------------------------0.1306
0.0493
0.1550
-----0.0146
OCARBON:
-------------------------0.0368
0.0709
0.0791
-----0.0075
SO4:
0.0010
0.0015
0.0016
0.0016
0.0034
0.0037
0.0057
0.0192
0.0003
0.0030
Total Exhaust PM:
0.0048
0.0057
0.0061
0.0058
0.0545
0.1711
0.1259
0.2532
0.0145
0.0305
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
Tire:
0.0020
0.0020
0.0020
0.0020
0.0022
0.0020
0.0020
0.0065
0.0010
0.0024
Total PM:
0.0122
0.0131
0.0135
0.0132
0.0621
0.1785
0.1332
0.2651
0.0209
0.0383
SO2:
0.0204
0.0262
0.0342
0.0284
0.0508
0.0700
0.1090
0.2741
0.0098
0.0488
NH3:
0.1015
0.1000
0.0990
0.0998
0.0451
0.0068
0.0068
0.0270
0.0113
0.0911
----------------------------------------------------------------------------------------------------------------------Veh. Type:
LDGT1
LDGT2
LDGT3
LDGT4
LDDT12
LDDT34
------------------------------VMT Mix:
0.0758
0.2523
0.0840
0.0386
0.0003
0.0018
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
----------GASPM:
0.0042
0.0042
0.0045
0.0045
----------ECARBON:
--------------------0.1174
0.0384
OCARBON:
--------------------0.1689
0.0553
SO4:
0.0015
0.0015
0.0016
0.0016
0.0036
0.0060
Total Exhaust PM:
0.0057
0.0057
0.0061
0.0061
0.2899
0.0998
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053

Tire:
0.0020
0.0020
0.0020
0.0020
0.0020
0.0020
Total PM:
0.0131
0.0131
0.0135
0.0135
0.2972
0.1071
SO2:
0.0262
0.0262
0.0342
0.0342
0.0694
0.1153
NH3:
0.1000
0.1000
0.0990
0.0990
0.0068
0.0068
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
----------------------------------------VMT Mix:
0.0293
0.0010
0.0004
0.0012
0.0025
0.0010
0.0000
0.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
GASPM:
0.0512
0.0547
0.0564
0.0481
0.0475
0.0483
0.0491
0.0000
ECARBON:
----------------------------------------OCARBON:
----------------------------------------SO4:
0.0036
0.0035
0.0022
0.0024
0.0024
0.0024
0.0022
0.0000
Total Exhaust PM:
0.0547
0.0583
0.0586
0.0505
0.0500
0.0507
0.0513
0.0000
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0000
Tire:
0.0020
0.0030
0.0030
0.0030
0.0030
0.0030
0.0090
0.0000
Total PM:
0.0621
0.0666
0.0670
0.0589
0.0583
0.0591
0.0657
0.0000
SO2:
0.0486
0.0526
0.0542
0.0619
0.0613
0.0669
0.0710
0.0000
NH3:
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0000
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
----------------------------------------VMT Mix:
0.0092
0.0028
0.0030
0.0014
0.0071
0.0103
0.0124
0.0438
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
----------------------------------------GASPM:
----------------------------------------ECARBON:
0.0585
0.0511
0.0519
0.0483
0.1140
0.1157
0.1418
0.2033
OCARBON:
0.0609
0.0532
0.0540
0.0502
0.0896
0.0909
0.1114
0.0642
SO4:
0.0107
0.0118
0.0135
0.0139
0.0158
0.0182
0.0209
0.0219
Total Exhaust PM:
0.1301
0.1162
0.1194
0.1124
0.2194
0.2247
0.2741
0.2895
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
Tire:
0.0020
0.0030
0.0030
0.0030
0.0030
0.0030
0.0090
0.0090
Total PM:
0.1374
0.1245
0.1277
0.1207
0.2277
0.2330
0.2884
0.3038
SO2:
0.1522
0.1686
0.1924
0.1985
0.2252
0.2597
0.2983
0.3134
NH3:
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
----------------------------------------------------------------------------------------------------------------------Veh. Type:
GasBUS
URBAN
SCHOOL
---------------VMT Mix:
0.0002
0.0009
0.0017
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
----------GASPM:
0.0984
----------ECARBON:
-----0.2870
0.3030
OCARBON:
-----0.2255
0.2381
SO4:
0.0011
0.0318
0.0221
Total Exhaust PM:
0.0995
0.5442
0.5631
Brake:
0.0053
0.0053
0.0053

Tire:
0.0030
0.0030
0.0030
Total PM:
0.1079
0.5525
0.5715
SO2:
0.0788
0.4545
0.3153
NH3:
0.0451
0.0270
0.0270
-----------------------------------------------------------------------------------------------------------------------

MOBILE6.2 Output File for I/M scenario: NOx
***************************************************************************
* MOBILE6.2.03 (24-Sep-2003)
*
* Input file: PM05INV\TEST\PM10.IN (file 1, run 1).
*
***************************************************************************
* Reading non-default I/M CUTPOINTS from the following external
* data file: CUTPNT05.D
* Reading Registration Distributions from the following external
* data file: 02REG05.D

*
*
*
*

# # # # # # # # # # # # # # # # # # # # # # # # #
I/M Scenario
File 1, Run 1, Scenario 1.
# # # # # # # # # # # # # # # # # # # # # # # # #

* Reading PM Gas Carbon ZML Levels
* from the external data file PMGZML.CSV
* Reading PM Gas Carbon DR1 Levels
* from the external data file PMGDR1.CSV
* Reading PM Gas Carbon DR2 Levels
* from the external data file PMGDR2.CSV
* Reading PM Diesel Zero Mile Levels
* from the external data file PMDZML.CSV
* Reading the First PM Deterioration Rates
* from the external data file PMDDR1.CSV
* Reading the Second PM Deterioration Rates
* from the external data file PMDDR2.CSV
M616 Comment:
User has supplied post-1999 sulfur levels.
*** I/M credits for Tech1&2 vehicles were read from the following external
data file: TECH12.D
M 48 Warning:
there are no sales for vehicle class HDGV8b
* Reading Ammonia (NH3) Basic Emissiion Rates
* from the external data file PMNH3BER.D
* Reading Ammonia (NH3) Sulfur Deterioration Rates
* from the external data file PMNH3SDR.D
Calendar Year:

2005

Month:
Altitude:
Minimum Temperature:
Maximum Temperature:
Absolute Humidity:
Fuel Sulfur Content:

July
Low
56.0
97.0
75.
90.

Exhaust I/M Program:
Evap I/M Program:
ATP Program:
Reformulated Gas:

Yes
Yes
Yes
Yes

Vehicle Type:
GVWR:

LDGV

(F)
(F)
grains/lb
ppm

LDGT12
LDGT34
LDGT
HDGV
LDDV
LDDT
HDDV
MC
All Veh
<6000
>6000
(All)
--------------------------------------------------VMT Distribution:
0.4132
0.3281
0.1227
0.0357
0.0008
0.0021
0.0926
0.0048
1.0000
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
0.913
1.099
1.406
1.183
1.353
0.731
0.817
0.500
3.45
1.024
Composite CO :
9.53
11.89
13.47
12.32
10.33
1.814
1.411
2.588
16.33
10.185
Composite NOX :
0.757
0.975
1.314
1.067
4.183
1.563
1.365
11.251
1.24
1.995
---------------------------------------------------------------------------------------------------------------------Veh. Type:
LDGT1
LDGT2
LDGT3
LDGT4
LDDT12
LDDT34
------------------------------VMT Mix:
0.0758
0.2523
0.0840
0.0386
0.0003
0.0018
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
1.058
1.111
1.388
1.445
2.635
0.528
Composite CO :
11.37
12.05
13.36
13.69
4.615
0.902
Composite NOX :
0.779
1.034
1.191
1.581
2.736
1.147
---------------------------------------------------------------------------------------------------------------------Veh. Type:
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
----------------------------------------VMT Mix:
0.0293
0.0010
0.0004
0.0012
0.0025
0.0010
0.0000
0.0000
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
1.244
1.638
2.594
1.701
1.628
1.864
2.200
0.000
Composite CO :
9.23
16.42
20.97
12.46
11.88
14.73
16.50
0.00
Composite NOX :
4.021
4.440
4.766
4.841
4.785
5.372
5.957
0.000
---------------------------------------------------------------------------------------------------------------------Veh. Type:
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
----------------------------------------VMT Mix:
0.0092
0.0028
0.0030
0.0014
0.0071
0.0103
0.0124
0.0438
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
0.230
0.251
0.297
0.319
0.441
0.545
0.501
0.583
Composite CO :
0.958
1.122
1.281
1.373
1.566
1.954
2.780
3.381
Composite NOX :
3.996
4.443
5.286
5.642
7.711
9.578
12.217
14.339
---------------------------------------------------------------------------------------------------------------------Veh. Type:
GasBUS
URBAN
SCHOOL
----------------

VMT Mix:
0.0002
0.0009
0.0017
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
5.426
0.534
0.695
Composite CO :
65.48
4.518
2.329
Composite NOX :
7.827
17.002
11.940
----------------------------------------------------------------------------------------------------------------------

MOBILE6.2 Output File for no I/M scenario: PM10, SOx, and NH3
***************************************************************************
* MOBILE6.2.03 (24-Sep-2003)
*
* Input file: PM05INV\TEST\PM10N.IN (file 1, run 1).
*
***************************************************************************
*
*
*
*

# # # # # # # # # # # # # # # # # # # # # # # # #
I/M Scenario
File 1, Run 1, Scenario 1.
# # # # # # # # # # # # # # # # # # # # # # # # #
Calendar Year: 2005
Month: July
Gasoline Fuel Sulfur Content:
90. ppm
Diesel Fuel Sulfur Content: 309. ppm
Particle Size Cutoff: 10.00 Microns
Reformulated Gas: Yes
Vehicle Type:
GVWR:

LDGV

LDGT12
LDGT34
LDGT
HDGV
LDDV
LDDT
HDDV
MC
All Veh
<6000
>6000
(All)
--------------------------------------------------VMT Distribution:
0.4132
0.3281
0.1227
0.0357
0.0008
0.0021
0.0926
0.0048
1.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
---------------0.0000
0.0000
GASPM:
0.0042
0.0046
0.0050
0.0047
0.0587
---------------0.0205
0.0060
ECARBON:
-------------------------0.1420
0.0536
0.1685
-----0.0158
OCARBON:
-------------------------0.0401
0.0771
0.0859
-----0.0081
SO4:
0.0010
0.0015
0.0016
0.0016
0.0034
0.0037
0.0057
0.0192
0.0003
0.0030
Total Exhaust PM:
0.0052
0.0061
0.0066
0.0063
0.0621
0.1857
0.1363
0.2736
0.0208
0.0331
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
Tire:
0.0080
0.0080
0.0080
0.0080
0.0087
0.0080
0.0080
0.0262
0.0040
0.0097
Total PM:
0.0257
0.0267
0.0272
0.0268
0.0833
0.2063
0.1569
0.3123
0.0374
0.0553
SO2:
0.0204
0.0262
0.0342
0.0284
0.0508
0.0700
0.1090
0.2741
0.0098
0.0488
NH3:
0.1015
0.1000
0.0990
0.0998
0.0451
0.0068
0.0068
0.0270
0.0113
0.0911
----------------------------------------------------------------------------------------------------------------------Veh. Type:
LDGT1
LDGT2
LDGT3
LDGT4
LDDT12
LDDT34
------------------------------VMT Mix:
0.0758
0.2523
0.0840
0.0386
0.0003
0.0018
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
----------GASPM:
0.0046
0.0046
0.0050
0.0050
----------ECARBON:
--------------------0.1276
0.0418
OCARBON:
--------------------0.1836
0.0601
SO4:
0.0015
0.0015
0.0016
0.0016
0.0036
0.0060
Total Exhaust PM:
0.0061
0.0061
0.0066
0.0066
0.3148
0.1079
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
Tire:
0.0080
0.0080
0.0080
0.0080
0.0080
0.0080
Total PM:
0.0267
0.0267
0.0272
0.0272
0.3353
0.1285

SO2:
0.0262
0.0262
0.0342
0.0342
0.0694
0.1153
NH3:
0.1000
0.1000
0.0990
0.0990
0.0068
0.0068
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
----------------------------------------VMT Mix:
0.0293
0.0010
0.0004
0.0012
0.0025
0.0010
0.0000
0.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
GASPM:
0.0580
0.0636
0.0709
0.0577
0.0568
0.0581
0.0598
0.0000
ECARBON:
----------------------------------------OCARBON:
----------------------------------------SO4:
0.0036
0.0035
0.0022
0.0024
0.0024
0.0024
0.0022
0.0000
Total Exhaust PM:
0.0616
0.0671
0.0731
0.0602
0.0593
0.0605
0.0620
0.0000
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0000
Tire:
0.0080
0.0120
0.0120
0.0120
0.0120
0.0120
0.0360
0.0000
Total PM:
0.0822
0.0917
0.0976
0.0847
0.0838
0.0851
0.1106
0.0000
SO2:
0.0486
0.0526
0.0542
0.0619
0.0613
0.0669
0.0710
0.0000
NH3:
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0000
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
----------------------------------------VMT Mix:
0.0092
0.0028
0.0030
0.0014
0.0071
0.0103
0.0124
0.0438
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
----------------------------------------GASPM:
----------------------------------------ECARBON:
0.0636
0.0556
0.0564
0.0525
0.1240
0.1257
0.1541
0.2210
OCARBON:
0.0662
0.0579
0.0587
0.0546
0.0974
0.0988
0.1211
0.0698
SO4:
0.0107
0.0118
0.0135
0.0139
0.0158
0.0182
0.0209
0.0219
Total Exhaust PM:
0.1405
0.1252
0.1286
0.1210
0.2371
0.2427
0.2961
0.3127
Brake:
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
0.0125
Tire:
0.0080
0.0120
0.0120
0.0120
0.0120
0.0120
0.0360
0.0360
Total PM:
0.1610
0.1498
0.1531
0.1455
0.2616
0.2672
0.3446
0.3613
SO2:
0.1522
0.1686
0.1924
0.1985
0.2252
0.2597
0.2983
0.3134
NH3:
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
----------------------------------------------------------------------------------------------------------------------Veh. Type:
GasBUS
URBAN
SCHOOL
---------------VMT Mix:
0.0002
0.0009
0.0017
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
----------GASPM:
0.1366
----------ECARBON:
-----0.3119
0.3293
OCARBON:
-----0.2451
0.2588
SO4:
0.0011
0.0318
0.0221
Total Exhaust PM:
0.1377
0.5888
0.6102
Brake:
0.0125
0.0125
0.0125
Tire:
0.0120
0.0120
0.0120
Total PM:
0.1622
0.6133
0.6347

SO2:
0.0788
0.4545
0.3153
NH3:
0.0451
0.0270
0.0270
-----------------------------------------------------------------------------------------------------------------------

MOBILE6.2 Output File for no I/M scenario: PM2.5
***************************************************************************
* MOBILE6.2.03 (24-Sep-2003)
*
* Input file: PM05INV\TEST\PM25N.IN (file 1, run 1).
*
***************************************************************************
*
*
*
*

# # # # # # # # # # # # # # # # # # # # # # # # #
I/M Scenario
File 1, Run 1, Scenario 1.
# # # # # # # # # # # # # # # # # # # # # # # # #
Calendar Year:
Month:
Gasoline Fuel Sulfur Content:
Diesel Fuel Sulfur Content:
Particle Size Cutoff:
Reformulated Gas:
Vehicle Type:
GVWR:

LDGV

2005
July
90. ppm
309. ppm
2.50 Microns
Yes

LDGT12
LDGT34
LDGT
HDGV
LDDV
LDDT
HDDV
MC
All Veh
<6000
>6000
(All)
--------------------------------------------------VMT Distribution:
0.4132
0.3281
0.1227
0.0357
0.0008
0.0021
0.0926
0.0048
1.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
---------------0.0000
0.0000
GASPM:
0.0038
0.0042
0.0045
0.0043
0.0511
---------------0.0142
0.0054
ECARBON:
-------------------------0.1306
0.0493
0.1550
-----0.0146
OCARBON:
-------------------------0.0368
0.0709
0.0791
-----0.0075
SO4:
0.0010
0.0015
0.0016
0.0016
0.0034
0.0037
0.0057
0.0192
0.0003
0.0030
Total Exhaust PM:
0.0048
0.0057
0.0061
0.0058
0.0545
0.1711
0.1259
0.2532
0.0145
0.0305
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
Tire:
0.0020
0.0020
0.0020
0.0020
0.0022
0.0020
0.0020
0.0065
0.0010
0.0024
Total PM:
0.0122
0.0131
0.0135
0.0132
0.0621
0.1785
0.1332
0.2651
0.0209
0.0383
SO2:
0.0204
0.0262
0.0342
0.0284
0.0508
0.0700
0.1090
0.2741
0.0098
0.0488
NH3:
0.1015
0.1000
0.0990
0.0998
0.0451
0.0068
0.0068
0.0270
0.0113
0.0911
----------------------------------------------------------------------------------------------------------------------Veh. Type:
LDGT1
LDGT2
LDGT3
LDGT4
LDDT12
LDDT34
------------------------------VMT Mix:
0.0758
0.2523
0.0840
0.0386
0.0003
0.0018
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
----------GASPM:
0.0042
0.0042
0.0045
0.0045
----------ECARBON:
--------------------0.1174
0.0384
OCARBON:
--------------------0.1689
0.0553
SO4:
0.0015
0.0015
0.0016
0.0016
0.0036
0.0060
Total Exhaust PM:
0.0057
0.0057
0.0061
0.0061
0.2899
0.0998
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
Tire:
0.0020
0.0020
0.0020
0.0020
0.0020
0.0020
Total PM:
0.0131
0.0131
0.0135
0.0135
0.2972
0.1071

SO2:
0.0262
0.0262
0.0342
0.0342
0.0694
0.1153
NH3:
0.1000
0.1000
0.0990
0.0990
0.0068
0.0068
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
----------------------------------------VMT Mix:
0.0293
0.0010
0.0004
0.0012
0.0025
0.0010
0.0000
0.0000
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
0.0000
GASPM:
0.0512
0.0547
0.0564
0.0481
0.0475
0.0483
0.0491
0.0000
ECARBON:
----------------------------------------OCARBON:
----------------------------------------SO4:
0.0036
0.0035
0.0022
0.0024
0.0024
0.0024
0.0022
0.0000
Total Exhaust PM:
0.0547
0.0583
0.0586
0.0505
0.0500
0.0507
0.0513
0.0000
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0000
Tire:
0.0020
0.0030
0.0030
0.0030
0.0030
0.0030
0.0090
0.0000
Total PM:
0.0621
0.0666
0.0670
0.0589
0.0583
0.0591
0.0657
0.0000
SO2:
0.0486
0.0526
0.0542
0.0619
0.0613
0.0669
0.0710
0.0000
NH3:
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0451
0.0000
----------------------------------------------------------------------------------------------------------------------Veh. Type:
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
----------------------------------------VMT Mix:
0.0092
0.0028
0.0030
0.0014
0.0071
0.0103
0.0124
0.0438
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
----------------------------------------GASPM:
----------------------------------------ECARBON:
0.0585
0.0511
0.0519
0.0483
0.1140
0.1157
0.1418
0.2033
OCARBON:
0.0609
0.0532
0.0540
0.0502
0.0896
0.0909
0.1114
0.0642
SO4:
0.0107
0.0118
0.0135
0.0139
0.0158
0.0182
0.0209
0.0219
Total Exhaust PM:
0.1301
0.1162
0.1194
0.1124
0.2194
0.2247
0.2741
0.2895
Brake:
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
0.0053
Tire:
0.0020
0.0030
0.0030
0.0030
0.0030
0.0030
0.0090
0.0090
Total PM:
0.1374
0.1245
0.1277
0.1207
0.2277
0.2330
0.2884
0.3038
SO2:
0.1522
0.1686
0.1924
0.1985
0.2252
0.2597
0.2983
0.3134
NH3:
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
0.0270
----------------------------------------------------------------------------------------------------------------------Veh. Type:
GasBUS
URBAN
SCHOOL
---------------VMT Mix:
0.0002
0.0009
0.0017
----------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Lead:
0.0000
----------GASPM:
0.0984
----------ECARBON:
-----0.2870
0.3030
OCARBON:
-----0.2255
0.2381
SO4:
0.0011
0.0318
0.0221
Total Exhaust PM:
0.0995
0.5442
0.5631
Brake:
0.0053
0.0053
0.0053
Tire:
0.0030
0.0030
0.0030
Total PM:
0.1079
0.5525
0.5715

SO2:
0.0788
0.4545
0.3153
NH3:
0.0451
0.0270
0.0270
-----------------------------------------------------------------------------------------------------------------------

MOBILE6.2 Output File for no I/M scenario: NOx
***************************************************************************
* MOBILE6.2.03 (24-Sep-2003)
*
* Input file: PM05INV\TEST\PM10N.IN (file 1, run 1).
*
***************************************************************************
*
*
*
*
*
*

Reading Registration Distributions from the following external
data file: 02REG05.D
# # # # # # # # # # # # # # # # # # # # # # # # #
I/M Scenario
File 1, Run 1, Scenario 1.
# # # # # # # # # # # # # # # # # # # # # # # # #

* Reading PM Gas Carbon ZML Levels
* from the external data file PMGZML.CSV
* Reading PM Gas Carbon DR1 Levels
* from the external data file PMGDR1.CSV
* Reading PM Gas Carbon DR2 Levels
* from the external data file PMGDR2.CSV
* Reading PM Diesel Zero Mile Levels
* from the external data file PMDZML.CSV
* Reading the First PM Deterioration Rates
* from the external data file PMDDR1.CSV
* Reading the Second PM Deterioration Rates
* from the external data file PMDDR2.CSV
M616 Comment:
User has supplied post-1999 sulfur levels.
M 48 Warning:
there are no sales for vehicle class HDGV8b
* Reading Ammonia (NH3) Basic Emissiion Rates
* from the external data file PMNH3BER.D
* Reading Ammonia (NH3) Sulfur Deterioration Rates
* from the external data file PMNH3SDR.D
Calendar Year:
Month:
Altitude:
Minimum Temperature:
Maximum Temperature:
Absolute Humidity:
Fuel Sulfur Content:

2005
July
Low
56.0
97.0
75.
90.

(F)
(F)
grains/lb
ppm

Exhaust I/M Program:
Evap I/M Program:
ATP Program:
Reformulated Gas:
Vehicle Type:
GVWR:

LDGV

No
No
No
Yes

LDGT12
LDGT34
LDGT
HDGV
LDDV
LDDT
HDDV
MC
All Veh
<6000
>6000
(All)
--------------------------------------------------VMT Distribution:
0.4132
0.3281
0.1227
0.0357
0.0008
0.0021
0.0926
0.0048
1.0000
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
1.009
1.213
1.526
1.298
1.414
0.731
0.817
0.500
3.45
1.118
Composite CO :
11.30
13.64
15.43
14.13
11.63
1.814
1.411
2.588
16.33
11.774
Composite NOX :
0.863
1.083
1.420
1.175
4.214
1.563
1.365
11.251
1.24
2.088
---------------------------------------------------------------------------------------------------------------------Veh. Type:
LDGT1
LDGT2
LDGT3
LDGT4
LDDT12
LDDT34
------------------------------VMT Mix:
0.0758
0.2523
0.0840
0.0386
0.0003
0.0018
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
1.184
1.222
1.510
1.562
2.635
0.528
Composite CO :
13.25
13.76
15.36
15.58
4.615
0.902
Composite NOX :
0.888
1.141
1.298
1.688
2.736
1.147
---------------------------------------------------------------------------------------------------------------------Veh. Type:
HDGV2B
HDGV3
HDGV4
HDGV5
HDGV6
HDGV7
HDGV8A
HDGV8B
----------------------------------------VMT Mix:
0.0293
0.0010
0.0004
0.0012
0.0025
0.0010
0.0000
0.0000
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
1.298
1.724
2.725
1.778
1.702
1.954
2.313
0.000
Composite CO :
10.35
18.72
24.22
14.07
13.40
16.71
18.91
0.00
Composite NOX :
4.052
4.461
4.805
4.875
4.819
5.408
6.007
0.000
---------------------------------------------------------------------------------------------------------------------Veh. Type:
HDDV2B
HDDV3
HDDV4
HDDV5
HDDV6
HDDV7
HDDV8A
HDDV8B
----------------------------------------VMT Mix:
0.0092
0.0028
0.0030
0.0014
0.0071
0.0103
0.0124
0.0438
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
0.230
0.251
0.297
0.319
0.441
0.545
0.501
0.583
Composite CO :
0.958
1.122
1.281
1.373
1.566
1.954
2.780
3.381
Composite NOX :
3.996
4.443
5.286
5.642
7.711
9.578
12.217
14.339
---------------------------------------------------------------------------------------------------------------------Veh. Type:
GasBUS
URBAN
SCHOOL
---------------VMT Mix:
0.0002
0.0009
0.0017
---------------------------------------------------------------------------------------------------------------------Composite Emission Factors (g/mi):
Composite VOC :
5.806
0.534
0.695
Composite CO :
76.80
4.518
2.329
Composite NOX :
7.874
17.002
11.940
----------------------------------------------------------------------------------------------------------------------