AQ-2017-010-RULE_600_BOARD_OF_SUPERVISORS_REPORT-2021-12-08[1].PDF

Executive Summary 
of the Report to the Board of Supervisors 
Prepared by the Maricopa County Air Quality Department 
Board Hearing Date: 
Case Number/Title:  
Agenda Item: 
Supervisor Districts: 
December 08, 2021 
AQ-2017-010-Rule 600 (Emergency Episodes) 
(Pending) 
All Districts 
The Maricopa County Air Quality Department (MCAQD) complied with all statutory and county 
policies throughout this rulemaking process. Per the Enhanced Regulatory Outreach Program 
(EROP) Policy: “In addition to the required staff report, an executive summary of the report 
including an overview of stakeholder input and staff responses will be provided to the Board of 
Supervisors at least one week prior to any Board of Supervisors’ public hearing.”   
Overview of the Report to the Board of Supervisors: 
Rule 600 establishes criteria to determine when air pollutant concentrations are significantly elevated 
and establishes appropriate control actions to prevent the occurrence of ambient air pollutant 
concentrations which would cause significant harm to the health of persons. The advisories 
described in Rule 600 are not the same as a Health Watch or High Pollution Advisory. A Health 
Watch or High Pollution Advisory is issued when air pollution levels are expected to approach or 
exceed the federal health-based air quality standards. The federal health-based air quality standards 
are lower than the thresholds for air pollution alerts, warnings, and emergencies described in Rule 
600. The MCAQD is proposing to amend Rule 600 to align the rule with the episode level criteria 
and significant harm levels with the criteria listed in Arizona Administrative Code (A.A.C.) R18-2-
220 (Air Pollution Emergency Episodes) which was amended by the Arizona Department of 
Environmental Quality in March of 2019. In addition, the MCAQD is proposing to amend Rule 600 
to address stakeholder comments received after the original Notice of Proposed Rulemaking was 
posted to the EROP website in June 2019. 
Rule 600 is needed to support the Maricopa County portion of Arizona’s infrastructure State 
Implementation Plan (SIP). Each time a new National Ambient Air Quality Standard (NAAQS) is 
promulgated, each state is required to submit an infrastructure SIP revision demonstrating that the 
state has the legal authority and resources to implement the NAAQS. Among other things, the 
infrastructure SIP must demonstrate that state and local agencies have adequate permitting, 
compliance, and enforcement programs and authority to implement contingency plans during an air 
quality emergency. 
Overview of Stakeholder Input and Staff Responses:  
During the rulemaking process, the MCAQD has received written feedback from two (2) 
stakeholders. The stakeholders did not express support nor opposition to the rulemaking. The 
MCAQD evaluated the comments and drafted responses. The stakeholder comments and the 
MCAQD responses to the comments are included in Section 9 of the attached Draft Notice of Final 
Rulemaking.

Report to the Board of Supervisors 
Prepared by the Maricopa County Air Quality Department 
Board of Health 
Meeting Date: 
October 25, 2021 
Board Hearing Date: 
December 08, 2021 
Case Number/Title:  
AQ-2017-010-Rule 600 (Emergency Episodes) 
Agenda Item: 
(Pending) 
Supervisor Districts: 
All Districts 
______________________________________________________________________________ 
Applicant:  
Staff 
Request: 
Approve revisions to Rule 600 (Emergency Episodes) and approve 
submission of the revised rule as a revision to the Arizona State 
Implementation Plan. 
Rule 600 establishes criteria to determine when air pollutant 
concentrations are significantly elevated and establishes appropriate 
control actions to prevent the occurrence of ambient air pollutant 
concentrations which would cause significant harm to the health of 
persons. The advisories described in Rule 600 are not the same as a 
Health Watch or High Pollution Advisory. A Health Watch or High 
Pollution Advisory is issued when air pollution levels are expected to 
approach or exceed the federal health-based air quality standards. The 
federal health-based air quality standards are lower than the 
thresholds for air pollution alerts, warnings, and emergencies 
described in Rule 600. The Maricopa County Air Quality Department 
(MCAQD) is proposing to amend Rule 600 to align the rule with the 
episode level criteria and significant harm levels with the criteria listed 
in Arizona Administrative Code (A.A.C.) R18-2-220 (Air Pollution 
Emergency Episodes) which was amended by the Arizona 
Department of Environmental Quality in March of 2019. In addition, 
the MCAQD is proposing to amend Rule 600 to address stakeholder 
comments received after the original Notice of Proposed Rulemaking 
was posted to the Enhanced Regulatory Outreach Program (EROP) 
website in June 2019. 
Rule 600 is needed to support the Maricopa County portion of 
Arizona’s infrastructure State Implementation Plan (SIP). Each time 
a new National Ambient Air Quality Standard (NAAQS) is 
promulgated, each state is required to submit an infrastructure SIP 
revision demonstrating that the state has the legal authority and 
resources to implement the NAAQS. Among other things, the 
infrastructure SIP must demonstrate that state and local agencies

have adequate permitting, compliance, and enforcement programs 
and authority to implement contingency plans during an air quality 
emergency. 
Support/Opposition: 
During the rulemaking process, the MCAQD has received written 
feedback from two (2) stakeholders. The stakeholders did not express 
support nor opposition to the rulemaking. 
Staff 
Recommendation:
Approve 
Board of Health 
Recommendation:
Approve 
Additional Comments: 
This rulemaking is following procedures identified in state statutes 
and the Maricopa County EROP Policy. The County Manager 
briefed the Board of Supervisors regarding the rulemaking in 
December 2017. Stakeholder workshops for Rule 600 were held on 
June 11, 2018 and December 12, 2018. The Board of Health Meeting 
to initiate regulatory change for Rule 600 occurred on July 23, 2018. 
A Notice of Proposed Rulemaking for the rule was posted on the 
EROP website on June 03, 2019, and a Notice of Supplemental 
Proposed Rulemaking was posted on the EROP website on 
September 03, 2021. On October 25, 2021, the Board of Health 
made a recommendation to the Board of Supervisors to approve the 
revisions to Rule 600. 
A newspaper notice of the Board of Supervisors public hearing will 
be published in the Arizona Business Gazette on November 4, 2021 
and November 11, 2021. This regulatory change will take effect 
immediately upon approval by the Board of Supervisors. 
Presented By: 
Philip A. McNeely, R.G., Director 
Planning and Analysis Division 
Prepared By:     
 
 
     
Preamble required by Arizona Revised Statutes (A.R.S.) § 49-471.07 
(See the Draft Notice of Final Rulemaking) 
Summary of the proposed regulatory change (See Item 4 of the Draft 
Notice of Final Rulemaking) 
Analysis of input received during the process and how that input was 
responded to (See Item 9 of the Draft Notice of Final Rulemaking) 
Language of proposed regulatory change or amendment (See the 
Draft Notice of Final Rulemaking) 
Minutes from Board of Health meeting 
Copies of all written and electronic Stakeholder input 
Attachments:

DRAFT NOTICE OF FINAL RULEMAKING 
MARICOPA COUNTY AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI – EMERGENCY EPISODES 
RULE 600: EMERGENCY EPISODES 
The Maricopa County Air Quality Department (MCAQD) is proposing to amend Rule 600 
(Emergency Episodes). The Control Officer is posting this Draft Notice of Final Rulemaking on the 
Maricopa County Enhanced Regulatory Outreach Program (EROP) website as part of the Report to 
the Board of Supervisors, in accordance with the Maricopa County EROP Policy. This notice 
includes the preamble, as prescribed in A.R.S. § 49-471.05, and the full text of the rule, including the 
intended actions to make new sections or amend, repeal, or renumber the sections of the rule. This 
notice also includes a list of all previous notices posted on the Maricopa County EROP website 
addressing the proposed rule and the concise explanatory statement prescribed in A.R.S. § 49-
471.07, subsection B. 
PREAMBLE 
1.
Statutory authority for the rulemaking:
A.R.S. §§ 49-112, 49-474, 49-479 and 49-480
2.
Name and address of department personnel with whom persons may communicate
regarding the rulemaking:
Name:
Scott Kahldon or Kimberly Butler 
Maricopa County Air Quality Department 
Planning and Analysis Division 
Address: 
3800 N Central Avenue, Suite 1400 
Phoenix, AZ 85012 
Telephone:
(602) 506-6010
Fax:
(602) 506-6179
Email:
AQPlanning@maricopa.gov
Online: 
Submit a Comment 
3.
Rulemaking process:
This rulemaking (AQ-2017-010-Rule 600) is following procedures identified in state statutes
and the Maricopa County EROP Policy. The following rulemaking steps have been
completed:
County Manager Briefing:
December 2017 
Stakeholder Workshops:
June 11, 2018 
December 12, 2018 
Board of Health Meeting to Initiate Regulatory Change: 
July 23, 2018 
Notice of Proposed Rulemaking: 
June 03, 2019 
Return to list of attachments

Notice of Supplemental Proposed Rulemaking: 
September 03, 2021 
Board of Health Meeting to Recommend Approval to the 
Board of Supervisors: 
October 25, 2021 
Board of Supervisors Formal Meeting to set the Public 
Hearing: 
November 03, 2021 
Board of Supervisors Public Hearing: 
December 08, 2021 
4.
Explanation of the rule, including the control officer's reasons for initiating the
rulemaking:
Rule 600 establishes criteria to determine when air pollutant concentrations are significantly
elevated and establishes appropriate control actions to prevent the occurrence of ambient air
pollutant concentrations which would cause significant harm to the health of persons. The
advisories described in Rule 600 are not the same as a Health Watch or High Pollution
Advisory. A Health Watch or High Pollution Advisory is issued when air pollution levels are
expected to approach or exceed the federal health-based air quality standards. The federal
health-based air quality standards are lower than the thresholds for air pollution alerts,
warnings, and emergencies described in Rule 600. The MCAQD is proposing to amend Rule
600 to align the rule with the episode level criteria and significant harm levels with the
criteria listed in Arizona Administrative Code (A.A.C.) R18-2-220 (Air Pollution Emergency
Episodes) which was amended by the Arizona Department of Environmental Quality
(ADEQ) in March of 2019. In addition, the MCAQD is proposing to amend Rule 600 to
address stakeholder comments received after the original Notice of Proposed Rulemaking
was posted to the EROP website in June 2019.
Rule 600 is needed to support the Maricopa County portion of Arizona’s infrastructure State
Implementation Plan (SIP). Each time a new National Ambient Air Quality Standard
(NAAQS) is promulgated, each state is required to submit an infrastructure SIP revision
demonstrating that the state has the legal authority and resources to implement the NAAQS.
Among other things, the infrastructure SIP must demonstrate that state and local agencies
have adequate permitting, compliance, and enforcement programs and authority to
implement contingency plans during an air quality emergency.
5.
Studies relied on in the control officer's evaluation of or justification for the rule and
where the public may obtain or review the studies, all data underlying the studies,
any analysis of the studies and other supporting material.
Not Applicable.
6.
An economic, small business and consumer impact statement:
The following discussion addresses each of the elements required for an economic, small
business and consumer impact statement, as prescribed by A.R.S. §§ 41-1055, subsections A,
B and C, and 41-1035:
An identification of the proposed rulemaking, including all of the following:
This rulemaking is proposing to revise Rule 600.
(a) The conduct and its frequency of occurrence that the rule is designed to change.
Return to list of attachments

Not Applicable. This rule is being revised to align the rule with A.A.C. R18-2-220. Rule 
600 is also being revised to more closely align with ADEQ’s Procedures for the 
Prevention of Emergency Episodes and to address stakeholder comments. 
(b) The harm resulting from the conduct the rule is designed to change and the 
likelihood it will continue to occur if the rule is not changed. 
Not Applicable. This rule is being revised to align the rule with A.A.C. R18-2-220. Rule 
600 is also being revised to more closely align with ADEQ’s Procedures for the 
Prevention of Emergency Episodes and to address stakeholder comments.  
(c) The estimated change in frequency of the targeted conduct expected from the 
rule change. 
Not Applicable. This rule is being revised to align the rule with A.A.C. R18-2-220. Rule 
600 is also being revised to more closely align with ADEQ’s Procedures for the 
Prevention of Emergency Episodes and to address stakeholder comments.  
A brief summary of the information included in the economic, small business and 
consumer impact statement. 
The economic, small business and consumer impact statement addresses each of the 
elements required for an economic, small business and consumer impact statement, as 
prescribed by A.R.S. §§ 41-1055, subsections A, B, and C, and 41-1035. 
Name and address of agency employees who may be contacted to submit or request 
additional data on the information included in the economic, small business and 
consumer impact statement. 
Name: 
Scott Kahldon or Kimberly Butler 
Maricopa County Air Quality Department 
Planning and Analysis Division 
Address: 
3800 N Central Avenue, Suite 1400 
Phoenix, AZ 85012 
Telephone:
(602) 506-6010
Fax:
(602) 506-6179
Email:
AQPlanning@maricopa.gov
Online: 
Submit a Comment 
An identification of the persons who will be directly affected by, bear the costs of or 
directly benefit from the proposed rulemaking. 
This rulemaking should not impose any significant costs on Maricopa County residents or 
businesses unless an emergency episode occurs. Maricopa County residents and businesses 
will benefit from this rulemaking because Rule 600 is part of the required elements of an 
infrastructure SIP. 
A cost benefit analysis of the following: 
(a) The probable costs and benefits to the implementing agency and other agencies 
directly affected by the implementation and enforcement of the proposed 
rulemaking.

This rulemaking should not impose any new costs on the MCAQD or on any other 
agencies affected by the proposed rulemaking unless an emergency episode occurs. 
(b) The probable costs and benefits to a political subdivision of this state directly 
affected by the implementation and enforcement of the proposed rulemaking. 
This rulemaking should not impose any significant new costs on political subdivisions of 
this state affected by the proposed rulemaking unless an emergency episode occurs. If an 
emergency episode does occur, the costs will vary depending on the pollutant and the 
length and severity of the emergency. 
(c) The probable costs and benefits to businesses directly affected by the proposed 
rulemaking, including any anticipated effect on the revenues or payroll 
expenditures of employers who are subject to the proposed rulemaking. 
This rulemaking will not directly affect any businesses unless an emergency episode 
occurs. If an emergency episode does occur, the costs will vary depending on the 
pollutant and the length and severity of the emergency. 
A general description of the probable impact on private and public employment in 
businesses, agencies and political subdivisions of this state directly affected by the 
proposed rulemaking. 
This rulemaking should not have any impact on private and public employment in 
businesses, agencies, or political subdivisions of this state. This rulemaking will not directly 
affect any businesses, agencies, or political subdivisions of this state unless an emergency 
episode occurs. If an emergency episode does occur, the costs and the subsequent impact to 
private and public employment will vary depending on the pollutant and the length and 
severity of the emergency. 
A statement of the probable impact of the proposed rulemaking on small businesses. 
The statement shall include: 
(a) An identification of the small businesses subject to the proposed rulemaking. 
This rulemaking should not affect any small businesses unless an emergency episode 
occurs. If an emergency episode does occur, small businesses may be asked to reduce or 
curtail vehicle use and small businesses operating under an air pollution control permit 
may be asked to curtail operations that generate emissions and maximize the efficiency 
of control equipment.  
(b) The administrative and other costs required for compliance with the proposed 
rulemaking. 
There are no administrative costs required for compliance with the proposed rulemaking. 
If an emergency episode does occur, small businesses may be asked to reduce or curtail 
vehicle use and small businesses operating under an air pollution control permit may be 
asked to curtail operations that generate emissions and maximize the efficiency of 
control equipment. If an emergency episode does occur, the costs will vary depending on 
the pollutant and the length and severity of the emergency episode. 
(c) A description of the methods that the agency may use to reduce the impact on 
small businesses.

i.
Establish less stringent compliance or reporting requirements in the rule for
small businesses.
There are no reporting requirements in Rule 600 unless an emergency episode
occurs. There are no compliance requirements in Rule 600 unless an emergency
episode occurs. If an emergency episode occurs, the Control Officer will cooperate
with the Director of the ADEQ to determine which control actions are necessary to
reduce elevated concentrations of air pollutants. In addition, the Control Officer will
communicate the necessary control actions to permit holders, businesses, and the
public.
ii. Establish less stringent schedules or deadlines in the rule for compliance or
reporting requirements for small businesses.
There are no schedules or deadlines for compliance or reporting in Rule 600.
iii. Consolidate or simplify the rule's compliance or reporting requirements for
small businesses.
There are no reporting requirements in Rule 600 unless an emergency episode
occurs. There are no compliance requirements in Rule 600 unless an emergency
episode occurs. If an emergency episode occurs, the Control Officer will cooperate
with the Director of the ADEQ to determine which control actions are necessary to
reduce elevated concentrations of air pollutants. In addition, the Control Officer will
communicate the necessary control actions to permit holders, businesses, and the
public.
iv. Establish performance standards for small businesses to replace design or
operational standards in the rule.
There are no design standards or operational standards in Rule 600.
v. Exempt small businesses from any or all requirements of the rule.
There are no reporting requirements in Rule 600 unless an emergency episode
occurs. There are no compliance requirements in Rule 600 unless an emergency
episode occurs. If an emergency episode occurs, the Control Officer will cooperate
with the Director of the ADEQ to determine which control actions are necessary to
reduce elevated concentrations of air pollutants. The extent to which small
businesses are required to comply with control actions would depend on the
pollutant and the length and severity of the emergency episode.
(d) The probable cost and benefit to private persons and consumers who are directly 
affected by the proposed rulemaking. 
Private persons and consumers would only be affected by Rule 600 if an emergency 
episode occurred, and the pollutant level was high enough to constitute an air pollution 
emergency. If an air pollution emergency were to occur, the costs would vary depending 
on the pollutant and the length of the emergency. However, because an air pollution 
emergency can only be declared when a pollutant concentration is approaching the 
significant harm level, the health benefits associated with resolving the emergency 
episode will far outweigh the costs associated with temporary restrictions on public 
vehicle use.

A statement of the probable effect on state revenues. 
It is unlikely that this rulemaking will impose increased monetary or regulatory costs on 
other state agencies, political subdivisions of this state, persons, or individuals so regulated. 
Without costs to pass through to customers, there is no projected change in consumer 
purchase patterns and, thus, no impact on state revenues from sales taxes.  If an emergency 
episode does occur, the costs will vary depending on the pollutant and the length and 
severity of the emergency episode. 
A description of any less intrusive or less costly alternative methods of achieving the 
purpose of the proposed rulemaking, including the monetizing of the costs and 
benefits for each option and providing the rationale for not using nonelected 
alternatives. 
The MCAQD was not able to identify less intrusive or costly methods for rapidly reducing 
the concentration of air pollutants during an emergency episode. 
A description of any data on which a rule is based with a detailed explanation of how 
the data was obtained and why the data is acceptable data. 
This rule is not directly based on any data. The pollutant concentrations that would trigger 
an air quality alert, warning, or emergency are identified by the United States Environmental 
Protection Agency (EPA) when a new NAAQS is promulgated, or an existing NAAQS is 
revised. 
7.
The proposed effective date of the rule:
The proposed effective date of this rulemaking is December 08, 2021.
8.
Such other matters as are prescribed by statute and that are applicable to the county
or to any specific rule or class of rules:
Under A.R.S. § 49-479(C), a county may not adopt a rule or ordinance that is more stringent
than the rules adopted by the Director of the Arizona Department of Environmental Quality
(ADEQ) for similar sources unless it demonstrates compliance with the applicable
requirements of A.R.S. §49-112.
§ 49-112 County regulation; standards
§ 49-112(A)
When authorized by law, a county may adopt a rule, ordinance or regulation that is more 
stringent than or in addition to a provision of this title or rule adopted by the director or any 
board or commission authorized to adopt rules pursuant to this title if all of the following 
requirements are met: 
1.
The rule, ordinance or regulation is necessary to address a peculiar local condition.
2.
There is credible evidence that the rule, ordinance or regulation is either;
(a) Necessary to prevent a significant threat to public health or the environment that
results from a peculiar local condition and is technically and economically feasible. 
(b) Required under a federal statute or regulation, or authorized pursuant to an 
intergovernmental agreement with the federal government to enforce federal statutes

or regulations if the county rule, ordinance or regulation is equivalent to federal 
statutes or regulation. 
3.
Any fee or tax adopted under the rule, ordinance or regulation does not exceed the
reasonable costs of the county to issue and administer the permit or plan approval
program.
§ 49-112(B)
When authorized by law, a county may adopt rules, ordinances or regulations in lieu of a 
state program that are as stringent as a provision of this title or rule adopted by the director 
or any board or commission authorized to adopt rules pursuant to this title if the county 
demonstrates that the cost of obtaining permits or other approvals from the county will 
approximately equal or be less than the fee or cost of obtaining similar permits or approvals 
under this title or any rule adopted pursuant to this title. If the state has not adopted a fee or 
tax for similar permits or approvals, the county may adopt a fee when authorized by law in 
the rule, ordinance or regulation that does not exceed the reasonable costs of the county to 
issue and administer that permit or plan approval program. 
The MCAQD is in compliance with A.R.S. §§ 49-112 (A) and (B). Rule 600 is required under 
§ 110(a)(2) of the Clean Air Act, which requires States to submit an infrastructure SIP within
three years after the promulgation or revision of any NAAQS. Each infrastructure SIP must 
contain adequate provisions prohibiting emissions of any air pollutants in amounts which 
will interfere with measures for the prevention of significant deterioration of air quality. In 
addition, each infrastructure SIP must provide authority and adequate contingency plans to 
prevent pollution from any source or combination of sources from causing imminent and 
substantial endangerment to public health or welfare. The infrastructure SIP must also 
provide necessary assurances that the State and any local government agencies designated by 
the State, will have adequate authority to carry out such implementation plans. 
9.
List of all previous notices posted to the Maricopa County EROP website addressing
the proposed rule and a concise explanatory statement, as prescribed by A.R.S. § 49-
471.07, subsection B:
(a) List of all previous notices posted to the Maricopa County EROP website
addressing the proposed rule: 
Notice 
Date of Posting 
Briefing Notification to County Manager 
December 2017 
Notice of Stakeholder Workshop 
May 23, 2018 
November 21, 2018 
Notice of Board of Health Meeting 
July 06, 2018 
Notice of Proposed Rulemaking 
June 03, 2019 
Notice of Supplemental Proposed Rulemaking 
September 03, 2021 
Notice of Board of Health Meeting to Make a 
Recommendation to the Board of Supervisors: 
October 08, 2021 
(b) The following discussion addresses each of the elements required for a concise 
explanatory statement, as prescribed by A.R.S. § 49-471.07, subsection B: 
Return to Executive Summary
Return to list of attachments

i.
A description of any change between the proposed rule or ordinance, the final
rule or ordinance or notice of final supplemental rule or ordinance.
No changes were made after the Notice of Supplemental Proposed Rulemaking was
published on September 03, 2021.
ii. A summary of the comments and arguments for and against the notice and the
county’s response to the comments and arguments.
The following discussion evaluates the arguments for and against the rule and 
includes responses to comments received on the proposed rule or the preamble in 
the Notice of Proposed Rulemaking. The MCAQD received written comments from 
two (2) stakeholders. All of the comments were reviewed and evaluated by the 
MCAQD. 
Comment #1: The Notice of Proposed Rulemaking does not provide the reader 
with a clear date for the close of public comment. Usually in the preamble to the 
proposed rule, the County will provide a date for the close of comment period. 
Although the preamble in Section 3 sets a date for receipt of request for an oral 
proceeding, we were unable to find a date for the close of comments. Accordingly, 
we are submitting prior to July 5 just to make certain our comments are timely. 
Response #1: We appreciate your efforts to provide timely comments. Statue does 
not provide any requirements for the close of comments, other than that the 
comment period must be closed before the Board of Supervisors can act on the 
proposed rule. We encourage all interested parties to attend stakeholder workshops 
and to provide comments as early as possible during the rulemaking process. 
Comment #2: Section 301.1 of the proposed rule reads as follows: 
Section 301.1 “continuance or recurrence of alert level concentrations for the same 
pollutant during the subsequent 24-hour period.” 
Section 301.2 “continuance or recurrence of concentrations of the same pollutant 
exceeding the warning level during the subsequent 24-hour period.” 
Section 301.3 “continuance or recurrence of concentrations of the same pollutant 
exceeding the emergency level during the subsequent 24-hour period.” 
For consistency, it would be helpful if all three sections used similar language. 
Accordingly, we would suggest that Section 301.1 be rewritten to mirror the language 
in 301.2 and 301.3. 
Response #2: Thank you for your comment. The MCAQD has revised Section 
301.1 to mirror the language in Sections 301.2 and 301.3. Section 301.1 now reads as 
follows: 
Section 301.1 – An air pollution alert shall be declared when any of the alert level 
concentrations listed in Table 600-1 are exceeded at any monitoring site and when 
meteorological conditions indicate that there will be a continuance or recurrence of 
concentrations of the same pollutant exceeding the alert level during the subsequent 
24-hour period.

Comment #3: Pursuant to Section 301, the triggers for an Episode Level (i.e. Alert, 
Warning or Emergency) include an exceedance of the associated level coupled with 
“meteorological conditions” indicating a continuance or recurrence during the 
subsequent 24 hour period. (See, Section 301). We were unable to find in the rule 
any indication about what factors are used to determine the meteorological 
conditions requirement and also what agency or group is responsible for this task. 
Accordingly, since this is such an important part of the rule, it would be helpful for 
the reader, and the regulated community, if the County included the factors that go 
into making the meteorological conditions determination and also the agency or 
group that is responsible for making this determination. 
Response #3: Thank you for your comment. The MCAQD has revised Section 301 
and added Section 403 (Acquisition of Forecasts) to identify the types of information 
the Control Officer will use to determine if an emergency episode is occurring. It is 
not possible to enumerate every combination of meteorological factors that may 
result in the declaration of an air quality alert, warning, or emergency. 
Section 301 – The Control Officer’s designated representative shall acquire air 
quality forecasts and meteorological data in accordance with Section 403 of this rule. 
The Control Officer shall declare air pollution alerts, warnings, and emergencies in 
accordance with the following criteria: 
Section 403 – The Control Officer’s designated representative shall review air quality 
forecasts from ADEQ, weather forecasts and alerts from the National Weather 
Service (including atmospheric stagnation advisories, heat advisories, wind advisories, 
and high wind watches and warnings), and other reliable sources of meteorological 
data to determine if it is likely that the episode level criteria in Table 600-1 will be 
exceeded. The Control Officer will also use air quality forecasts, weather alerts, other 
reliable sources of meteorological data, and monitoring data to determine if a 
continuance or recurrence of alert level, warning level, or emergency level pollutant 
concentrations is likely. 
Comment #4: It appears that Section 301.3 creates two separate triggers for an Air 
Pollution Emergency. First is the emergency based upon exceedance of the 
Emergency threshold. Second, is if the air quality associated with a Warning Level 
exceedance does not improve within 48 hours. If this is the case, it would be helpful 
if the County added an “or” to the end of subsection (a) so that the reader 
understands that those are two separate authorities and that they are not otherwise 
conflicting. 
Additionally, in Section 301.3(b) what does the County mean by “not improved?” Is 
it possible to have a monitor show signs of “improvement,” yet still be above the 
“Warning Level?” Can a monitor show signs of improvements below the warning 
level, but still be close enough to the Warning Level to justify declaring the 
emergency? Also, if meteorological conditions improve, but the concentrations at the 
affected monitors do not, or visa-versa, shall an emergency be declared? In other 
words, must there be both an improvement in concentrations and meteorological 
conditions to avoid an emergency under Section 301.3(b)? We would like to see the 
County clarify these issues so that the reader, and regulated community, has greater 
understanding and certainty about when an event may be triggered.

Response #4: Thank you for your comment. The MCAQD has added “or” to the 
end of Section 301.3(a) and revised 301.3(b) to clarify when an air pollution 
emergency shall be declared. 
Section 301.3 Air Pollution Emergency: An air pollution emergency shall be 
declared: 
Section 301.3(a) When any of the emergency level concentrations listed in Table 600-
1 are exceeded at any monitoring site and when meteorological conditions indicate 
that there will be a continuance or recurrence of concentrations of the same 
pollutant exceeding the emergency level during the subsequent 24-hour period; or  
Section 301.3(b) If air pollution concentrations have not decreased below the 
warning level concentrations listed in Table 600-1 within 48-hours after the 
declaration of an air pollution warning. 
Comment #5: Section 301 sets the standards under which an Alert, Warning, or 
Emergency “shall be declared.” However, the rule appears silent on who actually 
declares the Alert, Warning or Emergency. It would appear that the Control Officer, 
under Section 302, directs the implementation of Control Actions. However, the rule 
is silent on who actually declares the event or, for that matter, who directs its 
termination. Accordingly, [Our Company] would like the County to provide language 
that helps to answer these questions, so that should we encounter an Episode Level 
event, all parties are aware of the authorities and responsibilities. 
Response #5: Thank you for your comment. The MCAQD has revised Section 301 
to clarify that the Control Officer shall declare air pollution alerts, warnings, and 
emergencies. 
Comment #6: The County asserts that “The MCAQD is proposing to amend Rule 
600 (Emergency Episodes) to align the rule with A.A.C. R18-2- 220 (Air Pollution 
Emergency Episodes) which was amended by the Arizona Department of 
Environmental Quality (ADEQ) in March of 2019.” However, the ADEQ rules do 
not set the emergency procedures in rule. Therefore, it is unclear how the County is 
“aligning the rule” with ADEQ, only to have a clear difference in approach. For 
example, the ADEQ rules do not provide any requirements for source abatement or 
permit restrictions during an emergency episode. The only reference to agency action 
is set forth in the attached document entitled “Procedures for the Prevention of 
Emergency Episodes.” Even this document provides only limited authority stating, 
“the Director will request emission reduction by applicable sources under State 
jurisdiction.” The document goes on to provide that “[t]he Director will contact local 
control agencies and health departments in the affected area(s) to inform them of the 
situation and request emission reduction by applicable sources under their 
jurisdiction.” The County approach does not include “request emission reduction,” 
but rather is more rigid and sets forth as series of command-and-control 
requirements. It is unclear how the County goes from ADEQ’s general language to 
the specific requirements set forth in Section 302. 
Response #6: Thank you for your comment. The proposed changes align the 
episode level criteria and significant harm levels with the criteria listed in A.A.C. R18-
2- 220 (Air Pollution Emergency Episodes).

For sources under MCAQD control, Rule 600 includes specific control actions to 
ensure that MCAQD can successfully curtail emissions during an emergency episode. 
In “Procedures for the Prevention of Emergency Episodes,” ADEQ divides 
responsibility for the preparation and issuance of Air Quality Advisories into two 
categories. Section 2.1 specifies that urban advisories “will be prepared by the local 
pollution control agencies in consultation with ADEQ.” Section 2.2 specifies that 
ADEQ will prepare advisories for emergency episodes that are the result of 
industrial emissions in rural areas. 
The “Procedures for the Prevention of Emergency Episodes,” also states that during 
an alert, warning, or an emergency, “the Director will contact local control agencies 
and health departments in the affected area(s) to inform them of the situation and 
request emission reduction by applicable sources under their jurisdiction.” 
To ensure the MCAQD can successfully curtail emissions during an air pollution 
alert, warning, or emergency, the Control Actions in Rule 600 need to be more 
specific to the sources that exist within Maricopa County. The specific requirements 
set forth in Section 302 are similar to the Example Regulations for Prevention of Air 
Pollution Emergency Episodes in Appendix L to 40 CFR 51. 
In addition, new language in Section 302.2(f) was added to “request emission 
reductions to minimize air pollution” from sources subject to Rule 322. The Section 
now reads as follows: 
Section 302.2(f): As demand for electricity decreases, as a result of the cutbacks 
implemented in accordance with subsections 302.2(a) through (e) of this rule, the 
MCAQD shall contact the operators of power plants subject to Rule 322 to request 
emission reductions to minimize air pollution. 
Comment #7: Section 302.1 asserts that the rule is to protect “that portion of the 
population at risk.” To this end the Alert, Warning and Emergency levels anticipate 
that any exceedance at any monitoring site can trigger “control actions.” Yet the 
Control Actions set forth in Section 302 are not localized to a portion of the 
population at risk or the exceedance of any monitoring site. Instead, the Control 
Actions seem to be without relation to a specific monitoring site or a portion of the 
population at risk or even related to the pollutant at issue. 
For example, Section 302.1(a) reads as follows: “All permits to burn shall be 
suspended until further notice. The forest service shall be notified to postpone slash 
burning in affected areas.” This section seems a rather blunt response to the specific 
nature of the exceedance. A burn permit could be issued for land far away from the 
affected monitor, yet be directly impacting that affect monitor. In this case, would it 
be possible to still allow the burning since it was not “in the affected areas?” 
Response #7: Thank you for your comment. You are correct that the control 
actions are not localized to the specific geographic area where the episode criteria 
have been exceeded. 
Although there are situations where a single source of air pollution could result in an 
exceedance of the episode level criteria, such as a leaf blower operating near an air 
quality monitor, these are not the types of situations that would result in the 
declaration of an alert, warning, or an emergency. When significantly elevated

concentrations of air pollutants are detected at a monitor, the MCAQD typically 
dispatches staff to determine what is causing the pollution. If the source of the 
pollution is identified, the MCAQD will generally conduct an inspection and use the 
principles of compliance assurance to ensure a reduction in emissions. If the 
standard compliance and enforcement procedures do not result in emission 
reductions, and if the actions of a single source or a small group of sources is causing 
imminent and substantial endangerment to the public health or the environment, the 
MCAQD can use authority granted under A.R.S. § 49-512 to reduce the emission of 
air pollutants from the source or sources causing the imminent and substantial 
endangerment. 
In most cases, the concentration of pollutants varies from one monitor to another. 
While sources near a monitor can have an effect, the actual concentration observed 
at each monitor is generally the result of aggregate emissions over a large area and 
atmospheric conditions. For example, the Falcon Field monitor frequently records 
the highest concentration of ozone. This is not because there are major sources of 
ozone precursors near the monitor. Rather, this occurs due to atmospheric 
conditions and because there are many sources of ozone precursors in Maricopa 
County and the surrounding areas. Due to transport, it is often not possible to 
reduce the concentration of air pollution in one area without reducing aggregate 
emissions over a larger area. 
Further, the pollution levels that qualify as “episodes” under this rule are 
considerably higher than exceedances of a NAAQS. The thresholds are very near the 
upper limit of what EPA has determined to be unhealthy with respect to an “alert,” 
very unhealthy with respect to a “warning,” and hazardous with respect to an 
“emergency.” The MCAQD has no record of events that caused a declaration of an 
air pollution warning in the past 35 years. “Alert” level concentrations have occurred 
for PM2.5 on New Year’s Day, for PM10  during dust storms qualifying as exceptional 
events, prior to 1987 for CO, and possibly prior to 1980 for ozone. Consequently, 
these extreme pollutant concentrations are not likely to be limited to the area near a 
specific monitor. 
Finally, from a practical standpoint, if it is necessary to implement control actions to 
prevent significant harm from air pollution, these actions need to be communicated 
and implemented as efficiently as possible. Therefore, by using easily understood 
boundaries (such as the borders of Maricopa County) it is easier for affected sources 
to know how to respond. This is very similar to the concept of a restricted burn 
period, which is declared for all of Maricopa County to prevent the exceedance of a 
NAAQS. 
Comment #8: Additionally, Section 302.1(b) reads as follows: “Incineration shall be 
limited to the hours of 12 noon to 4:00 p.m.” This is similar to our comments on 
Section 302.1(a) above. There is no requirement that the incinerator be located in the 
affected areas or impacting the affected areas just that it exists within Maricopa 
County. Moreover, is there a reason for the limitation of 12 noon to 4:00 pm? It 
would seem that these limited hours of operation would be based in science, but it

would be helpful for the County to explain the reasoning behind the hour 
restrictions in its response to public comments. 
Response #8: The hours of 12 noon to 4:00 pm were included in the Example 
Regulations for Prevention of Air Pollution Emergency Episodes in Appendix L to 
40 CFR 51 because mid-day is generally the period of highest atmospheric 
turbulence. The increased atmospheric turbulence at mid-day allows for increased 
vertical and horizontal distribution of air pollutants. These provisions allow sources 
to operate when air pollution concentrations are elevated during the portion of the 
day when pollutants are least likely to accumulate. These provisions make sense in 
Maricopa County where atmospheric inversions are the predominant cause of winter 
particulate matter exceedances. 
Comment #9: In the root of Section 302.1 and 302.2, the County has inserted the 
clause “as applicable to the source(s) emitting the pollutant(s) of concern” in an 
apparent attempt to provide some limitation on the County’s use of this section. We 
appreciate the intent of using this limiting language. Unfortunately, this limiting 
language is rather broad and undefined. For example, “pollutants of concern” is 
undefined. How does the County intend to address ozone exceedances when no 
source actually emits ozone? Additionally, neither NOx nor VOCs are listed in Table 
600-1, yet both are integral to ozone exceedances. 
Response #9: Thank you for your comment. The MCAQD has added a definition 
for the term “pollutant of concern” to Section 202. 
202 
POLLUTANT OF CONCERN: If an air quality alert, warning, emergency is 
declared for: 
202.1 Sulfur dioxide (SO2), the pollutants of concern shall be sulfur oxides; 
202.2 PM10, the pollutants of concern shall be PM10 and PM2.5; 
202.3 PM2.5, the pollutants of concern shall be PM2.5, ammonia, volatile 
organic compounds (VOC), nitrogen oxides (NOX), and SO2; 
202.4 Ozone, the pollutants of concern shall be NOX, VOC, and carbon 
monoxide (CO); 
202.5 Nitrogen dioxide (NO2), the pollutants of concern shall be NOX; and 
202.6 CO, the pollutant of concern shall be CO. 
Comment #10: Furthermore, Section 302.1(c) states that “Sources operating 
pursuant to an air pollution control permit shall be notified to minimize emissions.” 
This section does not require the emissions to be the pollutant identified in Table 
600-1 and exceeding the level. Finally, this section leaves open the question of, does 
the source need to be permitted for the NAAQS in question or just any pollutant? 
We would like to see the County put in more specific language that clearly spells out 
when a permitted source will be required to take action. Or, in the alternative, put in 
language allowing the Control Officer to work with affected source to find 
reasonable and workable reductions.

Response #10: 
The MCAQD has clarified Section 302.1(c) to specify that sources shall minimize 
emissions of the pollutant of concern. 
Section 302.1(c) – Sources operating pursuant to an air pollution control permit shall 
be notified to minimize emissions of the pollutant of concern by curtailing or 
deferring operations not on a required schedule and by maximizing the collection 
efficiency of control equipment. Emissions from batch operations shall be limited to 
the hours of 12 noon to 4:00 p.m. This control action shall not be applicable to any 
operations that are necessary to protect public health, public safety, or public welfare. 
Comment #11: Section 302.2(d) sets forth the requirements associated with power 
plants during an Air Pollution Warning. It states that “[i]f technologically feasible, 
power plant generating loads shall be transferred outside the affected area. Power 
plant production shall be reduced by purchase of available energy from neighboring 
utilities.” 
We have several concerns with this wording. First, utilities do not “generate load.” 
Utilities generate power which serves a load. Second, it is unclear how a power plant 
can “transfer loads outside the affected area.” As mentioned above, utilities do not 
generate load, so utilities are unable to transfer loads outside the affected area. Third, 
the requirement that “power plant production shall be reduced by purchase of 
available energy from neighboring utilities” is confusing, counterproductive and 
likely beyond the County’s authority. Although we understand the general idea that 
the County is seeking to employ here, there are some technical, financial and legal 
limitations that must be understood. Our generation mix is varied in source, be it 
coal, gas, nuclear, solar, biomass or battery. Additionally, our generation is located 
throughout the state of Arizona, not just within Maricopa County. Accordingly, it 
may be possible for [Our Company] to utilize its own resources outside of the 
County to meet the needs of an Episode Level event, yet the rule appears to require 
us to purchase energy from a neighboring utility. This seems counterproductive. 
Additionally, electrical transmission is subject to the potential for constraint. In other 
words, power lines can only carry so much power, which is often why generation is 
located close to what is called the “load pocket.” Consequently, it may not be 
possible to reduce generation within a load pocket if the transmission lines are 
constrained. Moreover, there are legal requirements on utilities that may conflict with 
the County’s assumed authority (See, comment VIII below). 
Finally, the use in Section 302.2(d) of the term “technologically feasible” in place of 
“possible” creates significant burdens for a regulated utility as transfer of power into 
and out of a load pocket is technologically feasible, but may not be operationally or 
legally possible or have other limitations. Accordingly, we request that the County 
revert to the original language of “possible,” as that will give the utilities the 
opportunity to work with the County to find a solution, instead of being forced to 
do something that may have unintended consequences but is technologically feasible. 
Also, the County’s use of the term “power plant” is inconsistent with the air quality 
rules. There are, in fact, “power plants” that produce low or zero emissions, such as 
solar and nuclear power plants. It would be helpful if the County defined power

plant to include fossil fuel fired power generation so that the focus would be on the 
fossil fleet and not bring into question solar or nuclear operations. 
Furthermore, ADEQ’s Procedure states that “The general public will be urged to 
remain indoors whenever possible and avoid prolonged or strenuous exertion.” The 
procedure of requiring that people shelter indoors is generally at odds with reducing 
power generation since it is likely that Episode Level exceedances would happen 
during hot, stagnant, summer days, which will be the time that the grid is under the 
most stress further limiting the ability of the utility to reduce generation or import 
power into the load pocket, even if technologically feasible. 
Response #11: Thank you for your comment. The MCAQD has removed the 
language in section 302.2(d) and revised the language in section 302.2(f) to read as 
follows: 
As demand for electricity decreases, as a result of the cutbacks implemented in 
accordance with subsections 302.2(a) through (e) of this rule, the MCAQD shall 
contact the operators of power plants subject to Rule 322 to request emission 
reductions.to minimize air pollution. 
Comment #12: Section 302.3(c) states, “As energy demand decreases, as a result of 
the control actions in Sections 302.3(a) and 302.3(b), power plants shall reduce 
operations so that generating loads do not exceed energy demand.” Again, as 
mentioned before, power companies generate electricity to serve a load. Power 
companies do not “generate load.” Also, energy demand is a temporal issue. In other 
words, the load or demand is continuously fluctuating requiring us to use various 
methods to ensure we have adequate power available as called upon to serve load, 
protect the integrity of the grid, and maintain reliability. It would appear that the 
purpose of this section is to prevent a power plant from generating more power in 
the affected area than needed to serve load in the affected area. The concept makes 
sense in times of a health emergency, but is not easily defined. In order to comply 
with service and reliability requirements, utilities have certain limitations on their 
ability to limit generation. [Our Company] is happy to work with the County to 
better define the terms and conditions applicable for these Event Level Exceedances, 
but we are concerned that the current language is not workable. 
Response #12: The initially proposed language as drafted in the 2019 Notice of 
Proposed Rulemaking referred to in this comment, has been removed. 
Comment #13: It may be prudent for the County to ask the Arizona Corporation 
Commission (“ACC”) for input on these rules. If the Episode Level Criteria are 
exceeded and the County enacts the Control Actions in 302.2, the County may be 
interfering with the authorities given to the ACC under Article 15 of the Arizona 
Constitution. Also, if the Episode Level Criteria are exceeded during peak summer 
months, curtailing energy production and transfer of the load may impact reliability 
as well as the health and safety of customers. 
Response #13: Many revisions to the rule language have been made since this 
comment was received, including revisions to language in Section 302.2. The 
revisions may address the commenter’s concerns. If stakeholders are concerned that

Rule 600 language may conflict with regulatory requirements imposed by the ACC, it 
may be helpful to run the language by the ACC. 
Comment #14: Perhaps consider moving these to the definitions? It doesn’t seem 
to really fit well in this paragraph. 
Response #14: The MCAQD considered your comment but determined it was not 
necessary to revise the purpose language for rule clarity. 
Comment 15: In Section 101 above, the purpose is described as establishing criteria 
used to determine when air pollutant concentrations are significantly elevated and to 
establish appropriate control actions to prevent the occurrence of ambient air 
pollutant concentrations that would cause significant harm to the health of persons 
and the words “pollution emergency episides” was struck, yet in this paragraph, the 
word “episodes” remains. Would it be more appropriate to change episodes to air 
pollutant concentrations are significantly elevated to align with the purpose of this 
rule? 
Response #15: The MCAQD considered your comment but decided to leave 
episode in the rule. Episode is used in the ADEQ's "Procedures for Prevention of 
Emergency Episodes" and air pollutant concentrations is not used. Also, episodes is 
used throughout this rule and is a common term. 
Comment #16: Is CO a pollutant of concern for Ozone? 
Response #16: The MCAQD considered your comment but determined that 
carbon monoxide should remain as a pollutant of concern for ozone as it participates 
in the creation of ozone. 
Comment #17: How do sources measure this? Is a 40% reduction from permitting 
limits, or from actual emissions? 
Response #17: The MCAQD revised the language and added actual emissions to 
clarify the rule. 
Comment #18: Recommend not removing this control measure. If it’s a PM10 
episode, it would be helpful if this activity would be able to be postponed. 
Response #18: MCAQD considered your comment and determined the 
strikethrough language is appropriate as the MCAQD does not have the authority to 
regulate agriculture. 
Comment #19: This is a bit vague. How does MCAQD define “as demand for 
electricity decreases”? Who decides what reduced demand means? Is it when 
customer demand decreases? Also, this is dependent upon the pollutant of concern? 
Suggest taking this out entirely, or suggest language that says “shall reduce emissions 
as much as possible”…Or power plants subject to Rule 322 will ensure 
implementation of best management practices ro minimize air pollution…This is a 
bit vague also, Can MCAQD clarify what a request for emissions reductions look 
like? See above comment. 
Response #19: The MCAQD considered your comment and defines a decrease in 
demand for electricity as a decrease in activity from cutbacks implemented in 
accordance with subsections 302.2(a) through (e). The MCAQD also considered

your comment on "request for emissions reductions" and determined to add 
language "to minimize air pollution" at the end of the sentence for rule clarity. 
Comment #20: To me, this means if the Governor directs us, [Our Company] shall 
stop operating it’s generating units. 
Response #20: The MCAQD considered your comment and determined that it was 
not necessary to revise this section. When an air pollution emergency has been 
declared, sources operating pursuant to an air pollution control permit shall cease 
operations as directed by the Governor. 
Comment #21: Perhaps add the word forecasts from NWS? 
Response #21: The MCAQD revised the language and added weather forecasts. 
Comment #22: Whose emissions? Do you mean pollutant concentrations in the air? 
Response #22: The MCAQD considered your comment and deleted "emissions" 
and revised "pollutant concentrations" to read “air pollutant concentrations” for 
further clarity. 
Comment #23: Since episode is used throughout the document, it may be helpful to 
add this term within the section 
Response #23: The MCAQD considered your comment and determined that is was 
not necessary to revise this section. 
Comment #24: Why is CO listed here? 
Response #24: The MCAQD considered your comment but determined that 
carbon monoxide should remain as a pollutant of concern for ozone as it participates 
in the creation of ozone. 
Comment #25: Rather than listing 2 specific rules, consider using verbiage related 
to essential public service (see Southcoast Air Pollution Emergency Contingency 
Actions). There are other services that may need to operate to ensure public safety – 
One example are our microgrids – non-emergency engines that operate under Rule 
324. As written, operation of these units would be limited even if they are deemed 
necessary to maintain grid stability. Clearly, the last sentence of this section capture 
this. 
Response #25: The MCAQD considered your comment and deleted language 
specific to Rule 322 and Rule 324 for rule clarity. 
Comment #26: Palo Verde is a power plant that does not operate under Rule 322! 
So, it strengthens our comment that the language related to Rule 322 and 324 should 
be removed and only keep “control action shall not be applicable to any operation 
that are necessary to protect public health, public safety, or public welfare.” 
Response #26: The MCAQD considered your comment and deleted language 
specific to Rule 322 and Rule 324 for rule clarity. 
Comment #27: Same comment as above – If language related to Rule 322 is kept in 
Rule 600, it needs to be made clear units complying with Rule 322 by taking 
operational limits (<10% capacity factor). Again, I would say that the last sentence

would suffice since electricity would be considered operation necessary to protect 
public safety 
Response #27: The MCAQD considered your comment and deleted language 
specific to Rule 322 and Rule 324 for rule clarity. 
Comment #28: This rule has not monitoring or recordkeeping requirements noted. 
Am I correct to interpret that facilities would not be required to maintain records 
related to their emission reductions? 
Response #28: The MCAQD considered your comment and added a section for 
Monitoring and Records. The Section now reads as follows: 
500 
MONITORING AND RECORDS: 
501 
RECORDKEEPING AND REPORTING: Any owner or operator subject 
to this rule shall comply with the requirements set forth in this section. Any 
records and data required by this section shall be kept on site at all times in a 
consistent and complete manner and be made available without delay to the 
Control Officer or designee upon request. 
502 
RECORDS RETENTION: Copies of reports, logs, and supporting 
documentation required by the Control Officer shall be retained for at least 5 
years. Records and information required by this rule shall also be retained for 
at least 5 years. 
503 
RECORDS OF CONTROL ACTION: An owner or facility shall maintain a 
log of the control actions taken during an Air Pollution Alert, Air Pollution 
Warning and Air Pollution Emergency. 
In addition, each owner and operator is responsible to follow the recordkeeping 
within their permit and other applicable rules. 
Comment #29: I think it is important to note that generation of electricity always 
follows demand – this occurs within minutes. It is also important to note, that 
decreased demands within Maricopa County, does not always equal decreased 
demand on the system. The grid is maintained at a much larger level than county 
based geography, so units within Maricopa County may be need to help support the 
western loop. I am not opposed to the language since it states the agency will request 
the emission reductions, but it is unnecessary. 
Response #29: The MCAQD considered your comment on requesting emission 
reductions and determined to add language "to minimize air pollution" at the end of 
the sentence for rule clarity. 
Comment #30: Include language related excluding operations necessary to maintain 
public safety. 
Response #30: The MCAQD considered your comment and added "except those 
vital for public safety and welfare and enforcement of the emergency episode control 
actions." at the end of the sentence in section 302.3(a). 
EXACT WORDING OF THE RULE

MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI – EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
INDEX 
SECTION 100 – GENERAL 
101 
PURPOSE 
102 
EPISODE PROCEDURES GUIDELINES 
SECTION 200 – DEFINITIONS 
201 
EMERGENCY EPISODE PLAN 
202 
POLLUTANT OF CONCERN 
SECTION 300 – STANDARDS 
301 
EPISODE LEVEL CRITERIA 
302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN 
SECTION 400 – ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION 
402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY 
403 
ACQUISITION OF FORECASTS 
404 
COMMUNICATION OF EMERGENCY EPISODES 
SECTION 500 – MONITORING AND RECORDS (NOT INCLUDED) 
501 
RECORDKEEPING AND REPORTING 
502 
RECORDS RETENTION 
503 
RECORDS OF CONTROL ACTION 
Return to list of attachments

Revised 07/13/1988; Revised 02/03/2016; Revised MM/DD/YYYY 
MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI - EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
SECTION 100 – GENERAL 
101 
PURPOSE: To establish criteria used to determine when air pollution emergency episodes 
pollutant concentrations are significantly elevated and the to establish appropriate control 
actions to prevent the occurrence of ambient air pollutant concentrations which would cause 
significant harm to the health of persons. This rule describes control and advisory 
procedures reached at each of the three episode levels. The advisories described in this rule 
are not the same as a Health Watch or High Pollution Advisory issued by the Arizona 
Department of Environmental Quality (ADEQ). A Health Watch or High Pollution 
Advisory is issued when air pollution levels are expected to approach or exceed the federal 
health based air quality standards. The federal health based air quality standards are lower 
than the thresholds for air pollution alerts, warnings, and emergencies described in this rule. 
102 
EPISODE PROCEDURES GUIDELINES: Guidelines for the procedures and 
communication steps to be followed during an air pollution episode are presented in this rule 
and in the Arizona Department of Environmental Quality’s “Procedures for Prevention of 
Emergency Episodes,” amended as of October 18, 1988 August 2018 (and no future 
edition). 
SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definition shall 
apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of 
these rules. In the event of any inconsistency between any of the Maricopa County air pollution 
control rules, the definition in this rule takes precedence. 
201 
EMERGENCY EPISODE PLAN: A system designed to reduce the levels of air 
contaminants which may reach or have reached the level which may be harmful to health, 
and to protect that portion of the population at risk. 
202 
POLLUTANT OF CONCERN: If an air quality alert, warning, or emergency is declared 
for: 
202.1 Sulfur dioxide (SO2), the pollutants of concern shall be sulfur oxides; 
202.2 PM10, the pollutants of concern shall be PM10 and PM2.5; 
202.3 PM2.5, the pollutants of concern shall be PM2.5, ammonia, volatile organic 
compounds (VOC), nitrogen oxides (NOX), and SO2; 
202.4 Ozone, the pollutants of concern shall be NOX, VOC, and carbon monoxide (CO); 
202.5 Nitrogen dioxide (NO2), the pollutants of concern shall be NOX; and 
202.6 CO, the pollutant of concern shall be CO.

SECTION 300 – STANDARDS 
301 
EPISODE LEVEL CRITERIA: An air pollution alert, warning or emergency shall be 
declared when the following air pollutant concentrations are exceeded at any monitoring site 
and when meteorological conditions indicate that there will be a recurrence of those 
concentrations for the same pollutant(s) during the subsequent 24-hour period: The Control 
Officer’s designated representative shall acquire air quality forecasts and meteorological data 
in accordance with Section 403 of this rule. The Control Officer shall declare air pollution 
alerts, warnings, and emergencies in accordance with the following criteria: 
301.1 Air Pollution Alert: An air pollution alert shall be declared when any of the alert 
level concentrations listed in Table 600-1 are exceeded at any monitoring site and 
when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations for the same pollutant exceeding the alert level during 
the subsequent 24-hour period. 
301.2 Air Pollution Warning: An air pollution warning shall be declared when any of the 
warning level concentrations listed in Table 600-1 are exceeded at any monitoring 
site and when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations of the same pollutant exceeding the warning level 
during the subsequent 24-hour period. 
301.3 Air Pollution Emergency: An air pollution emergency shall be declared: 
a. When any of the emergency level concentrations listed in Table 600-1 are
exceeded at any monitoring site and when meteorological conditions indicate
that there will be a continuance or recurrence of concentrations of the same
pollutant exceeding the emergency level during the subsequent 24-hour period;
or
b. If air pollution concentrations have not decreased below the warning level
concentrations listed in Table 600-1 within 48-hours after the declaration of an
air pollution warning.
TABLE 600-1 
EPISODE LEVEL CRITERIA AND SIGNIFICANT HARM LEVELS 
EPISODE LEVEL CRITERIA 
Significant
Harm Level
Pollutant 
Averaging 
Time 
Alert 
Warning 
Emergency 
Sulfur Dioxide (ug/m3)
24-hr 
800 
1,600 
2,100 
2,620
Small Particulates (PM10) (ug/m3) 
24-hr 
350 
420 
500 
600 
Fine Particulates (PM2.5) (ug/m3) 
24-hr 
350 140.5
420 210.5 
500 280.5 
350.5 
Total Particulates (ug/m3) 
24-hr 
375 
625 
875 
Sulfur Dioxide and Particulates 
Combined (ug/m3) 
24-hr 
6.5x104 
26.1x104 
39.3x104 
Ozone (ug/m3)
1-hr 
400 
(0.2 ppm)
800 
(0.4 ppm) 
1,000 
(0.5 ppm) 
1,200 
(0.6 ppm) 
Nitrogen Dioxide (ug/m3)
1-hr 
1,130 
2,260 
3,000 
3,750
24-hr 
282 
565 
750 
938 
Carbon Monoxide (mg/m3) 
8-hr 
17 
34 
46 
57.5

EPISODE LEVEL CRITERIA 
Significant
Harm Level
Pollutant 
Averaging 
Time 
Alert 
Warning 
Emergency 
(15 ppm) (20 30 ppm)
(40 ppm) 
(50 ppm) 
4-hr 
86.3
(75 ppm) 
1-hr 
144
(125 ppm) 
302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN: When an air pollution 
alert, warning or emergency has been declared, one or more of the control actions as 
applicable to the source emitting the pollutant of concern shall be implemented in the 
affected area. 
302.1 Control Actions - Air Pollution Alert: When an air pollution alert has been 
declared, the following control actions, as applicable to the source(s) emitting the 
pollutant(s) of concern, shall be implemented as directed by the Control Officer: 
a. All permits to burn shall be suspended until further notice. The forest service
shall be notified to postpone slash burning in affected areas.
b. Incineration shall be limited to the hours of 12 noon to 4:00 p.m.
c. Those manufacturing facilities with prearranged emission reduction plans as
noted in the State Air Pollution Control Implementation Plan shall be notified to 
initiate alert stage control actions. Other sources Sources operating pursuant to 
an air pollution control permit shall be notified to minimize emissions of the 
pollutant of concern by curtailing or deferring operations not on a required 
schedule and by maximizing the collection efficiency of control equipment. 
Emissions from batch operations shall be limited to the hours of 12 noon to 4:00 
p.m. This control action shall not be applicable to any operations that are 
necessary to protect public health, public safety, or public welfare. 
d. The public shall be requested to voluntarily eliminate all unnecessary usage of
restrict motor vehicles vehicle use as much as possible.
302.2 Control Actions - Air Pollution Warning: When an air pollution warning has been 
declared, the following control actions, as applicable to the source(s) emitting the 
pollutant(s) of concern, shall be implemented as directed by the Control Officer: 
a. Burning of refuse, vegetation, trade wastes, and debris shall not be permitted by
any person.
b. Use of incinerators shall be prohibited.
c. Those manufacturing facilities with prearranged emission reduction plans as
noted in the Arizona Air Pollution Control Implementation Plan shall be notified 
to initiate warning stage control actions. Other sources Sources operating 
pursuant to an air pollution control permit shall be notified to initiate a 40 
percent or greater reduction in actual emissions by curtailment or cessation of 
operations. All processing industries shall be requested to effect a maximum 
reduction in heat load demands. This control action shall not be applicable to

any operations that are necessary to protect public health, public safety, or public 
welfare. 
d. If possible, power plant generating loads shall be transferred outside the affected
area. Power plant production shall be reduced by purchase of available energy 
from neighboring utilities. 
e. 
d. Highway construction and paving activities shall be halted, unless it is 
technologically infeasible to do so. All soil removal or grading operations at other 
construction sites shall be postponed. 
f.
Dust producing crop preparation and cultivation activities shall be postponed. A
maximum reduction in agricultural processing and handling operations shall be 
effected. 
g. 
e. The public shall be requested to voluntarily reduce motor vehicle usage by use of 
carpools and other means of transportation and elimination of unnecessary 
operation. Schools, businesses, industrial facilities, and government agencies shall 
be asked to limit activities as much as possible to reduce motor vehicle use. 
f.
As demand for electricity decreases, as a result of the cutbacks implemented in
accordance with subsections 302.2(a) through (e) of this rule, the MCAQD shall
contact the operators of power plants subject to Rule 322 to request emission
reductions to minimize air pollution.
302.3 Control Actions - Air Pollution Emergency: When an air pollution emergency has 
been declared, the following control actions shall be implemented: 
a. Those manufacturing facilities with prearranged emission reduction plans as
noted in the Arizona Air Pollution Control Implementation Plan shall be notified 
to initiate emergency stage control actions. Other manufacturing establishments 
Sources operating pursuant to an air pollution control permit shall cease 
operations as directed by the Governor., except those vital for public safety and 
welfare and enforcement of the emergency episode control actions. 
b. As directed by the Governor, all commercial, governmental, and institutional
establishments, except those vital for public safety and welfare and enforcement
of the emergency episode control actions, shall be closed.
c.
Generating loads at power plants shall be reduced further, resulting from
industrial and commercial cutbacks.  
d. 
c. All construction shall be halted as directed by the Governor except that which 
must proceed to avoid emergent physical harm. 
e. 
d. As directed by the Governor, use of motor vehicles shall be prohibited except in 
emergencies with approval of the local police. 
SECTION 400 – ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION: Once declared, any status reached by application of these 
criteria shall remain in effect until the criteria for that level are no longer met. At such time, 
the next lower status will be assumed.

402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY: When the conditions justifying the proclamation of an 
air pollution alert, warning, or emergency are determined to exist in any place in Maricopa 
County, the Control Officer shall be guided by the following criteria as established by state 
regulation R18-2-219 R18-2-220 (Air Pollution Emergency Episodes), and shall cooperate 
directly with the State Director, Arizona Department of Environmental Quality in all 
pertinent areas of control, communication, and surveillance. 
402.1 If the average wind speed for 24 hours is greater than 9.0 miles per hour, the criteria 
levels for particulates and sulfur dioxide and particulates combined shall not apply 
and no source control actions shall be taken. 
402.2 If, after an alert or warning episode level has been declared, and air pollution 
concentrations and meteorological conditions do not deteriorate further, or improve 
after 48 hours and control actions have been taken, the next higher episode shall be 
declared and its associated control actions implemented. 
403 
ACQUISITION OF FORECASTS: The Control Officer’s designated representative shall 
review air quality forecasts from ADEQ, weather forecasts and alerts from the National 
Weather Service (including atmospheric stagnation advisories, heat advisories, wind 
advisories, and high wind watches and warnings), and other reliable sources of 
meteorological data to determine if it is likely that the episode level criteria in Table 600-1 
will be exceeded. The Control Officer will also use air quality forecasts, weather alerts, other 
reliable sources of meteorological data, and monitoring data to determine if a continuance or 
recurrence of alert level, warning level, or emergency level pollutant concentrations is likely. 
404 
COMMUNICATION OF EMERGENCY EPISODES: When an air pollution alert, 
warning, or emergency is declared, the Control Officer’s designated representative will 
prepare a news release that describes the affected area, air pollutant concentrations, and 
meteorological conditions. The news release will also include control actions that will be 
implemented to reduce the concentration of pollutants in the ambient air and steps that 
individuals can take to reduce their exposure to pollutants in the ambient air. The news 
release will be distributed and/or announced using one or more of the following methods: 
404.1 Press releases to electronic and print media; 
404.2 Email and/or text messages; 
404.3 Social media; 
404.4 The Maricopa County Air Quality Department website; and 
404.5 The Clean Air Make More website and mobile application. 
SECTION 500 – MONITORING AND RECORDS (NOT INCLUDED) 
501 
RECORDKEEPING AND REPORTING: Any owner or operator subject to this rule 
shall comply with the requirements set forth in this section. Any records and data required 
by this section shall be kept on site at all times in a consistent and complete manner and be 
made available without delay to the Control Officer or designee upon request.

502 
RECORDS RETENTION: Copies of reports, logs, and supporting documentation 
required by the Control Officer shall be retained for at least 5 years. Records and 
information required by this rule shall also be retained for at least 5 years. 
503 
RECORDS OF CONTROL ACTION: An owner or operator shall maintain a log of the 
control actions taken during an Air Pollution Alert, Air Pollution Warning and Air Pollution 
Emergency.

MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI – EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
INDEX 
SECTION 100 – GENERAL 
101 
PURPOSE 
102 
EPISODE PROCEDURES GUIDELINES 
SECTION 200 – DEFINITIONS 
201 
EMERGENCY EPISODE PLAN 
202 
POLLUTANT OF CONCERN 
SECTION 300 – STANDARDS 
301 
EPISODE LEVEL CRITERIA 
302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN 
SECTION 400 – ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION 
402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY 
403 
ACQUISITION OF FORECASTS 
404 
COMMUNICATION OF EMERGENCY EPISODES 
SECTION 500 – MONITORING AND RECORDS 
501 
RECORDKEEPING AND REPORTING 
502 
RECORDS RETENTION 
503 
RECORDS OF CONTROL ACTION 
Return to list of attachments

Revised 07/13/1988; Revised 02/03/2016; Revised 12/08/2021 
MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI - EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
SECTION 100 – GENERAL 
101 
PURPOSE: To establish criteria used to determine when air pollutant concentrations are 
significantly elevated and to establish appropriate control actions to prevent the occurrence 
of ambient air pollutant concentrations which would cause significant harm to the health of 
persons. The advisories described in this rule are not the same as a Health Watch or High 
Pollution Advisory issued by the Arizona Department of Environmental Quality (ADEQ). A 
Health Watch or High Pollution Advisory is issued when air pollution levels are expected to 
approach or exceed the federal health based air quality standards. The federal health based 
air quality standards are lower than the thresholds for air pollution alerts, warnings, and 
emergencies described in this rule. 
102 
EPISODE PROCEDURES GUIDELINES: Guidelines for the procedures and 
communication steps to be followed during an air pollution episode are presented in this rule 
and in the Arizona Department of Environmental Quality’s “Procedures for Prevention of 
Emergency Episodes,” amended as of August 2018 (and no future edition). 
SECTION 200 – DEFINITIONS: For the purpose of this rule, the following definition shall 
apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of 
these rules. In the event of any inconsistency between any of the Maricopa County air pollution 
control rules, the definition in this rule takes precedence. 
201 
EMERGENCY EPISODE PLAN: A system designed to reduce the levels of air 
contaminants which may reach or have reached the level which may be harmful to health, 
and to protect that portion of the population at risk. 
202 
POLLUTANT OF CONCERN: If an air quality alert, warning, or emergency is declared 
for: 
202.1 Sulfur dioxide (SO2), the pollutants of concern shall be sulfur oxides; 
202.2 PM10, the pollutants of concern shall be PM10 and PM2.5; 
202.3 PM2.5, the pollutants of concern shall be PM2.5, ammonia, volatile organic 
compounds (VOC), nitrogen oxides (NOX), and SO2; 
202.4 Ozone, the pollutants of concern shall be NOX, VOC, and carbon monoxide (CO); 
202.5 Nitrogen dioxide (NO2), the pollutants of concern shall be NOX; and 
202.6 CO, the pollutant of concern shall be CO. 
SECTION 300 – STANDARDS

301 
EPISODE LEVEL CRITERIA: The Control Officer’s designated representative shall 
acquire air quality forecasts and meteorological data in accordance with Section 403 of this 
rule. The Control Officer shall declare air pollution alerts, warnings, and emergencies in 
accordance with the following criteria: 
301.1 Air Pollution Alert: An air pollution alert shall be declared when any of the alert 
level concentrations listed in Table 600-1 are exceeded at any monitoring site and 
when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations for the same pollutant exceeding the alert level during 
the subsequent 24-hour period. 
301.2 Air Pollution Warning: An air pollution warning shall be declared when any of the 
warning level concentrations listed in Table 600-1 are exceeded at any monitoring 
site and when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations of the same pollutant exceeding the warning level 
during the subsequent 24-hour period. 
301.3 Air Pollution Emergency: An air pollution emergency shall be declared: 
a. When any of the emergency level concentrations listed in Table 600-1 are
exceeded at any monitoring site and when meteorological conditions indicate
that there will be a continuance or recurrence of concentrations of the same
pollutant exceeding the emergency level during the subsequent 24-hour period;
or
b. If air pollution concentrations have not decreased below the warning level
concentrations listed in Table 600-1 within 48-hours after the declaration of an
air pollution warning.
TABLE 600-1 
EPISODE LEVEL CRITERIA AND SIGNIFICANT HARM LEVELS 
Significant
Harm 
Level 
Pollutant 
Averaging 
Time 
Alert 
Warning
Emergency 
Sulfur Dioxide (ug/m3) 
24-hr 
800 
1,600 
2,100 
2,620 
Small Particulates (PM10) (ug/m3) 
24-hr 
350 
420 
500 
600 
Fine Particulates (PM2.5) (ug/m3) 
24-hr 
140.5 
210.5 
280.5 
350.5 
Ozone (ug/m3) 
1-hr 
400 
(0.2 ppm)
800 
(0.4 ppm)
1,000 
(0.5 ppm) 
1,200 
(0.6 ppm) 
Nitrogen Dioxide (ug/m3) 
1-hr 
1,130 
2,260 
3,000 
3,750 
24-hr 
282 
565 
750 
938 
Carbon Monoxide (mg/m3) 
8-hr 
17 
(15 ppm)
34 
( 30 ppm)
46 
(40 ppm) 
57.5 
(50 ppm) 
4-hr
86.3
(75 ppm) 
1-hr
144
(125 ppm)

302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN: 
302.1 Air Pollution Alert: When an air pollution alert has been declared, the following 
control actions, as applicable to the source(s) emitting the pollutant(s) of concern, 
shall be implemented as directed by the Control Officer: 
a. All permits to burn shall be suspended until further notice. The forest service
shall be notified to postpone slash burning in affected areas.
b. Incineration shall be limited to the hours of 12 noon to 4:00 p.m.
c. Sources operating pursuant to an air pollution control permit shall be notified to
minimize emissions of the pollutant of concern by curtailing or deferring
operations not on a required schedule and by maximizing the collection
efficiency of control equipment. Emissions from batch operations shall be
limited to the hours of 12 noon to 4:00 p.m. This control action shall not be
applicable to any operations that are necessary to protect public health, public
safety, or public welfare.
d. The public shall be requested to voluntarily restrict motor vehicle use as much as
possible.
302.2 Air Pollution Warning: When an air pollution warning has been declared, the 
following control actions, as applicable to the source(s) emitting the pollutant(s) of 
concern, shall be implemented as directed by the Control Officer: 
a. Burning of vegetation, trade wastes, and debris shall not be permitted by any
person.
b. Use of incinerators shall be prohibited.
c. Sources operating pursuant to an air pollution control permit shall be notified to
initiate a 40 percent or greater reduction in actual emissions by curtailment or
cessation of operations. All processing industries shall be requested to effect a
maximum reduction in heat load demands. This control action shall not be
applicable to any operations that are necessary to protect public health, public
safety, or public welfare.
d. Highway construction and paving activities shall be halted, unless it is
technologically infeasible to do so. All soil removal or grading operations at other
construction sites shall be postponed.
e. Schools, businesses, industrial facilities, and government agencies shall be asked
to limit activities as much as possible to reduce motor vehicle use.
f.
As demand for electricity decreases, as a result of the cutbacks implemented in
accordance with subsections 302.2(a) through (e) of this rule, the MCAQD shall
contact the operators of power plants subject to Rule 322 to request emission
reductions.to minimize air pollution.
302.3 Air Pollution Emergency: When an air pollution emergency has been declared, the 
following control actions shall be implemented:

a. Sources operating pursuant to an air pollution control permit shall cease
operations as directed by the Governor, except those vital for public safety and
welfare and enforcement of the emergency episode control actions.
b. As directed by the Governor, all commercial, governmental, and institutional
establishments, except those vital for public safety and welfare and enforcement
of the emergency episode control actions, shall be closed.
c. All construction shall be halted as directed by the Governor except that which
must proceed to avoid emergent physical harm.
d. As directed by the Governor, use of motor vehicles shall be prohibited except in
emergencies with approval of the local police.
SECTION 400 - ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION: Once declared, any status reached by application of these 
criteria shall remain in effect until the criteria for that level are no longer met. At such time, 
the next lower status will be assumed. 
402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY: When the conditions justifying the proclamation of an 
air pollution alert, warning, or emergency are determined to exist in any place in Maricopa 
County, the Control Officer shall be guided by the criteria established by state regulation 
R18-2-220 (Air Pollution Emergency Episodes), and shall cooperate directly with the State 
Director, Arizona Department of Environmental Quality in all pertinent areas of control, 
communication, and surveillance. 
403 
ACQUISITION OF FORECASTS: The Control Officer’s designated representative shall 
review air quality forecasts from ADEQ, weather forecasts and alerts from the National 
Weather Service (including atmospheric stagnation advisories, heat advisories, wind 
advisories, and high wind watches and warnings), and other reliable sources of 
meteorological data to determine if it is likely that the episode level criteria in Table 600-1 
will be exceeded. The Control Officer will also use air quality forecasts, weather alerts, other 
reliable sources of meteorological data, and monitoring data to determine if a continuance or 
recurrence of alert level, warning level, or emergency level pollutant concentrations is likely. 
404 
COMMUNICATION OF EMERGENCY EPISODES: When an air pollution alert, 
warning, or emergency is declared, the Control Officer’s designated representative will 
prepare a news release that describes the affected area, air pollutant concentrations, and 
meteorological conditions. The news release will also include control actions that will be 
implemented to reduce the concentration of pollutants in the ambient air and steps that 
individuals can take to reduce their exposure to pollutants in the ambient air. The news 
release will be distributed and/or announced using one or more of the following methods: 
404.1 Press releases to electronic and print media; 
404.2 Email and/or text messages; 
404.3 Social media; 
404.4 The Maricopa County Air Quality Department website; and

404.5 The Clean Air Make More website and mobile application. 
SECTION 500 – MONITORING AND RECORDS 
501 
RECORDKEEPING AND REPORTING: Any owner or operator subject to this rule 
shall comply with the requirements set forth in this section. Any records and data required 
by this section shall be kept on site at all times in a consistent and complete manner and be 
made available without delay to the Control Officer or designee upon request. 
502 
RECORDS RETENTION: Copies of reports, logs, and supporting documentation 
required by the Control Officer shall be retained for at least 5 years. Records and 
information required by this rule shall also be retained for at least 5 years. 
503 
RECORDS OF CONTROL ACTION: An owner or operator shall maintain a log of the 
control actions taken during an Air Pollution Alert, Air Pollution Warning and Air Pollution 
Emergency.

Vice President Hughes called the meeting to order at 1:39 p.m. 
ROLL CALL: 
Members Present: 
Members Not Present: 
Don Cassano 
Bill Gates 
Henri Cournand 
Kristen Acton (via phone) 
Robert MacMillan 
Nedra Halley (via phone) 
Don Hughes  
Debra Baldauff 
Ex-Officio: Max Porter 
CALL TO THE PUBLIC: 
Vice President Hughes announced that we have speaker slips for anyone wishing to speak on any action items.  
Speakers will be called after the item is heard.  Each speaker will have 2 minutes to speak. 
DISCUSSION/ACTION ITEMS 
1.
Approval of Minutes:  Vice President Hughes asked for a motion to approve the minutes from the BOH Meeting
held on April 23, 2018. Motion was made by Mr. Cassano to approve the BOH minutes as presented.  Motion
was seconded by Mr. MacMillan and all were in favor. The motion passed unanimously.
2.
Election for Board of Health president/vice president
Mr. Don Hughes was nominated as President of the Board of Health.  A motion was made by Mr.
Don Cassano and seconded by Mr. Cournand and all were in favor. The motion passed unanimously.
Mr. Robert MacMillan was nominated as Vice President of the Board of Health.  A motion was made by Mr.
Don Cassano and seconded by Dr. Baldauff and all were in favor. The motion passed unanimously.
3.
Appointment for Finance Committee vacancies
Mr. Henri Cournand and Ms. Kristen Acton were appointed to the Finance Committee.
4.
Fee Waiver Applications 
 
 
 
 
 
 
 
Ms. Jeannie Taylor
Ms. Jeannie Taylor presented thirty-eight (38) fee waivers for review and consideration of approval.  A summary
sheet document was provided.
Motion to approve the thirty-eight (38) fee waiver applications was made by Mr. Cassano, seconded by Mr.
Cournand and all were in favor. The motion passed unanimously.
MARICOPA COUNTY BOARD OF HEALTH MEETING MINUTES 
Monday, July 23, 2018 at 3:00 pm 
205 W. Jefferson Street, Phoenix, Arizona  85003 
Board of Supervisors Auditorium 
Return to list of attchments

5.
Approval of initiation of regulatory change for Rule 352 (Gasoline Cargo Tank Testing and Use)
and the New Source Review (NSR) rules
Mr. Philip A. McNeely 
Gregory Verkamp 
AQ-2017-009-Rule 352 (Gasoline Cargo Tank Testing and Use): The Maricopa County Air Quality Department 
(MCAQD) is proposing to revise Rule 352 to address Environmental Protection Agency comments to ensure the 
revised rule meets Reasonably Available Control Technology (RACT) requirements as required by the Clean Air 
Act. 
AQ-2017-010-NSR (New Source Review): The MCAQD is revising the NSR rules in order to secure their approval as 
part of the State Implementation Plan (SIP) under the Federal Clean Air Act. 
Mr. Philip A. McNeely director of Air Quality introduced Gregory Verkamp, supervisor of the rules division of the 
department.   
Mr. Verkamp presented on item number 5.  He explained that this is air quality departments request for approval 
of the initiation of the regulatory change.  Rule 352 (Gasoline Cargo Tank testing and Use) rule and the New Source 
Review (NSR) rules.  Both rule makings have been before this board before and they’ve also been before the Board 
of Supervisors.  Both these rules have been submitted to the EPA for inclusion in the Arizona State implementation 
plan.  The EPA has reviewed the rules and they have some comments they would like us to address in the rules.  
We are here today requesting the initiation of the rule makings so we can address the EPA comments so they can 
be incorporated into the Arizona State implementation plan.  They have had stake holder workshops previous to 
this meeting today and they will have more in the future after this meeting, will have future stake holder 
workshops and then they’ll come back later after they’ve gone through stakeholder workshops.  This is just the 
first step requesting these rule makings today. 
 President Hughes asked we’re just responding to the comments from the EPA and are those are the only changes? 
Mr. Verkamp explain that yes they are responding to the EPA comments and there are some smaller changes from 
our internal department, rule improvements, but the major changes are EPA. The changes will be going before 
our stakeholders for review and comment and this just initiates the process. 
Vice President MacMillan asked if as far as the purpose of the rule making is it because of trying to address RACT 
for the EPA.  Mr. Verkamp explained that is correct, with RACT there’s the control technique guidelines that we 
use and the EPA uses to determine RACT.  They also look at the GAP rules and the NESHAP rules and the NSPS 
rules (New Source Performance Standard Rules) and then they also look at other air districts that have the same 
non-attainment status as ourselves.  The EPA will look at non-attainment, particularly in region nine, most of the 
California districts, they’ll look at those districts and see what their rules look like for districts that are in moderate 
non-attainment for ozone such as ours. 
Motion was made by Mr. MacMillan for approval of the initiation of regulatory change for Rule 352 (Gasoline 
Cargo Tank Testing and Use) and for approval of the New Source Review (NSR) rules.  Motion was seconded by 
Mr. Cournand and the motion passed unanimously. 
6.
Make recommendations to the Board of Supervisors on the proposed revisions to Rule 316 (Nonmetallic Mineral
Processing) and Rule 320 (Odors and Gaseous Air Contaminants)
Mr. Philip A. McNeely 
Gregory Verkamp 
AQ-2013-001-Rule 316 (Nonmetallic Mineral Processing): The MCAQD is proposing to revise Rule 316 to make the 
rule more clear for the regulated community by incorporating alternative control measures and information from 
department guidance documents and consolidating all applicable requirements for control of particulate matter 
emissions from nonmetallic mineral processing and related operations in a single rule.

Mr. Philip A. McNeely presented on Rule 316.  He explained that they put all the standards into one rule, 
streamlining the rule to make it easier to understand for better compliance. 
Mr. McNeely commented that he thinks we should take these rules, 316 and 320 separately.  They are two 
separate rules. 
President Hughes asked what Rule 316 deals with exactly?  Mr. McNeely replied sand and gravel, asphalt plants 
and concrete plants.  It’s a PM-10 Rule.  320 is an odor rule, hydrogen sulfide rule, stack height. 
Mr. Cassano clarified that they can make a motion on these rules separately.  
Rule 316 
There was 1 request for public comment received. 
-
1st speaker Linda Butler
Vice President MacMillan asked that you mentioned that 316 was not a loosening of the standard, it was just a 
consolidation of different rules, right?  Mr. McNeely replied yes, federal standards, 310 and 316 plus some safety 
issues.  Plus this is in the SIP so this will be approved by EPA, we’ll have to submit this to EPA for approval.   
Motion to approve recommendations to the Board of Supervisors on the proposed revisions to Rule 
316 (Nonmetallic Mineral Processing) was made by Mr. Cassano, seconded by Ms. Halley and all 
were in favor. Roll call vote was requested. 
Vice President MacMillan – AYE 
Mr. Cassano – AYE 
Ms. Halley – AYE 
Ms. Acton – AYE 
Mr. Cournand – AYE 
Dr. Baldauff – AYE 
President Hughes - AYE 
Motion passed unanimously. 
AQ-2016-004-Rule 320 (Odors and Gaseous Air Contaminants): The MCAQD is proposing to revise Rule 320 to 
update and enhance the rule and to clarify MCAQD’s authority so that it is consistent with the intent of the 
Maricopa County Air Pollution Control Regulations and the general air pollution prohibition standard in Rule 100. 
Mr. Philip A. McNeely presented on Rule 320.  
He explained that they had an oral proceeding at the request of the residents and stakeholders on April 4th and 
they’ve revised the rule and made some changes to it.  The rule was about 40 years old so the intent was to 
enhance it, to clarify the language and to bring it in line with intent of rule 100.  There’s nothing in this rule that 
prevents us from responding to odor complaints.  We have that authority completely in rule 100.  There’s nothing 
in this rule that’s going to change the way we do our procedures.  We’re trying to make it consistent with our 
other rules. 
Mr. McNeely reviewed the various changes and explained that with the changes they’ve tried to be responsive to 
the stakeholder concerns. 

Added definition of odor tied to regulated air pollutant back in.

Section 305 Titled Odors from Regulated Air Pollutants (Added the word Odor).

Returned stack height, how high you can put stacks.

Hydrogen sulfide standard.
174


Adding in for reduction animal matter.

Added a monitoring and record keeping section.
There were 18 request for public comment received. 
-
1st speaker Jackie Avilla (deferred time to Dan Blackson)
-
2nd speaker Dan Blackson
-
3rd speaker Sonia Lopez
-
4th speaker Billie Fidlin
-
5th speaker Paul Burton
-
6th speaker Sandy Larson
-
7th speaker Carolyn Burton
-
8th speaker Rhonda Mack
-
9th speaker Dan Mack
-
10th speaker Scott Manka
-
11th speaker Timothy Avilla
-
12th speaker Linda Butler
-
13th speaker Lorna Proper
-
14th speaker Steve Love
-
15th speaker Tom Martinez
-
16th speaker Leslie Saunders
-
17th speaker Brent Backus
-
18th speaker Linda Kinman
After all the discussion and all the public comments Mr. President stated that he’s concerned about a number of 
things that were discussed today.  The fact that you’ve made some major changes in the rule and the community 
doesn’t seem to have had the opportunity to review those rule to see if they address the concerns that they have.  
I’m bothered by a number of other things and at this point I would like to either deny or table this for further 
study.   
Mr. Cournand stated that he thinks there’s a lot of questions still within the community that need to be answered.  
He doesn’t think there’s a major driving need to try to force this through either way.  At this point I think further 
study and review make the most sense.   
Motion to table the initiation of the rulemaking for proposed revisions to Rule 320 was made by 
Mr. Cournand seconded by Dr. Baldauff.  Roll call vote was requested. 
Vice President MacMillan – AYE 
Mr. Cassano – AYE 
Ms. Halley – AYE 
Ms. Acton – AYE 
Mr. Cournand – AYE 
Dr. Baldauff – AYE 
President Hughes - AYE

Discussion Items: 
1.
Public Health Report
Max Porter and Dr. Rebecca Sunenshine 
i.
Human Resources
ii.
Communication
iii.
Infrastructure
iv.
Strategic Planning
v.
Programs
vi.
Disease Update
vii.
Future Topics
Max Porter stated that as far as the Director’s report we have several initiative, several grants that are new, but I 
think we can cover all of that in our next meeting.  There’s two issues that have a medical bearing that I’d like you 
to hear about from Dr. Sunenshine.  They have to do with us.  We are critically pushing our herd immunity with 
childhood immunization.  It’s something that you’ll hear about in the news, especially as we hit our back to 
school rush.    
Dr. Sunenshine presented on the following (Review attached handouts for details): 

Immunizations
o
Maricopa County immunization rates in Kindergarteners have dropped below the threshold for
herd immunity
o
We just got our numbers back from Arizona Department of Health Services from 2017.
From 2016 to 2017, the nonmedical immunization exemption rates have risen from five
point four percent to five point nine percent. The reason why that's important is because
94 to 95 percent of the population being immunized is that critical threshold for Herd
Immunity to measles.  Measles is the most contagious disease. While we worry about all
the vaccine preventable diseases, Measles is the one we use as a marker. And so right
now if we've got almost six percent of our population who are exempted from receiving
vaccines, we have now crossed the 95 percent threshold.  Combined with medical
exemptions, we are just below 94 percent. And this has shown a downward trend for the
last several years.
o
There are already six countries in Europe that have lost herd immunity to measles and these are
not developing countries.  Belgium, France, Germany, Italy, Poland, and Romania have already lost
herd immunity.  If we lose that threshold for herd immunity, it means that the measles will spread
rapidly through our population. Whereas when we're above that threshold, it exposes a couple of
people but then stops. So because we're at this critical point, we are going to work with Maricopa
County and try to do an educational campaign within Maricopa County employees and all the
different departments as well as with the public.
o
We're working closely with Arizona Department of Health Services who developed an educational
module, which is an evidence based intervention. Basically anyone who wants to exempt their
child from vaccines would be required to take a five minute educational course online for each
vaccine they want to exempt, and then obtain a certificate so that they could exempt their child.
And what this has been shown to do is make it less convenient to exempt your child. So it's equally
as challenging to go get an appointment at the doctor's office as it is to exempt their children from
vaccines. Whereas now all they have to do is take a form, sign it and fill it out. We have reason to
believe that some folks are actually being handed the form and think that it's their only option for
their children to continue to go to school.  We're working with schools to let them know, to give
parents some lead time that they need to go get their kids immunized and not tell them the day
before it's due. So we're trying to get at these convenience exemptions with this module. This
module was developed two years ago. We piloted it in Maricopa County at about 10 schools. It was
really successful. But they have not implemented it yet. They're doing another pilot this year and
our understanding is that there is some push back from certain folks in implementing the module
and we know it's effective, it worked in Michigan and in several other states, so we want you to be
176

aware of this. If you're hearing about pushback, please know that this module could be the 
difference between having these diseases spreading again in our community or not. 
Mr. President commented that losing herd immunity is pretty scary.  To have measles and some of 
these other diseases that really have not been a threat for since I was a kid or before and to have 
them come back is just pretty scary. 
Dr. Sunenshine commented that Max pointed out that Pima County already has a similar system in 
place and they have one of the highest rates of immunizations in the State and we are one of the 
lower. 
Max commented that one reason Dr. Sunenshine is bringing that to your intention is we're getting 
a little bit of pushback and it's not from the individual schools were also getting pushback from the 
Department of Education who doesn’t want to add another item for their schools to do. This is of 
vital importance and we need you to be aware of the situation as it develops.  
Mr. President commented would the Department of Education prefer schools dealing with a big 
outbreak of measles. 
Max replied No, they are worried about education and the piece and health aspect is not foremost 
on their plate.  We try to put it foremost on their plate.  That’s our job and that’s what we’re trying 
to do.  So as Dr. Sunenshine goes through these things, we’re doing our best to do that, but if 
we're not successful you need to understand that, that might be something that we will have to 
bring back before you in order to take action that will get them on board with us. But right now 
we're trying to work with them so they see the importance as you do. 
Mr. President stated Thank you, I don't want to belabor this, but I would simply point out for the 
record that a kid who has measles is not getting educated because he’s at home. 
Mr. Cournand asked just a quick question you mentioned, 95 percent is kind of the threshold for 
herd immunity. If you were to break apart that five percent, that's not getting the vaccine, could 
you either separate between, a tourist coming in from even developed countries that haven't been 
vaccinated, that can be an issue.  How much of it is really in the schools versus some of the other 
ways that I'm anti vaccinated folks can come in. Is it, if we get there, if we got the school situated, 
we're at 98. If we got the school situated, we're at 99 or if we got the school situated, it's at 96 and 
they're still 4 percent out there for tourists and what have you. 
Dr. Sunenshine replied if we're above that threshold of 95 percent, then if someone in a school is 
exposed, what we would do is we would remove everyone who is unvaccinated who is exempt 
from school so that they couldn't spread it and they would have to stay home for a minimum of 21 
days, but then it would not spread efficiently in the school. If we drop below that threshold of 94 
and 95 percent, then there's nothing we can do. It will just spread through the population 
regardless of who we keep on. We keep them home anyway, but it would spread efficiently.    
Mr. Cournand responded Thanks.  For what it's worth, the sooner that we can help you in any way 
please let us know. Not having Herd Immunity is a non-option, that can't happen. 
Dr. Sunenshine continued with her remaining items. 

STDs going up nationwide.  Specifically syphilis.

Maricopa County is the third highest rate of syphilis and gonorrhea in the entire nation. And one of the
tragic pieces of having one of the highest rates of syphilis is that we also have one of the highest rates of

congenital syphilis or babies born with syphilis or born deceased,  (still birth). The numbers went from 16 
babies with syphilis in 2016 and it nearly doubled in 2017 to 30.  Nineteen of those were in Maricopa 
County.  Of the 16 babies with congenital syphilis in 2018, 12 of them are in Maricopa County.  What are 
we doing about that? Jeanene Fowler can talk to you more about an ad campaign that was rolled out in 
the last couple of weeks.  We’ve already seen a near doubling of users on our STD site which is a good 
thing.  We still have some other things to do with Provider Education.  They are required to test pregnant 
women twice during pregnancy rather than the standard recommendation of just once because of our 
high congenital syphilis rates.  So we have some education to do with our healthcare providers.  

Those are the two things that we're working right now with the state. We also have some issues in our
tribal areas across the state and we need to be focused on a comprehensive approach.
Max stated we tried to keep it brief.  We’re very busy in public health, so we have a lot of things that we
could tell you. We, we're tired just like you so if you do have questions, we're not trying to avoid the
questions, so if you have anything you would like to know, we'll be glad to answer anything.
ANNOUNCEMENTS AND CURRENT EVENTS 

Next meeting is October 22, 2018
ADJOURNMENT: There being no further business, motion to adjourn the meeting was made by Ms. Halley, seconded 
by Mr. MacMillan and motion was passed unanimously. The meeting was adjourned at 3:56p.m. 
ADJOURNMENT: There being no further business, motion to adjourn the meeting was made by Ms. Halley, seconded 
by Mr. MacMillan and motion was passed unanimously. The meeting was adjourned at 5:23p.m.

Board of Health Meeting Minutes 
October 25, 2021
(Pending)

Subject:
FW: Rule 600 comments 
Attachments:
APS comments Rule 600.pdf
From: Michael.Denby@aps.com <Michael.Denby@aps.com>  
Sent: Wednesday, July 3, 2019 11:34 AM 
To: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Kristi Beck (AQD) <Kristi.Beck@Maricopa.gov> 
Subject: Rule 600 comments  
I wanted to let both of you know that APS has submitted comments on Rule 600.  I submitted them through the EROP 
system.  I am also attaching a copy here for your reference.  If you have any questions about our comments, please let 
me know. 
Thanks and I hope you have a fun July 4 weekend. 
Mike 
Michael Denby 
Corporate Environmental 
Arizona Public Service Co. 
400 N. 5th Street 
Phoenix, AZ 85004 
602‐250‐2870 (office) 
602‐571‐9384 (mobile) 
‐‐‐ NOTICE ‐‐‐ 
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Copies of all written and electronic Stakeholder input
Return to list of attachments

Michael Denby 
PO Box 53999 
Telephone: 602-250-2870 
Corporate Environmental 
Mail Station 9303 
e-mail: Michael.Denby@aps.com 
Phoenix, AZ 85072-3999 
July 3, 2019 
Electronically submitted 
Kristi Beck and Kimberly Butler 
Maricopa County Air Quality Department 
Planning and Analysis Division 
3800 N Central Avenue, Suite 1400 
Phoenix, AZ 85012 
Re: 
Arizona Public Service Company Comments on Maricopa County Proposed Rulemaking 
Regulation VI – Emergency Episodes,  Rule 600: Emergency Episodes 
Dear Ms. Beck and Ms. Butler: 
The Arizona Public Service Company (“APS”) appreciates the opportunity to submit 
comments on the Maricopa County Proposed Rulemaking Regulation VI – Emergency Episodes, 
Rule 600: Emergency Episodes (“Proposed Rule”). 
We understand the value and purpose of the rules and hope that our comments help the 
County craft an even better rule.   
It is important to note that we appreciate the reality that these rules may never be utilized 
because the exceedance thresholds are so high and our air quality is steadily improving.  
However, it would be remiss of us to ignore this language, in hopes it would never be triggered.  
Instead, we would like to help the County craft as useful and usable a rule as possible so that if 
an event is triggered all parties would know and understand the responsibilities and limitations.    
I. 
General Comments:

a.
The Notice of Proposed Rulemaking does not provide the reader with a clear date for
the close of public comment.  Usually in the preamble to the proposed rule, the County
will provide a date for the close of comment period.  Although the preamble in Section
3 sets a date for receipt of request for an oral proceeding, we were unable to find a date
for the close of comments.  Accordingly, we are submitting prior to July 5 just to make
certain our comments are timely.
b. Section 301.1 of the proposed rule reads as follows:
Section 301.1  “continuance or recurrence of alert level concentrations for the 
same pollutant during the subsequent 24-hour period.” 
Section 301.2  “continuance or recurrence of concentrations of the same 
pollutant exceeding the warning level during the subsequent 24-hour period.” 
Section 301.3 “continuance or recurrence of concentrations of the same 
pollutant exceeding the emergency level during the subsequent 24-hour 
period.” 
For consistency, it would be helpful if all three sections used similar language.  
Accordingly, we would suggest that Section 301.1 be rewritten to mirror the language in 
301.2 and 301.3.   
II.
Section 301
a.
Pursuant to Section 301, the triggers for an Episode Level (i.e. Alert, Warning or
Emergency) include an exceedance of the associated level coupled with
“meteorological conditions” indicating a continuance or recurrence during the
subsequent 24 hour period. (See, Section 301).   We were unable to find in the
rule any indication about what factors are used to determine the meteorological
conditions requirement and also what agency or group is responsible for this task.
Accordingly, since this is such an important part of the rule, it would be helpful
for the reader, and the regulated community, if the County included the factors
that go into making the meteorological conditions determination and also the
agency or group that is responsible for making this determination.
b. It appears that Section 301.3 creates two separate triggers for an Air Pollution
Emergency. First is the emergency based upon exceedance of the Emergency
threshold.  Second, is if the air quality associated with a Warning Level
exceedance does not improve within 48 hours.  If this is the case, it would be
helpful if the County added an “or” to the end of subsection (a) so that the reader
understands that those are two separate authorities and that they are not otherwise
conflicting.
Return to Comment #1
Return to Comment #2
Return to Comment #3
Return to Comment #4

Additionally, in Section 301.3(b) what does the County mean by “not improved?”  
Is it possible to have a monitor show signs of “improvement,” yet still be above 
the “Warning Level?”  Can a monitor show signs of improvements below the 
warning level, but still be close enough to the Warning Level to justify declaring 
the emergency?  Also, if meteorological conditions improve, but the 
concentrations at the affected monitors do not, or visa-versa, shall an emergency 
be declared?  In other words, must there be both an improvement in 
concentrations and meteorological conditions to avoid an emergency under 
Section 301.3(b)?  We would like to see the County clarify these issues so that the 
reader, and regulated community, has greater understanding and certainty about 
when an event may be triggered. 
III.
Declaration of the Warning, Alert, or Emergency.
Section 301 sets the standards under which an Alert, Warning, or Emergency “shall
be declared.”  However, the rule appears silent on who actually declares the Alert,
Warning or Emergency.  It would appear that the Control Officer, under Section 302,
directs the implementation of Control Actions. However, the rule is silent on who
actually declares the event or, for that matter, who directs its termination.
Accordingly, APS would like the County to provide language that helps to answer
these questions, so that should we encounter an Episode Level event, all parties are
aware of the authorities and responsibilities.
IV.
Section 302
a.
The County asserts that “The MCAQD is proposing to amend Rule 600
(Emergency Episodes) to align the rule with A.A.C. R18-2- 220 (Air Pollution
Emergency Episodes) which was amended by the Arizona Department of
Environmental Quality (ADEQ) in March of 2019.”  However, the ADEQ rules
do not set the emergency procedures in rule.  Therefore, it is unclear how the
County is “aligning the rule” with ADEQ, only to have a clear difference in
approach.   For example, the ADEQ rules do not provide any requirements for
source abatement or permit restrictions during an emergency episode.  The only
reference to agency action is set forth in the attached document entitled
“Procedures for the Prevention of Emergency Episodes.”  Even this document
provides only limited authority stating “the Director will request emission
reduction by applicable sources under State jurisdiction.”  The document goes on
to provide that “[t]he Director will contact local control agencies and health
departments in the affected area(s) to inform them of the situation and request
emission reduction by applicable sources under their jurisdiction.”  The County
approach does not include “request emission reduction,” but rather is more rigid
and sets forth as series of command and control requirements.   It is unclear how
the County goes from ADEQ’s general language to the specific requirements set
forth in Section 302.
Return to Comment #5 
Return to Comment #6

V. 
Section 302.1 
a.
Section 302.1 asserts that the rule is to protect “that portion of the population at
risk.”1  To this end the Alert, Warning and Emergency levels anticipate that any
exceedance at any monitoring site can trigger “control actions.”   Yet the Control
Actions set forth in Section 302 are not localized to a portion of the population at
risk or the exceedance of any monitoring site.  Instead, the Control Actions seem
to be without relation to a specific monitoring site or a portion of the population at
risk or even related to the pollutant at issue.
For example, Section 302.1(a) reads as follows:  “All permits to burn shall be 
suspended until further notice. The forest service shall be notified to postpone 
slash burning in affected areas.” This section seems a rather blunt response to the 
specific nature of the exceedance.  A burn permit could be issued for land far 
away from the affected monitor, yet be directly impacting that affect monitor.   In 
this case, would it be possible to still allow the burning since it was not “in the 
affected areas?”   
Additionally, Section 302.1(b) reads as follows:  “Incineration shall be limited to 
the hours of 12 noon to 4:00 p.m.” This is similar to our comments on Section 
302.1(a) above.  There is no requirement that the incinerator be located in the 
affected areas or impacting the affected areas just that it exists within Maricopa 
County.  Moreover, is there a reason for the limitation of 12 noon to 4:00 pm?  It 
would seem that these limited hours of operation would be based in science, but it 
would be helpful for the County to explain the reasoning behind the hour 
restrictions in its response to public comments. 
In the root of Section 302.1 and 302.2, the County has inserted the clause “as 
applicable to the source(s) emitting the pollutant(s) of concern” in an apparent 
attempt to provide some limitation on the County’s use of this section.   We 
appreciate the intent of using this limiting language.  Unfortunately, this limiting 
language is rather broad and undefined.  For example, “pollutants of concern” is 
undefined.  How does the County intend to address ozone exceedances when no 
source actually emits ozone?  Additionally, neither NOx nor VOCs are listed in 
Table 600-1, yet both are integral to ozone exceedances.  Furthermore, Section 
302.1(c) states that “Sources operating pursuant to an air pollution control permit 
shall be notified to minimize emissions.”  This section does not require the 
emissions to be the pollutant identified in Table 600-1 and exceeding the level.  
Finally, this section leaves open the question of, does the source need to be 
1 County Rule 600, Section 201 Emergency Response Plan. 
Return to Comment #7
Return to Comment #8
Return to Comment #9
Return to 
Comment 
#10

permitted for the NAAQS in question or just any pollutant?  We would like to see 
the County put in more specific language that clearly spells out when a permitted 
source will be required to take action.  Or, in the alternative, put in language 
allowing the Control Officer to work with affected source to find reasonable and 
workable reductions.  
VI.
Section 302.2(d)
Section 302.2(d) sets forth the requirements associated with power plants during an
Air Pollution Warning.  It states that “[i]f technologically feasible, power plant
generating loads shall be transferred outside the affected area. Power plant production
shall be reduced by purchase of available energy from neighboring utilities.”
We have several concerns with this wording.  First, utilities do not “generate load.”  
Utilities generate power which serves a load.  Second, it is unclear how a power plant 
can “transfer loads outside the affected area.”  As mentioned above, utilities do not 
generate load, so utilities are unable to transfer loads outside the affected area.  Third, 
the requirement that “power plant production shall be reduced by purchase of 
available energy from neighboring utilities” is confusing, counterproductive and 
likely beyond the County’s authority.  Although we understand the general idea that 
the County is seeking to employ here, there are some technical, financial and legal 
limitations that must be understood.  Our generation mix is varied in source, be it 
coal, gas, nuclear, solar, biomass or battery.  Additionally, our generation is located 
throughout the state of Arizona, not just within Maricopa County.  Accordingly, it 
may be possible for APS to utilize its own resources outside of the County to meet the 
needs of an Episode Level event, yet the rule appear to require us to purchase energy 
from a neighboring utility.  This seems counterproductive.  Additionally, electrical 
transmission is subject to the potential for constraint.  In other words, power lines can 
only carry so much power, which is often why generation is located close to what is 
called the “load pocket.”  Consequently, it may not be possible to reduce generation 
within a load pocket if the transmission lines are constrained.  Moreover, there are 
legal requirements on utilities that may conflict with the County’s assumed authority 
(See, comment VIII below). 
Finally, the use in Section 302.2(d) of the term “technologically feasible” in place of 
“possible” creates significant burdens for a regulated utility as transfer of power into 
and out of a load pocket is technologically feasible, but may not be operationally or 
legally possible or have other limitations.  Accordingly, we request that the County 
revert to the original language of “possible,” as that will give the utilities the 
opportunity to work with the County to find a solution, instead of being forced to do 
something that may have unintended consequences but is technologically feasible.  
Also, the County’s use of the term “power plant” is inconsistent with the air quality 
Return to Comment #11

rules.  There are, in fact, “power plants” that produce low or zero emissions, such as 
solar and nuclear power plants.  It would be helpful if the County defined power plant 
to include fossil fuel fired power generation so that the focus would be on the fossil 
fleet and not bring into question solar or nuclear operations. 
Furthermore, ADEQ’s Procedure states that “The general public will be urged to 
remain indoors whenever possible and avoid prolonged or strenuous exertion.”  The 
procedure of requiring that people shelter indoors is generally at odds with reducing 
power generation since it is likely that Episode Level exceedances would happen 
during hot, stagnant, summer days, which will be the time that the grid is under the 
most stress further limiting the ability of the utility to reduce generation or import 
power into the load pocket, even if technologically feasible.   
VII.
Section 302.3
Section 302.3(c) states, “As energy demand decreases, as a result of the control 
actions in Sections 302.3(a) and 302.3(b), power plants shall reduce operations so that 
generating loads do not exceed energy demand.”  Again, as mentioned before, power 
companies generate electricity to serve a load.  Power companies do not “generate 
load.”  Also, energy demand is a temporal issue.  In other words, the load or demand 
is continuously fluctuating requiring us to use various methods to ensure we have 
adequate power available as called upon to serve load, protect the integrity of the 
grid, and maintain reliability.  It would appear that the purpose of this section is to 
prevent a power plant from generating more power in the affected area than needed to 
serve load in the affected area.  The concept makes sense in times of a health 
emergency, but is not easily defined.  In order to comply with service and reliability 
requirements, utilities have certain limitations on their ability to limit generation.  
APS is happy to work with the County to better define the terms and conditions 
applicable for these Event Level Exceedances, but we are concerned that the current 
language is not workable. 
VIII.
Corporation Commission
It may be prudent for the County to ask the Arizona Corporation Commission
(“ACC”) for input on these rules.  If the Episode Level Criteria are exceeded and the
County enacts the Control Actions in 302.2, the County may be interfering with the
authorities given to the ACC under Article 15 of the Arizona Constitution.  Also, if
the Episode Level Criteria are exceeded during peak summer months, curtailing
energy production and transfer of the load may impact reliability as well as the health
and safety of customers.
Return to Comment #12
Return to Comment #13

APS is grateful for the opportunity to comment and add what we hope is constructive and 
useful input to the Proposed Rule.  If the County has questions or requires greater information 
related to our comments, please do not hesitate to contact us. 
Sincerely, 
Michael Denby 
Corporate Environmental  
Arizona Public Service Company

Subject:
FW: Rule 600 Stakeholder Comments Review
Attachments:
AQ-2017-010_Rule600-WorkingDraft SRP Comments 2021-06-02.docx
From: Watt Kristin L <Kristin.Watt@srpnet.com>  
Sent: Monday, June 14, 2021 12:48 PM 
To: Scott Kahldon (AQD) <Scott.Kahldon@maricopa.gov>; Marina.Estrella@aps.com 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: RE: Rule 600 Stakeholder Comments Review 
Hi Scott, 
Thank you again for providing SRP the opportunity to review Rule 600. Attached are some additional 
comments/feedback from SRP. I’m happy to discuss these in more detail if you’d prefer. 
Thanks 
Kristin 
Kristin Watt 
Manager, Air Quality Services 
SRP  |  Environmental Services  |  PAB359 
P.O. Box 52025, Phoenix, AZ 85072‐2025 
P: (602) 236‐5448  |  M: (602) 369‐2939 
Confidentiality Notice 
This message and any accompanying attachments may contain confidential and/or privileged information. The message 
and attachments should be read and retained by intended recipients only. If you received this message in error, please 
notify the sender immediately and delete the message and any attachments. 
From: Scott Kahldon (AQD) <Scott.Kahldon@maricopa.gov>  
Sent: Tuesday, May 25, 2021 2:44 PM 
To: Watt Kristin L <Kristin.Watt@srpnet.com>; Marina.Estrella@aps.com 
Cc: Kimberly Butler (AQD) <Kimberly.Butler@Maricopa.gov>; Gregory Verkamp (AQD) 
<Gregory.Verkamp@Maricopa.gov> 
Subject: Rule 600 Stakeholder Comments Review 
CAUTION ‐ EXTERNAL EMAIL 
Phishing? Click the fish in Outlook 
For mobile forward to phish@srpnet.com 
Good Afternoon Marina and Kristin, 
I’m working on Rule 600 and wanted to coordinate with both of you regarding the working draft and incorporated 
Stakeholder comments. The attached files contain the R600 working draft that includes EPA feedback and Stakeholder

comments along with the Stakeholder comments from Michael Denby. If your interested in reviewing any of the 
previous rulemaking documents pertaining to Rule 600, please visit the EROP Website and review the previous folder.  
When you have an opportunity, please review the draft rule and let me know if you have any additional 
comments/feedback. We are planning on posting the second Notice of Proposed Rulemaking in July, so please provide 
your comments/feedback by June 14th.  
If you have any additional questions, please let me know and we can schedule a meeting to further discuss. 
Thanks, 
Scott  
Scott Kahldon • Senior Planner 
Maricopa County Air Quality Department 
3800 N. Central Avenue, Suite 1400 | Phoenix, AZ 85012 
Desk: 602‐506‐6706 | Cell: 602‐695‐5728 | Scott.Kahldon@maricopa.gov 
Maricopa.gov/AQ | CleanAirMakeMore.com | Take Our Survey 
Help Reduce Ozone Pollution. Drive Less, Refuel After Dark, and Avoid Idling.

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI - EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
INDEX 
SECTION 100 - GENERAL 
101 
PURPOSE 
102 
EPISODE PROCEDURES GUIDELINES 
SECTION 200 – DEFINITIONS 
201 
EMERGENCY EPISODE PLAN 
202 
POLLUTANT OF CONCERN 
SECTION 300 - STANDARDS 
301 
EPISODE LEVEL CRITERIA 
302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN 
SECTION 400 - ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION 
402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY 
403 
ACQUISITION OF FORECASTS 
404 
COMMUNICATION OF EMERGENCY EPISODES 
SECTION 500 - MONITORING AND RECORDS (NOT INCLUDED) (NOT 
APPLICABLE)

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
Revised 07/13/1988; Revised 02/03/2016; Revised MM/DD/YYYY 
MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI - EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
SECTION 100 - GENERAL 
101 
PURPOSE: To establish criteria used to determine when air pollution emergency episodes 
pollutant concentrations are significantly elevated and the to establish appropriate control 
actions to prevent the occurrence of ambient air pollutant concentrations which would cause 
significant harm to the health of persons. This rule describes control and advisory 
procedures reached at each of the three episode levels. The advisories described in this rule 
are not the same as a Health Watch or High Pollution Advisory issued by the Arizona 
Department of Environmental Quality (ADEQ). A Health Watch or High Pollution 
Advisory is issued when air pollution levels are expected to approach or exceed the federal 
health based air quality standards. The federal health based air quality standards are lower 
than the thresholds for air pollution alerts, warnings, and emergencies described in this rule. 
102 
EPISODE PROCEDURES GUIDELINES: Guidelines for the procedures and 
communication steps to be followed during an air pollution episode are presented in this rule 
and in the Arizona Department of Environmental Quality’s “Procedures for Prevention of 
Emergency Episodes,” amended as of October 18, 1988 August 2018 (and no future 
edition). 
SECTION 200 - DEFINITIONS: For the purpose of this rule, the following definition shall 
apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of 
these rules. In the event of any inconsistency between any of the Maricopa County air pollution 
control rules, the definition in this rule takes precedence. 
201 
EMERGENCY EPISODE PLAN: A system designed to reduce the levels of air 
contaminants which may reach or have reached the level which may be harmful to health, 
and to protect that portion of the population at risk. 
202 
POLLUTANT OF CONCERN: If an air quality alert, warning, or emergency is declared 
for: 
202.1 Sulfur dioxide (SO2), the pollutants of concern shall be sulfur oxides; 
202.2 PM10, the pollutants of concern shall be PM10 and PM2.5; 
202.3 PM2.5, the pollutants of concern shall be PM2.5, ammonia, volatile organic 
compounds (VOC), nitrogen oxides (NOX), and SO2; 
202.4 Ozone, the pollutants of concern shall be NOX, VOC, and carbon monoxide (CO); 
Commented [WKL1]: Perhaps consider moving these to the 
definitions? It doesn’t seem to really fit well in this paragraph.
Commented [WKL2]: In Section 101 above, the purpose is 
described as establishing criteria used to determine when air 
pollutant concentrations are significantly elevated and to establish 
appropriate control actions to prevent the occurrence of ambient air 
pollutant concentrations that would cause significant harm to the 
health of persons and the words “pollution emergency episides” was 
struck, yet in this paragraph, the word “episodes” remains. Would it 
be more appropriate to change episodes to air pollutant 
concentrations are significantly elevated to align with the purpose of 
this rule?  
Commented [KB-A3]: Added definition based on Stakeholder 
Comment. 
Commented [WKL4]: Is CO a pollutant of concern for Ozone?
Return to Comments #14 and #15
Return to Comment #16

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
202.5 Nitrogen dioxide (NO2), the pollutants of concern shall be NOX; and 
202.6 CO, the pollutant of concern shall be CO. 
SECTION 300 - STANDARDS 
301 
EPISODE LEVEL CRITERIA: An air pollution alert, warning or emergency shall be 
declared when the following air pollutant concentrations are exceeded at any monitoring site 
and when meteorological conditions indicate that there will be a recurrence of those 
concentrations for the same pollutant(s) during the subsequent 24-hour period: The Control 
Officer’s designated representative shall acquire air quality forecasts and meteorological data 
in accordance with Section 403 of this rule. The Control Officer shall declare air pollution 
alerts, warnings, and emergencies in accordance with the following criteria: 
301.1 Air Pollution Alert: An air pollution alert shall be declared when any of the alert 
level concentrations listed in Table 600-1 are exceeded at any monitoring site and 
when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations for the same pollutant exceeding the alert level during 
the subsequent 24-hour period. 
301.2 Air Pollution Warning: An air pollution warning shall be declared when any of the 
warning level concentrations listed in Table 600-1 are exceeded at any monitoring 
site and when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations of the same pollutant exceeding the warning level 
during the subsequent 24-hour period. 
301.3 Air Pollution Emergency: An air pollution emergency shall be declared: 
a. When any of the emergency level concentrations listed in Table 600-1 are
exceeded at any monitoring site and when meteorological conditions indicate
that there will be a continuance or recurrence of concentrations of the same
pollutant exceeding the emergency level during the subsequent 24-hour period;
or
b. If air pollution concentrations have not decreased below the warning level
concentrations listed in Table 600-1 within 48-hours after the declaration of an
air pollution warning.
TABLE 600-1 
EPISODE LEVEL CRITERIA AND SIGNIFICANT HARM LEVELS 
EPISODE LEVEL CRITERIA 
Significant
Harm 
Level 
Pollutant 
Averaging 
Time 
Alert 
Warning
Emergency
Sulfur Dioxide (ug/m3)
24-hr 
800 
1,600 
2,100 
2,620
Small Particulates (PM10) (ug/m3) 
24-hr 
350 
420 
500 
600 
Fine Particulates (PM2.5) (ug/m3) 
24-hr 
350 140.5
420 210.5
500 280.5
350.5
Total Particulates (ug/m3) 
24-hr 
375
625
875
Commented [KB-A5]: Added based on stakeholder comment
Commented [KB-A6]: Reworded based on stakeholder 
comment. 
Commented [KB-A7]: Add “or” and revised based on 
stakeholder comment.

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
EPISODE LEVEL CRITERIA
Significant
Harm 
Level 
Pollutant 
Averaging 
Time 
Alert 
Warning
Emergency
Sulfur Dioxide and Particulates 
Combined (ug/m3) 
24-hr 
6.5x104 
26.1x104 
39.3x104 
Ozone (ug/m3)
1-hr 
400 
(0.2 ppm)
800 
(0.4 ppm)
1,000 
(0.5 ppm) 
1,200 
(0.6 ppm) 
Nitrogen Dioxide (ug/m3)
1-hr 
1,130
2,260
3,000
3,750
24-hr 
282
565
750
938
Carbon Monoxide (mg/m3) 
8-hr 
17 
(15 ppm) 
34
(20 30 
ppm) 
46
(40 ppm) 
57.5
(50 ppm) 
4-hr 
86.3
(75 ppm) 
1-hr 
144
(125 ppm) 
302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN: When an air pollution 
alert, warning or emergency has been declared, one or more of the control actions as 
applicable to the source emitting the pollutant of concern shall be implemented in the 
affected area. 
302.1 Control Actions - Air Pollution Alert: When an air pollution alert has been 
declared, the following control actions, as applicable to the source(s) emitting the 
pollutant(s) of concern, shall be implemented as directed by the Control Officer: 
a. All permits to burn shall be suspended until further notice. The forest service
shall be notified to postpone slash burning in affected areas.
b. Incineration shall be limited to the hours of 12 noon to 4:00 p.m.
c. Those manufacturing facilities with prearranged emission reduction plans as
noted in the State Air Pollution Control Implementation Plan shall be notified to 
initiate alert stage control actions. Other sources Sources operating pursuant to 
an air pollution control permit, excluding power plants subject to Rule 322 and 
emergency engines subject to Rule 324, shall be notified to minimize emissions 
of the pollutant of concern by curtailing or deferring operations not on a 
required schedule and by maximizing the collection efficiency of control 
equipment. Emissions from batch operations shall be limited to the hours of 12 
noon to 4:00 p.m. This control action shall not be applicable to any operations 
that are necessary to protect public health, public safety, or public welfare. 
d. The public shall be requested to voluntarily eliminate all unnecessary usage of
restrict motor vehicles vehicle use as much as possible.
302.2 Control Actions - Air Pollution Warning: When an air pollution warning has been 
declared, the following control actions, as applicable to the source(s) emitting the 
pollutant(s) of concern, shall be implemented as directed by the Control Officer:

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
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Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
a. Burning of refuse, vegetation, trade wastes, and debris shall not be permitted by
any person.
b. Use of incinerators shall be prohibited.
c. Those manufacturing facilities with prearranged emission reduction plans as
noted in the Arizona Air Pollution Control Implementation Plan shall be notified 
to initiate warning stage control actions. Other sources Sources operating 
pursuant to an air pollution control permit, excluding power plants subject to 
Rule 322 and emergency engines subject to Rule 324, shall be notified to initiate 
a 40 percent or greater reduction in emissions by curtailment or cessation of 
operations. All processing industries shall be requested to effect a maximum 
reduction in heat load demands. This control action shall not be applicable to 
any operations that are necessary to protect public health, public safety, or public 
welfare. 
d. If possible, power plant generating loads shall be transferred outside the affected
area. Power plant production shall be reduced by purchase of available energy 
from neighboring utilities. 
e. 
d. Highway construction and paving activities shall be halted, unless it is 
technologically infeasible to do so. All soil removal or grading operations at other 
construction sites shall be postponed. 
f.
Dust producing crop preparation and cultivation activities shall be postponed. A
maximum reduction in agricultural processing and handling operations shall be 
effected. 
g. 
e. The public shall be requested to voluntarily reduce motor vehicle usage by use of 
carpools and other means of transportation and elimination of unnecessary 
operation. Schools, businesses, industrial facilities, and government agencies shall 
be asked to limit activities as much as possible to reduce motor vehicle use. 
f. As demand for electricity decreases, as a result of the cutbacks implemented in 
accordance with subsections 302.2(a) through (e) of this rule, the MCAQD shall 
contact the operators of power plants subject to Rule 322 to request emission 
reductions. 
302.3 Control Actions - Air Pollution Emergency: When an air pollution emergency has 
been declared, the following control actions shall be implemented: 
a. Those manufacturing facilities with prearranged emission reduction plans as
noted in the Arizona Air Pollution Control Implementation Plan shall be notified 
to initiate emergency stage control actions. Other manufacturing establishments 
Sources operating pursuant to an air pollution control permit shall cease 
operations as directed by the Governor. 
b. As directed by the Governor, all commercial, governmental, and institutional
establishments, except those vital for public safety and welfare and enforcement
of the emergency episode control actions, shall be closed.
Commented [WKL8]: How do sources measure this? Is a 40% 
reduction from permitting limits, or from actual emissions?  
Commented [WKL9]: Recommend not removing this control 
measure. If it’s a PM10 episode, it would be helpful if this activity 
would be able to be postponed. 
Commented [WKL10]: This is a bit vague. How does MCAQD 
define “as demand for electricity decreases”? Who decides what 
reduced demand means? Is it when customer demand decreases? 
Also, this is dependent upon the pollutant of concern? Suggest 
taking this out entirely, or suggest language that says “shall reduce 
emissions as much as possible”…Or power plants subject to Rule 
322 will ensure implementation of best management practices ro 
minimize air pollution… 
Commented [WKL11]: This is a bit vague also, Can MCAQD 
clarify what a request for emissions reductions look like? See above 
comment. 
Commented [WKL12]: To me, this means if the Governor 
directs us, SRP shall stop operating it’s generating units.
Return to Comment #17
Return to Comment #18
Return to Comment #19
Return to Comment #20

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
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Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
c.
Generating loads at power plants shall be reduced further, resulting from
industrial and commercial cutbacks. 
d. 
c. All construction shall be halted as directed by the Governor except that which 
must proceed to avoid emergent physical harm. 
e. 
d. As directed by the Governor, use of motor vehicles shall be prohibited except in 
emergencies with approval of the local police. 
SECTION 400 - ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION: Once declared, any status reached by application of these 
criteria shall remain in effect until the criteria for that level are no longer met. At such time, 
the next lower status will be assumed. 
402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY: When the conditions justifying the proclamation of an 
air pollution alert, warning, or emergency are determined to exist in any place in Maricopa 
County, the Control Officer shall be guided by the following criteria as established by state 
regulation R18-2-219 R18-2-220 (Air Pollution Emergency Episodes), and shall cooperate 
directly with the State Director, Arizona Department of Environmental Quality in all 
pertinent areas of control, communication, and surveillance. 
402.1 If the average wind speed for 24 hours is greater than 9.0 miles per hour, the criteria 
levels for particulates and sulfur dioxide and particulates combined shall not apply 
and no source control actions shall be taken. 
402.2 If, after an alert or warning episode level has been declared, and air pollution 
concentrations and meteorological conditions do not deteriorate further, or improve 
after 48 hours and control actions have been taken, the next higher episode shall be 
declared and its associated control actions implemented. 
403 
ACQUISITION OF FORECASTS:  The Control Officer’s designated representative shall 
review air quality forecasts from ADEQ, weather alerts from the National Weather Service 
(including atmospheric stagnation advisories, heat advisories, wind advisories, and high wind 
watches and warnings), and other reliable sources of meteorological data to determine if it is 
likely that the episode level criteria in Table 600-1 will be exceeded. The Control Officer will 
also use air quality forecasts, weather alerts, other reliable sources of meteorological data, 
and monitoring data to determine if a continuance or recurrence of alert level, warning level, 
or emergency level pollutant concentrations is likely. 
404 
COMMUNICATION OF EMERGENCY EPISODES:  When an air pollution alert, 
warning, or emergency is declared, the Control Officer’s designated representative will 
prepare a news release that describes the affected area, pollutant concentrations, emissions, 
and meteorological conditions. The news release will also include control actions that will be 
implemented to reduce the concentration of pollutants in the ambient air and steps that 
individuals can take to reduce their exposure to pollutants in the ambient air. The news 
release will be distributed and/or announced using one or more of the following methods: 
404.1 Press releases to electronic and print media; 
Commented [WKL13]: Perhaps add the word forecasts from 
NWS? 
Commented [WKL14]: Whose emissions? Do you mean 
pollutant concentrations in the air?
Return to Comment #21
Return to Comment #22

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
404.2 Email and/or text messages; 
404.3 Social media; 
404.4 The Maricopa County Air Quality Department website; and 
404.5 The Clean Air Make More website and mobile application. 
SECTION 500 - MONITORING AND RECORDS (NOT INCLUDED) (NOT 
APPLICABLE)

Subject:
FW: Rule 600 Comments 
Attachments:
2020.06.Rule600.APS Comments.docx
From: Anne.Carlton@aps.com <Anne.Carlton@aps.com>  
Sent: Monday, June 14, 2021 4:24 PM 
To: Scott Kahldon (AQD) <Scott.Kahldon@maricopa.gov> 
Cc: James.D.Edwards@aps.com; Marina.Estrella@aps.com 
Subject: Rule 600 Comments  
Hello Scott,  
Thank you so much for the opportunity to provide feedback on Rule 600. Attached you will find our comments to the 
proposed language. Please feel free to reach out if you have any questions or would like to discuss in more detail.  
Thank you,  
Anne Carlton 
Manager, Environmental Support 
480‐322‐9313 Cell 
Arizona Public  Service 
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AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI - EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
INDEX 
SECTION 100 - GENERAL 
101 
PURPOSE 
102 
EPISODE PROCEDURES GUIDELINES 
SECTION 200 – DEFINITIONS 
201 
EMERGENCY EPISODE PLAN 
202 
POLLUTANT OF CONCERN 
SECTION 300 - STANDARDS 
301 
EPISODE LEVEL CRITERIA 
302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN 
SECTION 400 - ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION 
402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY 
403 
ACQUISITION OF FORECASTS 
404 
COMMUNICATION OF EMERGENCY EPISODES 
SECTION 500 - MONITORING AND RECORDS (NOT INCLUDED) (NOT 
APPLICABLE)

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
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Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
Revised 07/13/1988; Revised 02/03/2016; Revised MM/DD/YYYY 
MARICOPA COUNTY 
AIR POLLUTION CONTROL REGULATIONS 
REGULATION VI - EMERGENCY EPISODES 
RULE 600 
EMERGENCY EPISODES 
SECTION 100 - GENERAL 
101 
PURPOSE: To establish criteria used to determine when air pollution emergency episodes 
pollutant concentrations are significantly elevated (i.e. pollution emergency episodes) and the 
to establish appropriate control actions to prevent the occurrence of ambient air pollutant 
concentrations which would cause significant harm to the health of persons. This rule 
describes control and advisory procedures reached at each of the three episode levels. The 
advisories described in this rule are not the same as a Health Watch or High Pollution 
Advisory issued by the Arizona Department of Environmental Quality (ADEQ). A Health 
Watch or High Pollution Advisory is issued when air pollution levels are expected to 
approach or exceed the federal health based air quality standards. The federal health based 
air quality standards are lower than the thresholds for air pollution alerts, warnings, and 
emergencies described in this rule. 
102 
EPISODE PROCEDURES GUIDELINES: Guidelines for the procedures and 
communication steps to be followed during an air pollution episode are presented in this rule 
and in the Arizona Department of Environmental Quality’s “Procedures for Prevention of 
Emergency Episodes,” amended as of October 18, 1988 August 2018 (and no future 
edition). 
SECTION 200 - DEFINITIONS: For the purpose of this rule, the following definition shall 
apply, in addition to those definitions found in Rule 100 (General Provisions and Definitions) of 
these rules. In the event of any inconsistency between any of the Maricopa County air pollution 
control rules, the definition in this rule takes precedence. 
201 
EMERGENCY EPISODE PLAN: A system designed to reduce the levels of air 
contaminants which may reach or have reached the level which may be harmful to health, 
and to protect that portion of the population at risk. 
202 
POLLUTANT OF CONCERN: If an air quality alert, warning, or emergency is declared 
for: 
202.1 Sulfur dioxide (SO2), the pollutants of concern shall be sulfur oxides; 
202.2 PM10, the pollutants of concern shall be PM10 and PM2.5; 
202.3 PM2.5, the pollutants of concern shall be PM2.5, ammonia, volatile organic 
compounds (VOC), nitrogen oxides (NOX), and SO2; 
Commented [CAB1]: Since episode is used throughout the 
document, it may be helpful to add this term within the section 
Commented [KB-A2]: Added definition based on Stakeholder 
Comment. 
Return to Comment #23

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
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Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
202.4 Ozone, the pollutants of concern shall be NOX, VOC, and carbon monoxide (CO); 
202.5 Nitrogen dioxide (NO2), the pollutants of concern shall be NOX; and 
202.6 CO, the pollutant of concern shall be CO. 
SECTION 300 - STANDARDS 
301 
EPISODE LEVEL CRITERIA: An air pollution alert, warning or emergency shall be 
declared when the following air pollutant concentrations are exceeded at any monitoring site 
and when meteorological conditions indicate that there will be a recurrence of those 
concentrations for the same pollutant(s) during the subsequent 24-hour period: The Control 
Officer’s designated representative shall acquire air quality forecasts and meteorological data 
in accordance with Section 403 of this rule. The Control Officer shall declare air pollution 
alerts, warnings, and emergencies in accordance with the following criteria: 
301.1 Air Pollution Alert: An air pollution alert shall be declared when any of the alert 
level concentrations listed in Table 600-1 are exceeded at any monitoring site and 
when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations for the same pollutant exceeding the alert level during 
the subsequent 24-hour period. 
301.2 Air Pollution Warning: An air pollution warning shall be declared when any of the 
warning level concentrations listed in Table 600-1 are exceeded at any monitoring 
site and when meteorological conditions indicate that there will be a continuance or 
recurrence of concentrations of the same pollutant exceeding the warning level 
during the subsequent 24-hour period. 
301.3 Air Pollution Emergency: An air pollution emergency shall be declared: 
a. When any of the emergency level concentrations listed in Table 600-1 are
exceeded at any monitoring site and when meteorological conditions indicate
that there will be a continuance or recurrence of concentrations of the same
pollutant exceeding the emergency level during the subsequent 24-hour period;
or
b. If air pollution concentrations have not decreased below the warning level
concentrations listed in Table 600-1 within 48-hours after the declaration of an
air pollution warning.
TABLE 600-1 
EPISODE LEVEL CRITERIA AND SIGNIFICANT HARM LEVELS 
EPISODE LEVEL CRITERIA
Significant
Harm 
Level 
Pollutant 
Averaging 
Time 
Alert 
Warning
Emergency
Sulfur Dioxide (ug/m3)
24-hr 
800 
1,600 
2,100 
2,620
Small Particulates (PM10) (ug/m3) 
24-hr 
350 
420 
500 
600 
Commented [CAB3]: Why is CO listed here? 
Commented [KB-A4]: Added based on stakeholder comment
Commented [KB-A5]: Reworded based on stakeholder 
comment. 
Commented [KB-A6]: Add “or” and revised based on 
stakeholder comment. 
Return to Comment #24

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
EPISODE LEVEL CRITERIA
Significant
Harm 
Level 
Pollutant 
Averaging 
Time 
Alert 
Warning
Emergency
Fine Particulates (PM2.5) (ug/m3) 
24-hr 
350 140.5
420 210.5
500 280.5 
350.5 
Total Particulates (ug/m3) 
24-hr 
375 
625 
875 
Sulfur Dioxide and Particulates 
Combined (ug/m3) 
24-hr 
6.5x104 
26.1x104 
39.3x104 
Ozone (ug/m3)
1-hr 
400 
(0.2 ppm)
800 
(0.4 ppm)
1,000 
(0.5 ppm) 
1,200 
(0.6 ppm) 
Nitrogen Dioxide (ug/m3)
1-hr 
1,130
2,260
3,000
3,750
24-hr 
282
565
750
938
Carbon Monoxide (mg/m3) 
8-hr 
17 
(15 ppm) 
34
(20 30 
ppm) 
46
(40 ppm) 
57.5
(50 ppm) 
4-hr 
86.3
(75 ppm) 
1-hr 
144
(125 ppm) 
302 
CONTROL ACTIONS – EMERGENCY EPISODE PLAN: When an air pollution 
alert, warning or emergency has been declared, one or more of the control actions as 
applicable to the source emitting the pollutant of concern shall be implemented in the 
affected area. 
302.1 Control Actions - Air Pollution Alert: When an air pollution alert has been 
declared, the following control actions, as applicable to the source(s) emitting the 
pollutant(s) of concern, shall be implemented as directed by the Control Officer: 
a. All permits to burn shall be suspended until further notice. The forest service
shall be notified to postpone slash burning in affected areas.
b. Incineration shall be limited to the hours of 12 noon to 4:00 p.m.
c. Those manufacturing facilities with prearranged emission reduction plans as
noted in the State Air Pollution Control Implementation Plan shall be notified to 
initiate alert stage control actions. Other sources Sources operating pursuant to 
an air pollution control permit, excluding power plants subject to Rule 322 and 
emergency engines subject to Rule 324, shall be notified to minimize emissions 
of the pollutant of concern by curtailing or deferring operations not on a 
required schedule and by maximizing the collection efficiency of control 
equipment. Emissions from batch operations shall be limited to the hours of 12 
noon to 4:00 p.m. This control action shall not be applicable to any operations 
that are necessary to protect public health, public safety, or public welfare. 
d. The public shall be requested to voluntarily eliminate all unnecessary usage of
restrict motor vehicles vehicle use as much as possible.
Commented [CAB7]: Rather than listing 2 specific rules, 
consider using verbiage related to essential public service (see 
Southcoast Air Pollution Emergency Contingency Actions). There 
are other services that may need to operate to ensure public safety – 
One example are our microgrids – non-emergency engines that 
operate under Rule 324. As written, operation of these units would 
be limited even if they are deemed necessary to maintain grid 
stability.  
Clearly, the last sentence of this section capture this -
Return to Comment #25

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
302.2 Control Actions - Air Pollution Warning: When an air pollution warning has been 
declared, the following control actions, as applicable to the source(s) emitting the 
pollutant(s) of concern, shall be implemented as directed by the Control Officer: 
a. Burning of refuse, vegetation, trade wastes, and debris shall not be permitted by
any person.
b. Use of incinerators shall be prohibited.
c. Those manufacturing facilities with prearranged emission reduction plans as
noted in the Arizona Air Pollution Control Implementation Plan shall be notified 
to initiate warning stage control actions. Other sources Sources operating 
pursuant to an air pollution control permit, excluding power plants subject to 
Rule 322 and emergency engines subject to Rule 324, shall be notified to initiate 
a 40 percent or greater reduction in emissions by curtailment or cessation of 
operations. All processing industries shall be requested to effect a maximum 
reduction in heat load demands. This control action shall not be applicable to 
any operations that are necessary to protect public health, public safety, or public 
welfare. 
d. If possible, power plant generating loads shall be transferred outside the affected
area. Power plant production shall be reduced by purchase of available energy 
from neighboring utilities. 
e. 
d. Highway construction and paving activities shall be halted, unless it is 
technologically infeasible to do so. All soil removal or grading operations at other 
construction sites shall be postponed. 
f.
Dust producing crop preparation and cultivation activities shall be postponed. A
maximum reduction in agricultural processing and handling operations shall be 
effected. 
g. 
e. The public shall be requested to voluntarily reduce motor vehicle usage by use of 
carpools and other means of transportation and elimination of unnecessary 
operation. Schools, businesses, industrial facilities, and government agencies shall 
be asked to limit activities as much as possible to reduce motor vehicle use. 
f. As demand for electricity decreases, as a result of the cutbacks implemented in 
accordance with subsections 302.2(a) through (e) of this rule, the MCAQD shall 
contact the operators of power plants subject to Rule 322 to request emission 
reductions. 
302.3 Control Actions - Air Pollution Emergency: When an air pollution emergency has 
been declared, the following control actions shall be implemented: 
a. Those manufacturing facilities with prearranged emission reduction plans as
noted in the Arizona Air Pollution Control Implementation Plan shall be notified 
to initiate emergency stage control actions. Other manufacturing establishments 
Sources operating pursuant to an air pollution control permit shall cease 
operations as directed by the Governor. 
Commented [CAB8]: Same comment as above –  
If language related to Rule 322 is kept in Rule 600, it needs to be 
made clear units complying with Rule 322 by taking operational 
limits (<10% capacity factor). Again, I would say that the last 
sentence would suffice since electricity would be considered 
operation necessary to protect public safety 
Commented [CAB9]: This rule has not monitoring or 
recordkeeping requirements noted. Am I correct to interpret that 
facilities would not be required to maintain records related to their 
emission reductions?  
Commented [CAB10]: I think it is important to note that 
generation of electricity always follows demand – this occurs within 
minutes. It is also important to note, that decreased demands within 
Maricopa County, does not always equal decreased demand on the 
system. The grid is maintained at a much larger level than county 
based geography, so units within Maricopa County may be need to 
help support the western loop.  
I am not opposed to the language since it states the agency will 
request the emission reductions, but it is unnecessary.    
Commented [CAB11]: Include language related excluding 
operations necessary to maintain public safety. 
Return to Comment #27
Return to Comment #28
Return to Comment #29
Return to Comment #30

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
b. As directed by the Governor, all commercial, governmental, and institutional
establishments, except those vital for public safety and welfare and enforcement
of the emergency episode control actions, shall be closed.
c.
Generating loads at power plants shall be reduced further, resulting from
industrial and commercial cutbacks. 
d. 
c. All construction shall be halted as directed by the Governor except that which 
must proceed to avoid emergent physical harm. 
e. 
d. As directed by the Governor, use of motor vehicles shall be prohibited except in 
emergencies with approval of the local police. 
SECTION 400 - ADMINISTRATIVE REQUIREMENTS 
401 
EPISODE TERMINATION: Once declared, any status reached by application of these 
criteria shall remain in effect until the criteria for that level are no longer met. At such time, 
the next lower status will be assumed. 
402 
COORDINATION WITH THE STATE DEPARTMENT OF 
ENVIRONMENTAL QUALITY: When the conditions justifying the proclamation of an 
air pollution alert, warning, or emergency are determined to exist in any place in Maricopa 
County, the Control Officer shall be guided by the following criteria as established by state 
regulation R18-2-219 R18-2-220 (Air Pollution Emergency Episodes), and shall cooperate 
directly with the State Director, Arizona Department of Environmental Quality in all 
pertinent areas of control, communication, and surveillance. 
402.1 If the average wind speed for 24 hours is greater than 9.0 miles per hour, the criteria 
levels for particulates and sulfur dioxide and particulates combined shall not apply 
and no source control actions shall be taken. 
402.2 If, after an alert or warning episode level has been declared, and air pollution 
concentrations and meteorological conditions do not deteriorate further, or improve 
after 48 hours and control actions have been taken, the next higher episode shall be 
declared and its associated control actions implemented. 
403 
ACQUISITION OF FORECASTS:  The Control Officer’s designated representative shall 
review air quality forecasts from ADEQ, weather alerts from the National Weather Service 
(including atmospheric stagnation advisories, heat advisories, wind advisories, and high wind 
watches and warnings), and other reliable sources of meteorological data to determine if it is 
likely that the episode level criteria in Table 600-1 will be exceeded. The Control Officer will 
also use air quality forecasts, weather alerts, other reliable sources of meteorological data, 
and monitoring data to determine if a continuance or recurrence of alert level, warning level, 
or emergency level pollutant concentrations is likely. 
404 
COMMUNICATION OF EMERGENCY EPISODES:  When an air pollution alert, 
warning, or emergency is declared, the Control Officer’s designated representative will 
prepare a news release that describes the affected area, pollutant concentrations, emissions, 
and meteorological conditions. The news release will also include control actions that will be 
implemented to reduce the concentration of pollutants in the ambient air and steps that

AQ-2017-010-Rule 600 (Emergency Episodes) 
Draft Rule 600 for Discussion 
Submit Comments on EROP 
Maricopa County Air Quality Dept. 
Planning & Analysis Division 
3800 N. Central Ave. Ste. 1400 
Phoenix, AZ 85012 
individuals can take to reduce their exposure to pollutants in the ambient air. The news 
release will be distributed and/or announced using one or more of the following methods: 
404.1 Press releases to electronic and print media; 
404.2 Email and/or text messages; 
404.3 Social media; 
404.4 The Maricopa County Air Quality Department website; and 
404.5 The Clean Air Make More website and mobile application. 
SECTION 500 - MONITORING AND RECORDS (NOT INCLUDED) (NOT 
APPLICABLE)

From: Anne.Carlton@aps.com <Anne.Carlton@aps.com>  
Sent: Wednesday, June 16, 2021 2:16 PM 
To: Scott Kahldon (AQD) <Scott.Kahldon@maricopa.gov> 
Cc: James.D.Edwards@aps.com; Marina.Estrella@aps.com 
Subject: RE: Rule 600 Comments  
Scott,  
My apologies, we have one more thing for consideration!!! Palo Verde is a power plant that does not operate under Rule 
322! So, it strengthens our comment that the language related to Rule 322 and 324 should be removed and only keep 
“control action shall not be applicable to any operation that are necessary to protect public health, public safety, or 
public welfare.” 
Thank you,  
Anne  
From: Carlton, Anne B  
Sent: Monday, June 14, 2021 4:24 PM 
To: Scott.Kahldon@maricopa.gov 
Cc: Edwards, James D <James.D.Edwards@aps.com>; Estrella, Marina <Marina.Estrella@aps.com> 
Subject: Rule 600 Comments  
Hello Scott,  
Thank you so much for the opportunity to provide feedback on Rule 600. Attached you will find our comments to the 
proposed language. Please feel free to reach out if you have any questions or would like to discuss in more detail.  
Thank you,  
Anne Carlton 
Manager, Environmental Support 
480‐322‐9313 Cell 
Arizona Public  Service 
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Return to Comment #26