230178-CONTRACT_EASTERN RESEARCH GROUP INC. ERG.DOCX

CONTRACT AIR QUALITY SERVICES 230178-RFP
This contract is entered into this 6th day of DECEMBER, 2023 by and between Maricopa County 
(“County”), a political subdivision of the State of Arizona, and Eastern Research Group, Inc., a 
Massachusetts corporation (“Contractor”) for the purchase of professional technical assistance for a wide 
range of air quality management services.
1.0
CONTRACT TERM
1.1
This contract is for a term of one year, beginning on the 6th of DECEMBER, 2023 and 
ending the 30th of NOVEMBER, 2024.
2.0
OPTION TO RENEW
The County may, at its option and with the concurrence of the Contractor, renew the term of this 
contract up to a maximum of four additional years, (or at the County’s sole discretion, extend the 
contract on a month-to-month basis for a maximum of six months after expiration). The Contractor 
shall be notified in writing by the Office of Procurement Services of the County’s intention to renew 
the contract term at least 60 calendar days prior to the expiration of the original contract term.
3.0
CONTRACT COMPLETION
In preparation for contract completion, the Contractor shall make all reasonable efforts for an 
orderly transition of its duties and responsibilities to another provider and/or to the County. This 
may include, but is not limited to, preparation of a transition plan and cooperation with the County 
or other providers in the transition. The transition includes the transfer of all records and other data 
in the possession, custody, or control of the Contractor that are required to be provided to the 
County either by the terms of this agreement or as a matter of law. The provisions of this clause 
shall survive the expiration or termination of this agreement.
4.0
PRICE ADJUSTMENTS
Any requests for reasonable price adjustments must be submitted 60 calendar days prior to 
contract expiration. Requests for adjustment in cost of labor and/or materials must be supported 
by appropriate documentation. The reasonableness of the request will be determined by comparing 
the request with the Consumer Price Index or by performing a market survey. If County agrees to 
the adjusted price terms, County shall issue written approval of the change and provide an updated 
version of the contract. The new change shall not be in effect until the date stipulated on the 
updated version of the contract.
5.0
PAYMENTS
5.1
As consideration for performance of the duties described herein, County shall pay 
Contractor the sum(s) stated in Exhibit A-1 – Pricing.
5.2
Payment shall be made upon the County’s receipt of a properly completed invoice.
5.3
INVOICES

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5.3.1
The Contractor shall submit one legible copy of their detailed invoice before 
payment(s) will be made. Incomplete invoices will not be processed. At a minimum, 
the invoice must provide the following information:
•
Company name, address, and contact information
•
County bill-to name and contact information
•
Contract serial number
•
County purchase order number
•
Project name and/or number
•
Invoice number and date
•
Payment terms
•
Date of service or delivery
•
Quantity 
•
Contract item number(s)
•
Arrival and completion time
•
Description of purchase (product or services)
•
Pricing per unit of purchase
•
Extended price
•
Freight (if applicable)
•
Mileage with rate (if applicable)
•
Total amount due
5.3.2
Labor, services, and maintenance must be billed as a separate line item.
5.3.3
Problems regarding billing or invoicing shall be directed to the department as listed 
on the purchase order.
5.3.4
Payment shall only be made to the Contractor by Accounts Payable through the 
Maricopa County Vendor Express Payment Program. This is an electronic funds 
transfer (EFT) process. After contract award, the Contractor shall complete the 
Vendor Registration Form accessible from the County Department of Finance 
Vendor 
Registration 
Web 
Site 
https://www.maricopa.gov/5169/Vendor-
Information.
5.3.5
Discounts offered in the contract shall be calculated based on the date a properly 
completed invoice is received by the County. 
5.3.6
EFT payments to the routing and account numbers designated by the Contractor 
shall include the details on the specific invoices that the payment covers. The 
Contractor is required to discuss remittance delivery capabilities with their 
designated financial institution for access to those details.
5.4
APPLICABLE TAXES
5.4.1
It is the responsibility of the Contractor to determine any and all applicable taxes 
and include those taxes in their proposal. The legal liability to remit the tax is on 
the entity conducting business in Arizona. Tax is not a determining factor in 
contract award.
5.4.2
The County will look at the price or offer submitted and will not deduct, add, or alter 
pricing based on speculation or application of any taxes, nor will the County 
provide Contractor any advice or guidance regarding taxes. If you have questions 
regarding your tax liability, seek advice from a tax professional prior to submitting 
your bid. You may also find information at https://www.azdor.gov/Business.aspx. 
Once your bid is submitted, the offer is valid for the time specified in this solicitation, 
regardless of mistake or omission of tax liability. If the County finds overpayment 
of a project due to tax consideration that was not due, the Contractor will be liable 
to the County for that amount, and by contracting with the County agrees to remit

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any overpayments back to the County for miscalculations on taxes included in a 
bid price.
5.4.3
Tax Indemnification: Contractor and all subcontractors shall pay all Federal, State, 
and local taxes applicable to their operation and any persons employed by the 
Contractor. Contractor shall, and require all subcontractors to, hold Maricopa 
County harmless from any responsibility for taxes, damages, and interest, if 
applicable, contributions required under Federal and/or State and local laws and 
regulations, and any other costs including: transaction privilege taxes, 
unemployment 
compensation 
insurance, 
Social 
Security, 
and 
workers’ 
compensation. Contractor may be required to establish, to the satisfaction of 
County, that any and all fees and taxes due to the City or the State of Arizona for 
any license or transaction privilege taxes, use taxes, or similar excise taxes are 
currently paid (except for matters under legal protest).
6.0
AVAILABILITY OF FUNDS
6.1
The provisions of this contract relating to payment for services shall become effective when 
funds assigned for the purpose of compensating the Contractor as herein provided are 
actually available to County for disbursement. The County shall be the sole judge and 
authority in determining the availability of funds under this contract. County shall keep the 
Contractor fully informed as to the availability of funds.
6.2
If any action is taken by, any State agency, Federal department, or any other agency or 
instrumentality to suspend, decrease, or terminate its fiscal obligations under, or in 
connection with, this contract, County may amend, suspend, decrease, or terminate its 
obligations under, or in connection with, this contract. In the event of termination, County 
shall be liable for payment only for services rendered prior to the effective date of the 
termination, provided that such services are performed in accordance with the provisions 
of this contract. County shall give written notice of the effective date of any suspension, 
amendment, or termination under this section, at least 10 days in advance.
7.0
DUTIES
7.1
The Contractor shall perform all duties stated in Exhibit B – Scope of Work, or as otherwise 
directed in writing by the procurement officer.
8.0
TERMS AND CONDITIONS
8.1
INDEMNIFICATION
8.1.1
To the fullest extent permitted by law, and to the extent that claims, damages, 
losses, or expenses are not covered and paid by insurance purchased by the 
contractor, the contractor shall defend, indemnify, and hold harmless the County 
(as Owner), its agents, representatives, officers, directors, officials, and employees 
from and against all claims, damages, losses, and expenses (including, but not 
limited to attorneys' fees, court costs, expert witness fees, and the costs and 
attorneys' fees for appellate proceedings) arising out of, or alleged to have resulted 
from, the negligent acts, errors, omissions, or mistakes relating to the performance 
of this contract.
8.1.2
Contractor's duty to defend, indemnify, and hold harmless the County, its agents, 
representatives, officers, directors, officials, and employees shall arise in 
connection with any claim, damage, loss, or expense that is attributable to bodily 
injury, sickness, disease, death, or injury to, impairment of, or destruction of 
tangible property, including loss of use resulting therefrom, caused by negligent 
acts, errors, omissions, or mistakes in the performance of this contract, but only to 
the extent caused by the negligent acts or omissions of the contractor, a 
subcontractor, anyone directly or indirectly employed by them, or anyone for

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whose acts they may be liable, regardless of whether or not such claim, damage, 
loss, or expense is caused in part by a party indemnified hereunder.
8.1.3
The amount and type of insurance coverage requirements set forth herein will in 
no way be construed as limiting the scope of the indemnity in this section.
8.1.4
The scope of this indemnification does not extend to the sole negligence of County.
8.2
INSURANCE
8.2.1
Contractor, at Contractor’s own expense, shall purchase and maintain, at a 
minimum, the herein stipulated insurance from a company or companies duly 
licensed by the State of Arizona and possessing an AM Best, Inc. category rating 
of B++. In lieu of State of Arizona licensing, the stipulated insurance may be 
purchased from a company or companies, which are authorized to do business in 
the State of Arizona, provided that said insurance companies meet the approval of 
County. The form of any insurance policies and forms must be acceptable to 
County.
8.2.2
All insurance required herein shall be maintained in full force and effect until all 
work or service required to be performed under the terms of the contract is 
satisfactorily completed and formally accepted. Failure to do so may, at the sole 
discretion of County, constitute a material breach of this contract.
8.2.3
In the event that the insurance required is written on a claims-made basis, 
Contractor warrants that any retroactive date under the policy shall precede the 
effective date of this contract and either continuous coverage will be maintained, 
or an extended discovery period will be exercised for a period of two years 
beginning at the time work under this contract is completed.
8.2.4
Contractor’s insurance shall be primary insurance as respects County, and any 
insurance or self-insurance maintained by County shall not contribute to it.
8.2.5
Any failure to comply with the claim reporting provisions of the insurance policies 
or any breach of an insurance policy warranty shall not affect the County’s right to 
coverage afforded under the insurance policies.
8.2.6
The insurance policies may provide coverage that contains deductibles or self-
insured retentions. Such deductible and/or self-insured retentions shall not be 
applicable with respect to the coverage provided to County under such policies. 
Contractor shall be solely responsible for the deductible and/or self-insured 
retention and County, at its option, may require Contractor to secure payment of 
such deductibles or self-insured retentions by a surety bond or an irrevocable and 
unconditional letter of credit.
8.2.7
The insurance policies required by this contract, except Workers’ Compensation 
and Errors and Omissions, shall name County, its agents, representatives, officers, 
directors, officials, and employees as additional insureds.
8.2.8
The policies required hereunder, except Workers’ Compensation and Errors and 
Omissions, shall contain a waiver of transfer of rights of recovery (subrogation) 
against County, its agents, representatives, officers, directors, officials, and 
employees for any claims arising out of Contractor’s work or service.
8.2.9
If available, the insurance policies required by this contract may be combined with 
Commercial Umbrella Insurance policies to meet the minimum limit requirements. 
If a Commercial Umbrella insurance policy is utilized to meet insurance 
requirements, the Certificate of Insurance shall indicate which lines the 
Commercial Umbrella Insurance covers.

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8.2.9.1 Commercial General Liability
Commercial General Liability (CGL) insurance and, if necessary, 
Commercial Umbrella insurance with a limit of not less than $2,000,000 
for each occurrence, $4,000,000 Products/Completed Operations 
Aggregate, and $4,000,000 General Aggregate Limit. The policy shall 
include coverage for premises liability, bodily injury, broad form property 
damage, personal injury, products and completed operations and 
blanket contractual coverage, and shall not contain any provisions which 
would serve to limit third party action over claims. There shall be no 
endorsement or modifications of the CGL limiting the scope of coverage 
for liability arising from explosion, collapse, or underground property 
damage.
8.2.9.2 Errors and Omissions/Professional Liability Insurance
Errors and Omissions (Professional Liability) insurance which will insure 
and provide coverage for errors or omissions or professional liability of 
the contractor, with limits of no less than $2,000,000 for each claim.
8.2.9.3 Workers’ Compensation
8.2.9.3.1
Workers’ compensation insurance to cover obligations 
imposed by Federal and State statutes having jurisdiction of 
Contractor’s employees engaged in the performance of the 
work or services under this contract; and Employer’s Liability 
insurance of not less than $1,000,000 for each accident, 
$1,000,000 disease for each employee, and $1,000,000 
disease policy limit. 
8.2.9.3.2
Contractor, its subcontractors, and sub-subcontractors waive 
all rights against this contract and its agents, officers, 
directors, and employees for recovery of damages to the 
extent these damages are covered by the workers’ 
compensation and Employer’s Liability or Commercial 
Umbrella Liability insurance obtained by Contractor, its 
subcontractors, and its sub-subcontractors pursuant to this 
contract.
8.2.10
Certificates of Insurance
8.2.10.1
Prior to contract award, Contractor shall furnish the County with 
valid and complete Certificates of Insurance, or formal endorsements as 
required by the contract in the form provided by the County, issued by 
Contractor’s insurer(s), as evidence that policies providing the required 
coverage, conditions and limits required by this contract are in full force 
and effect. Such certificates shall identify this contract number and title.
8.2.10.2
In the event any insurance policy(ies) required by this contract is 
(are) written on a claims-made basis, coverage shall extend for two years 
past completion and acceptance of Contractor’s work or services and as 
evidenced by annual certificates of insurance.
8.2.10.3
If a policy does expire during the life of the Contract, a renewal 
certificate must be sent to County 15 calendar days prior to the expiration 
date.
8.2.11
Cancellation and Expiration Notice

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Applicable to all insurance policies required within the insurance requirements of 
this contract, Contractor’s insurance shall not be permitted to expire, be 
suspended, be canceled, or be materially changed for any reason without 30 days 
prior written notice to Maricopa County. Contractor must provide to Maricopa 
County, within two business days of receipt, if they receive notice of a policy that 
has been or will be suspended, canceled, materially changed for any reason, has 
expired, or will be expiring. Such notice shall be sent directly to Maricopa County 
Office of Procurement Services and shall be mailed, or hand delivered to 301 W. 
Jefferson St. Suite 700, Phoenix, AZ 85003, or emailed to the procurement officer 
noted in the solicitation.
8.3
FORCE MAJEURE
8.3.1
Neither party shall be liable for failure of performance, nor incur any liability to the 
other party on account of any loss or damage resulting from any delay or failure to 
perform all or any part of this contract, if such delay or failure is caused by events, 
occurrences, or causes beyond the reasonable control and without negligence of 
the parties. Such events, occurrences, or causes include, but are not limited to, 
acts of God/nature (including fire, flood, earthquake, storm, hurricane, or other 
natural disaster), war, invasion, act of foreign enemies, hostilities (whether war is 
declared or not), civil war, riots, rebellion, revolution, insurrection, military or 
usurped power or confiscation, terrorist activities, nationalization, government 
sanction, lockout, blockage, embargo, labor dispute, strike, and interruption or 
failure of electricity or telecommunication service, and pandemic.
8.3.2
Each party, as applicable, shall give the other party notice of its inability to perform 
and particulars in reasonable detail of the cause of the inability. Each party must 
use best efforts to remedy the situation and remove, as soon as practicable, the 
cause of its inability to perform or comply.
8.3.3
The party asserting Force Majeure as a cause for non-performance shall have the 
burden of proving that reasonable steps were taken to minimize delay or damages 
caused by foreseeable events, that all non-excused obligations were substantially 
fulfilled, and that the other party was timely notified of the likelihood or actual 
occurrence which would justify such an assertion, so that other prudent 
precautions could be contemplated.
8.4
ORDERING AUTHORITY
Any request for purchase shall be accompanied by a valid purchase order issued by a 
County department or directed by a Certified Agency Procurement Aid (CAPA) with a 
purchase card for payment.
8.5
PROCUREMENT CARD ORDERING CAPABILITY
County may opt to use a procurement card (Visa or Master Card) to make payment for 
orders under this contract.
8.6
NO MINIMUM OR MAXIMUM PURCHASE OBLIGATION
This contract does not guarantee any minimum or maximum purchases will be made. 
Orders will only be placed under this contract when the County identifies a need and proper 
authorization and documentation have been approved.
8.7
PURCHASE ORDERS
8.7.1
County reserves the right to cancel purchase orders within a reasonable period of 
time after issuance. Should a purchase order be canceled, the County agrees to

SERIAL# 230178-RFP
reimburse the Contractor for actual and documentable costs incurred by the 
Contractor in response to the purchase order. The County will not reimburse the 
Contractor for any costs incurred after receipt of County notice of cancellation, or 
for lost profits, or for shipment of product prior to issuance of purchase order.
8.7.2
Contractor agrees to accept verbal notification of cancellation of purchase orders 
from the County procurement officer with written notification to follow. Contractor 
specifically acknowledges to be bound by this cancellation policy.
8.8
BACKGROUND CHECK
Respondents may be required to pass multiple background checks (e.g., Sheriff’s Office, 
County Attorney's Office, Courts, as well as Maricopa County general government) to 
determine if the respondent is acceptable to do business with the County. This applies to, 
but is not limited to, the company, subcontractors, and employees, and the failure to pass 
these checks shall deem the respondent non-responsible.
8.9
SUSPENSION OF WORK
The procurement officer may order the Contractor, in writing, to suspend, delay, or interrupt 
all or any part of the work of this contract for the period of time that the procurement officer 
determines appropriate for the convenience of the County. No adjustment shall be made 
under this clause for any suspension, delay, or interruption to the extent that performance 
would have been so suspended, delayed, or interrupted by any other cause, including the 
fault or negligence of the Contractor. No request for adjustment under this clause shall be 
granted unless the claim, in an amount stated, is asserted in writing as soon as practicable 
after the termination of the suspension, delay, or interruption, but not later than the date of 
final payment under the contract.
8.10
STOP WORK ORDER
8.10.1
The procurement officer may, at any time, by written order to the Contractor, 
require the Contractor to stop all, or any part, of the work called for by this contract 
for a period of 90 calendar days after the order is delivered to the Contractor, and 
for any further period to which the parties may agree. The order shall be specifically 
identified as a stop work order issued under this clause. Upon receipt of the order, 
the Contractor shall immediately comply with its terms and take all reasonable 
steps to minimize the incurrence of costs allocable to the work covered by the order 
during the period of work stoppage. Within a period of 90 calendar days after a 
stop work order is delivered to the Contractor, or within any extension of that period 
to which the parties shall have agreed, the procurement officer shall either:
8.10.1.1
cancel the stop work order; or 
8.10.1.2
terminate the work covered by the order as provided in the 
Termination for Default or the Termination for Convenience clause of this 
contract.
8.10.1.3
The procurement officer may make an equitable adjustment in the 
delivery schedule and/or contract price, and the contract shall be modified, 
in writing, accordingly, if the Contractor demonstrates that the stop work 
order resulted in an increase in costs to the Contractor
8.11
TERMINATION FOR CONVENIENCE
Maricopa County may terminate the resultant contract for convenience by providing 60 
calendar days advance notice to the Contractor.
8.12
TERMINATION FOR DEFAULT

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8.12.1
The County may, by written Notice of Default to the Contractor, terminate this 
contract in whole or in part if the Contractor fails to:
8.12.1.1
deliver the supplies or to perform the services within the time 
specified in this contract or any extension; 
8.12.1.2
make progress, so as to endanger performance of this contract; 
or
8.12.1.3
perform any of the other provisions of this contract.
8.12.2
The County’s right to terminate this contract under these subparagraphs may be 
exercised if the Contractor does not cure such failure within 10 business days (or 
more if authorized in writing by the County) after receipt of a Notice to Cure from 
the procurement officer specifying the failure.
8.13
PERFORMANCE
It shall be the Contractor’s responsibility to meet the proposed performance requirements. 
Maricopa County reserves the right to obtain services on the open market in the event the 
Contractor fails to perform, and any price differential will be charged against the Contractor.
8.14
CONTRACTOR EMPLOYEE MANAGEMENT
8.14.1
Contractor shall endeavor to maintain the personnel proposed in their proposal 
throughout the performance of this contract.
8.14.2
If Contractor personnel’s employment status changes, Contractor shall provide 
County a list of proposed replacements with equivalent or greater experience.
8.14.3
Under no circumstances shall the implementation schedule to be impacted by a 
personnel change on the part of the Contractor.
8.14.4
Contractor shall not reassign any key personnel identified in their proposal without 
the express consent of the County.
8.14.5
County reserves the right to immediately remove from its premises any Contractor 
personnel it determines to be a risk to County operations.
8.14.6
County reserves the right to request the replacement of any Contractor personnel 
at any time, for any reason.
8.15
INSPECTION OF SERVICES
8.15.1
The Contractor shall provide and maintain an inspection system acceptable to 
County covering the services under this contract. Complete records of all 
inspection work performed by the Contractor shall be maintained and made 
available to County during contract performance and for as long afterwards as the 
contract requires.
8.15.2
County has the right to inspect and test all services called for by the contract, to 
the extent practicable at all times and places during the term of the contract. 
County shall perform inspections and tests in a manner that will not unduly delay 
the work.
8.15.3
If any of the services do not conform to contract requirements, County may require 
the Contractor to perform the services again in conformity with contract

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requirements, at no cost to the County. When the defects in services cannot be 
corrected by re-performance, County may:
8.15.3.1
require the Contractor to take necessary action to ensure that 
future performance conforms to contract requirements; and
8.15.3.2
reduce the contract price to reflect the reduced value of the 
services performed.
8.15.4
If the Contractor fails to promptly perform the services again or to take the 
necessary action to ensure future performance in conformity with contract 
requirements, County may:
8.15.4.1
by contract or otherwise, perform the services and charge to the 
Contractor, through direct billing or through payment reduction, any cost 
incurred by County that is directly related to the performance of such 
service; or
8.15.4.2
terminate the contract for default.
8.16
USAGE REPORT
The Contractor shall furnish the County a usage report, upon request, delineating the 
acquisition activity governed by the contract. The format of the report shall be approved by 
the County and shall disclose the quantity and dollar value of each contract item by 
individual unit of measure.
8.17
STATUTORY RIGHT OF CANCELLATION FOR CONFLICT OF INTEREST
Notice is given that, pursuant to A.R.S. § 38-511, the County may cancel any contract 
without penalty or further obligation within three years after execution of the contract, if any 
person significantly involved in initiating, negotiating, securing, drafting, or creating the 
contract on behalf of the County is at any time, while the contract or any extension of the 
contract is in effect, an employee or agent of any other party to the contract in any capacity 
or consultant to any other party of the contract with respect to the subject matter of the 
contract. Additionally, pursuant to A.R.S. § 38-511, the County may recoup any fee or 
commission paid or due to any person significantly involved in initiating, negotiating, 
securing, drafting, or creating the contract on behalf of the County from any other party to 
the contract arising as the result of the contract.
8.18
OFFSET FOR DAMAGES
In addition to all other remedies at Law or Equity, the County may offset from any money 
due to the Contractor any amounts Contractor owes to the County for damages resulting 
from breach or deficiencies in performance of the contract.
8.19
SUBCONTRACTING
8.19.1
The Contractor may not assign to another Contractor or subcontract to another 
party for performance of the terms and conditions hereof without the written 
consent of the County. All correspondence authorizing subcontracting must 
reference the bid serial number and identify the job or project.
8.19.2
The subcontractor’s rate for the job shall not exceed that of the prime Contractor’s 
rate, as bid in the pricing section, unless the prime Contractor is willing to absorb 
any higher rates. The subcontractor’s invoice shall be invoiced directly to the prime 
Contractor, who in turn shall pass-through the costs to the County, without mark-
up. A copy of the subcontractor’s invoice must accompany the prime Contractor’s 
invoice.

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8.20
AMENDMENTS
All amendments to this contract shall be in writing and approved/signed by both parties. 
Maricopa County Office of Procurement Services shall be responsible for approving all 
amendments for Maricopa County.
8.21
ADDITIONS/DELETIONS OF REQUIREMENTS
The County reserves the right to add and/or delete materials and services to a contract. If 
a service requirement is deleted, payment to the Contractor will be reduced proportionately 
to the amount of service reduced in accordance with the bid price. If additional materials 
or services are required from a contract, prices for such additions will be negotiated 
between the Contractor and the County.
8.22
RIGHTS IN DATA
8.22.1
The County shall have the use of data and reports resulting from a contract without 
additional cost or other restriction except as may be established by law or 
applicable regulation. Each party shall supply to the other party, upon request, any 
available information that is relevant to a contract and to the performance 
thereunder.
8.22.2
Data, records, reports, and all other information generated for the County by a third 
party as the result of a contract are the property of the County and shall be provided 
in a format designated by the County or shall be and remain accessible to the 
County into perpetuity.
8.23
ACCESS TO AND RETENTION OF RECORDS FOR THE PURPOSE OF AUDIT AND/OR 
OTHER REVIEW
8.23.1
In accordance with Section MC1-372 of the Maricopa County Procurement Code, 
the Contractor agrees to retain (physical or digital copies of) all books, records, 
accounts, statements, reports, files, and other records and back-up documentation 
relevant to this contract for six years after final payment or until after the resolution 
of any audit questions, which could be more than six years, whichever is longest. 
The County, Federal or State auditors and any other persons duly authorized by 
the department shall have full access to and the right to examine, copy, and make 
use of, any and all said materials.
8.23.2
If the Contractor’s books, records, accounts, statements, reports, files, and other 
records and back-up documentation relevant to this contract are not sufficient to 
support and document that requested services were provided, the Contractor shall 
reimburse Maricopa County for the services not so adequately supported and 
documented.
8.24
AUDIT DISALLOWANCES
If at any time it is determined by the County that a cost for which payment has been made 
is a disallowed cost, the County shall notify the Contractor in writing of the disallowance. 
The course of action to address the disallowance shall be at sole discretion of the County, 
and may include either an adjustment to future invoices, request for credit, request for a 
check, or a deduction from current invoices submitted by the Contractor equal to the 
amount of the disallowance, or to require reimbursement forthwith of the disallowed amount 
by the Contractor by issuing a check payable to Maricopa County.
8.25
STRICT COMPLIANCE

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Acceptance by County of a performance that is not in strict compliance with the terms of 
the contract shall not be deemed to be a waiver of strict compliance with respect to all other 
terms of the contract.
8.26
VALIDITY
The invalidity, in whole or in part, of any provision of this contract shall not void or affect 
the validity of any other provision of the contract.
8.27
SEVERABILITY
The removal, in whole or in part, of any provision of this contract shall not void or affect the 
validity of any other provision of this contract.
8.28
RELATIONSHIPS
8.28.1
In the performance of the services described herein, the Contractor shall act solely 
as an independent Contractor, and nothing herein or implied herein shall at any 
time be construed as to create the relationship of employer and employee, co-
employee, partnership, principal and agent, or joint venture between the County 
and the Contractor.
8.28.2
The County reserves the right of final approval on proposed staff. Also, upon 
request by the County, the Contractor will be required to remove any employees 
working on County projects and substitute personnel based on the discretion of 
the County within two business days, unless previously approved by the County.
8.29
NON-DISCRIMINATION
Contractor agrees to comply with all provisions and requirements of Arizona Executive 
Order 2009-09, including flow down of all provisions and requirements to any 
subcontractors. Executive Order 2009-09 supersedes Executive Order 99-4 and amends 
Executive Order 75-5 and is hereby incorporated into this contract as if set forth in full 
herein. During the performance of this contract, Contractor shall not discriminate against 
any employee, client, or any other individual in any way because of that person’s age, race, 
creed, color, religion, sex, disability, or national origin. (Arizona Executive Order 2009-09 
can be viewed at https://apps.azsos.gov/public_services/register/2009/46/governor.pdf).
8.30
WRITTEN CERTIFICATION PURSUANT to A.R.S. § 35-393.01
If vendor engages in for-profit activity and has 10 or more employees, and if this agreement 
has a value of $100,000 or more, vendor certifies it is not currently engaged in, and agrees 
for the duration of this agreement to not engage in, a boycott of goods or services from 
Israel. This certification does not apply to a boycott prohibited by 50 U.S.C. § 4842 or a 
regulation issued pursuant to 50 U.S.C. § 4842.
8.31
CERTIFICATION REGARDING DEBARMENT AND SUSPENSION
8.31.1
The undersigned (authorized official signing on behalf of the Contractor) certifies 
to the best of his or her knowledge and belief that the Contractor, its current 
officers, and directors:
8.31.1.1
are not presently debarred, suspended, proposed for debarment, 
declared ineligible, or voluntarily excluded from being awarded any 
contract or grant by any United States department or agency or any state, 
or local jurisdiction;
8.31.1.2
have not within a three-year period preceding this contract:

SERIAL# 230178-RFP
8.31.1.2.1
been convicted of fraud or any criminal offense in 
connection with obtaining, attempting to obtain, or as the 
result of performing a government entity (Federal, State or 
local) transaction or contract; or
8.31.1.2.2
been convicted of violation of any Federal or State antitrust 
statutes or conviction for embezzlement, theft, forgery, 
bribery, falsification or destruction of records, making false 
statements, or receiving stolen property regarding a 
government entity transaction or contract;
8.31.1.3
are not presently indicted or criminally charged by a government 
entity (Federal, State or local) with commission of any criminal offenses in 
connection with obtaining, attempting to obtain, or as the result of 
performing a government entity public (Federal, State or local) transaction 
or contract;
8.31.1.4
are not presently facing any civil charges from any governmental 
entity regarding obtaining, attempting to obtain, or from performing any 
governmental entity contract or other transaction; and 
8.31.1.5
have not within a three-year period preceding this contract had 
any public transaction (Federal, State or local) terminated for cause or 
default.
8.31.2
If any of the above circumstances described in the paragraph are applicable to the 
entity submitting a bid for this requirement, include with your bid an explanation of 
the matter including any final resolution.
8.31.3
The Contractor shall include, without modification, this clause in all lower tier 
covered transactions (i.e., transactions with subcontractors or sub-subcontractors) 
and in all solicitations for lower tier covered transactions related to this contract. If 
this clause is applicable to a subcontractor or sub-subcontractor, the Contractor 
shall include the information required by this clause with their bid.
8.32
VERIFICATION REGARDING COMPLIANCE WITH A.R.S. § 41-4401 AND FEDERAL 
IMMIGRATION LAWS AND REGULATIONS
8.32.1
By entering into the contract, the Contractor warrants compliance with the 
Immigration and Nationality Act (INA using E-Verify) and all other Federal 
immigration laws and regulations related to the immigration status of its employees 
and A.R.S. § 23-214(A). The Contractor shall obtain statements from its 
subcontractors certifying compliance and shall furnish the statements to the 
procurement officer upon request. These warranties shall remain in effect through 
the term of the contract. The Contractor and its subcontractors shall also maintain 
Employment Eligibility Verification forms (I-9) as required by the Immigration Reform 
and Control Act of 1986, as amended from time to time, for all employees performing 
work under the contract and verify employee compliance using the E-Verify system 
and shall keep a record of the verification for the duration of the employee’s 
employment or at least three years, whichever is longer. I-9 forms are available for 
download at www.uscis.gov.
8.32.2
The County retains the legal right to inspect documents of Contractor and 
subcontractor employees performing work under this contract to verify compliance 
with paragraph 10.32.1 of this section. Contractor and subcontractor shall be given 
reasonable notice of the County’s intent to inspect and shall make the documents 
available at the time and date specified. Should the County suspect or find that the 
Contractor or any of its subcontractors are not in compliance, the County will 
consider this a material breach of the contract and may pursue any and all remedies

SERIAL# 230178-RFP
allowed by law, including, but not limited to: suspension of work, termination of the 
contract for default, and suspension and/or debarment of the Contractor. All costs 
necessary to verify compliance are the responsibility of the Contractor.
8.33
CONTRACTOR LICENSE REQUIREMENT
8.33.1
The Contractor shall procure all permits, insurance, and licenses, and pay the 
charges and fees necessary and incidental to the lawful conduct of his/her 
business, and as necessary complete any requirements, by any and all 
governmental or non-governmental entities as mandated to maintain compliance 
with and remain in good standing. The Contractor shall keep fully informed of 
existing and future trade or industry requirements, and Federal, State, and local 
laws, ordinances, and regulations which in any manner affect the fulfillment of a 
contract and shall comply with the same. Contractor shall immediately notify both 
Office of Procurement Services and the department of any and all changes 
concerning permits, insurance, or licenses.
8.34
INFLUENCE
8.34.1
As prescribed in MC1-1203 of the Maricopa County Procurement Code, any effort 
to influence an employee or agent to breach the Maricopa County Ethical Code of 
Conduct or any ethical conduct, may be grounds for disbarment or suspension 
under MC1-902.
8.34.2
An attempt to influence includes, but is not limited to:
8.34.2.1
A person offering or providing a gratuity, gift, tip, present, 
donation, money, entertainment or educational passes or tickets, or any 
type of valuable contribution or subsidy that is offered or given with the 
intent to influence a decision, obtain a contract, garner favorable 
treatment, or gain favorable consideration of any kind.
8.34.3
If a person attempts to influence any employee or agent of Maricopa County, the 
chief procurement officer, or his designee, reserves the right to seek any remedy 
provided by the Maricopa County Procurement Code, any remedy in equity or in 
the law, or any remedy provided by this contract. 
8.34.4
ABSOLUTELY NO CONTACT BETWEEN THE RESPONDENT AND ANY 
COUNTY PERSONNEL, OTHER THAN THE OFFICE OF PROCUREMENT 
SERVICES, IS ALLOWED DURING THE SOLICITATION PROCESS UNLESS 
THE COMMUNICATION IS IN REGARD TO PRE-EXISTING BUSINESS WITH 
THE COUNTY. ANY COMMUNICATIONS REGARDING THE SOLICITATION, 
ITS PARTICIPANTS, OR ANY DOCUMENTATION PRIOR TO THE CONTRACT 
AWARD MAY BE GROUNDS FOR DISMISSAL OF THE RESPONDENT FROM 
THE EVALUATION PROCESS.
8.35
CONFIDENTIAL INFORMATION
8.35.1
Any information obtained in the course of performing this contract may include 
information that is proprietary or confidential to the County. This provision 
establishes the Contractor’s obligation regarding such information.
8.35.2
The Contractor shall establish and maintain procedures and controls that are 
adequate to assure that no information contained in its records and/or obtained 
from the County or from others in carrying out its functions (services) under the 
contract shall be used by or disclosed by it, its agents, officers, or employees, 
except as required to efficiently perform duties under the contract. The Contractor’s 
procedures and controls, at a minimum, must be the same procedures and controls 
it uses to protect its own proprietary or confidential information. If, at any time

SERIAL# 230178-RFP
during the duration of the contract, the County determines that the procedures and 
controls in place are not adequate, the Contractor shall institute any new and/or 
additional measures requested by the County within 15 business days of the 
written request to do so.
8.35.3
Any requests to the Contractor for County proprietary or confidential information 
shall be referred to the County for review and approval, prior to any dissemination.
8.36
PUBLIC RECORDS
Under Arizona law, all offers submitted and opened are public records and must be 
retained by the County at the Maricopa County Office of Procurement Services. Offers shall 
be open to public inspection and copying after contract award and execution, except for 
such offers or sections thereof determined to contain proprietary or confidential information 
by the Office of Procurement Services. If an offeror believes that information in its offer or 
any resulting contract should not be released in response to a public record request, under 
Arizona law, the offeror shall indicate the specific information deemed confidential or 
proprietary and submit a statement with its offer detailing the reasons that the information 
should not be disclosed. Such reasons shall include the specific harm or prejudice which 
may arise from disclosure. The records manager of the Office of Procurement Services 
shall determine whether the identified information is confidential pursuant to the Maricopa 
County Procurement Code.
8.37
INTEGRATION
This contract represents the entire and integrated agreement between the parties and 
supersedes 
all 
prior 
negotiations, 
proposals, 
communications, 
understandings, 
representations, or agreements, whether oral or written, expressed, or implied.
8.38
UNIFORM ADMINISTRATIVE REQUIREMENTS
By entering into this contract, the Contractor agrees to comply with all applicable provisions 
of 
Title 
2, 
Subtitle 
A, 
Chapter 
II, 
Part 
200—UNIFORM 
ADMINISTRATIVE 
REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL 
AWARDS contained in Title 2 C.F.R. § 200 et seq.
8.39
GOVERNING LAW
This contract shall be governed by the laws of the State of Arizona. Venue for any actions 
or lawsuits involving this contract will be in Maricopa County Superior Court, Phoenix, 
Arizona.
8.40
FORCED LABOR
8.40.1
By submitting a bid for this solicitation and/or entering into a contract as a result of 
this solicitation, contractor agrees to comply with all applicable portions of Arizona 
Revised Statutes Section 35-394. Contracting; procurement; prohibition; written 
certification; remedy; termination; exception; definitions.
8.40.2
Contractor certifies that it does not currently, and agrees for the duration of the 
contract, that it will not use: 
8.40.2.1
The forced labor of ethnic Uyghurs in the People’s Republic of 
China.
8.40.2.2
Any goods or services produced by the forced labor of ethnic 
Uyghurs in the People’s Republic of China.

SERIAL# 230178-RFP
8.40.2.3
Any contractors, subcontractors or suppliers that use the forced 
labor or any good or services produced by the forced labor of ethnic 
Uyghurs in the People’s Republic of China.
8.40.3
If contractor becomes aware during the term of the agreement that contractor is 
not in compliance with this paragraph, the contractor shall notify the County within 
five business days after becoming aware of the noncompliance. If the contractor 
fails to provide a written certification to the County that the contractor has remedied 
the noncompliance within 180 days after notifying the County of its noncompliance, 
then the agreement terminates, except that if the agreement termination date 
occurs before the end the 180-day period, the agreement terminates on the 
agreement termination date.
8.41
PRICES
Contractor warrants that prices extended to County under this contract are no higher than 
those paid by any other customer for these or similar services.
8.42
ORDER OF PRECEDENCE
In the event of a conflict in the provisions of this contract and Contractor’s license 
agreement, if applicable, the terms of this contract shall prevail.
8.43
INCORPORATION OF DOCUMENTS
8.43.1
The following are to be attached to and made part of this Contract:
8.43.1.1
Exhibit A – Vendor Information
8.43.1.2
Exhibit A-1 - Pricing
8.43.1.3
Exhibit B – Scope of Work
8.43.1.4
Exhibit C – Office of Procurement Services Contractor Travel and 
Per Diem Policy
8.44
NOTICES
All notices given pursuant to the terms of this contract shall be addressed to:
For County:
Maricopa County
Office of Procurement Services
301 W. Jefferson St. Suite 700
Phoenix, Arizona 85003-1647
For Contractor:
Eastern Research Group, Inc.
561 Virginia Road, Building 4, Suite 300
Concord, MA 01742
8.45
INQUIRIES
8.45.1
Inquiries concerning information herein must be submitted prior to the question 
deadline date/time posted in the e-procurement platform, Periscope S2G, using 
the link in the “Q&A” tab.

SERIAL# 230178-RFP
8.45.2
Administrative telephone/email inquiries shall be addressed to:
MICHAEL GALE, PROCUREMENT OFFICER
TELEPHONE: (602) 506-4866 
Michael.Gale@maricopa.gov
8.45.3
Inquiries may be submitted by telephone but must be followed up in writing. No 
oral communication is binding on Maricopa County.

SERIAL# 230178-RFP
IN WITNESS WHEREOF, this contract is executed on the date set forth above.
CONTRACTOR
AUTHORIZED SIGNATURE
PRINTED NAME AND TITLE
ADDRESS
DATE
MARICOPA COUNTY
CHAIRMAN, BOARD OF SUPERVISORS
DATE
ATTESTED:
CLERK OF THE BOARD
DATE
APPROVED AS TO FORM:
DEPUTY COUNTY ATTORNEY
DATE

SERIAL# 230178-RFP
Exhibit A - Vendor Information
COMPANY NAME:
Eastern Research Group, Inc.
DOING BUSINESS AS (dba):
MAILING ADDRESS:
561 Virginia Road, Building 4, Suite 300, Concord, 
MA 01742
REMIT TO ADDRESS
P.O. Box 845037, Boston, MA 02284-5037
TELEPHONE NUMBER:
781-674-7200
FAX NUMBER:
WWW ADDRESS:
www.erg.com
REPRESENTATIVE NAME:
Sandeep Kishan
REPRESENTATIVE  TELEPHONE NUMBER:
512-680-5121
REPRESENTATIVE EMAIL ADDRESS
sandeep.kishan@erg.com
YES
NO
REBATE
WILL ALLOW OTHER GOVERNMENTAL ENTITIES TO PURCHASE 
FROM THIS CONTRACT:
X
WILL ACCEPT PROCUREMENT CARD FOR PAYMENT:
X
PAYMENT TERMS: NET 30 DAYS

SERIAL# 230178-RFP
Exhibit A-1 – Pricing
1.1
Permit Engineering
 
 
1.1.1
Professional Level 1
 $             89.17 
PER HOUR
1.1.2
Professional Level 2
 $           115.33 
PER HOUR
1.1.3
Professional Level 3
 $           125.18 
PER HOUR
1.1.4
Professional Level 4
 $           136.32 
PER HOUR
1.1.5
Professional Level 5
 $           167.51 
PER HOUR
1.1.6
Professional Level 6
 $           219.12 
PER HOUR
 
 
 
 
1.2
Permitting Support
 
 
1.2.1
Professional Level 1
 $             89.17 
PER HOUR
1.2.2
Professional Level 2
 $           115.33 
PER HOUR
1.2.3
Professional Level 3
 $           125.18 
PER HOUR
1.2.4
Professional Level 4
 $           136.32 
PER HOUR
1.2.5
Professional Level 5
 $           167.51 
PER HOUR
1.2.6
Professional Level 6
 $           219.12 
PER HOUR
 
 
 
 
1.4
Air Quality Technical Research, Training, and 
Consultation
 
 
1.4.1
Professional Level 1
 $             89.17 
PER HOUR
1.4.2
Professional Level 2
 $           115.33 
PER HOUR
1.4.3
Professional Level 3
 $           125.18 
PER HOUR
1.4.4
Professional Level 4
 $           136.32 
PER HOUR
1.4.5
Professional Level 5
 $           167.51 
PER HOUR
1.4.6
Professional Level 6
 $           219.12 
PER HOUR
 
 
 
 
1.5
Regulatory Planning: Rules
 
 
1.5.1
Professional Level 1
 $             89.17 
PER HOUR
1.5.2
Professional Level 2
 $           115.33 
PER HOUR
1.5.3
Professional Level 3
 $           125.18 
PER HOUR
1.5.4
Professional Level 4
 $           136.32 
PER HOUR
1.5.5
Professional Level 5
 $           167.51 
PER HOUR
1.5.6
Professional Level 6
 $           219.12 
PER HOUR
 
 
 
 
1.6
Regulatory Planning: Analysis
 
 
1.6.1
Professional Level 1
 $             89.17 
PER HOUR
1.6.2
Professional Level 2
 $           115.33 
PER HOUR
1.6.3
Professional Level 3
 $           125.18 
PER HOUR
1.6.4
Professional Level 4
 $           136.32 
PER HOUR
1.6.5
Professional Level 5
 $           167.51 
PER HOUR
1.6.6
Professional Level 6
 $           219.12 
PER HOUR
 
 
 
 
1.8
Air Monitoring Technical Assistance
 
 
1.8.1
Professional Level 1
 $             89.17 
PER HOUR
1.8.2
Professional Level 2
 $           115.33 
PER HOUR
1.8.3
Professional Level 3
 $           125.18 
PER HOUR
1.8.4
Professional Level 4
 $           136.32 
PER HOUR
1.8.5
Professional Level 5
 $           167.51 
PER HOUR
1.8.6
Professional Level 6
 $           219.12 
PER HOUR

SERIAL# 230178-RFP
Exhibit B – Scope of Work
Primary Task 1 (Permit Engineering)
ERG staff have drafted permits for many agencies, including MCAQD. In addition, our staff have reviewed draft 
permits from dozens of agencies throughout the country. Furthermore, we have synthesized that expertise and 
experience into an acclaimed class on permit writing, with students attending from every geographic region of the 
United States. Our experience and ongoing efforts include supporting enforcement, giving our permits work a real-
world test of effectiveness and opportunities for improvement. 
Primary Task 2 (Permitting Support)
ERG staff have deep experience working with State and local permitting authorities. This breadth of knowledge allows 
us to access a variety of approaches for a particular problem. In addition, our work with MCAQD—most recently with 
the Permits Division, and earlier with the Planning and Analysis Division, gives us depth and familiarity with methods 
and techniques that MCAQD uses.  
Primary Task 4 (Air Quality Technical Research, Training, and Consultation)
ERG has provided a wide range of research, training, and consulting services related to air quality issues to state and 
federal clients for over 35 years. We have extensive experience in reviewing and writing air quality permits, 
developing air quality rules and regulations, evaluating and summarizing emission reduction technologies for both 
criteria and hazardous air pollutants, and developing emission estimation calculation methods and tools. 
As requested by MCAQD, ERG will draw upon this experience to develop white papers and technical memoranda on 
any air quality subject requested, provide subject matter experts, and develop and deliver training materials and 
procedures. As with all Tasks, ERG staff will work closely with MCAQD to develop timelines, identify needed data 
resources, and define the deliverables needed to meet the objectives of the Task. 
Primary Task 5 (Regulatory Planning – Rules)
ERG has supported rulemaking efforts for government clients for over 35 years, including technical support to the 
U.S. EPA in all phases of the development of air pollution emission standards, including new source performance 
standards (NSPS), Section 111(d) emission guidelines, national emission standards for hazardous air pollutants 
(NESHAPs), and risk and technology reviews (RTR’s) for more than 50 source categories. Our regulatory 
development experience encompasses a wide range of industrial, municipal, commercial, residential, and energy 
source categories.
For both regulatory development and state implementation plan (SIP) development, ERG will gather data from 
permits, emission test reports, and federal EPA rulemakings and databases, or industry surveys, among other sources, 
to characterize the industry category to be regulated, the emission sources, the controls used and the achievable 
emission limitations. ERG will then compile the data into a database to complete the analyses needed to identify the 
achievable level of control for new and existing sources, estimated emission reductions and other environmental 
impacts, and the cost-effectiveness (i.e., cost per ton of emissions reduced) for each regulatory option identified, 
including the incremental cost effectiveness for more stringent options. The data collected and the analyses performed 
will be documented into the technical support documents for the action. ERG will also summarize and assist MCAQD 
in responding to public comments on the action. 
Primary Task 6 (Regulatory Planning – Analysis)
For over 35 years, ERG has conducted technical analyses needed to support development of air pollution regulations 
for agencies at the federal, state, local and tribal levels. Our regulatory development experience encompasses a wide 
range of industrial, municipal, commercial, residential, and energy sources of air pollution. A very relevant example 
of this is ERG’s support to MCAQD’s Planning and Analysis Division from 2016 to 2021 under the previous Air 
Quality Rule Development Technical Support contract (SERIAL #16077-RFP). 
Primary Task 8 (Air Monitoring Technical Assistance)
ERG’s Measurements Group has provided high-quality air monitoring and sampling support services to Federal, State, 
Local, and Tribal clients for almost four decades. With our experience and expertise, we will continue to provide the 
same level of support to Maricopa County. ERG's experience along with our laboratory facility designed and equipped 
specifically to support client air quality programs, means we are ready to do the work requested by MCAQD as area 
of work experts without steep learning curves, equipment acquisition, or other startup delays.

SERIAL# 230178-RFP
Technical Approach
ERG’s general technical approach is presented below in Section 1.2.1. The specific technical approach 
Primary Tasks 1, 2, 4, 5, 6, and 8 are provided in Sections 1.2.2 through 1.2.7.
General Approach 
At the beginning of each assigned project, ERG staff (i.e., Project Manager, Deputy Project Manager, and 
appropriate Task Lead) will meet with MCAQD staff to review the project scope of work and project 
schedule and tasks, outlines for each of the deliverables, appropriate data resources, rationales, and specific 
information about the techniques or methodologies to be used.
After the initial meeting (within one week), the ERG will deliver a report summarizing the initial meeting 
and outlining the following: 
Work Plan: A description of work activities or tasks agreed upon by MCAQD and the ERG Project 
Manager, including the sequence of activities. 
Detailed Outlines of Deliverables: A detailed outline and description of each document and analysis. 
Methodology: A description of the methodology or techniques to be used including what data, specific 
methods, criteria, and tools will be used. The methodology will vary depending on the specifics of the 
Primary Task. 
Schedule: Final milestones for deliverables and progress reports. 
Work Products: The work products will generally consist of white papers or other appropriate 
documentation on assigned subjects. The work products will vary depending on the specifics of the 
Primary Task. Such papers will integrate original and secondary research, analysis of the state-of-
practice and best practices in technical analysis of – or alternative and comparative regulatory 
approaches to – air quality issues, pollutants, controls, and related subjects. ERG will compile and 
present findings, commentary, and recommendations for permit actions, process improvement, 
regulatory rulemaking, policy development, and further study. Document format will be consistent with 
MCAQD graphic standards and will include links or references to all data sources utilized. ERG will 
submit all documents as electronic preliminary and final drafts. All supporting documentation (e.g., 
data, modeling input and output files, calculations, technical references) will be presented in a clear and 
transparent format. 
Primary Task 1 — Permit Engineering
ERG staff have drafted permits for multiple state, local, and tribal agencies including MCAQD and Navajo Nation 
EPA. In addition, our staff have reviewed draft permits from dozens of agencies throughout the country. We have 
synthesized that expertise and experience into an acclaimed class on permit writing, with students attending from 
every geographic region of the United States, including Maricopa County. Our experience and ongoing efforts include 
supporting enforcement, giving our permits work a real-world test of effectiveness and opportunities for improvement.
Our technical approach starts with a rigorous review to determine if all the information necessary to review an 
application is included. Once an application is complete, we assess all applicable requirements, review and, where 
necessary, independently calculate proposed methods of compliance with those requirements, including control 
technology, ability to comply with prohibitory rules, and limits on potential to emit. We closely examine all emissions 
estimates and assess the methodology used to ensure that the emissions estimates are likely representative of potential 
emissions. Finally, we draft a permit that ensures that all requirements are enforceable as a practical matter. We 
transparently document our determinations in a Technical Support Document that is clearly written and legally 
defensible.
A thorough understanding of applicable air regulations is critical to the successful completion of any Title I (including 
minor source permits, referred to by MCAQD as non-Title V permits) or Title V permitting project. ERG has 
unequalled knowledge of federal regulations developed over our history of over 35 years supporting federal and state 
permitting, as well as decades of experience of ERG’s senior permit reviewers in direct issuance of federal permits 
and oversight of state and local permit programs. A key factor in reviewing permit applications is determining if the 
source correctly identified all applicable requirements such as New Source Performance Standards (NSPS), National 
Emission Standards for Hazardous Air Pollutants (NESHAP), non-attainment, New Source Review (NSR), Prevention

SERIAL# 230178-RFP
of Significant Deterioration (PSD), or State Implementation Plan (SIP) requirements. ERG has the experience and 
knowledge of these regulations to ensure all applicable requirements are included in the final permit. Given ERG’s 
experience assisting EPA in the development of many NSPS and NESHAPs, as well as our assistance to states in 
issuing PSD permits, we are uniquely qualified to make accurate independent assessments of which rules apply to a 
particular source.
Title I permits authorize construction of a new source or modification of an existing source and specify applicable 
state and federal regulations (e.g., emission limits, monitoring, testing, etc.), the types of controls that will be required, 
and any federally enforceable limits taken to avoid a regulation (e.g., PSD minor limits) for the new or modified 
emissions units. Title V permits authorize operation of a facility and contain all applicable air emission limitations 
that apply to stationary sources, as well as associated compliance demonstration, monitoring, record keeping and 
reporting requirements. Our staff will help MCAQD successfully complete permitting projects, because our permit 
writers are : (1) familiar with the permitting process, including the requirements for completeness reviews, public 
comment periods, EPA review, and adherence to permit issuance/denial deadlines; (2) knowledgeable about all 
relevant MCAQD, state and federal regulations and able to make accurate applicability determinations; (3) able to 
accurately calculate emissions and potential to emit; (4) able to write complete and concise technical support 
documents; (5) able to write limits that are federally enforceable, including what monitoring, recordkeeping, and 
reporting conditions are necessary to demonstrate compliance; and (6) experienced in handling applicants in a 
courteous and unbiased manner.
ERG has also demonstrated its knowledge and understanding of preparing and issuing permits through its development 
and presentation of its Effective Permit Writing course. Over the last three years, ERG has presented this course to 
over 200 state, local, and tribal air agency staff, including several from Maricopa County, working through Multi-
Jurisdictional Organizations including the Western States Air Resources Council (WESTAR), Lake Michigan Air 
Directors Consortium (LADCO), Mid-Atlantic Regional Air Management Association (MARAMA) and the 
Northeast States for Coordinated Air Use Management (NESCAUM). 
Through our decades of experience writing and reviewing thousands of permits, we understand the requirements of 
Title I permits, including minor NSR, non-attainment NSR, and PSD. Our staff determine when minor source, PSD, 
or non-attainment permitting is triggered for new construction and modifications, calculating emission increases due 
to the modification and emissions netting. We determine source status (i.e., whether a facility is a major or minor 
under NSR) using emissions calculations and considering any federally enforceable emission limits. If major PSD 
review is triggered, as well as for certain minor sources, we perform a well-supported best available control technology 
(BACT) analysis. In reviewing top-down BACT analyses, we pay particular attention to the control techniques 
examined, the emission reduction estimates, and the calculated costs and cost effectiveness. We review the Reasonably 
Achievable Control Technology (RACT)/BACT/LAER Clearinghouse (RBLC) for controls applied to similar sources 
and ensure the applicant has considered these controls, as well as other relevant sources of information, including 
actual performance of similar emissions units, research papers in the public domain, and EPA White Papers. ERG will 
work with MCAQD to ensure that data regarding technical and economic feasibility used to determine BACT are 
technically correct, consider all relevant data sources, and, as appropriate, consider site-specific situations. If a source 
is subject to non-attainment NSR, then LAER must be determined. ERG personnel have conducted dozens of LAER 
determinations, including researching the most stringent emission limitation which is contained in implementation 
plans of any state for such class or category of source, or the most stringent limit which is achieved in practice by such 
class or category.
Many applicability determinations rely on the accuracy of the emissions calculations. For example, the requirement 
to obtain a Title I or Title V permit often depends on the potential to emit calculations prepared by the source. It is 
therefore very important to carefully review and evaluate emissions calculations submitted in permit applications. Our 
staff has reviewed source emission calculations and assessed their accuracy for hundreds of industrial facilities in both 
the permit development and enforcement settings. We bring a critical eye to this review, as we have found that 
inappropriate sources of emission estimates can lead to lax permits. ERG developed sections of EPA’s Compilation 
of Air Pollutant Emission Factors (AP-42) and has calculated detailed site-specific emissions for numerous stationary 
sources. We are, therefore, familiar with the strengths and weaknesses of using AP-42 for site-specific emissions 
estimates, as well as relevant EPA guidance. Our staff is familiar with the various approaches to calculating emissions, 
including site-specific measurement data, process knowledge, vendor data, and emission factors. We also know that 
some approaches to calculating emissions are more accurate than others. For example, emissions calculated using 
mass balance calculations or site-specific emissions factors developed using stack test data are generally more reliable 
than using default emission factors developed by industry trade organizations or EPA, since the former approaches 
account for any unique operating characteristics or conditions of the plant.

SERIAL# 230178-RFP
An important consideration in drafting Title V and NSR permits is assuring that the compliance monitoring, testing, 
operation and maintenance, recordkeeping, and reporting requirements are fully consistent with the underlying 
regulations and are adequate to determine continuous compliance. ERG will carefully review the source’s application, 
the applicable Maricopa County and federal rules, and available MCAQD permit guidance and policies in developing 
draft permit conditions. 
In addition to preparing the permit, ERG will prepare a technical support document for each permit. This document 
lists the Maricopa County, state, and federal regulations that are included in the permit; explains why each rule applies 
to a particular facility; and summarizes the applicable limits, monitoring, maintenance, record keeping, and reporting 
requirements. This document also discusses and documents MCAQD and federal regulations that were evaluated but 
determined to be not applicable. For example, an emissions unit may be found to be not subject to a NSPS because it 
was constructed prior to the applicability or because its capacity is smaller than the applicability threshold. We 
understand the importance of fully documenting the basis for all draft permit conditions and decisions. We also 
recognize how useful a detailed and accurate technical support document can be to future permit writers when 
preparing construction permits or Title V renewals.
Finally, to be legally defensible, all procedural aspects of permit development must be strictly followed. These include 
the completeness review and preparation of a letter to the source to request additional information if the permit 
application is incomplete, documentation of technical analysis and the permit basis, including evaluation and/or 
development of an O&M plan for control equipment, and Dust Control plans as required, release of the draft permit 
package, notice of opportunity for public comment, thorough consideration and documentation of responses to public 
comments, EPA review, and issuance of the final permit. For each permit, we will deliver status reports, results of 
technical and regulatory evaluations, documentation of completeness reviews, statements of basis and technical 
support documents, analysis reports, draft permit packages, proposal permit package, public notice documents, 
responses to comments, and final permit packages. States and local agencies may be bound by strict schedules for 
certain types of permits; ERG will meet all permit deadlines. ERG will notify MCAQD immediately when we identify 
significant technical or regulatory issues requiring a decision from MCAQD. This last step is critical to the successful 
completion of any permit, since issues that arise during the review of permit applications and drafting of the permit 
and supporting documents must be resolved early to avoid impacting the schedule. Using these procedures, we have 
successfully met permit schedules for MCAQD and other states and local agencies, including the successful 
completion of many expedited construction permits. 
Development of SOPs for Permit Related Topics
ERG staff have deep expertise in areas related to offsets and environmental justice. For example, we have developed 
white papers for MCAQD regarding mobile source offset rule development, and for specific questions related to 
offsets proposed by Arizona Public Service. ERG has provided support for the EPA’s Region 9 office related to 
environmental justice in the issuance of a UIC permit, and to the Massachusetts DEP across all of its permit programs. 
Because of our engagement with a wide variety of regulatory agencies, including the various offices at the EPA, and 
State and local agencies, ERG is well positioned to support MCAQD by providing options that have been used by 
other agencies.
 
Modeling
Both Title V and non-Title V permit applications require an ambient impact assessment to demonstrate that the 
proposed project will not significantly degrade air quality. Under Arizona and federal law, new and existing sources 
that increase emissions of criteria air pollutants (CAPs) above certain thresholds must use air quality modeling to 
demonstrate that pollutant emissions will not cause or contribute to a violation of the National Ambient Air Quality 
Standards (NAAQS). EPA sets NAAQS for six CAPs - carbon monoxide (CO), particulate matter (PM), nitrogen 
dioxide (NO2), lead (Pb), ozone (O3), and sulfur dioxide (SO2) - for various averaging periods, under the CAA.
Air dispersion models use mathematical formulas to simulate pollutant fate and transport in the atmosphere. These 
models use information on an emission source, including source location, source characteristics (e.g., stack height, 
stack diameter), and emission rate, as well as information on meteorological conditions, terrain, and land use to 
calculate downwind pollutant concentration. In general, air dispersion models may be divided into two categories – 
simplified screening models, which evaluate worst-case impacts from a single emission source, and refined models, 
which use detailed input data to produce more realistic offsite pollutant concentrations at specific locations and are 
capable of handling multiple emission sources. AERMOD is EPA’s preferred/recommended air quality model for 
regulatory applications (40 CFR Part 51, Appendix W). AERSCREEN is AERMOD’s associated screening model 
and EPA’s preferred/recommended screening model for regulatory applications. Both AERMOD and AERSCREEN 
are steady-state, Gaussian plume models, developed by the American Meteorological Society/Environmental 
Protection Agency Regulatory Model Improvement Committee (AERMIC). The AERMOD modeling system includes

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AERMET, a meteorological data preprocessor, and AERMAP, a terrain data preprocessor. Conversely, AERSCREEN 
uses MAKEMET to generate a site-specific matrix of screening meteorological conditions. Both AERMOD and 
AESCREEN use BPIPPRIM to evaluate plume downwash due to building wake effects.
ERG has extensive experience applying air dispersion models (e.g., AERMOD and AERSCREEN for air permitting 
and regulatory compliance/enforcement. ERG also has experience with EPA’s HEM, EJSCREEN, and emissions 
models, such as MOVES. Note that ERG does not currently hold a license for TankESP; however, ERG has experience 
using similar methods to estimate VOC emissions from fixed and floating roof tanks on behalf of clients, including 
EPA’s Office of Pollution Prevention and Toxics.
MCAQD, ADEQ, and federal guidelines allow permit applicants to conduct screening-level modeling analyses to 
determine if more refined modeling analyses are required to demonstrate compliance with the NAAQS. Additionally, 
MCAQD offers permit applicants the option of either running a screening model in-house or requesting MCAQD run 
a screening model on their behalf. Regardless, the applicant must fill out MCAQD’s AERSCREEN Data Input Form, 
which is provided as Appendix A to the Maricopa County Permitting Handbook (Permitting Handbook). The 
Permitting Handbook also indicates that the applicant should include a description of the facility, project, modeling 
approach, and model input parameters in a separate modeling report. If the screening model indicates that maximum 
offsite concentrations could potentially exceed the NAAQS, a more refined modeling analysis may be required. It is 
the applicant’s responsibility to perform a refined air dispersion modeling and demonstrate that modeled 
concentrations will not cause NAAQS exceedances, considering local background concentrations. In this case, the 
Permitting Handbook indicates that the applicant must first submit a written modeling protocol to MCAQD for 
approval. Note that MCAQD provides a modeling protocol checklist as Appendix D to its Permitting Handbook. 
Following protocol approval, the applicant may perform the agreed-upon modeling analysis and summarize the results 
in a modeling report, accompanied by electronic modeling files.
Ambient air quality modeling analyses may be more complicated in areas that are in nonattainment of the NAAQS 
for one or more CAP. Portions of Maricopa County are currently designated as nonattainment areas for coarse 
particulate matter (PM10) and ozone (specifically with respect to the 8-hour ozone standard). ADEQ and EPA provide 
additional guidance for conducting modeling demonstrations for nonattainment pollutants, including guidance for 
emission sources that trigger PSD modeling requirements. Although EPA offers a tiered approach for PSD modeling, 
PSD modeling efforts can be substantial, and may require the consideration of all permitted sources within a defined 
significant impact area.
ERG staff routinely apply EPA-approved air dispersion models for a wide range of applications including permitting 
and enforcement assistance. ERG has conducted ambient impact assessments on behalf of regulated parties using both 
screening-level and refined air quality models. For example, ERG recently completed screening modeling to evaluate 
fenceline xylene concentrations from spray coating operations at a metals fabrication facility in Maricopa County. The 
permit package that ERG developed for this facility included a summary of model results and the associated input/out 
files. ERG also used AERSCREEN to conduct offsite impact assessments for two separate projects at a Naval facility 
in Maryland. As part of these assessments, ERG developed model inputs for two new Toxic Air Pollutant (TAP) 
emission sources, including stack parameters, emission rates, land use and surface characteristics, and building 
downwash parameters. ERG compared maximum, modeled TAP concentrations to relevant one-hour, eight hour, and 
annual screening levels to satisfy Maryland’s TAP requirements.
ERG recently used AERMOD to support a permit application to modify several existing boilers and install a new 
boiler at a central utilities plant serving an institution in Washington, DC. ERG determined that the project’s potential-
to-emit was below applicable NSR thresholds and should be permitted as a minor modification to an existing stationary 
source and that the area where the facility is located was in nonattainment with the 8-hour ozone NAAQS. ERG 
developed representative model inputs for the AERMOD analysis, including CAP emission rates, emission source 
parameters, and building parameters for the building downwash analysis. ERG also selected representative 
meteorological measurement stations to develop AERMOD surface and profile files and used AERMAP to process 
terrain data. ERG used a nested receptor grid (i.e., finer grid spacing near the source and coarser grid spacing further 
away) to capture worst-case air quality impacts. ERG compared maximum modeled CAP concentrations to the 
NAAQS, considering relevant averaging.
Additionally, ERG has experience conducting and reviewing air quality modeling analyses to assist EPA with 
compliance and enforcement actions. For example, ERG recently provided technical air dispersion modeling support 
to EPA’s Office of Compliance and Enforcement (OCE) for a CAA enforcement case related to air emissions from a 
malfunctioning flare at a petroleum refinery in the U.S. Virgin Islands. EPA used ERG’s work to develop a CAA 
Section 303 order, as the refinery was determined to pose “imminent and substantial endangerment” to human health 
and the environment. The project included a review of the refinery’s historical air dispersion modeling files and 
development of revised model inputs to better characterize offsite exposures to sulfur dioxide (SO2) and hydrogen

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sulfide (H2S). ERG also used air dispersion modeling to assess off-site impacts due to “acid gas flaring events” by 
modeling flare emissions on an hourly basis over a six-month period. ERG assisted EPA in evaluating the adequacy 
of existing ambient air monitoring stations and provided guidance on the siting of new, downwind monitoring stations 
to assess off-site impacts from process upsets and flare emissions. 
Additionally, ERG provided technical air dispersion modeling support to EPA/OCE on a CAA enforcement case 
related to air emissions from a chemical manufacturing facility. ERG used air dispersion modeling to assess off-site 
VOC concentrations from over sixty point and fugitive sources at the facility and evaluated the impact of proposed 
control measures. ERG compared annual (long-term) modeled concentrations to human health benchmarks to assess 
whether proposed controls reduced offsite concentrations to “acceptable” levels. ERG also reviewed HEM modeling 
conducted by the Facility to evaluate whether the modeling conducted according to EPA guidelines and was 
representative of onsite conditions.
Primary Task 2 — Permitting Support
ERG staff have deep experience working with State and local permitting authorities. This breadth of knowledge allows 
us to access a variety of approaches for a particular problem. In addition, our work with MCAQD—most recently with 
the Permits Division, and earlier with the Planning and Analysis Division, gives us depth and familiarity with methods 
and techniques that MCAQD uses.
 
Prepare Templates, Forms, and Training Materials
As we described above in Section 1.2.2, we are familiar with federal, state, and MCAQD requirements. ERG has also 
developed a wide range of trainings, including remote and in-person trainings such as the Effective Permits course, 
and web-based synchronous and asynchronous courses such as Inspector Training and CAA Section 112(r) (Risk 
Management Planning). We are therefore able to synthesize and simplify key concepts to create templates and forms 
that are meaningful and easy to use. 
Guidance and Policy Documents
ERG staff have drafted policy and guidance for a number of EPA offices, as well as for State agencies. Our past work 
with MCAQD resulted in creation of White Papers, which provide regulatory and technical support, and are very 
much like guidance and policy documents. These documents included an analysis of technical, legal and regulatory 
requirements for establishing a mobile source offset rule, and an analysis of EPA comments on offsets proposed by 
Arizona Public Service (APS). For the EPA, our staff drafted the its penalty policy for violations of the North 
American Emissions Control Area, and enforcement alerts for Metal Recycling, AP-42, Natural Gas Gathering 
Operations (Pigging), and Storage Vessels at Onshore Oil and Natural Gas Production Facilities.  We also drafted a 
Plain Language guide for the pulp and paper NESHAP as well as the WebFIRE Procedures Manual.
Evaluate Permit Findings and Records
Individual ERG staff have over 35 years of experience reviewing permit actions, including the administrative record, 
for hundreds of permits proposed or issued by State and local agencies. These reviews have included application 
materials and agency analysis and findings. These reviews have occurred in the context of program reviews, public 
notice periods, and enforcement.
Fee Sufficiency
ERG has over 30 years of experience in economic analysis, including estimating costs of emissions controls and socio-
economic costs. ERG’s robust economics staff has the expertise and experience to review costs, fees and other income 
streams to advise MCAQD if its fees are sufficient for current and future anticipated staffing and other expenses. 
ERG uses a methodical approach to identifying the full costs of a program or control in order to assess the adequacy 
of associated fee structures. For the Food and Drug Administration (FDA), for example, ERG has assessed and 
developed recommendations related to fee structures related to the Agency’s drug and biologic review programs, 
which are funded by fees to applicants. A few examples include:
FDA human drug review program Standard Cost Model: FDA uses this model to develop standard costs 
for its human drug review program activities—which it also uses to determine eligibility for user fee 
waivers. ERG created a schema to depict the full costs of human drug reviews and assessed the model’s 
adequacy in capturing those costs. We deconstructed the model, audited data sources and inputs, 
assessed the model’s alignment with standard cost accounting, assessed the model’s alignment with 
FDA’s current human drug review responsibilities, and evaluated the model’s adequacy for its intended 
uses. We developed a set of findings and concepts for alternatives for discussion with FDA, then

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prepared a report documenting the evaluation. At FDA’s request, ERG designed idealized and interim 
alternatives for the PDUFA Standard Cost Model that could improve its use for human drug review 
program management as well as its use in the PDUFA Workload Adjuster.
FDA human drug review program Workload Adjuster Model: Each year, FDA uses this model to 
determine how to adjust human drug review program user fees based on changes in the number and 
complexity of drug applications and staffing needs. Following a process similar to that described above, 
ERG analyzed the adequacy of the model in capturing the full costs of changes to drug review program 
activities and thus its adequacy in determining appropriate fee changes.
FDA biosimilars program cost estimation: An Act of Congress established a new human drug review 
program – for biosimilars – that is funded by user fees from biosimilar applicants. Because this was a 
new program requiring different activities, processes, and staffing, FDA asked ERG to perform a 
comprehensive process analysis and full cost accounting (based on estimates of biosimilar application 
volume and complexity) to estimate costs per category of program activity – which FDA used to 
establish adequate, reasonable biosimilar program user fees.
Database Management
As a result of ERG’s past work with MCAQD Permits Division, we have a working knowledge and familiarity with 
the IMPACT database, and we therefore have the ability and permissions to input facility and permit data into the 
system. 
Primary Task 4 — Air Quality Technical Research, Training, and Consultation
ERG has provided a wide range of research, training, and consulting services related to air quality issues to state and 
federal clients for over 35 years. We have extensive experience conducting air quality research, developing air quality 
rules and regulations, evaluating and summarizing emission reduction technologies for both criteria and hazardous air 
pollutants, developing emission calculation methods and tools, and conducting and reviewing airshed modeling.
ERG’s technical approach to develop the deliverables listed in Section 2.6 of the RFP demonstrates our extensive 
experience in providing air quality services covering all relevant scope areas. Through our work for EPA and state 
and local agencies, ERG has conducted numerous types of analyses and prepared the deliverables required under this 
contract (i.e., listed in Section 2.6 of the RFP).
Technical Research and Consultation
ERG routinely conducts technical research on the air quality issues faced by our federal, state, local, and tribal air 
agency clients. We understand many of the issues faced and will provide support based on our comprehensive 
knowledge of emission sources and potential control options. Most often the needed technical research and 
consultation is directly tied to specific emissions sources, and we will identify the most experienced ERG staff to 
provide support. In some cases, technical research will be based on identification and analysis of information published 
by research organizations and other air quality agencies. Conducting this type of secondary research and assessing it 
specific to the needs of MCAQD is the most efficient and effective way to provide such support. 
Related to regulatory support, technical research and consultation support consists of researching and documenting 
the entire data gathering and analysis process, documenting all of the calculations performed to assess and verify 
emission reductions, and preparing detailed Technical Support Documents. For example, industry might advocate for 
adoption of a new, more cost-effective compliance alternative that provides equivalent emission reductions based on 
a technological advance in manufacturing process, air emission reduction systems, or even air emission monitoring 
techniques. We will review these industry evaluations to ensure the technical accuracy and veracity of the claims made 
for the technological advances or new emission reduction system. Our review could include a wide variety of analyses 
depending on the information submitted. Similarly, a request by industry could be made for situations where an 
emission source is determined to pose negligible health risks and/or a source desires to undertake a voluntary emission 
reduction, possibly in exchange for an extension in compliance date. These analyses could involve comparison of 
long-term emission reductions using the voluntary approach with the emission reduction levels associated with 
compliance with the standard. In these types of reviews and analyses, ERG will provide a summary of the data and 
analytical approach used in the review and prepare draft recommendations and conclusions for MCAQD to review 
and consider in deliberations.

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ERG can support MCAQD’s permitting and planning needs related to the possible reclassification of the 
Phoenix/Mesa area to serious for the 8-hour ozone (2015) NAAQS using the same process described above. Given 
that reclassification will affect permitting and planning—more major sources and more RACT requirements—we will 
conduct the needed data gathering, analysis, and emission estimation calculations in order to document and present 
our results and recommendations to MCAQD. 
ERG’s air quality experts can also conduct laboratory studies, field studies, design and construct prototype monitoring 
analyzers and equipment in order to test and evaluate new technologies, as well as evaluate existing technologies. 
After preparation and approval of a work plan and QAPP, we document the results of this type of work in field reports, 
letter reports, and Work-to-Date reports.
On-call Subject Matter Expertise
ERG has subject matter experts related to the types of air quality issues MCAQD may need to address under the 
proposed contract, including enforcement and compliance, construction and operating permitting, and regulatory 
development activities. ERG has a large staff of environmental professionals with extensive expertise in air quality 
pollution controls, regulatory development, emissions inventory development, socioeconomic analyses, air quality 
management, process engineering and evaluation, human health and ecological risk, occupational health and safety, 
communications, and information technology. ERG’s deep bench of in-house staff will allow us to draw upon easily 
accessible subject matter experts, avoiding the costs and schedule delays associated with subcontracting outside 
experts. In cases where our internal staff may not be suited to address a specific issue, ERG may also procure the 
services of outside experts.
Much of our experience has been gained supporting state/local/tribal and federal air quality agencies in developing 
rules and regulations aimed at improving air quality. We have provided technical support to the U.S. EPA in all phases 
of the development of air pollution emission standards, including new source performance standards (NSPS), Section 
111(d) emission guidelines, national emission standards for hazardous air pollutants (NESHAPs), and risk and 
technology reviews (RTR’s) for more than 50 source categories. Our regulatory development experience encompasses 
a wide range of industrial, municipal, commercial, residential, and energy source categories.
ERG’s staff of potential subject matter experts include:
More than 100 CAA regulatory development specialists who have supported regulatory projects 
covering every major U.S. manufacturing sector.
More than 40 credentialed inspectors who have supported thousands of inspections spanning every 
major U.S. manufacturing sector.
Once MCAQD identifies a specific need for a subject matter expert (or experts), ERG will conduct an internal review 
of our staff resumes and previous projects to identify candidates with relevant experience. ERG will work closely with 
MCAQD to ensure that the staff we have identified are suitable and meet the needs of the department. 
Develop Training Materials and Procedures
ERG has significant experience developing and providing work instructions, guidelines, handbooks, and training 
directly to personnel or as train-the-trainer. As mentioned in Task 1, ERG has developed and delivered training courses 
for NESCAUM, LADCO, MARAMA, and WESTAR. These courses covered topics such as the Clean Air Act, Title 
I New Source Review pre-construction permits (including emissions offsets), BACT and LAER, and Title V operating 
permits.
ERG recently developed and delivered a three-day course on nitrogen oxides (NOx) emissions control technologies 
for the NESCAUM states in November 2022. The course was taught by three instructors as an interactive online 
course. Again using a combination of PowerPoint presentations, videos, quizzes, polls, and breakout sessions, the 
instructors covered source categories subject to NOx control requirements and types of NOx control technologies for 
combustion devices, such as turbines, boilers, engines, hot mix asphalt plants, glass plants, and municipal waste 
incinerators, as well as NOx control technologies that can address CAA requirements, such as Reasonably Available 
Control Technology (RACT), Best Available Control Technology (BACT), and Lowest Achievable Emission Rate 
(LAER).
ERG will utilize its extensive training knowledge and skills to develop and deliver training for MCAQD. ERG can 
develop in-person or online, interactive, instructor-led courses, or online, interactive self-study materials, depending 
on MCAQD’s needs. ERG will begin the process by discussing the scope of the desired training with MCAQD. We

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then develop an appropriate timeline and milestones for course development. We will use tools such as Teams and 
Zoom for presenting online, in-person, and PowerPoint and other audiovisual tools for in-person classroom training.
Primary Task 5 — Regulatory Planning: Rules
ERG’s technical approach to develop regulations, SIPs, and performing socioeconomic analyses demonstrates 
extensive experience in the environmental field, and specifically in supporting rulemaking efforts for government 
clients for over 35 years. Through our work for EPA and state and local agencies, ERG has conducted numerous types 
of analyses and prepared the deliverables required under this contract (i.e., listed in Section 2.7 of the RFP).
We have provided technical support to the U.S. EPA in all phases of the development of air pollution emission 
standards, including new source performance standards (NSPS), Section 111(d) emission guidelines, national 
emission standards for hazardous air pollutants (NESHAPs), and risk and technology reviews (RTR’s) for more than 
50 source categories. Our regulatory development experience encompasses a wide range of industrial, municipal, 
commercial, residential, and energy source categories. ERG’s regulatory development experience is summarized in 
Table 2 by sector or topic.
Regulation Development Assistance
ERG has extensive experience in supporting regulatory development and recommending and implementing best 
practices for rulemaking workflows to efficiently develop and document new regulations. Typical sub-tasks in the 
rulemaking process supported by ERG include Data Gathering, Data Analysis and Documentation, Regulatory 
Proposal Development, Public Comment Summary and Response Development, and Stakeholder and Management 
Briefings.
Data Gathering. ERG will conduct a review of available information for an industry category to be regulated, such 
as from permits, compliance reports, federal rulemakings, and emission inventories. These data generally include 
facility background information; plant parameters; past, current, and future estimates of production; emission control 
equipment and work practices currently applied to control emissions and the cost of these air pollution controls and 
practices. Other data sources can include the EPA’s RACT/BACT/LAER Clearinghouse (RBLC), and the EPA’s 
Environmental Compliance History Online (ECHO) database.
ERG will prepare a document summarizing the data gaps that are identified after completing a review of existing 
information and discuss those data gaps with the client and propose a strategy to collect information to fill those data 
gaps. 
If necessary, ERG can develop a survey or questionnaire. ERG has developed many CAA Section 114 Information 
Collection Requests (ICRs) for the EPA to collect data on current emission sources, pollutants, controls (including 
performance and cost data, and data needed to estimate the cost of controls), and work practices being used to minimize 
emissions. ERG has also developed ICRs to collect data through industry emissions source sampling/emissions testing 
(e.g., stack testing). 
ERG compiles submitted responses to the ICR and conducts analyses of the data submitted by industry. The data from 
the ICRs and other sources are compiled into either a MS Access or MS Excel database, with the preference to use a 
MS Excel database if possible, depending on the complexity and volume of the data. The data are reviewed and 
checked for illogical or unreasonable values and statistical outliers according to quality assurance plans developed for 
each project. 
ERG also conducts literature reviews to identify emissions and control information relevant to specific industries and 
prepares a literature review memorandum to document and summarize the resources consulted and identify any 
technologies and practices that can be used to reduce emissions.
ERG can review rules from other states and regional programs, and the related technical support documents, to identify 
achievable emission limitations and methodologies to estimate costs and emission impacts. ERG used this approach 
extensively in developing regulations for oil and natural gas production in New Mexico.
ERG can also conduct site visits to collect information on the use of add-on pollution controls, innovative and low 
emitting technologies and practices that are available and benefits, costs, and challenges to adopting those technologies 
and practices. ERG prepares a list of questions and a health and safety plan before site visits and then documents each 
site visit in a report for each site.

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Data Analysis. ERG will prepare an electronic database that contains the information gathered permits, test reports, 
and survey responses. ERG will use separate fields for each class or type of data to enable easy identification of the 
specific facilities associated with any combination of data fields. Data fields typically include the following: 
A facility identifier code, and the name of the owner, the operator, the North American Industry 
Classification System (NAICS) code, and location. 
If the facility or the parent company of the facility is a small business using the SBA definition for this 
industry based on applicable NAICS code. 
Operating permit limits for toxic and criteria pollutants (including GHG) for the affected operations for 
each facility.
Stack test data for toxic and criteria pollutants (including GHG) for the affected operations for each 
facility, if available.
The annual emissions of toxic and criteria pollutants for the affected operations. ERG will carefully 
document the methodology, assumptions, and references used to prepare the emission estimates. 
Projected production rates and the number of new facilities that will be constructed or reconstructed in 
a given time period when there are separate standards for new and existing sources or when a 
projection is needed for modeling. This projection will be based on the construction and reconstruction 
dates for existing facilities obtained from the permits for these facilities.
The products produced, type of feed stocks used, various fuels used, and design production capacity.
ERG will analyze the data to identify the achievable level of control for new and existing sources, estimated emission 
reductions, and the cost-effectiveness (i.e., cost per ton of emissions reduced) for each regulatory option identified, 
including the incremental cost effectiveness for more stringent options.
Other analyses will include the environmental impacts and cost impacts of each identified control alternative for the 
regulated entity. ERG will estimate the baseline emissions for all toxics and associated criteria pollutants, and the 
estimated emissions reduction for each control alternative presented. ERG will estimate capital and annual costs of 
each control alternative presented, including the costs per facility (if possible) and for the whole source category. ERG 
will include a description of the methodology and a list of all references used to prepare the cost estimates. For add-
on controls, ERG will estimate the capital and annual costs using the EPA OAQPS cost algorithms, when available. 
For other control options, such as process changes, ERG will need to rely on cost information collected from industry 
members or vendors.
Documentation. ERG will prepare the technical support documentation for proposed rules that summarizes the data 
gathering process, the data received, and the results of the analyses completed. The data and information presented 
will provide the technical rationale for the proposed standards. The documentation includes all references, the results 
of the analyses, and the conclusions drawn, detailed information about the new requirements (i.e., emission reductions, 
cost of achieving additional emission reductions, non-air quality health and environmental impact and energy 
requirements, etc.) if applicable. 
Regulatory Proposal Development. ERG will assist in drafting the proposal regulatory text and supporting reports 
following County templates. ERG can provide support for the County during Board of Supervisor briefings, 
stakeholder workshops, preparing the notice of proposed rulemaking, and during public hearings with the County 
Board of Supervisors. ERG has been providing these same services to our federal clients, including technical support 
for both in-person and virtual public hearings.
ERG will provide presentation materials, such as PowerPoint slides, briefing documents or supporting documentation 
at the direction of the County. These materials will include information such as the proposed rule and regulatory 
alternatives, economic and environmental impacts, control costs, and cost effectiveness of any revisions to the rule 
and any regulatory alternatives that were examined. 
ERG will participate in and provide support for meetings with industry, State and local agencies, and environmental 
organizations affected by rulemakings and will provide written summaries of any meetings in which ERG participates.

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State Implementation Plan (SIP) Development
ERG has used numerous methods to develop emission inventories, depending on the nature of the source category and 
the budget and schedule constraints. We generally typically start by obtaining permit files and databases from state 
and local agencies, as well as information from federal sources (e.g., National Emissions Inventory, Toxics Release 
Inventory, etc.). We collect data on source location, emissions, process configurations, current regulations that apply, 
and baseline controls. We then obtain supplemental data from site visits, trade associations, industry meetings, 
technical publications, and industry databases. In some cases, we have developed questionnaires to survey the industry 
either comprehensively or by surveying a representative subset of facilities with different process configurations. 
Our inventory specialists have developed survey questionnaires and worked hand-in-hand with industrial facilities to 
collect production, fuel usage, control device performance, and other emissions-related data used in bottom-up 
inventories. These methods ensure accurate data are used in estimating baseline and post-control emissions estimates. 
Also, our experience in working with government agencies, industry, and all types of stakeholders contributes to good 
communications, safe handling of confidential business information (CBI), and adherence to agency procedures and 
processes.
As part of the rule development process, we typically analyze the emissions data and develop a profile of the target 
industry. The profile describes the different production processes, identify the significant emission points and emission 
mechanisms, quantify emissions by facility, explain the factors affecting emissions, and provide a geographic location 
of the facilities and a growth projection. If necessary, we also identify emission release characteristics for use in 
dispersion modeling, public health risk assessments, and control strategy development.
To ensure that databases are documented and that technical analyses are sound, ERG develops quality management 
plans for regulatory projects, which we tailor to the needs of specific projects. A senior engineer with experience in 
rule development is assigned to help plan the data collection and analysis, and to peer review the analytical results. In 
preparing regulatory databases, we document every data source, peer review data interpretations, and provide QA of 
the data entry.
SIP Control Strategy Analysis. Once the agency approves the selection of control techniques, ERG develops control 
strategies that serve as the basis for the regulatory decision. We customize the control strategies to the source category 
depending on the types of emission points (e.g., sources may have stack emissions, waste handling emissions, and 
fugitive emissions, etc.), availability of control techniques with different levels of emission control, and nature of the 
governing statute (i.e., severe air quality problems or serious health effects require more aggressive approaches, where 
costs are less of a factor in structuring options). 
A primary consideration is the technical feasibility of the control measure for different process configurations. For 
example, in the miscellaneous metal parts and products NESHAP, we developed different control strategies for general 
use coatings, high performance coatings, magnet wire coatings, and rubber-to-metal coatings. The same control 
options were not feasible for all these subcategories of coatings because high performance coatings must withstand 
severe conditions such as high temperature and exposure to harsh chemicals, magnet wire processes use a unique 
design of curing oven that burns exhaust gases as supplemental fuel in the oven, and low HAP coatings have not been 
demonstrated for rubber-to-metal coating applications. 
ERG develops multiple control strategy options for each rule. The options represent a range of stringencies, each 
associated with a different emission reduction and other environmental and cost impacts. After considering the options, 
the agency chooses a single control strategy to propose. We structure control strategy options to encompass which 
sources and types of emission points to regulate, alternative control techniques, and ranges of performance levels. 
Formats of the options differ depending on the process to be regulated. For example, control strategy options may 
present alternative emission control technologies upon which the rule and its emission limits could be based (e.g., an 
electrostatic precipitator versus a fabric filter, etc.). Alternatively, the control strategy options may involve a single 
control technique, but different levels of emission reduction that can be achieved (e.g., a caustic scrubber designed 
and operated to get 90 percent reduction versus 95 percent reduction). For other process conditions, we may specify 
options that rely on a single control technique but differ in terms of which sources would be required to apply control 
(e.g., a 98 percent efficient combustion device for process vent streams that exceed alternative flow rate and VOC 
concentration levels, etc.). We develop a different set of control strategies for new and existing sources, because there 
may be technical limitations and higher costs for retrofitting controls on existing sources.
SIP Cost/Benefit Analysis. To support the regulatory decision-making process, ERG estimates the emission 
reduction of each control strategy compared to baseline emissions. We generally compute the emission impact for

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each facility using a site-specific emission inventory. If sufficiently detailed inventory data are not available, we 
develop a set of engineering models to represent the industry based on available inventory information, such as the 
type of products manufactured, processes used, and production rates. To estimate emission impacts, we may apply 
control device efficiencies to baseline emissions, use emission factors, or apply mass balance principles depending 
on the processes being regulated, the types of controls, and available data. 
Besides the regulated pollutant, we estimate the impacts on other emissions. For example, a combustion device to 
control VOC may also reduce organic HAP, but result in an increase of NOx. Similarly, a limit on the HAP content of a 
surface coating product or commercial or institutional cleaning products may cause an increase in VOC due to 
product reformulation. Rules that lead to energy efficiency may reduce greenhouse gas emissions. ERG routinely 
documents the multi-pollutant and multi-media impacts of each control strategy, including differences in energy 
demand and any water and solid waste discharges.
To support rulemaking analyses, ERG estimates the full compliance costs to the industry, including control costs and 
the cost of testing, monitoring, recordkeeping, and reporting. We report the costs in terms of capital investment, 
annualized costs, and cost-effectiveness (i.e., annualized cost per mass of emission reduced). Generally, we compute 
costs on a site-specific basis, but we may use engineering models of the industry for source categories with limited 
data or with a large number of sources, such as dry cleaners or boilers.
Our control cost estimates include capital and operating costs. For capital costs, we include purchased equipment, 
site preparation, installation costs (e.g., foundation, erection, utilities), and indirect costs (e.g., engineering, start-
up, contractor fees, etc.). For annual operating costs, we include operating labor, maintenance labor, materials, 
electricity, compliance costs, and indirect costs (e.g., overhead, administration, property taxes, insurance, etc.). For 
compliance costs, we include the capital costs and annual labor costs. Labor costs cover the requirements for 
regulatory notifications, collecting process data, operating monitoring equipment, performing equipment 
calibrations and tests, and submitting compliance reports.
To prepare cost estimates, we gather actual cost data from multiple plants and control technology vendors, and 
review these data to understand the cost components and develop cost algorithms that are specific to the industry. 
To facilitate costing efforts, ERG has developed a library of computerized algorithms in spreadsheet or Access 
database format for a number of control devices, including the following: 
Biological treatment
Leak detection and repair 
Boilers
Mechanical collectors (e.g., cyclones)
Carbon adsorbers
Packed tower gas absorbers
Carbon injection
Piping
Catalytic incinerators
Refrigerated condensers
Combustion turbines
Selective catalytic reduction (SCR)
Dry sorbent injection
Selective noncatalytic reduction (SNCR)
Ductwork and miscellaneous associated equipment
Spray drying 
Electrostatic precipitators
Steam strippers
Fabric filters
Storage tank controls
Flares
Thermal incinerators
Flue gas desulfurization
Venturi scrubbers
Internal combustion engines
Wet scrubbers
The computerized algorithms are based on procedures in the EPA Air Pollution Control Cost Manual and other the 
EPA guidance documents. ERG updated the cost routines based on newer guidance and data collected from recent 
NSPS and NESHAP rulemakings and other costing efforts. Using these programs and recognized cost indices (e.g., 
Chemical Engineering magazine’s “Chemical Engineering Plant Cost Index”, etc.), we can update or customize these 
algorithms to develop control cost estimates for a broad range of industry processes quickly and efficiently.

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Socioeconomic Impact Analysis.
ERG offers MCAQD nearly 30 years of experience in supporting rule development with tailored socioeconomic 
analyses. 
We begin a socioeconomic impact analysis by developing a profile of the industry that addresses such factors such as 
the number of facilities and companies in the regulated community and whether they are public or private, large or 
small, stand-alone operations or integrated/interrelated facilities under the same ownership. We also characterize the 
industry market structure (e.g., competitive, oligopolistic, or monopolistic) and other salient factors that may affect 
how it interacts with suppliers and customers, such as the existence of barriers to entry or exit. The industry profile 
lays the groundwork for the structure of the economic analysis.
We then identify the regulatory baseline (i.e., the best assessment of the way the world would look absent the proposed 
regulation). We evaluate affected entity practices in the absence of the proposed regulatory action; impacts are then 
assessed relative to this baseline. Determining the baseline requires summarizing demographic information and 
population trends, as well as creating a database of entities organized by county, industry, and employment size. In 
addition, the database may include firm/establishment revenues, payroll, and estimates of net income, employment, 
and other economic data by major industry groups in the relevant geographic region. 
This also gives us the opportunity to include important socioeconomic factors such as poverty and unemployment in 
the analysis. The socioeconomic analysis should account for the geographical distribution of both affected facilities 
and the socio and demographic characteristics of the region to answer questions such as: if a rule negatively impacts 
employment, will it occur in a region with already high levels of unemployment, or will there be other employment 
opportunities for affected workers? To this end, we frequently plot facilities on a map of the region that then may also 
be layered with variables such as unemployment rates, poverty rates, emissions of pollutants of interest, or other 
factors of interest to the region to evaluate the potential environmental justice implications of a rule. 
ERG economists and engineers work together to understand the costs of pollution controls and evaluate the 
incremental changes to engineering controls or practices that will enable the entity to meet the proposed emissions 
limits, and the associated cost of implementing and operating such controls. The economists take the capital, one-time 
non-equipment, and annual operating and maintenance costs developed by the engineers and annualize them taking 
into account the lifetime of the capital investment, cost-of-capital (discount rate), and depreciation. If desired by the 
client, we can also estimate post-tax annualized compliance costs by accounting for corporate structure and tax rates, 
although such estimates are subject to greater uncertainty. Cost annualization converts a variable stream of costs over 
time into an equivalent equal annual amount, and thus is a convenient way to compare the cost of the rule with its 
benefits on a consistent basis, examine the impacts of the additional costs on projected cash flows, and estimate the 
cost-effectiveness of the proposed controls. 
By combining the annualized costs and removals, ERG examines the relative cost-effectiveness for each pollution 
control option. An option that costs more but removes less pollution than another option is inefficient and is dropped 
from the analysis. A cost-effectiveness analysis also indicates whether there is a marked change in the marginal cost 
relative to the marginal removals moving from one option to another. Such a point indicates where an option costs 
much more but removes little more pollution than another option under consideration.
These costs may include a mix of one-time equipment retrofit or replacement costs, permit fees, and recurring 
operating and maintenance costs. To estimate costs efficiently, we use engineers who specialize in EPA costing 
procedures, such as the EPA Air Pollution Control Cost Manual (Cost Manual), Co$t-Air, CueCost, and other EPA-
developed cost programs. Our engineers have developed several chapters in the Cost Manual, as well as aspects of 
CueCost. ERG has developed spreadsheets with all the cost algorithms from the Cost Manual; algorithms for good 
combustion practices, incinerators, flares, condensers, absorbers, carbon adsorption, carbon injection, fabric filters, 
electrostatic precipitators, and leak detection and repair using EPA Method 21; and the alternative work practice of a 
gas-imaging camera. The spreadsheets include other ERG-developed control algorithms, such as low NOx burners, 
spray dryers, oxidation catalysts, SCR, and selective non-catalytic reduction (SNCR). Cost algorithms may not be 
available for some emission control options, such as process modifications, operator training, equipment standards, or 
work practices. In these cases, we estimate costs using standard engineering practices and data collected from the 
industry, equipment vendors, material suppliers, trade associations, and state agencies. We annualize one-time costs 
over 10 years and add these to each year’s recurring costs. Calculating annualized costs is important for comparing 
costs and benefits that are often incurred over different time horizons.

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We also estimate and assign costs by entity employment and revenue size categories developed in the economic 
profile, if applicable. This is necessary for a small business analysis that delineates entities as small based on 
employment and/or revenues because costs may be relatively larger or more burdensome for small businesses.
In general, we usually assess the significance of impacts using the ratio of annualized compliance costs to revenues, 
as is the standard approach for agencies such as the U.S. EPA and Department of Labor. However, if sufficient 
information exists for the industry, we may combine forecasting methods, industry data, and discounted cash flow 
analysis to create industry-specific facility- and company-closure analyses. ERG has used this approach for EPA 
Office of Water based on company-specific data collected through a survey. We also developed an alternative 
modeling methodology that approximates cashflow for a sequence of “typical facilities” using custom tabulated data 
from the Census Bureau to evaluate the impacts of added costs on establishments. We may also use financial ratios, 
discriminate analysis of financial ratios such as Altman’s Z models, and access to capital to evaluate the impacts of 
new pollution control requirements. 
ERG typically uses input-output based models such as IMPLAN to examine not just the direct output and employment 
impacts of a rule on affected facilities, but also indirect impacts to their suppliers and induced impacts on consumer 
spending and thus other industries as well. This allows us to analyze community and regional economic impacts. 
Combining these results with socioeconomic and demographic characteristics of potentially affected regions forms 
the basis for assessing socioeconomic and environmental justice impacts. 
We have developed and applied many methods for estimating the improvement in social welfare from a policy 
decision. We have used revealed and stated preference, hedonic, and avoided costs methods to estimate changes in 
use and non-use values. Our benefits analysis is integrated with our market models and industry profile to give a 
complete picture of changes in private and public well-being.
ERG has successfully completed all of these socioeconomic analyses for many industries and regulations. Each study 
has been tailored to the industry, level of information available, and level of detail specified by the client. We are used 
to quick-turnaround requests, particularly during the option selection period. Our senior staff have extensive track 
records of managing projects from initial phases through proposal, promulgation, and—if needed—litigation. 
The methods and data used, and results derived from the socioeconomic impacts analyses will be documented. ERG 
will prepare draft, final draft, and final versions of each report as determined by MCAQD. Following each draft and 
final draft document submittal by ERG, MCAQD will provide comments and ERG will address the comments in 
subsequent version(s) of the document, culminating with a Final Document. All Final Documents will be submitted 
to MCAQD along with all references, related data, etc. 
Planning Support
ERG’s scientists and engineers have been supporting the federal and state governments in developing and 
implementing air quality regulations and related planning, inventory, and permitting programs since before the Clean 
Air Act amendments of 19990. 
Because we have provided technical support to the U.S. EPA, and many state and regional agencies, in all phases of 
the development and implementation of air pollution emission standards, including NSPS, Section 111(d) emission 
guidelines, NESHAPs, and risk and technology reviews, we have the familiarity to assist in developing 
recommendations and positions related to policy and technical issues. At the same time, we can provide training and 
mentoring to MCADQ staff to develop these recommendations or positions while addressing the unique political, 
geographic, and socioeconomic conditions that impact air quality programs in Arizona. 
Primary Task 6 — Regulatory Planning – Analysis
For over 35 years, ERG has conducted technical analyses need to support development of air pollution regulations for 
agencies at the federal, state, local and tribal levels. We have supported the development and analysis of consumer 
and commercial product standards under Clean Air Act Section 183(e), new source performance standards (NSPS), 
and national emission standards for hazardous air pollutants (NESHAPs) for more than 50 source categories. Our 
regulatory development experience encompasses a wide range of industrial, municipal, commercial, residential, and 
energy sources of air pollution. A very relevant example of this is ERG’s support to MCAQD’s Planning and Analysis 
Division from 2016 to 2021 under the previous Air Quality Rule Development Technical Support contract (SERIAL 
#16077-RFP). Task orders under that contract focused on rule-specific Reasonably Available Control Technology 
(RACT) and economic analyses for nine rules (i.e., Rules 323, 324, 332, 336, 342, 350, 351, 352, and 353); RACT-
only analyses for two other rules (i.e., Rules 322 and 342); review of MCAQD’s RACT SIP; impacts of rule recissions 
of four rules (i.e., Rules 317, 325, 334, and 339); benchmarking of Arizona’s emission reduction credit (ERG) banking

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system; and review of MCAQD’s draft New Source Review (NSR) rules. We expect similar types of analytical work 
to be issued under this Primary Task.
SIP development
Our discussion of technical analyses conducted for SIP development is included in Section 1.2.5 of this proposal.
Socioeconomic Impacts
Our discussion of the technical analyses conducted for socioeconomic impacts is discussed in Section 1.2.5 of this 
proposal.
Exceptional Event Demonstration
In 2016, EPA published a final rule and final guidance on how to treat data influenced by exceptional events as 
required by section 319(b) of the Clean Air Act. We will build upon our experience in conducting the first periodic 
review and evaluation of ADEQ’s dust mitigation plan for PM10 nonattainment areas in the state. ADEQ developed 
and submitted the state’s dust mitigation plan to EPA in 2018 (also known as Exceptional Event Mitigation Plan). 
This mitigation plan covered four of the PM10 nonattainment areas in Arizona identified by EPA as subject to the 
mitigation plan requirements in 40 CFR 51.930(b) (2016 exceptional events rule). Under this work, we reviewed 
ADEQ’s 2018 dust mitigation plan working with various stakeholders such as Arizona Department of Transportation 
(ADOT), Maricopa County Air Quality Department (MCAQD), Maricopa Association of Governments (MAG), Pima 
County Department of Environmental Quality (PDEQ), Pinal County Air Quality Control District (PCAQCD), and 
Yuma County. We updated the dust mitigation plan based on information compiled during the review process and 
performed a qualitative assessment of the effectiveness of mitigation plan components such as air quality forecasting, 
monitoring, public notification programs, and educational programs.
Emission Inventory, Periodic Emission Inventory (PEI), and Greenhouse Gas (GHG) Emissions Inventory 
Key components of regulatory planning and analysis are the emission inventories. ERG has several decades of 
experience developing emissions inventories and analyzing inventory data. ERG is nationally known for developing 
emission inventories for the U.S. EPA, Arizona, California, Texas, other U.S. states, as well as the first Mexico 
National Emissions Inventory (INEM 1999). Over the past several years, ERG developed multiple emission 
inventories for Mexico, including the U.S.-Mexico border region. ERG has also developed several modeling 
inventories covering the United States, Canada, and Mexico in support of modeling efforts by the Maricopa 
Association of Governments (MAG). For the past 10 years, ERG’s proposed Project Manager and Deputy Project 
Manager have been directly involved in the development of emission estimates for Natural Gas and Petroleum Systems 
in the U.S. National Greenhouse Gas Emissions Inventory. In addition, ERG’s proposed Project Manager and Deputy 
Project Manager and other technical staff have been improving emission factors and inventory estimates for a number 
of source categories for the California Air Resource Board, including: surface cleaning and degreasing, marine 
petroleum loading and unloading, wine fermentation and aging, and non-electroplating sources of hexavalent 
chromium. 
The main aspects of ERG’s technical approach in developing emission inventories are as follows: 
Define inventory scope. Defining the inventory scope is an essential first step for any emissions inventory. This 
consists of characterizing the following aspects of the inventory, typically in an Inventory Preparation Plan: base year, 
geographic domain, source types, pollutants, geographic resolution, temporal resolution, and inventory projections.
Identification of preferred and alternate estimation methods. The choice of the estimation method will likely be 
driven by availability of required data. Emissions for most area source categories can be estimated using emission 
factors and relevant activity data. Default emission factors are available from the U.S. EPA and other state sources 
(e.g., CARB). ERG may also review recent peer-reviewed research studies (e.g., journal publications) to identify 
relevant data that can be used to develop source-specific emission factors. In some cases, depending on data 
availability, other estimation methods such as mass-balance can be used to estimate emissions. For example, VOC 
emissions from autobody refinishing can be estimated using the quantity of coatings used within the inventory domain 
and their VOC contents.
 
Compile/develop activity data. Activity data required for estimating emissions will depend on the estimation method. 
ERG will compile the required data, primarily from publicly available sources (e.g., Energy Information 
Administration (EIA), U.S. Census Bureau, and U.S. Department of Agriculture (USDA)). As needed, under 
MCAQD’s direction, ERG will conduct data surveys to compile activity data for specific area sources of concern. For 
example, autobody refinishing businesses and/or industry group(s) can be surveyed to compile solvent-based coatings

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quantities. Additionally, for some sources, activity data can be purchased from 3rd party vendors (e.g., market research 
companies and industry group or trade association publications). 
Compile/develop emission factors. ERG will identify the most recent emission factors. As noted above, default 
emission factors are available from the U.S. EPA and CARB for many source categories. ERG will also review 
research studies and data to identify required emissions and activity data (e.g., emission measurements, production 
throughput, energy usage, and equipment counts) that can be used to develop emission factors for certain emission 
sources. As directed by MCAQD, ERG can also develop Arizona-specific emission factors for certain area source 
categories such as solvent evaporation categories. For example, “top-down” methods using solvent data (sales or 
consumption) along with employee counts can be used to develop per-employee VOC emission factors. Alternatively, 
emission factors can also be developed using “bottom-up” methods such as solvent end-user survey. 
Other inventory inputs. After developing base year uncontrolled estimates, ERG will perform the required 
adjustments to account for point source reconciliation and area source controls. Point source reconciliation is needed 
to avoid double-counting between area and point source types. For example, state-level industrial natural gas fuel 
consumption data includes fuel consumption at point source facilities and area sources. In order to avoid double-
counting, point source reconciliation is performed by deducting either point source fuel usage or emissions from area 
source fuel usage or emissions. Similarly, base year uncontrolled estimates must be adjusted to account for controls. 
Point sources. ERG will compile reported point source inventory data from various sources such as MCAQD’s point 
source inventory and permit data, ADEQ’s point source inventory, and the U.S. EPA’s NEI and Toxics Release 
Inventory (TRI) data. As directed by MCAQD, ERG will perform a QC review of the compiled data. Outliers and 
inconsistent data will be flagged, and ERG will perform corrective actions to improve data quality. For example, we 
may find it necessary to replace reported emissions with estimates calculated using activity data and emission factors. 
Alternatively, ERG can conduct a data survey amongst the identified point source facility population to identify 
emission sources and compile required data to estimate emissions (i.e., data on emissions activity, fuel consumption, 
control equipment, etc.). ERG can then develop emission estimates from the compiled survey data. Additionally, 
required data for point source air quality modeling (e.g., stack parameters and coordinates) can be compiled from 
sources such as ADEQ, U.S. EPA, local air agencies, and data surveys. We will review compiled data for accuracy 
and outliers will be corrected and/or replaced by default data. As requested by MCAQD, ERG will input point source 
data into MCAQD’s IMPACT’s database. 
Auditing Inventories. As requested by MCAQD, ERG will audit existing MCAQD records, correct erroneous entries, 
and enter missing data. We will review each subject emissions unit (EU) and compare information provided by the 
permittee with emission and physical information recorded in IMPACT. These data will be further compared to EUs 
listed in the current permit. MCAQD will be notified where discrepancies exist. We will work in conjunction with 
MCAQD staff to establish the appropriate EUs to be included in IMPACT. Once the final list of EUs has been 
approved, ERG will input the EUs into IMPACT along with available emission information and physical parameters 
of the equipment and processes.
Other considerations – ERG will conduct inventory development considering temporal resolution, spatial resolution, 
future projections, and ensuring appropriate documentation and data files are developed. 
Temporal resolution will rely primarily on the underlying data, such that the greatest resolution will be 
maintained (e.g., daily, monthly, annually, etc.) throughout the calculations. As needed, ERG will 
develop temporal activity and emissions profiles to meet the requirements of the inventory scope, 
including episodic events such as stagnation or high wind episodes. Depending on the required 
resolution, ERG will develop temporal profiles for average daily activity, average summer daily activity, 
and average winter daily activity. Default temporal activity profiles are available from the U.S. EPA and 
temporal profiles can also be developed using data from public sources such as U.S. Census and EIA 
(e.g., heating degree days or monthly manufacturer shipment values). 
ERG will develop emissions at the spatial resolution defined in the inventory scope. ERG will retain the 
base data resolution throughout the calculations and sum/adjust as needed to meet inventory scope, 
match EPA modeling needs, etc. Priority will be placed on local data, relying on coarser data and spatial 
surrogates from the U.S. EPA’s modeling platform as needed to gap-fill local/regional data. Inventory 
emissions estimates can be represented as vector (i.e., point, line, and polygon) and/or raster (i.e., 
gridded) formats. Emissions will be represented at the most granular resolution possible, as determined

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by available input data. If a spatial component is not inherent in the input data, appropriate spatial 
surrogates will be identified and used to properly allocate activity and emissions throughout the 
modeling domain. Geodata can be provided in a format easy to pull into standard GIS software for 
future MCAQD needs. For point sources, ERG will compile facility geographic coordinates. We will rely 
on existing inventory data, permit data, geocoding services, and data surveys to compile spatial data for 
the point source inventory. QA and gap-filling will be conducted to address errors and omissions to the 
extent possible, using historical and open-source data as applicable. 
ERG will develop projection factors to project the base year emissions inventory to future years. For 
most of the source categories (and source types), projection factors can be developed using surrogates 
such as economic growth, industrial/manufacturing growth, energy demand, population growth, and 
land use/land change projections. ERG will compile the data needed to develop projection factors from 
public sources such as EIA and the Census Bureau. As needed, ERG will also review permit data to 
develop projection factors for certain point source facilities. Spatial representations will also be adjusted 
as needed to account for changing activities in projected years (e.g., new point source facilities coming 
online in future years). 
ERG will develop detailed documentation of input data and data sources. We will author reports that 
include detailed description of inventory characterization, estimation methods, input data and sources, 
assumptions used, sample calculations, summary of results, discussion on representativeness of input 
data and accuracy of results, and recommendations for future work. Along with the inventory 
documentation, we will also provide copies of all publicly available data used in developing the 
emissions inventory. As needed, ERG will provide the emission inventory in the desired format (e.g., air 
quality model input files). 
Air Quality Modeling
ERG has extensive experience applying air dispersion models (e.g., AERMOD and AERSCREEN), particularly for 
air permitting and regulatory compliance/enforcement. Specifically, ERG has used air dispersion models to conduct 
ambient impact assessments for permitting projects in Arizona, Maryland, and Washington D.C. For example, ERG 
recently completed screening modeling to evaluate fenceline xylene concentrations from spray coating operations at 
a metals fabrication facility in Maricopa County. The permit package that ERG developed for this facility included a 
summary of model results and the associated input/out files.
ERG typically begins a modeling project by developing a modeling protocol that identifies the project objectives, 
outlines our modeling approach, and summarizes the overarching technical and regulatory framework used to develop 
the modeling approach. The protocol will outline any assumptions and/or limitations inherent in the modeling 
approach. ERG will provide a draft modeling protocol to Maricopa County, so as to provide the opportunity for client 
feedback. ERG will provide Maricopa County with a complete set of model inputs/outputs and a summary writeup, 
which describes any deviations from the modeling protocol, outlines QA/QC and model validation procedures, discuss 
limitations and uncertainties, and provide recommendations for further analysis.
Geographic Information Systems (GIS)
ERG offers an extensive range of integrated services to take full advantage of geographically referenced information. 
With over 20 years of experience in Geographic Information Systems (GIS), ERG has a history of excellence in 
geospatial analysis, data generation, network creation, suitability analysis, and data modeling. Our certified GIS 
professionals work closely with clients to apply high-quality GIS technology in cartography, geodatabase creation, 
and geoprocessing to inform environmental questions, solve environmental problems, and communicate research 
results. 
Data Curation and Creation: ERG staff have the requisite technical and environmental knowledge to identify high-
quality GIS data sources, create customized original data and accompanying metadata, and perform advanced 
geospatial analyses to meet project needs. ERG staff are well versed in authoritative data sources including U.S. 
Census Bureau demographic data; NLCD land cover data; Bureau of Transportation Statistics highway, rail, and other 
transportation data. ERG regularly converts between spatial and nonspatial data formats to facilitate data sharing, 
editing, and review.
Data Visualization: ERG has extensive experience integrating complex variables and providing clear results and 
dynamic tools for users to answer environmental questions. Custom maps highlight research goals, issues, and results

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and are specialized for presentation or publication needs. Web-based GIS interfaces allow users worldwide to 
interactively access data and investigate scenarios without the need for advanced GIS software or experience. 
Information Technology ERG’s GIS experts team up with project managers, database designers, Web programmers, 
and technology analysts to provide comprehensive technical services from start to finish. This unique approach allows 
ERG to produce state-of-the-art GIS solutions tailored to specific needs now and in the future, from providing graphics 
for documentation to generating new GIS data layers for future analyses. 
Data Analysis: ERG can provide insightful evaluations of the relationships between emission inventory estimates and 
actual measured pollutant ambient concentrations. We assess meteorological data and conduct back trajectory analyses 
to identify potential emission sources and evaluate ambient and inventory data correlation. Additional geospatial 
support could include hot spot analysis, trend analysis in spatial patterns over time, proximity and other geospatial 
analyses, and data visualization products for communications. Geospatial services could include assistance in devising 
an air quality monitoring approach; communicating needs and actions to researchers, administrative partners, and the 
public; collaborative mapping exercises to obtain input from stakeholders, including vulnerable communities and 
others impacted by air quality issues; curation of custom data both from and for modeling efforts.
Network Analysis: ERG has unique and specialized experience and capabilities in transportation network creation 
and analysis. ERG also created a dynamic railroad model that integrates several different activity data sources along 
with a spatial network of railway tracks to provide segment, county, and state level activity and emissions by SCC 
code. The model was further enhanced with segment-specific growth factors to facilitate visualization and analysis of 
changing railroad activity and emissions through 2020.
Primary Task 8 — Air Monitoring Technical Assistance
Introduction
ERG’s Measurements Group has provided high-quality air monitoring and sampling support services to Federal, State, 
Local, and Tribal clients for almost four decades. With our experience and expertise, we will continue to provide the 
same level of support to Maricopa County. ERG's experience along with our laboratory facility designed and equipped 
specifically to support client air quality programs, means we are ready to do the work requested by MCDAQ as area 
of work experts without steep learning curves, equipment acquisition, or other startup delays. We have continuously 
developed new techniques and approaches to meet the growing needs of client’s regional air quality monitoring, 
community-based exposure investigations, or target specific investigative needs. The foundation of our success is our 
proven quality assurance system and history of helping clients develop 
project specific quality assurance plans. ERG understands the need for 
quality and defensibly data from field sampling and monitoring activities 
and will continue our recognized high-quality services to meet these 
objectives.
ERG’s laboratory supports clients like U.S. EPA and the U.S. Centers for 
Disease Control and Prevention with high quality data that meet the 
National Ambient Air Quality Standard for lead and are a National 
Environmental Laboratory Accreditation Program (NELAC) certified 
laboratory for many hazardous air pollutants (HAPs). We are frequently 
audited by NELAC and EPA and participate quarterly in proficiency 
testing program where samples with a known concentration are analyzed 
and results based on the recovery determine how well our lab’s 
performance is. ERG staff write, review, and adhere to EPA Level 1 
Quality Assurance Protocol Plans, which are the highest level of quality 
mandated by EPA. Aside from our corporate quality plan the ERG lab 
maintains its own library of standard operating procedures (SOP) that are 
strictly followed, reviewed annually, and updated often. We are more than 
prepared to deliver the highest quality of data for MCDAQ.
Technical Approach
The following technical approach is based on 39 years of experience 
supporting multiple client’s monitoring and sampling needs. We will 
continue to refine our approach as necessary to ensure high-quality, 
representative sample collection. ERG will conduct the following base tasks to support MCAQD in any requested 
effort. These tasks can be modified for any monitoring effort whether fenceline monitoring, community based 
monitoring, method research and development, sensor network, or geospatial. 
Figure 1 ERG deployed SPOD which is a 
sensor-based monitor that measures VOCs 
and collects a canister sample when an 
ambient threshold is exceeded.

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Perform site logistics and coordination. At the onset of program activities, ERG contacts participants to 
discuss field shelter and utility requirements, field staff requirements, and the schedule for site 
installation and sample collection. Pre-siting surveys can also be performed with handheld or geospatial 
monitoring platforms to determine the optimal locations when developing a monitoring network or 
siting samplers. 
Develop project specific plans. ERG will develop needed quality assurance, work, sampling, or health 
and safety plans necessary. We have developed countless plans to ensure work is being done according 
to clients’ needs and provide them with the level of data required. This same level of foresight and 
planning will be continued to support MCAQD. When necessary, project specific data or measurement 
quality objectives can be established to ensure all project requirements are met and documented. 
Quality Assurance Plans will be developed as part of each assigned task to establish data quality objectives. 
These will inform MCAQD or other data users that data collected are of the highest quality and met agreed upon 
standards. If any quality objectives are not met MCAQD staff will be informed and data will be flagged as 
necessary. If these situations happen the root cause of the issue will be found and documented to inform future 
analysts how to avoid the same issue and see that it does not reoccur. 
Provide monitoring and sample collection systems. ERG provides project specific sample collection 
systems in accordance with project specific requirements. Many sample collection systems are 
designed, fabricated, and owned by ERG. In the event where ERG cannot provide a system one will be 
sourced, if possible, from one of our frequently used vendors for the time of the work being performed. 
If equipment is provided by MCAQD, ERG has experience with many monitoring technologies and 
equipment for criteria pollutants and hazardous air pollutants (HAPS). We’ve sourced, tested, deployed, 
operated, and maintained equipment for federal, state, and local clients across the country and are 
prepared to bring this experience to support MCAQD.
Perform sample collection system certification. Prior to field deployment, ERG certifies (non-biasing and 
functional) each monitor or sampling system. ERG has performed thousands of sampler certifications for 
our own equipment as well as equipment produced by commercial vendors. After certification, ERG 
supplies the certified systems for use in the field. Certifications typically first involve checking all working 
components like pumps, flow controllers, and temperature sensors to make sure they are with 
specifications. Systems are then typically assessed with a zero air standard to determine if there are any 
contaminations or bias in the system. A certified standard or pollutants is typically the final test to verify 
the monitor is accurate or the sampling system is meeting method specifications. 
If samplers or monitoring equipment do not pass certifications or quality checks for any reason, we will work 
with vendors to determine the issue, work with MCAQD or the vendor to correct the issue, and bring the equipment 
back into control. 
If the need is sensor-based ERG can source a site with a Federal Regulated Method (FRM) or Federal 
Equivalent Method (FEM) equipment to compare against the sensor for a pre-determined period of time prior to 
deployment. This will characterize the accuracy, precision, bias, or climate condition effects of each sensor prior to 
deployment. This will help determine if each sensor should be deployed or if any data corrections need to be done 
prior to reporting data publicly.

SERIAL# 230178-RFP
Perform sample collection system installation. After the 
field site has been established and the sample collection 
systems have been certified, an ERG staff member travels 
to the sampling site, installs the collection system(s), 
checks all system functions, and initializes the sampling 
per the project specific sampling calendar. This could be 
sampling devices that collect canister, filter, PUF, or resin-
based sampling media. 
Sensors and other real-time monitoring equipment will be 
treated with the same care. ERG has installed, operated, and 
trained operators on sensor and real-time monitoring equipment 
and understand all aspects of installation and operation. 
Manage or perform sample collection activities. After 
the initiation of sample collection, ERG reviews or 
performs collection activities. Oversight is maintained 
continuously to identify and troubleshoot sample 
collection issues if they arise. Communication will be maintained with Maricopa County staff throughout 
any monitoring or sampling effort to ensure everyone is briefed on status of operations.
For larger data sets generated by continuous monitoring technologies like sensors, periodic summaries can be 
generated that provide MCDAQ with quick results that are easy to understand and get a picture of what is being 
measured by the instruments. We’ve also supported clients by producing online dashboards and public facing 
websites that quickly allow individuals to see understandable data at a glance. As with our work with CleanAire NC, 
we can also provide deeper data analytics to determine the status of sensors or monitors in a network, whether 
monitors are in good locations near potential sources of emission, where sensors or monitors are needed, or whether 
underserved communities are being represented in the data. 
Sample Analysis. Based on project needs sample analysis can be performed by ERG for several EPA 
Compendium and Specialty Methods including:
o TO-11,
o TO-12/ASTM D5953M,
o TO-13A,
o TO-15/TO-15A,
o EPA SW-846 Method 8270D,
o IO-3.5,
o Speciated Nonmethane Organic Compounds,
o ASTM D7614, and
o Gravimetric Analysis of Filters.
When an analysis is required that ERG does not perform a suitable laboratory will be sourced based on quality 
and pricing that meets the needs of the project. 
Technical Writing and Report Preparation. ERG will prepare periodic summary, field, analytical, or final 
reports based on project requirements. The reports can include summaries of activities or findings, 
analytical reports of analyzed samples and data quality metrics, deviations for previously established 
plans, and any other necessary information that Maricopa County will require. All data reports will 
present results that are clear, reproducible, and easy to understand. Prior to developing these reports, 
ERG will communicate with Maricopa County about any changes, updates, or revisions needed for the 
next iteration. We follow the proven techniques of our Quality Management Plan (QMP) process in 
preparing the data for summary and statistical analyses. We present results that are completely 
transparent and consistent, such that meaningful conclusions can be reproduced and verified by all 
stakeholders. Over the past 39 years, we have characterized and reported data for several hundred 
sites, resulting in millions of sampling and monitoring data points.
Figure 2 An ERG deployed community monitoring 
campaign to measure respirable crystalline silica and 
other particulate matter near a silica plant.

SERIAL# 230178-RFP
Exhibit C – Office of Procurement Services Contractor Travel and Per Diem Policy
1.0
All contract-related travel plans and arrangements shall be prior-approved by the County contract 
administrator.
2.0
Lodging, per diem, and incidental expenses incurred in performance of Maricopa County/Special 
District (County) contracts shall be reimbursed based on current U.S. General Services 
Administration (GSA) domestic per diem rates for Phoenix, Arizona. Contractors must access the 
following internet site to determine rates (no exceptions): www.gsa.gov.
2.1
Additional incidental expenses (i.e., telephone, fax, internet, and copying charges) shall 
not be reimbursed. They should be included in the contractor’s hourly rate as an overhead 
charge.
2.2
The County will not (under any circumstances) reimburse for contractor guest lodging, per 
diem, or incidentals.
3.0
Commercial air travel shall be reimbursed as follows:
3.1
Coach airfare will be reimbursed by the County. Business class airfare may be allowed 
only when preapproved in writing by the County contract administrator as a result of the 
business needs of the County when there is no lower fare available. 
3.2
The lowest direct flight airfare rate from the contractor’s assigned duty post (pre-defined at 
the time of contract signing) will be reimbursed. Under no circumstances will the County 
reimburse for airfares related to transportation to or from an alternate site.
3.3
The County will not (under any circumstances) reimburse for contractor guest commercial 
air travel.
4.0
Rental vehicles may only be used if such use would result in an overall reduction in the total cost 
of the trip, not for the personal convenience of the traveler. Multiple vehicles for the same set of 
travelers for the same travel period will not be permitted without prior written approval by the County 
contract administrator.
4.1
Purchase of comprehensive and collision liability insurance shall be at the expense of the 
contractor. The County will not reimburse a contractor if the contractor chooses to purchase 
this coverage.
4.2
Rental vehicles are restricted to sub-compact, compact, or mid-size sedans unless a larger 
vehicle is necessary for cost efficiency due to the number of travelers. (NOTE: Contractors 
shall obtain pre-approval in writing from the County contract administrator prior to rental of 
a larger vehicle.)
4.3
County will reimburse for parking expenses if free, public parking is not available within a 
reasonable distance of the place of County business. All opportunities must be exhausted 
prior to securing parking that incurs costs for the County. Opportunities to be reviewed are 
the DASH, shuttles, etc. that can transport the contractor to and from County buildings with 
minimal costs.
4.4
County will reimburse for the lowest rate, long-term, uncovered (covered or enclosed 
parking will not be reimbursed) airport parking only if it is less expensive than shuttle 
service to and from the airport.
4.5
The County will not (under any circumstances) reimburse the contractor for guest vehicle 
rental(s) or other any transportation costs.
5.0
Contractor is responsible for all costs not directly related to the travel except those that have been 
pre-approved by the County contract administrator. These costs include, but are not limited to, the

SERIAL# 230178-RFP
following: in-room movies, valet service, valet parking, laundry service, costs associated with 
storing luggage at a hotel, fuel costs associated with non-County activities, tips that exceed the per 
diem allowance, health club fees, and entertainment costs. Claims for unauthorized travel 
expenses will not be honored and are not reimbursable.
6.0
Travel and per diem expenses shall be capped at 15 percent of project price unless otherwise 
specified and approved by the County in individual contracts.
7.0
Contractor shall provide, (upon request) with their invoice(s), copies of receipts supporting travel 
and per diem expenses, and, if applicable, with a copy of the written consent issued by the County 
contract administrator. No travel and per diem expenses shall be paid by County without copies of 
the written consent as described in this policy and copies of all receipts.