Evaluation of SIP Attainment Demonstrations

For the following cities: Miami & Douglas

June 7, 2001 
3601 Via De La Cometa 
Green Valley, Arizona 85614 
Evaluation of SIP Attainment Demonstrations for Miami and Douglas, Arizona

Dear Mr. McKenna: 
I appreciated the discussion we had recently regarding the re-designation of S02 non-attainment areas in Miami 
and Douglas, Arizona. Since the closure of copper smelter operations in those two towns in the 1980’s, the 
improvement in air quality has been apparent. However, the specific and detailed data required to officially 
achieve redesignation as attainment areas for the S02 National Ambient Air Quality Standards (NAAQS) are 
difficult to obtain and defend. The required evidence that must be presented in a State Implementation Plan 
(SIP) attainment petition is quite extensive. It is clear from the redesignation petition materials I reviewed that 
your personal effort in this area was comprehensive and resourceful. Evidence of improvement in air quality 
was obtained from a variety of non-traditional sources, and the analysis of the data was insightful and concise. 
As to the monetary value of the work, that is difficult to precisely define. If an independent contractor, such 
as URS, were to prepare similar documentation packages and analyses I would estimate that the total cost 
would be in excess of $75,000. Another measure of the value of this work is the untold long-term economic 
benefit to Miami and Douglas. Without the burden of non-attainment status, these areas may more readily 
attract development and economic growth that will improve the lives of its citizens. 
I wish you the best of luck in your future endeavors. 
URS Corporation 
Robert W. Farmer, .D.. P.E. 
Senior Chemical Encineer 
Team Leader, Air Quality Services 
RWF Correspondence File 
URS Corporation 
7878 North 16th Street. Suite 200 
Phoenix, AZ 85020 
Tel: 602.371.1100 
Fax: 602.371.1615

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