Evaluation of SIP Attainment Demonstrations
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.
Robert W. Farmer, .D.. P.E.
Senior Chemical Encineer
Team Leader, Air Quality Services
RWF Correspondence File
7878 North 16th Street. Suite 200
Phoenix, AZ 85020