San
Juan
County,
New
Mexico
Early
Action
Compact
for
Ozone
Clean
Air
Action
Plan
March
2004
Prepared
by:
New
Mexico
Environment
Department,
Air
Quality
Bureau
City
of
Aztec,
New
Mexico
City
of
Bloomfield,
New
Mexico
City
of
Farmington,
New
Mexico
San
Juan
County,
New
Mexico
Submitted
to:
United
States
Environmental
Protection
Agency,
Region
6
ii
TABLE
OF
CONTENTS
LIST
OF
ACRONYMS
....................................................................................................
III
1.
INTRODUCTION...............................................................................................
1
2.
OZONE
IN
SAN
JUAN
COUNTY.................................................................
2
2.1
NATIONAL
OZONE
STANDARDS...............................................................................
2
2.2
OZONE
MONITORING
IN
SAN
JUAN
COUNTY............................................................
2
2.3
THE
1­
HOUR
OZONE
STANDARD
IN
NORTHWESTERN
NEW
MEXICO.........................
2
2.4
THE
8­
HOUR
OZONE
STANDARD
IN
NORTHWESTERN
NEW
MEXICO.........................
2
2.5
NONATTAINMENT
AREAS........................................................................................
3
3.
SAN
JUAN
COUNTY
EARLY
ACTION
COMPACT
FOR
OZONE
4
3.1
EARLY
ACTION
COMPACT
PROTOCOL
.....................................................................
4
3.2
SAN
JUAN
COUNTY
EARLY
ACTION
COMPACT
........................................................
5
3.2.1
Reporting........................................................................................................
6
3.2.2
Emissions
Inventories
.....................................................................................
6
3.2.3
Photochemical
Modeling
................................................................................
6
3.2.4
Maintenance
for
Growth
and
Future
Growth
Scenarios
..................................
6
3.2.5
Public
Involvement
.........................................................................................
6
3.3
SAN
JUAN
COUNTY
EARLY
ACTION
COMPACT
RESULTS
..........................................
7
4.
CLEAN
AIR
ACTION
PLAN
COMPONENTS........................................
8
4.1
STATE
IMPLEMENTATION
PLANS
AND
ENFORCEABLE
CONTROL
MEASURES
.............
8
4.2
PUBLIC
OUTREACH
CAMPAIGN
...............................................................................
8
4.2.1
Web
Site..........................................................................................................
8
4.2.2
Public
Service
Announcements
.......................................................................
9
4.2.3
Educational
Outreach
Materials
For
Children................................................
9
4.3
VOLUNTARY
PROGRAM
FOR
EMISSIONS
CONTROLS.................................................
9
iii
List
of
Acronyms
CAA
Clean
Air
Act
CAAP
Clean
Air
Action
Plan
EAC
Early
Action
Compact
EPA
United
States
Environmental
Protection
Agency
NAAQS
National
Ambient
Air
Quality
Standards
NMED
New
Mexico
Environment
Department
NOx
Nitrogen
Oxides
ppm
parts
per
million
PSA
Public
Service
Announcement
SIP
State
Implementation
Plan
VOC
Volatile
Organic
Compounds
1
1.
Introduction
In
December
2002,
the
New
Mexico
Environment
Department
(
NMED),
the
United
States
Environmental
Protection
Agency
(
EPA),
the
Cities
of
Aztec,
Bloomfield
and
Farmington,
and
San
Juan
County
entered
into
a
voluntary
agreement
to
research
and
analyze
air
quality
in
northwestern
New
Mexico
with
respect
to
the
8­
hour
standard
for
ground­
level
ozone.
The
agreement,
known
as
the
San
Juan
County
Early
Action
Compact
for
ozone
(
EAC),
set
forth
a
schedule
for
the
development
of
technical
information
about
the
formation
of
ozone
and
the
adoption
and
implementation
of
any
necessary
emissions
control
measures.
The
goal
of
the
EAC
is
to
ensure
San
Juan
County's
continued
compliance
with
the
8­
hour
ozone
standard
through
December
31,
2007.

This
document,
the
San
Juan
County
Clean
Air
Action
Plan
(
CAAP),
is
an
important
deliverable
under
the
EAC.
The
CAAP
synthesizes
results
of
extensive
ozone
modeling
into
a
discussion
of
measures
to
help
San
Juan
County
maintain
attainment
of
the
8­
hour
ozone
standard,
while
raising
public
awareness
of
the
issue.
The
following
sections
describe
the
ground
level
ozone
pollution
situation
in
San
Juan
County,
the
EAC
and
its
results,
and
components
of
the
CAAP
that
will
be
implemented
in
San
Juan
County.
2
2.
Ozone
in
San
Juan
County
2.1
National
Ozone
Standards
The
Federal
Clean
Air
Act
(
CAA)
is
the
comprehensive
law
that
regulates
airborne
emissions
from
area,
mobile,
and
stationary
sources
nationwide.
This
law
authorizes
the
EPA
to
establish
National
Ambient
Air
Quality
Standards
(
NAAQS)
for
several
pollutants
in
order
to
protect
public
health
and
the
environment.
The
EPA
currently
has
two
NAAQS
for
ozone:
the
1­
hour
peak
standard
of
0.12
parts
per
million
(
ppm)
and
the
8­
hour
standard
of
0.08
ppm.

2.2
Ozone
Monitoring
in
San
Juan
County
The
New
Mexico
Environment
Department
operates
two
continuous
ozone
monitors
in
San
Juan
County.
The
"
Substation"
ozone
monitor
is
located
west
of
Farmington
and
the
"
Bloomfield"
monitor
is
located
just
north
of
Bloomfield.
Ozone
monitoring
data
is
collected
by
NMED,
submitted
to
EPA,
and
used
to
determine
the
status
of
air
quality
in
the
northwestern
corner
of
New
Mexico
with
respect
to
the
ozone
NAAQS.

2.3
The
1­
Hour
Ozone
Standard
in
Northwestern
New
Mexico
To
meet
this
standard,
an
area
must
have
a
monitored
hourly
peak
ozone
concentration
at
or
below
0.12
ppm.
If
an
area
exceeds
the
standard
more
than
three
times
in
three
years,
it
is
subject
to
a
nonattainment
designation.
San
Juan
County
has
never
exceeded
the
1­
hour
ozone
standard.

2.4
The
8­
Hour
Ozone
Standard
in
Northwestern
New
Mexico
During
the
past
several
years,
8­
hour
average
ozone
concentrations
in
San
Juan
County
have
approached
the
8­
hour
ozone
NAAQS
of
0.08
ppm.
The
status
of
an
area
with
respect
to
the
8­
hour
standard
is
determined
by
averaging
the
fourth
highest
8­
hour
average
ozone
concentrations
from
each
of
the
most
recent
three
years.
This
number,
called
the
design
value,
must
be
equal
to
or
less
than
the
standard
concentration
for
an
area
to
meet
the
standard.
The
Substation
monitor's
current
design
value
(
averaging
from
the
years
2001,
2002,
and
2003)
is
0.0747
ppm
and
the
Bloomfield
monitor's
current
design
value
is
0.0743
ppm.
San
Juan
County
has
never
exceeded
the
8­
hour
ozone
standard.
Although
San
Juan
County
has
always
been
and
is
currently
in
attainment
of
the
8­
hour
ozone
standard,
signatories
to
the
San
Juan
County
EAC
will
strive
to
continue
to
meet
the
terms
of
the
EAC,
which
is
described
in
detail
in
3.2.
Failure
to
meet
the
obligations
of
the
EAC
will
result
in
immediate
reversion
to
the
traditional
process
of
nonattainment
designation,
if
the
area's
design
value
is
violating
the
8­
hour
NAAQS.
3
2.5
Nonattainment
Areas
Areas
formally
declared
in
violation
of
the
NAAQS
and
areas
contributing
to
a
violation
are
designated
"
nonattainment
areas."
Nonattainment
areas
must
meet
certain
Clean
Air
Act
requirements,
such
as:


Transportation
Conformity
­
Requires
a
demonstration
that
regional
long­
range
transportation
plans
will
not
negatively
impact
air
quality,
or
federal
transportation
funds
can
be
withheld.


New
Source
Review
­
Requires
a
review
of
new
or
modified
industrial
operations
to
minimize
air
pollution.


Rate
of
Progress
Requirements
­
A
certain
percentage
of
pollutants
must
be
reduced
each
year.


Specific
attainment
date
­
Consequences
of
failure
to
reach
attainment
by
the
specified
date
include
stricter
control
measures
and
the
potential
for
stiff
penalties.


10­
year
maintenance
plan
­
Includes
additional
or
continuing
mandatory
programs
for
10
years
following
redesignation
to
attainment.

Another
requirement
obligates
the
state
to
develop
and
implement
a
prescriptive,
enforceable
clean
air
plan
that
mandates
how
the
area
will
come
into
compliance
with
the
NAAQS
that
is
exceeded.
The
enforceable
clean
air
plan
and
revisions
to
it
are
known
as
the
State
Implementation
Plan
(
SIP).
4
3.
San
Juan
County
Early
Action
Compact
for
Ozone
3.1
Early
Action
Compact
Protocol
EPA
developed
the
Protocol
for
Early
Action
Compacts
(
EAC
Protocol)
during
2002.
In
exchange
for
relief
from
certain
provisions
of
the
nonattainment
area
requirements,
the
protocol
establishes
a
two­
step
process
that
offers
a
more
expeditious
time
line
for
achieving
the
8­
hour
ozone
standard
than
expected
under
EPA's
8­
hour
ozone
standard
implementation
rulemaking.
In
the
case
of
San
Juan
County,
the
8­
hour
ozone
NAAQS
is
achieved,
so
following
the
EAC
Protocol
allowed
the
signatories
to
complete
a
technical
modeling
analysis
that
gives
EAC
signatories
and
local
stakeholders
a
more
comprehensive
understanding
of
the
issue
and
aims
to
keep
the
area
within
the
standard.
The
principles
of
the
EAC
Protocol
to
be
executed
by
local,
state
and
EPA
officials
include
the
following:


Early
planning,
implementation,
and
emission
reductions
leading
to
expeditious
attainment
and
maintenance
of
the
8­
hour
ozone
standard;


Local
area
control
of
any
measures
to
be
employed,
with
broad­
based
public
input;


State
support
to
ensure
technical
integrity
of
the
Clean
Air
Action
Plan;


If
necessary,
formal
incorporation
of
the
Clean
Air
Action
Plan
into
the
State
Implementation
Plan
(
SIP);


Deferral
of
the
effective
date
of
nonattainment
designation
and
related
requirements,
if
applicable,
as
long
as
all
terms
and
milestones
are
met;
and

Safeguards
to
return
areas
to
traditional
nonattainment
SIP
requirements
should
terms
and/
or
milestones
go
unfulfilled,
with
appropriate
credit
given
for
emission
reduction
measures
already
implemented.

When
EPA's
8­
hour
implementation
guidelines
call
for
designations,
EPA
will
defer
the
effective
date
of
any
nonattainment
designation
and
related
requirements
for
participating
areas
that
fail
to
meet
the
8­
hour
ozone
standard
as
long
as
all
terms
and
milestones
of
the
EAC
are
being
met.
If
the
nonattainment
designation
is
deferred,
EPA
will
move
expeditiously
to
designate
the
area
as
attainment
and
impose
no
additional
requirements,
provided
that
the
monitors
in
the
area
reflect
attainment
by
December
31,
2007.

If
at
any
time
the
area
does
not
meet
all
terms
of
the
EAC,
including
agreed­
upon
milestones,
then
the
area
will
forfeit
participation
and
attainment
or
nonattainment
designation
(
or
redesignation
if
necessary)
will
become
effective.
The
EPA
will
offer
such
an
area
no
delays,
exemptions
or
other
favorable
treatment
because
of
the
area's
previous
participation
in
this
program.

If
an
area
violates
the
8­
hour
ozone
standard
as
of
December
31,
2007,
and
an
area
has
had
the
effective
date
of
any
nonattainment
designation
deferred,
such
nonattainment
designation
will
become
effective.
The
State
must
then
submit
a
revised
attainment
demonstration
SIP
revision
according
to
the
Clean
Air
Act
and
EPA's
8­
hour
implementation
rule,
unless
the
8­
hour
implementation
schedule
requires
SIPs
from
8­
5
hour
nonattainment
areas
before
December
31,
2008.
In
that
event,
a
revised
attainment
demonstration
SIP
revision
for
the
participating
area
will
be
due
as
soon
as
possible
but
no
later
than
December
31,
2008.
Under
no
circumstances
will
EPA
extend
the
attainment
date
for
the
area
beyond
that
required
by
the
CAA
and/
or
EPA's
8­
hour
implementation
rule.
The
region
will
not
be
allowed
to
renew
this
EAC
after
December
31,
2007
or
to
initiate
a
new
EAC
if
it
has
previously
forfeited
its
participation.

3.2
San
Juan
County
Early
Action
Compact
In
December
2002
the
state
and
local
governments
of
San
Juan
County
entered
into
a
Memorandum
of
Agreement
with
EPA
Region
6
consistent
with
terms
specified
in
the
EPA's
EAC
Protocol.
Signatories
to
the
agreement
include:


The
New
Mexico
Environment
Department

The
City
of
Aztec

The
City
of
Farmington

The
City
of
Bloomfield

San
Juan
County

U.
S.
Environmental
Protection
Agency,
Region
6
The
geographic
area
include
in
the
EAC
is
all
of
San
Juan
County,
excluding
the
Navajo
Nation
and
Ute
Mountain
Reservation.

The
EAC
photochemical
modeling
focused
on
four
distinct
elevated
ozone
episodes
during
the
summer
of
2002
within
a
longer
50­
day
ozone
period:


June
4­
8,
2002

June
16­
19,
2002

June
30­
July
2,
2002

July
16­
18,
2002.

The
EAC
established
several
planning
milestones
that
must
be
met
for
the
EAC
to
remain
in
effect.
The
milestones
are
as
follows:


June
16,
2003
 
Potential
state,
local
and
other
emission
reduction
strategies
identified
and
described
(
milestone
met);


March
31,
2004
 
NMED
must
propose
a
Clean
Air
Action
Plan

May
31,
2004
 
NMED
must
finalize
a
Clean
Air
Action
Plan

December
31,
2004
 
If
necessary,
NMED
must
complete
any
required
public
rulemaking
hearings,
adopt
the
Clean
Air
Action
Plan
as
part
of
the
New
Mexico
SIP,
and
submit
the
SIP
revision
to
EPA
for
approval

September
30,
2005
 
EPA
must
take
final
action
on
the
SIP
submittal

December
31,
2005
 
Any
mandatory
emission
reduction
strategies
are
to
be
implemented
no
later
than
this
date

December
31,
2007
 
Demonstrated
attainment
of
the
8­
hour
ozone
standard.
6
The
EAC
also
establishes
several
other
requirements
that
must
be
included
in
the
early
action
SIP
and
planning
process:

3.2.1
Reporting
The
NMED
assesses
and
reports
progress
towards
milestones
in
a
regular,
public
process,
at
least
every
six
months,
beginning
in
June
2003
and
concluding
in
December
2007.

3.2.2
Emissions
Inventories
The
National
Emission
Inventory
maintained
by
EPA
was
used
to
determine
point
and
mobile
source
emissions
for
San
Juan
County.
The
New
Mexico
Oil
and
Gas
Association
contributed
estimates
of
additional
emissions
from
oil
and
gas
exploration
and
production
activities
that
fall
below
air
permitting
thresholds.
Future
year
inventories
sufficiently
account
for
projected
future
growth
in
ozone
precursor
emissions
through
2007,
particularly
from
stationary,
area,
and
mobile
sources.
Emissions
inventories
were
compared
and
analyzed
for
trends
in
emission
sources
over
time.
All
adopted
federal
and
state
emission
reduction
strategies
that
have
been
or
will
be
implemented
by
the
December
31,
2007
attainment
date
are
included
in
all
emission
inventories.

3.2.3
Photochemical
Modeling
Base
and
future
case
photochemical
modeling
is
required
and
was
performed
with
technical
assistance
from
a
modeling
contractor.
All
modeling
is
SIP
quality
and
performed
within
EPA's
accepted
margin
of
accuracy
and
based
on
EPA's
guidance.
The
modeling
is
carefully
documented
in
a
series
of
reports,
sufficiently
accounts
for
projected
future
growth
in
ozone
precursor
emissions,
was
concurrently
reviewed
by
EPA
and
a
variety
of
technical
and
non­
technical
stakeholders,
and
was
used
to
determine
the
effects
of
changes
and
additions
to
the
emissions
inventory
for
future
years.

3.2.4
Maintenance
for
Growth
and
Future
Growth
Scenarios
The
modeling
includes
a
component
to
address
emissions
growth
at
least
5
years
beyond
December
31,
2007,
making
a
best
effort
to
ensure
that
the
area
will
remain
in
attainment
of
the
8­
hour
standard
during
that
period.
This
was
accomplished
with
a
modeling
run
for
the
year
2012.
Additional
future
modeling
runs
for
2007
focused
on
a
variety
of
growth
scenarios
dependent
on
changes
and
additions
to
the
components
of
the
emissions
inventory.
These
included
modeling
runs
that
incorporated
the
following:
ozone
source
apportionment
runs,
the
addition
of
two
new
coal­
fired
power
plants
to
the
area,
condensing
year
2012
oil
and
gas
exploration
and
production
to
occur
prior
to
2007,
increased
mobile
source
emissions,
doubled
area
source
emissions,
and
doubled
biogenic
emissions.

3.2.5
Public
Involvement
7
Public
involvement
was
vital
to
all
stages
of
technical
work
per
the
EAC.
Periodic
meetings
with
local
EAC
signatory
parties
were
held
by
NMED.
Several
meetings
with
the
Four
Corners
Ozone
Task
Force
and
the
public
were
held
during
the
course
of
the
technical
modeling
analysis
per
the
requirements
of
the
EAC.
Technical
decision­
making
and
modeling
was
performed
with
involvement
of
a
Technical
Peer
Review
Committee,
which
was
responsible
for
review
and
critique
of
work
plans
and
products.
The
Technical
Peer
Review
Committee
held
several
conference
calls
and
one
meeting.
NMED
solicited
and
received
input
from
stakeholders
continually
throughout
the
analysis
through
telephone
and
email
contacts.
Information
about
the
EAC
and
inventory
and
modeling
reports
are
available
to
the
public
on
the
Four
Corners
Ozone
Task
Force
webpage
(
http://
www.
nmenv.
state.
nm.
us/
ozonetf/).
Additionally,
the
project
has
been
well
publicized
in
the
local
press.
Articles
and
opinion
pieces
about
air
quality
and
ozone,
as
well
as
advertisements
and
press
releases
for
meetings,
appeared
in
local
newspapers.
Local
radio
and
television
broadcasts
focused
on
air
quality
and
ozone.

3.3
San
Juan
County
Early
Action
Compact
Results
The
results
of
the
EAC
modeling
indicates
that
San
Juan
County
is
expected
to
remain
in
attainment
of
the
8­
hour
ozone
standard
through
2007
by
a
substantial
margin.
Concentrations
of
ozone
are
predicted
to
remain
nearly
the
same
during
the
next
three
years.
Modeling
predicted
the
Substation
monitor's
2007
design
value
to
be
0.07437
ppm
and
the
Bloomfield
monitor's
2007
design
value
to
be
0.07249
ppm.

The
modeled
impact
of
adding
two
new
power
plants
in
the
Four
Corners
region
is
projected
to
have
minimal
impact
on
8­
hour
ozone
concentrations.
If
the
estimated
year
2012
development
of
the
San
Juan
Basin
oil
and
gas
field
is
accelerated
to
actually
occur
three
years
from
now
(
i.
e.,
by
2007)
the
modeled
impact
on
8­
hour
ozone
concentrations
is
expected
to
be
insignificant.
Impacts
on
8­
hour
ozone
concentrations
were
also
insignificant
when
on­
road
motor
vehicle
emissions
rates
were
increased
to
reflect
an
older
vehicle
fleet,
and
when
the
area
source
emissions
inventory
was
doubled.
In
addition,
the
impact
of
year
2012
emissions
on
8­
hour
ozone
concentrations
was
also
modeled
to
be
minimal.

The
impact
on
8­
hour
ozone
concentrations
was
greatest
when
biogenic
VOC
and
NOx
were
doubled,
indicating
that
an
exceedence
of
the
8­
hour
ozone
NAAQS
in
San
Juan
County
in
the
future
will
require
a
significant
increase
in
VOC
emissions
and/
or
heightened
VOC
reactivity.
8
4.
Clean
Air
Action
Plan
Components
4.1
State
Implementation
Plans
and
Enforceable
Control
Measures
The
purpose
of
the
CAAP
is
to
serve
as
San
Juan
County's
official
air
quality
improvement
plan,
with
quantified
emission­
reduction
measures.
The
CAAP
needs
to
include
necessary
elements
of
a
comprehensive
air
quality
plan,
but
must
be
tailored
to
meet
local
needs
and
driven
by
local
decisions.

One
of
the
milestones
of
the
EAC
is
the
formal
incorporation
of
the
CAAP
into
the
SIP
for
New
Mexico.
Included
with
the
incorporation
of
the
CAAP
is
the
adoption
of
enforceable
control
measures
for
reducing
ozone
forming
pollutants
within
the
EAC
area
as
a
means
of
maintaining
the
8­
hour
NAAQS
for
ozone.
Due
to
the
low
ozone
designed
values
that
have
been
modeled
for
the
EAC
area,
the
NMED
does
not
feel
that
these
results
indicate
that
mandatory
control
measures
are
needed
to
avoid
San
Juan
County
from
being
designated
nonattainment,
nor
are
any
measures
mandatory
at
present
in
order
to
model
2007
8­
hour
ozone
concentrations
in
San
Juan
County
that
are
within
the
8­
hour
ozone
NAAQS.
However,
the
San
Juan
County
EAC
signatories
are
committed
to
ensuring
that
their
area
remains
in
attainment
of
the
8­
hour
ozone
NAAQS.

The
EAC
signatories,
in
partnership
with
the
Four
Corners
Ozone
Task
Force
and
other
interested
parties,
have
compiled
the
components
of
the
San
Juan
County
Clean
Air
Action
Plan
described
in
the
following
section
as
a
best
attempt
to
keep
maintain
attainment
of
8­
hour
ozone
NAAQS.
Although
the
measures
to
be
taken
are
neither
mandatory
nor
enforceable,
they
represent
San
Juan
County's
best
effort
at
continuing
to
take
early
action
to
maintain
good
air
quality.
Additional
strategies
will
be
developed
and
implemented
to
meet
the
requirements
of
the
EAC
if
the
voluntary
strategies
outlined
in
the
CAAP
fail.

4.2
Public
Outreach
Campaign
4.2.1
Web
Site
NMED
will
develop
a
web
site
dedicated
to
the
dissemination
of
ozone­
related
outreach
material
related
to
the
San
Juan
County
EAC
region.
Included
in
the
web
site
will
be:


Health
related
information
developed
by
the
EPA;


Basic
ozone
information;


Ozone
monitoring
for
the
two
ozone
monitoring
sites
located
in
San
Juan
County;


Public
outreach
materials
of
children;


Related
ozone
studies
and
presentation
for
the
EAC
region;
and

Upcoming
meetings,
press
releases,
and
public
service
announcements.
9
4.2.2
Public
Service
Announcements
The
NMED
is
collaboration
with
the
local
governments
within
San
Juan
County
will
develop
a
series
of
public
service
announcements
(
PSA).
These
PSAs
will
advise
local
citizens
in
San
Juan
County
to
the
hazards
associated
with
ozone
pollution
and
how
to
reduce
ozone
forming
contaminates
in
their
daily
lives.
The
PSAs
will
be
aired
on
two
local
radio
stations
in
San
Juan
County
during
the
months
of
May
through
August.

4.2.3
Educational
Outreach
Materials
For
Children
The
NMED
has
created
an
ozone
education
workbook
for
children
between
the
ages
of
10
and
12
years.
The
workbook
takes
the
children
through
the
adventures
of
Tripper
the
cat
and
Bear
the
Hamster
as
they
learn
about
ozone
pollution
is
San
Juan
County.
Included
in
the
workbook
is
information
on
what
ozone
pollution
is,
how
ozone
pollution
is
created,
how
ozone
pollution
differs
from
stratospheric
ozone,
ozone
in
San
Juan
County,
and
how
to
reduce
ozone
pollution
at
the
local
level.
The
workbook
also
includes
a
color
poster
that
lists
ozone
pollution
reduction
suggestions.

4.3
Voluntary
Program
for
Emissions
Controls
The
emission
control
program
would
be
a
flexible,
voluntary
initiative
administered
by
the
NMED.
The
purpose
of
the
program
would
be
to
identify
and
promote
the
implementation
of
cost­
effective
technologies
and
practices
to
reduce
ozone­
forming
emissions
from
oil
and
gas
production.
Companies
that
choose
to
participate
in
the
program
would
be
recognized
by
the
NMED
as
Clean
Air
Partners
for
San
Juan
County.
The
program
would
be
modeled
after
the
EPA
Natural
Gas
Star
Program.
