By BARBARA HANEY
In an earlier column here, I argued that before the Department of Environmental Conservation splits the borough’s air quality area in two, it owes North Pole a look at the bill.
Since then, DEC has published a second, separate regulation package, and I have spent time reading the state’s own records on the monitor that drives North Pole’s numbers.
What I found raises a simpler question than cost. Before North Pole pays for a stand-alone cleanup plan, are we sure the instrument setting the target is giving us numbers we can trust?
A second package, published separately
On Oct. 25, DEC posted the “2026 18 AAC 50 Adoption Updates and Standard Conditions Regulations.” Most of it deals with Anchorage carbon monoxide and industrial permits. Two pieces matter to North Pole.
First, this package amends 18 AAC 50.030, the same section the North Pole split amends. The split package’s history note quietly reserved a slot for an “additional amendment” to that section without saying what it was. Now we know. Two rulemakings are changing the same section of the State Air Quality Plan at the same time, on different comment schedules, and neither notice mentions the other.
Second, the package adopts DEC’s Quality Assurance Project Plan for its air monitoring program. That is the rulebook for how monitors are calibrated, audited, and checked, and how bad data gets thrown out. The notice calls it the “revised and approved” plan. The file DEC attached is dated July 2023 and labeled Revision 0.
That plan governs the numbers behind every burn ban and every design value in North Pole. It deserves more attention than a line item buried in an Anchorage CO package.
The monitor behind North Pole’s numbers
North Pole’s air quality is judged largely by one station: the Hurst Road site, formerly called North Pole Fire Station #3. DEC describes it as the maximum-impact PM2.5 site in the nonattainment area, and it has recorded some of the highest readings in the nation. If the split goes through, this station will effectively define the North Pole area.
DEC’s own records raise two questions about it.
The site. Federal siting guidance says particulate monitors should not be placed in unpaved areas unless there is year-round vegetative ground cover. DEC’s site evaluation lists that criterion and, beside it, notes an adjacent gravel parking lot with relatively low traffic. DEC’s 2025 network plan nonetheless rates the site fully compliant, with no waivers. The guidance is phrased as “should,” not “must,” so DEC has some discretion. It still owes the public an explanation of why a gravel lot is acceptable at the most important monitor in the borough.
The real-time instrument. Hurst Road runs two kinds of PM2.5 monitors. Filter-based federal reference samplers produce the official numbers used to judge attainment. A continuous instrument, a BAM 1020, produces the hourly readings DEC uses to forecast and call curtailments. DEC’s 2023 network plan reported that at Hurst Road, the continuous monitor’s winter-quarter comparisons against the reference samplers did not meet the federal performance criteria for equivalent methods.
In plain terms: the instrument whose readings help trigger burn bans in North Pole did not, by DEC’s own report, keep pace with the official method in winter, which is exactly when burn bans are called.
None of this means North Pole’s air is clean. Wood smoke on a forty-below inversion night is real, and residents can see it. It does mean the state should show its work before it builds a separate regulatory area, and a separate set of future controls, around a single station.
What happens when the lights go out
There is one more gap, and this winter it may be the most urgent. Golden Valley Electric issued its first energy emergency alert on October 12, asking members to conserve and prepare for possible controlled outages. If those come, GVEA plans to rotate outages across its zones in roughly 30- to 60-minute intervals.
For many North Pole homes, no power means no furnace, no boiler, and no circulation pump. The wood stove becomes the only heat that works.
Neither of DEC’s new packages says a word about power outages. The only protection today sits in DEC’s Fairbanks Emergency Episode Plan, which requires curtailment exceptions when an outage prevents the use of other heat. The regulation itself does not name outages; it says only that each curtailment notice must list “any applicable exceptions.” Whether a family is covered depends on what DEC writes into each announcement.
That plan was not written for rolling outages. It does not say whether a household whose power drops for an hour at a time qualifies, or for how long. It does not suspend opacity enforcement for families burning in an emergency. Smoke from those nights still counts at the monitor, and against North Pole’s design value, unless DEC asks EPA to set those days aside and EPA agrees. The emergency plan is also built on today’s three control zones, and the split package does not update it.
A rule that carves out North Pole, the part of the borough most dependent on wood heat, should put outage protections in the regulation itself, in plain language, before the coldest months arrive.
What to ask, and when
North Pole residents now have two open comment periods, and both matter.
On the split, questions are due Friday, Nov. 20, and comments close at 11:59 pm Monday, Nov. 30. DEC holds a hearing at Hotel North Pole on Wednesday, Nov. 18, from 3:30 to 7:00 pm.
On the second package, DEC will hold its December 1 teleconference hearing only if someone requests it by 5 pm Monday, Nov. 23. Call Rebecca Smith at 907-465-5121 or email rebecca.smith@alaska.gov. Questions are due Tuesday, Dec. 1, and comments close at 11:59 pm Friday, Dec. 11.
Questions worth putting to DEC in writing:
- How do the two packages amending 18 AAC 50.030 fit together, and which is adopted first?
- Is the quality assurance plan being adopted the July 2023 version, or a newer revision?
- What is DEC’s justification for an unpaved site at Hurst Road, and what share of winter PM2.5 there is road or gravel dust, according to DEC’s own speciation data?
- Are the reference samplers ever operated below their rated temperatures, and how is data from those days handled?
- Given the continuous monitor’s winter performance, why are curtailments called on its readings?
- Will DEC release the last three winters of calibration, flow-check, and audit records for Hurst Road?
- During GVEA controlled outages, will curtailment exceptions apply automatically by outage zone, how long will they last, and will opacity enforcement be suspended?
- Will DEC write a power-outage exception into 18 AAC 50 itself, and will it seek EPA exceptional-event treatment for outage-driven smoke?
All comments go to dec.air.comment@alaska.gov, or through DEC’s online comment page under each package’s name.
North Pole has never asked to be excused from clean air. We are asking for numbers we can trust and rules we can read before the state draws a line around us.
Barbara Haney, PhD, is an economist, former Fairbanks North Star Borough Assembly member, and candidate for Alaska State House District 33.
One thought on “Barbara Haney: Before North Pole pays, check the monitor”
Question: Where are the air monitors placed? Usually they are placed at the area of highest concentration of particulate matter and noxious gases. This is done purposely to skew and drive the numbers up. A Democrat’s old trick in order to get the attention they want. And, the funding they want.