UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 900 Seattle, WA 98101-3140

The Honorable Rudy Peone Chair, Spokane Tribe Business Council Spokane Tribe of Indians P.O. Box 100 Wellpinit, Washington 99040-0100

Subject: Offer for Consultation and Coordination on the U.S. Environmental Protection Agency's Review of and Action on the Spokane Second 10-Year Limited Maintenance Plan for Carbon Monoxide

Dear Chairman Peone:

The Spokane Regional Clean Air Agency, in coordination with the Washington State Department of Ecology (Ecology), contacted the U.S. Environmental Protection Agency requesting our review of a draft limited maintenance plan for carbon monoxide (CO) in the former Spokane nonattainment area (Spokane CO area). The Spokane area was designated nonattainment for CO upon enactment of the 1990 Clean Air Act amendments and includes the cities of Spokane, Spokane Valley, Millwood, and surrounding urban areas in Spokane County, Washington. Ecology submitted an attainment plan for the Spokane CO area on January 22, 1993, with the area coming into attainment of the National Ambient Air Quality Standards (NAAQS) in 1997. Monitored CO levels have declined steadily ever since, with the EPA formally redesignating the Spokane CO area from nonattainment to attainment status on June 29, 2005 (70 FR 37269).

Under the Clean Air Act, states must demonstrate that former nonattainment areas will continue to meet the NAAQS for two 10-year periods following redesignation to attainment. The first 10-year maintenance plan, covering the years 2005 through 2015, relied on the Federal Motor Vehicle Emission Control Program establishing emission standards for new motor vehicles (40 CFR Part 86), a motor vehicle inspection and maintenance program under Washington Administrative Code (WAC) 173-422, and an administrative order and amendment for the Kaiser Aluminum and Chemical Corporation Mead Works facility. Ecology is currently preparing a second 10-year maintenance plan, covering the years 2015 through 2025. This second 10-year limited maintenance plan would not change any of the control measures from the first 10-year plan, except to acknowledge the 2013 shutdown and dismantling of the Kaiser Aluminum and Chemical Corporation Mead Works facility.

A limited maintenance plan is an expedited means of meeting Clean Air Act requirements for an area that has previously been designated nonattainment, but has a low likelihood of violating the NAAQS again. Qualification under the limited maintenance plan guidance is based primarily on a demonstration of continued low levels of pollution at air quality monitors in the area. Based on the EPA's preliminary SEP'11 2015 OFFICE OF AIR, WASTE AND TOXICSreview of air quality data, the Spokane CO area appears to meet the limited maintenance plan

qualification criteria. Monitored levels of CO in the area are 2.3 parts per million (ppm), well below the NAAQS of 9.0 ppm and the limited maintenance plan threshold of 7.65 ppm (85 percent of the CO NAAQS).

We believe this is a noncontroversial action based primarily on confirmation of the most recent monitoring data available to us and because the second 10-year maintenance plan does not make changes to the existing plan; however, because the Spokane Tribe may have an interest in this area, we are offering consultation and coordination in accordance with the EPA Policy on Consultation and Coordination with Indian Tribes (www.epa.gov/tribal/consultation /consult-policy.htm).

Please have your staff notify Jeff Hunt at (206) 553-0256 by October 15, 2015, if you would like to schedule a consultation meeting or to request further information about the EPA's analysis of the limited maintenance plan. Furthermore, there will be future opportunities for tribal involvement through both the EPA's and Ecology's public comment processes. A comment period will be open for at least 30 days as part of Ecology's public comment process prior to final submission of the limited maintenance plan to the EPA. The EPA will also provide 30 days for public comment as part of any proposed action to approve or disapprove the limited maintenance plan following final submission. Feel free to call me at (206) 553-1271 if you have any questions.

cc: Mr. Twa-le Abrahamson Air Quality Coordinator, Spokane Tribal Natural Resources (e-mail)

Mr. James F. Zokan Environmental Specialist, Office of Ecosystems Tribal And Public Affairs Region 10 ate elly, P ctor Office of A' aste, and Toxics