Gregory Mendoza 

Governor 

Stephen Roe Lewis 

Lieutenant Governor 

GILA RIVER INDIAN COMMUNITY 

November 15, 2013 

Jared Blumenfeld 

Regional Administrator 

USEP A Region 9 

75 Hawthorne Street 

San Francisco, CA 94105 

Executive Office 

"A New Generation of Leadership Serving the People " 

RE: Designation and Boundary Recommendations by the Gila River Indian 

Community for the Revised Primary Annual Fine Particle (PM2.5) NAAQS (78 

Fed. Reg. 3086, January 15, 2013) 

Dear Mr. Blumenfeld: 

Under Section 107( d) and Section 301( d) of the Clean Air Act, tribes have one year after 

promulgation of a revised NAAQS or in the case of the revised primary annual PM2.

5 NAAQS, 

until December 13, 2013, to submit designation and boundary recommendations to the EPA 

Administrator. There then follows a sequence of communications and events that are described 

in a memorandum from Stephen D. Page, Director of OAQPS to EPA Regional Administrators 

(December 20, 2011). The guidance memorandum describes the procedures for collaboration 

between tribes and EPA during the designation process. These documents and the documents 

they reference establish the criteria for a nonattainment/attainment designation and the five 

factors EPA will evaluate in determining the nonattainment area boundaries. 

The Gila River Indian Community was previously designated attainment/unclassifiable 

on November 26, 2012 under the 2006 24 hour PM2.

5 NAAQS. In addition, the lands within the 

exterior boundaries of the Community were separated from the surrounding jurisdictions (Pinal 

County, Maricopa County) for the purposes of establishing designation boundaries. This original 

designation was based on monitoring data and the facts bulleted below. 

The purpose of this letter is to make both the designation and boundary recommendations 

under the Revised Primary Annual Fine Particle (PM2.5) NAAQS (78 Fed. Reg. 3086, January 

15, 2013). The designation and boundary determination process contemplated by the foregoing 

. documents and guidance is resource intensive and complex, but that process is simply 

unnecessary in the case of the Gila River Indian Community. Thus, the Community believes it 

can make its recommendations now. 

525 West Gu u Ki • Post Office Box 97 • Sacaton, Arizona 85147 • Telephone: (520) 562-9841 • Fax Line: (520) 562-9849 

web: www.gilariver.org 
Jared Blumenfeld 

November 15,2013 

Page 2 

The Community's recommendations are based on the following undisputed facts: 

• On September 21 , 2004, EPA concurred with the Community's decision to discontinue 

monitoring of PM2.5 concentrations within the external boundaries of the Community 

because PM2.s concentrations "are well below the NAAQS for PM25." 

• Thus, there are no measured concentrations of PM2.5 above the annual fine particulate 

NAAQS during the three-year period of concern. 

• There are no significant sources of PM2.

5 on Community land -- no combustion sources 

and no other significant sources of PM2.5• There are sand and gravel operations but the 

emissions from the crushing and screening activities at these operations are of much 

larger particles than PM2.5• 

• Elevated concentrations of PM2.

5 measured in Maricopa County to the north of and 

adjoining the Community are either from identified sources such as wood burning 

fireplaces during the Christmas season or are associated with other combustion sources 

associated with urban conditions. 

• Elevated concentrations of PM2.5 measured in Pinal County to the south of and adjoining 

the Community are also from identified sources such as huge cattle feedlots and dairy 

operations. 

• No activity or source on Community land is capable of making any significant 

contribution to elevated PM2.s levels measured in either County. 

In sum, there are no directly measured exceedances of the annual fine particulate 

NAAQS on the Community and no evidence to support a finding that sources or activities on the 

Community are contributing to off-Community measurements of elevated levels of PM2.

5 in the 

adjoining counties. 

For the foregoing reasons the undersigned, on behalf of the Gila River Indian 

Community, recommends that all land within the external boundaries of the Community be 

designated attainment for the Revised Primary Annual Fine Particle (PM2.5) NAAQS (78 Fed. 

Reg. 3086, January 15, 2013). 

Sincerely.,. 

___.. 

/ 

Gregory endoga(Governor 

GiJf Ri,v r Indian Community / 

Cc: Ondrea Barber, DEQ 

EPA R9 Air Division