1

 Law Office of Robert Ukeiley

507 Center Street ◦ Berea, Kentucky 40403 ◦ tel.859-986-5402 ◦ fax.866-618-1017

Robert Ukeiley

rukeiley@igc.org

VIA EMAIL

March 10, 2014

Jeff Hunt, EPA Region 10,

Office of Air, Waste and Toxics (AWT–107), 

1200 Sixth Avenue, Suite 900,

Seattle, WA 98101

Email: R10-Public_Comments@epa.gov

RE: Washington: Kent, Seattle, and Tacoma Second 10-Year PM10 Limited 

Maintenance Plan

Docket #: EPA–R10–OAR–2013–0713

Dear Mr. Hunt:

On behalf of the Sierra Club and its many thousands of members and supporters who are 

at risk of adverse impacts of exporting coal mined in the Powder River Basin (PRB) via ports on 

the West Coast, we are writing to comment on the United States Environmental Protection 

Agency’s (EPA) proposal to approve a limited second 10-year PM10 maintenance plan for Kent, 

Seattle and Tacoma (Maintenance Plan). EPA must disapprove the Maintenance Plan because, 

as explained below and as the picture below demonstrates, the Maintenance Plan fails to protect 

these areas from dramatic increases in PM10 caused by coal exports. 
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The Northwest is facing at least three new coal export facilities that would export coal 

mined in the Powder River Basin (PRB) to Asia. Coal would be transported via rail to the ports 

and then shipped abroad. There are also existing coal trains traveling through Washington to 

Canadian ports which could see significant increases in train traffic. Finally, trains carrying tar 

sands and/or Bakken oil to refineries may also rapidly increase. EPA did not address tar sands/oil 

causing increased locomotive traffic in the maintenance areas. Thus, it is imperative that the

Maintenance Plan adequately address these increases in PM10 emissions to ensure the PM10 

National Ambient Air Quality Standard (NAAQS) is maintained. 

I. EXPORT TERMINALS

Washington State has eleven deep draft ports, including seven in Puget

Sound, one on the Washington coast, and three on the lower Columbia River. Powder River 

Basin coal shipped on BNSF rail lines can access each port. Originally there were six potential 

coal terminals but due to strong public opposition only three proposals remain. The three 

remaining terminals include: Cherry Point/Bellingham, WA, Longview, WA, Port of Morrow, 

OR. There are also rumors of an additional facility being built by County Coal Limited but EPA 

did not address this possibility. Additionally, there are three terminals in Canada which are 

planning on dramatically increasing their coal exports, and some U.S. coal travels by rail through 

Washington to reach these ports. See Ex. 1 at Slide 4. 

A. Northwest Coal Export Proposals that would impact Kent, Seattle and 

Tacoma1

1. Cherry Point/Bellingham, WA: Gateway Pacific Terminal

The Gateway Pacific Terminal proposed by Peabody Coal and SSA Marine would export 

at 52.5 million tons of coal per annum (MTPA). Ex. 1 at Slide 4. The EIS scoping process 

concluded in early in 2013, and a draft EIS is expected in the next year or two.

2. Longview, WA: Millennium Bulk Terminals 

In late February of 2012 Millennium Bulk Logistics – in partnership with Arch Energy 

and Ambre Energy – filed an application with the Washington Department of Environmental 

Quality (DEQ) for a new coal export terminal at the existing bulk terminal site in Longview, 

WA.. The project application estimated the total coal capacity for the terminal at 48 MTPA. Ex. 

1 at Slide 4. Draft EIS scoping is currently underway for this project following a scoping period 

in the fall of 2013 that elicited over 210,000 public comments.

 

1

See Exhibit 2.
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3. Canadian Ports 

There are several operating coal export facilities in Canada, some of which are 

expanding—Westshore/Roberts Bank, Ridley, Neptune, and Port Metro Vancouver. Some 

capacity at these terminals is for coal from the PRB, much of which travels via Washington. 

Arch Coal announced that it had reached an agreement with Canadian Crown Corporation Ridley 

Terminals Inc. in Prince Rupert, British Columbia to export 2.5 million tons of PRB coal 

annually. This will increase to 5 MTPA. See Ex. 2 at Slide 4. There are also proposals to ship 

significant qualities of coal from the Vancouver and Roberts Bank facilities. Id. Cloud Peak 

exports at least 3.3 MTPA from its Spring Creek Mine in the PRB out of Westshore, and 

potentially as much as 4.7 MTPA from this port.

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The U.S. coal being shipped out of the 

Canadian ports is likely shipped via Washington through the Seattle and Tacoma area.

II. RAILROAD CONNECTIONS

A. Potential rail routes

BNSF Railway (formerly known as Burlington Northern Santa Fe) has major rail lines 

that stretch from the PRB to Washington, near Woodland and the port of Longview and Cherry

Point. The port at Longview has eight berths, seven of which are rail accessible in

varying capacities: directly accessible, direct transfer, transfer into storage and hopper to

rail. The port at Cherry Point will feature berths for three ships and will be linked to the

shore by a 1,250 foot trestle that will move cargo to or from the ships in enclosed

conveyor systems.3

One rail route for Canadian or Cherry Point coal would be from Billings, MT, west to 

Sandpoint, ID, and then northwest to Cherry Point/Bellingham (All BNSF lines for the 1,003 

rail miles). The same route extends to Canada.4 Additionally Cherry Point is projected to be 48-

54 MTPA. At volumes of 50 MTPA, that amounts to more than 22 loaded and coal trains, each 

more than a mile long. 

B. Impacts on Kent, Seattle and Tacoma

The proposed coal export terminals will cause communities along the rail line, from the 

Powder River Basin in Montana and Wyoming, to Idaho to Washington and beyond will 

experience increased rail traffic through their communities. In communities split by rail lines, 

this could significantly increase the amount of fugitive coal emitted into the air and water, impact 

local air quality from increased train and ship diesel emissions, delay traffic, cause delays for 

 

2

See http://www.businesswire.com/news/home/20110614005387/en/Cloud-Peak-EnergyAgrees-Terms-Terminal-Capacity#.Ux0_fIUlRgs; See also http://online.wsj.com/article/PR-CO20140213-917200.html (Cloud Peak exported 4.7 MTPA to Asia in 2013.)

3

See http://www.gatewaypacificterminal.com/project/what.shtml . 

4

See http://www.wstc.wa.gov/Rail/RailFinalReport.pdf
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emergency vehicles, increase noise pollution, and enhance the likelihood of pedestrian accidents 

and auto-train collisions.

There are several different communities across the western United States that

are currently and would increasingly be impacted by coal trains on a daily basis. Below is a list

of some of the different rail routing scenarios through Washington:

• Utilizing the northern line out of Spokane the communities through which trains travel include 

Wenatchee, Monroe (west side of Cascades), and then after meeting up with

the north-south running line, Everett, north of Seattle. 

• Taking the middle line out of Spokane the communities through which trains travel include

Kennewick, Yakima (including Yakima Indian Reservation), Ellensburg (on

outskirts of town), and then after meeting up with the north-south running

line, Auburn, just south of Seattle.

• Taking the southern line out of Spokane the communities through which trains travel include 

Kennewick, Vancouver turning north running along the I-5 corridor and

hitting the town of Centralia, then Lakewood entering the SeattleTacoma area, where the line then meets with the middle line at Auburn. Running

north from Auburn that line goes through Kent, Renton, Seattle, Richmond,

Edmonds, and then meets with the north line at Everett.

 At Everett all three lines merge and the one line runs north through

Marysville, Mt. Vernon, Burlington , Bellingham and into Canada. See Ex. 2; See also The Kent, 

Seattle, and Tacoma, WA Second 10-year limited maintenance plan for PM10, EPA-R10-OAR0714-0004 (Dk# 0004) at 5, 6, 7 (map of rail line running through maintenance areas). 

III. THE MAINTENANCE PLAN FAILS TO PROTECT KENT, SEATTLE AND 

TACOMA FROM INCREASING PM10 EMISSIONS FROM COAL EXPORT 

TRAINS.

A. EVEN ASSUMING ALL THE ANALYSIS IN THE SIP SUBMITTAL 

REGARDING THE CURRENT EMISSION INVENTORY AND AMBIENT 

PM10 LEVELS ARE CORRECT, THE SIP DOES NOT ENSURE THAT 

THE PM10 NAAQS WILL BE MAINTAINED. 

EPA explains that limited maintenance plans are appropriate when there is little risk of 

violating the PM10 NAAQS again. 78 Fed. Reg. at 78,311. The coal export trains create a 

substantial risk of Kent, Seattle, and Tacoma violating the PM10 NAAQS again. Therefore, 

EPA cannot approve this limited maintenance plan because it does not “ensure” maintenance. 

See 42 U.S.C. § 7505a(a). 

The 2011 emission categories include locomotives (including fugitive dust). 78 Fed. 

Reg. at 78,313. The SIP submittal calculated 4.8 million tons per year of coal being shipped as 
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part of the emission inventory. Actually, coal exports ranged from 30,581 tons in 2008 to 

4,854,451 tons in 2011 during the period from which EPA is relying on ambient monitoring data. 

Ex. 1 at Slide 3. As explained above, Cherry Point has the potential to require shipment of 52.5

million tons per year during the maintenance period. The Millennium Bulk Terminal at 

Longview Project will ship approximately 48 million tons per year. Amber Energy’s Coyote 

Island Terminals, LLC will ship approximately 9 million tons per year. Thus, these three 

facilities could result in over 100 million tons per year of coal shipped through the three 

maintenance areas. See also Ex. 1 at Slide 4 (EPA acknowledges 134 million ton per year 

increase by 2022). This represents over a 20 fold increase based on the highest year and 3270 

fold increase from the low year. EPA itself said the “number of coal trains per day on rail routes 

would significantly increase if these terminals are built.” Ex. 1 at Slide 6 (emphasis added). 

Even if we assumed that the coal bound for the Coyote Island Terminal would not pass through

any of the maintenance areas, we are still talking about an increase between 19 and 3073 fold. 

EPA tries to dismiss locomotive (including fugitive dust) emissions because they are 

currently “small relative to other source categories” during what EPA claims is the critical winter 

day period. See EPA-R10-OAR-2013-0713-0007 (Dk# 0007) at PDF page 2. But even if 

locomotive (including fugitive dust) emissions were 2% of the inventory, a 19 fold increase 

means a 36% increase in overall emissions (2*19 + 98 / 100 = 1.36). See Dk# 0007 at pdf page 

2. A 36% increase in the emission budget for Tacoma could result in a design value of 89.75 

ug/m3. Considering all the uncertainty in the design value (which is not based on actual PM10 

monitoring) and the emission inventory (which is not based on any testing) a potential 89.75 

ug/m3 design value means the SIP fails to “ensure” maintenance. Furthermore, on the other end 

of the spectrum, if Kent saw a 3073 fold increase in locomotive (including fugitive dust) 

emissions, that would be an increase of 18,532% of the total emission budget. (6 * 3073 + 94 

/100 = 18,532). An 18,532% increase over the Kent design value assumed by EPA, 46+/- 3, 

would be no less than 8524.72 ug/m3 which significantly exceeds the NAAQS. For Seattle, if 

we assumed the bottom of the range 19 fold increase, and also accept EPA’s assumptions of 5% 

of the current inventory being locomotive (including fugitive dust) and a design value of 50 +/-5 

ug/m3, we would end up with a design value of 104.5 ug/m3 which is above the limited 

maintenance plan threshold of 98 ug/m3. 

Calculated another way, the emission factor, according to the SIP submittal, is 0.0066 

kg/ton for Seattle. If Seattle saw an increase of 100 million tons per year of coal from the Cherry 

Point and Longview terminals, the fugitives from the coal trains alone, not counting emissions 

from the diesel engines, would add 727 tons per year of PM10 or approximately double the total 

emission inventory from 2011. Even if one used the 85% control efficiency, which we strongly 

disagree with for the reasons explained below, there would still be an increase of 138 tons per 

year, converting locomotives (including fugitive dust) to the second largest source of PM10 in 

the maintenance area. 

For Kent, again, even accepting the unsupportable control efficiency of 85%, the 100 

million tons per year would add 55.3 tons per year of PM10 to the maintenance area. This would 

make locomotives (including fugitive dust) the largest source of PM10 in the maintenance area 

and increase the total emission inventory by near 40%. If one used no control efficiency, 

because there is absolutely no support that any control efficiency will be achieved when the coal 
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trains are running through the maintenance area, the emission factor yields an addition of 368.5 

tons per year of PM10. Total emissions that are 262% greater than the emissions in the 2011 

emission inventory should surely be enough to not conclude that the Maintenance Plan will 

ensure maintenance. Even if the increase was an extra 50 million tons per year being shipped, 

we are still talking about an increase in the total emission inventory of 131%. This is clearly a 

maintenance problem. 

Similarly, for Tacoma, with the 85% unsupportable control efficiency, fugitives from the 

coal trains alone would increase emissions by 43 tons per year or 8%. Doing the calculation 

properly by assuming no controls because there is no requirement in the Maintenance Plan for 

controls and there is no evidence that there is any controls yields an increase of 276.4 tons per 

year. This would change the locomotives (including fugitive dust) category from the smallest to 

the largest source category and increase total emissions by 52.3%. Increasing by half is hardly 

ensuring maintenance. 

Moreover, the above calculations underestimate actual emissions because we are just 

calculating increases in fugitive coal dust emissions. We are not adding in the additional 

emissions from the diesel engines in the locomotives. WE are also not counting emissions from 

“empty” rail cars returning from the Port to the mines. Yet, this is a source of emissions which 

has been reported as being a source of “heavy fugitive dusting.” Ex. 3 at 25. Also, emissions 

from the locomotive engines would be twice as high if the export facilities go into operation

because locomotive engines would have to bring the rail cars back to the mines. 

We are not asserting that there is definitely a linear relationship between design values 

and locomotive (including fugitive dust) emissions, although EPA certainly often relies on 

assumptions of such linear relationships in this and other rule making. Nevertheless, when 

maintenance areas face the prospect of such dramatic increases in emissions in one source 

category during the maintenance period, those increases can create dramatic increases in overall 

emissions, and there are no regulatory mechanisms to address these increases currently in place 

or in the contingency measure, EPA cannot rationally conclude that the maintenance SIP will 

ensure maintenance of the NAAQS. 

The PM2.5 monitors do not provide adequate protection against future violations. To 

begin with, this is a maintenance SIP, not a “catch future violations and do something to fix the 

future violations a couple of years later” SIP. PM10 can kill people and causes a variety of other 

public health and welfare adverse impacts. It is no comfort to those who die during any future 

violations that the violation will be detected and may be addressed months or, more likely, years 

later. Rather, the plain language of the Clean Air Act provides that the SIP must “ensure” 

“maintenance.” See 42 U.S.C. § 7505a(a). 

Furthermore, there are only PM2.5 monitors in the PM10 maintenance areas.

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 EPA has 

no evidence about what percentage, if any, of the fugitive emissions from coal trains are larger

 

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Should EPA refuse to require PM10 monitors, the contingency measure trigger needs to be clarified that it is 

triggered by PM2.5 monitors showing “violations” using the equivalency factors, not by PM10 violations at the 

FRM monitoring. Also, the Maintenance Plan cannot use the procedures outlines in 40 C.F.R. Part 50 because, 

again, there are no PM10 monitors. See Dk# 0007 at 36. While it is clearly illegal for the SIP to ignore Part 50, it is 
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than PM2.5. PM2.5 monitors cannot physically monitor PM10-2.5 which is the size range coal 

dust may fall into. Likewise, there is no evidence in the record to establish that the span and 

range of the PM2.5 monitors are adequate to that they can record very high bursts of PM10, like 

the levels that are obviously present in the picture on the first page of these comments. 

In addition, Washington switched to PM2.5 monitoring in 2007 but in 2008 coal exports 

were only 30,581 tons. See Dk# 0004 at 14, 15, 17, 19. Thus, there is no evidence that EPA’s 

claimed correlation between PM10 and PM2.5 took into consideration fugitive coal dust. 

This is important because the correlation between modeled and monitored PM10 readings 

is not particularly strong to begin with. See Dk# 0004 at 22. For example, one point in Figure 

4.2.2 appears to show a modeled value of 20 ug/m3 which was actually a monitored value of 

approximately 47 ug/m3. In other words, the actual value was over twice as high as the modeled 

value. Seattle also demonstrates values where the actual value is twice as high as the modeled 

value. See Dk# 0004 at 24. Tacoma is even worse. One data point appears to have a modeled 

value of 23 ug/m3 but an actual monitored value of 95 ug/m3. A “quasi-monitoring” method 

that can under-predict so significantly is not adequate to protect people against a pollutant which 

can kill innocent people. 

Finally, the fact that the PM2.5 monitors are “nearby” to the trains does not establish that 

they will appropriately monitor PM10 from the trains. EPA offers no evidence that the 

placement of the monitors is appropriate for monitoring the trains. EPA does not define nearby. 

Nearby for one thing may not be nearby enough to accurately detect PM10 from trains. EPA 

also does not discuss the site specific meteorology where the trains and monitors are located. 

For example, EPA does not establish that the monitors will not be “upwind” of the trains the vast 

majority of the time. Also, EPA does not discuss evaluation changes or other physical barriers, 

if any, between the trains and the monitors. The Kent monitor is a neighborhood scale site to be 

representative of the Kent Valley Area, not coal trains. See Dk# 0004 at B30. The same is true 

of the 4401 E. Marginal Way, S monitor. Id. at B37. If EPA could resolve the other problems 

discussed above, which it cannot, EPA would have to use AERMOD or a similar model to 

ensure that the monitors are at locations where the maximum PM10 impacts are expected. 

For all of the above reasons, EPA must disapprove the Maintenance SIP. 

B. EPA’S EMISSION FACTOR UNDERPREDICTS PM10 EMISSIONS 

FROM COAL TRAINS

Above, we demonstrated that even assuming the Maintenance Plan’s emission 

calculations were correct, there could be a massive increase in PM10 emissions from coal export 

trains during the second maintenance period which the Maintenance Plan fails to address. Here, 

we explain why the Maintenance Plan’s emission calculations are not reliable. 

 

also illegal and absolutely not protective for the SIP to require a violation to be determined pursuant to a procedure 

that it is impossible to use. 
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The Maintenance Plan’s fugitive coal dust calculation is derived from a paper entitled “A 

Study of Fugitive Coal Dust Emissions in Canada,” November 2001, by Douglas L. Cope and 

Kamal K. Bhattacharyya (Cope 2001). See Ex. 3; Dk# 0004 at C-16 and Ftnt 10. Cope 2001 

was not published. Ex. 3 at iii. It had a “limited” technical review. Id. 

The Maintenance Plan assumes 177 days of precipitation per year. Dk# 0004 at C-16. 

However, Cope 2001 acknowledges that “Hot and dry weather ‘up route’ of the emissions can 

influence the emissions at the point of observation.” Ex. 3 at 17. The Powder River Basin and 

Idaho, which are up route of the three maintenance areas, are very dry areas and can be very hot 

during the summer. However, the Maintenance Plan does not take this factor into its 

calculations. 

Similarly, the 2011 emission inventory does not take into account fugitive coal dust 

emissions from “empty” rail cars returning to the mines. Yet, this is a source of emissions. See

Ex. 3 at 35. Sometimes, this is because the coal in the car is frozen and thus does not get fully 

dumped out before the return trip. Ex. 3 at 41.

It also very well could be the case that the emission factor used in the Maintenance Plan 

double counts control. The basic emission factor that Cope used, 0.1 * (0.62*D)0.6, stated that it 

was based on 75% control. Ex. 3 at 28-29. Yet, despite the fact that the basic emission factor 

explicitly stated it already had built in a 75% control factor, Cope determined that it was an 

uncontrolled emission factor and added in a provision to his formula to account for control. Id.

The basic formula also picks the low end of the range for coal loss versus the high end or 

middle. That is, the range is 0.5 to 3% of the total car load. The formula which the Maintenance 

Plan ultimately relies on used 0.5%. Id. at 44. 

Also, EPA uses a scaling factor for TSP to PM10 of 0.75 for truck loading, which is the 

most similar situation to coal trains. Id. at 47. Yet, the Maintenance Plan uses a 0.5 scaling 

factor. Thus, a scaling factor of 0.5 is inappropriate.

EPA acknowledges that the percent of dust control measures remaining at the end of the 

journey effects the amount of fugitive coal dust. Ex. 1 at Slide 9, 14. However, EPA’s formula 

does not take that factor into account. 

According to BNSF, each coal car releases 500-2000 lbs of coal dust per trip, and thus a 

typical 125 car train could lose up to 250,000 lbs of coal per trip.6The Maintenance Plan 

assumes 85% control from a topping agent or surfactant that is applied to the top of loaded coal 

cars at the mine. This "requirement" is from a BNSF tariff to require the use of surfactants on 

PRB coal. In late 2013, the Surface Transportation Board (STB) finally approved this tariff but 

 

6

See Burlington Northern Santa Fe Railway, “Coal Dust FAQ,” Mar 2011, 

http://www.coaltrainfacts.org/docs/BNSF-Coal-Dust-FAQs1.pdf.
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it has no enforcement mechanism and is essentially voluntary. Industry has been quoted as

saying that many coal shippers are simply ignoring the tariff—only 30% of coal shippers were 

applying surfactants as of late 20117. Even if coal shippers do not ignore the tariff, surfactants 

wear off over the rail route and are not 85% effective—likely closer to 0% the further the coal 

gets from the mine like in Washington. Further evidence and expert commentary on the 

inaccuracy of the 85% control efficiency assumption can be found at pages 7-9 of Phyllis Fox’s 

Fugitive Particulate Matter Emissions from Coal Train Staging at the Proposed Coyote Island 

Terminal, attached as Ex. 5 and incorporated herein by reference. 

C. THERE IS OTHER RELIABLE EVIDENCE THAT INDICATES THE 

UNREGULATED INCREASE IN COAL EXPORT TRAINS MEANS THE 

MAINTENANCE PLAN DOES NOT ENSURE THAT THE PM10 NAAQS 

WILL BE MAINTAINED

In addition to the dramatic increase in the PM10 emission inventory that the coal export 

trains will cause, there is other reliable evidence that indicates the unregulated increase in coal 

export trains means the maintenance plan does not ensure that the PM10 NAAQS will be 

maintained. 

For example, Sierra Club had a modeling expert prepare an evaluation of the ambient air 

quality impacts of the proposed Ambre Energy’s Coyote Island Terminals in Morrow, Oregon 

(Morrow). Khanh Tran produced a report entitled, “The AERMOD Modeling of Air Quality 

Impacts of the Proposed Morrow Pacific Project.” See Ex. 4. The Morrow project involves 

trains to deliver approximately 8.5 million tons per year, which is significantly less than the 

approximately 100 million tons per year for Cherry Point and Longview combined. See Ex. 1 at 

Slide 4. The modeling analysis used an annual emission figure of 12.8 tons per year PM2.5 from 

train cars and 0.92 tons per year from tug boats. Ex. 4 at 5. This is significantly less than the 

fugitive emissions in each of the maintenance areas which would come from coal trains bound 

for Longview and Cherry Point. See above. AERMOD, the model used in Mr. Tran’s analysis, 

does not distinguish between PM10 and PM2.5 in terms of modeled impacts. Thus, results for 

PM2.5 could be assumed to be PM10 if the emissions were PM10. 

Even with these much smaller emissions, the modeling analysis predicted an impact of 

388.6 ug/m3 with open trains and closed barges. Ex. 4 at 20. This value exceeds the PM10 

NAAQS. Open trains is the appropriate scenario to look at because there is no requirement for 

the trains passing through the maintenance areas to be covered. In any event, the emissions used 

in this scenario are still significantly less than the emissions calculated for the three maintenance 

areas, even assuming 85% control. This modeling analysis is a strong indication that the 

Maintenance Plan will not maintain the PM10 NAAQS in light of the proposed coal export 

terminals.

 

7 Tavanger, Sayeh, “Some shippers not complying with BNSF coal dust tariff,” Nov 3, 2011, 

Platts Energy Week, WUSA 9

accessedhttp://www.wusa9.com/news/local/story.aspx?storyid=173329
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D. THE MAINTENANCE PLAN SHOULD REQUIRE PM10 MONITORS IN 

THE PM10 MAINTENANCE AREAS 

There are no PM10 monitors in Kent, Seattle, and Tacoma. 40 C.F.R. § 58.14(c) says 

monitors can be discontinued if they meet the requirements of Appendix D. Appendix D says 

the monitoring system has to meet three objectives. The first is TO provide air pollution data to 

the general public in a timely manner. 40 C.F.R. § 58, Appx. D, 1.1(a). Washington’s SIP does 

not require the collection of any data about PM10. Therefore, it does not meet the first objective. 

The second objective provides: “Data from FRM, FEM, and ARM monitors for NAAQS 

pollutants will be used for comparing an area's air pollution levels against the NAAQS.” 40 

C.F.R. § 58, Appx. D, 1.1(b). The SIP violates this because there is no data from FRM, FEM or 

ARM PM10 monitors. 

The 2011 emission categories include locomotives (including fugitive dust). 78 Fed. 

Reg. at 78,313. Fugitive dust includes dust in the PM10-2.5. It is not physically possible for a 

PM2.5 monitor to accurately serve as a surrogate for PM10-2.5 because PM2.5 monitors cannot 

detect PM10-2.5. Even if there was a past correlation between PM2.5 levels and the emission 

inventory, there is no mechanism to explain why the correlation would continue in the future. 

IV. CONCLUSION

If you have any questions, or require any addition data, please do not hesitate to contact 

us. Otherwise, we appreciate your careful consideration of these comments on this very 

important matter. We look forward to EPA’s disapproval of the PM10 maintenance SIP 

submittals.

Sincerely,

Robert Ukeiley

Counsel for Sierra Club