PALA BAND OF MISSION INDIANS

35008 Pala Temecula Rd. PMB 50

Pala, CA 92059

February 22, 2012

Jared Blurnenfeld

U.S. EPA Regional Administrator

74 Hawthorne Street

San Francisco, CA 94105

Subject: Proposed Unclassifiable/Attainment Ozone Designation for the Pala Band of Mission

Indians Reservation.

Dear Mr. Blumenfeld,

Thank you for the opportunity to submit a designation recommendation for the area under the

Pala Band of Mission Indians jurisdiction for the revised 2008 ozone National Ambient Air

Quality Standard (NAAQS). The goals of the Pala Band ofMission Indians are to maintain good

air quality, strive to protect the air resources for future generations, and exercise our inherent

sovereign authority over our air shed as provided in sections 301(d) and 110(o) of the Clean Air

Act. Pala recommends that the lands within the exterior boundaries of the reservation be

designated as an unclassifiable/attaimrient area for the revised 2008 ozone NAAQS. The basis

for our request is listed below:

1. Jurisdictional Boundaries

The Pala Indian Reservation is located in north San Diego County approximately 10 miles

southeast ofTemecula and 60 miles northeast of San Diego. Established in the early 1900s, the

reservation covers an area of approximately 12,449 acres held in trust for the tribe by the Bureau

of Indian Affairs under the direction ofthe Department of the Interior. The total reservation

population is approximately 1,315.

2. Geographic Area

The reservation lies within an alluvial valley surrounded by steep granitic mountains and is

divided into two areas by the San Luis Rey River, which are referred to as the north side and the

south side. Elevations range from around 340 feet above mean sea level (MSL) at the valley

floor to around 1,250 feet MSL in the northern and southern mountainous areas with most

residential, agricultural, and industrial activities occurring in the lower elevations of the

Ph: (760) 891-3500

Fax: (760)742-1411
reservation. Neighboring the reservation is the Cleveland National Forest to the north and east

and private agricultural lan:ls to the south and west.

3. Population Density and Degree of Urbanization

While San Diego County is one of the most populated counties in California, the northern part of

the county and the Pala Reservation specifically is sparsely populated. The Census Bureau

defines

Reservation

an “urban area” as an area containing at least 1,000 persons per square mile. The

consists of 12,449 acres, or 19.45 square miles. With a population of 1,315, the

Diego

reservation population density is 68 persons per square mile. Compare this with the City of San

at a population of I.5 million and a density of 3,877 persons per square mile, and it

becomes readily apparent Oat the two entities are vastly different. The Reservation is 60 miles

to the north of the City of S m Diego. To combine these two entities into the same geographic

area for the purpose of air quality classification simply because they are within the same county

is not reasonable.

4. Traffic and Commuting Patterns

Riverside

US l-Iighway ISis a major commuter corridor between San Diego County in the south and

County to the nor:h. Traffic volumes are heavy and contribute to the overall

deterioration of air quality. US-IS is located seven miles west of the Pala Reservation.

and

Prevailing

affords

winds blow from the Southwest toward the reservation. The Pauma Valley is narrow

a limited area ol exposure to commuter traffic pollution. California State l-lighway

volume

76 crosses the Reservation fom east to west. Caltrans traffic volume counts show a peak hourly

of 1,200 vehicles. Vehicles using S}-l-76 are a mix of local residents, visitors to the

casinos and limited commutr traffic.

5. Growth Rates and Patterns

Overall the growth rate in Sm Diego County is declining, both numerically and percentage-wise.

The slowed growth rate county-wide is in response to out migration by those seeking more

which

affordable housing. Of the 12,449 acres within the Reservation only 2,639 acres are fee land

have strict regulations governing their disposition. Land development and concurrent

population growth on the Pala Reservation is strictly regulated by the U.S. Department of

Interior, Bureau of Indian Affiuirs in concert with the Pala Band of Mission Indians, and not

subject to the same developniental pressures as privately held lands elsewhere. With a total

tribal population of 762 therc is little demand for development at the present time. \Vith

foreseeable

significant growth restraints, air quality on the reservation should remain unchanged in the

future.

6. Meteorological Data

Temperatures

°F during

in the Pala Va! ley are relatively moderate, ranging from an average of around 55

total annual

the winter months to an average of around 72.3 °F during the summer. In 2011 the

rainfall for the Pala area was approximately 9.7 inches with the wettest month being
February. The prevailing wind direction blows from the south-southwest toward the northeast

region of the reservation at an average of 3.3 miles per hour.

7. Emissions Data

Ground-level ozone is created by a chemical reaction between oxides of nitrogen (NOx) and

volatile organic compounds (VOC) in the presence of sunlight. The Pala Environmental

Department recently completed an Emissions Inventory for 2011 and found no significant NOx

or VOC emitting facilities present on or near the reservation. The majority of our NOx and VOC

emissions are produced by traffic offthe SH-76. Not only are there no significant sources of

NOx and VOC emissions on the reservation, but our 3-year ozone design value shows we fall

under the new standard of 0.075 ppm (see section 8). Please see emissions totals chart below.

- Area On-Road Non-Road 2011 2006

Emissions (No—Po,nt) .Enusswns Mobile Mobile Total Total

Type E,mscioits (iois/yeai) Eniissioiis Emiccioiis Estimated Estimated

(tons/yeai) (tonc/yea) (to;ls/yeai) Emissi’onc Emicu,,as

(tons/yeai) (tons/ycal)

--

VOC 1.2527 15.6693 - 1.1791 18.10 43.34

NO 1.0801 7.1434 7.3694 0.0224 15.62 5.02

8. Air Quality Data

Pala is curi-ently conducting ozone monitoring with a Teledyne-API 400e Ozone Analyzer. We

have been sampling with this ozone monitor since 2003 and have collected the three years of

data required to make an attainment designation. The last three years of data clearly

demonstrates Pala meeting the newly revised ozone standard of 0.075 ppm (see chart below).

Not accepting attainment “doughnut holes” even if the data shows we meet the standard ignores

the science behind the data that EPA is paying to have collected.

2009 331 91% 0.O69ppm

2010 343 94% 0.078 ppm

2011 330 90% O.O7Opprn

Design J’aiue 0.072 ppm

If you have any questions regarding this recommendation please contact:

Shasta Gaughén Pala EPA Director 760-891-3515

Rodney Watkins Air Quality Specialist 760-891-3511

Frank Spurgeon Air Technician 760-891-3540

in conclusion we respectfiully request that the Pala Indian Reservation be designated as

unclassifiable/attainment for the revised 2008 ozone NAAQS. Thank you for your attention to

this matter.
Regards.

Robert H. Smith

Tribal Chairman