Jared Blumenfeld, Regional AdministratorU.S. Environmental Protection Agency, Region IX

75 Hawthorne Street

San Francisco, CA 94105

RE: Area Designation of 2012 Revised Primary Annual PM2.5 National Ambient

Air Quality Standard for Salt River Pima-Maricopa Indian Community

Dear Mr. Blumenfeld,The Salt River Pima-Maricopa Indian Community (SRPMIC) is a federally recognizedtribe interested to provide the opportunity to participate in the recommendation processfor designating areas for the Environmental Protection Agency’s (EPA) NationalAmbient Air Quality Standard (NAAQS) on 2012 revised primary annual PM2.5pollutant. The proposed processes regards to December 14, 2012, when EPA revised theprimary annual PM2.5 NAAQS that strengthen the standard from 15.0 micrograms per

cubic meter (uglm 3)to 12.0 ug/m 3,but retained the existing 24-hour PM2.5standard at 35ug/m 3 These designation process based on Clean Air Act (CAA) section 107(d) requiresdesignating all areas of the country in a timely manner following promulgation of a newor revised NAAQS.

We recognize EPA’s mission is to protect human health and the environment to set limits

on levels of certain air pollutants to ensure necessary health and environmental

protections as well as providing support and funding for air quality agencies. We

appreciate the opportunity to submit our recommendation of the revised primary annual

PM2.5NAAQS area designation.

The SRPMIC has collected sufficient air quality information to determine the area ismeeting the NAAQS. The thbal air quality data is certified annually in EPA’s Air Quality

System (AQS) and the data is sufficient quality to be used for designation purposes. Theair quality status of PM25 concentration design values for 2010 to 2012 is well below the

NAAQS standard therefore, the Community is recommending the area to be designated

“attainment”.

The SRPMIC provides an attached document of air quality data information that supports

the area recommendation to 2012 revised primary annual PM2.5 NAAQA designation.

Should you have any questions or concerns with comments addressed with Christopher
Manager

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land.

The SRPMIC’s location within a dense urban region results in a broad range of economic

development and land uses which, in turn, lead to variety of pollution sources. The SRPMIC

includes 12,000 acres of agricultural cultivation, large scale aggregate mining operation as well

as landfill operations. The continued urbanization of the region has also encroached on theCommunity boundaries, with major highways such as the Pima Loop 101 (Hwy lOl-Pima

Freeway), Loop 202 (Red Mountain Freeway) and Beeline Highway (AzHwy 87) coursingthrough the Community.

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The PM2.5 is monitored at the SRPMIC’s Senior Center air monitoring station which is

designated as State and Local Air Monitoring Station (SLAMS) Tribal monitoring station, AQS

site ID 040137020 in Maricopa County, AZ. The data collected from this monitor is a regulatory

monitor in compliance with 40 CFR Part 58 Appendix A and have adequately achieved thequality assurance and data requirements for annual data certifications.

The PM2.5annual design value for 2010 to 2012 in Graph 1 show the SRPMIC site monitor

Senior Center at 5.6 ug/m 3along with site monitors West Phoenix and South Phoenix from

Maricopa County and one site monitor Super Site from the (State) Arizona Department ofEnvironmental Quality (ADEQ). Also graphed is the PM2.5annual design value for 2009 — 2010

that all graphs shown are below the NAAQS standard and Senior Center annual design value isthe lowest of the four monitors.

16.0

14.0

12.0 __. - 4.0 PM2.5 Annual Design Value 2010-20 12

——PM2.5 Annual Design Value 2009-2011

2.0 —_—2012 Standard

—2011 Standard

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West Phoenix South Phoenix Senior Center Super Site

PM25 Annual Design Values 2010 - 2012 and 2009 - 2011 of the State,

Maricopa County and SRPMIC Site Monitors

Graph I

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The SRPMIC’s PM data indicates the lowest of the five locations for the 2010- 2012 annual

design value for the area that evidently would categorize as attainment area. All of the sitesannual design values are below the 2012 PM2NAAQS standard at 12 ug/m 3.

PM2.5 Design Value Annual 2010-2012

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Graph 2

2005-2007 2(X)6-2008 2007-200’) 2008-2010 2009-2011 2010-2012

Three-year Moving Averages of Annual Design Value PM25

Concentrations

SPRMIC 2005 - 2012

‘——Senior Center

Standard

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Graph 3

Three-year Moving Averages of 24-Hour PM, 598th Percentiles

S RPMIC

2005 - 2012

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3025

20

15

——Senior Center

Standard

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2005-2007 2006-200 2007-2009 200K-2() 10 2009-201 I 2010-20 I 2

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