SIP Revision

for the

Spokane County, Washington

Second 10-Year Limited Maintenance Plan 

for PM10

Spokane Regional Clean Air Agency

Spokane, Washington

In conjunction with

Air Quality Program

Washington State Department of Ecology

Olympia, Washington

November 2015
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November 2015

Publication and Contact Information

This report is available on Spokane Regional Clean Air Agency’s website, www.SpokaneCleanAir.org.

Contact:

Spokane Regional Clean Air Agency

Attn: Margee Chambers

3104 E. Augusta Avenue

Spokane, WA 99207

Phone: (509) 477-4727

Fax: (509) 477-6828

Email: mchambers@spokanecleanair.org

If you need this document in an alternate format for the visually impaired or hearing loss, call Spokane 

Regional Clean Air Agency at (509) 477-4727.
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Contents

Publication and Contact Information............................................................................................................ ii

List of Figures and Tables............................................................................................................................. iv

Figures...................................................................................................................................................... iv

Tables....................................................................................................................................................... iv

Acronyms and Abbreviations........................................................................................................................ v

Acknowledgements..................................................................................................................................... vii

Abstract/Executive Summary..................................................................................................................... viii

1. Introduction ..............................................................................................................................................1

2. Background ...............................................................................................................................................2

3. Limited Maintenance Plan Option ............................................................................................................5

4. Particulate Matter Monitoring..................................................................................................................6

5. Emission Inventory....................................................................................................................................7

6. Control Measures......................................................................................................................................9

7. Contingency Measures............................................................................................................................11

8. Commitment to Continued Monitoring..................................................................................................12

9. Verification of Continued Attainment ....................................................................................................12

10. Summary of Maintenance Plan Commitments.....................................................................................13

11. Required Plans Complete......................................................................................................................13

Summary of Control and Contingency Measures.......................................................................................13

Appendix A. Limited Maintenance Plan Qualification ................................................................................15

Appendix B. Ecology 2014 Network Report/EPA approval.........................................................................18

Appendix C. Emission Inventory Documentation .......................................................................................27

Appendix D. Changes to Regulation 1 – Article VI – Emissions Prohibited since adoption into the SIP.....30
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List of Figures and Tables

Figures

Figure 1. Spokane County Maintenance Area (SCMA) .................................................................................3

Figure 2. PM10 Maximum and Second Highest Values..................................................................................4

Figure 3. Smoke Control Zone.....................................................................................................................10

Figure 4. Out Year VMT Estimate Plot ........................................................................................................16

Tables

Table 1. Comparison of First and Second LMP Emissions Inventory ............................................................7

Table 2. Annual and Daily PM10 Emissions 2011...........................................................................................8

Table 3. Second 10-Year LMP Commitments..............................................................................................13

Table 4. Tabular Estimation of PM10 Design Values....................................................................................15

Table 5. Tabular Estimation of PM10 Look-Up Concentrations Using Table 6-1 of PM10 SIP Guidelines....15

Table 6. Modeled VMT Data .......................................................................................................................16

Table 7. Mobile Source Contribution to Design Value................................................................................17

Table 8. Particulate Matter 10 PM10, Parameter code 81102 ....................................................................19

Table 9. Spokane County Residential Wood Combustion Emissions..........................................................28

Table 10. Unpaved Road Emissions Calculations........................................................................................29
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Acronyms and Abbreviations

μg/m3 micrograms per cubic meter

ADT Average Daily Traffic

ADVMT Average Daily Vehicle Miles Traveled

AP42 EPA's compilation of Air Pollutant Emission Factors

AQI Air Quality Index

AQS Air Quality System

CAA Clean Air Act

CAAA Clean Air Act Amendments

CARB California Air Resources Board

DOL Washington State Department of Licensing

DQO Data Quality Objectives

DV Design Value

Ecology Washington State Department of Ecology

EI Emission Inventory

EPA U.S. Environmental Protection Agency

FEM Federal Equivalent Method

FRM Federal Reference Method

FTA Federal Transit Administration

g/hr grams per hour

HPMS U.S. Department of Transportation Highway Performance Monitoring System

I/M Vehicle Inspection and Maintenance

IPP/QAP Inventory Preparation Plan and Quality Assurance Plan

LMP Limited Maintenance Plan

MOS Margin of Safety

MOVES EPA Motor Vehicle Emission Simulator

NAA Nonattainment Area

NAAQS National Ambient Air Quality Standards

NAMS National Ambient Monitoring Site

NEAP Columbia Plateau Windblown Dust Natural Events Action Plan

NEI National Emission Inventory

OSPI Washington State Office of the Superintendent of Public Instruction

PM10 Particulate Matter, ten microns or less

PM2.5 Particulate Matter, 2.5 microns or less

RACM Reasonably Available Control Measures

RWC Residential Wood Combustion

SCAPCA Spokane County Air Pollution Control Authority1

SCMA Spokane County Maintenance Area

SIP State Implementation Plan

 1 In 2007 the Board of the Spokane County Air Pollution Control Authority (SCAPCA) changed their name to the 

Spokane Regional Clean Air Agency (SRCAA), Resolution #07-15
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SLAMS State and Local Ambient Monitoring Site

SRCAA Spokane Regional Clean Air Agency

SRTC Spokane Regional Transportation Council

TEOM Tapered Element Oscillating Microbalance

TSP Total Suspend Particulate 

VMT Vehicle Miles Traveled

WRAP Western Regional Air Partnership

WSDOT Washington State Department of Transportation

WSU Washington State University
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Acknowledgements

The authors of this report would like to thank the following people for their contribution to this study:

Spokane Regional Clean Air Agency

Margee Chambers

Ron Edgar

Carl Gross

Julie Oliver

Mark Rowe

April Westby

Washington State Department of Ecology

Ranil Dhammapala

Laurie Hulse-Moyer

Sean Lundblad

Sally Otterson

Mike Ragan

Spokane Regional Transportation Council

Sylvia Ferrin

Anna Ragaza-Bourassa

Spokane County 

John Pederson
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Abstract/Executive Summary

The cities of Spokane, Spokane Valley, Millwood and surrounding unincorporated areas in Spokane 

County, Washington meet the federal standard for Particulate Matter 10 microns and smaller (PM10). 

This State Implementation Plan (SIP) explains how this area will continue to meet this standard through 

2025. 

Environmental Protection Agency (EPA) sets standards for particulate pollution because smaller particles 

such as soot, dust and unburned fuel can penetrate deeply into the lungs and cause health problems. 

The current 24-hour federal health standard for PM10, set in 1987, is 150 micrograms per cubic meter of 

air (μg/m3

). To maintain compliance with the standard, monitored levels should not exceed this level in 

the area more than once a year averaged over a three year period.

The Spokane County Maintenance Area (SCMA or maintenance area) which includes the cities of 

Spokane, Spokane Valley, Millwood and surrounding unincorporated areas, violated the 24 hour 

standard in the 1980s. Windblown dust, re-entrained road dirt and sanding material, unpaved road dust 

and smoke from woodstoves and fireplaces all contributed to the violations of the standard. The 

Spokane Regional Clean Air Agency (SRCAA) operates federal reference method (FRM) and/or federal 

equivalent method (FEM) ambient air monitors in the SCMA to track compliance with the federal PM10

standard. Ambient monitoring has shown the SCMA in attainment since 1994. With completion of an 

approved attainment SIP and Limited Maintenance Plan (LMP) the SCMA was re-designated to 

attainment in 2005. SRCAA has enforcement authority for the SCMA.

The Clean Air Act (CAA) requires an area being re-designated to attainment have an EPA-approved 

maintenance plan that provides for the area’s continued compliance with the PM10 standard for 10 

years. A second 10-year plan must follow the first. This SIP Revision is for the Spokane County 

Washington, Second 10-year Limited Maintenance Plan for PM10. This plan:

• Meets the requirement for a second 10-year plan,

• Covers the period through 2025, and

• Fulfills the final maintenance planning requirements of the CAA for the SCMA.

Since the maintenance area meets EPA criteria and shows little risk of re-violating the federal standards, 

this streamlined maintenance plan called a LMP has been developed. The LMP relies on the same 

control measures that brought the area into attainment and supported the initial maintenance plan. 

These measures include:

• Control of dust from paved and unpaved roadways

• Controls to prevent particulate matter from becoming airborne

• Curtailment of wood burning devices during impaired air quality

• Standards for new solid fuel burning devices

• Outdoor burning restrictions
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The underlying control measures and contingency measures from the attainment and maintenance plan 

are still in place, thus meeting the LMP guidance criteria. Any changes or potential revisions to these 

control measures will be addressed in separate submittals to the EPA as discussed in this document. 

SRCAA proposes that Ecology, as the Governor’s designee for the SIP, submit this LMP to EPA and 

request EPA approve this LMP as a revision under the SIP.

Ecology will lead the public comment period to fulfill federal requirements for public comment and 

hearings. SRCAA will continue to monitor air quality in the SCMA and document the area’s continued 

compliance with the 1987 PM10 Standard.
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1. Introduction

This State Implementation Plan (SIP) revision explains how the Spokane County Maintenance Area 

(SCMA) currently meets and will continue to meet the 1987 National Ambient Air Quality Standard 

(NAAQS) for particulate matter 10 microns or smaller (PM10) through 2025. Spokane Regional Clean Air 

Agency2 (SRCAA), the local clean air agency with jurisdiction over Spokane County, prepared this plan.

Particulate Matter Standards – The Environmental Protection Agency (EPA) set air quality standards for 

particulate matter to protect public health. Particulate matter pollution is a public health issue because 

smaller particles can penetrate deep into the lungs and cause health problems. Particulate matter 

comes from soot, dust and unburned fuel suspended in the air. EPA revised the particulate matter 

NAAQS from total suspended particulate (TSP) to PM10 on July 1, 1987, since smaller particles were 

determined to be more harmful. The primary or health-based 24-hour standard for PM10 was set at 150 

μg/m3

, and cannot be exceeded more than once a year on average over three years. This standard 

remains in effect today. Ten years later on July 18, 1997, EPA set a 24-hour for fine particulate matter 

(particulate matter 2.5 microns or smaller or PM2.5) at 65 μg/m3

. In 2006, the 24-hour standard was 

revised from 65 μg/m3 to 35 μg/m3

.

Spokane County Maintenance Area Compliance History – Spokane County violated the 24-hour PM10

NAAQS multiple times a year from 1985 through 1993. There were three main causes of these 

exceedances of the NAAQS: windblown dust, re-suspended dust from traction sand and tracking of dirt 

from unpaved roads, and wood burning heating devices. These exceedances were recorded at multiple 

locations throughout the maintenance area. The primary location and highest values were at the PM10

monitor located at Freya St and Ferry Ave. (Spokane-Ferry St site) in the City of Spokane. When the 1990 

Clean Air Act Amendments (CAAA) was passed, EPA designated the Spokane County Maintenance Area 

(SCMA) a nonattainment area, an area out of compliance with the PM10 standards.

Ecology and SRCAA prepared plans to fulfill the Clean Air Act (CAA) requirements. An attainment plan 

described how the area would comply with the standard; a maintenance plan described how the area 

would stay in compliance.

The three main sources of particulate matter continue to be windblown dust (dust storms), dust from

roadways and smoke from wood stoves and fireplaces. Wood stoves and fireplace smoke is a 

wintertime issue. Control measures to limit wood burning during period of poor air quality were put 

into place and included in the attainment plan. These control measures and state requirements on new 

wood fueled burning devices have reduced smoke particulate. 

Resuspended road dust is mainly a late winter and early spring problem. A control measure requiring 

cities, Spokane County and Washington State Department of Transportation to submit and follow plans 

to reduce use of sanding material, use cleaner sanding material and clean roadways within the 

maintenance area more frequently and in a more timely manner. There have been no further 

exceedances attributed to road dust since the implementation of road dust control plans.

 2 In 2007 the Board of the Spokane County Air Pollution Control Authority (SCAPCA) changed their name to the 

Spokane Regional Clean Air Agency (SRCAA), Resolution #07-15 
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November 2015

Frequency of windblown dust impacts has been down as soil conservation programs have led to 

increased use of no-till and minimal till farming practices. Additional road paving by city and county 

have controlled critical unpaved roads that were shown to impact PM10 levels.

The control measures and contingency measures from the attainment and maintenance plan are still in 

place. The area monitored attainment in the 1995-1997 years and EPA redesignated the area to 

attainment in 2005. The area continues to be in compliance with the PM10 NAAQS. 

Plan Structure – This SIP revision includes the SCMA compliance history and describes the how the area 

met and will continue to meet the standards, as well as what will be done if the standard is exceeded. 

This plan also includes other EPA required elements, such as an emissions and monitoring review and 

public process requirements.

This document is organized as follows:

• Section 2 – SCMA and PM10 Standard Background – describes the area’s compliance history and 

contains back ground information on the PM10 standard

• Section 3 – Limited Maintenance Plan (LMP) Option – describes the criteria an area must meet 

to qualify for this option and how the SCMA meets these criteria

• Section 4 – PM10 Monitoring History – provides a brief history of monitoring in the SCMA

• Section 5 – Emission Inventory – includes historical information on the most significant PM10

emission categories from the original maintenance plan and an updated inventory on these 

categories

• Section 6 – Control Measures – lists the measures and rules that were in place in the original 

maintenance plan, the current rules that maintain and enforce these measures and includes a 

request that EPA incorporate and include the updated rules in Washington State’s SIP

• Section 7 – Contingency Measures – describes the provisions that are in place in rules and will 

be taken, if the PM10 standard is violated

• Section 8 – Commitment to Continue Monitoring – states that continued monitoring will be 

done

• Section 9 – Verification of Continued Attainment – describes how continued compliance will be 

confirmed

• Section 10 – Summary of Maintenance Plan Commitments – outlines commitments of this plan

• Section 11 – Completion of Required Plans – states that this document fulfills federal planning 

requirements

2. Background

Historical information on the SCMA, its compliance, and federal plan history are below.

Spokane County Maintenance Area – The SCMA is located in Washington State, east of the Cascade 

Mountains, 300 miles east of Seattle just west of the Idaho State boarder. Much of the SCMA is located 

in the drainage basin of the Spokane River with elevations ranging from around 1700 feet in the river 

valley near downtown Spokane to 2300 feet on the western boundary of the SCMA and 2200 feet on the 

eastern edge. The primary PM10 monitor, Spokane Augusta established in 2009, is located on the east 

side of the City of Spokane at an elevation of 1945 feet. Prior to 2009 Spokane Ferry St was the primary 
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November 2015

and design value monitor located approximately 1⁄2 mile south of the Augusta site along the same traffic 

corridor. The topography and location influence the meteorology throughout the SCMA. In general the 

climate is mild and arid in the summer, cold and moist in the winter. The predominant wind direction is 

from the south to southwest with most high wind speed condition coming out of this direction. High 

pressure over the region during winter months leads to strong temperature inversions in the river basin.

Figure 1. Spokane County Maintenance Area (SCMA)

Spokane County Compliance History – The SCMA shown in Figure 1 was designated Group I for violating 

the 24-hour PM10 standard in 1987. The area was designated as a PM10 Non-Attainment Area (NAA), 

which was classified as Moderate, under the 1990 CAA Amendments. The Spokane NAA was determined 

by EPA to attain the PM10 24-hour NAAQS by its extended attainment date of December 31, 1997. A 

PM10 attainment plan was submitted in 1994 and approved by EPA in 1997. The first PM10 Limited 

Maintenance Plan (LMP) and request for re-designation was submitted in 2004 and approved in 2005.3

 

Due to a lack of evidence linking health problems to long-term exposure to coarse particle pollution, the 

EPA revoked the annual PM10 standard in 2006.4 Figure 2 on next page shows maximum concentration 

for each year, 2000 through 2014, and the second highest value for that year. Data for the chart comes 

from the EPA AirData site and includes data flagged as an exception event.

 3 (70 FR 38029) Federal Register/ Vol. 70, No. 126/ Friday, July 1, 2005/ Rules and Regulations 

Approval and Promulgation of Air Quality Implementation Plans; Spokane PM10 Limited Maintenance Plan and 

Redesignation Request. Direct final rule effective August 30, 2005 4 (71 FR 61144) Federal Register/ Vol. 71, No. 200/ Tuesday, October 17, 2006/ Rules and Regulations

National Ambient Air Quality Standards for Particulate Matter. Effective December 18, 2006
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Figure 2. PM10 Maximum and Second Highest Values

The data for the year 2000 to through the first quarter of 2009 is from Ferry St, the remainder through 

2014 is from Augusta Ave. The first maximum values for the years 2001, 2005, 2008 and 2013 were 

flagged as exceptional events. 5

Plans Submitted – Ecology and SRCAA prepared attainment and the first of the two required 

maintenance plans to fulfill CAA requirements. An attainment plan describes how the area complies

with the standard; a maintenance plan describes how the area stays in compliance. These plans are:

• Attainment Plan – A revised PM10 SIP was submitted November 15, 1991 that used rollback 

modeling to demonstrate attainment. EPA subsequently requested dispersion modeling to 

demonstrate attainment. On December 9, 1994 Ecology submitted the Spokane PM10

Attainment plan for the Spokane PM10 nonattainment area. EPA approved the plan on January 

27, 1997 (62 FR 3800).

• Redesignation Request and Maintenance Plan – Ecology submitted the Limited Maintenance 

Plan (2005 LMP) and request for redesignation November 30, 2004, EPA approved the Plan and 

request which became effective August 30, 2005 (70 FR 38029).

 5 Data have been flagged, but unless there is regulatory significance, that is, the area is in danger of violating the 

standard, a demonstration would not be submitted. The values stay in the record until EPA approved a 

demonstration and places a concurrence flag on the data. 
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November 2015

This plan, the SIP Revision for the Spokane County, Washington Second 10-Year Limited Maintenance 

Plan for PM10, is the last maintenance plan for this area. This maintenance plan revision ensures 

compliance through 2025 and fulfills the second 10-year planning requirements of CAA Section 175A (b).

3. Limited Maintenance Plan Option

Because the SCMA is a maintenance area, the CAA requires Ecology to adopt and submit a plan that 

demonstrates compliance with the NAAQS through 2025. EPA developed the Limited Maintenance Plan 

(LMP) option so areas with little risk of reviolating the PM10 standard could be easily redesignated from

nonattainment to attainment (also called maintenance status). EPA also allows states to use this policy 

to prepare the required second 10-year maintenance plans, if the area meets the qualification criteria in 

the EPA Limited Maintenance Plan Option Guidance (LMP Guidance). This section describes the 

advantages of the LMP option and how the SCMA meets the qualification criteria.

Maintenance Demonstration – A maintenance plan normally contains an emissions or modeling 

demonstration that shows how the area will stay in compliance through the 10-year maintenance 

period. This demonstration normally requires a projected emissions inventory. However, an area 

meeting the LMP qualification criteria is at little risk of violating the standard because emissions are not 

expected to grow sufficiently to threaten maintenance of the standard. Therefore, when an area meets 

the criteria, the maintenance demonstration is presumed to be satisfied and there is no need to project 

emissions over the maintenance period. 

Transportation Conformity – The transportation conformity rule (40 CFR Parts 51 and 93) applies to 

nonattainment and maintenance areas. It is not reasonable to expect that motor vehicle emissions 

would grow enough to threaten maintenance if an area expects only limited growth in traffic emissions 

and qualifies for the LMP option. Therefore, a regional emissions analysis in not required to determine 

whether the region’s long-range transportation plan and short-term transportation improvement 

program conform to the maintenance plan. Other conformity requirements, such as consultation 

between agencies on air quality impacts of transportation projects, still apply.

LMP Qualification Criteria – To take advantage of the LMP option, an area must be attaining the 

NAAQS, cannot exceed the average 24-hour PM10 design value of 98 μg/m3 based on the most recent 5 

years of data and should expect only limited growth in on-road motor vehicle emissions. The SCMA 

meets these criteria as described below; supporting information can be found in Appendix A.

How the SCMA qualifies for the LMP option:

1. The area must be attaining the NAAQS: Spokane County attained the standard in 1997, was 

formally redisignated as in attainment in 2005, and has continued to be in compliance.

2. The average 24-hour PM10 design value for the area based upon the most recent five years of 

data should not exceed 98 μg/m3

. A design value is the statistic based on monitoring data that 

determines and area’s compliance status. The LMP Guidance directs the design value be based 

on the most recent five years of data. The SCMA design value on Federal Reference Method 

(FRM) and Federal Equivalent Methods (FEM) 24-hour PM10 monitoring data from 2010 through 

2015 is 80 μg/m3 using the “Tabular Estimation of PM10 Design Concentrations” Table 6-1 of the 
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November 2015

PM10 SIP Guidance. Since this value is below 98 μg/m3

, the value stipulated in the LMP Guidance, 

the SCMA meets this condition.

3. The area should expect only limited growth in on-road motor vehicle PM10 Emissions (including 

fugitive dust) and should have passed a motor vehicle regional emissions analysis test (i.e., 

passes the Motor Vehicle Regional Analysis Methodology found in Attachment B of the LMP 

Guidance.) SCMA meets both these criteria. First, the Spokane Regional Transportation Council 

(SRTC) projects only limited growth in on-road motor vehicle PM10 emissions for the SCMA from 

2015 through 2025. Second, the area passes the motor vehicle regional emissions analysis test.

The SCMA continues to attain the PM10 NAAQS. The design values are below the defined margin of 

safety and the growth in PM10 emissions from motor vehicles will not threaten compliance with the 

standard. Thus, the SCMA meets the LMP qualification criteria and qualifies for the LMP option.

The analysis has been provided to Ecology and EPA Region 10 office. EPA and Ecology mutually agreed 

to the LMP approach. SRCAA will calculate the 5-year design value estimate and provide it to Ecology 

annually by April 30th of each year. If the design value estimate is below 98 μg/m3

, Ecology will include a 

statement that the area continues to qualify for the LMP option in the annual monitoring network 

report.

4. Particulate Matter Monitoring

This section discussed the history of PM10 and to some extent PM2.5 monitoring in the SCMA. 

Particulate Matter Monitoring History – SRCAA conducts ambient monitoring in Spokane County. 

Starting in 1985 and in the early 90s there were as many as 9 PM10 FRM monitoring sites in Spokane 

County, one of them, the Crown Zellerbach site (3530 E. Ferry Ave., Spokane, WA), consistently showed 

the highest concentration of PM10. That site was later renamed Spokane-Ferry St. Ferry St was used to 

determine the design value for the attainment SIP and the first 10-year maintenance plan. The 

Spokane-Augusta site (3104 E. Augusta Ave., Spokane, WA) replaced Ferry St. as the primary site for 

PM10 monitoring when the equipment was moved in 2009. 

Today there are two locations where PM10 is monitored, Spokane-Augusta and Turnbull Slough, located 

on the Turnbull Wildlife Refuge southwest of the City of Spokane. The Augusta Ave. FEM is used for 

determining compliance with the NAAQS. Turnbull is a Special Purpose Monitor (SPM) operated by 

SRCAA to measure background PM10 levels and evaluate windblown dust events.

Types of Particulate Monitors – Spokane-Augusta monitors both PM10 and PM2.5 using both Federal 

Reference Method (FRM) and Federal Equivalent Method (FEM). The manual FRM data is no longer 

reported to Ecology. SRCAA continues to operate, maintain and collect the FRM data for its own use. 

Data from the PM10 FEM is reported by Ecology to AQS. The following monitors have been used to 

measure particulate matter at the Ferry St. and Augusta Ave. sites;

• FRM

o PM10 SA/GMW 1200 High Volume (HI-Vol) monitor

o PM2.5 R&P Partisol 2025 sequential monitor

• FEM
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November 2015

o PM10 R&P 1400AB TEOM 

o PM2.5 R&P 1400AB TEOM with 8500 FDMS unit and Very Sharp Cut Cyclone

o Met One BAM 1020 (The BAM is being evaluated as a replacement for the PM2.5 TEOM)

SRCAA commits to maintaining a PM10 NAAQS compliance monitor through the LMP period. The 

monitor will be maintained and operated in accordance with federal siting and design criteria set forth 

in 40 CFR Part 58. Any changes to the monitor will be proposed under Ecology’s annual network plan

and subject to EPA approval.

5. Emission Inventory

This section presents the emissions inventory for this second 10-year LMP and briefly describes its 

development. The LMP Guidance requires the maintenance plan include an attainment inventory – that 

is, an inventory with emission levels consistent with attainment of the PM10 standard.

In the original maintenance plan and LMP SRCAA contracted with E.H. Pechan and Associates, Inc. to 

develop a very detailed emission inventory. For this 2nd LMP EPA agreed that SRCAA should develop the 

maintenance plan inventory from readily available information. Emission estimates are from Ecology’s 

2011 and EPA’s triennial emission inventories. The National Emissions Inventory (NEI) is based on EPA 

and state inputs. Appendix C. Emission Inventory Documentation provides details.

Maintenance Plan Inventory – Washington State’s 2011 Emissions Inventory (EI) is the most recent, 

complete, readily available emission inventory for Spokane County. Since neither Ecology nor SRCAA 

have local information on emissions for a number of categories, Ecology accepted the EPA estimates for 

the missing categories. (See Appendix C.)

Significant source categories – The most significant sources of PM10 listed from the original 

maintenance plan for the SCMA are Paved Roads, Unpaved Roads and Residential Wood Combustion.

Three “Worst-Case” scenarios were looked at in the first 10-year maintenance plan; Levels for Unpaved 

Roads, Paved Roads and Residential Wood Combustion. Windblown dust was not included in the 

analysis. Windblown dust during high wind events is addressed under the Columbia Plateau Windblown 

Dust Natural Events Action Plan (NEAP)6 and the Exceptional Events Rule Guidance7

. There are no new 

major point sources in the SCMA and other activities and emissions estimates remain about the same as 

during the first 10-year plan. 

Table 1. Comparison of First and Second LMP Emissions Inventory

Year Spokane County SCMA

Annual (tons) Daily (tons) Annual (tons) Daily (tons)

2002 18,612 55.1 10, 059 30.0

2011 18,933 66.82 6,884 28.10

The detailed emission inventory for Spokane County and the SCMA is shown in Table 2.

 6 A link to Ecology’s NEAP is at https://fortress.wa.gov/ecy/publications/SummaryPages/0302014.html 7 Friday, May 10, 2013, EPA issued interim guidance to help state, local and tribal governments manage air quality 

data recorded during “exceptional events”.
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November 2015

Table 2. Annual and Daily PM10 Emissions 2011

Sources Sector Spokane County SCMA

Annual (tons) Daily (tons) Annual (tons) Daily (tons)

Air Craft 14 0.03 14 0.03

Recreational boats 16 0.08 1 0.01

Construction 4,810 18.6 3,561 13.8

Commercial fuel use 36 0.12 32 0.11

Residential fuel use 7 0.03 5 0.03

Wildfires 14 0.03 0 0

Food and Kindred Products 173 2.59 158 2.37

Structure and Motor vehicle 

fires, cremation etc.

6 0.02 5 0.02

Nonroad Mobile 164 1.07 71 0.46

Agricultural and silvicultural 

burning

99 0.88 3 0.03

Residential outdoor burning 101 0.35 0 0

On road mobile 469 1.28 346 0.94

Point sources8 200 0.72 160 0.57

Paved roads 1051 2.64 780 1.96

Unpaved roads9 5624 15.42 567 1.56

Locomotives 42 0.12 15 0.04

Woodstoves 1,353 7.51 1,062 5.89

Agricultural tiling & harvesting 4,156 13.7 15 0.05

Totals 18,933 66.82 6,884 28.10

Sources considered negligible – Ecology and SRCAA have no local information on emissions for 

construction dust, cigarette smoke, or commercial charbroiling, but these are assumed to be minimal. 

Some of these values are included in the 2011 NEI, however the emission estimates have large 

uncertainties because it was not developed specifically for local areas, or for sub-county regions like the 

Spokane County Maintenance Area. Other sources are deemed insignificant, including outdoor burning, 

aircraft emissions, and wildfires. 

Smoke from wildfires is considered negligible as no PM10 data has recently been flagged as being 

impacted by wild fires. Wildfires also would have a much more significant impact on PM2.5 and the 

Spokane area continues to meet the PM2.5 NAAQS. Outdoor burning is prohibited in the maintenance 

area, so emissions would be minimal.

Construction Dust in the inventory is data from EPA’s 2011 NEI as accepted by Ecology into their 2011 EI. 

This data is not estimated by Ecology or SRCAA and is included as found in the NEI. The 2011 data 

includes construction dust in four categories: Industrial/Commercial/Institutional, Residential 

Construction, Mining/Quarrying, and Road Construction. Top-down inventories such as the NEI have 

inherent uncertainties because data is collected nationally and aggregated. The previous attainment 

plan and 2005 LMP SRCAA’s consultant gathered local information to calculate construction dust that 

resulted in a much lower contribution than reported in the NEI. Construction dust was not identified as

significant in either the attainment plan or the first LMP. SRCAA local regulation in place to control 

 8 Air Operating Permit Billing Data 2012 (reports 2011 emissions), Spokane Regional Clean Air Agency, April 

Westby, March 2, 2015

9 Spokane Regional Transportation Council updated unpaved road data, email from Anna Ragaza-Bourassa, March 

11, 2015
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November 2015

construction dust, Section 6.0510, is listed under control measures for unpaved roads but also applies to 

construction activities. 

Windblown dust from high wind events is not included as part of the Washington State EI.

6. Control Measures

There were three “Worst-case” scenarios discussed in the first 10-year LMP for Unpaved Roads, Paved 

Roads and Residential Wood Combustion. SRCAA and Ecology relied on Reasonably Available Control 

Measures (RACM) to return the area to compliance with the PM10 standard. Ecology and SRCAA have 

continued to implement the control measures established in the attainment plan and in the first 10-year 

LMP. 

Control Measures for Unpaved Roads – The following resolutions and regulations were adopted to 

address dust from unpaved roads. SRCAA’s regulation remains in effect and enforced. City and County 

paving projects identified in the attainment plan were completed prior to the approval of the first LMP.

• SRCAA Regulation Section 6.15 Standards for Control of Particulate Matter on Unpaved Roads11

• City of Spokane Resolution 90-93, October 8, 1990, Street Paving

• City of Spokane Resolution 91-42, June 17, 1991, Six Year Comprehensive Street Program

• Spokane County Resolution 90-1219, October 9, 1990, Street Paving

• Spokane County Resolution 04-0461, 2004, County Zoning Code, Chapter 14.802 Off-street 

Parking and Loading Standards (replaces Spokane County Resolution 90-0812 and Spokane 

County Zoning Code Ordinances 4.17.059 and 14.802.080, May 24, 1990, Paving of New Parking 

Lots)12

Control Measures for Paved Roads – The following regulations and resolutions were adopted to address 

the dust from paved roads.

• SRCAA Regulation Section 6.05 Particulate Matter & Preventing Particulate Matter from 

becoming Airborne

• SRCAA Regulation Section 6.14 Standards for Control of Particulate Matter on Paved Surfaces13

• City of Spokane Resolution 93-43, May 10 1993, Street Sweeping & Reduced Use of Sanding 

Materials

SRCAA Regulation Section 6.14 which was adopted in 1993 was amended October 7, 2004 Resolution 

04-21; this is a change from the 1993 version listed by EPA. The changes are shown in Appendix D. 

 10 SRCAA Regulation Section 6.05 Particulate Matter & Preventing Particulate Matter from becoming Airborne. 

SRCAA notes that Section 6.05(A) is a nuisance provision outside the scope of regulating criteria pollutants under 

Clean Air Action section 110 and requests that the EPA correct the SIP to remove this provision. 11 SCAPCA Resolution 07-15 Agency name change from SCAPCA to SRCAA 12 E-mail from John Pederson, Planning Director, Spokane County 2/21/2015. This control measure was labeled as 

a contingency on Region 10 web page and called SCAPCA Zoning Code Ordinance 4.17.059 and 4.802.080, May 24, 

1990, Paving of New Parking Lots. It is in the attainment plan as a control measure and was not included in the 

first LMP. 

13 SCAPCA Resolution 07-15 Agency name change from SCAPCA to SRCAA
10

November 2015

After 10 years of trying to track multiple private companies, most were small and tended not to stay in 

business from year to year, and finding that the larger private companies did not use 250 tons of 

sanding material in a season Regulation 6.14 was amended to remove private sanding and sweeping 

companies from the requirements. It was decided that is was more effective to control particulate 

emissions from paved surfaces on private property using Regulation 6.05, Particulate Matter & 

Preventing Particulate Matter from becoming Airborne. As long as the sanding or sweeping is on private 

property, not a public roadway, SRCAA can require that the material be cleaned up if it becomes a 

problem or material is tracked onto a public roadway. Traffic speeds in parking lots and driveways do 

not cause much particulate matter to become airborne and are not considered a significant contributor 

to particulate levels. Tracking on to critical streets during the winter months is mitigated by the cities 

doing frequent sweeping of these roadways as required by Section 6.14.

The City of Spokane, Spokane County and the Washington Department of Transportation have 

submitted Sanding and Sweeping Plans as required by SRCAA Regulation Section 6.14. With its 

incorporation on March 31, 2003 the City of Spokane Valley submitted their plan in 2005 taking over the

portion of the Spokane County Plan that is now within the City of Spokane Valley boundaries. Annual

reports are on file with SRCAA. 

Control Measures for Residential Wood 

Combustion – The following regulations were 

adopted to address PM10 and PM2.5 from 

Residential Wood Combustion, use of woodstoves 

and fireplaces.

• SRCAA Article VIII Solid Fuel Burning Device 

Standards14

• WAC 173-433 Solid Fuel Burning Device 

Standards

SRCAA has implemented a solid fuel burning 

device curtailment program for Spokane County, 

when PM pollution impairs air quality SRCAA 

restricts wood burning. When SRCAA calls burn 

bans for the area, woodstove use is restricted and 

outdoor burning is prohibited. The SRCAA 

outdoor burning rule is not included as a control 

measures as it has never been considered a 

significant contributor to “worst-case” residential 

wood combustion and no credit was taken in the 

attainment SIP. 

Burn bans can be called in two stages and for 

either the “Smoke Control Zone” as shown in 

Figure 3 or the whole of Spokane County. The 

 14 This rule has been amended to conform to the state WAC 173-433, SRCAA Resolution 14-08 July 10, 2014 and 

will be submitted to EPA as a SIP revision. Should there be any problem with its adoption into the SIP the 

previously approved rule is sufficient to assure compliance with the PM10 NAAQS.

Figure 3. Smoke Control Zone
11

November 2015

Smoke Control Zone encompasses the entire SCMA and includes additional areas that extend farther 

into the drainage basins of the Spokane River, Little Spokane River and Latah Creek, all of which can 

impact the SCMA during stagnant weather conditions. 

• A Stage 1 ban prohibits the use of all uncertified wood heating devices when pollution levels 

approach unhealthful levels. As defined in the WAC and SRCAA Article VIII a Stage 1 burn ban 

(first stage of impaired air quality) is declared if meteorological conditions are predicted to 

cause PM2.5 levels to exceed 35 μg/m3 in the next 48 hours, based on a 24 hour average. 

• A Stage 2 burn ban (second stage of impaired air quality) is declared if meteorological 

conditions are not expected to change in the next 24 hours, PM2.5 levels have reached 25 μg/m3

and a Stage 1 ban has not been sufficient to reduce the increasing PM2.5 trend. A Stage 2 ban 

may be declared without first declaring a Stage 1 ban if PM2.5 levels are at or above 25 μg/m3

,

meteorological conditions have cause a rapid rise in PM2.5 levels and 35 μg/m3 may be exceeded 

in the next 24 hours.

The Stage 1 and 2 burn bans are designed to maintain the PM2.5 standard and are protective of the PM10

standard. PM2.5 is monitored at our primary site at Augusta in addition to multiple locations throughout 

Spokane County and the SCMA.

Wind Blown Dust – The SCMA is covered by the Washington State Department of Ecology Columbia 

Plateau Windblown Dust Natural Events Action Plan (NEAP). Windblown dust events will be evaluated 

for qualification under the Exceptional Events Rule (EER). If appropriate, exceedances will be flagged for 

exclusion of data from EPA’s AQS database to hold for future demonstration submittal. If values qualify 

for EER treatment, and they have regulatory significance, documentation will be submitted per EER 

requirements. 

SRCAA Orders – In addition to Regulations and Resolutions the following agency Orders were issued and 

remain in place from the first 10-year LMP. 

• SCAPCA15 Order No. 91-01, December 12, 1991, Alternate Opacity Limit for Kaiser Aluminum

• SCAPCA Order No. 96-03, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

• SCAPCA Order No. 96-04, April 24, 1996, Revised May 8, 1996, Limiting Potential to Emit, Kaiser 

Aluminum

• SCAPCA Order No. 96-05, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

• SCAPCA Order No. 96-06, October 19, 2000, Limiting Potential to Emit, Kaiser Aluminum

These Orders have been included in the Kaiser Aluminum Title V Air Operating Permit as federally 

enforceable.

7. Contingency Measures

CAA Section 175(A) requires a maintenance plan to include contingency measures necessary to ensure 

prompt correction of any violation of the standard that may occur after redesignation. 

 15 In 2007 the Board of the Spokane County Air Pollution Control Authority (SCAPCA) changed the Authority’s name 

to the Spokane Regional Clean Air Agency (SRCAA), Resolution #07-15, May 3, 2007
12

November 2015

Contingency Measure for Paved Roads – SRCAA’s Regulation 1, Section 6.14 C. 4 require review and 

modification of emission reduction and control plans for paved roads to provide sufficient reduction in 

PM10. SRCAA will consider additional control measures for paved roads, including reinstating 

requirements on businesses and private sweeping and sanding contractors removed in 2004.

Contingency Measure for Unpaved Roads – SRCAA Regulation 1, Section 6.15 G., provides a procedure

in the event that emissions from unpaved roads cause a violation of the PM10 standard. The applicable 

governmental entities shall modify their emission reduction plans to ensure compliance with the 

standard.

Contingency Measure for Residential Wood Combustion – SRCAA’s Regulation 1, Article VIII, Section 

8.09 provides a procedure for prohibition of the use of uncertified woodstoves in the Smoke Control 

Zone for the sole purpose of meeting CAA requirements for contingency measures. 

Contingency Measure Trigger – The contingency measures will be triggered if a violation of the PM10

standard occurs in the SCMA based on FRM and/or FEM monitoring. A violation of the PM10 standard 

will be determined by the procedures outlined in 40 CFR Part 50, Appendix K – Interpretation of the 

NAAQS for Particulate Matter.

8. Commitment to Continued Monitoring

EPA considers continued monitoring especially important in a LMP area because there is no cap on 

emissions; LMPs do not require an emissions budget. Emissions in the SCMA are not expected to grow 

enough to threaten compliance with the standards as discussed in Section 3.

SRCAA commits to maintaining a PM10 NAAQS compliance monitor through the LMP period. The 

monitor will be maintained and operated in accordance with federal siting and design criteria set forth 

in 40 CFR Part 58 and Ecology’s PM10 Standard Operating Procedures. Any changes to the monitor will 

be proposed under Ecology’s annual network plan and subject to EPA approval. 

9. Verification of Continued Attainment

SRCAA will calculate the SCMA PM10 3 and 5 year design values annually and submit them to Ecology for 

inclusion in the annual monitoring network report by April 30th each year through 2025 to confirm the 

area continues to meet the PM10 NAAQS. A 3-year PM10 design value below 150 μg/m3 or a 3-year 

average of 1 or fewer exceedances demonstrates continued compliance with the PM10 NAAQS16. A 5-

year design values calculated in accordance with the LMP guidance of less than 98 μg/m3 shows the 

area’s continued qualification for the LMP option. Ecology will include a statement in the annual 

network report to inform EPA of continued attainment and LMP qualification for the SCMA.

 16 Using the method in 40 CFR Part 50 Appendix K – Interpretation of the National Ambient Air Quality Standards 

for Particulate Matter 2.0 Attainment Determinations
13

November 2015

10. Summary of Maintenance Plan Commitments

Commitments made in this maintenance plan are summarized in Table 3.

Table 3. Second 10-Year LMP Commitments

Section Commitment Responsible 

Agency

3 Annual calculation of the SCMA PM10 5-year design value through 2025 to show 

continued qualification for the LMP option. Report to Ecology.

SRCAA

3 Reporting to EPA on continued qualification of the SCMA for the LMP option in 

the annual monitoring network report.

Ecology

7 Implementation of the contingency measures if the SCMA violates the PM10 

standards based on monitoring. 

SRCAA

8 Continued Monitoring of PM10 in the SCMA through 2025. SRCAA

9 Annual calculation of the SCMA PM10 3-year design value through 2025 to 

assess compliance with the PM10 standard. Report to Ecology.

SRCAA

9 Reporting to EPA on continued PM10 Attainment of the SCMA in the annual 

monitoring network report.

Ecology

11. Required Plans Complete

The SCMA was redesignated to attainment for the 1987 24-hour PM10 standard in 2005. EPA approved 

the first 10-year maintenance plan in August of 2005. This second LMP ensures compliance through 

2025 and fulfills the final requirement for maintenance plans specified by the CAA.

Summary of Control and Contingency Measures

Rules

SRCAA Section 6.05 Particulate Matter & Preventing Particulate Matter from becoming Airborne

SRCAA Section 6.14 Standards for Control of Particulate Matter on Paved Surfaces

SRCAA Section 6.15 Standards for Control of Particulate Matter on Unpaved Roads

SRCAA Article VIIISolid Fuel Burning Device Standards17

WAC 173-433 Solid Fuel Burning Device Standards

Resolutions & Orders

City of Spokane Resolution 90-93, October 8, 1990, Street Paving

City of Spokane Resolution 91-42, June 17, 1991, Six Year Comprehensive Street Program

City of Spokane Resolution 93-43, May 10, 1993, Street Sweeping & Reduced Use of Sanding Materials

Spokane County Resolution 90-1219, October 9, 1990, Street Paving

Spokane County Resolution 04-0461, 2004, County Zoning Code, Chapter 14.802 Off-street Parking and 

Loading Standards

SCAPCA Order No. 91-01, December 12, 1991, Alternate Opacity Limit for Kaiser Aluminum

 17As amended 1/6/94 Resolution 94-02. The 2014 amendments, 7/10/2014 Resolution 14-08, is proposed as a 

separate SIP amendment.
14

November 2015

SCAPCA Order No. 96-03, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

SCAPCA Order No. 96-04, April 24, 1996, Limiting Potential to Emit, Kaiser Aluminum

SCAPCA Order No. 96-05, October 4, 2000, Limiting Potential to Emit, Kaiser Aluminum

SCAPCA Order No. 96-06, October 19, 2000, Limiting Potential to Emit, Kaiser Aluminum

Contingency Measures

SRCAA Section 6.14 C.4., Standards for Control of Particulate Matter on Paved Surfaces

SRCAA Section 6.15 G., Standards for Control of Particulate Matter on Unpaved Roads

SRCAA Section 8.07 & Section 8.09, Ban on Uncertified Stoves
15

November 2015

Appendix A. Limited Maintenance Plan Qualification

Design Values

The SCMA design value based on FRM and FEM 24-hour PM10 Monitoring data from the Ferry St. and 

Augusta Ave. sites in Spokane, Washington. The LMP Guidance directs the design value be based on the 

most recent five years of data. The most recent five years of data is from 2010-2014 using a 

combination of FRM and FEM data from the Spokane-Augusta site.

SCMA Design Value

The PM10 SIP Development Guideline (SIP Guideline) allows determining the design value based on 

Table 4. Tabular Estimation of PM10 Design Values of observation ranges that designates the highest 

value to be used for the design concentration. The relevant values are shown in Table 5 below.

Table 4. Tabular Estimation of PM10 Design Values18

Number of Values Data Point to be Used

1 - 347 Highest Value

348 - 695 Second Highest Value

696 - 1042 Third Highest Value

1043 - 1390 Fourth Highest Value

Table 5. Tabular Estimation of PM10 Look-Up Concentrations Using Table 6-1 of PM10 SIP Guidelines

Spokane Ferry St FRM and FEM data 2006-2009 Spokane Augusta Ave. FRM and FEM 2009-2014

5-year Period Number of 

Observations

Look-Up Concentration

μg/m3

Data Point Used for 

Concentration

2007-2011 901 89 Third Highest Value

2008-2012 779 94 Third Highest Value

2009-2113 819 84 Third Highest Value

2010-2014 1047 80 Fourth Highest Value

Since the value for 2010-2014 is below 98 μg/m3

, the value stipulated in the LMP guidance, the SCMA 

meets this condition.

Motor Vehicle Regional Analysis

To qualify for the PM10 LMP option, an area should expect only limited growth in on-road motor vehicle 

PM10 emissions. This means the area must pass the Motor Vehicle Regional Analysis, found in 

Attachment B of the LMP Guidance. The result of the analysis must be less than 98 μg/m3

, the margin of 

Safety (MOS) value for the 24-hour PM10 standard.

The following methodology was used to determine whether increased emissions from on-road mobile 

sources could, in the next 10 years, increase concentrations in the SCMA and threaten the assumption 

of maintenance that underlies the LMP Guidance.

DV + (VMTpi x DVmv) < MOS

 18 PM-10 SIP Development Guidelines, publication EPA 450/2 86-001, Table 6-1, pp.6-5
16

November 2015

5,000,000

5,500,000

6,000,000

6,500,000

7,000,000

7,500,000

2010 2015 2020 2025 2030

VMT

VMT

Linear (VMT)

Where:

DV = The area’s design value based on the most recent 5 years of data, μg/m3

VMTpi = The projected percent increase in vehicle miles traveled (VMT) on paved roads over the next 

10 years

VMTupi = The projected percent increase in vehicle miles traveled (VMT) on unpaved roads over the 

next 10 years

DVmv = Motor vehicle design value based on on-road mobile portion of the attainment year 

inventory, μg/m3

MOS = Margin of safety for 24-hour PM10 standard is 98 μg/m3

Step 1. Determine the 5-year design value (DV)

The design value for the 5-years of data (2010-2014) as shown above is 80 μg/m3

.

Step 2. Determine the percent increase in maintenance area average VMT over the next ten years 

(VMTpi)

The VMT data for the SCMA for 2011 and 2025 was supplied by the Spokane Regional Transportation 

Council (SRTC). The percent increase in VMT was calculated by taking the difference between 2015 and 

2025 VMT per day and determining the % change. VMT on unpaved roads within the SCMA are not 

expected to increase and are given a value of 0 percent. This is the same assumption made and included 

in the first 10-year LMP, so the first calculation is done with the same assumptions. In addition the same 

calculations are done with the estimated increase on all roadways paved and unpaved. VMT values are:

Table 6. Modeled VMT Data19

Area Year

2010 2020 2030

PM10 Boundary 5,694,290 6,383,360 7,277,925

Spokane County 8,408,329 9,491,705 10,832,029

Interpolating between the 2010, 2020 and 

2030 gives the 2015 and 2025 results as:

2025 = 6,830,643

2015 = 6,038,825

This is a 10 year increase of 791,817.5 VMT

Percent Increase (VMTpi) = 13%

VMTupi = 0%

Step 3. Determine the motor vehicle design 

value based on on-road mobile portion of the 

attainment inventory (DVmv).

 19 Modeled VMT data from SRTC’s current model set used for “Horizon 2040”, their long range 

transportation plan that was approved in December of 2013.

Figure 4. Out Year VMT Estimate Plot
17

November 2015

The third paragraph of Attachment B of the LMP Guidance offers: “Please note that DVmv is derived by 

multiplying DV by the percentage of the attainment year inventory represented by on-road mobile 

sources. This variable should be based on both primary and secondary PM10 emissions of the on-road 

mobile portion of the attainment year inventory, including road dust.” Again to be conservative in our 

calculations the emissions from construction are not used in the total of all sources. This has the effect 

of increasing the contribution of onroad emissions to the design value. This further ensures that the 

NAAQS will most likely not be exceeded based on expected VMT growth.

The SCMA is further split into paved and unpaved road dust.

• DVmvp = DV * (Total paved mobile / Total all sources)

• DVmvup = DV * (Total unpaved mobile/ Total all Sources)

• DVmvet = DV * (Total on-road mobile / Total all Sources)

Table 7. Mobile Source Contribution to Design Value

Category Annual, 

tons/year

Tons/Day Contribution to 

Design Value μg/m3

Vehicle Exhaust and Tire Wear 346 .94 DVmvet 5.2587

Road Dust, Paved 780 196 DVmvp 10.9650

Road Dust, Unpaved 567 2.4520 DVmvup 13.7063

Total, all sources (less construction) 3323 14.3 DVmv 29.93

As calculated in the First 10-year Maintenance Plan

Step 4. Calculate the Regional Emissions Analysis

DV + (VMTpi * DVmvp) + (VMTupi * DVmvup) + (VMTpi * DVmvet) =

80 + (.13 * 10.9650) + (0 * 13.7063) + (.13 *5.2587) = 82 μg/m3

Step 5. Compare with MOS ≤ 98

82 μg/m3 < 98 μg/m3

Using a 13% increase in all onroad mobile emission the calculation is as follows: 

Step 4. Calculate the Regional Emissions Analysis

DV + (VMTpi * DVmv) =

80 + (.13 * 29.93) = 84 μg/m3

Step 5. Compare with MOS ≤ 98

84 μg/m3 < 98 μg/m3

The SCMA qualifies for the LMP option with either calculation.

 20 Maximum Daily Value
18

November 2015

Appendix B. Ecology 2014 Network Report/EPA approval

Purpose of the report

The Department of Ecology (Ecology) reviews its ambient air quality monitoring network each year to 

ensure that it collects adequate, representative, and useful air quality data on which to base policy 

decisions. This report summarizes the results of the 2014 review. These results include:

• Identifying modifications to Ecology’s ambient air monitoring network since the 2013 annual 

network report 

• Identifying proposed modifications to the network for the upcoming year

• Documenting Ecology’s ambient air quality monitoring needs, goals, and priorities

2014 Network Report, PM Section

The following is the PM monitoring section of the Ecology 2014 Network report for all monitors in 

Washington State, references to other monitoring has been removed.

Particulate Matter 10 (PM10, 81102)

Recommendations/Proposed Modifications: None 

Additional Monitors: None. Continue all identified sites

Thurston County Maintenance Area (Lacey PM2.5)

The Lacey College Street PM2.5 nephelometer site (530670013) is being used to assure continued 

compliance with the PM10 NAAQS as well as to confirm the Thurston County 

Maintenance Area (TCMA) continues to meet the qualification criteria of EPA’s Limited Maintenance 

Plan (LMP) approach.

A 5-year NPM10 design value below 98μg/m3 demonstrates the TCMA continues to qualify for the LMP 

approach. The Lacey-College Street nephelometer site (53670013) 5-year PM10 design value estimate 

for 2009-2013 was 45 μg/m3. The PM10 design value estimate for 2011-2013 was 45 μg/m3. This current 

design value estimates demonstrate the TCMA complies with the PM10 standard and continues to meet 

EPA’s LMP qualification criteria. 

Kent, Seattle, & Tacoma PM10 Maintenance Areas

Three and five year design values for the Kent, Seattle, and Tacoma PM10 Maintenance Areas were 

calculated using the table look up method and the statistical fit method outlined in the LMP guidance 

document.

A 3-year PM10 design value of 150 μg/m3 or below demonstrates continued compliance with the PM10 

NAAQS. A 5-year design value below 98 μg/m3 is required to qualify for the LMP approach. Design 

values calculated using the table look up method fall within the range of uncertainty of the statistical fit 

method. Because they are the most conservative values, only the statistical fit values are presented 

here.

The PM2.5 FEM TEOM at James St. and Central Ave. (530332004) is used to assure continued compliance 

with the PM10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. 

The five year design value is 47±4 μg/m3 and the three year design value is 47±3 μg/m3.
19

November 2015

The PM2.5 FEM TEOM at Seattle-Duwamish (530330057) is used to assure continued compliance with the 

PM10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The five 

year design value is 58±6 μg/m3 and the three year design value is 59±8 μg/m3.

The PM2.5 Nephelometer at Tacoma – Alexander Ave. (530530031) is used to assure continued 

compliance with the PM10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan 

approach. The five year design value is 64±12 μg/m3 and the three year design value is 65±13 μg/m3.

Table 8. Particulate Matter 10 PM10, Parameter code 81102

AQS# Site Name Est. Type Scale Sampling

Type

Action 

for 2014

530650004 Colville, S Oak 11/96 

3/07

SLAMS Neighborhood Continuous Continue

530050002 Kennewick, Metaline 

Ave.

10/94 SLAMS Neighborhood Continuous Continue

530630021 Spokane, Augusta Ave. 3/09 SLAMS Middle 1/6 Continue 

530630021 Spokane, Augusta Ave. 3/09 Collocated Middle 1/12 Continue

530770009 Yakima, S 4th 4/00 SLAMS Neighborhood 1/6 Continue

Additional Monitors: None. 

Recommendations/Proposed Modifications: None 

Note: 

Thurston County Maintenance Area (Lacey PM2.5)

The Lacey College Street PM2.5 nephelometer site (530670013) is being used to assure continued 

compliance with the PM10 NAAQS as well as to confirm the Thurston County 

Maintenance Area (TCMA) continues to meet the qualification criteria of EPA’s Limited Maintenance 

Plan (LMP) approach.

A 5-year NPM10 design value below 98μg/m3 demonstrates the TCMA continues to qualify for the 

LMP approach. The Lacey-College Street nephelometer site (53670013) 5-year PM10 design value 

estimate for 2009-2013 was 45 μg/m3. The PM10 design value estimate for 2011-2013 was 45 μg/m3. 

This current design value estimates demonstrate the TCMA complies with the PM10 standard and 

continues to meet EPA’s LMP qualification criteria. 

Kent, Seattle, & Tacoma PM10 Maintenance Areas

Three and five year design values for the Kent, Seattle, and Tacoma PM10 Maintenance Areas were 

calculated using the table look up method and the statistical fit method outlined in the LMP guidance 

document.”

A 3-year PM10 design value of 150 μg/m3 or below demonstrates continued compliance with the PM10 

NAAQS. A 5-year design value below 98 μg/m3 is required to qualify for the LMP approach. Design 

values calculated using the table look up method fall within the range of uncertainty of the statistical fit 
20

November 2015

method. Because they are the most conservative values, only the statistical fit values are presented 

here.

The PM2.5 FEM TEOM at James St. and Central Ave. (530332004) is used to assure continued compliance 

with the PM10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. 

The five year design value is 47±4 μg/m3 and the three year design value is 47±3 μg/m3.

The PM2.5 FEM TEOM at Seattle-Duwamish (530330057) is used to assure continued compliance with the 

PM10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan approach. The five 

year design value is 58±6 μg/m3 and the three year design value is 59±8 μg/m3.

The PM2.5 Nephelometer at Tacoma – Alexander Ave. (530530031) is used to assure continued 

compliance with the PM10 NAAQS and to confirm continued eligibility for the Limited Maintenance Plan 

approach. The five year design value is 64±12 μg/m3 and the three year design value is 65±13 μg/m3.

Colville, S Oak 

Site Name Colville, S Oak

AQS ID 530650004

GPS coordinates LAT/LONG: 048 32' 41" / 117 54' 13"

Location On the roof of the Courthouse

Address 215 South Oak, Colville

County Stevens

Distance to road from gaseous probe (meters) 20

Traffic count (AADT, year) N/A
21

November 2015

Groundcover Asphalt, cement, grass

Statistical Area Not in an urban area

Monitor Information Pollutant, POC 

Parameter code 81102

Basic monitoring objectives(s) NAQQS Compliance

Site type(s) Population Exposure

Monitor type(s) SLAMS

Instrument manufacturer and model Thermo TEOM

Method code 079

FRM/FEM/ARM/other FEM

Collecting Agency Ecology

Analytical Lab N/A

Reporting Agency Ecology

Spatial scale Neighborhood 

Monitoring start date 11/96

Current sampling frequency Continuous

Calculated sampling frequency N/A

Sampling season Year-round

Probe height (meters) 2

Distance from supporting structure (meters) N/A

Distance from obstructions on roof (meters) N/A

Distance from obstructions not on roof (meters) N/A

Distance from trees (meters) 50+

Distance to furnace or incinerator flue (meters) N/A

Distance between collocated monitors (meters) N/A

Unrestricted airflow (degrees) 360

Spacing from minor sources No minor sources

Probe material for reactive gases Teflon

Residence time for reactive gases (seconds) N/A

Changes within the next 18 months? None anticipated

Is it suitable for comparison against the PM10

NAAQS? 

Yes

Design value 0.34

Purpose: Colville S. Oak is a neighborhood scale site for PM10 established in 1996, located in the 

commercial/residential area of Colville on the roof of the Courthouse. 

Exceedences: This site has exceeded the standard for PM10 in the past 3 years (2011). 

Kennewick, Metaline Avenue – (BCAA) 

Site Name Kennewick, Metaline Avenue

AQS ID 530050002

GPS coordinates LAT/LONG: 046 13' 06" / 119 12' 03"

Location On the roof of the Kennewick Skills Center

Address 5929 West Metaline, Kennewick

County Benton
22

November 2015

Distance to road from gaseous probe (meters) 84

Traffic count (AADT, year) N/A

Groundcover Rooftop- asphalt, ground-grass & asphalt

Statistical Area Richland-Kennewick-Pasco, WA

Kennewick, Metaline Avenue Monitor Information 

Pollutant, POC 

Parameter code 81102

Basic monitoring objectives(s) NAQQS Compliance

Site type(s) Population Exposure

Monitor type(s) SLAMS

Instrument manufacturer and model Thermo TEOM

Method code 079

FRM/FEM/ARM/other FEM

Collecting Agency Benton County Clean Air Agency

Analytical Lab N/A

Reporting Agency Ecology

Spatial scale Neighborhood

Monitoring start date 10/94

Current sampling frequency Continuous

Calculated sampling frequency N/A

Sampling season Year-round

Probe height (meters) 7

Distance from supporting structure (meters) N/A

Distance from obstructions on roof (meters) 18

Distance from obstructions not on roof (meters) N/A

Distance from trees (meters) 66

Distance to furnace or incinerator flue (meters) N/A

Distance between collocated monitors (meters) 6

Unrestricted airflow (degrees) 360

Probe material for reactive gases Teflon

Residence time for reactive gases (seconds) N/A

Changes within the next 18 months? None anticipated

Is it suitable for comparison against the PM10 NAAQS? Yes

Design value 1.6 (0.41)

Purpose: Kennewick is a neighborhood scale site for PM10 established in 1994 and located in the 

downtown Kennewick area. It is representative of Kennewick and the surrounding area which is subject 

to windblown dust. 

Exceedences: Kennewick had 3 exceedances of 24-hr PM10 standard in 2013 and Washington plans to 

pursue exceptional event status for them. 

1 Pending exceptional events demonstration for high winds on 9/15/2013, 10/28/2013 and 11/02/2013.

Spokane, Augusta Ave. – (SRCAA) 

Site Name Spokane, Augusta Avenue.

AQS ID 530630021
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November 2015

GPS coordinates LAT/LONG: 047 39' 39" / 117 21' 26"

Location On the roof of the Spokane Region Clean Air Agency

Address 3104 E. Augusta Ave., Spokane

County Spokane

Distance to road from gaseous probe (meters) 27

Traffic count (AADT, year) N/A

Groundcover Membrane roof, asphalt

Statistical Area Spokane, WA

Monitor Information Pollutant, POC 

Parameter code 81102

Basic monitoring objectives(s) NAQQS Compliance

Site type(s) Population Exposure

Monitor type(s) SLAMS - Collocated

Instrument manufacturer and model Thermo TEOM 

Method code 079

FRM/FEM/ARM/other FEM/FRM

Collecting Agency Spokane Region Clean Air Agency

Analytical Lab Ecology

Reporting Agency Ecology

Spatial scale Middle

Monitoring start date 3/09

Current sampling frequency Continuous & 1/6

Calculated sampling frequency N/A

Sampling season Year-round

Probe height (meters) 3

Distance from supporting structure (meters) 0.5

Distance from obstructions on roof (meters) N/A

Distance from obstructions not on roof (meters) N/A

Distance from trees (meters) N/A

Distance to furnace or incinerator flue (meters) N/A

Distance between collocated monitors (meters) N/A

Unrestricted airflow (degrees) 360

Spacing from minor sources No minor sources

Probe material for reactive gases Teflon

Residence time for reactive gases (seconds) N/A

Changes within the next 18 months? None anticipated

Is it suitable for comparison against the PM10 NAAQS? Yes

Design value 0.35

Purpose: Augusta Ave. is a middle scale site for PM10 located in a commercial area of Spokane. The site 

is representative of the Spokane area which is a past PM10 nonattainment area.

Exceedences: We had one exceedance of the 24-hour PM10 standard at Spokane. We have flagged this 

value, leaving open the possibility that we could submit an exceptional event demonstration to EPA in 

the future.

Yakima, S 4th – (YRCAA) 
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November 2015

Site Name Yakima, S 4th

AQS ID 530770009

GPS coordinates LAT/LONG: 046 35' 42" / 120 30' 44"

Location On the roof of Yakima Comprehensive Mental Health

Address 402 South 4th Avenue, Yakima

County Yakima

Distance to road from gaseous probe (meters) N/A

Traffic count (AADT, year) N/A

Groundcover Membrane roof, cement

Statistical Area Yakima, WA

Monitor Information Pollutant, POC 

Parameter code 81102

Basic monitoring objectives(s) NAQQS Compliance

Site type(s) Population Exposure

Monitor type(s) SLAMS

Instrument manufacturer and model Grasby Anderson

Method code 063

FRM/FEM/ARM/other FRM

Collecting Agency Yakima Region Clean Air Agency

Analytical Lab Ecology

Reporting Agency Ecology

Spatial scale Neighborhood

Monitoring start date 4/00

Current sampling frequency 1/6

Calculated sampling frequency N/A

Sampling season Year-round

Probe height (meters) 2 rooftop, 12 ground

Distance from supporting structure (meters) N/A

Distance from obstructions on roof (meters) 7

Distance from obstructions not on roof (meters) N/A

Distance from trees (meters) 34

Distance to furnace or incinerator flue (meters) N/A

Distance between collocated monitors (meters) N/A

Unrestricted airflow (degrees) 360

Spacing from minor sources No minor sources

Probe material for reactive gases Teflon

Residence time for reactive gases (seconds) N/A

Changes within the next 18 months? None anticipated

Is it suitable for comparison against the PM10 NAAQS? Yes

Design value 0

Purpose: S 4th is a neighborhood scale site for PM10 located in a commercial/residential area near 

downtown Yakima. The site is representative of the Yakima area, a past PM10 nonattainment area. 

Exceedences: This site has not exceeded standard for PM10 in the past 3 years.
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Appendix C. Emission Inventory Documentation

Ecology’s 2011 triennial emissions inventory (2011 EI) was used for the 2nd 10-year LMP. The 2011 

estimates were available as annual emissions for Spokane County. In the original maintenance plan and 

LMP (2005) SRCAA contracted with E.H. Pechan and Associates, Inc. to develop a very detailed emission 

inventory. For this LMP we concentrated on the significant emissions involved in the three worst-case 

scenarios from the attainment plan and first LMP; unpaved roads, paved roads and residential wood 

combustion. Temporal and spatial allocations to the maintenance area of most of the source categories 

were the same as developed by Pechan21 for the first LMP. For any emissions not modified from the 

2011 Emissions Inventory, refer to the discussion found in that document. For categories where local 

data was not available Ecology accepted the EPA estimates in the NEI for the missing categories.

 

Point Sources

Point source emissions were based on 2011 data22 submitted directly to SRCAA by the Air Operating 

Permit sources and spatially allocated based on facility location. 

Nonpoint Sources

Residential Wood Combustion, Paved Road Dust and Unpaved Road Dust are nonpoint sources. These 

emissions are typically estimated by multiplying an activity level, such as wood combusted or Vehicle 

Miles Traveled (VMT), by an emission factor in mass per activity.

Emissions = Activity level x Emission Factor

Estimation methods and data sources for these nonpoint sources are described below.

Residential Wood Combustion

Residential wood combustion (RWC) emissions are based on the 2011 Emission Inventory. RWC consists 

of home heating and recreational use of woodstoves, fireplaces, and fireplace inserts. Activity 

parameters for the 2011 EI include the type of wood burning devices [certified (catalytic and 

noncatalytic) woodstoves, uncertified woodstoves and fireplaces], the amount and species of wood 

burned from each device and seasonal, daily and hourly usage rates. A survey was conducted in 2007 by 

the National Research Center (NRC2007). It covered the central Puget Sound region. The NRC2007 

survey was used in the 2011 EI to characterize all counties except those classified as eastern WA 

rangeland. Spokane County was characterized using the household weighted average of all the Puget 

Sound survey areas from the NRC2007 except King County. Emission factors in pounds of PM10 per ton 

of wood burned were taken from version 1 of EPA’s 2011 Residential Wood Combustion tool. 

Temporal and spatial allocations to the maintenance area of the RWC emissions were the same as 

developed by Pechan23 for the first LMP.

 21 E.H. Pechan and Associates, Inc., 2002 PM10 Emission Inventory for the Spokane Nonattainment Area, September 

2004, Pechan Report No. 04.08.002/9443.003 22 2011 emission data was obtained from the SRCAA 2012 AOP billing information. 23 E.H. Pechan and Associates, Inc., 2002 PM10 Emission Inventory for the Spokane Nonattainment Area, September 

2004, Pechan Report No. 04.08.002/9443.003
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Table 9. Spokane County Residential Wood Combustion Emissions

Device Type Emission 

rate by 

type

Tons Burned

(Spokane 

County)

Emissions

Tons/year

Fireplace 23.6 21459 253.22

Inserts, certified catalytic 20.4 4319 44.05

Woodstoves, certified catalytic 20.4 6931 70.70

Inserts, certified non-catalytic 19.6 12956 126.96

Woodstoves, certified non-catalytic 19.6 2079 203.78

Inserts, uncertified 30.6 15933 243.77

Woodstoves, uncertified 30.6 25574 391.28

Pellet stoves 3.06 2291 3.51

Firelogs, all devices 29.32 1051 15.41

Total 1352.68

Paved Road Dust

Paved Road Dust emissions are based on the 2011 EI. Average Daily Vehicle Miles Traveled (ADVMT) for 

Spokane County was estimated by Washington State Department of Transportation (WSDOT) under the 

national Department of Transportation’s Highway Performance Monitoring System (HPMS). HPMS is a 

system of traffic counts collected over several urban and rural sampling areas. WSDOT makes estimates 

of county VMT by roadway (functional) classification using the HPMS data. PM10 emission rates in grams 

per mile were calculated using equation 2 in EPA’s AP42. Monthly emissions were calculated using 

monthly adjustment factors and summing the appropriate months to get seasonal and annual 

emissions.

Unpaved Road Dust

Similar to paved roads, unpaved road dust emissions are generated as vehicles pass along unpaved 

roadways and disturb the layer of loose material on or near the road surface. The unpaved road 

calculation excludes emissions from exhaust and brake and tire wear, which are estimated as part of the 

onroad mobile source emissions. 

ADVMT is used to estimate unpaved road activity and calculate dust emissions. The County Road 

Administration Board (CRAB) provided roadway mileage and ADVMT estimates on unpaved roads by 

county. WSDOT provided estimates of city jurisdiction unpaved roadway mileage for each county. The 

CRAB data was used to develop average daily traffic (ADT) per mile; this was multiplied by the latest 

miles of unpaved roads in Spokane County and the SCMA obtained from the Spokane Regional 

Transportation Council to get the ADVMT.

Ecology used equation 2 of EPA’s AP42 to develop monthly unpaved roads PM10 Emission Rates in lb/mi, 

Table 3-8 of the 2011 EI. SRCAA used ADVMT for Spokane County’s SCMA unpaved roads and the 

monthly emission rate to get daily and annual unpaved road emissions. 
29

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Table 10. Unpaved Road Emissions Calculations

Spokane County SCMA

Month lb/mi Days ADVMT Tons/month Tons/day ADVMT Tons/month Tons/day

JAN 0.202 31 116708 365 11.79 12929 37 1.19

FEB 0.283 28 116708 462 16.51 12929 47 1.67

MAR 0.121 31 116708 219 7.06 12929 22 0.71

APR 0.167 30 116708 292 9.75 12929 29 0.98

MAY 0.202 31 116708 365 11.79 12929 37 1.19

JUN 0.306 30 116708 536 17.86 12929 54 1.80

JUL 0.323 31 116708 584 18.85 12929 59 1.90

AUG 0.417 31 116708 754 24.33 12929 76 2.45

SEP 0.362 30 116708 634 21.12 12929 64 2.13

OCT 0.229 31 116708 414 13.36 12929 42 1.35

NOV 0.264 30 116708 462 15.41 12929 47 1.55

DEC 0.296 31 116708 535 17.27 12929 54 1.74

Annual Unpaved Road Emissions 5624 567

Average Daily Unpaved Road Emissions 15.42 1.56

ADVMT

ADT/mile 96.5

Spokane Co

miles

1209.41 116708

SCMA miles 121.97 11770

 
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Appendix D. Changes to Regulation 1 – Article VI – Emissions Prohibited

since adoption into the SIP

SRCAA notes that Section 6.05(A) is a nuisance provision outside the scope of regulating criteria 

pollutants under Clean Air Action section 110 and requests that the EPA correct the SIP to remove this 

provision.

SECTION 6.05 PARTICULATE MATTER AND PREVENTING PARTICULATE MATTER FROM

BECOMING AIRBORNE

A. It shall be unlawful for any person to cause or allow the discharge of particulates in sufficient 

numbers to unreasonably cause annoyance to any other person when deposited upon the real property 

of others, except as follows:.

1. Temporarily due to breakdown of equipment provided the breakdown is reported as soon as 

possible but no later than the next regular working day and repairs are promptly made.

2. The time period allowed by the Control Officer for the owner or operator to meet the 

compliance order.

B. It shall be unlawful for any person to cause or permit particulate matter to be handled, transported or 

stored without taking reasonable precautions to prevent the particulate matter from becoming 

airborne.

C. It shall be unlawful for any person to cause or permit a building or its appurtenances or a road to be 

constructed, altered, repaired, or demolished without taking reasonable precautions to prevent 

particulate matter from becoming airborne. Reasonable precautions to prevent particulate matter from 

becoming airborne must also be used on roads used as detour routes around roads, or section of road 

that are being constructed, altered, repaired, demolished, or closed for any purpose.

D. It shall be unlawful for any person, including the owner or person in control of real property to cause 

or allow particulate matter to be deposited upon a paved roadway open to the public without taking 

every reasonable precaution to minimize deposition. Reasonable precautions shall include, but are not 

limited to, the removal of particulate matter from equipment prior to movement on paved streets and 

the prompt removal of any particulate matter deposited on paved streets.

E. It shall be unlawful for any person to cause or allow visible emissions of fugitive dust unless 

reasonable precautions are employed to minimize the emissions. Reasonable precautions may include, 

but are not limited to, one or more of the following:

1. The use of control equipment, enclosures, and wet (or chemical) suppression techniques, and 

curtailment during high winds;

2. Surfacing roadways and parking areas with asphalt, concrete, or gravel;

3. Treating temporary, low traffic areas (e.g., construction sites) with water or chemical 

stabilizers, reducing vehicle speeds, constructing pavement or rip rap exit aprons, and cleaning 
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November 2015

vehicle undercarriages and tires before they exit to prevent the track-out of mud or dirt onto 

paved public roadways; or

4. Covering or wetting truck loads or allowing adequate freeboard to prevent the escape of 

dust-bearing materials.

SECTION 6.14 STANDARDS FOR CONTROL OF PARTICULATE MATTER ON PAVED SURFACES

A. Applicability. The provisions of Section 6.14 shall apply to any government agency of a state, county, 

city or local government municipal corporation or private company that applies or contracts for 

application of sanding materials to or mechanically sweeps or vacuums or contracts for sweeping or 

vacuuming of paved surfaces within the PM10 Nonattainment area, or within the PM10 maintenance 

area after the nonattainment area is redesignated to attainment. This Section shall also apply to all 

suppliers of sanding materials to be used by these affected entities.

B. Definitions.

1. Affected Entity is any governmental agency of a state, county, city or local government

municipal corporation as or private company that applies sanding material to, or mechanically 

sweeps or vacuums paved surfaces within the PM10 Nonattaiment area described in Subsection 

A.

2. Approved Laboratory means a certified or approved facility capable of performing the 

specified tests in a competent, professional, and unbiased manner in accordance with ASTM 

testing procedures.

3. The Authority is the Spokane County Air Pollution Control Authority Regional Clean Air 

Agency.

4. Base Sanding Amount is the average amount of sanding materials applied per lane mile by 

each affected entity within the PM10 Nonattainment Area during the 1992 – 1993 season or 

another base season, as requested by an affected entity and approved by the Authority.

5. Durability Index means the percent loss of weight as determined using ASTM "Standard Test 

Method for Resistance to Degradation of Small-Size Coarse Aggregate by Abrasion and Impact in 

the Los Angeles Machine", designated C131-89, or other approved ASTM procedure.

6. Full Deployment means that sanding materials have been applied to all priority roadways 

targeted for treatment during a snow/ice event are sanded.

7. Percent Fines means the percent material passing a #100 sieve as determined by the 

American Society for Testing Materials (ASTM) "Standard Method for Sieve Analysis of Fine and 

Coarse Aggregates", Designation C136-84a (1988) (American Highway and Transportation 

Officials designation T27-88), or other approved ASTM procedure.

8. PM10 Maintenance Area means the same as the PM10 Nonattainment area unless otherwise 

defined in an approved PM10 Maintenance Plan.
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89. PM10 Nonattainment Area means the Spokane County PM10 Nonattainment Area, defined 

in CFR Title 40, Part 81, as designated on November 15, 1990. This definition will remain in 

effect, even after the United States Environmental Protection Agency makes a determination 

that the PM10 standard that existed before September 16, 1997, no longer applies to Spokane 

County. Retaining the definition ensures compliance with the Environmental Protection 

Agency’s Guidance for Implementing the 1-Hour Ozone and Pre-Existing PM10 NQQAS, dat3ed 

December 29, 1997, by continuing implementation of control measures in the State 

Implementation Plan and preserving air quality gains.

910. Priority Roadway means any street, arterial, or highway, within the PM10 Nonattainment 

Area, with more than 15,000 average daily traffic count, and any connecting entrance or exit 

ramp. 

101. Recycled Sanding Materials means previously used sanding materials which have been 

collected from roadways or paved areas and are then re-used as is, after washing, or after 

blending with new sanding materials.

112. Sanding Materials means natural geologic materials, excluding salt and other de-icing 

chemicals, used to provide increased traction on roadways or paved areas.

123. Season means the period beginning, November 1, in one calendar year and concluding on 

April 30, the next calendar year.

C. Emission reduction and control plans. Each affected entity shall submit to the Authority an initial plan, 

including an implementation schedule describing the programs and methods to be used to reduce PM10 

emissions from paved surfaces, within 30 days after the effective date of this regulation. If the affected 

entity incorporated after the effective date of this regulation, that entity shall submit an initial plan 

within 180 days of incorporation. In reviewing each plan, the Authority shall allow consideration of 

mobility and transportation safety factors. Approval of any plan shall require that the Authority 

determine In approving any initial plan, or plan revision the Authority must make a finding, in 

consultation with the Washington State Department of Ecology, that the cumulative effect of the plans 

submitted by all affected entities will achieve and maintain at least a 70% reduction, from the 1992 -

1993 base season, in the 24 hour PM10 emissions from paved surfaces.

1. Each plan is subject to approval by the Authority and shall address but not necessarily be 

limited to, at a minimum, all of the following:

a. Base sanding amount;

b. Percent sanding reduction goal;

c. Sanding materials specifications to be employed;

d. Criteria for application of sanding materials. Where and when sanding materials are 

applied;

de. Identification of priority roadways;
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November 2015

ef. Locations, application rates, and circumstances for the use of chemical deicers and 

other sanding alternatives;

fg. Street sweeping frequency and technology to be employed;

h. Factors for determining when and where to initiate street sweeping following a 

sanding event, with the goal of expeditious removal of sanding materials from priority 

roadways when safety and mobility requirements have been satisfied;

hi. An implementation schedule giving the estimated dates of start and completion, if 

applicable, of each part of the plan; and

j. A schedule for removal of sanding materials from all surfaces to which they are 

applied.

2. Beginning 30 days after the effective date of the regulation, t The plans submitted shall be 

implemented by each affected entity. Uupon approval of each plan, the affected entity shall 

implement the approved plan. 

3. Within 45 days of submittal of the reports required in Subsection GF. of this Section, the 

Authority shall determine if the plan commitments have been met and shall notify any each 

affected entity that has failed to meet plan commitments fully implement its plan.

4. If the authority determines that any governmental entity has failed to meet the plan 

commitments, the Authority, shall require that any affected governmental entity submit a 

revised plan within 30 days of notification by the Authority. The revised plan shall establish 

methods for meeting the plan commitments. Any revised plan must be implemented upon 

approval by the Authority.

54. If the Authority, after consultation with the affected entities, the Washington Department of 

Ecology, and the United States Environmental Protection Agency, determines that the emission 

reduction and control plans do not provide for sufficient reduction in PM10 emissions to achieve 

the emission reduction credit for paved road surfaces as contained in the State Implementation 

Plan, the Authority may require the any or all affected governmental entities to modify their 

plans in order to achieve additional reductions.

5. Each affected entity shall review their approved plan within 90 days of the effective date of 

the amendment to this regulation and every five (5) years thereafter and within 90 days of the 

Authority’s determination made pursuant to Subsection C. 4. and revise the plan as appropriate 

to ensure that identified priority roadways reflect changes in traffic counts and driving patterns 

and that all aspects of the plan reflect current sanding and sweeping technologies, programs, 

and schedules of the affected entity and requirements of the Authority. All amended plans are 

subject to approval by the Authority.

D. Sweeping requirements. Beginning the effective date of this regulation, the City of Spokane, 

Spokane County, and the Washington State Department of Transportation, or their contractors, shall 

clean all priority roadways in an expeditious manner following each event when road conditions are 
34

November 2015

appropriate and safety and mobility requirements have been satisfied. Cleaning shall be accomplished 

with broom sweepers or a more effective technique approved by the Authority.

ED. Sanding Materials Specifications

1. Material Standards. No affected entity shall use sanding materials, whether new or recycled, 

which equal or exceed 3% fines and 25% durability index.

2. Contractual Requirements. After the effective date of this regulation, no affected entity shall 

execute a contract for the purchase of sanding materials unless the contract includes standards 

at least as stringent as those set forth in Subsection E.1. of this Section.

FE. Testing

1. Supplier Testing Requirements

a. Suppliers of sanding materials shall have tests performed by an approved laboratory 

to determine the percent fines and durability index on representative samples of their 

sanding materials which are supplied to affected entities.

b. The sampling and test frequency and methodology used shall ensure that the samples 

are representative and enable the supplier to certify to the affected entity that the 

actual sanding materials supplied for use will meet the requirements of Subsection ED. 

of this Section.

2. User Requirements. Affected entities or their contractors shall have at least one test

performed by an approved laboratory to determine the percent fines and durability index on all 

recycled materials at least once for the first 250 tons of recycled materials used each season and 

at least once for every 500 tons of recycled materials used thereafter during the same season.

3. Authority Audits. The Authority may enter the site of any affected entity or supplier of 

sanding materials subject to this Section for the purpose of obtaining a sample of sanding 

materials to determine if the materials meet the requirements of Subsection ED. of this Section.

GF. Reporting

1. Supplier Reporting Requirements. Prior to, or upon, delivery of sanding materials, suppliers 

shall provide affected entities that use their sanding materials a report demonstrating that the 

supplier has met all testing requirements of this Section applicable to the time period in which 

deliveries are made. The supplier shall certify in writing to the affected entity that the sanding 

materials meet the requirements of Subsection ED. of this Section.

2. Affected Entity Reporting Requirements

a. Affected entities that use recycled sanding materials shall submit to the Authority 

copies of the results of testing conducted according to Subsection FE.2. of this Section 

no later than 30 days after the tests are conducted.
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November 2015

b. No later than June 30, of each year, affected governmental entities shall submit a 

report to the Authority containing information for the preceding season on:

1) the total amount of sanding materials (both new and recycled) and salt and 

other deicing chemicals used;

2) the number of lane miles sanded, salted and deiced; and

3) the number of full deployment episodes; and

4) the same information specified in b.(1), b.(2) and b.(3), for all private 

companies performing sanding, salting, or deicing services under contract with 

the affected governmental intity.

c. No later than June 30, of each year, private companies that use 250 tons of sanding 

material or more per season for non-governmental applications within the PM10 

nonattainment area shall submit a report to the Authority containing information for 

the preceding season on the total amount of sanding materials (both new and recycled) 

and salt and other deicing chemicals used; 

dc. Within 7 calendar days of awarding a contract for the purchase of sanding materials 

to a supplier, an affected entity shall notify the Authority of the supplier's name and 

location of the aggregate sources from which the materials will be supplied.

ed. Affected entities shall maintain on file reports received under the provisions of

Subsection GF.1. of this Section for a period of three (3) years.

3. Sweeper Reporting Requirements

a. Affected entities shall maintain monthly records to document the information 

described below. No later than June 30, of each year, each affected entity shall submit a 

report to the Authority which that shall contain the information described below for 

each priority roadway.

1) Date of each sweeping operation;

2) Priority Llane miles swept;

3) All other lane miles swept;

34) Type of equipment used; and

45) Number of passes on priority roadways.

5) The same information specified in a.(1), a(2), a(3) and a.(4), for all private 

companies performing sweeping under a contract with the affected 

governmental entity.
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November 2015

4. Authority Audits. All records generated under the provisions of this Section shall be made 

available for inspection upon request by the Authority.

HG. Alternate Test Methods and Standards. Alternate percent fines and durability index test procedures 

may be approved by the Authority should they be determined to provide a measure that is equivalent to 

the test procedures of this Section.

IH. Alternate Sanding Materials. Experimentation with new sanding materials may be approved by the 

Authority provided the Authority finds that the impact of such experiments will not cause or contribute 

to a violation of the National Ambient Air Quality Standard (NAAQS) for PM10 a failure to maintain the 

70% reduction in PM10 emissions from the 1992-93 base season, as described in Subsection C.

J. Failure to comply with this Section will subject affected entities and/or suppliers to penalties as 

provided in Article II of this Regulation.

SECTION 6.15 STANDARDS FOR CONTROL OF PARTICULATE MATTER ON UNPAVED ROADS

A. Applicability. The provisions of Section 6.15 shall apply to:

1. The City of Spokane, the Town of Millwood, Spokane County, and other governmental entities 

responsible for the maintenance of unpaved public roads within the PM10 Nonattainment Area; 

and

2. Those specific unpaved public roads which have been identified by Ecology or the Authority 

for inclusion in an implementation plan or a maintenance plan for control of PM10 emissions.

B. Definitions.

1. Authority means the Spokane County Air Pollution Control Authority Regional Clean Air 

Agency.

2. Ecology means the Washington Department of Ecology.

3. EPA means the United States Environmental Protection Agency or the Administrator of the 

United States Environmental Protection Agency or his/her designated representative.

4. Implementation Plan has the same meaning as in Section 110 of the Federal Clean Air Act (42 

USC 7410).

5. Maintenance Plan has the same meaning as in Section 175A of the Federal Clean Air Act (42 

USC 7505).

6. Palliative means salts and other hygroscopic materials, petroleum resins, asphalt emulsions, 

adhesives, chemical soil stabilizers or other surface treatment materials acting as a method of 

dust control, and not prohibited for use by any local, state, or federal law, rule, or regulation.

7. Paved means application of concrete, asphaltic concrete, asphalt, or combination thereof as a 

means of forming a permanent surface for a road.
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November 2015

8. PM10 Nonattainment Area means the Spokane County PM10 Nonattainment Area, defined in 

CFR Title 40, Part 81, as designated on November 15, 1990. This definition will remain in effect, 

even after EPA makes the determination that the PM10 standard that existed before September 

16, 1997, no longer applies to Spokane County. Retaining the definition ensures compliance with 

the EPA’s Guidance for Implementing the 1-Hour Ozone and Pre-Existing PM10 NAAQS, dated 

December 29, 1997, by continuing implementation of control measures in the Implementation 

Plan and preserving air quality gains.

9. Reasonable Further Progress has the same meaning as in Section 171(1) of the Federal Clean 

Air Act (42 USC 7501).

C. Emission Reduction and Control Plan. Each applicable governmental entity shall submit an Emission 

Reduction and Control Plan for approval by the Authority, which includes the following for each 

applicable unpaved road:

1. A schedule for paving, periodic application of palliative, or implementation of other control 

measures.

2. Specification of the type of palliative to be applied and its application rate, paving 

specifications, or specifications of other control measures with sufficient detail for the Authority 

to determine emission reductions.

D. Emission Reduction Contingency Plan. Each applicable governmental entity shall submit an Emission 

Reduction Contingency Plan for approval by the Authority, which includes the following for each 

applicable unpaved road:

1. A schedule for paving, periodic application of palliative, or implementation of other control 

measures.

2. Specification of the type of palliative to be applied and its application rate, paving 

specifications, or specifications of other control measures with sufficient detail for the Authority 

to determine emission reductions.

E. Effective dates. The applicable governmental entities shall comply with the following effective dates 

whenever an unpaved road is identified by Ecology or the Authority for control of PM10 emissions as 

part of an implementation plan:

1. For any unpaved road so identified prior to the effective date of Section 6.15 of this 

regulation, the entity shall submit the Emission Reduction and Control Plan or Emission 

Reduction Contingency Plan, whichever applies, within 60 days after the effective date.

2. For any unpaved road so identified after the effective date of Section 6.15 of this regulation, 

the entity shall submit the Emission Reduction and Control Plan or Emission Reduction 

Contingency Plan, whichever applies, within 60 days after such identification.

F. Approval and Implementation.
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November 2015

1. The Authority shall review the Emission Reduction and Control Plan submitted pursuant to 

Section 6.15.C. of this Regulation and within 60 days after approval by the Authority, the 

applicable governmental entity shall implement the plan.

2. The Authority shall review the Emission Reduction Contingency Plan submitted pursuant to 

Section 6.15.D of this Regulation and upon approval by the Authority and within 60 days after 

the EPA makes the findings in Section 6.15.G of this Regulation, the applicable governmental 

entity shall implement the plan.

3. The Authority will not approve an Emission Reduction and Control Plan or an Emission 

Reduction Contingency Plan unless the Authority finds that the plans will achieve the total 

emission reductions required by the implementation plan. If the Authority finds that a plan will 

not achieve the required reductions, then the applicable governmental entity shall revise the 

plan to achieve the required reductions and resubmit the plan for review by the Authority.

G. Findings by EPA. In the event the EPA determines that the Spokane PM10 Nonattainment Area has 

failed to make Reasonable Further Progress or has failed to timely attain a National Ambient Air Quality 

Standard for PM10 or has violated a National Ambient Air Quality Standard for PM10 after redesignation 

as an attainment area, and emissions from unpaved roads are determined by the EPA, in consultation 

with Ecology and the Authority, to be a contributing factor to such failure or violation, the applicable 

governmental entities shall comply with the requirements of Section 6.15.F.2 of this Regulation.

H. Reporting. Within 6 months after the effective date of Section 6.15 of this Regulation, and annually 

thereafter as determined by the Authority, each applicable governmental entity shall submit a written 

report to the Authority which demonstrates compliance with the Emission Reduction and Control Plans 

and the Emission Reduction Contingency Plans.

I. Failure to comply. Failure to comply with Section 6.15 of this Regulation will subject affected entities 

to penalties as provided in Article II of this Regulation.

SECTION 6.16 MOTOR FUEL SPECIFICATIONS FOR OXYGENATED GASOLINE (Repealed 9/1/05,

Res. 05-19)