# Response to Comments :

State Implementation Plan Revision

f or Spokane County Second 10

- Year Limited Maintenance Plan for PM 10



### December 2015

Publication no. 15

- 02

- 023

## Publication and Contact Information

This report is available on the Department of Ecology’s website at https://fortress.wa.gov/ecy/publications/SummaryPages/1502023.html

For more information contact:

Air Quality Program

P.O. Box 47600 Olympia, WA 98504

- 7600

Phone: 360

- 407

- 6800

Washington State Department of Ecology

- www.ecy.wa.gov

o Headquarters, Olympia 360

- 407

- 6000

o Northwest Regional Office, Bellevue 425

- 649

- 7000

o Southwest Regional Office, Olympia 360

- 407

- 6300

o Central Regional Office, Yakima 509

- 575

- 2490

o Eastern Regional Office, Spokane 509

- 329

- 3400

To request ADA accommodation, call (360) 407

- 6800, 711 (relay service), or 877

- 833

- 6341 (TTY).

# Response to Comments :

State Implementation Plan Revision



# for Spokane County Second 10

- Year

Limited Maintenance Plan for PM 10

Air Quality Program Washington State Department of Ecology

Olympia, WashingtonSpokane PM 10 LMP i December 2015 

# Table of Contents

Page

Acknowledgements

................................ ................................ ................................ ............. ii

Executive Summary

................................ ................................ ................................ ........... iii

Reasons fo r Adopting SIP Revision

................................ ................................ .................... 1

Differences Between the Proposed SIP Revision and Adopted SIP Revision

..................... 1

Summary of Public Involvement Process

................................ ................................ ............ 2 Affidavit of Publication, Legal Notice, Spokesman Review, October 2, 2015

..... 3 News Release or Blog, October 1, 2015

................................ ................................ 4 Ecology website, October 1, 2015

................................ ................................ ........ 5 Ecology Public Involvement Calendar Notices

................................ ..................... 6 Spokane Regional Clean Air Agency News Release, October 1, 2015

................ 8 Spokane Regional Clean Air Outre ach,

................................ ............................... 10 September 28 and 29 Email and Stakeholder List

................................ ............... 10 Ecology Listserv Message, October 1, 2015

................................ ....................... 12 Message

................................ ................................ ................................ ............... 12 Memo Certifying No Hearing Was Requested

................................ .................... 13 Hearing Cancellation Notice/Public Involvement Calendar, October 26, 2015

. 14

Response to Comments

................................ ................................ ................................ ...... 16 Comment Received from Fred Greef, November 8, 2015

................................ .. 16 Ecology’s Response

................................ ................................ ............................. 19Spokane PM 10 LMP ii December 2015 

# Acknowledgements

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

document :

 Washington State Department of Ecology

o Laurie Hulse

- Moyer

o Diane Butorac

o Farren Herron

- Thorpe

o Stephanie Summers

 Spokane Regional Clean Air Agency

o Ron Edgar

o Margee Chambers

o Julie OliverSpokane PM 10 LMP iii December 2015 

# Executive Summary

Spokane Regional Clean Air Agency has prepared a second 10

- year limited maintenance plan (LMP) for Spokane County PM 10 Maintenance area. Ecology is submitting it to E nvironmental

P rotection A gency (EPA) for inclusion in Washington’s State Implementation Plan (SIP).

T he Spokane County Maintenance Area (SCMA) includes the cities of Spokane, Spokane Valley, Millwood

, and surrounding unincorporated areas

. In the 1980’s, the SCMA violat ed the

24

- hour standard for PM 10

. At that time, EPA designated the area as nonattainment. Windblown dust, re

- entrained road dirt and sanding material, unpaved road dust, and smoke from woodstoves and fireplaces all contributed to the violations

.

Ambient air monitoring data shows that the SCMA has been in attainment of the PM 10 standard

since 1994. In 2005, an attainment SIP revision and maintenance plan was approved and the area

was re

- designated to attainment

. When an area is being re

- designated to atta inment, the C lean

A ir A ct (CAA) requires the development of two EPA

- approved maintenance plans. These plans show how the area will continue compliance with the standard that was violated.

The SCMA’s first plan ran from 2005

- 2015. The second plan will run from 2015

- 2025. The updated plan does not add rules or change requirements, but continues the same control strategies developed in 2005. PM 10 levels have dropped in the area and pollution levels from population growth and increases in vehicle use are not expected to exceed the standard. Due to this expectation, Ecology is able to submit a simplified plan called a Limited Maintenance

Plan

— or LMP

, to revise the SIP.

The PM 10 LMP SIP revision explains how the SCMA will continue to meet the PM 10 standard

th rough 2025. Ecology is adopting the SIP revision and will submit it to EPA for approval into Washington’s SIP.

Ecology provided public notice of its proposed adoption of the PM 10 LMP and SIP revision.

C omments were accepted from October 1 through November 9, 2015. One comment was received. There were no requests for a public hearing.

The purpose of this Response to Comments is to:

 Meet the federal CAA requirements that agencies prepare a response to comments.

 Provide reasons for adopting the SIP revision.

 Describe any difference between the proposed SIP revision and the adopted SIP revision.

 Provide Ecology’s response to comments.

To see more information related to this SIP revision, please visit our Maintenance SIP site ( http://www.ecy.wa.gov/programs/air/sips/plans/maintenancesip.htm )

.Spokane PM 10 LMP 1 December 2015



# Reasons for Adopting SIP Revision

In the 1980s

, Spokane was designated as being in nonattainment for the federal health

- based NAAQS for co a rse particle pollution, PM 10 . Not meeting this standard puts people’s health at risk and triggers strict federal requirements that impose economic constraints on the area in order to bring the area back into attainment

.

Ambient air monitoring shows that the Spokane County Maintena nce Area ( SCMA ) has been in

attainment of the PM 10 standard since 1994. The 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 PM 10 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 PM 10 . This plan:

 Meets the requirement for a second 10

- year plan,

 Covers the period th rough 2025, and

 Fulfills the final maintenance plan requirement of the CAA.

Ecology is adopting this SIP revision to:

 Improve air quality and help the area continue to meet health

- based federal air quality

standards for PM 10

.

 Fulfill the CAA maintenance planning requirements.



# Difference s B etween the Proposed SIP Revision

and Adopted SIP Revision

There are no differences between the proposed and adopted SIP revision

.Spokane PM 10 LMP 2 December 2015



# Summary of Public Involvement Process

Ecology posted a notice of the public comment per iod and the request for hearing on its public involvement calendar and web site. A legal notice was published in The Spokesman Review on October 2, 2015. A notice was sent to Ecology’s Air Quality Rule and State Implementation Plan Updates email list (listserv)

, as well as other social med ia outreach including Facebook and Twitter posts. A joint news release was issued by Ecology and Spokane Regional Clean Air Agency ( SRCAA ) on October 1, 2015. SRCAA assisted with outreach efforts by posting information on their website, sending a notice to the ir regulatory update list serve, and stakeholder outreach

emails. Copies of these documents are included

.

Ecology accepted comments from October 1, 2015 through November 9, 2015. The re were no requests for a public hearing.Spokane PM 10 LMP 3 December 2015



### Affidavit of Publication

, Legal Notice, Spokesman Review, October 2,
2015Spokane PM 10 LMP 4 December 2015



### News Release or Blog, October 1, 2015Spokane PM 10 LMP 5 December 2015



### Ecology website, October 1, 2015Spokane PM 10 LMP 6 December 2015



### Ecology Public Involvement Calendar Notices

Announcing Opportunity to Comment and Request a HearingSpokane PM 10 LMP 7 December 2015Spokane PM 10 LMP 8 December 2015



### Spokane Regional Clean Air Agency News Release, October 1, 2015

Home 

### Public comment sought on Spokane County’s updated air quality plan

View All News

The Washington Department of Ecology and Spokane Regional Clean Air Agency invites the public to
review and comment on this draft second ten

- year plan, called the PM 10 Limited Maintenance Plan

. This plan shows how Spokane County will stay in compliance with the National Ambient Air Quality
Standard (NAAQS) for Parti culate Matter 10 microns or less (PM 10 .) The public can review and comment on the plan now through November 9, 2015.

The updated plan does not add rules or change requirements for controlling PM 10 , but continues the same control strategies that are in plac e from the county’s first maintenance plan developed to address air quality from 2005 through 2015. These control strategies include street cleaning inside the maintenance area, paving requirements for parking lots, temporary bans on woodstove use during

p eriods of poor air quality, emission requirements for new stoves, limits on some major industrial sources and air quality monitoring.



### Cleaning up and maintaining clean air

In the 1980s, the urbanized areas of Spokane County violated the NAAQS for PM 10 . Th is area includes the cities of Spokane, Spokane Valley, Millwood and surrounding unincorporated areas. The violations led to the area being designated a non

- attainment area by the U.S. Environmental Protection Agency (EPA) in 1990. Ecology and Spokane Regi onal Clean Air Agency had to develop an initial plan to clean up air quality and keep it clean.

Spokane County has shown that PM 10 levels have dropped to a point that the population and vehicle use growth are not expected to cause pollution levels to excee d the national standard. Due to this, the area qualifies for a streamlined plan, called a Limited Maintenance Plan, to fulfill the requirements. The updated plan is the final federal requirement for areas once in violation of the standard. Learn more
about the process on Ecology’s Air Quality webpage

.Spokane PM 10 LMP 9 December 2015



### Submitting comments

The plan is available for review. The deadline to submit comments is November 9, 2015. Citizens may also request a hearing. Hearing requests must be received no later than October 23, 2015.

To submit public comments on the plan, or reque st a hearing, please email Laurie Hulse

- Moyer or mail Ecology at:

Laurie Hulse

- Moyer

Washington State Department of Ecology

P.O. Box 47600 Olympia, WA 98504

- 76 00

If a hearing request is received by the deadline, two hearings will be held November 5, 2015 at 9:30 a.m. and 6:00 p.m., at Spokane Regional Clean Air Agency offices, 3104 E. Augusta Avenue, Spokane, WA 99207. If a hearing request is not received, Ecolo gy will announce a cancellation online on its public involvement calendar

.

Ecology will review and consider all comments before submitting the plan to EPA. All comments will be summarized and publ ished along with Ecology’s responses.

3104 E Augusta Ave, Spokane, WA 99207 · (509) 477

- 4727 · working with you for
clean air File an Air Quality Complaint | Terms of Use | Privacy Policy

Spokane Web Design by Switch Up Web | Print PageSpokane PM 10 LMP 10 December 2015



### Spokane Regional Clean Air Outreach,

September 28 and 29 Email and Stakeholder List

SRCAA Stakeholder Outreach

- from Margee Chambers, SRCAA 9/28/15 & 9/29/15, email s sent to local stakeholders: City of Millwood

 Tom Richardson, Tom.richardson@millwoodwa.us

City of Spokane

 Mark Serbousek, Director of Street Department 232

- 8810
mserbousek@spokanecity.org

901 N Nelson
Spokane, WA 99202

City of Spokane Valley

 Art Jenkins, Stormwater Engineer 720

- 5018
ajenkins@spokanevalley.org
11707 E Sprague, Suite 106 Spokane Valley, WA 9 9206 Spokane County

 Greg Baldwin, Road Department phone #
gbaldwin@spokanecounty.org Public Works Building 1026 W Broadway Spokane, WA 99260

 Bob Keneally, Operations & Maintenance Superintendent 477

- 3600 rkeneally@spokanecounty.org 1026 W Broadway Spokane, WA 99260

 John Pederson, Planning Director 477

- 7212 Jpederson@spokanecounty.org Public Works Building 1026 W Broadway Spokane, WA 99260 Washington State Department of Transportation

 Doug Bierce, Assistant Maintenance Superintendent, Spokane Area 1 324

- 6591
bierced@wsdot.wa.gov
2714 N Mayfair Spokane, WA 99207

CAP R

- Spokane Chapter

 John nwgrassroots@gmail.com

 Cindy Zapotockey, chapter president zapox6@afo.netSpokane PM 10 LMP 11 December 2015

Sample Email: Hello _____, I wanted to let you know about an upcoming pub lic comment period for the Second 10

- Year Limited Maintenance Plan for PM10. The public comment period for the draft plan runs 10/1

- 11/9. The draft plan will be posted on our website (under hearings and notices) on October 1 and will provide information on where to send comments. Some background on why we developed the Second 10

- Year Limited Maintenance Plan for

PM10:

 Many years ago, our area was violating the federal, health based standards for PM10. As a result, in 1990, we were designated as non

- attainm ent for the PM10 standards.

 That set forth the process of developing an attainment plan and cleaning up our air so we could be redesignated as in

- attainment of the standard.

 In 2005 we were designated as in attainment. With this designation we were requir ed to develop two, 10

- year maintenance plan to show how we will continue to keep our air clean. The first plan ran from 2005

- 2015. The second plan will run from 2015

- 2025.

 No new rules, requirements, or changes to existing state or local rules are being p roposed.

 This updated plan is the final step to complete federal requirements for areas once in

violation of the standard. Thank you for your time and your interest in air quality.Spokane PM 10 LMP 12 December 2015



### Ecology Listserv Message, October 1, 2015

Message

From: Ecology's Air Quality Rule and State Implementation Plan Updates [ mailto:ECY

- AQ

RULE

- AND

- SIP

- UPDATES@LISTSERV.WA.GOV ] On Behalf Of Laurie Hulse

- Moyer
Sent: Thursday, October 01, 2015 3:18 PM

To: ECY

- AQ

- RULE

- AND

- SIP

- UPDATES@LISTSERV.WA.GOV Subject: Washington SIP Notice: Public comment period and opportunity to request a hearing

on a SIP revision

 

### Ecology is accepting comments through November 9, 2015 on a proposed State Implementation Plan (SIP) revision to include Spokane Regional Clean Air Agency’s (SRCAA) updated particulate matter maintenance plan in the Washington SIP. Two public hearings, at 9:30 and 6 pm, will be held

N ovember 5, if one is requested by October 23.

 

### Visit Ecology’s Maintenance Plans webpage to see the plan and find out how to comment or request a hearing. Also, see the SRCAA/ Ecology joint news release

.

Visit us on the web or social media

.

Subscribe or Unsubscribe

Message sent to subscriber lis t of 155 people.Spokane PM 10 LMP 13 December 2015



### Memo Certifying No Hearing Was RequestedSpokane PM 10 LMP 14 December 2015



### Hearing Cancellation Notice / Public Involvement Calendar, October 26,
2015

CALENDAR





 More Ecology

Events 

## Public Involvement Calendar

The Public Involvement Calendar is designed to engage the public in our

decision

- making process . We encourage you to read Frequently Ask ed

Questions about Effective Public Commenting

.

Activities that are educational only or are co

- sponsored by Ecology may be found

under the "More Ecology Events" link in the left column of this page. We invite

your feedback about this Public Involvement Calendar.



### Public Hearings, Meetings, Workshops, Open

Houses
(Next 21 days. Use t he search feature (right) for events beyond 21 days.)

Nov 5 2015 9:30AM Public Hearing

- Spokane

------------------------- HEARING CANCELLED: Update to Air Quality

Maintenance Plan for Spokane Area

Ecology proposes to submit to EPA an updated air quality plan for Spokane

County. The plan, which will be included in the state's air quality plan, ensures

the area will maintain the particle standard through 2025. If the public requests

a hearing by October 23, two public hearings will be held in Sp okane. If not

requested by October 23, the hearings will be cancelled and a cancellation notice

will be posted on Ecology's Public Involvement Calendar. There are no new rules

or requirements proposed.

More Information: More Information

Location: Spokane Regional Clean Air Agency

3104 East Augusta Avenue

Spokane , WA

Sponsor: Ecology

ECY HQ

Contact: Laurie Hulse

- Moyer

(360 ) 407

- 6783 / laurie.hulse

- moyer@ecy.wa.gov

Public Comment Period

- Oct 1 2015

- Nov 9 2015

Public Hearing

- Nov 5 2015 6:00PMSpokane PM 10 LMP 15 December 2015 Nov 5 2015 6:00PM Public Hearing

- Spokane

------------------------- HEARING CANCELLED: Update to Air Quality

Maintenance Plan for Spokane Area

Ecology proposes to submit to EPA an updated air quality plan for Spokane

County. The plan, which will be included in the state's air quality plan, ensures

the area will maintain the particle standard through 2025. If the public requests

a hearing by October 23, two public hearings will be held in Spokane. If not

requested by October 23, the hearings will be cancelled and a cancellation notice

will be posted on Ecology's Public Involvement Calendar. There are no new rules

or requirements proposed.

More Information: More Information

Location: Spokane Regional Clean Air Agency

3104 East Augusta Avenue

Spokane , WA

Sponsor: Ecol ogy

ECY HQ

Contact: Laurie Hulse

- Moyer

(360) 407

- 6783 / laurie.hulse

- moyer@ecy.wa.gov

Public Comment Period

- Oct 1 2015

- Nov 9 2015

Public Hearing

- Nov 5 2015 9:30AM

Oct 01 2015 Public Comment Period

- Spokane

Nov 09 2015 HEARING CANCELLED: Update to Air Quality Maintenance

Plan for Spokane Area

Ecology proposes to submit to EPA an updated air quality plan for Spokane

County. The plan, which will be included in the state's air quality plan, ensures

the area will maintain the parti cle standard through 2025. If the public requests

a hearing by October 23, two public hearings will be held in Spokane. If not

requested by October 23, the hearings will be cancelled and a cancellation notice

will be posted on Ecology's Public Involvement Calendar. There are no new rules

or requirements proposed.

More Information: More Information

Location:

Spokane , WA

Sponsor: Ecology

ECY HQ

Contact: Laurie Hulse

- Moyer

(360) 407

- 6783 / laurie.hulse

- moyer@ecy.wa.govSpokane PM 10 LMP 16 December 2015 Public Hearing

- Nov 5 2015 6:00PM

Public Hearing

- Nov 5 2015 9:30AM



 Copyright © Washington State Department of

Ecology

Contact Us | Privacy Notice | Site Info



# Response to Comments

Ecology received one comment from the public on the proposed SIP revision. This section

includes the comment and Ecology’s response. Below is a copy of the original, unaltered text for

the comment received.



### Comment Received from Fred Greef, November 8, 2015Spokane PM 10 LMP 17 December 2015Spokane PM 10 LMP 18 December 2015

have done this already, and if you have any PM monitors in rail

- adjacent locations that can give you surety of health safety for at least the most susceptible populations ( c hildren, schools, elderly, hospitals , nursin g homes ) and the densest rail

- adjacent residential areas.

There are many other communities throughout this state at great risk from a ten

- fold increase in unit train traffic, for many other reasons. These include derailment and giant fires and explosions . Please do your part and help at least protect all of us from the potential worst

- case air quality threats

, by monitoring and modeling to help establish the actual emissions and the future

10

- year worst

- case emission growth from big diesel engines and ope n

- car coal dust. I know Ecology has excellent air quality modeling staff that can do the requested air quality emission modeling. Your Plan will be far more credible if you can add at least a small demonstration and explanation as to why PM NAAQS will not be violated over the next ten years by huge increases in locomotive coal dust and diesel engine emissions. If this is not done, I hope you can at least share with me your immediate commitment to a science

- based inquiry that can truly demonstrate

whether t hese public health air

- quality concerns are justified , and whether your air quality plan is fatally flawed

.

Thank you very much for this opportunity to comment.

Sincerely, Fred Greef (private Washington citizen)Spokane PM 10 LMP 19 December 2015



### Ecology’s Response

Thank you for you r comment. You expressed concern over proposed increases in rail activity, particularly coal and oil cars. Impacts of new facilities serviced by rail are beyond the scope of

this L imited M aintenance P lan

. However, the following information is provided for your reference

.

Environmental Reviews: Ecology is a co

- lead agency with other federal, state and local agencies for several environmental reviews of separate coal and oil proposals that involve rail transportation. These proposals include the Gateway Pac ific Terminal in Whatcom County, the Millennium Bulk Terminals Longview, the Shell rail unloading facility in Anacortes and crude oil export terminals proposed in Grays Harbor (Westway, Imperium and Grays Harbor Rail Terminal).

Potential air quality and rail transportation impacts will be identified in the environmental reviews for each of these proposals , through the State Environmental Policy Act ( SEPA ) and

N ational E nvironmental P olicy A ct (NEPA) processes . Each environmental review has opportunities f

or public comment.

Below are websites with further information on the status of the environmental review process and opportunities for public comment on each project . If you would like to be notified, sign up on the email lists (listserv) for each review to receive announcements.

 Environmental review of Westway Terminal and Imperium Terminal http://www.ecy.wa.gov/geographic/graysharbor/terminals.html These Draft Environmental Impact Statements are available for public comment until Nov 30, 2015

 Environmental review of Gateway Pacific Terminal http://www.eisgatewaypacificwa.gov/ and http://www.ecy.wa.gov/geographic/gatewaypacific/

 Environmental review of Millennium Bulk Terminals Longview http://www.millenniumbulkeiswa.gov/ and http://www.ecy.wa.gov/geographic/millennium/index.html

 Environmental review of Grays Harbor Rail Terminal http://www.ecy.wa.gov/geographic/graysharbor/ghrt.html

 Environmental review of Shell Anacortes Rail Unloading Facility http://shellraileis.com/ and http://www.ecy.wa.gov/geographic/anacortes/shelloil.html

Proposed increases in rail traffic : The Washington State Department of Transportation’s “Washington State Rail Plan Integrated Freight and Passenger Rail Plan 2013

- 2035 ” forecasts that at the current 3.4% growth rate for routes in and out of Spokane, the rail lines will be at 150% to 170% of capacity by 2035. These levels cannot be reached without operational changes and/or capital improvements to manage anticipated fre ight rail volumes. The number and capitalSpokane PM 10 LMP 20 December 2015

costs of the needed improvements will likely constrain the growth in rail traffic through Spokane

.

Based on current capacity it is not possible for a 1,000% increase in rail traffic as was mentioned

in the comm ent letter. T he Washington State Department of Transportation (WDOT) 2014 Marine and Rail Oil Transportation Study (oil train safety study) predicts the maximum possible

in crease in rail traffic in Spokane through 2025 would be closer to 50 %.

Newer trains ( Tier 3 and 4 1 ) have stricter emission standards and would achieve a 50% or 90%

reduction in die sel particulate emissions respectively, compared to older trains. Without taking the additional reductions from the stricter standards into account, a 50% increase from Ecology

2011 locomotive emissions would increase annual railroad PM 10 emissions from 4 2 tons per year to 63 tons per year. In addition, locomotive emissions from fuel use are estimated to be just

.22% of overall PM 10 emissions in Spokane County and e ven a 50% increase for this source
category would not cause concern

. Fugitive dust emissions from locomotives are not estimated by Ecology, but are not expected to contribute enough for the area to be at risk for violating the

PM 10 standard. Lead agencies will determine how i ndividual proposed project SEPA reviews will address fugitive e missions.

The introduction of Tier 4 locomotives and current restrictions in rail infrastructure throughout

Idaho and Spokane County

, as well as other capacity restrictions along these routes

, should minimize any increase in rail traffic through the area for a least the next 10 years

, limiting its impact on Spokane’s compliance with the PM 10 standard

.

Jaffe Study estimates: Increase in emissions from rail traffic would be highly unlikely to threaten particulate standards: The Jaffe study was specific to the Tacoma area. Impacts from

locomotives are v ery localized and vary due to area meteorology, terrain and proximity to the tracks. Currently the locomotiv e emissions for Spokane County from fuel use are about 1% of the fine particle (PM 2.5 or particulate matter 2.5 microns or less) emissions in Spokane. Fugitive emissions are not estimated, but not expected to threaten the area’s compliance with particulate

matter standard s

.

Concerns over blocked crossings: Increases in vehicle idling emis sions at crossings would be more likely to increase carbon monoxide (CO ) levels than PM 10

. However, there should be no

issues with CO either because m ost crossing s with major arterials in the central business district of Spokane are grade separated , meani ng they are at a different levels, like an overpass or a bridge . So there should be no problem with buildup of vehicle emissions, as there would be few blocked crossings. Those few street level crossings in the valley are in open areas with little

chance o f a buildup of CO emissions.

Oil train safety study: You also expressed concerns with the WDOT Department of Transportation’s recent oil train safety study

. Th is study was conducted with the Washington Utilities and Transportation Commission , Emergency Management Division and others and was published in March this year. The oil train safety study was intended to assess the environmental impact of an accident and not the long term impact of increase d rail traffic

. For questions on rail

1 http://www3.epa.gov/otaq/standards/nonroad/locomotives.htmSpokane PM 10 LMP 21 December 2015

transportation studies, contact the Washington Department of Transportation Freight Rail office.

Contact information is available at http://www.wsdot.wa.gov/Freight/Rail/default.htm

.

Future projections using modeling not required: In order to qualify for the LMP (Limited Maintenance Plan), Ecology and SRCAA had to show that PM 10 levels have dropped to a point that population grow th and increases in vehicle use are not expected to cause pollution levels to exceed the standard in Spokane. The area qualified to submit a LMP . Since it is highly unlikely

PM 10 emissions will increase significantly, the LMP option does not require future year projections emissions. It is assumed that currently monitored levels are low enough that an emissions increase in any source category will not cause a violation of the standard in the next ten years. Continued monitoring for PM 10 in the out years wil l alert us if that should prove to not

be the case.

Other efforts : Several years ago, SRCAA entered into a voluntary partnership with Burlington Northern Santa Fe (BNSF) to have BNSF retrofit up to eleven locomotives with idle reduction technology to reduce air emissions and conserve fuel in Washington. The pool of locomotives retrofitted operates out of the BNSF rail yards in Spokane and Pasco

, Washington

. Also, in 2012 SRCAA Board directed staff to try to find funding for additional monitoring of PM 2.5 near railways. Any such study would be expensive, requiring both sampling and speciation lab work. A special modeling project is not in the current budgets of the SRCAA or Ecology, and no outside funding is currently available.

We appreciate your compliment of Ecology’s modeling staff

.

Since the Spokane a rea measured monitored values are far below the PM 10 standard, this area is

at little risk of violating this standard

. SRCAA commits to continuing to monitor in the Spokane area through 2025

.